All construction and industrial activity is subject to the whims of Mother Nature, leaving local ecosystems vulnerable to pollution-laden runoff each time it rains.
While certain controls or best management practices (BMPs) can help mitigate the issue, proper planning and coordination between contractors and subcontractors is required for maximum efficiency.
For this reason, the EPA requires all construction sites that apply for an NPDES permit to develop a stormwater pollution plan (SWPPP) outlining a crew’s attempts to reduce pollution that flows out of the site.
Unfortunately, navigating the complexities of SWPPP development can be daunting and take time away from other essential tasks.
One option many site managers opt for is to enlist the help of a qualified SWPPP developer (QSD) who can assist in SWPPP creation, implementation, and ongoing maintenance.
This guide will discuss the role and importance of a QSD and how one can help you navigate common challenges when developing a SWPPP.
When Is a SWPPP Required for Projects?
The EPA mandates Stormwater pollution prevention plans for any construction site attaining a Pollutant Discharge Elimination System (NPDES) Permit. This allows construction crews to discharge into public water systems, such as rivers controlled by federal law.
However, there are many specific instances where SWPPPs are required by federal, state, or municipal law to be aware of:
- Extensive Land Disturbance: All construction activity that disturbs one acre or more of land is required to draft a SWPPP.
- Municipal Stormwater Discharge: Your NPDES permit or local municipality will require a SWPPP if you plan to discharge runoff in a municipal conveyance, otherwise known as an MS4.
- Specific Industrial Activity: Standard Industrial Classification (SIC) codes outline specific instances when a SWPPP is required for industrial activity.
While SWPPPs may seem like unnecessary red tape, they protect local ecosystems and communities from harmful pollution.
In turn, SWPPPs not only help you meet regulatory compliance requirements but also ensure your company remains environmentally friendly, protecting its reputation.
Challenges of Developing a SWPPP
A stormwater management plan is a fairly sophisticated document that often falls outside the knowledge and training of many construction managers. Some of the most common challenges of developing a SWPPP include:
- Complex Regulations: Depending on the location and nature of your construction activity, your SWPPP could be subject to multiple layers of state, federal, and municipal oversight.
- Requires Extensive Environmental Knowledge: SWPPPs require site managers to identify and control several pollution sources, which can be fairly complex. For example, activity controls must be drafted based on the composite runoff coefficient of a slope or any given area where runoff will be most dangerous.
- “Living” Document: SWPPPs are far from set-it-and-forget-it documents and require ongoing maintenance, inspection, and amendment.
- Sitewide Buy-In: Stormwater controls don’t just fall under the purview of the site manager but also any construction crew member and subcontractor involved on the site. This requires ongoing training and education, which most managers are not equipped to provide.
- Adapting to Changing Conditions: Construction and industrial sites are dynamic environments that often change rapidly. Adapting the SWPPP to accommodate changes in project scope, site conditions, weather events, and regulatory requirements requires flexibility and proactive management.
In many instances, drafting a SWPPP requires the help of a professional. That’s where a QSD comes in.
How a Qualified SWPPP Developer (QSD) Can Help
A QSD stands for qualified SWPPP developer, and their role is exactly as it sounds.
As experts in stormwater management, a SQD possesses the knowledge and skills necessary to navigate regulatory requirements and design effective pollution prevention measures. The primary role of a QSD includes:
- SWPPP development and maintenance
- Erosion and sediment control implementation
- Weekly site inspection or rain-driven inspection
- Spill assessment and prevention
- General housekeeping practices
QSDs provide several essential functions for any crew, whether it’s identifying pollution sources, implementing BMPs, or providing training materials to crew members. In turn, QSDs allow managers to devote more time to other tasks that improve their organizational efficiency to be better managers.
Difference Between a QSD and QSP
In the world of environmental consulting, you might run into QSDs and qualified stormwater practitioners (QSPs). QSPs are often brought in for active SWPPP management, but typically later on in the process.
A QSD can serve all of the same functions as a QSP, including ongoing site inspection and maintenance while assisting in the early planning and development stages.
Tips for Finding the Right QSD for Your Next Project
Finding the right QSD is pivotal for your project’s success and ensuring proper regulatory compliance. Some general things we recommend you look for in a QSD include:
- Relevant Qualifications: All QSDs require proper certification, either from a state or third-party agency. The EPA even requires all onsite inspections to be performed by a certified inspector.
- Evaluate Experience: Look for a QSD with a proven track record of successfully developing SWPPPs for projects similar to yours. One tip we could provide is looking for a QSD with experience in your state that understands its complex regulatory structure.
- Consider Industry Affiliations: Look for SWPPP developers who are affiliated with reputable industry organizations or associations, such as the International Erosion Control Association (IECA) or the American Society of Civil Engineers (ASCE). Affiliation with these organizations can indicate a commitment to professionalism and ongoing education in stormwater management.
- Review References: Request references from previous clients or projects to assess the QSD’s reputation and the quality of their work.
Ensuring proper regulatory compliance with the vast legal framework of the EPA and your local state is no small undertaking.
Ensure proper compliance and protect your construction site from potential lawsuits with the help of a professional QSD. A QSD can assist not only in SWPPP creation but also in ongoing maintenance and inspection.
FAQs: Qualified SWPPP Developer
What does QSD stand for?
QSD stands for Qualified Stormwater Pollution Prevention Plan Developer. QSDs are certified professionals responsible for the initial development and oversight of SWPPPs.
Why is SWPPP development important?
SWPPP development is crucial for preventing stormwater pollution and ensuring compliance with environmental regulations. By identifying and mitigating potential pollution sources, SWPPPs help protect water quality and ecosystems.
Can I develop a SWPPP without a QSD?
While it’s possible to develop a SWPPP without a QSD, it’s highly recommended to work with a qualified professional to ensure compliance and effectiveness. QSDs possess the expertise needed to navigate regulatory requirements and design effective pollution prevention measures