1. Pollution Control: For Field Office Construction Sites

2. Pollution Control during Construction Objectives: Provide awareness of NRCS Policy Provide history of pollution control Review legal requirements Become familiar with typical pollution control installations for a conservation practice

3. NEM and National Pollutant Discharge Elimination System (NPDES) NRCS Policy – NEM Part 520 NPDES Permit Requirements -Stormwater runoff from construction sites -Use of Best Management Practices (BMP) to manage runoff

4. Policy (NEM Part 520 Subpart A) NRCS is to minimize erosion and sediment in construction operations carried out under all programs. Sediment control measures are included in all work where: –NRCS provides engineering services –NRCS financial assistance is provided Engineering done by NRCS for individuals and groups is to include satisfactory sediment control measures.

5. Regulations - NPDES 1972 Federal Water Pollution Control Act (Clean Water Act – Gave EPA authority for pollution control programs) Point sources 1987 Clean Water Act Amendments Defined Stormwater as a point source Phased approach

6. Examples of Point Source Pollution Fire on the Cuyahoga River Jan 8, 1969 Oil covered fishermen on Lake Erie May, 1976

7. Regulations - NPDES Phase I of the National Pollution Discharge Elimination System (NPDES) was enacted by EPA in November 1990. Phase I addressed “large construction activities” that disturb areas that are greater than or equal to 5 acres in size. NPDES Phase II was enacted in December 1999 to include “small construction activities” that disturb areas that are greater than or equal to 1 acre but less than 5 acres in size.

8. NPDES – Agriculture Exclusion 40 CFR 122.3 NPDES Permit not required for non-point- source agricultural activities including: Cultivated crops Orchards Pastures Range lands Forest lands

9. NPDES and/or State Permit - Requirements Best management practices (BMPs), Control of specific pollutants, Development and implementation of a Stormwater Pollution Prevention Plan (SWPPP), Submittal of a site plan for review that incorporates consideration of water quality impact. All permits, regardless of permitting authority, must included requirements for:

10. Permittee or Permittees An operator has control of the plans and specifications An operator has day to day operational control of those activities at the project necessary to ensure compliance with the SWPPP Each operator must obtain a permit.

11. Permittee or Permittees The owner may be the sole permittee The contractor may be the sole permittee The owner and the contractor may be joint permittees

12. What is contained in the SWPPP? Description of BMP’s Structural and non-structural Sedimentation basins required Site layout plan showing location of BMP’s and sedimentation basins Additional site management BMP’s Site inspections requirements

13. Non-Structural BMP’s Temporary and final seeding Mulching and/or tackifiers Preserving and protecting existing vegetation and trees along drainage courses Stabilized site entrances/exits

14. Structural BMP’s Silt fences (geotextile or straw bales) Earthen diversions Rock check dams Sediment traps Sediment basins Drainage swales Storm drain inlet and outlet protection

15. SWPPP and NRCS Inspector SWPPP should be discussed at pre-construction meeting and agree on parties duties All parties maintain a copy of SWPPP NRCS should explain BMP requirements Structural BMP’s installed before construction activity or as part of activity – notify permittee if not installed

16. SWPPP and NRCS Inspector (continued) Locate BMP’s per site plan as needed. Recognize need for additional locations based on site conditions Assist with site inspections if requested or conduct if authorized by QAP Document installations and inspections in narrative reports

17. Review Friendly Farmer GSS SWPPP Handout  SWPPP narrative  Construction specifications describing pollution control and/or final stabilization  Site Plan  BMP installation details  Inspection Checklist