Lumos & Associates has been preparing Storm Water Pollution Prevention Plans (SWPPPs), which are required for construction sites larger than one acre, in Nevada and California for over a decade. Typically, these SWPPPs involve providing standard Best Management Practices (BMPs) to control erosion, contain runoff on site where possible, prevent tracking of sediments and pollutants off site by vehicles, and treat runoff that discharges off site to the greatest extent practicable.
There are many other elements that can go into these plans and documents. A construction site is a dynamic environment, and to account for this we prepare documents that identify general types of pollution problems that could occur on site; we label obvious potential discharge points; we design standard BMPs for the site perimeter and obvious problem areas; and we provide a BMP “tool kit” that provides dozens standard and some specialized BMPs that can be applied to any circumstance that may occur on site. The documents are flexible so that the Contractor can adjust the SWPPP to address changing site and runoff conditions.
In California, the game changed in 2009. The California Department of Water Resources wrote a new permit for construction site storm water discharges that required monitoring of storm water discharges and imposed limits on the turbidity and Ph level of any storm water discharge. In the Lake Tahoe Basin, additional limits are placed on Nitrogen and Phosphorous as well. If these limits are exceeded, fines can be imposed up to $10,000 per violation. The 2009 permit also places additional procedural requirements for SWPPP implementation, some of which are daily inspections of construction site BMPs, immediate electronic reporting requirements to the State Water Quality Control Board, and most importantly, SWPPPs must be developed by a certified Qualified SWPPP Developer (QSD), and on site monitoring of storm water discharge during storm events must be conducted by a certified Qualified SWPPP Practitioners (QSPs). In response to these requirements, Lumos now has certified QSD/QSP personnel and water quality monitoring equipment.
Given the complexity of the 2009 permit and the amount of responsibility placed on the QSD/QSP, contractors and some public agencies are now choosing to hire subconsultants to perform these duties. Lumos recently secured two large contracts with GC Environmental Consultants to provide QSD and QSP services on two Southwest Gas pipeline replacements.
The first gas line replacement is on Highway 89 between Tahoma and Tahoe Pines on the west shore of Lake Tahoe. Lumos prepared the plans for the SWPPP that protects almost 4 miles of gas main replacement with frequent lateral replacements and patch paving. The replacement crosses three major streams, and approximately ¾ of a mile of the replacement occurs within TRPA designated Stream Environment Zone (SEZ). Another portion of the replacement contends with steep cross-slopes, which require additional effort to protect.
The second gas line project is in Truckee, California along Joeger Rd. For this project, Lumos developed a SWPPP that protects more than 2 miles of gas main replacement with moderately frequent lateral replacements.
Lumos will also be the QSP for one other commercial site in South Lake Tahoe and we will be conducting Nevada SWPPP inspection and testing for Phase 1 of the Nevada Stateline to Stateline Bikeway South Demonstration Project.
To cover our responsibilities on these projects, the Tahoe office will be making daily inspections of all of these project sites to ensure SWPPP compliance, we will monitor weather forecasts on a daily basis, and when the rain comes, we will be on site to monitor any discharge of storm water. Following any rain event we will upload our monitoring data to the California Department of Water Resources website to ensure compliance. It’s not quite like chasing tornados, testing for avalanches, or flying into the eye the hurricane, but when the rain event occurs we’ll be out looking at puddles.