Construction Site Runoff Inspections And Enforcement - City Of Thornton

BMPs) or administrative/procedural activities that are part of the Operator’s work practices and procedures (non‐structural BMPs). Installed BMPs will be reviewed for correct application, correct installation, adequacy, and maintenance. City‐approved SWMP and drawings for the project phase of construction are used to verify features that should be in place, and their specific locations. Full Level Inspections are conducted when a site has indications of site-wide BMP issues, or when repeated noncompliance items reported to the Operator during a Reconnaissance Inspection have not been resolved. The Operator shall be responsible for any additional or unforeseen conditions not addressed by the original SWMP. Inspections and Enforcement Escalation Inspections City Inspectors typically make unannounced site visits; however, City Inspectors may make courtesy calls to notify Operators that they will be on‐site. During the site visit, the City Inspector may consider, inspect, and evaluate any or all of the following: Outfalls and discharge points for evidence of sediment migration, pollutants, or erosion. Site boundaries and perimeter controls for containment with some form of sediment barrier. Ponds, basins, traps, drainage ditches/swales, and other water quality features for correct construction, function, protection, integrity, and maintenance. Disturbed areas for correct phasing and dormant areas not currently being worked that require stabilization, temporary seeding or other means of cover. Areas with final stabilization for germination, adequate cover, and/or need for reapplication or maintenance. Paved surfaces for evidence of dirt tracking, dirt ramps, need for cleaning, installation of vehicle track pads, and sediment barriers installed adjacent to disturbed sections. Inlets for correct and adequate protection, maintenance, or staining from pollution sources. Material storage and waste handling areas and practices to verify that appropriate measures are in place and exercised to manage all potential pollution sources. This may include waste receptacles, lay‐down and staging areas, designated liquid waste washout areas, fuel storage, and waste piles. Post storm event inspection and BMPs appropriate for the seasons. Appropriate controls for site drainage leaving the limits of the site (run-off) and management of adjacent site drainage entering the site (run‐on). Other implemented or required procedural, non‐structural or administrative control measures. Documentation of required self‐inspections including maintenance logs and SWMP updates. Consistency between current, site‐specific SWMP and installed/implemented controls and site conditions. Demolition activities, including saw cutting operations, for adequate waste management. This list is not intended to be all‐inclusive, but is intended to identify the general scope of City inspections for compliance with the City’s stormwater management requirements for construction activities. Inspections Resulting in Non-Compliance Site conditions that constitute non‐compliance include, but are not limited to: BMPs that are not installed according to the approved SWMP and drawings. BMPs not installed correctly, or not implemented correctly. Neglected BMPs, or in need of significant maintenance or replacement. 4

Portable toilets that are improperly stationed on paved surfaces or at curb flow lines or are not anchored properly. Evidence of liquid waste or washouts that are discharged directly onto the ground without containment. Concrete washout area that is near failure, not installed or signed properly. Fuel leaks/spills that have not been properly remediated. Inadequate vehicle tracking control measures to prevent sediment tracking onto paved sections. Vehicle tracking onto City streets, roads or paved areas. Repeated neglect and/or findings from previous reports that have not been adequately addressed. Inspection Escalation Process Inspection Reporting: 1. A copy of the Stormwater Construction Site Inspection Report may be provided to the Operator’s SWMP Administrator, if deficiencies exist. 2. The report identifies one of the following four situations: a. Passing inspection: only minor deficiencies need to be addressed or no action is required. The City Inspector may notify the Operator by verbal or written communication. The written communication may be a copy of the City Inspector’s report. The Operator must correct any deficiencies immediately. b. Notice of non‐compliance: Numerous deficiencies are noted. A Notice of non-compliance is issued to the Operator in written form. The written communication may be a copy of the inspection report or a formal notice issued by the City Inspector. The Operator must correct the deficiencies immediately. c. Notice of Violation (NOV): Indicates a site with site‐wide or systematic BMP issues and/or repeated non‐compliance items which must be resolved immediately. Site‐wide or systemic violations include (but are not limited to) illicit discharges, and BMP condition with an imminent potential for failure. (1) Violations requiring maintenance may include observations noted where it has been determined that the condition of the BMP is such that there is significant potential for pollutants to be conveyed to the MS4. It is possible that several observations of the same violation could escalate the finding into a significant violation. If the City Inspector notes a violation requiring maintenance after four inspections, this may be noted as a significant violation. The written communication will be issued by the City Inspector. (2) For the resolution of an NOV, all non‐compliant areas of concern and violations must be adequately addressed immediately. Larger action items such as pond installation, temporary or permanent landscaping installations will be noted separately, and will need to be completed within 48 hours. If an action item, other than typical temporary BMP maintenance, that require more than 48 hours to complete, a remediation action plan must be submitted within 48 hours, and the corrective action must be completed within seven (7) calendar days. NOVs remain open and unresolved until an on‐site inspection is conducted by a City Inspector to verify that all of the issues and concerns have been addressed, the site is free of violations, and Operator receives written notification from the City that the NOV has been resolved and closed. (3) It is possible that the observed violations may escalate to a level where the City may issue a Stop Work Order. 3. Stop Work Order (SWO): A SWO is a written notification given to the Operator to cease all on-site construction activities for Flagrant Violations or repeated unresolved NOVs. SWOs require the Operator to immediately stop all construction activities, but continue to remediate all violations. 5

SWOs remain in force until an on-site inspection is conducted by a City Inspector to verify that all issues and concerns have been properly addressed, and the site is violation free. The SWO is removed by the City when the Operator receives written notification from the City that the SWO has been lifted. 6

Stormwater Construction Full Level Inspection Permittee: Cert. No. COR-03- Date: Project: Project No. Start/End Time: Address: Inspector: Site Operator: Weather Information Has there been a storm event recently? Yes No If yes, provide: Storm Start Date & Time: Storm Duration (hrs.): Approximate Amount of Participation (inches): Date Time: Hrs Inches Weather at time of inspection: Clear Cloudy Rain Sleet Fog Snowing High Winds Other: Temperature: Inspection Results Passing Inspection: Only minor or no deficiencies exist. Notice of non-compliance: Numerous deficiencies are noted. Number of Notices issued to date: 1 2 3 4 5 Notice of Violation: Indicates a site with site-wide or systematic BMP issues and/or repeated non-compliance items which must be resolved immediately. Number of NOVs issued to date: 1 2 Records Review Copy of SWMP confirmed on-site: Yes No Notes: Copy of Erosion Control Plans confirmed on-site: Yes No 1. Site Description: Does Stormwater Management Plan (SWMP) provide a description of the following: a) A description of the construction activity? Yes No Yes No c) Estimates of the total area of the site that is expected to undergo clearing, excavation or grading? Yes No d) Existing data used in the development of the site construction plans or SWMP describing the soil, soil erosion potential or the quality of any discharge from the site? Yes No e) A description of the existing vegetation at the site and an estimate of the percent vegetative ground cover? Yes No f) The location and description of any other potential pollution sources, such as vehicle fueling, storage of fertilizers or chemicals, etc.? Yes No g) The location and description of any anticipated non-stormwater components of the discharge, such as springs, landscape irrigation return flow; construction dewatering and concrete washout? Yes No h) The name of the receiving water(s) and the size, type and location of any outfall or, if the discharge is to a municipal discharge, and the ultimate receiving water(s)? Yes No b) The proposed sequence for major activities? 7

2. Site Map: Does plan provide a generalized site map or maps which indicate: a) Construction site boundaries; b) All areas of soil disturbance; c) Areas of cut and fill; d) Areas used for storage of building materials, soils or wastes; e) Locations of all structural BMPs; f) Locations of non-structural BMPs; g) Locations of springs, streams, wetlands and other surface waters; Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes No No No No No No No No No No No No No Yes No Yes No Yes No Yes No 3. Stormwater Management Controls a) SWMP Administrator; responsible for developing, implementing, maintaining and revising the SWMP. b) Identification of potential pollutant sources. 1) Disturbed and stored soils; 2) Vehicle tracking of sediments; 3) Management of contaminated soils; 4) Loading and unloading operation; 5) Outdoor storage activities; 6) Vehicle and equipment maintenance and fueling; 7) Dust or particulate generating processes; 8) Activities involving fertilizers, pesticides, fuels, solvents, oils, etc.; 9) Waste management practices; waste piles, liquid wastes, dumpsters, etc.; 10) Concrete truck washing; 11) Asphalt and concrete batch plants; 12) Non-industrial waste, worker trash and portable toilets; 13) Other areas or procedures where potential spills can occur c) Best Management Practices (BMPs): identifies and describes appropriate BMPs. 1) Structural Practices. Does BMP section include a description of structural site management practices that will minimize erosion and sediment transport? i.e. silt fence, earth dike, drainage swales, sediment traps, inlet protection, sediment basins, etc.) 2) Non-structural Practices. Does BMP section include a description of interim and permanent stabilization practices, including site-specific scheduling of the implementation of the practices? (i.e. seeding, mulching, grading, sod, geotextiles, veg. buffer, etc.) 3) Phased BMP Implementation. Does SWMP describe construction phasing? (i.e. clearing and grubbing, road construction, infrastructure installation, final grading and final stabilization) 4) Materials Handling and Spill Prevention. Does SWMP address Material Handling and Spill Prevention? (i.e. exposed storage of building materials, fertilizers or chemicals; waste piles; equipment maintenance, or fueling procedures, notification procedures, cleanup, identification of spill kits locations.) 8

5) Dedicated Concrete or Asphalt Batch Plant. Does SWMP clearly describe and locate all practices implemented at the site to control stormwater pollution for dedicated concrete or asphalt batch plants. 6) Vehicle Tracking Control. Does SWMP clearly describe and locate all practices implemented to control potential sediment discharges from vehicle tracking: minimizing site access; street sweeping; gravel parking, etc. 7) Waste Management and Disposal, Including Concrete Washout. Does SWMP address: concrete wash out waste disposal; liquid and solids waste disposal, etc. 8) Groundwater and Stormwater Dewatering. Does SWMP clearly describe the practices implemented to ensure that no groundwater from construction dewatering is discharged from the site as surface runoff or to surface waters? Yes No Yes No Yes No Yes No Yes No Yes No Are inspection records kept? Note: Examine a 3 month sample. Yes No Are inspections conducted as required in the permit? Note: Inspection reports by operator must be dated and signed. Yes No 4. Final Stabilization and Long-term Stormwater Management Does plan include a description of the measures used to achieve final stabilization and measures to control pollutants in stormwater discharges that will occur after construction operations have been completed? Note: If permitee relies on landscape plan, then it must be attached to the SWMP. 5. Inspection and Maintenance Does plan include a description of procedures to inspect and maintain in good and effective operating condition the vegetation, erosion and sediment control measures and other protective measures identified in the SWMP? Facility Inspection BMP 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Silt Fence Check Dams Erosion Logs Sediment Trap Basin Inlet Protection Outlet Protection Vehicle Tracking Pad Concrete Washout Straw Bales (Not to be used as a primary BMP) Street Sweeping Surface Roughing Curb Socks Seeding Mulching Sod Erosion Blankets BMP Installed? Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes Yes Yes Yes Yes Yes Yes Yes No No No No No No No No Maintenance Corrective Action Needed and Notes Required? Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes Yes Yes Yes Yes Yes Yes Yes No No No No No No No No 9

BMP 18 19 20 BMP Installed? Yes No Yes No Yes No Observation 1 Evidence of offsite transport of sediment or other pollutant? Evidence of discharges other than stormwater? Is trash/litter from work areas collected and place in covered dumpsters? Is area free of spills, leaks, or any other deleterious material? Are materials that are potential stormwater contaminants stored inside or under cover? Corrective Action Needed and Notes Yes No Yes No Yes No Yes No Yes No 6 Yes No 7 Yes No 2 3 4 5 Maintenance Corrective Action Needed and Notes Required? Yes No Yes No Yes No Field Notes 10

Stormwater Construction Site Inspection General Information Project Name CDPS Cert. No. Project No. COR-03- Location Start/End Time Date of Inspection Inspector’s Name(s) Site Operator: Describe present phase of construction Type of Inspection: Reconnaissance Inspection Permit 14 day inspection Initial Inspection Post-storm event Weather Information Has there been a storm event since the last inspection? Yes No If yes, provide: Storm Start Date & Time: Storm Duration (hrs.): Approximate Amount of Precipitation (in): Date Time: Hrs. Inches Weather at time of this inspection? Clear Cloudy Rain Sleet Fog Snowing High Winds Other: Temperature: Have any discharges occurred since the last inspection? If yes, describe: Yes Were any discharges observed at the time of inspection? If yes, describe: Yes No No Inspection Results Passing Inspection: Only minor or no deficiencies exist. Notice of non-compliance: Numerous deficiencies are noted. Number of Notices issued to date: 1 2 3 4 5 Notice of Violation: Indicates a site with site-wide or systematic BMP issues and/or repeated non-compliance items which must be resolved immediately. Number of NOVs issued to date: 1 2 Site-specific BMPs BMP 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Silt Fence Check Dams Erosion Logs Sediment Trap Basin Inlet Protection Outlet Protection Vehicle Tracking Pad Concrete Washout Straw Bales (Not to be used as a primary BMP) Street Sweeping Surface Roughing Curb Socks Seeding Mulching Sod BMP Installed? Yes No Yes No Yes No Maintenance Required? Yes No Yes No Yes No Yes No Yes No Yes Yes No No Yes Yes No No Yes No Yes No Yes No Yes No Yes No Yes No Yes Yes Yes Yes Yes Yes No No No No No No Yes Yes Yes Yes Yes Yes No No No No No No Corrective Action Needed and Notes 11

BMP 16 17 18 19 20 Erosion Blankets BMP Installed? Yes No Yes No Yes No Yes No Yes No Maintenance Required? Yes No Yes No Yes No Yes No Yes No Corrective Action Needed and Notes Overall Site Issues Observations 1 2 3 4 5 6 7 Are all slopes and disturbed areas not actively being worked properly stabilized? Are perimeter controls and sediment barriers adequately installed? Are discharge points and receiving waters free of any sediment deposits? Is trash/litter from work areas collected and placed in covered dumpsters? Are vehicle and equipment fueling, cleaning, and maintenance areas free of spills, leaks, or any other deleterious material? Are materials that are potential stormwater contaminants stored inside or under cover? (Other) Implemented? Yes No Yes No Yes No Yes No Yes No Yes No Yes No Corrective Action Needed and Notes Field Notes 12

13

14

Reconnaissance Inspection: an inspection to assess the construction site for indicators of noncompliance, but not fully assessing the adequacy of the BMPs and overall site management. Stop Work Order (SWO): a written notification given to the Operator to cease all on-site construction activities for repeated unresolved NOVs.