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Storm Water Pollution Prevention
- Thread starter TxPE
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Have you checked with TNRCC (or whatever they're called now) to get copies of studies used by the EPA to create the rule? Have you checked with your local EPA office?
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I would suggest that it does have some value. However, the question should be, do construction swppp's provide enough value? Some procedures clearly do help, but many do very little since the construction occurs so rapidly, the permanent measures are much more effective than the temporary construction measures. Is it worth all the effort for a project that will be completely finished construction in a year or less?
How about going after the perennial bigtime polluters like agriculture, power plants, heavy industry and gas guzzling SUV drivers? The new phase 2 requirements for smaller cities could do quite a bit, although it will be a huge tax burden.
How about going after the perennial bigtime polluters like agriculture, power plants, heavy industry and gas guzzling SUV drivers? The new phase 2 requirements for smaller cities could do quite a bit, although it will be a huge tax burden.
KRSServices
Civil/Environmental
TxPE,
I suppose the relevance and value will be different, depending on whom you are asking. If you ask a fish cop, the absence of deliterious materials introduced into habitat (cloudy water, etc.) is an absolute value. To the project manager or Owner, it is a matter of higher cost. To the contractor, it is an opportunity to make more money, or an inconvenience.
Personally, mother nature can put up with dirty water in a reasonable fashion. Up here the fish cops can arrest and carry handguns and cuffs, so while I believe they carry their juridiction way too far, I am forced to respect them and not argue too much!
Much of the temporary requirements, I feel, are a complete waste of money and are of absolutely no benefit to the overall environment. In fact, in some cases, the installation of some barriers and measures creates more problems than they solve. That being stated, I do know that the fish cops do not agree with me.
KRS Services
I suppose the relevance and value will be different, depending on whom you are asking. If you ask a fish cop, the absence of deliterious materials introduced into habitat (cloudy water, etc.) is an absolute value. To the project manager or Owner, it is a matter of higher cost. To the contractor, it is an opportunity to make more money, or an inconvenience.
Personally, mother nature can put up with dirty water in a reasonable fashion. Up here the fish cops can arrest and carry handguns and cuffs, so while I believe they carry their juridiction way too far, I am forced to respect them and not argue too much!
Much of the temporary requirements, I feel, are a complete waste of money and are of absolutely no benefit to the overall environment. In fact, in some cases, the installation of some barriers and measures creates more problems than they solve. That being stated, I do know that the fish cops do not agree with me.
KRS Services
bltseattle
Civil/Environmental
As a designer, I think that the intent of SWPPP practices is positive and that benefits can be achieved. Preventing sedimentation or release of spills to salmon streams is clearly a positive benefit of SWPPP practices, and one where lack of controls has led to severe impacts in the past. And I think its appropriate to properly store and handle toxic chemicals in manners that prevent accidental spills. Requiring a written SWPPP plan ensures that thinks about it at least once during the course of the project. I don't have hard data to quantify these benefits, but it seems intuitive.
The problem is that some agency reviewers often expect and engineers often write/draft/design the same standardized boilerplate stuff on every project, whether it makes sense or not. For example, some agencies won't approve TESC plans if Straw Bale Barrier notes are not included, even if there is no where to put Straw Bale Barriers on the site. And I've reviewed TESC narratives by colleagues where they copied verbatim from another project (hey, you have to remember to change the project name!). I encountered this frequently with road projects, which have some different issues than site development. This kind of boilerplate approach could be counterproductive, in my opinion, because it makes it hard for contractors to discern what type of SWPPP practices are clearly beneficial and important for resource protection, versus those that are required just so the reviewer will issue the permit and feel that the agency's liability is minimized.
The problem is that some agency reviewers often expect and engineers often write/draft/design the same standardized boilerplate stuff on every project, whether it makes sense or not. For example, some agencies won't approve TESC plans if Straw Bale Barrier notes are not included, even if there is no where to put Straw Bale Barriers on the site. And I've reviewed TESC narratives by colleagues where they copied verbatim from another project (hey, you have to remember to change the project name!). I encountered this frequently with road projects, which have some different issues than site development. This kind of boilerplate approach could be counterproductive, in my opinion, because it makes it hard for contractors to discern what type of SWPPP practices are clearly beneficial and important for resource protection, versus those that are required just so the reviewer will issue the permit and feel that the agency's liability is minimized.
I think that everyone should share the burden. Construction in my opinion, is only a small part of the pollution problem. Other polluters continue to get by without any additional control because it is either too expensive or too difficult. Examples include a farm field where runoff from the field carries massive amounts of fertilizer, pesticides, herbicides and sediment. How about the first flush from a highway which carries accumulated sediment, oils, grease and whatever else is on the pavement into the ditch and eventually into the watercourse? Shouldn't our focus be here where the problem is much greater?
KRSServices
Civil/Environmental
In the Province of Alberta highway contractors must provide an environmental report indicating the potential hazards and issues and remedial techinques and solutions. This adds a substantial cost to the project but is does place the onus of pollution and environmental harm prevention squarely on the contractors shoulders.
cvg really brings up a good point, and you know how our beloved fish cops have responded?....they insist that barriers and screens be erected onto bridges so that any substances from a birdge flush will be caught.
The result...many bridges are no longer flushed and relay on a few melts or heavy storms to "wash" the deliterious material into a stream.
Same goes for the chlorides (road salts) as now being labelled as "toxic substances" by the Ministery of Environment!
KRS Services
cvg really brings up a good point, and you know how our beloved fish cops have responded?....they insist that barriers and screens be erected onto bridges so that any substances from a birdge flush will be caught.
The result...many bridges are no longer flushed and relay on a few melts or heavy storms to "wash" the deliterious material into a stream.
Same goes for the chlorides (road salts) as now being labelled as "toxic substances" by the Ministery of Environment!
KRS Services
EnviroConsult
Civil/Environmental
In response to the original question, whether there are benefits in the SWPPP, I can vouch that there are significant benefits that are measurable in water quality samples. I have seen TSS results drop from over 490 mg/l to less than 40 mg/l in a single season with the installation of settling ponds and filter berms. The SWPPP itself is merely a tool that spells out BMPs and includes a monitoring plan. Through the monitoring plan however; real problems should be identified and addressed through operational or physical improvements.
Did this allow a higher quality of fish to exist, or improve any recreational or water uses? Probably not, but the measures are effective based on measurable parameters.
I disagree with CVG in the above posts:
"How about going after the perennial bigtime polluters like agriculture, power plants, heavy industry and gas guzzling SUV drivers"
First of all, power plants and heavy industry are subject to stormwater regulations, and I would argue they carry a larger regulatory burden than construction. Exemptions to agriculture are eroding (pardon the pun) and will be regulated soon enough. SUV drivers??? that's just plain irrelevant and provocative!
Anyway, the SWPPP as a document is not so important at the tasks of implementation and critical evaluation and re-design. Done diligently, improvements can occur. The unfortunate part is that it is having to occur under a regulatory program usually results in one size fits all approaches.
Did this allow a higher quality of fish to exist, or improve any recreational or water uses? Probably not, but the measures are effective based on measurable parameters.
I disagree with CVG in the above posts:
"How about going after the perennial bigtime polluters like agriculture, power plants, heavy industry and gas guzzling SUV drivers"
First of all, power plants and heavy industry are subject to stormwater regulations, and I would argue they carry a larger regulatory burden than construction. Exemptions to agriculture are eroding (pardon the pun) and will be regulated soon enough. SUV drivers??? that's just plain irrelevant and provocative!
Anyway, the SWPPP as a document is not so important at the tasks of implementation and critical evaluation and re-design. Done diligently, improvements can occur. The unfortunate part is that it is having to occur under a regulatory program usually results in one size fits all approaches.
jheidt2543
Civil/Environmental
I few comments of my own:
1. The burocrates that dream up most of these regulations should be made to produce a realistic cost/benifit analysis of the consequences of the rule. IMHO many of them would be found to be too costly by any streach, for the benifit they MAY have. Feel good, make work programs are too costly in today's world.
2. CVG's comments are off base. First of all, the power industry has made huge strides in cleaning up their act - by force yes, but progress none the less. The same can be said for the car industry. As far as agriculture, it depends a lot on the State you are in. In Wisconsin great changes have been made, not just by State mandated requirements, but working arrangements with groups like Trout Unlimited. Working with sportsman's groups like TU doesn't spend tax dollars, but produces results without costing the farmer an arm and a leg either.
Frankly, I get tired of the same old environmental mantra. I think some of the enviromental movements would get farther with a positive approach rather than the same old, tired confrontational approach. There has been a lot of progress over the last thirty years, how about giving credit where credit is do? And, how about recognizing that people have to make a living too? They would get a lot farther with a balanced approach, IMHO.
1. The burocrates that dream up most of these regulations should be made to produce a realistic cost/benifit analysis of the consequences of the rule. IMHO many of them would be found to be too costly by any streach, for the benifit they MAY have. Feel good, make work programs are too costly in today's world.
2. CVG's comments are off base. First of all, the power industry has made huge strides in cleaning up their act - by force yes, but progress none the less. The same can be said for the car industry. As far as agriculture, it depends a lot on the State you are in. In Wisconsin great changes have been made, not just by State mandated requirements, but working arrangements with groups like Trout Unlimited. Working with sportsman's groups like TU doesn't spend tax dollars, but produces results without costing the farmer an arm and a leg either.
Frankly, I get tired of the same old environmental mantra. I think some of the enviromental movements would get farther with a positive approach rather than the same old, tired confrontational approach. There has been a lot of progress over the last thirty years, how about giving credit where credit is do? And, how about recognizing that people have to make a living too? They would get a lot farther with a balanced approach, IMHO.
The environmental measures (SWPPS, NPDES) are on target folks. I've seen construction projects so foul with mud/silt and waste runoff that it was pitiful. Entire swales filled with silt and clear streams turn to mud in one day. I hate the tree huggers as much as the next developer/contractor, but I also hate when people take their trash and throw it over a hillside in the woods. And that's what happens when a construction project turns into a mud and/or dust mess with no means to control it. So let's give respect to the neighbors whether it's a residential zone, contractor, or fish. Keep the waste onsite and deal with it!
KRSServices
Civil/Environmental
Y'know folks, i have been reading your thoughts and would like to add one further. I realize that we have deviated slightly form the original thread, but up here, as in the USA, legislators have tried to provide bills and regulations that always assume a "worst-case" scenario. The results being cumbersome guidelines and sometimes restrictive (and costly) construction practices. In my years, I have grown quite accustomed to dealing with bureaucrats and find it quite surprising as to just how protective they get in their little world, where the word moderation and compromise do not exist. Flip the page to the practices of some contractors/project Owners and you'll quickly appreciate the fact that these rules exist.
I know it will never happen, but just once I would love to see regulations enforced with a degree of moderation and qualifying expertise and understanding of the overall impacts of construction with a corresponding balance and care practiced by the contractor. If this should ever occur, perhaps then, all stakeholders will be satisfied and happy with the nature of the job to be done!
That's 'nuff of my rambling and philisophical stew!
KRS Services
I know it will never happen, but just once I would love to see regulations enforced with a degree of moderation and qualifying expertise and understanding of the overall impacts of construction with a corresponding balance and care practiced by the contractor. If this should ever occur, perhaps then, all stakeholders will be satisfied and happy with the nature of the job to be done!
That's 'nuff of my rambling and philisophical stew!
KRS Services
Texas TNRCC has been renamed Texas Commission on Environmental Quality (TCEQ). They have been delegated the responsibility to enforce the Phase II regulations in Texas.
They have issued the TPDES General Permit TXR150000 (Construction) that is fairly definitive of what is required for SWPPP's.
Permit available at
As a PE & CPESC, I do not find the burden of preparation and implementation excessive. If done properly, the erosion & sediment controls can be effective and fairly economical. Having worked in the northeast for 5+ years during the late 80's, I find that Texas is still lagging as far as environmental concerns. Elimination of tracking dirt/mud onto pavement, control of dust and minimization of polluted runoff does make a large difference in stream pollution, especially in a city with major construction projects.
The Trinity River runs through the center of Dallas and is very polluted.
Check this web site for Texas impaired waters.
They have issued the TPDES General Permit TXR150000 (Construction) that is fairly definitive of what is required for SWPPP's.
Permit available at
As a PE & CPESC, I do not find the burden of preparation and implementation excessive. If done properly, the erosion & sediment controls can be effective and fairly economical. Having worked in the northeast for 5+ years during the late 80's, I find that Texas is still lagging as far as environmental concerns. Elimination of tracking dirt/mud onto pavement, control of dust and minimization of polluted runoff does make a large difference in stream pollution, especially in a city with major construction projects.
The Trinity River runs through the center of Dallas and is very polluted.
Check this web site for Texas impaired waters.
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