|Rainstorms and daily activities at construction sites can damage stormwater BMPs, necessitating regular inspection and maintenance.
Stormwater control BMPs need regular
inspections to ensure their effectiveness, and many permitting
authorities require self-inspection for construction projects.
Three types of BMP inspections are performed: routine
inspections, inspections performed before rain events, and
inspections performed after rain events.
Routine inspections are an integral part of regularly performed
maintenance activities--cleaning, repair, and replacement--necessary to
ensure the integrity and effectiveness of BMPs. Construction
site activities can damage BMPs. Earthmoving equipment, for example,
can easily dislodge an entrenched silt fence. Routine inspection and
maintenance minimizes the work required to prepare a site before a
rain event, and it helps protect a site from unforeseen rains.
Inspections Before Rain Events
It is critically important that construction site operators pay
attention to weather forecasts. To prepare for impending rains,
operators should walk the construction site and ensure that BMPs are
cleaned out and operating properly. They should verify that dumpsters
are covered, paint and other chemicals are covered, and no oil spills are
present. Such housekeeping practices are routinely performed in all
good inspection and maintenance programs. Operators should also
visually inspect all BMPs when the site will be inactive for several
days, such as weekends or holidays. This will help to prepare for
rains that might occur when workers are off-site. Planning and
preparation minimize the risk of on- or off-site property damage
occurring because of inoperative or malfunctioning BMPs.
Inspections After Rain Events
After a rain event, prepare the site for the next rain
event. Typically within 48 hours after rain, inspect, clean,
and repair the site's BMPs. This will keep the site "clean"
and minimize complaints from nearby residents. To prevent health and
safety hazards, remove mud in traffic areas and remove mosquito-breeding standing
water. Clean mud and debris from silt fences and other BMPs.
Clogged BMPs will not prevent pollutant releases
during subsequent rain events, so clean,
repair, or replace them as quickly as possible.
Construction operators are required to comply with federal NPDES
construction site stormwater regulations, which are often implemented
by state agencies. These regulations include developing stormwater
pollution prevention plans and implementing erosion and sediment
control and housekeeping BMPs. Federal construction site stormwater
regulations typically apply to sites that are 1 acre or larger.
Additionally, construction operators may be subject to local erosion
and sediment control requirements, such as requirements for grading
permits, that apply to sites smaller than 1 acre. Adequate BMP
performance requires not only proper installation, but also regular
maintenance. Maintenance needs are best determined by a
A construction site operator has several options to ensure that
regular inspections are occurring. At small sites, the site
superintendent or another management staff member can perform the
task. At large sites, a firm with expertise in erosion and sediment
control can be contracted to implement an inspection, maintenance, and
repair program for the site. Some permitting authorities have
implemented their own inspector certification programs. Individuals
that enroll receive the stormwater management training required to
become certified inspectors (e.g.,
Maine's Voluntary Contractor
Certification Program [Maine DEP,
2004]). Regardless of the process selected, it is the responsibility
of the construction site operator to assure that a mechanism for
regular inspections is established and functioning.
Inspectors must be familiar with the location, design
specifications, maintenance procedures, and performance expectations
of each BMP. The Stormwater Pollution Prevention Plan (SWPPP), based
on state and local requirements, should include specifications for BMP
maintenance (e.g., when sediment has reached one-third the height of
the silt fence, it must be cleaned out).
Regardless of who performs the inspections, it is critical to maintain
proper documentation. Use an inspection form or checklist
for each inspection. Log books are often used, but
they need to include more information than merely the date of the
inspections. Permitting authorities require self-inspections, and if
they audit the site, they will want to see proof of inspections to
document compliance. Permitting authorities may also wish to see
inspection and maintenance documentation for each specific BMP.
During a project's life, several persons may be responsible for site inspections.
Therefore, it is
important to keep adequate documentation of dates of inspections,
findings, and maintenance and repair of all BMPs.
Construction site operators should allocate adequate time frames and
resources for BMP maintenance and repair. Those responsible for
inspecting and maintaining BMPs should be trained in their design and
operation. This will help ensure that workers know when BMPs require
cleaning, repair, or replacement. Similarly, as site conditions change, BMP designs may prove to be inadequate in controlling erosion and sedimentation. A knowledgeable inspector will be able to identify these deficiencies and ensure that necessary improvements are made.
The effectiveness of BMP self-inspection and maintenance programs
vary according the amount of resources allocated to the tasks. When
made a priority, inspections and maintenance ensure that BMPs function
properly and help prevent pollution discharges. Education of on-site personnel is
another important factor in an effective program. To
recognize and preempt problems, those responsible for maintaining BMPs
must be familiar with their design and installation. However, making everyone at the site aware of general erosion and sedimentation control principles can expedite identification of maintenance issues and repairs.
BMP inspection and maintenance requires dedicating both management and
staff time to inspect, clean, and repair or replace BMPs.
Also, additional BMP materials may need to be purchased. For example,
a silt fence that has been ripped will require replacement.
Maine Department of Environmental Protection. 2004. Voluntary
Contractor Certification Program. [http://www.maine.gov/dep/land/training/ip-vccp.html ]. Last
updated August 2004. Accessed June 3, 2005.