What Is Stormwater Management?
When soil disturbance and vegetation removal occurs during construction projects, there is a drastic increase in water and wind erosion. Consequently, when rain events take place, water inevitably flows through those unprotected, eroded soil surfaces and have the potential to transport sediment into U.S. waterways. This sediment-laden water is referred to as, “stormwater.” As that “stormwater” flows over construction and industrial sites, it can carry other pollutants ranging from pesticides, chemicals and asphalt, to petroleum, and other debris collected from the soil surface and deposit those materials into water sources that serve as drinking water, aquatic habitats, and even public beaches and swimming areas. Urban stormwater discharged from storm sewers, often referred to as “Municipal Separate Storm Sewer Systems” (MS4s), has been found to be a leading source of water quality impairment. The stormwater flow picks up and transports these pollutants and then discharges contaminated water into U.S. waterways through MS4s.
The Clean Water Act and other relevant mandates require that all federal and state regulated construction sites, Municipal Separate Storm Sewer Systems (MS4) communities and industrial sites be covered under a National Pollutant Discharge Elimination System (NPDES) stormwater permit to have the ability to legally discharge stormwater into waters of the United States of America. Most, if not all, of the mandatory stormwater permits require that the implementation of erosion and sediment control (ESC) Best Management Practices (BMPs) are applied to curtail and minimize pollutant discharges entering surface waters, MS4s and other bodies of water such as lakes, streams, rivers and oceans.
Any construction project site, industrial facility or MS4 covered under a NPDES stormwater permit is subject to compliance inspections either from a federal organization (EPA), state entity and/or a third party inspection service. These stormwater compliance inspections consist of an on-site examination for:
- Proper National Pollutant Discharge Elimination System (NPDES) permit coverage.
- Prepared and amended a Storm Water Pollution Prevention Plan (SWPPP).
- Inadequate Storm Water Pollution Prevention Plans (SWPPPs).
- Proper installation, maintenance and replacement of erosion and sediment control devices and pollution prevention Best Management Practices (BMPs).
- Proper documentation (Notice of Intent (NOI), permit waivers, consultation letters, etc).
- Updated and amended reports (inspection reports, corrective action forms, spill reports, etc).
Failure to meet the required compliance standards can and typically result in fines. From 2008 to 2010 there has been over $20,000,000 in Clean Water Act Violations and stormwater non-compliance alone. Table 1.0 shows the civil penalties assessed from 2008 to 2010 for stormwater non-compliance:
|Fiscal Year (FY)||Estimated Pollutants to be Reduced or Treated (lbs)*||Estimated Investments in Pollution Control ($)**||Civil Penalties ($)***|
|2008||1,300 million||$69 million||$7.7 million|
|2009||200 million||$59 million||$4.9 million|
|2010||660 million||$99 million||$7.4 million|