How to Survive a DEC Construction Site Inspection

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How to Survive a DEC Construction Site Inspection
Bill Lupo, Environmental Engineer 2 NYSDEC
Division of Water, Region 5
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Overview

• Site Inspection Procedures
• Common Problems and Site Examples
• Remediation Procedure

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DEC does conduct site inspections!

• Purpose
• Document Compliance
• Provide Technical
• Assistance
• Protect Water Resources

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DEC Site Inspection Procedure

• Initiated by
• Follow-up to Plan review
• Citizen Complaint (mud tracked on to road?)
• Drive-by
• Routine visit based on NOI listing
• Inspection schedule
• Document Permit Compliance (stop at job trailer
  first)
• Tour construction site (invite project manager
  along)
• Re-visit trailer and discuss inspection results

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Construction Site Stormwater Inspection Report
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Construction Site Stormwater Inspection Report
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Construction Site Stormwater Inspection Report
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On the job site Bare Soil Precipitation

• Cleanup costs
• Lost work days
• Materials and equipment
• replacement costs

and . . . Water Quality Standards Violation and
potential fines from DEC more
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Construction Sequencing
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Improper Construction Sequencing
Rock outfall stabilization should be installed
before placing rolled erosion control materials
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Erosion Sediment Control Notes
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Erosion Sediment Control Notes
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Current Site Conditions
Site Inspectors will consider current site
conditions in determining if contractors and
developers are employing ESC measures adequately
Recent Rainfall / Snowmelt Season Soils Drainage
Area Water Courses / Flow Paths Topography /
Slope Length Percent Impervious Cover Vegetative
Cover
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Stabilized Construction EntranceMust be
maintained throughout project!
? Okay
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Common silt fence application problems

• ? Too far from the gutter
• Flapping fabric
• (must be embedded at least 6)

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Common silt fence application problems
? Not maintained should be cleaned and replaced
? Not maintained should be replaced
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Wetland or Sensitive Area Boundaries should be
properly protected to avoid encroachment
Okay ?
Unacceptable ? ?
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• Check Dam Materials should properly direct flow

• Stone Check Dam constructed in conformance with
  NYS Technical Standards

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Check Dam Materials should properly direct flow
Square-notch silt fence and hay bale check dams
are not accepted by NYS Technical Standards
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• Seed and Mulch
• Reduces soil loss by up to 90
• Reduces maintenance costs

• ?
• Unacceptable

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Hydroseeding reduces runoff and erosion by
promoting vigorous establishment of plant cover
Your local Soil and Water Conservation District
may be available to assist with hydroseeding
applications
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Rolled Erosion Control Products
Should be applied up and down the slope with
overlapping edges
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Rolled Erosion Control Products
RECP applied across the slope can peel back in
a storm event ?
? RECP could have prevented this gully erosion
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Steep Slopes (gt 21) should be protected
Terracing Rolled Erosion Control Products
Seed and Mulch !!!
Okay ?

• Unacceptable

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Spillways and Inlets must also be stabilized

• Lack of outlet stabilization can cause
• Channel Cutting
• Undercut Pipes

• Unacceptable ?

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Drop Inlet ProtectionA handful of accepted
techniques
? Stone and block inlet protection
? Filter fabric inlet protection
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Drop Inlet Protection and SO many wrong ways!
? Unacceptable straw bales arent protecting
the catch basin
? Unacceptable sand bags over grate caused
ponding
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Drop Inlet Protection more wrong ways!
? Unacceptable fabric under grate causes
ponding
The same catch basin a few months later ?
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Grass Swales They work great if theyre
installed correctly
Good ?
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Grass Swales
? Unacceptable needs to be seeded and mulched
Unacceptable tracks should run up and down side
slopes ?
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Stormwater Management StructuresImproper
installation and maintenance can lead to Water
Quality Violations
? Eroding banks
? Flow bypasses outlet berm doesnt meet box
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Stormwater Management Structures
? Lack of Forebay or settling time excessive
turbid discharge
Forebay berm doesnt meet side slopes ?
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Compacted Cracking Subsiding doesnt provide
acceptable infiltration!
Infiltration / Filtering Problems
Under-drains dont work if they are grouted in!
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Should be embedded in the soil, tightly abutted
and replaced frequently
Straw Bale Dike
Straw / hay bales are NOT acceptable check dam
material
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No rock outlet does not provide sediment
settlingNo rock on slopesSilt fence barrier
does not allow discharge
Sediment Traps
? No rock on slopes increases sediment load in
trap
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Wetlands arent meant to be sediment traps!
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After the Inspection

• Letter to owner, contractor, and/or engineer
• If inspection rating is unsatisfactory
• Follow-up inspection
• Meeting with DEC Regional staff to discuss
  deficiencies and achieve compliance
• Notice of Violation
• Consent Order and assessment of penalty
• Stop Work Order

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Stop Work Order
Upon a finding of significant non compliance with
the permit or the applicable SWPPP, the
Department may order an immediate stop to all
construction activity at the site until the
non-compliance is remedied.
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Consent Orders

• Any permit non-compliance constitutes violations
  of the CWA and ECL
• Maximum penalties are 37,500 per violation per
  day
• Who is the responsible party?
• The operator must comply with all conditions of
  the permit
• All contractors and subcontractors associated
  with the project must comply with the terms of
  the SWPPP

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Resources to Help with These Practices

• New York State Stormwater Management Design
  Manual
• http//www.dec.state.ny.us/website/dow/mainpage.ht
  m
• New York State Standards for Erosion and Sediment
  Control (Blue Book)
• http//www.dos.state.ny.us/lgss/stormwaterpub-old/
  index.html

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DEC Regional Stormwater Contacts

• Region 1 631-444-0405 Nassau, Suffolk
• Region 2 718-482-4033 Bronx, Kings, New York,
  Queens, Richmond
• Region 3 914-332-1835 Dutchess, Orange,
  Putnam, Rockland, Sullivan, Ulster,
  Westchester
• Region 4 518-357-2045 Albany, Columbia,
  Delaware, Greene, Montgomery, Otsego,
  Rensselaer, Schenectady, Schoharie
• Region 5 518-623-3671 Clinton, Essex,
  Franklin, Fulton, Hamilton, Saratoga,
  Warren, Washington

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DEC Regional Stormwater Contacts

• Region 6 315-793-2554 Herkimer, Jefferson,
  Lewis, Oneida, St. Lawrence
• Region 7 315-426-7500 Broome, Cayuga,
  Chenango, Cortland, Madison, Onondaga,
  Oswego, Tioga, Tompkins
• Region 8 585-226-2466 Chemung, Genesee,
  Livingston, Monroe, Ontario, Orleans,
  Schuyler, Seneca, Steuben, Wayne,
  Yates
• Region 9 716-851-7070 Allegany, Cattaraugus,
  Chautauqua, Erie, Niagara, Wyoming

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Websites for Training Professional Associations

• Stormwater Managers Resource Center
  http//www.stormwatercenter.net
• Center for Watershed Protection
  http//www.cwp.org
• Certified Professional in Erosion and Sediment
  Control, Inc.
• http//www.cpesc.net
• SUNY-ESF Continuing Education - Stormwater
  Management Program http//www.esf.edu/outreach/sto
  rmwater/

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Government Websites