Developing and Launching an Effective Erosion and Sediment Control Implementation Plan

Nov. 1, 2001
Beers Construction Company has a long history of adopting innovative construction techniques and management practices, so when it first heard of Georgia’s stormwater permit law, to become effective in the summer of 2000, it adopted an aggressive implementation strategy. When the new permit took effect on August 1, 2000, the Beers team was determined to be not only ready, but at the forefront of compliance in Georgia’s construction community.From the outset, developing and implementing a compliance plan presented a tremendous challenge. Georgia’s new General Storm Water Permit mandates the most stringent guidelines in the United States for stormwater runoff from construction sites. Designed to reduce turbidity (the level of suspended solids that makes water look muddy), the permit holds general contractors, owners, and developers jointly responsible for compliance with the law. The law requires that all sites disturbing 5 ac. or more of soil have best management practices (BMPs) in place and that they be properly designed, installed, and maintained. Projects found out of compliance can be fined and/or shut down.Beers’ first step in developing a plan for compliance with the new law was to have executives, senior managers, and legal consultants closely read both the permit and the law. While the documents were being reviewed, Geoff Bewley–then a manager in Beers’ Environmental Department–and I, Bob Provan, assessed the full scope of the task before us.
Silt-Saver is a one-man installation job and reduces the turbidity by about 1,000 NTUs compared to silt fence.We determined that there were 25 Beers projects in the state of Georgia falling under the provisions of the new permit: They met the criteria of disturbing 5 ac. or more of land. The projects were as diverse as the terrain in which they were situated, ranging from a sprawling 160-ac. wastewater treatment plant site on the outskirts of Atlanta to a school in the heart of the Blue Ridge Mountains.After determining which sites were affected by the law, we began the process of determining what we would have to do to bring each site into compliance. Georgia’s new permit is written around the design criteria of a 25-year rain event, which correlates to 6.75 in. of rain falling in a 24-hour period. Permittees are in compliance as long as their construction sites’ BMPs have been designed by a competent state-registered engineer, have been properly installed, and are being diligently maintained.Particularly challenging to us was the fact that there are no data to confirm that the desired nephelometric turbidity units (NTUs) can be met on a job-site level. The permit allows the addition of 25 NTUs to a state warm-water fishery’s background readings and 10 NTUs to a state cold-water trout fishery’s background readings. For example, water leaving a job site near a state trout fishery can only raise the background turbidity level in the stream 10 NTUs–roughly the equivalent of pouring bottled water into the same stream.Coffer dam at a water treatment plant projectEffluent pumped from the coffer dam into the sand filter and small stone energy dissipater berm at the edge of the filterWe soon learned that another difficult aspect of the new permit to qualify was the Memorandums of Agreement (MOAs). MOAs give a municipality or a local government the option of letting its own job-site runoff guidelines, provided that those guidelines are at least as strict as the state guidelines and that the local government proves to the state’s Environmental Protection Division (EPD) that it can enforce and document violations.We enrolled in what was then the State of Georgia’s only sanctioned class to qualify us as competent persons as mandated by the new permit/law. By the end of the two-day class, it was apparent that a number of Beers team members would have to qualify as competent persons in order for Beers to meet its goal of unequivocal code compliance.At that time, however, no training class large enough to handle the number of people we needed to train was available anywhere in Georgia. We worked with Jim Spotts, a state-approved consultant, to set up our own monthly Competent Person Training Classes. We advertised the class internally through mini-presentations at our 2000 Superintendents Retreat and other company functions. To date, more than 175 Beers’s project managers, superintendents, engineers, and estimators have attended these classes.To supplement in-class training, Bewley developed a Field Manual for Erosion Control and NPDES for Project Managers, Superintendents and Project Engineers. The manual provides all the necessary forms and permits, instructions on how to complete and submit them, and a color-coded erosion control procedures sheet that is time-sequenced from the initial Notice of Intent (NOI) to the Notice of Termination.We received approval from Beers’ CEO Joe Riedel and COO Dwight Morgan to establish an in-house Erosion Control Committee with representatives from each Beers group doing work in the state of Georgia. The committee’s mission was to distribute information on our procedures and evolving corporate policy to the 25 projects initially affected, as well as new project startups after August 1, 2001.The committee meets monthly and has proven to be tremendously beneficial, particularly in the early stages. In addition to dispersing information, the committee has established and maintains a database of BMPs. We have tested and kept records on numerous state-of-the-art BMP products, including (but not limited to) polyacrylamides, tackifiers, geotextile fabrics, and various seed blends. Our database gives us the resources to overcome any erosion control problem that might arise at our sites in Georgia and other states.Slopes before test application of Soil GuardBy August 2001, a competent person had been trained for each of our 25 sites and each site had submitted an NOI. That month was hectic, particularly since the permit was as new to government officials as it was to us. Bewley regularly monitored the initial 25 sites to ensure that they were compliant with the new law and to troubleshoot sites where erosion control was particularly challenging. Our preparation paid off: We have yet to be shut down or fined. In fact, we recently procured a contract based on our superlative erosion control policy/programs.Since the implementation of the new erosion control law, we have continued to monitor affected sites to check in-place BMPs and assist in developing erosion control measures for sites with difficult terrain or close proximity to wetlands. We also continue to evaluate and test new erosion control products and methods. A few of these have proven particularly effective on our job sites and are worth mentioning.Mat Inc.’s Soil Guard, tested at the Rockdale County Water Treatment Plant and Bear Creek Water Treatment Plant, has greatly reduced erosion in mass excavations. Soil Guard can be used with or without seed in a hydroapplication and goes down thin enough to not affect backfill compaction around concrete walls. It also eliminates mud and silt cleanup around concrete formwork. Soil Guard germinates seed very well and does not break the surface tension of hydroseed applications.We also have used polyacrylamide at numerous sites with great results. Currently we are testing it in conjunction with multiple erosion control materials and methods. To date, all tests are very promising.Test application of Soil Guard without seed around slopesSlopes after 1.5-in. rainfall event in 24 hours. Broken areas are from equipment operator moving materials across slope areas.Silt-Saver saves time and money because it requires only one person for installation. We install Silt-Saver over stormwater drop inlets, and it greatly reduces the NTUs passing through the device, as compared to silt fencing. Silt-Saver’s design is very strong, supporting mud all the way up to the top of the device.We are currently testing about 15 other products and methods. To support our field implementation program, Beers remains proactive in keeping up with erosion control regulations. Beers currently represents “big construction” on the Georgia Governor’s Storm Water Advisory Committee. This 20-member committee meets monthly and is made up of a wide range of community and business representatives. Members are charged with drafting recommendations for the new permit/law that is slated to take effect on August 1, 2003, and will apply to all construction sites disturbing 1ac. or more of soil.This committee also is charged with the review and evaluation of General NPDES Permit No. GAR 100000 for the discharge of stormwater associated with construction activity. Committee members evaluate alternatives, taking into account current construction practices. Our committee’s recommendations are submitted to the director of Georgia’s EPD.The Governor’s Storm Water Advisory Committee is chaired by Bob Kerr, director of the Pollution Prevention Assistance Division of Georgia’s Department of Natural Resources. He also serves as the State of Georgia’s senior representative in the “Water Wars” negotiations between South Carolina, Georgia, Alabama, and Florida over state water rights/ownership. His many years of experience in successfully dealing with complex matters serve him well as he chairs the diverse social cross-section making up the Governor’s Storm Water Advisory Committee.Both Beers and Skanska–our parent company–welcome Georgia’s new stormwater runoff guidelines. Because commitment to initiatives that protect our environment is an integral part of our corporate culture, we are proactive in addressing such issues as the supply of available drinking water. We understand that as worldwide populations soar and population centers shift, we all must take steps to safeguard and improve our environment. This permit and any successors are a step in the right direction.Similar to many other states, Georgia is seeing the financial impact of substandard water. The expense of dredging reservoirs that have lost capacity as a result of silt deposits is paid through tax dollars. Municipal water treatment plants must charge customers for the increased chemicals and electricity necessary for water treatment when influent raw water has high turbidity levels.Additionally, recreational sport-fishing is a major industry in Georgia. State waterways that cannot support fish do not draw fishermen, not only reducing revenues from fishing licenses but–more importantly–reducing revenues for the small businesses that serve the fishing industry: motels, campgrounds, stores, restaurants, and bait and tackle shops located near once-productive fishing spots.From the construction industry’s perspective, the new law helps address the public’s perception of construction’s negative impact on the environment. Although most silt enters state waterways through such nonconstruction means as logging operations, farming, and major rain/wind storms, the public often attributes silt to nearby construction sites.In Georgia, a long-standing drought has increased stormwater runoff. Vegetation has died on streambanks and lakeshores and is no longer able to help prevent erosion, resulting in significantly increased levels of soil-laden runoff flowing into state waterways.The new law affords construction firms an opportunity to protect themselves through documentation of background turbidity levels in state waterways adjacent to our projects. By documenting fluctuating background turbidity levels, construction companies help fulfill the intent of the new permit/law by tracking “true data.”Our analysis shows that, in the long run, proper erosion control saves construction projects money. Unchecked erosion washes out project access roads. Not only do the roads have to be reestablished, but productivity is reduced when accessibility is reduced. Unprotected manholes can fill up with silt, as can associated piping. Storm drains and their associated piping have the same problem. These scenarios necessitate the labor-intensive removal of soil and the costly high-pressure water jetting of piping systems.Unchecked erosion also fills riprap channels with silt and reduces the storage capacity of detention ponds via sediment deposits. On larger projects, mud-covered material lay-down areas can cause project teams to reorder material that is no longer “readily visible.”The bottom line and corporate social responsibility are not mutually exclusive. Ultimately we all share stewardship of the environment. Beers understands the importance of this commitment and has incorporated it into its corporate culture.

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