FCCD Preconstruction Meetings and FCCD Expectations

1. FCCD Preconstruction Meetings andFCCD Expectations

2. Preconstruction Meetings • FCCD requires a preconstruction meeting per NPDES permit conditions • Conservation District needs at least 7 days notice to schedule a preconstruction meeting • Who should attend the pre-con. meeting? Developer, contractor's (site superintendent & project manager), project engineer, municipal representative, & Conservation District E&S technician Good opportunity to get all parties on the same page & address any previously unforeseen issues.

3. The contractor must have the approved stamped E&S plan available on site upon District’s request. • (including PPC & PCSM plans) • PPC = Preparedness, Prevention, & Contingency plans • PCSM = Post-construction stormwater management plan

4. 2)District needs to be made aware of any revisions made to approved E&S plan.

5. Revisions/additions to approved plans often made or required due to: • Projects being broken into phases • Wetland mitigation required • Penn DOT road improvements required • Lot and/or street layout changed • Proposed utilities not shown ex. offsite sanitary sewer • Unforeseen circumstances

6. 3) Co-permittee requirement • NPDES permit requires once a general contractor (operator) is selected to become a co-permittee • If not a co-permittee, working without a permit • Should be completed prior to starting work – good idea to have ready at the pre-con. meeting • A written agreement should be attached detailing the contractor’s specific responsibilities

7. 4) State & Federal Permits • Penn DOT HOP – for construction entrances, storm sewers, etc. • DEP General Permits for stream crossings, wetland impacts, pipe outfalls • Army Corp of Engineers

8. 5)PPC plans must be available on site • For storing fuel or other hazardous materials on site • Liquids to have secondary containment • Do not discharge concrete wash water to BMPs

9. 6) Outlet structures need to be on siteprior to earthmoving • Permanent concrete outlet structures • Barrels • CMP risers • Trash racks • Skimmers

10. 7)Field mark wetlands and limits of disturbance • Orange construction fence often required by Army Corp of Engineers • Silt fence may be used to mark off-limit areas where shown on approved E&S plan • Areas to be field marked off-limits may include wetlands, streams/floodways, steep slopes, existing trees to be saved, on-lot septic systems, and stormwater infiltration areas

11. 8) Discuss The Construction Sequence • Criticalpart of E&S plan since construction sites are constantly changing and altering the flow path of storm water runoff – ex. streets, curbs, trenches, tire ruts, etc. • Intent is to show the installation of BMPs prior to upslope earth disturbance at each stage of construction • Perimeter BMPs must be installed prior to upslope disturbance(except for minimal disturbance for upslope borrow/fill areas required for BMP construction only and which drain back into the BMP under construction)

12. Avoid taking chances with the weather • Prolonged wet weather can involve multiple pollution events • Install and stabilize BMPs the right way the first time.

13. Clearing & grubbing = earth disturbance Required BMPs not installed and area of disturbance not limited

14. Collector channel installed on wooded slope prior to clearing & grubbing of site Sediment basin installed prior to clearing & grubbing of site.

15. Same basin discharging cloudy runoff, no offsite discharge Basin berm stabilized & basin with skimmer functioning during heavy rain event

16. Offsite discharge to roadside swale, state highway, and stream The other side of the ridge rough graded and no basin installed.

17. Inlets not functional. Runoff bypasses basin. Inlet berms not properly installed. Runoff is bypassing inlet

18. 9) Discuss offsite activity • An approved & fully implemented E&S plan is required for all offsite borrow/spoil areas regardless of location • May utilize another NPDES permitted site that has an approved E&S plan

19. 10) Call the Conservation District for a site visit/inspection once perimeter BMPs have been completed & prior to upslope disturbance • District requests at every preconstruction meeting but very few contractors call • Gets all parties off to a good start and contains the site disturbance

20. 11) Review Stabilization Requirements • Chapter 102.22 requires “immediate” seeding and mulching upon completion of an activity (or) any stage or phase of an activity” • Agree upon a reasonable date to complete with District inspector given favorable weather • Replace topsoil

21. Use straw mulch at 3 tons per acre (1/2” to ¾” loose layer) and anchor • Erosion control blankets required on slopes steeper than 3:1 areas of concentrated flows such as channels, & within 50’ of streams • Install the correct blanket & per the manufacturer’s instructions • Straw-mulching required during non-growing season (ex. winter, drought) • Over excavate for proper rock placement

22. 12) BMP Maintenance • Weekly inspections required • Inspections after each runoff event required • Written maintenance log required to be kept on site (includes date, time, inspector, and summary of BMPs and compliance) • Repair washouts/BMP blow outs as soon as soil conditions permit

23. Don’t make more of a mess by attempting to repair washouts during wet conditions • If there is a potential for pollution, install interim BMPs • NPDES permit requires that the District be contacted if BMPs are found to be inoperative or ineffective

24. 13) Review Inspection Procedures • District investigates complaints and performs routine inspections on NPDES permitted site (per DEP delegation agreement) • District completes an inspection report • District requests responsible party to agree to reasonable dates to voluntarily comply • Also document Compliance Assistance site visits/meetings. Complete page 3 of report and have all parties sign.

25. 14) Review Enforcement Options • Generally 3 strikes and then referred to DEP Compliance Specialist • If pollution is occurring, site conditions present a significant potential for pollution, and responsible party has demonstrated an unwillingness to comply now or in the past District may refer to DEP on first inspection • Fines, field orders, & withholding permits are options • District seeks voluntary compliance but it is ultimately up to the responsible party

26. 15) Local Municipality’s Involvement • Obtain all land development approvals from township or borough • Be aware of any local E&S and/or stormwater management ordinances that may have additional requirements • Address any E&S concerns they may have (ex. equipment entrances, mud on streets, dust, inlet berms, etc)

27. 16) & 17) Permanent Stabilization & BMP Removal • Permanent stabilization is defined as “a minimum uniform 70% perennial vegetative cover….” over all disturbed areas • Compacted stone, pavement, wood mulch • Contact District to visit the site or discuss over the phone before removing any BMPs • Seed & mulch areas disturbed by BMP removal

28. 18) Discuss Post Construction Stormwater Management BMPs • Refer to PCSM plan required by NPDES Phase II • PCSM BMPs to be installed once the site is permanently stabilized • PCSM BMPs to provide for infiltration and water quality treatment • Need to avoid clogging infiltration trenches, underground storage facilities with sediment • Special wetland plantings may be required

29. 19) Notice of Termination (NOT) • Contractor should submit NOT form once site is completed & permanently stabilized • Contractor may choose to submit NOT once BMPs are complete and initial site work (ex. streets, curb, utilities) is complete and seeded and mulched – Developer must agree to NOT • Then come back on as co-permittee to remove/convert BMPs at end of project • Certifies PCSM BMPs are installed