Who is Responsible?

In February 2015, the Florida Department of Environmental Protection (FDEP) revised the Construction Generic Permit (CGP) for Stormwater Discharge from Large and Small Construction Activities defining the term “site operator” as follows:

“The person, firm, contractor, public organization, or other legal entity that owns or operates the construction activity and that has authority to control those activities at the project to ensure compliance with the terms and conditions of this permit.”

The construction site operator frequently visits the facility or construction site on a regular basis. The operator will provide supervision over the facilities stormwater activity measures, such as Best Management Practices (BMPs) and should also perform proper maintenance to BMPs.  Maintaining a current documented Stormwater Pollution Prevention Plan (SWPPP) is critical for obtaining the FDEP permit. The SWPPP will act as the site operators stormwater compliance continuity plan for ongoing support through-out the life of the project.

Here are some of the responsibilities, but not limited to, for construction site operators associated to maintaining and managing stormwater.

  • Required to obtain permit coverage under the Florida Construction Generic Permit (CGP) for Stormwater Discharge.
  • Ensures all compliance with the permit requirements.
  • The lead individual who has operational control over the project.
  • Person willing to accept responsibility for compliance with the permit.
  • Review and sign the facility’s stormwater pollution prevention plan.
  • Conduct weekly and after storm event comprehensive stormwater inspections.
  • Proactively oversee and implement appropriate pollution prevention techniques to minimize erosion and sedimentation from stormwater discharges during construction.
  • Responsible to post the project’s proof of permit coverage with a copy of the Notice of Intent (NOI) or acknowledgement letter and make available for public viewing.

Although the site operator takes full responsibility for the health and sustainability for the sites stormwater compliance, everyone involved on the project should take responsibility and do their part to make sure the construction site maintains compliant at all times.

Many BMP’s will certainly need attention from time to time primarily due to the vulnerability to accidental BMP damage caused by trade workers and various construction teams performing work on the site. Here are some frequent occurrences that take place that may create a situation of becoming non-compliant.

  • Vehicle sediment tracking on to the road.
  • Lack of effective containment for Paint, stucco, and other liquid waste wash out.
  • Silt fence may be damaged due to being disturbed or altered by heavy equipment.
  • Inlet protection sediment buildup.
  • Non-functioning Concrete Washouts.
  • Non-functioning Waste Management.

Many of these issues can be avoided by General Housekeeping and proactively Educating onsite teams and trades. Based on our extensive experience and time in the field performing many inspections and consulting with clients, we consistently find there are specific areas needing attention that will help site operators ensure compliance and maintain a rewarding stormwater management program.

KCI can help site operators put in place low-cost awareness and enablement orientation initiatives that can dramatically increase environmental proficiency and reduce overall cost. We help site operators perform the job responsibly. Give us a call at (888) 346-7779.

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