Due to Shelter-in-place COVID-19 precautions, several construction sites in the Bay Area have been ordered to shut down. Essential construction sites, such as those necessary for healthcare, affordable housing, public safety, essential transportation projects and others are able to remain active. However, many private projects such as residential housing and commercial developments are shutting down.
The difficult part is that many have sediment and erosion control or other Best Management Practices (BMPs) in place that will need to be maintained and beefed up in order to protect stormwater and the environment during the shut-down.
Sites with over 1 acre of soil disturbance have active Stormwater Construction General Permits that would be impractical to put on hold due to the unknown time frame of the shut-down.
So what BMP measures are needed for a shut-down?
The answer: the same BMPs needed for winterization
Here are some key elements to consider:
Make sure all inlets are properly protected
Cover and berm stockpiles of dirt, asphalt, concrete debris and materials
Put chemicals away into covered, secondary containment
Secure portable toilets so that they can’t tip over during a wind storm
Pick up and throw out trash and debris
Move materials and stockpiles out of flow lines so that stormwater can’t co-mingle with construction materials
Make sure all sediment controls (silt fence, fiber roll, gravel bags, etc) are installed properly and repaired where needed
Add erosion control to disturbed soil areas
Cover waste bins
Cover concrete washouts or call and have them removed while you are on suspension to save costs
Do I really need Erosion Control?
Yes. Even though we are entering the dry season, erosion control is needed for disturbed soil areas on sites with an Stormwater Construction General Permit if the areas will be inactive over 14 days.
Unfortunately, the quick shut-downs didn’t allow much time for arranging erosion control which usually means calling an erosion control subcontractor and scheduling the application of hydraulic mulch, hydroseeding or temporary cover.
Have your Qualified SWPPP Developer and/or Qualified SWPPP Practitioner evaluate your site for what needs to be protected. An effective combination of erosion and sediment control must be in place to prevent turbid discharges or wind erosion at the site.
Can you suspend stormwater inspections during a shut-down?
This is a tricky question. Essentially the State Water Resources Control Board (SWRCB) will allow inspections or required monitoring and reporting to be put on hold if there is a good reason and it is well documented. They are leaving it up to local jurisdictions to assess whether or not a project is essential.
If your site is essential and active and you can safely access the site, then inspections should continue. If your site is shut down due to COVID-19 and can’t be safely accessed, then inspections can be suspended but a letter should be provided through SMARTS to the SWRCB.
Typically workers on outdoor construction sites can keep the appropriate social distance from other workers. I recommend to maintain toilets, hand washing stations and good housekeeping of wastes so that employees and inspectors are safer from virus spreading mechanisms.
Can I put my stormwater permit on hold?
We do not recommend closing your permits at this time. To close a permit out, all construction activities must be completed, temporary BMPs removed and permanent erosion control must be in place and be established.
This is not realistic in a quickly rolled out shut-down. Because of this we recommend keeping your permit open; it is hopeful sites will be back up and running sometime in May or early June.
Have any more questions? Ask them in the comments, or email our estimating team at firstname.lastname@example.org