Environmental & Stormwater Compliance Scope of Services

Whitson Contracting and Management, Inc. manages every aspect of these new regulations. WCM has mitigated several enforcement actions taken by the RWQCB against permit holders. We have managed and kept compliant dozens of construction and industrial projects throughout Southern California since 2004. Most importantly, we guarantee compliance for projects that we manage. The environmental compliance division has been operating since 2007 and is a California Certified Small Business Enterprise (#37019). Our staff is entirely composed of certified professionals in erosion/sediment control and storm water quality.

A. Preliminary Risk Level Assessment Project Review

• Project-Specific Risk Level determination
• Review of topographical and project related maps
• SWRCB database research for existing pollutants found onsite
• Determination of impairment for downstream 303(d) Receiving Water Bodies

B. Project Planning Due Diligence

• Construction phasing and planning coordination with the project engineer and grading contractor in regards to the new regulations.
• Coordination of construction scheduling based on the project-specific Risk Level.
• Management of subcontractor storm water training requirements; Management of appropriate environmental permits and training for how the permit affect construction activities; and Development of a project management checklist to ensure appropriate required measures are occurred during the construction project.

C. Preparation of Storm Water Pollution Prevention Plan (SWPPP)

• A Qualified SWPPP Developer will prepare a Notice of Intent (NOI)
• Development of a Risk Level specific SWPPP
• Development of the Risk Level specific Construction Site Monitoring Program (CSMP)

D. Prepare Notice of Termination (NOT)

• A Qualified SWPPP Developer will electronically file a Notice of Termination including a final site map, a New and Re-development Performance Standard Worksheet, and finalized photos when the construction project is deemed complete. Post-construction final walk through with owner.

E. SWPPP Inspection Services

• A Qualified SWPPP Practitioner will conduct weekly site inspections per requirements of the General Construction Permit 2009-009-DWQ
• Inspections will include documentation, including photographs, of BMPs; including recommendations for any additional BMPs or necessary maintenance; and documentation of BMPs installed.
• A Qualified SWPPP Developer will prepare and electronically submit an Annual Report no later than September 1 of each year using the Storm Water Multiple Application Report Tracking System (SMARTs).
• The Annual Report submittal package will include all requirements of the Construction General Permit Section XVI a through e.
• The Qualified SWPPP Practitioner, data submitter, we will electronically file all required Permit Registration Documents (PRDs) such as the Notice of Intent (NOI), Notice of Termination (NOT), Change of Information (COI), Annual Reports and any other compliance documents using SMARTS.

F. SWPPP Auditing Services

• A Qualified SWPPP Practitioner will conduct weekly site audit reporting on the required documentation for SWPPP inspections, maintenance and repair of Best Management Practices (BMPs) per the requirements of the Construction General Permit.
• Site audits will include reporting on the required documentation for the Construction Site Monitoring Program (CSMP), the Rain Event Action Plan (REAP) and the appropriate Risk Level documentation requirements.
• Site audits will also include the documentation of BMPs installed, BMP actions implemented, and BMPs that need maintenance or failed to operate as intended.

G. Storm Water Monitoring and Sampling Program Services

• A Qualified SWPPP Practitioner will conduct visual observations, documentation and properly collect 3 storm water samples at all monitoring locations identified in the SWPPP or identified by the owner (or the owner’s representative) during likely precipitation events that are anticipated to produce at least ½ inch of precipitation for Risk Level 2 and 3. Risk Level 1 projects will be sampled for Turbidity and pH based on visual observations and approval by the owner (or the owner’s representative).
• The Practitioner will coordinate and properly deliver project-specific 303(d) listed pollutant storm water samples to an authorized laboratory for analysis.
• The Practitioner will prepare a Rain Event Action Plan (REAP) for each likely precipitation event in accordance with the General Construction Permit. The REAP is a Construction General Permit requirement for risk level 2 and 3 projects designed to protect all exposed portions of the site within 48 hours prior to any weather pattern forecasted to have a 50% or greater chance of producing precipitation in the project area (i.e., “likely precipitation event”).
• Monitoring Program services will include a written report of the storm water sample results, documentation of the pre-event, during event and post-event site inspections and a recommendation of corrective actions.
• For risk level 2 and 3 projects effluent sampling of discharges is required during rain events. If the Numeric Action Level (NAL) exceeds 250 NTUs for turbidity or falls outside the range of 6.5 to 8.5 pH then an onsite evaluation will be performed and if necessary corrective actions, such as implementing additional BMPs will be taken.
• In the event that a single sample exceeds an applicable NAL, the Practitioner will electronically submit all storm event sampling results to the State Water Board no later than 10 days after the conclusion of the storm event. In the event that a daily average exceeds an applicable NAL, the Practitioner will prepare an internal report. If the SWRCB refers the exceedance to the RWQCB an external report will be prepared, after owner’s authorization.
• For Risk Level 3 projects effluent samples that exceed the Numeric Effluent Limitation (NEL) are in violation of the General Permit. If pH is outside of the range of 6.0-9.0 and/or turbidity samples exceed 500 NTUs then the project is in exceedance of the NEL and therefore we will implement additional monitoring and BMPs and revise the SWPPP.
• For Risk Level 3 project the Practitioner will electronically submit all storm event sampling results to the State Water Board no later than 5 days after the conclusion of the storm event. In the event that any effluent sample exceeds an applicable NEL, the Practitioner will submit an NEL Violation Report to the State Water Board within 24 hours after the NEL exceedance has been identified. In the event that a daily average exceeds an applicable NEL, the Practitioner will prepare and electronically file the monitoring results in violation within 5 business days of obtaining the results.

H. Notice of Violation and Clean-Up and Abatement Compliance Services

• An experienced Certified Project Manager will coordinate, inspect, audit and manage non-compliant projects into compliance; and for the ultimate goal of settlement.
• Compliance Services includes coordination with project’s representative environmental attorney, coordination with the State Water Resources Control Board staff, and coordination with local municipal staff.
• Management services include over-sight of the project’s sediment and erosion control contractor, management with construction operation supervisors for improving construction best management practices, construction scheduling, BMP implementation, etc.
• The experienced Certified Project Manager will also perform necessary site inspections and audits per the requirements of the violation or authorization by the project’s environmental attorney.

I. Storm Water and Sampling Training Services

• A Qualified Trainer will conduct a four-hour Storm Water training course every six months or when requested by the owner.
• Storm Water training will include an over-view of the rules and regulations of the Construction General Permit, local municipality’s ordinance, and detailed information on proper storm best management practice implementation.
• Classes will also discuss Regional Board and municipal site inspection procedures, local Regional Board and municipal enforcement activities, proper construction scheduling, site specific BMP installation, recommendations of long-term BMP effectiveness, site specific BMP maintenance, site specific good housekeeping practices, site specific high priority locations, site specific implementation of the Rain Event Action Plan and Construction Site Monitoring Program.
• Storm Water Sampling training course annually (prior to the beginning of the wet weather season) or when requested by the owner based on the Surface Water Ambient Monitoring Program.
• Storm Water Sampling training will include an over-view of the Monitoring Program and Reporting Requirements of the Construction General Permit; non-storm water discharge inspections; storm event related inspections; required sampling constituents; site specific storm water sampling locations; storm water sample collection and handling instructions; monitoring methods including visual observation locations; visual observation procedures; visual observation follow-up and tracking procedures; Chain of Custody handling procedures; record keeping; annual reporting requirements;
• A discussion of the procedures and requirements for the Numeric Action Level (NAL) Exceedance as well Numeric Effluent Level (NEL) Exceedance Reporting.

J. Prepare Water Quality Technical Report (WQTR)

• A Professional Engineer will prepare a WQTR (or similar Post-Construction Best Management Practice report) in accordance with the project’s municipal Standard Urban Storm Water Mitigation Plan for post-construction BMPs.
• Designs and calculations will be prepared for applicable source control, low impact development, structural and non-structural post-construction BMPs.

K. Habitat Revegetation

• Develop a hydroseed specification matrix including soil amendments based on compost soil sample.
• Develop a bid specification and submit to three qualified firms.
• Provide scheduling recommendations and soil preparation procedures for hydroseeding installation.
• Manage the hydroseeding process and field-verify all hydroseed specifications are being deployed during installation.

L. Post-Construction Monitoring Services

• A Qualified SWPPP Practitioner will conduct visual observations, documentation and perform (or manage) proper maintenance for applicable source control, low impact development, structural and non-structural post-construction BMPs for the project property.
• Post-Construction Monitoring Services will be conducted based on the project-specific municipality guidelines for post construction.
• Maintenance activities for structural post-construction BMPs will be performed based on the manufacturer’s recommendations.