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Why Alpha EMC
Where All Success Has A Beginning
Alpha Environmental Management Corp. (Alpha EMC) Alpha Environmental Management Corporation (Alpha EMC) is a company dedicated to the overall management, support, education and partnership of our client's environmental needs and requirements.
Our Mission
Alpha EMC is a client-focused corporation striving to assist our business partners in reaching their goals as well as improving the lives of those who reside and conduct business in the their particular community. Our focus is Erosion and Stormwater Management, however, our over-arching objective is to create an environment of trust, dependability and creativity in supporting our clients’ federal, state, and local requirements as well as individual business goals without adding internal personnel and labor costs. Alpha EMC prides itself as a business partner that believes character, integrity and ingenuity are key ingredients for success. Alpha EMC...Where all success has a beginning.
The Challenge
The EPA is monitoring the effectiveness of Stormwater Pollution Prevention Plans (SWPPPs) and Best Management Practices (BMPs). As each month progresses, the intensity and severity of non-compliance grows to new heights. According to the FSA, Florida, for example, is both blessed and cursed with abundant rainfall during most years. Most states are faced with the same issues. Prior to the 1970s, most communities viewed water as "the common enemy". Abundant rainfall provides natural irrigation for urban lawns and agricultural activities, replenishes ponds and lakes, maintains flows in creeks and streams, provides essential hydro-period fluctuations in our wetland systems and is essential to the recharge of our regional aquifer systems.
However, this same stormwater is a curse because frequent small storms cause pollutants from cars, fertilizers, pesticides and herbicides to enter waterways, and high rainfall intensities and/or large storm event volumes combined with under-designed or poorly maintained drainage systems produce flooding and severe erosion. It is this duality that creates storm water management challenges for communities.
Stormwater problems, unlike water and wastewater processes, are not steady state operations with flows that are directly related to the community's population. Due to the vagaries of weather, stormwater flows are not readily predictable on a daily or monthly basis. If a reporter were to ask any stormwater manager to name the community's stormwater management problems it is likely that the list would include flooding, storm water quality, aesthetics, ecological impacts, increasing Federal and State regulatory pressures and inconsistent funding. This is the litany of stormwater challenges that each community has faced or is currently trying to cope with in order to satisfy citizen expectations.
Obviously, this matter requires serious attention and regard. In 2003 the EPA implemented Phase II of the NPDES for Large and Small Construction Projects disturbing 1 or more acres. This mandates that all construction projects must contain a comprehensive Stormwater Pollution Prevention Plan depending on your State.
Will your company's Stormwater plans (SWPPPs) meet the EPA requirements? How will your documentation compare to government expectations? Are internal measures adequate or even effective? How much time is necessary for you to coordinate the necessary BMPs? Is there a level of comfort with compliance? Is it worth the cost should any gaps be in existence? As a result of the Federally mandated NPDES Stormwater Program and it’s aggressive outreach and enforcement efforts, EPA has the authority to enforce violations up to $32,500 per violation per day.
In addition, this may include municipal systems along with construction sites and industrial facilities that have not obtained permit coverage. Departments may enforce against those found to be operating without proper permit coverage or that are out of compliance, often imposing significant penalties. One enforcement case with a city was estimated at a value of $1,000,000. A construction project in the Jacksonville area recently was assessed more than $20,000 for operating without permit coverage and being significantly out of compliance.
The NPDES Stormwater program continues to sweep throughout the country and construction sites without NPDES Storm Water permit coverage are common targets. Subsequent enforcement will ensue for those sites found to be out of compliance.
Over the last three years, National Pollutant Discharge Elimination System (NPDES) Stormwater program has brought thousands of Stormwater systems under permit coverage and increased system compliance thanks to aggressive public outreach and enforcement. Surface water quality and citizens are the beneficiaries. However, there is still much room to improve. During a set period of time in 2005 in one U.S. region, over 350 construction inspections, over 300 industrial inspections and over 100 Municipal Separate Storm Sewer System inspections were performed. The result was over 320 minor enforcement actions and 125 significant enforcement actions.
National Pollutant Discharge Elimination System
Polluted stormwater runoff is a leading cause of impairment to the nearly 40 percent of surveyed U.S. water bodies which do not meet water quality standards. Over land or via storm sewer systems, polluted runoff is discharged, often untreated, directly into local water bodies. When left uncontrolled, this water pollution can result in the destruction of fish, wildlife, and aquatic life habitats; a loss in aesthetic value; and threats to public health due to contaminated food, drinking water supplies, and recreational waterways.
Mandated by Congress under the Clean Water Act, the NPDES Storm Water Program is a comprehensive two-phased national program for addressing the non-agricultural sources of storm water discharges which adversely affect the quality of our nation's waters. The Program uses the National Pollutant Discharge Elimination System (NPDES) permitting mechanism to require the implementation of controls designed to prevent harmful pollutants from being washed by storm water runoff into local water bodies.
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Phase I
In response to the 1987 Amendments to the Clean Water Act (CWA), the U.S. Environmental Protection Agency (EPA) developed Phase I of the NPDES Storm Water Program in 1990. The Phase I program addressed sources of stormwater runoff that had the greatest potential to negatively impact water quality.
Phase II
The Phase II Final Rule, published in the Federal Register on December 8, 1999, requires NPDES permit coverage for stormwater discharges from: Certain regulated small municipal separate storm sewer systems (MS4s); and Construction activity disturbing between 1 and 5 acres of land.
Note: The builder must file for a permit and is required to complete a SWPPP and complete weekly inspections with related BMPs necessary for compliance.
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Several entities are involved with compliance and enforcement. They include the EPA, State Regulators and Water Management Districts.
Failure to comply may bring about warnings, reminders and penalties. In fact, the EPA may apply penalties up to $32,500 per violation per day with potential for retroactive application.
Most penalties will not be that significant, however, that does not diminish the reality of non-compliance. Increasingly, companies are working through non-compliance issues that not only include the encumbrance of penalties but the cost of time and effort of internal and third parties.
Non-compliance may come in several forms. (i.e. failure to apply for permit, failure to comply with permit instructions, failure to conduct weekly inspections with reports, lack of Best Management Practices ( BMPs), and improper use of BMPs, etc.)
It is not uncommon for Alpha EMC to speak to parties whom "feel no risk" or may be indifferent only to receive a call weeks later hearing of a non-compliance issue.
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A few preventative and proactive steps go a long way in protecting our water and our clients.
A NOI is a Notice of Intent and is basically the permit application required for NPDES.
Generally, a NOI will suffice for the life of the project if for example, a builder both develops land and also constructs homes. It may be advisable for a builder/developer to create separate NOIs or Co-Permittee Agreements if, for example, they are only developing property or only constructing homes. Recall that the NOI usually requires that a SWPPP be created, a permit be filed and compliance with the permit be enacted (this includes inspections and use of BMPs). Alpha EMC prepares packets for our clients for NOIs and NOTs to assist in filing.
The NOT is the Notice of Termination signifying that the construction activity is completed. It illustrates the permittee has achieved final stabilization on all portions of responsible work. A NOT is also advisable when a new operator has assumed control on all areas of the site. An example, as mentioned earlier, would include the development of property that is sold to another group that will perform home construction only. The new operator would then apply for their own NOI.
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As indicated previously, Phase II ushered in requirements whenever one or more acre(s) is disturbed.
The permittee is the responsible party. Therefore, Alpha EMC's counsel is to create an objective program rather than simply passing responsibility to a party to "oversee themselves."
In the development phase, for example, some companies have chosen to place the responsibility for the NOI and inspections on a site contractor. The obvious issue here is "Why?" As the responsible party, it is advisable for the developer to utilize a professional service that works on behalf of the developer with an objective view of erosion control issues.
During the home construction phase, the issues are just as viable. Homeowners are now involved (they have the right to complain to the EPA) and the concern over improper infiltration of the MS4 is heightened.
Therefore, it is highly advisable to place this focus equally on development and home construction where applicable.
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A SWPPP is a Storm Water Pollution Prevention Plan. In most States, it must be developed prior to any ground breaking activity, and is required for both development and residential construction stages. SWPPPs are often required for permitting and the NOI (notice of intent). Many organizations have applied for permits without a SWPPP under the notion that the few paragraphs under the "Erosion Plan" on the construction plans will suffice. When signing the NOI, one is acknowledging creation of a SWPPP in States that require one. SWPPPs contains information on, among other items, vegetation, hazardous materials, endangered species, BMPs, historical data, intended sequence of events, spill prevention program and wetlands. The SWPPP shall be amended whenever there is change in design, construction, operation or maintenance which has a significant effect on the potential for discharge of pollutants to surface waters of the state or a MS4 (Municipal Separate Storm Sewer System).
The SWPPPs are kept on the job site to be referenced and amended as needed by the storm water professional inspector associated with weekly inspections, classification changes and rain events.
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Depending on your state, inspections are usually required once every seven days and within twenty four hours of a rainfall greater than 0.5 inches in a twenty four hour period (blue sky to blue sky).
The inspection requires several points to be monitored, recorded and logged as well as attached to the SWPPP (where required).
In most states, the inspections should be performed by a certified NPDES inspector that is trained and capable of supporting all of the reporting requirements set forth.
A common error in inspections is leaving the work to non-certified or non-specialized entities that are not completely fulfilling all aspect of the inspections. This includes frequency, process, reporting and necessary follow-up.
Alpha EMC, for example, covers every parameter as set forth by State regulators during each inspection while also recording updates from the previous inspection and creating two databases to create a log of activity, corrective action and a record of compliance efforts along with a start/stop log for each individual lot.
With well over several dozen items that must be evaluated, inspections are a critical component to the builder, which places a greater need for the appropriate personnel to support such measures.
A Recent EPA Study illustrated that using over 60,000 construction starts subject to stormwater control regulations, roughly two thirds lacked the necessary permits.
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BMPs are Best Management Practices. They include schedule of activities, prohibition of practices, maintenance procedures and other management practices to prevent or reduce the discharge of pollutants to US waters. BMPs also include treatment requirements, operating procedures and practice to control plant site runoff, spillage, or leaks, sludge or waste disposal, or drainage from raw material storage.
BMPs are required to be identified in the SWPPP when your state requires a SWPPP. Examples include: Silt Fencing, Vegetative Strips, Hydro-seeding, Mulching, etc.
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The days of indifference and lack of enforcement have come to an end. Most companies realize this when they find themselves in non-compliance. Others have "heard the news" and are actively working to create programs.
When considering the scope of the situation, we believe there is an opportunity to maximize effectiveness with minimal strain. The facets of the process include NOIs, SWPPPs, inspections, NOTs, BMPs, compliance, agency interaction, education, program audits, consultation and proper reporting just to name a few.
This is where Alpha EMC brings value to our clients. As a single point of contact for the aforementioned issues, we become your partner in Erosion Control and Stormwater Management.
So, where do we go from here? Put a plan in place.
We are extensively trained in this endeavor and are pleased to create this plan with you. Of course, this is much more than a few simple steps. We strongly believe that a "program" best describes the approach to this arena as we are positioned to keep you abreast of new NPDES regulations, changing processes and new methods of efficiency.
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