The NPDES Phase I program requires permits for storm water discharges to surface waters or into a municipal separate storm system from construction activities that disturb five or more acres of land. The Phase II program requires permits for storm water discharges from construction activities that disturb one to five acres of land. Snow melt is regulated by the NPDES permit program and is classified as storm water runoff.

As a contractor, developer, builder, and/or engineer, your storm water permit responsibilities include the following:

• Submitting a Notice of Intent (NOI) at least 48 hours before construction commences;
• Developing and implementing a Storm Water Pollution Prevention Plan (SWPPP);
• Installing, inspecting, monitoring, and maintaining BMPs on your job site;
• Conducting and documenting the required inspections;
• Reporting any releases; and
• Submitting a Notice of Termination (NOT) once final stabilization has occurred.

If you have an existing job site and, due to weather, are just returning to work then, at a minimum, your storm water permit responsibilities include the following:

• Re-read your site specific SWPPP and maps;
• Walk the perimeter of the job site looking for evidence of storm water runoff, specifically rills and gullies that may have formed under the existing BMPs;
• Inspect all of the erosion control BMPs, such as: erosion control fabrics, straw wattles, and/or soil binders; • Inspect all of the sediment control BMPs, such as silt fences, temporary sediment traps, ingress and egress locations, and/or sediment retention basins;
• Inspect all of the drainage-way protection BMPs, such as stormdrain inlet and outlet protection, and/or catch basin inlet filters;
• Inspect all of the general site and material BMPs, such as concrete washout area, staging area, and/or the stockpile management;
• Inspect all of runoff control BMPs, such as check dams, temporary slope drains; and/or permanent diversions;
• Implement all of the BMP maintenance needs that were identified in the inspections and install any new BMPs that are needed; and
• Update your SWPPP and maps to reflect the projects changes.

Additional BMPs may need to be implemented due to the past, current, and future winter months. During these months, off tracking is a real concern for job sites. H&C recommends that all egress locations are inspected daily. In addition to daily inspections, maintain the sediment traps, replace the geotextiles and gravels/crushed rock, and/or install a tire wash station at the egress locations. Recognize the need for all of these BMPs and follow through with the results of your inspections.