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Strategies for Construction Sites
By Carol Brzozowski
In his position as a project manager with Pulte Homes as well as managing all of the company’s stormwater quality programs for his division in the greater Sacramento, CA, area, Russell Foster has supervised construction-site compliance on everything from beginning land development through vertical construction.
Across the country since 2003, many smaller cities, counties, and developments are operating under the National Pollutant Discharge Elimination System (NPDES) Phase II, which affects construction sites from one to five acres.
As such, they are charged with the task of controlling runoff during construction and afterward. Key to that task is having a stormwater pollution prevention plan (SWPPP) that details, among other things, the type of erosion and sediment controls planned for a site.
While some construction companies hire an erosion and sediment control provider to provide materials and install them, Foster buys erosion control materials from Horizon, an Arizona distributor, and hires labor to install it, conducting inspections himself. In executing his work, Foster notes a big difference in erosion control measures taken during each construction phase.
“In vertical construction, typically a project would have finished streets and active storm drain systems,” he says. “The last line of defense becomes the back of the curb or sidewalk. At that point, the obvious goal is to keep any dirt or sediment out of the streets.
“Once it gets into the gutter, I call that the ‘super highway’ because the storm drain system is basically the discharge point. In vertical construction, the site perimeter changes—it moves into the middle of the site at the storm drains—whereas in land development, the perimeter of your site typically is exactly that: out on the edges of the site.”
At that point, the goal is to keep dirt, erosion, and sediment from getting into the roads, gutters, and storm drains, says Foster.
He takes several steps during the vertical construction phase on most projects in an effort to prevent erosion. During the first phase, the lot soil is stabilized with straw mulch or a type of bonded fiber matrix and handed over to the vertical construction department.
“Once the vertical construction starts, the first step is always digging the footings or foundation and pouring the foundation of the home. Obviously, at that point, they’re disturbing and tearing up everything we’ve done,” says Foster.
The most effective best management practice (BMP) at that point is good scheduling, he points out.
“You don’t want to be digging when you know you’ve got potential rain. Here in northern California, we have a very specific rainy season and non-rainy season, and it’s usually not an issue during the non-rainy season,” he says.
Construction crews keep an eye on the forecast during the rainy season, however.
“We’re looking for weather—for when we know we’re going to have seven full days of dry weather—before we start digging in the soil and making a mess, so we have an opportunity to dig, pour, and re-stabilize the soil around the work we’ve done.”
Once the work is done, Foster typically applies an erosion control blanket such as a Curlex blanket or a geotextile fabric like Mirafi 140N to cover up the spoil piles and dirt disturbed around the house’s newly poured foundation.
“They are easy to roll up and go to work and then put back down until we get to the point where the utility connections have been made from the street to the house,” he says. “Once the slabs are poured, you’re going to make the gas and electrical connections. As we’re tearing the ground up to make those connections, we’re looking for weather windows again, making sure we are using scheduling as a BMP, and [finding] those five to seven days of clear weather we need.”
Next comes grading, because all of the digging generates a great deal of dirt in the area. The lot gets a rough grade and, once completed, a nonwoven geotextile erosion-control fabric is stapled or pinned to the ground.
“We cover the entire front of the lot with the fabric,” says Foster. “The fabric’s very nice, because now we’re able to walk on the lots without tracking dirt out onto the streets.”
He notes that tracking has become a key issue of concern in California. “You get a lot of people walking around on the lot, and they bring a lot of mud out on their boots into the street,” he points out. “Inspectors have become very keen on foot tracking, so by covering the entire front of the lot with fabric, we’ve created a stabilized area where we can walk on and off the lot without getting our boots muddy and tracking out the mud from the lot.”
Once the fabric is anchored in place, it is kept there throughout the remainder of the house construction until it is pulled up to accommodate the landscaping efforts.
At that point, maintenance is the focus. “We routinely come through on a minimum of a weekly basis and before and after storm events as well to check the BMPs we’ve put in place and maintain them, because they do get torn or ripped,” says Foster. “It’s a construction site and there’s a lot of activity, so it’s not perfect, but we do a good job of maintaining the products we put down.”
Erosion Versus Sediment Control
Sediment control calls for another approach, Foster says.
“That’s our secondary line of defense,” he says. “Erosion is where we try to focus, but we’ve put in sediment controls at the back of the curb or walk in front of every lot.”
Those controls usually include Earth Saver’s straw wattles installed at the same time as the mulch during the land development phase. The lots are turned over to vertical construction with the wattles already in place and stabilized.
Beyond sediment controls at the back of the walk or curb, Foster’s crew also uses energy dissipaters—mainly rock bags—in the gutters to slow down water-flow and allow sediment to drop out so it can be returned to an appropriate place onsite.
Filter bags are placed in the storm drain inlets as a last line of defense for sediment control.
Augmenting the approach is regular street-cleaning maintenance, conducted a minimum of once a week with a sweeper truck. The trade subcontractors are required to clean up after the end of each day.
Once sediment controls are installed, maintenance again becomes the focus, Foster says. “Oftentimes, we end up having to replace the wattles entirely at least probably two times during the construction phase,” he says, and that becomes a matter of training.
“We do a lot of training with the trades to let them know why those wattles, fabric, and blankets are there, what their responsibilities are, and how they’re supposed to treat and act around those BMPs that are deployed onsite,” says Foster.
“That’s really where we get the most bang for our buck with our BMPs,” he adds. “If the stucco guys, the framers, the plumbers, and everybody else knows what they are there for and that they’re important, they are more likely to treat that work as such.”
Foster says he tries to convey to other trades that everybody’s work deserves the same amount of respect—and that includes the erosion and sediment control work. He believes his efforts have been successful; to ensure that success, it’s built into the language of the contract that subcontractors are to perform their work in an SWPPP-compliant manner.
“That means treating the BMPs appropriately, and if you have to move one to perform one of your work tasks in building, you are expected to put it back,” says Foster. “We do a pretty good job of holding them to that contractual responsibility to make sure they’re caring for the BMPs we’ve put out.”
The proactive approach is effective in avoiding problems with permitting authorities, he says. “If you’re just reacting, you’re too late. The only way to do it is to take a very proactive approach. It’s like the ounce of medicine being worth a pound of cure—especially with erosion control, more so than sediment control.
“Whereas if you don’t do that, trying to catch up and clean up later is a nightmare. The ratio flips on you: it takes a pound of prevention to get that ounce of cure if you wait and react rather than be proactive, in my experience.”
Operating out of northern California is another influencing factor in being proactive on construction site compliance, Foster says.
“I think we are hyper-advanced in this compared to a majority of the country. We’ve been around the country doing training for Pulte, and we see what’s going on in other regions. We’re on the cutting edge of a lot of this. That has to do with the regulations we face in northern California.”
Unlike other parts of the country, inspectors visit California construction sites weekly, if not more often, Foster points out.
“Most of the cities have inspectors specifically dedicated to stormwater inspections; they aren’t framing inspectors who do stormwater on the side,” he says. “Also, people from our regional boards regularly visit the sites. In California, there are nine regional boards under the state board, and they are responsible for enforcement of our state stormwater construction permits that we all get coverage under for our sites.”
Foster says that the state and regional boards have pushed MS4s “quite hard” to enforce jurisdictional water quality.
“They usually leave an inspection report, and if they see something they don’t like, they’ll leave you a correction notice,” Foster says.
BMPs: Who Chooses?
David Marin, who handles SWPPP enforcement for Oltman’s Construction Company in Whittier, CA, says sometimes his company is instructed to use one type of erosion control only to find it ineffective.
“We have a job site where, compliance-wise, we were told to use sandbags all around our site,” he says. “Unfortunately, it’s the type of job site where employees had to park on the street, and there was high traffic in and out of the site.
“So besides the employees stepping on the bags and popping them open, we also had cars hitting the bags. Once these bags are open, they pretty much cause the problem we are trying to solve.”
The job site entailed a commercial tilt-up building. “Construction takes up a lot of space on the streets sometimes,” says Marin. “For erosion control, it’s big. For the most part, our sites take in water.”
In this case, Marin spoke with an inspector and requested permission to use what he believed would be a more appropriate solution. Marin was given the green light, as long as the approach worked as well as or better than the first, he was told.
Marin opted for a solution to reduce construction sedimentation and control stormwater runoff: ERTEC’s Curb Inlet Guard. The HDPE product is a 2-inch-high integrated filter that allows water to bypass during high-flow events; the brackets prevent collapse into the storm drain; modules can be overlapped to various size openings; and the Curb Inlet Guard is reusable.
“The reason I like it is that it doesn’t protrude into the street like sand bags, where people are running them over all the time,” says Marin. “I started using those and, sure enough, every city started liking them, and I’ve seen other people using it.”
Marin’s experience with inspections is different from Foster’s and is more aligned with what others are seeing throughout the country.
“In most cities I’ve seen—except for San Bernardino, which has its own SWPPP department—the guys really only inspect after a rain,” says Marin. “That’s why my job was created—to keep an eye out. I try to go to job sites twice a week. I’ve kept a lot of guys busy, because with compliance, after every rain event you’ve got to clean everything up and start all over again.”
Marin says there are three major issues of concern to him on every job site: dewatering, tracking, and inlet protection.
“The dewatering issue we have now is that some cities don’t want drinking water going through,” Marin says. “It’s tough. If you look at the SWPPP, it says [the BMP] has to be cost-effective. The machines are $75,000 and up, and we have 30 job sites; we couldn’t afford something like that for every job site.
“For me, it means talking to the inspector from every city, asking what is allowable for us to take the water out. Some will tell us to put in a Mirafi [geotextile fabric] or a certain type of dewatering bag.
“Some dewatering bags will do a good job, but they don’t take any oils, and on a lot of our job sites, we have a lot of construction equipment,” Marin points out. “We use bags from UltraTech International that will catch oil. I’ll hold a data sheet for them, and if inspectors ask me about them, I can tell them that the bag catches silt and oil, and they’ll be OK with that.”
Some inspectors in Orange County, CA, have had Marin build small detention or desilting basins.
“I’ll buy 50 rolls of straw bales and visqueen and do three sections. It’s a little cumbersome, but it does the job,” he says.
One reason why Marin’s position was created was to spend more time talking with inspectors rather than merely following the SWPPP plan. Because his company operates in so many locales, he has to keep track of the various regulations.
“Everyone says, ‘Let’s do what the plan says.’ We’ll lay out bags, and usually that’s not the best thing to do,” says Marin. “I found out that most sandbags have a UV [ultraviolet] rating of about 1,500 to 1,600 hours, which is a month or two. Our job sites last seven months, so we find ourselves not only buying bags and fill, but replacing them, and it’s not cheap—not when you have to do it five times in a row.
“There are less expensive ways to do it, like using a silt fence and straw wattles. Every engineer will put on their plan to use sandbags, and that just doesn’t work it on half of my jobs.”
Marin deals with his concerns about tracking by utilizing Contractor Services’ Rumble Track, which is placed on job site exit roads that meet up with public streets. Job site dirt, mud, and debris stay on the site as it is removed from vehicle tires. The track’s use helps reduce the need for water trucks and street sweeping.
“We use the Rumble Track and street sweeping,” says Marin. “My main focus every time we have a safety meeting is on keeping the streets clean. If you have a dirty street, inspectors are going to say, ‘if it’s dirty out here, it’s dirty inside.’ We can’t just do it good, we’ve got to look good, too.”
Sometimes that’s nearly impossible, Marin concedes. “The SWPPP rules say when you do have that situation [of dirt tracked from a site], you should have a guy or two out there sweeping. The guys say, ‘what am I supposed to do? There’s mud all the time.’ Well, I get them the Type III fluorescent vest, teach them what to do, and they’re out there. If I have to shut down a lane, I will. I’ve thrown all the lights on my truck and shut down the lane to keep the guys safe, and they’ll clean. You’ve got to do it.”
As for inlet protection, Marin relies on ERTEC’s Curb Inlet Guard to do the job. Of sandbags, he notes, “They’re almost a foot long and you’ve go to go two high, so you’ve got something that’s sticking out into the street about a foot. On most job sites, there’s regular traffic and the bags are getting hit.
“Water hits these dirt bags and there’s mud coming out of them. So we use gravel bags, but people also hit them, and all of a sudden you’ve got gravel going straight into an inlet. My way of solving it was buying those Curb Inlet Guards. In fact, I can’t keep them in stock. They’re not cheap, but they’re cheaper than any other product I’ve seen out there.”
They’re also easy to maintain, Marin says, adding that their use saves on labor costs. “You just pull it out, tap it, and put it right back on,” he says. “Maintenance is about two minutes, if that. When we are using sandbags, I’ve got to send a truck out there with two guys, and all for what? Thirty, forty bags? It’s not worth it.”
With the economy being as it is these days in the construction industry, cost savings are sought at every turn, Marin says.
“We have to do it right the first time,” he says. “It might cost us a little more up front, but in the long run we’ll save. I’m getting an inspector’s license and getting more education on that. Everything changes all the time, and it’s going to change again drastically.”
Marin uses other approaches to ensure construction site compliance, such as dust control, asking employees to not walk on the bags, and requesting them to park their cars outside the site if possible.
“If they do have to bring their car in and it leaks oil, they have to diaper it, because we don’t want oil on our job sites,” he says. “That goes for our subcontractors, too. The forklifts and other equipment leak oil, and it’s one of those things we don’t want going on here. I hound them for that, and if I have to, I give them a citation. It’s a little fix-it ticket. Everyone hates seeing the safety officers, but someone’s got to do it.”
A case in point: on one job site, the roofers were pumping tar onto the roof and didn’t have their machines diapered. “I told them to turn them off and not to turn them back on until it was done, because that’s 100% of what we don’t want right on the ground,” Marin says.
Marin does see some improvement in the industry. “We like to think we are getting a lot better faster than most people. They hired me to make sure this happens,” says Marin. “I’m 100% SWPPP [enforcement]; I don’t do anything but that. It’s a 365-day-a-year job. It’s a little tough during the summertime—there are silt issues and tracking.”
A Nightmare on the Green
Tim Freeland has what he considers a dream job as a golf course architect. In February 2007, he was asked to team with LPGA star Jan Stephenson on the construction of the Long Leaf Pines Golf Club in Baldwin County, AL.
By November, however, construction was curtailed.
“Construction did not follow the proper schedule; they got too far ahead with disruption of the soil and did not follow along quickly enough with stabilization of the earth,” notes Freeland.
Consequently, more than 170 acres of exposed land created severe erosion problems. The project received a notice of violation from the Alabama Department of Environmental Management (ADEM), citing excessive erosion and unstable soil.
“It was finding its way to the perimeter of the wetlands adjacent to almost every hole [on the golf course],” adds Freeland.
New contractors were hired with a focus on stabilizing the entire area before site work could be resumed, pending ADEM’s approval of the remediation plan for the clean out of the wetland perimeters. Site stabilization was included in the plan.
Belted Silt Retention Fence (BSRF) from Silt-Saver was installed around the wetland perimeters as well as on steep slopes and around fairway drains.
“Before [this project], I thought that all silt fence fabric was the same, either with wood or steel posts,” says Freeland. “I soon learned this product far outperformed the standard silt fence and, in fact, this fabric on oak posts performed as well as traditional fabric with wire mesh reinforcement and steel posts. The BSRF is far easier to install and repair.”
Freeland says that the project entailed trenching a line, installing posts on 4-foot centers, and making a “sandwich” of the material with a wooden slat and a carbon-dioxide-powered heavy-duty staple gun.
The job can be handled by a crew of five, Freeland says, including a trencher operator, an operator for the utility cart or tractor with a trailer for materials, a laborer unrolling 300-foot fence rolls, a laborer pulling the fabric and holding the slat for the sandwich, and a staple gun operator.
“All that is left to do is backfill, compact, and go to the next area,” he says. “This fence is also much easier to maintain and to remove than a steel-reinforced fence. Our crew can install up to 4,000 feet per day. The BSRF silt fence is better, cheaper, faster to install, and easier to maintain than any other silt fence product on the market today. The good news is the overall cost versus steel is significantly less.”
In addition to installing the fences, Geographic Solutions Inc. of Bay Minette, AL—the project’s environmental consultant and engineer—added measures to improve site BMPs.
“Our detention basins were draining too quickly. Once those were cleaned out, we used the silt fencing as a baffle to redirect water in the basin to allow more fine particles to settle out of the stormwater,” Freeland says.
The course was designed to reduce and slow down sheet flow runoff, since the site is surrounded by “fingers of wetland” coming from the protected tributaries of a nearby creek.
“There’s a misconception that golf courses are bad for the environment,” Freeland says. “Turf grass is a proven stormwater filter. With proper design, the use of state-the-art construction materials such as BSRF silt fence and an environmentally sensitive management program, a golf course community can become a model for environmental sensitivity and erosion control.”
Pointing out that the root of the problem was failure to disturb the land in stages and stabilizing in each stage, Freeland says he’s never seen a construction site go from a “poor example of erosion control to a great example of erosion control so quickly.”
The project completion date is set for September 2008.
Varied Inspections
As the workplace compliance manager with KB Homes, Dale Hoffman acts as an inspector or auditor who monitors SWPPP plans to ascertain what BMPs have been designed for a particular construction site. The most common mistakes he notes on job sites is typically poor or incorrect BMP installation and subcontractor damage.
Hoffman is one of two inspectors for KB Homes who performs workplace compliance inspections. They visit each division twice a year. How often the local permitting authorities visit job sites varies, Hoffman notes.
“I can go to Dallas, TX, and there, some of our job sites are inspected weekly by the MS4 regulator in that area. We might go to another area and [the permitting authority] never shows up. There’s no consistency to it across the country.”
Hoffman believes better training is in order. “I see poor installation, but then that’s what the inspections are for,” he says. “Most builders rely on their inspection company to tell them what’s wrong, but some inspectors aren’t trained enough to realize a silt fence or an inlet protection device is installed improperly.”
Hoffman believes current stormwater programs are ineffective. “There’s not much accountability or responsibility,” he says. “The [MS4 inspectors] don’t come out and look at your stormwater program, or the state doesn’t show up, and the chances of the EPA showing up are slim.
“The reality of it is that some municipalities come out weekly, look at the BMPs on your job site, and say, ‘you guys are doing a pretty good job; there’s not much dirt in the streets; just keep doing what you’re doing.’ They never look at any of the paperwork, never look at the SWPPP, don’t know if the right BMPs are installed, and don’t know if inspections are being done routinely as they’re supposed to be.
“Then the EPA could show up, go back through two years’ worth of paperwork, and say you’ve got about $2 million worth of fines. And you’d been thinking that everything was fine for the past two years because the county had come out weekly to say everything you were doing was great. That’s the reality of what can happen in the stormwater program.”
Until there is accountability, the problem will persist, says Hoffman.
In some areas, residential house closings are tied into stormwater programs, he adds. However, it’s a different story elsewhere. “There are some areas, for example, where if you’ve got issues with your stormwater program that aren’t being addressed as they should be, [the county] won’t do any building inspections for you or they won’t give you the Certificate of Occupancies for the houses. Therefore, the house can’t close. Now it starts tying the two together and makes you a little bit more accountable for your stormwater program.”
A Case for Accountability
Accountability is built into building inspection, Hoffman points out.
“For example, if you’re building a house and it comes to the point where you’re getting ready to start hanging the sheetrock, then you have to go through a framing inspection. The inspectors come out to look at your electrical, plumbing, and framing, and if all of those don’t pass inspection, you can’t go any further.”
The same should hold true of stormwater programs, Hoffman contends.
“You’ve got a plan of how not to pollute, but it doesn’t make any difference if you are following it or not—the houses are still going to close and your project’s still going to move forward.
“Until there is more regulatory accountability and more inspections, I don’t think it will change. The EPA targets paperwork. You may not be a polluter, you may do a great job getting your BMPs installed, and they’re working well; you’ve got retention or detention ponds catching all of the pollutants on your job site; you’re really not polluting any of the waters of the state—but you didn’t document it properly. You really haven’t done anything wrong to the environment, yet you’ve got a $2 million fine because you didn’t note on a piece of paper the days you did certain things. It’s a poor system.”
For contractors and subcontractors to avoid that predicament, Hoffman says, it’s best to ensure paperwork is accurate.
“I try to get it across to our guys that this paperwork needs to be complete. If you’re going to depend on a third-party inspector to come out and inspect your site when those items are completed, you’ve got to make sure your paperwork is initialed and dated, because if the EPA ever shows up, that’s what they’re going to look at.
“If you’ve got some inlet protectors that are damaged or not installed correctly, it doesn’t mean that’s what it looked like six months ago.” He notes that the only way to give authorities a picture of what something may have looked like six months previously is to document inspections that were conducted in a particular week as well as what problems were found and what measures were taken to address them in a given timeframe.
“They wouldn’t have any reason to question that unless they go out and look at your job site and you’ve obviously got inlet protectors with mud, dirt, and weeds growing in them and, according to your inspection reports, you just fixed this three days ago. Now that’s when the EPA inspectors aren’t going to believe your paperwork,” he says.
Carol Brzozowski is a journalist living in Coral Springs, FL.
EC - Products and Services Directory 2009
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