Overview of RIPDES Construction Overview of RIPDES Construction General PermitGeneral Permit RequirementsRequirements

Developed by:Developed by:Greg Goblick, Laura StephensonGreg Goblick, Laura Stephenson

RI Department of Environmental ManagementRI Department of Environmental ManagementRIPDES Permitting ProgramRIPDES Permitting Program

•• Review and introduction of Phase I and Review and introduction of Phase I and

Phase II requirementsPhase II requirements

•• When is a permit required?When is a permit required?

•• Who is responsible to implement the Who is responsible to implement the permit?permit?

•• Who is responsible for compliance?Who is responsible for compliance?

Introduction: RIPDES Introduction: RIPDES Construction Storm Construction Storm Water ProgramWater Program

Goals of the Construction Goals of the Construction Storm Water ProgramStorm Water Program

Minimize erosion during Minimize erosion during constructionconstruction

Reduce/eliminate Reduce/eliminate pollutants in storm water pollutants in storm water to protect water qualityto protect water quality

Consider post-Consider post-construction storm water construction storm water managementmanagement

Large Construction Large Construction (Phase I) Permitting(Phase I) Permitting

Construction General Permit (CGP)Construction General Permit (CGP)

– RIPDES issued in 1993RIPDES issued in 1993– Re-issued March 1998Re-issued March 1998– Re-issued September 9, 2003 (Phase II Re-issued September 9, 2003 (Phase II

requirements incorporated in new CGP)requirements incorporated in new CGP)

Authorization under the old CGPAuthorization under the old CGP – Allowed automatic authorization for projects Allowed automatic authorization for projects

approved by CRMC, DEM Freshwater Wetlands, approved by CRMC, DEM Freshwater Wetlands, DEM WQC (only an NOI needed to be submitted to DEM WQC (only an NOI needed to be submitted to RIPDES)RIPDES)

Small Construction Small Construction Permitting (Phase II)Permitting (Phase II)

Municipalities required to developed local Municipalities required to developed local programs (refer to Small MS4 General Permit)programs (refer to Small MS4 General Permit)

Covers construction activity one or more acres Covers construction activity one or more acres RIDEM permits required StatewideRIDEM permits required Statewide No waiversNo waivers RIDEM organized 3 focus group meetings RIDEM organized 3 focus group meetings

(consultants, municipalities, environmental (consultants, municipalities, environmental organizations, stateorganizations, state and federal agencies to and federal agencies to discuss draft CGP permitdiscuss draft CGP permit))

SWPPP RequirementsSWPPP Requirements

11. Stamped/signed by one of the following:. Stamped/signed by one of the following: Registered Professional Engineer (P.E.)Registered Professional Engineer (P.E.) Certified Professional in Soil Erosion Control Certified Professional in Soil Erosion Control

(CPESC) (CPESC) Certified Professional in Storm Water Quality Certified Professional in Storm Water Quality

(CPSWQ)(CPSWQ)

Registered Landscape ArchitectRegistered Landscape Architect

Note: SWPPPs that require engineering Note: SWPPPs that require engineering must be stamped/signed by P.E. must be stamped/signed by P.E.

SWPPP Requirements SWPPP Requirements cont.cont.

2. Identify potential sources of pollutants which may reasonably be expected to affect the quality of storm water discharges associated with the construction activity.

SWPPP Requirements SWPPP Requirements cont.cont.

3. Describe and ensure 3. Describe and ensure the implementation of the implementation of Best Management Best Management Practices (BMPs) used to Practices (BMPs) used to reduce or eliminate reduce or eliminate pollutants in storm water pollutants in storm water discharge(s) and assure discharge(s) and assure compliance with the compliance with the permit.permit.

44. BMP selection shall include an evaluation of the effectiveness of available practices and be made with proper references.

SWPPP Requirements SWPPP Requirements cont.cont.

•• Permit includes conditions that Permit includes conditions that incorporate department approved QLPs incorporate department approved QLPs

•• Compliance with QLP = compliance Compliance with QLP = compliance with RIPDESwith RIPDES

•• QLPs issue permits for sites 1-5 acres and QLPs issue permits for sites 1-5 acres and greater than 5 if QLP chooses to do so greater than 5 if QLP chooses to do so

Permit Changes: Permit Changes: Qualifying Qualifying Local Programs (QLPs)Local Programs (QLPs)

Permit Changes: Permit Changes: Reasons for QLPsReasons for QLPs

Requirements tailored to localityRequirements tailored to locality Local oversight more effective than just Local oversight more effective than just

State oversightState oversight Protect local infrastructure and prevent Protect local infrastructure and prevent

introduction of pollutants into the local introduction of pollutants into the local storm sewers and drainage system (MS4)storm sewers and drainage system (MS4)

Streamline duplicative permitting Streamline duplicative permitting requirements requirements

Reduce permit feesReduce permit fees

Permit Changes: Permit Changes: Phase II RequirementsPhase II Requirements

Requires permit coverage for:Requires permit coverage for:– Construction activity disturbing Construction activity disturbing >> 1 acre 1 acre

and < 5 acres and < 5 acres – Construction activity below 1 acre that is Construction activity below 1 acre that is

part of a larger common plan of part of a larger common plan of development or saledevelopment or sale

Potential permit coverage for:Potential permit coverage for:– Construction activity that disturbs Construction activity that disturbs less less

than 1 acrethan 1 acre of land may be designated of land may be designated based on water quality impactbased on water quality impact

Permit Changes: Permit Changes: StreamliningStreamlining Incorporate RIPDES NOI requirements in Incorporate RIPDES NOI requirements in

wetlands application processwetlands application process Wetlands application serves as RIPDES NOI Wetlands application serves as RIPDES NOI

for all sites greater than 1 acrefor all sites greater than 1 acre NOI does not have to be submitted for sites NOI does not have to be submitted for sites

with a Qualifying State or Local Program with a Qualifying State or Local Program permit or approval*permit or approval*

Less paper, less time, less money!Less paper, less time, less money!* Federal/State agencies do not have to apply for QLP approval if * Federal/State agencies do not have to apply for QLP approval if

a RIPDES Permit is obtaineda RIPDES Permit is obtained

Professional (a P.E., CPESC, CPSWQ, or Professional (a P.E., CPESC, CPSWQ, or Registered Landscape Architect) must Registered Landscape Architect) must certify information in Part V of NOI: certify information in Part V of NOI: – Is the site within or directly discharging to a Is the site within or directly discharging to a

Natural Heritage Area? (Yes or No)Natural Heritage Area? (Yes or No)

– If the site is within or directly discharging to If the site is within or directly discharging to a NHA, do you have previous approval from a NHA, do you have previous approval from the DEM Natural Heritage Program (NHP)? If the DEM Natural Heritage Program (NHP)? If yes, include a copy of the approval letteryes, include a copy of the approval letter

Permit Changes: Permit Changes: NOI Form Part IX:NOI Form Part IX:Natural Heritage AreasNatural Heritage Areas

Submit MapSubmit Map Location of construction Location of construction

– Street addressStreet address– Nearest utility pole Nearest utility pole

numbernumber– Assessors plot and lotAssessors plot and lot

Total area of siteTotal area of site– Limits of disturbanceLimits of disturbance

Permit Changes: Permit Changes: Part IX NHA’s ContinuedPart IX NHA’s ContinuedProjects that propose a storm water or Projects that propose a storm water or allowable non-storm water discharge to or allowable non-storm water discharge to or has discharge related activities that may has discharge related activities that may potentially affect a NHA:potentially affect a NHA:

Permit Changes: Permit Changes: NOI Form Part X: NOI Form Part X: SWPPP DevelopmentSWPPP Development Needs to be filled out for activities that are not required to submit Needs to be filled out for activities that are not required to submit

a SWPPP (see authorization)a SWPPP (see authorization)

Ensure that a site specific SWPPP was prepared consistent with Ensure that a site specific SWPPP was prepared consistent with requirementsrequirements

Does not alleviate or limit liability and sole responsibility of the Does not alleviate or limit liability and sole responsibility of the owner/operator to implement & amend SWPPPowner/operator to implement & amend SWPPP

Do I require any of Do I require any of the following?the following?• CRMC permit• QLP approval• WQ Certification• Wetlands permit

Is my site Is my site 1 1 << x < 5 x < 5

acres?acres?

Submit Submit NOI and NOI and approvalapproval

Automatically Automatically AuthorizedAuthorized

AuthorizatioAuthorizationnIf CRMC or If CRMC or

QLP QLP Approval, Approval, and WQ and WQ

CertCert(if appl.)(if appl.)

Is my site Is my site >> 5 acres? 5 acres?

If If Freshwater Freshwater Wetlands Wetlands

PermitPermit

YESYES

THENTHEN

YESYES

NONO

YESYESTHENTHEN

YESYES

THENTHEN

Do I require any of Do I require any of the following?the following?• CRMC permit• QLP approval• WQ Certification• Wetlands permit

Is my site Is my site 1 1 << x < 5 x < 5

acres?acres?

Submit Submit SWPPP SWPPP and NOIand NOI

Authorization Authorization upon upon

notificationnotification

AuthorizatioAuthorizationn

Is my site Is my site >> 5 acres? 5 acres?

Discharging Discharging directly to a directly to a NHA?NHA?

YESYES

THENTHEN

NONO

YESYES

NONO

Submit NOISubmit NOI

Automatically authorizedAutomatically authorized

Submit Submit NOINOI

Automatic Automatic authorizatioauthorization w/i 30 n w/i 30 daysdays

YESYES NONO

NONO

Prior approval Prior approval from NHP?from NHP?

Submit NOI & Submit NOI & approvalapproval

YESYES

THENTHEN

THENTHEN

Future ImprovementsFuture ImprovementsKick it up a notchKick it up a notch

•• Termination of project - P.E. certifies that Termination of project - P.E. certifies that any permanent structures constructed are any permanent structures constructed are according to SWPPP/design manualaccording to SWPPP/design manual

• • Revise goals to be consistent with updated Revise goals to be consistent with updated Storm Water Design ManualStorm Water Design Manual

Future Improvements Future Improvements cont.cont.

•• Consider additional measures for final Consider additional measures for final stabilization and long term storm water stabilization and long term storm water managementmanagement

• • Consider requiring various measures Consider requiring various measures such as sediment traps, basins or other such as sediment traps, basins or other controls based on area of disturbancecontrols based on area of disturbance

RIPDES RIPDES Contact InformationContact Information

Greg GoblickGreg GoblickSenior Environmental Senior Environmental EngineerEngineer

RIDEM RIPDES ProgramRIDEM RIPDES Program

tel:tel: (401) 222-4700 ext.7265 (401) 222-4700 ext.7265

email:email: ggoblick@dem.state.ri.usggoblick@dem.state.ri.us

Margarita Margarita ChattertonChattertonSenior Environmental EngineerSenior Environmental Engineer

RIDEM RIPDES ProgramRIDEM RIPDES Program

tel:tel: (401) 222-4700 ext.7605 (401) 222-4700 ext.7605

email:email: mchatter@dem.state.ri.us mchatter@dem.state.ri.us

Web: Web: http://www.state.ri.us/dem/programs/http://www.state.ri.us/dem/programs/

benviron/water/permits/ripdes/stwater/index.htmbenviron/water/permits/ripdes/stwater/index.htm