NATIONAL POLLUTION D ISCHARGE ELIMINATION SYSTEM
(NPDES)
ISSUE:
The process of obtaining a National Pollution Discharge Elimination System
(NPDES) permit for Storm Water Management for Construction Activities.
BACKGROUND:
Often, problems arise with the NPDES permitting procedure that could cause
delays in the construction process. If a permit is not submitted to the state for
approval, it could delay the start of construction for up to 90 days, depending on
state requirements. Also, when changes are made to the original NPDES plan
during construction, those changes must be sent to the state and filed with the on-
site Storm Water Pollution Prevention Plan. If a state inspector arrives at the site
and all of NPDES information is not up-to-date, the job may be shut down.
DISCUSSION:
NPDES permitting requirements vary from state to state. CHECK THE
REQUIREMENTS OF THE STATE IN WHICH THE CONSTRUCTION WILL
OCCUR. Usually, the NPDES permit should be acquired prior to the start of
construction. Most state reviews could take up to 90 days to process the permit.
This is probably the timeframe in which you can expect the process to take. Once
the plan is approved, the contractor may want to make changes to the plan so it
conforms to his method of operation or phasing plans.
RECOMMENDATIONS/CONCLUSION:
The Site Development Professional Group recommends that the NPDES
permit be obtained during the final stages of contract documents. This is
usually accomplished by the design A/E. The VAMC Project Engineer or R/E
should make sure that the NPDES plan has been submitted and approved so that
a construction can begin on time. If the contractor wants to deviate from the
original documents, he should discuss the changes with the VAMC Project
Engineer or R/E and submit those changes to the state for their review. The
purpose is to keep the state informed of any action that differs from the original
documents. Otherwise, the state may shut down the construction activities. In
most cases, the contractor would not have await for approval of the changes
unless the state has a problem with it. The VAMC Project Engineer or R/E
7 November 1995
FM-087C-DA45
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