Showing posts with label New California NPDES Permit. Show all posts
Showing posts with label New California NPDES Permit. Show all posts

Wednesday, August 3, 2011

QSP / QSD Training in California

We are now down to less than 30 days until you will be required to be a QSP to inspect your projects. Even with the partisan dysfunctional behavior of Washington and Sacramento everything appears to be on track.

July's QSP/QSD class went well with 28 people attending, a good group of people with a lot of field experience and great interaction. The next class (QSP Only) is scheduled for August 12th and 13th and as of today, is more than half filled. As a result, I have had to schedule a 2nd class (QSP/QSD) this month for August 25th, 26th and 27th. I will also be teaching a CISEC class August 30th and 31st in Gardena. Despite all the bickering of our representatives, business continues to be looking up, and appears to be moving along in fits and starts. Currently we have around 8 SWPPPs on the books for the month, and the month is just starting, as well as a new series of QSP inspection contracts. Several new QSP's will start working for CAL-Storm next month. As to the various clients out there, well it's a mixed bag of private, public, state and local, as well as a smattering of federal. If there is one comment to make, it is that we have now reached a state where the consultants are consulting the consultants, with all the inherent issues of self justification that this process requires, specifically SWPPP reviewers with various levels of competency making comments in order to justify their positions with the agencies. Personally I like the challenge, and view it as peer review that allows me to see other perspectives, even when they appear to be inconsistent, and at times pedantic. If there is one thing that professional life has shown me, that is that we all operate with our own personal bias, and that although it is at times challenging to understand an others perspective, there is always a new opportunity to learn and improve the final deliverable.

On another note, I am still coming across GC's that do not have a clue, can you spell BMP? It amazes me to see organizations that have either because of ignorance, or arrogance, chosen to be oblivious to the changes around us. Knowledge and understanding of the regulations, documentation, BMPs, implementation and inspection requirements are the keys to controlling the cost of compliance. It's not a difficult concept, if you understand how the pieces fit together, you can develop the processes to minimize the impact to your bottom line.

To get people to understand the motivation, and neccessity behind these standards I use the analogy of air pollution in Southern California. Imagine what the air quality would look like had we not taken steps to reformulate the gasoline, combined with new emission controls 40 years ago. Given the amount of growth in this area the air quality of Mexico City would look like paradise compared to LA. But as a direct result we seldom have smog alerts warning people to not venture out or schools closed because of air quality issues. The other example I use is OSHA and safety in general. Many of us long for the good old days, when we weren't constantly scrutinized by these agencies, forgetting as an example, the time when old Charlie the factory worker, lost his arm in the machine and had the gaul to survive, he got sent home with no pension, no disability or other recourse, except a half days pay and a hearty "have a good life", next...(and so it went on with no improvements to safe working conditions.

According to the EPA, 40% of the waters of the US are unswimmable, unfishable, or undrinkable. You may have heard about how the Soviets managed it with centralized planning and how they in there "socialist" ways destroyed the pristine wilderness that was Siberia...we in our free market democracy should be able to do better, I do expect more...(Gulf Oil Spill, Yellowstone Pipeline, Exon Valdez)

What's wrong with this picture?

Thursday, July 1, 2010

July 1st, 2010 The New NPDES Permit is here

The new NPDES Permit is here, but what does that mean for you. Over the past 30 days I have been heavily involved with updating existing SWPPP's to bring them in line with the new permit requirements, and then posting them on the SMARTS site with the State. The process is simple enough, the LRP...Legally Responsible Person (Owner) receives a notice from the State to create an account and certify an existing NOI. The LRP is provided with a SCN or Secret Code Number which is linked to the WDID number from the NOI. Once the LRP registers and validates the NOI they can then add data submitters like the GC and consultants such as me. The LRP must be provided the USER ID's of the data submitters to add them into the system. With this accomplished the data submitter has full visibility of all projects that are linked to that USER ID, and can now log into each and perform updates as needed such as uploading the SWPPP.

As to credentials, and people that are qualified to perform these tasks.

Under the new permit it clearly states that you must be a QSP, Qualified SWPPP Practitioner to perform BMP inspections and supervise the installation of BMP's. The QSP training and testing do not exist as yet, but are slated to come on line (be available) sometime in the next 60 days. The prequalifications for becoming a QSP are that you possess a CA-PE, (CA-Professional Engineer) CISEC (Certified Inspector of Sediment and Erosion Control) or CESSWI (Certified Erosion, Sediment and Storm Water Inspector). All these certifications require formal and informal training, as well as time in the field (industry). It is my understanding that inspections must be performed by individuals with the required prequalification’s until training and the QSP exam are fully available with some added time (Sept 2011).

Under the new permit you must be a QSD (Qualified SWPPP Developer) to write a SWPPP and make amendments to an existing plan. The QSD training and testing do not exist as yet, but are slated to come on line (be available) sometime in the next 60 days. The prequalification’s to be a QSD are: CA-PE, CPESC (Certified Professional in Erosion and Sediment Control) or CPSWQ (Certified Professional in Storm Water Quality). All these certifications require formal and informal training, as well as time in the field (industry). It is my understanding that all SWPPP's developed after July 1st must be developed by individuals with at least the prerequisite credentials until the QSD training and exams are generally available, and that this testing must be accomplished by a given date (as yet somewhat ambiguous to me).

Wednesday, March 17, 2010

New California NPDES Permit

I wanted to provide a quick overview of the New California NPDES Permit, and how it will impact estimators, project managers and field personnel. Initially there are 8 points to consider.
1st. Tier 1, 2, 3, Risk Assessment of the project site. 2nd. Turbidity & pH testing for all Tier 2 & 3 sites. 3rd. NEL's, Numeric Effluent Limits, have been established for the state. 4th. NAL's, Numeric Action Levels have been established for the state. 5th. REAP, Rain Event Action Plans, will be required for all Tier 2 & 3 sites. 6th. Receiving Water and Bioassessment evaluation and testing for some Tier 3 sites. 7th. State Standardized Exams for QSP, Qualified Stormwater Practitioner, and QSD, Qualified Stormwater Developer. 8th. Electronic submission of all PRD's. All in all a good collection of new standards, requiring a much deeper understanding of Storm Water related Documentation, BMP's, Inspection and run-off. People will need serious training to comply on each project site, and the state claims it will balance the budget with the fines levied against violators...just kidding, maybe?