CHRIS BAUDHUIN, P.E., is the manager of the industrial/commercial/
institutional market group for C. R. Meyer and Sons Co. Baudhuin has 15 years of engineering and construction experience that is backed by a B.S. degree in civil and environmental engineering and an M.S. degree in civil and structural engineering.

CONSTRUCTION MANAGEMENT
Storm water discharge control planning

THE BASICS. Construction disrupting five or more acres of land requires a business owner to obtain a Pollutant Discharge Elimination System (PDES) permit. Originally, the Environmental Protection Agency (EPA) managed the PDES permitting process. Now, most states have implemented their own storm water discharge control programs that meet or exceed federal EPA requirements and may include construction disrupting fewer than five acres of land. Often, county and municipal requirements are even more stringent.

In all cases, a Notice of Intent (NOI) must be submitted to the governing agency-usually 30 days prior to construction. At the very least, an NOI outlines the following:

1. Owner/operator of the expanding business

2. Contractor information

3. Construction site information that includes the specific location, the type of construction, the storm water discharge location, an analysis of runoff for pollutants, and a blueprint showing that the construction site plan and permanent site design complies with the regional PDES.

STORM WATER RUNOFF PLANNING. Developed by a site designer-usually a civil engineer-the site plan includes a strategy for controlling runoff during construction and a permanent site plan for regulating runoff once construction is completed.

During construction, erosion is commonly controlled with hay bales and silt fencing made of woven filter fabric. Both are strategically placed throughout a construction site in areas of heavy drainage to slow water movement and allow for settling of sediment particles.

Post-construction runoff is controlled by a variety of methods. Retention ponds, which control the rate of runoff discharge, are becoming common requirements in many municipalities. Riprap, ground cover, strategic site grades, and other man-made control structures are usual tools for controlling erosion and siltation. States, counties, and even municipalities are becoming increasingly involved in permanent storm water runoff plans as a means of controlling the quality of local waterways.

EFFECTS ON MILL CONSTRUCTION. Mill managers need to be concerned with Clean Water Act compliance for three major reasons:

1. It is the law. The Clean Water Act is a federal law and improper site development or incorrect permitting is a violation of that law.

2. Responsibility for compliance lies with the mill, not the contractor or engineer. In the case of The Clean Water Act, a contractor is only responsible to a mill for construction services rendered. If violations of the Clean Water Act occur due to negligence, lack of knowledge, or any other reason, the mill is liable. The contractor is not.

3. No PDES permit means no construction permit. In most cases, building permits are only issued after all PDES requirements are met and a permit has been issued. Improperly filing an NOI may delay a project up to a month, and this precious time can cost a mill money if startup is delayed.

ASSISTANCE FOR THE PERMITTING PROCESS. Full-service general contractors with site designers, civil engineers, and construction professionals can be helpful in assisting mills through the permitting process. However, it takes time to find an informed, trustworthy contractor that is familiar with federal, state, and local permitting.

Things to consider when searching for a full-service construction professional include:

1. Checking references. This step saves time. A contractor that is trusted by a respected colleague deserves serious consideration.

2. Evaluating "claims to fame." A few architects or engineers do not equal a full-service firm. A mill must determine whether a contractor has seasoned engineers, architects, and project managers in place. Specialists-like civil, industrial, and environmental engineers-should be on board. Or, at least, the contractor should have a strong relationship with an experienced consulting firm.

3. Finding a firm with permitting experience. Find out whether the contractor has worked near the new project and if it has experience with permitting in a variety of geographical regions.

A competent firm can spare mill managers sleepless nights. For smooth construction and storm water permitting, conducting a search for a qualified contractor is worth investing the time.