During an active project, it’s common that an installed BMP (Best Management Practice) is not performing as optimally as intended. Maybe your routine stormwater inspector suggested an alternative BMP, or you actively observed sediment traveling off site boundaries. Either way, real-life situations require adaptive management and flexibility. In this blog, we’ll cover what to do if you find yourself in a situation where you need to swap out a BMP on your Colorado construction project.
Start with Your SWMP
As we’ve discussed in previous blog posts, the Stormwater Management Plan (SWMP) Narrative is a living document that reflects on-site conditions. If a change needs to be made, referencing the SWMP is a good place to start. In examining the SWMP, you should find a detailed map and BMP description. This should include how BMPs should be installed and where. Often, when reviewing the BMP specifications, there may be an easy fix. These can include as re-installing or relocating the existing BMP — before a full swap is necessary.
When a Simple Fix Isn’t Enough
If the BMP on your site checks all the boxes for proper installation but is still not functioning correctly, it may be time to consider replacing it entirely. Consulting the civil engineer or Qualified Stormwater Manager (QSM) professional who designed the SWMP is a great next step. Between their expertise and your on-site routine stormwater inspector’s recommendations, a more appropriate BMP may be identified for your specific site conditions.
In Colorado, construction sites operating under a Colorado Discharge Permit System (CDPS) stormwater permit are required to document BMP changes in the SWMP. Any swap must be reflected in an updated SWMP Narrative. They must also be reflected in the site map. These steps will keep the project in compliance with the Colorado Department of Public Health and Environment (CDPHE) regulations. Failing to update the SWMP after a BMP change can result in permit violations during routine and state/local jurisdiction inspections.
A Real-World Example
Here is a common scenario where a BMP swap makes sense:
You have sediment control logs (SCLs) installed along disturbed soil, but sediment keeps migrating beyond them. In this case, an appropriate swap may be to remove the SCLs and install a curb cutback. This solution is better suited to controlling sediment flow in that particular area. Once the new BMP is in place, be sure your SWMP is updated to reflect the change. Don’t forget to include the location, BMP type, and installation specifications!
Document Everything
Regardless of which BMP you choose, documentation is key. Update your SWMP Narrative and site map promptly after any change is made. A Summit Services stormwater inspector will do this step for you and note the swap in their inspection reports. Keeping thorough records protects your project in the event of a regulatory inspection. It also demonstrates your commitment to responsible stormwater management on your Colorado job site.
Need Help Managing Your Stormwater Compliance?
Navigating BMP selection and SWMP updates can be complex. Whether you’re dealing with a non-performing BMP or need guidance on staying compliant with Colorado stormwater regulations, our team is here to help. With our inspectors’ extensive compliance knowledge and experience, we provide solutions and make sure you remain compliant no matter the situation. Contact us today to learn more about our stormwater management services.