Schools-2009 SSp1: Construction Activity Pollution Prevention

  • NC_Schools_CS_SSp1-Type3-ConstructionPollutionPrev Diagram
  • Generally standard practice, anyway

    In general, complying with this prerequisite is standard practice in most urban and suburban areas, where most or all of the EPA Construction General PermitEPA's Construction General Permit. Outlines the provisions necessary to comply with Phase I and Phase II of the National Pollutant Discharge Elimination System (NPDES) program. (CGPEPA's Construction General Permit. Outlines the provisions necessary to comply with Phase I and Phase II of the National Pollutant Discharge Elimination System (NPDES) program.) requirements have been adopted and implemented at the state or county level. Regulators at those levels often threaten heavy fines for not complying with CGP requirements, so most projects do so without the added incentive of the LEED prerequisite.

    Early on in project planning, compare your local code requirements to the CGP to determine which is more stringent. If your local code is more stringent, then you will meet the prerequisite just by following that. If it is less stringent, follow the CGP to achieve the prerequisite.

    Create an ESC plan

    The CGP extends compliance with the National Pollutant Discharge Elimination System (NPDESThe National Pollutant Discharge Elimination System (NPDES) is a permit program that controls water pollution by regulating point sources that discharge pollutants into waters of the United States. Industrial, municipal, and other facilities must obtain permits if their discharges go directly to surface waters.) stormwater regulations to construction activities. It has three main categories that need to be addressed as you create an erosion and sedimentation control (ESC) plan:

    • Prevent the loss of topsoil during construction. Proper staging of earth-moving activities and the preservation of mature vegetation can aid in preventing topsoil loss and controlling stormwater pollutant discharge. Stabilization methods such as seeding, mulching, and the use of geo-textiles should also be included in your plan.  
    • Prevent the sedimentation of receiving streams. Your plan should outline the placement of planned structural control measures such as silt fences, drainage swales, and storm drain inlet protection. 
    • Prevent air pollution by particulate matter. Your plan should describe measures to prevent the tracking of soil onto paved surfaces off-site and the generation of dust from construction vehicles—for example, gravel skirts at drive entries and exits, transit ways for heavy vehicles, and wash stations for trucks.

    Simply put, your ESC plan implements good housekeeping on a site-wide basis, minimizing the impact of construction on local environmental resources and surrounding properties. 

    As written, the CGP applies to sites of one acre or larger. However, all projects pursuing LEED certification must meet the requirements of the CGP, regardless of size. 

    Often the civil engineer is responsible for creating the ESC plan, which is then implemented by the general contractor. Smaller projects may find the contractor is the one providing the plan, often one that is standard for their company.

    Documenting your plan

    The ESC plan may be submitted as documentation, in the form of a site plan or a narrative report. 

    Inlet protectionInlet protectionTo demonstrate that your ESC plan was implemented, your projects will also be required to provide one of the following: 

    • An inspection check list―signed, and dated periodically. 
    • Date-stamped photos of the following:  
    • measures to prevent topsoil loss including staging of earth-moving activities and stabilization techniques; 
    • measures to prevent sedimentation of nearby streams including structural controls and inlet protection;  
    • measures to prevent air pollution including tracking control at entrances and exits.
    • Description of corrective actions taken in response to problems with the performance of ESC measures.

    Zero lot lines

    Many urban projects have zero lot lines and, therefore, no associated “site.” If your project is like this, you are not exept from developing and implementing an ESC plan. However, strategies and BMPs will differ from those implemented on projects with site area. Inlet protection will still be required, even if storm drains are not immediately on site and within your LEED boundary. Tenting work areas and using temporary enclosures can prevent dust and airborne particulatesTotal suspended particulate matter found in the atmosphere as solid particles or liquid droplets. Chemical composition of particulates varies widely, depending on location and time of year. Sources of airborne particulates include: dust, emissions from industrial processes, combustion products from the burning of wood and coal, combustion products associated with motor vehicle or non-road engine exhausts, and reactions to gases in the atmosphere. (EPA) from leaving the project site. Vehicle tracking and concrete washout will also need to be addressed, and washout will likely have to be managed onsite somehow. Don't forget to include staging areas.

    Concrete washoutConcrete washoutDocument the plan with a narrative report explaining which CGP requirements don’t apply to your project conditions, which do, and how you plan to implement them.

    FAQs for SSp1

    Am I exempt from this prerequisite if I have a zero-lot-line building? What if the site work is minimal due to the scope? What about a renovation? What if the excavation and foundation work is minimal due to the construction materials I am using?

    No. You must always do an ESC plan according to the credit requirements. We have yet to hear of a project that didn't have some issues to address. See the above section titled "Zero lot lines."

    What are BMPs for steep slopes?

    BMPs for steep slopes should address soil retention, but not water retention. These could include silt fencing and straw wattles, hydro seeding and stabilized mulching, geotextiles and mats, and most importantly, preservation of natural vegetation.

    I have a technical question about a specific control measure and whether LEED requires it. What guidance is available?

    LEED does not offer specific requirements on ESC control measures, beyond the standards that it references, and the documentation requirements. LEEDuser recommends working with a civil engineer who understands the LEED and EPA requirements, and relying on the professional judgment of the engineer for specific technical questions. LEEDuser has not heard that LEED reviewers are deeply scrutinizing ESC plans and coming back with highly technical questions.

    Is there a preferred method for documentation?

    This prerequisite offers several options for documentation, including date-stamped photographs, a narrative describing the ESC plan implementation, or a builder declaration of periodic inspection and documentation of ESC implementation. You can rely on project specifics to choose the best option for you—LEED has no preference.

    What suffices as far as a date-stamped photo?

    Ideally, use your cameras to imprint a visible date on a corner of the image. Most cameras offer this option. Digital files also typically encode a date when the file was created, or encode that date in the file name, and while these methods aren't ideal, some project teams have reported success submitting this type of documentation.

    Can I still earn the prerequisite if the project started considering LEED after work began?

    As long as the project has been actively implementing an ESC plan during the current development of the project site, you should be okay. If that's not the case, then the outcome will depend on project specifics, and you will likely need official guidance from GBCI.

    LEEDuser has advised teams that in multi-phase projects, it's okay to focus documentation of the ESC plan only on the current phase, when LEED became part of the project scope. In general, if there is some question about whether controls were in place during the LEED project, you may not be able to earn the prerequisite.

    How do I know if my local code is more or less stringent than the EPA CGP?

    USGBC has not identified specific standards for judging this, or defined certain codes as compliant with the credit, or not. The stringency of other codes relative to EPA's Construction General Permit is judged on a case-by-case basis.

Legend

  • Best Practices
  • Gotcha
  • Action Steps
  • Cost Tip

Pre-Design

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  • Review pages B-1 through B-4 of the EPA Construction General Permit (CGP) (see Resources) to determine if your state administers the CGP requirements for all projects. 


  • In regions where the EPA CGP is not standard practice, compare the local code with the CGP and make adjustments, if necessary, to include all the CGP requirements.


  • Meeting the requirements of this prerequisite is standard practice in many regions and, therefore, no- or low-cost for LEED. 


  • The materials cost to implement these measures is minimal and can potentially save money by preserving the vegetation and topsoil on-site. 


  • Conduct a site evaluation to assess opportunities for minimizing the alteration of the natural stormwater runoff patterns of your site and the disruption of mature vegetation, especially trees. This will save money and time in terms of earth-moving and replanting vegetation. 


  • Ask your civil engineer about soil types and what type of drainage you will have once the topsoil and vegetation are disturbed.

Schematic Design

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  • Establish who will create your ESC and stormwater pollution prevention plans. Usually, the civil engineer creates them, and the contractor is responsible for their onsite implementation. 


  • It is best to include your ESC plan in both project drawings and project specifications so that the intention of the plan is clearly communicated to the project team, especially contractors and subcontractors. 


  • Determine whether the 2003 EPA CGP or local erosion and sedimentation control standards are more stringent―and follow the more stringent standards. Often the state department of environmental protection or equivalent will have a written ruling on the comparison of the CGP standards and the local standards.  


  • A good first step to determine which is more stringent is to review your local code to be sure it contains at minimum the general categories contained in the CGP. If not, you’ll know that you need to follow the CGP. If so, you’ll need to review your local code in detail to be sure that all of the requirements are included. The general categories are as follows: 

    • allowable stormwater discharges
    • allowable non-stormwater discharges
    • limitations on coverage
    • a stormwater pollution prevention plan
    • releases in excess of reportable quantities
    • treatment of spills.

  • If local standards are equal to or more stringent than the CGP,you'll need to provide a narrative report detailing this. Write the narrative when you do the comparison, so that it's fresh in your mind.  

Design Development

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  • All written ESC plans must include the following:

    • an introduction describing the standard being followed, existing site conditions, and responsible parties
    • a list of the temporary and permanent control measures that will prevent loss of topsoil, sedimentation of receiving streams and storm sewers, and air pollution by particulate matter
    • details of the plan for implementation and ongoing maintenance to prove implementation, including one of the following measures: 
      • A checklist or inspection report demonstrating implementation of your ESC plan and providing sample dates, inspection frequency, at least three equally spaced inspections over the project timeline, and a description of any corrective actions taken. (For LEED documentation, you need to upload this document and have the builder or general contractor sign the LEED Online credit form.)
      • Date-stamped photos of implementation and corrective actions, as applicable, including at least three photos from three different monthly inspections equally spaced over your project site's work timeline. (For LEED documentation, you need to upload these images, but there is no specific required signatory for this option.)
      • A narrative outlining the implementation and corrective action taken to effectively implement your ESC plan. (For LEED documentation, you provide the narrative itself; there is no required signatory for this option.) 

  • Determine which path your project will follow to demonstrate implementation compliance: inspection report, photos, or narrative report. 


  • Photos are likely the easiest way to demonstrate compliance, unless an inspection report has already been completed. 


  • Develop a site-wide, earth-moving schedule to minimize the impact on established vegetation and to stockpile topsoil and protect it from erosion. This can also complement your strategy to achieve SSc5.1: Site Development—Protect or Restore Habitat, by limiting site disturbance and maintaining native vegetation.  


  • Proper scheduling and staging of earth-moving activities can lower the costs associated with sediment and erosion controls.


  • Retain as much of the existing vegetation as possible, not only to lower costs for replacements, but also to decrease the cost of structural controls.


  • Careful implementation of the stormwater pollution prevention plan (SWPPP) by the contractor should inform the design and installation of stormwater management systems onsite. This will enable those systems to be integrated to the greatest extent possible during construction, preventing unexpected stormwater discharges into receiving waterways.  


  • If attempting one or both of the stormwater management credits SSc6.1 and SSc6.2 confirm with the contractor that the SWPPP accurately represents the hydrologic characteristics of the site and is performing as anticipated. Check on assumed infiltration rates, suspected rate and quantity of run-off to receiving streams, and discuss potential storage options. Make changes to the stormwater management system accordingly to improve its effectiveness and ensure that the credit calculations are accurate.


  • Create a draft ESC plan drawing or a narrative report that outlines how your project will comply with the requirements of the CGP or the local standard. See the Documentation Toolkit for samples.


  • Make sure that you use the same LEED project boundary as all other LEED credits your project is attempting (this is particularly relevant with other Sustainable Sites credits).


  • A project drawing should include anticipated stormwater flows and indicate the location and type of any planned ESC measures. 

Construction Documents

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  • Review your ESC and stormwater pollution prevention plans to ensure adequate measures will be implemented to meet the CGP, or local requirements. A discussion between the contractor and the civil engineer on the schedule and implementation of planned measures should be part of this review. 


  • Finalize your ESC plan drawings or narrative report. Verify that your plan is in compliance with the CGP or local standards. 

Construction

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  • Review all ESC project drawings and construction specifications prior to construction activities. 


  • Verify that all ESC measures are in place before any construction activities begin. 


  • The general contractor implements the ESC plan until construction is completed and all disturbed areas have been stabilized. 


  • Have a representative from the general contractor’s office onsite daily to monitor and implement necessary measures laid out in your ESC plan.


  • The civil engineer, contractor, or a third party should inspect your ESC plan measures on a weekly basis (bi-weekly if inspections are also conducted after any weather event involving more than 0.5 inches of rain), and submit status reports on ESC plan implementation. These reports should include labeled and dated photographs, an inspection log, or a narrative report describing the performance of the measures implemented. 


  • Provide corrective actions immediately after any rain event.


  • Corrective actions can range from adjusting the placement of silt fencing and removing debris from stormwater catchment basins to replanting areas of temporary seeding and adding material to gravel skirts at entrances and exits.


  • Preserve existing vegetation, especially mature trees, whenever possible. This will decrease costs for temporary stabilization measures and erosion controls. In addition, the vegetation may also be used as part of your landscaping plan. 


  • After completion of all construction activities, document credit compliance in LEED Online by uploading these documents: 

    • A narrative that declares the standard followed (2003 EPA CGP or local). If you used a local standard, write a narrative report detailing how it is equal to or more stringent than the CPG (Phases I and II, NPDES program). 
    • A written ESC plan or project drawings showing the control measures used.
    • Proof of implementation with one of the following: an inspection report with the required signature, nine photos, or a narrative report.

Operations & Maintenance

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  • Implement an ongoing stormwater system maintenance plan with the landscape manager. This should include a regular schedule for monitoring the performance of the stormwater management system and guidelines for repairing or modifying site features that are causing problems. These guidelines could include replacing or increasing vegetation, redirecting runoff, and increasing storage.   

  • USGBC

    Excerpted from LEED 2009 for Schools New Construction and Major Renovations

    SS Prerequisite 1: Construction activity pollution prevention

    Required

    Intent

    To reduce pollution from construction activities by controlling soil erosion, waterway sedimentation, and airborne dust.

    Requirements

    Create and implement an erosion and sedimentation control plan for all construction activities associated with the project. The plan must conform to the erosion and sedimentation requirements of the 2003 EPA Construction General PermitEPA's Construction General Permit. Outlines the provisions necessary to comply with Phase I and Phase II of the National Pollutant Discharge Elimination System (NPDES) program. OR local standards and codes, whichever is more stringent. The plan must describe the measures implemented to accomplish the following objectives:

    • To prevent loss of soil during construction by stormwater runoff and/or wind erosion, including protecting topsoil by stockpiling for reuse.
    • To prevent sedimentation of storm sewers or receiving streams.
    • To prevent pollution of the air with dust and particulate matter.

    The EPA’s construction general permit outlines the provisions necessary to comply with Phase I and Phase II of the National Pollutant Discharge Elimination System (NPDESThe National Pollutant Discharge Elimination System (NPDES) is a permit program that controls water pollution by regulating point sources that discharge pollutants into waters of the United States. Industrial, municipal, and other facilities must obtain permits if their discharges go directly to surface waters.) program. While the permit only applies to construction sites greater than 1 acre, the requirements are applied to all projects for the purposes of this prerequisite. Information on the EPA construction general permit is available at http://cfpub.epa.gov/ npdes/stormwater/cgpEPA's Construction General Permit. Outlines the provisions necessary to comply with Phase I and Phase II of the National Pollutant Discharge Elimination System (NPDES) program..cfm.

    Credit substitution available

    You may use the LEED v4 version of this credit on v2009 projects. For more information check out this article.

    Potential Technologies & Strategies

    Create an erosion and sedimentation control plan during the design phase of the project. Consider employing strategies such as temporary and permanent seeding, mulching, earthen dikes, silt fencing, sediment traps and sediment basins.

Publications

EPA – Construction General Permit

Referenced Standard.


Stormwater Pollution Prevention Plans for Construction Activities

Resources here include Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites, SWPPP Templates, Sample Inspection Form, Example SWPPPs, Key Resources, and Selected State BMPBest Management Practice/Guidance Manuals.


BMP Manual

BMPBest Management Practice Manual.

Organizations

International Erosion Control Association

Connect with worldwide member based erosion and sediment control community.


Certified Professional in Erosion and Sedimentation Control

Provides certification programs a list of qualified professionals. 

Technical Guides

Canada Mortgage and Housing Corporation

A variety of Canadian resources on stormwater management and BMPs.

Photos

Take photos like these to document proper implementation of your ESCAn Erosion and Sedimentation Control (ESC) plan is a collection of measures designed to reduce pollution from construction activities by controlling soil erosion, waterway sedimentation and airborne dust generation plan.

Construction Submittal

HardhatDocumentation for this credit is part of the Construction Phase submittal.

Erosion and Sedimentation Control Plan Drawings

Posted here are sample drawings for erosion and sedimentation control (ESCAn Erosion and Sedimentation Control (ESC) plan is a collection of measures designed to reduce pollution from construction activities by controlling soil erosion, waterway sedimentation and airborne dust generation) plans from a LEED project.

LEED-NC Platinum Senior Housing Sample Documentation

Samples from this LEED Platinum project demonstrate how to document SSp1. This 8-story, 100-unit public senior housing development will use 50% less energy than a comparable code compliant building. Although on a tight urban site, the project also features innovative stormwater management plans, and a pilot graywaterGraywater is untreated household waste water which has not come into contact with toilet waste. Graywater typically includes used water from bathtubs, showers, bathroom wash basins, and water from clothes-washer and laundry tubs, though definitions may vary. Some states and local authorities also allow kitchen sink wastewater to be included in graywater. Project teams should comply with the graywater definition established by the authority having jurisdiction in the project area. reuse system—all on a tight budget under a major urban housing authority.

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Jul 25 2014
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