EPSC Goes Under the Microscope: An In-depth Approach to Program Audits
This silt fence has not provided adequate erosion protection at this Louisville construction site.Opening eyes, scoring results, documenting trends and deficiencies, and establishing a baseline for future improvements is what an in-depth EPSC program audit is all about. “We wanted to evaluate the effectiveness of what we were currently doing-what we had to target for improvement-to get the most impact from our training and resources at the least cost,” explains Jason Gillespie, programs administrator for the Soil and Water Conservation District in Greenville County, SC, which completed an in-depth EPSC program audit in 2001. The South Carolina Department of Transportation (SCDOT) recently wrapped up its first in-depth audit assessing the effectiveness of its sediment reduction program on road construction sites. Ray Vaughan, hydraulic design manager in the Hydraulic Engineering Department at SCDOT, says the department decided to conduct the audit after receiving penalties against a couple of its roadway projects. “Penalties are expensive-they can be as much as $10,000 a day or more-and we need to avoid any potential future violation,” Vaughan says. “We want to ensure that we are focusing on the appropriate areas, such as water crossings and streams, and that avoiding water-body impacts is our top priority.” Woolpert’s audits of these three EPSC programs revealed the following typical findings:Erosion controls on design plans are sometimes not installed.Inspectors might be adding or subtracting controls at will.Engineers might be “cutting and pasting” controls from one plan to the next.Standard details crucial for proper installations of standard and nonstandard best management practices (BMPs) are sometimes omitted from design plans.Erosion control is sometimes treated as an after-the-fact item rather than being designed in.Developers, contractors, and inspectors often pay more attention to control measures in urban areas, where visibility and the likelihood of complaints are greater, than in less populated rural areas, where water-body impacts from construction activities might go unnoticed.Old technologies and methods for sediment and erosion control are often not as effective compared with newer technologies and methods.Contractors and inspectors might not be aware of or trained in recently passed state and local ordinances requiring stricter EPSC controls and fines for noncompliance.Because inspectors are typically generalists-responsible for numerous types of inspections in addition to erosion prevention and sediment control-they are often overwhelmed with too much paperwork and too many sites to inspect within short timeframes.
This deep-cut channel would not exist if EPSC BMPs had been installed.Because every EPSC program is unique, the process for conducting an in-depth audit varies based on the community or organization. Following is a general process to consider when planning an in-depth audit. Step 1: Determine Who and What to Audit Organizations must decide whether to compare and contrast plan and field data based on district, region, watershed, or some other criteria. What types of sites-residential, commercial, industrial, or institutional-will be audited? Will design engineers, plan reviewers, contractors, and inspectors be audited individually?MSD, for example, audited its five Area Teams-design engineers, contractors, and inspectors-by their assigned watersheds. SCDOT evaluated new road, road expansion, and ramp construction projects by comparing original design plans against site implementations. According to Vaughan, the plan reviews were crucial to the audit. “Are contractors deviating from the plans? Are designed controls being ignored? Are the contractors going by our standards, or coming up with their own? Those are the things we wanted to know,” Vaughan says.
Extent of property impact?
Type of site erosion?
Erosion location? Step 8: Score Field Review Results Woolpert also uses E/SCORE to score field review results and determine the overall Field General Score. Some questions can be weighted based on relevancy. Questions related to water-body impacts, for example, can be weighted based on importance: No impact (2 points)Minimal impact (1 point)Needs attention (0)Severe impact (-1 point)Catastrophic impact (-2 points)BMPs are scored after the plan and field reviews are completed. The BMP Score is the average score for a particular BMP, such as silt fences or sediment traps, on a site. The Overall Site BMP Score is the average score for all BMPs audited at a site. The Overall Individual BMP Score is the average score for a particular BMP taken from BMP Scores for every site audited. Step 9: Analyze Results In typical audits, each site receives a Plan General Score and a Field General Score, and each BMP receives a BMP Score. Scores can be aggregated in additional ways based on project needs. Typically organizations conducting a baseline audit should expect an average Field General Score of approximately 50% because a single severe water-body impact will dramatically lower the score. The auditing team should analyze Field General, Plan General, BMP, and Overall Scores so conclusions, trends, and systemic deficiencies can be documented and recommendations made. The team can produce various charts summarizing, comparing, and contrasting data collected, scores, and observations. Gillespie was surprised by some of Greenville County’s audit results. “Sometimes a bad set of plans produced a good implementation,” he says. “Sometimes the contractor covered all the bases with controls, which resulted in sediment being maintained on-site and no offsite impacts.”Although Greenville County’s average Plan General Score was 76.5%, its average Field General Score was 56%. This 20-point difference told Gillespie that contractors might not always understand the importance of properly installing and maintaining a designed BMP.Gillespie also learned that contractors find it easier to install and maintain certain types of BMPs and that engineers might need to consider designing with these controls more frequently. The county’s audit concluded that silt fences get overused-sometimes effectively, sometimes not-and that contractors needed additional training in the use and installation of certain BMPs. Vaughan says he was surprised to learn that SCDOT had the lowest scores at water crossings. “Highway construction is linear by nature and crosses many drainage patterns in this area. Erosion is going to occur. There seems to be a lack of relaying the importance of those areas to field personnel and contractors.” SCDOT’s audit showed that contractors sometimes install different, often unacceptable controls instead of those on design plans. Vaughan learned that some controls used routinely were not performing well and should be replaced with better controls or newer products that reduce the possibility of water-body impacts. The audit also revealed that SCDOT’s plans were often too general. “Contractors sometimes can’t tell from the plans what we want to have done,” he notes.“A generalized note such as “˜use silt fence as directed by engineer’ might not be enough to get the job done.”Cunningham says MSD’s audit showed that plan reviewers needed more training in EPSC design because too often they had approved plans that clearly weren’t acceptable. The audit also proved that engineers sometimes designed EPSC plans without ever visiting the site. “How can you design a plan that’s going to work if you have never even been to the site?” she asks. “We were seeing cookie-cutter plans for sediment and erosion control.”
MSD’s ordinance took effect January 1, 2001, approximately two years after the audit was completed. Among other requirements, the ordinance mandates training and certification for developers and contractors involved in land-disturbing activities at construction sites. A plan-preparation course is highly recommended for engineers. “The classes help make sure everyone is aware of ordinance requirements,” Pardue says. “None of the ordinance requirements is new, but now we have the ability to deal with noncompliance. People realize there are real financial consequences for failing to comply with the approved erosion control plan.”Within 16 months after the ordinance took effect, MSD had issued eight fines totaling approximately $8,100, says Pardue, who called MSD’s ordinance requirements tough but fair. “Communication is the key to compliance,” he notes. “If it’s a complex problem, or if the contractor demonstrates there are attempts being made to fix the problem, we will work with the contractor toward compliance.” A contractor who ignores a Notice of Violation, however, can accumulate penalties until the problem is corrected.