EFCOG Best Practice #32

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FACILITY:   DOE/NNSA: Pantex Plant

POINT OF CONTACT:   D. David McBride, 806-477-4874, dmcbride@pantex.com

Any construction project that will result in disturbance of more than 1 acre is required to develop and implement a Storm Water Pollution Prevention Plan (SWP3), by state regulation in Texas.  Pantex has developed an SWP3 that is used for all impacted construction projects at the site.  The SWP3 identifies acceptable control measures, reporting and record keeping requirements, and provides for continued coverage of the project area upon release of the construction contractor until the permit’s coverage may be terminated.

Construction projects are time-critical activities. The SWP3 was a relatively new requirement that many contractors needed support to develop; especially when they were from outside the local area and thus were not familiar with the weather patterns of the Texas Panhandle (i.e. localized high-intensity storms, frequently of short duration).  SWP3s had to be developed and certified by senior management of the firms that were implementing them (e.g., general contractors and sub-contractors).  Additionally, permit coverage needed to continue after release of the contractor/subcontractor (i.e., until the disturbed site had achieved a perennial vegetative cover with a density of 70 percent of the native background species).  The SWP3 thus had to be certified by the site operator (BWXT Pantex L.L.C.).

Contractors are provided with a General SWP3 that has been developed and certified by BWXT management.  The contractor uses a pre-formatted addendum to the General Plan to adapt the plan meet their specific project’s scope, location, and methodology.  After the contractor’s management has certified the plan, it is then reviewed, returned for modification if necessary, and then certified by BWXT management.  Upon completion of signatures, all parties to the plan may submit separate Notifications of Intent (NOI) to the state; construction may begin 48 hours after the submittal of an NOI).

• It ensures consistency in SWP3s from project to project;

• It expedites the plan development process by the contractor, reducing the pre-start paperwork;

• It facilitates the review and approval of contractor-developed SWP3;

• It assures that contractors utilize control measures and techniques that have been found to be effective and appropriate to the Texas Panhandle and specifically to the Pantex Plant area;

• It allows the contractor and BWXT to ‘share’ a common SWP3 so that when BWXT releases the contractor (takes Beneficial Occupancy of the construction area), the SWP3 is already in place;

• Facilitated training of construction site inspectors, project engineers and project managers on their responsibilities in meeting the regulatory requirements.

After the general SWP3 was developed, getting contractors to use the plans, rather than prepare separate, project specific plans was overcome by making use of the prepared plan, with project-specific-developed addenda, a contractual requirement.  Pantex uses a series of general specifications in developing contracts for construction; once the specification was modified, making use of the general SWP3 a requirement, this problem ended.

Time to review and approve a contractor’s SWP3 went from several weeks (nearly 6 weeks on one project) before implementation of the general plan to approval by both BWXT and the contractor(s) in less than one week.  Prior to the implementation of the general SWP3, there could be numerous iterations on plans between the contractor and regulatory compliance staff.  This led to delays in start of construction activities while contractor’s plans were revised, re-submitted, reviewed and approved.  Having an SWP3 in place has assisted site contractors in preparing, submitting and complying with the regulatory requirements. 

An additional success is that BWXT is better positioned to assume the required inspection duties and evaluate the discharge control measures by having a pre-determined set of measures authorized for use at the plant.

Use of the General Plan has been a contractual requirement for several years and over 20 projects have been started using the General Plan, with project-specific addenda.