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Stormwater Pollution Preventionon K. Hovnanian Jobsites

A Guide for Trade PartnerCompliance

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Purpose of This Guide

This guide was developed to educate K. Hovnanian's TradePartners:

Regarding requirements for stormwater pollutionprevention compliance. This includes:

o Specific requirements assigned to Tradeso Specific actions all Trades must take to comply

To understand what to do if you observe a conditionrequiring attention.

To educate K. Hovnanian's Trade Partners as to theconsequences of site non-compliance.

How Trade Partners Should Use This Guide

Review Guide and refer to your Site StormwaterCompliance Representative(s) if further clarification isneeded.

All Trade Partner actions are noted in blue font.

This Guide can be used to train required designees fromyour company who have the authority to oversee, instructand direct employees and sub-contractors working at aK. Hovnanian site in regard to stormwater compliance.

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Why are we here today?

The Environmental Protection Agency (EPA) has developed apermitting program entitled the National Pollutant DischargeElimination System (NPDES) to regulate stormwater dischargethat we, K. Hovnanian and you as our Trade Partners mustcomply with. Permits are required for all sites over 1 acre orlots that are within part of a common development. Thiscovers essentially all that we do.

The EPA is currently focusing its attention on residentialhomebuilding industry to ensure compliance. Most largehomebuilders have been affected by these increasedenforcement actions.

Compliance to the EPA's requirements are critical to oursuccess as a builder.Potential fines are very large; as much as $36,000 perviolation, per day.The EPA has the ability to shut down construction sites fornot complying with the regulations.

K. Hovnanian has a company-wide Stormwater Program thatwas created to ensure compliance with the EPA's requirements.This guide was developed to provide you with an understandingof our role and your role regarding stormwater management onour jobsites.

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K. Hovnanian’s Stormwater ProgramTrade Partner Compliance Expectations

Who Should You Contact for Stormwater Inquiries?

1. Every K. Hovnanian construction site has a Site StormwaterCompliance Representative(s) that is responsible for continuouscompliance with all permits and with the K. Hovnanian StormwaterProgram.

2. All K. Hovnanian sites will have a visible sign posted on the siteidentifying the individual Site Stormwater ComplianceRepresentative(s) for the site.

a. As Trade Partners, it is your responsibility to know who theSite Stormwater Compliance Rep(s) are for everyK. Hovnanian site you work.

3. Each construction site is inspected for compliance with the permit ona regular basis. Any non-compliance is required to be repairedpromptly.

What's a SWPPP, BMP & What Do I Need To Know About Them?

1. The permitting process requires a written Stormwater PollutionPrevention Plan (SWPPP) be developed for each site by trainedStormwater Consultants. The SWPPP defines how stormwater andother potential pollutants (e.g., trash, debris, etc.) will be controlledon the site to minimize entry into downstream waters.

2. The SWPPP identifies Best Management Practices, known as BMP’s,for managing stormwater at the site. Silt fences, concretewashouts, rock entrances and a waste containment structures areall examples of BMPs.

a. Silt fencing is used to control sediment leaving the site.b. A concrete washout is used to contain common pollutants in

concrete from entering the ground.c. Rock entrances are used to minimize tracking of dirt and

debris.d. A waste containment structure is used to manage waste in a

confined area and facilitate removal from the site.

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3. If a BMP has been modified or moved by you as a Trade Partner, itmust be replaced immediately.

4. If damage to a BMP is unavoidable for completing work (pouring afoundation, delivering lumber, etc.), the Site StormwaterCompliance Rep(s) must be notified before damaging BMP’s so theycan determine whether or not to proceed with the activity at thattime, and or, schedule repairs to be completed by a BMP contractor.

5. All K. Hovnanian sites will have a visible sign posted on the siteidentifying the location of the SWPPP.

6. All K. Hovnanian sites will have a copy of the SWPPP available at thejobsite construction trailer or other designated location.

7. As Trade Partners, it is your responsibility to review the SWPPP withthe Site Stormwater Compliance Rep(s) and comply with all of theSWPPP's requirements.

8. Trade Partners shall report any pollution controls that are in need ofrepair or not functioning properly to the Site StormwaterCompliance Rep(s).

Are There Any Other Off-Site Compliance Requirements?

1. As Trade Partners, you are required to designate a representativewho has the authority to oversee, instruct and direct employees andsub-contractors working at the site when it comes to stormwatercompliance.

2. As Trade Partners, it is your responsibility to provide yourcompany's designated representative(s) with a copy of thisTraining Guide.

3. Consequences to Trade Partners of not complying with the SWPPPrequirements and the items outlined in is Training Guide mayinclude fines, stop work orders and/or termination.

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Trade Partner Do’s and Don’ts

Below are a few Trade Partner Do's and Don’ts that highlightimportant points.

DO:

1. DO go to the Site Stormwater Compliance Rep(s) with anyquestions regarding stormwater pollution prevention or theDo's and Don'ts list.

2. DO properly handle, store, cover and contain all materials.

3. DO place all trash and debris in the receptacles provided.

4. DO use designated washout areas for (and only for) cleaningequipment (i.e. concrete trucks must use the designatedconcrete washout area).

5. DO immediately report any spills of any quantity ofpetroleum or other chemicals to the Site StormwaterCompliance Rep(s). The Site Stormwater Compliance Rep(s)will determine the necessary actions based on the quantity ofthe spill and the type of chemical.

6. DO immediately comply with any instructions given by theSite Stormwater Compliance Rep(s) or other K. Hovnanianpersonnel.

7. DO replace / re-install any BMPs altered by you immediately.Do not leave the site until complete.

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DO NOT:

1. DO NOT track dirt onto streets. Use provided trackingcontrols and sweep or remove excess dirt from streets.

2. DO NOT allow any solvents, chemicals, paint, drywallfinishing materials, any masonry materials, stucco materialsor rinse liquids to drain into a street or storm drain, a creek,waterway, or other water body.

The above mentioned materials may not be washed out onsite.

3. DO NOT disable, damage or interfere with any silt fence orsimilar erosion control.

For example, DO NOT run over a silt fence, straw wattleor forget to replace any silt fence or straw wattle youtemporarily relocate, damage or dislodge.

4. DO NOT disable, damage or interfere with any inlet controls.For example, DO NOT remove inlet controls (unless anaction is needed to prevent flooding) or place dirt or debrisin or adjacent to inlet controls.

5. DO NOT disable, damage, evade or interfere with anystormwater pollution prevention controls at constructionentrances.

For example, DO NOT drive around stone constructionentrances.

6. DO NOT disable, damage, drive over or interfere with anygeotextile, matting or mulch.

7. DO NOT disable, damage or interfere with any otherstormwater pollution prevention controls.

Remember: The failure to comply with stormwater requirements at anyK. Hovnanian site is a breach of your contractual obligations and mayresult in economic sanctions or termination.

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Notes

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Good Housekeeping Practices

Construction related waste can end up polluting stormwaterrunoff if not properly managed. There are eight key areas togood housekeeping practices:

1. Waste Management

2. Concrete Washout

3. Material Storage

4. Equipment and Vehicle Fueling

5. Spill Prevention and Response Plan

6. Tracking

7. Stabilization

8. Dewatering

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1. Waste Management

What does this mean to me?

Make sure to put trash in the container.

If containers are full, please report to the SiteStormwater Compliance Rep(s).

Remove left over materials from the site promptly.

Portable toilets? These are common on job sites andare often noted as violations for not being staked down,too close to roads or overturned.

GOOD:- Container placed off road- Trash is not overflowing- Tracking pad in front ofcontainer

POOR: - Area around containershould be clean- Tracking pad might needrefreshing

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2. Concrete Washout Areas

Concrete wash materials and water are highly polluted and maynot be discharged onto the ground or into uncontained areas.

What does this mean to me?

Do not washout concrete trucks or equipment outsidedesignated washout areas.

Entrances to washout areas should be maintained toprevent tracking into streets or alleys. Any entrances towashout areas that are not functioning as intended shouldbe reported to the Site Stormwater Compliance Rep(s)immediately.

Grout and stucco shall also be disposed of in thedesignated washout area.

When using washout area, inspect for leaks and tearsand report to the Site Stormwater Compliance Rep(s)and do not use until repaired.

Hardened concrete shall be removed from the site andnever disposed of in the concrete washout area.

- Look for signage atdesignated area.

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3. Material Storage

Good material management is essential to prevent stormwaterpollution.

What does this mean to me?

Consult with your Site Stormwater Compliance Rep(s) todetermine proper storage area locations and storagetechniques.

Building materials should not be stored in the road.

Verify with the Site Stormwater Compliance Rep(s) thatthe materials you want to store on site are allowed to bestored onsite by the SWPPP.

Building materials such as paint, solvents, pesticides, fueland oils, or those materials having the potential tocontaminate stormwater runoff, should be stored indoorsor under cover OR should be removed from the site ifappropriate storage is not available.

Secondary containment to prevent a spill from spreadingshould be provided.

Designated staging areas for fueling, mixing paints,stucco, mortar, etc. should be predetermined with theSite Stormwater Compliance Rep(s).

Train your employees and subcontractors on theimportance of pollution prevention.

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4. Equipment and Vehicle Fueling

Fuel for thought:

Train your employees and subcontractors in proper fuelingprocedures:

Stay with vehicles during fuelingProperly use pumps and shutoff valves

Do not allow vehicle fueling to take place in the middle ofa field or where a lot of gas can go onto the ground.

Keep fueling in designated areas.

Inspect fueling equipment regularly for leaks, damage andother service issues.

Report any fuel spills to the Site Stormwater ComplianceRep(s) immediately.

- Outdoor vehicle fuelingand maintenance can be asignificant source ofstormwater pollution.

- Consider performingthese activities at an off-site facility.

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5. Spill Prevention Plan

Most state and EPA construction general permits require thepreparation of a spill prevention plan and response plan.

What does this mean to me?

Review the spill prevention plan with your Site StormwaterCompliance Rep(s).

Know how to dispose of contaminated spill materialproperly (this should be outlined in the plan).

Train your employees and subcontractors on spillprevention and required response.

In the event that a hazardous material or chemical isreleased, which is in excess of reportable quantity,you must contact the National Response Center at1-800-424-8802 for assistance and immediately reportrelease to the Site Stormwater Compliance Rep(s).*

* The reportable quantity is located on MSDS sheets that are required to be available.

- This fuel storage shouldhave a secondary pan as abackup in the event ofleakage.

- Container and equipmentshould be inspected dailyfor leaks and damage.

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6. Tracking

One of the most common stormwater related complaints fromthe public is dirt in the street. We can reduce these complaintsand avoid likely enforcement actions by taking measures toretain all sediment on site.

What does this mean to me?

Remove mud and dirt from the tires of constructionvehicles before entering a paved roadway.

Use only designated construction exits that have trackingcontrols.

Sweep or remove excess dirt from streets.Do not wash dirt from streets.

Notify Site Stormwater Compliance Rep(s) whenentrance(s) need to be refreshed.

Work out a plan with the Site Stormwater ComplianceRep(s) while working on a specific lot or area within acommunity, to prevent tracking at that location.

- Trade Partners areresponsible for their owntracking.

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7. Stabilization

When construction activities have temporarily or permanentlyceased, we are required to stabilize exposed soils to minimizeerosion.

What does this mean to me?

Keep off home sites that have been stabilized. Thisincludes vacant lots that have not begun construction yet.

Do not park on home sites. This includes vacant lots thathave not begun construction yet.

Do not store materials on home sites that have beenstabilized.

Report damaged BMPs around stabilized areas.

Report vehicle activity on stabilized lots.

- Keep stockpiles andmaterials off stabilized lots.

- Trade Partners areresponsible for repairingBMPs they have damaged.

- For example, in this casethe silt fence should havebeen repaired by the Tradethat dumped the piles ofsoil.

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8. Dewatering

Dewatering practices typically result in muddy water beingpumped out of excavations.

What does this mean to me?

Pump muddy water from these areas to a temporary orpermanent sedimentation basin or to an area completelyenclosed by silt fence in a flat vegetated area wheredischarges can infiltrate into the ground.

Never pump muddy discharge into storm drains, streams,lakes or wetlands.

Some permits may have specific requirements fordewatering, you are required to follow those instructions.

Depending on your state, dewatering may require aseparate permit.

Consult with your Site Stormwater Compliance Rep(s)prior to any dewatering activity.

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Stormwater Compliance Review forTrade Partners

Know the names and contact information for thecommunity Site Stormwater Compliance Rep(s).

Trades are required to designate a representative who hasthe authority to oversee, instruct and direct employeesand sub-contractors working at a K. Hovnanian site inregard to stormwater compliance.

If a BMP must be removed to complete a task (such as siltfence) it must be replaced upon completion of the taskand no later than the end of the day.

Report BMP abuse.

Make every attempt to keep vehicles on the roadway andnot on lots.

Do not store materials in roadway or on paved surfaces.

Know where spill kits are located and how to use them.

Contact your Site Stormwater Compliance Rep(s) for moreinformation or any questions.

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Conclusion:

We are all responsible for stormwater pollution or pollutedrunoff, and it all boils down to one problem: As stormwatertravels across a jobsite, it picks up sediment, trash (cigarettebutts, wrappers, cups, construction waste, joint compound,concrete spillage, paint, etc.), and other pollutants such asgasoline, motor oil, hydraulic fluid, antifreeze, etc. This pollutedrunoff can flow directly into storm drains, rivers, lakes andstreams.

It is up to all of us, K. Hovnanian Associates, Trade Partners,Suppliers and Consultants to follow the permit, SWPPP andguidelines in this handbook. Prevention and control ofstormwater on the jobsite is not only required by law, it is thecorrect thing to do for the environment. Continual education inmanaging stormwater is a primary factor in the success ofpreventing stormwater pollution as well as using common sensewhile working on our home sites.

Only by working as a team can we truly prevent pollution fromleaving our sites.

Thank you for your participation in managingstormwater at K. Hovnanian communities.

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Notes

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