CESSWI Documentation and Reporting 4 — Questions and Answers
Question 1: Under the EPA CGP, for how many years after permit termination must stormwater inspection records be retained?
- 1 year
- 2 years
- 3 years (Correct answer)
- 5 years
Correct answer: 3 years
The EPA CGP requires that all inspection records, SWPPPs, and supporting documents be retained for at least 3 years after permit termination.
Question 2: Which element of a Notice of Intent (NOI) is critical for establishing the legal start of stormwater permit coverage?
- The contractor's license number
- The anticipated start date of land disturbance (Correct answer)
- The estimated project cost
- The name of the on-site environmental consultant
Correct answer: The anticipated start date of land disturbance
The anticipated start date of land disturbance is critical because permit coverage must be obtained before earth-moving begins, and this date establishes the legal beginning of coverage.
Question 3: When documenting BMP inspections during winter conditions, which additional observation is most important to record?
- Air temperature at the time of inspection
- Frozen ground and snow/ice coverage affecting BMP operability and potential spring melt runoff conditions (Correct answer)
- Contractor crew size
- Number of vehicles on-site
Correct answer: Frozen ground and snow/ice coverage affecting BMP operability and potential spring melt runoff conditions
Frozen ground and snow/ice conditions directly affect BMP performance and can create large-scale sediment discharge when melt occurs, making these critical observations for winter inspection records.
Question 4: A site has a permitted disturbance area of 5 acres. Which document would FIRST alert a regulator that an additional 2 acres was disturbed without authorization?
- The contractor's daily log
- The as-built drawing
- The SWPPP inspection report noting disturbance beyond the permit boundary (Correct answer)
- The project schedule
Correct answer: The SWPPP inspection report noting disturbance beyond the permit boundary
The SWPPP inspection report, which compares actual site conditions to the permitted disturbance limits, would be the primary document identifying unauthorized disturbance for regulatory review.
Question 5: What information should be captured in a 'non-stormwater discharge' documentation entry within a SWPPP?
- Only discharges that exceed a TMDL limit
- The type of discharge, authorization basis (if any), location, and date of observation (Correct answer)
- Payroll records for workers managing the discharge
- Only discharges that cause visible turbidity
Correct answer: The type of discharge, authorization basis (if any), location, and date of observation
Non-stormwater discharge records must identify what the discharge is, whether it is authorized under the permit or another approval, where it occurred, and when it was observed.
Question 6: Which documentation element distinguishes a 'qualified inspector' from an 'authorized signatory' for SWPPP purposes?
- They are the same role with different titles
- A qualified inspector performs and documents site evaluations; an authorized signatory has legal authority to certify and submit regulatory documents on behalf of the operator (Correct answer)
- An authorized signatory must have a state license; a qualified inspector does not
- A qualified inspector signs permit applications; an authorized signatory conducts inspections
Correct answer: A qualified inspector performs and documents site evaluations; an authorized signatory has legal authority to certify and submit regulatory documents on behalf of the operator
The qualified inspector conducts physical site assessments and prepares inspection records, while the authorized signatory is the senior official legally accountable for certifying submittals to the regulatory agency.
Question 7: What is the significance of recording 'no observed discharge' during a CESSWI inspection when stormwater has fallen but has not left the site?
- It negates the need for an inspection report for that event
- It positively documents that BMPs functioned effectively, providing evidence of compliance (Correct answer)
- It indicates that a NOI must be resubmitted
- It has no regulatory significance
Correct answer: It positively documents that BMPs functioned effectively, providing evidence of compliance
Recording 'no observed discharge' during a rain event documents that installed controls were effective, creating positive compliance evidence that regulators can review.
CESSWI Documentation and Reporting 4
Under the EPA CGP, for how many years after permit termination must stormwater inspection records be retained?