CESSWI Regulatory Compliance & Reporting 2 — Questions and Answers
Question 1: Under the NPDES Construction General Permit, what is the maximum allowable turbidity benchmark for discharges to waters supporting cold-water fisheries?
- 10 NTU above background
- 25 NTU above background (Correct answer)
- 50 NTU above background
- 100 NTU above background
Correct answer: 25 NTU above background
The EPA's CGP sets a turbidity benchmark of 25 NTU above background for discharges to cold-water fisheries, which are more sensitive aquatic ecosystems.
Question 2: Which federal law primarily governs the regulation of stormwater discharges from construction sites as a point source of pollution?
- Safe Drinking Water Act
- Resource Conservation and Recovery Act
- Clean Water Act (Correct answer)
- National Environmental Policy Act
Correct answer: Clean Water Act
The Clean Water Act Section 402 establishes the NPDES permit program, which regulates stormwater discharges from construction sites as point sources.
Question 3: A construction project disturbs 0.8 acres. Under federal NPDES rules, is a permit required?
- Yes, all earth disturbance requires a permit
- No, only sites disturbing 1 acre or more require a permit (Correct answer)
- Yes, but only if within 100 feet of a waterbody
- No, permits are only required for sites over 5 acres
Correct answer: No, only sites disturbing 1 acre or more require a permit
Federal NPDES Construction General Permits apply to sites disturbing 1 acre or more of land, so a 0.8-acre project does not trigger the federal permit threshold.
Question 4: What document must an operator submit to notify the permitting authority before construction begins under most NPDES Construction General Permits?
- Notice of Termination (NOT)
- Discharge Monitoring Report (DMR)
- Notice of Intent (NOI) (Correct answer)
- Erosion Control Plan (ECP)
Correct answer: Notice of Intent (NOI)
A Notice of Intent (NOI) is submitted to obtain coverage under the NPDES Construction General Permit before earth-disturbing activities begin.
Question 5: Which scenario would trigger the need to file a Notice of Termination (NOT) under the NPDES CGP?
- When a new contractor takes over site operations
- When the SWPPP is updated significantly
- When final stabilization has been achieved and permit coverage is no longer needed (Correct answer)
- When a rainfall event exceeds 1 inch in 24 hours
Correct answer: When final stabilization has been achieved and permit coverage is no longer needed
A Notice of Termination is filed once final stabilization has been achieved and the operator no longer needs permit coverage for the site.
Question 6: Under the 2017 EPA Construction General Permit, how soon after a qualifying storm event must a post-storm inspection be conducted?
- Within 24 hours
- Within 72 hours (Correct answer)
- Within 7 days
- Within 14 days
Correct answer: Within 72 hours
The 2017 EPA CGP requires post-storm inspections to be conducted within 72 hours after a storm event of 0.25 inches or more.
Question 7: Which of the following best describes a 'qualified inspector' under most state NPDES construction stormwater programs?
- Any licensed professional engineer
- A person trained to evaluate BMPs and identify compliance issues (Correct answer)
- An EPA regional staff member
- Any employee of the general contractor
Correct answer: A person trained to evaluate BMPs and identify compliance issues
A qualified inspector is someone trained to recognize and evaluate the effectiveness of BMPs and identify compliance deficiencies, though specific credentials vary by state.
CESSWI Regulatory Compliance & Reporting 2
Under the NPDES Construction General Permit, what is the maximum allowable turbidity benchmark for discharges to waters supporting cold-water fisheries?