CESSWI Regulatory Compliance & Reporting 4 — Questions and Answers
Question 1: During a routine inspection, an inspector discovers that a subcontractor is operating without being listed on the site's SWPPP. What is the appropriate corrective action?
- Issue a stop-work order to the subcontractor immediately
- Add the subcontractor to the SWPPP and ensure they receive a copy of relevant sections (Correct answer)
- Report the subcontractor to the state environmental agency
- Require the subcontractor to obtain a separate NPDES permit
Correct answer: Add the subcontractor to the SWPPP and ensure they receive a copy of relevant sections
All subcontractors performing earth-disturbing work must be identified in the SWPPP; the operator should update the plan and provide the subcontractor with applicable SWPPP requirements.
Question 2: Which of the following is an example of a 'non-stormwater discharge' that must be identified and addressed in a SWPPP?
- Runoff from a 0.5-inch rainfall event
- Water used to wash out concrete trucks (Correct answer)
- Groundwater infiltrating into a graded swale
- Runoff from an undisturbed forest buffer
Correct answer: Water used to wash out concrete trucks
Concrete washout water is a regulated non-stormwater discharge that must be identified in the SWPPP and managed to prevent discharge to waterways.
Question 3: A project site drains to an impaired water body listed on the state's 303(d) list. What additional SWPPP requirement typically applies?
- A separate stormwater permit is required for each discharge point
- Enhanced or additional BMPs must be implemented to address the specific pollutant causing impairment (Correct answer)
- No additional requirements apply if the site is under 5 acres
- The project must install an offline retention pond
Correct answer: Enhanced or additional BMPs must be implemented to address the specific pollutant causing impairment
When a site drains to a 303(d)-listed impaired water, most NPDES CGPs require the implementation of additional BMPs targeted at the pollutant causing the impairment.
Question 4: What is the significance of Section 303(d) of the Clean Water Act for stormwater inspectors?
- It establishes permit fees for industrial stormwater dischargers
- It requires states to list impaired waters and develop TMDLs for them (Correct answer)
- It sets numeric effluent limits for all construction discharges
- It authorizes EPA to conduct wetland delineations
Correct answer: It requires states to list impaired waters and develop TMDLs for them
Section 303(d) requires states to identify water bodies that don't meet water quality standards and develop Total Maximum Daily Loads (TMDLs) to restore them.
Question 5: A construction project operator fails to submit a required quarterly inspection report. Under the NPDES CGP, what is the most likely consequence?
- Automatic permit termination
- Civil penalties and potential enforcement action by the permitting authority (Correct answer)
- A warning letter with no further action
- Mandatory third-party environmental audit
Correct answer: Civil penalties and potential enforcement action by the permitting authority
Failure to submit required reports constitutes a permit violation and can result in civil penalties and enforcement actions under the Clean Water Act.
Question 6: What information is typically NOT required to be included in a stormwater inspection report?
- Date, time, and name of the inspector
- Weather conditions and rainfall amount since the last inspection
- The contractor's project profitability and budget data (Correct answer)
- Description of any BMPs that need maintenance or corrective action
Correct answer: The contractor's project profitability and budget data
Inspection reports document environmental conditions, inspector identity, BMP status, and corrective actions — financial or budget information is not part of regulatory reporting.
Question 7: Under the NPDES framework, what is a Total Maximum Daily Load (TMDL)?
- The maximum volume of stormwater a detention pond can hold
- The maximum amount of a pollutant a water body can receive and still meet water quality standards (Correct answer)
- The maximum daily runoff rate from a construction site
- The total sediment load allowed in a stream per season
Correct answer: The maximum amount of a pollutant a water body can receive and still meet water quality standards
A TMDL is the calculated maximum amount of a specific pollutant that a water body can receive while still meeting water quality standards, accounting for all sources.
CESSWI Regulatory Compliance & Reporting 4
During a routine inspection, an inspector discovers that a subcontractor is operating without being listed on the site's SWPPP.
What is the appropriate corrective action?