CESSWI Site Inspection Procedures 5 — Questions and Answers
Question 1: What is the correct procedure when an inspector discovers a previously unidentified discharge point that is not addressed in the SWPPP?
- Ignore it if no active discharge is occurring at the time of inspection
- Document the new discharge point and require the SWPPP to be updated to address it (Correct answer)
- Install a BMP at the location without updating the SWPPP
- Notify only the state agency and take no site-level action
Correct answer: Document the new discharge point and require the SWPPP to be updated to address it
Unidentified discharge points must be documented and the SWPPP must be amended to address all actual discharge locations from the site.
Question 2: A CESSWI inspector is reviewing a site where the buffer zone between a stockpile and a stream has been reduced by additional grading. What is the priority concern?
- Loss of the designated equipment staging area
- Increased risk of sediment entering the stream due to reduced setback distance (Correct answer)
- Potential violation of property boundary setback requirements
- Reduction in available topsoil storage volume
Correct answer: Increased risk of sediment entering the stream due to reduced setback distance
Reduced buffer distance between disturbed soil and a waterway significantly increases the risk of sediment transport to the stream, which is the primary erosion control concern.
Question 3: When an inspector notes a 'repeat deficiency' — the same BMP failure found at a previous inspection — what additional documentation step is required?
- No additional steps; document as a new deficiency
- Reference the prior inspection report finding and note the extended non-compliance period (Correct answer)
- Automatically escalate to a regulatory agency notification
- Issue a formal stop-work order for the entire site
Correct answer: Reference the prior inspection report finding and note the extended non-compliance period
Repeat deficiencies must reference the prior inspection finding to document the duration of non-compliance and demonstrate a pattern, which strengthens enforcement actions if needed.
Question 4: What weather condition is used to trigger a required post-storm inspection event under the EPA CGP?
- Any measurable rainfall, regardless of amount
- A storm event that results in a discharge from the site
- A storm event of 0.25 inches or greater within a 24-hour period (Correct answer)
- A storm resulting in visible erosion anywhere on the site
Correct answer: A storm event of 0.25 inches or greater within a 24-hour period
The EPA CGP requires post-storm inspections after storm events that produce 0.25 inches or more of precipitation within a 24-hour period.
Question 5: During a linear construction project (pipeline or road), how are inspection locations typically determined?
- Only at the project endpoints and the midpoint
- At each active work area, disturbed area, and discharge location along the corridor (Correct answer)
- At fixed intervals of every 1,000 feet regardless of site conditions
- Only where BMPs have been previously installed
Correct answer: At each active work area, disturbed area, and discharge location along the corridor
Linear projects require inspections at each active work area, all disturbed areas, and every discharge location along the entire corridor, not just fixed intervals.
Question 6: An inspector observes concrete washout waste that has been discharged to a drainage channel rather than the designated washout area. How should this be classified?
- Minor housekeeping violation with no environmental significance
- A significant non-compliance requiring immediate corrective action due to high pH and toxicity risk (Correct answer)
- An acceptable practice if the concrete slurry has partially dried
- A deficiency only if the discharge reaches a navigable waterway
Correct answer: A significant non-compliance requiring immediate corrective action due to high pH and toxicity risk
Concrete washout discharged outside designated areas is a significant non-compliance because concrete slurry has a very high pH that is acutely toxic to aquatic life.
Question 7: Which of the following best describes the 'corrective action deadline' field on a site inspection report?
- The date the inspector will return for a follow-up inspection
- The date by which the contractor must address a noted deficiency to restore compliance (Correct answer)
- The deadline for submitting the inspection report to the regulatory agency
- The expiration date of the current NPDES permit coverage
Correct answer: The date by which the contractor must address a noted deficiency to restore compliance
The corrective action deadline specifies when the contractor must fix a noted deficiency, and it must be reasonable given the severity and weather forecasts.
CESSWI Site Inspection Procedures 5
What is the correct procedure when an inspector discovers a previously unidentified discharge point that is not addressed in the SWPPP?