CESSWI SWPPP and Plan Management 5 — Questions and Answers
Question 1: Which of the following best describes 'final stabilization' as defined under the EPA Construction General Permit?
- All grading and earthwork has been completed
- All soil-disturbing activities are complete and a uniform perennial vegetative cover of at least 70% density is established, or equivalent non-vegetative cover (Correct answer)
- The site has received a certificate of occupancy
- All sediment basins have been removed from the site
Correct answer: All soil-disturbing activities are complete and a uniform perennial vegetative cover of at least 70% density is established, or equivalent non-vegetative cover
Final stabilization under the CGP requires that all earth disturbance is complete and vegetative cover of at least 70% density (or equivalent) is uniformly established across previously disturbed areas.
Question 2: During a routine SWPPP inspection after a 0.5-inch rainfall, no discharge was observed. The inspector should:
- Skip documenting the inspection since no discharge occurred
- Document inspection findings including the no-discharge observation and BMP conditions (Correct answer)
- Only inspect areas within 50 feet of receiving waters
- Reschedule the inspection for a larger rain event
Correct answer: Document inspection findings including the no-discharge observation and BMP conditions
All required inspections must be fully documented regardless of discharge conditions, including observations of BMP status and the no-discharge finding.
Question 3: A SWPPP requires inspections every 7 days and within 24 hours after a 0.25-inch rain event. During a week with two qualifying rain events, the minimum number of required inspections is:
- 2
- 3 (Correct answer)
- 4
- 1
Correct answer: 3
The two post-storm inspections (within 24 hours of each event) satisfy the weekly requirement if they occur within the 7-day interval, resulting in a minimum of 2 inspections for that week.
Question 4: Which element distinguishes a pollution prevention plan from a standard erosion control plan within a SWPPP?
- Pollution prevention plans include sediment basin design calculations
- Pollution prevention plans address non-sediment pollutants such as concrete washout, fuels, and chemicals (Correct answer)
- Pollution prevention plans are only required on sites over 10 acres
- Pollution prevention plans replace the need for BMPs
Correct answer: Pollution prevention plans address non-sediment pollutants such as concrete washout, fuels, and chemicals
Pollution prevention measures address non-sediment construction pollutants (fuels, concrete, paints, chemicals), while erosion control focuses on soil loss and sedimentation.
Question 5: Which scenario would most likely require an operator to obtain individual NPDES permit coverage rather than coverage under a Construction General Permit?
- A site disturbing exactly 1 acre with no downstream impaired waters
- A site with a history of permit violations and a significant potential for water quality harm (Correct answer)
- A site using a proprietary sediment control device
- A site that uses a phased grading approach
Correct answer: A site with a history of permit violations and a significant potential for water quality harm
EPA or a state agency may require individual permit coverage when a site poses a significant risk to water quality, such as a pattern of violations or proximity to sensitive resources.
Question 6: What role does the 'corrective action log' play in SWPPP management?
- It records changes to the permit fee schedule
- It documents deficiencies found during inspections, required repairs, responsible parties, and completion dates (Correct answer)
- It tracks daily equipment maintenance records
- It serves as the official notice of permit termination
Correct answer: It documents deficiencies found during inspections, required repairs, responsible parties, and completion dates
The corrective action log creates an auditable record of identified deficiencies, the actions required to correct them, and confirmation that repairs were completed within required timeframes.
Question 7: A SWPPP is prepared for a site but a large rain event causes significant sediment discharge before all BMPs are installed. The most appropriate regulatory response from the permitting authority is:
- Automatic permit revocation
- Assessment of potential permit non-compliance and possible enforcement action (Correct answer)
- Mandatory SWPPP revision within 48 hours
- Issuance of a variance for weather-related events
Correct answer: Assessment of potential permit non-compliance and possible enforcement action
A discharge caused by BMPs not being in place before disturbance is a permit non-compliance event and may result in enforcement action; weather does not automatically excuse the violation.
Which of the following best describes 'final stabilization' as defined under the EPA Construction General Permit?