CPESC Permit Requirements 4 — Questions and Answers
Question 1: In the context of NPDES permitting, what does a 'common plan of development or sale' include?
- Only projects owned by the same legal entity
- Any contiguous area where multiple separate and distinct land disturbance activities may be taking place at different times on different schedules (Correct answer)
- Projects that share the same contractor
- Only projects within the same tax parcel
Correct answer: Any contiguous area where multiple separate and distinct land disturbance activities may be taking place at different times on different schedules
A common plan of development includes any contiguous area where multiple separate land disturbance activities may occur at different times, regardless of ownership.
Question 2: Which of the following is typically required to be included in a SWPPP for a construction site?
- A contractor payment schedule and bonding information
- Site map, BMP descriptions, inspection procedures, and responsible party contact information (Correct answer)
- Architectural drawings and structural engineering calculations
- Soil boring logs and geotechnical reports only
Correct answer: Site map, BMP descriptions, inspection procedures, and responsible party contact information
A SWPPP must include a site map, descriptions of BMPs, inspection schedules, and identification of responsible parties for BMP implementation and maintenance.
Question 3: When a construction project crosses state lines, which permitting approach is correct?
- Only one state permit is needed from the state where most disturbance occurs
- Permit coverage must be obtained from each state where land disturbance occurs (Correct answer)
- A federal permit from EPA headquarters supersedes state permits
- No permit is needed because federal projects are exempt
Correct answer: Permit coverage must be obtained from each state where land disturbance occurs
Construction activities must obtain NPDES permit coverage from each state where land disturbance occurs, as each state administers its own program.
Question 4: What is a key difference between an Individual NPDES Permit and a General Permit for construction stormwater?
- Individual permits are issued by local governments; general permits are issued federally
- Individual permits are site-specific and negotiated; general permits cover a broad category of similar activities (Correct answer)
- General permits require more stringent conditions than individual permits
- Individual permits do not require a SWPPP
Correct answer: Individual permits are site-specific and negotiated; general permits cover a broad category of similar activities
Individual permits are tailored to a specific facility's conditions, while general permits establish standardized conditions for a category of similar activities like construction stormwater.
Question 5: A SWPPP must be amended when which of the following occurs?
- The project manager takes a vacation
- There is a change in design, construction, operation, or maintenance that may affect BMP effectiveness (Correct answer)
- The permit is renewed at the annual anniversary date
- A new subcontractor is added to the project regardless of their scope of work
Correct answer: There is a change in design, construction, operation, or maintenance that may affect BMP effectiveness
The SWPPP must be updated whenever project changes could affect the discharge of pollutants or the effectiveness of installed BMPs.
Question 6: What is the primary purpose of requiring electronic NOI submission in many state NPDES programs?
- To reduce paper costs for the permitting agency
- To improve data tracking, reduce processing time, and enable real-time permit coverage confirmation (Correct answer)
- To allow contractors to bypass engineering review
- To eliminate the need for site inspections
Correct answer: To improve data tracking, reduce processing time, and enable real-time permit coverage confirmation
Electronic NOI systems improve data management, reduce processing time, and provide instant or near-instant permit coverage confirmation for operators.
Question 7: Under NPDES regulations, who qualifies as a 'co-permittee' on a construction site?
- Any licensed engineer who stamps the SWPPP
- A municipality or other operator who participates in the construction activity and shares responsibility for compliance (Correct answer)
- The surety company that bonds the project
- Only the property owner, never the contractor
Correct answer: A municipality or other operator who participates in the construction activity and shares responsibility for compliance
A co-permittee is an entity that participates in the permitted activity and shares joint responsibility for NPDES permit compliance.
CPESC Permit Requirements 4
In the context of NPDES permitting, what does a 'common plan of development or sale' include?