CSM Stormwater Regulations & Compliance 3 — Questions and Answers
Question 1: A municipality wants to discharge treated stormwater from a wet pond into a stream listed as impaired for phosphorus. Which additional requirement likely applies?
- A new Section 404 permit
- Compliance with the TMDL-derived wasteload allocation for phosphorus (Correct answer)
- An underground injection control permit
- A solid waste disposal permit
Correct answer: Compliance with the TMDL-derived wasteload allocation for phosphorus
Discharges to impaired water bodies must meet wasteload allocations established in the applicable Total Maximum Daily Load (TMDL).
Question 2: What does 'no exposure' certification allow certain industrial facilities to avoid?
- Preparing an emergency spill response plan
- Obtaining NPDES stormwater permit coverage (Correct answer)
- Installing secondary containment for chemicals
- Submitting annual toxics release inventory reports
Correct answer: Obtaining NPDES stormwater permit coverage
Facilities that can certify all industrial materials and activities are protected from stormwater contact (no exposure) may qualify for an exemption from NPDES industrial stormwater permit coverage.
Question 3: Under the Construction General Permit, how frequently must a qualified person conduct site inspections during active grading when there is no rain?
- Daily
- Every 7 calendar days
- Every 14 calendar days (Correct answer)
- Monthly
Correct answer: Every 14 calendar days
The EPA CGP requires routine inspections at least every 14 calendar days during active construction, with post-storm event inspections within 24 hours of a qualifying event.
Question 4: Which CWA section is the primary authority for establishing water quality standards that stormwater permits must achieve?
- Section 301
- Section 303 (Correct answer)
- Section 402
- Section 404
Correct answer: Section 303
CWA Section 303 requires states to establish water quality standards (designated uses + criteria) that serve as the basis for permit limits.
Question 5: A Phase I MS4 permittee must demonstrate 'maximum extent practicable' (MEP) pollutant reduction. How does MEP differ from technology-based effluent limits used for industrial dischargers?
- MEP is more stringent and requires numeric effluent limits
- MEP is a flexible standard that considers costs and technical feasibility rather than fixed numeric limits (Correct answer)
- MEP only applies to nutrient discharges
- MEP requires compliance within 90 days of permit issuance
Correct answer: MEP is a flexible standard that considers costs and technical feasibility rather than fixed numeric limits
MEP allows MS4s to implement cost-effective and technically feasible BMPs rather than meeting fixed numeric effluent limits, acknowledging the diffuse nature of stormwater.
Question 6: Which federal act requires municipalities to develop and implement stormwater management programs as a condition of receiving federal transportation funding?
- RCRA
- CERCLA
- Safe Drinking Water Act
- Clean Water Act Section 402 (NPDES) (Correct answer)
Correct answer: Clean Water Act Section 402 (NPDES)
The NPDES program under the CWA Section 402 is the primary federal driver for municipal stormwater programs, including those connected to transportation project funding conditions.
Question 7: A stormwater manager discovers a non-stormwater discharge (sanitary sewage) entering a storm drain. Under the MS4 permit, what is the required response?
- Issue a written warning to the discharger and monitor quarterly
- Investigate and eliminate the illicit discharge under the IDDE program (Correct answer)
- Report the discharge to FEMA within 30 days
- Apply for a combined sewer overflow permit
Correct answer: Investigate and eliminate the illicit discharge under the IDDE program
The Illicit Discharge Detection and Elimination (IDDE) minimum control measure requires MS4 permittees to find and eliminate non-stormwater discharges from their systems.
CSM Stormwater Regulations & Compliance 3
A municipality wants to discharge treated stormwater from a wet pond into a stream listed as impaired for phosphorus.
Which additional requirement likely applies?