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Water Quality Standards
State or tribal requirements that define the water quality goals of a water body by designating the beneficial uses and setting criteria to protect those uses
CWA Section 401
Regulates water quality impacts and state certification programs. Required for any permit or license issues by a federal agency for any activity that may result in a discharge to waters of the U.S.
CWA Section 402
Established NPDES in 1972 to control discharges from defined point sources. 1987 amendments included requirements for stormwater runoff.
CWA Section 404
Regulates impacts to waters of the U.S./ discharges of dredged or fill materials.
Key goals for NPDES Program Implementation
Reduce the discharge of pollutants to "maximum extent practicable"; protect water quality; satisfy requirements of CWA
Administrative Orders
-Class I Maximum is $16,000 per day with maximum of $37,500.
-Class II Maximum is $11,000 per day with a maximum of $177,500.
Civil Penalties
Maximum penalty is $37,500 per violation per day with no upper limit.
Criminal Penalties
-Negligent Violations: $2,500 to $25,000 per day per violation and/or 1 year in prison.
-Knowing Violations: $5,000 to $50,000 per day per violation and/or 3 years in prison.
-Knowing Engagement: $250,000 maximum and/or 15 years in prison.
NOV Common Causes
Inadequate inspection reports; failure to implement SWPPP/BMPs; corrective actions not implemented; sediment-laden or pollutant discharges.
Good Communications
Professional, courteous, impartial, consistent, honest and accurate
Precon Meeting Objectives
Clarify stormwater objectives; designate contact person; determine if SWPPP works with schedule/activities; ensure everyone reviews SWPPP; remind that BMPS could change; conduct meeting onsite; verify schedules; maintenance requirements for controls in SWPPP; containment, storage, and spill procedures of on-site pollutants; establish open communication.
What to do when Dealing with Difficult People
Act like a professional; clarify the issue; handle the problem immediately; allow the person to be part of the solution; agree on a solution; walk away if needed.
Note Taking Practices
-Be specific (facts not opinions)
-Identify proper personnel
-Avoid vague terminology
-Record critical data
-Initial and date all changes
-Use ink and marker, not pencil
-Store documentation in central location
Reporting Practices
-Complete and factual records
-Support potential enforcement action
-Communicate with others
-Document what you see (do not assume)
-Report what you observe on that day (snapshot in time)
-Make objective observations only
-Do not make personal observations about people
-Provide copy to appropriate party
The map is a living document and should...
-Be created to scale
-Be a tracking tool for BMP installation and locations throughout the life of the project
-Reflect actual site conditions at the time of the inspections
What to look for on a map
-Marked up drawings with changes, initials and dates
-Clearly defines legends, identified BMPs and their locations and date of installation
-Location of housekeeping controls
Complaint Resolution
-Follow through with all complaints/enforcement ASAP
-Respond appropriately to complaints (with documentation/photos)
-Document all response and info
Enforcement Resolution
-Ensure consistency with city, county, agency, regulations
-Ensure continuity of info
-Take thorough notes and pics
-Follow up with appropriate personnel
Roles of an Inspector
-Official rep on site
-Fact finder and record keeper
-Enforcement case developer
-Technical instructor
Skills of Good Inspector
Inquisitiveness; thoroughness; consistency; integrity; conflict resolution; communication
Components of Pre-inspection Site Review
-Documentation (accuracy, expiration dates, signatures and dates, posting requirements, regulatory visits and enforcement files)
-Important Contacts (name and info of owner, operator, contractors; emergency contacts; responsible party in case of enforcement)
What should you determine from the Erosion and Sediment Control Drawings (Pre-inspection)?
-Map contours
-Sensitive areas
-Critical areas
-Site perimeter
-Entrances and exits
What should you determine from the SWPPP (Pre-inspection)?
-Phasing measures and construction schedules
-Temp. stabilization measures
-Erosion, sediment, and stormwater measures
-Final stabilization measures
-Borrow materials and waste disposal areas
Industrial Site Review
-Verify that onsite drainage systems match approved plans and inspect for spills and discharges
-Storage and delivery areas (inspect for proper containment or cover)
-Processes associated with construction activities that may contribute pollutants
-Sampling requirements
Post Construction MS4 Site Review
-Review archived files for info such as as-built of GPS records of drainage systems
-The SWMP
-Verify inspection freqency
Inspector's Objectives
-Professional and courteous conduct
-Site compliance
-Thorough reporting
Components of Inspection Report
-Name and credentials
-Date
-Name and location of site
-Project key individual contact info
-Inspection frequency
-Rainfall data
-Weather and soil conditons
-Phase and type of construction
-BMPs operating condition and need for maintenance
-Evidence of discharges
-Corrective action report
-Signature and date
-Pictures
Sampling Process
-Collect samples
-Verify chain of custody
-Document collection methods of non visual pollutant samples
-Document sampling equipment and calibration
Proper Way to Fill Sample Bottle
-Avoid cross contamination
-Use clean and prepared bottles
-Know bottle types
-Stand downstream of sampling point
-Label bottles immediately
-Place samples in cooler with ice if needed
Sampling Constituents
-Turbidity
-pH
-Metals
-Hydrocarbons
-Toxicity
-Nutrients
-Others
SWPPP
Addresses operations that come in contact with stormwater/precipitation and the specific BMPs for reduction or elimination of pollutant discharges.
ESCP
Shows all required erosion and sediment controls including design, placement and details of BMPs.
Grading and Grading Plan
-Component of SWPPP
-Used for inspections of stormwater systems under MS4 requirements
-Sometimes combined with ESCP
SPCC
Details all spill prevention measures onsite, clean up, training requirements of staff, source control and good housekeeping BMPs.
SWMP
-Outlines 6 minimum control measures for Phase II municipalities
-Outlines all requirements of implementing a stormwater program at Phase 1 municipalities
-Details post construction inspection requirements and maintenance standards
Pollutants of Concern (all NPDES)
Sediment, turbidity, hydrocarbons-petroleum products, biological, nutrients, metals, pH, Solid waste, temp., hazardous/toxic waste, trash, construction materials handling, organics
SWPPP Amendments
-Changes in area of disturbance
-Inadequate or additional BMPs
-Other identified pollutants
-Changes in drainage area
-Post construction BMP changes
-Changes in project duration
Slope Percentage Equation
Slope %= (CL x CI)/MS