Introduction to Construction General Permit InspectionsPre-Inspection Preparation

Pre-Inspection Preparation

• Review of Permit Required Documents• Assessment of Compliance History• Communications and Logistics

Permit Required Documents

• Notice of Intent (NOI)• Risk Assessment • Site Map• Storm Water Pollution Prevention Plan• Annual Fee• Signed Certification Statement• Post-Construction Water Balance Calculator Results• Complete Active Treatment System Plan• Certification of Proof that ATS design was completed by a

Certified/Licensed Professional• Particle Size Analysis

Notice of Intent

• The following should be included in an NOI:– WDID - The facility identification number or WDID number is the

number the SWRCB gives each permittee when they apply for an NOI.

– Risk Level– Property Owner Information

• including name• Address• contact information.

– Contractor/Developer Information• including name• Address• contact information.

Notice of Intent (cont.)

• The following should be included in an NOI:– Construction Site Information

• Address• site contact information• Coordinates• construction area size• Schedule• type of construction site• QSD information.

– Certification Information• Name of certificate holder• Title of certificate holder

Risk Assessment

1. Determine Sediment Risk2. Determine Receiving Water Risk3. Determine Combined Risk Level

Risk Assessment – Sediment Risk

• Determine Sediment Risk using one of the methods listed:– GIS Map Method using EPA Rainfall Erosivity Calculator

and GIS Maps provided in SMARTS– Individual Method using EPA Rainfall Erosivity Calculation

and Site Specific Data

Risk Assessment – Receiving Water Risk

• Determine Receiving Water Risk using one of the methods listed:– GIS map of Sediment Sensitive Watersheds provided

SMARTS– Site Specific analysis based on Regional Board Basin Plans

and the State Water Board 303d list of impaired waterbodies

Site Map

• A site map should include the following:– The project’s surrounding area (vicinity) – Site layout – Construction site boundaries – Drainage areas – Discharge locations – Sampling locations – Areas of soil disturbance (temporary or permanent) – Active areas of soil disturbance (cut or fill) – Locations of all runoff BMPs

Site Map (cont.)

• A site map should include the following:– Locations of all erosion control BMPs – Locations of all sediment control BMPs – ATS location (if applicable) – Locations of sensitive habitats, watercourses, or other

features which are not to be disturbed – Locations of all post-construction BMPs – Locations of storage areas for waste, vehicles, service,

loading/unloading of materials, access (entrance/exits) points to construction site, fueling, and water storage, water transfer for dust control and compaction practices

Storm Water Pollution Prevention Plan

• The SWPPP should be project specific and should be developed by a Qualified SWPPP Developer (QSD)

• The amount of detail included in the SWPPP is dependent upon the project risk level

• The inspector should compare the PRDs to the information included in the SWPPP document

Storm Water Pollution Prevention Plan

• SWPPPs should address the following:– All pollutants and their sources– All non-storm water discharges not already permitted– All site BMPs addressing storm water discharges and

authorized non-storm water discharges– Any calculations and design details– All stabilization BMPs

Annual Fee

• In order to obtain permit coverage, an annual fee must be submitted to the SWRCB

• The inspector can verify that the discharger paid the necessary fee on SMARTS

Signed Certification Statement

• The signed certification statement is a signed document stating that the PRDs were:– Prepared under the direction or supervision of the Legally

Responsible Person (LRP), and– The information submitted is true, accurate, and complete.

Post Construction Water Balance Calculator

• The Post Construction Water Balance Calculator must be completed by dischargers in unincorporated areas of the State – areas not already subject to post-construction standards of an

active Phase I or II municipal separate storm sewer system (MS4) permit that has an approved Storm Water Management Plan

• There are two parts of the Post Construction Water Balance Calculator– Map portion – Worksheet portion

Post Construction Water Balance Calculator (cont.)

• The map portion should show a topographic map of the site with pre- and post-construction information

• The map should be easily readable with an appropriate scale• Note the locations where the construction project will result

in slope increases from existing slope– Results should be consistent with the areas reported in the

spreadsheet section of the calculator• Note the locations where impervious surfaces are added to

the site– Results should be consistent with the areas reported in the

spreadsheet section of the calculator.

Post Construction Water Balance Calculator (cont.)

• The worksheet section of the calculator is meant to show the projected increase of runoff from the site and determine methods to mitigate the increase in runoff

• The worksheet allows credits for the following:– Runoff Volume Reduction Credit– Runoff Volume Reduction

• Each of these credits has its own tab which should be checked for accuracy by the inspector

• A majority of the tabs contain yes/no questions which can be easily confirmed by reviewing the site plan

• Some tabs (such as pervious pavement) require an area calculation.

Post Construction Water Balance Calculator (cont.)

• Runoff Volume Reduction Credit– Porous Pavement– Tree Planting– Downspout Disconnection– Impervious Area Disconnection– Green Roof– Stream Buffer– Vegetated Swales

• Runoff Volume Reduction– Rain Barrels/Cisterns– Landscape Soil Quality

Active Treatment System Plan

• An Active Treatment System Plan is required for all projects implementing ATS

• All plans should include (Page 2 of Appendix F of CGP):– ATS Operation and Maintenance Manual for All Equipment– ATS Monitoring, Sampling & Reporting Plan, including Quality

Assurance/Quality Control (QA/QC)– ATS Health and Safety Plan– ATS Spill Prevention Plan– Active Treatment Systems shall include the following treatment

processes (Appendix F of the CGP):– Treatment - Coagulation and Flocculation– Filtration

Active Treatment System Plan

• Appendix F provides the permit requirements to which Active Treatment Systems should conform

• The ATS will be based on design storm assumptions– The inspector should verify whether the assumptions are

reasonable • the compliance storm event is the 10 year, 24 hour storm

determined by maps provided in Appendix F of the CGP

Active Treatment System Plan

• The inspector should pay particular attention to the ATS Operation and Maintenance Plan and ATS monitoring proposed by the Discharger – ATS require continuous monitoring

• During site inspections, the inspector should confirm that the Operation and Maintenance plan and monitoring are being conducted properly.

Active Treatment System Plan

• The inspector should verify that any ATS system is designed and approved by:– Certified Professional in Erosion and Sediment Control(CPESC)– Certified Professional in Storm Water Quality (CPSWQ)– California registered civil engineer– any other registered engineer”

• The certification of proof should indicate the qualifications of the designer.

• The inspector should verify that personnel operating any ATS system have completed training consistent with the minimum requirements in Attachment F, page 7 of the CGP– Upon request, operators should provide certificate copies.

Particle Size Analysis

• Dischargers who are proposing an Alternate Risk Justification are also required to submit a Particle Size Analysis as part of the PRD submittal.

Assessment of Site Compliance History

• Review previous inspections conducted on the construction site

• Review the compliance actions taken in response to a previous visit

• Note any issues with the site that may have been noted but did not require a compliance action

• The inspector should consider what actions were taken by the Discharger to correct the historical issues.

Communications and Logistics

• Inspectors may conduct announced or unannounced inspections of construction sites

• Unannounced inspections are preferred, but if an Inspector chooses to conduct an announced inspection, 24 hours of notice is appropriate

• Inspectors can communicate with the Discharger to ask for clarification of permit required documentation.

• If some of the permit required documentation is lacking, the inspector may request submittal of additional information.

Coordination with Other Agencies

• Inspectors are encouraged to coordinate with other oversight agencies to avoid duplicate inspections

• Possible Agencies include:– Regional Water Quality Control Board(s)– State Water Resources Control Board– U.S. Environmental Protection Agency– Authorized representative of the municipal operator of the MS4

storm system receiving discharge