Introduction to Construction General Permit Inspections

Training Course Objectives

• This course is intended to assist construction site inspectors with the procedures for conducting a compliance inspection at construction sites.

Course Overview

• Introduction and Qualifications• Pre-Inspection Preparation• Construction Site Compliance Evaluation• Field Monitoring at Construction Sites• Compliance Inspection Reports• Compliance Inspection Data Management• Compliance Enforcement Activities

Overview of the Construction General Permit

• General Permit for Storm Water Discharges Associated with Construction and Land Disturbance Activities – Order no. 2009-0009-DWQ– Adopted on September 2, 2009– Effective on July 1, 2010

Activities Covered By CGP

• Any construction or demolition activity– Clearing– Grading– Grubbing– Excavation– Other activity that results in a land disturbance of one acre or

more

Activities Covered By CGP (cont.)

• Any construction or demolition activity that results in a land disturbance of:– one acre or more of soil; or– less than one acre if the construction activity is part of a larger

common plan of development or the sale of one or more acres of disturbed land surface

• Construction activity related to residential, commercial, or industrial development on lands currently used for agriculture including, but not limited to, the construction of buildings related to agriculture that are considered industrial pursuant to U.S. EPA regulations, such as dairy barns or food processing facilities.

Activities Covered By CGP (cont.)

• Construction activity associated with Linear Underground/Overhead Utility Projects (LUPs) including, but not limited to, those activities necessary for the installation of underground and overhead linear facilities and include, but are not limited to, underground utility mark-out, potholing, concrete and asphalt cutting and removal, trenching, excavation, boring and drilling, access road and pole/tower pad and cable/wire pull station, substation construction, substructure installation, construction of tower footings and/or foundations, pole and tower installations, pipeline installations, welding, concrete and/or pavement repair or replacement, and stockpile/borrow locations.

Activities Covered By CGP (cont.)

• Example LUPs– Conduits– Substructures– Pipelines– Towers– Poles– Cables

– Wires– Connectors– Switching– Regulating and transforming

equipment and associated ancillary facilities

Activities Covered By CGP (cont.)

• Discharges of sediment from construction activities associated with oil and gas exploration, production, processing, or treatment operations or transmission facilities

• Storm water discharges from dredge spoil placement that occur outside of U.S. Army Corps of Engineers jurisdiction (upland sites) and that disturb one or more acres of land surface from construction activity are covered by this General Permit. Construction sites that intend to disturb one or more acres of land within the jurisdictional boundaries of a CWA § 404 permit should contact the appropriate Regional Water Board to determine whether this permit applies to the site.

Training Course Overview

• Introduction and Qualifications• Pre-Inspection Preparation• Construction Site Compliance Evaluation• Field Monitoring at Construction Sites• Compliance Inspection Reports• Compliance Inspection Data Management• Compliance Enforcement Activities

Inspector Qualifications

• Completion of erosion and sediment control training from the Water Board Academy or other credible provider

• Completion of Qualified SWPPP Developer Training (CASQA course)– Overview of Regulations– Erosion Theory– SWPPP Implementation– Project Planning– Risk Determination– SWPPP Preparation– Project Close Out

• Supervised Field Experience (New Inspectors)

Continuing Education

• Inspectors should remain up to date with current practices– Attend presentations on “lessons learned” by another inspector– Stormwater training seminar sponsored by the State Water

Board Training Academy– Authoring a presentation on “lessons learned” on a particular

site of over a period of time– Participate in a “peer review” of completed inspection reports

and compliance issues– Develop a case study for use as SWRCB training materials

Overview of Pre-Inspection Preparation

• Review of PRDs– Notice of Intent– Risk Assessment– Site Map– Stormwater Pollution Prevention Plan (SWPPP)– Post Construction Water Balance Calculator– Active Treatment System Plan (if applicable)– Particle Size Analysis (if applicable)

• Assessment of site compliance history• Communications and logistics

Overview of Construction Site Compliance Evaluation

• Legal entry into construction sites• Pre-inspection opening conference• Review of onsite documentation• Construction site inspection procedures• Post inspection closing conference

Overview of Field Monitoring at Construction Sites

• Overview of field monitoring techniques that inspectors may need to perform in order to confirm compliance or document exceedances of NALs or violations of NELs

• The calibration and use of field equipment and sampling techniques are presented. The inspector should also be familiar with proper selection and location of representative sampling locations

Overview of Compliance Inspection Reports

• Provides guidance in writing inspection reports and providing sufficient documentation for enforcement actions

• Discusses when re-inspection and additional actions may be necessary after the initial site inspection

Overview of Compliance Inspection Data Management

• Outlines the inspector’s use of the Storm water Multi Application and Report Tracking System (SMARTS)

Overview of Compliance Enforcement Activities

• Provides the inspector with guidance on enforcement of the provisions in the CGP