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CESSWI PART I Questions and Answers Graded A+

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CESSWI PART I Questions and Answers Graded A+ Types of Permitting Authority • NPDES states with general permitting authority • NPDES states with individual permitting authority • NPDES states with both general and individual permitting authority State-Specific Requirements • The states that have NPDES authority include their statespecific requirements in the general permits. • Individual permits can also contain state requirements within the individual (site-specific) permits • State requirements must be at least as stringent as federal requirements

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CESSWI PART I Questions and Answers
Graded A+

Types of Permitting Authority • NPDES states with general permitting authority


• NPDES states with individual permitting

authority

• NPDES states with both general and individual

permitting authority




State-Specific Requirements • The states that have NPDES authority include their state-

specific

requirements in the general permits.

• Individual permits can also contain state requirements within the

individual (site-specific) permits

• State requirements must be at least as stringent as federal requirements




U.S. EPA has three types of enforcement: • Administrative orders


• Civil actions

,• Criminal prosecutions




Notice of Violation (NOV) Common causes NOVs:


• Inadequate inspection reports

• Failure to implement the SWPPP (BMPs)

• Corrective actions not implemented

• Sediment-laden or polluted discharges




Administrative Orders • U.S. EPA can impose fines and penalties without court


action




Civil Penalties • U.S. EPA may bring civil suit without


administrative order

• Maximum penalty is $37,500 per violation

(per day) with no upper limit




Precon Meeting Objectives • Clarify the stormwater objectives


• Designate a contact person

,• Determine if the SWPPP will work for the

schedule, and work activities

• Ensure everyone reviews the SWPPP

• Remind everyone that BMPs are performance

based and could require change

• Conduct meeting onsite

• Verify schedules...

clearing, grading, stabilization, operational

activities, etc.

• Discuss maintenance requirements for controls

identified in SWPPP

• Discuss containment, storage and spill procedures

of on-site pollutants

• Establish open communication




Safety test question scapes, cuts, etc. sustained on-site must be treated and reported

immidiately

, MSDS MSDS should be included for all chemicals onsite




Note Taking Notes taken from the


inspection reflect the

conditions observed on

site.

• Be specific...facts not opinions

• Identify proper personnel

• Avoid vague terminology

• Record critical data




Pictures record area of site, direction, georeference photos


• Use video to capture motion

* May be used as evidence in legal proceedings




Good Reporting Practices Complete and factual records


• Support potential enforcement action

• Communicate with others

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