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