Introduction to Construction General Permit Inspections

1. Introduction to Construction General Permit Inspections Construction Site Compliance Evaluation

2. Legal Entry Into Construction Sites Inspectors may enter any site which is regulated under the general permit Inspectors should be familiar with the inspection and entry provisions of the CGP which are included in the Order # 2009-0009-DWQ NPDES NO. CAS000002 under Item IVSpecial Provisions H. Inspection and Entry Inspectors should choose reasonable times to conduct inspections and allow themselves sufficient time to conduct the inspection Reasonable times are periods when the construction site is active

3. Legal Entry Into Construction Sites (cont.) The discharger shall allow the Regional Water Board, State Water Board, U.S. EPA, and/or, in the case of construction sites which discharge through a municipal separate storm sewer, an authorized representative of the municipal operator of the separate storm sewer system receiving the discharge, upon the presentation of credentials and other documents as may be required by law, to: Enter upon the discharger’s premises at reasonable times where a regulated construction activity is being conducted or where records must be kept under the conditions of this General Permit;

4. Legal Entry Into Construction Sites (cont.) Access and copy at reasonable times any records that must be kept under the conditions of this General Permit;  Inspect at reasonable times the complete construction site, including any off-site staging areas or material storage areas, and the erosion/sediment controls; and Sample or monitor at reasonable times for the purpose of ensuring General Permit compliance

5. Legal Entry Into Construction Sites (cont.) Upon entering a site the inspector should: Introduce themselves Ask to meet with the QSP Provide identification indicating that the inspector is an employee of the Regional Water Quality Control Board, State Water Resources Control Board, the U.S. Environmental Protection Agency, or authorized representative of the municipal operator of the storm system receiving discharge 

6. Legal Entry Into Construction Sites (cont.) Upon entering a site the inspector should ask for consent to: Conduct an inspection Take original or copies of documents Take photos Take samples

7. Legal Entry Into Construction Sites (cont.) If entry into the construction site is denied, the Inspector should: Thoroughly document any reasons provided for denial In no case should inspectors attempt to conduct an inspection if they feel threatened or that their personal safety may be in jeopardy Communicate that the Executive Officer of the Regional Water Quality Control Board will be notified regarding the denial of entry and that the inspector may obtain an inspection warrant  for entry with a law enforcement officer to inspect the premises and records Inspectors should immediately contact their manager(s) to inform them of the specifics of any situation resulting in denial of entry 

8. Pre-Inspection Opening Conference Once the inspector has gained access to the site, the inspector should request to have a brief initial conference with the QSP onsite The QSP may request to have the construction manager and site engineer or other onsite representatives present During the opening conference, the inspector should interact with the QSP to the extent possible

9. Pre-Inspection Opening Conference (cont.) The inspector should ask for introductions and be very cognizant of the roles (if any) of the other representatives relative to their ability to represent the facility’s compliance with the CGP For example, if the QSD is onsite, the inspector might consider their input relative to compliance issues If representatives are present who do not have a legally defined role relative to the CGP compliance, the inspector should tactfully confirm any information they provide through the QSP or QSD

10. Pre-Inspection Opening Conference (cont.) Some appropriate questions and conversation starters to obtain general information about the site and people working on the site include: Provide an overview of this construction project. What are your responsibilities at this location? What is your background or experience prior to working here? How long have you been working here? How long has construction been taking place? Has work been progressing as scheduled? Why or why not?

11. Pre-Inspection Opening Conference (cont.) Some appropriate questions and conversation starters to obtain general information about the site and people working on the site include: How has sampling been going? Describe the basics of your REAP and SWPPP. Have there been any storm water concerns? Have you encountered any problems with your BMPs? Answers to these questions may verify, contradict, or indicate inconsistencies in statements included in the onsite documentation or may give clues as to the QSPs understanding of these documents.

12. Pre-Inspection Opening Conference (cont.) During the opening conference, the inspector should inform the QSP that this is an inspection for the Regional Water Quality Control Board (or other qualified agency) and provide a brief inspection plan of action and describe any associated activities (e.g., sampling, photography) that the inspector will be performing onsite  The inspector should ask the QSP about site safety procedures and any other site concerns At busy construction sites the inspector should coordinate with the site’s QSP to minimize safety hazards associated with construction traffic and controlled access areas  

13. Review of Onsite Documentation The determination to conduct additional review of the documentation should be based on whether the inspector identifies problems or potential violations warranting further investigation   Inspectors may elect to collect documents, as originals or copies, for review at a later time All documents collected during the inspection should be noted as collected evidence If copies are not available, the inspector may take photographs of important documents for review

14. Review of Onsite Documentation All PRD’s submitted to the RWQCB should also be readily available onsite. The Inspector should verify that all of the following are included onsite: Storm Water Pollution Prevention Plan (SWPPP) – one of the PRDs Self-monitoring data and reports Visual Inspection Log Corrective Actions Log Spill Response Plan (located in the SWPPP) Rain Event Action Plans Construction Site Monitoring Program (located in the SWPPP)

15. Visual Inspection Logs All construction sites should have a readily available visual inspection log The visual inspections logs are a critical component in maintaining site compliance with the CGP since this allows the QSP to proactively identify and correct deficiencies before they cause offsite discharges

16. Visual Inspection Logs (cont.) Inspectors should confirm that the visual inspection logs should include the following: Site information including stage of construction completed activities approximate area of each drainage area. Visual observations including Odors floating materials suspended materials Sheens Discolorations Turbidity.

17. Visual Inspection Logs (cont.) Inspectors should confirm that the visual inspection logs should include the following: Personnel performing the inspections Weather conditions current and predicted (i.e. for pre-event inspections) Outfall or BMP locations inspected Corrective actions taken and SWPPP or REAP changes required The inspector should target subsequent site inspections to include those areas that where the visual inspections log indicates an observed discharge or BMP deficiency

18. Corrective Actions and Follow-Up Records Construction sites should maintain records of the corrective actions and follow-ups resulting from visual inspection or other monitoring The corrective actions records may be included with the visual inspection log Construction site may have a separate log The inspector should confirm that corrective actions and follow-ups were implemented in timely and complete manner and these actions are properly documented in the onsite records.

19. Spill Response Plan All construction sites should have a spill response element of the SWPPP, even if it only applies to sanitation facilities The inspector should review the spill response and implementation element of the SWPPP and confirm that: proper procedures are in place clean up materials and equipment are available on site appropriate spill response personnel are assigned and trained The spill response plan should cover any spill including, but not limited to, sanitation facilities, hazardous waste, and other liquid streams generated at the construction site.

20. Rain Event Action Plans Risk levels 2 and 3 construction sites are required to develop a REAP for all stages for construction and within 48-hours of a likely precipitation event A paper copy of the REAP should be onsite and implementation initiated no later than 24 hours prior to a likely precipitation event

21. Rain Event Action Plans The inspector should verify that the QSP has developed a REAP for previous and upcoming storm events REAPs are being developed and disseminated for inactive construction sites Each trade or activity has been properly notified and responded to the actions suggested in the REAP

22. Rain Event Action Plans REAPs should include the following: Site Information and risk level Predicted probability of rain Site storm water manager information Name Company 24-hour emergency telephone number Erosion and sediment control provider information Name Company 24-hour emergency telephone number

23. Rain Event Action Plans REAPs should include the following: Storm water sampling agent Name Company 24-hour emergency telephone number Current phase of construction site activities Trades active on the construction site during each construction phase and CGP related training or other information provided to trade contractors Trade contractor information Suggested actions to perform or items to inspect prior to rain event

24. Construction Site Monitoring Program Risk levels 2 and 3 construction sites are required to have a Construction Site Monitoring Program Inspectors should verify the Construction Site Monitoring Program (CSMP) is maintained onsite The construction site monitoring program can be found as an appendix to the SWPPP documentation The inspector should verify that the site is in compliance with its own CSMP The inspector should complete the CSMP checklist .

25. Self-Monitoring Data and Reports Self-monitoring data and reports should be kept onsite for three years Self monitoring data should include: General information Date Time weather conditions General site conditions Sampling conducted samples taken sample locations sample types name of the person conducting the sampling

26. Self-Monitoring Data and Reports Self-monitoring data and reports should be kept onsite for three years Self monitoring data should include: Lab information Laboratory used Results for storm related and non-storm related discharges Rain gauge readings of storm events Uncontaminated samples from the site

27. Uncontaminated Sample An uncontaminated sample is one which has not come in contact with the disturbed soil or any materials stored or used onsite Protected vegetation areas are a good source of uncontaminated samples upstream side of a construction site near the site perimeter (normally there is a buffer area near the perimeter of the construction site which will not be disturbed) The inspector should confirm that sample location of the uncontaminated sample is not in the active areas of the construction site when conducting the site walkthrough.

28. Required Self Monitoring

29. Risk Level 2 NALs

30. Risk Level 3 NALs and NELs

31. Construction Site Inspection Procedures While onsite, the inspector will be required to inspect many different attributes of the construction site. These attributes are broken into the following categories: Offsite Problems Good Site Management Point in Time BMP inspections Review of Effluent Monitoring Locations and Sampling Procedures Upon completion of the inspection, the inspector will be required to determine whether the discharger is in compliance with their permit.

32. Field Documentation and Photos    Proper documentation of the inspection is important, especially for justification of enforcement actions related to BMP problems. The inspector should take detailed notes during the site inspection. Photographs should be taken to document: offsite impacts Ineffective perimeter controls Ineffective BMP’s Improperly covered inactive areas Final stabilization areas site diversions

33. Field Documentation and Photos    Inspector should keep scale in mind while taking photographs A good method to show scale is to place an object of known size in the photograph The date and time of photographs should be accurate to increase credibility of photographs should they be examined in an enforcement action at a later date The inspector should retain the original copy of all photographs taken on an inspection, as altered photographs cannot be used as evidence It is especially important to not delete erroneous photographs as photographs missing from a sequence may be construed as bias or hidden evidence in the case of an enforcement action

34. Offsite Problems Note any problems offsite which are caused by discharges from the construction site Confirm that all discharge locations from the construction site have been correctly identified in the SWPPP and during visual monitoring Verify that there are adequate controls at all discharge points and adequate controls upslope/upgradient from the discharge location

35. Offsite Problems Typical offsite problems may include: Observable sedimentation Evidence of discharges off the construction site. Plumes or sheens in downstream flows clearly originating from the site If offsite problems exist, the inspector should attempt to determine the source and extent of the problem

36. Good Site Management Practices Good Site Management Practices are methods to manage construction sites which help reduce pollutant creation on the construction site Good Site Management can be categorized as follows: Construction Materials Waste Management Vehicle Storage Landscape Materials Potential Pollution Sources

37. Good Site Management – Construction Materials Verify that the construction site has a complete inventory of construction site products in use which may cause or contribute to discharges Verify the locations of the inventoried construction site products Stockpiles and other loose materials or equipment that is not being actively used should be properly covered and bermed All construction materials not designed for outdoor exposure should have minimal exposure to the elements Chemicals should be stored in watertight containers and have proper secondary containment at their storage locations

38. Good Site Management – Waste Management The site should have proper washout areas, especially for concrete Confirm that any rinse or wash waters are properly collected and disposed of Sanitation facilities should be properly bermed and maintained Look for sanitation facilities which are too close to storm drains look for liquid near sanitation facilities because this is a good indication of a leak

39. Good Site Management – Waste Management Confirm that all waste disposal containers have covers which can be deployed at the end of each day and during rain events and properly contained to prevent discharges to the storm water drainage system look for liquid near sanitation facilities because this is a good indication of a leak Confirm that stockpiled waste materials are contained and securely protected from wind and rain at all times.

40. Good Site Management – Vehicle Storage Construction site vehicles should have a designated storage and maintenance area which is fitted with appropriate BMPs to prevent oil, grease, or fuels to leak into the ground, storm drains, or surface waters Confirm that designated vehicle storage area has proper equipment to clean up leaks of oil, grease, and fuel from reaching the storm drain system Reference the spill response element of the SWPPP when inspecting vehicle storage areas

41. Good Site Management – Landscape Material Landscaping material includes: Fertilizers Plants Mulches other temporary landscape stabilization materials All landscaping materials stored onsite should have proper containment and storage

42. Good Site Management – Landscape Material Verify that the discharger is applying erodible landscaping materials properly and stacking or covering un-used erodible landscape material The inspector should review the REAPs and look for physical evidence that the discharger discontinues the use of erodible landscape material before a storm event (minimum of two days before the storm event).

43. Good Site Management – Potential Pollution Sources The construction site should maintain a list of potential pollution sources Normally found with the SWPPP documentation The inspector should review this list and determine that proper BMPs are in place to prevent these pollution sources from reaching the storm drain system or receiving waters

44. Best Management Practices Inspection Note the condition of storm water BMP’s currently in place Evaluate their conformance with the specifications Evaluate their conformance with design criteria outlined in the SWPPP Verify that the BMPs are appropriately installed and maintained In general, BMPs should be in place for the following potential discharges: Non-Storm Water Management Erosion Control Sediment Control Run-on/Run-off Control

45. BMPs – Non-Storm Water Management The inspector should confirm that non-storm water management measures are properly installed and maintained to prevent non-storm water related discharges Simple management practices that accomplish this include: cleaning local streets affected by the construction site on a regular basis Recovering vehicle washwater Inspectors should verify that the construction site is in compliance with the SWPPP documentation and is preventing any non-storm water related discharges to surface waters or a MS4 drainage system.

46. BMPs – Erosion Control The inspector should confirm that effective erosion control measures are deployed to prevent erosion from wind or storm water runoff at the construction site Effective soil covers should be in place for any location with erosion potential including: inactive areas (currently has no construction activity) finished slopes utility backfill completed lots

47. BMPs – Erosion and Sediment Control The inspector should encourage the use of environmentally friendly soil covers and minimizing the use of plastic cover materials If used, the inspector should confirm that plastic covers are resistant to UV degradation Verify that the soil covers recommended in the SWPPP are deployed at the site

48. BMPs - Sediment Control The inspector should confirm that effective sediment control measures including Proper perimeter controls Construction site entrance/exit stabilization The inspector should confirm that sediment basins are designed according the CASQA Construction BMP Handbook

49. BMPs – Sediment Controls Risk Levels 2 & 3 The sediment control measures should be used in conjunction with erosion control measure to best manage onsite sediment generation Inspectors should confirm the following: Linear Sediment Controls (i.e. coir logs) Linear Sediment control measures are incorporated on slopes, usually in the form of coir logs or other types of slope barriers Linear sediment control measures should be in place at the toe of the slope, at grade breaks, and the face of the slope. Spacing of linear control measures should be 10 to 20 feet based on the slope percentage. Inspectors should look for damage to slope protection measures.

50. BMPs – Sediment Controls Risk Levels 2 & 3 Inspectors should confirm the following: Storm drain entrances are properly protected and maintained, especially near construction entrance/exits. Perimeter controls, runoff controls, and pollution controls are in place, protected, and maintained, especially near construction entrance/exits. Construction traffic is limited to properly controlled entrances/exits. Access roads are inspected daily and prior to rain event per REAP The discharger is required to remove sediment and other construction debris deposited on the road.