Know Your Role
Go through the sections below.
Construction Site Inspectors and NPDES
The connection between construction site inspectors and NPDES is simple:
Construction activities generate sediment and other pollutants that may be discharged to waterways.
Municipal NPDES Permits require pollution prevention measures at construction sites, and enforcement actions when measures are not in place.
So the main role of construction site inspectors under the NPDES Program is to ensure pollution prevention measures are in place, and to compel compliance if they are not in place.
Construction Site NPDES Violations
The two main types of NPDES violations at construction sites are:
Illicit discharges of sediment or other construction wastes, and
failure to implement Best Management Practices (BMPs) to prevent stormwater pollution from sediment and other construction raw and waste materials.
An illicit discharge is a discharge of polluted water to the storm drain system. A stormwater BMP is any practice that prevents or reduces stormwater pollution.
Prohibiting NPDES Violations
NPDES regulations include procedures to prohibit NPDES violations. They include:
Identifying and eliminating the sources of active or potential illicit discharges, including overseeing clean-up if needed.
Identifying and requiring the timely correction of stormwater BMP deficiencies
Following up to ensure continued compliance, and enforcing if necessary.
Reporting results.
We will discuss these procedures. Your role implementing these procedures may vary, as noted below.
Your Role is Specific to Your Agency
The scope of your role in NPDES is determined by your Agency. Below are common examples where the NPDES responsibilities of construction site inspectors may be limited:
A separate NPDES inspector may be assigned to conduct NPDES inspections at construction sites.
NPDES at municipal construction projects might be handled by a Public Works Inspector, with a separate Building & Safety Inspector for private projects.
NPDES violations that occur on public property might be handled by an O&M division of Public Works.
Enforcement might be handled by Code Enforcement.
Even if your role does not involve NPDES, you should be trained in identifying NPDES violations during field visits to construction sites. If you are uncertain of your role, contact your supervisor.
You might ask: Which staff positions are the best fit for specific NPDES roles? This is also a decision specific to your Agency. Regulators are less concerned with the job titles of staff implementing the NPDES Program, and more concerned that a process is in place to ensure it is implemented.
