QSP Confronts a Missing BMP, No Sampling Kit, and an Open Drum Before Rain
You are the Qualified SWPPP Practitioner (QSP) on an 8-acre California construction site covered under the Construction General Permit. The Qualified SWPPP Developer (QSD) prepared the SWPPP. A 0.3-inch rain event is forecast in 18 hours. During your inspection you find: the SWPPP lists a vegetated swale as a perimeter BMP, but the swale was never built; the sampling schedule says "sample when discharge occurs," but no sampling kit is on site and no one has been trained to use one; the concrete washout is uncovered; and a subcontractor has a 55-gallon drum of form release oil open about 20 feet from a catch basin. The project has an active notice of intent, and the site drains toward a municipal storm drain. The superintendent says the swale is "on the punch list" and asks whether the drum can wait until the environmental consultant visits next week.
1. Identify which deficiencies must be corrected before the forecast rain and which can wait for a formal SWPPP amendment. Explain the QSD/QSP division.
Read the worked answer
Before rain, correct the conditions that can discharge pollutants in the next 18 hours:
- Close and move the open drum. Twenty feet from a catch basin is an imminent spill pathway. This is not a wait-for-consultant item.
- Cover or contain the concrete washout. Washout water is alkaline and the site drains to a municipal storm drain.
- Establish an equivalent perimeter control for the missing swale, such as silt fence or a temporary berm, before runoff reaches the storm drain.
The missing swale also requires a SWPPP amendment because the design BMP was not built. The QSD prepares or amends the SWPPP; the QSP implements it and reports deficiencies. The QSP should not unilaterally rewrite the SWPPP, but the QSP must not let a paper BMP substitute for a field control. Notify the QSD immediately, request an amendment, and install interim controls. The drum and washout are immediate corrections; the swale is both an immediate interim control and an amendment issue.
2. The sampling schedule says "sample when discharge occurs" and no kit is on site. What do you do before the rain?
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Treat the schedule as incomplete for operational purposes. Before rain:
- Obtain the sampling kit specified by the SWPPP and the permit, or confirm in writing that no discharge is expected and document the basis.
- Identify who will sample, when, and where. "When discharge occurs" is not a trigger a field crew can act on at 2 a.m.; define the visual observation point and the response window.
- Train the designated sampler on the kit, the preservation method, the labeling, and the chain-of-custody.
- Verify that the kit is stored where it will be accessible during the storm, not locked in an office.
If the kit cannot be obtained before the rain, document the gap, notify the QSD and owner, and establish a visual monitoring and photo log. Do not fabricate sampling or record a sample that was not taken. The judgment is to convert an ambiguous permit requirement into an executable field procedure while preserving the record of what was and was not possible.
3. What records and notifications should exist by the end of the day?
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By the end of the day, the file should contain:
- A dated inspection report identifying each deficiency, its location, the SWPPP provision affected, and the corrective action required.
- A corrective-action log with responsible parties and deadlines, including the drum, washout, and interim perimeter control.
- Photo documentation of the open drum, the catch basin, the washout, and the swale location.
- A notification to the QSD requesting a SWPPP amendment for the unbuilt swale.
- A notification to the owner or responsible officer of the deficiencies and the sampling-kit gap.
- A sampling readiness record showing who is assigned, what kit is available, and what trigger will be used.
The superintendent's request to wait for the consultant should be answered in writing: the drum and washout will not wait, and the swale needs an interim control today. The record should distinguish immediate field corrections from the amendment request so a reviewer can see that the QSP acted on both.