6.1 Pre-Construction Meetings, Entrance Posting, and On-Site Document Inspections

Signatory and qualification checks

A professional credential is separate from authority to sign permit documents. Under 40 CFR 122.22(b), a report signatory must have written authorization by a person described in paragraph (a), the authorization must specify a responsible individual or position, and it must be submitted to the permitting authority. EPA CGP Appendix G and Part 7.2.10 allow SWPPP certification by the appropriate responsible official or duly authorized representative; do not infer that only an officer may sign every SWPPP document. Verify the provider’s construction-inspection training subjects under Part 6.3, not just the credential number. These requirements were checked in the modified EPA CGP on October 13, 2026.

Pre-Construction Meetings and Initial Pre-Disturbance Walkthroughs

On the Certified Erosion, Sediment and StormWater Inspector (CESSWI) examination, Specific Area of Practice (SAOP) 7: Inspection Elements for Construction represents 7% to 9% of the Part B examination. Effective construction stormwater compliance begins before a bulldozer ever strips topsoil. The pre-construction meeting and initial pre-disturbance site walkthrough establish institutional accountability, verify permit authorization, and confirm that initial sediment controls are installed according to the approved phasing sequence.

Mandatory Attendees and Operational Roles

Because stormwater compliance cuts across project financing, civil design, heavy earthmoving, and regulatory oversight, the pre-construction conference must assemble seven core stakeholders:

1. Owner / Developer (Permittee with Plan Control): Possesses operational control over construction plans and specifications under 40 CFR § 122.2, along with the financial authority to fund additional Best Management Practices (BMPs) or authorize plan modifications.
2. General Contractor Superintendent (Permittee with Day-to-Day Control): Exercises day-to-day operational control over site activities, trade scheduling, haul road routing, and subcontractor enforcement.
3. Earthwork / Mass Grading Subcontractor Foreman: Directs heavy equipment operators executing clearing, grubbing, topsoil stripping, cut-and-fill grading, and temporary diversion construction.
4. BMP Installation and Stabilization Subcontractor: Installs perimeter sediment barriers, rock check dams, inlet protection, rolled erosion control products (RECPs), and hydroseeding/mulching applications.
5. SWPPP Designer (CPESC or Licensed Professional Engineer): Explains watershed drainage divides, runoff calculations, sediment basin sizing, and structural installation details.
6. CESSWI Compliance Inspector: Establishes inspection frequencies, rain gauge verification procedures, photo-documentation standards, and corrective action communication workflows.
7. Local MS4 / State Regulatory Inspector: Clarifies municipal grading permit conditions, local buffer ordinances, notification milestones, and stop-work authority.

Key Pre-Construction Agenda Items and Walkthrough Verification

Following the tabletop agenda review, the CESSWI and project team conduct a physical pre-disturbance walkthrough across the project footprint to verify five non-negotiable readiness criteria:

• Chain of Command and 24-Hour Emergency Contacts: Establish a clear organizational chart naming the primary Stormwater Compliance Lead, duly authorized representatives, and 24-hour emergency contact telephone numbers for responding to severe weekend storms, breached embankments, or hazardous chemical spills.
• Verifying NOI Authorization and Waiting Periods: Confirm that the electronic Notice of Intent (NOI) was certified and submitted via the EPA NPDES eReporting Tool (NeT-CGP) or state electronic portal, and that the mandatory 14-calendar-day waiting period has fully elapsed without an administrative hold for Endangered Species Act (ESA) or National Historic Preservation Act (NHPA) reviews.
• Walking the Limits of Disturbance (LOD) and Sensitive Buffers: Physically walk the site perimeter to verify that high-visibility barrier fencing or surveyor staking clearly delineates the Limits of Disturbance (LOD). Confirm that 50-foot natural vegetative buffers (or 100-foot buffers adjacent to Tier 2, Tier 2.5, Tier 3, or sediment-impaired receiving waters), delineated jurisdictional wetlands, stream channels, and the Critical Root Zones (CRZs) of heritage trees ($1.0\text{ to }1.5\text{ feet}$ of radius per inch of trunk diameter at breast height) are flagged and fenced off from equipment entry.
• Confirming the Construction Sequencing Schedule: Verify that Phase 1 controls—specifically the stabilized construction entrance/exit pad, downgradient perimeter sediment barriers (silt fence, compost filter socks), upland clean-water diversions, and initial sediment traps or basins—are scheduled and installed before stripping topsoil or initiating mass grading.
• Establishing Inspection and Corrective Action Communication Procedures: Define how inspection findings and EPA CGP Part 5 corrective action triggers will be transmitted immediately to the superintendent, how routine maintenance (due by the close of the next business day) versus significant structural repairs (due within $\le 7\text{ calendar days}$) will be tracked, and who holds authority to red-line the site maps.

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Inspecting the Site Entrance and Public Notice Posting (EPA CGP Part 1.5)

When arriving at an active construction project, the CESSWI inspector's field routine begins at the main construction entrance. Under EPA Construction General Permit (CGP) Part 1.5 (and equivalent state general permits), the operator must post a durable, weatherproof public notice board at a safe, publicly accessible location in close proximity to the construction site entrance.

Accessibility and Visibility Standards

The notice sign must be positioned so that a member of the public or a visiting regulator can read it clearly from a public sidewalk, public roadway, or public right-of-way without entering active heavy-equipment haul lanes, climbing over jersey barriers, or trespassing behind locked security gates.

Four Mandatory Information Elements on the CGP Public Notice Sign

During every inspection, the CESSWI must verify that the entrance notice board remains legible, intact, and displays four mandatory regulatory elements:

1. NPDES Permit Tracking Number: The official permit tracking number assigned to the operator on the EPA NeT-CGP Notice of Coverage letter (or state general permit authorization number).
2. Operator Contact Name and Telephone/Email: The name and current telephone number (and/or email address) of the designated operator representative whom the public can contact to inquire about the project, report observed stormwater issues, or request access to the Stormwater Pollution Prevention Plan (SWPPP).
3. SWPPP Location and Public Access Instructions: A clear statement identifying where the current SWPPP is maintained—either its specific physical on-site location (e.g., "SWPPP binder located in the white compliance box at the main job trailer") or an active electronic URL/QR code—along with instructions on how a member of the public may arrange to view it during normal working hours.
4. EPA / Regulatory Reporting Statement: The mandatory standardized statement instructing observers on how to contact the U.S. Environmental Protection Agency (EPA) (or the delegated state environmental agency and local MS4) if stormwater pollution or an illicit discharge is observed leaving the construction site.

While at the entrance, the inspector simultaneously evaluates the physical stabilized construction entrance/exit pad—confirming it utilizes $2\text{- to }3\text{-inch}$ coarse crushed aggregate at least $6\text{ inches}$ thick over a woven geotextile separator fabric across a minimum length of $50\text{ feet}$ (or local DOT standard)—and inspects the adjacent public asphalt roadway for vehicle sediment track-out.

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Auditing the On-Site SWPPP Binder and Required Records

Before walking the interior grading areas and outfalls, the CESSWI performs a rigorous administrative document audit of the on-site SWPPP compliance binder (or authorized electronic compliance tablet). A SWPPP is not a static engineering submittal left on a shelf; it is a living legal document that must continuously reflect real-time site conditions.

Mandatory Records Verified During an On-Site SWPPP Audit

• Signed NOI and Authorization Letter: Copy of the certified Notice of Intent and the official EPA/state confirmation letter verifying active permit coverage for all co-permittees.
• Complete Copy of the Governing Permit: Full reference copy of the EPA CGP or delegated state general permit.
• Signatory Certifications and Delegations of Authority (40 CFR § 122.22):
  • The initial SWPPP narrative and NOI must be signed under penalty of law by a responsible corporate officer (president, secretary, treasurer, or vice-president), general partner, proprietor, or principal executive officer/ranking elected official under 40 CFR § 122.22(a).
  • Ongoing inspection reports, corrective action logs, and SWPPP amendments may be signed by a duly authorized representative (such as the project manager or site superintendent) only if a signed, dated Delegation of Authority letter from the corporate officer is filed in the SWPPP binder pursuant to 40 CFR § 122.22(b).
• Stormwater Team Roster and Inspector Qualifications: Identification of all named stormwater team members (CGP Part 6.1), employee training rosters, and documented proof of the inspector's credentials—such as the EPA course completion or a current construction-inspection certification/license covering every Part 6.3 subject; record supplemental training for any missing subject.
• Chronological Inspection Reports and Corrective Action Log: All past routine and post-storm inspection reports completed within 24 hours of each inspection and signed by the authorized operator signatory (CGP Parts 4.7.1–4.7.2), alongside the Corrective Action Log (CGP Part 5.4) containing initial discovery entries logged within 24 hours and completion entries signed within 24 hours of finishing repairs.
• Rain Gauge and Weather Log: Daily precipitation log recording site rainfall to the nearest $0.01\text{ inch}$ from an unobstructed on-site rain gauge (or representative NOAA weather station), confirming that storm-event inspections were triggered for every rainfall event $\ge 0.25\text{ inches}$ (or state-specific $0.50\text{-inch}$ threshold) and snowmelt runoff event.
• Grading and Stabilization Activity Log: A dedicated log tracking the exact calendar dates when earth-disturbing activities began, when grading temporarily or permanently ceased in each phase or sub-basin, when soil stabilization measures were initiated (mandatory immediate initiation once earthwork ceases for $\ge 14\text{ calendar days}$), and when stabilization was completed ($\le 14\text{ calendar days}$ where $\le 5\text{ acres}$ are disturbed at one time; $\le 7\text{ calendar days}$ where $> 5\text{ acres}$ are disturbed at one time or on sites discharging to sediment-impaired or Tier 2/2.5/3 waters).
• Chemical, Dewatering, and Spill Logs: Safety Data Sheets (SDS), anionic polymer authorizations, daily dewatering turbidity monitoring logs (evaluating the 50 NTU weekly-average benchmark under CGP Part 3.3), and hazardous substance spill/release logs.
• Up-to-Date Red-Lined Site Maps: Current erosion and sediment control plan sheets actively annotated ("red-lined") with dated, initialed field markups showing newly installed, modified, or removed BMPs, relocated concrete washouts, active topsoil stockpiles, and stabilized sub-areas.

Pre-Construction and On-Site Document Audit Checklist