July 1st, 2010 The New NPDES Permit is here

The new NPDES Permit is here, but what does that mean for you. Over the past 30 days I have been heavily involved with updating existing SWPPP's to bring them in line with the new permit requirements, and then posting them on the SMARTS site with the State. The process is simple enough, the LRP...Legally Responsible Person (Owner) receives a notice from the State to create an account and certify an existing NOI. The LRP is provided with a SCN or Secret Code Number which is linked to the WDID number from the NOI. Once the LRP registers and validates the NOI they can then add data submitters like the GC and consultants such as me. The LRP must be provided the USER ID's of the data submitters to add them into the system. With this accomplished the data submitter has full visibility of all projects that are linked to that USER ID, and can now log into each and perform updates as needed such as uploading the SWPPP.

As to credentials, and people that are qualified to perform these tasks.

Under the new permit it clearly states that you must be a QSP, Qualified SWPPP Practitioner to perform BMP inspections and supervise the installation of BMP's. The QSP training and testing do not exist as yet, but are slated to come on line (be available) sometime in the next 60 days. The prequalifications for becoming a QSP are that you possess a CA-PE, (CA-Professional Engineer) CISEC (Certified Inspector of Sediment and Erosion Control) or CESSWI (Certified Erosion, Sediment and Storm Water Inspector). All these certifications require formal and informal training, as well as time in the field (industry). It is my understanding that inspections must be performed by individuals with the required prequalification’s until training and the QSP exam are fully available with some added time (Sept 2011).

Under the new permit you must be a QSD (Qualified SWPPP Developer) to write a SWPPP and make amendments to an existing plan. The QSD training and testing do not exist as yet, but are slated to come on line (be available) sometime in the next 60 days. The prequalification’s to be a QSD are: CA-PE, CPESC (Certified Professional in Erosion and Sediment Control) or CPSWQ (Certified Professional in Storm Water Quality). All these certifications require formal and informal training, as well as time in the field (industry). It is my understanding that all SWPPP's developed after July 1st must be developed by individuals with at least the prerequisite credentials until the QSD training and exams are generally available, and that this testing must be accomplished by a given date (as yet somewhat ambiguous to me).