NCEES Problem 517 2011 Edition

[clintonvillian]

Just a little curious what you guys thought of this question. I would have answered it wrong. Here in WV you only need a permit for disturbances larger than 3 acres. Most of our projects don't require them.

I wouldn't have included a washout pit as part of the answer.

 

[John QPE]

What is the question?

 

[clintonvillian]

Which of the following construction related activities do not generally require NPDES permit coverage:

1. Digging Borrow Pit

2. Concrete Truck Washout area

3. Interior remodeling of a retail store

4. Tree removal on a 10 acre parcel of land

Here in WV a permit is not required for anything under 3 acres of disturbance.

I could see a borrow pit being large enough to warrant a permit this of course still is size dependant. A concrete wash out is typically no larger than a 10 x 10 hole in the ground, interior would require nothing, treemoval is larger than 3 acres.

They list 3 as the correct answer. I would have at least said 2 and 3 don't need permits......

 

[John QPE]

NPDES permits are required for 1 acre disturbance or more. How are you getting away with 3 acres in :wv: ?

Regardless,

3 is definitely no land disturbance, because it is all interior work.

SWPP/PCSM Plans, whatever they call them in :wv: , which are required to be submitted with you NOI for an NPDES Permit require you to show where your washout area is. I think that is a pretty flaky answer, but still ... interior work is a definite no NPDES permit.

 

[clintonvillian]

I stand corrected, less than one acre, no permit. 1-3 is NOI (it is still an npdes permit).

 

[clintonvillian]

I wonder how many questions on the actual test are like this. I had a few that seemed "flaky" on similar subject matter. Makes you wonder if it is one of the ones you missed. I guess thats why they don't let you see your results............

 

[John QPE]

Choose the "BEST ANSWER" is what they always say. The test questions on the actual exam are reviewed, reviewed, reviewed again, studied and analyzed....I'd have to hope that this one would be removed from the question pool.

 

[Peele1]

You'd be amazed what people get away with in WV without a permit, and even with a permit.

Clear-cutting, surface mining, creek/stream filling, water polluting...

 

[ptatohed]

Correct me if I am wrong but any construction activity, no matter how big or small, is subject to CWA's EPA/NPDES permit program requirements (the project may not discharge directly into the MS4) but the permitting agency only requires, under the NPDES permit, that the developer obtain a Construction General Permit when the area of disturbance is one or more acres of soil. All of the answer choices have the potential for pollutant surface run-off except the interior store.

 

[clintonvillian]

I agree that any size project can be regulated, the DEP is not going to let you do whatever you want just because the site is less than an acre. The question specifically asks "NPDES permit coverage" which I take to mean that it requires you to get a permit for.

10 acre tree removal (over 3 acres thats a given), Interior of the store definately not needed, but the washout and borrow pit are completely determinate upon size, The washout pits at our concrete plants aren't even close to an acre.

I can't help it, I just think it is a flky question with answers that could go either way. Especially if you know one acre is the limit (if I didn't know that beforehand I would probably answer the store).

 

[desantmf]

Clintonvillian, I think we all agree with you the question is worded poorly which could lead to confusion. NCEES most likely will not ask that question on the exam because of this potential misinterpretation. However, if they did, DO NOT over-think it. Just go with the most right answer, which would be the interior work for reasons listed above.

 

[ptatohed]

[SIZE=10.5pt]I see what you guys are saying, and I'd agree the problem could be written more clearly and I am probably way over-thinking this, but here's my thought. Since the '90s cities and counties have had to, themselves, obtain NPDES permit coverage for their stormwater discharges (MS4 permits). As part of their requirement under these MS4 permits, "each regulated MS4 is required to develop and implement a stormwater management program (SWMP) to reduce the contamination of stormwater runoff and prohibit illicit discharges". As part of each MS4 permittee's SWMP program, I can almost guarantee you that it requires anyone coming in for a grading, building, encroachment, etc. permit, no matter how small the project, to adhere to established guidelines limiting discharges into the MS4. For instance, I bet most cities (which have an NPDES MS4 permit themselves), as part of their program, would require even a small stockpile project to apply for a grading or stockpile permit and as part of that permit, they'd probably have to submit a plan showing proposed BMPs, but at the least be required to implement the city's erosion and sediment control requirements. Thus, even a small project, less than 1 acre is affected under NPDES permit coverage requirements. [/SIZE]

[SIZE=10.5pt]Am I making any sense? [/SIZE]

http://cfpub.epa.gov/npdes/stormwater/munic.cfm

 

[John QPE]

See now I think you are overthinking this question ptatohed. While everything you said is correct, individual projects need to get coverage under their own site specific general or individual permit.

I think we can all agree, however, that the interior renovations are the clear cut answer to this question. The more I think about this, and see the discussion, maybe this is a really good question, with some really good distractors? We can sit here and make a case for every answer, EXCEPT for the interior work.

 

[ptatohed]

See now I think you are overthinking this question ptatohed. While everything you said is correct, individual projects need to get coverage under their own site specific general or individual permit.

I think we can all agree, however, that the interior renovations are the clear cut answer to this question. The more I think about this, and see the discussion, maybe this is a really good question, with some really good distractors? We can sit here and make a case for every answer, EXCEPT for the interior work.

JQ,

You are right and you are right.