How to Fill Out TxDOT Form 2118: BMP Ratings, Corrective Actions, and Sign-Off

To fill out TxDOT Form 2118, the Construction Stormwater Pollution Prevention Plan Field Inspection and Maintenance Report, work top to bottom: enter the project identifiers, select the inspection cycle that matches your SWP3, rate every best management practice (BMP) on site, log any deficiencies in the corrective-action table with a priority and deadline, complete the stabilization section, and have an authorized certifying representative sign. A blank PDF is available on TxDOT’s SWP3 guidance page.¹

Know Which Inspection Date and Cycle to Enter

Form 2118 asks you to pick an inspection cycle at the top, and it has to match whatever cycle the SWP3 plan sheets specify. The default for most TxDOT projects is at least once every 14 calendar days plus within 24 hours after any rainfall of half an inch or more. A seven-day cycle is also allowed.²

Finally stabilized sites, and sites in arid (0–10 inches average annual rainfall) or semi-arid (10–20 inches) areas, drop to monthly inspections.²

The underlying obligation comes from the TPDES Construction General Permit, which is triggered when a project disturbs one acre or more.³

Project Information Block

The top of the form ties the report to a specific project and permit authorization. Complete each field as follows.⁴

Inspection Cycle: Choose 14-day plus rainfall trigger, 7-day, or monthly. Match the SWP3.
Inspection Date: The date you physically walked the site.
CSJ: The controlling Control-Section-Job number, entered without dashes.
RN: The TCEQ Regulated Entity number from the Notice of Intent (NOI). Enter “N/A” if no NOI was required.
Project and Highway: Project number for the controlling CSJ and the highway designation.
County: The county where the project sits.
TxDOT Authorization No.: For large projects (five or more acres disturbed), enter the number from TxDOT’s NOI issued by TCEQ. For small projects (one to under five acres), enter general permit number TXR150000. For projects under one acre, enter “N/A.”
Contractor Authorization No.: Same rule, using the contractor’s own NOI number on large projects.
Date and Amount of Last Rainfall: Record the most recent rainfall date and inches. TxDOT recommends keeping a rain gauge on site. Rainfall data is not strictly required by the Construction General Permit under the seven-day cycle, but your district may still want it.

Rating Every BMP on the Checklist

The checklist is the heart of the form. Walk the entire site — disturbed areas, discharge points, material storage, truck wash areas — and evaluate each BMP for condition, whether it is working as designed, and whether maintenance is needed. Add comments where the rating alone does not tell the story.²

The checklist groups BMPs into four categories:

Erosion Control: vegetation, mulch, erosion-control blankets and mattings, sodding, swales, dikes, stone outlet structures, and pipe slope drains.
Sediment Control: sandbag berms, silt fence, filter dikes, rock berms, hay bale dikes, construction exits, brush berms, sediment traps, and sediment basins.
Permanent Sediment Control: grassy swales, retention or irrigation systems, filter strips, detention basins, constructed wetlands, wet basins, and sand filters.
Other Controls: good housekeeping, construction waste management, hazardous materials storage, vehicle tracking controls, sanitary facilities, and spill prevention.

If the walkthrough shows the SWP3 itself needs changes, say a new BMP in an area the plan did not cover, those modifications must be done within seven calendar days of the inspection. Adding BMPs beyond what the plan shows requires the engineer’s approval.²

Logging Deficiencies in the Corrective Action Table

Every BMP that is damaged, displaced, or not performing goes in the corrective-action table. For each entry, fill in the BMP number or label from the plan set, the station or location, which side of the centerline it falls on, the specific issue, its cause, and the action required to fix it. Mark whether the finding is new or carried over from the previous inspection, and flag any item that represents a potential noncompliance.⁴

Assign each corrective action a low, medium, or high priority using the Form 2118 Priority Escalation Ladder. Corrections must be made as soon as possible and before the next anticipated rain event, and no later than seven calendar days after the site is accessible. The only acceptable reasons for missing that deadline are conditions too wet to work or other adverse conditions listed in the Construction General Permit.⁴

If a deficiency becomes a potential noncompliance and is not corrected in time, the engineer may suspend other work on the project. Time charges keep running until the site is back in compliance and documentation of the corrective action has been provided. When the fix is done, record the completion date and have a TxDOT representative initial the verification field.⁴

Anything that looks like a potential permit noncompliance goes to your supervisor immediately. Don’t hold it for the next inspection.²

Don’t Skip the Stabilization Section

Form 2118 has a dedicated section for stabilization that trips up a lot of inspectors. It tracks two things: when construction activity temporarily or permanently stops on any portion of the site, and when stabilization measures begin.⁵

Temporary stabilization is required when soil-disturbing work on an area has stopped and will not resume for 14 or more calendar days. Permanent stabilization must be started immediately when soil-disturbing activity will not resume at all in that area. Fill in the area number, sheet number, phase, location, activity dates, cover achievement, stabilization measures used, and notes.⁵

TxDOT guidance is explicit that this section needs to be completed on every Form 2118 per Appendix C instructions, not only when stabilization work is actively happening.⁵

Who Can Sign the Certifying Representative Line

Three signature blocks sit at the bottom: inspector, contractor representative, and certifying representative. Each line needs a printed name, title, signature, and date.⁶

The certifying-representative line is restricted. Under 30 TAC 305.128(a), reports submitted under a TPDES permit must be signed by someone with responsibility for the overall operation of the regulated activity, and that authority must be delegated in writing. The positions authorized to certify Form 2118 are the District Engineer, Deputy District Engineer, Division Directors, Area Engineers, Assistant Area Engineers, Project Architects or Engineers, and Project Inspectors who have overall responsibility for the project and have completed stormwater compliance training.⁵

Contract employees working as Construction Engineering Inspectors (CEIs) cannot be delegated signature authority for the certifying-representative line. When the Area Engineer does delegate it, the delegation has to be documented in the SWP3 Binder. If no delegation is issued, the SWP3 Binder should state that no delegation past the Area Engineer is allowed.⁵

The inspector’s name and qualifications are recorded on the form itself. If you are a contractor inspector, check with your Area Engineer that your training documentation is on file before you start signing reports.

Where the Completed Form Goes

File each completed Form 2118 in Attachment 2.5 of the SWP3 Binder, which stays on site during construction and must be available to TCEQ, EPA, or other regulators on demand.⁷

After the project wraps, TxDOT and the contractor keep every Form 2118, along with the rest of the SWP3 records, for at least three years from the date the Notice of Termination is submitted to TCEQ.⁸

1
Texas Department of Transportation. Stormwater Pollution Prevention Plan (SWP3) Guidance Document
2
Texas Department of Transportation. Storm Water Field Inspector’s Guide
3
TCEQ. Stormwater General Permit for Construction Activities
4
Texas Department of Transportation. Guidance: Stormwater Pollution Prevention Plan (SWP3)
5
Texas Department of Transportation. Guidance Manual: SWP3 Section 2 – Documentation Requirements
6
The National Academies Press. Construction Stormwater Program Management, Tracking, Reporting, and Compliance
7
Texas Department of Transportation. SWP3 Template – Attachment 2.5 Inspection Records
8
Texas Department of Transportation. Guidance Manual: SWP3 Section 1 – Administrative Requirements