NCS000482_ENG 3222 ESC Inspection Writing Procedure_20220526

SOP No. ENG - 3222
Adoption Date: 09/17/2021
Revision Date: 00/00/0000
Monroe
City of Approved:
Engineering
ESC Inspection Report Writing Guidance and Procedure
Purpose
To provide guidance and uniformity in the completion of Sedimentation Inspection Reports for active, permitted
construction sites within corporate limits the City of Monroe and Extra Territorial Jurisdiction for the City of
Monroe.
Procedure
Filling Out the Inspection Report
Since the inspection reports are legal documentation of the City of Monroe's on -site inspections, reports
must be documented in writing the day of the inspection. No report will be rewritten to delete or change
information documented at the time of the inspection.
The inspection report should be completed using the interpretation given below. Inspectors should strive
to clearly document the on -site conditions that exist on the day of the inspection.
County — Project — River Basin
Record the county, the project name and the river basin. The project name should be taken from the
Financial Responsibility/Ownership Form (FR/O) and should remain the same for all subsequent
inspection reports for that specific site. The River Basin Is the Yadkin or Catawba. Listing of local sub -
basins is not necessary.
Person Financially Responsible — Project #
The person, firm, company, partnership or LLC that is financially responsible for the project should be
listed on the inspection. This information should be obtained from the FRO or the deed in cases where
the financially responsible person is the property owner.
Address
The complete mailing address including city and zip code should be located on this line. Obtain prior
authorization from the Director before mailing inspections to out of town corporate offices. In some
instances, inspections have caused confusion for companies whose management is far removed from the
project, and local contact with company representatives will suffice. For such entities, a cover letter
explaining the purpose of the inspection report should be included with the first inspection. The
template for this letter can be found here: I:\Erosion Control\ESC Templates.
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SOP No. ENG — 3222
Adoption Date:09/17/2021
Revision Date: 00/00/0000
Approved:
1. Project Location - Pictures
A brief description of the project location, such as street and/or city, will enable persons not familiar with
the site to locate the project. If pictures are taken during the inspection indicate yes, along with the type
of media used: prints, slides, digital photos or video. Pictures should be taken to document major issues,
offsite sedimentation, and to track the condition of the site. If compliance has become difficult to
achieve, including photos with the inspection report may help to show the need for compliance.
2. Weather and Soil Conditions
Record the actual weather and soil conditions at the time of inspection. This is to show if site conditions
are suitable for work to be in progress. Example: (sunny, clear, rainy, etc.) and (dry, wet, contractor
grading, workable, etc.).
3. Is Site Currently Under Notice of Violation?
If the site is not currently under a NOV mark "no". Mark "yes" if the site has previously been cited via
Notice of Violation (NOV) and remains out of compliance with the NOV. If an NOV has not been sent but,
as a result of the current inspection, will be sent then it should be noted in the "Comments" section, but
the block provided should be checked as "no". If the site is under a NOV and shows visible progress,
provide adequate documentation describing the progress and any additional work needed to correct any
remaining violation(s).
4. Is the site in compliance with City of Monroe Erosion Control Ordinance and the S.P.C.A. and the
rules?
Mark the appropriate answer based on the actions to be taken under the next item, "5. Violations". If
this item is checked "yes", nothing under item 5 should be checked and conversely, if this item is checked
"no", at least one box under item 5 must be checked. If this inspection is a follow-up to a NOV issuance
or continuing enforcement action, a "yes" check means that the site is no longer accumulating daily
penalties. The civil penalty will be stopped as of the last inspection that the site was out of compliance
with the NOV. A project is not to be noted as in compliance until all violations have been corrected,
including being in compliance with the plan requirements. If measures are installed but are not
adequate, then it is not in compliance. If the site has adequate E&SC measures to prevent off -site
sedimentation but not groundcover sufficient to restrain erosion it can be checked as "yes" noting the
temporary groundcover requirements, as long as the statutory time periods for ground cover have not
expired. An absence of groundcover sufficient to restrain erosion beyond the statutory time is a
violation.
5. Violations:
• The ten labeled violations, a through j, are condensed text of the full ordinance and statutory
requirements that can be found in the referenced City of Monroe Ordinance and North Carolina General
Statutes and Administrative Code sections and correspond directly with the similarly lettered full text
descriptions in the Notice of Violations and similar documents. Please use the citations appropriately:
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SOP No. ENG - 3222
Adoption Date:09/17/2021
Revision Date: 00/00/0000
Approved:
a. No approved plan: If the inspection is for a complaint or a newly discovered unpermitted land
disturbance, the site should be measured for an approximate disturbed acreage.
b. Failure to follow approved plan: This should be checked almost any time a violation is found on a
permitted site. As well, when a project starts without a pre -con this item should be checked instead
of "a".
c. Failure to submit revised plan: This violation should only be cited if prior documentation exists that
verifies that the Erosion Control Inspector has previously requested a revised plan. If a revised plan is
needed as a result of the inspection do not mark "c", but list the revised plan request in the comment
section or corrective actions in order to be able to cite this violation in a future inspection if it proves
necessary.
d. Failure to provide adequate groundcover: This violation can only be cited if a previous inspection
observed a disturbed area that has had completion of construction or development for more than
the time frame allowed by the current ordinance.
e. Insufficient measures
f. Failure to take reasonable measure
g. Inadequate buffer zone: Please note the following decision tree:
Decision Tree for Markinq Violations "e, f andg" on Sedimentation Inspection Reports:
1. a. Site less than 12,000 sq ft or one acre for residential 2.
b. Site greater than 12,000 sq ft or one acre for residential 4.
2. a. Sedimentation damage has occurred4 3.
b. Sedimentation damage has not occurred-) f may be marked if there is potential for sedimentation
damage; g may be marked if sediment has crossed more than 25% of the buffer zone
3. a. Sedimentation damage has occurred to lake/natural watercourse4 Mark violations f and g
b. Sedimentation damage has occurred to other property, but not a lake/natural watercourse
Mark violation f
4. a. Sedimentation damage has occurred-> 5
b. Sedimentation damage has not occurred-> Do not mark e; f may be marked if there is a potential
for sedimentation damage; g may be marked if sediment has crossed more than 25% of the buffer
zone
5. a. Sedimentation damage to other property only4Mark e and f
b. Sedimentation damage to lake/natural watercourse only on tract4Mark f and g
c. Sedimentation damage to lake/natural watercourse off the tract-> Mark e, f & g
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SOP No. ENG — 3222
Adoption Date:09/17/2021
Revision Date: 00/00/0000
Approved:
h. Graded slopes and fills too steep: While a default standard of 2 horizontal to 1 vertical exists for
graded slopes and fills, there is a performance expectation that requires the developer to revisit a
problem location. If bank erosion exists, this item should be cited and appropriate action, which
could include re -grading or a revised plan, should be requested.
Unprotected exposed slopes: As with item d., this citation should be preceded with an inspection
noting finished slopes have had a completion of a phase of grading for 14 calendar days prior to the
current inspection. A note should be made that a phase of grading has been completed in Section 10
(comments). After the first time documenting completion of any phase of grading, a general
comment and warning/reminder should be left in the comment section so that the site is in
continuous notice of the ground cover requirements. Add specific locations after the general
comment as they are documented during site inspections.
j. Failure to maintain erosion control measures: Measure has to be installed in order for this citation to
be valid. A measure's omission should be handled in violations c, e, f & i above. Maintenance may
include a measure that has failed and needs repair or work necessary to ensure that a functioning
measure does not fail.
k. Other (describe): Items that might be cited but may not be considered serious enough to warrant
enforcement action could include:
— Failure to post the Certificate of Plan Approval
— Failure to notify this agency of initiation of the approved land -disturbing activity.
— Failure to hold a pre -construction conference. Check "b" if warranted due to damage, offsite
sedimentation, when pre -con is noted on plans, and when violator had prior knowledge of the
requirement.
Of Special Note: All violations that may be the subject of a civil penalty assessment must be specifically
cited in a Notice of Violation.
6. NPDES Permit Violation?
• This item references the National Pollutant Discharge Elimination System General Permit for construction
sites (Construction Activities Permit No. NCG010000, available at
http://Portal.ncdenr.org/web/wq/ws/su/npdessw#General Permits NPDES), which is enclosed with the
Letter of Approval issued by the ESC Plan Reviewer and received during the Pre -con for each permitted
site. Generally, any violation noted during an inspection by the Erosion Control Inspector on sites over an
acre is considered a violation of NPDES; therefore, if any violation marked should result in marking item 6
"yes" with a typical accompanying description such as "non-compliance with SPCA". Even if no SPCA
violations are noted, a possible NPDES Permit violation would be a failure to provide the required rainfall
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SOP No. ENG — 3222
Adoption Date:09/17/2021
Revision Date: 00/00/0000
Approved:
monitoring, appropriate inspection records, oil spills or pesticide spills. The enforcement of NPDES
Permit requirements is the jurisdiction of the Division of Water Quality, not the City of Monroe;
therefore, it is the discretion of the inspector to inquire about monitoring records at locations where the
SPCA requirements are in compliance. If potential violations of the NPDES permit are documented, the
Division of Water Quality should be notified. A carbon or digital copy of the inspection report is
adequate notification.
7. Has sedimentation damage occurred since last inspection?
• This inquiry is asking about both off -site and on -site damage, and the second row of blocks asks the
inspector to make the distinction. The "Other Property' block is a reference to off -site sedimentation
onto adjacent private property or the public street right-of-way. The "Description" line should be used to
give the name of the lake, river or stream if known, describe it if not known, or in the case of other
property, that property's owner or description. Typical descriptions would be "an unnamed tributary of
(known water body downstream)", "on -site wetland", "existing drainage canal for (nearby) community"
or "DOT right-of-way ditch. The inspector must quantify damage in the general terms as either "slight",
"moderate" or "severe". The use of photos or video can aid in substantiation of the inspector's decision.
Show the photos to the Land Development & Infrastructure Engineer and/or Engineering Director if
degree of damage determination is less than obvious. Inspection reports that will be used in
enforcement action should be accompanied with photos, sketch showing the location of sedimentation,
and/or a photocopy of a marked up plan.
8. Contact made with (Name)
• It is the policy of the City of Monroe ESC Program to make contact with appropriate on -site personnel.
The contact asked for in this line assumes a person associated with the land -disturbing activity taking
place such as owner, contractor, engineer, or other person on -site. Other City employees or other
regulatory agency representatives such as NCDENR LQS & DWQ, Solid Waste, Corps of Engineers, DOT or
others present but not representing the developer should be listed at the bottom of the page in the
"Others present" blank. If a copy of the inspection report is given out, please note this in the appropriate
area on the inspection.
9. Corrective actions needed:
• This area is to be used to explain in detail what actions are necessary to correct deficiencies or violations
noted above under item 5. Write "No corrective actions at this time" in this area if the site is considered
in compliance and no violations are marked under item 5. Corrective actions should provide sufficient
detail to be clear, but avoid "designing" specific practices. Exact locations of violations should be
provided where possible to expedite corrective actions and avoid the necessity of follow-up verbal
explanation by the inspector. If additional space is needed, please include a second page. If performing a
follow up inspection note the completed corrective actions, and re -state previous corrective actions left
incomplete and show the original date those corrective actions were issued. If all corrective actions have
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SOP No. ENG — 3222
Adoption Date:09/17/2021
Revision Date: 00/00/0000
Approved:
been completed write, "Previous corrective actions have been completed. No further corrective actions
at this time."
10. Comments:
• This space is to be used to provide general comments or information the inspector may note about the
project, such as raising maintenance issues in order to prevent a violation notation during the next
inspection noting corrective action that have taken place or giving words of encouragement in regards
to actions taken since the last inspection. The section can be used for clarifying shorter comments
under earlier items. Comments should be limited to facts of which the inspector has personal
knowledge and which are relevant to the site inspection. Keep in mind that every inspection report is a
public document available upon request; therefore, non -essential or editorial comments should not be
included. This section can also be used to give notice for ground cover requirements.
Report by: - Others present
• The inspection report author must provide his or her name. Please list any other regulatory agency
representatives as the others present.
Date of Inspection: - Time arriving at site: - Time leaving site:
• Any inspection report has the potential of becoming an exhibit in an evidentiary hearing and could be
challenged for its authenticity. Witnesses have claimed to have been present on a construction site all
day and not have seen an inspector. Therefore, it is imperative that the time arriving and departing the
site is accurately given on each inspection report in order to substantiate the inspector's observations on
a given date. Each inspection must be signed or initialed by the inspector.
cc: - Additional sheets
DISTRIBUTION OF COPIES
1. Original signed / initialed copy of the inspection is to be sent to the Financially Responsible Party via U.S.
Mail, Fax, or e-mail.
2. Original fax, photocopy, or PDF copy of the inspection should be copied to the General Contractor, Site
Contractor, Sub -Contractor in control of ESC, and any development consultants or management team
members requested by the Financially Responsible Party.
3. The Plan Reviewer and Engineering Administrative Assistant should also receive a carbon copy for their use in
managing the monthly reports to NCDENR.
4. Copy the Land Development & Infrastructure Engineer and/or Engineering Director on inspections that may
or will lead to increased enforcement actions.
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SOP No. ENG — 3222
Adoption Date:09/17/2021
Revision Date: 00/00/0000
Approved:
Copy the Land Development & Infrastructure Engineer and/or Stormwater Engineer on inspections that may
or will affect Stormwater regulation, or Stormwater SCM implementation.
If the project is under a NOV or NOCV, copy the Land Development & Infrastructure Engineer and Engineering
Director on inspections.
Site Visits between Inspections
• Due to the close proximity of construction sites to one another within the City of Monroe and the
Inspectors ability to respond quickly to requests to review issues on a site or meet with project
personnel, many times construction sites are visited in between inspections. These visits may not require
an inspection be completed however; they may be logged with a project diary sheet. The project diary
sheet should contain at minimum:
1. Project Name and Location as stated on inspection reports.
2. Contractor information.
3. Reason for visit.
4. Persons spoken to on site.
5. Time on site.
6. Weather and site conditions.
If violations are found, an inspection report may be needed. If the site is under an inspection with
corrective actions or under a NOV or NOCV take care not to add additional violations until the cure period
has expired. The comment section of the report should be used to convey the possibility of additional
violations if the area or issue found during the site visit is not resolved.
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