43_Industrial Facilities Inspections SOP

Stormwater Industrial Facilities
Inspection Program
Standard Operating Procedures
City of Greensboro
Water Resources Department
Stormwater Management Division
Version 4.0
2021

Revision Log
..Changes/Updates
Edited
Edited
6/6/2018
ZM
Ver. 3.0 Revision Log
Added Revision Log to the SOP
Reorganized the document sections and
6/6/2018
ZM
Ver. 3.0 Entire
Document
corrected grammar andspelling
6/6/2018
ZM
Ver. 3.0 1.0 & 6.0
Clarified that inspectors should speak with the
WQ Supervisor before forwarding permitting
concerns to NCDEQ
6/6/2018
ZM
Ver. 3.0
3.1
Changed the procedure for inspection priority
7/24/2018
ZM
Ver. 3.0
Apps. C & D
Added questions to the inspection forms
7/24/2018
ZM
Ver. 3.0
4.1
Added a classification to the Permitted Facilities
7/30/18
ZM Ver. 3.0 4.2 & 7.0 Added note that inspectors should obtain updated
SWPPPs from city facilities and give to Good
Housekeeping Program Oversight
ZM Ver. 4.0 App. C Added a question to the inspection form
11/13/18
concerning the documentation of stormwater
accumulated in secondary containment
5/21/19
ZM
Ver. 4.0
App. C
Changed "major spills" to "significant spills"
4/21/21
JL
Ver. 4.0
3.1
Changed "regularly" to "semi-annually"
7/8/2021
BS
Ver. 4.0
2.2
Added note that the training records are kept as a
part of the NPDES permit.
Stated that enforcement actions would be pursued
9/9/2021
BS
Ver. 4.0
8.0
according to the cities stormwater ordinance.
Page 2 of 24

Table of Contents
1.0 PURPOSE
5
2.0 PERSONNEL QUALIFICATIONS AND TRAINING...........................................................................................5
2.1 REVIEW OF GUIDANCE/RESOURCE MATERIAL...........................................................................................5
2.2 TRAINING.................................................................................................................................................5
2.3 SCHEDULES AND UPDATES........................................................................................................................6
3.0 INSPECTION METHODS.............................................................................................................................6
3.1 SELECTION, PRIORITIZATION, AND FREQUENCY.........................................................................................6
3.2 OFFICE PREPARATION (BEFORE INSPECTING)............................................................................................6
4.0 INSPECTION OF NPDES PERMITTED FACILITIES..........................................................................................7
4.1 CLASSIFICATION.......................................................................................................................................7
4.2 INSPECTION.............................................................................................................................................7
4.2.1 ON -SITE RECORDS REVIEW.........................................................................................................7
4.2.2 PHYSICAL WALKTHROUGH OF FACILITY......................................................................................8
4.2.3 WRAP-UP MEETING...................................................................................................................8
5.0 INSPECTION OF TRI FACILITIES..................................................................................................................9
5.1 CLASSIFICATION.......................................................................................................................................9
5.2 INSPECTION.............................................................................................................................................9
5.2.1 PHYSICAL WALKTHROUGH OF FACILITY......................................................................................9
5.2.2 WRAP-UP MEETING...................................................................................................................9
6.0 INSPECTION OF NO EXPOSURE FACILITIES.................................................................................................9
6.1 CLASSIFICATION.......................................................................................................................................9
6.2 INSPECTION...........................................................................................................................................11
7.0 RECORDS MANAGEMENT (AFTER INSPECTION).......................................................................................10
8.0 ENFORCEMENT OF VIOLATIONS..............................................................................................................12
APPENDIX A: REFERENCES .....................
APPENDIX B: INSPECTION FLOWCHART.....
APPENDIX C: NPDES INSPECTION FORM..
APPENDIX D: TRI INSPECTION FORM .......
APPENDIX E: NPDES INSPECTION LETTERS
LETTER 1: NO DEFICIENCIES
LETTER 2: MINOR DEFICIENCIES
.........................................................................................................14
.........................................................................................................14
.........................................................................................................15
.........................................................................................................18
.........................................................................................................18
18
19
Page 3 of 24

LETTER 3: MAJOR DEFICIENCIES, STATE NOTIFICATION
20
APPENDIXG : DATABASE ENTRY........................................................................................................................... 21
Page 4 of 24

1.0 Purpose
The purpose of this Standard Operating Procedure (SOP) is to establish uniform procedures for the
inspection of industrial facilities that have the potential of discharging nonstormwater into either local
receiving streams or the municipal storm sewer system (City of Greensboro NPDES permit
NCS000248, Part II, Section H). This includes NPDES permitted facilities, facilities that report toxic
releases under the guidelines of SARA Title I II, Section 313 (TRI facilities), and facilities with a
Certificate of No Exposure. This SOP is designed specifically for these types of facilities, though any
facility in Greensboro —regardless of its regulatory status —is inspected when staff are alerted to
pollution problems (whether by citizen concerns, other city and county departments, reported spills,
high pollutant values from fixed interval stream sampling, outfall screenings, etc.). Procedures for spills
and complaints are followed in these cases (See reference in Appendix A). If a city inspector suspects
that a nonpermitted facility may require a permit based on industrial activities and/or Standard Industrial
Classification Code (SIC), the inspector discusses observations with the Water Quality Supervisor and
this information is forwarded to the appropriate contact at the North Carolina Department of
Environmental Quality (NCDEQ).
Chapter 30, Article 12, Section 7.1(C-5) of the City of Greensboro Code of Ordinance allows the City of
Greensboro to conduct facility inspections and provides for enforcement of any violation of the
Stormwater Management Ordinance.
The provisions of this ordinance are stated as follows:
"The Director of Water Resources may inspect the facilities of any user in order to ensure
compliance with this chapter. Such inspection requires the consent of the owner, manager, or
signatory official. If such consent is refused, the Director of Water Resources may seek issuance
or an administrative search warrant."
2.0 Personnel Qualifications and Training
2.1 Review of Guidance/Resource Material
Inspectors familiarize themselves with guidance and resource materials (Appendix A). These materials
provide information on general stormwater permits in North Carolina, material handling and storage
activities associated with different industries, industry terminology, equipment and structures that are
helpful to industries in mitigating pollution concerns, the components contained in a Stormwater
Pollution Prevention Plan (SWPPP), chemicals associated with TRI facilities, etc.
2.2 Training
Inspectors attend ongoing training and meetings, both internally and externally. In addition, inspectors
participate in workshops, webinars, conferences, etc. as available and appropriate. This may include
activities such as the Industrial Forum Users Group, Spill and Response training, Emergency
Management training, etc. City staff also participate in joint inspections with staff from NCDEQ to
ensure accuracy and consistency. These efforts include inspections and investigations of NPDES
facilities, hazardous waste operations, etc. All training records are kept as a part of the City of
Greensboro NPDES permit and is located at
"Y:\Storm Mgmt\bv section\bv waterguality\bv projects\Training Records".
In addition to formal training, opportunities are taken to work with industries in various capacities in
order to better understand how they work, to build relationships, and to learn their needs as they relate
to stormwater.
Page 5 of 24

2.3 Schedules and Updates
It is the responsibility of each inspector to stay current as to the status of his or her assigned facilities
by regularly checking the spreadsheet and database for updates. Inspectors should be aware of when
inspections are scheduled for permitted facilities and adhere to the schedule.
3.0 Inspection Methods
The inspection steps in the following sections apply to NPDES permitted facilities, TRI facilities, and
facilities with Certificates of No Exposure. For further clarification on the differences between NPDES
permitted facilities and TRI facilities, see sections 4.0 and 5.0.
Inspectors should follow the inspection procedures listed in this section to ensure consistency and
efficiency for all inspections.
Note: In this document, "permitted facilities" refer to those with either a general permit or individual
permit. "TRI facilities" refer to those that are listed on the Toxic Release Inventory but do not have a
general or individual NPDES permit. They may have a Certificate of No Exposure.
3.1 Selection, Prioritization, and Frequency
A complete list of all facilities in Guilford County that have NPDES permits or No Exposure certificates
is obtained annually from NCDEQ. A list of TRI facilities are identified yearly via the EPA's database on
submitted toxic reports. Updates to both lists are ongoing as annexations occur, as facilities are added,
or when there is a status change. The compiled list is imported into ArcMap to determine which facilities
are within the jurisdictional boundaries of the City of Greensboro, and the finalized list is divided among
all inspectors. The scheduling of NPDES permitted facilities is coordinated with the NCDEQ regional
office to prevent inspection redundancy.
Each inspector prioritizes his or her facilities as high risk, medium risk, or low risk based on pollution
potential, housekeeping practices, past investigations or violations, etc.
High: A facility in this category may have a large amount of outdoor processing activities,
materials stored on site and in direct contact with the elements (precipitation), poor
housekeeping, a greater potential of releasing harmful materials into the city stormwater
conveyance system and receiving streams, and/or have a past history of
noncompliance.
Medium: A medium -level site is one in which there is moderate pollution risk to the stormwater
system, such as those with loading docks that receive and deliver materials via tractor
trailer trucks, have some outdoor storage areas, and/or may perform vehicle
maintenance or washing.
Low: A low-level facility has limited or no outdoor processing areas and exhibits good
housekeeping practices (such a facility with a Certificate of No Exposure).
All inspections are performed once per permit cycle with the exception of city -owned facilities and high -
risk facilities, which are both performed twice per permit cycle (Appendix B). Additionally, contact
should be made annually for city facilities, offering a courtesy inspection to the facility official. Contacts
with officials at city -owned facilities are logged in the correspondence spreadsheet. Each staff member
inspects an average of 20% of his or her assigned facilities each year, with scheduled permitted
facilities being priority. Once all of an inspector's permitted and TRI facilities are inspected, the facilities
with No Exposure certificates are inspected.
Page 6 of 24

3.2 Office Preparation (Before Inspection)
The following steps may be necessary to prepare for the inspection of an industrial facility.
1. Check the spreadsheet, electronic file, database, and physical folder for updates.
2. Review materials specific to the facility as noted below and in Appendix C:
• General permit or No Exposure Certificate for facility type
Each permit type has different guidelines and requirements, dependent on a facility's
manufacturing and processing activities. A permit type will specify what is required by a
facility regarding monitoring, reporting, etc. Permits may be found electronically using
`information links' spreadsheet.
• TRI report (SARA)
• Stormwater maps (ArcReader, ArcMap, city block sheets)
Prior to visiting the site, inspectors review in-house drainage and sewer maps via ArcMap or
ArcView (or block sheets) to identify on -site drainage features. The inspector also notes
outfall locations so he or she is aware of where runoff enters the City municipal storm sewer
system or receiving stream.
• In-house documentation: past city and state inspection information, Industrial Facilities
Database, Spill and Concerns Database, Pretreatment Database, Outfall Screenings
Database, enforcement files, etc.
• Facility website
3. Create a correspondence log to document emails, phone messages, voicemail, letters, inspections,
etc.
4. Contact the appropriate facility representative to set up the inspection for permitted and TRI
facilities.
Contact information may be obtained from NCDEQ and/or EPA websites, NCDEQ staff, GIS
parcel information, the Industrial Facilities Database, data from Guilford County tax parcels, the
Internet, the phone book, etc.
When making contact with the facility, the inspector should ask to speak to the person who
handles environmental matters for the site. It is common for industrial facilities to have one
person who deals with all environmental issues. Explain to the representative why the City is
conducting the inspection and what pertinent areas the inspection will focus on (i.e., SWPPP
review and physical walkthrough of the facility). Also ask the company representative what
necessary equipment is needed for a safe inspection of the facility (Table 3.1 includes a list of
personal protective equipment and materials that may be needed to properly complete the
inspection.).
If for some reason the company official questions or is hesitant to allow the inspection, explain
the provisions of the Greensboro Stormwater Ordinance (Section 1.0 of this document) that
allow for the inspection of any facility in the jurisdictional boundaries of the City. If entry to a
facility is denied once on site, tactfully question the company representative for reasons behind
this denial. If the issues cannot be resolved at the facility, the inspector should leave the scene
and discuss the matter with the Water Quality Supervisor for further direction.
5. Gather the necessary documents, equipment, and PPE (Table 3.1).
Page 7 of 24

Table 3.1 List of Inspection Equipment
Documents and Inspection Tools
Personal Protection Equipment
• City ID and business cards
• Hard hat
• Facility file (records and maps)
• Hearing protection
• Inspection forms
• Safety shoes (steel toe)
• Field notebook
• Reflective safety vest
• Clipboard
• Safety glasses
• Cell phone
• Digital camera
• Flashlight/mirror
• Manhole pick
• Tape measure
4.0 Inspection of NPDES Permitted Facilities
4.1 Classification
Certain industrial facilities are prohibited to discharge various potential stormwater pollutants unless
permitted by a general or individual NPDES permit. General permits cover a variety of industrial
activities. A facility that requires a general permit is issued a Certificate of Coverage and must follow
the same requirements as all facilities under the same general permit. If a facility conducts industrial
activities that are not covered under a general permit or has site conditions/operations unique from
other facilities, it must operate under an individual permit. General and individual permits are issued for
five-year cycles. The NCDEQ regional offices or cities with their own NPDES permits inspect these
facilities on a five-year cycle.
4.2 Inspection
Upon arrival at the facility, the inspector introduces himself or herself as a City of Greensboro inspector
and offers the appropriate credentials (i.e. business card and/or employee ID). After introductions, the
inspector communicates to the company representatives the following components of the inspection.
4.2.1 On -Site Records Review
Inspectors should begin the on -site records review with an evaluation of the facility's Stormwater
Pollution Prevention Plan (SWPPP). As a requirement of the state's NPDES program, the SWPPP is a
document utilized by the facility to manage and minimize the likelihood of pollution due to stormwater
runoff and spills. The Stormwater Industrial Inspection Form (Appendix C) should be used during the
review of documents, as it is important to document any pertinent notes about the plan. If the facility
being inspected is a City of Greensboro facility, the inspector should obtain a copy of the most recent
SWPPP.
The major components to look for when reviewing the facility's SWPPP are noted below. When
properly applied, these components play an important part in reducing pollution from stormwater runoff.
Refer to the EPA and NCDEQ documents for a thorough description of how to develop an SWPPP.
• Stormwater pollution prevention team
• Site description (activities, maps, etc.)
• Summary of potential pollutant sources
• Description of control measures (good housekeeping, spill response plan, training, etc.)
• Schedules and procedures (inspecting, monitoring, etc.)
• Documentation to support eligibility considerations under other federal laws if applicable
Page 8 of 24

• Certification of the SWPPP
Once the review of the SWPPP is complete, the inspector should have a good working knowledge of
the facility site and overall layout of the processing areas. In addition to the SWPPP, the inspector
should evaluate records that are relevant to the management of stormwater on the facility. Other
relevant records may include items such as maintenance logs on facility equipment, prior
correspondence with the City or other government agencies, stormwater sampling data, documentation
from any reportable spills, and any other relevant documents.
4.2.2 Physical Walkthrough of the Facility
After review of the on -site records, the next phase of the inspection will be the physical walkthrough of
the facility. A thorough inspection of the entire facility should be completed. General things an inspector
looks for are as follows:
• On -site BMPs
• Outside processing/manufacturing areas
• Secondary containment (including closed, functioning valves with locks or other security
features)
• Presence of illicit connections and improper disposals
• Evidence of past spills
• Material handling and storage areas, including loading/unloading areas
• Equipment fueling and maintenance areas
• Stormwater structures and receiving streams, outfalls, presence of dry -weather flow
• Ground disturbance and contamination
• Materials storage, labeling, and location (away from high -traffic areas)
• Successful implementation of SWPPP strategies and guidelines
• Materials type and potential for impact on water quality from spill or rain event
When conducting the on -site inspection, it will be beneficial to have the company representative supply
a copy of the site map that shows all areas of concern. The inspector should observe outside
processing and manufacturing areas; note where and how materials are stored (properly labeled,
located out of high -traffic areas); and examine storm drains, drainage swales, and outfalls for debris
and evidence of spills. Document any non-stormwater (dry -weather) flows in storm drains and outfalls.
It is appropriate for the inspector to have a field notebook and camera to document any findings while
doing the walkthrough. In some cases the company official may convey concerns about allowing the
inspector to take photographs. If this situation occurs, cordially talk about the concerns and attempt to
come up with a solution that both parties agree on. Allowing the company representative to view the
pictures on the camera's display or avoiding pictures of sensitive areas that have no relevance to the
inspection are potential fixes to this problem.
Not all scenarios that an inspector may encounter in the field can be covered in this document. Each
site will be unique and will have different processes that have the potential to impact stormwater runoff;
therefore, inspectors need to keep the big picture in mind (e.g. noting where materials will go and how
the receiving stream may be affected if there is a spill or heavy rain). Moreover, inspectors should note
whether the strategies outlined in the SWPPP are being implemented successfully and whether
appropriate BMPs are in place. Remember that being on the site is the most opportune time to discuss
the facility's operations with the company representative. When in doubt, ask for clarification; being
hesitant may cause the inspector to miss a potential problem area.
Page 9 of 24

4.2.3 Wrap -Up Meeting
A wrap-up meeting with the facility official will provide a final opportunity to answer questions, gather
information, and present findings and deficiencies. Inspectors should be prepared to discuss the
preliminary findings of the inspection. However, it is not necessary to share all findings of the inspection
with the facility official, especially if advice or direction is needed on a particular issue. Explain the next
steps in the process and what further communications the City of Greensboro may have with the
company, such as sending the inspection letter (or form) or the possibility of a follow-up inspection from
the state.
5.0 Inspection of TRI Facilities
5.1 Classification
A facility that meets criteria as specified in Section 313 of EPCRA (SARA Title III) —which includes
manufacturing, processing, or using defined chemicals in certain amounts —are required to report these
activities on an annual basis. Section 313 requires manufacturing facilities of a variety NAICS/SIC
codes to submit an annual toxic chemical release report if they have ten or more full-time employees
and if they manufacture, process, or use specified chemicals in amounts greater than threshold
quantities. This report, commonly known as Form R, covers releases and transfers of toxic chemicals to
various facilities and environmental media, and allows EPA to compile the national Toxic Release
Inventory (TRI) database. A list of TRI-covered industries can be found on the EPA's website.
As facilities report annually and their activities may vary or change frequently, facilities in this inspection
category may change from year to year. Facilities meeting these criteria are required to submit Form R
to the EPA, which is then compiled in the EPA's reporting database.
5.2 Inspection
Just like at an inspection of a NPDES facility, the inspector will introduce himself or herself and explain
to the company representatives the following components of the inspection. It is important to note that
on -site records reviews are not required for inspections of TRI facilities.
5.2.1 Physical Walkthrough of the Facility
When inspecting TRI facilities, the same walkthrough procedures for inspecting NPDES facilities
(section 4.2) are followed. Special attention should be given to evidence of past spills, equipment
fueling and maintenance areas, material storage, and material type and potential impact to stormwater.
5.2.2 Wrap -Up Meeting
The wrap-up meeting allows the inspector to gather further information or answer any final questions.
At this time, the inspector can discuss the findings or deficiencies from the inspection but does not need
to disclose all findings. If the inspector needs further guidance regarding a potential compliance issue,
he or she may choose to complete the carbon inspection form (Appendix D) in the office and mail or
email it to the official. If the form is filled out at the end of the inspection, it will be signed by both the
inspector and facility official. The white copy (top) is given to the facility official. The yellow copy is
taken back to the office to be filed. The yellow copy is scanned and saved in that facility's electronic file
and filed in the physical file folder.
Page 10 of 24

6.0 Inspection of No Exposure Facilities
6.1 Classification
NCDEQ determines if a facility requires an NPDES permit based on its industrial activity. However,
there are instances in which a facility is excluded from permit coverage if there is no exposure to
stormwater, in which case they qualify for a Certificate of No Exposure. NCDEQ defines a No Exposure
facility as follows: "Facilities with stormwater discharges associated with industrial activity may be
excluded from permit coverage if industrial materials and operations are not exposed to stormwater...
The facility must maintain this condition of No Exposure in accordance with the Self Recertification
Information to qualify for the permitting exclusion."
6.2 Inspection
An inspection for a facility with a Certificate of No Exposure is visual only unless further investigation is
warranted. The inspection consists of driving by the facility or on the facility grounds to verify there is
still no outdoor exposure, housekeeping practices are up to standard, and there are no threats to water
quality. If a city inspector observes anything that may disqualify a facility from this classification, the
inspector discusses observations with the Water Quality Supervisor and NCDEQ is notified for further
examination. The inspector follows the steps in section 3.2.3 where applicable.
7.0 Records Management (After Inspection)
Create/update electronic file folder. (See Figures 3.2.a and 3.2.b.)
• Facility folders are located at
Y:\Storm Mgmt\bv section\bv waterquality\bv projects\Industrial Inspections\Industry Files.
• If the site has been previously inspected by the city, find the correct electronic file in Industry
Files. In that facility's folder, create a new folder and title it with the year, such as "2014." If
applicable, create a folder titled with the correct year of the past inspection and put all
corresponding documents in that year's folder.
• If this is the city's first inspection of the facility, create a new folder with the facility name. If
the facility has had a name change, rename the folder with the new name and put the old
name in parentheses, such as "Valley Proteins (Carolina By -Products)."
• If an industry has more than one facility, create a folder for each and include an abbreviation
of the address in the file name (Fig. 3.2.1b)
• If the inspected facility is a City of Greensboro facility, a copy of the updated SWPPP should
be given to the Good Housekeeping Program Oversight staff or saved in the City -Owned
Facilities folder: Y:\Storm Mgmt\bv section\bv waterquality\by prolects\Industrial
Inspections\SWPPPs for City -Owned Sites. The Program Oversight staff should be notified
that the updated SWPPP has been added to the folder.
Page 11 of 24

Figure 3.2.a
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by_aterquality
Industrial Inspections
l> j.
by -application
2006 Inspection Information
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Name
Dow Corning
q, 2011 Inspection Le[ ,docx
Eagle Transport
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East Coast Leasing Co
'S7 E,—k2011 Inspection Letter.pdf
Elastic Fabrics of A—
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Ernie', Machines
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C I_
• E:`onik (Stockhausen)
Estes ExpressM corp
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, Eonik (Stockhausen)
c IMG 4112JPG
ry s
V
2006
2011
t IMG_4113 JPG
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2011
F11 Greensboro LLC
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Filtrona GSO
First Student Inc
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Figure 3.2.b
Convatec (American Avenue)
C o nvatec (C essn a D rive)
2. Download the facility's inspection photos into the appropriate folder. For future reference, it is
recommended that photos are labeled or subfolders are created.
3. Only for inspections of a NPDES facility will letters need to be created and sent. Open the
appropriate letter, and save that letter in the correct facility folder under the current year. After
editing the letter with the inspection information, make a copy for the physical file. In addition to the
Word document, save the letter as a pdf and title the document with the permit number, site name,
year, and "Greensboro Inspection." For example, a 2013 inspection of Dow Corning would be titled
as follows: "NCS000077, Dow Corning, 2013 Greensboro Inspection." Send the letter to the facility
via email or regular mail, copying the NCDEQ's Environmental Specialist, and the Water Quality
staff member overseeing the program (See Appendix E for letter templates).
4. Enter the inspection information in the Permitted Facilities database (in Locator). If the facility has
been inspected previously by the City of Greensboro, a record should exist and only updating is
needed. If this is the first City inspection, the inspector creates a record for that facility. For TRI
facilities and those with No Exposure certification, the form at the bottom will remain blank and any
deficiencies (or lack thereof) are noted in the comments box (See Appendix F for entry
explanations). If a facility has undergone a name change, rename the database entry with the new
name and put the old name in parentheses (same procedure as outlined in Paragraph 1). If a
facility has changed ownership, create a new facility entry in the database.
5. Update the contact log for that facility as applicable.
Page 12 of 24

6. Add a copy of the inspection letter to the physical file along with any other paperwork or maps, and
place the file folder in the cabinet in the Water Quality section. If no file exists, create a file labeled
with the facility name, facility address, and permit number, certificate number, and/or "TRI." If a
facility has undergone a name change, follow the same naming procedures as the electronic
folders.
7. Upon completion of an inspection and issuance of the official inspection letter, a copy of the letter
shall be sent via email to the appropriate NCDEQ Winston-Salem regional office representative.
The industrial program administrator shall be copied to this email as well.
8. Update the industrial facilities excel spreadsheet. Add the exact date the inspection was completed
for the appropriate facility in the column `GSO Inspection (Actual).' Remember, once per permit
cycle for low and medium risk facilities and twice per permit cycle for high risk facilities. It is the
responsibility of each inspector to update this spreadsheet as well as notify the program
administrator when an inspection has been completed.
8.0 Enforcement of Violations
If water quality violations are observed during the inspection, these findings should be discussed with
the Water Quality Supervisor. Based on the seriousness of the situation, it may be decided to issue the
facility a Notice of Violation (NOV) under Cities Stormwater Management Ordinance. If this occurs,
inspectors should follow procedures outlined in the Enforcement Standard Operating Procedures,
which is located at
Y.•Ibv proiectslEnforcementlEnforcement procedures.
In cases where an NOV is sent, the letter denoting major deficiencies will be used and include
information about the pending violation letter. The addition to the deficiency letter for the facility
inspection may be worded similarly to the following:
Please note that [recipient's name) received a notice of violation on [date from the City of
Greensboro regarding an [improper discharge/illicit connection) to the stormwater conveyance
system. This violation is due to [activity or activities of noncompliance].
Enforcement documentation should be filed both physically and electronically per the guidance in the
enforcement SOP. Place a copy of the enforcement letter in the industrial physical file, referring to the
enforcement file. In the industry's electronic file, add a shortcut leading to the enforcement file.
Page 13 of 24

Appendix A: References
EPA: No Exposure Guidance: https://ncdenr.s3.amazonaws.com/s3fs-
Public/Water%20Quality/Surface%20Water%20Protection/SPU/SPU%20-
%20NPDES%20Permit%20Forms%20and%20Documents/NPDES-NoExposure-EPAFactSheet-2005-
DWQ-SPU.pdf
EPA: Toxics Release Inventory Overview: https://www.epa.gov/enviro/tri-overview
EPA: Website for Industrial Facilities: https://www.epa.gov/npdes
General Stormwater NPDES Permits —North Carolina (includes template permit for each industry type)
(NCDENR, 1992)
Industrial Stormwater Permit Guide: http://www.pneac.org/stormwater/
Standard Industrial Classification Manual (Office of Management and Budget, Federal Government,
1987)
Standard Operating Procedures: Administrative Procedures for Completing an Enforcement Action, City
of Greensboro
Standard Operating Procedures: Illicit Discharge and Improper Disposal Program, City of Greensboro
Standard Operating Procedures: Spill Response, City of Greensboro
State of North Carolina Best Management Practice (BMP) Manual for Industries, The
Stormwater Pollution Prevention Plans for Stormwater Runoff at Industrial Activities (NCDENR, 1998)
Page 14 of 24

Appendix B: Inspection Flowchart
ISTHE FACIUTY PERMITTED?
ISTHE PERMITTED FACILITY MUNICIPAL? YES NO
ES NO
PERMITTED FACILITY IN
(MUNICIPALONLY)
♦ Twice per permit cycle,
minimum
♦ Yearly courtesy call
♦ Meetcontact on site
♦ Outside site inspection
♦ Paperwork review
♦ Official letter
PERMITTED FACILITY (HIGH
RISK, NON -MUNICIPAL)
♦ Twice per permit cycle
♦ Meet contact on site
♦ Outside site inspection
♦ Paperworkreview
♦ Official letter
PERMITTED FACILITY
(LOW/MEDIUM RISK, NON -
MUNICIPAL)
♦ Once per permit cycle
♦ Meet contact on site
♦ Outside site inspection
♦ Paperworkreview
♦ Official letter
NO EXPOSURE
♦ Drive-byonly(outside
visual)
♦ Once perpermitcycle
♦ No official contact
necessary
♦ No paperwork review
SARA FACILITY (HIGH) SARAFACILITY (LOW/MED)
♦ Twice per permit cycle ♦ Once perpermitcycle
♦ Meet contact on site ♦ Meet contact on site
♦ Outside site inspection ♦ Outside site inspection
♦ No paperwork review ♦ No paperwork review
♦ Carbon report filled out ♦ Carbon reportfilled out
Facility Type
Frequency
(per cycle)
Paperwork
Review
Onsite
Observation
Facility Contact
Present
Follow-up
Contact
NPDES (High -Risk Facilities)
2
V
V
V
Letter
NPDES (Low- to Medium -Risk Facilities)
1
V
d
V
Letter
City -Owned NPDES
2
V
d
V
Letter
SARA (with or without NE)
1
X
d
V
Carbon
No Exposure (exclusively NE)
1
X
d
X
X
Page 15 of 24

Appendix C: NPDES Inspection Form
64�-
BO� City of Greensboro
tc.rmwate.r Industrial Inspection Report
Faciiity Information
Faci%, Name: Date:
Address: Phone #I:
Contact Person: NAICSISIC Code:
N-C. Permit ID#. Industrial Activity:
Inslxection TypelPurpgse (Select one]
Fi4UTIPiE COMPLIAhICE 1FJSFEGTIOtS Inspector Name:
RESPOr,2E TO CCMPI A W Telephone:
SPILL E retry Time:
OTHER DESCRIBE Exit. Time:
S.tQrl>ayote.r Pollution Prmrerrtion PlaniSpill Plan Review
A. SITE MAPS & SWP3
YES
NO
NA
1. Is a coov of the current NPDES Permit A the facil ?
2. If the facility has an expired individual permit, did the faciky sunmit the Renewal
Application Farm ail least 180 days prior to expiration?
3. Is a copy of the SWP3 at the facaW .
4. is the SVVP3 - ned? rmit: Pt. ll Sew A, Par. S
6. Is the general location rrkap presenU
6. Is there a site map that shovrs drainage plattems, Dutfalls. floor drains- etc.?
7. Is there a written or unwritten .tpA�" Facility Inspeclion Prograrn (i.e. routine site
observatiorts noting tential issues)?
6..Zre reoords present documenting the description and releases of �pA, y
accumulated in arri secondary containment? rmit: Pt. II, Sec. A Par. 2b
g. Are the names of Pef&iAnl wagers listed for shown and labeled on the site map)?
10. is there a signed, annual certifiGalion stating That the facility has been tesied far non -
discharges from the site? mV: Pt. II Sec. A. Par. 1 e j
D. SPI Lt_ PREVENTION & RESPONSE PLAN
E3
N C.
!.".A
1. Aae procedures in p4ace fors ill response and cleanu ?
2. Is there a fist of siclinfficant spills lhat have uacurred since permit was issued?
S. Does the spill plan state how to properly dispose of materials after a spol?
4. Are the contact erson[s and plafl u tc-date?
C. IuIONITORING
`-:ES
NO
4YA
1. Is analytical water ual sam in up -to -dale and are records readily available?
2. Have any of the required sampling arameters been outside of the benchmark values?
3. if so, have Tiered Response procedures been irnplenwinted and documented?
4. Is Qualitative monitorin up-to-date and are records readih available?
D. EMPLOYEE TRAINING
YES
NO
A
1. Are employees trained at least arinuatly on spill respanse prXedures?
2. Does training include gkMRVAW discharge prohibitions and wasteviater discharge
r uirentents?
. Are employees properly trained at least annually on the appropriate record-keepi ng
and ins lions of the drainage network?
4. Are trainirtQ records readily available and a part of the SVVP3?
S. Axe the tFainina reooads u io-date?
RecommendationsrRequirernents:

5AqMWAW Indystriai Inspection Report (con Cd)
Site Inspection
A. PRE VENTATrVE M11 TENANCEfGOOD HOUSEKEEPING
YES
NO
rJ. .
1..=.re ,materials stored in areas Thal limit exposure to precipitaiion or runoff (Dumpsters
oaveredpallets properlystored, eic. ?
2. Is there adequate secondary ccniainment for above -ground storage tanks and
malerial handling areas ',i.e appropriate storage capacity based on visual
observation)?
a. Is there a process in place for property removing irainv�ater from the secondary
oDntainment areas?
4. Do secondary containment valves Va-•e -_i 7cfoning locks?
S. Are-nater'als 'e r c ie-ni--a Is 1 121---va I': al_-eled?
a.'Peas Il-e vehicle e uiornenz mai.i:enarce area evaluated at time of ins a ion?
i . Is vehicle andcr equipment washing done in an area so that the urastetvater can be
Properly managed?
-9. Are leaks present at rnateriaklhandliing and fueling sialions?
9. If leaks are present, are they properly contained?
10. Are loading and unloading areas being properly maintained to prevent non-
slamwidtr es?
11. Are appropriate spill containment and cleanup materials!equi.pment kept -onsile and
located in an obvious or convenient location?
B. NON-STDRMWATER DISCHARGES
-.: =5
`,G
A
1. Was the WOMWjft drainage system inspected for non yftdischarges or
evidence thereof?
2. Do the WiU,tMI CM curtfalls listed on the rile map match what was. visually -observed in
the field?
RecommendafionafRequirerrkents:
Final Evaluation
(Check most appropriate box.)
No defiriiencies were observed during inspection.
Minor issues were observed during inspection.
Major issues were observed during inspection. Site needs to be fon�iarded to
the North Carolina aeparlment of Environment Quality for TjqqWaKa
Water quality violation (.or si gn ificant th reat) tivas observed. Local enforcement is recommended
and site should be referred to the N.C. department of Environment Quality.
Inspector Signature: Date..
w18
Page 17 of 24

Appendix D: TRI Inspection Form
J
MEENSBSRG
I ity of reensboro tqm), at?,r. IndUstrial Inspection Report
FACILITY INFORMATION
Facility:
Add ress:
Contact
Phone:
Date:
NAIL ISIC Code:
Industrial AcG04-,.
CHECKLJST: PREVENTATIVE MAINTENANCEfGOOD HOUSEKEEPING
4 = In Compliance
X = Needs Renkediation
NA = Not Applicable
Materials are stored in areas that limit exposure to precipitation or runoff.
Materials (e.g., chemicals) are properly labeled.
Ahave-grounv =forage tarks and material -handling areas have adequate secondary containment.
including furs—. -3-irg vaivesriocks.
Processes are n pJaoe for property removing raimMer from secondary containment.
Loading and unloading areas are property maintained to prevent non-WpZMWaW
Vehiclelequipment maintenance areas are properly maintained.
Vehicle andlor equipment washing is done in an area so that wastewater can be prep&rly managed.
Leaks at material -handling areas and fueling stations are properly contained, 5'riil, pro:.crl_res n
place for proper dis posal.
ADDITIONAL COMMENTSICORRECTIONS
FINAL EVALUATION
❑ No deficiencies were observed dUring inspection.
❑ Facility should remedy issues noted above by
❑ Facility is noncompliant. A Notice of Violation will follow.
Facility Official: Date:
Inspector: Date:
GENERAL RECOMMENDATIONS
+ Regularly train employees on gpgaV*j�� discharge prohibitions. wastewater discharge requiremerrWprohibilions.
and spill response and clean-up.
+ Routinely inspect drainsioutlets, eval uating and eliminating any non-ftUyft discharges.
+ Add maintain spill kits and keep them in easily acoessible areas.
. t..-,.:• Cft of — .e E.U.
Page 18 of 24

Appendix E: NPDES Inspection Letters
Letter 1: No Deficiencies
City of Greensboro
J North Carolina
[DATE]
[NAME]
[BUSINESS]
[ADDRESS]
[CITY, STATE, ZIP]
RE: Industrial Compliance Inspection
Inspection location: [FACILITY NAME]
[FACILITY ADDRESS]
SW Permit #: [PERMIT #]
Dear [CHOOSE] [LAST NAME]:
On [INSPECTION DATE] the City of Greensboro Stormwater Management Division completed an industrial compliance inspection of
[FACILITY NAME]. Local regulations pen -nit an inspection of industrial facilities under authority granted by City of Greensboro Code of
Ordinance Chapter 30, Article 12, Section 7.1 (C-5). This inspection consisted of two parts: a review of the facility files/records and an on -
site facility inspection.
The inspection was performed by [CHOOSE], and the following deficiencies/observations were noted during the inspection.
Storm water Pollution Prevention Plan/Spill Plan Review
Site Maps and SWP3
♦ No deficiencies observed.
Spill Prevention and Response Plan
♦ No deficiencies observed.
Monitoring
♦ No deficiencies observed.
Employee Training
♦ No deficiencies observed.
Site Inspection
Preventative Maintenance/Good Housekeeping
♦ No deficiencies observed.
Non-Stormwater Discharges
♦ No deficiencies observed.
We appreciate your cooperation and proactive approach. If you have questions or concerns at any time, please contact me at [CHOOSE].
Sincerely,
[CHOOSE]
City of Greensboro, Water Resources Department
cc: Peter Schneider, Water Quality Supervisor
[CHOOSE], N.C. Dept. of Environment Quality
Industrial Inspection File
P.O. Box 3136 m Greensboro, NC 27402-3136 ® www.greensboro-nc.gov m (336) 373-CITY (2489) ® TTY # 333-6930
Page 19 of 24

Letter 2: Minor Deficiencies
rpd-�
City of Greensboro
A-01
North Carolina
[DATE]
[NAME]
[BUSINESS]
[ADDRESS]
[CITY, STATE, ZIP]
RE: Industrial Compliance Inspection
Inspection location: [FACILITY NAME]
[FACILITY ADDRESS]
SW Permit #: [PERMIT #]
Dear [CHOOSE] [LAST NAME]:
On [INSPECTION DATE] the City of Greensboro Stormwater Management Division completed an industrial
compliance inspection of the [FACILITY NAME]. Local regulations permit an inspection of industrial facilities under
authority granted by City of Greensboro Code of Ordinance Chapter 30, Article 12, Section 7.1 (C-5). This inspection
consisted of two parts: a review of the facility files/records and an on -site facility inspection.
The inspection was performed by [CHOOSE], and the following deficiencies/observations were noted during the
inspection.
Stormwater Pollution Prevention Plan/Spill Plan Review
Site Maps and SWP3
♦ Deficiencies observed.
Spill Prevention and Response Plan
♦ Deficiencies observed.
Monitoring
♦ Deficiencies observed.
Employee Training
♦ Deficiencies observed.
Site Inspection
Preventative Maintenance/Good Housekeeping
♦ Deficiencies observed.
Non-Stormwater Discharges
♦ Deficiencies observed.
It is recommended that [FACILITY NAME] take appropriate actions to correct the noted deficiencies. If you have any
questions concerning this inspection, please contact me at [CHOOSE].
Sincerely,
[CHOOSE]
City of Greensboro, Water Resources Department
cc: Peter Schneider, Water Quality Supervisor
[CHOOSE], N.C. Dept. of Environment Quality
Industrial Inspection File
P.O. Box 3136 ® Greensboro, NC 27402-3136 ® www.greensboro-nc.gov m (336) 373-CITY (2489) ® TTY # 333-6930
Page 20 of 24

Letter 3: Maior Deficiencies, State Notification
r City of Greensboro
J North Carolina
[DATE]
[NAME]
[BUSINESS]
[ADDRESS]
[CITY, STATE, ZIP]
RE: Industrial Compliance Inspection
Inspection location: [FACILITY NAME]
[FACILITY ADDRESS]
SW Permit #: [PERMIT #]
Dear [CHOOSE] [LAST NAME]:
On [INSPECTION DATE] the City of Greensboro Stormwater Management Division completed an industrial compliance
inspection of the [FACILITY NAME]. Local regulations permit an inspection of industrial facilities under authority granted
by City of Greensboro Code of Ordinance Chapter 30, Article 12, Section 7.1 (C-5). This inspection consisted of two parts: a
review of the facility files/records and an on -site facility inspection.
The inspection was performed by [CHOOSE], and the following deficiencies/observations were noted during the inspection.
Storm water Pollution Prevention Plan/Spill Plan Review
Site Maps and SWP3
♦ Deficiencies
Spill Prevention and Response Plan
♦ Deficiencies
Monitoring
♦ Deficiencies
Employee Training
♦ Deficiencies
Site Inspection
Preventative Maintenance/Good Housekeeping
♦ Deficiencies
Non-Stormwater Discharges
♦ Deficiencies
Based on the above deficiencies, the City of Greensboro will notify the North Carolina Department of Environmental and
Natural Resources (NCDENR) and request a follow-up inspection. [FACILITY NAME] may be notified by NCDENR in
advance of this inspection so proper scheduling of personnel can take place. Furthermore, any penalties assessed against the
City by the State as a result of this non-compliance will be assessed against [FACILITY NAME].
If you have any questions concerning this inspection, please contact me at [CHOOSE].
Sincerely,
[CHOOSE]
City of Greensboro, Water Resources Department
cc: Peter Schneider, Water Quality Supervisor
[CHOOSE], N.C. Dept. of Environment Quality
Industrial Inspection File
P.O. Box 3136 m Greensboro, NC 27402-3136 ® www.greensboro-nc.gov m (336) 373-CITY (2489) ® TTY # 333-6930
Page 21 of 24

Appendix F: Database Entry
Sections A, B, and C refer to the facility record. Each facility has one record but
may have multiple inspections (Section D).
E Permitted Facilities
Permitted Facilities
Facility Name
VeceIIioand Grogan, Inc.
Fad I ity Address
6311 Burnt Poplar Rd.
City Zip Code
Greensboro 274M
Assigned Inspector
Wells, Rebecca
Contact Info Contact Address Website
Contact First Name Contact Last Name
John Riley
Contact Phone Fax
(336) 235 275b U)12 5 2743
Contact Email
J o h n. Ri I ey@sha rpebrosvg.com
A It 92 of 98 1 ► I ►I ►
Permit# Id Information
NCG16017F 91 1 Links
SIC Code Industry Activity
2951 Asphalt Paving Mixtures, Blo
Last City Inspection Last Permitted
J2/5f2011 I�
Last State Inspection: Inspected By:
RN Analytical Sampling. r No Exposure
Vehicle Maint.? P- NPDES
Comments F SARA
New Inspection Delete Facility
Inspection Date: Inspector is Inspector2:
F 1215/2011 Wells, Rebecca 0 50 1 of 2 1
RecomrrhendationSf ReWirements: Insp. IR:95
-Conduct ind document water quality sampling.1 Delete lnspectior.
-Properlytrain employeeson appropriate record keepingand inspections
SWP3-A-1
Is a copyof the signed SWP-3 at the facility?
Q Yes Q No Q Ply
L
SWP3-A-2
Is the general location map present? D
Yes 0 No 0 MA
SWP3-A-3
Isthere a site map that shows drainage patterns, outfalls, floor drains,
(j) Yes Q No Q NA
etc.?
SWP3-A-4
Isthere a written or unwritten Stormwater Facility Inspection Program
0 Yes Q No Q NA
(i.e. routine site observations noting potential issues)?
SWP3-A-5
Are the names of receivingwater(s) listed (orshown and ade ed on the
Yes 0 No Q NA
site map)?
r
Page 22 of 24

Facility Manta
Vecellio and Grogan, Inc.
Facility Address
6311 Burnt Poplar Rd.
city
Greensboro
Assigned Inspector
Wells, Rebecca
Zip Code
27409
Section A reflects the
most recent facility
information, such as the
business name and
address. This section also
reflects the assigned
inspector.
7Contactfo Contact Address
Website
Section B is where the
current contact
Contact First Name
Contact Last Name
information is stored
John
Riley
via the three tabs:
Contact Phone
Contact Fax
Contact Info, Contact
[phone]
[phone]
Address, and Website.
Contact Email
[e-mail]
Permit# ID Infarmation
NCG16417b F84 Links
SIC Code Industry Activity
2951 Asphalt Paving Mixtures, Blo
Last City Inspection Last Permitted
iz{s{zaii
Last State Inspection_ Inspected By:
r Analytical Sampling? F- No Exposure
r Vehicle Maint.? W NPDES
Camrnents FH- SARA
Section C considers information related to the
facility's NPDES permit, TRI, status, or No
Exposure Certification. Included in this section are
permit number, activity type, sampling
requirements, etc. Comments can also be included
I in this section and serves a good location to note
past business names, parent companies, and/or
other information that cannot be noted elsewhere in
the record.
Page 23 of 24

Inspection Date: Inspector L- Inspector2:
12/5/2011 Wells, Rebecca 4 1 of 2 111
Recommendations/Requirements: Insp. ID: 95
,-Conduct and document water quality sampling.! Delete Inspection
-Properly train employees on appropriate record keeping and inspections .
SWP3-A-1 Is a copy of the signed SWP-3 at the facility? O' Yes Q No 0 NA
SWP3-A-2 Is the general location map present? Q Yes Q No O NA
SWP3-A-3 Is there a site map that shows drainage patterns, outfalls, floor drains, E) Yes Q No Q NA
etc.?
SWP3-A-4 Is there a written or unwritten Stormwater Facility Inspection Program 0 Yes 0 No O NA
(i.e. routine site observations noting potential issues)?
SWP3-A-5 Are the names of receiving water(s) I isted (or shown and labeled on the G Yes O No Q NA
site map)?
Section D reflects individual inspections of the facility. There will be multiple
inspections over time for the same facility, but all are found here within the facility
record. For permitted facilities, the form in this is filled out based on the form used
while inspecting. Deficiencies are noted in the Recommendations/Requirements
box. For TRI and NE facilities, only the top section is filled out, with the box noting
compliance or deficiencies.
Page 24 of 24