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HomeMy WebLinkAboutNCS000240_Industrial Facility SOP_20220930RTb CHARLOTTE,. CITY OF CHARLOTTE PERMIT NUMBER NCS000240 INDUSTRIAL FACILITIES INSPECTION AND MONITORING PROCEDURES MANUAL County Workplan Element IN-I(1) and IN-M(1) Most recent update: October 2021 Table of Contents 1.0 INTRODUCTION ............... ........ 3 2.0 PROGRAM OVERVIEW......................................................................................................................................................3 3.0 INVENTORY OF FACILITIES 4.0 PRE -INSPECTION PREPARATION..........................................................................................................................5 4.1 RECORDS REVIEW...................................................................................................................................................................... s 4.2 SCHEDULING THE INSPECTION..........................................................................................................................................7 4.3 SAFETY GEAR, EQUIPMENT AND TOOLS...................................................................................................................7 4.4 EMPLOYEE TRAINING..........................................................................................8 5.0 ON -SITE INSPECTION PROCEDURES................................................................................................................8 5.1 GENERAL ATTITUDE, ROLE AND BEHAVIOR.........................................................................................................8 5.2 PRESENTATION OF CREDENTIALS.................................................................................................................................. s 5.3 CONSENT......................................................................................................................................................9 5.4 WAIVERS, RELEASES, AND SIGN -IN LOGS..............................................................................................................10 5.5 OPENING CONFERENCE........................................................................................................................................................10 5.6 DOCUMENTATION....................................................................................................................................................................11 5.7 PHYSICAL INSPECTION............................................................................................................................................................12 5.8 CLOSING CONFERENCE...........................................................................................................................................................13 6.0 DISCHARGE SAMPLING, DYE TESTING AND STORMWATER MONITORING.13 6.1 NON-STORMWATER DISCHARGE SAMPLING...........................................................................................13 6.2 DYE TESTING...................................................................................................................................................................14 6.3 STORMWATER RUNOFF MONITORING.............................................................................................................14 7.0 INSPECTION REPORTS....................................................................................................................................................15 7.1 GENERAL.........................................................................................................................................................................15 7.2 REPORT CONTENT.............................................................................................................................................................16 7.3 MONITORING REPORT CONTENT...........................................................................................................................17 7.4 RULES AND TECHNIQUES FOR PREPARING THE INSPECTION REPORT.......................17 8.0 NOTICES OF VIOLATION AND ENFORCEMENTS.............................................................................20 8.1 FOLLOW-UP ACTIVITIES..................................................................................................................................................20 9.0 REVIEW AND FILING.........................................................................................................................................................21 9.1 CITYWORKS SERVER...........................................................................................................................................................21 APPENDICES 1. Industrial Facilities Master List 2. Industrial Facilities Inspection Prioritization Strategy 3. Stormwater Inspection Report Checklist 4. Industrial Inspection Explanation Letter Industrial Facilities Inspection and Monitoring Procedures Manual 1 Revised October 2021 5. State (NPDES) Compliance Inspection Report Templates 6. City (Non-NPDES) Compliances Inspection Report Templates 7. State (NPDES) Stormwater Monitoring Report and Table Templates 8. City (Non-NPDES) Stormwater Monitoring Report and Table Templates 9. Follow -Up Stormwater Monitoring Report and Table Templates 10. Industrial Facility Monitoring Follow-up Standard Administrative Procedures 10-1 Stormwater Monitoring Follow up Template Letter 10-2 Analytical Results Template 10-3 Analysis of Industrial Stormwater Sampling 11. Vehicle Maintenance Facility Inspection Form 12. Vehicle Maintenance Facility Inspection Report Cover Letter — Satisfactory 13. Vehicle Maintenance Facility Inspection Report Cover Letter — Unsatisfactory Industrial Facilities Inspection and Monitoring Procedures Manual 2 Revised October 2021 1.0 INTRODUCTION This manual was prepared for and used by Charlotte -Mecklenburg Storm Water Services (CMSWS) to implement the City of Charlotte's (City) Industrial Facilities Inspection and Monitoring Program. This program is performed to comply with requirements of the City's Municipal Separate Storm Sewer System (MS4) permit (NCS000240). Specifically, the permit states the following: "Evaluate pollutants in storm water discharges to the permittee's MS4 from hazardous waste treatment, disposal, and recovery facilities, industrial facilities subject to Section 313 of Title III of the Superfund Amendments and Reauthorization Act of 1986 (SARA), and industrial facilities that the Permittee determines are contributing or have a potential to contribute a substantial pollutant loading to the municipal storm sewer system." The purpose of the Industrial Facilities Inspection and Monitoring Program is to inspect facilities located within the City that have the potential to contaminate stormwater or may discharge non - permitted flows into either the municipal separate storm sewer system (MS4) or directly to surface water. The overall goal is to reduce stormwater pollution and eliminate illicit connections and other non -permitted discharges to protect surface water quality. This manual provides the following: • instructions and guidance to prepare for and conduct industrial inspections and monitoring, collect vital information, write reports and conduct follow-up activities • guidance for consistent program implementation and quality assurance and control • template documents for program implementation. The City has a contractual agreement with Mecklenburg County Land Use and Environmental Services Agency's Water Quality Program (LUESA — WQP) for staff to conduct stormwater inspections within the City and determine compliance with the City's Stormwater Pollution Control Ordinance. City staff work with LUESA — WQP staff to develop procedures and protocols, analyze reports and monitoring data, establish priorities, and decide on appropriate enforcement paths. LUESA-WQP also has a verbal understanding with the NC Department of Environmental Quality (NC DEQ) Division of Energy, Mineral, and Land Resources (DEMLR) that we will alert them of our findings during industrial inspections of permitted facilities and they will follow up on permit related violations. DEMLR's staff in the Mooresville Regional Office (MRO) has primary oversight for the delegated inspection program. 2.0 PROGRAM OVERVIEW The Industrial Facilities Inspection and Monitoring Program includes inspection and monitoring activities. An industrial facility inspection focuses on four main areas: 1. Inspectors conduct a detailed records review with emphasis on records in LUESA files (in-house files) and those maintained at facilities (on -site files). 2. Inspectors conduct an inspection of the physical facility to review relevant facility Industrial Facilities Inspection and Monitoring Procedures Manual Revised October 2021 operations, material storage areas and handling practices, waste streams, stormwater controls, conveyance structures and outfalls, Stormwater Pollution Prevention Plan (SPPP) development, implementation and documentation, and observed impacts to the receiving stream(s). 3. Inspectors conduct dye testing when necessary to ensure that all waste streams are properly plumbed and sample any unidentified discharges to determine pollution potential. 4. Inspectors prepare a written report detailing the inspection findings. The inspection report is issued by LUESA-WQP on behalf of the City, with copies provided to NCDEMLR (NPDES permitted facilities) and all other cooperating organizations as applicable. In cases where pollution problems are detected, a second inspection may be necessary to ensure that any corrective actions proposed by the facility have been implemented. Facilities that do not have an industrial permit and/or have not developed or are not required to develop a formal SPPP are also inspected per plan guidelines. Inspection reports cite any discovered violations of the City's Surface Water Pollution Control Ordinance, and the NPDES Stormwater permit or North Carolina General Statutes where applicable. Following the inspection process, selected facilities are targeted for industrial stormwater monitoring. Facilities are selected for stormwater monitoring based primarily on the facility's potential to pollute stormwater and prior compliance history with local and state stormwater regulations. Analytical results are documented in a Facility Monitoring Report issued by LUESA-WQP on behalf of the City, with copies provided to NCDEMLR (NPDES permitted facilities) and all other cooperating organizations as applicable. 3.0 INVENTORY OF FACILITIES The City maintains master lists of industrial facilities in the City and facilities that have been inspected from FY06 until present. These lists are compiled and reviewed annually. The most current lists are provided as Industrial Facilities Master List, Attachment 1. The Phase I permit requires that the following be included on the inventory list: 1. Hazardous waste transfer/storage/disposal facilities 2. Facilities subject to SARA Title III Section 313 (Toxic Release Inventory reporting) 3. Facilities that have an NPDES Stormwater permit. Facilities may also be placed on the Master List because of the following conditions: casual observations, ambient stream monitoring results, stormwater and industrial monitoring results, biomonitoring, reported spills, citizens' complaints, municipal field personnel referrals, stream walks, and reports from various inspection agencies, including the Charlotte Fire Dept(CFD), Charlotte -Water, LUESA, NCDEQ — Division of Energy, Minerals, and Land Resources (DEMLR) and NCDEQ — Division of Water Resources (DWR). Facilities on the master list are targeted for inspections and monitoring each year based on a prioritization process. That process is detailed in the Industrial Facilities Inspection Prioritization Strategy, Attachment 2. Industrial Facilities Inspection and Monitoring Procedures Manual 4 Revised October 2021 4.0 PRE -INSPECTION PREPARATION 4.1 Records Review A thorough records review is essential for the overall success of a compliance inspection. The amount of information collected about a facility depends on many factors including the inspection purpose, prior knowledge of the Inspector, and the availability of information. Inspectors may write down information relevant to the facility on the Stormwater Inspection Report/Checklist, Attachment 3 which they use for their inspection. The completed checklists and notes may then be used to prepare the inspection report following the inspection. On the day of the inspection, Inspectors may also want to take copies of relevant in-house documents to be used as reference materials. Table 1 presents a variety of sources and the types of information that may be gathered. Table 1: Information Sources Agency / Source Types of Information Organization Facility Files at facility or corporate office; Permits, SPPP, SPCC, maps/layout, process and company website production info, materials storage, photos, contact info, monitoring data, consultant studies, safety info, other LUESA (WQ, AQ,) Facility files; Cityworks Server Same as facility files, depending on previous inspection history and info gathering; additional sampling, previous inspection reports, citizen complaints, other EPA - ECHO https:Hecho.epa.gov/ EPA's ECHO website can be used to search for facilities to assess their compliance with environmental regulations, investigate pollution sources, or examine and create enforcement - related maps EPA http://www.epa.gov/lawsregs/ Laws and regulations NC DEQ - DEMLR http://portal.ncdenr.org/web/Ir/npde Permitting info, laws/regulations, technical s-stormwater, MRO staff bulletins, 303(d)-listed impaired waters, knowledge, MRO files watershed management plans, compliance database information Mecklenburg County POLARIS; GeoPortal Land records info, aerial photographs, GIS geographical info, stream buffer info, storm drain & sanitary sewer infrastructure, other Charlotte Water Mapping, Pretreatment Division Sanitary sewer maps, pretreatment permits, wastewater compliance and sampling data, general facility info, process & production info Charlotte Fire Hazardous Materials database Facility hazardous materials storage info, Department inspection reports, contact info To conduct a thorough records review, it may be necessary to contact the facility in advance of the inspection to request copies of their records. Typically, the larger and more complicated the facility, the more time needed to review facility records. For smaller facilities, the Inspector may choose to review facility files at the site. Industrial Facilities Inspection and Monitoring Procedures Manual Revised October 2021 The following outlines the documents that inspectors review prior to inspections. 1. Facility Map(s) Inspectors review maps and aerial photos and determine general location, terrain, drainage patterns, land use/zoning, street and facility layout, buffer requirements, sub -basin number and other valuable information. Maps of the facility and surrounding area are obtained via http://charlotteexplorer/ and/or http://polaris3,g.mecklenbur cg ouatync.gov/ . Storm and sanitary sewer maps are available via CityWorks and on the Arc GIS Collector app. LUESA files for the facility may also contain site maps that may be helpful. 2. LUESA and NC DEQ Information Inspectors review hard copy and electronic files available for the facility from LUESA and NC DEQ sources. LUESA files provide documentation about permits, incidents, spills, violations, prior inspections, contact information, manufacturing processes and materials storage, correspondence and other pertinent information. NC DEQ's Basinwide Information Management System (BIMS) database https://deq.nc.gov/about/divisions/water-resources/bims provides additional information, and correspondence should be sent to the BIMS-listed contact for NPDES permitted facilities. If Inspectors find that any information is incorrect or outdated, they notify NC DEQ staff. 3. Facility's Discharge Permit If a facility has been issued NPDES Stormwater and Charlotte Water Pretreatment permits, the inspector reviews them and any associated records before inspection. These records may include sampling logs, analytical results, maintenance logs, documentation and correspondence, spill reports, etc. 4. Facility's SPPP An important part of the on -site records review is a thorough review and evaluation of the facility's SPPP, if developed. A SPPP is a document that is required for NPDES permitted facilities. It identifies sources of potential stormwater pollutants and outlines the methods and procedures to control and minimize the likelihood of stormwater pollution from the facility due to spills and other industrial activities. A SPPP has six major components: 1. Site Plan 2. Stormwater Management Plan 3. Spill Prevention and Response Plan 4. Preventative Maintenance and Good Housekeeping Plan 5. Training Schedules 6. Inspection Program A SPPP must be updated annually so it is important for the Inspector to review the most updated version and note whether the annual updates have been made. If not, lack of annual updates or reviews is a deficiency. For non -permitted facilities that are not required to develop a SPPP, the individual components of a SPPP are still relevant for pollution prevention and should be kept in mind during the inspection. Industrial Facilities Inspection and Monitoring Procedures Manual 6 Revised October 2021 4.2 Scheduling the Inspection Inspections are typically scheduled, as opposed to unannounced. Unannounced inspections may be conducted based on complaints. One reason for scheduling inspections ahead of time is because the overall nature of the program is assistive rather than punitive, although enforcement actions will be taken if violations or problems are found. A second reason is to allow facility staff to gather records prior to inspection. To schedule an inspection, the Inspector contacts the person who handles environmental issues (i.e., Environmental Engineer, Health & Safety Officer, Plant Manager). When contacting the facility, the Inspector should inform the representative of the following: 1. Name and agency 2. Request to conduct the inspection 3. Purpose of the inspection and the necessary inspection components 4. The authority to conduct the inspection under the City's Storm Water Pollution Control Ordinance 5. Records that are needed for review 6. The facility's right to assert a claim of confidentiality on business information If the facility representative is reluctant to allow the inspection, the inspector should advise that the City's Storm Water Pollution Control Ordinance allow the right of entry by authorized persons to conduct inspections. Inspectors should send the Industrial Inspection Explanation Letter, Attachment 4 to the facility contact prior to the inspection to further explain the inspection's purpose and what to expect. Records that are requested for review may include the SPPP, permits, correspondence, reports and logs. Depending on the size and type of the facility (SIC Code/NPDES permit) the facility may not be required to maintain all of these documents. Finally, the Inspector should inquire about safety requirements at the facility, special gear that will be required, and entry procedures, including security considerations and parking. 4.3 Safety Gear, Equipment and Tools Most industrial facilities have specific safety requirements. At a minimum, the Inspector shall bring along a hard hat, steel -toed boots, safety glasses, hearing protection, a reflective safety vest, and dress appropriate for the conditions to be encountered. Other safety gear and equipment to bring along may include: Additional Safety gloves rainwear coveralls or change of clothes Equipment/Tools credentials/ID flashlight records review files logbook/notebook standard forms and checklists tape measure cell phone with camera, capabilities video, calculator, and watch Industrial Facilities Inspection and Monitoring Procedures Manual 7 Revised October 2021 4.4 Employee Training Inspectors should have a thorough understanding of laws and regulations applicable to Industrial Inspections and Monitoring Program. A lack of knowledge in this area may undermine the Inspector's authority during an inspection and limit their ability to provide adequate, objective judgments about facility conditions. Inspectors need to be familiar with the components of SPPPs, best management practices (BMPs), NPDES Stormwater permits and NPDES stormwater guidance materials. EPA and NC DEQ websites are valuable resources for applicable requirements as well as DWR and DEMLR Surface Water Protection staff in the MRO. 5.0 ON -SITE INSPECTION PROCEDURES 5.1 General Attitude, Role and Behavior The primary nature of the compliance inspection is to be assistive, meaning that Inspectors should have the attitude that they are at the facility to help achieve compliance. If violations are discovered, they should be addressed according to the permit and appropriate laws; however, the Inspector should work with facility personnel to determine possible corrective actions and options for implementation. Corrective actions and implementation options should not be prescriptive in nature; rather, the facility should determine the appropriate path forward to avoid liability to the regulatory agency. Facility personnel are often nervous and occasionally confrontational. The Inspector should do their best to put personnel at ease by maintaining a calm, pleasant demeanor. The Inspector should bring along copies of educational materials and resources to emphasize the assistive nature of the inspection and have copies of appropriate permits/regulations for reference in case personnel misunderstand regulations. All information should be recorded accurately and objectively. During an inspection, any act or failure to act, motivated by private gain, is illegal. Actions that could be construed as such should be scrupulously avoided. Finally, all inspections are to be conducted with due regard for individual rights regardless of race, sex, religion, or national origin. 5.2 Presentation of Credentials Upon arrival at the facility, the Inspector introduces himself or herself as an Inspector from CMSWS and presents their County issued identification badge and provides a business card with contact information. These credentials indicate that the holder is a lawful representative of the regulatory agency and is authorized to perform facility compliance evaluations under the City's Storm Water Pollution Control Ordinance. These credentials must be presented whether or not identification is requested. If facility personnel question the Inspector's credentials, they may telephone the LUESA — WQP office for verification. Credentials should never leave the Inspector's sight or be photocopied. Industrial Facilities Inspection and Monitoring Procedures Manual Revised October 2021 5.3 Consent Consent to inspect the premises must be given by the owner or operator at the time of the inspection. As long as the Inspector is allowed to enter, entry is considered voluntary and consensual, unless the Inspector is expressly told to leave the premises. Expressed consent is not necessary; absence of an expressed denial constitutes consent. The receptiveness of facility personnel toward the Inspectors varies among facilities. Most inspections proceed without difficulty. In other cases, personnel may be reluctant to give entry consent because of misunderstood responsibilities, inconvenience to their schedule, or other reasons that may be overcome by diplomacy and discussion. Whenever there is difficulty gaining consent to enter, Inspectors should tactfully probe the reasons and work with personnel to overcome the problems. Care should be taken to avoid threats of any kind, inflammatory discussions, or deepening of misunderstandings. If consent to enter is still denied, the Inspector should follow these denial of entry procedures: Ensure that all credentials and notices are presented properly to the facility owner or agent in charge. 2. Ask the reason for the denial to see if obstacles (such as misunderstandings) can be cleared. If resolution is beyond the authority of the Inspector, he or she may suggest that the officials seek advice from their attorneys to clarify inspection authority under the City's Storm Water Pollution Control Ordinance and the NPDES permit if applicable. 3. If entry is still denied, the Inspector should withdraw from the premises and contact his or her supervisor. DEMLR in Mooresville should be contacted when entrance to a NPDES permitted facility has been denied. LUESA-WQP and DEMLR may confer with attorneys to discuss the desirability of obtaining an administrative warrant. 4. All observations pertaining to the denial are to be carefully noted in the field notebook and inspection report. Information such as the facility name and exact address, name and title of person(s) approached, name and title of the person(s) who refused entry, date and time of denial, detailed reasons for denial, facility appearance, and any reasonable suspicions of regulatory violations should be documented. All this information will be important if a warrant is sought. If the facility personnel ask the Inspector to leave the premises after the inspection has begun, the Inspector should leave as quickly as possible following the procedures discussed above for denial of entry. All activities and evidence obtained before the withdrawal of consent are valid. The Inspector should ensure that all personal and government equipment is removed from the facility. If access to only some parts of the facility is denied, the Inspector should make notes about the circumstances surrounding the denial of access and of the portion of the inspection that could not be completed. The Inspector should then proceed with the rest of the inspection. After leaving the facility, the Inspector should contact his or her supervisor, and the DEMLR's Supervisor in Industrial Facilities Inspection and Monitoring Procedures Manual 9 Revised October 2021 Mooresville if applicable, to confer with legal representatives about whether an administrative warrant should be obtained to complete the inspection. 5.4 Waivers, Releases, and Sign -In Logs When a facility provides a blank sign -in sheet, log, or visitor register, it is acceptable for Inspectors to sign it. However, CMSWS employees must not sign any type of "waiver" or "visitor release" that would relieve the facility of responsibility for injury or that would limit the rights of CMSWS to use data obtained from the facility. The Inspector may cross out and initial any wording that is unacceptable due to its restrictive nature. If such a waiver or release is presented, the Inspector should politely explain that they cannot sign it and request a blank sign -in sheet. If the Inspector is refused entry because they do not sign the release, they should leave and immediately report all pertinent facts to their supervisor. All events surrounding the refused entry should be fully documented. 5.5 Opening Conference Once credentials have been presented and legal entry has been established, the Inspector can proceed to outline inspection plans with personnel at a pre -inspection meeting called the "Opening Conference". At the Opening Conference, the Inspector will provide the names of the Inspectors, the purpose of the inspection, authorities under which the inspection is being conducted, and procedures to be followed. The following provides a list of topics pertinent to the Opening Conference: 1. Inspection Objectives An outline of inspection objectives informs facility officials of the purpose and scope of the inspection and may help avoid misunderstandings. 2. Order of Inspection A discussion of the order in which the inspection will be conducted helps eliminate wasted time by allowing officials time to make records available and start up intermittent operations. 3. Claims of Confidentiality The Inspector should explain the permittee's right to claim certain material as confidential business information (CBI). Confidential information is discussed in greater detail in Section 12.3 Documentation. 4. Records to be Reviewed A list of facility records to be reviewed during the inspection should be provided to facility personnel (e.g., permit, SPPP, monitoring reports, sampling data, operation and maintenance records, training records, lab data sheets, and other records). This will allow adequate time for gathering records for the Inspector. 5. Accompaniment Facility personnel must accompany the Inspector during the inspection to not only answer questions and describe the plant and its principal operating characteristics, but also for safety and Industrial Facilities Inspection and Monitoring Procedures Manual 10 Revised October 2021 liability considerations. Discussion of such needs with facility personnel will provide them the opportunity to allocate personnel for this purpose. 6. Permit Verification The Inspector should verify pertinent information included in its permit, such as facility name and address, receiving waters, and discharge points. The Inspector should also validate (or obtain) accurate outfall location data (i.e., the precise latitude and longitude of each outfall). 7. Safety and Security Requirements The Inspector should discuss site -specific safety and security requirements with facility personnel. OSHA safety standards and internal safety policies should always be followed. Under no circumstances should an Inspector attempt to enter any confined space, nor should he or she climb to an elevated level without proper fall prevention equipment. 8. Closing Conference A post -inspection meeting should be scheduled with appropriate officials to provide a final opportunity to gather information, answer questions, present findings and deficiencies, and complete administrative duties. 9. New Requirements The Inspector should discuss and answer questions pertaining to any new rules and regulations that might affect the facility. If the Inspector is aware of proposed rules that might affect the facility, he or she may wish to encourage facility officials to obtain a copy. 10. Photography/Video Photography is an essential tool used to assist the Inspector in preparing a thorough and accurate inspection report, to present evidence in enforcement proceedings, and to document conditions found at a site. There may be areas that are electrically -classified, prone to explosion, and/or sensitive to a camera and/or flash. The Inspector should discuss any concerns that facility personnel have with pictures being taken. Photos and video of certain parts of the process and facility may be claimed as confidential business information and should be handled accordingly. If the facility personnel express reservations about allowing the Inspector to take photographs, a mutually acceptable solution should be achieved. This can be as simple as agreeing to avoid photographing sensitive items which are irrelevant to the inspection, and/or allowing the representative to immediately view the image and have the option to delete it if is deemed unacceptable. 5.6 Documentation Documentation is a general term referring to all printed information and mechanical media produced, copied, or taken by an Inspector to provide evidence of suspected violations. Forms of documentation include the field notes, statements, photographs, videotapes, drawings, maps, printed matter, mechanical recordings, and copies of records. Proper collection and handling of documents and evidence is one of the most critical elements of the inspection process. Because an enforcement action depends on the evidence gathered, Industrial Facilities Inspection and Monitoring Procedures Manual 11 Revised October 2021 Inspectors must keep detailed records of each inspection. Notes and documentation are used for preparing the inspection report, determining the appropriate enforcement response, and giving testimony in an enforcement case. Inspector's Field Notes The field notes are the core of all documentation relating to an inspection. They provide accurate and inclusive documentation of all inspection activities. All information that appears in the final inspection report should also appear in the field notes or other inspection documentation such as the Inspection Report Checklist. The following are important information and rules that Inspectors shall follow related to field notes: • All entries should be made in permanent ink. • Note the date and time of arrival and departure each day. • Language should be objective, factual, and free of personal feelings or terminology that might prove inappropriate. • Avoid making legal assumptions. • Errors should be crossed out, initialed and dated. • The Inspection Report Checklist and associated notes should never leave the inspector's possession during the inspection. • Do not allow a facility to copy the field notes. • Filed notes become an important part of the evidence package and are admissible in court. • Field notes are a part of government records and are not to be considered the inspector's personal record. Photographs The documentary value of photographs ranks high as admissible evidence. Clear photographs of relevant subjects provide an objective record of conditions at the time of inspection. Inspectors should try to keep "sensitive" operations out of the photographed background. Photographs showing confidential operations or information must be handled as confidential information. Identification of Documents Inspectors should be able to identify all documents collected after an inspection. Document identification is especially important if an Inspector is called to testify in a court case. 5.7 Physical Inspection Following the opening conference, the Inspector conducts the Physical Inspection which consists of a walk-through of the facility buildings and grounds to review the status of SPPP implementation; inspection of best management practices (BMPs) and stormwater controls; search for any pollution problems or potential problems; review outfalls, sampling locations and receiving waters; and verification of the existence or non-existence of illicit connections and/or connections. The Inspector brings a copy of the Stormwater Inspection Report/Checklist and refers to it during the inspection. The Inspector should review any outdoor processes or storage practices that may cause a Industrial Facilities Inspection and Monitoring Procedures Manual 12 Revised October 2021 problem. The inspector should pay particular attention to vehicle maintenance shops, production areas, loading/unloading areas, machine shops, heavy equipment storage areas, fueling areas and any other areas unique to the facility. Observe the entire site for signs of spills or illegal dumping and inquire about waste storage and disposal. Check the catch basins, drainage ditches, and outfalls for buildup of debris and evidence of spillage. Any non-stormwater (dry weather) flows should be noted. When inspecting the receiving stream, observe the condition of the water and review the stream banks for evidence of debris build up and spillage. In addition, note the areas where it is feasible to conduct sampling activities. If a violation of the Stormwater Pollution Control Ordinance is discovered, potential penalties, especially penalty amounts, should not be discussed. The Inspector should, however, point out violations and deficiencies and may briefly suggest ways to remedy the situation, although a more detailed discussion should be left to the closing conference and inspection report. Inspectors should be careful to only provide options, not specific or prescriptive remedies. 5.8 Closing Conference Facility personnel are usually anxious to discuss the findings of an inspection before the Inspector leaves. To achieve the most effective results, the Inspector should hold a closing conference to promptly communicate preliminary findings to the facility personnel. The conference provides an opportunity to describe deficiencies found and identify areas of concern (e.g., unpermitted discharge, parts of a SPPP missing, inspections not being done, silt fence not installed, discharge to a storm drain, etc.). During this conference, Inspectors can answer final questions, provide information about the NPDES program, and request the compilation of data that were not available at the time of the inspection. The closing conference also presents an opportunity for the Inspector to deliver compliance assistance materials and DEMLR contact information if specific NPDES permitting issues arise. Inspectors should be prepared to discuss follow-up procedures, such as how inspection results will be compiled to prepare a report and what further communications CMSWS and DEMLR may have with the facility. 6.0 DISCHARGE SAMPLING, DYE TESTING AND STORMWATER MONITORING Sampling and dye testing activities will be conducted as deemed necessary on a case -by -case basis. The parameters to be sampled and the sampling strategies will be determined based on facility conditions and observations, facility type, industrial processes, materials stored on -site and the type of pollution problem(s) being investigated. 6.1 Non-stormwater Discharge Sampling In cases where non -permitted flows are detected, the Inspector should sample the discharge as soon as possible to identify the presence or absence of pollution from illicit discharges and connections. Inspectors should follow the Standard Administrative Procedure for Industrial Facility Monitoring. The Inspector may want to conduct additional parameter testing of the discharge based on information obtained during the inspection. Industrial Facilities Inspection and Monitoring Procedures Manual 13 Revised October 2021 6.2 Dye Testing In cases where illicit connections are suspected but not easily identified (e.g., floor drains, suspicious pipes, etc.), Inspectors will conduct dye testing to determine the discharge point(s) for sanitary plumbing and/or drainage systems. Any systems discharging inappropriately should be documented and corrective measures should be addressed immediately. Inspectors should refer to CMSWS' Illicit Discharge Detection and Elimination (IDDE) Manual for guidance on dye testing and response to illicit connections. 6.3 Stormwater Runoff Monitoring For select facilities, Inspectors sample stormwater runoff during representative rain events. Analysis of the runoff further identifies pollution problems and evaluates the effectiveness of the SPPP (if required) and any applicable management practices. Facilities selected for stormwater monitoring are those that, based on facility inspections, are determined to have the highest potential for generating polluted stormwater runoff. The strategy for sampling stormwater runoff is based on the type of sample and rain event needed and the on -site conditions at the facility. When sampling for pollution problems, grab samples should be taken during the first flush (taken within the first 30 minutes of stormwater runoff).. If a facility's NPDES permit designates a sampling point and sampling strategy, the Inspector should sample at this location if possible. NPDES permits specify runoff criteria for sample collection. NPDES permits issued in 2012 or later state that a stormwater sample may be collected during a measurable storm event which is defined as an event that results in an actual discharge from the permitted site outfall. The parameters to be sampled, at a minimum, include those specified in the City of Charlotte -Mecklenburg County Work Plan under IN-M(l ). The sampling point (i.e., outfall location) is another consideration for Inspectors. If the facility has a SPPP, the outfall sampled should be one of the outfalls designated as a sampling point. In cases where there are multiple outfalls, the Inspector may choose to sample several locations. In such cases, the drainage areas for the sampling points should contain varying materials and activities. If only one sampling point is chosen, that point should drain an area where especially poor housekeeping or illicit discharges were observed. Another selection factor may be how well the sampling point drainage area represents overall activities and conditions at the facility. Inspectors need to use proper sample collection, preservation, transportation, and delivery techniques as required by the Industrial Facilities Monitoring Sampling and Analysis Plan (SAP) and other monitoring Standard Operating Procedures (SOPS) referenced in that document. All monitoring -related SAPS and SOPS are included as appendices to CMSWS' Quality Assurance Project Plan. Industrial Facilities Inspection and Monitoring Procedures Manual 14 Revised October 2021 7.0 INSPECTION REPORTS 7.1 General Following all document review, inspection, and certain sampling activities, Inspectors create a detailed inspection report that includes: • a cover letter; • a CityWorks report generated from the Stormwater Inspection Report Checklist; and • illicit discharge sampling and dye test results (if applicable). The report should be written as promptly as possible following the inspection, within a maximum of fifteen (15) days, then issued to the permit holder and forwarded to NCDEMLR (for NPDES permitted facilities) and Charlotte Storm Water Services. All reports, NPDES and non-NPDES facilities are issued on CMSWS letterhead using the City's standard reporting format found in Stormwater Inspection Report/Checklist, Attachment 3. CMSWS only makes notes within the report regarding deficiencies related to a facility's NPDES permit, if applicable. For non -permitted facilities, inspection reports are issued in one of four formats: 1) Satisfactory: The facility is practicing good housekeeping, has adequate best management practices, and is compliant with all local, state and federal water quality laws/regulations. 2) Unsatisfactory: The facility has poor housekeeping issues or signs of actual or potential stormwater pollution, but no violations of local, state or federal water quality laws/regulations were found. 3) Notice of Violation (NOV): The facility is in violation of the City of Charlotte Storm Water Pollution Control Ordinance. 4) Notice of Violation/Recommendation for Enforcement (NOV-NRE): The facility is in serious or repeated violation of the City of Charlotte Storm Water Pollution Control Ordinance. For NPDES permitted facilities, the Inspector issues the Inspection Report based on deficiencies/violations observed under the City's Storm Water Pollution Control Ordinance only. Inspection Reports for NPDES permitted facilities are forwarded to DEMLR who then determines if deficiencies or violations of the facility's permit were found during CMSWS' inspection. They may then issue a separate report on DEMLR letterhead detailing compliance with the facility's permit. Inspectors should only make general statements in the cover letter and report regarding permit - related items (SWPPP, Qualitative Monitoring, Analytical Monitoring, and Permit and Outfall sections). An inspection report will not be issued as Unsatisfactory, NOV, etc. based on deficiencies/violations observed with permit -related items, but on deficiencies/violations observed under the City's Storm Water Pollution Control Ordinance. For cover letter templates see the following: • State (NPDES) Compliance Inspection Report Templates, Attachment 51 provides Industrial Facilities Inspection and Monitoring Procedures Manual 15 Revised October 2021 cover letter templates on CMSWS letterhead for NPDES permitted facilities. Language in these cover letter templates state that DEMLR has been copied on the report and made aware of observations pertaining to the facility's NPDES stormwater permit. These templates also contain sections where the Inspector can make general statements regarding permit -related items (SPPP, Qualitative Monitoring, Analytical Monitoring, and Permit and Outfalls). • City (Non-NPDES) Compliance Inspection Report Templates, Attachment 6, provides cover letter templates on CMSWS letterhead for non -permitted facilities. These cover letter templates do not reference DEMLR and do not have sections for permit - related items. All cover letter templates include recommendations and/or corrective actions for compliance with the City's Storm Water Pollution Control Ordinance. 7.2 Report Content Cover Letter The cover letter will be a general letter addressed to the Permit Contact for NPDES facilities or the highest ranking local official for non-NPDES permitted facilities. The letter and inspection report will be issued under City letterhead. The letter will discuss the date of the inspection, identify the Inspector, and call attention to problems and necessary recommendations noted in the report. Andrew DeCristofaro, City of Charlotte, should be provided with a final copy of all reports. Cover letters and reports for NPDES permitted facilities should be emailed DEMLR with correspondence to DEMLR uploaded in Cityworks. Stormwater Inspection Report/Checklist The Stormwater Inspection Report/Checklist, Attachment 3 should be completed for all facilities. The Checklist consists of five sections and contains questions under the following headings: • Site Inspection, • Stormwater Pollution Prevention Plan (SPPP), • Qualitative and Analytical Monitoring, Permit and Outfalls, and • Permit and Outfalls, In addition to the five main sections, the Inspection Report/Checklist also includes a section for facility description, file review/history, and Inspection Summary. Cityworks Server currently only allows 900 characters for each of these sections, so Inspectors should include the most pertinent information for each. If a question is not applicable, then NA should be selected. Examples when NA may be selected include: not all facilities may be required to perform analytical monitoring or non -permitted facilities are not required to develop and implement a SPPP. Questions answered under the Site Inspection section should be answered based on if deficiencies were observed. All other questions in the Checklist should be answered based on if the specific item(s) in the question was observed or conducted. For all sections, other than the Site Inspection section, if a Checklist question is answered "No", an explanation must be provided in the appropriate Comments section. Additional information regarding a facility's compliance with a given part of the NPDES permit should be included in the appropriate Industrial Facilities Inspection and Monitoring Procedures Manual 16 Revised October 2021 Comments section. The Inspector should refrain from prescriptive corrective actions or recommendations and allow the facility/permittee to decide the mechanism through which the permittee will obtain/maintain compliance with the NPDES permit. Certain NPDES general permits contain benchmark concentrations for analytical monitoring. The Inspector should ensure that the facility has addressed any elevated results in the SWPPP as required in the permit. The Inspector should include a description of the sampling results in the Comments section. 7.3 Monitoring Report Content For NPDES permitted facilities inspectors should use the State (NPDES) Stormwater Monitoring Report and Table Templates, Attachment 7 and for non -permitted facilities the City (Non-NPDES) Stormwater Monitoring Report and Table Templates, Attachment 8 should be used. Each report consists of a cover letter similar to the inspection report and follows with descriptions of sampling procedures, sample types, parameters, locations and times. A summary of monitoring results should be provided along with a general discussion/interpretation of the results. While there are no specific effluent limitations for stormwater runoff from industrial facilities, most NPDES Stormwater permits include benchmark values for certain parameters. In such cases, Inspectors should discuss results in relation to permit requirements concerning benchmark values. Stormwater monitoring results are an indicator of pollution potential and the success of best management practices at a facility. Inspectors should offer general recommendations to reduce pollution impacts if results indicate possible problems. 7.4 Rules and Techniques for Preparing the Inspection Report The following are rules and techniques to follow when preparing the report: 1. Write the report as soon as possible upon return from the field. 2. Write the report in the third person. 3. Use simple, direct language, and short sentences. 4. Identify, by name and relationship to the facility, who said what and when. 5. Clearly identify all potential violations observed during the inspection or evaluated prior to the report write-up. 6. Limit report text to factual information only. Do not make assumptions. 7. Provide a complete and detailed description of all materials gathered to support any identified violations (e.g., all photographs, maps, diagrams, etc.) 8. Identify, number, and reference all attachments in the narrative of the report. 9. Use consistent word choice (e.g., if a particular device is called a "Waste-o-Matic," use the term "Waste-o-Matic" throughout the report to describe that particular device). 10. Do not use negative inferences. For example, avoid saying "...the only drums found were...," which implies that no other drums were at the facility. Simply state what was observed (e.g., "During the inspection, five drums were observed..."). 11. Do not use vague and ambiguous terms or statements. For example, avoid using words like indicated, implied, suggested, several, many, some, or it was determined. 12. Do not use absolute terms like all, always, or every, unless the findings and observations have been fully verified and documented. Industrial Facilities Inspection and Monitoring Procedures Manual 17 Revised October 2021 13. Do not repeat or use information obtained from previous inspection reports that was not verified during the inspection. 14. Provide a time frame for a written response that describes all actions that the facility should complete as a result of the inspection. 8.0 NOTICES OF VIOLATION AND ENFORCEMENTS In cases where facilities have violated NPDES permit requirements, DEMLR will make determinations based on information provided by CMSWS. DEMLR issues Notices of Violation (NOVs) and follow-up enforcement actions for permit violations. When inspectors encounter violations of the City's Ordinance, such as an illicit discharge or connection, they should follow procedures for issuing an NOV as detailed in the Illicit Discharge Detection and Elimination Manual. All enforcements for industrial facilities are managed according to procedures outlined in that manual. 8.1 Follow -Up Activities The industrial facility inspection and monitoring process is not always complete after the first report is sent. Only in cases where a "Satisfactory" report was issued would the inspection be complete. In many cases facilities have various poor housekeeping and non-compliance issues, and Inspectors provide recommendations for improvement. When an NOV is issued, the facility is required to conduct certain corrective actions to bring the facility into compliance. Representatives from such facilities are required to submit a report describing what actions they took to address the noted violation(s). The Inspector who originally conducted the inspection should conduct a follow-up visit to ensure that the corrective actions are adequate or if the violations are ongoing (or other violations have taken place). The Inspector should also conduct follow-up inspections in cases where an "Unsatisfactory" report was issued to ensure that additional measures were implemented to correct the noted deficiencies. A follow-up inspection report should be issued to the facility once the facility is in compliance. The procedures for issuing a follow-up inspection report are the same as the initial inspection report. Follow-up inspection templates for NPDES permitted facilities and non - permitted facilities can be found in State (NPDES) Compliance Inspection Report Templates Attachments 5 and City (Non-NPDES) Compliances Inspection Report Templates Attachment 6. In many cases, facilities have monitoring results that exceed water quality action levels or exceed benchmark values (NPDES facilities). Follow up visits should be provided at these facilities to ensure that adequate measures are implemented to reduce polluted runoff. In cases where follow-up monitoring is conducted, Inspectors should work with facility personnel to create an action plan for the facility. The action plan may include additional monitoring for all or some of the parameters, a follow-up inspection, and/or recommendations to reduce polluted runoff from the facility's site. All action plans should be discussed with Andrew DeCristofaro before being implemented. In cases where follow-up monitoring is conducted, the Stormwater Monitoring Follow-up letter and results table provided in Follow -Up Stormwater Monitoring Report and Industrial Facilities Inspection and Monitoring Procedures Manual 18 Revised October 2021 Table Templates, Attachment 9 should be used. The Industrial Facility Monitoring Follow- up Standard Administrative Procedures, Attachment 10 should be used as guidance when determining the most appropriate action plan for follow-up activities. All protocols for conducting an inspection as described in this Procedures Manual should be followed during follow-up activities as well. Follow-up activities should always be documented in the same manner as the original inspection. This is especially important for continuing violations that will eventually involve enforcement procedures. The inspection is complete when the facility has implemented measures to achieve compliance, adequately improved housekeeping and/or has taken steps toward improving practices and procedures to the Inspector's satisfaction. In some cases when the facility has a lengthy path toward achieving compliance, the facility may be re -inspected the following year. 9.0 REVIEW AND FILING 9.1 Cityworks Server Inspections will be documented in Cityworks Server by Activity Reports. Inspectors will create separate Activity Reports for each facility. All IN-I(1) facilities should be attached to the corresponding facility in the GIS facility inspection point file. Inspectors should attach all associated documents pertaining to the inspection to the Activity Report. This may include facilities' Stormwater Pollution Prevention Plans, Spill Response Plans, correspondence pertaining to stormwater, training documents, monitoring reports, etc. If a large amount of photos were taken during the inspection, then the photos should be saved as a zip file and attached to the Activity Report. "Initial" should be selected for the Activity Stage for the initial inspection. If a follow-up inspection is needed, then a new Activity Report should be created and "follow-up" selected as the Activity Stage. The initial and follow-up Activity Reports should be linked together by creating the follow-up inspection as a "child" inspection to the initial report. If a facility is issued an NOV, then a separate NOV Activity Report should be created and linked to the facility Activity Report(s). "Industrial Inspection" should be selected for the Activity Type for initial and follow-up inspections and NOVs, if applicable. All Activity Reports (including NOV Activity Reports) related to IN-I(1), IN-M(1) and IN-M(2) activities should be submitted to Matthew Santiago for review and closure. IN-M(1) and IN-M(2) activities will be documented in an Activity Report. IN-M(1) activities will be documented as "initial" for the Activity Stage and IN-M(2) activities should be documented as "follow-up" for the Activity Stage. "Industrial Monitoring" should be selected under Activity Type for IN-M(1) and "Industrial Monitoring Follow-up" selected under Activity Type for IN-M(2). Attachments for Activity Reports under these program elements should include final and signed cover letters/reports issued by CMSWS as well as lab results. In addition, any associated correspondence with the facility relating to IN-M(1) or IN-M(2) activities should be attached to the Activity Report. If a facility is issued an NOV, then a separate NOV Activity Report should be created and linked to the facility Activity Report(s). All Activity Reports (IN-I(1), IN-M(1), and IN-M(2)) and NOV Activity Reports related to IN- I(1), IN-M(1), and IN-M(2) activities should be submitted to Matthew Santiago for review and Industrial Facilities Inspection and Monitoring Procedures Manual 19 Revised October 2021 closure. 9.2 Inspection Reports Inspection cover letters are prepared in MS Word and named using the facility name and fiscal year. This allows other users to easily identify the file as an inspection report. Inspection reports will be prepared using the Cityworks Server facility inspection template. Once the inspection cover letter and report are prepared, the report should be reviewed for content, wording, accuracy and spelling. The Inspector submits a copy of the cover letter and report to Matthew Santiago for review and approval. If changes are necessary, Matthew Santiago will return the report and advise the Inspector of necessary changes. When the report is final and correct, the Inspector signs the cover letter. The final, signed cover letter is then scanned and attached to the Activity Report before being processed. The Inspector then mails the report. In some cases, the final, signed report can be emailed as a .pdf to the facility contact(s) instead of post mailing. For NPDES permitted facilities, the MS Word cover letter and the inspection report (Cityworks .pdf) are emailed by the Inspector to DEMLR. Note that any CBI information must be placed in its own folder (same file, but a separate folder) marked "Confidential" so it is clear to anyone accessing the files that that folder is not to be provided as part of a file review. 9.3 Documentation During the inspection process, Inspectors generate documentation such as checklists, field notes, drawings, pictures and attachments. This documentation needs to be attached to the Activity Report. 9.4 Filing With the implementation of Cityworks Server, hard copies will no longer be maintained; therefore, all relevant documents to the inspection need to be attached to the Activity Report. Again, all CBI information should be clearly marked "Confidential." Once completed, all Activity Reports associated with each facility should be forwarded to Matthew Santiago to review and close. Rev 1: July 1995 Rev 2: April 1998 Rev 3: November 2002 Rev 4: July 2004 Rev 5: August 2005 Rev 6: August 2006 Rev 7: January 2008 Rev 8: January 2010 Rev 9: September 2010 Rev 10: January 2012 Rev 11: December 2012 Rev 12: January 2014 Rev 13: October 2014 Industrial Facilities Inspection and Monitoring Procedures Manual 20 Revised October 2021 Rev 14: August 2015 Rev 15: November 2016 Rev 16: August 2017 Rev 17: December 2017 Rev 18: August 2018 Rev 19: March 2019 Rev 20: December 2020 Rev 21: October 2021 Industrial Facilities Inspection and Monitoring Procedures Manual 21 Revised October 2021 ATTACHMENT 1 INDUSTRIAL FACILITY MASTER LISTS *See Excel file: Industrial Facility Inspection Master List.xlsx ATTACHMENT 2 INDUSTRIAL FACILITIES INSPECTION PRIORITIZATION STRATEGY Industrial Facilities Prioritization Strategy Charlotte -Mecklenburg Storm Water Services' (CMSWS) Industrial Facility Inspection Program inspects industrial facilities and vehicle maintenance facilities to comply with NPDES Phase I permit requirements and to reduce stormwater pollution in local surface waters within the City of Charlotte. Each year CMSWS inspects approximately forty industrial facilities and twenty vehicle maintenance facilities within the City of Charlotte, although the number of facilities may increase slightly if warranted. Industrial Facilities Beginning in Fiscal Year 2018, CMSWS began prioritizing industrial inspections based on two primary factors: the facility's potential to pollute stormwater, and prior compliance history with local and state stormwater regulations. Previously, these inspections were based on a 5-year rotating basis which led staff to spend equal time inspecting facilities with a low potential to pollute as those with a high potential. The goal of prioritizing inspections is to spend more resources on facilities where improvements are most needed and more efficiently reduce pollution sources. To select industrial facilities for inspection, CMSWS maintains a master database that is composed of facilities that have an NPDES stormwater permit within the City of Charlotte and/ or is required to: • submit Toxic Release Inventory (TRI) information to EPA; or, • treat, store, or dispose of hazardous waste (TSD Facility); or, • have a Pretreatment Permit for discharge into Charlotte Water's sanitary sewer. This master data base is the source from which facilities are then rated as High, Medium, or Low Priority. The rating for each facility determines how often it is inspected. The criteria for each rating and their inspection frequency are described below and outlined in the Figure 1: Flow Chart for the Prioritization of Industrial Facility Inspections. A facility rated "High Priority" typically has a history of non-compliance with local Stormwater Pollution Control Ordinances, a history of significant NPDES permit non-compliance, or a nature of operations that presents a pronounced potential for stormwater pollution. A High Priority Facility is inspected approximately every 1 to 2 years. A facility labeled "Medium Priority" typically has an NPDES permit that requires analytical monitoring, the CMSWS Industrial Monitoring Program has documented high concentrations of pollutants in its stormwater runoff, and/or it is located in close proximity to surface waters or other direct conveyance to surface waters. A Medium Priority Facility is inspected approximately every 3 to 5 years. A facility labeled "Low Priority" typically has an NPDES permit that does not require analytical monitoring and/or it has an NCG02 Mining permit that already requires an annual inspection from NCDEQ — DEMLR. It may also be a "no exposure" facility (no exposure to stormwater certification from the state) that staff recommends for Low Priority status based on review of aerial maps, a drive by, and/or service requests and/or watershed priorities. A Low Priority Facility is inspected every 6-8 years. A facility may also move between High, Medium and Low Priority based on its compliance with local and state regulations. For the purposes of this flow chart, "non -compliant" is defined as a facility that either received an NOV or two or more ordinance deficiencies the previous year. A facility may move into a higher level of priority if its last inspection was considered non- compliant. A facility may move into a lower level of priority if its last two inspections were considered compliant. Ordinance violations are generally active discharges to the ground or stormwater system, illicit connections, or other similar situations and generally handled with a Notice of Violation (NOV). A new violation written into the Ordinance under 18-80(d) called "Improper Storage, Handling, or Processing of Materials" may also be issued. It states "No Person shall store, handle, or process any material upon the land in any manner or method that would allow the material to deposit a Pollutant upon the land which may become intermixed with Stormwater entering the Stormwater System or the Waters of the State." The main intention is for industrial sites with chronic bad outdoor housekeeping where active illicit discharges aren't observed but the site is still very polluted as evidenced visually and by stormwater runoff monitoring results. Industrial facilities that have an NPDES permit, have received no exposure certification from the state and did not receive a recommendation for inspection by staff are not given a priority level and therefore not given an inspection frequency. These facilities will be kept in the master database for annual review, but they are not inspected until labeled a Low, Medium or High Priority. Vehicle Maintenance Facilities As of 2017, there were approximately five hundred vehicle maintenance facilities within the City of Charlotte. CMSWS inspects twenty of these facilities each year because many have poor housekeeping practices that contribute to stormwater pollution by the discharge of petroleum fuels, grease / oil or exposure of metal products. These facilities are not included in the industrial prioritization strategy because they are not permitted and criteria are different. To prioritize these facilities, a master list was developed and a layer was added to the Cityworks database to observe each facility's location in relation to watershed, streams, buffers, and other priority areas. Facilities chosen for inspections each year is based on a combination of staff recommendations, previous inspection results, their location within a "priority" watershed, and a desktop and/or drive -by evaluation. Sites that appear to have outdoor process areas, storage of wrecked cars, staining, odor and/or dead vegetation that may indicate the potential to discharge are prioritized for inspection. The Vehicle Maintenance Inspection Form (below) is utilized to perform vehicle maintenance facility inspections. A priority watershed, desktop evaluation, and drive -by evaluation are defined as: • A priority watershed is one that the City is focused on for the purpose of study or improvement, or a watershed where there is a dense cluster of vehicle maintenance facilities. • Desktop evaluation is evaluating a facility using aerial photography or anecdotal evidence from staff s documentation in the Cityworks database of CMSWS service requests. • Drive -by evaluation is observing a site by driving -by or stopping and taking a quick look from the street. z 1O u 2 N d N is N u C S . N O A ' � 2 N N N yugN YY° N CL `o d n• o O N N� p d N c O .0 m LLL N O ° 1 N O O w vC V C A m C Q p� O LbA Y N L W O c c v0 A O N d L V N N1� 5ppy� � m O N y N n G' c r c E i m 0 m 'R N C t3 ° G. 0 o n4 ° 2 a d g-og: o o S 06 7 m c =€offN V z f U O V O O O O Z o c C V O : 9 v C II N O C V2 o n ; o? ;,� C o�p? at Y • C Y 4O4 9 o L C = ^ .: E ti u ^ .G E EE n .� EE IL LC Eaa T ` iC � F u 1- Y• Figure 1: Flow Chart for Prioritization of Industrial Facility Inspections ATTACHMENT 3 STORMWATER INSPECTION REPORT/CHECKLIST MH-I ❑ PP-2 ❑ Facility Name: Inspection Type: PP-2-CMS ❑ PP-2-CPCC ❑ IN -I (non -permitted) ❑ NCG Permit No.: NCSO Permit Effective Date (if applicable): Not Applicable ❑ Permit Status (If not currently permitted): Inspection Discharges to: Date: Facility Personnel Inspector(s): Assisting with Inspection (Name/Phone Number): Entry Time: Exit Time: SIC Code: Facility Hours of Operation: Facility Description: File Review/History: Inspection Summary: This form is a procedural guide for Inspectors to follow when conducting facility stormwater compliance inspections. L Site Inspection Were deficiencies observed with the following items? (Inspector should comment on violations/deficiencies observed) Yes No NA Repeat Finding 1. Stormwater System: catch basins, open ditches, channels, pipes, outfalls, etc. ❑ ❑ ❑ ❑ Comments: 2. Erosion Issues ❑ ❑ ❑ ❑ Comments: 3. Structural Stormwater BMPs ❑ ❑ ❑ ❑ Comments: 4. Illicit Discharges / Connections ❑ ❑ ❑ ❑ Comments: 5. Aboveground Storage Tanks (ASTs): List size, material type, and if secondary containment is provided ❑ ❑ ❑ ❑ Comments: 6. Underground Storage Tank (UST) Fill Port Area ❑ ❑ ❑ ❑ Comments: 7. Outdoor Material Storage Area(s) ❑ ❑ ❑ ❑ Comments: 8. Outdoor Processing Area(s) ❑ ❑ ❑ ❑ Comments: 9. Loading/Unloading Area(s) ❑ ❑ ❑ ❑ Comments: 10. Vehicle/Equipment Area(s): fueling, washing, maintenance, storage ❑ ❑ ❑ ❑ Comments: 11. Oil/Water Separator / Pretreatment ❑ ❑ ❑ ❑ Comments: 12. Waste Storage / Disposal Area(s): scrap metal, dumpsters, grease bins, etc. ❑ ❑ ❑ ❑ Comments: 13. Food Service Area(s) ❑ ❑ ❑ ❑ Comments: 14. Indoor Material Storage Area(s) ❑ ❑ ❑ ❑ Comments: 15. Indoor Processing Area(s) ❑ ❑ ❑ ❑ Comments: L Site Inspection (continued) Yes No NA Repeat Finding 16. Floor drains — illicit connections ❑ ❑ ❑ ❑ Comments: 17. Spill Response Equipment ❑ ❑ ❑ ❑ Comments: II. Stormwater Pollution Prevention Plan Does the site have a Stormwater Pollution Prevention Plan (SPPP)? ❑ ❑ ❑ ❑ If the site has a SPPP, then complete questions in Sections II and III. 1. Does the Plan include a General Location (USGS) map? ❑ ❑ ❑ ❑ Facility location in relation to roads and surface waters. Includes: name of receiving stream or name of municipal storm sewer system, and accurate lat. and long. of point of discharge. 2. Does the Plan include a "Narrative Description of Practices"? ❑ I ❑ ❑ ❑ Should cover storage practices, loading and unloading areas, outdoor process areas, dust or particulate generating or control processes, waste disposal practices, etc. 3. Does the Plan include a detailed site map including outfall locations and ElEl ❑ El areas? Should show • Location of industrial activities (storage areas, disposal areas, process areas, unloading and loading areas) • The drainage structures • Drainage areas for each outfall and activities occurring in the drainage area • Building locations • Existing BMPs and impervious surfaces and the % of each drainage area that is impervious • For each outfall, a narrative description of the potential pollutants which could be expected to be present in the stormwater discharge. This forces permittee to analyze the site with relation to stormwater discharges. It is also a tool for the inspector to understand if the site has changed over time, i.e. if site map does not match facility they must update their plan. 4. Does the Plan include a list of significant spills occurring during the past 3 ElEl El Elyears? Needs to include corrective actions that were taken. The permittee needs to know what the reportable quantities are for wastewater, oil pollution, and SARA Title III. 5. Have stormwater outfalls been evaluated for the presence of non- ❑ ❑ ❑ ❑ stormwater discharges? Signature required: • Corporation - signed by Responsible Corporate Officer or assigned manager • Partnership or Sole Proprietorship — General Partner or the Proprietor Municipality, State, Federal, or other public agency — either principal executive officer or ranking elected official 6. Has the facility evaluated feasible alternatives to current practices? ❑ I ❑ ❑ I ❑ • Provide a review of the technical and economic feasibility of changing the methods of operations and/or storage practices to eliminate or reduce exposure of materials and processes to stormwater. • In areas where elimination of exposure is not practical, the stormwater management plan shall document the feasibility of diverting the stormwater runoff away from areas of potential contamination. 7. Does the facility provide all necessary secondary containment? ❑ ❑ ❑ ❑ • Applies to liquid raw materials, manufactured products, waste materials, or by-products • Single AST capacity > 660 gallons • Multiple AS containers in close proximity to each other with a total combined capacity of > 1,320 IL Stormwater Pollution Prevention Plan (continued) Yes No NA Repeat Finding • If connected to SW conveyance; controlled by manually activated valves or other similar devices? (Closed?) • Collected water observed for color, foam, outfall staining, visible sheens, and dry weather flow prior to release • Document individual making observation, description of water, date, and time of release Retain record 5 years 8. Does the Plan include a BMP summary? ❑ I ❑ ❑ ❑ Narrative description of BMPs to be considered including oil and grease separation, debris control, vegetative filter strips, infiltration and stormwater detention or retention, where necessary. The need for structural BMPs shall be based on the assessment of potential sources to contribute significant quantities of pollutants to stormwater discharges and data collected through monitoring of stormwater discharges. 9. Does the Plan include a Spill Prevention and Response Plan (SPRP)? ❑ I ❑ ❑ ❑ • Assessment of potential pollutant sources based on materials inventory of the facility • Facility personnel responsible for implementing the SPRP shall be identified • Responsible person shall be on -site at all times during facility operations that have the potential to contaminate stormwater runoff through spills or exposure of materials associated with the facility operations. 10. Does the Plan include a Preventative Maintenance and Good ❑ ❑ El El Plan? • Document schedules of inspections and maintenance activities of stormwater control systems, plant equipment and systems • Inspect material handling areas • Regular cleaning schedules of these areas 11. Does the facility provide and document Employee Training? ❑ I ❑ ❑ ❑ • Provide at a minimum, annual training for all personnel including: proper spill response, cleanup procedures, preventative maintenance activities for all personnel involved in any of the facility's operations that have the potential to contaminate stormwater runoff • Develop training schedule and identify facility personnel responsible for implementing the training 12. Does the Plan include a list of Responsible Parties? ❑ I ❑ ❑ ❑ Identify position responsible for the overall coordination, development, implementation, and revision of the SPPP 13. Is the Plan reviewed and updated annually? ❑ I ❑ ❑ 1 ❑ Have there been any changes to the design, construction, operation, or maintenance of the facility, which would have a significant effect on the potential for the discharge of pollutants to surface waters? Does plan include changes? 14. Does the Plan include a Stormwater Facility Inspection Program? ❑ I ❑ ❑ ❑ • Inspect semi-annually at a minimum - once in Fall and once in Spring • Inspection and subsequent maintenance activities performed shall be documented o Record date and time o Individual performing inspection o Narrative description of the stormwater outfall and plant equipment and systems • Records should be incorporated into the SPPP Stormwater Pollution Prevention Plan Comments: III. Qualitative and Analytical Monitoring Yes No NA Repeat Finding 1. Has the facility conducted its Qualitative Monitoring semi-annually? ❑ ❑ ❑ ❑ Color Odor Clarity Floating Solids Suspended solids Foam Oil Sheen Other indicators 2. Has the facility conducted its Analytical Monitoring? ❑ ❑ ❑ ❑ 3. Has the facility conducted its Analytical Monitoring from Vehicle El ❑ ❑ El areas? Qualitative and Analytical Monitoring Comments: IV Permit and Outfalls 1. Is a copy of the Permit and the Certificate of Coverage available at the El El El Elsite? 2. Were all outfalls observed during the inspection? ❑ ❑ ❑ ❑ 3. If the facility has representative outfall status, has it been documented by ❑ ❑ ❑ ❑ the NC Division of Water Quality? 4. If the facility has a No -Exposure Certificate, has the facility self -inspected ❑ ❑ ❑ ❑ and documented this on an annual basis? Permit and Outfalls Comments: V. Phase 11 Permit Requirements 1. Does the permittee properly dispose of waste removed from the MS4 and municipal operations, including street sweeping wastes, dredge spoil, ❑ ❑ ❑ ❑ accumulated sediment, floatables, and other debris? (inspector should indicate the disposal method in the comments section) 2. Did the permittee perform any public transportation (roadway) projects ❑ ❑ ❑ ❑ within the last year? (list roadway projects in comments section) 3. Does the permittee maintain written records of the date, location and number of curb miles swept and parking lots swept? (inspector should copy an ❑ ❑ ❑ ❑ example record) 4. Does the permittee maintain written records of the date, location and number of catch basins cleaned and length of storm drain pipe cleaned? ❑ ❑ ❑ ❑ (inspector should copy an example record) 5. Does the permittee maintain written records of pesticide/herbicide applicator licenses for staff and contractors that perform services for the ❑ ❑ ❑ ❑ permittee? (inspector should copy an example record 6. Does the permittee document areas treated with pesticides/herbicides for ❑ ❑ ❑ ❑ comparison to annual thresholds? 7. If annual pesticide/herbicide thresholds were exceeded, was a discharge permit application submitted? ❑ ❑ ❑ ❑ 8. Did permittee comply with pesticide limitations specific to the Goose Creek ❑ ❑ ❑ ❑ Watershed? Phase II Permit Requirement Comments: ATTACHMENT 4 INDUSTRIAL INSPECTION EXPLANATION LETTER <DATE> <NAME, TITLE> <FACILITY NAME> <ADDRESS> Charlotte, NC <ZIP> Re: Industrial Facility Inspection and Monitoring Program Dear <NAME>: You were recently contacted by Charlotte -Mecklenburg Storm Water Services (CMSWS) to schedule a stormwater inspection of your facility. This letter is to further explain the authority for and purpose of the inspection and monitoring program, and to provide more details about what to expect during and after the inspection. CMSWS administers a State -issued stormwater permit under the National Pollutant Discharge Elimination System (NPDES). One of the permit requirements is to implement an inspection and monitoring program of industrial and commercial facilities that discharge to the permittee's municipal storm water system. The City of Charlotte Storm Water Pollution Control Ordinance grants right -of -entry authority to City personnel and other duly authorized representatives "for the purpose of inspection, observation, measurement, sampling and testing." CMSWS has a cooperative working agreement with the North Carolina Department of Environment and Natural Resources (NCDEQ) — Division of Energy, Mineral and Land Resources (DEMLR). NCDEQ — DEMLR will be made aware of inspection observations at facilities that possess an NPDES stormwater permit and at non -permitted facilities that may be required to obtain an NPDES stormwater permit. The main purpose of the inspection and monitoring program is to identify sources of stormwater pollution at your facility. A secondary purpose for sites with an NPDES Storm Water permit is to determine compliance with permit requirements. Inspectors will request copies of certain records and information, including but not limited to your NPDES Storm Water permit; Storm Water Pollution Prevention Plan; Spill Prevention, Control and Countermeasures Plan; monitoring data; training rosters; spill reports; maintenance logs; process, production and materials storage information; and maps. If so designated, certain information may qualify as confidential. The Inspector will provide a separate letter and form about confidential information. Following the records review, the Inspector will tour the facility grounds to look for potential sources of storm water pollution. At least one person from your facility should escort the Inspector during the entire inspection process. The Inspector is trained to follow all facility safety and security measures, so please inform them of such measures. The Inspector might take photos, which are also items that may be claimed as confidential. Finally, a closing conference will be held to summarize preliminary findings and explain what will occur following the inspection. Stormwater discharge and/or dry weather flow sampling will be conducted at some facilities. Sampling data is another tool used to determine the amount or degree of storm water pollution discharging from a facility. Inspectors may request access to the facility at a later date to conduct sampling. The inspection and monitoring process described in this letter is only a summary of the program. Other procedures not mentioned in this letter may be carried out by Inspectors in order to identify sources of storm water pollution and to determine compliance with permit requirements. If you have any questions or concerns regarding CMSWS' inspection and monitoring program, please contact me at <PHONE NUMBER>, or you may contact the inspection and monitoring program administrator,, at (xxx) xxx xxxx. Sincerely, YOUR NAME TITLE ATTACHMENT 5 STATE (NPDES) COMPLIANCE INSPECTION REPORT TEMPLATES (IN-I(1)) Attachment 5.a — Satisfactory Attachment 5.b — Unsatisfactory Attachment 5.c — Follow-up letter Attachment 5.d — Notice of Violation Attachment 5.a - Satisfactory <DATE> <FACILITY NAME> Attn: <FACILITY CONTACT>, <TITLE> <STREET ADDRESS> <CITY, STATE, ZIP> Subject: Industrial Facility Inspection <FACILITY NAME> Dear <FACILITY CONTACT>: On <1NSPECTION DATE>, <INSPECTOR'S NAME> of Charlotte -Mecklenburg Storm Water Services (CMSWS) conducted an inspection of the above referenced facility as a requirement of the City of Charlotte's NPDES Permit, NCS000240, Part II Section H. Inspection authority is granted by Charlotte City Code Chapter 18, Article III, Section 18-82. At the time of inspection, the facility was observed to be in compliance with the City of Charlotte Storm Water Pollution Control Ordinance. The inspection was also conducted as part of a cooperative working agreement between Mecklenburg County and the North Carolina Department of Environmental Quality (NCDEQ) — Division of Energy, Mineral and Land Resources (DEMLR). NCDEQ — DEMLR has been copied on this report and made aware of the following observations regarding the facility's NPDES stormwater permit: 1) Stormwater Pollution Prevention Plan (SPPP) A Stormwater Pollution Prevention Plan (SPPP) has been developed, recorded, and implemented. 2) Qualitative Monitoring Qualitative monitoring has been conducted and recorded. 3) Analytical Monitoring Analytical monitoring has been conducted and recorded. 4) Permit and Outfalls Note any deficiencies or noteworthy practices relative to this Ggglment line anng if nra_c Thank you for the assistance and cooperation with the site inspection. The attached report provides details about inspection observations and should be self-explanatory. Please contact me at <PHONE #> if you have any questions or need additional information. For questions specifically regarding your NPDES stormwater permit, please contact James Moore with NCDEQ — DEMLR at (704) 663-1699. Sincerely, <INSPECTOR' S NAME> <INSPECTOR' S TITLE> Charlotte -Mecklenburg Storm Water Services cc: Andrew DeCristofaro, Charlotte Storm Water Services James Moore, NCDEQ — DEMLR Attachment Attachment 5.b - Unsatisfactory <DATE> <FACILITY NAME> Attn: <FACILITY CONTACT>, <TITLE> <STREET ADDRESS> <CITY, STATE, ZIP> Subject: Industrial Facility Inspection <FACILITY NAME> Dear <FACILITY CONTACT>: On <INSPECTION DATE>, <INSPECTOR' S NAME> of Charlotte -Mecklenburg Storm Water Services (CMSWS) conducted an inspection of the above referenced facility as a requirement of the City of Charlotte's NPDES Permit, NCS000250, Part II Section H. Inspection authority is granted by Charlotte City Code Chapter 18, Article III, Section 18-82. The following observations were noted during the inspection as part of the Charlotte Storm Water Pollution Control Ordinance review and can be found in more detail within the Site Inspection section of the attached report: 1) Charlotte Storm Water Pollution Control Ordinance Review • Note any deficiencies, noteworthy practices, and/or recommendations relative to this section of the report. • Note any deficiencies, noteworthy practices, and/or recommendations relative to this section of the report. The inspection was also conducted as part of a cooperative working agreement between Mecklenburg County and the North Carolina Department of Environment and Natural Resources (NCDEQ) — Division of Energy, Mineral and Land Resources (DEMLR). NCDEQ — DEMLR has been copied on this report and made aware of the following observations regarding the facility's NPDES stormwater permit: 2) Stormwater Pollution Prevention Plan (SPPP) A Stormwater Pollution Prevention Plan (SPPP) has been developed, recorded, and implemented. 3) Qualitative Monitoring Qualitative monitoring has been conducted and recorded. 4) Analytical Monitoring Analytical monitoring has been conducted and recorded. 5) Permit and Outfalls Note any deficiencies or noteworthy practices relative to this Comment line and h if n0 oaf �'an niae [I/PYP l[hQ PY[)PA Thank you for your assistance and cooperation with the site inspection. Please submit a written response addressing items in Section 1 of this cover letter to <INSPECTOR' S NAME> by <DEADLINE DATE>. Your response should explain what actions have been taken to address the deficiencies. Items under Sections 2 — 5 of this cover letter are specifically related to requirements in your State -issued NPDES Stormwater Certificate of Coverage <COC NUMBER>, and as such, you may receive a separate letter from NCDEQ asking you to follow- up and address those particular items. The attached report provides details about inspection observations and should be self- explanatory. Please contact me at <PHONE #> if you have any questions or need additional information. For questions specifically regarding your NPDES stormwater permit, please contact James Moore with NCDEQ — DEMLR at (704) 663-1699. Sincerely, <INSPECTOR' S NAME> <INSPECTOR' S TITLE> Charlotte -Mecklenburg Storm Water Services cc: Andrew DeCristofaro, Charlotte Storm Water Services James Moore, NCDEQ — DEMLR Attachment Attachment 5.c — Follow up <DATE> <FACILITY NAME> Attn: <FACILITY CONTACT>, <TITLE> <STREET ADDRESS> <CITY, STATE, ZIP> Subject: Follow-up Industrial Facility Inspection <FACILITY NAME> Dear <FACILITY CONTACT>: On <INSPECTION DATE>, <INSPECTOR' S NAME> of Charlotte - Mecklenburg Storm Water Services (CMSWS) conducted a follow-up inspection of the above referenced facility under authority granted by Charlotte City Code Chapter 18, Article III, Section 18-82. A written response to the Notice of Violation issued on <NOV ISSUED DATE> was received on <RESPONSE RECEIVED DATE>. The inspection was also conducted as part of a cooperative working agreement between Mecklenburg County and the North Carolina Department of Environment and Natural Resources (NCDEQ) — Division of Energy, Mineral and Land Resources (DEMLR). NCDEQ — DEMLR has been copied on this report and made aware of the following observations regarding the facility's NPDES stormwater permit: 1) Stormwater Pollution Prevention Plan (SPPP) A Stormwater Pollution Prevention Plan (SPPP) has been developed, recorded, and implemented. 2) Qualitative Monitoring Qualitative monitoring has been conducted and recorded. 3) Analytical Monitoring Analytical monitoring has been conducted and recorded. 4) Permit and Outfalls Note any deficiencies or noteworthy pr r delete this comment line and heading if no deficiencies were observed. Thank you for the assistance and cooperation with the follow-up site inspection. The attached report provides details about follow-up inspection observations and should be self- explanatory. Please contact me at <PHONE #> if you have any questions or need additional information. For questions specifically regarding your NPDES stormwater permit, please contact James Moore with NCDEQ — DEMLR at (704) 663-1699. Sincerely, <INSPECTOR' S NAME> <INSPECTOR' S TITLE> Charlotte -Mecklenburg Storm Water Services cc: Andrew DeCristofaro, Charlotte Storm Water Services James Moore, NCDEQ — DEMLR Attachment Attachment 5.d — Notice of Violation <DATE> CERTIFIED MAIL RETURN RECEIPT REOUESTED <COMPANY> Attention: <Mr. or Ms.> <HIGHEST RANKING RESPONSIBLE OFFICIAL>, <TITLE> <ADDRESS> <CITY, STATE, ZIP> Subject: NOTICE OF VIOLATION Industrial Facility Inspection <FACILITY NAME> CITY OF CHARLOTTE CODE OF ORDINANCES Chapter 18, Article III Stormwater Pollution Section 18-80(a), Illicit Discharge(s) and Disposal(s) Dear <Mr. or Ms.> <RESPONSIBLE OFFICIAL>: North Carolina General Statute 160A-459 authorizes cities to adopt and enforce a stormwater control ordinance to protect water quality and control water quantity. The City of Charlotte has adopted a Stormwater Pollution Control Ordinance (the "Ordinance") which was amended and effective as of June 9, 2008. On <DATE>, <Mr. or Ms.> <INSPECTOR' S NAME> of Charlotte - Mecklenburg Storm Water Services (CMSWS) conducted an inspection at <FACILITY NAME>, <ADDRESS> in Charlotte, North Carolina. The inspection was conducted as a requirement of the City of Charlotte's NPDES Municipal Stormwater Permit and under authority granted by the Ordinance, as specified in Section 18-82, Powers and Authority for Inspection. As a result of the inspection, the following conditions were observed at the facility in violation of the Ordinance, Section 18-80(a), Illicit Discharge(s) and Disposal(s): <State condition(s) causing the violation; note if discharge reached the ground, the stormwater drainage system and/or stream; list stream name; include the activity that caused the violation; describe all areas affected by the violation; include any other facts, findings and environmental impacts >. The inspection determined that < COMPANY> is the "Person" responsible for the violation, as defined by the Ordinance. As such, <Mr. or Ms.> < INDIVIDUAL> with < COMPANY> was verbally notified of the violation on <DATE> and directed to immediately cease the discharge causing the violation. To achieve compliance with the legal requirements of the Ordinance, < COMPANY> must implement the corrective actions listed below: • Immediately cease any discharge contributing to the violation if not done so already; and, • <Add any other corrective actions here, if necessary>; and, • Restore areas affected by the violation, as described above, to their pre -violation condition; and, • Take appropriate remedial and/or preventive actions to prevent future illegal discharges. < COMPANY> is required to submit a written response to this office within ten (10) days following receipt of this notice. The response should specify 1.) why the violation occurred, 2.) the actions taken to correct the violation, 3.) the actions taken to restore the affected areas, 4.) the actions taken to prevent the occurrence of violations in the future, and 5.) any other information or explanation < COMPANY> wishes to present regarding the violation. The response will be taken into consideration in penalty assessment decisions. Please send the response to: Charlotte -Mecklenburg Storm Water Services Attention: <Supervisor's Name> 2145 Suttle Ave. Charlotte, NC 28208-5237 In accordance with the Ordinance, Section 18-83(c) Civil Penalties, <COMPANY > is subject to civil penalties of up to Five Thousand Dollars ($5,000.00) per day beginning with the first day of violation and every day thereafter up until the violation ceases. It is the responsibility of < COMPANY> to contact the Inspector ( <INSPECTOR'S NAME >, at < INSPECTOR'S PHONE #>) immediately upon ceasing the violation and restoring the areas affected by the violation in order to document compliance with the Ordinance and to minimize the total potential penalty. Unless scheduled earlier by < COMPANY>, a follow-up inspection will occur no later than <DATE> to determine compliance with the Ordinance. Please note that until that determination occurs, <COMPANY > will continue to be in violation of the Ordinance. CMSWS will take any steps necessary to secure compliance with the Ordinance. One such step is that CMSWS or a contractor designated by CMSWS may abate a violation and/or restore impacted areas to their pre -violation condition should <COMPANY > fail to do so in a timely manner, especially in situations where the violation may cause an imminent threat to human health or the environment. Any expense incurred by CMSWS for such violation abatement and/or restoration work will be charged to <COMPANY >, in addition to the civil penalty. If you have any questions or would like to request a meeting with CMSWS to discuss the violation and provide additional information, please contact me at <SUPERVISOR PHONE #> within ten (10) days following receipt of this notice. Please be aware that a meeting request or an actual meeting with CMSWS does not relieve <COMPANY > from completing the corrective actions listed above and does not negate a potential penalty. Achieving and maintaining compliance with Section 18-80(a) of the Ordinance does not relieve <COMPANY > from complying with other sections of the Ordinance or other local, state, or federal regulations. For your information, the Ordinance is available for view on the Internet at: http://charlottenc. gov/StormWater/Regulations/Documents/CharlotteS WPollControlOrd0609200 8.pdf. Copies of the Ordinance are also available in print or PDF file format from CMSWS upon request. The enclosed inspection report provides specific details about the inspection and should be self- explanatory. If you have any questions or need additional information concerning this report, please contact <INSPECTOR' S NAME >, at < INSPECTOR'S PHONE #>. < DELETE PARAGRAPH IF NOT APPLICABLE>Please note, because your facility has been issued a NPDES stormwater permit, the inspection was also conducted as part of a cooperative working agreement between CMSWS and the North Carolina Department of Environmental Quality (NCDEQ) — Division of Energy, Mineral and Land Resources (DEMLR). NCDEQ-DEMLR has been given a copy of this report and made aware of the observations regarding the permit. For questions specifically regarding your NPDES stormwater permit, please contact James Moore with NCDEQ-DEMLR at (704) 663-1699. Your prompt cooperation in this matter is requested. Sincerely, <SUPERVISOR NAME> Water Quality Supervisor Charlotte -Mecklenburg Storm Water Services <SUPERVISOR INITIALS>/ <INVESTIGATOR INITIALS> Enclosure: Copy of Industrial Facility Inspection Report, <DATE> cc: <Add others as necessary, local site reps, etc.> Steve Jadlocki, CMSWS Rusty Rozzelle, CMSWS Andrew DeCristofaro, CMSWS James Moore, NCDEQ-DEMLR FILE: NOV Cityworks Activity Report # ATTACHMENT 6 CITY (NON-NPDES) COMPLIANCE INSPECTION REPORT TEMPLATES (IN-I(1)) Attachment 6.a — Satisfactory Attachment 6.b — Unsatisfactory Attachment 6.c — Follow-up letter Attachment 6.d — Notice of Violation Attachment 6.a - Satisfactory <DATE> <FACILITY NAME> Attn: <FACILITY CONTACT>, <TITLE> <STREET ADDRESS> <CITY, STATE, ZIP> Subject: Industrial Facility Inspection <FACILITY NAME> Dear <FACILITY CONTACT>: On <INSPECTION DATE>, <INSPECTOR' S NAME> of Charlotte - Mecklenburg Storm Water Services (CMSWS) conducted an inspection of the above referenced facility under authority granted by Charlotte City Code Chapter 18, Article III, Section 18-82. The attached report provides details about inspection observations and should be self-explanatory. At the time of inspection, the facility was observed to be in compliance with the City of Charlotte Storm Water Pollution Control Ordinance. Thanks again for your cooperation with the site inspection. Please contact me at <PHONE #> if you have any questions or need additional information regarding the attached report. Sincerely, <INSPECTOR' S NAME> <INSPECTOR' S TITLE> cc: Andrew DeCristofaro, Charlotte Storm Water Services Attachment Attachment 6.b - Unsatisfactory <DATE> <FACILITY NAME> Attn: <FACILITY CONTACT>, <TITLE> <STREET ADDRESS> <CITY, STATE, ZIP> Subject: Industrial Facility Inspection <FACILITY NAME> Dear <FACILITY CONTACT> On <INSPECTION DATE>, <INSPECTOR' S NAME> of Charlotte - Mecklenburg Storm Water Services (CMSWS) conducted an inspection of the above referenced facility under authority granted by Charlotte City Code Chapter 18, Article III, Section 18-82. At the time of inspection, the following conditions were observed at the facility that have the potential to negatively impact water quality and need corrective action: • Area/Section of Report the problem was observed: Description of the condition. Corrective Actions l Recommendation to correct the issue in italics. Please submit a written response to the recommendations and corrective actions within the attached report to <INSPECTOR'S NAME> by <DEADLINE DATE>. Your response should explain what actions have been taken to address the recommendations and corrective actions. The attached report provides details about inspection observations and should be self- explanatory; however, should you have any questions concerning the report or any other matters, please contact me at <PHONE #>. Sincerely, <INSPECTOR' S NAME> <INSPECTOR' S TITLE> cc: Andrew DeCristofaro, Charlotte Storm Water Services Attachment Attachment 6.c — Follow up <DATE> <FACILITY NAME> Attn: <FACILITY CONTACT>, <TITLE> <STREET ADDRESS> <CITY, STATE, ZIP> Subject: Follow-up Industrial Facility Inspection <FACILITY NAME> Dear <FACILITY CONTACT> On <INSPECTION DATE>, <1NSPECTOR' S NAME> of Charlotte - Mecklenburg Storm Water Services (CMSWS) conducted a follow-up inspection of the above referenced facility under authority granted by Charlotte City Code Chapter 18, Article III, Section 18-82. At the time of inspection, the facility was observed to be in compliance with the City of Charlotte Storm Water Pollution Control Ordinance. A written response to the Notice of Violation issued on <NOV ISSUED DATE> was received on <RESPONSE RECEIVED DATE>. The attached report provides details about inspection observations and should be self-explanatory. Thank you for your cooperation with the follow-up site inspection. Please contact me at <PHONE #> if you have any questions or need additional information regarding the attached report. Sincerely, <INSPECTOR' S NAME> <INSPECTOR' S TITLE> cc: Andrew DeCristofaro, Charlotte Storm Water Services Attachment Attachment 6A — Notice of Violation <DATE> CERTIFIED MAIL RETURN RECEIPT REOUESTED <COMPANY> Attention: <Mr. or Ms.> <HIGHEST RANKING RESPONSIBLE OFFICIAL>, <TITLE> <ADDRESS> <CITY, STATE, ZIP> Subject: NOTICE OF VIOLATION Industrial Facility Inspection <FACILITY NAME> CITY OF CHARLOTTE CODE OF ORDINANCES Chapter 18, Article III Stormwater Pollution Section 18-80(a), Illicit Discharge(s) and Disposal(s) Dear <Mr. or Ms.> <RESPONSIBLE OFFICIAL>: North Carolina General Statute 160A-459 authorizes cities to adopt and enforce a stormwater control ordinance to protect water quality and control water quantity. The City of Charlotte has adopted a Stormwater Pollution Control Ordinance (the "Ordinance") which was amended and effective as of June 9, 2008. On <DATE>, <Mr. or Ms.> <INSPECTOR' S NAME> of Charlotte - Mecklenburg Storm Water Services (CMSWS) conducted an inspection at <FACILITY NAME>, <ADDRESS> in Charlotte, North Carolina. The inspection was conducted as a requirement of the City of Charlotte's NPDES Municipal Stormwater Permit and under authority granted by the Ordinance, as specified in Section 18-82, Powers and Authority for Inspection. As a result of the inspection, the following conditions were observed at the facility in violation of the Ordinance, Section 18-80(a), Illicit Discharge(s) and Disposal(s): <State condition(s) causing the violation; note if discharge reached the ground, the stormwater drainage system and/or stream; list stream name; include the activity that caused the violation; describe all areas affected by the violation; include any other facts, findings and environmental impacts >. The inspection determined that < COMPANY> is the "Person" responsible for the violation, as defined by the Ordinance. As such, <Mr. or Ms.> < INDIVIDUAL> with < COMPANY> was verbally notified of the violation on <DATE> and directed to immediately cease the discharge causing the violation. To achieve compliance with the legal requirements of the Ordinance, < COMPANY> must implement the corrective actions listed below: • Immediately cease any discharge contributing to the violation if not done so already; and, • <Add any other corrective actions here, if necessary>; and, • Restore areas affected by the violation, as described above, to their pre -violation condition; and, • Take appropriate remedial and/or preventive actions to prevent future illegal discharges. < COMPANY> is required to submit a written response to this office within ten (10) days following receipt of this notice. The response should specify 1.) why the violation occurred, 2.) the actions taken to correct the violation, 3.) the actions taken to restore the affected areas, 4.) the actions taken to prevent the occurrence of violations in the future, and 5.) any other information or explanation < COMPANY> wishes to present regarding the violation. The response will be taken into consideration in penalty assessment decisions. Please send the response to: Charlotte -Mecklenburg Storm Water Services Attention: <Supervisor's Name> 2145 Suttle Ave. Charlotte, NC 28208-5237 In accordance with the Ordinance, Section 18-83(c) Civil Penalties, <COMPANY > is subject to civil penalties of up to Five Thousand Dollars ($5,000.00) per day beginning with the first day of violation and every day thereafter up until the violation ceases. It is the responsibility of < COMPANY> to contact the Inspector ( <INSPECTOR'S NAME >, at < INSPECTOR'S PHONE #>) immediately upon ceasing the violation and restoring the areas affected by the violation in order to document compliance with the Ordinance and to minimize the total potential penalty. Unless scheduled earlier by < COMPANY>, a follow-up inspection will occur no later than <DATE> to determine compliance with the Ordinance. Please note that until that determination occurs, <COMPANY > will continue to be in violation of the Ordinance. CMSWS will take any steps necessary to secure compliance with the Ordinance. One such step is that CMSWS or a contractor designated by CMSWS may abate a violation and/or restore impacted areas to their pre -violation condition should <COMPANY > fail to do so in a timely manner, especially in situations where the violation may cause an imminent threat to human health or the environment. Any expense incurred by CMSWS for such violation abatement and/or restoration work will be charged to <COMPANY >, in addition to the civil penalty. If you have any questions or would like to request a meeting with CMSWS to discuss the violation and provide additional information, please contact me at <SUPERVISOR PHONE #> within ten (10) days following receipt of this notice. Please be aware that a meeting request or an actual meeting with CMSWS does not relieve <COMPANY > from completing the corrective actions listed above and does not negate a potential penalty. Achieving and maintaining compliance with Section 18-80(a) of the Ordinance does not relieve <COMPANY > from complying with other sections of the Ordinance or other local, state, or federal regulations. For your information, the Ordinance is available for view on the Internet at: htlp:Hcharlottenc. gov/StormWater/Regulations/Documents/CharlotteSWPollControlOrdO6O9200 8.pdf. Copies of the Ordinance are also available in print or PDF file format from CMSWS upon request. The enclosed inspection report provides specific details about the inspection and should be self- explanatory. If you have any questions or need additional information concerning this report, please contact <INSPECTOR' S NAME >, at < INSPECTOR'S PHONE #>. < DELETE PARAGRAPH IF NOT APPLICABLE>Please note, because your facility has been issued a NPDES stormwater permit, the inspection was also conducted as part of a cooperative working agreement between CMSWS and the North Carolina Department of Environmental Quality (NCDEQ) — Division of Energy, Mineral and Land Resources (DEMLR). NCDEQ-DEMLR has been given a copy of this report and made aware of the observations regarding the permit. For questions specifically regarding your NPDES stormwater permit, please contact James Moore with NCDEQ-DEMLR at (704) 663-1699. Your prompt cooperation in this matter is requested. Sincerely, <SUPERVISOR NAME> Water Quality Supervisor Charlotte -Mecklenburg Storm Water Services <SUPERVISOR INITIALS>/ <INVESTIGATOR INITIALS> Enclosure: Copy of Industrial Facility Inspection Report, <DATE> cc: <Add others as necessary, local site reps, etc.> Steve Jadlocki, CMSWS Rusty Rozzelle, CMSWS Andrew DeCristofaro, CMSWS James Moore, NC Department of Environmental Quality (optional, if the facility needs permit) FILE: NOV Cityworks Activity Report # ATTACHMENT 7 STATE (NPDES) STORMWATER MONITORING REPORT AND TABLE TEMPLATES (IN-M(1)) Attachment 7.a — Industrial Monitoring Report Template Attachment 7.b — Summary of Stormwater Analytical Results Attachment 7.a — Industrial Monitoring Report Template <DATE> <FACILITY NAME> Attn: <FACILITY CONTACT>, <TITLE> <FACILITY ADDRESS> Subject: Stormwater Monitoring <FACILITY> Dear <FACILITY CONTACT>: On <DATE>, <SAMPLER> of Charlotte -Mecklenburg Storm Water Services (CMSWS) sampled stormwater runoff from the subject facility located at <ADDRESS>, Charlotte, North Carolina. The monitoring was conducted under authority granted by Charlotte City Code Chapter 18, Section 18-82. The monitoring was also conducted as part of a cooperative working agreement between Mecklenburg County and the North Carolina Department of Environment and Natural Resources (NCDEQ) — Division of Energy, Mineral and Land Resources (DEMLR). NCDEQ — DEMLR has been copied on this report and made aware of monitoring results regarding the facility's NPDES permit. At the time the stormwater sample was collected, approximately inches of rain had fallen. Rainfall data was reported by the United States Geologic Survey (USGS) real-time station <USGS STATION LOCATION>. CMSWS sampled stormwater runoff from <DESCRIPTION OF SAMPLING LOCATION>. A summary table of results is attached to this report. Monitoring results were compared to local and state stream standards (CMSWS Action Levels and North Carolina Water Quality Standards). Since the stormwater sample was not collected from the stream, the stream standards do not necessarily apply; however, these standards can be used to indicate the potential of polluted runoff from the facility to impact the receiving stream. The results indicate <DESCRIPTION OF RESULTS; COMPARE TO BENCHMARK VALUES>. CMSWS recommends that you consistently implement good housekeeping, pollution prevention, and preventative maintenance measures in order to minimize contamination in your site's stormwater runoff. Please contact me at <PHONE #> if you have any questions or need additional information. For questions specifically regarding your NPDES stormwater permit, please contact James Moore with NCDEQ — DEMLR at (704) 663-1699. Sincerely, <INSPECTOR' S NAME> <INSPECTOR' S TITLE> Charlotte -Mecklenburg Storm Water Services Attachment cc: Andrew DeCristofaro, City of Charlotte James Moore - DEMLR Attachment 7.b - Summary of Storm Water Analytical Results STORM W Y ATE Sarv�kaai 7 C+ 2145 LI.&,Ave Charlotte, ITC 2SIQ2 uminary of !>C l Moinitorkag and Analysis Facility: Sample Date: Ram Event Total: " inches ( RN-**) 5#�F�t C1kISR-S �C: }1aEer Parameter T Units Dutfgll U{Il Disckwrge 4c6m.Level Q-6t3 Standard Banclm s (3n-stream} (NCG" , _L-_tream> bmchmaikzin hold) Temperatnm Disaoh,ed on•gen (me1'r - 4.0 C:oudmetn s PH < 6-o and > 9.0 Fecal {;oliform ] £ f 30W 200 EMBacteria 100ML: - Total Suspended Solid a (ERE 1 , Turbidity 11= - Copper* (me L'} 0.07 ti-�036 Ziac* (mgi} 4.Ob7 0.0? 6 Chramiam (mgL} D-05 0.016 Leadx (mgL} Oil and Grease, 13 and TPH son Cf}D (ma L} 120 Yelknv indicate3 emeedmice of PErwit Balchm ark Value, CNIFS%'S Achou Lgrel or NC Water Quality $tamed. *',Mcndmmg data �-Aa&ed dune this Ln Eon L& based on toi I reemwable meta:&. Thelahiea for the LKILI t IaLl $, y Perini Die chug e Beue�*mrk- and CMS 4clu mLL-vele are a1co baled on total reom-ffable metals. The NC Water Quatitt- Standard farm stream u based on mebnot-L-ed meta.La ivitli am aesimued m-st ram 6—udn rss kalae aft] p3aLm v a To report pollution or dzaiaage problems, o$ll; 311 :�. http.l+atermwas_er.rharmeck.erc atf1�1irl-11 ATTACHMENT 8 CITY (NON-NPDES) STORMWATER MONITORING REPORT AND TABLE TEMPLATES (IN-M(1)) Attachment 8.a — Industrial Monitoring Report Template (non -permitted) Attachment 8.b — Analytical Monitoring Results Table (non -permitted) Attachment 8.a — Industrial Monitoring Report Template (non -permitted) <DATE> <FACILITY NAME> Attn: <FACILITY CONTACT>, <TITLE> <FACILITY ADDRESS> Subject: Stormwater Monitoring <FACILITY> Dear <FACILITY CONTACT>: On <DATE>, <SAMPLER> of Charlotte -Mecklenburg Storm Water Services (CMSWS) sampled stormwater runoff from the subject facility located at <ADDRESS>, Charlotte, North Carolina. The monitoring was conducted under authority granted by Charlotte City Code Chapter 18, Section 18-82. At the time the stormwater sample was collected, approximately inches of rain had fallen. Rainfall data was reported by the United States Geologic Survey (USGS) real-time station <USGS STATION LOCATION>. CMSWS sampled stormwater runoff from <DESCRIPTION OF SAMPLING LOCATION>. A summary table of results is attached to this report. Monitoring results were compared to local and state stream standards (CMSWS Action Levels and North Carolina Water Quality Standards). Since the stormwater sample was not collected from the stream, the stream standards do not necessarily apply; however, these standards can be used to indicate the potential of polluted runoff from the facility to impact the receiving stream. The results indicate <DESCRIPTION OF RESULTS>. CMSWS recommends that you consistently implement good housekeeping, pollution prevention, and preventative maintenance measures in order to minimize contamination in your site's stormwater runoff. Please contact me at <PHONE #> if you have any questions or need additional information. Sincerely, <INSPECTOR' S NAME> <INSPECTOR' S TITLE> Charlotte -Mecklenburg Storm Water Services Attachment cc: Andrew DeCristofaro, City of Charlotte Attachment 8.b — Analytical Monitoring Results Sheet (non -permitted) STORM 3145 Ave .R-RWATER Charlotte, ITC 2S_.Q2 sonkaa E Summary of $,tqMWAjpr, Monitoring and Analysis Facility: Sample Date: Ram Event Total: *-` inches ( RN-**) Fermi!In ENV INC water Parameter L-uita Out{all001 DiE. ActiouLerel Quaiit3 5taudard Bmd n.Lrkn -stream} ,L-_tream> bomhM IkEinhaw Temperature (° l - 32 - DimDh ed oxyg (mgi} .0 Condnctnit,+ PH 6.4w9-0 - <60and >9.0 Fecal C:olifom jc0)o 3wo 200 EMBacteris - - - I07mL} Tots) Suspended SaGas Turbidity ¢TTC.; - 50.0 Crupper' (U914 7.OG 0-0036 Zincx (-LL) 0.06- 0.036 C:bronaimu (mgL) U-US 0.016 Leadx (uSeL} M3 0.t}'- Oil and Greases ( .L} 15 and TPH BOD (mgl } 15.0 Cf}D OWL) 12D - Yellrnu rudreatea �eedance o&Permrt B_Zci� Value, C%iS'1 S Actrem Level or NC V rater Q dihy 5t mdard. tMonemmg data fiBated dunnE this Ln-entu based ontota€ reooiwablesv,efaEa- Tbenahlee for the Industrial $�Peami are also bored on total reooc-ffable mabL. The NC WzEer Quatits- Standard fo-r in stream is based on dismh-ed metrL nri as assumed in-etmam hardness value of25 -L- i Tc report pollution or drainage problems, call: 311 http.I+et0rmwateT-rharmeck.crQ f" �11111�ITf17; ATTACHMENT 9 FOLLOW-UP STORMWATER MONITORING REPORT AND TABLE TEMPLATES (IN-M(2)) Attachment 9.a — Industrial Monitoring Follow-up Template Attachment 9.b — Monitoring Results Table Summary (non -permitted) Attachment 9.c — Monitoring Results Table Summary (permitted) Attachment 9.a — Industrial Monitoring Follow-up Template <DATE> <FACILITY NAME> Attn: <FACILITY CONTACT>, <TITLE> <FACILITY ADDRESS> Subject: Stormwater Monitoring Follow-up <FACILITY> Dear <FACILITY CONTACT>: Stormwater monitoring results for your facility were sent to you on <DATE>. Due to elevated results for certain pollutant parameters, additional grab sampling was conducted at Outfall on <DATE> by <SAMPLER> of Charlotte -Mecklenburg Storm Water Services (CMSWS). The results of that sampling event are enclosed. The results indicate <DESCRIPTION OF RESULTS; COMPARE TO BENCHMARK VALUES AND ACTION LEVELS>. In order to reduce pollutant concentrations of elevated parameters, you need to perform a detailed investigation into pollution sources at your facility that may be contributing to elevated discharges. Once pollution sources are identified, corrective actions to eliminate or minimize polluted runoff from those sources should be implemented. All investigations and corrective actions should be documented as well. <I will be in contact soon to schedule a follow-up inspection. The purpose of the inspection will be to review efforts taken to investigate and eliminate pollution sources contributing to elevated pollutant concentrations at your facility.> Should you have any questions concerning the sampling results, the corrective action process, or the follow-up inspection, please contact me at <PHONE #>. Sincerely, <YOUR NAME> <TITLE> Charlotte -Mecklenburg Storm Water Services Attachment cc: Andrew DeCristofaro, City of Charlotte Attachment 9.b — Monitoring Results Table Summary (non -permitted) t- :,liarlokte, NC 28;.€i2 Survfcaa�---�= Summary of _%ql1 1 4f 14ionitoring and Analysis Facility: Sample Date: Rain Event Total: ** inches (CRIv-**',% 19 1 Permit �. -s - kl atPr Parameter Unks 04tfal€001 DiZCkarge ctionLered 4 Sraudand Benchmark -stream} (I�cr* _::-: tre mi wnrF m�rL a m hold i Tempzrature Difaolved Oween C:Onductil: ttu ( Al am} PH 60to9_0 - 5.0and>9.0 Fecal C.clirarns low 3M 2OG E-gl$acteria ] ODml.} Total Snapmded 5olids (ms'L) 100 - Turbidity 50.0 COPPer* (cueL) O.Od7 0-0045 Zinc* (msL) 0.067 0.036 CliranAuun [meL� 6-U5 0.016 head (us lL 6-0= 0.014 Oil and grease, and TPH�'; i 130D (MV0 -1 COI} CAL, 120 - - Yellmu indicates eaoceedmice of Permit B enc[im is Value, C�i3%'S A aton Level or NC Rrater QuaUhy standard *,Monda mg data o.liek-ted donne tIIis ece»t i.& based am tobI recmwable mebd3. The-Lalnee Ex the 1ndu_tri-4 ftM4)WW Pe=tz Discharge SemAu,eis3 and CROWS Action LL- ele axe also based an total reom-ffahlemeW . The NC Water Quaky Standard faT in stream is based cmdmwh-ed mebls with an as��ed in-etFeaut lnrdues; kaive at:.23 -L- L! • o report pollution or drainage prablemg, o$ll; 311 http.listermwa[ar.oloarmeak.org c airu� �rrn: Attachment 9.c — Monitoring Results Table Summary (permitted) CN�Rj*q" STORM2145 Ave +WATER Charlotte, NC 2SIG2 ' SarvfCegi -�-.: umin ar- of tgrX 'A(pr_AUiidtoriag and Analysis Facility_ Sample Date: Rain Event Total: *$ inc (CRN-**,, FT 5kpw;wgw Permit IMEWS NC rater Parameter units Ou##aQIF[11 DisekargP -yictionLecel Q-fin SFsndai'd Seac6maA ;v (Iu stream) bemrhtrarT� iR hol;'s Temparatu re _ Diz-Awed Os3aen - 4-1 Camldutivi+ ( CM! �30 pH 6-0 to 4-0 - c 6.0 ar L -, 9.0 FermCO}ifaM low 30w 200 E Badaxia (am' . ]ODMLi - - Total 5u2p mded Solids (mZ} 100 _ Turbidity 30.0 Cogper� 4914 O-W7 0-0036 ZEnex OLT) 0.067 0.036 C:kranai.uut (tneL) 0-05 0.OI6 Lead (mg'L) 0-03 0.014 Oil and Grease. and TFH ( 1} - son c L} -1 .6-0 - COD (mg+I } 120 - Yeilnw indicate3 a meeedmmae ad•Fe=t B-and n ark Value, CNiSW'S ,' dinn Lgrel ar NC Rater Quality �dL *Mmearmg data intler-ted dimne th'=_ e�'FTft u based on tobi reom.-gable mef h- Tila Savoie £or #11e Fn i ,stoat Peron Die clarEe BewnhmwL- and 00M cbgm Levels are z1 o based on total regn-gable metals. The NC Water QuaUty St mdzd fin m stream u based am d> -ed metals vV7tl1 an d3.a1] ned an-9team hudarss value: aft] `L- J Ec report pollution ar drainage prablam9, call; 31! ,q http:eter mwater.claarmeck,I-rc 114;1!1ILI 1• ATTACHMENT 10 INDUSTRIAL FACILITY MONITORING FOLLOW-UP STANDARD ADMINISTRATIVE PROCEDURES City of Charlotte NPDES MS4 Permit Program Industrial Facility Monitoring Follow-up Program Standard Operating Procedure Charlotte -Mecklenburg STORM WATER Services Permit Number NCS000240 Version 2.0 March 2022 Document Approval The following City of Charlotte staff have reviewed and approved this Industrial Facility Monitoring Follow-up Program Standard Operating Procedure as of the date shown below: Name Title Si nature City of Charlotte 3/7/22 Craig Miller NPDES MS4 Permit •� Supervisor h 4/13/22 Andrew DeCristofaro water Quality Program Specialist Mecklenburg County Richard Farmer Environmental Supervisor 3/7/22 4/ 19/22 Matt Santiago Environmental Specialist M Document Revision History This Industrial Facility Monitoring Follow-up Program Standard Operating Procedure has been revised as of the dates shown below: Version Effective IF Lead Author Summary of Changes Number Date 1.0 October 2011 Craig Miller Original Version 1.1 December Craig Miller General review and updates to SOP and 2016 appendices 1.2 November Kristen O'Reilly General review and updates to SOP and 2019 appendices 1.3 November Craig Miller General review and updates to SOP and 2020 appendices Richard Farmer, General review and updates to SOP and 2.0 March 2022 Andrew DeCristofaro appendices; updated SOP to new SOP template format Table of Contents 1. Purpose 2. Introduction 2.1. Program Purpose and Background 2.2. Program Organization 2.3. Program Schedule 2.4. Quality Objectives and Criteria 2.5. Documentation and Records 3. Implementation Methods and Procedures 3.1. Prioritization 3.2. Implementation Procedures 3.3. Monitoring Results Review and Interpretation 3.4. Enforcement 3.5. Additional Monitoring 4. Program Assessment List of Appendices: Appendix A Stormwater Monitoring Follow-up Letter Template...................................7 Appendix B Monitoring Results Summary Table Templates..........................................8 Appendix C Industrial Monitoring Data Statistical Summaries.....................................10 Purpose The purpose of this Industrial Monitoring Follow-up Program Standard Operating Procedure (SOP) is to provide the necessary guidance, instructions, methodologies, procedures, and documentation requirements to ensure the proper implementation and operation of the program to meet the applicable requirements of the City of Charlotte NPDES MS4 permit and associated Stormwater Management Plan. Introduction 2.1 Program Purpose and Background Industrial facilities sometimes conduct activities that, when not managed properly, may generate polluted stormwater runoff and negatively impact surface water quality. The purpose of the industrial facility monitoring follow-up program is to monitor stormwater runoff from those facilities and, based on the results, work with industrial facility personnel to identify pollution sources and implement corrective actions to minimize polluted runoff. The City of Charlotte's MS4 NPDES permit, under Section H "Program to Monitor and Evaluate Stormwater Discharges to Municipal Systems," requires that the permitee evaluate control measures at industrial facilities including hazardous waste TRD facilities, SARA Title III facilities, NPDES Stormwater permitted facilities, and other facilities that are contributing or have the potential to contribute substantial pollutant loading to the municipal stormwater system. The inspection and monitoring program has been ongoing since the City of Charlotte has held an NPDES MS4 Stormwater Permit. Significant changes were implemented in 2007 with renewal of permit coverage at that time. Currently forty facilities are inspected, while stormwater monitoring is conducted at eight of those forty facilities (20%). 2.2. Program Organization The City of Charlotte's Water Quality Specialist (WQS) is responsible for overall management and oversight of the Industrial Facility Monitoring Follow-up program. The WQS assists in reviewing monitoring data, determining the level of follow-up, recommending enforcement actions, and completing an annual report to DEQ. Employees of the Mecklenburg County Land Use and Environmental Services Water Quality Program (LUESA-WQP), which is a part of Charlotte -Mecklenburg Storm Water Services, are also directly involved in the program. Staff schedule and conduct facility monitoring, conduct data analysis, prepare written reports, conduct additional monitoring if needed, and work with facilities to implement corrective actions. LUESA-WQP implements many permit program requirements through contract services for the City of Charlotte. Select employees are involved in the industrial monitoring follow-up program. An Environmental Specialist II (ESII) from LUESA-WQP is responsible for overall implementation of activities described for this program in the contract Work Plan. Additional input and direction for the program are also provided by the City's NPDES MS4 Permit Supervisor, the Surface Water Quality and Environmental Permitting Program Manager, and the Senior Water Quality Program Specialist as well as the County's Environmental Supervisor over the Compliance Group 2.3. Program Schedule Each fiscal year, eight facilities are selected for monitoring from among the forty facilities that were inspected the previous fiscal year. Those selected are ones at which illicit discharges/connections, poor housekeeping, poor materials storage and handling, and/or similar issues were observed during facility inspections. Monitoring is typically conducted during the first half of the fiscal year (July — December), and follow-up, if necessary, is conducted during the second half. For various reasons, satisfactory corrective actions are not always completed by facilities in a timely manner, so follow-up activities sometimes extend into the following fiscal year. 2.4. Quality Objectives and Criteria The main objective of the inspection program is to reduce and prevent stormwater pollution at industrial facilities, with an overall goal of protecting the municipal stormwater system and surface water quality. To help accomplish the main objective and goal, specific program objectives are as follows: • Conduct timely reviews of stormwater monitoring data and evaluate the data against a set of criteria to determine if follow-up corrective actions are warranted. • Work with facility personnel to implement corrective actions (mainly best management practices) at facilities where monitoring indicates that such actions are warranted. • Implement enforcement actions when warranted in order to facilitate the accomplishment of corrective actions and compliance with the Stormwater Pollution Control Ordinance. Achievement of these objectives and goals are measured against a set of criteria in order to help measure program success. The criteria used to measure achievement of objectives and goals include: Accomplishment of corrective actions Reduction in key pollution parameters at facilities as indicated by follow-up monitoring results • Improvement over time in good housekeeping and pollution prevention practices at industrial facilities 2.5. Documentation and Records The LUESA-WQP ESII generates monitoring assignments and all work and data is entered and tracked by employees in Cityworks activity reports. All correspondence sent to facility contacts are attached to the activity reports. The ESII reviews and closes out all activity reports. For State permitted and non -permitted facilities, follow-up stormwater monitoring reports are issued on behalf of the City of Charlotte and the cover letter template provided in Appendix A is used. The letter is issued along with the sampling results table shown in Appendix B. The cover letter and results form are issued jointly to report follow-up monitoring results, to bring attention to any elevated monitoring results, and to direct facility personnel to identify potential pollution sources and implement corrective actions. The letter also states that a follow-up inspection will be conducted to review corrective action efforts, if warranted. The report should be drafted as promptly as possible following the receipt of monitoring results, but always within a maximum of fifteen (15) days after receiving sampling results. Within those 15 days, the draft report should be submitted electronically to the LUESA-WQP Project Manager for review, who will then review the report and send it back to the Inspector for edits. Also within the 15 days, the Inspector should contact the City's WQS to discuss sampling results. Together they will decide what actions will be taken in terms of follow-up. The final report should then be sent to the industrial facility contact. Implementation Methods and Procedures 3.1. Prioritization Each year, eight industrial facilities are selected for stormwater monitoring from among the previous year's list of forty industrial facility inspections. Those selected are considered to be the "worst" sites in terms of housekeeping, management of outdoor process and materials storage, illicit discharges/connections, outfall condition, and similar issues. Once monitoring results are received, those selected for on -site follow-up are based on monitoring results and the level of corrective action response taken by facility personnel. Follow-up activity details are discussed below. 3.2. Implementation Procedures The procedural details for performing the stormwater monitoring for IN-M(2) are provided in the SOP for Industrial Facility Monitoring and Follow-up Monitoring in the QAPP. Inspectors should read through applicable sections of that document to obtain those details. 3.3 Monitoring Results Review and Interpretation Within 15 days of receiving monitoring results, the Inspector should contact the WQS to review monitoring results and determine follow-up actions. Follow-up may include any combination of (1) additional monitoring for specific parameters and outfalls, (2) developing a plan with the facility that identifies corrective actions to be taken, and (3) taking enforcement action and requiring corrective action. In all cases where corrective actions are requested or required, a follow-up inspection shall be conducted. Also, CMSWS staff should contact NC DEQ — DEMLR staff in Mooresville to discuss stormwater-permitted sites where monitoring results coupled with site conditions noted during inspections indicate significant pollution issues. A number of reference values are available for evaluating results, including stormwater permit benchmarks, local action levels, and State in -stream water quality standards. Some pollution parameters will have established reference values for all three, while others will not have any established values for comparison. In addition, statistical data analyses were performed on industrial stormwater sampling results obtained in Charlotte from 2008-2021. The table and graphs in Appendix C display the results of those analyses for 17 different pollution parameters. For all facilities, including State permitted facilities, results should be compared to the three reference values mentioned above, as available for each parameter, as well as the data in Appendix C. The reference values are all "benchmarks" in terms of the fact that they are target values rather than enforceable permit limits (e.g., an NOV cannot be issued strictly based on a stormwater sample result of 100 ug/L zinc, which exceeds the State in -stream standard of 50 ug/L). The State water quality standards and local action levels are based on ambient in -stream measurements, and thus are strictly references or indicators for evaluating stormwater sampling results. Typically, pollutant levels in stormwater will be significantly higher than those found in streams during ambient conditions. The data in Appendix C provide perhaps the best reference for comparison because the data are all from stormwater sampling done locally. The tables provide a summary of most of the data in the boxplots that follow them. Note that the minimum value for some pollutant parameters is the lower detection limit. In some cases, extremely high values were determined to be "outliers" and were removed for graphical purposes (i.e., to improve resolution of the boxplots), although all "maximum result values" are shown in the table in Appendix C for reference. The bulk of values tend to fall within the inter -quartile range (from 25th — 751h percentile). The 90th percentile is provided in the table for each parameter in order to provide a reference for what is considered a very high result. There is currently no formula for interpreting results and determining what follow-up actions to take based on those results. Sometimes just one pollution parameter is extremely high (e.g., >90th percentile), and that alone warrants that the facility be directed to implement corrective actions to reduce that particular parameter. Other times, no one individual parameter may be extremely high, but several are above the 75th percentile, or many are above the 50th percentile. In all of those cases, follow-up corrective actions may be warranted. If results from previous monitoring events are available, results should be compared in order to identify trends. Furthermore, decisions for follow-up are rarely made in isolation, but rather, an evaluation of site conditions should complement the decision -making process. In this way, the interpretation becomes both quantitative and qualitative. Some questions to ask include, "Do monitoring results and site conditions indicate significantly poor housekeeping and/or the presence of identifiable pollution sources?" and "Are the polluted discharges likely to impair the receiving stream and aquatic/plant life there?" 3.4 Enforcement In some cases, issuance of a notice of violation (NOV), possibly with addition of an enforcement action, may be warranted. The City's Enforcement Response Plan provides guidance regarding the issuance of NOVs and enforcement actions to industrial facilities in cases when site conditions and monitoring results indicate significant polluted runoff. In 2020, the City's revised its Stormwater Pollution Control Ordinance which included an additional prohibition in 18-80(d) stating, " No Person shall store, handle, or process any material upon the land in any manner or method that would allow the material to deposit a Pollutant upon the land which may become intermixed with Stormwater entering the Stormwater System or the Waters of the State." The intent of the prohibition is not to issue a violation notice when minor pollution issues associated with storage, handling and processing of materials are observed, but rather is reserved for sites with quite significant issues, especially when prior response and implementation of corrective actions by facilities have been inadequate. When City and LUESA-WQP personnel review monitoring results and prior facility history and determine that a notice of violation may be warranted, they should notify the LUESA-WQP Supervisor, City's NPDES Permit Supervisor, and the City's Senior Water Quality Specialist. The Senior WQS is primarily responsible for working with program personnel in such matters to determine whether an NOV should be issued and the wording of the NOV. 3.5 Additional Monitoring In some cases, additional rounds of monitoring may be warranted. In all cases when an NOV is issued, additional monitoring should be conducted once corrective actions are completed in order to verify that the completed actions adequately reduced pollution levels. In cases when an NOV was not issued, but site conditions and monitoring results warranted corrective actions on the part of the facility, additional monitoring may not always need to be done. If the Inspector is satisfied with site conditions based on observations made during a follow-up site inspection, then additional monitoring need not be done; however, additional monitoring is a supplemental, quantifiable verification of the adequacy of actions taken, and thus is supported by the City of Charlotte. Inspectors shall communicate and coordinate with the City's WQS and LUESA-WQP Program Manager about the follow-up inspection and monitoring process. If a second round of monitoring and observed site conditions still indicate significantly elevated pollutant levels at a facility, then the process of reporting, monitoring and follow-up shall continue. Program Assessment The industrial facility monitoring follow-up program is assessed annually to determine the following: • Are procedures described in this Plan being followed? • If procedures are not being followed properly, what steps should be taken to ensure that they are? • What progress has been made toward achievement of goals and objectives? • Does the Plan need to be modified based on the assessment outcome? The City's WQS conducts the assessment and obtains information for the assessment through input from the LUESA-WQP Project Manager during quarterly meeting as well as Inspectors assigned to the program. Input is also sought throughout the year by talking to management personnel and other employees who were involved in the monitoring program. Other key assessment metrics are monitoring results, observations during inspections, and number of corrective actions implemented. In order to thoroughly answer the questions listed above, specific questions are asked about what did and did not work well, specific problems encountered, and suggestions for program improvement. Based on the outcome of the assessment, specific actions are taken by the City's WQS to improve the program, including items such as revising this Plan, modifying the monitoring data assessment process, and/or modifying how follow-up activities are conducted. Attachment 10- 1 Stormwater Monitoring Follow-up Template Letter <DATE> <FACILITY NAME> Attn: <FACILITY CONTACT>, <TITLE> <FACILITY ADDRESS> Subject: Stormwater Monitoring Follow-up <FACILITY> Stormwater Permit COC Dear <FACILITY CONTACT>: Stormwater monitoring results for your facility were sent to you on <DATE>. Due to elevated results for certain pollutant parameters, additional grab sampling was conducted at Outfall on <DATE> by <SAMPLER> of Charlotte -Mecklenburg Storm Water Services. The results of that sampling event are enclosed. The results indicate <DESCRIPTION OF RESULTS; COMPARE TO BENCHMARK VALUES AND ACTION LEVELS>. In order to reduce pollutant concentrations of elevated parameters, you need to perform a detailed investigation into pollution sources at your facility that may be contributing to elevated discharges. Once pollution sources are identified, corrective actions to eliminate or minimize polluted runoff from those sources should be implemented. All investigations and corrective actions should be documented as well. I will be in contact soon to schedule a follow-up inspection. The purpose of the inspection will be to review efforts taken to investigate and eliminate pollution sources contributing to elevated pollutant concentrations at your facility. Should you have any questions concerning the sampling results, the corrective action process, or the follow-up inspection, please contact me at <PHONE #>. Sincerely, <YOUR NAME> <TITLE> Charlotte -Mecklenburg Storm Water Services Enclosure cc: Andrew DeCristofaro, City of Charlotte Attachment 10-2 Monitoring Results Table Summary C'AsrklEYnl�ac k hn 6uiQ STORM .WATER E Charlotte NC 23,202 ummaryf!> Monitoring and Analysis Facility: Sansple Date: Rain Event Total: *$ inches ( RN-**) �Pesmit INC Rater Parameter Units outF&E001 MN ActiAMIL- e; QuaLn- Standard BExcl n.LrIo O�TC sa Ru -stream} bom malkEinhaw Tempzrature (°j - 32 DiEz,alred on-gen (uSSi} - .0 C:unducthitT Nmbpaw 550 - PH Cr.O tv 9.0 - < 60 and > 9.0 Fecal Colilarm 1000 300 200 E-MBmtmis - - - Total Suspended rsolias- Turbidity ¢QTC:j - 50.0 copper* (me'1} 0.00- 0-0036 Z3c* (-LL) 0.45 - 0.036 chzamium (me'L) U-G5 0.016 Lead= (me'1} U-03 0.014 Oil and Grease, and TFH L} - BOD (mgL} 6.0 COI} (5'L) 12D - Yellow mdicatgs exr!eedance of Fe=t BmcLmark Value, C%iS'1 S ActiamLecel or NC lLratu Quakih, 5taedard. tNimmmmg data --,DhBa, ed during this Ln-E=m based ontoiaE remiwaIxLEmefaEe- The maluee for the Industrial &qpAi�jM Ram, Discharge Bencbmwa -- and CI&V6 S Ad=L ei-ele are aLo based on tatal reooc-ffable metals. The NC Waker QuaUK_ Standard fin ui--tram is based on dunk-ed metaLtivithanaesumedin-Ormmhudnessvalue of23 -L- • Tc report pollution or dzainage problems, call: 311 http.I+et0rmwatsT.chazmeck.crQ f" tf��IN�rlkl Attachment 10-3 Analysis of Industrial Stormwater Sampling 2008 - 2021 Analyte Count Min. Ql Median Mean Q3 90th Max. Inter - Result Percentile Result Quartile Value Value Range Ammonia - Nitrogen (mg/L) 88 0.1 0.1 0.16 0.59 0.45 1.2 9.4 0.35 Biochemical Oxygen Demand 126 2 4.4 12 116 42 135 4000 38 (mg/L) Chemical Oxygen Demand 136 10 35 95 320 333 565 6100 298 (mg/L) Chromium (ug/L) 135 2.9 5 13 36 36 85 560 31 Copper (ug/L) 135 2 12 32 89 76 197 200 65 E.Coli MPN/100m1 131 1 100 520 11521 3550 12000 240000 3450 Enterococcus (MPN/100ml) 84 100 463 1600 20561 5775 36500 242000 5313 Fecal Coliform (cfu/100ml) 131 10 100 1500 37251 9650 46000 1200000 9550 Hexane Extractable 138 5 5 5 10 6.5 16 170 1.5 Material O&G Lead (ug/L) 135 1.3 5 9.9 189 46 296 9000 41 Nitrate/Nitrite 88 0.05 0.31 0.59 1.1 1.2 2.23 14 0.9 (mg/L) Suspended Sediment Concentration 86 3.8 18 75 204 190 539 1900 172 (mg/L) Total Kjeldahl Nitrogen (mg/L) 88 0.25 0.63 1.5 4.2 2.8 5.3 98 2.2 Total Phosphorus 88 0.01 0.13 0.3 1.2 0.79 1.7 48 0.7 (mg/L) Total Suspended Solids (mg/L) 142 2 25 88 320 208 850 3000 182 Turbidity (NTU) 138 1.1 33 1 95 1 517 1 260 1300 1 7200 1 227 Zinc (ug/L) 135 10 62 180 2170 1 635 1220 130000 573 Count = # of samples Q1 = 25th Percentile Q3 = 75th Percentile Inter -quartile Range = 75th Percentile - 25th Percentile Ammonia -Nitrogen J 2 m Biochemical Oxygen Demand 400 300 J m 200 O m 100 Chemical Oxygen ❑emand J ID 0 U Chromium 250 200 150 J_ U 100 50 Copper E. Coli 15000 — 10000 E 2 0 a ui 5000 50000 40000 E 0 0 z 30000 a 2 s 20000 10000 50000 40000 30000 20000 10000 0 Enterococcus Fecal coliform I 20 15 J E Cd 10 0 m w 5 0 500 400 300 J IL 200 100 0 Hexane Extractable Materia (O&G) Leac 41 J m 750 250 Nitrate/Nitrite Suspended Sediment Concentration Total Kjeldahl Nitrogen 20 sa 15 e� Total Phosphorus 5 4 3 J 2 0 Total Suspended Solids Turbidity 4 1500 4- a 1rr,n =,pn Zinc 2500 2000 1500 J_ C N 1000 500 ATTACHMENT I I Vehicle Maintenance Facility Inspection Form c�jiwhxx'v t1��111'TORM'_el { 0145 SaitFe Avenue WATER Facility hi-s ectio1l Charlorte„NC 28209 ~ $erriees Facility Name: Inspection P - Contact: Watershed: Inspector 4nspeotion Dwe: Entry Time: Exit Time: Facility Description_ File Revie-WHistory: Inspection Summary: Site Ksp&c idm eft9r: Comments Indoor maintenance 1 process area and materials storage Outdoor material and vehicle storage area(s) Stormwater system and outfalJs Waste Storage f Disposal Ares(s) Floor Drains 001 Water Separator or Pretrea<rnent Spill Ms Bays ar parts pressure washed to the 411tside �lrair4S al d Deflomncy Comments Illicii disohargelconnection New and Used Fluid storage Condition Miseellaneeus Waste Maceriais Product Removal Information • To report pollution a drainage problems call. 31I �'�' II11k [IPIII'_ http:Iistormwater chsrmeck.org ananazs 4:27:32PM page 1 or 1 ATTACHMENT 12 Vehicle Maintenance Facility Inspection Report Cover Letter — Satisfactory Charlotte -Mecklenburg STORM WATERServices StormWater.CharMeck.org <date> <Recipient's Name> <Address> <City, State Zip Code> Subject: <subject> Vehicle Maintenance Facility Inspection <FACILITY NAME> <Recipient's Name:> <Add text for first paragraph here> On <INSPECTION DATE>, <INSPECTOR'S NAME> of Charlotte -Mecklenburg Storm Water Services (CMSWS) conducted an inspection of the above referenced facility under authority granted by Charlotte City Code Chapter 18, Article III, Section 18-82. At the time of inspection, the facility was observed to be in compliance with the City of Charlotte Storm Water Pollution Control Ordinance; however, the following observations were made: 1) Charlotte Storm Water Pollution Control Ordinance Review • <Problem Area> — Note any deficiencies, noteworthy practices, and/or recommendations relative to this section of the report. • <Problem Area> — Note any deficiencies, noteworthy practices, and/or recommendations relative to this section of the report. The attached report provides details about inspection observations and recommendations. Thank you for your cooperation with the site inspection. Please contact me at <PHONE #> if you have any questions or need additional information regarding the attached report. Thank you, <Name> <Title> Charlotte -Mecklenburg Storm Water Services <City of Charlotte OR Mecklenburg County> da • ( 2145 Suttle Avenue 600 East 4th Street Charlotte, NC 28208 Charlotte. NC 28202 charlottenc.gov ATTACHMENT 13 Vehicle Maintenance Facility Inspection Report Cover Letter — Unsatisfactory Charlotte -Mecklenburg STORM WATERServices StormWater.CharMeck.org <date> <Recipient's Name> <Address> <City, State Zip Code> Subject: <subject> Vehicle Maintenance Facility Inspection <FACILITY NAME> <Recipient's Name:> <Add text for first paragraph here> On <INSPECTION DATE>, <INSPECTOR'S NAME> of Charlotte -Mecklenburg Storm Water Services (CMSWS) conducted an inspection of the above referenced facility under authority granted by Charlotte City Code Chapter 18, Article III, Section 18-82. At the time of inspection, the following conditions were observed at the facility that have the potential to negatively impact water quality and need corrective action: Area/Section of Report the problem was observed: Description of the condition. Corrective Actions / Recommendation to correct the issue in italics. Please submit a written response to the recommendations and corrective actions within the attached report to <INSPECTOR'S NAME> by <DEADLINE DATE>. Your response should explain what actions have been taken to address the recommendations and corrective actions. <A follow up inspection will also occur no later than <DEADLINE DATE>, unless scheduled earlier by facility personnel.> DELTE THIS SECTION IF NOT APPLICABLE. The attached report provides details about inspection observations and should be self-explanatory; however, should you have any questions concerning the report or any other stormwater matters, please contact me at <PHONE #>. Thank you, <Name> <Title> Charlotte -Mecklenburg Storm Water Services <City of Charlotte OR Mecklenburg County> • 4 2145 Suttle Avenue 600 East 4th Street Charlotte, NC 28208 Charlotte, NC 28202 �. charlottenc.gov