03 - Citywide Spill Response Guidance Document - Final

Citywide Spill Response
Guidance Document
Prepared for
City of Raleigh
Engineering Services
Stormwater Management Division
November 23, 2021

Citywide Spill Response Guidance Document
Prepared for
City of Raleigh
Engineering Services
Stormwater Management Division
November 2021

ii
Citywide Spill Response Guidance Document
Table of Contents
List of Tables ...................................................................................................................................................... iii
List of Abbreviations .......................................................................................................................................... iv
Document Revisions ........................................................................................................................................... v
1. Overview .................................................................................................................................................... 1-1
1.1 Document Purpose ........................................................................................................................ 1-1
1.2 Intended Users ............................................................................................................................... 1-1
1.3 Key Concepts .................................................................................................................................. 1-1
1.3.1 Storm Drain System ......................................................................................................... 1-2
1.3.2 Authorized Discharges ..................................................................................................... 1-2
1.3.3 Spills ................................................................................................................................. 1-2
1.3.4 Illicit Discharges ............................................................................................................... 1-2
1.4 City Spill Response Requirements ................................................................................................ 1-2
1.4.1 Ordinances and Regulations ........................................................................................... 1-3
1.4.1.1 City of Raleigh Illicit Discharge Ordinance .............................................................. 1-3
1.4.1.2 State Regulations..................................................................................................... 1-3
1.4.1.3 Federal Regulations ................................................................................................. 1-3
1.4.2 City Standard Operating Procedures .............................................................................. 1-3
1.4.2.1 Facility SPPPs, SWPPPs, and SPCC Plans .............................................................. 1-3
1.4.2.2 Department of Public Utilities (DPU) SOPs ............................................................. 1-4
1.4.2.3 Parks, Recreation, and Cultural Resources (PRCR) Emergency Action Plan
Manual. ..................................................................................................................... 1-4
1.4.2.4 PRCR Integrated Pest Management Policy ............................................................ 1-4
1.4.2.5 Stormwater Management Division SOPs ............................................................... 1-4
2. Spill and Illicit Discharge Prevention ....................................................................................................... 2-1
2.1 Identifying Potential Sources ......................................................................................................... 2-1
2.2 Spill Prevention Practices at Facilities .......................................................................................... 2-1
2.2.1 Management of Stormwater ........................................................................................... 2-2
2.2.2 Minimize Exposure ........................................................................................................... 2-2
2.2.3 Good Housekeeping......................................................................................................... 2-2
2.2.4 Maintenance .................................................................................................................... 2-3
2.3 Spill Prevention Practices for Field Operations ............................................................................ 2-3
2.3.1 Stormwater and Utility Repairs and Maintenance ......................................................... 2-3
2.3.2 Parking Lot, Sidewalk, and Road Maintenance and Repair and Graffiti Removal ...... 2-4
2.3.3 Winter Road Maintenance and Salt Application ............................................................ 2-5
2.3.4 Landscape, Park, Right-of-Way, Pond, and Dam Maintenance .................................... 2-5
2.3.5 Pesticide and Herbicide Application ............................................................................... 2-6
2.3.6 Collection of Solid Waste, Recycling, and Yard Waste .................................................. 2-6
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2.3.7 Diesel Generators and Equipment .................................................................................. 2-7
3. Spill Response Guidance ......................................................................................................................... 3-1
3.1 Initial Response /Assess and Secure the Scene ......................................................................... 3-1
3.2 Containment ................................................................................................................................... 3-1
3.3 Clean Up ......................................................................................................................................... 3-2
3.4 Spill Response Materials and Supplies ........................................................................................ 3-2
3.5 Roles and Responsibilities ............................................................................................................ 3-2
3.6 Spill Contacts.................................................................................................................................. 3-3
4. Reporting and Tracking of Spills and Illicit Discharges .......................................................................... 4-1
4.1 Definitions of Major Spill and Minor Spill ..................................................................................... 4-1
4.2 Tracking Systems ........................................................................................................................... 4-1
4.2.1 Requirements for High-Priority and Permitted Sites ...................................................... 4-2
4.3 Spill Reporting Requirements ....................................................................................................... 4-2
4.4 MS4 Permit Annual Reporting ....................................................................................................... 4-2
5. Annual Document Evaluation .................................................................................................................. 5-1
6. References ................................................................................................................................................ 6-1
Appendix A: Flow Charts ................................................................................................................................. A-1

List of Tables
Spill Response Guidance Amendment Log ....................................................................................................... v
Table 3-1. Spill Response Roles and Responsibilities .................................................................................. 3-3
Table 4-1. Occurrences That Must Be Reported ........................................................................................... 4-2

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List of Abbreviations
BMP best management practice
CERCLA Comprehensive Environmental Response, Compensation and Liability Act
City City of Raleigh
CFR Code of Federal Regulations
CWA Clean Water Act
DOP Divisional Operating Procedure
DPU Department of Public Utilities
DWR Division of Water Resources
EPA US Environmental Protection Agency
EPCRA Emergency Planning and Community Right to Know Act
GS General Statutes
HAZMAT hazardous material
IDDE Illicit Discharge Detection and Elimination
MS4 Municipal Separate Storm Sewer System
NCDEQ North Carolina Department of Environmental Quality
NESP Notification, Evacuation and Shelter Plan
NPDES National Pollutant Discharge Elimination System
PPGH pollution prevention and good housekeeping
PRCR Parks, Recreation, and Cultural Resources
RFD Raleigh Fire Department
SCM stormwater control measure
SDS safety data sheet
SOP standard operating procedure
SPCC Spill Prevention, Control, and Countermeasure
SPPP Site Pollution Prevention Plan
SSO sanitary sewer overflow
SWMP Stormwater Management Plan
SWPPP Stormwater Pollution Prevention Plan
WOTUS Waters of the United States

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Document Revisions
The following table includes a record of revisions to this documentation. Modifications may occur as a
result of operational changes or as a part of the annual program evaluation described in Section 5.

Spill Response Guidance Amendment Log
Date Description of Modification Modifier Name Modifier Signature

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Section 1
Overview
This Citywide Spill Response Guidance Document was developed to support compliance with the
pollution prevention and good housekeeping (PPGH) requirements of the City of Raleigh’s (City’s)
National Pollutant Discharge Elimination System (NPDES) Municipal Separate Storm Sewer System
(MS4) permit (Permit number NCS000245) Part II.G.2(d) through (f) which requires that the City:
· Maintain spill response procedures for municipal facilities and operations owned and operated by
the permittee that have been determined by the permittee to have significant potential for
generating polluted stormwater runoff (Part II Section G.2(d))
· Describe measures that prevent or minimize contamination of stormwater runoff from all areas used
for vehicle and equipment cleaning (Part II Section G.2(e))
· Implement best management practices (BMPs) to reduce polluted stormwater runoff from City-
owned and City-operated streets, roads, and public parking lots within the corporate limits (Part II
Section G.2(f)).
While the above-cited sections of the City’s MS4 permit apply only to City-owned and City-operated
facilities and operations within Raleigh’s corporate limits, the practices and procedures described in this
document can be implemented at City facilities that are not subject to requirement of this permit.
1.1 Document Purpose
The purpose of this document is to serve as a reference manual for spill prevention practices and spill
response procedures for City staff at municipal facilities and for crews conducting municipal operations
in the field and to describe roles and responsibilities of City staff for preventing and eliminating illicit
discharges. This document also includes general procedures and guidance for responses to spills,
including notification and reporting requirements and containment and cleanup practices.
1.2 Intended Users
It is understood that users of this document fulfill a variety of roles within the City. This document is
intended for use by City staff and contractors conducting municipal operations outside of a facility and by
City staff and contractors at facilities that do not have a site-specific Stormwater Pollution Prevention
Plan (SWPPP) or Site Pollution Prevention Plan (SPPP).
Facilities that do not maintain an SWPPP or SPPP should maintain a copy of this document on site in a
location where it can be easily accessed by staff in the event of a spill. At a minimum, field crews should
keep a copy of the spill response and reporting flow charts in Appendix A on-hand or readily accessible
during field operations.
1.3 Key Concepts
The release of unauthorized discharges to the stormwater system can negatively impact downstream
waterways. These discharges introduce pollutants into the stormwater system, which may degrade
habitat conditions of downstream surface waters and restrict public use of waterways due to poor water
quality. The cumulative effect of many untreated discharges, even in small amounts, can significantly
decrease the quality and use of receiving waters.
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1.3.1 Storm Drain System
The City is authorized to discharge stormwater from its MS4 to receiving waters of the State by its MS4
permit. The MS4 or storm drain system is the collection of inlets, pipes, ditches, and channels that
collect and convey stormwater within Raleigh’s corporate limits. Stormwater is discharged from the MS4
to receiving waters at outfalls identified and tracked by the City. Receiving waters, as defined in the City
MS4 Stormwater Management Plan (SWMP), are water bodies included in the North Carolina
Department of Environmental Quality (NCDEQ) Waterbody Classification Map or the most recent Final
303(d) List approved by the U.S. Environmental Protection Agency (EPA). Put more simply, receiving
waters are the natural waterways downstream of the MS4.
1.3.2 Authorized Discharges
Stormwater discharges from municipal, industrial, and construction activities that are permitted by the
City’s MS4 permit are authorized discharges.
Not all non-permitted non-stormwater discharges are illegal. Some flows have been determined to not
significantly impact water quality and are therefore considered incidental. The following non-stormwater
discharges are allowable by the City’s MS4 permit (Part I Section I.2) and by the City’s Illicit Discharge
Ordinance if they do not significantly impact water quality:
· Water line flushing
· Landscape irrigation
· Diverted stream flows
· Rising groundwater
· Uncontaminated groundwater infiltration
· Uncontaminated pumped groundwater
· Uncontaminated potable water sources
· Foundation drains
· Air conditioning condensate
· Irrigation waters
· Springs
· Water from crawl space pumps
· Footing drains
· Lawn watering
· Residential and charity car washing
· Splash pad water from potable water
sources only
· Flows from riparian habitats and wetlands
· Dechlorinated swimming pool discharges
· Street wash water
· Flows from firefighting activities (not
including firefighter training discharges)
The City MS4 SWMP includes an evaluation of the water quality impacts, if any, of these non-stormwater
discharges. If a flow type is determined to have more than an incidental impact on water quality, the
SWMP describes how the City will address the potential effects.
1.3.3 Spills
A spill has occurred when a substance has fallen, flowed, or run out of its containment. Depending on
the size, type, and location of the spill, the City may be subject to state and/or federal requirements.
Additionally, if not properly contained and cleaned up, spills can become illicit discharges if combined
with stormwater runoff during subsequent storm events.
In some cases, spills must be reported to the NCDEQ or the National Response Center. Whether or not
the spill qualifies as reportable depends on the substance and quantity of the material released. For
more information on reportable spills, see Section 4.
1.3.4 Illicit Discharges
An illicit discharge is any discharge to the MS4 that is not composed entirely of stormwater, except
stormwater discharges authorized by an NPDES permit, allowable non-stormwater discharges (described
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in Part I Section I of the City MS4 permit and Section 1.3.2), and discharges resulting from fire-fighting
activities (Part VIII Definition 12 of the City MS4 permit).
To be defined as an illicit discharge, the material must reach the storm sewer system or surface waters.
For example, if a spill reaches a waterway that is considered a jurisdictional water or Waters of the
United States (WOTUS), the spill must be reported, per the procedures specified in Sections 3.3 and 4.2.
For municipal facilities and operations, common sources of illicit discharges include:
· Vehicle and equipment use, storage, and fueling
· Vehicle and equipment washing
· Chemical use, storage, and disposal
· Fuel, oil, and grease storage
· Diesel generator maintenance and use
· Sanitary sewer line repair and maintenance
· Storm sewer/drain repair and maintenance
· Water line repair and maintenance
· Sidewalk repair and maintenance
· Parking lot maintenance
· Minor road repair and maintenance
· Winter road repair and maintenance
· Landscape and park maintenance
· Other construction activities
· Pesticide and herbicide application
· Leaf collection
· Solid waste and recycling cleanup and pickup
· Graffiti removal
In addition to the City MS4 permit, the City’s Illicit Discharge Ordinance (Municipal Code Chapter 5
Section 13-5007(a)) outlines detailed criteria for what is considered an illicit discharge.
1.4 City Spill Response Requirements
As an MS4 permitholder, the City maintains a program to comply with the requirements of its permit.
This document will address procedures to fulfill Part II Section G.2 (d), (e), and (f) of the permit.
Some City facilities are also subject to additional requirements from industrial and construction
stormwater permits as a result of the types of activities performed on the site or the types of chemicals
and/or materials present. Staff at facilities with industrial or construction stormwater permits are
responsible for complying with the requirements of those permits. In addition to permit required
materials, some City departments maintain other spill prevention and response procedures that staff are
expected to follow.
The following sections outline the spill response requirements of the City MS4 permit, relevant City
ordinances as well as state and federal regulations, and City standard operating procedures (SOPs) and
other guidance documents related to spill response.
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1.4.1 Ordinances and Regulations
The procedures outlined in this document align with the following City, state, and federal regulations.
1.4.1.1 City of Raleigh Illicit Discharge Ordinance
The City’s Illicit Discharge Ordinance (Municipal Code Chapter 5 Section 13-5007, effective February 20,
2011) prohibits illicit discharges, spills or leaks, and illicit connections that result in polluted discharges
or releases entering, or having the potential to enter, the City’s MS4 or waters of the state.
1.4.1.2 State Regulations
State requirements for reporting spills are documented in General Statutes (GS) Chapter 143
Section 215.85 (GS §143-215.85) (2015) for required notice.
1.4.1.3 Federal Regulations
The federal government has established requirements for spills of oil or hazardous substances that
reach a federally determined limit. Regulations that determine the criteria for a reportable spill include:
· Emergency Planning and Community Right to Know Act (EPCRA), also known as Title III of the
Superfund Amendments and Reauthorization Act of 1986
· Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) of 1980, also
known as Superfund
· Clean Water Act (CWA), including the Discharge of Oil Regulation and the Spill Prevention, Control,
and Countermeasure (SPCC) Rule
There are separate reporting requirements for oil spills and hazardous substance releases. If a listed
material is released above the regulatory threshold or the specified reportable quantity, the facility staff
responsible for the spill or discharge must report the spill according to the applicable requirements.
1.4.2 City Standard Operating Procedures
In addition to this document, the City maintains other guidance for select facilities and departments that
describe methods to prevent, respond to, and report spills and illicit discharges associated with
municipal activities.
1.4.2.1 Facility SPPPs, SWPPPs, and SPCC Plans
The City is required to maintain and implement SPPPs for municipal facilities owned and operated by the
City that are within Raleigh’s corporate limits and have significant potential to generate polluted
stormwater runoff. These plans document the site conditions, activities performed on the site and
associated pollutant sources, stormwater control measures, and BMPs to prevent or minimize
contamination of stormwater pollution. These SPPPs include facility-specific inspection and spill
response procedures.
Some municipal facilities are also covered by NPDES industrial stormwater permits that require the
development and implementation of an SWPPP. The requirements of that plan vary by the industrial
activities performed at the facility. Some permitted facilities that have an aggregate aboveground oil
storage capacity greater than 1,320 gallons or underground capacity greater than 42,000 gallons with a
reasonable potential for an oil discharge into WOTUS are also required to develop an SPCC plan.
SPPPs, SWPPPs, and SPCC plans include facility-specific spill response procedures that facility staff are
expected to implement.
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1.4.2.2 Department of Public Utilities (DPU) SOPs
DPU is responsible for response, clean-up, and reporting in the event of a sanitary sewer overflow (SSO)
or leaks occurring within DPU operated facilities. The following list includes guidance documents relevant
to chemical releases at DPU facilities and SSO response:
Water Treatment Plant Divisional Operating Procedures (DOP) Number 002: Chemical Leak Response
· Organizations Affected: Water Treatment Plant Operations/Maintenance Staff
· Purpose: Establishes procedures for operators to follow in the event of a chemical leak at a
treatment plant. This document includes flow charts for initial responses to chemical leaks.
Sewer Maintenance DOP SM 0002: Sanitary Overflow Response
· Organizations Affected: DPU
· Purpose: Describes procedures to respond to discharges from the wastewater collection system. The
guidelines were established to avoid issues or failures in the collection system that may negatively
affect the environment or lead to violations of the City’s collections system permit.
Notification, Evacuation and Shelter Plans (NESPs)
· Organizations Affected: Wastewater Treatment Plant Staff
· Purpose: Each wastewater treatment plant maintains an NESP, which outlines how staff should
respond in the event of a chemical release at the Neuse River Resource Recovery Facility, the Smith
Creek Wastewater Treatment Plant, and the Little Creek Wastewater Treatment Plant.
Water Distribution 600 SOP 5270.0024.628: Protection of Storm Drains During a Water Asset
Repair/Maintenance Event
· Organizations Affected: DPU
· Purpose: Establishes procedures to minimize the amount of solid materials (e.g., mud, rocks, and
debris) that enter the storm drain during repair or maintenance of City assets.
1.4.2.3 Parks, Recreation, and Cultural Resources (PRCR) Emergency Action Plan Manual
The Emergency Action Plan establishes general emergency procedures for building and park occupants
to follow in the event of emergencies that arise at facilities owned or operated by the PRCR Department.
The Emergency Action Plan includes procedures to be followed in the event of a chemical spill or
chemical attack and an inventory of spill kits and spill kit materials maintained at PRCR facilities.
The PRCR Department also maintains an Emergency Response Guide to serve as a companion
document to the Emergency Action Plan. The Emergency Response Guide is a quick reference for use
during an emergency and includes a section for hazardous material (HAZMAT) chemical spills. As such, a
copy of the Guide is included in all PRCR spill response kits throughout Raleigh.
1.4.2.4 PRCR Integrated Pest Management Policy
The Integrated Pest Management Policy specifies the use and application of pesticides on the landscape
and grounds of property owned, controlled, or managed by the PRCR Department. This document
includes training requirements, application practices, and general pesticide handling procedures to
avoid the misuse or runoff of pesticides.
1.4.2.5 Stormwater Management Division SOPs
The City Stormwater Management Division has developed several SOPs related to the detection and
elimination of spills and illicit discharges. The following list includes relevant Stormwater Management
Division SOPs:
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SOP SW-100: Illicit Discharge Detection and Elimination (IDDE)
· Organizations Affected: Engineering Services Stormwater Management Division, Transportation Field
Services, DPU, Fire Department, Inspections, City Attorney
· Purpose: Establishes procedures for addressing non-stormwater discharges and connections into
the stormwater conveyance system and waters of the state
SOP SW-101: Managing Spills of Materials which Threaten to Enter the Stormwater Conveyance System
· Organizations Affected: Engineering Services Stormwater Management Division
· Purpose: Establishes the responsibilities and procedures to be followed by Stormwater Management
staff in response to emergencies involving hazardous and non-hazardous materials that threaten to
enter the stormwater conveyance system
SOP SW-102: Managing Spills of Materials which Threaten to Enter the Stormwater Conveyance System
· Organizations Affected: All City departments
· Purpose: Establishes the responsibilities and procedures to be followed by City staff in response to
emergencies involving hazardous and non-hazardous materials that threaten to enter the
stormwater conveyance system
SOP SW-103: Outfall Inspections for Illicit Discharge Detection
· Organizations Affected: Engineering Services Stormwater Management Division
· Purpose: Establishes responsibilities and procedures to locate and eliminate water quality problems
in streams and lakes during routine outfall inspections within the City

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Section 2
Spill and Illicit Discharge Prevention
The City is committed to implementing practices and programs that encourage activities that prevent
spills and illicit discharges.
2.1 Identifying Potential Sources
A range of common pollutants can be generated by municipal facilities including sediment, nutrients,
trash, organics (from grass clippings, insecticides, paints, and other sources), oil and grease, and
oxygen-demanding substances (from plant debris, sewage, solvents, and other sources). An important
component of preventing spills and illicit discharges at municipal facilities is the identification of
potential sources of pollution. Facilities and operations with a greater likelihood to produce stormwater
pollution can be identified based on activities that may be a source of pollutants.
Facilities with the following features have potential to produce polluted stormwater runoff:
· Dumpsters or other waste disposal
containers
· Pool maintenance
· Chemical, fuel, oil, or grease storage
· Material stockpiles
· Vehicle and equipment storage
· Boat houses
· Construction activities
· Brine/salt storage
· Fueling stations
· Vehicle and equipment maintenance
· Vehicle washing
· Equipment hydraulic lines
· Diesel generators
· Dog parks
Municipal operations conducted in the field also can pollute stormwater runoff, including:
· Sanitary sewer line repair and maintenance
· Storm sewer/drain repair and maintenance
· Water line repair and maintenance
· Sidewalk repair and maintenance
· Parking lot maintenance
· Road repair and maintenance
· Winter road maintenance and salt
application
· Landscape, park, and right-of-way
maintenance
· Pesticide and herbicide application
· Leaf collection
· Solid waste and recycling pickup and
transfer
· Graffiti removal
The following sections describe general spill prevention practices that may be implemented at City
facilities and by field crews conducting field operations.
2.2 Spill Prevention Practices at Facilities
This section describes recommended PPGH practices that can be implemented at City facilities to
prevent spills and illicit discharges. Facilities with an SPPP or SWPPP should also refer to the facility-
specific plan for guidance and requirements.
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2.2.1 Management of Stormwater
As required by the City’s MS4 permit, non-stormwater flows may not be discharged to the City’s storm
drain system.
Facilities where vehicle and equipment cleaning is performed (excluding fire stations with three or fewer
fire trucks or ambulances) must manage the wash water according to the following guidance:
· Perform all cleaning operations, including pressure washing, indoors or under cover, ensure wash
water drains to the sanitary sewer system and not the storm sewer system, or collect wash water
and stormwater run-on from the cleaning area and provide treatment or recycling (or equivalent
measures).
· If the sanitary sewer system is not available and cleaning operations occur outdoors, drain wash
waters to a stormwater control measure (SCM) for treatment, or the cleaning operations should
occur on or drain directly to a grassed or gravel area to prevent a point source discharge to the MS4
or receiving waters.
· If cleaning operations are performed in the vicinity of the storm drain system and the above-listed
practices cannot be performed, then the drain is to be covered with a temporary drain cover during
cleaning activities. The excess water shall be removed and properly handled before removing the
drain cover.
Facilities with three or fewer fire trucks or ambulances should attempt to comply with the above
requirements. If a facility determines it cannot comply with the requirements described above, the
facility staff should contact the Stormwater Management Division for further discussion.
2.2.2 Minimize Exposure
The following list includes practices that municipal facilities can implement to minimize exposure of
potential spill and illicit discharge sources to precipitation and stormwater.
· When possible, conduct industrial activities (including, but not limited to, the list of features and
activities in Section 2.1) indoors or under cover.
· Store chemicals indoors or under cover and with secondary containment to limit the spread of
releases.
· Store empty chemical containers, and containers that have come in contact with chemicals, upright
in a covered area.
· Fuel, service, and repair City vehicles and equipment at designated sites and locations where
preventative measures are in place to reduce the possibility of an illicit discharge.
· Cover dumpsters and other waste receptacles with a lid, tarp, or awning.
· Regularly inspect dumpsters and waste receptacles to ensure they are in good condition. Replace
dumpsters with significant corrosion or with stains that indicate a leak has occurred.
· Drain City vehicles or equipment of fluids if they are to be stored on the site long-term. Otherwise,
use a drip pan or similar spill containment structure to capture potential leaks.
· When possible, store vehicles and equipment in a covered area.
2.2.3 Good Housekeeping
The following list includes practices that municipal facilities can implement to keep exposed areas free
of potential spills and illicit discharges include:
· Keep the site grounds clean of waste and debris.
· Empty waste containers at a frequency that prevents overflow.
· Properly label chemical containers.
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· Store, handle, and dispose of chemicals as described in the safety data sheets (SDSs) or according
to the manufacturer’s instructions.
· Provide and maintain spill response materials on site.
· Use drip pans or a similar containment structure under vehicles or equipment with evidence of a
leak or spill until maintenance can be completed.
· Clean up stains on pavement and on the ground and, if possible, determine the source of the stain
and eliminate the discharge.
· Educate and train staff on pollution prevention, good housekeeping, and IDDE.
2.2.4 Maintenance
The following list includes procedures that municipal facilities can perform to: (1) maintain industrial
equipment and systems to minimize the potential for pollutant discharges and (2) maintain the operating
condition of control measures (i.e., the BMPs used to prevent or contain potential spills and illicit
discharges):
· Inspect stormwater infrastructure and report issues to the Stormwater Management Division.
· Inspect spill response materials and restock, as needed.
· Inspect chemical and fuel containers for condition and risk of failure.
· Inspect vehicle and equipment storage areas for signs of leaks.
· Regularly service vehicles and equipment.
· Perform and document regular maintenance of control measures, such as oil-water separators and
grease traps.
2.3 Spill Prevention Practices for Field Operations
Field operations, which occur throughout the City, also have the potential to produce pollutants that may
be discharged to the MS4 or nearby creeks, streams, or lakes. Unlike facilities where permanent
pollution prevention practices can remain in place, field operations are mobile. As a result, pollution
prevention practices must be regularly implemented each day or at each new location.
The following sections outline practices that field staff can implement to prevent pollution from common
field operations listed in Section 2.1 that have a significant potential to produce stormwater pollution.
2.3.1 Stormwater and Utility Repairs and Maintenance
Sanitary sewer, water, and stormwater infrastructure repairs and maintenance have the potential to
create sediment, trash, and oil and grease. Additional pollutants associated with sanitary sewer line
repairs include sewage, bacteria, organics, and nutrients.
The following general pollution prevention practices should be implemented during sanitary sewer, water
line, and storm sewer line repairs and maintenance:
· When possible, work should be performed during dry weather.
· Field staff should carry spill response materials in their vehicles unless working at a facility where
spill response materials are readily available.
· For long term projects, implement erosion control measures, such as silt fences and swale
protection, to prevent the release of sediment from the work area.
· Install inlet protection, such as filter socks, around nearby catch basins and drop inlets to prevent
sediment from entering the stormwater system.
· Waste materials and chemicals should never be poured into a storm drain.
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· When possible, keep the work area clear of trash and debris. Street sweepers, vacuums, blowers,
and shovels may be used to remove sediment from the gutter and sidewalk.
· Chemicals and chemical waste should be handled, stored, and disposed of according to the SDS or
manufacturer’s instructions and in a manner that prevents leaks or spills.
· Stockpile materials away from storm drains, ditches, or waterways. If stockpiles are to be present
more than three days or if inclement weather is expected, they should be stored indoors or covered
by a tarp or equivalent measure.
· When performing sanitary sewer line repairs and maintenance, DPU staff should take additional
precautions to prevent the release of sewage.
· Equipment cleaning and maintenance should be performed in designated wash areas only.
2.3.2 Parking Lot, Sidewalk, and Road Maintenance and Repair and Graffiti Removal
Parking lot, sidewalk, and road maintenance and repairs have the potential to create sediment, trash,
metals, organics, and oil and grease pollution.
Listed below are general pollution prevention practices that should be implemented during parking lot,
sidewalk, and road maintenance and repairs. These practices are in addition to other plans or SOPs
provided to field staff.
· When possible, work should be performed during dry weather.
· For long term projects, implement erosion control measures, such as silt fences and swale
protection, to prevent the release of sediment from the work area.
· Install inlet protection, such as filter socks, around nearby catch basins and drop inlets to prevent
sediment from entering the stormwater system.
· Waste materials and chemicals should never be poured into a storm drain.
· When possible, keep the work area clear of trash and debris. Street sweepers, blowers, and shovels
may be used to remove sediment from the gutter and sidewalk.
· Chemicals and chemical waste should be handled, stored, and disposed of according to the SDS or
manufacturer’s instructions and in a manner that prevents leaks or spills.
· Stockpile materials away from storm drains, ditches, or waterways. If stockpiles are to be present
more than three days or if inclement weather is expected, they should be stored indoors or covered
by a tarp or equivalent measure.
· When possible, use dry removal methods, such as blowers, brooms, or sweeper vehicles. Do not
allow swept debris to enter the stormwater system.
· Do not use soaps or chemicals when pressure washing sidewalks or pavement. Sweep the sidewalk
before pressure washing to remove excess debris.
· When sealcoating, use an asphalt-based sealant, if feasible, and avoid use of coal-tar-based
sealants. Do not apply if rain is forecasted in the next 48 hours.
· Equipment used to store or transport concrete should be washed out only in a designated concrete
washout area so that concrete wash water or liquid concrete waste does not reach the storm sewer
system.
· When removing graffiti, use biodegradable solvents only on affected areas.
· Take necessary precautions to prevent wastewater from pressure washing from entering the storm
sewer system.
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2.3.3 Winter Road Maintenance and Salt Application
Winter road maintenance and salt application have the potential to create sediment, salt, and oil and
grease pollution.
The following general pollution prevention practices should be implemented during plowing or deicing
winter roads. These practices are in addition to other plans or SOPs provided to field staff.
· Reduce truck speed and modify snowplow angles near water bodies, wetlands, or other
environmentally sensitive areas.
· Install inlet protection, such as filter socks, around nearby catch basins and drop inlets to prevent
sediment, salt, or ice melt from entering the stormwater system during road maintenance.
· Stockpile salt and ice melt away from storm drains, ditches, or waterways. If stockpiles are to be
present more than three days or if inclement weather is expected, they should be stored indoors or
covered by a tarp or equivalent measure.
· Follow product labels and/or the City’s MS4 Operations and Maintenance plan to calibrate
spreading equipment (deicers) so that only the amount of salt needed is applied. Limit excess salt
on roadways.
· Clean salt spreaders and remove excess salt and debris before storage. Vehicles should be cleaned
in a designated area where the wash water will not be allowed to discharge to the storm drain
system or a natural waterway. Excess salt should be used or disposed of properly.
2.3.4 Landscape, Park, Right-of-Way, Pond, and Dam Maintenance
Landscape, park, pond, right-of-way, and dam maintenance have the potential to create sediment,
fertilizer, trash, pesticides, herbicides, debris, and nutrient pollution.
The following general pollution prevention practices should be implemented during park, landscape,
right-of-way, pond, and lake maintenance:
· When possible, work should be conducted during dry weather. Apply fertilizers and other chemicals
only on days where precipitation is not forecasted within 24 hours (or the manufacturer’s specified
period) of the application.
· Avoid mowing stream banks or other buffer vegetation around waterbodies.
· Before working in or around an SCM, review the SCM’s Operation and Maintenance Manual.
· Remove grass clippings, leaves, branches, and debris from paved areas and walkways on the same
day maintenance is performed.
· Avoid blowing grass clippings, leaves, branches, and debris in storm drains or surface waters. If
possible, bag and dispose of clippings and other debris.
· Do not water or irrigate vegetated areas following chemical application.
· Avoid applying fertilizer near streams, lakes, and ponds.
· Prepare only as much fertilizer as needed for the anticipated project.
· Calibrate fertilizer applicators to ensure that proper quantities are dispensed. Follow manufacturer’s
recommendations (or a nutrient management plan) to avoid application of excess amounts of
fertilizer.
· Avoid overcasting or accidental spread of fertilizers on sidewalks, parking lots, or roads, which can
then wash into a storm drain or into a natural watercourse. Remove any fertilizer residuals
incidentally deposited on paved areas.
· Protect and stabilize disturbed soils or high erosion areas with mulch control nets, erosion control
blankets, or similar erosion control products.
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· Use a sediment barrier or other inlet protection around stormwater inlets during construction
upstream or in adjacent areas.
· Some maintenance activities around waterways may require additional erosion control practices or
permits. Staff should refer to Chapter 6 of the City Stormwater Design Manual for more information
about erosion and sediment control requirements.
2.3.5 Pesticide and Herbicide Application
Pesticides and herbicides contain toxic chemicals that may pose a risk to human health and the
environment if released into the stormwater system or waterways.
The following general pollution prevention practices should be implemented during pesticide and
herbicide application:
· Pesticides and herbicides should be applied only by trained and certified applicators.
· Follow application techniques outlined in the PRCR Integrated Pest Management Plan and the
product’s instructions.
· Prior to working in or around an SCM, review the SCM’s Operation and Maintenance Manual.
· Chemicals and chemical waste should be handled, stored, and disposed of according to the SDS or
manufacturer’s instructions and in a manner that prevents leaks or spills.
· Apply only as needed and only to areas of concern.
· Do not stockpile pesticides and herbicides outdoors during application. Only bring to the field what is
necessary for that day’s application. Store material not in use under cover or inside of a truck.
· Do not water or irrigate areas on the same day as application.
· Apply pesticides or herbicides on days where precipitation is not forecasted within 24 hours (or the
manufacturer’s specified period) of the application.
· Avoid overcasting or accidental spread of chemicals on sidewalks, parking lots, or roads, which can
then wash into a storm drain or into a natural watercourse. Remove any chemical residuals from
paved areas following application.
· Waste materials and chemicals should never be poured into a storm drain.
2.3.6 Collection of Solid Waste, Recycling, and Yard Waste
Solid waste, recycling, and leaf collection have the potential to create sediment, debris, nutrient, and
trash pollution.
Listed below are general pollution prevention practices that should be implemented during solid waste
and loose-leaf collection. These practices are in addition to other plans or SOPs provided to field staff.
· Verify that collected leaves, waste, or recycled materials are secure in the vehicle during waste pick-
up and transport to the disposal location.
· Check the surrounding area while loading waste collection vehicles for any overflow of trash or litter.
· Dispose of collected waste in the appropriate site.
· Collection vehicles, equipment, and attachments should be routinely serviced and verified to be in
working order. Repair any leaks or container defects prior to collection services.
· Collect and dispose of litter throughout the duration of the operation and again at the time of
completion.
· Trash generated by municipal operations should be properly disposed of to avoid creation of litter.
· Do not sweep litter or debris into the storm sewer system, stormwater conveyances, or waterways.
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2.3.7 Diesel Generators and Equipment
Diesel generators and equipment, such as diesel-powered pumps, have the potential to create oil,
grease, oxygen demanding substances, and organics pollution.
The following general pollution prevention practices should be implemented for the use and
maintenance of diesel generators and equipment:
· Staff responsible for fueling, operation, and testing of diesel-powered generators or equipment
should be trained in the proper procedures to fuel and use the generator/equipment.
· Diesel generators should be stored with secondary containment.
· Diesel pumps and generators should have a spill kit or materials nearby in the event of a spill or
leak.
· Diesel generators and equipment should be inspected and tested routinely. Repair any defects as
soon as possible.
· Diesel generators or equipment used for field operations should be inspected for leaks prior to
transport to the site where it will be used.
· Before, during, and after use, check the area around the diesel generator/equipment for signs of
spills or leaks. If a leak is observed, contact your supervisor and/or take necessary containment
measures until repairs can be made.
· Diesel generators and equipment should be stored under cover when not in use.

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Section 3
Spill Response Guidance
This section describes how City staff and contractors performing municipal operations should respond to
a spill, including initial actions, spill containment and clean-up, the locations of spill response materials,
and who to contact during and immediately following a spill event. City staff may also refer to the flow
charts included in Appendix A for a visual representation of the processes described in this section.
3.1 Initial Response /Assess and Secure the Scene
In the event of a spill or leak, the staff member who observed the spill or leak (initial responder) will
notify his/her supervisor of the situation and then investigate the scene, if it is safe to do so.
Upon arrival at the scene, the initial responder or supervisor will assess the safety of employees in the
area and determine whether an illicit discharge has occurred.
1. If there are injuries or fires, potential for injuries or fires, or if the release could endanger the public,
call 9-1-1 immediately.
2. Once safety concerns have been addressed, onsite staff and responders should strive to contain
and clean up the spill using available materials. See next section for more details.
3. Initial responder should assess the scene for possible illicit discharges.
4. If no illicit discharge has occurred, the initial responder will return to the office and submit the
appropriate documentation.
5. If a violation of the Illicit Discharge Ordinance is observed, the initial responder will determine
whether Raleigh Fire Department (RFD) and/or HAZMAT response1 is needed.
6. Following emergency contacts and initial response activities, contact the Stormwater Management
Division to report the spill.
For less severe incidents, the initial responder will determine whether additional staff support is needed
and contact his/her supervisor to request additional staff at the scene if needed.
3.2 Containment
If the spill material is non-hazardous and onsite staff can safely access the spill area, staff should try to
contain and clean the spill with the below steps using the spill response materials available. If the spill
cannot be contained, the initial responder will notify the Emergency Communications Center (Call 9-1-1).
1. Determine whether the spill is flowing toward or into the storm drainage system through a drop inlet,
catch basin, ditch, or other conveyance element.
2. If a spill has the possibility of entering a storm inlet, remove the plastic covering of a boom sock or
equivalent and place the boom sock around the stormwater inlet entrance to protect the inlet from
contaminants. If the spill is flowing under the boom sock, pour loose absorbent or equivalent on the
ground in front of the boom sock to prevent the spill from entering the stormwater conveyance
system.

1 Members of the RFD HAZMAT Team follow the guidelines outlined in Number 1020.5.3 of the City’s Fire Department
Operational Procedures manual for HAZMAT response.
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3. If a spill has already entered a storm inlet or other feature of the stormwater conveyance system,
still place the boom sock around the inlet entrance to contain the spill and prevent further
contaminants from entering the stormwater conveyance system.
4. After the storm inlet(s) is (are) protected, take at least one bag of loose absorbent or equivalent and
spread the absorbent over the spill area. More than one bag may be necessary to cover the entire
spill area. Properly apply loose absorbent or equivalent according to the following procedure:
1. Cut an opening into one corner of the bag (or remove absorbent bin lid).
2. Tilt the bag and shake the absorbent lightly over the entire spill area.
3. Use a broom to spread and thoroughly rub absorbent or equivalent into the spill material.
4. Repeat steps above until the spill is fully absorbed.
5. Staff must ensure that the site is cleaned up after containing the spill. Use a flat headed shovel to
transfer the used absorbent material into a labeled five-gallon bucket for waste characterization and
proper disposal by an approved contractor.
3.3 Clean Up
Following spill containment, clean-up activities must be completed to the satisfaction of the City.
Individuals responsible for spill clean-up vary depending on the type and volume of spilled material.
Clean-up activities may include but are not limited to removing contaminated water from a stream,
removing contaminated soil from a stream bank, ditch, or detention basin, or recovering material from
impacted surfaces.
Upon final inspection by the initial responder to confirm the clean-up is complete, the responder will
coordinate with his/her supervisor on the necessary reporting. All reports of hazardous materials spills,
accidents, fires, and other emergencies will be directed to the Emergency Communications Center.
3.4 Spill Response Materials and Supplies
Spill response materials are available at some City facilities or are carried by some City staff. This section
will describe where staff can locate spill response materials.
· A spill kit is maintained at all City owned and operated fueling stations.
· All RFD fire trucks have spill materials on the truck.
· Spill response trailers are maintained at the two City water treatment plants.
· Facilities with an industrial stormwater permit or those with an SPCC plan maintain spill kits on site.
All facilities with an SPPP or SWPPP have some spill response materials on site, as documented in
the SPPP or SWPPP.
· The locations of spill response kits and their contents at PRCR facilities are specified in the PRCR
Emergency Response Guide. In general, spill kits are available at aquatic centers and with
pesticide/herbicide applicators.
Facilities with spill kits or materials are expected to ensure that used materials are replaced in the event
of future spills.
3.5 Roles and Responsibilities
Table 3-1 summarizes the key roles and responsibilities during and after a spill.

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Table 3-1. Spill Response Roles and Responsibilities
Entity Responsibility
Initial Responder • Initiates spill response procedures (e.g., the supervisor on-staff or staff
member who discovered the spill/leak)
Facility or Operations Contact/Supervisor • Provides guidance to the initial responder during spill containment
• Responsible for assessing the degree of containment of the spill and if the
materials entered the stormwater conveyance system
• Responsible for facilitating clean-up of the spill by a responsible City entity
or a professional environmental clean-up/remediation company
• Responsible for notifying the Stormwater Management Division of the spill
RFD • First responder for some major spills and spills of hazardous substances
• In a hazardous material emergency, RFD will assess the degree of hazard
and implement appropriate emergency action to contain the spill
DPU • Responsible for response, clean-up, and reporting in the event of an SSO
Stormwater Management Division • First responder for minor spills
• Second or third responder for large spills
• Responsible for determining responsible party
• Assist with assessing the degree of containment of the spill and if the
materials entered the stormwater conveyance system
• Responsible for ensuring spills are reported to NCDEQ and additional
parties, as necessary
• Provides guidance on clean-up and site remediation.

3.6 Spill Contacts
Supervisors (or the spill response contact) of municipal facilities must notify the City’s Stormwater
Management Division by phone at [phone] or via email at [e-mail] of all
spills. The Stormwater Management Division should be contacted as soon as safely possible (following
emergency contacts and initial response activities).
SSOs should be reported to DPU by phone [phone] or via email at
[e-mail].
The NCDEQ Division of Water Resources (DWR) must be notified of situations that will significantly
impact waters of the State. The responsible party and the Stormwater Management Division must notify
DWR.
If an oil spill occurs, DWR must be notified if more than 25 gallons are discharged, if the discharge
occurs within 100 feet of a surface water body, or if a sheen is noticed on a nearby waterbody.
If the spill occurs during business hours (Monday-Friday, 8 AM to 5 PM), the spill must be reported to the
Regional Office at [phone]. If no answer, call [phone]. Oil spills must also be reported to
the National Response Center at [phone]. Notification must occur within 24 hours of the
discharge.
If the spill occurs after hours or on a weekend, call [phone] in addition to the National Response
Center.
For spills of hazardous substances, the spill must be reported if it exceeds the reportable quantities
under Section 311 of the CWA, Section 102 of CERCLA, or North Carolina GS § 143-215.85.
Section 4 includes additional guidance on when other spills must be reported.

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Section 4
Reporting and Tracking of Spills and
Illicit Discharges
Maintaining accurate and up-to-date documentation of spills and illicit discharges and the City’s
response will ensure that incidents are resolved, and all necessary information is documented for
compliance with the requirements of the City MS4 permit and other regulations.
4.1 Definitions of Major Spill and Minor Spill
A minor spill is one that can be safely resolved by facility or operations staff, does not reach the MS4 or a
receiving water, and does not otherwise meet the criteria to be considered a major or reportable spill. An
example of a minor spill is a small fuel release at a pump that is more than 100 feet from a water body
and that can be cleaned up using the materials in a spill response kit.
A major spill is one that cannot safely be resolved or contained by facility or operations staff, that
involves a hazardous substance, or that meets the criteria to be a reportable spill. Because DPU is
required to report SSOs that reach surface waters as part of the City NPDES wastewater permit, an SSO
may be considered a major spill for the purposes of this document. DPU may categorize SSOs differently
based on other characteristics, such as the volume released.
Whether a spill must be reported is determined by the content and quantity of the material released. For
oils or hazardous substances, any release that exceeds the reportable quantity thresholds established in
the CWA Section 311 (see 40 Code of Federal Regulations [CFR] Parts 110.6 and 117.21) or
Section 102 of the CERCLA (Chapter 42 of the United States Code, §9602) or that meets the criteria
described in Part H of the North Carolina General Permit for Transit and Transportation must be
reported. For SSOs, staff should contact DPU, which will determine if the event is reportable and
complete the necessary response actions. More information about what is considered a reportable spill
is included in Section 4.3.
4.2 Tracking Systems
Following initial containment activities of a major spill, the responsible division or department staff must
conduct a preliminary assessment of the spill and then submit a work order. Minor spills of non-
hazardous materials that can be contained and cleaned without the assistance of emergency
responders do not need to be reported.
The Facility Contact and Stormwater Management Division must ensure that major spills that are greater
than the stipulated reportable quantities (defined in Section 4.3) are reported to the appropriate
agencies following completion of cleanup activities and within the required reporting period. Records of
reported spills must be maintained for a minimum period of five years from the date of the report.
Any corrective actions, resolutions, or follow-up activities should be recorded and maintained at the
facility or with the responsible division or department.
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4.2.1 Requirements for High-Priority and Permitted Sites
Facilities with SPPPs and SWPPPs are required to maintain a record of spills or illicit discharges at the
site for five years. All spills and illicit discharges that occur at these facilities should be documented
within the SPPP or SWPPP document in the appropriate table.
4.3 Spill Reporting Requirements
All reports of hazardous material or oil spills must be reported to Emergency Communications (9-1-1), as
well as the parties described in Section 3.5. A list of occurrences that shall be reported to the NC DEQ
Regional Office is included in Table 4-1 below.

Table 4-1. Occurrences That Must Be Reported
Occurrence Reporting Timeframes (After Discovery) and Other Requirements
Visible sedimentation in a stream or wetland
1. Within 24 hours, an oral or electronic notification must be made.
2. Within 7 calendar days, a report that contains a description of the
sediment and actions taken to address the cause of the deposition
must be submitted.
3. Division staff may waive the requirement for a written report on a
case-by-case basis.
Oil spills if they:
· Are 25 gallons or more
· Are less than 25 gallons but cannot be cleaned up within 24 hours
· Cause sheen on surface waters (regardless of volume)
· Are within 100 feet of surface waters (regardless of volume)
Within 24 hours, an oral or electronic notification must be made. The
notification shall include information about the date, time, nature,
volume, and location of the spill or release.
Anticipated bypasses [40 CFR 122.41(m)(3)]
A report at least ten days before the date of the bypass must be
submitted, if possible. The report shall include an evaluation of the
anticipated quality and effect of the bypass.
Unanticipated bypasses [40 CFR 122.41(m)(3)]
1. Within 24 hours, an oral or electronic notification must be made.
2. Within 7 calendar days, a report that includes an evaluation of the
quality and effect of the bypass must be submitted.
Any SSO and/or spill over 1,000 gallons to the ground or any SSO
and/or spill, regardless of volume, that reaches surface waters
[GS 143-215.1C]
The discharge must be reported as soon as practicable but no later than
24 hours after determination that the discharge reached surface waters.
The statute includes additional requirements for public notification of the
discharge based on the volume released.
Releases of hazardous substances in excess of reportable quantities
under Section 311 of the CWA (40 CFR 110.3; 40 CFR 117.3) or sec
102 of CERCLA (40 CFR 302.4) or G.S. 143-215.85
Within 24 hours, an oral or electronic notification must be made. The
notification shall include information about the date, time, nature,
volume, and location of the spill or release.

4.4 MS4 Permit Annual Reporting
As required in Part IV.B of the City’s MS4 permit, the City must submit an annual report to NCDEQ that
tracks the City’s progress in implementing its SWMP. Spills, leaks, connections, and releases that qualify
as an illicit discharge or illicit connection (as defined in Section 1.4) should be included in the annual
report with information about management measures and suggested program improvements. The
Stormwater Management Division tracks this information and submits this report annually.

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Section 5
Annual Document Evaluation
Each year, the City will assess the effectiveness of the PPGH program, including spill response, by
evaluating recorded spills and associated response activities. This evaluation will be used to identify
potential improvements to City procedures and practices.
As part of this internal evaluation, this guidance document and the City’s spill record will be reviewed
annually. Additional meetings with individual City departments will be conducted as needed.
Interdepartmental coordination meetings relating to other parts of the City’s MS4 permit may also be
utilized to review the City’s PPGH practices.
Any changes to this document resulting from annual evaluations will be recorded in an updated version
of this document with the revisions logged in Section 1.2.

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Section 6
References
City of Raleigh NPDES MS4 Permit Number NCS000245, NCDEQ, October 10, 2018 - October 9, 2023.
City of Raleigh Stormwater Management Plan, Permit Number NCS000245. Updated February 2021.
City of Raleigh. Illicit Discharge Ordinance, Municipal Code Chapter 5 Section 13-5007(a).
City of Raleigh, PRCR. Emergency Action Plan Manual. April 2014.
City of Raleigh, PRCR. Emergency Response Guide.
City of Raleigh, PRCR. Pesticide Management Policy (Landscape and Grounds). January 27, 2016.
City of Raleigh, RFD and Operations Division. Fire Department Operational Procedures, No. 1020.5.3 (Hazardous
Materials Team Response Guidelines). Revised October 17, 2017.
City of Raleigh, DPU. Sewer Maintenance DOP Number 002 – Sanitary Overflow Response.
City of Raleigh, DPU. Water Treatment Plan DOP Number 002 – Chemical Leak Response. Effective June 6, 2005.
City of Raleigh, DPU. Water Distribution 600 SOP 5270.0024.628 – Protection of Storm Drains during a Water Asset
Repair/Maintenance Event.
EPA 40 CFR Part 117, Determination of Reportable Quantities for Hazardous Substances, 7-1-11 Edition.
EPA 40 CFR Part 302, Designation, Reportable Quantities, and Notifications, 7-1-11 Edition.
EPA. Consolidated List of Chemicals Subject to EPCRA, CERCLA and Section 112(r) of the CAA, EPA 550-B-20-001.
August 2020. https://www.epa.gov/sites/default/files/2015-03/documents/list_of_lists.pdf
NCDEQ. NPDES General Permit Number NCG080000 (Transit and Transportation). July 1, 2021 – June 30, 2026.
NCDEQ. PowerPoint on “MS4 Pollution Prevention & Good Housekeeping”. March 2021.
http://northcarolina.apwa.net/Content/Chapters/northcarolina.apwa.net/Documents/Powell%20PPGH%202021.pd
f
North Carolina GS § 143-215.1C.
Standard Operating Procedures:
Solid Waste Services. Operational Procedure Number 1: Chemical Spill Reporting and Response Policy.
Stormwater Management Division, SOP SW-100(D): IDDE. Effective date: June 14, 2018.
Stormwater Management Division, SOP SW-102(B): Managing Spills of Materials which Threaten to Enter the Stormwater
Conveyance System. Effective date: July 26, 2018.
Stormwater Management Division, SOP SW-103(B): Outfall Inspections for Illicit Discharge Detection. Effective date:
July 10, 2020.
Stormwater Utility, SOP SW-101(C): Managing Spills of Materials which Threaten to Enter the Stormwater Conveyance
System. Effective date: July 30, 2018.

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Appendix A: Flow Charts

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Appendix A1: Initial Spill Response Activities
Citywide Spill Response Guidance Document A-3 Citywide Spill Response Guidance Document Appendix A2: Spill Reporting Requirements and Expectations Spill Response Roles and Responsibilities Entity Responsibility Initial Responder • Initiates spill response procedures (e.g., supervisor on-staff or member who discovered the spill/leak) Facility or Operations Contact/Supervisor • Provides guidance to the first responder during spill containment • Responsible for assessing the degree of containment of the spill and if the materials entered the stormwater conveyance system • Responsible for facilitating cleanup of the spill by a responsible City entity or a professional environmental clean-up/remediation company • Responsible for notifying the Stormwater Management Division of the spill RFD • First responder for major spills and spills of hazardous substances • In a hazardous material emergency, RFD will assess the degree of hazard and implement appropriate emergency action to contain the spill DPU • Responsible for response, clean-up, and reporting in the event of an SSO. Stormwater Management Division • First responder for minor spills • Second or third responder for large spills • Responsible for determining the responsible party • Assist with assessing the degree of containment of the spill and if the materials entered the stormwater conveyance system • Responsible for reporting spills to NCDEQ and additional parties, as necessary • Provide guidance on clean-up and site remediation