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Home My WebLink About08 - Industrial Facility Inspection Program Plan Industrial Facility Inspection Program Plan City of Raleigh Storwmater Management Divison November 2021 i Table of Contents List of Acronyms ...................................................................................................................... iii List of Definitions ..................................................................................................................... iv 1 Introduction ................................................................................................................... 6 1.1 Purpose of Document .......................................................................................... 6 1.2 Regulatory Context .............................................................................................. 6 1.2.1 NPDES MS4 Permit ................................................................................. 6 1.3 Related Regulatory Programs .............................................................................. 7 1.3.1 Nutrient Sensitive Waters ......................................................................... 7 1.3.2 Total Maximum Daily Loads ...................................................................... 8 2 Organization, Roles, and Responsibilities ................................................................... 8 2.1 City Organization ................................................................................................. 8 2.2 Roles and Responsibilities ................................................................................... 9 2.2.1 Stormwater Management Division ............................................................ 9 2.2.2 Other City Divisions and Departments ...................................................... 9 2.2.3 Non-City Entities ..................................................................................... 10 2.2.4 MS4 Permit Holders Within the City of Raleigh ....................................... 11 3 Industrial Facility Inventory ........................................................................................ 11 3.1 Hazardous Waste Facilities ................................................................................ 11 3.2 SARA Title III Facilities ....................................................................................... 11 3.3 NPDES Industrial Permit Facilities ..................................................................... 11 3.4 Reporting Requirements and Documentation ..................................................... 12 3.5 Available Information and Tools ......................................................................... 12 3.6 MS4 Base Map .................................................................................................. 13 3.7 Stormwater Outfalls ........................................................................................... 13 3.7.1 Analytical Monitoring .............................................................................. 13 3.7.2 Qualitative Monitoring ............................................................................. 14 4 Facility Inspection ....................................................................................................... 14 4.1 Inspection Purpose ............................................................................................ 14 4.2 Inspection Protocols ........................................................................................... 14 4.3 NCDEQ Notification Protocol ............................................................................. 14 4.4 Safety ................................................................................................................ 15 4.5 Documentation and Closeout ............................................................................. 15 5 Training, Education, and Outreach ............................................................................ 16 5.1 SWPPP Training ................................................................................................ 16 5.2 City-wide IDDE and PPGH Training ................................................................... 16 5.3 Stormwater Management Staff ........................................................................... 16 5.4 General Public ................................................................................................... 16 6 Program Evaluation and Reporting ............................................................................ 17 6.1 Effectiveness Evaluation .................................................................................... 17 6.2 Annual Reporting ............................................................................................... 17 7 Revision History .......................................................................................................... 17 8 References ................................................................................................................... 18 ii Figures Figure 1 City of Raleigh Organization .......................................................................................... 8 Figure 2 Stormwater Management Division ................................................................................. 9 Tables Table 1 Summary of EPA-Approved TMDLs or Nutrient Management Strategies ........................ 7 Table 2 Other Responsible City Departments ............................................................................ 10 iii List of Acronyms BMP Best Management Practice City City of Raleigh EPA Environmental Protection Agency ETJ GIS Extra Territorial Jurisdiction Geographic Information System IDDE Illicit Discharge and Detection and Elimination MS4 Municipal Separate Storm Sewer System NCAC North Carolina Administration Code NCDEQ North Carolina Department of Environmental Quality NCDOT North Carolina Department of Transportation NCSU North Carolina State University NOV Notice of Violation NPDES National Pollutant Discharge Elimination System NSW Nutrient Sensitive Waters PPE personal protection equipment PPGH Pollution Prevention and Good Housekeeping RCRA RFD Resource Conservation and Recovery Act Raleigh Fire Department SARA SCM Superfund Amendments and Reauthorization Act of 1986 stormwater control measure SOP standard operating procedure SPCCP SPPP SWMP Spill Prevention, Control, and Countermeasure Plan Site Pollution Prevention Plan Stormwater Management Plan SWPPP Stormwater Pollution Prevention Plan TRI Toxic Release Inventory UDO Unified Development Ordinance iv List of Definitions Illicit Discharge: Any unlawful disposal, placement, emptying, dumping, spillage, leakage, pumping, pouring, emission, or other discharge of any substance other than stormwater into a stormwater conveyance, the waters of the State, or upon the land in such proximity to the same, such that the substance is likely to reach a stormwater conveyance or the waters of the State, as defined in the City of Raleigh Illicit Discharge Ordinance. Illicit Discharge Ordinance: City of Raleigh Unified Development Ordinance (UDO), Chapter 5 Offenses Against the Environment, Section 13-5001, Ordinance No. 1995-573, §2, 3-7-95. Industrial Facility: All permitted 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), No Exposure Certifications issued by NCEDEQ and industrial facilities identified with an industrial activity permitted to discharge storm water to the City of Raleigh’s MS4 identified by NCDEQ and requiring an individual permit. Inspection: Any site visit, scheduled or otherwise, used to investigate or assess compliance with site permits, potential impacts to the City of Raleigh MS4 or natural watercourses, and/or contact with facility staff to provide education, information or guidance pertaining to stormwater management. The two types of inspections are identified as: • Informal Inspection: Inspection of any priority level site and involves inspection for visual evidence of discharges at outfalls from a site. This is done externally from the site, with or without notification of the permit holder. • Full Inspection: Inspection that is focused on all parts of the NPDES MS4 permit-required SWPPP. This is done with the permit holder present and will involve the review of the site layout and preventative plans for spills and containment, training, monitoring, and general housekeeping issues. Full inspections are completed each reporting year for City-owned sites and are typically completed once during each NPDES MS4 permit reporting year for all other sites, excluding No Exposure Certifications. Municipal Separate Storm Sewer System (MS4): As defined by the Illicit Discharge Ordinance, is a stormwater conveyance or unified stormwater conveyance system (including without limitation: roads with drainage systems, municipal streets, catch basins, stormwater detention facilities, curbs, gutters, ditches, natural or man-made channels, or storm drains), that: • Is located within the corporate limits of Raleigh, North Carolina. • Is owned or operated by the State, County, the City, or other public body. • Discharges to waters of the State, excluding publicly owned treatment works, and lawful connections thereto, which in turn discharge into the waters of the State. No Exposure Certification: Issued by NCDEQ to a facility associated with an industrial activity that is not exposed to stormwater. v Outfall: a point source as defined by 40 CFR 122.2 at the point where a municipal separate storm sewer discharges to waters of the United Sates and does not include open conveyances connecting two municipal separate storm sewers, or pipes, tunnels, or other conveyances which connect segments of the same stream or other waters of the United States and are used to convey waters of the United States. Receiving Waters: As defined by the State of North Carolina General Statutes (G.S.) 143-212(6), are surface waters within or flowing through the boundaries of the State of North Carolina including the following: any intermittent or perennial stream, river, creek, brook, swamp, lake, sound, tidal estuary, bay, reservoir, wetland, or any other surface water or any portion thereof that is identified as “Receiving Waters” in the City’s Stormwater Management Plan. Reporting Year: As defined by Stormwater Management staff, the 12-month period between the submittal of the NPDES MS4 Permit Annual Report to NCDEQ and the due date for the next year’s submittal. Historically, this has been October 1st – September 30th of each year. Responsible Party: Party determined as financially culpable, the cause, and/or the source of an illicit discharge. Stormwater Control Measure (SCM): As defined in 15A NCAC 02H .1002, also known as Best Management Practice (BMP), a permanent structural device that is designed, constructed, and maintained to remove pollutants from stormwater runoff by promoting settling or filtration, or mimic the natural hydrologic cycle by promoting infiltration, evapotranspiration, post-filtration discharge, reuse of stormwater, or a combination thereof. Stormwater Conveyance (System): Any feature or system of features, natural or man-made, that collects and transports stormwater, including but not limited to, roads with drainage systems, streets, catch basins, curbs, gutters, ditches, man-made and natural channels, pipes, culverts, and storm drains, and any other natural or man-made feature or structure designed or used for collecting or conveying stormwater, as defined in the City of Raleigh Illicit Discharge Ordinance. Waters of the State: Surface waters within or flowing through the boundaries of the State including the following: any intermittent or perennial stream, river, creek, brook, swamp, lake, sound, tidal estuary, bay, reservoir, wetland, or any other surface water or any portion thereof that is mapped as solid or dashed blue lines on United States Department of the Interior Geological Survey 7.5 minute series topographic maps. Treatment systems, consisting of man-made bodies of water, which were not originally created in waters of the State and which are not the result of impoundment of waters of the State, are not waters of the State, as defined in the City of Raleigh Illicit Discharge Ordinance. 6 1 Introduction The City of Raleigh (City) is identified as the Permittee in National Pollutant Discharge Elimination System (NPDES) MS4 Permit Number NCS000245. The current iteration of this permit became effective October 10, 2018 and extends through October 9, 2023. This permit authorizes the City to discharge stormwater from the City’s MS4 to receiving waters of the State within the Neuse River Basin. The City’s Stormwater Management Plan (SWMP) establishes the methods by which the City implements the permit requirements for complying with six minimum control measures for protecting receiving stream water quality and controlling the discharge of pollutants associated with stormwater runoff and illicit discharges to the extent allowable under State and local law. 1.1 Purpose of Document This document describes the City’s program plan to implement an Industrial Facility Inspection program to evaluate pollutants in stormwater discharges to the permittee’s MS4 from industrial facilities, as defined in 40 CFR 122.26, that the Permitee determines are contributing or have a potential to contribute a substantial pollutant loading to the MS4. In conjunction with this document, the following Standard Operating Procedure (SOP) supports the City’s Industrial Facility Inspection program: • SOP SW-111 Industrial Site Inspection, December 1, 2020 is utilized by Stormwater staff. 1.2 Regulatory Context The following NPDES permit, the Raleigh City Code, and specific State of North Carolina programs provide the regulatory context for the Industrial Facility Inspection Program Plan, prioritization, and implementation requirements. 1.2.1 NPDES MS4 Permit The City’s NPDES MS4 Permit, Part II, Section H (“Program to Monitor and Evaluate Storm Water Discharges to Municipal Systems”), requires the City to: • Evaluate pollutants in stormwater 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 Permitee determines are contributing or have a potential to contribute a substantial pollutant loading to the MS4. • Implement the following BMPs: (a) Maintain an inventory of Industrial Facilities, (b) Identify priorities and inspection procedures as part of an inspection program, (c) Evaluate industrial facilities discharging stormwater to the City’s MS4. The City is authorized to inspect the permitted industrial facilities per the authorization established in NPDES Permit No. NCS000245, effective October 10, 2018 through October 9, 2023 that discharge to the City’s MS4. 7 1.3 Related Regulatory Programs The following restoration strategies have been established in response to assessed impairments of Waters of the State and will be considered in Industrial Facility Inspection Program planning, response, and outreach programs. Table 1 describes a brief overview of these EPA-approved Total Maximum Daily Loads (TMDL) and Nutrient Management Strategies. Table 1 Summary of EPA-Approved TMDLs or Nutrient Management Strategies Water Body Name TMDL Pollutant(s) of Concern Assigned Numeric MS4 WLA (Y/N) Water Quality Recovery Program (Y/N) Pigeon House Branch Copper and Fecal Coliform No No Perry Creek Benthos No No Falls Lake Nitrogen and Phosphorus No City participating in 4B nutrient management strategy Neuse River Estuary Nitrogen No City is implementing the State Nutrient Sensitive Waters Management Strategy 1.3.1 Nutrient Sensitive Waters All waters of the Neuse River Basin are supplementally classified as Nutrient Sensitive Waters (NSW) pursuant to 15A North Carolina Administration Code (NCAC) 02B .0223 due to excess nutrient inputs. The following strategies have been established in response to this classification. Falls Nutrient Strategy The Falls of Neuse reservoir, and all waters draining to it, have been supplementally classified as Nutrient Sensitive Waters (NSW) pursuant to 15A NCAC 02B .0101(e)(3) and 15A NCAC 02B .0223. The Falls Nutrient Strategy classifies the waterbody’s uses and maintains and enhances protections currently implemented by the local governments, including the City of Raleigh. Neuse Nutrient Strategy The Neuse River estuary, ending in the Pamlico Sound, and all water draining to it, have been supplementally classified as NSW pursuant to 15A NCAC 02B .0223. The Rule and Rules 15A NCAC 02B .0711 and .0715 were established to attain designated uses of the Neuse River estuary with respect to meeting nutrient-related water quality standards. The Neuse nutrient strategy rules require controls to reduce nitrogen loads from significant sources of this nutrient throughout the Neuse Basin. These rules do not address sources for which there is insufficient scientific knowledge to base regulation. Additional information is provided in Sections 2.5 and 8 of the SWMP. 8 1.3.2 Total Maximum Daily Loads The EPA has identified two TMDLs in the Upper Neuse River Basin within the City’s MS4 as part of the assessment performed and presented in the Section 303(d) list of impaired waters, according to their priority ranking. These TMDLs are briefly described below: Pigeon House Branch On the draft 2002 North Carolina Integrated Report, the NCDEQ identified a 2.9-mile segment (27-33- 18) of Pigeon House Branch in the Neuse Basin as impaired by fecal coliform bacteria and copper. The impaired segment extends from the stream’s source to its confluence with Crabtree Creek, and was monitored at the station along Dortch Street near Wade Ave. Perry Creek The NCDEQ established a TMDL to address impaired biological integrity in the Perry Creek Watershed on May 13, 2010, with the goal to improve the watershed ecosystem through stormwater BMPs and restore the beneficial uses of the waterbody. The TMDL applies to the entire Perry Creek watershed that comprises a drainage area of 11 square miles. Based on a weight of evidence analysis for the Perry Creek watershed, the two most important factors contributing to impairment are scour and habitat degradation. Additional information is provided in Section 2.5 SWMP and the EPA-approved TMDL(s). 2 Organization, Roles, and Responsibilities 2.1 City Organization The organizational structure of the City includes a governing body, City Manager, and multiple City departments, all of which are supported by the City Attorney’s Office, organized as shown in Figure 1 Figure 1 City of Raleigh Organization 9 2.2 Roles and Responsibilities The Stormwater Management Division implements the Industrial Facility Inspection Program which includes both City -owned and privately-owned facilities. While the Stormwater Division does not operate an industrial facility, several other City departments have roles and responsibilities and manage Industrial facilities. 2.2.1 Stormwater Management Division The Stormwater Management Division, housed within the Engineering Services Department, is responsible for NPDES MS4 permit compliance, implementation of the Industrial Facility Inspection Program and proper notification of NCDEQ upon observation of potential compliance issues. The Stormwater Management Division includes programs and staff that support a wide range of stormwater initiatives, including plan review and active construction inspection, stormwater fee billing, asset management, drainage and water quality CIP project management, public education and outreach, SCM inspection, and water quality. Specifically, the Water Quality Section staff is responsible for implementing the Industrial Facility Inspection Program, which includes facility inspection, investigation of complaints, coordination and notification of NCDEQ staff, and outreach and assistance for City-owned industrial permit holders and their staff. Figure 2 Stormwater Management Division 2.2.2 Other City Divisions and Departments Several City departments play a role in the Industrial Facility Inspection Program. Raleigh Fire Department (RFD) act as first responders and provide HAZMAT response capabilities in the event of an emergency at any industrial facility. RFD staff typically secure the scene and assist responsible parties with containing a spill until a remediation contractor can begin clean-up. 10 In addition, there are nine (9) City-owned facilities that have NPDES industrial permits due to the operations that are performed on site. A site-specific Stormwater Pollution Prevention Plan (SWPPP) has been developed and implemented at each facility. Staff at each respective facility is required to complete training annually on their SWPPP and implement both required and preventive measures to prevent impacts to stormwater runoff. Furthermore, the City has a Citywide Spill Response Guidance document that applies to all City departments. See Table 2 for a summary of all City Industrial permit holders and facility information. Table 2 Other Responsible City Departments City Department Permit Number Facility Name Engineering Services NCG080932 Downtown Remote Operations Facility Go Raleigh NCG080929 Paratransit Operations Facility Go Raleigh NCG080874 Transit Operations Facility Public Utilities1 NCG110001 Neuse River Resource Recovery Facility Public Utilities1 NCG110006 Smith Creek WWTP Public Utilities1 NCG110049 Little Creek WWTP Solid Waste Services NCG080886 Wilders Grove Service Center Solid Waste Services NCG240012 Yard Waste Center Engineering Services Pending Northeast Remote Operations Facility 1. These facilities are located outside the City’s MS4, are covered under this Industrial Facility Inspection Program Plan but are not inspected for NPDES MS4 compliance. 2.2.3 Non-City Entities North Carolina Department of Environmental Quality (NCDEQ) is the permitting and enforcement authority for NPDES Industrial permit facilities and holders. City staff will regularly coordin ate and assist NCDEQ staff with permit renewals, compliance investigations and site inspections. See Section 4.4 for additional information on reporting. 11 2.2.4 MS4 Permit Holders Within the City of Raleigh The City’s MS4 is interconnected with two regulated MS4s and both accepts and conveys stormwater runoff to and from the North Carolina Department of Transportation (NCDOT) and North Carolina State University (NCSU) storm sewer systems, as determined by the City’s storm sewer system conveyance data. There are multiple points of interconnection between the City and NCDOT, at the edge of the roadway rights-of-way, and the City and NCSU at the property boundaries within the City’s corporate limit. All industrial facilities within either of these MS4s are the responsibility of the respective permit holder and City staff do not inspect any industrial facilities that are located within either of these two regulated MS4s. 3 Industrial Facility Inventory Point source stormwater discharges associated with industrial activities are regulated under the federal NPDES Stormwater Program and are defined in federal regulations 40 CFR §122.26(b)(14)(i)-(xi). These industrial facilities are characterized either by a Standard Industrial Classification (SIC) code or a narrative description to characterize the activities. City staff maintain an inventory of industrial facilities and facilitate annual updates of this inventory at the beginning of each NPDES reporting year. The following section discusses the details of the City’s Industrial Facility Inventory of permitted hazardous waste treatment, disposal and recovery facilities, SARA industrial facilities, and NPDES permitted industrial facilities authorized to discharge storm water to the City’s MS4. Additionally, this section presents details on no exposure certificate holders, and the reporting requirements to maintain the City’s permit. 3.1 Hazardous Waste Facilities Hazardous waste treatment, disposal and recovery facilities are identified using the Environmental Protection Agency’s website Resource Conservation and Recovery Act (RCRA) Info Search Tool: https://enviro.epa.gov/facts/rcrainfo/search.html. Staff add active sites and remove inactive sites annually throughout the reporting year. 3.2 SARA Title III Facilities Industrial facilities subject to Section 313 of Title III of the SARA are identified using the Environmental Protection Agency’s website Toxic Release Inventory (TRI) Search Tool: https://www.epa.gov/toxics- release-inventory-tri-program#trisearch. Staff add active sites and remove inactive sites annually and as staff become aware throughout the reporting year. 3.3 NPDES Industrial Permit Facilities Industrial permitted facilities that discharge to the City’s MS4 are identified by contacting NCDEQ and requesting a list of permitted facilities located within the City, or accessing the NCDEQ Laserfiche Weblink for Active Industrial Permit List for both General Permit and Individual Permits: https://edocs.deq.nc.gov/WaterResources/Welcome.aspx?dbid=0&repo=WaterResources 12 Staff add active facilities and remove inactive facilities annually and as staff become aware throughout the reporting year. Facilities with stormwater discharges associated with industrial activity that are excluded from permit coverage if industrial materials and operations are not exposed to stormwater possess a no exposure certification. The facility must maintain this condition of No Exposure in accordance with the NCDEQ Self- Recertification Process to qualify for the permitting exclusion. Industrial discharges associated with the two regulated MS4s that convey discharges and flows from the North Carolina Department of Transportation (NCDOT) and North Carolina State University (NCSU) storm sewer systems are not inspected by the City as they are not a part of the City’s jurisdictional boundary and are regulated under their respective MS4 permit. 3.4 Reporting Requirements and Documentation Per the Phase I NPDES MS4 that the City operates under, it is required that the City retain records of all inspection information, including calibration and maintenance documents, and all copies of reports for a period of at least five years from the date of the sample, measurement, report, or application. The City shall document the date of inspection, and details describing the state of the facility’s operation and discharges observed during the inspection. The City responds with a summary email to the industrial facility’s representative expressing the deficiencies and recommendations and allowing the opportunity for feedback. If, in the event of clear violations of their stormwater permit, or deficiencies requiring State of North Carolina notice, the City will forward information to the NCDEQ Industrial Stormwater Program representative and defer to the State for follow-up and enforcement action as necessary. As the inspection is completed, all investigation photos, notes, correspondence, and official documents are uploaded to the City’s CityWorks database and are georeferenced by location of the incident. Supplemental reporting tools including Crystal Report and Microsoft Power BI are also utilized with this data to produce reports for tracking, inspection prioritization and outreach efforts. 3.5 Available Information and Tools Various information and tools are utilized from the State, County and City to support City staff during inspections. These include: • MS4 Geospatial Data incorporated into various mapping tools that include iMaps PUMA, ESRI GIS software and other GIS platforms. • North Carolina State Surface Water Classification Map that identifies all blue-line waterways within the State. • 303(d) list of waters that exceed water quality criteria • USGS Hydrologic Unit Maps • State of North Carolina Active Stormwater Permit Map 13 3.6 MS4 Base Map In fiscal year 2014, the City initiated an MS4 mapping program which compiled and documented all known MS4 infrastructure and outfalls within the City’s corporate limits and extra territorial jurisdiction (ETJ) in a geographic information system (GIS). Since this initial effort, the City has continually updated the MS4 mapping, which includes pipes, ditches, inlets, catch basins, culverts, headwalls, channels, manholes, and outfalls, including sizes and inverts. The MS4 mapping updates are incorporated into the illicit discharge detection and elimination program, which is described in Section 6 of the SWMP. This geospatial data is utilized by City stormwater staff to support their Industrial program inspections and is utilized as a tool for communication and direction to other agencies, contractors and representatives. The condition of the MS4 stormwater inlets and conveyance system are evaluated by the City storm sewer system inspection and maintenance program on a regular basis. 3.7 Stormwater Outfalls An Outfall means a point source as defined by 40 CFR 122.2 at the point where a municipal separate storm sewer discharges to waters of the United Sates and does not include open conveyances connecting two municipal separate storm sewers, or pipes, tunnels, or other conveyances which connect segments of the same stream or other waters of the United States and are used to convey waters of the United States. As part of the Industrial facility inventory annual update, identified industrial facilities that do not have outfalls and do not discharge stormwater are not included in the inspection inventory and would not require an NPDES Industrial Permit. All other industrial facilities should have listed stormwater and wastewater discharge outfalls, and have identified on-site and adjacent surface waters, wetlands, and industrial activity areas, per their NPDES permit requirements. These discharge outfalls are subject to monitoring, controls and limitations for their permitted discharges depending on the individual or general NPDES permit requirements. 3.7.1 Analytical Monitoring Analytical monitoring is performed per the individual or general NPDES permit requirements at outfalls associated with industrial activity only. Each permit establishes quantitative benchmark values and/or ranges for individual parameters that trigger additional monitoring requirements if exceeded, follow up actions, or increased sampling frequency. Limitations and exemptions can exist depending for each individual or general NPDES permit requirements. Analytical monitoring requirements for stormwater discharges from the permitted site’s outfalls are subject to analytical suites related to the facility’s operations. All monitoring and sampling is performed by the facility representatives. City staff will perform duplicate monitoring as needed to confirm analytical data records provided by the Permitee are representative and complete. If a facility is required to sample multiple discharge locations with very similar stormwater discharges, the permittee may petition NCDEQ for representative outfall status. Approved representative outfall status 14 will reduce the number of outfalls where analytical sampling requirements apply. If Representative Outfall Status is granted, all outfalls are still subject to the qualitative monitoring requirements of the facility’s permit, unless otherwise allowed. 3.7.2 Qualitative Monitoring Qualitative monitoring is performed to evaluate the effectiveness of the permittee’s stormwater pollution prevention plan and to identify the potential for new sources of stormwater pollution. This monitoring approach is performed by the facility representatives and typically involves a visual inspection of each stormwater outfall during routine facility inspections. Requirements of the qualitative monitoring are specified in each individual or general NPDES permit and SWPPP. 4 Facility Inspection The following section discusses the purpose of Industrial facility inspections and how the inspections are scheduled, completed, and documented. 4.1 Inspection Purpose The Industrial Facility Inspections are required to comply with the City’s current NPDES Permit No. NCS000245, Section H, Program to monitor and evaluate stormwater discharges into municipal systems. 4.2 Inspection Protocols The COR is required to inspect all Industrial Facilities, as defined by the Industrial Site Inspection SOP SW-111 Industrial Site Inspection v1.3, Section 4 Definitions. Staff are to conduct full inspections at each City-owned industrial facility once every reporting year, and typically all other industrial facilities excluding no exposure certifications, each reporting year. Staff will conduct an informal inspection at all no exposure certificate sites once per NPDES permit cycle. Staff conduct informal inspections at a site as needed to respond to inquiries, complaints, and/or for investigations. NCDEQ coordination may be necessary if further inspection or enforcement actions is necessary. Staff initiates contact with the site staff prior to arrival of an upcoming inspection. Once staff arrive on site, City staff make contact with a site representative, discuss safety requirements, and outline the inspection process, including the defining of City and NCDEQ involvement and roles regarding inspections and enforcement jurisdiction. As part of the inspection, staff review the SWPPP and site map, inspect all outfalls for any signs of sheen, discoloration, water column separation, dead biotics, etc. Staff identifies and inspect all stormwater control measures (SCM) and potential pollutant sources at the facility. Once the site inspection complete, staff discusses their findings with the site contact and explains that any deficiencies will be reported to NCDEQ for their review and appropriate follow-up. 4.3 NCDEQ Notification Protocol For permitted facilities, the City has established procedures for reporting deficiencies and non- compliance to the NCDEQ. The City’s notifies NCDEQ via phone or email if any of the following apply: • There is any evidence of non-permitted industrial discharges. 15 • A potential permit violation involving non-compliance with the permit or SWPPP is observed. • The SWPPP is not present on site. • The NPDES permit for the site has expired and is not pending renewal, or no exposure exemption has not been given. • Site Activity has changed and is no longer covered under the existing permit. • Observed or recorded analytical monitoring exceedances • Ownership or responsible party has changed and has not been updated with the NCDEQ. NCDEQ notification and correspondence is saved electronically using the Cityworks Application. 4.4 Safety City staff will be prepared to follow all safety instructions and requirements by the industrial facility’s safety program and any site-specific requirements for each facility. Personal protection equipment (PPE) including safety vests, safety shoes/boots and eye protection should be used as the situation requires. PPE should be used by staff when performing and inspection within the right-of-way (ROW), construction sites, industrial operations, or any other situations where staff deems it is necessary. Staff should utilize the vehicle’s emergency lights, park in a location that does not interfere with the facility’s operations, and in a location does not impede the flow of traffic. 4.5 Documentation and Closeout Per the City’s NPDES MS4 permit, it is required that the City retain records of all monitoring information, including all calibration and maintenance records and all copies of reports for a period of at least five years from the date of the sample, measurement, report, or application. The City documents the date of the inspection and any deficiencies and recommendations identified. The City responds with a summary email to the industrial facility’s representative expressing the deficiencies and recommendations and allowing the opportunity for feedback. If, in the event of clear violations of their stormwater permit, or deficiencies requiring State of North Carolina notice, the City will forward information to the NCDEQ Industrial Stormwater Program representative and defer to the State. As the inspection is completed, all investigation photos, notes, correspondence, and official documents are uploaded to the City’s CityWorks database and are georeferenced by location of the incident. Supplemental reporting tools including Crystal Report and Microsoft Power BI are also utilized with this data to produce reports and for tracking. 16 5 Training, Education, and Outreach 5.1 SWPPP Training Each Industrial permit holder, as a requirement of their permit, have a SWPPP which describes annual training requirements and documentation requirements. It is the responsibility of each permittee to complete this permit requirement and document training topics and attendees as part of their SWPPP implementation. City-owned Industrial facility staff meet with Stormwater staff annually to discuss site conditions, SWPPP implementation, and best management practices. City-owned industrial facilities utilize a range of training mechanisms, ranging from informal team trainings to consultant-led annual training events. 5.2 City-wide IDDE and PPGH Training City-wide IDDE training is provided to all City employees, while PPGH training is assigned to staff that work at a facility or conduct an operation that has potential to impact stormwater runoff. While not directly related to the Industrial permit, IDDE and PPGH awareness is relevant to these facilities and operations. Both modules are assigned to City staff via the iLearn training platform, a web-based platform that allows employees to complete the training remotely, track completion status, notify the supervisor of their employees’ training status, and generate weekly reports for Stormwater staff and reporting requirements. IDDE training is part of the City’s new-hire, on-boarding process, which is implemented by the Human Resources Department. All new employees are assigned this training and must complete it to clear the required orientation process. PPGH training is assigned by each department to relevant staff. Both modules are then assigned to staff on a three-year cycle via the City’s iLearn internal/on-line training platform. Staff and their supervisors are notified of the upcoming required trainings and/or failure to complete the trainings as assigned. Stormwater staff also provide In-person training upon request. Stormwater staff coordinate with department staff to assist with the training implementation and ensure that all employees have access to the training. 5.3 Stormwater Management Staff Water Quality staff are trained in multiple disciplines that span a wide range of stormwater topics. Specific to industrial stormwater discharges, IDDE, staff mentorship and internal instruction on NPDES permit and SWMP requirements is required and reinforced through regular duties and during program assessment. Most Water Quality staff that respond to ID complainants have completed the 40-HR HAZWOPER certification and regularly attend informational webinars for topics specific to stormwater.. 5.4 General Public Stormwater Quality Section staff regularly work with Communications staff to identify pollutant sources that are routinely identified through IDDE investigation and enforcement and Industrial Facility inspections. This coordination allows for City staff to determine target audiences and an appropriate media to conduct occasional pollutant-specific public outreach efforts. Information is disseminated via multiple platforms including, but not limited to, the website, print material, social media and email marketing. Additional detail and references are included in the Education and Outreach Program Plan and the City-wide Spill Response Guidance Document. 17 6 Program Evaluation and Reporting The Stormwater Management Division uses several mechanisms to evaluate and track the Industrial Facility Inspection Program effectiveness, including annual inspection reporting, regular review of existing plans and SOPs, tracking of enforcement actions, and tracking of pollutant sources. 6.1 Effectiveness Evaluation Water Quality staff conduct annual review meetings at the beginning of each NPDES MS4 permit reporting year. All staff involved in implementing the Industrial Facility Inspection Program attend, and the meeting agenda includes evaluation of current practices and recommendations for program improvement. Any necessary updates to program metrics, goals, and other processes associated with the Industrial Facility Inspection Program are reported to the Water Quality Manager who updates the City’s Stormwater Management Plan (SWMP) accordingly. Any updates or changes made to the SWMP are documented in the City’s NPDES MS4 Permit Annual Report, which is submitted to NCDEQ. 6.2 Annual Reporting City staff refer to the current SWMP to identify annual reporting metrics, track these metrics throughout the year, and report these metrics to the Water Quality Manager at the end of the reporting year to include in the NPDES MS4 permit annual report to NCDEQ. 7 Revision History Revision date Details 18 8 References City of Raleigh, 2021. The City Code. September 10, 2021. https://library.municode.com/nc/raleigh/codes/code_of_ordinances City of Raleigh, 2021. City of Raleigh City-Wide Spill Response Guidance Document. December 2021. City of Raleigh 2021. City of Raleigh Illicit Discharge Detection and Elimination Plan. November 2021. City of Raleigh, 2021. City of Raleigh Stormwater Management Plan. June 2021. City of Raleigh, 2021. City of Raleigh Pollution Prevention and Good Housekeeping Plan. December 2021. City of Raleigh, 2020. Stormwater Education and Outreach Plan. August 2021. City of Raleigh, 2012. SW-101 Managing Spills Which Threaten to Enter the Stormwater Conveyance System. Standard Procedure, amended May 4, 2020. City of Raleigh, 2020. SW-111 Industrial Site Inspection. Standard Procedure amended December 1, 2020. NCDEQ, 2010. Total Maximum Daily Load to Address Impaired Biological Integrity in the Perry Creek Watershed, Neuse River Basin. EPA approved May 13, 2010. NCDEQ, 2003. Total Maximum Daily Loads for Fecal Coliform Bacteria and for Copper to Pigeon House Branch, North Carolina. EPA approved June 2003.