19 - SW-121 Pollution Prevention and Good Housekeeping Site Inspection SOP SW-121

STANDARD PROCEDURE
CITY OF RALEIGH, N.C.
MANUAL

STORMWATER MANAGEMENT DIVISION
SUBJECT

POLLUTION PREVENTION AND
GOOD HOUSEKEEPING SITE
INSPECTION

NUMBER

SW-121
REV

1.1
EFFECTIVE DATE

1/1/2021
PAGE OF

1 7
SUPERCEDES

1.0
PREPARED BY
D. Kirsch
Water Quality Technician
APPROVED BY
J. Harcum
Project Engineer I

1.0 Purpose:

Pollution prevention and good housekeeping (PPGH) site inspections are required to
comply with the City’s current NPDES Permit No. NCS000245, Section G, Pollution
prevention and good housekeeping for municipal operations within the City limits.

2.0 Organizations Involved

Engineering Services, Stormwater Division, Water Quality Section and portions
of all City-wide Departments

3.0 References:
NCDEQ NPDES Permit # NCS000245, Section G

4.0 Definitions:

4.1 high priority site

Site where material or operations are exposed or potentially exposed to stormwater with a
high risk of impacting stormwater if not properly managed.

4.2 low priority site

Site where material or operations are exposed, or potentially exposed to stormwater, with
a minimal risk of impacting stormwater if not properly managed.

4.3 PPGH Inventory

List of City-owned properties, leased properties and properties where City activity and
operations are taking place are exposed to stormwater and have potential to impact water
quality.

4.4 PPGH Operations Inventory

List of operations performed by city staff that have potential to impact water quality.

4.5 no exposure site

Site where staff has determined that there is no potential to impact stormwater

4.6 outfall
CITY OF RALEIGH, N.C.
SUBJECT
POLLUTION PREVENTION AND GOOD
HOUSEKEEPING SITE INSPECTION

NUMBER

SW-121
REV

1.1
EFFECTIVE DATE

1.1.2021
PAGE OF
2 7

Location where stormwater runoff leaves a site. This may include, but is not limited to,
drop inlets, curb inlets, swales, ditches, stormwater conveyances, or natural watercourses.

4.7 permit

NCDEQ NPDES Permit # NCS000245

4.8 site

An identified property or facility that has been added to the PPGH Inventory, has
potential to impact stormwater runoff and requires inspection and/or regular assessment.

4.9 Site Pollution Prevent Plan (SPPP)

A site management plan required by Section G, 2(c) of the permit, which is not required
by a separate NPDES Industrial permit.

4.10 Stormwater Pollution Prevention Plan (SWPPP)

A site management plan required by a separate NPDES Industrial permit and used to
meet requirements defined in Section G, 2 (c) of the permit.

5.0 PPGH Inventory

5.1 The PPGH inventory is maintained through ESRI platform, using Survey123
to add and remove sites and ArcGIS Online to manage dataset attributes. This
dataset then serves as the layer used to populate and implement the inspection
application with Cityworks.

5.2 Sites are added and removed from the inventory when staff is made aware of
new projects completed, property sold, or the site’s potential to impact stormwater
changes. Attribute fields are updated by staff after site inspections if site contact,
property attributes or locations change.

5.2.1 To facilitate Stormwater staff awareness of new facilities and
operations, an annual email should be sent to pertinent City staff across
departments requesting information on any new facility or operation at the
beginning of each reporting year. This email will include contacts within,
but is not limited to, Public Utilities, Solid Waste Services, Engineering
Services, Transportation and Real Estate. New facilities and operations
will be added to the inventory.

6.0 Site prioritization

CITY OF RALEIGH, N.C.
SUBJECT
POLLUTION PREVENTION AND GOOD
HOUSEKEEPING SITE INSPECTION

NUMBER

SW-121
REV

1.1
EFFECTIVE DATE

1.1.2021
PAGE OF
3 7

Staff uses a list of criteria to prioritize sites in the PPGH inventory based on
potential to impact stormwater. A site can be categorized as either a high priority,
low priority or no exposure site. Sites that are located outside of the City limits
are not subject to inspection through this program.

6.1 High priority sites

If staff determines a site has a high potential to impact stormwater, or the site has
a separate NPDES industrial permit, or the site has any of the following
operations occurring on the premises, or any of these specific features located at
the site, the site can be prioritized as a high priority site based on staff discretion:

1. Vehicle or equipment washing operation or facility
2. Vehicle repair or maintenance
3. Vehicle fueling station or fuel point
4. Pool or aquatic center
5. Boat house that services or houses gasoline motors
6. Brine or salt storage
7. Stockpiles

6.2 Low priority sites
If staff determines that the site has minimal potential to impact stormwater and
does not meet any of the criteria defined in 6.1, the site is prioritized as a low
priority site.

6.3 No exposure sites
If staff determines that a site currently has no potential to impact stormwater and
does not meet the threshold of being prioritized as a low priority site, the site will
be a no exposure site.

7.0 Inspection Frequency

7.1 Staff will inspect the sites in the PPGH inventory to assess whether adequate
management practices are implemented to reduce the potential for stormwater
impact, changes at the site that influences the potential to impact stormwater, and
to educate and provide guidance to site staff. Inspection frequency will be based
on site prioritization as follows:

High priority sites Annually
Low Priority sites Twice during permit cycle
No exposure sites Once during permit cycle

7.2 City-owned sites that operate under a separate NPDES Industrial permit will
be inspected annually through the Industrial Inspections Program, referenced in
City of Raleigh Industrial Inspection SOP SW-111.

CITY OF RALEIGH, N.C.
SUBJECT
POLLUTION PREVENTION AND GOOD
HOUSEKEEPING SITE INSPECTION

NUMBER

SW-121
REV

1.1
EFFECTIVE DATE

1.1.2021
PAGE OF
4 7

8.0 Site Inspection Procedures

8.1 Inspection Procedure

1. Locate site and gather information from PPGH Inventory.
2. Contact City staff or site representative if necessary.
3. Determine if site is a no exposure site and update PPGH Inventory
accordingly.
4. Determine if site has a NPDES Industrial Permit and has been
inspected within the last 12 months by Stormwater staff. If yes, the
site inspection is complete. If no, complete the remainder of the
inspection procedure.
5. Inspect all parking lots at the site and determine if City-owned
vehicles are stored at any location. Inspect site for:
a. debris in curbline and parking lot
b. evidence current and past of spills on asphalt and parking areas
c. active or evidence of dripping fluids from parked vehicles
6. Locate and inspect all dumpsters at the site for:
a. covered when not in use
b. capped to prevent discharge from inside the unit
7. Identify site drainage areas and outfalls visually using GIS data, site
maps or records provided from previous visits and inspect site outfalls
for:
a. any discoloration
b. sheen
c. need for maintenance
d. evidence of current or past contamination (e.g. water column
separation, dead biotics, etc.)
8. Determine if chemicals, pesticides, herbicides and/or fertilizer is used
or stored at the site. If confirmed, inspect for:
a. proper storage (e.g. under cover, off the ground)
b. sufficient measures present to prevent chemicals from coming in
contact during storage and use
c. proper disposal per product labels
d. existence and implementation of a pesticide, herbicide and
fertilizer application plan
e. evidence of regular training for chemical applicators and users
9. If site is a fire station, inspect for:
a. whether the site is exempt by the NPDES permit (3 or less fire
trucks) from vehicle washing requirements. Ensure best
management practices are being used when possible. If more than
three trucks, ensure vehicles are washed so that wastewater does
not have potential to impact stormwater runoff.
10. If site has is vehicle maintenance and/or fueling point inspect for:
a. properly located and stock spill kit
b. proper storage of used oil
CITY OF RALEIGH, N.C.
SUBJECT
POLLUTION PREVENTION AND GOOD
HOUSEKEEPING SITE INSPECTION

NUMBER

SW-121
REV

1.1
EFFECTIVE DATE

1.1.2021
PAGE OF
5 7

c. the presence of oil/water separators with maintenance records
d. that street sweepers, trash trucks and other vehicles/equipment
washed without impacting stormwater runoff
e. proper chemical storage and disposal
f. spill SOP unique to the site
11. If site has a pool, inspect for:
a. confirmation that pool backwash discharges to sanitary sewer or
have and regularly implements a dichlorination procedure prior to
discharge. Records of dichlorination should be reviewed.
b. proper chemical storage and disposal.
12. If site is a park, inspect for:
a. maintained and covered trash receptacles.
b. pet waste disposal stations with equipped bags and signage.
c. proper maintenance of all stormwater control measures throughout
the site (e.g. SCMs, stream buffers, stormwater conveyances).
d. opportunity to incorporate a vegetated buffer along any natural
watercourse through the site.
13. If site is a laydown/storage yard, inspect for:
a. debris, sediment or waste material in parking lots
b. presence of spill kits
c. proper containment of stockpiles to limit impact to surface runoff
d. best management practices throughout the site to protect storm
drains, inlets and natural watercourses (e.g. vegetated buffers,
secondary containment, inlet protection, construction entrance,
etc.).
14. If site has a generator, inspect for:
a. secondary containment and/or measures to prevent impact to
stormwater runoff
15. Determine if the site has a SPPP and if so, inspect for:
a. current and accurate information or updates needed
b. documentation of BMPs
c. necessary SPPP updates and changes
16. Identify if site requires a SPPP/SWPPP developed if one is not already
present.
17. Document observations and findings through Cityworks Application.

8.2 Site Deficiency Notification Procedure

1. Notify site contact listed in PPGH Inventory of deficiency and permit
requirements.
2. Provide guidance and information on best management practices or
remediation needed to address deficiencies.
3. Complete a follow-up site inspection to confirm deficiency has been
remediated.

9.0 No Exposure Sites
CITY OF RALEIGH, N.C.
SUBJECT
POLLUTION PREVENTION AND GOOD
HOUSEKEEPING SITE INSPECTION

NUMBER

SW-121
REV

1.1
EFFECTIVE DATE

1.1.2021
PAGE OF
6 7

9.1 Sites identified during inspection as no exposure sites will be inspected once
every permit cycle to document site changes or new potential to impact
stormwater runoff.

10.0 Stormwater Pollution Prevention Plans (SWPPP)
10.1 All City-owned sites that operate under a separate NPDES Industrial permit
are required to have, implement and maintain a SWPPP. See City of Raleigh
Industrial Inspection SOP SW-111 for inspection requirements.

11.0 Site Pollution Prevention Plan (SPPP)

11.1 All sites identified as high priority will develop, implement and maintain a
SPPP that should include:

a. Narrative describing site activities and target pollutants
b. Site plan showing outfalls
c. Description of Best Management Practices (BMP)
d. Record of spills that have occurred at the site during the permit
period
e. Spill Prevention/Response Plan
f. Employee training
g. Facility inspection records

Stormwater and site staff can determine if any of these components should not be
included or if additional components are needed to adequately manage the site.

11.2 If a site inspection reveals that a SWPPP or SPPP is needed, staff will notify
the appropriate staff contact that the site requires a SWPPP or SPPP. Staff will
provide templates, resources and guidance to assist in SWPPP or SPPP
development and implementation.

12.0 Record keeping

12.1 Inspection reports will be saved electronically utilizing scanned or
electronically generated inspection forms from the Cityworks Application.

12.2 Site information, site contact information, site features and comments will be
regularly updated in the PPGH Inventory.

13.0 Annual Review

13.1 Staff will conduct an annual review meeting at the beginning of each NPDES
MS4 Annual reporting year. All staff involved in implementing the Industrial
Inspection Program will be involved and the meeting agenda will include
evaluation of current practices and recommendations for program improvement.
CITY OF RALEIGH, N.C.
SUBJECT
POLLUTION PREVENTION AND GOOD
HOUSEKEEPING SITE INSPECTION

NUMBER

SW-121
REV

1.1
EFFECTIVE DATE

1.1.2021
PAGE OF
7 7

14.0 Revision History

Revision Date Description of changes Requested by
n/a 7/22/2020 Initial SOP Development Justin Harcum
1.1 1/1/2021 Added site prioritization, inspection
frequency & SPPP implementation
Justin Harcum