H3 - Stormwater Inspection Program Guidelines Mar 2022 (signed)

Description, Guidelines, and Procedures
for the Stormwater Inspections Program
CITY OF
DURHAM
City of Durham, North Carolina
Department of Public Works
Stormwater and GIS Services
Water Quality Unit
March 2022
Reviewed by: Date:
Michelle Woolfolk, Water Quality Manager
M a r 24, 2022
1

TABLE OF CONTENTS
Preface............................................................................................................................................ 1
City Authority to Conduct Stormwater Inspections of Industrial Activities ................................... 2
StateLaw..................................................................................................................................... 2
CityOrdinance............................................................................................................................. 2
Inspecting NPDES-Permitted Facilities........................................................................................ 4
What Types of Operations Do We Inspect?.................................................................................... 4
What is an "industrial" operation?............................................................................................. 5
NPDES Stormwater Permits for Industrial Activities.................................................................. 8
Which agency assigns permits in North Carolina?.................................................................. 8
GeneralPermits...................................................................................................................... 8
IndividualPermits................................................................................................................... 9
No Exposure Certification....................................................................................................... 9
How Does the City Identify Industrial Facilities?..........................................................................
10
City MS4 Permit Requirement..................................................................................................
10
Generally...................................................................................................................................
10
Identifying NPDES Stormwater Permitted Facilities.................................................................
10
Identifying Permitted Hazardous Waste Treatment, Disposal, and Recovery Facilities..........
11
Identifying Facilities Subject to Section 313 of SARA Title III ...................................................
12
Identifying Municipal Facilities Requiring Inspection...............................................................
14
Cleaning of Municipal Equipment and Vehicles...................................................................
14
CityJurisdictional Limits............................................................................................................
15
How are Industrial Facilities Inventoried?....................................................................................
15
Prioritizing Facility Inspections.....................................................................................................
16
Private Facility Priority System.................................................................................................
17
Municipal Facility Priority System.............................................................................................
19
Contract -Operated Facilities.....................................................................................................
21
Overview of the Inspection Process.............................................................................................
22
Pre -Inspection Tasks & Matters....................................................................................................
23
SchedulingInspections.............................................................................................................
23
0)

SpotInspections....................................................................................................................
23
Inspections Scheduled in Advance........................................................................................
23
ReviewFacility History..............................................................................................................
24
Gather Equipment and Supplies...............................................................................................
24
Assess Safety Concerns.............................................................................................................
24
Personal Protective Equipment................................................................................................
25
Injury Response and Reporting.................................................................................................
25
Entryonto Premises..................................................................................................................
26
Evidence of a violation in plain view.....................................................................................
26
Consent to enter premises...................................................................................................
27
Conductingthe Inspection............................................................................................................
28
Interacting with Facility Representatives.................................................................................
28
Care and Control of Evidence...................................................................................................
28
Routine Periodic Inspection Form............................................................................................
28
FormSetup............................................................................................................................
29
HeaderInformation..............................................................................................................
29
Illicit Discharges & Connections............................................................................................
30
GeneralSite Condition..........................................................................................................
33
Pollutant, Container, and Tank Management......................................................................
33
AutomotiveActivities............................................................................................................
35
SpillResponse.......................................................................................................................
35
Trash and Solid Waste Management....................................................................................
36
Other Best Management Practices.......................................................................................
37
NPDES Stormwater Permit....................................................................................................
38
Stormwater Pollution Prevention Plan.................................................................................
38
Stormwater Runoff Monitoring............................................................................................
42
Quarterly Facility Self-Inspections........................................................................................
46
Annual Employee Training....................................................................................................
47
AdditionalComments...........................................................................................................
47
3

Resultsand Signature...........................................................................................................
47
Photographs..............................................................................................................................
48
Review Results with Responsible Party....................................................................................
49
Public Works Server Inspections Data Storage.............................................................................
50
Private Facility Data Storage.....................................................................................................
50
Municipal Facility Data Storage................................................................................................
50
Enter Inspection Results Into Database........................................................................................
51
Issue Notice of Compliance, Requirement, or Violation..............................................................
51
Return for Follow-up Inspection...................................................................................................
51
CityCode Violations......................................................................................................................
52
CitableViolations......................................................................................................................
52
SpillReporting...............................................................................................................................
53
Reporting Major Spills to State Regulators, Generally.............................................................
53
Reporting Spills of Hazardous Substances to State Regulators ................................................
53
Reporting Petroleum Spills to State Regulators.......................................................................
54
InspectionField Audits..................................................................................................................
55
C!

PREFACE
This document describes how the City of Durham Stormwater Inspections Program fulfills
multiple requirements of the City's Municipal National Pollutant Discharge Elimination System
(NPDES) Stormwater Discharge Permit.
In 1992 the City initiated stormwater characterization and other programs to assist in preparing
the City's initial permit application. The Stormwater & GIS Services Division (the "Division")
added staff to assume responsibility for implementing the City's illicit discharge program in
1997. At that time, the City Fire Department conducted facility Fire Code inspections, which
included observations of hazardous materials storage. The City's Stormwater Management and
Pollution Control Ordinance was adopted in 2006 to more explicitly identify prohibited
practices, to improve progressive enforcement, and to include certain preventative
requirements intended to reduce contamination of stormwater. Included in that Ordinance is
authorization of a Stormwater Inspections Program.
Under a revised and reissued NPDES permit in 2007, the Division assumed responsibility and
began developing a more effective Inspections Program.
Inspection of municipal facilities has remained relatively constant, as most municipal sites
requiring inspection were identified during the first year of the inspection program. On the
average, the Program conducts about 35 inspections of municipal facilities each year.
This document covers stormwater inspections of both private and municipal facilities and
completes the transition from the 2007 guidance and procedures document.
Other guidance documents for stormwater inspections include:
• Stormwater Inspections Program Database User/Administrator Guide
• Illicit Discharge Detection and Elimination (IDDE) Investigations Guidelines
• Water Quality Enforcement Guidelines
• Stormwater Pollution Prevention Plan Development Guide

CITY AUTHORITY TO CONDUCT STORMWATER INSPECTIONS OF INDUSTRIAL ACTIVITIES
State Law
A municipality in North Carolina may exercise only the powers granted to it by the State
Legislature. Accordingly, authorization for the City's Stormwater Quality Program comes from
N.C.G.S. § 143-214.7(c). The most relevant portion of that statute, for our purposes, is this:
...units of local government are authorized to adopt ordinances and regulations
necessary to establish and enforce stormwater control programs. Units of local
government are authorized to create or designate agencies or subdivisions to
administer and enforce the programs.
City Ordinance
With this authorization by the State Legislature, the City adopted a Stormwater Management
and Pollution Control ordinance in November 2006, which gives Stormwater and GIS the
authority and powers necessary to implement the measures required by our municipal
stormwater permit. According to City Code Sec. 1-12, this ordinance is only "effective within the
applicable jurisdiction of the City." These limits are specifically described in City Code Part 1,
Chapter 1, Section 2.
The authorization of a routine stormwater inspection program is codified under City Code § 70-
525.
Sec. 70-525. - Authority to enter, inspect, and monitor; routine inspection program.
a) Right to inspect. City representatives, upon presentation of credentials and other
documents as may be required by law, may enter public or private properties at all
reasonable times to inspect, investigate, or monitor activities and conditions subject
to this article. If consent has not been given through a permit or other similar
authorization, or a person able to give consent has not consented to entry or
inspection, or entry is not otherwise authorized, the director shall obtain an
administrative search warrant from a magistrate as provided under G.S. 15-27.2. The
director shall show either that the property is subject to a routine inspection
program and inspection under such program is due, or that probable cause exists to
inspect.
b) Inspection activities. City representatives are authorized to do the following as
necessary to determine compliance or noncompliance with this article:
1) Observe, inspect, measure, sample, test, and monitor;
2) Place devices to remain on site for runoff or discharge sampling, monitoring,
flow measuring, or metering;

3) Inspect, copy, or examine any records, reports, plans, test results or other
information; and
4) Photograph or video record property conditions, activities, potential causes of
pollution, and potential violations.
c) Confidential information. City representatives shall treat as confidential information
the composition of materials and substances documented during an investigation if
a claim is timely made and substantiated that such substances are trade secrets.
d) Obstruction. No person shall obstruct, hamper, or interfere with a city
representative carrying out official duties. Upon presentation of credentials by city
inspectors, necessary arrangements shall be made to allow immediate access onto
premises or into an area protected by security measures. Any obstruction to the safe
and easy access to property, a facility or enclosure on property, or to monitoring
devices shall immediately be removed. Unreasonable delays in providing safe and
reasonable access or removing obstructions shall be a violation of this article.
e) Routine inspection program. The director may establish, though guidelines, a routine
inspection program for properties, businesses, or other activities in order to gather
information regarding stormwater, pollution of the drainage system, and compliance
with this article. The inspection cycles for categories of properties, businesses, or
activities may differ depending on location, proximity to particular streams or other
waters of the state, prior history, type of business or activity conducted on site, size
of facility, nature of substances on site, or other parameters related to the
objectives of this article.
In summary, a City Stormwater Inspector has the authority to:
• Enter premises within the City Limits to check for compliance with the Stormwater
Management and Pollution Control Ordinance
• Apply for, and execute, an administrative search warrant, if necessary
• Make observations, take photos, collect samples of water/air/soil, view and copy
documents
• Keep facility trade secrets in confidence, if revealed during inspection
• Enforce obstruction of inspection as an ordinance violation
• Inspect operations periodically as part of a routine program
The above are in addition to the enforcement powers further specified in City Code § 70-538
through § 70-542. Please refer to the Water Quality Enforcement Standard Operating
Procedures document for a discussion of enforcement procedures.

Inspecting NPDES-Permitted Facilities
While the City is required and authorized to inspect facilities permitted under the NPDES
stormwater program, the City is not authorized by the State DEQto adjudicate compliance
status of those facilities. This means that the City cannot enforce requirements of an NPDES
permit, nor can the City determine compliance with an NPDES permit. Therefore, the staff
member conducting an inspection of a NPDES-permitted facility may collect evidence to
support limited conclusions:
1) If the facility cannot demonstrate any compliance with the NPDES stormwater
permit, then this is fully enforceable under City Code §70-514 as a violation. This
must additionally be reported to the state DEMLR Stormwater Permitting Division
via the Raleigh Regional Office.
2) If the facility's compliance with one or more requirements of its NPDES stormwater
permit is deficient, these deficiencies must be reported to the state DEMLR
Stormwater Permitting Division via the Raleigh Regional Office. The Stormwater
Inspector may provide guidance and recommendations to the facility to ameliorate
the deficiencies.
3) If the facility demonstrates compliance with its NPDES stormwater permit, no
further action is necessary.
The above does not apply to facilities with state -issued No Exposure Certification. These
facilities do not have the obligations and protections of a NPDES stormwater permit and are
therefore fully subject to City Code.
Inspectors should use the Contact List for Water Quality Investigations to find up-to-date
contact information for a representative of the DEMLR Stormwater Permitting Program. This
representative should be emailed a full report of the facility inspection.
WHAT TYPES OF OPERATIONS DO WE INSPECT?
The City is required by its NPDES Stormwater Permit and enforceable Stormwater Management
Plan to inventory and inspect: 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), industrial facilities that the City determines are
contributing or have a potential to contribute a substantial pollutant loading to the municipal
storm sewer system, and selected facilities associated with a history of illicit discharges under
the IDDE Program.
4

What is an "industrial" operation?
The City follows the definition found in 40 C.F.R. 122.26 for industrial activity when identifying
such facilities to inspect.
The Code of Federal Regulations (CFR) definition relies on the "Standard Industrial
Classification" (SIC) system for grouping similar operations into groups. An SIC code is a four -
digit number. The first two digits of the code represent the major industry sector to which a
business belongs. The third and fourth digits describe the sub -classification of the business
group and specialization, respectively. For example, "36" refers to a business that deals in
"Electronic and Other Equipment." Adding "7" as a third digit to get "367" indicates that the
business operates in "Electronics, Components and Accessories." The fourth digit distinguishes
the specific industry sector, so a code of "3672" indicates that the business is concerned with
"Printed Circuit Boards."
40 C.F.R. 122.26 includes the following types of facilities in the definition of "industrial activity:"
• Facilities subject to storm water effluent limitations guidelines, new source performance
standards, or toxic pollutant effluent standards under 40 CFR subchapter N
• [Manufacturing] Facilities classified as Standard Industrial Classifications 24 (except
2434), 26 (except 265 and 267), 28 (except 283), 29, 311, 32 (except 323), 33, 3441, 373:
o Lumber and Wood Products, except furniture
o Paper and Allied Products
o Chemicals and Allied Products
o Petroleum Refining and Related Industries
o Leather and Leather Products
o Stone, Clay, Glass, and Concrete Products
o Primary Metal Industries
o Fabricated Structural Metal Products
o Ship and Boat Building and Repairing
• Facilities classified as Standard Industrial Classifications 10 through 14:
o Metal Mining
o Coal Mining
o Oil and Gas Extraction
o Mining and Quarrying of Nonmetallic Minerals, Except Fuels
• Hazardous waste treatment, storage, or disposal facilities, including those that are
operating under interim status or a permit under subtitle C of RCRA (Resource
Conservation and Recovery Act)
5

• Landfills, land application sites, and open dumps that receive or have received any
industrial wastes (waste that is received from any of the facilities described under this
subsection) including those that are subject to regulation under subtitle D of RCRA
• Facilities involved in the recycling of materials, including metal scrapyards, battery
reclaimers, salvage yards, and automobile junkyards, including but limited to those
classified as Standard Industrial Classification 5015 and 5093:
o Used Motor Vehicle Parts
o Scrap and Waste Materials
• Steam electric power generating facilities, including coal handling sites
• Transportation facilities classified as Standard Industrial Classifications 40, 41, 42
(except 4221-25), 43, 44, 45, and 5171 which have vehicle maintenance shops,
equipment cleaning operations, or airport deicing operations:
o Railroad Transportation
o Local and Suburban Transit and Interurban Highway Passenger Transportation
o Motor Freight Transportation and Warehousing
o United States Postal Service
o Water Transportation
o Transportation by Air
o Petroleum Bulk Stations and Terminals
• Treatment works treating domestic sewage or any other sewage sludge or wastewater
treatment device or system, used in the storage treatment, recycling, and reclamation
of municipal or domestic sewage, including land dedicated to the disposal of sewage
sludge that are located within the confines of the facility, with a design flow of 1.0
million gallons per day or more, or required to have an approved pretreatment program
under 40 CFR 403.
• [Manufacturing] Facilities under Standard Industrial Classifications 20, 21, 22, 23, 2434,
25, 265, 267, 27, 283, 285, 30, 31 (except 311), 323, 34 (except 3441), 35, 36, 37 (except
373), 38, 39, and 4221-25:
o Food and Kindred Products
o Tobacco Products
o Textile Mill Products
o Apparel and Other Finished Products Made From Fabrics and Similar Materials
o Wood Kitchen Cabinets
o Furniture and Fixtures
o Paperboard Containers and Boxes
o Converted Paper and Paperboard Products
o Printing, Publishing, and Allied Industries
o Drugs

o Paints, Varnishes, Lacquers, Enamels, and Allied
o Rubber and Miscellaneous Plastics Products
o Leather and Leather Products
o Glass Products, Made of Purchased Glass
o Fabricated metal Products, Except Machinery and Transportation Equipment
o Industrial And Commercial Machinery And Computer Equipment
o Electronic And Other Electrical Equipment And Components, Except Computer
Equipment
o Transportation Equipment
o Measuring, Analyzing, And Controlling Instruments; Photographic, Medical And
Optical Goods; Watches And Clocks
o Miscellaneous Manufacturing Industries
o Farm Product Warehousing and Storage
o Refrigerated Warehousing and Storage
o General Warehousing and Storage
Not specifically included in the CFR definition, but also inspected by the City (due to the high
risk of stormwater pollution) is SIC group 753, which includes:
• 7532 Top, Body, and Upholstery Repair Shops and Paint Shops
• 7533 Automotive Exhaust System Repair Shops
• 7534 Tire Retreading and Repair Shops
• 7536 Automotive Glass Replacement Shops
• 7537 Automotive Transmission Repair Shops
• 7538 General Automotive Repair Shops
• 7539 Automotive Repair Shops, Not Elsewhere Classified
If you wish to look up a SIC Code, the US Department of Labor has a helpful online search tool.
Standard Industrial Classification (SIC) System Search
STATISTICS & DATA I SIC MANUAL
This page allows tlx user to search the 1487 version SIC manual 6ykeyward, to access descriptive information for a specified 2,3,4-digit SIC, and to examine the manual structure.
Enter a SIC CODE:
Enterthe search
keyword[s]:
Submit Clear
To arrive at this search page:
rA

1. Navigate to the US Department of Labor website
2. In the website's search text box, type "Standard Industrial Classification (SIC) System
Search" and press Enter.
3. Clicking the first result should take you to a page similar to the above screenshot
NPDES Stormwater Permits for Industrial Activities
Facilities with NPDES stormwater permits are inspected by the City, not only because they have
permits, but because they are defined as industrial activities by the CFR.
The NPDES program includes an industrial stormwater permitting component. This Guide will
discuss permit requirements in greater detail later on, but at a basic level, these permits require
stormwater pollution prevention practices at facilities with industrial activities exposed to
stormwater.
Which agency assigns permits in North Carolina?
The State of North Carolina is authorized by the US EPA to be the NPDES stormwater permitting
authority for industrial activities within the State. North Carolina's Stormwater Permitting
Program is a part of the Department of Environmental Quality (DEQ) 4 Division of Energy,
Mineral, and Land Resources (DEMLR).
General Permits
NPDES General Stormwater Permits are the State's attempt to simplify the process of regulating
stormwater pollution by grouping similar industrial facilities under the same permit
requirements. For example, rather than assess every beer brewery individually, assessing its
risks and setting requirements specific to each brewery (which would be near impossible due to
the staff level and time it would take), the General Permit program treats all beer breweries
equally and assigns them all the same NCG060000 "Food and Kindred" general permit.
That State Stormwater Permitting Program has many General Permits that cover stormwater
discharges associated with industrial activities. The State NPDES General Stormwater Permits
are:
Description of Activity
Permit
Number
Includes SIC(s)
Construction Activities
NCGO10000
N/A
Mining Activities
NCG020000
14
Metal Fabrication
NCG030000
335, 3398, 34, 35, 36, 37, 38 (but not 373)
Apparel, Printing, Leather, Rubber
NCG050000
23, 27, 267, 265, 39, 31, 30 (but not 311, 301)
Food and Kindred
NCG060000
20, 21, 284, 283, 4221-4225
Stone, Clay, and Glass
NCG070000
32 (but not 3273, 3241)
!✓'

Description of Activity
Permit
Number
Includes SIC(s)
Transit and Transportation
NCG080000
40, 41, 42, 43, 5171 < 1 mil. gal. (but not
4221-4225, 44, 45)
285
Paints and Varnishes
NCG090000
Used Motor Vehicles
NCG100000
5015, 5093
Treatment Works
NCG110000
N/A
Landfills
NCG120000
N/A
Non-metal Waste and Scrap
NCG130000
5093
Ready -Mixed Concrete
NCG140000
3273
Airports
NCG150000
45
Asphalt Paving Mixtures, Blocks
NCG160000
2951
Textile Mills
NCG170000
22
Furniture Manufacture
NCG180000
25,2434
Marinas and Shipbuilding
NCG190000
4493 with maintenance, 373
Scrap Metal
NCG200000
5093 (but not 5015 and non-metal)
Timber Products
NCG210000
24 (but not 2434, 2491)
Composting Operations
NCG240000
2875
Small MS4 outside coastal NCG230000 N/A
counties
Construction Activities for
projects permitted on or after Oct I NCG250000 N/A
1, 2020
Individual Permits
When an industrial operation does not fit into any of the General Permit categories, yet is of a
type where pollution generating activities or materials are exposed to stormwater, the State
Permitting Program may require an Individual NPDES Stormwater Permit. If such a permit is
required, the State will usually examine the nature of the activity and the exposure level and
require sampling and analysis of the facility's stormwater runoff. Using those data and
observations, the State will custom -tailor a NPDES permit for that facility.
No Exposure Certification
Facilities with stormwater discharges associated with industrial activity (otherwise required to
apply for a NPDES stormwater permit) may be excluded from permit coverage if industrial
materials and operations are not exposed to stormwater. The standard for achieving No
Exposure status is high. The NC DEQ provides an extensive exposure checklist for a facility to
complete. If even one of the items on this checklist is (or may at some time become) exposed to
t:,

precipitation, the facility is not eligible for No Exposure status. The facility must maintain this
condition of no exposure to qualify for the permitting exclusion.
Facilities with No Exposure Certifications must complete a self -recertification form each year,
which is kept onsite.
If the condition changes, the facility must seek permit coverage for industrial stormwater
discharges under a general or individual permit.
How DOES THE CITY IDENTIFY INDUSTRIAL FACILITIES?
City MS4 Permit Requirement
Section H of the City's MS4 Stormwater Permit requires:
Maintain an inventory of permitted hazardous waste treatment, disposal, and recovery
facilities, industrial facilities that are subject to Section 313 of Title III of the Superfund
Amendments and Reauthorization Act of 1986 (SARA), industrial facilities identified with
an industrial activity permitted to discharge storm water to the permittee's MS4, or as
identified as an illicit discharge under the IDDE Program. For the purposes of this permit,
industrial activities shall mean all permitted industrial activities as defined in 40 CFR
122.26.
Generally
The Stormwater Inspections Database inventory of facilities is continuously updated. New
businesses open and existing ones close constantly. We also routinely discover previously
unknown operations. Collectively, we refer to newly opened and newly discovered facilities as
"new facilities."
Inspectors can identify new facilities requiring inspection though observations made while in
the field, Water Quality IDDE investigation referrals, customer and City employee complaints
and reports, news reports, internet searches, and a few other specific resources discussed next.
Identifying NPDES Stormwater Permitted Facilities
The primary source for identifying these facilities is the State Stormwater Permitting Program.
Available on the Program's website (https://deq.nc.gov/deq.nc.gov/SW-maps) is a link to
download a MS Excel spreadsheet listing all "Active NPDES Stormwater" permits. There is also a
link to a useful "Active Stormwater Permits Map." These resources are generally updated on a
monthly basis.
To arrive at this program's website in the event of a broken URL:
its]

1. Navigate to the NC DEQwebsite
2. In the website search text box, type "Maps & Permit Data" and press Enter
3. Within the search results should be a link to the "Maps & Permit Data" page
The State's list should be consulted on a quarterly basis and used to update the City's inventory
of facilities in the Stormwater Inspections Database.
Identifying Permitted Hazardous Waste Treatment, Disposal, and Recovery
Facilities
The US EPA defines "treatment and disposal" facilities as those processing hazardous waste to
change "the physical, chemical, or biological characteristics of a waste to minimize its threat to
the environment." Not specifically mentioned in our MS4 Permit wording, but considered
included by the Inspections Program (due to similar high risk of stormwater pollution) are
storage facilities, which temporarily hold hazardous wastes before treatment, disposal, or
transfer to another storage facility. "Recovery" facilities are those either conducting solvent
recovery of Toxic Release Inventory -listed chemicals (see the EPA's list of reportable chemicals
here) or waste recycling. Solvent recovery facilities are identified via the EPA TRI Explorer (see
next section) and recycling facilities are identified using the same method as for treatment,
storage, and disposal facilities ("TSDFs").
A local list of TSDFs can easily be found by accessing the EPA's RCRAInfo search tool.
Generators, transporters, treaters, storers, and disposers of hazardous waste are required to
provide information on their activities to state environmental agencies. These agencies then
provide the information to regional and national US EPA offices through the Resource
Conservation and Recovery Act Information (RCRAInfo) System. Information on cleaning up
after accidents or other activities that result in a release of hazardous materials to the water,
air, or land must also be reported through RCRAInfo.
Search Method:
Navigate to the RCRAInfo Website
• In the "Geography Search" heading, enter in "Durham"" for city and "NC" for state.
1 Facilities designated as Durham City may have a city mailing address but may not be located within the City's
Jurisdictional Limits.
11

Geography Search
Enter a partial value for any geography option except for the state value.
contains a large number of facilities.
ZIP Code-
I
Address-
1 Beginning With UExar-t Match '.'Containing
CAT
Durham
State:
NC
• In the "Handler Universe" section, choose the radio button beside "Treatment, Storage,
Disposal Facilities" and be sure "Full Enforcement Universe" is selected from the drop
down menu.
Handler Universe
'-Al Handler Universes
4 Treatment, Storage, Disposal Facilities:
Full Enforcement Universe ■
Other Universes:
Large Quantity Generator
• Scroll to the bottom of the form and click "Search"
• Examine the search results. There is an option to export the results to .csv format for
use in MS Excel. You will see facility names and addresses, and have links to contact
information, operations descriptions, RCRA enforcement, maps, and more.
Once the RCRAInfo search is complete, the results should be compared with facility listings in
the Inspections Database to make facility edits and additions as necessary.
RCRAInfo's database is generally updated by the EPA on a monthly basis. It should be checked
quarterly and compared with existing Inspections Database facility records for additions and
edits.
Identifying Facilities Subject to Section 313 of SARA Title III
Section 313 of the Emergency Planning and Community Right -to -Know Act (EPCRA), which is
also known as Title III of the Superfund Amendments and Reauthorization Act (SARA), requires
12

certain facilities to report both routine and accidental chemical releases. A "release" of a
chemical means that it is emitted to the air or water, or placed in some type of land disposal.
(The chemicals triggering reporting are found on the EPA's "List of Lists.") These businesses
must submit reports to the EPA and the state emergency response commission by July 1 for
each preceding year.
The Toxics Release Inventory (TRI) tracks the management of over 650 toxic chemicals that
pose a threat to human health and the environment. U.S. facilities in certain industry sectors
that manufacture, process, or otherwise use these chemicals in amounts above established
levels must report how each chemical is managed through recycling, energy recovery,
treatment, and releases to the environment. The information submitted by facilities to the EPA
and states is compiled annually as the TRI, and is stored in a publicly accessible database, called
the TRI Explorer.
TRI data are available for all facilities that have submitted a Form R or Form A to EPA since the
program began in 1987. The most recent data reported are made available in late July with
updates occurring from August through October.
The TRI Explorer features many advanced search functions. The most routinely useful for the
purpose of identifying facilities for the Inspections Program is to query by facility.
Search method:
• Navigate to the TRI Explorer Facility Release Reports Query
TRI Explorer
You are here: EPA Home » TRI » TRI Explorer -Release Repons - Release Facility Report
Release Reports
�11___TransF 0.epor[s Wash 4�nhM Re__emicalI Facility I Federal Facility Trends Geography Industry I Dynamic Map
Release Facility Report O
This site uses pop-up mndmrs, click here for help on allowing pop -ups from this site
Year of Daza 0
Repon columns to include a)
2014
Geographic Location a)
El TRIF I❑
❑ Number of Form Rs
All of United States t
❑ Numher of Form (stoning As 1 995)
ChemiolM
❑ Longitude Latitude
All chemicals
RJ Total On -site Disposal or Other Releases
Industry 0
Oeraifs
All Industries
On -Site Disposal to Class I Wells. RCRA Subirle
Data Seto
C Landfills, and Other On -Site Landfills
Thedefauhis 2014ontnset Sreleasedseptamherzms)
LJ Other O) -Site Oispcsal o r Other Releases
sekn zars wra:er Irekased,u >=d zarsl
0 Total OffsiteDisposal or Othe r Releases
L75ektt20l3 NariorralRrulysis daraset (Meased0. ber
oeta'15
zots�(upd redwvza, zofal
1-1 Off -Site Disposal to Underground Inj­Wells,
RCRA Subtitle C Landfills, and Other Landfills
Other Off -Site Disposal or Other Releases
Total On -and Cl Disposal or Other Releas es
Generate Report
• Under "Geographic Location," choose "Select a state or county," then choose "North
Carolina" from the new menu. Click on the "Select from List of Counties" box when it
appears. Select "Durham."
13

North Carolina
r
ecombeyth
• Leave the rest of the options in their defaults, unless you specifically want an older Data
Set or additional details (not necessary for Inspections Program purposes)
• Click on "Generate Report"
• You will be returned a report of facilities for all of Durham County and will need to do
some additional work to determine if each facility is within the City's jurisdictional limits.
This report may also be exported to .csv for viewing in MS Excel.
Compare the TRI Explorer's report list with those facilities in the Inspections Database and
make additions and edits as necessary. This should be done twice per year, matching the TRI's
update schedule: late July and late October.
Identifying Municipal Facilities Requiring Inspection
The list of municipal facilities requiring inspection is broader than that for private facilities. A
municipal facility will be identified for inspection if it stores potential stormwater pollutants,
conducts pollutant -generating activities, requires a NPDES stormwater permit, or all of the
above. This includes many types of municipal operations, from fire stations (large amounts of
fuel storage) to water reclamation facilities (NPDES permitted treatment works).
Inspection staff members should remain informed of new facility construction by annually
reviewing the City's Capital Improvements Program, or by periodically making inquiries with
facility stormwater pollution prevention teams, General Services project managers, and reading
over City Council Agendas. The City's Stormwater Management Plan provides a listing of the
types of activities that have the potential to discharge pollutants to the drainage system. If a
new facility will support activities involving storage or use of potential stormwater pollutants,
the facility should be included in the routine inspection program., Inspection staff members or
supervisors should interface with the project manager for new facility construction and discuss
potential pollution risks and prevention strategies.
Changes in facility use and opening of new facilities should be recorded in the Inspections
Database once inspections staff members become aware of them (an ongoing basis).
Cleaning of Municipal Equipment and Vehicles
Cleaning of City equipment and vehicles must be conducted in compliance with the
requirements of the City's MS4 NPDES stormwater permit and City Code. Vehicle wash water
may not be discharged to the MS4.
14

Each wash facility listed below drains to the sanitary sewer system via an approved pre-
treatment device.
1. Public Works Operation Center Wash Pit- mainly used for cleaning earth -disturbing
and street cleaning equipment, but available for routine vehicle washing. This wash
pit is connected to the sanitary sewer system via an oil -water separator.
2. Solid Waste Vehicle Wash Facility- mainly used to clean off Solid Waste
Management garbage trucks. This fully -enclosed wash bay is connected to the
sanitary sewer system via an oil -water separator.
3. Go Durham (Bus Maintenance Facility) Wash Bay- This completely enclosed wash
bay is operated by a contractor and used for the cleaning of DATA buses and fleet
vehicles. This wash pit is connected to the sanitary sewer system via an oil -water
separator.
The Durham Fire Department ^^must comply with the City's MS4 NPDES permit
rule governing the washing of emergency vehicles. Washing of emergency vehicles is only
permitted at those stations where wastewater is directed into engineered retention areas,
grassed areas, or loosely graveled areas. An up-to-date list of these facilities may be found in
the Stormwater Management Plan.
City Jurisdictional Limits
As a critical step in the new facility identification process, an inspector should use the City and
County jurisdiction datasets in ArcGIS to determine if the facility is within our City jurisdiction.
Facilities outside of the City's jurisdiction should not be inspected by City staff. If there is a
suspected illicit discharge from a facility outside of the City limits, it should be reported to
Durham County Stormwater. If the facility has a NPDES Stormwater Permit, the report should
also be made to the DEMLR Stormwater Permitting Program.
For all industrial facilities, including those listed in the EPA TRI, RCRAInfo, or State Stormwater
Permitting Program permittee lists, it is generally advisable to create an entry in the Inspections
Database even if the facility is out of, but on the fringes of the City's jurisdiction. These entries
can assist other inspectors checking the jurisdictional status of those facilities.
HOW ARE INDUSTRIAL FACILITIES INVENTORIED?
The Inspections Program uses a MS Access database to store all data related to private and
municipal facilities in and around the City jurisdictional limits. This database is the central
repository for facility:
• locations (mailing/physical addresses)
15

• contact information (names, phone numbers, emails)
• operations descriptions
• stormwater permitting information
• inspection results
• City Code enforcement
A separate document Industrial Stormwater Inspections Program Database User -Administrator
Guide is available to reference as a full explanation of the industrial facility inventory.
PRIORITIZING FACILITY INSPECTIONS
Some facilities require more frequent inspection than others. To make efficient use of City
inspector time and effort, every facility is assigned and inspected according to a priority level
reflecting a combination of risk of stormwater pollution and history of compliance with
stormwater regulations. This paradigm allows us to focus on those facilities most in need of
oversight, corrective action, or both.
The Inspections Database tracks a facility's priority rank and automatically assigns the proper
inspection frequency. With the click of a button, the Database can then generate an up -to -the -
moment report of facilities due for inspection based on priority, inspection frequency, and time
since most recent inspection. There are separate reports for private facilities and municipal
facilities, accessible directly from the database main menu.
Facilities are occasionally elevated or demoted in priority according to the results of routine
periodic inspections. The below flowchart illustrates the procedure for changing facility priority
level.
i[:

H&h:
Inspect Annually
7
Compliance?
What is private facility priority
level?
Medium:
Inspect every
2 years
4
Compliance?
Conduct
and
toConductfolloup
['Led,'u-
folandupenforce
enforce
Priority
J
I
I
L
Promote to
High
Priority
All TRI facilities remain
high priority, regardless of
compliance history.
All facilities not yet
inspected begin at
Medium Priority by
default.
Low:
Inspect every
3 years
7
Compliance?
Conduct
follow-up
and
Remain
Low
enforce
Priority
i
Steps to
become No
Promote to
Medium
Priority
Exposure?
I Yes
Remain Low Demote fo
Priority NO
Exposure
No Exposure:
Inspect every
5 years
7
Compliance?
NaYes
Conduct
follow-up Remain
and No
enforce Exposure
Promote to
tow
Priority
Category includes
industrial sites certified as
NCGNE by the State and
non -certified light
industrial sites with no
exposure.
Generally, we inspect municipal facilities more frequently than private ones. Since each priority
rank has a corresponding inspection frequency, we have separate priority ranking systems for
Private and Municipal facilities.
Each priority system will be discussed separately.
Private Facility Priority System
Private facilities are inspected according to a hierarchy of priority, as follows:
1. Facilities requiring follow-up inspection
a. An initial inspection of the facility revealed one or more compliance issues
requiring corrective action. The inspector determined that a follow-up inspection
was necessary to confirm that the corrective actions were satisfactorily
completed.
2. High Priority
17

a. These are facilities with some combination of the highest risk of stormwater
pollution and a recent history of non-compliance with stormwater regulations.
b. A facility with High Priority status may be demoted to Medium Priority if it is
found to be in compliance after routine annual inspection.
c. This category also includes compliant facilities identified as TSDFs or appearing
on the EPA TRI Facility Release Report. These facilities may not be demoted in
priority, regardless of their compliance history.
3. Medium Priority
a. This is the default priority for all facilities that have not yet been inspected
b. A facility with Medium Priority status may be elevated to High Priority if it is
found to not be in compliance after routine 2-year inspection
c. A facility with Medium Priority status may be demoted to Low Priority if it is
found to be in compliance after routine 2-year inspection
4. Low Priority
a. These are facilities with the lowest risk and a history of continued compliance
with stormwater regulations.
b. A facility with Low Priority status may be elevated to Medium Priority if it is
found to not be in compliance after routine 3-year inspection
c. This status is the lowest to which a private facility may usually be demoted
5. No Exposure
a. These are facilities meeting the requirements for a NPDES Stormwater Permit
that have been issued No Exposure Certifications from NC DEQ
b. These are also facilities not requiring NPDES Stormwater Permits, but that the
City has observed have no exposure of pollutants or pollutant -generating
activities to stormwater
c. A facility with No Exposure status may be elevated to Low Priority if is it found to
not be in compliance with its Certified No Exposure status or stormwater
regulations after routine 5-year inspection
d. A facility may be demoted from Low Priority to No Exposure if the facility takes
steps to protect its pollutant storage or pollutant -generating activities from
stormwater exposure
6. No Inspection Needed
a. These are facilities that have no storage of pollutants or pollutant -generating
activities. This also includes facilities where such activities occurred at one time,
but have ceased.
b. As a result, no further inspection after making this determination is necessary.
Should we learn at a later time that the facility has resumed or begun industrial
iIRl

activities, the facility should be placed back on the inspection list — starting at
Medium Priority (unless other factors suggest a High or Low assignment).
The table below summarizes our private facility priority categories, associated risk of
stormwater pollution, and inspection frequency.
No
High
Medium
Low
No
Category �
Inspection
Priority
Priority
Priority
Exposure
Needed
Risk of
Stormwater
High
Medium
Low
Lowest
None
Pollution
Inspection
1x per
1x per 2
1x per 3
1x per 5
Not
Frequency
year
years
years
years
inspected
Municipal Facility Priority System
The Inspections Program is responsible for routinely evaluating City operations to identify those
with the potential for generating polluted stormwater runoff. City operations are ranked into
five priority categories.
With the exception of Special Action, the municipal facility priority categories are different from
the private facility priority categories and have different inspection frequencies. Generally
speaking, municipal facilities are inspected more frequently than private facilities.
Municipal facilities are inspected according to a similar but separate hierarchy of priority, as
follows:
1. Facilities requiring follow-up inspection
a. As with private inspections, an initial inspection revealed compliance issues
requiring corrective action. The inspector determined that a follow-up inspection
was necessary to confirm that the corrective actions were satisfactorily
completed.
2. High priority
a. These are facilities with some combination of the highest risk of stormwater
pollution and a recent history of non-compliance with stormwater regulations.
b. A facility may also be temporarily placed in this priority to receive extra oversight
and guidance if
i. Undergoing significant construction or renovation likely to impact
stormwater runoff quality
19

ii. Experiencing high staff turnover rate within the pollution prevention
team or under new management
iii. Anew NPDES permit is granted to the facility or there are substantial
changes made in a permit revision requiring extra guidance
iv. Other circumstances create a need
c. These facilities are inspected three times per year
3. Medium priority
a. This is the default rank for most facilities, balancing our interest in oversight with
time available to conduct frequent inspections
b. These facilities may have significant exposure of pollutants and pollutant -
generating activities to stormwater, but sufficient management practices to
mitigate the risks
c. These facilities are inspected twice per year
4. Low priority
a. These are facilities with minimal exposure of pollutants or pollutant generating
activities to stormwater
b. Overtime, inspections have routinely found these facilities to be in compliance
and managing risk appropriately
c. These facilities are inspected once per year
5. Lowest priority
a. This category is reserved for those facilities where there is little to no exposure
of pollutants or pollutant -generating activities to stormwater.
b. These facilities are inspected once every three years
The table below summarizes our municipal facility priority categories, associated risk of
stormwater pollution, and inspection frequency.
Category 4
High Priority
Medium
Priority
Low Priority
Lowest
Priority
Risk of
Stormwater
High
Medium
Low
Lowest
Pollution
Inspection
1x every 3
3x per year
2x per year
1x per year
Frequency
years
Below is a table of City "hot spot" facilities with their corresponding priority levels as of March
2022. The facilities in bold type are NPDES General Stormwater permittees. Stormwater
compliance -related records for these facilities are stored in the Inspections Database.
Pill

Table 1. Municipal "hot spot" facilities subject to routine stormwater inspections program. Priority levels are as of March 2022.
Facility
Quarterly
High
Medium
Low
Lowest
Public Works Operations Center (NCG08)
X
Fleet Maintenance (NCG08)
X
Go Durham Maintenance Facility* (NCG08)
X
South Durham Water Reclamation Facility
(NCG11)
X
North Durham Water Reclamation Facility
(NCG11)
X
Solid Waste Vehicle Wash (NCG08)
X
Solid Waste Disposal and Recycling Center*
X
General Services
X
Brown Water Treatment Plant
X
Williams Water Treatment Plant
X
Water Management Administration
X
Hillandale Golf Course*
X
Fire Dept. Maintenance Garage
X
Transportation Sign and Signal Shop
X
Parks and Recreation Admin. Center
X
Fire Dept. Training Academy
X
Fire Stations 1-19
X
* Facility is operated by third -party (private) contractor.
Contract -Operated Facilities
The Go Durham facility on Fay Street is where the City's bus fleet is maintained and parked. Go
Durham has a NCG08 Transit and Transportation NPDES Stormwater Permit. The facility and
grounds are owned by the City, but all work is conducted by a private contractor. This
contractor is responsible for NPDES Permit and City stormwater ordinance requirements.
Failure of the contractor to comply with those requirements is handled as if the facility were
purely a private facility (use of requirement and enforcement powers is allowed).
The Solid Waste Disposal and Recycling Center on East Club Boulevard houses several activities:
tipping floor for dumping waste and recyclables (contractor -operated), convenience center for
manually unloading waste, yard waste drop-off, and household hazardous waste collection
(contractor -operated). As with the Go Durham facility, if either contractor at the Solid Waste
Disposal and Recycling Center fails to comply with the City stormwater ordinance, requirement
and enforcement powers may be used.
21

Hillandale Golf Course is a privately -run and maintained public golf course on City -owned real
property. The company running the course is subject to compliance with the City stormwater
ordinance, including enforcement.
OVERVIEW OF THE INSPECTION PROCESS
No two facility inspections are exactly alike, so inspectors should be ready to adapt to
circumstances, but generally, all inspections follow this routine:
1. Use the priority list to find an appropriate facility to inspect
2. Determine an appropriate time to inspect the facility
a. Scheduled in advance with facility staff
b. Unannounced "spot check"
3. Review the facility's inspection history (if any)
4. Be prepared with and don appropriate PPE for the inspection
5. Gain lawful entry onto the facility premises
6. Conduct the inspection
a. Use the inspection form to thoroughly assess the site
b. Record observations
c. Take photographs
d. Collect water/soil samples (if needed)
7. Review any violations and required BMPs/corrective actions with responsible party
8. Enter inspection results into database, upload photos
9. Issue Notice of Requirement/Violation, if appropriate
10. Return for follow-up inspection, if necessary
Inspections are most often conducted by a single staff member responsible for completing all
the above tasks. Inspections are occasionally conducted by two or more staff members as part
of an inspection team or as part of new inspector training. In those instances, one member is
the lead inspector, tasked with overall responsibility for the inspection.
Each member of the team is responsible for following the procedures and guidelines outlined in
this document, though the lead investigator has primary responsibility for ensuring that the
inspection is conducted accordingly.
Tasks may be divided up among the team as the members agree upon, though the lead
inspector will be the primary contact for communications with facility management, property
owners, responsible parties, state regulators, etc., including for issuance of Notices. The lead
inspector will normally handle obtaining right -of -entry permission, and will be responsible for
control over evidence. The lead inspector will enter inspection information in the Industrial
PJOJ

Stormwater Inspections MS Access database and make sure that digital photos are uploaded to
the Public Works network server.
PRE -INSPECTION TASKS & MATTERS
Scheduling Inspections
Inspections may be conducted with or without advance notice to the facility to be inspected.
This usually depends on the type of facility to be inspected.
Spot Inspections
Inspections conducted without advance notice to the facility to be inspected are referred to as
"spot inspections." Our authority to conduct these inspections may be found in City Code § 70-
525(a):
City representatives, upon presentation of credentials and other documents as may be
required by law, may enter public or private properties at all reasonable times to
inspect, investigate, or monitor activities and conditions subject to [the Stormwater
Management and Pollution Control Ordinance].
The definition of "reasonable times" will vary, depending on the place to be inspected.
Generally, though, a reasonable time will be during normal operating hours for the facility. The
inspector may use judgment to determine if conducting an inspection during a facility's busiest
time of day is necessary under the circumstances, with one caveat; the busier the facility is, the
less likely it is that a supervisor will have time to accommodate the inspector. Also consider that
busier times may present different safety hazards (more traffic, busier production floor, etc.).
However, sometimes the busiest operating hours may present the most significant pollution
risks and therefore may be the best times to inspect.
Historically, spot inspections are used for the most ubiquitous type of facility in Durham: auto
service. Owners, managers, or supervisors are almost always available onsite for an inspection
during business hours. These types of inspections do not typically require much time.
Additionally, we are interested in observing these businesses' activities and practices when they
have no advance warning of the inspection.
Inspections Scheduled in Advance
Inspections may be scheduled in advance out of necessity or out of convenience. Several
facilities in the inspection program require advance security checks for entrance. Some require
that multiple members of a management team are present during the inspection. Other times,
the inspector wants to make absolutely sure that specific facility representatives will be onsite
during the inspection. These are all good reasons to schedule the inspection in advance. The
23

downside to advance notice to the facility is the chance that the facility will be prepared for the
inspection and neater, more orderly, and in a condition not representative of most other days.
The inspector should use judgment in balancing convenience with desire to observe the facility
in an un-notified, "representative" condition.
Review Facility History
Before arriving onsite, the inspector should review the facility's inspection history. The
inspector should be aware of the facility's compliance history and areas of stormwater pollution
concern. This familiarity allows the inspector to revisit problem areas around the facility to
check for recurring issues and inadequate or failed management practices. Knowledge of past
compliance issues is also important when considering incidents of repeat violations during the
enforcement phase.
Gather Equipment and Supplies
Before leaving the office for an inspection, inspectors should make sure that they have the
necessary equipment and supplies they need. Equipment needed may vary from one inspection
to another. Inspections will always require the use of inspection forms and cameras.
Occasionally, the inspector will need or wish to collect or field analyze runoff samples and must
make arrangements to bring the required equipment.
Some equipment and supplies are normally kept in vehicles while other equipment is normally
stored in the office or lab until needed.
Assess Safety Concerns
The City of Durham's most valuable resources are its employees. Under any set of
circumstances, your own safety is a priority over any inspection task. Inspectors must
continually be aware of potential hazards when conducting an inspection. Where potential
hazards exist, inspectors must evaluate the potential hazard and take appropriate precautions
to decrease the chance of injury.
As an inspector, you will encounter many different types of facilities and may find yourself
using more types of PPE more often than during the course of routine water quality
investigations. Generally, the safety hazards an inspector may face on a routine basis are:
• Chemical (flammable, toxic, or corrosive materials)
• Electrical (shocks)
• Mechanical failure
• Slips, Trips, and Falls
• Fire and Heat
• Noise
24

• Extreme temperatures
• Weather phenomena
It is not unusual for a single inspection site to present all of the above hazards!
Personal Protective Equipment
All city employees are required to use Personal Protective Equipment (PPE) appropriate for the
task or work assignment. As an inspector, you should always be able to find out in advance
what PPE is required at any inspection site simply by asking facility staff ahead of time.
Staff may procure most commonly needed PPE from the dispensary at the Public Works
Operations Center. Please talk to your supervisor if you need a particular type of PPE not
otherwise provided.
As a baseline, steel- or composite -toed safety shoes are so often required to enter facilities that
inspectors should always wear them in the field. Safety shoes should be oil- and slip -resistant,
since oil residue is frequently encountered on the ground at many facilities. Inspectors will also
encounter requirements for hard hats and safety glasses often enough that they should be kept
on hand as well.
If a facility has a required level of PPE for all who step onsite (and you will see this often), you
must at least follow those requirements.
Sometimes, a facility's own staff may follow more or less rigorous safety requirements than are
required by the City. In those instances, an inspector should follow whichever safety
requirements are greater, being sure to address each hazard with the appropriate level and type
of PPE. Respect the requirements of the place you are inspecting!
City employees must read and understand the City's safety policies. Safety Policy 5-201: Safety
Program indicates that "Each individual is in the very best position to ensure his/her own
personal safety, which will impact, not only the individual but others in his/her immediate work
environment." 5-201 goes on to list requirements that every City employee must observe.
Safety Policy 5-206: On the Job Accident Reporting and Procedures establishes requirements for
employees and supervisors that will result in prompt and accurate reporting of an accident,
injury or near miss.
Injury Response and Reporting
The City of Durham general safety procedures are located on the City's intranet portal and in
each employee's hard -copy policy handbook. In the event of an emergency, call 911 or
transport the injured employee to the nearest hospital.
25

Employees are required to promptly report on-the-job accidents, injuries, and illnesses to
their supervisor and the Public Works Safety Officer, and follow the additional reporting
requirements of Safety Policy S-206-2: On the Job Accident Reporting.
All employees must be familiar with and follow procedures and deadlines for all Workers'
Compensation claims. If an injury occurs during field operations, the supervisor or another
team member will be responsible for transporting the injured employee for medical attention
as warranted.
Entry onto Premises
A stormwater inspection usually requires that the inspector gain access to parts of facilities and
operations that are off-limits to the general public. Some of the same principles of entry for
IDDE investigations apply, but inspectors will largely be relying on consent to gain entry.
Remember, as a government agent, an inspector is forbidden by the U.S. Constitution from
conducting unreasonable searches and seizures.
An inspector may conduct a search in a way that is not "unreasonable" when it is conducted
either:
1. from an area covered by the "plain view" doctrine; or
2. on the premises with the consent of a person with authority to give it
Without consent or a warrant, an inspector should avoid entering places like closed
maintenance bays, sheds, office areas, fenced or walled off areas, or other places marked as
"Authorized Entry Only" (or similarly marked).
Evidence of a violation in plain view
If the inspector is lawfully present in a place where they can plainly see, smell, or hear the
evidence, there is no infringement of rights if the investigator records observations and uses
them as evidence.
Plain view observations are not always possible at industrial facilities due to fences, walls,
facility size, etc. In rare circumstances, administrative search warrants for periodic inspection
may be necessary.
This means that evidence may be collected by observing conditions and violations from places
like:
• City streets and sidewalks
• City easements
• City property
M&

• Public areas such as parks
• Adjacent private property once the investigator is granted consent (or a warrant) to
enter
• Business areas open to the public such as:
o Customer parking lots
o Sales floor
o Reception area
Consent to enter premises
Consent of a person who has control over, the right to joint access of, or authority over a
property must be granted before an inspector records observations or collects evidence from
areas that would be unreasonable to search.
Who maygrant consent?
Most of the time, inspectors will be dealing with business owners, managers, and supervisors
who are explicitly authorized to grant consent to entry by an inspector. Many times, the
inspector will have pre -arranged the inspection with one of these individuals, who agrees to
escort the inspector around the premises.
Tenants who lease property from landlords have possession of the property and the power of
consent to entry. A landlord may not grant valid consent to enter property leased to a tenant
(unless the lease specifies an exception). When dealing with co -tenants or co -owners, any of
the tenants or owners may grant valid consent to enter the premises. However, it only takes a
single co -tenant or co-owner to object or revoke the consent.
A non -owner or non -manager business employee may have authority to grant valid consent to
enter the premises if: 1) a higher-up has given him the appearance of authority (such as a
uniform or "manager" name tag/title); and 2) the inspector reasonably believes the employee
to have authority, based on that appearance.
When in doubt as to the validity of consent, an inspector should not conduct the inspection.
Except in the case of emergency, if an owner, manager, or other supervisor is not available, it is
usually best to return another time when such a person is available.
No person is required to give consent. Threats, tricks, bluffs, or coercion should not be used to
gain consent for entry. A valid tactic, however, is to inform the business representative that
your duties require you to inspect the facility, so you will be forced to apply for a search
warrant. ("Apply" is emphasized, since to say "get" is both hasty and borderline -threatening.)
Steps to follow in requesting consent to enter and inspect:
1. Identify yourself by name
PrA

2. Show your City ID badge
3. Request to speak with an owner, manager, supervisor, or other person in charge
4. Explain the purpose of your visit
5. Request permission to enter and conduct your inspection
The inspector should always include in the inspection notes the names of individuals who
granted, denied, or revoked consent to enter.
Remember: Once granted, consent may be limited or revoked at any time.
CONDUCTING THE INSPECTION
Interacting with Facility Representatives
Since the Inspection Program's inception in 2007, inspectors have worked hard to create and
maintain good relationships with facilities in the routine inspection program. We have observed
that, more often than not, good relationships foster cooperation and compliance.
It is important to keep in mind that as you revisit facilities for inspection, you will likely be
seeing many of the same facility representatives. Please try to help representatives feel that we
are working with facilities and not against them. Consider the City -facility relationship as a
partnership for compliance. That said, remember your role. City inspectors are not "pals" or
friends of facility representatives, but enforcement officers tasked with upholding the City's
stormwater ordinance.
Care and Control of Evidence
When conducting an inspection, it is important that information and evidence be gathered
using procedures intended to recognize property and privacy rights. Following proper
procedures reduces the possibility that evidence tending to show a party's guilt will be excluded
from use in Water Quality enforcement hearings or if the enforcement case is brought before a
court.
All physical evidence (notes, forms, and pictures) is stored in a secured area on the third floor of
City Hall that is inaccessible to the general public. Additionally, electronic records in the
Inspections Database can only be edited and accessed by staff members in the WQSection. This
level of security ensures that evidence supporting on -going cases is not compromised.
Routine Periodic Inspection Form
The Inspections Program has developed a standard form for use during routine periodic
inspection. The form is designed to walk an inspector through evaluation of the key areas of the
M

industrial activity. By completing each section of the form, the inspector can be sure that he has
evaluated all relevant aspects of the industrial activity.
The inspector must complete every section of the form. Since the form is general enough to be
used at any type of facility, if any particular section of the form is not applicable, the inspector
may make a notation as appropriate. Completely filling in forms not only assists the inspector in
completing Inspections Database data entry, but also assists future inspectors in reviewing
facility history.
Importantly, these inspection forms are public record! Whereas an inspector need not write in
complete sentences on the form, all comments should at least be complete thoughts, especially
considering that members of the public may review the forms in the future. Further, the
inspector should refrain from expressing opinions or making comments and instead record
observations and state facts.
Form Setup
Each criterion to be evaluated during the inspection appears on the form as a question. The
inspector must answer each question with a "Yes," "No," or "N/A" (not applicable) response,
plus a short comment, if necessary. Each question is written such that a "Yes" response means
compliance for that item. A "No" response means non-compliance or violation for that item.
"N/A" should only be selected when the question does not apply to the activities conducted at
the facility.
Header Information
Field
Description
Facility Name
Record the name of the facility to be inspected.
Record the street address of the facility to be inspected. City, state,
Facility Address
and ZIP are not necessary.
Record the name of each facility representative escorting the
Inspection Escort
inspector around the facility or giving consent for the inspector to
self -guide.
If not already known and entered into the Inspections Database,
Latitude/Longitude
determine the latitude and longitude coordinates of the facility
using, preferably, a field method. Alternatively, use City GIS webmap
or Google Maps to determine coordinates.
Date
Record the month, day, and year of the inspection.
Time Start/Time End Record the time the inspection actually began and actually ended.
Record first the name of the lead inspector, then initials of secondary
Inspector Name
inspectors present for the inspection.
P011

Record the XX-ISWI-XXX number, determined from the inspection
Inspection Number database (refer to the Inspections Database User -Administrator
Guide for instructions).
Illicit Discharges & Connections
Field
Description
Check the site's outfalls for visual and olfactory indicators of illicit
Is site free of illicit and non -
and unpermitted discharges. If the site has no discrete outfalls,
permitted discharges?
walk the perimeter of the site and make observations.
Check the site storm drains for unidentified pipes. Examine the
Is site free of illicit
interior spaces for floor drains and "ad hoc" sink drains. Dye test if
connections?
necessary.
What is an Illicit Discharge?
The City of Durham's simple educational slogan, "Only Rain in the Drain" promotes the general
rule that any substance that's not entirely rainwater ("non-stormwater") may not be put into
the storm drainage system. Generally, an "illicit discharge" is a non-stormwater discharge into
the storm drainage system. It's important to understand that no illicit discharge occurs unless
and until the substance actually enters the drainage system.
According to City Code § 70-493, the "drainage system" is:
...the system of natural and constructed conveyances for collecting and transporting
stormwater, whether publicly or privately owned. It includes lakes, ponds, rivers, perennial
and intermittent streams, connected wetlands, open ditches, catch basins and other inlets,
pipes, sewers, drains, culverts, and, in addition, created stormwater management facilities
that provide partial treatment by passive means such as wet detention ponds, detention
basins, and stormwater wetlands. The MS4 and waters of the state within the city are
components included within the drainage system, among other components.
City Code § 70-511(a) states the general rule prohibiting illicit discharges:
Prohibition. The discharge, emission, disposal, pouring, or pumping, directly or
indirectly, to the drainage system of any liquid, solid, gas, or other substance, other than
stormwater, is an illicit discharge and is prohibited, except as allowed in section 70-513.
This prohibition also includes airborne emissions where such emissions deposit
pollutants into the drainage system.
Direct vs. Indirect Illicit Discharges
§ 70-511(a) includes discharges "directly or indirectly." A direct illicit discharge is one where the
non-stormwater substance is dumped, poured, pumped, or otherwise aimed toward and flows
30

into the drainage system by its own force. An indirect illicit discharge is one where the
substance was deposited in an area where rainwater or snowmelt carried it into the drainage
system.
Direct discharge examples:
• An auto mechanic garage also sells washing services onsite. There is no wash pit or
other containment device set up. The dirty water from the cars runs off the pavement
and into a nearby storm drain.
• A tanker truck transferring chemicals to a factory develops a leak in the transfer hose
and chemicals spill onto the ground and run 20 feet across pavement and then into the
storm drain.
Indirect discharge examples:
• There is a business washing cars in a parking lot. The workers use a vacuum to clean car
interiors. At the end of the day, they scatter the vacuum contents on the parking lot far
from any storm drains. During the night, a rain storm washes the vacuum contents into
the storm drain.
• Oil leaks from a car outside on the lot at a mechanic's garage. The mechanic doesn't
clean up the puddle of leaked oil. It rains before he cleans it up. Stormwater runoff
carries the oil to the storm drain.
Exception to the Illicit Discharge Rule: NPDES-Permitted Facilities
If an industrial facility or operation has been issued a NPDES Stormwater Permit, then the
permit authorizes stormwater discharges associated with the industrial activity, provided the
facility or operation is in compliance with all of the requirements and conditions in the permit.
The term "associated with the industrial activity" means directly related to manufacturing,
processing, or raw material storage areas at an industrial site. Permitted discharges that are in
compliance with permit conditions are allowable under State law and are not illicit discharges
under the City of Durham's ordinance (see City Code § 70-513(1)).
For example, if a business has been issued a "Transit and Transportation" (NCG08) NPDES
Stormwater Permit, then the permit requires (among many conditions) secondary containment
for "bulk storage of liquid materials," a stormwater management strategy for vehicle and
equipment cleaning areas, spill prevention and response procedures, preventative
maintenance, and employee training. The permit specifically excludes from coverage "wash
water from steam cleaning operations."
Stormwater discharge from the maintenance and material storage areas contaminated with oil,
grease, and sediment is considered a "permitted stormwater discharge," provided that the
31

operator complies with the conditions of the NPDES permit. This is because oil, grease, and
sediment are foreseeable stormwater pollutants coming from this industry type. However, if
that same business was discharging sewage, or were allowing discharges associated with steam
cleaning to enter the stormwater drainage system, those discharges would be illicit, because
the sewage is not foreseeable from a transit and transportation activity and the steam cleaning
is specifically unpermitted.
In addition, NPDES stormwater permits almost always have some variation of the following
permit condition:
The stormwater discharges allowed by this General Permit shall not cause or contribute
to violations of Water Quality Standards.
When an inspection uncovers a discharge that may potentially involve a violation of water
quality standards, coordination with the Water Quality Environmental Planning & Compliance
Analyst supervising the City's water quality monitoring program is necessary. Though, under
normal circumstances, the discharge may be allowed by permit, if it causes or contributes to a
water quality violation, the discharge will not be allowed.
What is an Illicit Connection?
According to City Code § 70-493, an illicit connection
means any drain, junction, or conveyance, whether on the surface or subsurface, that
can discharge nonstormwater discharges, such as sewage, process wastewater, or wash
water, to the MS4 or to watercourses. Illicit connections include, but are not limited to,
interior floor drains, whether or not previously allowed under the building code.
Most commonly, inspectors find illicit connections at small business facilities, such as auto
mechanics. Often, the buildings will be old; predating a time when floor drains were plumbed
into oil -water separators leading to the sanitary sewer system (the proper method). The
inspector may need to conduct a dye test of the drains if unsure of the connection. Other times,
an auto service shop may install a wash sink where there is no plumbing service. Consequently,
the sink may have a drain line simply running out the building or into a storm drain. In all cases,
the facility management has the burden of proving that drains are properly connected to the
sanitary sewer system.
32

General Site Condition
Field
Description
Are pollutant -generating
Evaluate the operation's exposure to stormwater. If there is
activities conducted in a
exposure of industrial activities, can those activities be
location or manner that
reasonably conducted in a way to limit or eliminate exposure?
reduces the risk of illicit
Are facility staff already taking reasonable steps to prevent
discharge?
pollution? Is the exposure fairly minor?
Observe the grounds and especially the entrances and exits of
Are the grounds reasonably
facility buildings for signs that pollutants are not being
free of spills, leaks, fugitive
controlled. Keep in mind that this is an industrial activity and
materials, track -in, and
cannot be expected to be perfectly clean. For example, some
track -out (given the
drips of oil here and there are to be expected at a mechanic
activities onsite)?
shop or garbage truck parking area.
Are facility storm drains
Examine all or a representative sample of all site storm drains.
free from obstructions and
Check for signs that pollutants are entering the drains due to
signs of pollutants?
the site's industrial activities.
If the site has one or more Stormwater Control Measures
Are stormwater
(retention pond, bioretention area, etc.), inquire into and
management devices and
examine the inspection records. If compliance issues are
measures maintained and
observed, communicate those concerns to Stormwater
functioning properly?
Development Review.
Pollutant, Container, and Tank Management
This section relates to hazardous and other regulated wastes. Ordinary solid waste and trash is
addressed by a later section. If the site has hazardous or regulated materials and waste storage,
the inspector should examine those areas (this includes storage of motor vehicle fluids, both
new and waste).
33

Field
Are containers sealed,
labeled, and in good
condition? (no rust,
corrosion, bulges, dents)
Is secondary containment
and cover for pollutants
(fluids, solids, parts, etc.) in
use where required?
Is secondary containment
free of any cracks, holes, or
evidence of leaks?
Description
Containers should always be sealed when not in use. Labels are
required and are especially important if the contents spill.
Finally, any container that is not in good condition must be
disposed of promptly, its contents transferred to a good
container, or the entire thing should be overpacked into a
salvage container.
The general rule for storage of pollutants outside exposed to
stormwater is secondary containment and cover. The
containment must have sufficient capacity to contain 10% of
the volume of containers or the volume of the largest
container, whichever is greater. The cover must protect both
the container and the secondary containment from
precipitation. Both the containment and cover may be a high
or low -budget as necessary to work properly.
Examine the secondary containment for signs of leaks or
instability.
Check for pipes or valves used to drain the secondary
containment. They should be closed tightly at the time of
Are secondary containment
inspection. If signs of pollutants are visible leading from the
drain valves maintained
drain, or the drain is open at the time of inspection without
locked closed?
proper cause, the inspector should require installation of a lock
or permanent seal.
The contents of secondary containment must be properly
Are containment drain logs
disposed of, rather than simply drained to the MS4 if there are
and release observation I signs of pollution inside. If the containment is drained, a log of
records being maintained? releases should be kept with the date, time, visual
observations, and name of person making the release.
Are storage areas clean,
organized, safe to navigate,
All areas where pollutants are stored should meet these
and are materials properly
criteria. Storage of incompatible chemicals may lead to
segregated to prevent
significant illicit discharges and health and safety issues.
cross -contamination
and/or reaction?
34

Automotive Activities
As the heading implies, this section will only be applicable to those facilities where automotive
activities (mostly service) is conducted. Remember that automotive service may be one of
many different industrial activities conducted on a site.
Field
I Description
This is specifically required by City Code § 70-515(b)(3). There
Is all vehicle service
are three exceptions: 1) emergency road service; 2) glass
conducted inside covered
repair; and 3) electrical service. We conditionally allow tire
work bays?
replacement as long as the outdoor area is neat and any leaks
are cleaned up immediately.
All vehicle washing must be conducted so as to contain, collect,
and properly dispose of wastewater into the sanitary sewer
Are vehicle washing
system. Please refer to the Water Quality Unit's Proper
activities conducted with
Containment, Collection, and Disposal of Wastewater from
proper controls?
Mobile Vehicle Washing guide for specifics on compliant
practices.
Inspectors should take the time to review City Code § 70-516
as well. This section discusses the requirements for junkyards
and other premises where junked, salvaged, and unlicensed
If there are more than 9
vehicles are stored. This rule applies to any premises, even
junk, salvaged, or
those not specifically in the automotive business. The inspector
unlicensed vehicles on the
should also take note of the specific Stormwater Pollution
premises, is there a SPPP?
Prevention Plan requirements for such a premises. The SPPP
should be complete, up to date, and readily available for
review upon request of the inspector. Failure to develop or
produce the SPPP upon reasonable request is a violation.
Spill Response
With regard to spill cleanup kits, the City Code only specifically requires them for automotive
activities (see § 70-515). However, spill preparedness and cleanup is a common type of Best
Management Practice (BMP) and, accordingly, an inspector may require a spill cleanup kit or
kits at any industrial activity "where the location or manner of storage of pollutants on property
may cause a significant illicit discharge, or where an illicit discharge has previously occurred on
property." (City Code § 70-511(c)(1))
35

The Inspections Program maintains the guidance document for automotive activity spill cleanup
kits. That document, called Spill Cleanup Kit Guidelines for Automotive Activities, is accessible
on the Public Works server.
Field
Are spill kits available and
stocked as required?
Are spills cleaned up
promptly and completely?
Are significant spills
reported as required?
Description
The facility should: 1) have an appropriate number of spill
cleanup kits to cover its grounds; 2) keep those kits well -
stocked with supplies appropriate for the types of pollutants
and materials handled onsite; and 3) maintain the kits in areas
readily available and known to all employees.
Examine the outdoor areas, especially those outside
maintenance bays and fleet vehicle parking areas. For auto
mechanics, examine the entire parking area. Remember to
examine under vehicles for unchecked leaks. Accidents
happen. We recognize that; and it is not necessarily a violation
for there to be a spill as long as the spill is cleaned up
immediately. The inspector should use judgment in
determining if there is an excess of unaddressed spills or if
spills have not been completely cleaned.
The facility must report certain types of spills (see the Spill
Reporting section on page 53 for requirements). The inspector
should inquire into the site's spill history and reporting. If the
inspector observes a reportable spill during the inspection, the
inspector should instruct the facility representative to report
the spill immediately.
Trash and Solid Waste Management
This section refers only to non -hazardous and non -regulated wastes. The inspector should
always take the time to examine these areas, which can be significant sources of stormwater
pollution.
Field
Are dumpster pad and
other waste collection
areas kept clean to avoid
stormwater
contamination?
Description
Simply, trash should be put into the proper containers (carts,
dumpsters, etc.) and remain in those containers. Further, the
areas around those containers should be kept clean. Also pay
particular attention to trash compactors, which have hydraulic
lines that may be leaking.

All trash should fit within the facility's waste containers
without overflow.
Carts and dumpsters should be reasonably water -tight to keep
Are waste collection
rain out and garbage leachate in. The inspector should require
containers in good
cart or dumpster replacement or repair when the condition
condition, lidded, and have
indicates probable stormwater pollution. Broken or missing
drain plugs?
drain plugs is a common issue.
Are waste collection
If the facility is of a type that uses hazardous or regulated
containers free of
materials, the inspector should make at least a cursory
hazardous materials and
examination of the waste disposal areas for signs of improper
liquids?
disposal of these wastes.
Other Best Management Practices
Field Description
The inspector should remember to review the facility
If BMPs were required by inspection history and know if implementation of one or more
the City, are they being BMPs was required in the past. The inspector should check for
implemented? continued compliance with those requirements, if still
applicable.
Do currently implemented Simply, is the status quo at the facility enough to reasonably
facility BMPs appear to be protect stormwater from the activities onsite? If not, then the
effective in managing
stormwater pollution?
inspector should require appropriate BMPs be developed and
implemented at the site to control pollutant sources observed.
Are erosion control
Whether or not the facility is under construction, the inspector
practices implemented, if
should examine the grounds for significant erosion problems
necessary?
and require erosion control practices, if necessary.
This is likely a new concept for many facility representatives.
Do employees inspect and
The inspector should encourage them to routinely inspect site
maintain the onsite storm
storm drains for signs of pollutants and ensure that the drains
sewer system?
are free from obstruction.
All employees at a facility should know to where the storm
Do employees know to
drains discharge. The inspector is free to make an inquiry of
where the drains
any employee onsite. Facility representatives should be
discharge?
encouraged to inform all employees of how storm drains work.
(And in fact, some facilities are required to.)
37

NPDES Stormwater Permit
This section will only apply to those facilities required to have NPDES Stormwater Permits
(general or individual). Remember that a facility may apply for a No Exposure Certification in
lieu of a Permit if it meets the requirements.
Field
Description
The inspector should take note of the activities conducted
onsite. If the primary operation is an activity for which a NPDES
Does facility have a NPDES general stormwater permit is required, the site should already
permit or NCGNE cert. if
required?
Is the current Certificate of
Coverage available for
confirmation?
For NCGNE: Are annual
self-recertifications
completed and available for
review?
have one. If not, the inspector should require that the facility
file a Notice of Intent with NC DEMLR Stormwater Permitting.
Alternatively, the facility may file an application for No
Exposure.
If the facility has a NPDES Stormwater Permit or No Exposure
Certification, then it must have a Certificate proving that it
applied for and was granted current coverage.
This section only applies to No Exposure facilities. These
facilities must annually re -certify that they meet the
requirements for No Exposure.
Stormwater Pollution Prevention Plan
Stormwater Pollution Prevention Plans (SPPPs) are documents developed and implemented by
a facility or operation for these purposes:
1. To implement and maintain Best Management Practices (BMPs) that identify, reduce,
eliminate, and/or prevent the discharge of stormwater pollutants.
2. To prevent violations of surface water quality, groundwater quality, and sediment
management standards.
3. To eliminate illicit discharges to stormwater drainage systems.
Generally, the only facilities that will be required to have SPPPs are:
1. Facilities with NPDES Stormwater Permits (general or individual)
2. Facilities required to have one by a City Stormwater Inspector, pursuant to City Code §
70-511 c or § 70-516.
The inspector is encouraged to review the Stormwater Pollution Prevention Plan Development
Guide created by the Inspections Program for an in-depth discussion of all required elements of
91-

a SPPP. Additionally, each NPDES General Stormwater Permit has a full description of required
SPPP sections (the descriptions do not differ between general permits revised in the same
year). The table below will only have a brief descriptor of each SPPP requirement. The inspector
should keep in mind that, unless following the City standard format (which is optional), SPPPs
will be in all manner of formats with different organization schemes. If the inspector cannot
find any particular required section, he should ask the facility representative to assist.
Failure of the facility to include any required SPPP section constitutes a failure to have
developed a complete SPPP. (This is a separate violation from failure to maintain an updated
SPPP)
Field
Description
�`
The facility's SPPP must be produced at the time of
Is the SPPP available for review?
inspection. Failure to produce the SPPP for the inspector
should be considered failure to have developed a SPPP.
This should be a map showing the reader generally
where the facility is located relative to major
geographical features, such as roads, lakes, streams, etc.
General Location Map
It may or may not have topography. Commonly, facilities
will use a USGS topo map or a simple capture from
Google Maps.
This is a separate map (or maps) displaying much more
detail of the facility and grounds. The inspector can refer
Site Map
to the backside of the official inspection form for a
"cheat sheet" list of required map contents.
A simple discussion, written for the layman reader, of
Narrative Description of Facility &
the layout of the grounds and types of activities
Operations
conducted at the facility.
A list of the potential stormwater pollutants stored
Potential Pollutants Summary
onsite, with respective approximate quantities.
A list of all secondary containment installed for outdoor
Secondary Containment Records
storage of potential pollutants.
Every facility with a SPPP must make arrangements, in
writing, for twice yearly stormwater pollution prevention
self -inspections. This section should discuss when
Inspections and Evaluations Plan
inspections are conducted, who conducts them, how
issues are addressed, and provide an example inspection
form. The evaluations plan is only applicable to facilities
IC

Employee Training Plan
Runoff Monitoring Plan
required by NPDES Permit to have a SPPP. This section
should discuss who is responsible for annual evaluation
of the SPPP and BMPs, when the annual review is
conducted, and how the document and procedures are
updated.
This is only applicable to facilities required by NPDES
Permit to have a SPPP. This section should discuss who is
in charge of the training program, which employees
must be trained, and the content of the training
program.
This is only applicable to facilities required by NPDES
Permit to have a SPPP. This section should discuss who is
responsible for the Permit -required runoff monitoring
(visual and analytical), how samples are collected and
visually inspected, which laboratory service is used for
analysis, and how reports are submitted to NC DEMLR.
This section should list the members of the site Pollution
Pollution Prevention Team Prevention Team; the people in charge of stormwater
Members management onsite. This should list individuals or job
titles. Phone numbers are optional, but recommended.
BMP Summary
Spill Prevention & Response
Plan/Procedures
Preventative Maintenance and
Good Housekeeping Program
This section should house descriptions of all of the
facility's BMPs. Usually, the more complex or high -risk
the industrial activity, the more BMPs it will have in the
SPPP. The inspector should read over the BMPs and feel
free to ask questions about how they are implemented.
The inspector should also look for evidence of
implementation.
This is always a required BMP. The facility must have a
plan for preventing, containing, and cleaning up spills.
This includes staff responsible for response as well as
reporting procedures.
This is always a required BMP. The facility must have a
plan for routine maintenance of equipment and vehicles
and for "good housekeeping," which refers to general
cleanliness and neatness of the facility and grounds. The
inspector should evaluate the effectiveness of these
40

BMPs when walking the grounds and should require any
remedial maintenance or housekeeping as appropriate.
This is a required BMP, if applicable. Remember that
Vehicle and Equipment Cleaning wastewater from washing activities must be directed
Areas BMPs into the sanitary sewer system. This BMP must address
BMP Feasibility Study
Annual Update and Review
Report
Annual Certification of Non-
Stormwater Discharges
Annual BMP Effectiveness Review
Spill History Update
Annual Review of Runoff
Monitoring
that key aspect.
This is only applicable to facilities required by NPDES
Permit to have a SPPP. This section is a review of the
site's activities and BMPs, and whether it is feasible to
alter either to reduce or eliminate exposure to
stormwater.
This is only applicable to facilities required by NPDES
Permit to have a SPPP. NPDES facilities are required to
review and update their SPPPs annually. Updates are
required whenever site conditions or activities change
such that exposure or risk is changed. Updates are also
required for changes in staff responsible for SPPP tasks.
This is only applicable to facilities required by NPDES
Permit to have a SPPP. Each year, the facility must certify
that it has evaluated each stormwater discharge outfall
and affirms that there is no evidence of non-stormwater
discharges.
This is only applicable to facilities required by NPDES
Permit to have a SPPP. The facility must also write up an
annual report analyzing the effectiveness of facility
BMPs. If any BMPs were not performed adequately,
plans must be made for improving performance of those
duties.
Every SPPP must have a complete history of significant
spills that occurred onsite. The history must be updated
at least annually, but preferably after every spill event.
This is only applicable to facilities required by NPDES
Permit to have a SPPP. NC DEMLR requires that, in
addition to submission of individual Discharge
Monitoring Reports for each required monitoring event,
an annual summary sheet be submitted, which includes
41

the results from every monitoring event conducted
during the permit year.
Stormwater Runoff Monitoring
This section is only applicable to facilities with a NPDES Stormwater Permit. The inspector
should review and become familiar with the permit requirements (frequency of sampling,
discharge characteristics, type of monitoring required) before conducting the facility's records
inspection.
Most of the NPDES General Stormwater Permits (but not all!) require that stormwater runoff
from each of the facility's outfalls be monitored on a quarterly basis.
Measurable Storm Events
Samples must be collected from each outfall during a "measurable storm event." This is a
rainstorm that:
• Occurs at least 72 hours after the previous measurable storm event,
• Occurs during the facility's operating hours,
• Does not coincide with adverse weather conditions, and
• Is characteristic of the volume and nature of the permitted discharge
Samples must be collected within the first 30 minutes after discharge begins. Analytical and
Visual samples should be collected during the same storm event.
Types of Required Monitoring
Visual (a.k.a. Qualitative)
This type of monitoring is conducted on -site and consists of a visual inspection of a stormwater
runoff sample. The sample is described according to the following characteristics:
• Color
• Odor
• Clarity
• Floating Solids
• Suspended Solids
• Foam
• Oil Sheen
• Other obvious indicators of pollution
2YJ

These observations are recorded on a Qualitative Monitoring Form for each outfall. A copy of
this monitoring report must be retained and filed with the facility SPPP.
Analytical (a.k.a. Quantitative)
This type of monitoring consists of a laboratory analysis of a stormwater runoff sample and
comparison of the results to benchmark values set by the facility's NPDES permit.
As an example of benchmark values, take a look at the values for the NCG08 Permit:
Table 2: Summary of Quarterly Baseline Sampling Requirements for Stormwater Discharges
Parameter
Receiving Stream
Code
Parameter
Classification
Units
Benclimr�rk
Freshwater
Standard
5-9
00400
pH1
Saltwater
Standard
6.8-8.
Total Suspended Solids
All, except...
mg f L
100
C0530
HQW, ORW, Tr, PNA
mg f L
51)
(TSS]
Non -polar Oil & Grease per
00552
EPA Method 1664
All
mg/L
1
(SGT-HEM]
New Motor Oil or Hydraulic
NCO1L
Oil Usage
All
Gal/Mor.n
45529
Total Rainfall of Sampled
All
Inches
-
Event
i Crab samples shall be analyzed for pl I within 15 minutes.
The facility may contract with its chosen laboratory service company prior to sampling to
ensure appropriate processing time and for specific sampling instruction and chain -of -custody
procedures. Sampling materials (bottles) may also be available from the laboratory services
company.
Within 30 days of receipt of monitoring results, the Discharge Monitoring Form must be filed
electronically with DEMLR. A copy must be retained and filed with the facility SPPP.
If a facility's sampled runoff exceeds or is outside of the range of a benchmark, the facility is
subject to the additional "Tier" requirements found the Permit (as seen below). Importantly, a
benchmark exceedance is not a permit violation if the permittee is otherwise in compliance
(except in the case of wastewater monitoring). An exceedance is merely a "trigger" for
additional requirements.
43

If any sampling result is above the benchmark value for any parameter at any outfall, then the
permittee shall operate under the Tier One response table below.
Timeline from Receipt
of Sampling Results
Tier One Required Response/Aci ion
Continuously
i_ Document the exceedance and each required response/action in the
S WPPP in accordance with E-5(b) above.
Within two weeks
il. Nobfy the Division's Regional 0Mee of the exceedanee date and value
via email or, when it is developed, an electronic form treated by the
Division for reporting exceedances.
iii. Conduct stormwater management inspection.
iv. Identify and evaluate possible causes of the benchmark exceedance.
Within one month
v. Select specific, feasible courses of action to reduce concentrations of
the parameters] of concern including, but nat limited to, source
controls, operational controls, or physical improvements.
Within two months
vi. Implement the selected feasible actions.
If any two consecutive sampling results for the same parameter at the same outfall are above
the benchmark value, then the permittee shall operate under the Tier Two response table
below. The facility will remain in Tier Two status until three consecutive samples are under or
inside the benchmark ranges for all parameters.
Timeline from
Receipt of Sampling
Tier Two Required Response/Actian
Results
Continuously
i. Document the exceedance and each required response/ action in the
SWPDPP in accordance with l;-6fc1 above.
Within two week.,,
ii. Notify the Division's Regional Office in writing of the exceedance date and
value.
iii. Conduct a stormwater management inspection.
iv- Identify and evaluate possible causes of the benchmark exceedance.
Within one mont.-
Select specific, feasible courses of action to reduce concentrations of the
parameters) of concern including, but not limited to, source controls,
operational controls, or physical improvements.
Within two months
Vi. Implement the selected feasible actions.
vii. Implement monthly monitoring at every outfall where a sampling result
exceeded the benchmark value for two consecutive samples for all
parameters until three samples in a row are below the benchmark value.
MI

If any four sampling results within the permit term for any single parameter are above the
benchmark value at a sampled outfall, the facility shall operate under the Tier Three response
table below. The facility will remain in Tier Three status until three consecutive samples are
under or inside the benchmark ranges for all parameters.
Timeline from Receipt
of Fourth Sampling
Tier Three Required Response/Action
Result
continutousl.v
L Document the exceedances and each inquired response faction in
the SWPPP in accordance with l;-7fc1 above.
ii. Implement or continue monthly monitoring for all parameters at
the subject outfall and continue until three samples in a row are
below the benchmark value.
Within two weeks
iii. Notify the Division's regional Office in writing of the affected outfall,
four exceedance dates and values,
iv. Conduct astormwatermanagement inspection.
v. Identifyand evaluate possible causes of the benchmark exceedance.
Within one month
vi. prepare an Action Plan that should include .specific, feasible courses
of action to reduce concentrations of theparameter(s) of concern
including, but not limited to, source controls, operational controls,
or physical improvements and submit to the Division's Regional
Office for review and approval.
Upon Division Approval
vii. Implement the approved Action Plan,
Upon Completion of
viii.Notify the Division's Regional Office of Action Plan completion.
Approved Action Plan
Sampling Safety
Employees are not required to sample runoff if doing so would endanger personal safety or if
the outfalls are inaccessible.
If an adverse condition prevents staff from sampling during a sampling period, a Discharge
Monitoring Report must be filed indicating the reasons why a sample could not be taken.
Field
Has required stormwater runoff
monitoring been conducted?
Description
Check to see how often the facility is required to conduct
visual and analytical sampling. Has the facility provided
documentation to prove the sampling was done? Also
check to make sure the facility mailed the reports to the
State.
Glk,

The NPDES Permit requires that records of runoff
Are records of runoff monitoring monitoring be kept on site for at least 5 years. Extra
maintained (5 years)? records may be archived. For bulk reasons, these are not
always stored in the same physical book as the body of
the SPPP.
I Compare the results of the lab analysis with the
benchmark values on the permit. Note: a result outside
Are monitoring results within
the benchmark allowance is not a violation. It is a trigger
benchmark allowances?
for additional stormwater management tasks. (See the
Tier One through Three figures above.)
If sampling results did not conform to the permit
Are Tier 1/2/3 responses
benchmark allowances, were the proper Tier responses
completed as required?
completed? The inspector should be familiar with how
Tiers progress and the work required at each level.
Quarterly Facility Self -Inspections
Self -inspections are only required for facilities with NPDES stormwater permits and any other
facility specifically required by the Inspections Program. Some facilities may conduct self -
inspections to comply with a number of other agency requirements. It is acceptable for facility
staff to conduct combination inspections, as long as the inspection checklist contains sufficient
stormwater pollution prevention items. The inspector should use their own judgment in
determining sufficiency. The facility is welcome to use the City's stormwater inspection form. A
copy should be furnished upon request.
When reviewing self -inspection records, the inspector should take note of whether the facility
pollution prevention team is actively trying to identify issues and work toward correcting them.
Sometimes, it is a good sign to see multiple comments and concerns on a self -inspection sheet
and later notes on correction. This can support a finding that the facility is running an effective
stormwater management program. The inspector should be skeptical of perfect self -inspection
records. Likewise, if a particular issue appears multiple times on self -inspections, the inspector
should inquire as to what actions have been taken to correct the issue.
Field I Description
Have the required self-
NPDES Permitted facilities must conduct quarterly self -
inspections been completed? inspections. Other facilities conduct them as specified by
City requirement.
M.

Are copies of inspections and The NPDES Permit requires that these records be kept
follow-up records maintained (5 for a minimum of 5 years. For bulk reasons, these are not
years)? always stored in the same physical book as the body of
the SPPP.
Annual Employee Training
Annual employee stormwater pollution prevention training is only required for facilities with
NPDES permits and any other facility specifically required by the Inspections Program. Some
facilities may conduct various types of employee training to comply with a number of other
agency requirements. It is acceptable for facility staff to conduct combination trainings, as long
as the training contains sufficient stormwater pollution prevention material. The inspector
should use his own judgment in determining sufficiency.
Field
Description
These should be evidenced by training log forms. Some
Have required annual employee
facilities have a separate Training/HR department that
trainings been conducted?
maintains these records and can furnish them on
demand.
The NPDES Permit requires that these records be kept
Are employee training records
for a minimum of 5 years. For bulk reasons, these are not
maintained (5 years)?
always stored in the same physical book as the body of
the SPPP.
Additional Comments
This space is provided for the inspector to make additional notes and elaborate on checklist
items, as necessary. To aid future review, especially by other inspectors, management, or the
public, the use of complete sentences or an organizational structure (lists, diagrams, etc.) is
encouraged.
If the inspector will be citing violations at the facility, the inspector should note those violations
specifically in the Additional Comments section.
Results and Signature
In this final section, the inspector must select the compliance status of the facility as of the
completion of the inspection. There are four choices:
Cfl

Based on observations made during this inspection and review of pertinent documents, this facility:
Is in compliance with all applicable stormwater regulations.
❑ Will be issued a Notice of Requirement. (NOR) The operation is in need of one or more Best Management
Practices (BMI's) to correct or prevent violations. The NOR will describe the BMI's to be implemented, as
well as deadlines for implementation.
❑ Will be issued a Notice of Violation (NOV). Noted violation(s) (see comments) must be corrected by the
deadlines indicated in the NOV. The NOV will describethe administrative andlor civil remedies that the City
of Durham may pursue.
Is a City -operated facility at which one or more stormwater pollution prevention issueswere observed. The
pollution prevention team will be issued a summary report of this inspection's findings and recommended
corrective actions.
Inspector Signature:
D ate:
The first choice confirms that the facility is in compliance. The inspector may issue a Notice of
Compliance upon request of the facility. The second choice identifies that one or more issues
identified at the facility create a need for BMPs. The inspector will define and require these
BMPs for implementation at the facility via a Notice of Requirement. The third choice identifies
that the facility is in violation of one or more sections of the City Code and will be receiving a
Notice of Violation.
The final choice is for use when inspecting municipal facilities only. Since NORs and NOVs are
not issued to municipal facilities, this choice identifies that compliance issues were identified,
an inspection report will be sent to the facility pollution prevention team, and a follow-up
inspection will be scheduled and conducted to check for compliance.
Once the appropriate compliance status is selected, the inspector should sign and date the
form.
Photographs
The inspector should always take photographs of the facility and grounds. Photos are important
to provide additional proof that the inspection actually occurred, document good work that the
facility pollution prevention team is doing, highlight interesting structural or operational BMPs,
and document proof of violations and compliance issues.
Upon returning to the office, the inspector should upload all inspection photos into their
respective facility folders on the Public Works server (see the section on data storage on page
50).

On occasion, a facility may be reluctant to allow photography onsite. This may be due to the
presence of sensitive trade secrets or for rules set by U.S. Homeland Security (usually only parts
of facilities handling unusually dangerous hazards or certain areas of public utility facilities). The
inspector should reassure the facility representatives that should it be necessary to take photos
of sensitive areas, trade secrets are specifically protected as confidential by City Code § 70-
525(c). Secured areas protected by U.S. Homeland Security rules should not be photographed.
In the event that facility representatives continue to be reluctant to allow photography, the
inspector may choose to cite the facility for obstruction of a City inspection, obtain an
administrative search warrant, or both.
Review Results with Responsible Party
The inspector must clearly identify all observed City Code and NPDES Permit compliance
deficiencies and required corrective actions to the responsible individual(s) during the
inspection. All questions should be answered or referred to the appropriate City staff members
that can best provide a response. When discussing corrective actions, City staff should avoid
requiring specific actions and instead describe the required end result. For example:
A vehicle repair shop has a problem with cars leaking oil and other fluids onto the
pavement. Those fluids are washed into the storm drainage system when it rains. The
inspector should clearly identify that the compliance issue is a combination of "failure to
clean up spilled materials" and "illicit discharge." An appropriate corrective action would
be to require the management to implement Best Management Practices of their
choosing which prevent motor vehicle fluids from entering the storm drainage system.
Wording the corrective action in this way gives the business management a multitude of
options in finding the best solution for the situation.
The inspector must also be clear in communicating compliance deadlines with the responsible
party. Compliance deadlines should be set after considering a number of factors:
• Severity of the issue or violation
• Complexity of the corrective action
• Requirements of other City departments (for instance, when a structure must be built
and approval from Planning is required)
• Cost of the corrective action (some operations may require extra time to secure funds -
however a temporary action should be implemented during that time)
Under some circumstances, it may be useful to obtain the violator's estimate of how soon a
particular corrective action can be reasonably completed.

PUBLIC WORKS SERVER INSPECTIONS DATA STORAGE
The Inspections Program has its own folder on the Public Works network server. The file path is:
F:\SW\Division Files\Water Quality\Inspections
Private Facility Data Storage
Privately -owned facility documents and materials are stored in the folder:
F:\SW\Division Files\Water Qua lity\Inspections\Private Operations
Within that folder are sub -folders for all private facilities that have been inspected. Inspectors
should upload all photographs, Notices, correspondence, maps, and related materials in the
particular facility's folder. If no folder exists for the facility, the inspector should create it.
All new private facility folders should have this structure:
Name
Date modified Type
Enforcement Documents (NOR. NOV, N...
9!5I20141:24 PM
Filefolder
Inspection Reports
9.15J20141:35 PM
Filefolder
Maps
9�/5I20141:24 PM
Filefolder
NPDES Permit Materials
9/5120141:35 PM
Filefolder
Other Correspondence
915120141:24 PM
Filefolder
Photos
915120141:35 PM
Filefolder
SPPP
915120141:35 PM
Filefolder
Stormwater Sampling Data
9/5l20141:24 PM
Filefolder
This organization scheme was created in September 2014, so facility folders older than that
date may not be organized similarly. Be advised that already existing folders should not be
reorganized, since doing so would break folder links with the Inspections Database (thus
breaking photo reports and displays).
Municipal Facility Data Storage
Municipal facility documents and materials are stored in the folder:
F:\SW\Division Files\Water Quality\Inspections\Municipal Operations
Within that folder are sub -folders for all municipal facilities that are routinely inspected.
Inspectors should upload all photographs, Notices, correspondence, maps, and related
materials in the facility's folder. If no folder exists for the facility, the inspector should create it.
All new municipal facility folders should have this structure:
50

}
Name Date modified Type
Enfor€ement Do€uments (NOR, NOV, N...
9/5/20141:24 PM
Filefolder
Inspe€tion Reports
9/5/2014 1:35 PM
Filefolder
Maps
R/5/2014 1:24 PM
Filefolder
NPDES Permit Materials
9/5/20141:35 PM
Filefolder
Other Correspondence
9/5/2014 1:24 PM
Filefolder
Photos
Re'5120141:35 PM
Filefolder
SPPP
RI5120141:35 PM
Filefolder
Stormwater Sampling Data
9/5/2014 1:24 PM
Filefolder
This organization scheme was created in September 2014, so facility folders older than that
date may not be organized similarly. Be advised that already existing facility folders should not
be reorganized, since doing so would break folder links with the Inspections Database (thus
breaking photo reports and displays).
ENTER INSPECTION RESULTS INTO DATABASE
All inspection notes, results, and photos are entered into the Inspections Database after the
inspection is completed. The inspector should refer to the instructions in the Industrial
Stormwater Inspections Database User -Administrator Guide for guidance in this task.
ISSUE NOTICE OF COMPLIANCE, REQUIREMENT, OR VIOLATION
The inspector must follow the procedures developed for issuing Notices of Requirement (NOR)
and Notices of Violation (NOV), and assessing civil penalties for violations of City Code. This
procedures document can be found on the Public Works network drive and is titled, Water
Quality Enforcement Standard Operating Procedures.
As the inspector can learn from the Industrial Stormwater Inspections Database User -
Administrator Guide, NOCs, NORs, NOVs, civil penalties, and NOPs are automatically generated
by the Inspections Database.
RETURN FOR FOLLOW-UP INSPECTION
Follow-up inspections are conducted with the purpose of returning to a facility to ensure that
actions required for the correction of one or more ordinance violations have been completed. A
full facility re -inspection is not usually conducted at this time. Rather, an inspection focusing on
corrective actions is conducted. Depending on the number, type, and severity of the violations,
a facility may require more than one follow-up inspection.
51

Except in cases where a mix of immediate, short-term (< 3 months), and long-term (> 3 months)
deadlines are necessary, inspectors should consolidate deadlines into a single follow up visit to
conserve time. The inspector uses the "Industrial Stormwater Follow-up Inspection Form" for
recording the results of these inspections. Follow-up inspections are also recorded in the
database. All follow-up inspections receive their own unique inspection (XX-ISWI-XXX) number.
If all corrective actions have been completed, the facility is deemed to be in compliance. If
corrective actions have not been completed as required, a Notice may be issued to the
responsible party.
CITY CODE VIOLATIONS
Citable Violations
Inspectors must be thoroughly familiar with the Stormwater Pollution Control Ordinance. Here
is a list of all the possible City Code violations for which the inspector may cite a facility:
• Illicit Discharge: Failure to contain the discharge of a solid, liquid, or gas, other than
stormwater either directly or indirectly to the drainage system. (Durham City Code Art.
V, Div. 2, § 70-511(a) & (b))
• Illicit Connection: Existence of a pipe, ditch, or other conveyance that carries process
wastewater or wash water to the municipal separate storm sewer system or
watercourses. (Durham City Code Art. V, Div. 2, § 70-512(a))
• BMPs: Failure to implement Best Management Practices to prevent stormwater
pollution, as previously directed. (Durham City Code Art. V, Div. 2, § 70-511(c)(1))(a)
• Hazardous Materials Storage: Hazardous substances that are stored outdoors shall have
secondary containment and shall be stored in a covered area. (Durham City Code Art. V,
Div. 2, § 70-517)
• Spill Response:
o Spill cleanup kit(s) missing and/or inadequately stocked. (Durham City Code Art.
V, Div. 2, § 70-515(a))
o Improper/incomplete cleanup of spilled materials. (Durham City Code Art. V,
Div. 2 § 70-518(a))
o Failure to report a spill to Durham City -County EMS within one working day.
(Durham City Code Art. V, Div. 2, § 70-511(b) and § 70-518(b))
• Automotive Activities:
o Parts stored outside without containment and/or cover. (Durham City Code Art.
V, Div. 2, § 70-515(b)(4))
52

o Fluids stored outside without containment and/or cover. (Durham City Code Art.
V, Div. 2, § 70-515(a))
o Automotive service or maintenance being conducted outside covered service
bays. (Durham City Code Art. V, Div. 2 § 70-515(b)(3))
o Failure to contain and capture vehicle wash water (illicit discharge). (Durham
City Code Art. V, Div. 2, § 70-511(a) & (b))
o Failure to develop and implement a SPPP at a site where there are > 9 junked,
salvaged, or unlicensed vehicles outside exposed to rain. Durham City Code Art.
V, Div. 2 § 70-516(a))
If the compliance issue does not appear on this list, it cannot be cited as a violation of City Code.
SPILL REPORTING
Reporting Major Spills to State Regulators, Generally
Per its MS4 NPDES stormwater permit (Reporting and Record Keeping Requirements section),
the City is required to report to State Emergency Management "all discharges that constitute
an imminent threat to health or the environment."
Investigators should report discharges if they might be toxic, if they involve a sufficient volume
of sewage that actually or might cause a fish kill, if they are likely to be reported to Emergency
Management because of the public impact (odor over a large area), etc.
These reports are to be made "within 24 hours by phone or email to the Division Regional
Office during business hours, or to the NC Division of Emergency Management State Operations
Center hotline outside of business hours."
The Emergency Management State Operations Center hotline number (also known as the State
Warning Point number) is 1-800-858-0368.
Reporting Spills of Hazardous Substances to State Regulators
How to call
The State DEQ Environmental Emergency phone hotline is 1-800-858-0368. When calling, be
prepared to give a statement including: the time and date of the spill, a description of the
incident causing the spill, the type of substance spilled, the approximate volume of the spill, the
responsible parties, and any containment or remedial actions done or underway. Make a note
of the time and date of the call, as well as the person you spoke to. As of the time of this
writing, the State does not assign report numbers to these types of hotline calls.
53

When to call
The quantities and reporting times vary. Hazardous substances are reportable only if the spill
exceeds a reportable quantity threshold. Reportable quantities for hazardous substances are
available at the following website: https://www.epa.gov/epera/consolidated-list-lists
Reporting Petroleum Spills to State Regulators
How to call
The State DEQ Environmental Emergency phone hotline is 1-800-858-0368. When calling, be
prepared to give a statement including: the time and date of the spill, a description of the
incident causing the spill, the type of petroleum spilled, the approximate volume of the spill,
the responsible parties, and any containment or remedial actions done or underway. Make a
note of the time and date of the call, as well as the person you spoke to. As of the time of this
writing, the State does not assign report numbers to these types of hotline calls.
When to call
The reporting requirements for petroleum products are in North Carolina's Oil Pollution and
Hazardous Substances Control Act of 1978, N.C.G.S § 143-215.85(a) and (b):
IF the petroleum discharged, released or spilled:
• is 25 gallons or more, OR
• causes a sheen on nearby surface water, OR
• is 100 feet or less from surface water body,
THEN the person owning or having control over the oil must immediately take
measures to collect and remove the discharge, and report the discharge to NCDEQ
within 24 hours of discharge, and begin to restore area affected by discharge.
IF the petroleum released or spilled:
• Is less than 25 gallons, does not cause a sheen on nearby surface water, AND is
more than 100 feet from surface water bodies,
THEN the person who owns or has control over the oil must immediately take
measures to collect and remove the discharge. If it cannot be cleaned up within 24
hours of the discharge or causes a sheen on nearby surface water, the person must
immediately notify the NCDEQ.
If the petroleum released or spilled in any circumstances does not meet one of the above
requirements, or is not permitted by GS 143-215.1, or it is not pursuant to a rule adopted by
54

the Environmental Management Commission or, a regulation of USEPA, it must be reported to
NCDEQ immediately.
INSPECTION FIELD AUDITS
The purpose of conducting a field audit of stormwater inspections is to document and
determine if proper procedures have been developed and are being followed during each
inspection. The results of these audits and recommendations will help ensure consistency
between inspections regardless of staff involved. Notes are taken on general guideline
compliance and may address any deviations or ways to improve the inspection process. The
role of the auditor is to observe and report while offering no assistance to the lead inspector,
though relevant questions may be asked. Field audits will be conducted quarterly and
summaries will be located in the inspections folder on the Public Works network drive.
55

Stormwater Inspection Program Guidelines Mar
2022 (signed)
Final Audit Report
Created: 2022-03-24
By: James Azarelo ([e-mail])
Status: Signed
Transaction ID: CBJCHBCAABAAK-d1ArxVUFFpiD-cW9nXdlzOuTBcnTSN
2022-03-24
"Stormwater Inspection Program Guidelines Mar 2022 (signed)"
History
Document created by James Azarelo ([e-mail])
2022-03-24 - 5:05:40 PM GMT
Document emailed to Michelle Woolfolk ([e-mail]) for signature
2022-03-24 - 5:06:32 PM GMT
Email viewed by Michelle Woolfolk ([e-mail])
2022-03-24 - 6:21:07 PM GMT
&0 Document e-signed by Michelle Woolfolk ([e-mail])
Signature Date: 2022-03-24 - 6:21:40 PM GMT - Time Source: server
Agreement completed.
2022-03-24 - 6:21:40 PM GMT
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