Richland County Industrial and High Risk Runoff Program. Alan Trim BP Barber

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1 Richland County Industrial and High Risk Runoff Program Alan Trim

2 Industrial and High Risk Runoff Program Program Components: Richland County Storm Water Ordinance. Industrial and High Risk Facility Database. Inspection Schedule. Inspection Procedures. Self-Monitoring Program.

3 Richland County Storm Water Ordinance Provides Authority for: Inspections to implement the industrial and high risk inspection schedule as required by the Phase I NPDES Storm Water Permit. Self-Monitoring at industrial and high risk facilities as deemed necessary based on DPW storm water inspections, wet weather monitoring program, and dry weather screening.

4 Regulatory Requirement: Richland County Phase I NPDES Storm Water Permit Identify and locate industrial and high risk facilities discharging storm water to the Richland County municipal separate storm sewer system (MS4). Control pollutants in storm water discharges from industrial and high risk facilities. Development and implementation of an Industrial and High Risk Runoff Program.

5 Industrial And High Risk Facility Database Industrial and high risk facility definition Industrial and high risk facility database Notice to industries Annual database update

6 Industrial And High Risk Facility Database Definition: Landfills RCRA TSDFs EPCRA reporting facilities Industrial facilities Other

7 Industrial And High Risk Facility Database Database: Facility information Surface water body Watershed management unit

8 Industrial And High Risk Facility Database Notice To Industries: Publish in business section of local newspaper Requires industrial and high risk facilities to notify Richland County of storm water discharges into MS4

9 Industrial And High Risk Facility Database Annual Database Update: New building permits New business licenses Hazardous material management plan submittals EPCRA Reporting Field surveillance

10 Program Routine inspection Inspection Protocol Inspection frequency and Priority Documentation and records Follow-up inspections and exceptions Training

11 Program General Consideration: Inspect storm water drainage areas for evidence of pollutants entering the MS4 Inspect material handling, transfer, and storage areas for evidence for indications of a potential impact to storm water runoff Observe storm water BMPs for effectiveness and whether additional measures are needed Evaluate storm water management records Observe outfalls for illicit discharges Complete inspection form/report and notify manager of any unacceptable conditions

12 Program Typical inspection proceeds as three successive stages: Pre-inspection activities Inspection evaluation and assessment Closing/follow-up

13 Program Pre-inspection Activities: Select facility to inspect Review and evaluate available facility information Make initial contact and provide overview of the inspection purpose, process and storm water ordinance. Answer any questions. Schedule inspection, determine special considerations, and any PPE requirement Request a facility contact be available as escort during inspection ion Prepare for inspection contact information, inspection form, area map, camera, credentials, ordinance, review inspection protocol

14 Program Inspection Evaluation and Assessment: Upon arrival make brief drive by to observe facility perimeter Conduct introduction and briefing Request facility representative provide a brief overview of facility process operations Discuss safety considerations Determine if facility is subject to NPDES General Storm Water Permit

15 Program Inspection Evaluation and Assessment: Begin inspection with facility walk-around around Start at facility perimeter looking at sheet flow drainage areas, retention ponds, and defined outfalls for potential problems Look for visual signs of illicit discharges Document observations on inspection report form, collect photographic evidence, and prepare a sketch as needed.

16 Program General evidence of potential drainage problems may be: Stains Discoloration Stressed Vegetation Erosion Residues Odors Sheens Trash, debris and sediment accumulation

17 Program Inspection Evaluation and Assessment: Next inspect all material handling, transfer, and storage locations that are exposed to storm water Make an assessment of general housekeeping practices and BMPs Document observations on inspection report form, collect photographic evidence, and prepare a sketch as needed.

18 Typical material handling, transfer, and storage areas include, but are not limited to: Tanks Silos Bins Roll-offs offs Compactors Dumpsters Hoppers Loading docks Rail cars Piles Lagoons/basins Cooling towers Tote/drum storage Fill connections Piping Conveyors Pumps Dispensers

19 Program Inspection Evaluation and Assessment: Qualitatively evaluate the effectiveness of measures to reduce pollutant loading (curbing, secondary containment, cover, housekeeping, etc.) Inspect all equipment needed to implement storm water management program Evaluate whether additional storm water management measures are needed Document observations on inspection report form, collect photographic evidence, and prepare a sketch as needed.

20 Program Inspection Evaluation and Assessment: If the facility is subject to the requirement of the NPDES General Storm Water Permit for Industrial Activities review records for adequacy. Required records include: Written Storm Water Pollution Prevention Plan (SWP3) Current in-house inspection logs/checklists Documented SWP3 training Current comprehensive annual compliance evaluation Document the facility SWP3 review on inspection report form.

21 Program Closing and Follow-up: Upon completion of the visual inspection and records review, conduct a closing meeting Provide facility representative with preliminary findings and inspection status (satisfactory/unsatisfactory) If satisfactory, relay that no further action is required If unsatisfactory, discuss deficiencies and possible corrective actions Inform facility representative that exception notice may be issued requiring corrective action Advise facility representative that consideration may be given to t issuing a facility self-monitoring notice and discuss requirements for self monitoring Document any unacceptable condition on inspection report and report unsatisfactory finding to the Storm Water Manager.

22 Program Inspection Frequency and Priority: Each industrial and high risk facility is scheduled for inspection once during each permit cycle Inspection schedule priority will be set by the Storm Water Manager based on: Industrial or high risk category EPCRA reporting Watershed designation Proximity to and potential to contribute pollutant loading to MS4 Follow-up and exception inspections completed as needed within six months of initial inspection or exception notice

23 Program Documentation and Records: Document all inspections using the inspection report form All inspection must be designated as satisfactory or unsatisfactory Corrective actions must be noted on all unsatisfactory inspection reports All inspection reports must be reviewed for completeness, follow-up, and exceptions by the Storm Water Manager All inspection reports must be retained for at least one year after coverage under the NPDES Phase I permit terminates

24 Program Follow-up and Exceptions: An exception notice will be issued to any industrial or high risk facility that may reasonably be expected to contribute a significant pollutant load to the County MS4 Criteria for issuance should include, but is not limited to: Visual evidence of pollutants entering the storm water discharge Visual evidence of an illicit discharge Visual evidence of poor housekeeping and material management practices Lack of or ineffective BMPs (structural and procedural)

25 Program Follow-up and Exceptions: The exception notice must: Identify applicable requirements of the County Storm Water Ordinance Require the industrial or high risk facility to take all reasonable steps to minimize or prevent the discharge of pollutants to the County MS4 Contain a schedule for the industrial or high risk facility to respond with acknowledgement of intent to comply Require the industrial or high risk facility to provided proposed BMPs to prevent or minimize pollutants present in the storm water discharge

26 Program Training: Personnel designated to perform storm water industrial and high risk facility inspections will have received training Training will encompass: County Storm Water Ordinance Industrial and high risk facility database Inspection process (procedures and completion of inspection report form) Good housekeeping and material handling and management practices Reasons for and maintenance of storm water BMPs

27 Self-Monitoring Program Implementation triggers: Unsatisfactory Inspection Wet weather monitoring program Illicit discharge detection Notification of self monitoring requirement in writing Contain reference to storm water ordinance Copy of self monitoring program

28 Self-Monitoring Program Required analyses: Baseline parameters Facility specific parameters Analysis by SCDHEC certified laboratory Sampling requirement Minimum of once every calendar year Rain event criteria Grab sample Representative discharge

29 Self-Monitoring Program Start date Annual Reporting Existing Monitoring data Follow-up and Exceptions: Review all annual self-monitoring reports Assessment criteria Exception notice Records

61 Evaluation and Assessment

70 Airport Inspection Location

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