Industrial and High Risk Runoff Training - Richland County...Identify and locate industrial and high...

Richland CountyIndustrial and High Risk Runoff

Program

Alan TrimAlan TrimBP BarberBP Barber

BP Barber

Industrial and High Risk Runoff ProgramProgram Components:Program Components:

Richland County Storm Water Ordinance.Richland County Storm Water Ordinance.Industrial and High Risk Facility Database.Industrial and High Risk Facility Database.Inspection Schedule.Inspection Schedule.Inspection Procedures.Inspection Procedures.SelfSelf--Monitoring Program.Monitoring Program.

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Richland County Storm Water OrdinanceProvides Authority forProvides Authority for::

Inspections to implement the industrial and high risk inspectionInspections to implement the industrial and high risk inspectionschedule as required by the Phase I NPDES Storm Water Permit. schedule as required by the Phase I NPDES Storm Water Permit.

SelfSelf--Monitoring at industrial and high risk facilities as deemed Monitoring at industrial and high risk facilities as deemed necessary based on DPW storm water inspections, wet weather necessary based on DPW storm water inspections, wet weather monitoring program, and dry weather screening.monitoring program, and dry weather screening.

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Regulatory Requirement:

Richland County Phase I NPDES Storm Water PermitRichland County Phase I NPDES Storm Water Permit

Identify and locate industrial and high risk facilities Identify and locate industrial and high risk facilities discharging storm water to the Richland County discharging storm water to the Richland County municipal separate storm sewer system (MS4).municipal separate storm sewer system (MS4).Control pollutants in storm water discharges from Control pollutants in storm water discharges from industrial and high risk facilities.industrial and high risk facilities.Development and implementation of an Industrial and Development and implementation of an Industrial and High Risk Runoff Program.High Risk Runoff Program.

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Industrial And High Risk Facility Database

Industrial and high risk facility definitionIndustrial and high risk facility definitionIndustrial and high risk facility databaseIndustrial and high risk facility databaseNotice to industriesNotice to industriesAnnual database updateAnnual database update

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Industrial And High Risk Facility DatabaseDefinition:Definition:

LandfillsLandfillsRCRA RCRA TSDFsTSDFsEPCRA reporting facilitiesEPCRA reporting facilitiesIndustrial facilitiesIndustrial facilitiesOtherOther

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Industrial And High Risk Facility DatabaseDatabase:Database:

Facility informationFacility informationSurface water bodySurface water bodyWatershed management unitWatershed management unit

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Industrial And High Risk Facility DatabaseNotice To Industries:Notice To Industries:

Publish in business section of local Publish in business section of local newspapernewspaperRequires industrial and high risk facilities to Requires industrial and high risk facilities to notify Richland County of storm water notify Richland County of storm water discharges into MS4discharges into MS4

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Industrial And High Risk Facility DatabaseAnnual Database Update:Annual Database Update:

New building permitsNew building permitsNew business licensesNew business licensesHazardous material management plan Hazardous material management plan submittalssubmittalsEPCRA ReportingEPCRA ReportingField surveillanceField surveillance

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Inspection Program

Routine inspectionRoutine inspectionInspection ProtocolInspection ProtocolInspection frequency and PriorityInspection frequency and PriorityDocumentation and recordsDocumentation and recordsFollowFollow--up inspections and exceptionsup inspections and exceptionsTrainingTraining

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Inspection Program General Consideration:General Consideration:

Inspect storm water drainage areas for evidence of Inspect storm water drainage areas for evidence of pollutants entering the MS4pollutants entering the MS4Inspect material handling, transfer, and storage areas for Inspect material handling, transfer, and storage areas for evidence for indications of a potential impact to storm evidence for indications of a potential impact to storm water runoffwater runoffObserve storm water Observe storm water BMPsBMPs for effectiveness and whether for effectiveness and whether additional measures are neededadditional measures are neededEvaluate storm water management recordsEvaluate storm water management recordsObserve outfalls for illicit dischargesObserve outfalls for illicit dischargesComplete inspection form/report and notify manager of Complete inspection form/report and notify manager of any unacceptable conditionsany unacceptable conditions

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Inspection Program

Typical inspection proceeds as three Typical inspection proceeds as three successive stages:successive stages:

PrePre--inspection activitiesinspection activitiesInspection evaluation and assessmentInspection evaluation and assessmentClosing/followClosing/follow--upup

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Inspection Program PrePre--inspection Activities:inspection Activities:

Select facility to inspectSelect facility to inspectReview and evaluate available facility informationReview and evaluate available facility informationMake initial contact and provide overview of the inspection purpMake initial contact and provide overview of the inspection purpose, ose, process and storm water ordinance. Answer any questions.process and storm water ordinance. Answer any questions.Schedule inspection, determine special considerations, and any PSchedule inspection, determine special considerations, and any PPE PE requirementrequirementRequest a facility contact be available as escort during inspectRequest a facility contact be available as escort during inspectionionPrepare for inspection Prepare for inspection –– contact information, inspection form, area contact information, inspection form, area map, camera, credentials, ordinance, review inspection protocolmap, camera, credentials, ordinance, review inspection protocol

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Inspection Program

Inspection Evaluation and Assessment:Inspection Evaluation and Assessment:Upon arrival make brief drive by to observe Upon arrival make brief drive by to observe facility perimeterfacility perimeterConduct introduction and briefingConduct introduction and briefingRequest facility representative provide a brief Request facility representative provide a brief overview of facility process operationsoverview of facility process operationsDiscuss safety considerationsDiscuss safety considerationsDetermine if facility is subject to NPDES General Determine if facility is subject to NPDES General Storm Water PermitStorm Water Permit

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Inspection Program

Inspection Evaluation and Assessment:Inspection Evaluation and Assessment:Begin inspection with facility walkBegin inspection with facility walk--aroundaroundStart at facility perimeter looking at sheet flow Start at facility perimeter looking at sheet flow drainage areas, retention ponds, and defined drainage areas, retention ponds, and defined outfalls for potential problemsoutfalls for potential problemsLook for visual signs of illicit dischargesLook for visual signs of illicit dischargesDocument observations on inspection report form, Document observations on inspection report form, collect photographic evidence, and prepare a collect photographic evidence, and prepare a sketch as needed.sketch as needed.

BP Barber

Inspection Program

General evidence of potential drainage problems may be:General evidence of potential drainage problems may be:StainsStainsDiscolorationDiscolorationStressed VegetationStressed VegetationErosionErosionResiduesResiduesOdorsOdorsSheensSheensTrash, debris and sediment accumulationTrash, debris and sediment accumulation

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Inspection Program

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

BP Barber

Typical material handling, transfer, and storage areas include, but are not limited to:

TanksTanksSilosSilosBinsBinsRollRoll--offsoffsCompactorsCompactorsDumpstersDumpstersHoppersHoppersLoading docksLoading docksRail carsRail cars

PilesPilesLagoons/basinsLagoons/basinsCooling towersCooling towersTote/drum storageTote/drum storageFill connectionsFill connectionsPipingPipingConveyorsConveyorsPumpsPumpsDispensersDispensers

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Inspection Program

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

BP Barber

Inspection Program

Inspection Evaluation and Assessment:Inspection Evaluation and Assessment:If the facility is subject to the requirement of the NPDES If the facility is subject to the requirement of the NPDES General Storm Water Permit for Industrial Activities General Storm Water Permit for Industrial Activities review records for adequacy. Required records include:review records for adequacy. Required records include:

Written Storm Water Pollution Prevention Plan (SWP3)Written Storm Water Pollution Prevention Plan (SWP3)Current inCurrent in--house inspection logs/checklistshouse inspection logs/checklistsDocumented SWP3 trainingDocumented SWP3 trainingCurrent comprehensive annual compliance evaluationCurrent comprehensive annual compliance evaluation

Document the facility SWP3 review on inspection report Document the facility SWP3 review on inspection report form.form.

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Inspection ProgramClosing and FollowClosing and Follow--up:up:

Upon completion of the visual inspection and records review, conUpon completion of the visual inspection and records review, conduct duct a closing meetinga closing meetingProvide facility representative with preliminary findings and inProvide facility representative with preliminary findings and inspection spection status (satisfactory/unsatisfactory)status (satisfactory/unsatisfactory)If satisfactory, relay that no further action is requiredIf satisfactory, relay that no further action is requiredIf unsatisfactory, discuss deficiencies and possible corrective If unsatisfactory, discuss deficiencies and possible corrective actionsactionsInform facility representative that exception notice may be issuInform facility representative that exception notice may be issued ed requiring corrective actionrequiring corrective actionAdvise facility representative that consideration may be given tAdvise facility representative that consideration may be given to o issuing a facility selfissuing a facility self--monitoring notice and discuss requirements for monitoring notice and discuss requirements for self monitoringself monitoringDocument any unacceptable condition on inspection report and repDocument any unacceptable condition on inspection report and report ort unsatisfactory finding to the Storm Water Manager.unsatisfactory finding to the Storm Water Manager.

BP Barber

Inspection ProgramInspection Frequency and Priority:Inspection Frequency and Priority:

Each industrial and high risk facility is scheduled for Each industrial and high risk facility is scheduled for inspection once during each permit cycleinspection once during each permit cycleInspection schedule priority will be set by the Storm Water Inspection schedule priority will be set by the Storm Water Manager based on:Manager based on:

Industrial or high risk categoryIndustrial or high risk categoryEPCRA reportingEPCRA reportingWatershed designationWatershed designationProximity to and potential to contribute pollutant Proximity to and potential to contribute pollutant loading to MS4loading to MS4

FollowFollow--up and exception inspections completed as needed up and exception inspections completed as needed within six months of initial inspection or exception noticewithin six months of initial inspection or exception notice

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Inspection ProgramDocumentation and Records:Documentation and Records:

Document all inspections using the inspection report formDocument all inspections using the inspection report formAll inspection must be designated as satisfactory or All inspection must be designated as satisfactory or unsatisfactoryunsatisfactoryCorrective actions must be noted on all unsatisfactory Corrective actions must be noted on all unsatisfactory inspection reportsinspection reportsAll inspection reports must be reviewed for completeness, All inspection reports must be reviewed for completeness, followfollow--up, and exceptions by the Storm Water Managerup, and exceptions by the Storm Water ManagerAll inspection reports must be retained for at least one year All inspection reports must be retained for at least one year after coverage under the NPDES Phase I permit terminatesafter coverage under the NPDES Phase I permit terminates

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Inspection ProgramFollowFollow--up and Exceptions:up and Exceptions:

An exception notice will be issued to any industrial or high An exception notice will be issued to any industrial or high risk facility that may reasonably be expected to contribute risk facility that may reasonably be expected to contribute a significant pollutant load to the County MS4a significant pollutant load to the County MS4Criteria for issuance should include, but is not limited to:Criteria for issuance should include, but is not limited to:

Visual evidence of pollutants entering the storm water Visual evidence of pollutants entering the storm water dischargedischargeVisual evidence of an illicit dischargeVisual evidence of an illicit dischargeVisual evidence of poor housekeeping and material Visual evidence of poor housekeeping and material management practicesmanagement practicesLack of or ineffective Lack of or ineffective BMPsBMPs (structural and procedural)(structural and procedural)

BP Barber

Inspection ProgramFollowFollow--up and Exceptions:up and Exceptions:

The exception notice must:The exception notice must:Identify applicable requirements of the County Storm Identify applicable requirements of the County Storm Water OrdinanceWater OrdinanceRequire the industrial or high risk facility to take all Require the industrial or high risk facility to take all reasonable steps to minimize or prevent the discharge reasonable steps to minimize or prevent the discharge of pollutants to the County MS4of pollutants to the County MS4Contain a schedule for the industrial or high risk facility Contain a schedule for the industrial or high risk facility to respond with acknowledgement of intent to comply to respond with acknowledgement of intent to comply Require the industrial or high risk facility to provided Require the industrial or high risk facility to provided proposed proposed BMPsBMPs to prevent or minimize pollutants to prevent or minimize pollutants present in the storm water dischargepresent in the storm water discharge

BP Barber

Inspection ProgramTraining:Training:

Personnel designated to perform storm water industrial and Personnel designated to perform storm water industrial and high risk facility inspections will have received traininghigh risk facility inspections will have received trainingTraining will encompass:Training will encompass:

County Storm Water OrdinanceCounty Storm Water OrdinanceIndustrial and high risk facility database Industrial and high risk facility database Inspection process (procedures and completion of Inspection process (procedures and completion of inspection report form)inspection report form)Good housekeeping and material handling and Good housekeeping and material handling and management practicesmanagement practicesReasons for and maintenance of storm water Reasons for and maintenance of storm water BMPsBMPs

BP Barber

Self-Monitoring Program

Implementation triggers:Implementation triggers:Unsatisfactory InspectionUnsatisfactory InspectionWet weather monitoring programWet weather monitoring programIllicit discharge detectionIllicit discharge detection

Notification of self monitoring requirement in Notification of self monitoring requirement in writingwriting

Contain reference to storm water ordinanceContain reference to storm water ordinanceCopy of self monitoring programCopy of self monitoring program

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Self-Monitoring ProgramRequired analyses:Required analyses:

Baseline parametersBaseline parametersFacility specific parametersFacility specific parametersAnalysis by SCDHEC certified laboratoryAnalysis by SCDHEC certified laboratory

Sampling requirementSampling requirementMinimum of once every calendar yearMinimum of once every calendar yearRain event criteriaRain event criteriaGrab sampleGrab sample

Representative dischargeRepresentative discharge

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Self-Monitoring Program

Start dateStart dateAnnual ReportingAnnual ReportingExisting Monitoring dataExisting Monitoring dataFollowFollow--up and Exceptions:up and Exceptions:

Review all annual selfReview all annual self--monitoring reportsmonitoring reportsAssessment criteriaAssessment criteriaException noticeException notice

RecordsRecords

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Inspection

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Inspection Evaluation and Assessment

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Inspection

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Airport Inspection Location

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Inspection

Industrial and High Risk Runoff Training - Richland County...Identify and locate industrial and high...

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