The City is required to inspect certain industrial facilities on a routine basis to assess their compliance with federal and state water quality regulations as part of its NPDES stormwater permit. Below is guidance for such facilities.
City Inspection Process
The City has a list of the types of facilities that require inspection. This includes facilities with an NPDES permit as well as non-permitted facilities that may conduct activities with a potential to impact storm or surface waters.
My facility's mailing address is inside the City, but the facility is physically located outside City limits. Does City staff need to inspect it?
City Stormwater staff will only inspect those facilities physically located in the City. If a site only has a mailing address on file with Business Licensing, staff will confirm the physical address of the location through a tax map search. Any facility located outside of City limits comes off the list of sites to be inspected even if it has a mailing address inside City limits.
City personnel may contact you prior to the inspection and ask for a copy of your Stormwater Pollution Prevention Plan (if applicable) and other site documents. City personnel may also arrive unannounced to conduct inspections.
The City inspector will need to see any parts of your facility that are exposed to rain or have the potential to contribute to runoff pollution.
The City is required to inspect all identified facilities at least once during its 5-year permit term (ending in 2015). The City may conduct additional inspections if necessary.
Self-Inspections & Procedures
Of course, you should contact SC Department of Health and Environmental Control (DHEC) first if there are any problems with your Notice of Intent (NOI) paperwork. If you still need assistance, please contact Stormwater staff to let them know about the issues. While the City cannot control how SC DHEC handles a facility’s paperwork, staff may be able to help you work through issues with the NOI process for facilities located within City limits. This assistance will depend on the current workloads of our inspectors.
There are several things you might do to improve your operation:
- Hire an outside group to do a test inspection and audit. They may find issues with your operation that can be fixed before S.C. DHEC or City inspectors see them.
- Paint and tag your drains with special colors to make it easy for workers to tell the difference between stormwater and wastewater drains. For example, you might paint all stormwater drains blue and all wastewater drains red.
- Train any incoming personnel on proper procedures and give refresher trainings to all personnel who have the potential to pollute.
- Have supervisors trained to train employees (train-the-trainer), and make them responsible for training employees. This makes sure that supervisors know what procedures their subordinates should be following and reinforces the expectation that all employees should follow the proper procedures.
I don't believe my facility is likely to contribute to fecal coliform. Do I really need to test for it?
You will need to follow any sampling requirements in the permit to maintain compliance. For industrial facilities, you may be able to stop sampling for fecal coliform if you have four consecutive samples that are not above state limits. You will need to consult with S.C. DHEC and City Stormwater Staff before you stop any sampling regimen to avoid non-compliance.
You may not always be able to take a rain event sample during a quarter if there are no qualifying rain events. However, there are things you can do to show due diligence in attempting to catch those invents. You can:
Have several personnel on staff trained to collect samples. This way you minimize the chance that all personnel able to collect a sample are busy or off of work when a qualifying rain event occurs.
Consider using an auto-sampler if it is suitable for your sampling requirements.
Find out which local laboratories will process a fecal sample without subletting. This maximizes the amount of time you have to get the sample to the lab.
Keep a stock of the correct, pre-preserved sampling bottles/ bags on hand. Make sure you have easy access to ice. This will let you act quickly when a qualifying event occurs.
Safety first! Avoid sampling in conditions when it might be dangerous to take a sample. For example, if your sampling point is at the bottom of a steep embankment with poor night lighting, you may want to avoid sampling in the dark.
What should I do if a qualifying event happens at the end of one quarter and then another qualifying event happens at the beginning of the next quarter? Should I still sample when the second event happens or should I wait until later in the quarter?
Because you never know if another qualifying event will happen, you should go ahead and take that second sample even if it has been a short time since the first sample. You may want to sample again that quarter if another qualifying event occurs.
Document when you do not have a qualifying event during a quarter and/or if there are any particular hardships or hazards that prevented you from collecting during a qualifying event.