By Robert Kendall, SWCD Urban Conservationist
In May, the Indiana Department of Environmental Management (IDEM) led a Regulatory Inspections, Compliance, and Enforcement training session at the Indiana MS4 Partnership Annual Conference. During the IDEM inspection training, the presenters covered the importance of a detailed inspection report. To ensure inspections are thorough and comprehensive, the inspector must be familiar with and conduct inspections within the legal framework of local ordinances and the Construction Stormwater General Permit (CSGP). Below, I will summarize the recommended field inspection process and requirements for inspectors.
The complete presentation can be found here: https://www.indianams4.org/_files/ugd/83c520_73952d7bf5bc4000a078f8ee6c465f64.pdf.
Inspector Requirements
Training and Qualifications: Inspectors must be proficient in stormwater management, erosion, and sediment control. Proficiency is reached through completing an accepted certifying course work and maintaining it through periodic training.
Professional Conduct: Inspections demand the highest degree of professionalism, ethics, and diplomacy. Inspectors are required to remain objective and avoid any conflicts of interest.
Pre-Inspection Preparations
Safety First: Before any site visit, inspectors must be familiar with standard safety protocols and potential site-specific risks. All required Personal Protective Equipment (PPE), such as hard hats, safety vests, protective glasses, and gloves, must be ready.
Essential Equipment: A standard inspection toolkit should be prepared, including a digital camera, a device with GPS capabilities, inspection forms, pH strips, and a tape measure for documentation and measurement.
Documentation Review: A thorough review of all relevant documents is necessary before visiting a site. This includes the Stormwater Pollution Prevention Plan (SWP3), the site’s approved Construction Stormwater General Permit, and various site maps (topographic, aerial, soil surveys).
On-Site Inspection Protocol
Site Navigation: Upon arrival, announce your presence if possible. Conduct a systematic inspection of the site, evaluating the effectiveness of all sediment and erosion control measures, the implementation of the stabilization program, and the management of non-sediment pollutants.
Evidence Collection: The primary task during an inspection is to accurately document all site conditions. This involves taking detailed field notes, comprehensive photographs (including establishing, subject, and detail shots), and potentially video or voice recordings. Note that all collected data is a public record.
Closing Meeting: When feasible, a closing meeting with on-site personnel is recommended to communicate preliminary findings, discuss immediate concerns, and outline the next steps.
Post-Inspection Procedures
Reporting: Inspection reports must be developed promptly or within five days of inspecting a site. Reports need to be factual, clear, and concise, clearly identifying any deficiencies and referencing the specific regulatory requirements violated. All observations must be based on firsthand knowledge.
Enforcement: MS4 entities must have a clear, escalating enforcement policy. Actions can range from informal deficiency notices to formal measures like stop-work orders and monetary penalties, based on the severity of the violation.
