Environmental Affairs Newsletter Articles

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October 2020

Compliance and Emission Data Reporting Interface

In an effort to reduce the burden on the regulated community of redundant reporting, DHEC has begun to accept some National Emission Standards for Hazardous Air Pollutants (NESHAPs) electronic submittals to the Environmental Protection Agency’s (EPA) Compliance and Emission Data Reporting Interface (CEDRI) in lieu of submitting a hard copy to the Department. Full details can be found in the guidance document here. If you have any questions or would like any additional information, contact Bryan Nichols at 803-898-0341.

The EPA has also notified us that CEDRI can be used to submit the required notification to EPA pursuant to the Operational Flexibility (502(b)(10)) provision of the Title V regulation. Use of the electronic system is not required but encouraged to ensure a timely receipt by EPA and allow the applicant the ability to verify if it was received, especially important during this time when many workers are working from home.


High Hazard Potential Dam Rehabilitation Grant Program

There are currently 540 dams in South Carolina regulated by DHEC’s Dam Safety Program that are classified as High Hazard. High Hazard dams are those dams where failure will likely cause loss of life or serious damage to home(s), industrial and commercial facilities, important public utilities, main highway(s) or railroads. Of these, more than 30% have a condition rating indicating that they do not meet minimum dam safety standards and pose an unacceptable risk to the public. 

One of the most common questions from dam owners posed to DHEC are regarding financial mechanisms to pay to reduce the risk via repair or removal of the dam. In 2016, the Water Infrastructure Improvements for the Nation Act, or “WIIN Act”, was signed into law, which established through Federal Emergency Management Agency’s National Dam Safety Program the High Hazard Potential Dam Rehabilitation Grant Program (HHPD Grant Program). In May 2019 Congress authorized a total amount for all eligible States and Territories of $10 million. DHEC applied and was awarded $301,821. The first year of the grant did not allow for construction or repair work on dams, only preliminary studies, engineering, and design work, so DHEC’s Dam Safety Program decided to apply for funds to perform in-depth studies of the 22 dams that were determined to be eligible for grant funding. These studies will help identify the biggest vulnerabilities and most cost-effective rehabilitation needs for the eligible dams. 

DHEC Dam Safety staff, along with our consultants at CDM Smith, are working to complete the work under the 2019 grant. For this grant year, FY2020, FEMA has expanded the HHPD to provide technical, planning, design and construction assistance for eligible dams. Dams are deemed eligible under the grant if they meet each of the following criteria:

  • Non-federal dams or dam that was built under the federal authority of the Secretary of Agriculture (PL-556 dams)
  • Classified as ‘high hazard potential’ by DHEC
  • Has an Emergency Action Plan approved by DHEC
  • DHEC’s Dam Safety Program has determined the dam fails to meet minimum dam safety standards; and the dam poses an unacceptable risk to the public

DHEC again was successful at being awarded funds under the grant program with an award of $585,694. The plan for this year is to pass the entire allotment of funds directly to dam owners and/or project sponsors to undertake pre-construction activities for the purpose of identifying, and eventually reducing through rehabilitation or removal of eligible High Hazard Potential Dams. 

In addition to establishing eligibility criteria for dams, the HHPD has established eligibility criteria for the entity DHEC may subaward grant funds to. Subrecipients must be:

  • A non-federal governmental organization; or
  • A nonprofit organization registered as a 501(c)(3) with the IRS

It should also be noted that each subrecipients is responsible for securing at least a 35% cost-share in the form of non-Federal funds and/or in-kind services. 

Notice of this funding opportunity has been provided to owners, engineers and potential sponsors of pre-construction activities for the 66 dams identified as being eligible during this grant cycle. Applications for the FY2020 are due to DHEC by December 2. Dam Safety is fortunate to be led by an engineer with experience in the Bureau of Water’s State Revolving Loan Fund. John McCain has used the experience he gained in ushering large public works projects for water and wastewater through SRF in developing detailed roadmap and processes for the HHPD. In the coming weeks, John and program staff will be working feverishly with dam owners and engineers as they work to develop projects for eligible dams. 

If you are interested in obtaining more information regarding the HHPD program in South Carolina, please contact:

John McCain, P.E.
mccainjm@dhec.sc.gov
803-898-8178


Drinking Water PFAS Strategy

Per- and Polyfluoroalkyl Substances, otherwise known as PFAS, have become an increasing national concern as a potential drinking water contaminant. PFAS chemicals (more than 4,000) are not currently regulated by the EPA. The EPA has established a non-regulatory Health Advisory Level for two of the chemicals. Collectively, PFAS have earned the nickname of “forever chemicals” because they resist breakdown in natural environments.

In South Carolina, there were research gaps in drinking water data for PFAS. The Bureau of Water put together a team and developed a strategy document to assist and guide staff with monitoring and analyzing drinking water resources statewide. The strategy also outlines a communications plan and expectations for public water systems when these chemicals are found in their drinking water.

Forty-four of the 54 Community Drinking Water Systems in the State that use surface waters (i.e, rivers, lakes) as the raw water source were sampled by the Department; the other ten (10) of the 54 CDWS provided PFAS data they had already acquired to the Department. Approximately 4 million citizens in the State get their potable water from a CDWS. The 54 surface water-sourced systems sampled  accounts for approximately 3.3 million of the approximate 4 (about 82%) million users of water from a CDWS. The USEPA Lifetime Drinking Water Health Advisory for 2 specific PFAS compounds (PFOA and PFOS) is 70 nanograms per liter (ng/L) [parts per trillion], individually or combined. Sample results from the 54 surface water-sourced CDWS plants showed:

  • Number of exceedances of the USEPA Lifetime Drinking Water Health Advisory – zero (0)
  • Maximum PFOA concentration measured – 18 ng/L
  • Maximum PFOS concentration measured – 16 ng/L
  • Maximum combined PFOA and PFOS concentration measured – 32 ng/L

Sampling of groundwater-sourced CDWS (that serve the balance of approximately 700,000, or 18%, of citizens) by the Department is presently underway as is the development of strategy to assess the impacts of PFAS on ambient surface waters.

For more information on the Bureau of Water's completed and on-going activities related to PFAS, as well as sampling data, please visit the dedicated web page

If you wish to discuss PFAS in CDWS with someone, contact:

Richard Welch, Jr., P.E., Manager
Drinking Water & Recreational Waters Section
welchra@dhec.sc.gov
803-898-3546

For more information, please visit the Bureau of Water PFAS webpage.

February 2021

Wastewater Program Now in ePermitting

On January 1, 2020, the Wastewater Program transitioned all aspects of the regulatory life-cycle to ePermitting. One of the primary considerations driving the implementation of the Wastewater Program in ePermitting was the Federal Electronic Reporting Rule. This rule requires that all wastewater reporting be submitted electronically. This includes permit applications and reapplications, discharge monitoring reports, sludge disposal reports, sewer overflows, or any other type of report specified by the facility’s permit. To comply with these requirements, our customers are required to create an ePermitting account and have the account linked to the permit. There are two ways to accomplish this. First, the Wastewater Program mailed letters to each permit holder that introduced ePermitting, explained the requirements, and provided a verification code that is used to link the account to the permit during the account set-up process. The second method involves sending an electronic invitation from ePermitting to the customer that directs them to the account creation page and automatically links their account to the permit when set-up is complete.

The Wastewater Program has now enrolled over 800 permitees in ePermitting, but there are many that still need to enroll. Overall, feedback from the customers has been positive. They have found the account set-up to be like other types of online accounts and that using the system to submit paperwork is often easier than filing with paper. If you are not already an ePermitting user and are regulated by the Wastewater Program, please begin setting up your account as soon as possible. The link for the ePermitting portal is: https://epermweb.dhec.sc.gov/. If you have questions, you may contact the Bureau of Water at (803) 898-4300.

July 2021

DHEC’s Strategy to Assess PFAS on Ambient Surface Waters in South Carolina

On May 1, 2021, the S.C. Department of Health and Environmental Control (DHEC) Bureau of Water (BOW) released the agency’s strategy to determine the extent to which per- and polyfluoroalkyl substances (PFAS) may be affecting streams, rivers, lakes, and coastal waters within the State.

PFAS are broad class of more than 3,000 man-made chemicals with the unique ability to repel both oil and water. They are widely used in commercial products including as coatings for nonstick cookware, food packaging, stain-resistant fabrics, water-resistant clothing, and metal plating. PFAS are also used in firefighting foams, cosmetics, and industrial surfactants.

PFAS are ubiquitous in the environment and are commonly referred to as forever chemicals because they are highly persistent and resist degradation. Among the documented sources of PFAS to the environment, four are considered primary sources: fire training/response sites (military bases, civilian airports), industrial sites, landfills, and wastewater treatment plants.

PFAS have been found in the blood of animals and humans worldwide. The primary non-occupational route of exposure to PFAS is diet, meaning PFAS may also pose ecological risks as they are present in most food webs. 

The Agency for Toxic Substances and Disease Registry (ATSDR) notes possible associations between specific PFAS and several health outcomes including liver damage, increased total and low-density lipoprotein cholesterol, pregnancy-induced hypertension and preeclampsia, thyroid disease, decreased antibody response to vaccines, increased risk of asthma, decreased fertility, and decreased birthweight.

The Surface Water PFAS Strategy presents a scalable framework from which DHEC can: 1) evaluate which release sources may be impacting ecological integrity and pose human health concerns; 2) determine which areas of the State may be most impacted by PFAS; and, 3) identify what environmental media may be accumulating PFAS (and what type of PFAS). To answer these questions the Strategy identifies a series of priority watersheds distributed across each major river basin within the State based on past and present sources that may have released or may release PFAS to the environment. 

The BOW is currently developing a project plan based on the Surface Water PFAS Strategy. For more information and to access the Strategy, please visit: https://scdhec.gov/BOW/perfluoroalkyl-substances-pfas


Rabies Prevention - Bats

168 domestic and wild animals tested positive for Rabies in SC in 2020. Rabies is a viral disease that affects brain and nervous system tissue and can be transmitted through the saliva/fluid of mammals. As your families, pets, and you spend more time outside, learn more about how to prevent this disease:  https://scdhec.gov/health/diseases-conditions/insect-or-animal-borne-disease/rabies. 
 
Mid July marks the end of the maternity season for our state's bat species. Most bats in South Carolina are born between May and June. Bat pups should be mobile and out of the nest by this time. This allows for wildlife control operators to place excluder devices and safely remove bats from buildings without blocking any of the babies inside the structure. Therefore, sealing any entry points into a building and waiting until the end of July or the beginning of August to safely remove bats is recommended. See SC DNR's guidance on how to deal with nuisance bats.
 
Bats can transmit rabies through bites or the introduction of saliva into open wounds or areas such as the eyes, nose, or mouth. Because bats have small teeth, their bites may go unnoticed which makes it important to identify any person or pet who has had potential contact with a bat. Similarly, never release a bat that had potential contact with a person, pet, or livestock. These bats should be safely trapped in a sealed container and not touched. Once a bat is released, it cannot be tested for rabies. Never handle a bat or any wild or stray animal, alive or dead, with your bare hands. Bat contact/exposure is defined as: 

  • Waking up to find a bat in your room; 
  • Finding a bat where children, pets, or persons with impaired mental capacity (intoxicated or mentally disabled) have been left unattended; and/or 
  • A pet or person that has been in direct contact with a bat. 

September 2021

Watershed-Based Plan Development Grant Opportunity

DHEC’s Nonpoint Source (NPS) Program is currently in one of two annual Request for Proposals (RFP) periods. Each year, applications are accepted for watershed-based plan (WBP) development grants funded by the Drinking Water State Revolving Fund. Watershed-based plans are developed to address nonpoint source surface water pollutants by analyzing a watershed’s sources of pollution and proposing best management practices (BMPs) to address them. Nonpoint source pollution is caused by rainfall moving over the ground, eventually carrying natural and human-made pollutants into lakes, rivers, wetlands, and coastal waters. WBP development is crucial for understanding a watershed as it encourages community involvement, considers local stakeholder input, and evaluates all available water quality data. A completed WBP serves as the framework for future implementation of BMPs to reduce nonpoint source pollution.

Watershed-based plans approved by DHEC become eligible for funding opportunities including Clean Water Act Section 319 funds for implementing a WBP. The NPS Program sends out an RFP for Section 319 implementation grants in February of each year. This grant funds the implementation of BMPs in a WBP for water quality improvements in the watershed.

Approved WBPs must include EPA’s nine required elements and must address surface water pollutants that can impact source water for drinking water systems in South Carolina. Eligible applicants include public organizations such as local governments, public universities, soil and water conservation districts, and nonprofit organizations. See the WBP Development Grants page for more details on eligibility and application requirements. The current WBP RFP is open through October 22, 2021. For any questions or to be added to the NPS Program contact list for both WBP and Section 319 RFPs, please contact the Nonpoint Source Program Coordinator, Shea McCarthy at mccartsm@dhec.sc.gov.

January 2022

NPDES General Permit for Stormwater Discharges from Industrial Activities on Public Notice

In the coming weeks, DHEC’s Bureau of Water will be placing the latest iteration of the NPDES General Permit for Stormwater Discharges from Industrial Activities (SCR000000) on public notice. The permit covers more than 1700 facilities throughout the state whose operations have the potential to introduce pollutants into stormwater runoff. Each facility operator is required to develop and implement a Stormwater Pollution Prevention Plan (SWPPP) that identifies best management practices, visual inspection, and monitoring (as appropriate). Though the existing permit expired on September 20, 2021, it remains in effect until the department can get the new permit reissued. 

How can facilities locate the notice?

The department is utilizing a multi-pronged approach to ensure that interested stakeholders have an opportunity to provide comment. As with other NPDES permits, comments should be summitted via DHEC’s E-Permitting. The public notice, draft permit, and other relevant documents will be available for download in E-Permitting but will also be posted here: http://scdhec.gov/industrialstormwater

Notices will also be sent to mailed to each active facility. We encourage industries in the state to be on the lookout for the notice and check the program’s webpage routinely. 

What should facilities do in the meantime?

First and foremost, each permitted facility should continue to implement their SWPPP based on the existing permit. Once the new permit is reissued and becomes effective, each facility will be required to submit a new Notice of Intent using E-Permitting. Operators are encouraged to complete the steps to register for E-Permitting by visiting this page: http://epermweb.dhec.sc.gov. 

Each facility must also update their SWPPP based on the standards outlined in the reissued permit.