FINDINGS FOR THE
  SOUTH CAROLINA COASTAL NONPOINT PROGRAM
                      

FOREWORD

     This document contains the findings for the coastal
nonpoint pollution control program submitted by the State of South
Carolina pursuant to Section 6217(a) of the Coastal Zone Act
Reauthorization Amendments of 1990 (CZARA).  The findings are
based on a review of the South Carolina Coastal Nonpoint
Pollution Control Program, July 1995 and supplemental material
provided by South Carolina subsequent to the program submittal. 
The National Oceanic and Atmospheric Administration (NOAA)
and the U.S. Environmental Protection Agency (EPA) reviewed
this information and evaluated the extent to which it conforms with
the requirements of CZARA.

     NOAA and EPA commend South Carolina on the
substantial amount of time and effort put into developing your
program and we appreciate the commitment you have shown to
complete an ambitious task with limited resources.  We will
continue to work with coastal states and territories to ensure that
these findings represent an accurate assessment of current state and
territory abilities and efforts to address coastal nonpoint source
pollution.  We recognize that there may be further administrative
changes to the coastal nonpoint program that will impact these
findings and we assure you that, once such changes are finalized,
we will review these findings in light of the changes and make any
necessary adjustments. 


APPROVAL DECISION

     NOAA and EPA approve the coastal nonpoint pollution
control program submitted by the State of South Carolina pursuant
to Section 6217(a) of the Coastal Zone Act Reauthorization
Amendments of 1990, subject to certain conditions.  

     This document provides the specific findings used by
NOAA and EPA as the basis for the decision to approve South
Carolina's program.  It also provides the rationale for the findings
and includes conditions that will need to be met for South Carolina
to receive final approval of its program.  The timeframes
associated with conditions become effective on the date of the
approval letter for these findings.
INTRODUCTION

      This document is organized by the major nonpoint source
categories and subcategories identified in the section 6217(g)
guidance and the administrative elements identified in the program
guidance (including the boundary for the 6217 management area). 
Where appropriate, NOAA and EPA have grouped categories and
subcategories of management measures into a single finding.  The
structure of each finding follows a standard format.  Generally, the
finding is that the state program includes or does not include
management measures in conformity with the (g) guidance and
includes or does not include enforceable policies and mechanisms
to ensure implementation.  In some cases, the finding reflects that
the state has identified a back-up enforceable policy, but has not 
demonstrated the ability of the authority to ensure implementation. 
For further understanding of terms in this document, the reader is
referred to the following:

Guidance Specifying Management Measures for Sources of
Nonpoint Pollution in Coastal Waters (EPA, January 1993)
Coastal Nonpoint Pollution Control Program:  Program
Development and Approval Guidance (NOAA and EPA, January
1993)
Flexibility for State Coastal Nonpoint Programs (NOAA and EPA,
March 1995)

     The references in this document refer to the South Carolina
Coastal Nonpoint Pollution Control Program, July 1995 ("program
submittal").  NOAA and EPA have written this document as
succinctly as possible.  We have relied upon, but do not repeat
here, the extensive information that the State has included in its
program submittal.  Further information and analysis, including
material provided by South Carolina subsequent to the program
submittal, is contained in the administrative record for this
approval decision and may be reviewed by interested parties at the
following locations:

EPA/Office of Wetlands, Oceans and Watersheds
Assessment and Watershed Protection Division 
Nonpoint Source Control Branch
401 M St., SW (4503-F)
Washington, DC  20460
Contact: Dov Weitman (202-260-7088)

NOAA/Office of Ocean and Coastal Resource Management
Coastal Programs Division
SSMC-4, N/ORM3
1305 East-West Highway
Silver Spring, MD  20910
Contact: Joelle Gore (301/713-3117, x177)

U.S. EPA, Region 4
61 Forsyth Street, SW
Atlanta, GA 30303
CONTACT: Robert B. Howard (404-562-9370)
     I.   BOUNDARY

FINDING:  South Carolina's existing coastal zone boundary is
sufficient to control the land and water uses that have or are
reasonably expected to have a significant impact on the coastal
waters of South Carolina. 

RATIONALE: In correspondence provided to NOAA and EPA
subsequent to the State's program submission, the State identified
the existing coastal zone as the boundary of the 6217 management
area.  The existing coastal zone encompasses the eight coastal
counties of Beaufort, Jasper, Colleton, Dorchester, Charleston,
Berkeley, Georgetown and Horry.  South Carolina's Coastal
Nonpoint Pollution Control Program serves as an update and
expansion of the State's existing Nonpoint Source Management
Program. 

     II.  AGRICULTURE

FINDING:  South Carolina's program includes management
measures in conformity with the 6217(g) guidance.  South Carolina
has identified backup enforceable policies and mechanisms for
implementing the management measures, but the State has not
demonstrated the ability of these authorities to ensure 
implementation throughout the 6217 management area.

CONDITION:  Within one year, South Carolina will develop a
strategy (in accordance with section XIV, page 14) to implement
the agricultural management measures throughout the 6217
management area. 

RATIONALE:  South Carolina implements the agricultural
management measures through a number of existing voluntary
programs including the development of conservation plans under
the State's Soil and Water Conservation Districts Law, which is
administered by the SC Land Resources and Conservation Districts
Division (LRCD), consistent with the National Resource
Conservation Service (NRCS) Field Office Technical Guide.  In
1993, the LRCD also adopted a policy stating that the Division
along with the soil and water conservation districts would assist the
South Carolina Office of Ocean and Coastal Resource
Management (SCOCRM) in the implementation of the 6217
program.  Research programs in Clemson University, including an
Integrated Pest Management Program and Sustainable Research
and Education Program, provide new technology to develop
agricultural practices to enhance water quality.  Clemson
University Cooperative Extension Program provides the technical
assistance and education for these research programs and practices
directly to the farming community.  

The Pollution Control Act (48-1-10 et seq. ), which provides
broad enforcement authority to control nonpoint sources, has been
identified by the State as a backup authority when a more specific
authority does not exist.  However, South Carolina has not 
described the mechanism for using the Pollution Control Act to
achieve implementation of the management measures.   The
Pesticide Control Act (46-13-10 et seq.) and Chemigation Law
(46-1-40), both administered and enforced by Clemson
University, provide limited authority to address parts of the
pesticide and irrigation management measures.  The State is
encouraged to pursue a requirement for anti-backflow devices on
hoses at mixing and loading locations, as proffered by the State.  

South Carolina currently uses its authority under the National
Pollutant Discharge System (NPDES) to issue permits for confined
animal facilities in any case where the State determines that the
facility is a significant contributor of pollution.  Permit conditions
require either the collection of runoff in a lagoon or land
application of waste in accordance with NRCS standards and
specifications. 

The nutrient management measure is implemented by Cooperative
Extension Service through technical assistance.  However, some of
the technical support materials may not be consistent with the
measure and should be re-examined.  For example, the Cooperative
Extension Service's bulletin on land application of animal manure
contains several examples which lead to excessive application of
phosphorus.  The State is encouraged to include in its strategy the
necessary mechanisms for ensuring that the State administered
NPDES permitting program and associated technical assistance
efforts work together to fully achieve the management measures
for confined livestock operation and nutrient management.

The State will also target the implementation of management
measures through its Watershed Water Quality Management
Strategy Program (WWQMS) for priority watershed units where
nonpoint pollution is causing impacts.  The State will develop
strategies for all five large watersheds by 1996.  Although the
WWQMS is a water-quality based, rather than technology-based,
program, the State is encouraged to continue augmenting its
voluntary programs with this approach.

     III. FORESTRY

FINDING:  South Carolina's program includes management
measures in conformity with the 6217(g) guidance.  The State's
program identifies a backup enforceable policy and mechanism for
implementing the management measures, but the State has not
demonstrated the ability of the authority to ensure  implementation
throughout the 6217 management area.

CONDITION:  Within one year, South Carolina will develop a
strategy (in accordance with section XIV, page 14) to ensure
implementation of the forestry management measures throughout
the 6217 management area.  

RATIONALE:  South Carolina's has several voluntary efforts in
place to implement the forestry management measures, including
South Carolina's Best Management Practices for Forestry EPA-
approved BMP manual, the Logger Accreditation Program, BMP
education and training programs, and a monitoring program that
has shown increasing compliance rates with timber harvesting
BMPs since 1990.  These voluntary measures are backed by South
Carolina's Pollution Control Act  (48-1-10 et seq.), which
provides a general backup enforcement authority that the State can
use in response to complaints regarding the impact of forestry
activities on water quality.  

A trial Courtesy Exam Program for interested landowners and
operators is being conducted in the coastal region.  This two year
effort will conclude with another summary report that details
voluntary compliance with harvesting BMPs. 

     III. URBAN

     A.   NEW DEVELOPMENT

FINDING:  South Carolina's program includes management
measures in conformity with the 6217(g) guidance and enforceable
polices and mechanisms to ensure implementation throughout the
6217 management area, except the program does not include
measures and authorities for (1) the maintenance of post
development peak discharge rates and volumes at predevelopment
levels for sites disturbing less than two acres, and (2) a total
suspended solids loading reduction of 80 percent for sites
disturbing less than 10 acres.  South Carolina has identified a
backup enforceable policy and mechanism for sites not covered
under the State's existing program, but the State has not 
demonstrated the ability of the authority to ensure  implementation
throughout the 6217 management area.

CONDITION:  Within two years, South Carolina will include in
its program management measures and enforceable policies and
mechanisms for (1) the maintenance of post development discharge
rates and volumes at predevelopment levels for sites disturbing less
than two acres and (2) for a total suspended solids loading
reduction of 80 percent for sites disturbing less than 10 acres. 
Within one year, South Carolina will develop a strategy (in
accordance with section XIV, page 14) to ensure implementation
of the management measures throughout the 6217 management
area on sites not covered under the State's existing program.

RATIONALE:  South Carolina's Stormwater Management and
Sediment Reduction regulations require stormwater plans for all
land disturbing activities, regardless of size, and require, in the
coastal zone, a permit prior to any land disturbance, for all projects
within one-half mile of a receiving waterbody, regardless of size. 
For sites of two or more acres, the South Carolina Department of
Health and Environmental Control must approve a permit prior to
any land disturbance.  Projects between two and five acres must
achieve post development peak discharge rates that do not exceed
predevelopment discharge rates for the 2- and 10-year frequency
24-hour duration storm event (R.72-307(c)(4)(a), (I)(1)(e)(1)). 
Projects greater than 10 acres must also construct sediment basins
to achieve a total suspended solids removal efficiency of 80
percent (R.72-307(c)(5)(b)).  The regulations, however, do not
provide that sites under 10 acres achieve a total suspended solids
removal efficiency of 80 percent (R.72-307(H), (I)).  The State has
identified the Pollution Control Act (48-1-10 et seq,) as providing
a general backup enforcement authority where the stormwater
regulations are not applicable.  

     B.   WATERSHED PROTECTION, SITE
     DEVELOPMENT and EXISTING DEVELOPMENT

FINDING: South Carolina's program includes management
measures in conformity with the 6217(g) guidance, except it does
not include management measures for watershed protection to
avoid conversion of areas susceptible to erosion and sediment loss,
and to protect the natural integrity of waterbodies and natural
drainage systems; or management measures for site development
to limit land disturbance activities.  South Carolina's program
includes a backup enforceable policy and mechanism to implement
these management measures, but the State has not  demonstrated
the ability of the authority to ensure  implementation throughout
the 6217 management area.

CONDITION:  Within three years, South Carolina will include in
its program management measures in conformity with the 6217(g)
guidance to avoid conversion of areas susceptible to erosion and
sediment loss; protect the natural integrity of waterbodies and
natural drainage systems; and limit land disturbance activities. 
Within one year, South Carolina will develop a strategy (in
accordance with section XIV, page 14) to ensure implementation
of the management measures throughout the 6217 management
area.
 
RATIONALE:  South Carolina describes a number of programs
and authorities that implement some of the components of the
watershed protection and site development management measures. 
These include the Stormwater Management and Sediment
Reduction Regulations, which allow local governments to request
that a watershed be designated for special protection; the State's
Coastal Zone Management Program, which can provide watershed
protection through special area management planning; and the
State's Watershed Water Quality Management Strategy
(WWQMS), through which the South Carolina Bureau of Water
Pollution Control manages its program on a watershed basis and
develops management strategies for all five watersheds in the
State.  These programs, however, do not include provisions to
avoid conversion of areas susceptible to erosion and sediment loss,
protect the natural integrity of waterbodies and natural drainage
systems, or limit land disturbance activities.  The State identifies
the Pollution Control Act (48-1-10 et seq.) as a general backup
enforcement authority where the State's existing programs and
authorities do not apply.

The State's WWQMS provides a mechanism to address the
existing development management measure.  Under this program,
the State will develop a strategy to address each of the five major
watersheds.  The strategies will include a discussion of the
nonpoint source contributions to water quality, an identification of
priority areas, and a BMP implementation strategy.  The program
is currently being implemented in Savannah-Salkehatchie
watershed.  In addition, the Stormwater Management and Sediment
Reduction Rules enable localities to designate smaller watersheds
for additional protection, although the rules do not specify
measures or an implementation schedule.  NOAA and EPA
encourage the State to continue to develop these programs.  

     C.   CONSTRUCTION SITE EROSION AND SEDIMENT
     CONTROL

FINDING:  South Carolina's program includes management
measures in conformity with the 6217(g) guidance and enforceable
policies and mechanisms to ensure implementation throughout the
6217 management area.

RATIONALE:   South Carolina's Stormwater Management and
Sediment Reduction regulations require the use of erosion and
sediment control plans for all land disturbing activities.  (See the
discussion under the new development management measure,
above.)  Required design standards and plan specificity depend on
the size of the area disturbed.  A Guide to Site Development and
Best Management Practices for Storm Water Management and
Sediment Control and the South Carolina Stormwater Management
and Sediment Control Handbook for Land Disturbing Activities
include information on the permit application process, minimum
standards, design guidelines, best management practices, and
engineering aids approved by the State that meet the components
of this management measure.  The SCDHEC is responsible for the
implementation and supervision of the program and can issue stop
work orders or levy fines.

     D.   CONSTRUCTION SITE CHEMICAL CONTROL

FINDING:  South Carolina's program does not include
management measures in conformity with the 6217(g) guidance. 
South Carolina's program includes a backup enforceable policy
and mechanism, but the State has not  demonstrated the ability of
the authority to ensure  implementation throughout the 6217
management area.

CONDITION:  Within two years, South Carolina will include in
its program management measures for construction site chemical
control in conformity with the 6217(g) guidance.  Within one year,
South Carolina will develop a strategy (in accordance with section
XIV, page 14) to ensure implementation of the measure throughout
the 6217 management area.

RATIONALE:  The Rules and Regulations for the Enforcement
of the South Carolina Pesticide Control Act (R.27-1070 et seq.)
regulate the application of both restricted-use and non-restricted
pesticides, and the Hazardous Waste Management Act (44-56-10
et seq.) regulates the disposal and discharge of hazardous
materials.  The Pesticide Act, however, does not include fertilizers,
and the Hazardous Waste Management Act does not cover other
toxic substances that can be generated on construction sites such as
oil, gasoline, paint, and sealers.  In addition, the State's program
does not provide for proper storage and disposal of toxic
substances or the application of nutrients to establish and maintain
vegetation without causing significant nutrient runoff to surface
waters.  Where these authorities are not applicable, however, the
State has identified  the Pollution Control Act (48-1-10 et seq.) as
providing a general backup enforcement authority. 

     E.   NEW and OPERATING ONSITE DISPOSAL
     SYSTEMS (OSDS)

FINDING:  South Carolina's program includes management
measures in conformity with the 6217(g) guidance, except for
management measures that address: 1) denitrification where
nitrogen-limited surface waters may be adversely affected by
excess nitrogen loadings from OSDS; 2) inspection and
maintenance of existing OSDS; and 3) adequate separation
distances between OSDS system components and groundwater that
is closely hydrologically connected to surface waters.  South
Carolina's program includes enforceable policies and mechanisms
to ensure implementation of the measures throughout the 6217
management area, except policies and mechanisms to ensure the
implementation of the management measure for operation and
maintenance of existing OSDS.

CONDITION:  Within three years, South Carolina will include in
its program management measures in conformity with the 6217(g)
guidance to address:  1) denitrification where nitrogen-limited
surface waters may be adversely affected by excess nitrogen
loadings from OSDS; 2) inspection and maintenance of existing
OSDS systems; and, 3) adequate separation distances between
OSDS system components and groundwater that is closely
hydrologically connected to surface waters.  Within two years,
South Carolina will include in its program enforceable policies and
mechanisms to ensure implementation of the management measure
for operation and maintenance of existing OSDS.  

RATIONALE:   South Carolina's Individual Waste Disposal
System Rule (R.61-56) requires the Health Authority to issue a
permit before construction begins on an OSDS.  The regulations
include provisions for site evaluation prior to construction,
inspection of all commercial OSDS and some alternative and
experimental systems, and post-construction inspection of all
systems prior to final approval.  The regulations also establish
minimum siting and construction standards.  However, the State's
requirements for system siting do not meet the management
measure. There is only a six inch separation requirement between
the maximum high water table mark and the bottom of the
proposed soil absorption trench or alternate system.  This
separation distance is inadequate to meet the new OSDS
management measure, which requires OSDS be designed or sited
at a density so as not to adversely affect surface waters or ground
water that is closely hydrologically connected to surface waters.  

The State is currently developing a voluntary program for
inspection and maintenance for existing OSDS within the
designated coastal zone, but it has no means of ensuring that such
inspection and maintenance will occur.  NOAA and EPA
encourage the State to implement the voluntary program and
consider expanding implementation throughout the 6217
management area.  However, the State will need to include in its
program an enforceable policy and mechanism to ensure
implementation throughout the 6217 management area.  The State
also does not have a program to address denitrification where
nitrogen-limited surface waters may be adversely affected by
excess nitrogen loadings from OSDS. 

     F.   POLLUTION PREVENTION

FINDING:  South Carolina's program includes management
measures in conformity with the 6217(g) guidance.

RATIONALE: The Nonpoint Source Management Program
administered by the SCDHEC and many programs of the Clemson
University Cooperative Extension Service are devoted to pollution
prevention.  For example, SCDHEC produced Turning the Tide - A
Citizens Guide to Reducing Nonpoint Source Pollution.  South
Carolina provided an extensive number of outreach activities with
their program submittal.  The Solid Waste Act has enforceable
authorities to encourage recycling and use of recyclable materials
and authority to regulate disposal and storage of used oil.

     G.   ROADS, HIGHWAYS, AND BRIDGES

FINDING:  South Carolina's program includes management
measures for roads, highways, and bridges in conformity with the
6217(g) guidance and enforceable policies and mechanisms to
ensure implementation, except for construction site chemical
control and operation and maintenance for private and local roads.

CONDITION:  Within three years, South Carolina will include in
its program management measures and enforceable policies and
mechanisms to address construction site chemical control and
operation and maintenance for private and local roads.

RATIONALE:  The South Carolina Department of Transportation
(SCDOT) and SCDHEC have responsibility for reviewing and
approving planning, siting, and designs required by the Stormwater
Management and Sediment Reduction regulations (R.72-300 et
seq.) for roads, highways, and bridges projects causing land
disturbance.  Construction erosion and sediment control plans are
required (R.72-305 and 307H), and although disturbances less than
2 acres require less oversight than larger projects, they still must
meet basic stormwater and sediment control submission and
certification requirements.  SCDHEC's Stormwater Handbook
includes a report, Engineering Aids and Design Guidelines for
Control of Sediment in South Carolina, which is an excellent guide
for specialists who must prepare and certify erosion and sediment
control plans for larger sites.  The State also requires consideration
of runoff after construction during planning and design.   

For SCDOT projects, specifications for highway contract clauses
require contractors to use fertilizers properly and prevent harmful
pollutants from being washed or discharged into waters.  However,
for private and local roads, the State relies on the Pesticide Control
Act (46-13-10 et seq.), which does not include regulations for
fertilizers, and the Hazardous Waste Management Act (44-56-10
et seq.), which does not cover other toxic substances that can be
generated such as oil, gasoline, paint, and sealers.  In addition, the
State's program does not provide for proper storage and disposal of
toxic substances.  However, the State has identified the Pollution
Control Act (48-1-10 et seq.) as providing a general backup
enforcement authority.

The operation and maintenance and runoff systems measures are
met by R-63-380.   SCDOT must maintain State road, highway,
and bridge urban runoff and pollution control facilities after
construction is completed.  Programs include consideration of
correct herbicide and pesticide application with supervision by a
certified applicator, and appropriate disposal of sediment and other
road maintenance wastes.  Resident maintenance engineers are
required to prepare an inventory of roads, highways, and bridges
problem areas, prioritize the list with District offices, and correct
the problems as time and funds permit.

     V.   MARINAS AND RECREATIONAL BOATING

FINDING:   South Carolina's program includes management
measures in conformity with the 6217(g) guidance and enforceable
policies and mechanisms to ensure implementation of the
management measures.

RATIONALE:  South Carolina has a comprehensive program that
is designed to ensure implementation of all of the management
measures within the existing coastal zone.  Within the coastal zone,
the measures are addressed through a number of programs and
authorities, with an especially rigorous permitting program in the
Critical Area (the critical line, which delineates the critical area, is
the approximate boundary between salt water marsh and fresh
water marsh) which is administered and enforced by SCOCRM. 
South Carolina also reviews and approves through State
consistency permits for 404 of the Clean Water Act and 10 of
the Rivers and Harbors Act, to ensure that the measures are
implemented.  

South Carolina's permits provide enforceable means to implement
State rules, which authorize the review of proposed siting and
design of new marinas and the operation and maintenance of new
and existing marinas under several authorities including
SCOCRM's Rules and Regulations for Permitting in the Critical
Area (R.30-1 et seq.), Authorization and Criteria for the
Establishment of No-Wake Zones (50-21-710), and Stormwater
Management and Sediment Reduction regulations (R.72-300 et
seq.).  South Carolina also provides a technical manual for
guidance to marina operators and users and conducts frequent
inspections within the critical area.  The State plans to expand
inspections to include the entire coastal zone.

     VI.  HYDROMODIFICATION

FINDINGS:  South Carolina's program includes management
measures in conformity with the 6217(g) guidance, and includes
enforceable policies and mechanisms to ensure implementation of
the management measures, except;  the State's program does not
have management measures and enforceable policies and
mechanisms for: 1) a program to manage new channelization
projects throughout the 6217 management area; 2) a program to
improve surface water quality and restore instream and riparian
habitat through the operation and maintenance of existing modified
channels; 3) a program to manage the operation of dams to protect
surface water quality and instream and riparian habitat and to
assess nonpoint source problems resulting from excessive surface
water withdrawals; 4) a program to address chemical and pollutant
control for dam construction; and 5) a program to identify and
develop strategies to solve existing nonpoint source problems
caused by streambank or shoreline erosion that do not come up for
review under existing permit authorities.

CONDITIONS: Within three years, South Carolina will include in
its program: 1) management measures and authorities to manage
new channelization projects throughout the 6217 management
area; 2) management measures and authorities to improve surface
water quality and restore instream and riparian habitat through the
operation and maintenance of existing modified channels; 3)
management measures and authorities to manage the operation of
dams to protect surface water quality and instream and riparian
habitat and to assess nonpoint source problems resulting from
excessive surface water withdrawals; 4) management measures and
authorities to address chemical and pollutant control for dam
construction; and 5) management measures and authorities to
identify and develop strategies to solve existing nonpoint source
problems caused by streambank or shoreline erosion that do not
come up for review under existing permit authorities.

RATIONALE:  South Carolina implements measures in its
coastal zone for both new channelization activities and
modification of existing channels through State policies through its
Coastal Management Program (R.30-12. H. and L.).  Permit
applications are reviewed for impacts on wetlands, habitat, and
water quality.  Preference is given to less environmentally
damaging alternatives, such as constructing channels to carry
excess flows in less sensitive areas.  The State's program, however,
does not contain a process to identify opportunities to improve
surface water quality and instream and riparian habitat through
operation and maintenance of existing modified channels.  The
State used Coastal Zone Management Act 309 funds to develop
and implement a plan for restoring habitat in existing modified
channels.

For channelization projects outside of the critical area, certain
projects are subject to the Permit for Construction in Navigable
Waters.  However, the State does not have State enforceable
authority applicable to all channelization projects that could impact
coastal waters throughout the coastal zone.  

South Carolina's program implements management measures at
dams for erosion and sediment control, and for chemical and
pollutant control, through Stormwater Management and Sediment
Reduction regulations (R.72-300 et seq.).  Further implementation
of management measures for chemical and pollutant control will be
through the Pesticide Control Act (46-13-10 et seq.), the Solid
Waste Policy Act (44-96-10 et seq.), and the Hazardous Waste
Management Act (44-56-10 et seq.), which regulate the storage
and use of pesticides, and the disposal and discharge of solid and
hazardous wastes.  However, the Pesticide Act does not include
fertilizers, and the Hazardous Waste Management Act does not
cover other toxic substances that can be generated on construction
sites such as oil, gasoline, paint, and sealers.  In addition, the
State's program does not provide for proper storage and disposal of
toxic substances or the application of nutrients to establish and
maintain vegetation without causing significant nutrient runoff to
surface waters.  Where these authorities are not applicable,
however, the State has identified the Pollution Control Act (48-1-
10 et seq.) as providing a general backup enforcement authority. 

South Carolina maintains instream flows and establishes dam
releases to protect surface water quality and instream and riparian
habitats through the State navigable waters permit, the Federal
Energy Regulatory Commission (FERC) permits, and the 401
Water Quality Certification program, based on a case-by-case
review and analysis of downstream impacts.  South Carolina's
program does not have a program to manage the operation of dams
to protect surface water quality and instream and riparian habitat,
and to assess nonpoint source problems resulting from excessive
surface water withdrawals, that are not covered by the existing
programs.

South Carolina addresses the measure for shoreline or streambank
erosion through its State Stormwater Management and
Sedimentation Reduction regulations (R.72-300 et seq.). The State
also has authority to designate no wake zones (50-21-710) for
recreational boating on waterways.  However, the State does not
have a program to identify and develop strategies to solve existing
nonpoint problems caused by streambank or shoreline erosion that
do not come up for review under existing permit authorities.

     VII. WETLANDS, RIPARIAN AREAS AND VEGETATED
     TREATMENT SYSTEMS

FINDING: South Carolina's program includes management
measures in conformity with the 6217(g) guidance and enforceable
policies and mechanisms to ensure implementation, except the
State's program does not provide a process to identify and
implement opportunities to address problems in wetlands/riparian
areas in the absence of a permit application for a proposed
alteration or modification in or adjacent to an existing wetland.

CONDITION: Within three years, the State will include in its
program management measures in conformity with the 6217 (g)
guidance for wetlands/riparian areas not addressed under existing
permit authorities.

RATIONALE:  South Carolina requires a permit for dredging or
filling activities in coastal wetlands.  Proposals for new work in
coastal wetlands are reviewed for their impacts on altering
wetlands and on coastal water quality. The State's coastal program
requires development of nonpoint pollution systems to treat runoff
and sediments prior to release into wetland systems, and ensures
that wetlands systems can meet storage and release requirements
for runoff from adjacent development. The State, however, does
not have a mechanism to address adverse impacts to wetlands from
activities that are not required to seek a permit for alteration or
expansion.

Management measures promoting restoration of wetland and
riparian areas are implemented through the State's coastal
management program, and stormwater management program,
which require restoration for mitigation of wetlands loss or
degradation.  Management measures promoting vegetative
treatment systems are implemented through the State's erosion and
sediment control, and stormwater management programs, which
require development projects adjacent to wetlands to buffer
wetland systems from highly intensive land uses, and promote the
application of vegetative BMP's for stormwater runoff.

          VIII.     ADMINISTRATIVE COORDINATION

FINDING: South Carolina's program establishes mechanisms for
coordination among State agencies and between State and local
officials.

RATIONALE: South Carolina's Nonpoint Source (NPS)
Management Program is submitted to fulfill requirements for both
section 319 of the Clean Water Act, and section 6217 of the
CZMA.  The Coastal Nonpoint Pollution Control Program serves
as an update and expansion of existing NPS Management
Programs.  Thus, coordination between the primary SCDHEC
agencies (SCOCRM and SCEQC)  has been achieved by the
incorporation of the Coastal Nonpoint Program into the State's
existing NPS Management Program.  

Additionally, the State has a Nonpoint Source (NPS)Task Force
with representation from all relevant State agencies that
coordinates the various programs and activities related to nonpoint
source pollution.  The NPS Task Force meets regularly to provide
input regarding projects to be implemented as part of the NPS
Management Program and will include input for the State's NPS
Coastal Initiative.  The Task Force also identifies the list of
targeted waterbodies which are given the highest priority for
implementation program. 

     IX.  PUBLIC PARTICIPATION

FINDING: South Carolina's program provides opportunities for
public participation in the development and implementation of its
coastal nonpoint program.

RATIONALE: The State undertook early and extensive efforts to
involve a variety of parties in the development of its coastal
nonpoint program.  The State developed a questionnaire to reach
out to all county and local governments in the coastal zone, and
developed special committees that met regularly to provide input
and discuss options for development of the coastal nonpoint
program.  Additionally, the State made presentations to various
groups around the State to educate the public about the program
and about nonpoint source pollution and to encourage public
participation in the development process.  Public notices were
published in two State papers, and a public hearing was held.  The
State has included a copy of public comments and its response.

Additionally, the State developed a strategy for its nonpoint point
source pollution education and information program and devised a
process to prioritize educational needs with input from cooperating
agencies.  The State will ensure each nonpoint source category has
an  education program.  

     X.   CRITICAL COASTAL AREAS

FINDING: South Carolina's program identifies and includes a
process for the continuing identification of critical coastal areas
adjacent to impaired and threatened coastal waters. 

RATIONALE: The State has three designated areas that are
considered critical coastal areas and that require specific review
and permitting.  These three areas are: the area seaward of the
critical line as defined in its coastal management program that is
the approximate division between freshwater marsh and saltwater
marsh; Geographic Areas of Particular Concern which include
Areas of Unique Natural Resource Value, Activities or Facilities
Dependent on Coastal Location, and Areas of Special Historic,
Archeological or Cultural Significance; and receiving waterbodies. 
All three areas trigger additional management measure
implementation with the review of any project that has the
potential to impact the resource.

     XI.  ADDITIONAL MANAGEMENT MEASURES

FINDING: South Carolina's program provides for the
identification and continuing revisions of additional management
measures applicable to critical coastal areas and cases where
section 6217(g) management measures are fully implemented but
where water quality threats or impairments persist.

RATIONALE: The primary mechanisms that are outlined by the
State for determining whether additional management measures are
necessary and implementing those measures that are needed are the
Watershed Water Quality Management Strategy (WWQMS)
program and the Designated Watershed Program.  Through the
WWQMS, the State has identified land uses and potential growth
areas within the five main watersheds within the State, including
land uses that cumulatively or individually cause or threaten water
quality impairments.  Water quality monitoring data is used to
identify areas that are not attaining or maintaining water quality
standards, or that are threatened by reasonably foreseeable
increases in pollution from new or expanding sources.  If the
recommended management measures in a given area are fully
implemented but water quality impairment persists, additional
management measures will be evaluated and implemented on a
case-by-case basis.

In the Designated Watershed approach, as part of the State's
Stormwater Management and Sediment Reduction program, local
governments, through passage of a local ordinance, recommend
designation of specific watersheds.  State designation triggers
imposition of  more stringent stormwater management design
standards for development activities within the watershed.  Long
term implementation of additional management measures could be
accomplished through this approach. Additionally, the State's
coastal management program already requires additional
management measure for golf courses, which have been identified
by the State as a source of concern.

     XII. TECHNICAL ASSISTANCE

FINDING: South Carolina has included programs that will
provide technical assistance to local governments and the public
for implementing the (g) measures and additional management
measures.

RATIONALE: Technical assistance efforts were described
throughout the State's submittal, some of which are accomplished
through the State's education program.  For example, the State will
continue to educate and provide assistance to farmers regarding the
use of appropriate BMPs outlined in the USDA Field Office
Technical Guide, and the effectiveness of BMPs to address
nonpoint source problems. This, in part, is provided by SCDHEC
and the State's Cooperative Extension Service.  Likewise, for
nonpoint source impacts related to forestry, the State will conduct
annual monitoring and training sessions to ensure quality control in
the implementation and effectiveness of forestry BMPs.

          XIII.     MONITORING

FINDING:  South Carolina's program includes a plan to assess
over time the success of the management measures in reducing
pollutant loads and improving water quality.

RATIONALE:  In the program submittal, South Carolina
describes how it will apply existing and new monitoring efforts to
assess over time whether the management measures are reducing
pollutant loads and improving water quality.

     XIV.  STRATEGY AND EVALUATION OF BACKUP
     AUTHORITIES

Within one year, South Carolina will develop a strategy to
implement the management measures for agriculture, forestry, new
development, watershed protection, site development, and
construction site chemical control throughout the 6217
management area.  This strategy will include a description and
schedule for the specific steps the State will take to ensure
implementation of the management measures; describe how
existing or new authorities can be used to ensure implementation
where voluntary efforts are unsuccessful; and identify measurable
results which, if achieved, will demonstrate the State's ability to
achieve  implementation of the management measures using the
described approach.

In order to evaluate the adequacy of this strategy, South Carolina
will also develop and apply credible survey tools to demonstrate
the ability of the State's approach to achieve  implementation for
these management measures.  The use of credible assessment
techniques is necessary in order for NOAA and EPA to evaluate, at
the end of the three year period described in the March 16, 1995
guidance issued by NOAA and EPA entitled Flexibility for State
Coastal Nonpoint Programs, whether the State's approach has
been successful or whether new, more specific authorities will be
needed.