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HomeMy WebLinkAboutNCS000314_DOD Cherry Point MS4 Audit Report_20201123 MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) PROGRAM AUDIT REPORT NPDES PERMIT NO. NCS000314 MARINE CORPS AIR STATION CHERRY POINT CRAVEN COUNTY Audit Date: November 19 - 20, 2020 Report Date: November 24, 2020 North Carolina Department of Environmental Quality Division of Energy, Mineral & Land Resources Stormwater Program 512 N. Salisbury Street, 9th floor 1612 Mail Service Center Raleigh, NC 27699-1612 NCS000314_DOD Cherry Point MS4 Audit_20201119 i (This page intentionally left blank) NCS000314_DOD Cherry Point MS4 Audit_20201119 ii TABLE OF CONTENTS Audit Details .................................................................................................................................................. 1 Permittee Information .................................................................................................................................. 2 List of Supporting Documents ....................................................................................................................... 3 Program Implementation, Documentation & Assessment ........................................................................... 5 Illicit Discharge Detection and Elimination (IDDE) ........................................................................................ 9 Post-Construction Site Runoff Controls ...................................................................................................... 12 Pollution Prevention and Good Housekeeping for Municipal Operations ................................................. 13 Industrial Activities ..................................................................................................................................... 17 Monitoring .................................................................................................................................................. 20 Site Visit Evaluation: Facility No. 1 .............................................................................................................. 21 Site Visit Evaluation: Facility No. 2 .............................................................................................................. 23 Site Visit Evaluation: Facility No. 3 .............................................................................................................. 25 Site Visit Evaluation: Facility No. 4 .............................................................................................................. 27 Site Visit Evaluation: MS4 Outfall No. 1 ...................................................................................................... 29 Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1 ............................................ 31 Appendix A: Supporting Documents in Laserfiche DISCLAIMER This audit consists of an evaluation of program compliance with the issued permit and implementation of the approved Stormwater Management Plan. This audit report does not include a review of all program components, and program deficiencies in addition to those noted may be present. The permittee is required to assess program progress and permit compliance, and to implement the approved Stormwater Management Plan in accordance with the issued permit. NCS000314_DOD Cherry Point MS4 Audit_20201119 iii This page is intentionally left blank. NCS000314_DOD Cherry Point MS4 Audit_20201119 Page 1 of 33 Audit Details Audit ID Number: NCS000314_DOD Cherry Point MS4 Audit_20201119 Audit Date(s): November 19 - 20, 2020 Minimum Control Measures Evaluated: ☒ Program Implementation, Documentation & Assessment ☐ Public Education & Outreach ☐ Public Involvement & Participation ☒ Illicit Discharge Detection & Elimination ☐ Construction Site Runoff Controls – No delegated Sediment and Erosion Control Program ☐ Construction Site Runoff Controls – Delegated Sediment and Erosion Control Program ☒ Post Construction Site Runoff Controls ☒ Pollution Prevention and Good Housekeeping for Municipal Operations ☒ Oil Water Separators ☒ Industrial Activities ☒ Monitoring Requirements ☐ Impaired Waters & Total Maximum Daily Loads (TMDLs) Field Site Visits: ☒ Municipal Facilities. Number visited: 4 ☒ MS4 Outfalls. Number visited: 1 ☐ Construction Sites. Number visited: Choose an item. ☒ Post-Construction Stormwater Runoff Controls. Number visited: 1 ☐ Other: ________________________________. Number visited: Choose an item. ☐ Other: ________________________________. Number visited: Choose an item. Inspector(s) Conducting Audit Name, Title Organization Jeanette Powell, MS4 Program Coordinator DEQ-DEMLR Lauren Garcia, Raleigh Regional Office Inspector DEQ-DEMLR Audit Report Author: Jeanette Powell Signature Date: 11/24/2020 Audit Report Author: Lauren Garcia Signature Date: 11/24/2020 NCS000314_DOD Cherry Point MS4 Audit_20201119 Page 2 of 33 Permittee Information MS4 Permittee Name: Marine Corps Air Station Cherry Point Permit Effective Date: April 1, 2016 Permit Expiration Date: March 31, 2021 Mailing Address: PSC Box 8006 Cherry Point, NC 28533-0006 Date of Last MS4 Inspection/Audit: N/A Co-permittee(s), if applicable: N/A Permit Owner of Record: George W. Radford, Environmental Affairs Officer Primary MS4 Representatives Participating in Audit Dale McFarland P.E., Environmental Affairs Division, Environmental Compliance Supervisor Timothy Lawrence P.E., Environmental Affairs Division, Environmental Engineer Nathan Arnett, Environmental Affairs Division, Environmental Engineer Shannon Clunn, AECom Shea McMurry, Cherokee Nation MS4 Receiving Waters: White Oak River Basin Neuse River Core Sound Slocum Creek Bogue Sound Hancock Creek Fox Den Branch Cedar Creek Sweetbay Gut Ship Yard Branch Cedar Creek Cattail Gut Greenbriar Gut Sumac Gut Honeysuckle Gut Fern Gut NCS000314_DOD Cherry Point MS4 Audit_20201119 Page 3 of 33 List of Supporting Documents Item Number Document Title When Provided (Prior to/During/After) 1 IDDE Procedure Manual, August 2017 Prior 2 SCM Inventory & Inspection Report, March 2018 Prior 3 SPPP Plan, Volume I, October 2017 Prior 4 Comprehensive SWMP, November 2017 Prior 5 Stormwater Open Conveyance System Maintenance Action Plan, August 2016 Prior 6 Stormwater Sampling, Analysis and Monitoring Plan Vol. I, June 2017 Prior 7 Stormwater Sampling, Analysis and Monitoring Plan Vol. I, June 2017 Prior 8 Field Training Quick Reference Handbook, December 2014 During 9 Internal Environmental Compliance Evaluation (ECE) Checklist During 10 ECE Data Analysis Spreadsheet Demonstrated 11 MCAS Cherry Point Environmental Awareness Handout During 12 Public Education/Outreach Materials Demonstrated 13 Hotline Log Demonstrated 14 Spill Response Program Manual Demonstrated 15 Land Use Restriction Map Demonstrated 16 SCM O&M Plans Demonstrated 17 Stormwater Program Assessment, November 2017 Demonstrated 18 GIS MS4 Map Demonstrated 19 Air Station Orders Online 20 Monitoring Records (Visual and Analytical) Demonstrated NCS000314_DOD Cherry Point MS4 Audit_20201119 Page 4 of 33 21 Desktop Procedures / Turnover Binders Demonstrated 22 Annual Reports On File 23 Deicer SDS After NCS000314_DOD Cherry Point MS4 Audit_20201119 Page 5 of 33 Program Implementation, Documentation & Assessment Staff Interviewed: (Name, Title, Role) Dale McFarland P.E., Environmental Affairs Division, Environmental Compliance Supervisor Timothy Lawrence P.E., Environmental Affairs Division, Environmental Engineer Nathan Arnett, Environmental Affairs Division, Environmental Engineer Shannon Clunn, AECom Shea McMurry, Cherokee Nation Permit Citation Program Requirement Status Supporting Doc No. II.A.1-3 Program Implementation The permittee developed and maintained a Stormwater Plan. Yes 4 The permittee developed and maintained the authority to implement all provisions of the Stormwater Plan. Partial 19 The permittee maintained adequate funding and staffing to implement and manage the provisions of the Stormwater Plan. Partial - The permittee notified the Division of proposed major modifications to the Stormwater Plan and provided the reasons and justifications for those changes. Not Applicable - The permittee is current on payment of invoiced administering and compliance monitoring fees (see stormwater e-payments on DEMLR MS4 web page). No - Comments: Air Station Orders provide the authority to implement and require compliance with the stormwater management program and Environmental Compliance SOPs are updated regularly. The Illicit Discharge Prohibition Policy Statement needs to be finalized. Program staffing consists of approximately 1 FTE and contract support. The program is not sufficiently funded to maintain full compliance. Contract support for 2019 was not authorized and the program is struggling to prioritize and complete required activities and catch up. As of November 17, 2020, there is one overdue invoice for NPDES MS4 permit administering and compliance monitoring fees in the amount of $860. Payment was authorized to DFAS on August 25, 2020. III.1 Program Assessment Documentation The permittee maintains documentation of all program components that are being undertaken to implement the Stormwater Plan including, but not limited to, inspections, maintenance activities, educational programs, implementation of BMPs, enforcement actions, and other stormwater activities. Yes - The permittee maintains documentation of all monitoring and sampling being performed for a period of three years. Yes - NCS000314_DOD Cherry Point MS4 Audit_20201119 Page 6 of 33 Program Implementation, Documentation & Assessment Comments The permittee maintains required documentation for a minimum of three years. See details in specific sections of this audit report. III.2 Keeping the Stormwater Plan Up to Date The permittee reviewed the Stormwater Plan annually and updated as necessary. Yes 4 The permittee submitted comprehensive annual reports. Yes 22 Comments The Comprehensive SWMP includes a revision sheet which documents the annual review and any necessary updates. The SWMP is reviewed annually as a component of the annual assessment and reporting process. Comprehensive annual reports are submitted in a timely manner. Minor changes are incorporated, as necessary. Any major revisions would be submitted to the Division. There were no major updates to the Stormwater Plan during the current permit term. III.3 Stormwater Plan Modifications Did DEMLR require a modification to the Stormwater Plan? No --- If yes, did the permittee complete the modifications in accordance with the established deadline? Not Applicable --- Comments DEMLR did not require a modification to the Stormwater Plan. III.4 Additional Information Did DEMLR request additional reporting information to assess the progress and results of the Stormwater Plan? No --- If yes, did the permittee provide the information in accordance with the established deadline? Not Applicable --- Comments: DEMLR did not request any additional reporting information to assess the progress and results of the Stormwater Plan. IV.1 Records Retention The permittee documented and maintained visual monitoring records at the facility. Yes 6, 7, 20 The permittee documented and maintained analytical monitoring records at the facility. Yes 6, 7, 20 The permittee documented and maintained the Stormwater Pollution Prevention Plan at the facility. Partial 3 NCS000314_DOD Cherry Point MS4 Audit_20201119 Page 7 of 33 Program Implementation, Documentation & Assessment The permittee retained records of all monitoring information, including all calibration and maintenance records and all original strip chart recordings for continuous monitoring instrumentation, and copies of all reports required by this Permit for a period of at least 5 years from the date of the sample, measurement, report or application. Yes 6, 7, 20 Comments: The permittee demonstrated visual and analytical monitoring records during the audit. Records were maintained and monitoring was performed in accordance with the Stormwater Sampling, Analysis and Monitoring Plan. The permittee utilizes the state’s standard SDO DMR form. There were some unsigned forms completed in 2017, but otherwise documentation was in order. The Stormwater Pollution Prevention Plan is located in the Environmental Affairs office, but individual sites did not have a copy of the facility drainage map or pollution prevention activities/practices applicable to their site. IV.4 Twenty-four Hour Reporting The permittee reported to DEMLR any noncompliance that may constitute an imminent threat to health or the environment. Not Applicable - If yes, did the permittee provide the information orally within 24 hours? Not Applicable - If yes, did the Director waive the written report when the oral report was received within 24 hours? Not Applicable - Did the permittee provide a written report within 5 days? Not Applicable - If yes, did the written report contain a description of the noncompliance, and its causes; the period of noncompliance, including exact dates and times, and if the noncompliance has not been corrected, the anticipated time compliance is expected to continue; and steps taken or planned to reduce, eliminate, and prevent reoccurrence of the noncompliance? Not Applicable - Comments: There were no reportable events during the current permit term. NCS000314_DOD Cherry Point MS4 Audit_20201119 Page 8 of 33 Program Implementation, Documentation & Assessment Additional Comments: The permittee is well organized, informed, and aware of activities on base that impact water quality. The Environmental Affairs staff maintain good working relationships with facility staff and implement a good stormwater management program with the available resources. Observed compliance deficiencies are primarily due to underfunding of the program and contract support. Specific administration compliance issues to address include: • Fully fund the Stormwater Program • Finalize the Illicit Discharge Prohibition Policy Statement • Push SPPPs out to each industrial facility and provide stormwater-specific training to facility staff • Ensure standard forms/official records are fully completed • Include appropriate stormwater items on the standard ECE Checklist • Verify payment of the 2020 invoice for NPDES MS4 permit administering and compliance monitoring fees It is recommended that: • The pool backwash facility and operation and maintenance SOP be inspected/reviewed • Handwritten documents be typed for legibility and backup documentation • Staff be trained to complete all spaces in official forms NCS000314_DOD Cherry Point MS4 Audit_20201119 Page 9 of 33 Illicit Discharge Detection and Elimination (IDDE) Staff Interviewed: (Name, Title, Role) Dale McFarland P.E., Environmental Affairs Division, Environmental Compliance Supervisor Timothy Lawrence P.E., Environmental Affairs Division, Environmental Engineer Nathan Arnett, Environmental Affairs Division, Environmental Engineer Shannon Clunn, AECom Shea McMurry, Cherokee Nation Permit Citation Program Requirement Status Supporting Doc No. II.D.2.a Storm Sewer System Map The permittee maintained, assessed, and updated as necessary a map identifying major outfalls. Yes 18 The map components include major outfalls and receiving streams, and type of conveyance system (i.e., either closed pipe or open drainage). Yes 18 For closed pipe systems, the map identifies the pipe material, shape, and size. Partial 18 Comments The GIS MS4 map was demonstrated during the audit and contained appropriate fields to comply with the permit conditions. Some data was missing for pipe sizes. Other fields were completed appropriately. *Major outfalls are discharges from > 36” diameter pipes or drainage areas of > 50 acres. In areas zoned for industrial activity, major outfalls are > 12” or drainage area > 2 acres. II.D.2.b Dry Weather Screening The permittee maintains a written field screening procedure for detecting and tracing the sources of illicit discharges and for removing the sources or reporting the sources to the State to be properly permitted. Yes 1 The permittee implemented a program for conducting regular dry weather flow field observations in accordance with the written field screening procedure. Yes 1 Comments: The permittee performs regular dry weather screening and implements the written IDDE Procedure Manual. II.D.2.c Written Illicit Discharge Procedures The permittee maintained written procedures for conducting investigations into the source of all identified illicit discharges, including approaches to requiring such discharges to be eliminated. Yes 1 If yes, the written procedures were assessed annually and updated as necessary. Yes 1 Comments: The permittee maintained written procedures in the IDDE Procedure Manual for conducting investigations into the source of all identified illicit discharges, including approaches to requiring such discharges to be eliminated. II.D.2.d The permittee tracked and documented all illicit discharge investigations. Yes 1 NCS000314_DOD Cherry Point MS4 Audit_20201119 Page 10 of 33 Illicit Discharge Detection and Elimination (IDDE) Illicit Discharge Investigations If yes, the date(s) the illicit discharge was observed; the results of the investigation; any follow-up of the investigation; and the date the investigation was closed were documented. Yes 1 Comments: The permittee maintains a standard process for inspections and follow up, and a standard format is utilized for reporting and tracking illicit discharge investigations. II.D.2.e Employee Training The permittee implemented a training program for appropriate personnel who, as part of their normal job responsibilities, may come into contact with or otherwise observe an illicit discharge or illicit connection to the storm sewer system. Partial If yes, the permittee documented the training program including identified appropriate personnel, the schedule for conducting the training and the proper procedures for reporting and responding to an illicit discharge or connection. Yes The permittee provided follow-up training as needed to address changes in personnel, procedures, or techniques. Partial Comments: Base onboarding includes general stormwater awareness training. Environmental Coordinators (ECs) and Assistant Coordinators (ACs) at individual facilities are trained in spill response and management of hazardous materials. Landscape and public works employees do not receive specific training on illicit discharge identification. However, base-wide public education and outreach efforts do publicize a hotline to report observation of any unusual environmental issues. Training is managed through an electronic Learning Management System. At industrial facilities, the EC and AC complete monthly inspections and the facility CO is responsible for ensuring that follow-up training is provided to address changes in personnel, procedures, or techniques. Environmental Affairs reviews each facility annually. II.D.2.f Public Education The permittee informed public employees of hazards associated with illegal discharges and improper disposal of waste. Yes 12 The permittee informed businesses of hazards associated with illegal discharges and improper disposal of waste. Yes 12 The permittee informed the general public of hazards associated with illegal discharges and improper disposal of waste. Yes 12 Comments: In addition to required training at onboarding, the permittee relies heavily on the public education and outreach program to inform those on base about stormwater, illegal discharges, and proper waste disposal. The permittee does not maintain a budget for these informational handouts/products. NCS000314_DOD Cherry Point MS4 Audit_20201119 Page 11 of 33 Illicit Discharge Detection and Elimination (IDDE) II.D.2.g Reporting Mechanism The permittee promoted, publicized, and facilitated a reporting mechanism for the public to report illicit discharges. Yes 12 The permittee promoted, publicized, and facilitated a reporting mechanism for staff to report illicit discharges. Yes 12 The permittee established and implemented response procedures for citizen requests/reports. Yes 1, 14 The permittee conducted reactive inspections in response to complaints. Yes The permittee conducted follow-up inspections as needed to ensure that corrective measures have been implemented by the responsible party to achieve and maintain compliance. Yes Comments: The permittee relies heavily on onboarding training and promotional handouts/products to inform those on base. The web page also includes reporting information. Complaints are logged and inspected utilizing standard procedures, reporting, and tracking. Follow-up inspections are performed, and investigations are tracked through completion. II.D.2.h Sanitary Sewer Overflows The permittee implemented written procedures to identify and report sanitary sewer overflows and sewer leaks to the system operator. Yes 14 If yes, the permittee assessed annually, and updated as necessary the written procedures to identify and report sanitary sewer overflows and sewer leaks to the system operator. Yes 14 Comments: The permittee maintains standard procedures in the Spill Response Program Manual and reports sanitary sewer overflows to the system operator. Additional Comments: Specific compliance issues to address include: • Provide illicit discharge identification and reporting training to industrial facility, landscape and public works staff who are most likely to observe these issues during their routine duties • Ensure MS4 pipe size data is complete in the GIS MS4 map It is recommended that: • A specific budget be established for promotional products/handouts which are heavily relied upon to meet multiple permit conditions NCS000314_DOD Cherry Point MS4 Audit_20201119 Page 12 of 33 Post-Construction Site Runoff Controls Staff Interviewed: (Name, Title, Role) Dale McFarland P.E., Environmental Affairs Division, Environmental Compliance Supervisor Timothy Lawrence P.E., Environmental Affairs Division, Environmental Engineer Nathan Arnett, Environmental Affairs Division, Environmental Engineer Shannon Clunn, AECom Shea McMurry, Cherokee Nation Implementation (check all that apply): ☒ The permittee implements some components of this minimum measure. ☒ The permittee relies upon another entity to implement some components of this minimum measure: NCDEQ WARO Permit Citation Program Requirement Status Supporting Doc No. F.2. Post-Construction Runoff Controls The permittee submits projects disturbing 1 acre or more to the DEMLR WARO for review and approval. Yes 2, 15 Projects include public roads and bridges. Yes - The permittee implements a DEQ-approved approved Comprehensive Watershed Protection Plan. Not Applicable - Comments: The permittee relies upon NCDEQ-DEMLR Washington Regional Office to review and approve post-construction stormwater control plans for new development. The permittee maintains approved plans, as-built drawings, O&M Plans, and a land use restriction map that defines the permitted project area for each SCM device. The permittee is responsible for required inspections and operation and maintenance of SCMs in accordance with the DEQ-approved O&M plans. The permittee has not performed SCM inspections annually, as required. A comprehensive SCM inventory and evaluation was performed in 2018. The primary focus for inspections and maintenance/rehabilitation is on SCM devices that are due for permit renewal. DEQ staff performed a “drive by” inspection of multiple SCMs on base, which revealed that many devices are in need of major maintenance/repair/refurbishment. The permittee does not maintain an adequate program budget to perform the minimum required SCM inspections and maintenance. Additional Comments: Specific compliance issues to address include: • Perform annual inspections of all SCMs • Maintain all SCMs in accordance with permit and approved O&M Plans NCS000314_DOD Cherry Point MS4 Audit_20201119 Page 13 of 33 Pollution Prevention and Good Housekeeping for Base Operations Staff Interviewed: (Name, Title, Role) Dale McFarland P.E., Environmental Affairs Division, Environmental Compliance Supervisor Timothy Lawrence P.E., Environmental Affairs Division, Environmental Engineer Nathan Arnett, Environmental Affairs Division, Environmental Engineer Shannon Clunn, AECom Shea McMurry, Cherokee Nation Permit Citation Program Requirement Status Supporting Doc No. II.G.2.a & b Facility Inventory The permittee developed an inventory of facilities and operations with the potential for generating polluted stormwater runoff (map or list). Yes 3, 18 The permittee identified the stormwater outfalls corresponding to each of the facilities. Yes 3, 18 The permittee identified the receiving waters to which each facility discharges. Yes 3, 18 The permittee maintained and updated the inventory annually. Yes 4 Comments: The permittee maintains an inventory of relevant industrial SIC facilities and GIS layers that define the drainage areas, outfalls and receiving waters for each facility. Facility information sheets are maintained in the Appendix F of the SPPP and the SWMP includes an inventory list, which is reviewed and updated annually. II.G.2.c Operation and Maintenance (O&M) for Facilities The permittee maintained and implemented an O&M program for facilities and operations with the potential for generating polluted stormwater runoff. Yes 3 If yes, the O&M program specifies the frequency of inspections. Yes - If yes, the O&M program specifies the frequency of routine maintenance requirements. Yes - Comments: The permittee implements monthly ECE inspections at industrial facilities, which are performed by the EC in accordance with Air Station Orders. The monthly inspection records are maintained on site and are available upon request. The ECE checklist is a multi-faceted environmental inspection form, but does not include a specific section for stormwater. II.G.2.d Spill Response Procedures The permittee has written spill response procedures for facilities and operations with the potential for generating polluted stormwater runoff. Yes 3, 13, 14 NCS000314_DOD Cherry Point MS4 Audit_20201119 Page 14 of 33 Pollution Prevention and Good Housekeeping for Base Operations Comments: The permittee maintains a Spill Response Program Manual, Hotline Log and base-wide SPPP. ECs are trained to ensure that standard protocols are implemented. The permittee checks five major outfalls and spill gates weekly. II.G.2.e Streets, Roads, and Public Parking Lot Maintenance The permittee implements BMPs selected to reduce polluted stormwater runoff from base streets, roads, and parking lots. Yes - Comments: The permittee’s public works department implements sweeping and/or blowing on runways and paved surfaces that have curb and gutter. A daily log of quantity of materials collected is maintained, and street sweepings are properly disposed of in the landfill. II.G.2.f O&M for Catch Basins and Conveyance Systems The permittee developed an O&M program for the stormwater sewer system. If yes, then: Yes 5 The O&M Program includes catch basins and conveyance systems. Partial - The O&M Program includes route maps. Partial - The O&M Program specifies the frequency of inspections. Partial - The O&M Program specifies the routine maintenance requirements. Partial - Comments: The permittee developed a Stormwater Open Conveyance System Maintenance Action Plan and maintains the stormwater collection system on an as-needed basis. There is no routine collection system inspection program. Repairs are prioritized on the Work Induction Board. II.G.2.g Structural Stormwater Controls The permittee developed an inventory (map or list) of structural stormwater control measures. If yes, then: Yes 18 The inventory identifies the stormwater outfalls corresponding to each structural stormwater control measure. Yes 18 The inventory identifies the receiving waters to which each structural stormwater control measure discharges. Yes 18 The inventory of structural stormwater control measures is maintained and updated regularly. Yes 18 Comments: The permittee maintains GIS layers that includes the permitted project area, outfall(s) and receiving water(s) for each SCM device. The inventory is updated as new devices are accepted, and approved plans and as-built plans are maintained. NCS000314_DOD Cherry Point MS4 Audit_20201119 Page 15 of 33 Pollution Prevention and Good Housekeeping for Base Operations II.G.2.h O&M for Structural Stormwater Controls The permittee maintained and implemented an O&M program for structural stormwater controls. Partial 2, 16 The O&M program specified the frequency of inspections. Yes - The O&M program specified the routine maintenance requirements. Yes - The permittee inspected all structural stormwater controls in accordance with the schedule developed by permittee. No - The permittee maintained all structural stormwater controls in accordance with the schedule developed by permittee. No - The permittee documented inspections of all structural stormwater controls. Yes - The permittee documented maintenance of all structural stormwater controls. Yes - Comments: The permittee utilizes the standard O&M agreements in the DEQ SCM Manual and documents SCM inspections utilizing a standardized form and tracking mechanism. The permittee developed a comprehensive SCM Inventory and Inspection Report in 2018, but does not perform and document annual inspections of each device as required by the standard O&M agreements. Deferred maintenance was evident in multiple SCMs. II.G.2.i Staff Training The permittee implemented an employee training program for personnel involved in implementing pollution prevention and good housekeeping practices. Partial 8, 11, 12, 21 Comments: The permittee performs environmental and stormwater awareness training as part of the base-wide onboarding process, which includes contractors that will be on site for thirty (30) days or more. Environmental Coordinators and Assistant Coordinators are assigned to each facility and receive additional training in spill response, materials management, and proper disposal. The Field Training Quick Reference Book also includes relevant information for field operations. Public education is also a large component of base-wide training and awareness. EC and AC staff turnover frequently. Staff maintain desktop turnover binders annually, which include position-specific SOPs. Stormwater-specific pollution prevention and good housekeeping should be added for industrial facility staff training and standard ECE inspection forms. Ensure that each facility has an active EC and AC. II.G.2.j Vehicle and Equipment Cleaning The permittee described and implemented measures that prevent or minimize contamination of stormwater runoff from all areas used for vehicle and equipment cleaning. Yes 3 Comments: The permittee implements appropriate protocols for vehicle and equipment cleaning. Wash racks are required to be used for tactical vehicles, aircraft, and small equipment. NCS000314_DOD Cherry Point MS4 Audit_20201119 Page 16 of 33 Pollution Prevention and Good Housekeeping for Base Operations Additional Comments: Specific compliance issues to address include: • Implement and document an MS4 system inspections and maintenance program (II.G.2.f) • Add a stormwater section to the ECE Checklist or develop a separate stormwater inspection form • Implement and document stormwater pollution prevention and good housekeeping training for staff at subject facilities • Institutionalize SPPP components at industrial facilities • Ensure that each facility maintains a trained EC and AC NCS000314_DOD Cherry Point MS4 Audit_20201119 Page 17 of 33 Industrial Activities Staff Interviewed: (Name, Title, Role) Dale McFarland P.E., Environmental Affairs Division, Environmental Compliance Supervisor Timothy Lawrence P.E., Environmental Affairs Division, Environmental Engineer Nathan Arnett, Environmental Affairs Division, Environmental Engineer Shannon Clunn, AECom Shea McMurry, Cherokee Nation Permit Citation Program Requirement Status Supporting Doc No. II.H.2.a NCG08 for Vehicle Maintenance Facilities The permittee implements the requirements of NCG08 for vehicle maintenance areas with point source discharges of stormwater, including vehicle rehabilitation, mechanical repair, painting, fueling, lubrication, equipment cleaning operations and like activities. If yes, implementation includes: Not Applicable - List of significant spills and leaks of pollutants during the previous three (3) years and any corrective actions taken to mitigate spill impacts. Not Applicable - Proper management of outdoor cleaning activities. Not Applicable - Proper management of remote fueling activities Not Applicable - Spill prevention and response procedures. Not Applicable - Facility inspections at least semi-annually. Not Applicable - Estimated new motor oil and hydraulic oil usage (gal/month). Not Applicable - Implementation of appropriate Tiered responses. Not Applicable - Comments: The permittee implements a base wide SPPP. See II.H.3 below. II.H.2.b NCG15 for Air Transportation Facilities The permittee implements the requirements of NCG15 air transportation for facilities with point source discharges of stormwater, including air transportation, airports, aircraft service and maintenance including: aircraft cleaning, servicing/repair, maintenance shops, rehabilitation, painting, fueling, lubrication and material handling facilities. Not Applicable - List of significant spills and leaks of pollutants during the previous three (3) years and any corrective actions taken to mitigate spill impacts. Not Applicable - Annual certification of outfall evaluation for non-stormwater discharges. Not Applicable - NCS000314_DOD Cherry Point MS4 Audit_20201119 Page 18 of 33 Industrial Activities Appropriate secondary containment requirements and records. Not Applicable - Inventory of all liquid bulk storage, SARA 313 priority chemicals, and hazardous substances. Not Applicable - Pre-release inspections of accumulated rainwater. Not Applicable - Facility and stormwater system inspections at least semi-annually. Not Applicable - Appropriate vehicle and equipment cleaning practices. Not Applicable - Records of annual usage rate of deicing/anti-icing chemicals. Not Applicable - Comments: The permittee implements a base wide SPPP. See II.H.3 below. II.H.3 Base Wide SPPP & Monitoring Plan In lieu of complying with the requirements of paragraph 2 of this section [II.H.2] , the permittee proposed and submitted to the Division for their approval a base wide SPPP and Monitoring Plan that effectively meets the requirements to develop, maintain and implement a SPPP and Monitoring Plan for each facility and/or area with an industrial activity covered by this permit. Yes 3, 6, 7, 9, 10, 23 Comments: The permittee implements a base wide SPPP that incudes each facility/area with an industrial activity, as determined by SIC code. A base wide monitoring plan includes designation of representative outfalls and appropriate analytical monitoring. Benchmark cutoff concentrations are utilized appropriately and discontinuation of analytical monitoring in accordance with the benchmarks/tiers is documented in the annual report. EC’s perform monthly inspections utilizing a standard Internal Environmental Compliance Evaluation (ECE) Checklist. However, the ECE checklist is focused primarily on hazardous waste and spill management and does not include specific stormwater pollution prevention and good housekeeping measures. The permittee evaluates the ECE data utilizing a standardized spreadsheet. Per Site Visit Evaluation: Facility 3 the aircraft deicing procedure is to allow deicer runoff to infiltrate into a grassed basin. The SDS for the material used was provided following the audit. The permittee should evaluate this practice/material to ensure that it does not adversely affect the environment. However, no deicing activity has occurred during the permit term due to broken equipment. The ECE form needs a stormwater section, and the SPPP requirements and drainage area maps need to be institutionalized at each facility. NCS000314_DOD Cherry Point MS4 Audit_20201119 Page 19 of 33 Industrial Activities II.I Oil Water Separators The permittee developed an inventory of oil water separators that discharge to either the stormwater system, directly into the waters of the state, or have engineered diversionary catchment basins. If yes, the inventory includes: Yes 3, 18 The location of the oil water separator Yes - The activities that occur in the oil water separator’s drainage area Yes - The materials that are handled in the drainage area Yes - The name of the water body to which it drains Yes - The number of the outfall that the oil water separator discharges into Yes - The drainage area draining into the oil water separator Yes - The oil water separator’s design capacity Yes - Comments: The permittee maintains a GIS layer with OWS inventory data including the items above and designation as sanitary, stormwater or industrial. Additional Comments: Specific compliance issues to address include: • Add a stormwater section to the ECE Checklist or develop a separate stormwater inspection form • Implement and document stormwater pollution prevention and good housekeeping training for staff at subject facilities • Institutionalize SPPP components at industrial facilities • Ensure that each facility maintains a trained EC and AC It is recommended to: • Evaluate aircraft deicer materials/practices NCS000314_DOD Cherry Point MS4 Audit_20201119 Page 20 of 33 Monitoring Staff Interviewed: (Name, Title, Role) Dale McFarland P.E., Environmental Affairs Division, Environmental Compliance Supervisor Timothy Lawrence P.E., Environmental Affairs Division, Environmental Engineer Nathan Arnett, Environmental Affairs Division, Environmental Engineer Shannon Clunn, AECom Shea McMurry, Cherokee Nation Permit Citation Program Requirement Status Supporting Doc No. II.J.1.a-d Base-wide Analytical Monitoring The permittee performed annual qualitative monitoring at each outfall associated with industrial activity and/or each representative outfall. If yes: Yes 6, 7, 17 Parameters included TSS, Oil and Grease, and pH. Yes - Cutoff concentrations were applied appropriately. Yes - Comments: The permittee implements a base wide monitoring plan, which includes designation of representative outfalls and appropriate analytical monitoring for all parameters. Benchmark cutoff concentrations are utilized appropriately. Discontinuation of analytical monitoring in accordance with the benchmarks/tiers is documented in the annual report. II.J.1.e Base Wide Qualitative Monitoring Qualitative monitoring is performed twice per year (spring and fall) at each stormwater outfall associated with industrial activities and/or oil water separators regardless of representative outfall status. Yes - Comments: The permittee demonstrated standardized documentation of qualitative monitoring twice per year. Additional Comments: N/A NCS000314_DOD Cherry Point MS4 Audit_20201119 Page 21 of 33 Site Visit Evaluation: Facility No. 1 Facility Name: MASS - 1 Date and Time of Site Visit: 11/20/2020 at 9:00am Facility Address: USMC Cherry Point Building 3960 Facility Type: Transportation and Utilities Name of MS4 inspector(s) evaluated: Timothy Wright, Chief Warrant Officer II, MASS – 1 Environmental Coordinator Most Recent MS4 Inspection: 10/15/2020 Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit: Name and Title Nathan Arnett, Environmental Affairs Division, Environmental Engineer Shannon Clunn, AECom Shea McMurry, Cherokee Nation Matt Wallin, EAD Training Coordinator Observations Facility Documentation/Training Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility-specific? The facility has an onsite binder containing monthly EC audit reports. The monthly audits consist of the standard ECE checklist. Facility maps showing drainages, piping and exposure areas were not maintained on site. What type of stormwater training do facility employees receive? How often? Facility staff receive general environmental and stormwater awareness training at onboarding. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? The Environmental Coordinator and Assistant Coordinator receive annual RCRA and Environmental Coordinator training. Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? The EC appeared knowledgeable about EC responsibilities and requirements. However, the EC did not look at the site in relation to stormwater as much as hazardous waste and exposure; was not aware of the location of the outdoor spill kit and did not know where storm drains outlet from the facility. He did not take notes or pictures while performing the inspection, but appeared to know the facility very well. Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping? The EC appeared knowledgeable about good housekeeping. His inspection consisted of looking for oil spills and making sure the facility was clean; however, the standard inspection procedure is not developed around stormwater pollution prevention. Inspection Procedures Does the MS4 inspector’s process include the use of a checklist or other standardized form? Yes, the monthly EC audit consists of the standard ECE checklist. NCS000314_DOD Cherry Point MS4 Audit_20201119 Page 22 of 33 Site Visit Evaluation: Facility No. 1 Does the MS4 inspector’s process include taking photos? The inspector utilizes photographs when specific deficiencies are found. Does the MS4 inspector’s process include reviewing the facility’s SWPPP (or similar document)? The monthly audits are documented in the ECE checklist that are maintained in the onsite binder. The SPPP documentation is not maintained on site. Does the MS4 inspector’s process include walking the entire facility and inspecting all points of discharge? The inspector walked the entire facility. Outfalls were not observed, and the inspector was unaware of where storm drains at the site outlet. Did the MS4 inspector miss any obvious areas of concern? If so, explain: The outside spill kit was not visible from the fueling island or labelled. Does the MS4 inspector’s process include presenting the inspection findings to the facility contact? If deficiencies are found during the inspection, the EC contacts the CO who is responsible for resolving issues. Inspection Results Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)? No. If compliance corrective actions were identified, what timeline for correction/follow-up was provided? N/A Notes/Comments/Recommendations It was noted during the inspection that industrial facilities should maintain the SPPP on site (drainage maps, required stormwater pollution prevention / good housekeeping activities, etc.). The ECE form needs to include a stormwater section and training on stormwater specific practices should be provided to all staff. NCS000314_DOD Cherry Point MS4 Audit_20201119 Page 23 of 33 Site Visit Evaluation: Facility No. 2 Facility Name: MSCS Auto Skills Center (aka Hobby Shop) Date and Time of Site Visit: 11/20/2020 at 10:25 am Facility Address: USMC Cherry Point Building 4562 Facility Type (Vehicle Maintenance, Landscaping, etc.): Vehicle Maintenance Name of MS4 inspector(s) evaluated: Matt Hood, Facility Contact Most Recent MS4 Inspection: Only RCRA Inspections have been completed onsite. No Environmental Audits have occurred. Facility Environmental Coordinator was not completing the additional documents. Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit: Name and Title Nathan Arnett, Environmental Affairs Division, Environmental Engineer Shannon Clunn, AECom Shea McMurry, Cherokee Nation Matt Wallin, EAD Training Coordinator Observations Facility Documentation/Training Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility-specific? The facility has an onsite binder containing monthly inspection reports. Facility maps showing drainages, piping and exposure areas were not maintained on site. What type of stormwater training do facility employees receive? How often? Facility staff receive general environmental and stormwater awareness training at onboarding. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? The Environmental Coordinator and Assistant Coordinator receive annual RCRA and Environmental Coordinator training. Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? The facility EC was not available during the audit. The onsite contact was familiar with good housekeeping and the facility was clean. Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping? Same comment – facility inspectors are not focused on stormwater pollution prevention, but do keep the facility clean and orderly to satisfy other environmental requirements for hazardous waste. Inspection Procedures Does the MS4 inspector’s process include the use of a checklist or other standardized form? Yes. However, the standard ECE form was not being completed. NCS000314_DOD Cherry Point MS4 Audit_20201119 Page 24 of 33 Site Visit Evaluation: Facility No. 2 Does the MS4 inspector’s process include taking photos? No. Does the MS4 inspector’s process include reviewing the facility’s SWPPP (or similar document)? The monthly audits are documented using the ECE checklist and are maintained in the onsite binder. The SPPP documentation is not maintained on site. Does the MS4 inspector’s process include walking the entire facility and inspecting all points of discharge? Yes. Did the MS4 inspector miss any obvious areas of concern? If so, explain: There was not a plug in the onsite dumpster. There is an uncovered scrap metal bin onsite that was full of water during the site visit. Does the MS4 inspector’s process include presenting the inspection findings to the facility contact? Yes, if there are issues found. Inspection Results Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)? No. If compliance corrective actions were identified, what timeline for correction/follow-up was provided? N/A Notes/Comments/Recommendations The facility EC and AC were not available to perform the inspection. It was noted during the inspection that industrial facilities should maintain the SPPP on site (drainage maps, required stormwater pollution prevention / good housekeeping activities, etc.). The ECE form needs to include a stormwater section and training on stormwater specific practices should be provided to all staff. NCS000314_DOD Cherry Point MS4 Audit_20201119 Page 25 of 33 Site Visit Evaluation: Facility No. 3 Facility Name: Regional MEOTC Date and Time of Site Visit: 11/20/2020 at 11:00am Facility Address: USMC Cherry Point Facility Type (Vehicle Maintenance, Landscaping, etc.): Airport, Fueling and De-icing Name of MS4 inspector(s) evaluated: Lavon Vance, Visiting Aircraft Line Supervisor Most Recent MS4 Inspection (Date and Entity): Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit: Nathan Arnett, Environmental Affairs Division, Environmental Engineer Shannon Clunn, AECom Shea McMurry, Cherokee Nation Matt Wallin, EAD Training Coordinator Observations Facility Documentation/Training Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility-specific? There was no SWPPP maintained on site. What type of stormwater training do facility employees receive? How often? Facility staff receive general environmental and stormwater awareness training at onboarding. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? The Environmental Coordinator and Assistant Coordinator receive annual RCRA and Environmental Coordinator training. However, it was unclear whether this facility had an EC and/or AC assigned. Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? No. Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping? The inspector appeared knowledgeable about good housekeeping for pavement management, fueling and de-icing on the runway. Inspection Procedures Does the MS4 inspector’s process include the use of a checklist or other standardized form? No. Does the MS4 inspector’s process include taking photos? No. Does the MS4 inspector’s process include reviewing the facility’s SWPPP (or similar document)? No. NCS000314_DOD Cherry Point MS4 Audit_20201119 Page 26 of 33 Site Visit Evaluation: Facility No. 3 Does the MS4 inspector’s process include walking the entire facility and inspecting all points of discharge? The inspector performed a visual review of the fueling and de-icing areas at the request of the DEQ auditor. Did the MS4 inspector miss any obvious areas of concern? If so, explain: No. Does the MS4 inspector’s process include presenting the inspection findings to the facility contact? No. The inspector was the facility supervisor and is the responsible party for remedies. Inspection Results Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)? Yes. Assign an EC to the facility and complete monthly inspection audits. If compliance corrective actions were identified, what timeline for correction/follow-up was provided? N/A Notes/Comments/Recommendations This facility operates primarily as a passenger airport and aircraft handling/support facility. Staff perform fueling operations and deicing operations on aircraft. De-icing material is mixed 50/50 with water in the de-icing truck. The empty drums are used to fill truck with the correct amount of water for the mixture. Facility contact keeps 4-5 empty drums onsite in case there is a problem with the de-icing fluid and the mixture needs to be pumped out of the truck. There has been no de-icing activity in the last two years. The de-icing truck has been broken for two years. Deicing overspray falls into a paved catchment area and is directed into a grassed median to infiltrate. This facility needs an assigned EC and AC. Runway services staff should receive stormwater pollution prevention training. A SPPP should be maintained on site. It was noted during the inspection that industrial facilities should maintain the SPPP on site (drainage maps, required stormwater pollution prevention / good housekeeping activities, etc.). The ECE form needs to include a stormwater section and training on stormwater specific practices should be provided to all staff. NCS000314_DOD Cherry Point MS4 Audit_20201119 Page 27 of 33 Site Visit Evaluation: Facility No. 4 Facility Name: Work Center 510 Hanger 250 Date and Time of Site Visit: 11/20/2020 at 11:45 am Facility Address: USMC Cherry Point Hanger 250 Facility Type (Vehicle Maintenance, Landscaping, etc.): Aircraft Maintenance Name of MS4 inspector(s) evaluated: Brent Harriman, Environmental Coordinator Most Recent MS4 Inspection (Date and Entity): October 2020 ECE Inspection Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit: Nathan Arnett, Environmental Affairs Division, Environmental Engineer Shannon Clunn, AECom Shea McMurry, Cherokee Nation Matt Wallin, EAD Training Coordinator Observations Facility Documentation/Training Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility-specific? The Environmental Affairs Division maintains a base wide SPPP with facility drainage plans and stormwater pollution prevention activities, but this information was not available at the facility. What type of stormwater training do facility employees receive? How often? Facility staff receive general environmental training at onboarding. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? The Environmental Coordinator and Assistant Coordinator receive annual RCRA and Environmental Coordinator training. Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? The inspector was knowledgeable about hazardous waste and good housekeeping, but was not familiar with stormwater requirements. Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping? The inspector was knowledgeable about hazardous waste and the facility, but was not familiar with stormwater pollution prevention and good housekeeping measures. Inspection Procedures Does the MS4 inspector’s process include the use of a checklist or other standardized form? Yes, the standard ECE checklist. NCS000314_DOD Cherry Point MS4 Audit_20201119 Page 28 of 33 Site Visit Evaluation: Facility No. 4 Does the MS4 inspector’s process include taking photos? Only if an issue is encountered. Does the MS4 inspector’s process include reviewing the facility’s SWPPP (or similar document)? No, the EC and AC are not trained specifically in stormwater pollution prevention or the details of the SPPP. Does the MS4 inspector’s process include walking the entire facility and inspecting all points of discharge? The inspector walked the entire facility. Outfalls were not specifically observed, and the inspector was unaware of where storm drains at the site discharge to. Did the MS4 inspector miss any obvious areas of concern? If so, explain: Some empty containers without lids were placed outside in the facility dumpsters. It was stated that multiple areas utilize the dumpsters and controlling the waste management has been an ongoing issue. Does the MS4 inspector’s process include presenting the inspection findings to the facility contact? If deficiencies are found during the audit, the ECE contacts the necessary party to handle the issue. The CO is responsible for remedies and any follow-up training that may be needed. Inspection Results Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)? No. If compliance corrective actions were identified, what timeline for correction/follow-up was provided? N/A Notes/Comments/Recommendations The facility EC and AC were not available for the inspection. An inspector from another area performed the inspection. It was noted during the inspection that industrial facilities should maintain the SPPP on site (drainage maps, required stormwater pollution prevention / good housekeeping activities, etc.). The ECE form needs to include a stormwater section and training on stormwater specific practices should be provided to all staff. NCS000314_DOD Cherry Point MS4 Audit_20201119 Page 29 of 33 Site Visit Evaluation: MS4 Outfall No. 1 Outfall ID Number: Outfall 2 Date and Time of Site Visit: 11/20/2020 at 2:00pm Outfall Location: Sandy Branch – FRC East – Mockingbird Trail Outfall Description (Pipe Material/Diameter, Culvert, etc.): A drainage ditch discharges into the Sandy Branch in this area, but the monitoring station is located a few feet to the left of the discharge point and the outlet of the tube that the dip cup is inserted into for the sample is located beneath the surface of the water. Receiving Water: Sandy Branch Is Flow Present? If So, Describe (Color, Approximate Flow Rate, Sheen, Odor, Floatables/Debris, etc.): No flow Most Recent Outfall Inspection/Screening (Date): 11/13/2020 Days Since Last Rainfall: 6 Inches: Unknown Name of MS4 Inspector(s) evaluated: Nathan Arnett, Environmental Affairs Division, Environmental Engineer Shannon Clunn, AECom Observations Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? On-the-job training and DEQ Webinars. Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations? The inspectors demonstrated knowledge of illicit discharge indicators and investigations. Inspection Procedures Does the inspector’s process include the use of a checklist or other standardized form? Yes, DMRs and qualitative sampling reports are utilized. Does the inspector’s process include taking photos? Photos are utilized where specific issues are identified. Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they? The inspector did not miss any obvious indicators or maintenance issues. NCS000314_DOD Cherry Point MS4 Audit_20201119 Page 30 of 33 Site Visit Evaluation: MS4 Outfall No. 1 Inspection Results Did the outfall inspection result in any work orders or maintenance requests? If so, for what issue(s)? N/A Will a follow-up outfall inspection be conducted? If so, for what reason? N/A Notes/Comments/Recommendations N/A NCS000314_DOD Cherry Point MS4 Audit_20201119 Page 31 of 33 Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1 Site Name: SCM 50 Date and Time of Site Visit: 11/20/2020 at 10:00 am Site Address: USMC Cherry Point Building 3960 Outside of the Maintenance Facility on Bulldog Road SCM Type: Infiltration Basin Most Recent MS4 Inspection (Include Date and Entity): 2018 Name of MS4 Inspector(s) evaluated: Nathan Arnett, Environmental Affairs Division, Environmental Engineer Most Recent MS4 Enforcement Activity (Include Date): Name(s) and Title(s) of Site Representative(s) Present During the Site Visit: Name and Title Nathan Arnett, Environmental Affairs Division, Environmental Engineer Shannon Clunn, AECom Shea McMurry, Cherokee Nation Matt Wallin, EAD Training Coordinator Observations Site Documentation Does the site have an operation and maintenance plan? Yes. The SCM is subject to the standard state O&M plan for an infiltration basin. Does the site have records of annual inspections? Are they performed by a qualified individual? Inspections are performed by a qualified individual, but inspections are not performed annually as required. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? NC State training, webinars, on-the-job training. Did the MS4 inspector appear knowledgeable about MS4 requirements for post-construction site runoff controls? Yes. The inspector was knowledgeable about post-construction permitting and requirements. NCS000314_DOD Cherry Point MS4 Audit_20201119 Page 32 of 33 Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1 Did the MS4 inspector appear knowledgeable about post-construction BMPs (general purpose/function, components, O&M requirements, etc.)? Yes. The inspector was knowledgeable about SCMs, their purpose, function, etc. Inspection Procedures Does the MS4 inspector’s process include the use of a checklist or other standardized form? What format? Yes. The inspector utilizes a standard inspection form. Does the MS4 inspector’s process include taking photos? Photos are utilized where specific issues are identified. Does the MS4 inspector’s process include reviewing the site’s operation and maintenance plan and records of annual inspections? The site O&M Plan was not reviewed prior to the audit inspection. Consistent annual inspections are not available due to lack of funding. The construction plans for the SCM were available for the inspection. Does the MS4 inspector’s process include walking the entire site and inspecting all points of discharge? Yes. The inspector walked the site, reviewed the entire device, and inspected all points of discharge. Did the MS4 inspector miss any obvious operation and maintenance deficiencies? If so, explain: No. Does the MS4 inspector’s process include presenting the inspection findings to the site contact in writing? Yes, if a problem is found. Compliance/Enforcement What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in? N/A If compliance issues were identified, what timeline for correction/follow-up was provided? N/A Notes/Comments/Recommendations SCM inspection and maintenance is performed upon permit renewal. However, annual inspection and routine maintenance are required. The inspected SCM needs rehabilitation. Standing water and algae were observed in the infiltration basin, indicating that it is not functioning correctly. A leak was also observed in the discharge structure. While reviewing the construction plans at the outfall, it was discovered the piping was not constructed in accordance with the approved plans. Inspectors were directed to evaluate the discharge piping and As Built plans for conformity. NCS000314_DOD Cherry Point MS4 Audit_20201119 Page 33 of 33 APPENDIX A: SUPPORTING DOCUMENTS SUPPORTING DOCUMENTATION IS ON FILE AND READILY AVAILABLE IN THE NCDEQ PUBLIC LASERFICHE PORTAL.