NCS000399_NOD and Audit Report_20230829

�P�G km
u� D
ROY COOPER
Governor
ELIZABETH S.BISER
Secretary
DOUGLAS R.ANSEL NORTH CAROLINA
Interim Director Environmental Quality
August 29,2023
CERTIFIED MAIL 7022 2410 0003 1437 0477 l
RETURN RECEIPT REQUESTED
City of Jacksonville
Attn:Joshua Ray,City Manager
Post Office Box 128
Jacksonville,North Carolina 28541
Subject: NOTICE OF DEFICIENCY(NOD-2023-PC-0226)
City of Jacksonville
NPDES MS4 Permit No.NCS000399
Onslow County
Dear Mr. Ray:
On August 14,2023,staff from the North Carolina Department of Environmental Quality(DEQ)conducted a
compliance audit of subject National Pollutant Discharge Elimination System(NPDES) Municipal Separate
Storm Sewer System(MS4) Permit The audit identified minor deficiencies with the specific components of
the MS4 permit that were reviewed,as provided in the attached DEQ MS4 Permit Compliance Audit Report
This report lists and describes the deficiencies with certain components of the MS4 permit,which constitutes
a violation of the Clean Water Act and is grounds for enforcement action.
In accordance with Part VI of the permit and DEQ policy,a new 5-year MS4 permit will be issued in response
to the audit As such,the permittee is required to complete the following actions:
1. Respond in writing within thirty(30) calendar days from the date of receipt of this notice to
acknowledge these requirements and the intent to comply.
2. Develop a Stormwater Management Plan(SWMP)which details specific actions,measurable goals,
and implementation timelines for the stormwater management program over the new 5-year permit
term.The SWMP must be documented utilizing the DEQ Phase If MS4 SWMP Template. The
permittee shall submit the SWMP to DEQ for review and comment within one hundred twenty(120)
calendar days from the date of receipt of this letter.
3. Submit an NPDES MS4 permit application for whichever comes first:
a. At least one hundred eighty(180)days prior to permit expiration,or
b. Within thirty(30)days of receiving written DEQ concurrence that the submitted SWMP
documents a compliant stormwater management program and the MS4 should submit the
application including a signed Final Draft SWMP. A new 5-year NPDES MS4 permit will be
public noticed along with the Draft Final SWMP.
4. Respond to comments on the Draft Final SWMP and submit a signed Final SWMP for DEQ approval
and final permit issuance. The final DEQ-approved SWMP shall become an enforceable component of
the NPDES MS4 permit and an Annual Self-Assessment Template that corresponds to the approved
SWMP will be provided.
D_E Q.'�' North Carolina Department of Environmental Quality I Division of Energy.Mineral Land Resources
l 512 North Salisbury Street 11612 Mail Service Center I Raleigh,North Carolina 27699-1612
uoaxrc�ourw !/
oro�b m.m awiry 919.707.9200

Notice of Deficiency
City of Jacksonville
August 29,2023 j
Page 2 of 2
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Required documentation shall be submitted via e-mail to Isaiah.Reed(a�deq.nc.gov,or to:
DEQ-DEMLR Stormwater Program
Attn: Isaiah Reed
1612 Mail Service Center
Raleigh,NC 27699-1612 j
If the MS4 fails to meet the aforementioned requirements and/or submits a significantly noncompliant Draft
SWMP,DEQ may proceed with enforcement As is stated in Part V,Section A.1(c)of the permit:
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Understate law,a daily civil penalty of not more than twenty-five thousand dollars($25,000)per
violation may be assessed against any person who violates orfails to act in accordance with the terms,
conditions,or requirements of permit[North Carolina General Statute 143-215.6A]. Please note that
compliance with the requirements of this NOD and/or issuance of civil or criminal penalties levied by
DEQ does not preclude the EPA from carrying out its own enforcement case against the permittee.
Thank you for your attention to this matter. Should you have any questions,please contact Isaiah Reed at
[phone] or Isaiah.Reed(@deg.nc.gov.
Sincerely,
Isaiah Reed,PE, SWQ,MS4CECI
MS4 Program Coordinator
North Carolina Department of Environmental Quality
Enclosures: DEQ MS4 Permit Compliance Audit Report
CC: Pat Donovan-Brandenburg [e-mail]
Dan Sams,Regional Engineer dan.sams(@deq.nc.gov
Isaiah Reed,MS4 Program Coordinator [e-mail]
DEMLR NPDES MS4 Permit Laserfiche File

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MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM AUDIT REPORT
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NPDES PERMIT NO. NCS000399
JACKSONVILLE, NORTH CAROLINA
815 New Bridge Street.
Audit Date: August 14, 2023
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Report Date: August 29, 2023
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

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NCS000399 Jacksonville MS4 Audit 20230814 i

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TABLE OF CONTENTS
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AuditDetails..................................................................................................................................................1
PermitteeInformation ..................................................................................................................................2
List of Supporting Documents.......................................................................................................................3
Program Implementation, Documentation &Assessment...........................................................................4
Public Education and Outreach.....................................................................................................................7
Public Involvement and Participation...........................................................................................................8
Illicit Discharge Detection and Elimination (IDDE)........................................................................................9
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Post-Construction Site Runoff Controls ......................................................................................................11
Pollution Prevention and Good Housekeeping for Municipal Operations..................................................15
Site Visit Evaluation: Municipal Facility No. 1.............................................................................................17
Site Visit Evaluation: Municipal Facility No. 2.............................................................................................18
Site Visit Evaluation: M54 Outfall No. 1......................................................................................................19
Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1............................................20
II
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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.
NCS000399 Jacksonville MS4 Audit 20230814 ii

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NCS000399 JacksonviIleMS4Audit 20230814 iii

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Audit Details
Audit ID Number: Audit Date(s):
NCS000399-Jacksonville M54 Audit_20230814 August 14,2023
Minimum Control Measures Evaluated:
® Program Implementation, Documentation &Assessment j
® 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
M Pollution Prevention and Good Housekeeping for Municipal Operations
❑Total Maximum Daily Loads(TMDLs)
Field Site Visits:
® Municipal Facilities. Number visited:2
® M54 Outfalls. Number visited: 1
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❑ Construction Sites. Number visited:Choose an item.
® Post-Construction Stormwater Runoff Controls. Number visited: 1 l
❑ Other: . Number visited:Choose an item.
❑ Other: . Number visited: Choose an item.
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Inspector(s) Conducting Audit
Name Organization
Isaiah Reed, MS4 Program Coordinator NCDEQ
Dan Sams, Regional Engineer NCDEQ
Audit RepoZrzg- �
Author: ! Date:
Signature
NC5000399_Jacksonville MS4 Audit_20230814 Page 1 of 20

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Permittee Information
M54 Permittee Name: Permit Effective Date: Permit Expiration Date: �
City of Jacksonville 2/1/2018 1/31/2023 j
Mailing Address: Date of Last M54Inspection/Audit:
Post Office Box 128 Jacksonville, North Carolina 1/25/2012
Co-permittee(s),if applicable:
None
Permit Owner of Record:
Dr. Richard Woodruff,City Manager
Primary Ms4 Representatives Participating in Audit
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Name.Title Organization I
Pat Donovan-Bra nden burg,Stormwater I
City of Jacksonville
Manager
Andrew Bourlaud, Environmental Inspector
City of Jacksonville
11
Kelly Cannon,Streets Superintendent City of Jacksonville
Nic Lanier,City Engineer City of Jacksonville
Aaron Houran,SW/WQTech City of Jacksonville
Madeleine Loveless,SW/WQTech City of Jacksonville
Michael Connors, Department Director PS City of Jacksonville
NCS000399 Jacksonville M54 Audit 20230814 Page 2 of 20

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List of Supporting Documents
Item When Provided
Number Document Title
(Prior to/During/After)
1 2021 Annual Report After j
2 Written Programs During
3 2022-2023 Fiscal Year Summary After
4 IDDE Ordinance After
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5 Map Documents After
6 Post-CStormwater Ordinance After
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7 Draft Ownership Change Form After
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8 High Density Permit Approval After
9 SCM Inventory After
10 Draft SMWP Prior _.
11 Inspection Report After
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12 Applicator License After
13 Sign-in sheet from annual training After
14 Municipal 0&M Plan During
NCS000399_Jacksonville MS4 Audit_20230814 Page 3 of 20
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Program Implementation, Documentation & Assessment
Staff Interviewed: Pat Donovan-Brandenburg,Stormwater Manager
(Name,Title,Role) Andrew Bourlaud, Environmental Inspector II
Nic Lanier, City Engineer
Michael Connors, Department Director PS
Permit Citation Program Requirement Status supporting
Doc No.
II.A.1 The permittee maintained adequate funding and staffing to implement and manage
Staffing and the provisions of the Stormwater Plan and meet all requirements of the permit. Yes
Funding
The Stormwater Plan identifies a specific position(s) responsible for the overall j
Yes 1
coordination,implementation,and revision to the Plan.
Responsibilities for all components of the Stormwater Plan are documented and j
position(s)assignments provided. Yes ---
The permittee is current on payment of invoiced administering and compliance
Yes --
monitoring fees(see storm water e-payments on DEMLR M54 web page).
SW Utility$5 ERU 1850 ft2.
II.A.2 Stormwater j
The permittee evaluated the performance and effectiveness of the program Annual
Plan components at least annually. Yes Reports
Implementation
and Evaluation If yes,the permittee used the results of the evaluation to modify the program Not
components as necessary to accomplish the intent of the Stormwater Program. Reviewed
Did the permitted M54 discharges cause or contribute to non-attainment of an
applicable water quality standard? No
If yes,did the permittee expand or better tailor its BMPs accordingly to address Not
the non-attainment? Applicable
Water quality monitored weekly for surface water.Drainage ways samples.Fecal Coliform every week.DO,Salinity,conductivity,
turbidity, Temperature(every other week).Mobile unit.
II.A.3
Keeping the The permittee kept the Stormwater Plan up to date. Not applicable ---
Stormwater Plan
Up to Date
The permittee notified DEMLR of any updates to the Stormwater Plan. Not
Applicable
II.A.4 Availability The permittee kept an up-to-date version of its Stormwater Plan available to the
of the Stormwater Division and the public online. No --
Plan
The online materials included ordinances, or other regulatory mechanisms, or a list
Muni-
identifying the ordinances,or other regulatory mechanisms, providing the legal Yes Muni-
authority necessary to implement and enforce the requirements of the permit. code
SWMP not maintained available on the website. The website links to Municode.
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Program Implementation, Documentation &Assessment
II.A.3&II.A.5
Stormwater Plan Did DEMLR require a modification to the Stormwater Plan? Not
Applicable
Modifications
If yes,did the permittee complete the modifications in accordance with the Not
established deadline? Applicable
I I.A&Sharing
Responsibility Are any control measures implemented by an entity other than the permittee? No ---
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If yes, is there a written agreement in place? Not
Applicable --
II.A.7 The permittee maintained written procedures for implementing the six minimum
Written control measures. Yes 2
Procedures
Written procedures identified specific action steps,schedules, resources and
Yes 2
responsibilities for implementing the six minimum measures.
III_A The permittee maintained documentation of all program components including, but
Program not limited to, inspections,maintenance activities, educational programs, Yes ---
Documentation implementation of BMPs,enforcement actions etc.,on file for a period of five years. f
Indefinite.
111_8 The permittee submitted annual reports to the Department within twelve months
Not
Annual Report from the effective date of the permit(See Section/11.8.for the annual reporting Reviewed
Submittal period specific to this MS4).
The permittee submitted subsequent annual reports every twelve months from the Not
scheduled date of the first annual report submittal. Reviewed
The Annual Reports included appropriate information to accurately describe the progress,status,and results
of the permittee's Stormwater Plan,including, but not limited the following:
1. A detailed description of the status of implementation of the Stormwater Plan
as a whole.This will include information on development and implementation Not
of each major component of the Stormwater Plan for the past year and Reviewed
schedules and plans for the year following each report.
2. An adequate description and justification of any proposed changes to the
Stormwater Plan.This will include descriptions and supporting information for Not
the proposed changes and how these changes will impact the Stormwater Reviewed
Plan (results,effectiveness, implementation schedule, etc.).
3. Documentation of any necessary changes to programs or practices for
assessment of management measures implemented through the Stormwater Not —
Reviewed
Plan.
4. A summary of data accumulated as part of the Stormwater Plan throughout
the year along with an assessment of what the data indicates in light of the Not
Reviewed
Stormwater Plan.
Factions.
An assessment of compliance with the permit, information on the
establishment of appropriate legal authorities, inspections,and enforcement Not
Reviewed
NCS000399_JacksonviIle MS4 Audit_20230814 Page 5 of 20

Program Implementation, Documentation &Assessment
IV.B
Annual Reporting The Annual Reports document the following:
1. A summary of past year activities, including where applicable,specific Not
quantities achieved and summaries of enforcement actions. Reviewed
2. A description of the effectiveness of each program component. Not
Reviewed
3. Planned activities and changes for the next reporting period,for each Not
program component or activity. Reviewed
4. Fiscal analysis. Not
Reviewed
Comments:There is currently no approved Stormwater Management Plan maintained for the City of Jacksonville,as required by
the permit. However,upon review of previous NCDEQ guidance,it was determined that City of Jacksonville staff were acting in
accordance with the guidance received.Issues with the prior method of SWMP submittal and a corrected plan of action were
discussed. If the City of Jacksonville staff have any questions at all concerning SWMP submission and approval,please contact
the MS4 Program Coordinator.
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Public Education and Outreach
Staff Interviewed: Pat Donovan-Brandenburg,Stormwater Manager
(Name,Title,Role) Andrew Bourlaud, Environmental Inspector II
Nic Lanier,City Engineer
Michael Connors, Department Director PS
Permit Citation Program Requirement Status supposing
Doc No.
II.B.2.a
The permittee defined goals and objectives of the Local Public Education and
Goals and Yes 2
Outreach Program based on community wide issues.
Objectives i
Enviroscapes presented at public events. Works with Sturgeon City.New River Institute.Stormwater education is a standard 5tb
grade educational program.Events are done quarterly.Interactive online information.Media services department creates
Outreach material.1350 participants.
II.B.2.b The permittee maintained a description of the target pollutants and/or stressors and TY772
Target Pollutants likely sources.
Target pollutants do not change.
II.B.2.c The permittee identified,assessed annually and updated the description of the target Not
Target Audiences audiences likely to have significant storm water impacts and why they were selected. Reviewed
II.B.2.d Residential The permittee described issues,such as pollutants,the likely sources of those
and Industrial/ pollutants, potential impacts,and the physical attributes of stormwater runoff in Yes 2
Commercial Issues their education/outreach program.
II.B.2.e The permittee promoted and maintained an internet web site designed to convey the
Informational Yes Website
Web Site Program's message.
II.B2.f
The permittee distributed stormwater educational material to appropriate target
Public Education Yes 2
Materials groups.
Distributes letters to landscaping companies.Outreach to restaurants.Bill inserts 3-6 times a year.
II.B.2.¢ The permittee promoted and maintained a stormwater hotline/helpline for the
Hotline/Help Line Yes 2
purpose of public education and outreach.
II.B.2.h The permittee's outreach program, including those elements implemented locally or
Public Education through a cooperative agreement, included a combination of approaches designed to Yes 2
and Outreach reach the target audiences.
Program
For each media,event or activity, including those elements implemented locally or
through a cooperative agreement the permittee estimated and recorded the extent Yes 2
of exposure.
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Public Involvement and Participation
Staff Interviewed: Pat Donovan-Brandenburg,Stormwater Manager
(Name,Title,Role) Andrew Bourlaud, Environmental Inspector II
Nic Lanier, City Engineer
Michael Connors, Department Director PS
Permit Citation Program Requirement Status supporting
Doc No.
II.C.2.a Volunteer
Community The permittee included and promoted volunteer opportunities designed to promote yes 2
Involvement ongoing citizen participation.
Program
Jacksonville provides equipment for cleanup process.Jacksonville also picks up bogs.
II.C.2.b
Mechanism for The permittee provided and promoted a mechanism for public involvement that yes 2
Public provides for input on stormwater issues and the stormwater program.
Involvement
Publicized through TV,website.
II.C2.c The permittee promoted and maintained a hotline/helpline for the purpose of public
Yes Website
Hotline/Help Line involvement and participation. `
Citita jacksonville.com
Additional Stormwater Advisory Committee.
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Comments: Adopt-a-street includes a quarterly requirement. _
National Night Out:Outreach with enviroscape to demonstrate manmade impacts in linear park.
Had students build rain gardens.HOAs will have City staff come out to outline BMP maintenance.
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Illicit Discharge Detection and Elimination (IDDE)
Staff Interviewed: Pat Donovan-Brandenburg,Stormwater Manager
(Name,Title, Andrew Bourlaud, Environmental Inspector II
Role) Nic Lanier,City Engineer
Michael Connors, Department Director PS
Aaron Houran,SW/WQTech
Madeleine Loveless,SW/WQTech
Permit Citation Program Requirement Status Supporting
Dot No.
II.D.2.a
IDDE Program The permittee maintained a written IDDE Program. Yes 2
If yes,the written program includes provisions for program assessment and
No ---
evaluation and integrating program.
Annual review of Ordinance not documented.
The permittee maintained an IDDE ordinance or other regulatory mechanisms)that
II.D.2.6 provides the legal authority to prohibit illicit connections and discharges to the MS4. Yes 4
Legal Authorities If yes,the ordinance applies throughout the corporate limits of the permittee.
[Permit Part LD] Yes 4
II.D.2.c
The permittee maintained a current map showing major outfalls* and receiving
Storm Sewer Yes S
streams.
System Map
Mapping in progress.
II.D.2.d
The permittee maintained a program for conducting dry weather flow field
Dry Weather Flow Partial ---
Program observations in accordance with written procedures.
Checking for flaw. Confirming location of outfall.Documentation is insufficient.
II.D.2.e
The permittee maintained written procedures for conducting investigations of
Investigation Yes 2
Procedures identified illicit discharges.
II.D.2.f For each case of an illicit discharge or potential illicit discharge,the permittee documented and tracked the
Track and following:
Document
Investigations 1. The date(s)the illicit discharge was observed Partial --
2. The results of the investigation Partial ---
3. Any follow-up of the investigation Partial ---
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4. The date the investigation was closed Partial ---
Tracking of IDDE investigations is incomplete.
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Illicit Discharge Detection and Elimination (IDDE)
II.D.2.Q Employee The permittee implemented and documented a training program for appropriate
Training municipal staff who,as part of their normal job responsibilities, may come into Yes --- j
contact with or otherwise observe an illicit discharge or illicit connection.
Train every department on stormwater annually.[DOE training is mare far the streets department.
II.D.2.h The permittee informed public employees of hazards associated with illegal
Public Education discharges and improper disposal of waste. Yes 2
The permittee informed businesses of hazards associated with illegal discharges and Yes 2
improper disposal of waste.
The permittee informed the general public of hazards associated with illegal
Yes 2
discharges and improper disposal of waste.
II.13.2.1 The permittee promoted, publicized,and facilitated a reporting mechanism for the
Public Reporting public to report illicit discharges. Yes Website
Mechanism
The permittee promoted,publicized,and facilitated a reporting mechanism for staff
No
to report illicit discharges.
The permittee established and implemented response procedures for citizen
Partial ---
requests/reports.
II.D.2 j The permittee implemented a mechanism to track the issuance of notices of violation
Enforcement and enforcement actions administered by the permittee. Partial If yes,the mechanism includes the ability to identify chronic violators for
Partial ---
initiation of actions to reduce noncompliance.
One active NOV.Issue 5-6 NOVs a year.
The NOV Ordinance references are outdated and reference prior Ordinance sections.
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Post-Construction Site Runoff Controls
Staff Interviewed: Pat Donovan-Brandenburg,Stormwater Manager
(Name,Title, Role) Andrew Bourlaud, Environmental Inspector II
Nic Lanier,City Engineer
Michael Connors, Department Director PS j
Aaron Houran,SW/WQTech
Madeleine Loveless,SW/WQTech
Implementation(check all that apply):
® The permittee implements the components of this minimum measure.
❑ The permittee relies upon another entity to implement the components of this minimum measure: name of entity
❑ The permittee implements the following deemed-compliant program(s),which meet NPDES M54 post-construction
requirements for the areas where implemented and in compliance with the specific program requirements as provided in 15A
NCAC and noted below(Complete Session Law 2006-246 section below):
❑ Water Supply Watershed I (WS-1)—15A NCAC 213.0212
❑ Water Supply Watershed ll (WS-11)-15A NCAC 26.0214
❑ Water Supply Watershed III(WS-III)-15A NCAC 2B.0215
❑ Water Supply Watershed IV(WS-IV)—15A NCAC 2B.0216
❑ Freshwater High Quality Waters(HOW)—15A NCAC 2H .1006
❑ Freshwater Outstanding Resource Waters(ORW)—15A NCAC 2H .1007
❑ Neuse River Basin Nutrient Sensitive(NSW) Management Strategy—15A NCAC 2B.0235
❑ Tar-Pamlico River Basin Nutrient Sensitive(NSW) Management Strategy-15A NCAC 2B.0258
❑ Randleman Lake Water Supply Watershed Nutrient Management Strategy-15A NCAC 2B.0251
❑ Universal Stormwater Management Program—15A NCAC 2H .1020
Ordinance(s)(check all that apply):
The permittee utilizes the following ordinances and/or regulatory authority to fulfill post construction minimum measure program
requirements throughout the MS4 permitted area(check all that apply):
2 DEC.model ordinance
❑ MS4 designed post-construction practices that meet or exceed 15A NCAC 02H .1000.
❑ DEQ approved comprehensive watershed plan
❑ DEQ approved ordinance for a deemed-compliant Program(see list above)
Instructions:
For MS4s not implementing a S.L. 2006-246 deemed-compliant program,complete only the Permit Citation section below.
For MS4s implementing a S.L.2006-246 deemed-compliant program, complete the Session Law 2006-246 section below. If the MS4
does not implement a deemed-compliant program throughout the entire MS4 permitted area, then complete the Permit Citation
section below for the permitted area(s)not covered under the S.L.2006-245 deemed-compliant program.
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Post-Construction Site Runoff Controls
Session Law 2006- supporting '
246 Program Requirement Status
Doc No. �
Deemed-Compliant The permittee implements deemed-compliant Program requirements in
Program(s) accordance with the applicable 15A NCAC rules. Not
Reviewed
The permittee implements deemed-compliant Program requirements throughout
Not
the entire MS4 area (If not, also complete the Permit Citation section below.) Reviewed
The permittee applies deemed-compliant Program requirements to all federal,
state and local government projects within the permitted MS4 area who do not Not
Reviewed
have their own NPDES stormwater permit.
The permittee included deemed-compliant Program reporting in their MS4 Annual
Reports. 4
The permittee included deemed-compliant Program implementation in their Not
Stormwater Management Plan. Reviewed
Supporting
Permit Citation Program Requirement Status Doc No.
II.F2.a The permittee maintained an ordinance or other regulatory mechanism designed
Legal Authority to meet the objectives of the Post-Construction Site Runoff Controls Stormwater Yes 6
Management Program.
If yes,the ordinance applies throughout the corporate limits of the permittee !lll
(Verify permit coverage area listed in Part I.D of permit and modify Yes 6
accordingly).
The permittee has the authority to review designs and proposals for new
development and redevelopment to determine whether adequate stormwater Yes 6
control measures will be installed, implemented,and maintained.
The permittee has the authority to request information such as stormwater plans,
inspection reports,monitoring results, and other information deemed necessary to Yes 6
evaluate compliance with the Post-Construction Stormwater Management
Program.
The permittee has the authority to enter private property for the purpose of
inspecting at reasonable times any facilities,equipment, practices,or operations Yes 6
related to stormwater discharges.
Permits are not issued with an expiration date.
The following Ordinance language should be reviewed for functionality:
"This permit shall be valid for a period of two years from the date of issuance unless a valid building permit has been issued and
maintained for the site or the permit has been revoked by the City of Jacksonville.If, after two years the permitted activity has
not begun nor a valid building permit secured,this permit shall expire."
II.F.2.b
Stormwater Control The permittee utilizes strategies which include SCMs appropriate for the MS4. Yes 8
Measures(SCMs)
SCMs comply with 15A NCAC 02H .1000. Not
Reviewed
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Post-Construction Site Runoff Controls
II.F.2.c The permittee conducted site plan reviews of all new development and
Plan Reviews redeveloped sites that disturb greater than or equal to one acre(including sites
Yes ---
that disturb less than one acre that are part of a larger common plan of
development or sale).
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If yes,the site plan reviews addressed how the project applicant meets the Not
performance standards. Reviewed
If yes,the site plan reviews addressed how the project will ensure long-term Not
maintenance. Reviewed
II.F.2.d The permittee maintained an inventory of projects with post-construction
Inventory of Projects structural stormwater control measures installed and implemented at new Yes 9
development and redeveloped sites.
The inventory included both public and private sector sites located within the
permittee's corporate limits that are covered by its post-construction ordinance Yes 9
requirements. f
II.F.2.e The permittee provided mechanisms such as recorded deed restrictions and
Deed Restrictions
protective covenants that ensure development activities will maintain the project Yes 30
and Protective
Covenants consistent with approved plans.
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II.F2.f The permittee implemented or required an operation and maintenance plan for
Mechanism to Yes 8
the long-term operation of the SCMs required by the program.
Require Long-term
Operation and The operation and maintenance plan required the owner of each SCM to perform
Maintenance Yes 8
and maintain a record of annual inspections of each SCM.
Annual inspection of permitted structural SCMs are required to be performed by a
Yes 8
qualified professional.
II.F.2.g The permittee conducted and documented inspections of each project site covered
Inspections of under performance standards, at least one time during the permit term (Verify this Yes 8
Structural is o permit condition in Part II.F.2.g of permit and modify accordingly).
Stormwater Control Before issuing a certificate of occupancy or temporary certificate of occupancy,the
Measures permittee conducted a post-construction inspection to verify that the permittee's
performance standards have been met or a bond is in place to guarantee Yes 8
completion(Verify this is a permit condition in Part II.F.2.g of permit and modify
accordingly.
The permittee developed and implemented a written inspection program for SCMs
installed pursuant to the post-construction program(Verify this is a permit Yes 2
condition in Part II.F.2.g of permit and modify accordingly.
The permittee documented and maintained records of inspections. Yes 11
The permittee documented and maintained records of enforcement actions. Partial ---
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Post-Construction Site Runoff Controls
II.F2.h The permittee made available through paper or electronic means,ordinances,
Educational post-construction requirements, design standards checklists, and other materials
Materials and appropriate for developers. Yes Website
Training for Note:New materials may be developed by the permittee,or the permittee may use
Developers materials adapted from other programs and adapted to the permittee's new
development and redevelopment program. I
II.F.2.i Enforcement The permittee tracked the issuance of notices of violation and enforcement
No ---
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actions.
If yes,the tracking mechanism included the ability to identify chronic violators
No ---
for initiation of actions to reduce noncompliance.
Insufficient documentation and tracking of enforcement efforts.
II.F3.b The permittee fully complies with post construction program requirements on its
New Development own publicly funded construction projects. Yes ---
II.F3.c Does the MS4 have areas draining to Nutrient Sensitive Waters(NSW) pursuant to Not Nutrient Sensitive 15A NCAC 02H .0150? Reviewed ___
Waters f
If yes,does the permittee use SCMs that reduce nutrient loading in order to Not
meet local program requirements. Reviewed
If yes,does the permittee also still incorporate the stormwater controls Not
required for the project's density level. Reviewed
If yes,does the permittee also require documentation where it is not feasible to Not
use SCMs that reduce nutrient loading. Reviewed
II.F3.d The permittee ensured that the design volumes of SCMs take into account the
Design Volume Yes ---
runoff at build out from all surfaces draining to the system.
Where "streets'convey stormwater,the permittee designed SCMs to be sized to
treat and control stormwater runoff from all surfaces draining to the SCM including Yes ---
streets,driveways,and other impervious surfaces.
Additional It is recommended that the City of Jacksonville keep an open dialog with the NCDEQ Wilmington Regional
Comments: Office to ensure consistency in the Post Construction Program.
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Pollution Prevention and Good Housekeeping for Municipal Operations
Staff Interviewed: Pat Donovan-Brandenburg,Stormwater Manager
(Name,Title, Role) Andrew Bourlaud, Environmental Inspector II
Nic Lanier,City Engineer
Michael Connors, Department Director PS
Aaron Houran,SW/WQTech
Madeleine Loveless,SW/WQTech
Permit Citation Program Requirement Status SupportingDoc No.
II.G.2.a The permittee maintained a current inventory of facilities and operations owned
Facility Inventory and operated by the permittee with the potential for generating polluted Yes 2 i
stormwater runoff.
Maintained in the written program.
II.G.2.b The permittee maintained and implemented an O&M program for municipally
Operation and owned and operated facilities with the potential for generating polluted Yes 2
Maintenance(O&M) stormwater runoff.
for Facilities
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If yes,the O&M program specifies the frequency of inspections. Partial ---
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If yes,the 0&M program specifies the frequency of routine maintenance
No ---
requirements.
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If yes,the permittee evaluated the O&M program annually and updated it as L-
No
necessary.
Inspection outline does not include MS4 inspections.
II.G.2.c
Spill Response The permittee had written spill response procedures for municipal operations. Yes ---
Procedures
II.G.2.d Streets, The permittee evaluated existing and new BMPs that reduce polluted stormwater
Roads,and Public runoff from municipally-owned streets, roads,and public parking lots within its No ---
Parking Lots corporate limits annually.
Maintenance If yes,the permittee evaluated the effectiveness of existing and new BMPs Not
based on cost and the estimated quantity of pollutants removed. Applicable
II.G.2.f The permittee maintained and implemented an 0&M program for the stormwater
O&M for Catch
Basins and sewer system including catch basins and conveyance systems that it owns and Yes 2
maintains.
Conveyance Systems
II.G.2.e The permittee maintained a current inventory of municipally-owned or operated
Structural structural stormwater controls installed for compliance with the permittee's post- Yes 9
Stormwater Controls construction ordinance.
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Pollution Prevention and Good Housekeeping for Municipal Operations
II.G.2.h The permittee maintained and implemented an O&M program for municipally-
O&M for Structural owned or maintained structural stormwater controls installed for compliance with Yes 14
Stormwater Controls the permittee's post-construction ordinance. If yes,then:
The O&M program specified the frequency of inspections and routine Not
maintenance requirements. Reviewed
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The permittee documented inspections of all municipally-owned or maintained Not
structural stormwater controls. Reviewed !
The permittee inspected all municipally-owned or maintained structural Not
stormwater controls in accordance with the schedule developed by permittee. Reviewed
The permittee maintained all municipally-owned or maintained structural Not
stormwater controls in accordance with the schedule developed by permittee. Reviewed �-
The permittee documented maintenance of all municipally-owned or Not
maintained structural stormwater controls. Reviewed
II.G.2.i The permittee ensured municipal employees are properly trained in pesticide,
Pesticide,Herbicide Yes 12
herbicide and fertilizer application management.
and Fertilizer
Application The permittee ensured contractors are properly trained in pesticide,herbicide and ___
Management Yes
fertilizer application management.
The permittee ensured all permits,certifications, and other measures for
Yes ---
applicators are followed.
SW Department has general applicators with additional.Jacksonville pays for license renewals.
II.G.2.j The permittee implemented an employee training program for employees involved
Staff Training Yes 13
in implementing pollution prevention and good housekeeping practices.
II.G.2.k The permittee described and implemented measures that prevent or minimize
Vehicle and contamination of stormwater runoff from all areas used for vehicle and equipment Yes ---
Equipment Cleaning cleaning.
Wash bay used at public services.
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Site Visit Evaluation: Municipal Facility No. 1
Facility Name: Date of Site Visit:
Jacksonville W WTF August 15,2023
Facility Address: Facility Type(Vehicle Maintenance, Landscaping,etc.):
716 Fire Tower Road WWTF
Name of MS4 inspector(s)evaluated: Most Recent MS4 Inspection(List date and name of inspector):
Pat Donovan-Brandenburg Not Evaluated
Name(s)and Title(s)of Facility Representative(s)Present During the Site Visit: !i
Name Title I
Donnie Marshawn I Assistant Plant Operator
Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan(SWPPP)or similar document?Is it facility-specific?
No.
What type of stormwater training do facility employees receive?How often?
Annual SW Training.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive?How often?
Annual SW Training.
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
Yes. j
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Yes.
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form?
Yes.
Does the M54 inspector's process include taking photos?
Yes.
Does the MS4 inspector's process include reviewing the facility's SWPPP(or similar document)?
No.
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:
No.
Does the MS4 inspector's process include presenting the inspection findings to the facility contact?
Yes.
Inspection Results
Did the facility inspection result in any corrective actions to be implemented?If so,for what issue(s)?
Not discussed during the inspection.To be determined later by the MS4 Inspector.
If compliance corrective actions were identified,what timeline for correction/follow-up was provided?
Not determined during the inspection.
Notes/Comments/Recom men dati ons
Items discussed during the inspection included proper inspection of fuel storage,secondary containment of chemicals,and
potential non-stormwater discharges resulting from runoff from the grit collection/headwarks area.
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Site Visit Evaluation: Municipal Facility No. 2
Facility Name: Date and Time of Site Visit:
Public Services August 15,2023
Facility Address: Facility Type(Vehicle Maintenance, Landscaping,etc.):
350 S Marine Blvd Public Works/Vehicle Maintenance
Name of MS4 inspector(s)evaluated: Most Recent MS4 Inspection(Date and Entity): j
Pat Donovan-Brandenburg Not evaluated
Name(s)and Title(s)of Facility Representative(s)Present During the Site Visit:
Name Title �
Jesse Nelson Fleet Superintendent
Michael Connors Assistant Public Services Director
Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP)or similar document?Is it facility-specific?
No.
What type of stormwater training do facility employees receive?How often?
Annual SW Training.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive?How often?
Annual SW Training.
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
Yes.
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping? �
Yes.
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form?
Yes.
Does the MS4 inspector's process include taking photos?
Yes.
Does the M54 inspector's process include reviewing the facility's SWPPP(or similar document)?
No.
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:
Possibly. Prior inspections did not identify primary areas of concern.
Does the MS4 inspector's process include presenting the inspection findings to the facility contact?
Yes.
Inspection Results
Did the facility inspection result in any corrective actions to be implemented?If so,for what issue(s)?
Yes. M54 inspector will determine what actions are necessary.
If compliance corrective actions were identified,what timeline for correction/follow-up was provided?
Not determined during the inspection.
Notes/Comments/Recom men dations
Items discussed during the inspections included proper use of secondary containment,what chemicals need secondary
containment, housekeeping/litter issues, oil sheen, and concrete secondary containment inspection/maintenance.
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Site Visit Evaluation: MS4 Outfall No. 1
Outfall ID Number: Date and Time of Site Visit:
None Given August 15,2023
Outfall Location: Outfall Description(Pipe Material/Diameter,Culvert,etc.):
408 S Marine Blvd RCP
Receiving Water: Is Flow Present?If So, Describe(Color,Approximate Flow Rate,
Wetlands associated with the New River Sheen,Odor,Floatables/Debris,etc.):
Most Recent Outfall Inspection/Screening(Date):
Not evaluated None.
Days Since Last Rainfall: Inches:
Not evaluated N/A
Name of MS4 Inspector(s)evaluated:
Pat Donovan-Brandenburg
Observations
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive?How often?
Annual SW Training.
Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations?
Partially.
Inspection Procedures
Does the inspector's process include the use of a checklist or other standardized form?
No.
Does the inspector's process include taking photos?
Yes.
Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues?If so,what were they?
No.
Inspection Results
Did the outfall inspection result in any work orders or maintenance requests?If so,for what issue(s)?
No.
Will a follow-up outfall inspection be conducted?If so,for what reason?
Yes.Routine.
Notes/Comments/Recommendations
Permittee will be developing a thorough dry-weather screening program through the upcoming permit cycle.
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Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1
Site Name: Date and Time of Site Visit:
Arby's SCM August 15,2023
Site Address: SCM Type:
408 5 Marine Blvd Wet Pond
Most Recent MS4 Inspection(Include Date and Entity):
Not evaluated
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Name of MS4lnspector(s)evaluated: Most Recent MS4 Enforcement Activity(Include Date):
Pat Donovan-Brandenburg Not evaluated
Name(s)and Title(s)of Site Representative(s)Present During the Site Visit:
Name Title
None.
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Observations
Site Documentation
Does the site have an operation and maintenance plan?
Yes.
Does the site have records of annual inspections?Are they performed by a qualified individual?
Not evaluated.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive?How often?
Annual SW Training.
Did the M54 inspector appear knowledgeable about MS4 requirements for post-construction site runoff controls?
Yes.
Did the MS4 inspector appear knowledgeable about post-construction BMPs(general purpose/function,components, 0&M
requirements,etc.)?
Yes.
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form?What format?
Yes.
Does the M54 inspector's process include taking photos?
Yes.
Does the M54 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections?
If needed.
Does the MS4 inspectors process include walking the entire site and inspecting all points of discharge?
Yes.
Did the MS4 inspector miss any obvious operation and maintenance deficiencies?If so,explain:
No.
Does the M54 inspector's process include presenting the inspection findings to the site contact in writing?
Yes.
Compliance/Enforcement
What, if any,enforcement actions(verbal warnings, NOV,etc.)did the inspection result in?
None.
If compliance issues were identified,what timeline for correction/follow-up was provided?
N/A
NCS000399_Jacksonville MS4 Audit_20230814 Page 20 of 20