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HomeMy WebLinkAboutNCS000430_Audit Report_20220624MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) PROGRAM AUDIT REPORT NPDES PERMIT NO. NCS000430 MONTREAT, NORTH CAROLINA 1200 Montreat Rd. Montreat, North Carolina 28757 Audit Date: June 23, 2022 Report Date: June 24, 2022 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 (This page intentionally left blank) NC5000430 Montreat MS4 Audit 20220623 TABLE OF CONTENTS 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 Pollution Prevention and Good Housekeeping for Municipal Operations.................................................11 Site Visit Evaluation: Municipal Facility No. 1.............................................................................................13 Site Visit Evaluation: MS4 Outfall No. 1......................................................................................................14 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1............................................15 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. NCS000430 MontreatMS4Audit 20220623 ii This page intentionally left blank NC5000430 Montreat M54 Audit 20220623 Hi Audit Details Audit ID Number: Audit Date(s): NCS000430_Montreat MS4 Audit_20220623 June 23, 2022 Minimum Control Measures Evaluated: N Program Implementation, Documentation & Assessment N Public Education & Outreach N Public Involvement & Participation N 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 N Pollution Prevention and Good Housekeeping for Municipal Operations ❑ Total Maximum Daily Loads (TMDLs) Field Site Visits: N Municipal Facilities. Number visited: 1 N MS4 Outfalls. Number visited: 1 ❑ Construction Sites. Number visited: Choose an item. N 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 Isaiah Reed, Environmental Engineer NCDEQ James Rogers, Environmental Specialist ' NCDEQ Audit Report Auth % Date: Signature � / Audit Report Author: Date: Signature NCS000430_Montreat MS4 Audit_20220623 Page 1 of 16 Permittee Information MS4 Permittee Name: Town of Montreat Permit Effective Date: 2/20/2017 Permit Expiration Date: 2/19/2022 Mailing Address: 96 Rainbow Ter. Montreat, North Carolina 28757 Date of Last MS4 Inspection/Audit: 2/28/2014 Co-permittee(s), if applicable: Permit Owner of Record: Timothy R. Helms, Mayor Primary MS4 Representatives Participating in Audit Name, Title Organization Mary Roderick, Regional Planner Land of Sky (COG) Daniel Wiggs, Maintenance Tech Town of Montreat Ben Blackburn, Town Administrator Town of Montreat Barry Creasman, Public Works Director Town of Montreat MS4 Receiving Waters Waterbody Classification Impairments Flat Creek C Piney Branch C;HQW Kitchen Branch C Little Piney Branch C Puncheon Branch C NCS000430_Montreat MS4 Audit_20220623 Page 2 of 16 List of Supporting Documents Item Number Document Title When Provided (Prior to/During/After) 1 Water Quality Assessment Prior 2 Land of Sky Contract During 3 2016SWMP Prior 4 Land of Sky Powerpoint During 5 General Ordinance Prior 6 SCM Inventory During 7 Training certificates During NCS000430_Montreat MS4 Audit_20220623 Page 3 of 16 Program Implementation, Documentation & Assessment Staff Interviewed: Mary Roderick, Regional Planner (Name, Title, Role) Daniel Wiggs, Maintenance Tech Ben Blackburn, Town Administrator Barry Creasman, Public Works Director 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. No Funding The Stormwater Plan identifies a specific position(s) responsible for the overall coordination, implementation, and revision to the Plan. No 3 Responsibilities for all components of the Stormwater Plan are documented and position(s) assignments provided. No 3 The permittee is current on payment of invoiced administering and compliance monitoring fees (see stormwater e-payments on DEMCR M54 web page). No 2016 SWMP has not been maintained. II.A.2 Stormwater The permittee evaluated the performance and effectiveness of the program Plan components at least annually. No --- 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. Applicable Did the permitted MS4 discharges cause or contribute to non -attainment of an applicable water quality standard? No 1 If yes, did the permittee expand or better tailor its BMPs accordingly to address Not the non -attainment? Applicable .-- Water quality assessment done in 2020. No annual evaluation has been documented. II.A.3 Keeping the The permittee kept the Stormwater Plan up to date. No --- Stormwater Plan Up to Date The permittee notified DEMLR of any updates to the Stormwater Plan, Not Applicable The SWMP has not been maintained. 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 identifying the ordinances, or other regulatory mechanisms, providing the legal Partial Website authority necessary to implement and enforce the requirements of the permit. Townofmontreat.org NCS000430_Montreat MS4 Audit_20220623 Page 4 of 16 Program Implementation, Documentation & Assessment II.A.3 & II.A.S 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 II.A& Sharing Responsibility Are any control measures implemented by an entity other than the permittee? Yes 2 If yes, is there a written agreement in place? No --- Land of Sky has implemented an amount of Public Education/Outreach and Public Involvement/Participation. However, no agreement has been made. II.A.7 The permittee maintained written procedures for implementing the six minimum Written control measures. No --- Procedures Written procedures identified specific action steps, schedules, resources and responsibilities for implementing the six minimum measures. No Permittee did not maintain a written program for all MCMs. Ill 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. 1113 The permittee submitted annual reports to the Department within twelve months Annual Report from the effective date of the permit (See Section III.B. for the annual reporting Yes alms Submittal period specific to this MS4). The permittee submitted subsequent annual reports every twelve months from the scheduled date of the first annual report submittal. Yes BIMS 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 Plan. Reviewed 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 --- Stormwater Plan. Reviewed NCS000430_Montreat MS4 Audit_20220623 Page 5 of 16 Program Implementation, Documentation & Assessment 5. An assessment of compliance with the permit, information on the establishment of appropriate legal authorities, inspections, and enforcement Not Reviewed actions. IV.8 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 NC5000430_Montreat M54 Audit_20220623 Page 6 of 16 Public Education and Outreach Staff Interviewed: Mary Roderick, Regional Planner (Name, Title, Role) Daniel Wiggs, Maintenance Tech Ben Blackburn, Town Administrator Barry Creasman, Public Works Director Permit Citation Program Requirement Status Supporting Doc No. 11.6.2.a The permittee defined goals and objectives of the Local Public Education and Goals and No 3 Outreach Program based on community wide issues. Objectives Goals not specifically identified in SWMP. 11.8.2.b The permittee maintained a description of the target pollutants and/or stressors and Target Pollutants likely sources. Partial 3 The SWMP contains some language concerning target pollutants. II.B.2.c The permittee identified, assessed annually and updated the description of the target Target Audiences audiences likely to have significant storm water impacts and why they were selected. No 11.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 No --- Commercial Issues their education/outreach program. II.8.2.e The permittee promoted and maintained an internet web site designed to convey the Informational program's message. No --- Web Site No link on the Towns page to link to Landofsky. II.B.2.f Public Education The permittee distributed stormwater educational material to appropriate target Materials groups. No --- No material distributed. II.B.2.¢ The permittee promoted and maintained a stormwater hotline/helpline for the Hotline/Help Line purpose of public education and outreach. No 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 No --- 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 No --- of exposure. Activity was documented with Land of Sky. However, an agreement is not In place for Land of Sky to implement the requirements of this MCM. NCS000430_Montreat MS4 Audit_20220623 Page 7 of 16 Public Involvement and Participation Staff Interviewed: Mary Roderick, Regional Planner (Name, Title, Role) Daniel Wiggs, Maintenance Tech Ben Blackburn, Town Administrator Barry Creasman, Public Works Director Permit Citation Program Requirement Status supporting Doc No. II.C.2.a Volunteer Community The permittee included and promoted volunteer opportunities designed to promote Involvement NO ongoing citizen participation. Program Activity was documented with Land of Sky. However, an agreement is not in place for Land of Sky to implement the requirements of this MCM. II.C.2.b Mechanism for The permittee provided and promoted a mechanism for public involvement that Public provides for input on stormwater issues and the stormwater program. No Involvement II.C2.c The permittee promoted and maintained a hotline/helpline for the purpose of public Hotline/Help Line involvement and participation. ves Website Townofmontreat.or7 NCS000430_Montreat MS4 Audit_20220623 Page 8 of 16 Illicit Discharge Detection and Elimination (IDDE) Staff Interviewed: Mary Roderick, Regional Planner (Name, Title, Daniel Wiggs, Maintenance Tech Role) Ben Blackburn, Town Administrator Barry Creasman, Public Works Director Permit Citation Program Requirement Status supporting Doc No. II.D.2.a IDDE Program The permittee maintained a written IDDE Program. No --- If yes, the written program includes provisions for program assessment and Not evaluation and integrating program. Applicable No written IDDE program has been maintained. The permittee maintained an IDDE ordinance or other regulatory mechanism(s) that II.D.2.b provides the legal authority to prohibit illicit connections and discharges to the MS4. Partial S Legal Authorities If yes, the ordinance applies throughout the corporate limits of the permittee. [Permit Part I.D] Yes --- Penalty section of IDDE ordinance is not clear. II.D.2.c The permittee maintained a current map showing major outfalls* and receiving MS4 Storm Sewer Yes Field System Map streams. Map app Drainage areas not considered in creation of the map. II.D.2.d The permittee maintained a program for conducting dry weather flow field Dry Weather Flow observations in accordance with written procedures. No --- Program A dry weather flow field inspections program is in the process of being created. II.D.2.e The permittee maintained written procedures for conducting investigations of Investigation identified illicit discharges. No --- Procedures No written program has been maintained. 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 Not Applicable 2. The results of the investigation Not Applicable 3. Any follow-up of the investigation Not Applicable 4. The date the investigation was closed Not Applicable No IDDE events recorded. NCS000430_Montreat MS4 Audit_20220623 Page 9 of 16 Illicit Discharge Detection and Elimination (IDDE) II.D.2.e Employee The permittee implemented and documented a training p p g program for appropriate Training municipal staff who, as part of their normal job responsibilities, may come into No --- contact with or otherwise observe an illicit discharge or illicit connection. No Training program implemented. II.D.2.h The permittee informed public employees of hazards associated with illegal Public Education discharges and improper disposal of waste. No The permittee informed businesses of hazards associated with illegal discharges and improper disposal of waste. No The permittee informed the general public of hazards associated with illegal discharges and improper disposal of waste. No --- 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 to report illicit discharges. Yes Software The permittee established and implemented response procedures for citizen requests/reports. No --- The permittee implemented a mechanism to track the issuance of notices of violation Enforcement and enforcement actions administered by the permittee. No If yes, the mechanism includes the ability to identify chronic violators for Not initiation of actions to reduce noncompliance. Applicable --- No notices of violation have been issued. No tracking mechanism has been Implemented. NCS000430_Montreat MS4 Audit_20220623 Page 10 of 16 Pollution Prevention and Good Housekeeping for Municipal Operations Staff Interviewed: Mary Roderick, Regional Planner (Name, Title, Role) Daniel Wiggs, Maintenance Tech Ben Blackburn, Town Administrator Barry Creasman, Public Works Director Permit Citation Program Requirement Status Supporting Doc 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 No --- stormwater runoff. II.G.2.b The permittee maintained and implemented an 0&M program for municipally Operation and owned and operated facilities with the potential for generating polluted No --- Maintenance (O&M) stormwater runoff. for Facilities If yes, the O&M program specifies the frequency of inspections. Not Applicable If yes, the 0&M program specifies the frequency of routine maintenance Not requirements. Applicable --- If yes, the permittee evaluated the O&M program annually and updated it as Not necessary. Applicable --- No 0&M plan has been created and maintained. II.G.2.c Spill Response The permittee had written spill response procedures for municipal operations. No --- Procedures No Spill response plan has been developed and maintained. 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 No annual evaluation has been documented. II.G.2.f O&M for Catch The permittee maintained and implemented an 0&M program for the stormwater Basins and sewer system including catch basins and conveyance systems that it owns and No --- Conveyance Systems maintains. No operation and maintenance plan has been developed and maintained. II.G.2.d The permittee maintained a current inventory of municipally -owned or operated Structural structural stormwater controls installed for compliance with the permittee's post- yes 6 Stormwater Controls construction ordinance. Inventory maintained and provided. NC5000430_Montreat M54 Audit_20220623 Page 11 of 16 Pollution Prevention and Good Housekeeping for Municipal Operations II.G.2.e 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 No --- Stormwater Controls the permittee's post -construction ordinance. If yes, then: The C&M program specified the frequency of inspections and routine Not maintenance requirements. Applicable --- The permittee documented inspections of all municipally -owned or maintained Not structural stormwater controls. Applicable --- The permittee inspected all municipally -owned or maintained structural Not stormwater controls in accordance with the schedule developed by permittee. Applicable The permittee maintained all municipally -owned or maintained structural Not stormwater controls in accordance with the schedule developed by permittee. Applicable The permittee documented maintenance of all municipally -owned or Not maintained structural stormwater controls. Applicable --- No operation and maintenance plan has been developed and maintained. II.G.2.f The permittee ensured municipal employees are properly trained in pesticide, Not Pesticide, Herbicide herbicide and fertilizer application management. Applicable and Fertilizer Application The permittee ensured contractors are properly trained in pesticide, herbicide and Not Management fertilizer application management. Applicable The permittee ensured all permits, certifications, and other measures for Not applicators are followed. Applicable No Pesticides, Herbicides, or fertilizers are utilized by the permittee. II.G.2.g The ermittee implemented an employee trainin p pg program for employees involved Staff Training in implementing pollution prevention and good housekeeping practices. No --- No training program has been developed and implemented. II.G.2.h 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. Town vehicles are washed in Black Mountain. NCS000430_Montreat MS4 Audit_20220623 Page 12 of 16 Site Visit Evaluation: Municipal Facility No. 1 Facility Name: Public Works Facility Date and Time of Site Visit: 6/23/2022 3:00 pm Facility Address: Rainbow Terrace Facility Type (Vehicle Maintenance, Landscaping, etc.): Public works, landscaping Name of MS4 inspector(s) evaluated: Barry Creasman, Public Works Director Most Recent MS4 Inspection (List date and name of inspector): None Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit: Name Title Daniel Wiggs Maintenance Tech II Observations Facility Documentation/Training Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific? No SWPPP or other stormwater document for the facility has been developed. What type of stormwater training do facility employees receive? How often? None. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Applicable staff have become certified inspectors. Continued certification requires continuing ed hours. 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? 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. 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? N/A Inspection Results Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)? No. NCS000430_Montreat MS4 Audit_20220623 Page 13 of 16 Site Visit Evaluation: MS4 Outfall No. 1 Outfall ID Number: Date and Time of Site Visit: None given. June 23, 2022 3:30 pm Outfall Location: Outfall Description (Pipe Material/Diameter, Culvert, etc.): Kentucky Road 36" galvanized metal Receiving Water: Is Flow Present? If So, Describe (Color, Approximate Flow Rate, Flat Creek Sheen, Odor, Floatables/Debris, etc.): None Most Recent Outfall Inspection/Screening (Date): None Days Since Last Rainfall: Inches: Not reviewed N/A Name of MS4 Inspector(s) evaluated: Barry Creaasman Observations Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Applicable staff have become certified inspectors. Continued certification requires continuing ed hours. Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations? Yes. 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? No. 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 NCS000430_Montreat MS4 Audit_20220623 Page 14 of 16 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1 Site Name: Bio-cell at Town Hall Date and Time of Site Visit: 6/24/2022 Site Address: Rainbow Terrace SCM Type: Bio-Cell Most Recent MS4 Inspection (Include Date and Entity): None Name of MS4 Inspector(s) evaluated: Barry Creasman Most Recent MS4 Enforcement Activity (Include Date): None Name(s) and Title(s) of Site Representative(s) Present During the Site Visit: Name Title Barry Creasman Public Works Director Daniel Wiggs Maintenance Tech If Observations Site Documentation Does the site have an operation and maintenance plan? No. Does the site have records of annual inspections? Are they performed by a qualified individual? Not reviewed. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Applicable staff have become certified inspectors. Continued certification requires continuing ed hours. Did the MS4 inspector appear knowledgeable about M54 requirements for post -construction site runoff controls? No. 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? No. Does the MS4 inspector's process include taking photos? Not reviewed Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections? Not reviewed at time of inspection. Does the MS4 inspector's 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 MS4 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? Modifications to the permittee's documentation process will be made. NCS000430_Montreat MS4 Audit_20220623 Page 15 of 16 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1 If compliance issues were identified, what timeline for correction/follow-up was provided? Not evaluated. NCS000430_Montreat MS4 Audit_20220623 Page 16 of 16