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HomeMy WebLinkAboutNCS000431_Conover MS4 Audit_20191022ROY COOPER Governor MICHAEL S. REGAN Secretary S. DANIEL SMITH Director NORTH CAROLINA Environmental Quality October 22, 2019 City of Conover Attn: Terry Lail, Environmental Coordinator Post Office Box 549 Conover, North Carolina 28613 Subject: COMPLIANCE AUDIT REPORT TRANSMITTAL City of Conover NPDES MS4 Permit No. NCS000431 Catawba County Dear Mr. Lail: Enclosed please find the National Pollutant Discharge Elimination System (NPDES) Municipal Separate Storm Sewer System (MS4) Permit Compliance Audit Report for the subject NPDES MS4 Permit. The report documents staff findings from the September 26'h and 27", 2019 audit, which evaluated compliance with the permitted MS4 program administration requirements and the specific minimum control measures checked below: E Public Education and Outreach E Public Involvement and Participation E Illicit Discharge Detection and Elimination ❑ Construction Site Runoff Controls ® Post -Construction Site Runoff Controls E Pollution Prevention and Good Housekeeping for Municipal Operations Reported findings are based upon the documentation provided and staff observations at the time of the audit. Therefore, this report may not identify all permit compliance issues. The permittee is required to evaluate program compliance for the program components not checked above and take immediate action to correct all deficiencies. Any additional compliance reporting requirements and/or enforcement action by the Department of Environmental Quality (DEQ) shall be provided under separate cover. Should you have any questions regarding this MS4 Permit Compliance Audit Report, please feel free to contact me at Isaiah.Reeed �ncdenr. ) 296-4614. 4s4a ' , Reed,t4CE PS Environmental Specialist North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources Asheville Regional Office 12090 U.S. Highway 70 1 Swannanoa, North Carolina 28778 NOFM CAPIXINP o.p.mmmiwumoom.ma u..nry 828.296.4500 Enclosures: DEQ MS4 Program Audit Report (September 26 and 27, 2019, City of Conover) cc: Jeanette Powell, DEMLR MS4 Program Coordinator Alaina Morman, DEMLR Stormwater Compliance & Enforcement DEMLR NPDES MS4 Permit Laserfiche File MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) PROGRAM AUDIT REPORT NPDES PERMIT NO. NCS000431 CONOVER, NORTH CAROLINA Post Office Box 549 Conover, North Carolina 28613 Audit Date: September 26, 2019 Report Date: October 22, 2019 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) NCS000431 Conover MS4 Audit 20191022 TABLE OF CONTENTS AuditDetails..................................................................................................................................................1 PermitteeInformation..................................................................................................................................2 Listof Supporting Documents.......................................................................................................................3 Program Implementation, Documentation & Assessment...........................................................................4 Public Education and Outreach.....................................................................................................................7 Public Involvement and Participation...........................................................................................................8 Illicit Discharge Detection and Elimination(IDDE)........................................................................................8 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................... Site Visit Evaluation: MS4 Outfall No. 1............................ .......................................................................19 ........................................................................21 Site Visit Evaluation: MS4 Outfall No. 2......................................................................................................23 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1............................................25 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 Storm water Management Plan in accordance with the issued permit. NCS000431 Conover MS4 Audit 20191022 ii This page intentionally left blank NCS000431 ConoverMS4Audit 20191022 iii Audit Details Audit ID Number: Audit Date(s): NCS000431_Conover MS4 Audit_20191022 September 26, 2019 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 N 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: 2 N MS4 Outfalls. Number visited: 2 ❑ 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 Specialist NCDEQ Kenny Llywelyn, Environmental Specialist NCDEQ Christopher Graybeal, Assistant Regional Engineer NCDEQ Audit Report Author: Date: Signature n q Audit Report Author: Date Signature NCS000431_Conover MS4 Audit_20191022 Page 1 of 26 Permittee Information MS4 Permittee Name: City of Conover Permit Effective Date: February 20, 2017 Permit Expiration Date: February 19, 2022 Mailing Address: Post Office Box 549. Conover, North Carolina 28613 Date of Last MS4 Inspection/Audit: N/A Co-permittee(s), if applicable: N/A Permit Owner of Record: Donald Duncan, City Manager Primary MS4 Representatives Participating in Audit Name, Title ° '. Organization Terry Lail, Environmental Coordinator City of Conover Erik Schlichting, GISP-GIS Specialist City of Conover Jimmy Clark, Public Work Director City of Conover Terry Jones, Assistant Public Works Director City of Conover - Keith Lynch City of Conover Alan Glines, APA-Planning Director City of Conover MS4 Receiving Waters Waterbody Classification Impairments Clark Creek C N/A Cline Creek C N/A Conover Branch C N/A Hildebran Creek C N/A Long Creek WS-Iv N/A Lyle Creek C N/A McLin Creek C N/A Miller Branch C N/A Mull Creek WS-Iv N/A Mahaffie Branch C N/A NCS000431_Conover MS4 Audit_20191022 Page 2 of26 List of Supporting Documents Item Number Document Title When Provided (Prior to/During/After) 1 2010 SWMP Prior 2 Administrative Manual Prior 3 Stormwater Ordinance Prior 4 IDDE Inspection Form Prior 5 Vehicle Maintenance Washing Area Inspection Form Prior 6 Agreement with Western Piedmont Council of Governments Prior 7 Agreement with Catawba County Prior 8 Driveway Permit Application / Sedimentation and Erosion Control (<1 Acre) Permit Prior 9 Solid Waste Manual of Practice and Operations Summary Prior 10 Pesticide Use Policy Prior 11 Spill Prevention, Control and Countermeasures (SPCC) Plan (August 14, 2014) Prior 12 Stormwater Agreement Form Prior 13 Stormwater BM Facility Access Easement Prior 14 Street Department Operations Summary Prior 15 2018 Stormwater Annual Report During 16 IDDE SOP During 17 Illicit discharge case files for two incidents. During 18 WPCOG annual report on outreach During 19 Pet Waste and Stormwater Handouts During 20 Training Records During NCS000431_Conover MS4 Audit_20191022 Page 3 of 26 Program Implementation, Documentation & Assessment - Staff Interviewed: Terry Lail, Environmental Coordinator (Name, Title, Role) Permit Citation Program Requirement Status Supporting c. 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 Responsibilities for all components of the Stormwater Plan are documented and position(s) assignments provided. No --- The permittee is current on payment of invoiced administering and compliance monitoring fees (see stormwater e-payments on DEMLR MS4 web page). Yes --- A current SWMP has not been maintained. The SWMP contains the names of people who no longer work for the City of Conover. II.A.2 Stormwater The permittee evaluated the performance and effectiveness of the program Plan components at least annually. Partial 15 Implementation and Evaluation If yes, the permittee used the results of the evaluation to modify the program components as necessary to accomplish the intent of the Stormwater Program. No --- Did the permitted MS4 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 Mr. Lail provided me with a copy of the most recent Annual Report, sent in 2018. However, the annual report did not have all elements required by the permit. II.A3 Keeping the The permittee kept the Stormwater Plan up to date. No 1 Stormwater Plan Up to Date The permittee notified DEMLR of any updates to the Stormwater Plan. No --- The SWMP has not been updated since 2010. The permittee kept an up-to-date version of its Stormwater Plan available to the Division and the public online. No NCS000431_Conover MS4 Audit_20191022 Page 4 of 26 Program Implementation, Documentation & Assessment ILA.4 Availability The online materials included ordinances, or other regulatory mechanisms, or a list See of the Stormwater identifying the ordinances, or other regulatory mechanisms, providing the legal Partial Commen Plan authority necessary to implement and enforce the requirements of the permit. is Some of the Code/Ordinance information is available at Library.Municade.com, but all information required by the permit is not readily accessible online. -II.A.3&II.A.5 Stormwater Plan Did DEMLR require a modification to the Stormwater Plan? q Not Applicable Modifications r If yes, did the permittee complete the modifications in accordance with the Not established deadline? Applicable II.A.6 Sharing +Responsibility Are any control measures implemented by an entity other than the permittee? Yes 6 and 7 If yes, is there a written agreement in place? Yes 6 and 7 Public Outreach MCM is conducted by the Western Piedmont Council of Governments. Construction Stormwater MCM is conducted by Catawba County. 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. Partial 1 The SWMP has not been maintained or reviewed. Ill_A The permittee maintained documentation of all program components including, but Program not limited to, inspections, maintenance activities, educational programs, Partial Various Documentation. implementation of BMPs, enforcement actions etc., on file for a period of five years. Inspection reports and other documentation were provided. However, various parts of the Stormwater Management Program are conducted but not documented. 111.13 The permittee submitted annual reports to the Department within twelve months Annual Report from the effective date of the permit (See Section 111.8. for the annual reporting Yes is ..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 15 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: NCS000431_Conover M54 Audit_20191022 Page 5 of 26 Program Implementation, Documentation & Assessment 1. A detailed description of the status of implementation of the Stormwater Plan as a whole. This will include information on development and implementation Partial 15 of each major component of the Stormwater Plan for the past year and 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 No 15 the proposed changes and how these changes will impact the Stormwater 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 No 15 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 No 15 Stormwater Plan. 5. An assessment of compliance with the permit, information on the establishment of appropriate legal authorities, inspections, and enforcementFNo 15 actions. The Annual Report provided focuses on Public Outreach. The other MCMs described in the report are general overviews and do not contain all information required by the Permit. IV.B Annual Reporting The Annual Reports document the following: 1. A summary of past year activities, including where applicable, specific Partial 15 quantities achieved and summaries of enforcement actions. 2. A description of the effectiveness of each program component. No 15 3. Planned activities and changes for the next reporting period, for each No 15 program component or activity. 4. Fiscal analysis. No 15 The Annual Report provided focuses on Public Outreach. The other MCMs described in the report are general overviews and do not contain all information required by the Permit. Additional The deficiencies in the above section include, but are not limited to: Comments: Failing to maintain an up to date SWMP, documentation of stormwater control activities in the municipalty, and complete Annual Reports. NCS000431_Conover MS4 Audit_20191022 Page 6 of 26 Public Education and Outreach Staff Interviewed: Terry Lail, Environmental Coordinator (Name, Title, Role) Permit Citation Program Requirement Status supporting Doc No. _. II.B.2.a Goals The permittee defined goals and objectives of the Local Public Education and Yes 18 and Objectives Outreach Program based on community wide issues. 'll.B.2.b The permittee maintained a description of the target pollutants and/or stressors and Target Pollutants No --- likely sources. A description of the Public Outreach Program has not been maintained. However, the annual report sent to the City of Conover by the Western Piedmont Stormwater Patnership does contain some information on outreach events were conducted and the nature of those events. No measurable goals have been maintained and established. 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 --- An annual assessment of the Public Education and Outreach Program has not been conducted by the Permittee. 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 18 Commercial Issues their education/outreach program. II.B.2.e Informational The permittee promoted and maintained an internet web site designed to convey the program's message. No --- Web Site The City of Conover did not maintain an internet website describing the outreach efforts. `II.B.2.f The permittee distributed stormwater educational material to appropriate target Public Education Yes 19 Materials groups. The Permittee gives out handouts on pet waste and stormwater at community events and makes them available to the public. II.B.2.g The permittee promoted and maintained a stormwater hotline/helpline for the Hotline/Help Line purpose of public education and outreach. No No Hotline was maintained far the 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 18 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. Extent of exposure /exposure hours were not reported. NCS000431_Conover MS4 Audit_20191022 Page 7 of 26 Public Education and Outreach Additional The deficiencies in the above section include, but are not limited to: Comments: Better documentation of outreach efforts, documentation and establishing goals for the year, and complete reporting of Public Education and Outreach Efforts in the Annual Reports. Public Involvement and Participation Staff Interviewed: Terry Lail, Environmental Coordinator (Name, Title, Role)` 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 Partial ongoing citizen participation. Program The permittee holds several events through the year including: Adopt a Creek, Stormdrain Stenciling, National Night Out, Stormwater Advisory Board, and Litter Sweep. Documentation of these events (participation, time, promotion) has not been conducted. 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. Yes Involvement Stormwater Advisory Board. 2.cThe permittee promoted and maintained a hotline/helpline for the purpose of publicNo line/Help Line r involvement and participation.otline was made available on the City's website. Illicit Discharge Detection and Elimination (IDDE) Staff Interviewed: Terry Lail, Environmental Coordinator (Name, Title, Terry Jones, Assistant Public Works Director Role) ' Jimmy Clark, Public Works Director Permit Citation Program Requirement Status supposing Dot No. II.D.2.a IDDE Program... The permittee maintained a written IDDE Program. Partial 16 If yes, the written program includes provisions for program assessment and Partial 16 evaluation and integrating program. NCS000431_Conover MS4 Audit_20191022 Page 8 of26 Illicit Discharge Detection and Elimination (IDDE) SOPS were maintained for IDDE, but da not include all information required by the permit. 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 M54. Yes 3 Legal Authorities If yes, the ordinance applies throughout the corporate limits of the permittee. [Permit Part I.D] Yes 3 II.D.2.c The permittee maintained a current map showing major outfalls* and receiving Storm Sewer-... No --- System Map streams. A map of the City's MS4 system including outfalls is still being created. 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 program for conducting dry weather flow field observations has not been created, maintained, or conducted. II.D2.e The permittee maintained written procedures for conducting investigations of Investigation identified illicit discharges. Partial 16 Procedures SOPS for IDDE were available, but were not sufficient to meet permit requirements. 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 Yes 17 2. The results of the investigation Yes 17 3. Any follow-up of the investigation No --- 4. The date the investigation was closed No --- Thorough inspection reports and notes were maintained, but follow-up and closure were not documented. II.D.2.g 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 20 contact with or otherwise observe an illicit discharge or illicit connection. The permittee informed public employees of hazards associated with illegal FD2.h ducation discharges and improper disposal of waste. Partial 20 NCS000431_Conover MS4 Audit_20191022 Page 9 of26 Illicit Discharge Detection and Elimination (IDDE) 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. Yes 19 Municipal employee sign -in sheets were made available during the audit. A more thorough documentation of what the training included was not available. II.D.2.i The permittee promoted, publicized, and facilitated a reporting mechanism for the Public Reporting public to report illicit discharges. Yes 19 '.Mechanism The permittee promoted, publicized, and facilitated a reporting mechanism for staff to report illicit discharges. Yes 20 The permittee established and implemented response procedures for citizen requests/reports. Partial 16 Incomplete SOPS for IDDE were available. II.D.2.i The permittee implemented a mechanism to track the issuance of notices of violation Not .Enforcement and enforcement actions administered by the permittee. Applicable .-- If yes, the mechanism includes the ability to identify chronic violators for Not initiation of actions to reduce noncompliance. Applicable No NOVs have been documented and tracked. Additional The primary deficiencies in the above section include, but are not limited to: Comments: IDDE events and follow-ups have not been documented appropriately, IDDE SOPs are incomplete, Dry weather flow inspection schedule has not been created or implemented, a municipal wide MS4 map has not been completed. NCS000431_Conover MS4 Audit_20191022 Page 10 of 26 Post -Construction Site Runoff Controls Staff Interviewed: Terry Lail, Environmental Coordinator (Name, Title, Role) Alan Glines, Planning Director Jimmy Clark, Public Works Director 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 MS4 post -construction requirements forthe areas where implemented and in compliance with the specific program requirements as provided in 15A NCAC and noted below (Complete Session Law 2006-246section below): ❑ Water Supply Watershed I (WS-1) —15A NCAC 2B .0212 ❑ Water Supply Watershed 11 (WS-11) —15A NCAC 28.0214 ❑ 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 M54 permitted area (check all that apply): ® DEQ 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 M54s 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 2006-246section 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. 2006-246 deemed -compliant program. NCS000431_Conover MS4 Audit_20191022 Page 11 of 26 Post -Construction Site Runoff Controls Permit Citation .Program Requirement: Status supporting' 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 3 Management Program. If yes, the ordinance applies throughout the corporate limits of the permittee (Verify permit coverage area listed in Part I.D of permit and modify Yes 3 accordingly). - The permittee has the authority to review designs and proposals for new development and redevelopment to determine whether adequate stormwater Yes 3 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 evaluate compliance with the Post -Construction Stormwater Management Yes 3 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 3 related to stormwater discharges. II.F.2.b Stormwater Control The permittee utilizes strategies which include SCMs appropriate for the MS4. Yes 3 Measures [SCMs) SCMs comply with 15A NCAC 02H .1000. Yes 3 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 that disturb less than one acre that are part of a larger common plan of Yes --- development or sale). If yes, the site plan reviews addressed how the project applicant meets the performance standards. Yes If yes, the site plan reviews addressed how the project will ensure long-term maintenance. Yes Site file for Dollar General was reviewed and discussed during the Audit. 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 No --- 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 No --- requirements. No inventory was made available during the audit. NCS000431_Conover MS4 Audit_20191022 Page 12 of26 Post -Construction Site Runoff Controls II.F.2.e The permittee provided mechanisms such as recorded deed restrictions and Deed Restrictions and Protective protective covenants that ensure development activities will maintain the project No Covenants consistent with approved plans. II.F2.f The permittee implemented or required an operation and maintenance plan for Mechanism to the long-term operation of the SCMs required by the program. Yes Require Long-term Operation and The operation and maintenance plan required the owner of each SCM to perform Maintenance and maintain a record of annual inspections of each SCM. Yes --- Annual inspection of permitted structural SCMs are required to be performed by a qualified professional. Yes --- The site file for Dollar General was reviewed and discussed during the Audit. II.F.2.e 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 No 'Structural is a permit condition in Part H.F.2.g of permit and modify accordingly). Stormwater Control' The permittee developed and implemented a written inspection program for SCMs Measures installed pursuant to the post -construction program(Verify this is a permit No condition in Part II.F.2.g of permit and modify accordingly. The permittee documented and maintained records of inspections. No --- The permittee documented and maintained records of enforcement actions. No --- An inspection program for SCMs had not been developed or implemented at the time of the inspection. II.F.2.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. Training for Note: New materials may be developed by the permittee, or the permittee may use Yes --- Developers materials adopted from other programs and adapted to the permittee's new development and redevelopment program. The site file and submission information for Dollar General was reviewed and discussed during the audit. II.F.2.i Enforcement The permittee tracked the issuance of notices of violation and enforcement actions. No --- If yes, the tracking mechanism included the ability to identify chronic violators Not for initiation of actions to reduce noncompliance. Applicable No NOVs were documented at the time of the Audit. II.F.3.b The permittee fully complies with post construction program requirements on its Not New Development own publicly funded construction projects. Reviewed NCS000431_Conover MS4 Audit_20191022 Page 13 of26 Post -Construction Site Runoff Controls II.F.3.c Does the MS4 have areas drainingto Nutrient Sensitive Waters NSW (NSW) to -Nutrient Sensitive 15A NCAC 02H .0150? No Waters If yes, does the permittee use SCMs that reduce nutrient loading in order to '. meet local program requirements. No --- If yes, does the permittee also still incorporate the stormwater controls required for the project's density level. No If yes, does the permittee also require documentation where it is not feasible to use SCMs that reduce nutrient loading. No --- II.F.3.d The permittee ensured that the design volumes of SCMs take into account the Design Volume runoff at build out from all surfaces draining to the system. Yes r:. 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. The site file for Dollar General was reviewed and discussed during the Audit. NCS000431_Conover MS4 Audit_20191022 Page 14 of 26 Pollution Prevention and Good Housekeeping for Municipal Operations Staff Interviewed: _- Terry Lail, Environmental Coordinator (Name, Title, 'Role) Terry Jones, Assistant Public Works Director Jimmy Clark, 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. A written inventory of facilities and potential pollutants has not been maintained. 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 O&M program specifies the frequency of routine maintenance Not requirements. Applicable If yes, the permittee evaluated the C&M program annually and updated it as Not necessary. Applicable --- A written O&M Plan has not been maintained for the municipally owned facilities. II.G.2.c Spill Response The permittee had written spill response procedures for municipal operations. ves 11 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 An evaluation of BMP's was not included in the annual report made available at the time of the audit. II.G.2.f The permittee maintained and implemented an O&M program for the stormwater O&M for Catch sewer system including catch basins and conveyance systems that it owns and No --- Basins and Conveyance Systems maintains. An O&M plan had not been created and maintained at the time of the audit. II.G.2.¢ The permittee maintained a current inventory of municipally -owned or operated Structural structural stormwater controls installed for compliance with the permittee's post- No --- StormwaterComrols construction ordinance. An inventory had not been maintained at the time of the audit. NCS000431_Conover MS4 Audit_20191022 Page 15 of 26 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 Not Applicable 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. 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 According to City staff, there are no municipally awned SCMs required under the Yawn's ordinance. II.G.2.i The permittee ensured municipal employees are properly trained in pesticide, Pesticide, Herbicide herbicide and fertilizer application management. Yes --- and Fertilizer ' Application The permittee ensured contractors are properly trained in pesticide, herbicide and Management fertilizer application management. Yes --- The permittee ensured all permits, certifications, and other measures for applicators are followed. Yes --- II.G.2.j The permittee implemented an employee training program for employees involved Staff Training in implementing pollution prevention and good housekeeping practices. Yes 20 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 ves --- Equipment Cleaning cleaning. NCS000431_Conover MS4 Audit_20191022 Page 16 of26 Site Visit Evaluation: Municipal Facility No. 1 Facility Name: Conover Wastewater Treatment Plant Date and Time of Site Visit: September 26, 2019 Facility Address: 3680 Hillview Drive. Conover, NC 28613 Facility Type (Vehicle Maintenance, Landscaping, etc.): Wastewater Treatment Plant Name of MS4 inspector(s) evaluated: Terry Lail 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 Jimmy Clark Public Works Administrator Observations Facility Documentation/Training Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific? Yes. A SWPPP was available related to the facility's NCG110000 permit coverage. What type of stormwater training do facility employees receive? How often? Annual SWPPP training. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Annual SWPPP training and re -certification requirements. 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? This was the inspectors first MS4 inspection. Future inspections shall include the use of a checklist and photos. Does the MS4 inspector's process include taking photos? This was the inspectors first MS4 inspection. Future inspections shall include the use of a checklist and photos. Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)? This was the inspectors first MS4 inspection. Future inspections shall include the use of a checklist and photos, and reviewing the facility's SWPPP. NCS000431_Conover MS4 Audit_20191022 Page 17 of 26 Site Visit Evaluation: Municipal Facility No. 1 Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge? This was the inspectors first MS4 inspection. Future inspections shall include the use of a checklist and photos. 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? This was the inspectors first MS4 inspection. Future inspections shall include the use of a checklist and photos, and contacting the site personnel. Inspection Results Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)? Yes. Damage to a conveyor resulting in waste material getting deposited on the ground. Mr. Lail will follow up on corrective actions with the facility personnel. If compliance corrective actions were identified, what timeline for correction/follow-up was provided? Not decided at the time of the inspection. NCS000431_Conover MS4 Audit_20191022 Page 18 of 26 Site Visit Evaluation: Municipal Facility No. 2 Facility Name: Public Works Date and Time of Site Visit: September 27, 2019 Facility Address: 939 4" Street SW. Conover, NC Facility Type (Vehicle Maintenance, Landscaping, etc.): Vehicle maintenance, Landscaping, etc. Name of MS4 inspector(s) evaluated: Terry Lail Most Recent MS4 Inspection (Date and Entity): None Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit: Name Title Jimmy Clark Public Works 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 SWPPP 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? This was the inspectors first MS4 inspection. Future inspections shall include the use of a checklist and photos. Does the MS4 inspector's process include taking photos? This was the inspectors first MS4 inspection. Future inspections shall include the use of a checklist and photos. Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)? This was the inspectors first MS4 inspection. Future inspections shall include the use of a checklist and photos, and will review the SWPPP. NCS000431_Conover MS4 Audit_20191022 Page 19 of 26 Site Visit Evaluation: Municipal Facility No. 2 Does the MS4 inspectors process include walking the entire facility and inspecting all points of discharge? This was the inspectors first MS4 inspection. Future inspections shall include the use of a checklist and photos. 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 InspectionResults Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)? Yes. The facility must be covered under an NPDES General Permit, and secondary containment has not be provided for all bulk storage of liquid materials. Other issues were also observed. If compliance corrective actions were identified, what timeline for correction/follow-up was provided? To be determined at a later date by City staff. Notes/Comments/Recommendations NCS000431_Conover MS4 Audit_20191022 Page 20 of26 Site Visit Evaluation: MS4 Outfall No. 1 Outfall ID Number: Date and Time of Site Visit: None given September 27, 2019 Outfall Location: Outfall Description (Pipe Material/Diameter, Culvert, etc.): 310 Second Street NE. Conover, NC Pipe and drainage channel Receiving Water: Is Flow Present? If So, Describe (Color, Approximate Flow Rate, Mahaffie Branch Sheen, Odor, Floatables/Debris, etc.): No Most Recent Outfall Inspection/Screening (Date): None Days Since Last Rainfall: Inches: Not Evaluated Name of MS4lnspector(s) evaluated: Terry Lail 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? Yes Inspection Procedures Does the inspector's process include the use of a checklist or other standardized form? This was the inspectors first MS4 inspection. Future inspections shall include the use of a checklist and photos. Does the inspector's process include taking photos? This was the inspectors first MS4 inspection. Future inspections shall include the use of a checklist and photos. Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they? No NCS000431_Conover MS4 Audit_20191022 Page 21 of 26 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)? Erosion near the street. Will a follow-up outfall inspection be conducted? If so, for what reason? Yes. To be determined by the MS4 Inspector. NCS000431_Conover MS4 Audit_20191022 Page 22 of 26 Site Visit Evaluation: MS4 Outfall No. 2 Outfall ID Number: Date and Time of Site Visit: None Given September 27, 2019 Outfall Location: Outfall Description (Pipe Material/Diameter, Culvert, etc.): 361 Fifth Street SE. Conover, NC Drainage channel and metal pipe. Receiving Water: Is Flow Present? If So, Describe (Color, Approximate Flow Rate, McLin Creek Sheen, Odor, Floatables/Debris, etc.): None Most Recent Outfall Inspection/Screening (Date): None Days Since Last Rainfall: Inches: Not evaluated Name of MS4lnspector(s): Terry Lail 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? Yes Inspection Procedures" Does the inspector's process include the use of a checklist or other standardized form? Obtain copy. This was the inspectors first M54 inspection. Future inspections shall include the use of a checklist and photos. Does the inspector's process include taking photos? This was the inspectors first MS4 inspection. Future inspections shall include the use of a checklist and photos. Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they? No NCS000431_Conover MS4 Audit_20191022 Page 23 of 26 Site Visit Evaluation: MS4 Outfall No. 2 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? No NCS000431_Conover MS4 Audit_20191022 Page 24 of26 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1 Site Name: Dollar General Date and Time of Site Visit: September 27, 2019 Site Address: 1200 V Street West. Hickory SCM Type: Dry pond Most Recent MS4 Inspection (Include Date and Entity): None Name of MS4 Inspector(s) evaluated: Terry Lail Most Recent MS4 Enforcement Activity (Include Date): None Name(s) and Title(s) of Site Representative(s) Present During the Site Visit: Name Title None 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? No 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 MS4 requirements for post -construction site runoff controls? Yes Did the MS4 inspector appear knowledgeable about post -construction BMPs (general purpose/function, components, O&M requirements, etc.)? Yes Inspection Procedures Does the MS4 inspector's process include the use of a checklist or other standardized form? What format? This was the inspectors first MS4 inspection. Future inspections shall include the use of a checklist and photos. Does the MS4 inspector's process include taking photos? This was the inspectors first MS4 inspection. Future inspections shall include the use of a checklist and photos. NCS000431_Conover M54 Audit_20191022 Page 25 of 26 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1 Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections? This was the inspectors first MS4 inspection. Future inspections shall include the use of a checklist, file review and photos. 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 M54 inspector's process include presenting the inspection findings to the site contact in writing? Not evaluated. 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? None NCS000431_Conover MS4 Audit_20191022 Page 26 of26