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Home My WebLink AboutNCS000421_HIGH POINT MS4 AUDIT REPORT_20191122MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) PROGRAM AUDIT REPORT NPDES PERMIT NO. NCS000421 HIGH POINT, NORTH CAROLINA 211 South Hamilton Street PO Box 230 High Point, NC 27261 Audit Date: 8/19 & 8/20 Report Date: November 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) NCS000421_High Point MS4 Audit_20191122 TABLE OF CONTENTS AuditDetails......................................................................................................... Permittee Information......................................................................................... List of Supporting Documents.............................................................................. Program Implementation, Documentation & Assessment .................................. Construction Site Runoff Controls....................................................................... Post -Construction Site Runoff Controls............................................................... Pollution Prevention and Good Housekeeping for Municipal Operations .......... Site Visit Evaluation: Municipal Facility No. 1...................................................... Site Visit Evaluation: Municipal Facility No. 2...................................................... Site Visit Evaluation: Construction Site No. 1...................................................... Site Visit Evaluation: Construction Site No. 2...................................................... Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1..... Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 2..... Appendix A: Supporting Documents Appendix B: Photograph Log ......................................1 ...................................... 2 ...................................... 3 ...................................... 4 ...................................... 8 ....................................11 ....................................16 ....................................19 .................................... 21 .................................... 23 .................................... 25 .................................... 27 .................................... 29 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. NCS000421_High Point MS4 Audit_20191122 ii This page intentionally left blank NCS000421_High Point MS4 Audit_20191122 iii Audit Details Audit ID Number: Audit Date(s): NCS000421_High Point MS4 Audit_20191122 August 19th & August 20th, 2019 Minimum Control Measures Evaluated: ❑X Program Implementation, Documentation & Assessment ❑ Public Education & Outreach ❑ Public Involvement & Participation ❑ Illicit Discharge Detection & Elimination ❑ Construction Site Runoff Controls — No delegated Sediment and Erosion Control Program ❑X Construction Site Runoff Controls — Delegated Sediment and Erosion Control Program ❑X Post -Construction Site Runoff Controls ❑X Pollution Prevention and Good Housekeeping for Municipal Operations ❑ Total Maximum Daily Loads (TMDLs) Field Site Visits: ❑X Municipal Facilities. Number visited: 2 ❑ MS4 Outfalls. Number visited: Choose an item. ❑X Construction Sites. Number visited: 2 ❑X Post -Construction Stormwater Runoff Controls. Number visited: 2 ❑ Other: Number visited: Choose an item. ❑ Other: Number visited: Choose an item. Inspector(s) Conducting Audit Name, Title Organization Brandon Wise, Environmental Specialist I NCDEQ— Winston-Salem Regional Office Tyler Pearson, Environmental Specialist II NCDEQ— Winston-Salem Regional Office Zac Lentz, Assistant Regional Engineer NCDEQ— Winston-Salem Regional Office Audit Report Author: Date: November 22, 2019 Signature Audit Report Author: Date Signature NCS000421_High Point MS4 Audit_20191122 Page 1 of 48 Permittee Information MS4 Permittee Name: City of High Point Permit Effective Date: February 20, 2017 Permit Expiration Date: February 19, 2022 Mailing Address: 211 S. Hamilton Street, PO Box 230, High Point, NC 27261 Date of Last MS4 Inspection/Audit: N/A Co-permittee(s), if applicable: N/A Permit Owner of Record: Robby Stone Primary MS4 Representatives Participating in Audit Name, Title Organization Anita Simpson, Operations Analyst City of High Point Kelsie Burgess, Stormwater Specialist City of High Point Robert Baker, Stormwater Specialist City of High Point Robby Stone, Public Services Assistant Director City of High Point MS4 Receiving Waters Waterbody Classification Impairments Deep River and unnamed tributaries WS-IV; CA:* Fecal Coliform for certain sections High Point Lake WS-IV; CA:* Richland Creek WS-IV: * Fecal Coliform Kennedy Mill Creek C Fecal Coliform Rich Fork Creek C Boulding Branch WS-IV: Hiatt Branch WS-IV:* Payne Creek C NCS000421_High Point MS4 Audit_20191122 Page 2 of 48 List of Supporting Documents Item When Provided Number Document Title (Prior to/During/After) 01 Stormwater Management Program Report Prior To 02 Watershed Receiving Streams Map Prior To 03 2017-18 Annual Report Prior To 04 SW Organizational Chart Prior To 05 Stormwater Program Responsibilities Prior To 06 Highpointnc.gov/655/Stormwater (High Point Stormwater's Website) Prior To 07 Eastside Wastewater Treatment Plant Inspection Report During 08 HiTran Operations Center Inspection Report During 09 Westmoreland Place Notice of Violation During NCS000421_High Point MS4 Audit_20191122 Page 3 of 48 Program Implementation, Documentation & Assessment Staff Interviewed: Anita Simpson, Operations Analyst (Name, Title, Role) Kelsie Burgess, Stormwater Specialist Robert Baker, Stormwater Specialist Robby Stone, Public Services Assistant Director Permit Citation Program Requirement Status Supporting Doc No. The permittee maintained adequate funding and staffing to implement and manage II.A.1 Staffing and the provisions of the Stormwater Plan and meet all requirements of the permit. Yes 03 Funding The Stormwater Plan identifies a specific position(s) responsible for the overall 01, 04, coordination, implementation, and revision to the Plan. Yes 05 Responsibilities for all components of the Stormwater Plan are documented and Yes 01, 04, position(s) assignments provided. 05 The permittee is current on payment of invoiced administering and compliance Yes N/A monitoring fees (see stormwater e-payments on DEMLR MS4 web page). Comments (Briefly describe funding mechanism, number of staff, etc.) Funding is completed through a stormwater fee. As with a majority of municipalities more money would be useful however funding is adequate to cover current staff. All positions are given a list of responsibilities and what they are expected to cover and take care of. II.A.2 Stormwater The permittee evaluated the performance and effectiveness of the program Plan Yes 03 components at least annually. Implementation and Evaluation If yes, the permittee used the results of the evaluation to modify the program Yes 01,03 components as necessary to accomplish the intent of the Stormwater Program. Did the permitted MS4 discharges cause or contribute to non -attainment of an No N/A applicable water quality standard? If yes, did the permittee expand or better tailor its BMPs accordingly to address Not N/A the non -attainment? Applicable Comments NCS000421_High Point MS4 Audit_20191122 Page 4 of 48 Program Implementation, Documentation & Assessment I I.A.3 Keeping the The permittee kept the Stormwater Plan up to date. Yes 01 Stormwater Plan Up to Date The permittee notified DEMLR of any updates to the Stormwater Plan. Applicable tN/A Comments (Indicate the date of latest Stormwater Plan and describe the nature of any updates, if applicable). Date on received SWMP is February 13, 2017, however evidence was shown during the inspection of annual review. 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 06 Plan The online materials included ordinances, or other regulatory mechanisms, or a list identifying the ordinances, or other regulatory mechanisms, providing the legal Partial 06 authority necessary to implement and enforce the requirements of the permit. Comments (Note what materials are available on line) Information given on the High Point Stormwater website is detailed on what stormwater is and how the program works to ensure clean water/controlled water in the city. Detailed aspects of ordinances or other regulatory mechanisms are not available on site. II.A.3 & II.A.S Stormwater Plan Did DEMLR require a modification to the Stormwater Plan? Not Applicable N/A Modifications If yes, did the permittee complete the modifications in accordance with the Not N/A established deadline? Applicable Comments (Note date of DEMLR notification, modifications required, and date modifications were completed, as applicable) II.A.6 Sharing Responsibility Are any control measures implemented by an entity other than the permittee? Yes 01,03 If yes, is there a written agreement in place? Not Applicable 01 Comments (List the specific control measures implemented by others that do not have adequate written agreements, if applicable) City was originally part of the Piedmont Triad Water Quality Partnership, which was dissolved in 2018. This agreement and the details of what was done is described in the Annual Report. II.A.7 The permittee maintained written procedures for implementing the six minimum 01, 03, Written control measures. Yes 06 Procedures Written procedures identified specific action steps, schedules, resources and 01, 03, responsibilities for implementing the six minimum measures. Yes 06 Comments (List the specific minimum measures that do not have adequate written procedures, if applicable) Procedures are well documented and even available to the public in a more general description on the website. NCS000421_High Point MS4 Audit_20191122 Page 5 of 48 Program Implementation, Documentation & Assessment III. A The permittee maintained documentation of all program components including, but Program not limited to, inspections, maintenance activities, educational programs, Partial N/A Documentation implementation of BMPs, enforcement actions etc., on file for a period of five years. Comments (List the specific program components that do not have adequate documentation on file and why, if applicable) Records for the past 3 to 4 years are very well maintained. Some of the records for years prior are lacking. During the inspection it was very evident that the newer records are extremely well organized and detailed. 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.B. for the annual reporting Yes 03 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 03 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 of each major component of the Stormwater Plan for the past year and Yes 03 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 the proposed changes and how these changes will impact the Stormwater Yes 03 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 Yes 03 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 Yes 03 Stormwater Plan. 5. An assessment of compliance with the permit, information on the establishment of appropriate legal authorities, inspections, and enforcement Yes 03 actions. Comments (Note dates that annual reports cover under current permit and generally describe report deficiencies, if any) Annual report provided prior to audit was put together very well, new annual report sent after audit also put together well. IV.B Annual Reporting The Annual Reports document the following: 1. A summary of past year activities, including where applicable, specific quantities achieved and summaries of enforcement actions. Yes 03 2. A description of the effectiveness of each program component. Yes 03 3. Planned activities and changes for the next reporting period, for each program component or activity. Yes 03 NCS000421_High Point MS4 Audit_20191122 Page 6 of 48 Program Implementation, Documentation & Assessment 4. Fiscal analysis. Yes 1 03 Comments (Note dates that annual reports cover under current permit and generally describe report deficiencies, if any) Annual Reports are put together well and contain all required elements. Additional Comments: NCS000421_High Point MS4 Audit_20191122 Page 7 of 48 Construction Site Runoff Controls Staff Interviewed: Scott Ford, City Inspector with Engineering Services (Name, Title, Role) Anita Simpson, Operations Analyst Kelsie Burgess, Stormwater Specialist Robert Baker, Stormwater Specialist Program Delegation Status: ❑X The permittee has a delegated Sediment and Erosion Control Program and implements the North Carolina Sedimentation Pollution Control Act (SPCA) of 1973 components of this minimum measure (complete the permit citation and SPCA citation sections). ❑ The permittee does not have a delegated Sediment and Erosion Control Program and relies on DEMLR to comply with the North Carolina Sedimentation Pollution Control Act (SPCA) of 1973 components of this minimum measure (complete only the permit citation section). Permit Citation Program Requirement Status Supporting Doc No. II.E.3 Construction Site Runoff Controls The permittee provides and promotes a means for the public to notify the (NPDES Permit No. appropriate authorities of observed erosion and sedimentation problems (e.g., partial 06 NCS000435] promoting the existence of the DEQ DEMLR "Stop Mud" hotline). Comments (Describe how provided and promoted) Build HighPoint.com is used to ensure the proper steps are followed however outside of the regular hotline or finding the inspectors information online there is no extra means for the public to be able to contact High Point. SPCA Citation I Delegated Program Requirement I Status I Supporting Doc No. § 113A-60 Local The permittee has adopted an ordinance or other regulatory mechanism to enforce erosion and Yes 01, 03 sedimentation the erosion and sedimentation control program. control programs (a) If yes, the ordinance meets or exceeds the minimum requirements of the Yes 01,03 SPCA. If yes, the ordinance applies throughout the corporate limits of the permittee. Yes 01,03 [Permit Part I.D] Comments (Provide regulatory mechanism reference or Supporting Documentation number) Regulatory mechanisms used by the city are typically non -monetary and involve stop work orders although fines can be issued. § 113A-60 Local erosion and The permittee collects a fee paid by each person who submits an erosion and Yes 01,03 sedimentation sedimentation control plan. control programs (d) NCS000421_High Point MS4 Audit_20191122 Page 8 of 48 Construction Site Runoff Controls Comments (indicate the fee amount, if applicable) Fees vary depending on what is being built and size. From no fee to $300+ 113A-60 Local Has any person initiated a land -disturbing activity (within the permittee's erosion and jurisdiction) for which an erosion and sedimentation control plan is required in the Yes N/A sedimentation absence of an approved plan? control programs (e) If yes, the permittee has notified the North Carolina Sedimentation Control Commission of all such cases. Yes N/A Has the permittee determined that a person engaged in a land -disturbing activity No N/A has failed to comply with an approved erosion and sedimentation control plan? If yes, has the permittee referred any such matters to the North Carolina Not N/A Sedimentation Control Commission for inspection and enforcement? Applicable Comments April 2016 was last incident at the time of the inspection. 113A-61 Local The permittee reviews each erosion and sedimentation control plan submitted to approval of erosion them and notifies the person submitting the plan that it has been approved, Yes N/A and sedimentation approved with modification, or disapproved within 30 days of receipt. control plans The permittee only approves an erosion and sedimentation control plan upon Yes N/A determining that it complies with all applicable State and local regulations. The permittee has disapproved of an erosion and sedimentation control plan in No N/A order to protect riparian buffers along surface waters. If yes, the permittee notified the Director of the Division of Energy, Not N/A Mineral, and Land Resources within 10 days of the disapproval. Applicable Comments 111 Review of plans is typically completed in 10 days, can be extended if needed § 113A-61.1 Inspection of land- The certificate of approval of each erosion and sedimentation control plan disturbing activity; approved by the permittee includes a notice of the right to inspect. Yes 03 notice of violation (a) The permittee provides for inspection of land -disturbing activities to ensure compliance with the SPCA and to determine whether the measures required in an Yes 03 erosion and sedimentation control plan are effective. Comments NCS000421_High Point MS4 Audit_20191122 Page 9 of 48 Construction Site Runoff Controls § 113A-61.1 When the permittee determines that a person engaged in land -disturbing activity Inspection of land- has failed to comply with the SPCA, the Permittee immediately issues a notice of Yes 09 disturbing activity; violation upon that person. notice of violation Each notice of violation issued by the permittee specifies the date by which the (c) person must comply. Yes 09 Each notice of violation issued by the permittee informs the person of the actions that need to be taken to comply. Yes 09 Comments Example from Westmoreland Place attached. 113A-64 Penalties Does the permittee issue civil penalties as part of the erosion and sedimentation program? Yes 09 Comments (indicate when/why a civil penalty is issued, and the amount, if applicable) Violations lead to civil penalties in amount of $25,000. Additional Local program consists of 2 full time inspectors. Comments: NCS000421_High Point MS4 Audit_20191122 Page 10 of 48 Post -Construction Site Runoff Controls Staff Interviewed: Anita Simpson, Operations Analyst (Name, Title, Role) Kelsie Burgess, Stormwater Specialist Robert Baker, Stormwater Specialist Robby Stone, Public Works Assistant Director Implementation (check all that apply): ❑X 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 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 11 (WS-11) — 15A NCAC 213.0214 ❑ Water Supply Watershed III (WS-III) — 15A NCAC 26 .0215 ❑ Water Supply Watershed IV (WS-IV) —15A NCAC 213.0216 ❑ Freshwater High Quality Waters (HQW) —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): ❑x 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 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. 2006-246 deemed -compliant program. NCS000421_High Point MS4 Audit_20191122 Page 11 of 48 Post -Construction Site Runoff Controls Session Law 2006- Supporting 246 Program Requirement Status Dot No. Deemed -Compliant The permittee implements deemed -compliant Program requirements in Program(s) accordance with the applicable 15A NCAC rules. Yes 01,03 The permittee implements deemed -compliant Program requirements throughout the entire MS4 area (If not also complete the Permit Citation section below.) Yes 01,03 The permittee applies deemed -compliant Program requirements to all federal, state and local government projects within the permitted MS4 area who do not Yes 01,03 have their own NPDES stormwater permit. The permittee included deemed -compliant Program reporting in their MS4 Annual Reports. Yes 01,03 The permittee included deemed -compliant Program implementation in their Stormwater Management Plan. Yes 01,03 Comments Post -Construction requirements met in all phases of the permit. Permit Citation I Program Requirement I Status I Supporting Dot No. II.F.2.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 01,03 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 01,03 accordingly). The permittee has the authority to review designs and proposals for new development and redevelopment to determine whether adequate stormwater Yes 01,03 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 01,03 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 01 related to stormwater discharges. Comments (if the permittee relies upon another entity, specifically note the legal authority that allows that entity to implement the program within the MS4 area) City of High Point holds the authority inside of city limits. I I. F.2. b Stormwater Control The permittee utilizes strategies which include SCMs appropriate for the MS4. Yes 01,03 Measures (SCMs) SCMs comply with 15A NCAC 02H .1000. Yes 01,03 NCS000421_High Point MS4 Audit_20191122 Page 12 of 48 Post -Construction Site Runoff Controls Comments 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 01,03 development or sale). If yes, the site plan reviews addressed how the project applicant meets the performance standards. Yes 01,03 If yes, the site plan reviews addressed how the project will ensure long-term Yes 01,03 maintenance. Comments 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 N/A 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 N/A requirements. Comments Map included all post -construction measures in the city and was very well organized. Database also had all information about the SCMs. I I. 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 01,03 and Protective consistent with approved plans. Covenants Comments II.F.2.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 01,03 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 01,03 Annual inspection of permitted structural SCMs are required to be performed by a qualified professional. Yes 01,03 Comments NCS000421_High Point MS4 Audit_20191122 Page 13 of 48 Post -Construction Site Runoff Controls 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 03 Structural is a 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 N/A 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 N/A condition in Part II.F.2.g of permit and modify accordingly. The permittee documented and maintained records of inspections. Yes N/A The permittee documented and maintained records of enforcement actions. Yes N/A Comments 247 issues had been addressed in the past year. 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 06 Developers materials adopted from other programs and adapted to the permittee's new development and redevelopment program. Comments (if the permittee has adopted materials from other programs, indicate here which materials they are using) City of High Point Design Manual available via their website. II.F.2.i Enforcement The permittee tracked the issuance of notices of violation and enforcement Yes 03 actions. If yes, the tracking mechanism included the ability to identify chronic violators for initiation of actions to reduce noncompliance. Yes 03 Comments Tracked via database linked to mapping system. II.F.3.b The permittee fully complies with post construction program requirements on its Yes N/A New Development own publicly funded construction projects. Comments NCS000421_High Point MS4 Audit_20191122 Page 14 of 48 Post -Construction Site Runoff Controls II.F.3.c Does the MS4 have areas draining to Nutrient Sensitive Waters (NSW) pursuant to No N/A Nutrient Sensitive 15A NCAC 02H .0150? Waters If yes, does the permittee use SCMs that reduce nutrient loading in order to Not N/A meet local program requirements. Applicable If yes, does the permittee also still incorporate the stormwater controls Not N/A required for the project's density level. Applicable If yes, does the permittee also require documentation where it is not feasible to Not N/A use SCMs that reduce nutrient loading. Applicable Comments (Provide reference for local requirements) 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 01,03 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 01,03 streets, driveways, and other impervious surfaces. Comments Additional Post construction program was well implemented and mapping was very thorough with all types of measures Comments: mapped. Database was kept with information on last inspection and status. NCS000421_High Point MS4 Audit_20191122 Page 15 of 48 Pollution Prevention and Good Housekeeping for Municipal Operations Staff Interviewed: Anita Simpson, Operations Analyst (Name, Title, Role) Kelsie Burgess, Stormwater Specialist Robert Baker, Stormwater Specialist Robby Stone, Public Services Assistant 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 Yes N/A stormwater runoff. Comments (Note number of facilities, typical inventory data and any facilities that are not inventoried that should be) All 13 facilities owned and operated by the City of High Point were kept on a database and along with the location information was also kept on whether or not the facilities had permits or not. 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 Yes 01 Maintenance (O&M) stormwater runoff. for Facilities If yes, the O&M program specifies the frequency of inspections. Yes 01 If yes, the O&M program specifies the frequency of routine maintenance requirements. Yes 01 If yes, the permittee evaluated the 0&M program annually and updated it as Yes 01 necessary. Comments Full inspections are required annually by City of High Point Stormwater inspectors. A smaller "safety/environmental" inspection is performed by on -site employees once a month. II.G.2.c Spill Response The permittee had written spill response procedures for municipal operations. Yes N/A Procedures Comments General spill response exists for the City along with specific Spill Prevention Control and Countermeasure (SPCC) plans at the landfill and wastewater plants. 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 Yes 01 corporate limits annually. NCS000421_High Point MS4 Audit_20191122 Page 16 of 48 Pollution Prevention and Good Housekeeping for Municipal Operations Parking Lots If yes, the permittee evaluated the effectiveness of existing and new BMPs Maintenance Yes 01, 03 based on cost and the estimated quantity of pollutants removed. Comments II.G.2.f The permittee maintained and implemented an 0&M program for the stormwater O&M for Catch sewer system including catch basins and conveyance systems that it owns and Yes 01 Basins and Conveyance Systems maintains. Comments (Briefly describe O&M program) —1200 outfalls in City of High Point system. City of High Point will comfortably say at least 99% of their system is mapped. The city will use a camera truck to help figure out the status of the pipes and location. On the mapped system any conveyance on private property is mapped with a dashed line to help differentiate the system. II.G.2.g The permittee maintained a current inventory of municipally -owned or operated Structural structural stormwater controls installed for compliance with the permittee's post- Yes 01,03 Stormwater Controls construction ordinance. Comments (Describe inventory information and number of controls in inventory) 451 inspections of SCMs throughout the city were performed. II.G.2.h The permittee maintained and implemented an 0&M program for municipally - O&M for Structural owned or maintained structural stormwater controls installed for compliance with Yes 01 Stormwater Controls the permittee's post -construction ordinance. If yes, then: The O&M program specified the frequency of inspections and routine maintenance requirements. Yes 01 The permittee documented inspections of all municipally -owned or maintained structural stormwater controls. Yes 01 The permittee inspected all municipally -owned or maintained structural stormwater controls in accordance with the schedule developed by permittee. Yes 01 The permittee maintained all municipally -owned or maintained structural stormwater controls in accordance with the schedule developed by permittee. Yes 01 The permittee documented maintenance of all municipally -owned or maintained structural stormwater controls. Yes 01 Comments Yearly inspections of all municipally owned and operated SCMs. All records of inspections are kept on the database and can be easily found and organized by stormwater employees. II.G.2.i The permittee ensured municipal employees are properly trained in pesticide, Yes N/A herbicide and fertilizer application management. NCS000421_High Point MS4 Audit_20191122 Page 17 of 48 Pollution Prevention and Good Housekeeping for Municipal Operations Pesticide, Herbicide The permittee ensured contractors are properly trained in pesticide, herbicide and Not and Fertilizer fertilizer application management. Applicable N/A Application Management The permittee ensured all permits, certifications, and other measures for Yes N/A applicators are followed. Comments All staff related to application of chemicals are properly trained and certified. 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 03 Comments All municipal facility employees are trained, over 300 employees total. 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 01,03 Equipment Cleaning cleaning. Comments Additional Comments: NCS000421_High Point MS4 Audit_20191122 Page 18 of 48 Site Visit Evaluation: Municipal Facility No. 1 Facility Name: Date and Time of Site Visit: Eastside Wastewater Treatment Plant 8/20 @ 0830 Facility Address: Facility Type (Vehicle Maintenance, Landscaping, etc.): 5878 Riverdale Drive Wastewater Treatment Plant Name of MS4 inspector(s) evaluated: Most Recent MS4 Inspection (List date and name of inspector): Robert Baker/Kelsie Burgess 12/17/2018 - Robert Baker Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit: Name Title Anita Simpson, Robby Stone City of High Point Observations Facility Documentation/Training Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific? Yes. SWPPP is specific to facility as required by the General Stormwater permit maintained by the facility. What type of stormwater training do facility employees receive? How often? Facility employees receive a sit specific training performed by the MS4 employees. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? The MS4 inspector receives yearly training. Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? Yes. Inspector looks at all required areas and knows what type of pollutants are specific to this facility. Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping? Yes. Inspector identified a few areas that may need to be addressed and knew what the signs of impacts were at all locations. Inspection Procedures Does the MS4 inspector's process include the use of a checklist or other standardized form? Yes. Attachment 07. Does the MS4 inspector's process include taking photos? Yes. Photos were taken of outfalls and any areas that may have had issues. Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)? Yes. NCS000421_High Point MS4 Audit_20191122 Page 19 of 48 Site Visit Evaluation: Municipal Facility No. 1 Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge? Yes. MS4 inspector looked at all outfalls along with major areas of concern. 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)? It was recommended to inspector and facility to ensure access to all outfalls is kept maintained for inspection purposes. If compliance corrective actions were identified, what timeline for correction/follow-up was provided? During next mowing/maintenance cycle. Notes/Com ments/Recommend ations It was well noted that facility contacts knew and were friendly with all MS4 representatives. The contacts also mentioned upon arrival that an issue previously noted by the MS4 had been addressed. It was also noted during the inspection that the inspector struggled to locate one of the outfalls on the map. NCDEQ also noted that there was a storage area with large amounts of oil/lubricants and although it was covered some of the containers were stored without secondary containment. This area was indoors but should one of the containers bust the opportunity was there for fluids to reach the drains. NCS000421_High Point MS4 Audit_20191122 Page 20 of 48 Site Visit Evaluation: Municipal Facility No. 2 Facility Name: Date and Time of Site Visit: HiTran Transit Operations Center 8/20 @ 1000 Facility Address: Facility Type (Vehicle Maintenance, Landscaping, etc.): 716-718 W. Kivett Drive Vehicle (Bus) Maintenance Name of MS4 inspector(s) evaluated: Most Recent MS4 Inspection (Date and Entity): Robert Baker/Kelsie Burgess 12/31/2018 Robert Baker Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit: Name Title Anita Simpson, Robby Stone City of High Point Observations Facility Documentation/Training Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific? Yes, however the SWPPP had no evidence of being updated annually. What type of stormwater training do facility employees receive? How often? Facility employees receive a sit specific training performed by the MS4 employees. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? The MS4 inspector receives yearly training. Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? Yes. Inspector looks at all required areas and knows what type of pollutants are specific to this facility. Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping? Yes. Inspector did miss a large roll off container with rusted metal along with other rusted parts being stored outdoors. Inspection Procedures Does the MS4 inspector's process include the use of a checklist or other standardized form? Yes. Attachment 08. Does the MS4 inspector's process include taking photos? Yes. Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)? Yes. NCS000421_High Point MS4 Audit_20191122 Page 21 of 48 Site Visit Evaluation: Municipal Facility No. 2 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: Inspector missed one area with an uncovered metal roll -off. The roll -off appeared to be filled with trash and was surrounded by rusted metal. 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)? An annual updated form will be added to the SWPPP. If compliance corrective actions were identified, what timeline for correction/follow-up was provided? As soon as possible. Notes/Comments/Recommendations Inspector had obvious knowledge of site and all areas of the site with potential pollutants would be present for the main target pollutants. Inspector needs to ensure that the entire site is inspected including areas that may not have had target pollutants during a previous inspection. NCS000421_High Point MS4 Audit_20191122 Page 22 of 48 ISite Visit Evaluation: Construction Site No. 1 Site/Project Name: Date and Time of Site Visit: Pegg Road Industrial Facility 8/19 @ 1320 Site/Project Address: Operator: Pegg Road & Gallimore Dairy Road Spainhour & Sons High Point, NC 27265 Project Type (Commercial, Industrial, Residential, CIP, Roadway, etc.): Commercial NCG Permit ID Number: Disturbed Acreage: NCG01 10 Recent Enforcement Actions (Include Date): N/A Name of MS4 Inspector(s) evaluated: Scott Ford Name(s) and Title(s) of Site Representative(s) Present During the Site Visit: Name Title Anita Simpson, Robert Baker, Robby Stone City of High Point Observations Site Documentation/Training Does the site have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it site -specific? Site has an approved erosion and sediment control plan approved by the City of High Point Does the site have approved erosion and sedimentation control plans onsite? Are they representative of current site conditions? Unknown, inspector did not ask for the plans or look in job box for plans. What type of stormwater training do site employees receive? How often? Not Available. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Inspector receives annual training from the MS4. Did the MS4 inspector appear knowledgeable about MS4 and NCG010000 requirements for construction sites? Inspector appears knowledgeable about sediment requirements however inspector does not appear to have the knowledge about the extra requirements of the NCG01 Did the MS4 inspector appear knowledgeable about erosion and sedimentation control/stormwater pollution prevention BMPs? Yes. Inspector looked at the sediment ponds on site and noted small issues when present. NCS000421_High Point MS4 Audit_20191122 Page 23 of 48 Site Visit Evaluation: Construction Site No. 1 Inspection Procedures Does the MS4 inspector's process include the use of a checklist? No. Does the MS4 inspector's process include taking photos? No. Does the MS4 inspector's process include reviewing approved plans (erosion and sedimentation control and/or SWPPP)? Yes, inspector had a copy of the plans. 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 violations? If so, explain: Inspector walked right past an area where it appeared the contractor on site was working outside of the limits of disturbance. Inspector also did not note the large amount of sediment that was accumulating on Pegg Road. Inspector missed a drop inlet that was located on site that was completely covered with sediment where the inlet protection had failed. Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing? Inspector met with superintendent prior to leaving to talk about the site conditions. Does the MS4 inspector's process include providing construction stormwater educational materials to the site contact? No. Compliance/Enforcement What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in? N/A If compliance issues were identified, what timeline for correction/follow-up was provided? N/A Notes/Comments/Recommendations It should be noted that the site was not in bad condition and the inspector appeared to have a knowledge of the sediment control requirements. Inspector did note that the large basin on the western edge of the site was installed and that stormwater employees (Anita Simpson) had been on site to review the basin and ensure that it was installed properly and matched the approved design. It should be noted that given the timeline of the basin being installed the requirements for permanent groundcover state that groundcover should have been established at the basin. As stated previously the inspector also did not comment on area in southwest corner where it appeared contractor was outside of the established limits. There was also sediment being tracked off of the site onto Pegg Road due to lack of maintenance to the construction entrance. NCDEQ informed the City of High Point that this should be considered and issue due to the fact that from the road this sediment will directly enter the city stormwater system and can cause issues. Inspector also did not ensure that monitoring was being completed and did not check to ensure plans were being kept on site. NCS000421_High Point MS4 Audit_20191122 Page 24 of 48 ISite Visit Evaluation: Construction Site No. 2 Site/Project Name: Date and Time of Site Visit: Westmoreland Place 8/20 @ 1430 Site/Project Address: Operator: 4650 Johnson Street BSC Holdings High Point, NC 27265 Project Type (Commercial, Industrial, Residential, CIP, Roadway, etc.): Residential NCG Permit ID Number: Disturbed Acreage: NCG01 58 Recent Enforcement Actions (Include Date): NOV sent 8/16/2019 Name of MS4 Inspector(s) evaluated: Scott Ford Attachment 09 Name(s) and Title(s) of Site Representative(s) Present During the Site Visit: Name Title Anita Simpson, Robby Baker, Robby Stone City of High Point Observations Site Documentation/Training Does the site have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it site -specific? Site has an approved erosion and sediment control plan approved by the City of High Point. Does the site have approved erosion and sedimentation control plans onsite? Are they representative of current site conditions? Unknown, inspector did not ask for the plans or look in job box for plans. What type of stormwater training do site employees receive? How often? Not Available. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Inspector receives annual training from the MS4. Did the MS4 inspector appear knowledgeable about MS4 and NCGO10000 requirements for construction sites? Inspector appears knowledgeable about sediment requirements however inspector does not appear to have the knowledge about the extra requirements of the NCG01. Did the MS4 inspector appear knowledgeable about erosion and sedimentation control/stormwater pollution prevention BMPs? Yes. Inspector looked at the sediment ponds on site and noted small issues when present. NCS000421_High Point MS4 Audit_20191122 Page 25 of 48 Site Visit Evaluation: Construction Site No. 2 Inspection Procedures Does the MS4 inspector's process include the use of a checklist? Obtain copy. No. Does the MS4 inspector's process include taking photos? No. Does the MS4 inspector's process include reviewing approved plans (erosion and sedimentation control and/or SWPPP)? No. 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 violations? If so, explain: During the inspection with NCDEQ the inspector missed multiple violations including no groundcover, areas of downed silt fence, and lack of inlet protection in road inlets. Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing? Yes. Does the MS4 inspector's process include providing construction stormwater educational materials to the site contact? No site contact on site. Compliance/Enforcement What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in? NOV was issued week prior. If compliance issues were identified, what timeline for correction/follow-up was provided? NOV had 15-day timeline. Notes/Comments/Recommendations It should be noted that during this inspection the site was currently under a NOV. During the inspection the inspector did not make note of the lack of groundcover that was prevalent through the entire site. NCDEQ told all inspectors to inspect the site as they normally would therefore the lack of comment is an issue. It was noted that the NOV did document this issue however it was not observed by NCDEQ during the inspection. It was also noted by NCDEQ during the inspection that a >1-acre area near the northeastern part of the site was currently without any protection outside of silt fence. Evidence on site showed that the area had already suffered a loss of sediment and regulations require any drainage area over 1 acre have a control measure more than that of just silt fence. NCS000421_High Point MS4 Audit_20191122 Page 26 of 48 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1 Site Name: Date and Time of Site Visit: Fire Station #4 8/19/2019 @ 1045 Site Address: SCM Type: 930 Old Winston Road Wet Pond High Point, NC 27265 Most Recent MS4 Inspection (Include Date and Entity): Jan 2019, in compliance Name of MS4 Inspector(s) evaluated: Most Recent MS4 Enforcement Activity (Include Date): Kelsie Burgess N/A Name(s) and Title(s) of Site Representative(s) Present During the Site Visit: Name Title Anita Simpson Operations Analyst Robert Baker Stormwater Specialist 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? Yes, they are kept with the stormwater office. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Inspector receives annual training as well as being SCM inspector certified. 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? Yes, the inspector uses a checklist that is special for each site. Does the MS4 inspector's process include taking photos? Yes, any issues are photographed along with the outfall and intake to the measure. Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections? Yes, typically prior to getting on site as they are kept at the office. NCS000421_High Point MS4 Audit_20191122 Page 27 of 48 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1 Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge? Inspector looked at the entire SCM including its outfall. Did the MS4 inspector miss any obvious operation and maintenance deficiencies? If so, explain: Inspector did not look at the area that was feeding the SCM. Parking lot and trash containers are present and should be looked at to help catch issues that may impact the SCM in the future. 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? Site maintenance was informed that the outfall was overgrown and will need to be cut back in order for access to the outfall to be established. Inspector also noted that cattails were present and should be removed. If compliance issues were identified, what timeline for correction/follow-up was provided? As soon as possible. Notes/Com ments/Recommend ations Inspector was informed that the inspection of the measure was done well however since these measures are city owned the inspection, while not required to look at the entire site, should at least include the immediate up gradient areas. At this facility the main concern up gradient is the trash containers, that while during this inspection were kept up and very clean could present a potential issue that could be caught and addressed prior to reaching the measure. NCS000421_High Point MS4 Audit_20191122 Page 28 of 48 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 2 Site Name: Date and Time of Site Visit: High Point Athletic Complex 8/19/2019 @ 1115 Site Address: SCM Type: 2920 School Park Road Bio-Retention Cell High Point, NC 27265 Most Recent MS4 Inspection (Include Date and Entity): April 2019 — In compliance Name of MS4 Inspector(s) evaluated: Most Recent MS4 Enforcement Activity (Include Date): Robert Baker Out of Compliance December 2018 Name(s) and Title(s) of Site Representative(s) Present During the Site Visit: Name Title Anita Simpson Operations Analyst Kelsie Burgess Stormwater Specialist 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? Yes, they are kept at the stormwater office. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? MS4 inspector receives annual training from the MS4 and also has received NC State's SCM Inspector 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? Yes, the inspector uses a checklist that is special for each site. Does the MS4 inspector's process include taking photos? Yes, any issues are photographed along with the outfall and intake to the measure. Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections? Yes, typically prior to getting on site as they are kept at the office. NCS000421_High Point MS4 Audit_20191122 Page 29 of 48 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 2 Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge? Inspector looked at the entire measure including its outfalls. Did the MS4 inspector miss any obvious operation and maintenance deficiencies? If so, explain: Main issue missed by the inspector was large stockpile of sand being stored directly up gradient of storm drain that led to the bio- retention cell. 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? Bare areas need to be addressed as well as monitoring the potential dying plants in the cell. If compliance issues were identified, what timeline for correction/follow-up was provided? As soon as possible. Notes/Com ments/Recommend ations As with the previous inspection, the inspector appeared very knowledgeable about the measure and how it operates and how to take care of it. The inspector did not look up gradient and inspect a large pile of sand that was going to the drains that fed to the basin. Given the operation of a bio-retention cell this could have a large negative impact on the cell as it can cause decreased drainage therefore leading to decreased efficiency. This issue should have been addressed during the inspection. NCS000421_High Point MS4 Audit_20191122 Page 30 of 48 APPENDIX A: SUPPORTING DOCUMENTS Please Note: Copy of report sent to City of High Point does not include City supplied documents. NCS000421_High Point MS4 Audit_20191122 Page 31 of 48 APPENDIX B: PHOTOGRAPH LOG �Y,.."k .r!�4M.`SY`� �.' 4 ka'�>'-. Photo 1: Wet Pond at Fire Station #4 Photo 2: Wet Pond with noted cattails NCS000421_High Point MS4 Audit_20191122 Page 32 of 48 Photo 3: Location of overgrown outfall at wet pond NCS000421_High Point MS4 Audit_20191122 Page 33 of 48 Photo 5: Outfalls from bio-retention cell Photo 6: Noted bare areas along bio-retention cell NCS000421_High Point MS4 Audit_20191122 Page 34 of 48 Pr W74 _ �i ~ '•4� Photo 7: Pond without groundcover at Pegg Road project Photo 8: Offsite sedimentation from Pegg Road project that was not observed by inspector NCS000421_High Point MS4 Audit_20191122 Page 3S of 48 Photo 9: Concrete washout being done directly onto ground Photo 10: Offsite sedimentation via Pegg Road mud NCS000421_High Point MS4 Audit_20191122 Page 36 of 48 - - A SY6 Photo 11: Area of disturbance that appeared to be outside of limits and without protection 0. Photo 12: Drop inlet completely covered with sediment NCS000421_High Point MS4 Audit_20191122 Page 37 of 48 h, 1 Photo 13: Large area without groundcover and sediment reaching unprotected stormwater system at Westmoreland Place Photo 14: Offsite sedimentation and downed silt fence at Westmoreland Place NCS000421_High Point MS4 Audit_20191122 Page 38 of 48 Photo 15: Part of Large area at northeast corner that drains solely to silt fence at Westmoreland Place . T - i Photo 16: Evidence of large amounts of erosion at Westmoreland Place NCS000421_High Point MS4 Audit_20191122 Page 39 of 48 Photo 16: Evidence of large amounts of erosion at Westmoreland Place NCS000421_High Point MS4 Audit_20191122 Page 39 of 48 t,.. Photo 17: Large basin in need of maintenance at Westmoreland Place Photo 18: More offsite sedimentation and downed silt fence at Westmoreland Place NCS000421_High Point MS4 Audit_20191122 Page 40 of 48 Photo 19: General view of Westmoreland Place with limited to no groundcover Photo 20: Drying area at Eastside WWTP NCS000421_High Point MS4 Audit_20191122 Page 41 of 48 A4. ems. vo i �'e' ��► �, i �I. �" }fir IV � N \ FY Photo 23: Storage area for dried "cake" at Eastside WWTP Photo 24: Storage area for old materials at Eastside WWTP NCS000421_High Point MS4 Audit_20191122 Page 43 of 48 Photo 25: Oil/Lubricants being stored without secondary containment :A Photo 26: General storage area at Eastside WWTP (under cover) NCS000421_High Point MS4 Audit_20191122 Page 44 of 48 Photo 27: Diesel tank at Eastside WWTP with spill kit • � L-_... Photo 28: External "Junk" storage at Eastside WWTP NCS000421_High Point MS4 Audit_20191122 Page 45 of 48 Photo 29: General bus parking at HiTran facility Photo 30: Indoor used oil storage at HiTran facility NCS000421_High Point MS4 Audit_20191122 Page 46 of 48 1 4. ' 1 40 y Photo 31: Fueling station at HiTran facility . :AI:a:ri�u:i:tirmt^aursai-va±:`,f - Photo 32: Roll -off container and general metal storage at HiTran facility NCS000421_High Point MS4 Audit_20191122 Page 47 of 48 iiii�ii�iii/iii lllllllll!lllllllll rti1v�� ' Photo 33: Indoor bus wash area at HiTran Facility NCS000421_High Point MS4 Audit_20191122 Page 48 of 48