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Home My WebLink AboutNCS000421_High Point Self Audit_20200910 MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) PROGRAM SELF-AUDIT REPORT NPDES PERMIT NO. NCS000421 HIGH POINT, NORTH CAROLINA Davidson, Forsyth, Guilford and Randolph Counties Audit Dates: May 19, 2020 Report Date: September 9, 2020 North Carolina Department of Environmental Quality Division of Energy, Mineral & Land Resources Stormwater Program 512 N. Salisbury Street, 9th floor 1612 Mail Service Center Raleigh, NC 27699-1612 MS4 Permit Self-Audit Report High Point, NC: NPDES Permit No. NCS000421 Audit Date: May 19, 2020 i (This page intention ally left blank) MS4 Permit Self-Audit Report High Point, NC: NPDES Permit No. NCS000421 Audit Date: May 19, 2020 ii TABLE OF CONTENTS Self-Audit Details ....................................................................................................................................... 1 Permittee Information ............................................................................................................................... 2 Supporting Documents ............................................................................................................................... 3 Program Implementation, Documentation & Assessment ......................................................................... 4 Public Education and Outreach .................................................................................................................. 8 Public Involvement and Participation ....................................................................................................... 11 Illicit Discharge Detection and Elimination (IDDE) .................................................................................... 13 Total Maximum Daily Loads (TMDLs) ....................................................................................................... 17 Appendix A: Supporting Documents Appendix B: Photograph Log 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 note d 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. MS4 Permit Self-Audit Report High Point, NC: NPDES Permit No. NCS000421 Audit Date: May 19, 2020 iii This page intentionally left blank MS4 Permit Self-Audit Report High Point, NC: NPDES Permit No. NCS000421 Audit Date(s): May 19, 2020 Page 2 of 18 Permittee Information MS4 Permittee Name: City of High Point Permit Effective Date: February 20, 2017 Permit Expiration Date: February 19, 2022 City, State, ZIP: High Point, NC 27260 Date of Last MS4 Inspection/Audit: August 19, 2019 Co-permittee(s), if applicable: N/A Permit Owner of Record: City of High Point – Terry Houk, Public Services Director Primary MS4 Representatives Participating in Audit Name, Title Organization Trevor Spencer, Public Services Manager City of High Point, Public Services – Stormwater Division Anita Simpson, Operations Analyst City of High Point, Public Services – Stormwater Division Robbie Baker, Stormwater Specialist II City of High Point, Public Services – Stormwater Division Kelsie Burgess, Stormwater Specialist II City of High Point, Public Services – Stormwater Division MS4 Receiving Waters Waterbody Classification Impairments East Fork of Deep River WS-IV; WS-IV CA Fecal Coliform for certain sections West Fork of Deep River WS-IV; WS-IV CA Ecological / Biological Integrity Fish Community High Point Lake From source in backwaters of High Point Lake to dam at High Point Lake (City of High Point water supply intake) WS-IV; WS-IV CA See North Carolina 2018 Section 303(d) List Decision Document Appendix B: Waterbody Impairments Delisted Since the Previous Cycle Long Branch WS-IV; WS-IV CA Ecological / Biological Integrity Fish Community Richland Creek WS-IV Fecal Coliform Kennedy Mill Creek C N/A Rich Fork Creek C Fecal Coliform Boulding Branch WS-IV N/A Hiatt Branch WS-IV; WS-IV CA N/A Payne Creek C N/A MS4 Permit Self-Audit Report High Point, NC: NPDES Permit No. NCS000421 Audit Date(s): May 19, 2020 Page 3 of 18 Supporting Documents Item Number Document Title When Provided (Prior to/During/After) 1 Public Education and Outreach Plan (11.B.2.d) During 2 Stormwater Website (11.B.2.e) During 3 Educational Materials and Pictures (11.B.2.f & 11.B.2.h) During 4 Tracking Sheet Examples (11.B.2.h) During 5 Adopt-a-Stream Packet (11.C.2.a) During 6 Drain Marker Packet (11.C.2.a) During 7 Example Tracking Adopt-a-Stream (11.C.2.a) During 8 IDDE Manual (11.D.2.a) During 9 Dry Weather Monitoring SOP (11.D.2.d) During 10 IDDE Employee Training (11.D.2.e) During 11 IDDE SOP (11.D.2.g) During 12 Report IDDE via City Website (11.D.2.i) During 13 IDDE Excel Spreadsheet (11.D.2.j) During 14 IDDE Accela Database (11.D.2.j) During MS4 Permit Self-Audit Report High Point, NC: NPDES Permit No. NCS000421 Audit Date(s): May 19, 2020 Page 4 of 18 Program Implementation, Documentation & Assessment Staff Interviewed: (Name, Title, Role) Trevor Spencer – Public Services Manager Anita Simpson – Operations Analyst Permit Citation Program Requirement Status Supporting Doc No. II.A.1 Staffing and Funding The permittee maintained adequate funding and staff ing to implement and manage the provisions of the Stormwater Plan and meet all requirements of the permit. Yes --- The Stormwater Plan identifies a specific position(s) responsible for the overall coordination, implementation, and revision to the Plan. Yes --- Responsibilities for all components of the Stormwater Plan are documented and position(s) assignments provided. Yes --- The permittee is current on payment of invoiced administering and compliance monitoring fees (see stormwater e-payments on DEMLR MS4 web page). Yes --- Comments (Briefly describe funding mechanism, number of staff, etc.) The stormwater program is funded through a stormwater utility fee charged to property owners within city limits. Residential customers are charged 1 Equivalent Residential Unit (ERU) of $4 per month. All commercial and industrial properties are charged based on the total amount of impervious area on a property divided by the ERU (Equivalent Residential Unit) of 2,588 square f eet multiplied by $4 per month. Example: 100,000 sq. ft. / 2588 sq. ft. = 38.64 ERU, 38.64 ERU X $4 per month = $154.56 per month for the stormwater utility fee. The stormwater utility fee sufficiently funds program needs and services, and a staff of 26 employees. The staff consists of the 1 Public Services Manager, 1 Operations Analyst, 1 GIS Analyst, 2 Administrative Associate s, 3 Stormwater Specialists, 2 Stormwater Supervisors for field service crews, 1 Stormwater Technician (camera truck operator), and 15 Motor Equipment Operators for fi eld service crews. II.A.2 Stormwater Plan Implementation and Evaluation The permittee evaluated the performance and effectiveness of the program components at least annually. Yes --- 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. Yes --- 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 the non-attainment? Not Applicable --- Comments MS4 Permit Self-Audit Report High Point, NC: NPDES Permit No. NCS000421 Audit Date(s): May 19, 2020 Page 5 of 18 Program Implementation, Documentation & Assessment II.A.3 Keeping the Stormwater Plan Up to Date The permittee kept the Stormwater Plan up to date. Yes --- The permittee notified DEMLR of any updates to the Stormwater Plan. Not Applicable --- Comments (Indicate the date of latest Stormwater Plan and describe the nature of any updates, if applicable). II.A.4 Availability of the Stormwater Plan The permittee kept an up-to-date version of its Stormwater Plan available to the Division and the public online. Yes --- The online materials included ordinances, or other regulatory mechanisms, or a list identifying the ordinances, or other r egulatory mechanisms, providing the legal authority necessary to implement and enforce the requirements of the permit. Yes --- Comments (Note what materials are available on-line) The current NPDES Permit and Stormwater Management Plan Report can be viewed online via the Stormwater Division webpage. Other information available on this webpage include s the Phase II Stormwater Program, the 6 Minimum Measures required for NPDES compliance and related links, Runoff Controls, and FAQ regarding th e City’s Stormwater Policy. Ordinances and other regulatory information not contained within the Stormwater webpage can be accessed via the City’s websit e or through BuildHighPoint.com. II.A.3 & II.A.5 Stormwater Plan Modifications Did DEMLR require a modification to the Stormwater Plan? No --- If yes, did the permittee complete the modifications in accordance with the established deadline? Not Applicable --- Comments (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? No --- If yes, is there a written agreement in place? Not Applicable --- Comments (List the specific control measures implemented by others that do not have adequate written agreements, if applicable) II.A.7 Written Procedures The permittee maintained written procedures for implementing the six minimum control measures. Yes --- Written procedures identified specific action steps, schedules, resources and responsibilities for implementing the six minimum measures. Yes --- MS4 Permit Self-Audit Report High Point, NC: NPDES Permit No. NCS000421 Audit Date(s): May 19, 2020 Page 6 of 18 Program Implementation, Documentation & Assessment 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. III. A Program Documentation The permittee-maintained documentation of all program components including, but not limited to, inspections, maintenance activities, educational programs, implementation of BMPs, enforcement actions etc., on file for a period of five years. Yes --- Comments (List the specific program components that do not have adequate documentation on file and why, if applicable) III.B Annual Report Submittal The permittee submit ted annual reports to the Department within twelve months from the effective date of the permit (See Section III.B. for the annual reporting period specific to this MS4). Yes --- The permittee submitted subsequent annu al reports every twelve months from the scheduled date of the first annual report submittal. Yes --- 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 schedules and plans for the year f ollowing each report. Yes --- 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 Plan (results, effectiveness, implementation schedule, etc.). Yes --- 3. Documentation of any necessary changes to programs or practices for assessment of management measures implemented through the Stormwater Plan. Yes --- 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 Stormwater Plan. Yes --- 5. An assessment of compliance with the permit, information on the establishment of appropriate legal authorities, inspections, and enforcement actions. Yes --- Comments (Note dates that annual reports cover under current permit and generally describe report deficiencies, if any) Under the current permit, annual reports were submitted for the following years: November 1, 2016 to October 31, 2017; November 1, 2017 to October 31, 2018; and November 1, 2018 to October 31, 2019 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 --- 2. A description of the effectiveness of each program component. Yes --- MS4 Permit Self-Audit Report High Point, NC: NPDES Permit No. NCS000421 Audit Date(s): May 19, 2020 Page 7 of 18 Program Implementation, Documentation & Assessment 3. Planned activities and changes for the next reporting period, for each program component or activity. Yes --- 4. Fiscal analysis. Yes --- Comments (Note dates that annual reports cover under current permit and generally describe report deficiencies, if any) Under the current permit, annual reports were submitted for the following years: November 1, 2016 to October 31, 2017; November 1, 2017 to October 31, 2018; and November 1, 2018 to October 31, 2019 MS4 Permit Self-Audit Report High Point, NC: NPDES Permit No. NCS000421 Audit Date(s): May 19, 2020 Page 8 of 18 Public Education and Outreach Staff Interviewed: (Name, Title, Role) Kelsie Burgess – Stormwater Specialist II Robert Baker – Stormwater Specialist II Permit Citation Program Requirement Status Supporting Doc No. II.B.2.a Goals and Objectives The permittee defined goals and objectives of the Local Public Education and Outreach Program based on community wide issues. Yes --- Comments (Generally describe process for establishing goals/objectives) The overall goal of the Public Education component of the Stormwater Division is to increase citizens’ awareness of stormwater, stormwater pollution, and protect ion of the water quality of our local rivers and streams. Goals of the Public Education Program include raising public awareness on the causes and impacts of stormwater pollutio n, reducing pollutants that discharge into the Stormwater conveyance system, promoting techniques used to reduce pollutants that enter the stormwater conveyance system, and reducing the amount of floatables from litter/debris. In order to meet these goals, our Public Education program has adopted objectives that include conduct ing public education at a variety of events and locations, conducting educational programming in schools, distributing materials to residents and businesses, utiliz ing a variety of m edia to promote our overall goals (newspaper, social media, billboards, etc.), collaborat ing with other City departments/divisions. These goals and objectives have been established based on historical records from IDDE incidents, employee interactions wi th the public which has demonstrated the misunderstanding of basics concepts of stormwater and stormwater pollution and prevention, and observations of trash/litter within the City of High Point. II.B.2.b Target Pollutants The permittee maintained a description of the target pollutants and/or stressors and likely sources. Yes --- Comments (List target pollutants, note any that are missing or not appropriate) Trash, sediment, household chemicals/used motor oil, lawn care products and yard debris, fecal coliform, pet waste, industria l waste and construction waste. II.B.2.c Target Audiences The permittee identified, assessed annually and updated the description of the target audiences likely to have significant storm water impacts and why they were selected. Yes --- Comments (Describe any changes made, if applicable) We focus our education and outreach based on tr ends we see throughout the year, i.e., quantitative information such as common types of illicit discharges responded to during the year and number of responses to trash/litter complaints. We also use qua litative information gathered during conversations with the public at educational booths such as complaints about neighbors not picking up after their pets or improper disposal of yard waste. MS4 Permit Self-Audit Report High Point, NC: NPDES Permit No. NCS000421 Audit Date(s): May 19, 2020 Page 9 of 18 Public Education and Outreach II.B.2.d Residential and Industrial/ Commercial Issues The permittee described issues, such as pollutants, the likely sources of those pollutants, potential impacts, and the physical attributes of stormwater runoff in their education/outreach program. Yes --- We have information available on pollutants in our handouts at public booths, displayed in various places in City Hall, on the City website, and highlighted in public talks and school programs. Our identified pollutants fall into 2 basic categories: Re sidential (lawn care, yard debris, pet waste, automotive fluids/oils, litter/dumping) and Industrial/Commercial (cooking oils from restaurants, leaking dumpsters, biproducts from industrial activities and waste/wash water from construction activities ). II.B.2.e Informational Web Site The permittee promoted and maintained an internet web site designed to convey the program’s message. Yes --- We maintain a series of pages of stormwater information on the City of High Point’s website. There are many pages that cover information such as general information defining stormwater and stormwater pollution, public education opportunities, events, and public speaking, volunteer opportunities, IDDE, flooding, the City’s Stormwater Improvement Program and more. To access the City’s Stormwater webpage, go to www.highpointnc.gov/stormwater. II.B.2.f Public Education Materials The permittee distributed stormwater educational material to appropriate target groups. Yes --- Comments (List distributed materials and quantity, message, distribution mechanism, target audience for each if not included in program documentation/annual reporting) We keep educational materials for practically all target pollutants on hand and have these materials easily accessible when opportunities to arise for distribution. We continue to develop new materials a s needed are currently working on a yard waste informational handout. We distribute information throughout the year to businesses, offices, schools, and various groups deemed appropriate for the information. For example, pet waste brochures to veterinary clinics, general stormwater information to school administration and custodial staff, and to those restaurants who have been investigated for an IDDE. Brochures containing information on fats, oils, and grease are scheduled to be delivered to restaurant owners during their annual inspection by the City’s Pretreatment Division and Stormwater will be handing this information out as we respond to issues related to restaurant activities. We distribute our general stormwater information brochures to public areas such as customer service/bill pay areas, the Public Services office, the library, community centers, and the High Point Visitor Bureau/Chamber of Commerce. II.B.2.g Hotline/Help Line The permittee promoted and maintained a stormwater hotline/helpline for the purpose of public education and outreach. Yes --- Comments (Note hotline contact information and method(s) for advertising it) The City of High Point has one Customer Service line (336-883-3111) for all issues, including Stormwater -related issues, which is advertised and easily accessible to the public. All of the Stormwater Division’s printed educational materials and most products (dog waste bags, magnets, pens, etc.) contain the customer service phone number for issues or additional information. The Customer Service phone number can be also be found on our website, bus advertisements, Stormwater Facebook Posts, and newspaper articles. MS4 Permit Self-Audit Report High Point, NC: NPDES Permit No. NCS000421 Audit Date(s): May 19, 2020 Page 10 of 18 Public Education and Outreach II.B.2.h Public Education and Outreach Program The permittee’s outreach program, including those elements implemented locally or through a cooperative agreement, included a combination of approaches designed to reach the target audiences. Yes --- For each medi a, event or activity, including those elements implemented locally or through a cooperative agreement the permittee estimated and recorded the extent of exposure. Yes --- Comments (Generally describe approaches, extent of exposure. Note any cooperating entities, agreements and scope of services, or reference comments in Section II.A.6. above.) We use a variety of approaches to reach our population , i.e., the City of High Point, Keep High Point Beautiful and Guilford Creek Week Social Media (F acebook and Instagram), for posts relating to pollution prevention, stormwater concepts and to promote special projects. These platforms can track the number of people reached by views, likes and comments. We also have our Public Information Office post stormwater-related education to the Nextdoor website. We set up an information table at many of events including an annual health fair, a variety of career fairs for elementary up to college students, High Point’s cultural festival, H igh Point University’s Earth Day Festival, our annual Public Works Day event, many events during Guilford Creek Week, a monthly table at High Point’s Public Library, monthly table at the High Point Farmer’s M arket, and any other opportunities we can find throughout the year. A t these events we use a counting clicker to keep track of the number of interactions with visitors to our table. We also set up an information table at an annual event for National Night Out hosted by our Community Development and Housing Division and at tend neighborhood meetings hosted by their division. We present school-age programs in the elementary schools and offer summer camps and daycare facilities the opportunity for field trips to our local parks with creeks where we perform creek and stormwate r educational activities. We count the number of students and adults/teachers present at these events as well. Additionally, we advertise stormwater information inside and on the outside of our High Point Transit system buses , have stormwater information flyers sent out with utility bills on an annual/semi -annual basis, and run stormwater informational ads and editorials in the local Spanish language newspaper, La Noticia. Additional Comments: NOTE: Due to the impact of the Corona Virus Pandemic on local government activities, most of our Public Education and Outreach activities had to be canceled or postponed. MS4 Permit Self-Audit Report High Point, NC: NPDES Permit No. NCS000421 Audit Date(s): May 19, 2020 Page 11 of 18 Public Involvement and Participation Staff Interviewed: (Name, Title, Role) Kelsie Burgess – Stormwater Specialist II Robert Baker – Stormwater Specialist II Permit Citation Program Requirement Status Supporting Doc No. II.C.2.a Volunteer Community Involvement Program The permittee included and promoted volunteer opportunities designed to promote ongoing citizen participation. Yes --- Comments (Note opportunities promoted and date(s) of volunteer events) The City of High Point has several volunteer opportunities: 1) Adopt-A-Stream (Any time) 2) Adopt-A-Street (Any time) 3) Stormwater Drain Marking Program (Any time) 4) High Point Big Sweep (First Saturday of October) 5) The Great American Clean Up (One Saturday in April each year) 6) Swat-A-Litterbug (NCDOT Program that the Stormwater Division and Keep High Point Beautiful promotes) 7) Winter Wipeout (Multiple weeks in February each year) 8) Summer Trash Smash (One weekend in August each year) 9) Also willing to coordinate one-time street or stream cleanups if a group cannot commit to adopting (Any time) 10) Currently, the Stormwater Division is in the process of starting a storm drain art program. A “Call for Artists” is scheduled to go out within the next sixty days. II.C.2.b Mechanism for Public Involvement The permittee provided and promoted a mechanism for public involvement that provides for input on stormwater issues and the stormwater program. No --- Comments (Note mechanism(s) for input and how promoted) II.C.2.c Hotline/Help Line The permittee promoted and maintained a hotline/helpline for the purpose of public involvement and participation. Yes --- Comments (Note hotline contact information and how it is promoted) The City of High Point has one Customer Service line (336-883-3111) for all issues, including stormwater-related issues, which is advertised and easily accessible to the public. All of the Stormwater Division’s printed educational materials and most products (dog waste bags, magnets, pens, etc.) contain the customer service phone number for issues and/or additional information. The Customer Service phone number can be also be found on our website, bus advertisements, S tormwater Facebook Posts, and newspaper articles. MS4 Permit Self-Audit Report High Point, NC: NPDES Permit No. NCS000421 Audit Date(s): May 19, 2020 Page 12 of 18 Public Involvement and Participation Additional Comments: The Customer Service line is promoted throughout City of High Point as the number to call for any issues. The Stormwater Division puts the Customer Service number on all giveaways (i.e. pens, magnets, pamphlets, brochures, volunteer opportunity cards, and tabling signage) and specifically states to call that number if they have any drainage issues, concerns, have seen IDDE issues or have stormwater related questions. NOTE: Due to the impact of the Corona Virus Pandemic on local government activities, most of our Public Involvement and Participation activ ities had to be canceled or postponed. MS4 Permit Self-Audit Report High Point, NC: NPDES Permit No. NCS000421 Audit Date(s): May 19, 2020 Page 13 of 18 Illicit Discharge Detection and Elimination (IDDE) Staff Interviewed: (Name, Title, Role) Robert Baker – Stormwater Specialist II Kelsie Burgess – Stormwater Specialist II Permit Citation Program Requirement Status Supporting Doc No. II.D.2.a IDDE Program The permittee maintained a written IDDE Program. Yes --- If yes, the written program includes provisions for program assessment and evaluation and integrating program. Yes --- Comments (Note any deficiencies) The Illicit Discharge Detection and Elimination Program Manual details our IDDE Program, which includes an SOP for dry weathe r monitoring. Also included is an Annual Update Certificate stating that the IDDE Manual has been reviewed and updated as necessary. II.D.2.b Legal Authorities The permittee maintained an IDDE ordinance or other regulatory mechanism(s) that provides the legal authority to prohibit illicit connec tions and discharges to the MS4. Yes --- If yes, the ordinance applies throughout the corporate limits of the permittee. [Permit Part I.D] Yes --- Comments The Illicit Connection and Discharge Ordinance is located in the City of High Point Code of Ordinances, Title 12 - Offenses, Chapter 3 - Public Nuisances, Sections 12-3-1(12) and (13): Conditions constituting a public nuisance. II.D.2.c Storm Sewer System Map The permittee maintained a current map showing major outfalls * and receiving streams. Yes --- Comments Stormwater structures are contained in an Outfall Monitoring layer in GIS. *Major outfalls are discharges from > 36” diameter pipes or drainage areas of > 50 acres. In areas zoned for industrial acti vity, major outfalls are > 12” or drainage area > 2 acr es. MS4 Permit Self-Audit Report High Point, NC: NPDES Permit No. NCS000421 Audit Date(s): May 19, 2020 Page 14 of 18 Illicit Discharge Detection and Elimination (IDDE) II.D.2.d Dry Weather Flow Program The permittee maintained a program for conducting dry weather flow field observations in accordance with written procedures. Yes --- Comments (Generally summarize program, including frequency of observations and # or % of outfalls screened) We currently have 1183 outfalls and have inspected 693 (58.58%) as of 4-22-2020. An SOP for Dry Weather Monitoring is part of the Illicit Discharge Detection and Elimination Program Manual. Outfalls are inspec ted on an annual basis. Any outfalls that we are unable to inspect are prioritized for the following year. This can be seen on the Stormwater Web Map application that is use d during the inspection process. Ammonia, pH, temperature and physical condition (erosion, pipe damage, floatables, turbidity, discolored water and odor, etc.) are parameters that are measured and notated during outfall inspection s and anything out of normal parameters is investigated. II.D.2.e Investigation Procedures The permittee maintained written procedures for conducting investigations o f identified illicit discharges. Yes --- Comments (Generally describe what procedures are documented) We have an SOP detailing the procedures for conducting IDDE investigations. This SOP outlines how to add and/or update IDDE records within our Accela database. We also maintain an Excel IDDE Master Tracking List of all IDDEs that have been investigated from 2006 to present. The Illicit Discharge Detection and Elimination Program Manual goes into greater detail for tracking i llicit discharges. II.D.2.f Track and Document Investigations For each case of an illicit discharge or potent ial illicit discharge, the permittee documented and tracked the following: 1. The date(s) the illicit discharge was observed Yes --- 2. The results of the investigation Yes --- 3. Any follow-up of the investigation Yes --- 4. The date the investigation was closed Yes --- Comments (Note whether a standard inspection form is utilized to capture consistent information and a tracking mechanism is used) The Stormwater Division uses a standard “Memo to File” form which enables a more detailed statement of IDDE investigations by the Stormwater Specialists. All information pertaining to the investigation of an IDDE is entered into the Accela database a nd also stored on a secured drive of the City’s network. IDDEs that require Notices of Violation to be issued also have a physical file where hard copies of the documentation are stored. All major details of an IDDE (date of incident, location, status, etc.) is also entered into the Excel IDDE Master Tracking List. MS4 Permit Self-Audit Report High Point, NC: NPDES Permit No. NCS000421 Audit Date(s): May 19, 2020 Page 15 of 18 Illicit Discharge Detection and Elimination (IDDE) II.D.2.g Employee Training The permittee implemented and documented a training program for appropriate municipal staff who, as part of their normal job responsibilities, may come into contact with or otherwise observe an illicit discharge or illicit connection. Yes --- Comments (Generally describe the staff training program, including frequency and which staff are trained) Approximately 300 city staff members are trained on an annual basis. The training covers what constitutes an IDDE and how to identify and effectively report the IDDE. NOTE: Due to the impact of the Corona Virus Pandemic on local government acti vities, employee training has been put on hold until gathering restrictions have been increased or lifted completely. II.D.2.h Public Education The permittee informed public employees of hazards associated with illegal discharges and improper disposal of waste. Yes --- The permittee informed businesses of hazards associated with illegal discharges and improper disposal of waste. Yes --- The permittee informed the general public of hazards associated with illegal discharges and improper disposal of waste. Yes --- Comments (Note how each sector was informed, if applicable) Employees are informed of the hazards of illegal dumping and discharges through City -wide training and Spring Fling. Booths are set up at these events and informational pamphlets are distributed to City employees. Education of the general public, incl uding business owners, is done by setting up informational booths at Public Service Day annual event and regularly scheduled dates and times at the Farmers Market and Public Library. The general public is also notified of educational events held at local schools. Brochures containing information on fats, oils, and grease are scheduled to be delivered to restaurant owners during their annual inspection by the City’s Pretreatment Division and Stormwater will be providing this information as we respond to re staurant- related issues. All of our educational programs and materials that we distribute to the public touch on what an illicit discharge is and how illegal discharges and improper disposal can affect our water quality and emphasize that these acts of discharging and/or disposal are illegal. II.D.2.i Public Reporting Mechanism The permittee promoted, publicized, and facilitated a reporting mechanism for the public to report illicit discharges. Yes --- The permittee promoted, publicized, and facilitated a reporting mechanism for staff to report illicit discharges. Yes --- The permittee established and implemented response procedures for citizen requests/reports. Yes --- Comments (Generally describe reporting mechanisms and how promoted/publicized/facilitated/established) The general public can report IDDE incidents by calling the City’s Customer Service line 24 hours a day. Public Services and other City staff usually contact the Stormwater Division directly to report an incident. MS4 Permit Self-Audit Report High Point, NC: NPDES Permit No. NCS000421 Audit Date(s): May 19, 2020 Page 16 of 18 Illicit Discharge Detection and Elimination (IDDE) II.D.2.j Enforcement The permittee implemented a mechanism to track the issuance of notices of violation and enforcement actions administered by the permittee. Yes --- If yes, the mechanism includes the ability to identify chronic violators for initiation of actions to reduce noncompliance. Yes --- Comments (Generally describe the established tracking mechanism, if applicable) As of 2020, IDDE data is being stored in the City’s Accela database and since 2006 in the Excel IDDE Master Tracking List . Data stored in both of these applications can be filtered, sorted, etc., by multiple parameters. MS4 Permit Self-Audit Report High Point, NC: NPDES Permit No. NCS000421 Audit Date(s): May 19, 2020 Page 17 of 18 Total Maximum Daily Loads (TMDLs) Staff Interviewed: (Name, Title, Role) Anita Simpson – Operations Analyst Program Status: ☐ The permittee is not subject to an approved TMDL (skip the rest of this section). ☒ The permittee is subject to an approved TMDL for: name of parameter(s) and date(s) approved: Waterbody Name - (ID) Impairment Date Approved East Fork Deep River Fecal Coliform, Turbidity March 2004 Rich Fork Creek Fecal Coliform April 2004 Richland Creek Fecal Coliform May 2004 There ☒ is ☐ is not a Waste Load Allocation (WLA) in the approved TMDL. Permit Citation Program Requirement Status Supporting Doc No. II.H.3 TMDLs Within 12 months of final TMDL approval, the permittee’s annual reports included a description of existing programs, controls, partnerships, projects and strategies to address impaired waters. No --- Within 12 months of final TMDL approval, the permittee’s annual reports provided a brief explanation as to how the programs, controls, partnerships, projects and strategies address impaired waters. No --- Comments The Stormwater Division’s Water Quality Monitoring Program was not finalized until 201 5. II.H.4 TMDLs Within 24 months of final TMDL approval, the permittee’s annual reports included an assessment of whether additional structural and/or non -structural BMPs are necessary to address impaired waters. No --- Within 24 months of final TMDL approval, the permittee’s annual reports included a brief explanation as to how the programs, controls, partnerships, projects and strategies address impaired waters. No --- Comments The Stormwater Division’s Water Quality Monitoring Program was not finalized until 2015. MS4 Permit Self-Audit Report High Point, NC: NPDES Permit No. NCS000421 Audit Date(s): May 19, 2020 Page 18 of 18 Total Maximum Daily Loads (TMDLs) II.H.5 TMDLs Within 36 months of final TMDL approval, the permittee’s annual reports included a description of activities expected to occur and when activities are expected to occur. No --- Comments The Stormwater Services Division finalized its Water Quality Monitoring Plan in 2015 to address TMDL requirements for the following streams: Richland Creek and East Fork of the Deep River. Maps were created identifying the watersheds, streams, and corresponding outfalls that discharge into impaired streams with designated TMDLs. The Stormwater Division identified existing water quality data and created a monitoring plan for the Fecal Coliform TMDL that is currently in place for Richland Creek. The Stormwater Division has selected site locations for sampling and confirmed those sites using GPS equipment in the field . Our quarterly schedule for collecting samples at all 12 locations complies with the EPA standards (five samples examined during a 30 - day period). The City’s Water Treatment Plant has a certified lab which processes our TMDL samples throughout the year. NOTE: Due to the impact of the Corona Virus Pandemic on local government activities, our Spring 2020 TMDL sampling did not occur. II.H.6 TMDLs If there is no Waste Load Allocation in the approved TMDL, the permittee evaluated strategies and tailored and/or expanded BMPs within the scope of the six minimum measures to enhance water quality recovery strategies in the watershed(s) to which the TMDL applies. Not Applicable --- The permittee described strategies and tailored and/or expanded BMPs in their Stormwater Management Plan and annual reports Not Applicable --- Comments MS4 Permit Self-Audit Report High Point, NC: NPDES Permit No. NCS000421 Audit Date(s): May 19, 2020 APPENDIX A: SUPPORTING DOCUMENTS General Stormwater Information-Inside Page STORM WATER Defined by the Environmental : -· z . Protection Agency as: Rainwater and melted snow that runs off streets, lawns, farms, construction, and indmtrial sites and into . surface water. Surface Water •Streams •Lakes •Rivers •Ponds •Refers to any natural or man-made body of water When water flows over land, it collects pollutants and carries them into our waterways. Even if your house is not near a stream or lake, the runoff can flow down the street, into a ditch, storm drain, and eventually empty into a body of water, along with the pollutants collected during the runoff. By making wise decisions in our communities, we can prevent pollutants from reaching our lakes, rivers, and streams. Read on to find out howl TYPES OF POLLUTION Pet Waste •Be sure to fully and immediately clean up after pets on any public property (streets, sidewalks, right of ways, storm drains, creeks, etc.). - -'I •Carry a clean-up device (bag or scooper) when taking a pet on a walk. ,. •Dispose of pet waste in a closed trash receptacle or refuse container. Effects: Pet waste can be a serious water quality and pub- lic health issue. Stormwater runoff can carry bacteria, para- sites, viruses, and nutrients direct.ly into local waterways. Yard Waste • Do not rake, sweep, blow, or place any debris into the storm drainage system (catch basins, grate inlets, etc.). ,,..,._....,. .'II, ...... - _1"'< .• · ..... - -- . ::T,.• •.. --·,- •Property owners should keep all ditches, drains, swales, 1 ... l; -; :.; : - 1j P,. } : - and other drainage ways on their property free from obstructions, which can impede the flow of water. Effects: Debris can be defined as any yard waste (grass, clippings, leaves, pine straw, etc.), sediment, trash, litter, etc. Debris can cause significant water quality and infra- structural problems when it is directed into the storm drainage system. Sediment This is the Ill pollutant of water in the country! This can be caused by building and construction activities that remove the plants that keep the soil in place. .. ;.., 1., ..... ;r .... _j .J;· ·· . :., X'I --.. ,: - - '._" ;. - · . i1Gi:. B . . . :: ,.,_· ·_ .. e 1 • I "'iJ'I . r;·' .,,:,'r_ • • .i . TYPES OF POLLUTION Effects: Excessive sediment blocks sunlight needed by aquatic plants and animals, increases water temperature, and impairs feeding, vision, and breathing capabilities of these animals . Pesticides & Fertilizers •Use fertilizer and pesticides sparingly. •Keep fertilizer off paved surfaces. Sweep it back into the grass if it spreads to pavement. •Do not fertilize before a rainstorm. This could wash ma- terial into storm drains. Effects: Improper use of chemi- cals can impair water quality when it runs off into surface water. Te st your soil to determine lawn nutrient needs. Test kits are available through your county's cooperative extension office. Fats, Oils & Grease IFOG) •Generated from kitchens, vehicles, and machinery. •When fats, oils, and grease get into the sewer or storm system, they stick to the inside of pipes. Over time, FOG will build up in the pipe and create a blockage, which can cause an overflow. •Dispose of FOG in the trash or a designated container. •Do not dump FOG down a sink or drain. [Jlliil . -.. ,., .. >: .. Effects: The untreated sewage from an overflow can pollute our waters with bacteria, nutrients, and many other water quality contaminants. Restaurant Targeted Pamphlet -Inside Page Stormwater: What is it? Stormwater is defined by the United States Environmental Protection Agency as: Rainwater and melted snow that runs off streets, lawns, farms, construction, and industrial sites and into surface water. Surface Water Streams lakes Rivers Ponds Any natural or man-made body of water Stormwater pipes and ditches do not go to a facility that treats the water. Instead, they connect to other pipes that eventually empty directly into a stream, river, or lake. Any pollutants picked up along the way are deposited into that body of water. Stormwater pipes transfer water from the street directly into streams. Restaurant Related Pollutants •litter from outdoor areas •Trash and debris from overfilled, leaking or damaged dumpsters •Grease from spills/leaks or wash water from outdoor cleaning Best Management Practices Any practice that prevents or reduces pollution is a Best Management Practice (BMP). There are several BMPs that restaurants can employ to lower their stormwater pollution impact and comply with city ordinances. Outdoor Areas •Do not hose parking lots or sidewalks. Sweep these areas instead. •Prevent trash, cigarettes, chemicals, and other debris from getting into our waterways by keeping parking Jots, waste storage areas, and other outside areas clean. •Routinely check oil and grease containers for leaks and always make sure they are closed tightly. Never pour grease down a storm drain. •Replace rusted or damaged dumpsters. •Keep lids closed on dumpsters to prevent rainwater from washing trash from any holes or cracks. Washing and Cleaning •Never clean floor mats, garbage cans, etc. outside. Clean all equipment in an appropriate indoor area such as a mop basin or utility sink. •Do not dump mop water outside. Dispose of all wastewater in a mop basin, utility sink or sanitary sewer. Good Housekeeping •Make sure oil and grease containers are emptied regularly. •Properly dispose of toxic materials such as cleaners, solvents, and detergents. Spills and leaks •If you do not have one already, make or buy a spill kit. •If a spill does occur, it is important to remember to never hose down a spill. •Only use dry cleanup methods. If washing a dumpster, loading dock, or another outdoor surface is necessary, you must block the flow of water from entering the storm drain. Collect all wastewater and dispose of it in a mop basin or utility sink. •Post spill response information in a common employee area. Make sure employees know where spill kits are and · who to alert if a major spill occurs. •If a hazardous spill occurs, call 911. The Fire Department is the first line of defense and is trained and equipped to handle these types of situations. Employee Training •During the training we talk about what stormwater is and where leaves the facility. •We discuss where spill kits are located and how to use them. •We use this opportunity to discuss the most recent inspection. Employee Training •We have 3 DVD's and 3 presentations that we use for employee training. •The DVD's all have a quiz that goes along with it, which can be useful to reiterate certain points. •We purchased the DVD’s from Excal Visual. •The presentations are between 12 and 25 slides and are mostly made up of pictures that we have taken around the city or at facilities to illustrate the importance of proper pollution prevention and good house keeping. Employee Training Handouts MS4 Permit Self-Audit Report High Point, NC: NPDES Permit No. NCS000421 Audit Date(s): May 19, 2020 APPENDIX B: PHOTOGRAPH LOG (NONE)