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Home My WebLink AboutNCS000450_CARBORRO MS4 AUDIT REPORT_20201029MUNICIPAL, SEPARATE STORM SEWER SYSTEM (MS4) PROGRAM AUDIT REPORT NPDES PERMIT NO. NCS000450 CARRBORO, NORTH CAROLINA 301 West Main Street Carrboro, North Carolina 27510 Audit Date: August 12, 2020 Report Date: October 29, 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 (This page intentionally left blank) NCS000450-Town of Carrboro MS4 Audit_20190812 TABLE OF CONTENTS AuditDetails ........................................................................................................................ ...... 1 PermitteeInformation... ........... ............................................... . ...................................................... 2 Listof Supporting Documents................................................................................. .. . .................... 3 Program Implementation, Documentation & Assessment ... .. ................................................... . . 5 Illicit: Discharge Detection and Elimination (IDDE) ................................................................................... S Post -Construction Site Runoff Controls .......................... ........ ........................................... .. ... ... it Pollut n Preventiori a nd Goad Housekeeping for Municipal 0WaWns.................................................13 Site Visit Evaluation: Municipal Fadli•ty No. 1 . .. ...................................................... .......................16 Site Visit Evaluation.* M$4 OutlialI No. 1......................... ...................................................... .. .....18 Site Visit Evaluation: Post -Construction Stormwater Control Measure No,1........................................... 20 Appendix A. Supporting Documents 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. NCS000450 Town of Carrboro MS4 Audit 20190812 ii This page intentionally left blank NCS000450 Town of Carrboro MS4 Audit�20190812 iii Audit Details Audit ID Number: Audit Date(s): NCS000450 Carrboro MS4 Audit_20200812 August 12, 2020 Minimum Control Measures Evaluated: Program Implementation, Documentation & Assessment Public Education & Outreach Public Involvement & Participation x Illicit Discharge Detection & Elimination Construction Site Runoff Controls — No delegated Sediment and Erosion Control Program Construction Site Runoff Controls — Delegated Sediment and Erosion Control Program Post -Construction Site Runoff Controls J Pollution Prevention and Good Housekeeping for Municipal Operations 7 Total Maximum Daily Loads (TMDLs) Field Site Visits: ❑ Municipal Facilities. Number visited: Choose an item. ❑ MS4 Outfalls. Number visited: Choose an item. ❑ Construction Sites. Number visited: Choose an item. ❑ Post -Construction Stormwater Runoff Controls. Number visited: Choose an item. ❑ Other: Number visited: Choose an item. ❑ Other: Number visited: Choose an item. Inspector(s) Conducting Audit Name, Title Orsanizatian Thad Valentine, Senior Environmental Specialist NCDEQ NCDEQ NCDEQ Lauren Garcia, Environmental Specialist Natalie Norberg, Environmental Specialist Audit Report Author: Date: l f 1/�L �� 5iynature�� y"r�- r� / / � a"(�fir/ Audit Repo uthor: Date to lao Signatur a'q Audit Repa Author: Date , r I l�/Zq �JSignature v Li� NCS000450—Town of Carrboro MS4 Audit�20200812 Page 1 of 22 Permittee Information MS4 Permittee Name: Permit Effective Date: Permit Expiration Date: Town of Carrboro February 20, 2017 February 19, 2022 Mailing Address: Date of Last MS4 Inspection/Audit: 301 West Main Street, Carrboro, NC 27510 N/A Co-permittee(s), if applicable: Permit Owner of Record: Randy Dodd Primary MS4 Representatives Participating in Audit Names Title Oreanization Randy Dodd, Stormwater Utility Manager Town of Carrboro Heather Holley, Stormwater Specialist Town of Carrboro MS4 Receiving Waters WaterbodY Classification Impairments Bolin Creek (in/upstream of Carolina North Forest) C, NSW Impacts from low/medium density development Bolin Creek (downstream of Carolina North Forest) C, NSW Ecological/biological integrity•benthos WS-II, HQW, Some agricultural impacts, possible impacts from Morgan Creek (above University Lake} NSW quarry, low density development Some agricultural impacts, low density Morgan Creek (University Lake) WS-II, HQW, development; listed in 2014 Integrated Report NSW, CA for chlorophyll-a/nutrient impairment Urban runoff; listed in 2014 Integrated Report Morgan Creek (below University Lake) C, NSW for 20 parameters of interest for phosphorous, total nitrogen, chlorophyll -a, fish tissue mercury. NCS000450, Town of Carrboro MS4 Audit�20200812 Page 2 of 22 List of Supporting Documents Item Number Document Title When Provided (Prior to/During/After) 1 Stormwater Utility Town Code Prior to 2 2020 Rate Change Resolution Prior to 3 Stormwater Utility Rate Study Prior to 4 2018 Stormwater Plan Prior to 5 MS4 Program Overview Prior to 6 Stormwater Service Delivery Prior to 7 2020 IDDE Program Plan Prior to 8 MS4 O&M Plan Prior to 9 SCM O&M Plan Prior to 10 Town of Carrboro Land Use Ordinance During 11 IDDE Tracking Spreadsheet Prior to 12 2019 NPDES Annual Report Prior to 13 Carrboro Stormwater Map Prior to 14 NCCES Training PPGH and IDDE Prior to 15 Directional Boring BMPs Flyer Prior to 16 Stormwater Hotline Poster Prior to 17 Stormwater Reporting Business Card Prior to 18 Private Stormwater Cleaning Guidelines Prior to 19 Carrboro Town Properties After 20 SCM Inventory Prior to 21 Staff Stormwater Training PowerPoint Prior to NCS000450,Town of Carrboro MS4 AuditR20200812 Page 3 of 22 0*x 23 24 25 26 Pesticide License Contractor License Clean Water Education Partnership Annual Report Street Sweeping Tracking Sheets Equipment Cleaning After After During After After NCS000450_Town of Carrhoro MS4 AuditT20200812 Page 4 of 22 Program Implementation, Documentation & Assessment Staff Interviewed: Randy Dodd, Stormwater Utility Manager (Name, Title, Role) Heather Holley, Stormwater Specialist Joe Guckavan, Public Works Director Kristen Benoit, Assistant to Public Works Director Daniel Snipes, Public Works Superintendent Lakisha Kelly, Public Works Administrative Assistant Permit Citation Program Requirement Status Supporting Doc No. II.A.1 The permittee maintained adequate funding and staffing to implement and manage Staffing and the provisions of the Stormwater Plan and meet all requirements of the permit. Yes 1, 2, 3 Funding The Stormwater Plan identifies a specific position(s) responsible for the overall coordination, implementation, and revision to the Plan. Yes 4 Responsibilities for all components of the Stormwater Plan are documented and position(s) assignments provided. Yes 4 The permittee is current on payment of invoiced administering and compliance monitoring fees (see stormwater e-payments on DEMLR MS4 web page). Yes --- Comments Funding for the Town's Stormwater Program comes from the Stormwater Enterprise Fund. As of 2020, the Town has approximately one million dollars in funding. The Town currently has 2 full time Stormwater employees and are hiring a third full time Stormwater administrator as of August 2020. IIII.An2 Stormwater The permittee evaluated the performance and effectiveness of the program components at least annually. Yes 5 Implementation If yes, the permittee used the results of the evaluation to modify the program and Evaluation components as necessary to accomplish the intent of the Stormwater Program. Yes 6 Did the permitted M54 discharges cause or contribute to non -attainment of an applicable water quality standard? No — If yes, did the permittee expand or better tailor its BMPs accordingly to address Not the non -attainment? Applicable �- Comments The Program Overview documentation addresses the performance and effectiveness of the program. The Permittee provides service expansion options for their Stormwater Program. II.A.3 Keeping the The permittee kept the Stormwater Plan up to date. Yes --- Stormwater Plan Up to Date ha nermitteenotifted-DEMLi-of-an"ndates to the-Starmvaatec.Qla Not --- Applicable NCS000450_Town of Carrboro MS4 Audit_20200812 Page 5 of 22 Program Implementation, Documentation & Assessment Comments The permittee last updated their Stormwater Plan in 2018. II.A.4 Availability The permittee kept an up-to-date version of its Stormwater Plan available to the of the Stormwater Division and the public online. No --- Plan The online materials included ordinances, or other regulatory mechanisms, or a list identifying the ordinances, or other regulatory mechanisms, providing the legal Yes 10 authority necessary to implement and enforce the requirements of the permit. Comments The Permittee did not have an up-to-date version of the Stormwater Plan. The Permittee does provide the land use ordinance online for the public. II.A.3 & II.A.S Stormwater Plan Did DEMLR require a modification to the Stormwater Plan? No --- Modifications If yes, did the permittee complete the modifications in accordance with the Not established deadline? Applicable �- Comments 11.A.6 Sharing Responsibility Are any control measures implemented by an entity other than the permittee? Yes 24 If yes, is there a written agreement in place? No — Comments Orange County implements the Construction Site inspections. However, the Permittee does not have an up-to-date ordinance and resolution that allows Orange County to perform their duty. Clean Water Education Partnership conducts their public outreach and education measures. II.A.7 The permittee maintained written procedures for implementing the six minimum Yes 718,9 Written control measures. Procedures Written procedures identified specific action steps, schedules, resources and Partial 7, 8, 9 responsibilities for implementing the six minimum measures. Comments Although the documents were provided, the documents were not finalized and were in draft form. III. A The permittee maintained documentation of all program components including, but Program not limited to, inspections, maintenance activities, educational programs, Partial 11 Documentation implementation of BMPs, enforcement actions etc., on file for a period of five years. Comments The Permittee has not documented all program components. NCS000450—Town of Carrboro MS4 Audit�20200812 Page 6 of 22 Program Implementation, Documentation & Assessment 111.8 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 Partial 12 submittal period specific to this M54). The permittee submitted subsequent annual reports every twelve months from the scheduled date of the first annual report submittal. Partial 12 The Annual Reports included appropriate information to accurately describe the progress, status, and results of the permittee's Stormwater Plan, including, but not,limited the following: 1. A detailed description of the status of implementation of the Stormwater Plan as a whole. This will include information on development and implementation Not of each major component of the Stormwater Plan for the past year and Applicable schedules and plans for the year following each report. 2. An adequate description and justification of any proposed changes to the Stormwater Plan. This will include descriptions and supporting information for Not the proposed changes and how these changes will impact the Stormwater Applicable _ Plan (results, effectiveness, implementation schedule, etc.). I Documentation of any necessary changes to programs or practices for assessment of management measures implemented through the Stormwater Not Applicable Plan. 4. A summary of data accumulated as part of the Stormwater Plan throughout the year along with an assessment of what the data indicates in light of the Not Applicable ___ Stormwater Plan. 5. An assessment of compliance with the permit, information on the establishment of appropriate legal authorities, inspections, and enforcement Not Applicable actions. Comments The permittee submitted annual reports for 2017 and 2019. The 2018 annual report was not found in DEQ's database. As per Part 4b3 of their permit, submitting the annual report through RIMS satisfies the annual reporting requirements. IV.B Annual Reporting The Annual Reports document the following: 1. A summary of past year activities, including where applicable, specific Not quantities achieved and summaries of enforcement actions. Applicable -' 2. A description of the effectiveness of each program component. Not Applicable — 3. Planned activities and changes for the next reporting period, for each Not program component or activity. Applicable 4, FISCdI analysis. Not Applicable Comrnent5 As per Part 03 of their permit, submitting the annual report through RIMS satisfies the annual reporting requirements. NCS0004S0_Town of Carrboro M54 Audit_20200812 Page 7 of 22 Illicit Discharge Detection and Elimination (IDDE) Staff Interviewed: Randy Dodd, Stormwater Utility Manager (Name, Title, Heather Halley, Stormwater Specialist Role) Joe Guckavan, Public Works Director Kristen Benoit, Assistant to Public Works Director Daniel Snipes, Public Works Superintendent Lakisha Kelly, Public Works Administrative Assistant Trish McGuire, Planning Director Permit Citation Program Requirement Status supporting Roc No. Il.D.2.a IDDE Program The permittee maintained a written IDDE Program. Yes 7 If yes, the written program includes provisions for program assessment and evaluation and integrating program. No --- Comments A IDDE program was provided , but it appeared to be a generic outline that lacked any type of assessment and evaluation guidance for reporting and documenting, which is required as part of the IDDE program The permittee maintained an IDDE ordinance or other regulatory mechanism(s) that II.D.2.b provides the legal authority to prohibit illicit connections and discharges to the MS4. No -- if yes, the ordinance applies throughout the corporate limits of the permittee. Not Legal Authorities [Permit Part I.D] Applicable Comments The Permittee's reference the Town Code, Article IV in section 5 II.D.2.c The permittee maintained a current map showing major outfalls" and receiving Storm Sewer Yes 13 System Map streams. Comments The map shows the major outfalls and streams. II.D.2.d The permittee maintained a program for conducting dry weather flow field Dry Weather Flow observations in accordance with written procedures. No --- Program Comments The Permittee needs to fully implement the dry weather field and observation maintenance plan. II.D.2.e The permittee maintained written procedures for conducting investigations of Investigation identified illicit discharges. No -- Procedures Comments — Detailed procedures for conducting illicit discharge from reporting, investigation to its completion, which includes documenting the outcome and disposal, if needed, of any illicit materials was not provided. All parties involved should be identified and manifest should be available NCS000450—Town of Carrboro MS4 Audit�20200812 Page 8 of 22 Illicit Discharge Detection and Elimination (IDDE) II.D.2.f For each case of an illicit discharge or potential illicit discharge, the permittee documented and tracked the Track and following: Document Investigations 1. The dates) the illicit discharge was observed Yes 11 2. The results of the investigation Partial 11 3. Any follow-up of the investigation No --- 4. The date the investigation was closed No --- Comments Although the Permittee has documented the illicit discharge incidents, they did not thoroughly document the investigation and conclusions. II__.D.2.e Employee The permittee implemented and documented a training program for ap propriate municipal staff who, as part of their normal job responsibilities, may come into No --- contact with or otherwise observe an illicit discharge or illicit connection. Comments The Permittee provided training information. However, the Permittee does not have documented training records. II.D.2.h The permittee informed public employees of hazards associated with illegal Public Education discharges and improper disposal of waste. Yes 14 The permittee informed businesses of hazards associated with illegal discharges and 15, 16, improper disposal of waste. Partial 17,18 The permittee informed the general public of hazards associated with illegal 15, 16, discharges and improper disposal of waste. Partial 17,18 Comments Although the Town of Carrboro posted information on their website related to illegal discharge hazards, they do not distribute educational material to the public. NCS000450_Town of Carrboro MS4 Audit_20200812 Page 9 of 22 Illicit Discharge Detection and Elimination (IDDE) ll.D.2.i Public Reporting Mechanism The permittee promoted, publicized, and facilitated a reporting mechanism for the public to report illicit discharges. Yes Online The permittee promoted, publicized, and facilitated a reporting mechanism for staff to report illicit discharges. Partial The permittee established and implemented response procedures for citizen requests/reports. No Comments The public is encouraged to report illicit discharges through the Permittee's website, but the program lacks written procedures for staff that includes schedules, forms for reporting and tracking the illicit discharge from the release through to the cleanup and disposal. Provide written procedures for citizen requests/reports. II.D.2.1 Enforcement The permittee implemented a mechanism to track the issuance of notices of violation and enforcement actions administered by the permittee. No If yes, the mechanism includes the ability to identify chronic violators for Not initiation of actions to reduce noncompliance. Applicable --- Comments Develop a tracking system for notices of violation and enforcement actions. NCS000450 jown of Carrboro MS4 Audit_20200812 Page 10 of 22 Post -Construction Site Runoff Controls Staff Interviewed: Randy Dodd, Stormwater Utility Manager (Name, Title, Role) Heather Holley, Stormwater Specialist Josh Dalton, Sungate Engineering Marty Roupe, Development Review Administrator Patricia McGuire, Planning Director Joseph Guckavan, Public Works Director Lakisha Kelly, Public Works Administrative Assistant Kristen Benoit, Assistant to Public Works Director Implementation (check all that apply): — The permittee implements the components of this minimum measure. ❑ The permittee relies upon another entity to implement the components of this minimum measure: ® 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-I) — 15A NCAC 28 .0212 ® Water Supply Watershed II (WS-11) —15A NCAC 213.0214 ❑ Water Supply Watershed III (WS-111) —15A NCAC 28,0215 ® Water Supply Watershed IV (WS-IV) —15A NCAC 2B .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 213.0258 ❑ Randleman Lake Water Supply Watershed Nutrient Management Strategy —15A NCAC 28.0251 ❑ 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): ❑ DEQ model ordinance ❑ M54 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 M54s 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. NCS000450—Town of Carrboro MS4 Audit_20200812 Page 11 of 22 Post -Construction Site Runoff Controls Session Law 2006- supporting 246 Program Requirement Status Doc No. Deemed -Compliant The permittee implements deemed -compliant Program requirements in Program(s) accordance with the applicable 15A NCAC rules. Yes 10 NC5000450—Town of Carrboro MS4 Audit�20200812 Page 12 of 22 Pollution Prevention and Good Housekeeping for Municipal Operations Staff Interviewed: Randy Dodd, Stormwater Manager (Name, Title, Role) Heather Holley, Stormwater Specialist Josh Dalton, Sungate Engineering Marty Roupe, Development Review Administrator Patricia McGuire, Planning Director Joseph Guckavan, Public Works Director Lakisha Kelly, Public Works Administrative Assistant Kristen Benoit, Assistant to Public Works Director Mike Thompson, Engineering Inspector 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 19 stormwater runoff. Comments The Town has 6 facilities with the potential for generating polluted stormwater runoff. Il.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 Partial 9 Maintenance (O&M) stormwater runoff. for Facilities If yes, the O&M program specifies the frequency of inspections. Not Applicable If yes, the O&M program specifies the frequency of routine maintenance Not requirements. Applicable If yes, the permittee evaluated the O&M program annually and updated it as Not necessary. Applicable Comments Although a draft O&M plan was provided, the town needs to implement site -specific plans for each facility with the potential for generating polluted stormwater runoff. The O&M plans should specify the type of pollutant(s) generated. II.G.2.c Spill Response The permittee had written spill response procedures for municipal operations. No --- Procedures Comments The permittee did not provide written procedures for spill response for any of the town's operations. 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 25,22 Parking Lots corporate limits annually. Maintenance If yes, the permittee evaluated the effectiveness of existing and new BMPs based on cost and the estimated quantity of pollutants removed. Partial 25 NCS000450 Town of Carrboro MS4 Audit_20200812 Page 13 of 22 Pollution Prevention and Good Housekeeping for Municipal Operations Comments The Town provided a schedule that shows the number of miles of streets that were swept over the last 15 years with a schedule for sweeping. They maintain dump tickets to track the tonnage disposed and use all the information for review at the end of the year for effectiveness. The Town should formally evaluate and document the effectiveness of their BMPs. 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 Partial 8 Basins and maintains. Conveyance Systems Comments (Briefly describe O&M program) The permittee has a draft 0&M plan. 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 20 Stormwater Controls construction ordinance. Comments (Describe inventory information and number of controls in Inventory) The permittee provided a spreadsheet that listed the municipally -owned and operated SCMs. II.G.2.h The permittee maintained and implemented an O&M program for municipally - O&M for Structural owned or maintained structural stormwater controls installed for compliance with No --- stormwater Controls the permittee's post -construction ordinance. If yes, then: The 0&M program specified the frequency of inspections and routine Not maintenance requirements. Applicable �- The permittee documented inspections of all municipally -owned or maintained Not structural stormwater controls. Applicable --- The permittee inspected all municipally -owned or maintained structural Not stormwater controls in accordance with the schedule developed by permittee. Applicable �- The permittee maintained all municipally -owned or maintained structural Not stormwater controls in accordance with the schedule developed by permittee. Applicable �- The permittee documented maintenance of all municipally -owned or Not maintained structural stormwater controls. Applicable --- Comments The permittee has a draft O&M plan. However, it is not site -specific. The Town should develop individual O&M plans for each SCM that should contain all the requirements for that program. II.G.2.1 The permittee ensured municipal employees are properly trained in pesticide, Yes 22 Pesticide, Herbicide herbicide and fertilizer application management. and Ili Application The permittee ensured contractors are properly trained in pesticide, herbicide and Yes 23 Management fertilizer application management. NCS000450 Town of Carrboro MS4 Audit�20200812 Page 14 of 22 Pollution Prevention and Good Housekeeping for Municipal Operations The permittee ensured all permits, certifications, and other measures for applicators are followed. No --- Comments Provided copies of the pesticide certificates and Algae pond contractor license, but a checklist and inspection procedures were not developed for subcontractor pesticide application. II.G.2.j The permittee implemented an employee trainin p pg program for employees involved Staff Training in implementing pollution prevention and good housekeeping practices. Yes 21 Comments The Town provides PowerPoint training on pollution prevention and good housekeeping. The Town should document employee training with a sign -off training for each employee trained. 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 26 Equipment Cleaning cleaning. Comments The permittee has a wash station which water drains from into oil/water separator. The oil/water separator is maintained and pumped out by third party contractor on a quarterly basis NCS000450 Town of Carrboro M54 Audit 20200812 Page 15 of 22 Site Visit Evaluation: Municipal Facility No.1 Facility Name: Date and Time of Site Visit: Public Works Building August 12, 2020 1:00 PM Facility Address: Facility Type (Vehicle Maintenance, Landscaping, etc.): 100 Public Works Drive Vehicle Maintenance Name of M54 inspector(s) evaluated: Most Recent MS4 Inspection (List date and name of inspector): Randy Dodd None performed and documented by MS4 inspector Heather Holley Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit: Name Title Randy Dodd Stormwater Utility Manager Heather Holley Stormwater Specialist Observations Facility Documentation/Training Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific? No, the facility does not have an MS4 facility -specific SWPPP. What type of stormwater training do facility employees receive? How often? Pollution Prevention and IDDE Training from the NCGO8 Environmental Consultant Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? NC State Certifications and State Certifications Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? No - The MS4 inspectors were not aware that the site should be inspected by the MS4 inspector and were using the consultant for the NCGO8 permit to perform their inspections. Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping? No -- areas of the site that are integral in performing an MS4 inspection were only viewed at the MS4 auditor's prompting. Inspection Procedures Does the M54 inspector's process include the use of a checklist or other standardized form? The Environmental Consultant that oversees the NCG08 performed the inspection. The NCGO8 inspection report has a checklist. Does the MS4 inspector's process include taking photos? The Environmental Consultant took photos. Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)? The Environmental Consultant reviewed the SWPPP. NCS000450-Town of Carrboro MS4 Audit�20200812 Page 16 of 22 Site Visit Evaluation: Municipal Facility No.1 Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge? The MS4 inspectors walk the site with the NCG08 Environmental Consultant. Did the MS4 inspector miss any obvious areas of concern? If so, explain: An official MS4 inspection has never bene performed at the facility. The Environmental Consultant performs an inspection for the NCG08 permit assigned to the facility. The inspector had to be prompted to look in the vehicle storage sheds, maintenance shop, and the used oil tank. Multiple spills from the used oil tank were observed. Oil stains from continuous spillage were observed in vehicle storage areas. 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)? Corrective actions were requested for the staining around the used oil tank. If compliance corrective actions were identified, what timeline for correction/follow-up was provided? Immediately. Notes/Comments/Recommendations NCS000450-Town of Carrboro MS4 Audit�20200812 Page 17 of 22 Site Visit Evaluation: MS4 Outfall No. 1 Outfall ID Number: Date and Time of Site Visit: OET-1118 August 12, 2020 3:00 PM Outfall Location: Outfall Description (Pipe Material/Diameter, Culvert, etc.): Starlite Drive 18-inch concrete Receiving Water: Is Flow Present? If So, Describe (Color, Approximate Flow Rate, Tanbark Branch Sheen, Odor, Floatables/Debris, etc.): No Most Recent Outfall Inspection/Screening (Date): 2013 Days Since Last Rainfall: Inches: 2 days 2 Name of MS4 Inspector(s) evaluated: Randy Dodd Heather Holley Observations Inspector Training/Knowledge What type of stormwater training does the M54 inspector receive? How often? The MS4 inspectors receive training from NC State and Cooperative Extension. Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations? Yes Inspection Procedures Does the inspector's process include the use of a checklist or other standardized form? Yes Does the inspector's process include taking photos? Yes Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? if so, what were they? No NCS000450jown of Carrboro MS4 Audit�20200812 Page 18 of 22 Site Visit Evaluation: MS4 Outfall No. 1 Inspection Results Did the outfall inspection result in any work orders or maintenance requests? If so, for what issue(s)? No Will a follow-up outfall inspection be conducted? if so, for what reason? No Notes/Comments/Recommendations NC5000450_Town of Carrboro MS4 Audit�20200812 ~ Page 19 of 22 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1 Site Name: Date and Time of Site Visit: Baldwin Park August 12, 2020 2:35 PM Site Address: SCM Type: 346 Broad Street Bioretention Pond Carrboro, NC 27510 Most Recent MS4 Inspection (Include Date and Entity): Name of MS4 Inspector(s) evaluated: Most Recent MS4 Enforcement Activity (Include Date): Randy Dodd Heather Holley Name(s) and Title(s) of Site Representative(s) Present During the Site Visit: Name Title Mike Thompson observations Site Documentation Does the site have an operation and maintenance plan? No Does the site have records of annual inspections? Are they performed by a qualified individual? Yes — annual inspections are performed by a qualified individual Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Yes — the MS4 inspector is trained by the State and by NC State for plan review and maintenance. Did the M54 inspector appear knowledgeable about MS4 requirements for post -construction site runoff controls? Yes Did the MS4 inspector appear knowledgeable about post -construction BMPs (general purpose/function, components, 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, they used an !Pad to complete a mobile checklist. Does the MS4 inspector's process include taking photos? Yes NCS000450_Town of Carrboro M54 AuditT20200812 Page 20 of 22 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. I Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections? Yes Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge? Yes Did the MS4 inspector miss any obvious operation and maintenance deficiencies? If so, explain: No Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing? Yes — the inspection findings are available in the Town's share drive. Compliance/Enforcement What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in? None If compliance issues were identified, what timeline for correction/follow-up was provided? No compliance issues identified. Notes/Comments/Recommendations NC5000450—Town of Carrboro MS4 Audit20200812 Page 21 of 22 APPENDIX A: SUPPORTING DOCUMENTS All supporting documents can be found in the publicly accessible Laserfiche portal. NC5000450 Town of Carrboro M54 Audit�20200812 Page 22 of 22