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Home My WebLink AboutNCS000394_CAROLINA BEACH MS4 AUDIT REPORT_20201218MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) PROGRAM AUDIT REPORT NPDES PERMIT NO. NCS000394 Carolina Beach, North Carolina 1121 N Lake Park Blvd. Audit Date: December 2, 2020 Report Date: December 18, 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) NCS000394_Carolina Beach MS4 Audit_20201202 TABLE OF CONTENTS AuditDetails..................................................................................................................................................1 PermitteeInformation..................................................................................................................................2 List of Supporting Documents.......................................................................................................................3 Program Implementation, Documentation & Assessment...........................................................................4 Illicit Discharge Detection and Elimination (IDDE)........................................................................................8 Post -Construction Site Runoff Controls......................................................................................................11 Pollution Prevention and Good Housekeeping for Municipal Operations.................................................16 Site Visit Evaluation: Municipal Facility No. 1.............................................................................................19 Site Visit Evaluation: MS4 Outfall No. 1......................................................................................................21 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1............................................23 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. NCS000394 Carolina Beach MS4 Audit 20201202 This page intentionally left blank NCS000394_Carolina Beach MS4 Audit_20201202 Audit Details Audit ID Number: Audit Date(s): NCS000394_Carolina Beach M54 Audit 20201202 December 2, 2020 Minimum Control Measures Evaluated: ® Program Implementation, Documentation & Assessment ❑ Public Education & Outreach ❑ Public Involvement & Participation M 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 ® Pollution Prevention and Good Housekeeping for Municipal Operations ❑ Total Maximum Daily Loads (TMDLs) Field Site Visits: ® Municipal Facilities. Number visited: 1 ® MS4 Outfalls. Number visited: 1 ❑ Construction Sites. Number visited: Choose an item. ® Post -Construction Stormwater Runoff Controls. Number visited:1 ❑ Other: Number visited: Choose an item. ❑ Other: Number visited: Choose an item. Inspector(s) Conducting Audit Name, Title AMankgIon Alaina Morman, Environmental Specialist DEQ DEMLR Audit ReportAuthor: Date: ^�,� Signature l l X/A Aw r / "l o-r � AilA �1 O fa - NC5000394_Carolina Beach MS4 Audit_20201202 Page 1 of 25 Permittee Information MS4 Permittee Name: Town of Carolina Beach Permit Effective Date: February 20, 2017 Permit Expiration Date: February 19, 2022 Mailing Address: 1121 N Lake Park Blvd. Carolina Beach, North Carolina 28428 Date of last M54Inspection/Audit: April 12, 2011 Co-permittee(s), if applicable: N/A Permit Owner of Record: Bruce Oakley, Town Manager Primary M54 Representatives Participating in Audit Name, Title Organization Brian Stanberry, Public Works Director Town of Carolina Beach Ben Meister, Project Manager Town of Carolina Beach Ed Parvin, Assistant Town Manager Town of Carolina Beach Scott Weber, Stormwater Construction Supervisor Town of Carolina Beach Mark Dudenhaver, Utility Construction Review Technician Town of Carolina Beach Gigi Baggarley, GIS Administrator Town of Carolina Beach M54 Receiving Waters Waterbodv Classification Impairments Carolina Beach Yacht Basin SB Cape Fear River Sc Atlantic Ocean (Discharge option only in emergency situations) NCS000394_Carolina Beach MS4 Audit_20201202 Page 2 of 25 List of Supporting Documents Item Number Document Title When Provided (Prior to/During/After) 01 Stormwater Map Prior 02 Public Works Department Flow Chart Prior 03 Ordinance 17-1054: Stormwater Management Ordinance Prior 04 Municipal SCM Operation and Maintenance Plan Prior 05 MS4 Operation and Maintenance Plan Prior 06 Illicit Discharge Detection and Elimination Program Plan Prior 07 Nine Elements Watershed Restoration Plan - DRAFT Prior O8 Carolina Beach 2020 Annual Report SWMPA Prior 09 Current Fee Invoice Status Prior 10 Weekly Updates report to Town Council (11/16/20 — 1120/20) During 11 Various BMP Inspection Reports During 12 Street Sweeper Logs During 13 Vactor Truck Logs During 14 Inventory of Privately Owned SCMs After 15 SCM 0&M Agreement After 16 Immediate Corrective Actions Needed Letter After 17 Maintenance Log for Municipally Owned Wet Ponds After 18 Wet Pond Maintenance Contract with Dragonfly Pond Works During 19 Cityworks— DemonstratedOnsite During NCS000394—Carolina Beach MS4 Audit_20201202 Page 3 of 25 Program Implementation, Documentation & Assessment Staff Interviewed: Brian Stanberry, Ben Meister, Ed Parvin, and Scott Weber (Name, Title, Role) Permit Citation Program Requirement Status supporting Doc No. IIA.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 08 Funding The Stormwater Plan identifies a specific position(s) responsible for the overall coordination, implementation, and revision to the Plan. NO Responsibilities for all components of the Stormwater Plan are documented and position(s) assignments provided. No -- The permittee is current on payment of invoiced administering and compliance monitoring fees (see stormwater e-payments on DEMLR MS4 web page). yes 09 Comments The stormwater program is funded through the enterprise fund, which also supports water and sanitary sewer. The enterprise fund is self-sustaining through a monthly fee residents pay. This fund has been in existence for more than 10 years. The town does not have a recent Stormwater Management Plan (SWMP). There is a SWMP in Laserfiche, but the Assistant Town Manager said it was from around 2009. The town has restructured three times since the 2009 SWMP was drafted and the SWMP has not been maintained. As part of the initial documentation request, the town provided a Public Works Department flow chart that highlights which staff work on stormwater-related objectives. There are currently 6 full-time positions in the Stormwater Division. There is also a technician that reviews all construction/E&SC plans submitted through the town, but this position is not housed in the Stormwater Division. The Stormwater Division staff and the construction plan review technician are overseen by Brian Stanberry, the Public Works Director. Staff positions are not explicitly tied to components of the SWMP because there is no current SWMP. II.A.2 Stormwater The permittee evaluated the performance and effectiveness of the program Plan components at least annually. Partial 08,10 Implementation and Evaluation If yes, the permittee used the results of the evaluation to modify the program components as necessary to accomplish the intent of the Stormwater Program. Partial -- Did the permitted MS4 discharges cause or contribute to non -attainment of an applicable water quality standard? No If yes, did the permittee expand or better tailor its BMPs accordingly to address Not the non -attainment? Appllrable — NCS000394_Carolina Beach MS4 Audit_20201202 Page 4 of 25 Program Implementation, Documentation & Assessment Comments Stormwater activities are tracked and reported weekly to the Town Council. Additionally, stormwater activities are reviewed each year as part of the budget process. The town also submitted a 2020 annual report SWMPA. Stormwater staff also undergo annual employee assessments which provide the opportunity to talk about what they have done and what they think could be done better. II.A.3 Keeping the The permittee kept the Stormwater Plan up to date. No -- Stormwater Plan Up to Date The permittee notified DEMLR of any updates to the Stormwater Plan. Not Applicable — Comments The latest SWMP on file is from around 2009. 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 --- authority necessary to implement and enforce the requirements of the permit. Comments The town's stormwater-related ordinances are available online via Municode: https://library.municode.com/nc/carolina_beach/ordinances/code_of_ordinances?nodeld=838632 https://Iibrary.municode.com/nc/carolina_ beach/munidocs/mun idocs?nodeld=2909cb4469297 II.A.3 & II.A.5 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 II.A.6 Sharing Responsibility Are any control measures implemented by an entity other than the permittee? Yes --- If yes, is there a written agreement in place? Not Applicable Comments The state sediment program does E&SC plan reviews and approvals and inspects construction site runoff controls for projects disturbing an acre or more. Separately, the town requires any disturbance of 5,000 square feet or more to submit a drainage plan and obtain a fill/grade/clear permit. A silt fence requirement is included in the fill/grade/clear permit. Permits are issued through Cityworks. NCS000394_Carolina Beach MS4 Audit_20201202 Page 5 of 25 Program Implementation, Documentation & Assessment 1IA.7 The permittee maintained written procedures for implementing the six minimum 04, 05, Written control measures. Partial 06 Procedures Written procedures identified specific action steps, schedules, resources and responsibilities for implementing the six minimum measures. Partial 04,05 Comments The town submitted an IDDE Program Plan, MS4 0&M Plan, and Municipal SCM 0&M Plan, but those plans do not, in many cases, identify specific action steps, schedules, resources, and responsibilities for implementation. The audit did not include a review of Public Education and Outreach, Public Involvement and Participation, or Construction Site Runoff Controls, so written procedures for those MCMs were not requested. III. A The permittee maintained documentation of all program components including, but Program not limited to, inspections, maintenance activities, educational programs, Partial 11,12, Documentation implementation of BMPs, enforcement actions etc., on file for a period of five years. 13 Comments The town has been using Cityworks to document and track various stormwater-related functions for 3 years, but is still working on implementing the software to its fullest potential. Many stormwater maintenance activities are tracked on paper logs and inspection reports, but there isn't documentation of public education and outreach efforts. 111.13 The permittee submitted annual reports to the Department within twelve months Annual Report from the effective date of the permit. No Submittal The permittee submitted subsequent annual reports every twelve months from the scheduled date of the first annual report submittal. partial 08 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 No — 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 No --- Plan (results, effectiveness, implementation schedule, etc.). 3. Documentation of any necessary changes to programs or practices for assessment of management measures implemented through the Stormwater No --- Plan. 4. A summary of data accumulated as part of the Stormwater Plan throughout the year along with an assessment of what the data indicates in light of the No — Stormwater Plan. 5. An assessment of compliance with the permit, information on the establishment of appropriate legal authorities, inspections, and enforcement No — actions. NCS000394_Carolina Beach MS4 Audit_20201202 Page 6 of 25 Program Implementation, Documentation & Assessment Comments The town does not have a current Stormwater Management Plan (SWMP); therefore, there was no reporting on the SWMP that could have been done. The town did submit a Stormwater Management Program Assessment (SWMPA) for 2020, but did not submit a SWMPA, or any other type of annual report, for 2017, 2018, or 2019. IV.B Annual Reporting The Annual Reports document the following: 1. A summary of past year activities, including where applicable, specific Partial 08 quantities achieved and summaries of enforcement actions. 2. A description of the effectiveness of each program component. Partial 08 3. Planned activities and changes for the next reporting period, for each Partial 08 program component or activity. 4. Fiscal analysis. Partial 08 Comments Per Part IV.B.3 of the permit, completion and submission of the 2020 SWMPA through BIMS satisfies the annual reporting requirement. No SWMPA, or other type of annual report, was submitted for 2017, 2018, or 2019. Additional Comments: NCS000394_Carolina Beach MS4 Audit_20201202 Page 7 of 25 Illicit Discharge Detection and Elimination (IDDE) Staff Interviewed: Brian Stanberry, Ben Meister, and Scott Weber (Name, Title, Role) Permit Citation Program Requirement Status Supporting Doc No. II.D.2.a IDDE Program The permittee maintained a written IDDE Program. Partial 06 If yes, the written program includes provisions for program assessment and evaluation and integrating program. No --- Comments The town has a written IDDE Program Plan, but it is not as detailed as it needs to be. Program plans are supposed to detail who is responsible for doing what and when. The IDDE Program Plan provided does not start to address those details until page 4 (out of 4 pages) and even then, much of the information provided is vague. Additionally, the plan is not dated or signed. 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. yes Legal Authorities If yes, the ordinance applies throughout the corporate limits of the permittee. Yes — Comments The IDDE portion of the ordinance is found in Article IX of Ordinance No.17-1054, which can be accessed through Municode at the following address: https:Hlibrary.municode.com/nc/carolina_beach/ordinances/code of ordinances?nodeld=838632 II.D.2.c Storm Sewer The permittee maintained a current map showing major outfalls* and receiving System Map streams. Yes Ol Comments 'Major outfalls are discharges from > 36" diameter pipes or drainage areas of > 50 acres. In areas zoned for industrial activity, major outfolls are > 12" or drainage area > 1 acres. II.D.2.d Dr Weather Flow The permittee maintained a program for conducting dry weather flow field y observations in accordance with written procedures. Partial 06,11 Program Comments The IDDE Program Plan briefly touches on how dry weather screening is to be handled. The town inspects outfalls with backflow prevention devices quarterly, at least, but there is no documented set schedule for conducting dry weather flow field observations. It is also important to note that much of the stormwater system is underwater multiple times a day. 11.12.2.e Invetigation The permittee maintained written procedures for conducting investigations of Procedures identified illicit discharges. Nos -- NC5000394 Carolina Beach MS4 Audit_20201202 Page 8 of 25 Illicit Discharge Detection and Elimination (IDDE) Comments 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 No --- 2. The results of the investigation No --- 3. Any follow-up of the investigation No --- 4. The date the investigation was closed No -- Comments At this point, illicit discharges would only be documented through personal notes, unless the Vactor truck was involved and then that would be documented on the Vactor Log. II.D.2.a Employee The permittee implemented and documented a training program for appropriate Training municipal staff who, as part of their normal job responsibilities, may come into No --- contact with or otherwise observe an illicit discharge or illicit connection. Comments There is no formal IDDE training program for municipal staff. Stormwater Division staff receive information and guidance through twice daily informal meetings. II.D.2.h The permittee informed public employees of hazards associated with illegal Public Education discharges and improper disposal of waste. No --- The permittee informed businesses of hazards associated with illegal discharges and improper disposal of waste. No --- The permittee informed the general public of hazards associated with illegal No -- discharges and improper disposal of waste. Comments The town sends out announcements through social media, predominantly Facebook, when the New Hanover County HazWagon is coming so that residents may dispose of household hazardous waste. NCS000394 Carolina Beach MS4 Audit_20201202 Page 9 of 25 Illicit Discharge Detection and Elimination (IDDE) II.D.2.i The permittee promoted, publicized, and facilitated a reporting mechanism for the Public Reporting public to report illicit discharges. Partial --- Mechanism 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. Partial -- Comments The public can report illicit discharges through the "Submit a Service Request" portal on the town's website or by calling town staff. The website portal emails town staff who can generate a service request. The website portal does not communicate directly with Cityworks, so service requests are not automatically generated. Service requests can then be tracked by the public online. Internally, if town staff discover an issue, they can document it using Cityworks or call the Stormwater Supervisor, who would ideally document the issue in Cityworks and generate a work order. II.D.2.i The permittee implemented a mechanism to track the issuance of notices of violation Enforcement and enforcement actions administered by the permittee. Partial --- If yes, the mechanism includes the ability to identify chronic violators for initiation of actions to reduce noncompliance. partial -- Comments The town said IDDE violations are code violations, so the Code Enforcement Officer (in the Planning and Development Department) would be referred anything that gets severe enough. Currently, the only record of such a referral would be an email sent from the Public Works Director to the Code Enforcement Officer. This information would get transferred into Cityworks, which does have the ability to track violations, at some point in the process. Additional There is no SOP within the IDDE Program Plan for issuing and tracking violation notices and enforcement Comments: actions. Additionally, the Program Plan does not say who is responsible for issuing such documentation and when. It is also unclear what the compliance and enforcement escalation process is (i.e. when does a violation become sever enough that it gets transferred to the Code Enforcement Officer?). NCS000394—Carolina Beach MS4 Audit_20201202 Page 10 of 25 Post -Construction Site Runoff Controls Staff Interviewed: (Name, Title, Role) Brian Stanberry, Mark Dudenhaver, and Gigi Baggarley 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 Low 2006-246 section below): ❑ Water Supply Watershed I (WS-1) —15A NCAC 2B .0212 ❑ Water Supply Watershed 11 (WS-11) —15A NCAC 213.0214 ❑ Water Supply Watershed III (WS-III) —15A NCAC 2B .0215 ❑ Water Supply Watershed IV (WS-IV)-15A NCAC 28.0216 ❑ 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 .0255 ❑ Randleman Lake Water Supply Watershed Nutrient Management Strategy-15A NCAC 213.0251 ❑ 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) Permit Citation Program Requirement Status Supporting Oo< 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 03 Management Program. If yes, the ordinance applies throughout the jurisdictional area of the permittee. Yes 03 The permittee has the authority to review designs and proposals for new development and redevelopment to determine whether adequate stormwater Yes 03 control measures will be installed, implemented, and maintained. NCS000394_Carolina Beach MS4 Audit_20201202 Page 11 of 25 Post -Construction Site Runoff Controls The permittee has the authority to request information such as stormwater plans, inspection reports, monitoring results, and other information deemed necessary to evaluate compliance with the Post -Construction Stormwater Management Yes 03 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 03 related to stormwater discharges. Comments II.F.2.b Stormwater Control The permittee utilizes strategies which include SCMs appropriate for the MS4. Yes 03 Measures (SCMs) SCMs comply with 1SA NCAC 02H .1000. Yes 03 Comments The town's ordinance references the state's BMP manual in Sec. 32-3. II.F.2.c The permittee conducted site plan reviews of all new development and Plan Reviews redeveloped sites that disturb greater than or equal to one acre (including sites that disturb less than one acre that are part of a larger common plan of Yes 03 development or sale). If yes, the site plan reviews addressed how the project applicant meets the performance standards. yes 03 If yes, the site plan reviews addressed how the project will ensure long-term maintenance. Yes 03 Comments The Utility Construction Review Technician reviews the plans originally and then goes out to inspect once the SCM has been installed and has to sign off in order for the project to get a Certificate of Occupancy (CO). As -built plans are required to be signed and submitted upon completion of the SCM. 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 14,19 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 14,19 requirements. Comments Town -owned SCMs were viewed during the audit via Cityworks. NCS000394_Carolina Beach MS4 Audit_20201202 Page 12 of 25 Post -Construction Site Runoff Controls II.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 03 and Protective consistent with approved plans. Covenants Comments The town requires deed restrictions and access easements. II.F2.f The permittee implemented or required an operation and maintenance plan for Yes 03,25 Mechanism to the long-term operation of the SCMs required by the program. 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 03 Annual inspection of permitted structural SCMs are required to be performed by a Yes 03 qualified professional. Comments II.F.2.g The permittee developed and implemented a written inspection program for SCMs Partial 04 Inspections of installed pursuant to the post -construction program. Structural Stormwater Control Measures The permittee documented and maintained records of inspections. Partial 11,17 The permittee documented and maintained records of enforcement actions. Partial 16 Comments The town has a Municipal SCM Operation and Maintenance Plan which does list inspection frequencies for different SCMs and BMPs; however, the plan does not say who is responsible for doing each type of inspection or how the inspections are to be recorded. Also, the plan is not signed or dated. The town contracts with Dragonfly Pond Works to service the town -owned wet ponds. There is no inspection program for privately owned SCMs. Problems with privately owned SCMs usually surface when the town is investigating flooding complaints. If town staff discover a problem, they first approach the SCM owner and have a discussion about what needs to be fixed. If the owner fails to take any action to correct the problem, the town then sends a letter and the action is recorded in Cityworks. II.F.2.h Educational The permittee made available through paper or electronic means, ordinances, Materials and post -construction requirements, design standards checklists, and other materials Partial --- Training for appropriate for developers. Developers NCS000394_Carolina Beach MS4 Audit_20201202 Page 13 of 25 Post -Construction Site Runoff Controls Comments The town is using the state's SCM manual, but there is no link to it on the website. It was explained that the Utility Construction Review Technician and Director of Public Works meet with developers on site and talk through requirements and concerns. They also directly email developers with the required forms and any additional information that may be needed. Since the town only encompasses 2.5 square miles, there is no development going on that town staff are not aware of. II.F.2.i Enforcement The permittee tracked the issuance of notices of violation and enforcement actions. Yes 19 If yes, the tracking mechanism included the ability to identify chronic violators for initiation of actions to reduce noncompliance. Yes 19 Comments Cityworks tracks violation notices and penalties. This capability was demonstrated during the audit. II.F.3.b The permittee fully complies with post construction program requirements on its New Development own publicly funded construction projects. Yes Comments Publicly funded projects are permitted through the state. II.F3.c Does the MS4 have areas draining to Nutrient Sensitive Waters (NSW) pursuant to Not Nutrient Sensitive 15A NCAC 02H .0150? Applicable Waters If yes, does the permittee use SCMs that reduce nutrient loading in order to Not meet local program requirements. Applicable If yes, does the permittee also still incorporate the stormwater controls Not required for the project's density level. Applicable -"- If yes, does the permittee also require documentation where it is not feasible to Not use SCMs that reduce nutrient loading. Applicable Comments 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 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 03 streets, driveways, and other impervious surfaces. Comments NCS000394_Carolina Beach MS4 Audit_20201202 Page 14 of 25 I Post -Construction Site Runoff Controls I Comments: NCS000394_Carolina Beach MS4 Audit_20201202 Page 15 of 25 Pollution Prevention and Good Housekeeping for Municipal Operations Staff Interviewed: Brian Stanberry, Ben Meister, and Scott Weber (Name, Title, Role) 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 stormwater runoff. Comments The following facilities and operations have the potential for generating polluted stormwater runoff: the Wastewater Treatment Plant, the Operations Warehouse, the Fire Department, and the Bridge Barrier Road facility. II.G.2.b The permittee maintained and implemented an O&M program for municipally Operation and owned and operated facilities with the potential for generating polluted Partial 05 Maintenance (O&M) stormwater runoff. for Facilities If yes, the 0&M program specifies the frequency of inspections. Partial 05 If yes, the O&M program specifies the frequency of routine maintenance requirements. partial D5 If yes, the permittee evaluated the O&M program annually and updated it as necessary. No --- Comments The town has an MS4 Operation and Maintenance Plan, however it is unclear when it was developed because it is not signed or dated. The plan addresses maintenance of stormwater-related infrastructure but not municipally owned and operated facilities. The overall critique is that the plan needs to be more detailed. II.G.2.c Spill Response The permittee had written spill response procedures for municipal operations. No -- Procedures Comments 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 10 Parking Lots corporate limits annually. Maintenance If yes, the permittee evaluated the effectiveness of existing and new BMPs 11,12, based on cost and the estimated quantity of pollutants removed. Yes 13 Comments Stormwater activities are tracked and reported weekly to the Town Council. Additionally, stormwater activities are reviewed each year as part of the budget process. NCS000394_Carolina Beach MS4 Audit_20201202 Page 16 of 25 Pollution Prevention and Good Housekeeping for Municipal Operations 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 05 Basins and Conveyance systems maintains. Comments II.G.2.d The permittee maintained a current inventory of municipally -owned or operated Structural structural stormwater controls installed for compliance with the permittee's post- Yes --- Stormwater Controls construction ordinance. Comments Town -owned SCMs were viewed during the audit via Cityworks. II.G.2.e The permittee maintained and implemented an O&M program for municipally - O&M for Structural owned or maintained structural stormwater controls installed for compliance with Yes 04 stormwater Controls the permittee's post -construction ordinance. If yes, then: The C&M program specified the frequency of inspections and routine Yes 04 maintenance requirements. The permittee documented inspections of all municipally -owned or maintained Yes 11,17 structural stormwater controls. The permittee inspected all municipally -owned or maintained structural Yes stormwater controls in accordance with the schedule developed by permittee. The permittee maintained all municipally -owned or maintained structural stormwater controls in accordance with the schedule developed by permittee. Yes --- The permittee documented maintenance of all municipally -owned or maintained structural stormwater controls. Yes 11,17 Comments II.G.2.f The permittee ensured municipal employees are properly trained in pesticide, Not Pesticide, Herbicide herbicide and fertilizer application management. Applicable _ and Fertilizer Application The permittee ensured contractors are properly trained in pesticide, herbicide and Management g fertilizer application management. Partial 18 The permittee ensured all permits, certifications, and other measures for applicators are followed. Partial 18 NCS000394 Carolina Beach MS4 Audit 20201202 Page 17 of 25 Pollution Prevention and Good Housekeeping for Municipal Operations Comments Pond maintenance, along with pesticide/herbicide and fertilizer application, are contracted out. Town staff do not do any pesticide, herbicide, or fertilizer application. The town points to # 13 under Terms & Conditions in its contract with Dragonfly Pond Works as the requirement ensuring this particular contractor is properly trained and licensed. II.G.2.g The ermittee implemented an employee trainin P Pg program for employees involved Staff Training n implementing pollution prevention and good housekeeping practices. No --- Comments II.G.2.h The permittee described and implemented measures that prevent or minimize Vehicle and contamination of stormwater runoff from all areas used for vehicle and equipment No Equipment Cleaning cleaning. Comments Additional Comments: NCS000394_Carolina Beach MS4 Audit_20201202 Page 18 of 25 Site Visit Evaluation: Municipal Facility No. 1 Facility Name: Date and Time of Site Visit: December 2, 2020 Operations Warehouse ^'1:50 PM Facility Address: Facility Type (Vehicle Maintenance, Landscaping, etc.): 1121 N Lake Park Blvd. Equipment and material storage Name of MS4 inspector(s) evaluated: Most Recent MS4 Inspection (List date and name of inspector): Scott Weber No formal inspection Name(s) and Titles) of Facility Representative(s) Present During the Site Visit: Name Title Brian Stanberry Public Works Director Ben Meister Project Manager Observations Facility Documentation/Training Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific? There is no SWPPP, or similar document, for this facility. What type of stormwater training do facility employees receive? How often? The Operations Warehouse is a shared space, and the town does not have a formal stormwater training program for staff, so most employees that use and access the space do not have any stormwater training. Stormwater Division staff attend periodic seminars, typically offered through NC State University, on stormwater-related topics such as maintenance requirements for different SCMs. Additionally, 5 Stormwater Division staff have achieved the SCM Inspection and Maintenance Certification through NC State University (this includes the inspector observed during the facility inspection). Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? The inspector achieved his SCM certification through NC State University in 2007 and recently renewed the certification in 2017. Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? The inspector appeared somewhat knowledgeable about the MS4 permit requirements for pollution prevention and good housekeeping. Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping? Yes, the inspector is knowledgeable about stormwater pollution prevention and good housekeeping. Inspection Procedures Does the MS4 inspector's process include the use of a checklist or other standardized form? No. NCS000394_Carolina Beach MS4 Audit_20201202 Page 19 of 25 Site Visit Evaluation: Municipal Facility No. 1 Does the MS4 inspector's process include taking photos? No. Does the MS4 inspectors process include reviewing the facility's SWPPP (or similar document)? No, but this facility does not have a SWPPP or similar document in place. Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge? Yes. Did the MS4 inspector miss any obvious areas of concern? If so, explain: No. Does the MS4 inspector's process include presenting the inspection findings to the facility contact? If the inspector notices something that needs to be addressed, like a vehicle leaking oil, he goes ahead and puts a drip pan under the vehicle and reports the issue to management. If a utilities employee finds an issue, they contact the utilities director who then provides direction. Inspection Results Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)? No. If compliance corrective actions were identified, what timeline for correction/follow-up was provided? No. Notes/Comments/Recommendations An example of another good practice: equipment operators are required to do walk-arounds before using any piece of equipment. This is a good example of where having detailed, written plans and procedures is necessary because then there is no guessing on who to contact and what steps to take when possible pollution issues are identified. Also, all the staff that use and/or have access to the warehouse need to receive basic stormwater training so they are aware of what to look for and the importance of good housekeeping. NCS000394_Carolina Beach MS4 Audit_20201202 Page 20 of 25 Site Visit Evaluation: MS4 Outfall No. 1 Outfall ID Number: Date and Time of Site Visit: 15 December 2, 2020 —2:50 PM Outfall Location: Outfall Description (Pipe Material/Diameter, Culvert, etc.): Sandpiper Road & Canal Drive DWPP, 18", with a check valve Receiving Water: Is Flow Present? If So, Describe (Color, Approximate Flow Rate, Sheen, Odor, Floatables/Debris, etc.): Carolina Beach Yacht Basin There was a small flow, but no sheen, odor, Foatables, etc. Most Recent Outfall Inspection/Screening (Date): One week prior Days Since Last Rainfall: Inches: Sunday night, so approximately 3 days 2 Name of MS4 Inspector(s) evaluated: Scott Weber Observations Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? The inspector achieved his SCM certification through NC State University in 2007 and recently renewed the certification in 2017. He is also the stormwater supervisor and has been with the town for many years, so he very familiar with the storm sewer system. Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations? Yes, the inspector is knowledgeable about identifying illicit discharges. However, the town does not have clear procedures for how to investigate and enforce on illicit discharges, so the inspector's knowledge is limited in that regard. 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? Sometimes, if the inspector deems it necessary to visually document a discharge or needed maintenance. Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they? No. NCS000394_Carolina Beach MS4 Audit_20201202 Page 21 of 25 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 follow-up inspection is needed at this outfall. Notes/Comments/Recommendations The town is working on asset management development (i.e. recording pipe size, material, and flow direction) for the entire storm sewer system. Having this information will be invaluable when investigating illicit discharges going forward. NCS000394_Carolina Beach MS4 Audit_20201202 Page 22 of 25 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1 Site Name: Date and Time of Site Visit: Ocean Ridge December 2, 2020 —2:20 PM Site Address: SCM Type: The wet pond is accessed through 222 Winner Ave. Wet pond built in 1982, initially not owned by the town Most Recent MS4 Inspection (Include Date and Entity): November 23, 2020 Name of MS4 Inspector(s) evaluated: Most Recent MS4 Enforcement Activity (Include Date): Scott Weber None Names) and Title(s) of Site Representative(s) Present During the Site Visit: Name Title Brian Stanberry Public Works Director Ben Meister Project Manager 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. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? The inspector achieved his SCM certification through NC State University in 2007 and recently renewed the certification in 2017. 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 used a standardized paper form. Does the MS4 inspector's process include taking photos? Sometimes, if the inspector needs to document required maintenance. Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections? Yes. NCS000394_Carolina Beach MS4 Audit_20201202 Page 23 of 25 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? 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? In this case, the site contact was the town so the inspector just needed to make sure any required maintenance was recorded on the form and then transferred into Cityworks. Comp liance/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? N/A Notes/Comments/Recommendations NCS000394 Carolina Beach MS4 Audit_20201202 Page 24 of 25 APPENDIX A: SUPPORTING DOCUMENTS All supporting documentation cited in this report can be accessed from the Division of Energy, Mineral, and Land Resources' online Laserfiche repository at the following link: hftps://edocs.deq. nc.gov/WaterResources/Browse.aspx?dbid=0&sta rtid=717821 NCS000394_Carolina Beach MS4 Audit_20201202 Page 25 of 25