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Home My WebLink AboutNCS000335_DOD SJAFB MS4 Audit Report_20210331 MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) PROGRAM AUDIT REPORT NPDES PERMIT NO. NCS000335 SEYMOUR JOHNSON AIR FORCE BASE WAYNE COUNTY Audit Date: March 23 – 24, 2021 Report Date: March 31, 2021 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 NCS000335_SJAFB MS4 Audit_20201109 i (This page intentionally left blank) NCS000335_SJAFB MS4 Audit_20201109 ii TABLE OF CONTENTS Audit Details .................................................................................................................................................. 1 Permittee Information .................................................................................................................................. 2 List of Supporting Documents ....................................................................................................................... 4 Program Implementation, Documentation & Assessment ........................................................................... 5 Illicit Discharge Detection and Elimination (IDDE) ........................................................................................ 9 Post-Construction Site Runoff Controls ...................................................................................................... 12 Pollution Prevention and Good Housekeeping for Municipal Operations ................................................. 14 Industrial Activities ..................................................................................................................................... 18 Oil Water Separators (OWS) ....................................................................................................................... 20 Monitoring .................................................................................................................................................. 21 Site Visit Evaluation: Facility No. 1 .............................................................................................................. 22 Site Visit Evaluation: Facility No. 2 .............................................................................................................. 24 Site Visit Evaluation: MS4 Outfall No. 1 ...................................................................................................... 26 Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1 ............................................ 28 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. NCS000335_SJAFB MS4 Audit_20201109 iii This page intentionally left blank NCS000335_SJAFB MS4 Audit_20210326 Page 1 of 2 Audit Details Audit ID Number: NCS000335_SJAFB MS4 Audit_20210323 Audit Date(s): March 23-24, 2021 Minimum Control Measures Evaluated: ☒ Program Implementation, Documentation & Assessment ☐ Public Education & Outreach ☐ Public Involvement & Participation ☒ Illicit Discharge Detection & Elimination ☐ Construction Site Runoff Controls – No delegated Sediment and Erosion Control Program ☐ Construction Site Runoff Controls – Delegated Sediment and Erosion Control Program ☒ Post Construction Site Runoff Controls ☒ Pollution Prevention and Good Housekeeping for Municipal Operations ☒ Oil Water Separators ☒ Industrial Activities ☒ Monitoring Requirements ☐ Impaired Waters & Total Maximum Daily Loads (TMDLs) Field Site Visits: ☒ Municipal Facilities. Number visited: 2 ☒ MS4 Outfalls. Number visited: 1 ☐ Construction Sites. Number visited: Choose an item. ☒ Post-Construction Stormwater Runoff Controls. Number visited: 2 ☐ Other: ________________________________. Number visited: Choose an item. ☐ Other: ________________________________. Number visited: Choose an item. Inspector(s) Conducting Audit Name, Title Organization Jeanette Powell, MS4 Program Coordinator DEQ-DEMLR Mike Lawyer, FRO DEQ-DEMLR Thom Edgerton, WARO DEQ-DEMLR Audit Report Author: Jeanette Powell, MS4 Program Coordinator Signature: Date: March 26, 2021 NCS000335_SJAFB MS4 Audit_20210326 Page 2 of 3 Permittee Information MS4 Permittee Name: Seymour Johnson Air Force Base Permit Effective Date: April 1, 2016 Permit Expiration Date: March 31, 2021 Mailing Address: 1095 Peterson Ave. Building 3300 SJAFB, NC 27531 Date of Last MS4 Inspection/Audit: March 4, 2015 Co-permittee(s), if applicable: N/A Permit Owner of Record: Dennis G. Goodson, Base Deputy Engineer Primary MS4 Representatives Participating in Audit Name, Title Organization Jeff D’Agostino1, 2, 3 4CES/CE Ronnie Wilson1, 2, 3 4CES/CE Kirt Jarrett1, 2, 3 4CES/CE Russ Adams1 AFCEC John Grantham1 Construction Chief Paul Walker1, 2, 3 4CES/CEOHP Msgt. Greg Lund1, 3 4CES/CEOH Michael Dreez1, 2 4CES/CEOIU Msgt. Jason Phelps1 4CES/CEOIU Jodie Fussell1, 3 4CES/CEI Thomas J Miller3 Flight Chief, Ops Flight Lt. Col. Raymond Kerr3 Base Civil Engineer Brian Joyner3 Engineering Chief 1 Present March 23, 2021 (Interviews) 2 Present March 24, 2021 (Site Visits) 3 Present for Preliminary Findings Meeting March 24, 2021 MS4 Receiving Waters: Neuse River Basin Waterbody Classification Impairments Neuse River C-NSW Stoney Creek C-NSW Hospital Creeks Burge Ditch NCS000335_SJAFB MS4 Audit_20210326 Page 3 of 4 ACRONYMS AGE Above Ground Equipment BUA Built Upon Area CFT Cross Functional Training EASIER Enforcement Action, Spills, Inspections & Environmental Reporting eDASH Acronym undefined EISA Energy Independence and Security Act SCM Stormwater Control Measure SPCC Spill Prevention, Control and Countermeasure SPPP Stormwater Pollution Prevention Plan TEACH The Environmental Awareness Course Hub UEC Unit Environmental Coordinators Mayfield’s Ditch Golf Course Ditch Golf Course Lake Bulk Fuels Ditch NCS000335_SJAFB MS4 Audit_20210326 Page 4 of 5 List of Supporting Documents Item Number Document Title When Provided (Prior to/During/After) 1 DEQ Watershed Protection Plan Approval Letter (Oct. 11, 2015) Prior 2 Comprehensive Watershed Protection Plan (May 2015) Prior 3 SPCC Plan Inventory Prior 4 Illicit Discharge Detection & Elimination Plan (July 31, 2020) Prior 5 Storm Water Plan (April 2020) Prior 6 2020 Organizational Chart Prior 7 Shop/Industrial Processes Wastewater Discharge List Prior 8 2020 Oil Water Separators Prior 9 Work Management Playbook (Sept. 14, 2015) Prior 10 Air Force Instruction 32-1001 (Oct. 2019) Prior 11 Visitation Checklist for SCM O&M Prior 12 Enforcement Actions, Spills and Inspections Environmental Reporting (EASIER) Demonstrated on Site 13 DEQ ePayment Status Report N/A 14 Annual Reports for 2017 – 2020 (Laserfiche) On File 15 Section 01560 Environmental Protection Demonstrated on Site 16 Monitoring Reports Demonstrated on Site 17 MS4 Map Demonstrated on Site 18 TEACH (training, rosters, etc.) Demonstrated on Site 19 Visitation Checklist (for SCM inspections) Demonstrated on Site 20 Internal Industrial Stormwater Inspection Report Demonstrated on Site NCS000335_SJAFB MS4 Audit_20210326 Page 5 of 6 Program Implementation, Documentation & Assessment Staff Interviewed: (Name, Title, Role) See roster of Primary MS4 Representatives Participating in Audit on page 2. Permit Citation Program Requirement Status Support ing Doc No. II.A.1-3 Program Implementation The permittee developed and maintained a Stormwater Plan. Yes 5 The permittee developed and maintained the authority to implement all provisions of the Stormwater Plan. Yes 10, 15 The permittee notified the Division of proposed major modifications to the Stormwater Plan and provided the reasons and justifications for those changes. Not Applicable - The permittee maintained adequate funding and staffing to implement and manage the provisions of the Stormwater Plan. Yes 6 The permittee is current on payment of invoiced administering and compliance monitoring fees (see stormwater e-payments on DEMLR MS4 web page). Yes 13 21 IDDE Pamphlet Demonstrated on Site 22 LID Toolbox Demonstrated on Site 23 Medical Clinic Biannual SAFL Baffle O&M Inspection Record Demonstrated on Site 24 2020 Industrial Wastewater Survey Report Demonstrated on Site 25 Work management Playbook Demonstrated on Site 26 IBM TRIRIGA Work Order System Demonstrated on Site 27 Storm Drain Inspection and O&M Program for SCMs (Feb. 2020) Demonstrated on Site 28 Stormwater Asset Inventories & Condition Assessment Project Report Demonstrated on Site 29 eDASH (online environmental policy, procedures and guidance) Demonstrated on Site 30 SPCC Plan Demonstrated on Site NCS000335_SJAFB MS4 Audit_20210326 Page 6 of 7 Program Implementation, Documentation & Assessment Comments: The Stormwater Management Plan (SWP) is reviewed and updated annually. Stormwater Program authority and staff responsibilities are provided via base orders, Engineering Technical Letters, the Air Force Manual and contract requirements and standard conditions. There were no major modifications to the SWP during this permit term. The program was well organized and documented, indicating that available program administration funding is adequate. All payments are current for invoiced administering and compliance monitoring fees, as confirmed through DEMLRs ePayment system. III.1 Program Assessment Documentation The permittee maintains documentation of all program components that are being undertaken to implement the Stormwater Plan including, but not limited to, inspections, maintenance activities, educational programs, implementation of BMPs, enforcement actions, and other stormwater activities. Yes - The permittee maintains documentation of all monitoring and sampling being performed for a period of five years. Yes 16 Comments The permittee maintains all required documentation for a minimum of five years. See details in specific sections of this audit report. III.2 Keeping the Stormwater Plan Up to Date The permittee reviewed the Stormwater Plan annually and updated as necessary. Yes 5 The permittee submitted comprehensive annual reports Yes 14 Comments The SWP includes a tracking sheet for annual reviews and updates. Comprehensive annual reports for the entire current permit term are on file. Minor changes are incorporated, as necessary. Any major revisions would be submitted to the Division. There were no major updates to the Stormwater Plan during the current permit term. III.3 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 DEMLR did not require a modification to the Stormwater Plan during the term of the permit. III.4 Additional Information Did DEMLR request additional reporting information to assess the progress and results of the Stormwater Plan? No - NCS000335_SJAFB MS4 Audit_20210326 Page 7 of 8 Program Implementation, Documentation & Assessment If yes, did the permittee provide the information in accordance with the established deadline? Not Applicable - Comments: DEMLR did not request any additional reporting information to assess the progress and results of the Stormwater Plan. IV.1 Records Retention The permittee documented and maintained visual monitoring records at the facility. Yes 16 The permittee documented and maintained analytical monitoring records at the facility. Yes 16 The permittee documented and maintained the Stormwater Pollution Prevention Plan at the facility. Yes 5 The permittee retained records of all monitoring information, including all calibration and maintenance records and all original strip chart recordings for continuous monitoring instrumentation, and copies of all reports required by this Permit for a period of at least 5 years from the date of the sample, measurement, report or application. Yes 16 Comments: The permittee maintains all qualitative and quantitative monitoring reports in a central location. The base-wide SWPPP is online and accessible to all facilities. Analytical monitoring is performed via contract support services. DEQ forms are completed and maintained with chain of custody documentation and analytical results. IV.4 Twenty-four Hour Reporting The permittee reported to DEMLR any noncompliance that may constitute an imminent threat to health or the environment. Not Applicable - If yes, did the permittee provide the information orally within 24 hours? Not Applicable - If yes, did the Director waive the written report when the oral report was received within 24 hours? Not Applicable - Did the permittee provide a written report within 5 days? Not Applicable - If yes, did the written report contain a description of the noncompliance, and its causes; the period of noncompliance, including exact dates and times, and if the noncompliance has not been corrected, the anticipated time compliance is expected to continue; and steps taken or planned to reduce, eliminate, and prevent reoccurrence of the noncompliance? Not Applicable - NCS000335_SJAFB MS4 Audit_20210326 Page 8 of 9 Program Implementation, Documentation & Assessment Comments: There were no reportable events during the permit term. Additional Comments: The Stormwater Program is well managed. Staff were knowledgeable on permit requirements, program component sand staff responsibilities. Documentation was readily accessible and complete. The program relies heavily on contract support, and will need to maintain those services to achieve continuous compliance. NCS000335_SJAFB MS4 Audit_20210326 Page 9 of 10 Illicit Discharge Detection and Elimination (IDDE) Staff Interviewed: (Name, Title, Role) See roster of Primary MS4 Representatives Participating in Audit on page 2. Permit Citation Program Requirement Status Support ing Doc No. II.D.2.a Storm Sewer System Map The permittee maintained, assessed, and updated as necessary a map identifying major outfalls. Yes 17 The map components include major outfalls and receiving streams, and type of conveyance system (i.e., either closed pipe or open drainage). Yes 17 For closed pipe systems, the map identifies the pipe material, shape, and size. Yes 17 Comments The permittee maintains a detailed GIS map and asset inventory of the stormwater collection system. *Major outfalls are discharges from > 36” diameter pipes or drainage areas of > 50 acres. In areas zoned for industrial activity, major outfalls are > 12” or drainage area > 2 acres. II.D.2.b Dry Weather Screening The permittee maintains a written field screening procedure for detecting and tracing the sources of illicit discharges and for removing the sources or reporting the sources to the State to be properly permitted. Partial 4, 16, 21 The permittee implemented a program for conducting regular dry weather flow field observations in accordance with the written field screening procedure. Yes 4, 16 Comments: The permittee is implementing the permit requirements for dry weather screening. However, the permittee does not maintain a written field screening procedure for detecting and tracing the sources of illicit discharges. II.D.2.c Written Illicit Discharge Procedures The permittee maintained written procedures for conducting investigations into the source of all identified illicit discharges, including approaches to requiring such discharges to be eliminated. Partial 4, 16, 21 If yes, the written procedures were assessed annually and updated as necessary. Not Applicable - Comments: The permittee is implementing the appropriate measures. However, the permittee does not maintain written procedures for conducting investigations into the source of all identified illicit discharges. NCS000335_SJAFB MS4 Audit_20210326 Page 10 of 11 Illicit Discharge Detection and Elimination (IDDE) II.D.2.d Illicit Discharge Investigations The permittee tracked and documented all illicit discharge investigations. Yes 12 If yes, the date(s) the illicit discharge was observed; the results of the investigation; any follow-up of the investigation; and the date the investigation was closed were documented. Yes 12 Comments: Comprehensive illicit discharge documentation is managed in EASIER. II.D.2.e Employee Training The permittee implemented a training program for appropriate personnel, who, as part of their normal job responsibilities, may come into contact with or otherwise observe an illicit discharge or illicit connection to the storm sewer system. Yes 18 If yes, the permittee documented the training program including identified appropriate personnel, the schedule for conducting the training and the proper procedures for reporting and responding to an illicit discharge or connection. Yes 18 The permittee provided follow-up training as needed to address changes in personnel, procedures, or techniques. Yes 18 Comments: Comprehensive training and records are managed in TEACH. II.D.2.f Public Education The permittee informed public employees of hazards associated with illegal discharges and improper disposal of waste. Yes 18, 21, 29 The permittee informed businesses of hazards associated with illegal discharges and improper disposal of waste. Yes 18, 21, 29 The permittee informed the general public of hazards associated with illegal discharges and improper disposal of waste. Yes 18, 21, 29 Comments: Base onboarding includes employee, business and general public education via eDASH web site, newsletters, pamphlets and mandatory training assignments in TEACH, UECs and CFT. NCS000335_SJAFB MS4 Audit_20210326 Page 11 of 12 Illicit Discharge Detection and Elimination (IDDE) II.D.2.g Reporting Mechanism The permittee promoted, publicized, and facilitated a reporting mechanism for the public to report illicit discharges. Yes 18, 21, 29 The permittee promoted, publicized, and facilitated a reporting mechanism for staff to report illicit discharges. Yes 18, 21, 29 The permittee established and implemented response procedures for citizen requests/reports. Yes 18, 21, 29 The permittee conducted reactive inspections in response to complaints. Yes 12, 26 The permittee conducted follow-up inspections as needed to ensure that corrective measures have been implemented by the responsible party to achieve and maintain compliance. Yes 12, 26 Comments: Reporting mechanisms for the public, staff and citizens are publicized via public education (see section II.D.2.f). The permittee has a defined response tree to provide reactive inspections 24/7, which are documented in eDASH. II.D.2.h Sanitary Sewer Overflows The permittee implemented written procedures to identify and report sanitary sewer overflows and sewer leaks to the system operator. Yes 30 If yes, the permittee assessed annually, and updated as necessary the written procedures to identify and report sanitary sewer overflows and sewer leaks to the system operator. Yes 30 Comments: Sanitary sewer overflow procedures are a component of the Spill Plan. The spill plan is reviewed and updated annually. Additional Comments: The permit includes authorized representative outfall monitoring (Outfalls 2, 3, 4). Because petroleum products are the primary pollutant of concern, industrial facility runoff is routed to oil water separators or to the City of Goldsboro sanitary sewer system. The IDDE and pollution prevention programs are spill focused and rely upon the SPCC Plan for procedures. NCS000335_SJAFB MS4 Audit_20210326 Page 12 of 13 Post-Construction Site Runoff Controls Staff Interviewed: (Name, Title, Role) See roster of Primary MS4 Representatives Participating in Audit on page 2. Implementation (check all that apply): ☒ The permittee implements some components of this minimum measure. ☐ The permittee relies upon another entity to implement some components of this minimum measure: NCDEQ ☐ 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 2B .0212 ☐ Water Supply Watershed II (WS-II) – 15A NCAC 2B .0214 ☐ Water Supply Watershed III (WS-III) – 15A NCAC 2B .0215 ☐ Water Supply Watershed IV (WS-IV) – 15A NCAC 2B .0216 ☐ Freshwater High Quality Waters (HQW) – 15A NCAC 2H .1006 ☐ Freshwater Outstanding Resource Waters (ORW) – 15A NCAC 2H .1007 ☐ Neuse River Basin Nutrient Sensitive (NSW) Management Strategy – 15A NCAC 2B .0235 ☐ Tar-Pamlico River Basin Nutrient Sensitive (NSW) Management Strategy – 15A NCAC 2B .0258 ☐ Randleman Lake Water Supply Watershed Nutrient Management Strategy – 15A NCAC 2B .0251 ☐ Universal Stormwater Management Program – 15A NCAC 2H .1020 Program Requirement Status Support ing Doc No. F.2. Post-Construction Runoff Controls The permittee submits projects disturbing 1 acre or more to the DEMLR WARO for review and approval. Yes - Projects include public roads and bridges. Yes 1, 2, 22 The permittee implements the approved Comprehensive Watershed Protection Plan. Yes 1, 2, 22 NCS000335_SJAFB MS4 Audit_20210326 Page 13 of 14 Post-Construction Site Runoff Controls Comments: The post-construction program requirements include an approved Comprehensive Watershed Protection Plan, a 5,000 sf footprint threshold, maintenance of pre-development hydrology, and an impervious surface crediting system. The impervious surface crediting system includes “banked” impervious surface that was previously removed. Annual BUA accounting and a list of subject projects is provided in the annual reports. The current balance in the BUA crediting system is reported as 64.67 acres for FY20. Projects are tracked using SJAFB LID Toolbox software. The permittee has not submitted projects to DEMLR for review and permitting, as no SCMs have been required to date under the approved Comprehensive Watershed Plan phased development requirements. All projects disturbing 1 acre or more are submitted to WARO for erosion and sediment control permitting, and receive a NCG01 permit. Additional Comments: The approved Comprehensive Watershed Plan and LID Toolbox provides a detailed post- construction program structure that supports EISA compliance. The entire base is treated as a common plan of development. The toolbox automatically provides options for acceptable infiltration measures once the banked BUA is used. The permittee is not a named Neuse NSW community, but these SCM menu in the toolbox are infiltration focused to provide effective nutrient management. The permittee is currently in Phase 0, and the program phases are: Phase 0: Withdrawing from BUA bank (current balance 69.3 acres) Phase I: Banked BUA exceeded, infiltration SCMs in appropriate areas/soils Phase II: New structural SCMs It is recommended that the permittee not only track BUA >5,000 sf, but also periodically compute the base-wide impervious percentage as a check on the accounting system. NCS000335_SJAFB MS4 Audit_20210326 Page 14 of 15 Pollution Prevention and Good Housekeeping for Municipal Operations Staff Interviewed: (Name, Title, Role) See roster of Primary MS4 Representatives Participating in Audit on page 2. Permit Citation Program Requirement Status Support ing Doc No. II.G.2.a & b Facility Inventory The permittee developed an inventory of facilities and operations with the potential for generating polluted stormwater runoff (map or list). Yes 24 The permittee identified the stormwater outfalls corresponding to each of the facilities. Yes 24 The permittee identified the receiving waters to which each facility discharges. Yes 24 The permittee maintained and updated the inventory annually. Yes 24 Comments: The Industrial Wastewater Report provides an inventory of 35 industrial facilities and information is documented and tracked in eDASH. II.G.2.c Operation and Maintenance (O&M) for Facilities The permittee maintained and implemented an O&M program for facilities and operations with the potential for generating polluted stormwater runoff. Yes 9, 25, 26 If yes, the O&M program specifies the frequency of inspections. Yes 9, 25, 26 If yes, the O&M program specifies the frequency of routine maintenance requirements. Yes 9, 25, 26 Comments: The permittee maintains a site-specific Playbook for each facility which is readily available through eDASH. Facilities are inspected in accordance with SPCC requirements. The TRIRIGA work order system documents inspections and tasks, and automatically escalates issues that are not resolved and documented. II.G.2.d Spill Response Procedures The permittee has written spill response procedures for facilities and operations with the potential for generating polluted stormwater runoff. Yes 18, 30 Comments: The permittee maintains current spill plans and an appointed UEC is responsible for each facility. NCS000335_SJAFB MS4 Audit_20210326 Page 15 of 16 Pollution Prevention and Good Housekeeping for Municipal Operations II.G.2.e Streets, Roads, and Public Parking Lot Maintenance The permittee implements BMPs selected to reduce polluted stormwater runoff from municipally-owned streets, roads, and parking lots. Yes 26, 27 Comments: The permittee has a street sweeper in operation at all times during flight duty, typically 18 hours per day. Routes, schedules, etc. are documented in TRIRIGA work order system and the Storm Drain Inspection, Operation and Maintenance Program for Stormwater Control Measures. II.G.2.f O&M for Catch Basins and Conveyance Systems The permittee developed an O&M program for the stormwater sewer system. If yes, then: Yes 26, 28 The O&M Program includes catch basins and conveyance systems. Yes 26, 28 The O&M Program includes route maps. Yes 26, 28 The O&M Program specifies the frequency of inspections. Yes 26, 28 The O&M Program specifies the routine maintenance requirements. Yes 26, 28 Comments: The permittee utilizes TRIRIGA and the asset inventory and condition assessment to perform routine maintenance of the collection system. The permittee also contracts support services such as seasonal leaf collection. II.G.2.g Structural Stormwater Controls The permittee developed an inventory (map or list) of structural stormwater control measures. If yes, then: Yes 17, 26 The inventory identifies the stormwater outfalls corresponding to each structural stormwater control measure. Yes 17, 26 The inventory identifies the receiving waters to which each structural stormwater control measure discharges. Yes 17, 26 The inventory of structural stormwater control measures is maintained and updated regularly. Yes 17, 26 Comments: The permittee maintains a comprehensive asset inventory. NCS000335_SJAFB MS4 Audit_20210326 Page 16 of 17 Pollution Prevention and Good Housekeeping for Municipal Operations II.G.2.h O&M for Structural Stormwater Controls The permittee maintained and implemented an O&M program for structural stormwater controls. Yes 19, 23, 26 The O&M program specified the frequency of inspections. Yes 19, 23, 26 The O&M program specified the routine maintenance requirements. Yes 19, 23, 26 The permittee inspected all structural stormwater controls in accordance with the schedule developed by permittee. Yes 19, 23, 26 The permittee maintained all structural stormwater controls in accordance with the schedule developed by permittee. Yes 19, 23, 26 The permittee documented inspections of all structural stormwater controls. Yes 11, 19, 23, 26 The permittee documented maintenance of all structural stormwater controls. Yes 19, 23, 26 Comments: As a result of the approved Comprehensive Watershed Protection Plan, the permittee does not own/operate many SCMs. However, existing devices are subject to specific operation and maintenance, actions are traced in TRIRIGA, and devices appeared to be in good working condition. II.G.2.i Staff Training The permittee implemented an employee training program for personnel involved in implementing pollution prevention and good housekeeping practices. Yes 18, 21, 29 Comments: Staff onboarding includes education via eDASH web site, newsletters, pamphlets, and mandatory training assignments via TEACH, UECs and CFT. II.G.2.j Vehicle and Equipment Cleaning The permittee described and implemented measures that prevent or minimize contamination of stormwater runoff from all areas used for vehicle and equipment cleaning. Yes 30 Comments: The permittee implements a comprehensive management program for vehicle and equipment cleaning areas, which includes performing work in covered and/or contained areas and routing wash waters to oil water separators and/or sanitary sewer. NCS000335_SJAFB MS4 Audit_20210326 Page 17 of 18 Pollution Prevention and Good Housekeeping for Municipal Operations Additional Comments: The permittee implements a base wide SPPP, which includes a comprehensive SPCC and housekeeping program to collectively address pollution prevention and good housekeeping. It is recommended that the permittee expand the frequency of staff stormwater training/education/outreach to ensure that facility staff are aware of the differences between SPCC and SPPP, and that there is a base wide SPPP. NCS000335_SJAFB MS4 Audit_20210326 Page 18 of 19 Industrial Activities Staff Interviewed: (Name, Title, Role) See roster of Primary MS4 Representatives Participating in Audit on page 2. Permit Citation Program Requirement Status Support ing Doc No. II.H.2.a NCG08 for Vehicle Maintenance Facilities The permittee implements the requirements of NCG08 for vehicle maintenance areas with point source discharges of stormwater, including vehicle rehabilitation, mechanical repair, painting, fueling, lubrication, equipment cleaning operations and like activities. Yes 7, 20, 24 II.H.2.b NCG15 for Air Transportation Facilities The permittee implements the requirements of NCG15 air transportation for facilities with point source discharges of stormwater, including air transportation, airports, aircraft service and maintenance including: aircraft cleaning, servicing/repair, maintenance shops, rehabilitation, painting, fueling, lubrication and material handling facilities. Yes 7, 20, 24 Comments: The permittee implements the base wide SPPP, MS4 permit monitoring, and SPCC for eight facilities subject to NCG08 and 22 facilities subject to NCG15. Runoff from these facilities is routed to the sanitary sewer wherever possible and outdoor, uncovered activities are performed within containment areas. II.H.3 Base Wide SPPP & Monitoring Plan In lieu of complying with the requirements of paragraph 2 of this section [II.H.2] , the permittee proposed and submitted to the Division for their approval a base wide SPPP and Monitoring Plan that effectively meets the requirements to develop, maintain and implement a SPPP and Monitoring Plan for each facility and/or area with an industrial activity covered by this permit. Yes 3, 7, 8, 24, 29, 30 Comments: The permittee has an approved base wide SPPP in eDASH and proposed monitoring was incorporated into the MS4 permit conditions. II.J.1.d. Base Wide SPPP & Monitoring Plan Qualitative monitoring is performed twice per year (spring and fall) at each stormwater outfall associated with industrial activities and/or oil water separators regardless of representative outfall status. Yes 12, 16 NCS000335_SJAFB MS4 Audit_20210326 Page 19 of 20 Industrial Activities Comments: The permittee performs required qualitative monitoring and maintains appropriate documentation in EASIER. Additional Comments: The permittee implements a comprehensive program to perform good housekeeping, minimize pollutant potential and maintain documentation of required monitoring for subject industrial facilities. With a capacity of 2.9M gallons, the fuel tank farm may be subject to individual industrial stormwater permitting. Please work with the DEQ Washington Regional Office to obtain any necessary permits for this facility. NCS000335_SJAFB MS4 Audit_20210326 Page 20 of 21 Oil Water Separators (OWS) Staff Interviewed: (Name, Title, Role) See roster of Primary MS4 Representatives Participating in Audit on page 2. Permit Citation Program Requirement Status Support ing Doc No. Section I Oil Water Separators The permittee developed an inventory of oil water separators that discharge to either the stormwater system, directly into the waters of the state, or have engineered diversionary catchment basins. If yes, the inventory includes: Yes 8 The location of the oil water separator Yes 8 The activities that occur in the oil water separator’s drainage area Yes 8 The materials that are handled in the drainage area Yes 8 The name of the water body to which it drains Yes 8 The number of the outfall that the oil water separator discharges into Yes 8 The drainage area draining into the oil water separator Yes 8 The oil water separator’s design capacity Yes 8 Comments: The permittee maintains a detailed inventory of oil water separators (OWS) and routes runoff/discharges from all units to sanitary sewer, with the exception of two OWS where it was not feasible to connect to sanitary sewer. Oil water separator maintenance is performed by a contract service provider on a routine and as needed basis. Additional Comments: The permittee manages the OWS and activities draining to them appropriately. NCS000335_SJAFB MS4 Audit_20210326 Page 21 of 22 Monitoring Staff Interviewed: (Name, Title, Role) See roster of Primary MS4 Representatives Participating in Audit on page 2. Permit Citation Program Requirement Status Support ing Doc No. II.J.1.a. Base Wide Analytical Monitoring The permittee performed annual quantitative monitoring at Outfalls 2, 3 and 4. If yes: Yes 16 Parameters included TSS, oil and grease, and pH. Yes 16 Cutoff concentrations were applied appropriately. Yes 16 Comments: The permittee performed required monitoring and correctly applied the permit cutoff concentrations. Additional Comments: The permittee documented the cutoff concentration rationale/decision in the annual report. NCS000335_SJAFB MS4 Audit_20210326 Page 22 of 23 Site Visit Evaluation: Facility No. 1 Facility Name: Bldg. 2115 AGE Wash Rack Date and Time of Site Visit: March 24, 2021 0940 - 1015 Facility Address: Facility Type (Vehicle Maintenance, Landscaping, etc.): Vehicle Maintenance Name of MS4 inspector(s) evaluated: Ronnie Wilson Most Recent MS4 Inspection (List date and name of inspector): Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit: Name and Title See roster of Primary MS4 Representatives Participating in Audit on page 2. Observations Facility Documentation/Training Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility-specific? The facility has a site specific SPCC Plan and is part of the base-wide SPPP. What type of stormwater training do facility employees receive? How often? Facility staff receive standard onboarding training for stormwater awareness, spill control, etc. via TEACH. All facilities have a designated UEC. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? The inspector receives standard training and on the job training. Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? The inspector was knowledgeable about the MS4 permit requirements. Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping? The inspector was knowledgeable about pollution prevention and good housekeeping. The facility was well maintained and appropriate protocols were in place. Inspection Procedures Does the MS4 inspector’s process include the use of a checklist or other standardized form? The inspector records the inspection in a field log and types up the report following the inspection. Does the MS4 inspector’s process include taking photos? The inspector utilizes photographs when specific deficiencies are found. Does the MS4 inspector’s process include reviewing the facility’s SWPPP (or similar document)? The inspector was very familiar with the SWPP and SPCC Plans. NCS000335_SJAFB MS4 Audit_20210326 Page 23 of 24 Site Visit Evaluation: Facility No. 1 Does the MS4 inspector’s process include walking the entire facility and inspecting all points of discharge? The inspector performed a comprehensive inspection. Did the MS4 inspector miss any obvious areas of concern? If so, explain: The inspector did not miss any obvious areas of concern. Does the MS4 inspector’s process include presenting the inspection findings to the facility contact? Yes, the results are reviewed with site staff and entered in the eDASH system. Inspection Results Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)? The facility did not have any corrective actions to be implemented. If compliance corrective actions were identified, what timeline for correction/follow-up was provided? N/A Notes/Comments/Recommendations It is recommended that pallets be stored under cover when possible and the outfall be inspected at every inspection. NCS000335_SJAFB MS4 Audit_20210326 Page 24 of 25 Site Visit Evaluation: Facility No. 2 Facility Name: Auto Skills Development (Hobby Shop) Date and Time of Site Visit: March 24, 2020 1115 - 1130 Facility Address: Facility Type (Vehicle Maintenance, Landscaping, etc.): Vehicle Maintenance Name of MS4 inspector(s) evaluated: John Taylor Most Recent MS4 Inspection (Date and Entity): March 2, 2021 Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit: Name and Title See roster of Primary MS4 Representatives Participating in Audit on page 2. Observations Facility Documentation/Training Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility-specific? The facility is part of the base-wide SPPP. What type of stormwater training do facility employees receive? How often? Facility staff receive standard onboarding training for stormwater awareness. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? The inspector receives standard onboarding training for designated UEC. Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? The inspector was very knowledgeable about the facility and appropriate pollution prevention and good housekeeping measures. Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping? The inspector was knowledgeable about pollution prevention and good housekeeping. Inspection Procedures Does the MS4 inspector’s process include the use of a checklist or other standardized form? The standard protocol includes use of a standard checklist. Does the MS4 inspector’s process include taking photos? The inspector does not utilize photographs when specific deficiencies are found, but remedies them immediately. Does the MS4 inspector’s process include reviewing the facility’s SWPPP (or similar document)? Yes. NCS000335_SJAFB MS4 Audit_20210326 Page 25 of 26 Site Visit Evaluation: Facility No. 2 Does the MS4 inspector’s process include walking the entire facility and inspecting all points of discharge? The inspector performed an inspection of indoor activities, but did not include the stormwater collection system. There were no exposed activities. Did the MS4 inspector miss any obvious areas of concern? If so, explain: The inspector did not miss any obvious areas of concern.. Does the MS4 inspector’s process include presenting the inspection findings to the facility contact? The inspector is the facility contact. 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? N/A Notes/Comments/Recommendations The inspector performed a comprehensive evaluation of activities inside the facility and maintains reports in eDASH. It is recommended that the outdoor parking areas and stormwater collections system also be included in the inspection regardless of activity/materials exposure. NCS000335_SJAFB MS4 Audit_20210326 Page 26 of 27 Site Visit Evaluation: MS4 Outfall No. 1 Outfall ID Number: Outfall #4 Date and Time of Site Visit: March 24, 2021 1135-1145 Outfall Location: Outfall Description (Pipe Material/Diameter, Culvert, etc.): RCP in Concrete Headwall Receiving Water: Stoney Creek Is Flow Present? If So, Describe (Color, Approximate Flow Rate, Sheen, Odor, Floatables/Debris, etc.): Flow was present. Pollen was present. Most Recent Outfall Inspection/Screening (Date): Days Since Last Rainfall: Inches: Name of MS4 Inspector(s) evaluated: Ronnie Wilson Observations Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? The inspector receives. Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations? The inspector had an excellent knowledge of illicit discharge indicators and investigations. Inspection Procedures Does the inspector’s process include the use of a checklist or other standardized form? Yes, a standard form is utilized. Does the inspector’s process include taking photos? Photos are utilized where specific issues are identified. Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they? The inspector did not miss any obvious indicators or maintenance issues. NCS000335_SJAFB MS4 Audit_20210326 Page 27 of 28 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)? N/A Will a follow-up outfall inspection be conducted? If so, for what reason? N/A Notes/Comments/Recommendations The inspector is well trained and very knowledgeable about the collection system, outfall and monitoring locations. Standard protocols are efficient and effective, and documentation is standardized as well. NCS000335_SJAFB MS4 Audit_20210326 Page 28 of 29 Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1 Site Name: Medical Clinic Date and Time of Site Visit: March 24, 2021 1030-1110 Site Address: SCM Type: Green Roof Baffles Most Recent MS4 Inspection (Include Date and Entity): New Facility Name of MS4 Inspector(s) evaluated: Most Recent MS4 Enforcement Activity (Include Date): N/A Name(s) and Title(s) of Site Representative(s) Present During the Site Visit: Name and Title See roster of Primary MS4 Representatives Participating in Audit on page 2. Observations Site Documentation Does the site have an operation and maintenance plan? Yes. The SCMs are subject to a standard O&M plan. Does the site have records of annual inspections? Are they performed by a qualified individual? Yes. Inspection documents are maintained in a standardized records retention system and inspections are performed by qualified individuals. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? The inspector received on the job training and a checklist from the installer. Did the MS4 inspector appear knowledgeable about MS4 requirements for post-construction site runoff controls? Yes. The inspector as knowledgeable about the purpose, design and function of the SCM. Did the MS4 inspector appear knowledgeable about post-construction BMPs (general purpose/function, components, O&M requirements, etc.)? Yes. The inspector was knowledgeable about the SCMs, their purpose, function, design, and O&M requirements. Inspection Procedures Does the MS4 inspector’s process include the use of a checklist or other standardized form? What format? Yes. The inspector utilizes a standard inspection form and database. Does the MS4 inspector’s process include taking photos? Photos are utilized where specific issues are identified. NCS000335_SJAFB MS4 Audit_20210326 Page 29 of 30 Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1 Does the MS4 inspector’s process include reviewing the site’s operation and maintenance plan and records of annual inspections? Yes. The inspector was familiar with the location and content of the previous inspections and the O&M Plan. Does the MS4 inspector’s process include walking the entire site and inspecting all points of discharge? The inspector walked the site, reviewed the entire device but did not inspect all points of discharge. Did the MS4 inspector miss any obvious operation and maintenance deficiencies? If so, explain: The inspector did not miss any obvious deficiencies. Does the MS4 inspector’s process include presenting the inspection findings to the site contact in writing? Yes. The inspector utilizes a standardized system to document and report findings. Compliance/Enforcement What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in? N/A If compliance issues were identified, what timeline for correction/follow-up was provided? N/A Notes/Comments/Recommendations The inspector performs a comprehensive evaluation of the devices with a focus on water quality and device performance. NCS000335_SJAFB MS4 Audit_20210326 Page 30 of 30 APPENDIX A: SUPPORTING DOCUMENTS SUPPORTING DOCUMENTATION IS ON FILE IN THE NCDEQ PUBLIC LASERFICHE PORTAL.