HomeMy WebLinkAboutNCS000395_CMS MS4 AUDIT REPORT_20210505
MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM AUDIT REPORT
NPDES PERMIT NO. NCS000395
Charlotte-Mecklenburg Schools, North Carolina
Audit Date: April 26, 27, & 30, 2021
Report Date: May 5, 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
2021 MS4 Compliance Audit Report i
NPDES Permit No. NCS000395 – Charlotte-Mecklenburg Schools, NC
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2021 MS4 Compliance Audit Report ii
NPDES Permit No. NCS000395 – Charlotte-Mecklenburg Schools, NC
TABLE OF CONTENTS
Audit Overview ............................................................................................................................................. 1
Executive Summary ....................................................................................................................................... 1
Permittee Information .................................................................................................................................. 2
Supporting Documents ................................................................................................................................. 4
Pollution Prevention and Good Housekeeping for Municipal Operations ................................................... 5
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.
2021 MS4 Compliance Audit Report iii
NPDES Permit No. NCS000395 – Charlotte-Mecklenburg Schools, NC
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2021 MS4 Compliance Audit Page 1 of 9
NPDES Permit No. NCS000395 – Charlotte-Mecklenburg Schools, NC
Audit Overview
Audit ID Number:
NCS000395_CMS MS4 Audit_20210430
Audit Date(s):
April 26, 27 and 30, 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
☐ 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: Municipal Stormwater Control Measures. Number visited: Choose an item.
☐ Other: ________________________________. Number visited: Choose an item.
Auditor: Jeanette Powell, MS4 Program Coordinator
Signature__________________________________________
Date: May 5, 2021
Executive Summary
The co-permittee was well prepared and staff are very knowledgeable. Appropriate pollution prevention
and good housekeeping measures are implemented and documented.
Charlotte Mecklenburg Stormwater Services (CMSWS) leads and coordinates a comprehensive watershed-
based Phase II MS4 Program, which goes above and beyond the Phase II requirements to address local water
quality impacts and issues. The program framework and tools provide consistency and structured
regulatory compliance to the MS4s under this permit; and also coordinates with the City of Charlotte Phase I
MS4 program and requirements. CMSWS provides exceptional leadership, guidance and attention to detail
for all nine permittees. The eight co-permittees are engaged, knowledgeable and well versed in stormwater
management protocols and their specific responsibilities, as defined in an annual Work Plan. The suite of
custom and commercial program management tools, SOPs, templates and databases form the
comprehensive framework for stormwater management program asset and task management, reporting,
and assessment. This program is a shining example of how co-permittee relationships work to provide local
water quality benefits through consistent regional implementation.
2021 MS4 Compliance Audit Page 2 of 9
NPDES Permit No. NCS000395 – Charlotte-Mecklenburg Schools, NC
Permittee Information
MS4 Permittee Name:
County of Mecklenburg
Permit Effective Date:
February 17, 2017
Permit Expiration Date:
February 16, 2022
Address:
2145 Suttle Ave, Charlotte NC 28208-5237
Last MS4 Inspection/Audit:
November 10, 2015
Co-permittee(s), if applicable:
Towns of Cornelius, Davidson, Huntersville, Matthews, Mint Hill, Pineville
Charlotte-Mecklenburg Schools
Central Piedmont Community College
Permit Owner of Record: W.D. Canaan
Primary MS4 Representatives Participating in Audit
Mitchell, Jeff Manager Env. Services & Stewardship
Glover, Isiah EHS Specialist
Rozzelle, Rusty CMSWS Program Manager
Farmer, Richard L CMSWS Environmental Supervisor
Priddy, Corey CMSWS Environmental Supervisor
MS4 Receiving Waters
See Supporting Document 1
2021 MS4 Compliance Audit Page 3 of 9
NPDES Permit No. NCS000395 – Charlotte-Mecklenburg Schools, NC
2021 MS4 Compliance Audit Page 4 of 9
NPDES Permit No. NCS000395 – Charlotte-Mecklenburg Schools, NC
Supporting Documents
Item
Number Document Title When Provided
(Prior to/During/After)
01 Mecklenburg County MS4 Audit Report, May 5, 2021 On File
02 Stormwater Pollution Prevention Plan (SPPP) Demonstrated
03 Example SPPP & SPCC After
04 Training Log Demonstrated
2021 MS4 Compliance Audit Page 5 of 9
NPDES Permit No. NCS000395 – Charlotte-Mecklenburg Schools, NC
Pollution Prevention and Good Housekeeping for Municipal Operations
Staff Interviewed:
(Name, Title, Role)
Mitchell, Jeff Manager Env. Services & Stewardship
Glover, Isiah EHS Specialist
Rozzelle, Rusty CMSWS Program Manager
Farmer, Richard L CMSWS Environmental Supervisor
Priddy, Corey CMSWS Environmental Supervisor
Permit Citation Program Requirement Status Supporting
Doc No.
II.G.2.a
Facility Inventory
The permittee maintained a current inventory of facilities and operations owned
and operated by the permittee with the significant potential for generating
polluted stormwater runoff.
Yes 1
Comments
The co-permittee has identified a total of seven (7) facilities with significant potential for generating polluted
stormwater runoff. The Building Services Facility functions similarly to a municipal public works facility. There are a
total of six (6) garages and one (1) school with bus parking and mobile fueling. ASTs are double walled and the
Fuelmaster system prevents unauthorized fueling. Facilities are evaluated based on CMSWS standard criteria.
II.G.2.b
Operation and
Maintenance (O&M)
for Facilities
The permittee maintained and implemented an O&M program for municipally
owned and operated facilities with the significant potential for generating polluted
stormwater runoff.
Yes 1 - 3
If yes, the O&M program specifies the frequency of inspections. Yes ---
If yes, the O&M program specifies the routine maintenance requirements. Yes ---
If yes, the permittee evaluated the O&M program annually and updated as
necessary. Yes ---
Comments
The co-permittee maintains a SPPP for each site in a binder and digitally. The site-specific SPPPs were developed utilizing the
CMSWS standard SPPP template. The SPPPs incorporate appropriate SPCC requirements. The SPPP addresses storage, waste,
spill and leaks, non-stormwater discharges, SOPs, training records, preventive maintenance and good housekeeping measures.
SPPPs also include a spill plan, evaluation of BMPs, inspections, cleanup contractor contacts and reporting information. CMSWS
performs an annual compliance inspection of each SPPP facility, and the co-permittee performs at least one additional inspection
of each facility, which results in semi-annual inspections.
II.G.2.c
Spill Response
Procedures
The permittee has written spill response procedures for municipally owned or
operated facilities. Yes 1, 2
2021 MS4 Compliance Audit Page 6 of 9
NPDES Permit No. NCS000395 – Charlotte-Mecklenburg Schools, NC
Pollution Prevention and Good Housekeeping for Municipal Operations
Comments
The facility SPPP includes appropriate spill response procedures, which include specific actions to be taken to prevent
and respond to spills, clean up contractors, reporting protocols, etc. Staff easily located the spill procedures in the
SPPP.
II.G.2.d and e
Streets, Roads, and
Public Parking Lot
Maintenance
The permittee evaluated BMPs to reduce polluted stormwater runoff from
municipally-owned streets, roads, and public parking lots within the corporate
limits.
Yes 1
If yes, the permittee updated the Stormwater Plan within 12 months to include
the selected BMPs. Yes -
The permittee evaluated existing and new BMPs annually that reduce polluted
stormwater runoff from municipally-owned streets, roads and public parking lots
within the corporate limits.
Yes 1
If yes, the permittee evaluated the effectiveness of these BMPs based on cost
and estimated quantity of pollutants removed. Yes -
Comments
CMSWS has evaluated BMPs for reducing the discharge of floatables and other pollutants from streets and parking
lots. The co-permittee cleans streets and parking lots in identified problem areas and performs seasonal leaf pickup.
Problem areas are identified based on accumulations of leaves, trash, debris, blockages, flooding, etc. The co-
permittee provides trash receptacles at parking lots and performs scheduled manual trash pick-up. The co-permittee
maintains records documenting the number of streets and parking lots cleaned, and the pounds of trash, sediment,
and other pollutants removed, as well as the estimated cost of the program. This data is provided to CMSWS
annually for use in evaluating program effectiveness and annual reporting. CMSWS performs an annual cost-benefit
evaluation for housekeeping measures performed on municipal streets and parking lots and collection systems. The
costs and quantity of pollutants removed are benchmarked to established metrics to determine effectiveness.
II.G.2.f
O&M for Catch
Basins and
Conveyance Systems
The permittee maintained and implemented an O&M program for the stormwater
sewer system including catch basins and conveyance systems that it owns and
maintains.
Yes 1
Comments
The co-permittee cleans catch basins and conveyance systems and repairs the MS4 in identified problem areas. These
problem areas are identified based on accumulations of leaves, trash, debris, blockages, flooding, etc. The co-
permittee maintains records documenting the number of inlets, outlets and pipes cleaned and the pounds of trash,
sediment, and other pollutants removed. This data is provided to CMSWS annually for use in evaluating program
effectiveness and for inclusion in the annual report. CMSWS performs an annual cost-benefit evaluation for
collection systems owned and operated by the co-permittee. The costs and quantity of pollutants removed are
benchmarked to established metrics to determine effectiveness.
2021 MS4 Compliance Audit Page 7 of 9
NPDES Permit No. NCS000395 – Charlotte-Mecklenburg Schools, NC
Pollution Prevention and Good Housekeeping for Municipal Operations
II.G.2.g
O&M for Municipal
Structural
Stormwater Controls
The permittee maintained a current inventory of municipally-owned or operated
structural stormwater controls installed for compliance with the permittee’s post-
construction ordinances adopted by Mecklenburg County and the Towns of
Cornelius, Davidson, Huntersville, Matthews, Mint Hill, and Pineville on June 30,
2007 and by the City of Charlotte on July 1, 2008.
Yes 1
The O&M program specifies the frequency of inspections and routine maintenance
requirements. Yes 1
The permittee inspects and maintains municipally-owned or maintained structural
stormwater controls in accordance with the schedule developed by permittee. Yes 1
The permittee documented inspections and maintenance of all municipally-owned
or maintained structural stormwater controls. Yes 1
Comments
The co-permittee has a current inventory of twenty-three (23) municipal SCMs installed to comply with the Phase II
MS4 permit requirements. CMSWS inspects the Phase II SCMs annually and provides the reports to the co-permittee
for maintenance and/or resolution of any identified issues. Required maintenance and/or remedies are contracted
and verified as completed. The co-permittee inspects the SCMs once per year and maintains appropriate operation
and maintenance manuals.
II.G.2.h
Pesticide, Herbicide
and Fertilizer
Application
Management
The permittee ensured municipal employees are properly trained in pesticide,
herbicide and fertilizer application management. Yes 1
The permittee ensured contractors are properly trained in pesticide, herbicide and
fertilizer application management. Yes 1
The permittee ensured all permits, certifications, and other measures for
applicators are followed. Yes 1
Comments
The co-permittee maintains training and certification records in their SPPPs. CMSWS verifies that staff have maintained current
pesticide applicator certifications and training requirements as a standard component of each annual facility inspection.
Pesticide, herbicide and fertilizer contractors are required by contract to be certified and standard requirements for certification
includes training.
2021 MS4 Compliance Audit Page 8 of 9
NPDES Permit No. NCS000395 – Charlotte-Mecklenburg Schools, NC
Pollution Prevention and Good Housekeeping for Municipal Operations
II.G.2.i
Staff Training The permittee implemented an employee training program for employees involved
in implementing pollution prevention and good housekeeping practices. Yes 1, 4
Comments
CMSWS provides training and materials to the co-permittee. The co-permittee maintains training logs and reports to
CMSWS. Standard training includes a video featuring stormwater awareness, identification of issues and reporting
mechanisms. The training teaches the “street to stream” concept and is provided to staff who may identify issues
during their routine duties. The co-permittee utilizes quiz’s to determine training effectiveness.
Annual training is provided to the employees involved in implementing pollution prevention and good housekeeping
practices at the CMS operated facilities. Training is also provided for other employees involved in operations that
have the potential to cause negative water quality impacts. The goal of this training is to inform employees of the
actions necessary to reduce the discharge of pollution and protect water quality, as well as provide the steps for
reporting suspected illicit discharges and actions required for compliance with permit requirements.
II.G.2.j
Vehicle and
Equipment Cleaning
The permittee described and implemented measures that prevent or minimize
contamination of the stormwater runoff from all areas used for vehicle and
equipment cleaning.
Yes 1, 2
Comments
The SPPPs include a detailed evaluation of site operations and characteristics, which includes vehicle and equipment
cleaning. The primary goal is to eliminate exposure wherever feasible and implement appropriate SOPs where
exposure cannot be eliminated.
2021 MS4 Compliance Audit Page 9 of 9
NPDES Permit No. NCS000395 – Charlotte-Mecklenburg Schools, NC
APPENDIX A: SUPPORTING DOCUMENTS
SUPPORTING DOCUMENTATION IS ON FILE IN THE ONLINE
STORWATER PROGRAM LASERFICHE REPOSITORY