202104 Forsyth WS Gap Analysis

WSWP Audit Preparation Review
Gap Analysis Results
April 2021
1. SCM Plan Review and Approval
a. Create a current and accurate Salem Lake Watershed SCM spreadsheet for ensuring complete
inspection of all devices.
b. No properly executed O&M agreements, inspection and access easements, performance
securities, recorded plats, and as-builts exist for SCMs constructed 1994 — 2005 (under the
Inspections Division's purview) in the Salem Lake Watershed. These SCMs account for 75
percent of total SCMs in the Salem Lake Watershed. As a result, these improperly executed
SCMs create a current lack of enforcement capabilities for city staff to compel property owners
to maintain SCMs in compliant fashion.
c. No Salem Lake NOV template exists, which may cause a hardship for staff to issue a NOV in an
expeditious manner (as well as potentially jeopardizing the legal -binding nature of the created
document).
d. Perform a gap analysis of Salem Lake Ordinance to state's WSWP Ordinance, which was
updated July 22, 2013. To the best of staff s knowledge, a gap analysis has never been
performed on the Salem Lake Ordinance.
2. SCM Inspection
a. Operation and Maintenance Certification
i. Ensure all Inspectors are O&M certified. If Inspectors are not certified, but learning the
SCM inspection process, ensure that a certified employee completes and signs the
inspection form.
ii. Maintain an active list of Stormwater employees, who are O&M certified, including
license number and expiration date.
iii. Document all performed SCM inspection training activities, either on-the-job or external
learning classes
b. Forms
i. Ensure that inspection forms contain all revised NC DEQ SCM information, which was
updated 11/23/20.
ii. Ensure that WSWP and Salem Lake Ordinance regulatory information is contained in
inspection forms (e.g. 30' length of vegetative filter from wet pond outlet, 3' minimum
normal pool depth of wet ponds, etc.).
iii. Ensure that the appropriate inspection form is used for the specific SCM
iv. Ensure that each SCM has a corresponding inspection form
c. Approved Plans
i. Inspectors must have a copy of the SCM approved plan during site inspection to
determine proper operation.
d. Accessibility
i. Ensure that Inspectors have access to SCMs, as required by Salem Lake Ordinance
(Inspection Access Easements)
e. Improper Rating of SCM Condition (i.e. Good, Minor, and Poor)
i. Perform supplementary training to ensure Inspectors properly diagnose SCM condition
1. Scotland Ridge, Pond A —designed for the minimum 3' pool, but PY 2021
annotations state wet pond not holding the proper amount of water. Violation of
Salem Lake ordinance but denoted as a `minor' issue.

2. Vernon Farms Pond #3 —received a `Good' rating during PY 2021, but not
holding water.
f. Failure Resolution
i. Ensure that denoted deficiencies are successfully completed and properly tracked on
designated spreadsheet
ii. Disconnect of yearly SCM status, despite no maintenance activities completed (e.g.
Vernon Farms Pond #3) — went from `poor' in PY 2020 to `good' in PY 2021.
Action Item List to Complete Prior to WSWP Audit, which is scheduled for April 27, 2021
Create an accurate spreadsheet of all SCMs within the Salem Lake Watershed so that city staff can
ensure SCMs are accounted and inspected. Have staff update spreadsheet, as needed, with a
comprehensive review on an annual frequency (Joe).
2. Create a very brief strategic outline (i.e. SOPs) for attempting to obtain missing O&M agreements,
inspection and access easements, performance securities, recorded plats, and as-builts for Salem Lake
SCMs, which were constructed 1994 — 2005 (Andy).
3. Attempt to locate a WSWP NOV template from a sister community that one can modify for the
city/county to have on -hand, if the need arises (Matt).
4. SCM Inspection Process (Jamal)
a. Create a list of active O&M certified city professionals - please include certification number and
expiration date.
b. When SCM O&M training is performed, please complete a training log sheet.
c. Reinspect selected SCMs in the Salem Lake Watershed, since numerous PY 2021 forms are
incomplete. Please use current the SCM evaluation form; city staff will transition to a new wet
detention inspection form in PY 2022 (on city's post -construction website).
i. Ensure each SCM has its own corresponding inspection form.
ii. Ensure each inspection form is properly completed with applicable information annotated
in all corresponding fields, regardless of overall SCM condition.
iii. Ensure that Inspectors use the appropriate inspection form for the two bioretention cells
iv. Numerous errors were observed during the gap analysis process (e.g. no filed pictures for
several SCM locations, no annotations of `poor' rating SCMs on the master inspection
spreadsheet, etc.). Please have staff verify all inspection flow -processes for
programmatic completeness and rectify all missing and/or amended information.
v. Since Joe's handwritten SCM schematic drawings (contained within the Salem Lake
BMP Route book) are based on corresponding approved plans, please have the Inspectors
reference this information when completing inspection forms.