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NCS000407_NOV With Green Card_20210610
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O •�U to '� 6 O E N .F O N O =_ C y78 o,S ma i .loco {FL7 0= o� °9'� o `°c6oE 3c' 3 o9.8 tc1O°�m �r� • fir --�a9i 'm ai as 2E ig —6 ten C .� y B E LE �•ti.o 'n tv d m C mlLh Z_ a-hm=wLudI oETw �.•S °•o' > 9.r+ °w_' 0� o !�2� m to $�� o o c d �E to �'.oa O W?c�amn C�_io o°�i�-'ua �aEio E_�o=.G Ev�!!��E t`c°L a�i `�� c2 v Ec°'aC` •C M —'_—�— Q a� y ._ c 'E ppm 'o m¢ o Y a� 8 Q o e 0 a T 0 O_ N 'O O M ri r•i (CQ aJ +� 00 N ui O Ln tV c a co a ai O a a) 0 V EC C �� i Q 3 I o?S C L + O Z LLJ U N LL o U Z Lip o° p'•L�dA a+o L ��r rr 11 -0- ` V Lnj Q) Er may, O� ru 0 Cc o-' m -0 C) Er r- fU M -7 ru 1 „DFgcuSign Envelope ID: D05BB852-F220-4CEF-9911-292ACC49FDF1 ROY COOPER Governor- DIONNE DELLI-GATTI Secretary 41 BRIAN WRENN NORTH CAROL-INA Director Environmental Quality June 4, 2021 CERTIFIED MAIL RETURN RECEIPT REOUESTED City of Mount Holly Attention: Miles Braswell, City Manager, Owner Post Office Box 406 Mount Holly, North Carolina 28120-0406 7017 2620 0000 6788 0462 CERTIFIED MAIL 7017 2620 0000 6788 0455 RETURN RECEIPT REQUESTED City of Mount Holly Attention: Robert Whitt, Mayor, Co-owner Post Office Box 406 Mount Holly, North Carolina 28120-0406 Subject: NOTICE OF VIOLATION (NOV-2021-PC-0303) City of Mount Holly NPDES MS4 Permit No. NCS000407 Gaston County Dear Mr. Braswell and Mr. Whitt, On May 24, 2021, staff from the North Carolina Department of Environmental Quality (DEQ) conducted a compliance audit of subject National Pollutant Discharge Elimination System (NPDES) Municipal Separate Storm Sewer System (MS4) Permit. The audit identified major deficiencies with the specific components of the MS4 permit that were reviewed, as provided in the attached DEQ MS4 Permit Compliance Audit Report. This report lists and describes the serious deficiencies with certain components of the MS4 permit, which constitutes a violation of the Clean Water Act and is grounds for enforcement action. In accordance with Part V1 of the permit and DEQ policy, a new 5-year MS4 permit will be issued in response to the audit. To address the MS4 permit deficiencies, the City of Mount Holly is required to complete the following actions: (1) Respond in writing within thirty (30) calendar days from the date of receipt of this notice to acknowledge these requirements and the intent to comply. (2) Adopt a Council Resolution within sixty (60) calendar days from the date of receipt of this notice. The resolution must declare support for a compliant stormwater North Carolina Department of Environmental Quality 1 Division of Energy, Mineral and Land Resources FEW Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115 at�mY 1�l 704.663.1699 _ . DocuSign Envelope ID: D05BB852-F220-4CEF-9911-292ACC49FDF1 Notice of Violation City of Mount Holly June 4, 2021 Page 2 of 3 management program. A sample council resolution with the minimum requirements is enclosed with this letter. An original signed document must be submitted to DEQ. (3) Submit documentation for review and comment within one hundred twenty (120) calendar days from the date of receipt of this letter: a. The Illicit Discharge Detection and Elimination Program Plan, as required in Part II, Section A.7. and Section D.2.a. of the current permit. b. The MS4 Operation and Maintenance Program Plan, as required in Part II, Section A.7. and Section G.21 of the current permit. c. The Municipal SCM Operation and Maintenance Program Plan, as required in Part II, Section A.7. and Section G.2.g. of the current permit. d. Conduct a self -audit which includes, at a minimum, an evaluation of compliance with the permit conditions found in Part II Section E: Construction Site Runoff Controls; Section F: Post -Construction Site Runoff Controls; Section H: Total Maximum Daily Loads. The self -audit must be documented utilizing the appropriate sections of the DEQ standard MS4 Permit Compliance Audit Report Template. e. Develop a Draft Stormwater Management Plan (SWMP) which details specific actions, measurable goals, and implementation timelines to bring the stormwater management program into compliance with NPDES MS4 requirements over the new 5-year permit term. The SWMP must be documented utilizing the DEQ Phase II MS4 SWMP Template. The SWMP must address all known compliance deficiencies including, at a minimum, the items detailed in the DEQ MS4 Program Audit Report and the City of Mount Holly self -audit. (4) Submit an NPDES MS4 permit application within thirty (30) days of receiving written DEQ concurrence that the submitted Draft SWMP documents a compliant stormwater management program. A new 5-year NPDES MS4 permit will be public noticed along with the submitted SWMP. (5) Respond to public comments on the Draft SWMP and submit a Final SWMP for DEQ approval and final permit issuance. The final DEQ-approved SWMP shall become an enforceable component of the NPDES MS4 permit. Required documentation shall be submitted via e-mail to jesse.mcdonnell(a,ncdenr.gov, or to: DEQ-DEMLR Stormwater Program Attention: Jesse McDonnell 610 East Center Avenue Mooresville, North Carolina 28115 DO E nYSani caati�n�z Oe� nnunn M rm9wxwma� Ai�dry North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 2811[5 704,663.1699 , DocuSign Envelope ID: D05BB852-F220-4CEF-9911-292ACC49FDF1 Notice of Violation City of Mount Holly June 4, 2021 Page 3 of 3 If the City of Mount Holly fails to meet the aforementioned requirements and/or submits a significantly noncompliant Draft SWMP, DEQ may proceed with enforcement. As is stated in Part V, Section A.I (c) of the permit: Under state law, a daily civil penalty of not more than twenty-five thousand dollars ($25, 000) per violation may be assessed against any person who violates or fails to act in accordance with the terms, conditions, or requirements of a permit [North Carolina General Statute 143-215.6A]. Please note that compliance with the requirements of this notice and/or issuance of civil or criminal penalties levied by DEQ does not preclude the EPA from carrying out its own enforcement case against the permittee. Thank you for your attention to this matter. Should you have any questions, please contact Jesse McDonnell at (704) 235-2139 or jesse.mcdonnell&ncdenr.L-,ov. Sincerely, DocuSigned�b'y,: A'A ti b ' v 42CFABFC568C459... Zahid S. Khan, CPM, CPESC, CPSWQ Regional Engineer Land Quality Section Division of Energy, Mineral and Land Resources Enclosures: DEQ MS4 Permit Compliance Audit Report Example Council Resolution ec: Kimberly. Sturgis@mtholly.us, City of Mount Holly Stormwater Coordinator Annette.Lucas@ncdenr.gov, DEMLR Stormwater Program Supervisor Jeanette.Powell@ncdenr.gov, DEMLR MS4 Program Coordinator DEMLR NPDES MS4 Permit Laserfiche File HCNorth Carolina Department of Environmental Quality 4 Division of Energy, Mineral and Land Resources Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115 rx. �FHC�A-QURA yaw ma*;ws +� /�"� 704.663.1699 IUD WIPAL SEPARATE STORM SEVAIER SYSTEM/ (M54) PROGRAM ° AM AUDIT REPORT NPI)ES PERMIT NO. NCS000407 Mount Holly, NORTH CAROLINA 400 East Central Avenue, Mount Holly, North Carolina 28120 Audit Date- Miley 24, 2021 Report Date. June 4, 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 (This page intentionally left blank) NCS000407_Mount Holly MS4 Audit_20210524 TABLE OF CONTENTS AuditDetails..................................................................................................................................................1 PermitteeInformation..................................................................................................................................2 List of Supporting Documents.......................................................................................................................3 Program Implementation, Documentation & Assessment............................................................... :........... 4 Public Education and Outreach.....................................................................................................................7 Public Involvement and Participation...........................................................................................................8 Illicit Discharge Detection and Elimination(IDDE)........................................................................................9 Pollution Prevention and Good Housekeeping for Municipal Operations..................................................11 Site Visit Evaluation: Municipal Facility No. 1.............................................................................................13 Site Visit Evaluation: Municipal Facility No. 2.............................................................................................15 Site Visit Evaluation: Municipal Facility No. 3.............................................................................................17 Site Visit Evaluation: MS4 Outfall No. 1......................................................................................................19 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1............................................21 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. NCS000407_Mount Holly MS4 Audit_20210524 ii This page intentionally left blank NCS000407_Mount Holly MS4 Audit_20210524 Audit ID Number: Audit Date(s): NCS000407—Mount Holly MS4 Audit_20210524 May 24-25, 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. Numbervisited: 3 ® 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 tem. ❑ Other: Number visited: Choose an item. 1r "'Ode(s) Ct �duciing al�ci ti Narr9e, title Organization Jesse McDonnell, Environmental Specialist North Carolina Department of Environmental Quality Christopher Graybeal, Assistant Regional Engineer North Carolina Department of Environmental Quality Audit Report Author: Jesse McDonnell Date: I �f �� 1 June 4, 2021 Signature ; : f�/111) Audit Report -Author: Christopher Graybeal Date: L, June 4, 2021 Signature-.4_ NCS000407_Mount Holly MS4 Audit_20210524 Page 1 of 22 MS4 Permittee Name: Town of Mount Holly Permit Effective Date: February 2017 Permit Expiration Date: February 2022 Mailing Address: P.0 Box 406, Mount Holly, North Carolina 28120 Date of Last MS4 Inspection/Audit: June 5, 2012 Co-permittee(s), if applicable: Permit Owner of Record: Miles Braswell, City Manager; Robert Whitt, Mayor, Co -Owner; David Johnson, Utilities Director, Signature authority wa u i s8c �� �v ��$u0�a David Johnson, Utilities Director City of Mount Holly Kimberly Sturgis, Stormwater Coordinator City of Mount Holly Derek Dixon, Site Inspector City of Mount Holly 6gairm" Taylors Creek WS-IV None Known Fites Creek WS-IV None Known Dutchman's Creek WS-IV Turbidity Stanley Creek WS-IV None Known South Stanley Creek WS-IV None Known NCS000407_Mount Holly MS4 Audit_20210524 Page 2 of 22 yT gtgy t i 1 S Y agag �s i3Fy.t' ``5 Lam. .. £% ih`£ r� w4.�'3. `c �% - Y tom` ¢yQQppFyc L) �1� 12�i-.�d 3h< 3,YN r+ i ?. t f .31E L d :F:ti.. <. i` v` 4 .... a '.. ^S 'S <%�` �1s, ���.. ..� hl 3• E .& x' ,� } _9y'K' }�� �"�'_..'+J � � 1 Interlocal Agreement with Gaston County Prior to 1N 2 Mount Holly Website Prior to https://www.mtholly.us/ 3 IDDE ordinance After 4 Training Logs Prior to 5 Map of Municipally Owned Facilities After 6 Street Sweeper Hour Logs After 7 IDDE Response and Inspection After f 8 Pesticide and Herbicide Applicator Licenses After i NCS000407_Mount Holly MS4 Audit_20210524 Page 3 of 22 Kimberly Sturgis, Stormwater Coordinator �¢i 1ctf�eesbetnr r David Johnson, Utilities Director Derek Dixon, Site inspector �y{ -. � n�. Li ps•'r ■iR•4 The permittee maintained adequate funding and staffing to implement and manage S�: 41169, and No - the provisions of the Stormwater Plan and meet all requirements of the permit. Funding The Stormwater Plan identifies a specific position(s) responsible for the overall No coordination, implementation, and revision to the Plan. 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 Yes RIMS monitoring fees (see stormwater e-payments on DEMLR MS4 web page). Comments: The City currently has a small stormwater fee of $2.50/Residential Equivalent Unit (ERU)/month. Based on the audit, funding is not sufficient for this program. The City does not have a current Stormwater Management Plan (SWMP). The City was operating under the 2010-2015 SWMP. The stormwater fee is up to date with no balance due. I -NA2 Stair,�trsatev _m The permittee evaluated the performance and effectiveness of the program Plan components at least annually. No and Eval agora If yes, the permittee used the results of the evaluation to modify the program Not components as necessary to accomplish the intent of the Stormwater Program. Applicable Did the permitted MS4 discharges cause or contribute to non -attainment of an No - - applicable water quality standard? If yes, did the permittee expand or better tailor its BMPs accordingly to address Not the non -attainment? Applicable ___ Comments: No documentation. 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. No --- Comments: The City did not maintain the SWMP. The most recent SWMP is from 2015. No SWMP was in effect during this permit cycle. NCS000407_Mount Holly MS4 Audit_20210524 Page 4 of 22 f s i Ls f.. ,: »cvtY - YY }SS The permittee kept an up-to-date version of its Stormwater Plan available to the ���ruva��r�er Division and the public online. No The online materials included ordinances, or other regulatory mechanisms, or a list identifying the ordinances, or other regulatory mechanisms, providing the legal Yes 2 - authority necessary to implement and enforce the -requirements of the permit. Comments: The City does not have the SWMP available on the webpage. The ordinances for legal authority are on the website. storunviagep 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: No modifications were required by DEMLR. ILAX Sharing ResponsibilitV Are any control measures implemented by an entity other than the permittee? Yes 1 If yes, is there a written agreement in place? Yes 1 Comments: Gaston County Natural Resources performs erosion control inspections for the county. The permittee maintained written procedures for implementing the six minimum I wriMe" No --- control measures. procedures Written procedures identified specific action steps, schedules, resources and responsibilities for implementing the six minimum measures. No --- Comments: No documentation. iiie A The permittee maintained documentation of all program components including, but Program not limited to, inspections, maintenance activities, educational programs, No --- (���navae��i�d� ' implementation of BMPs, enforcement actions etc., on file fora period of five years. Comments: No documentation. iiio18 The permittee submitted annual reports to the Department vui 10 rttE�ft i ptueat,i Nepor fre�m the efnr,ivel €patio of the:*pti (See Section III. B. for the annual reporting No -- 514fownifi7ai period specific to this MS4). The permittee submitted subsequent annual reports every twelve months from the scheduled date of the first annual report submittal. Yes Laserfiche The Annual Reports included appropriate information to accurately describe the progress, status, and results of the permittee's Stormwater Plan, including, but not limited the following: 1. A detailed description of the status of implementation of the Stormwater Plan as a whole. This will include information on development and implementation Not of each major component of the Stormwater Plan forth e past year and Reviewed schedules and plans for the year following each report. NCS000407_Mount Holly MS4 Audit_20210524 Page 5 of 22 • � ��pH��b�V14B88 Y� �OJ&dM$9�Ki$�tlF$HB � �'� �� . {'� i&5 y' ., tom, tr.��r��,�BHtl 2. An adequate description and justification of any proposed changes to the YY Stormwater Plan. This will include descriptions and supporting information for Not the proposed changes and how these changes will impact the Stormwater Reviewed Plan (results, effectiveness, implementation schedule, etc.). _f 3. Documentation of any necessary changes to programs or practices for M, assessment of management measures implemented through th6 Stormwater Not i Reviewed } Plan. i 4. A summary of data accumulated as part of the Stormwater Plan throughout (( the along with an assessment of what the data indicates in light of the Not year Reviewed Stormwater Plan. 5. An assessment of compliance with the permit, information on the establishment of appropriate legal authorities, inspections, and enforcement Not Reviewed actions. j cotruamehft. 2018-2020 Annual reports are within Laserfiche. fx ,nu�jgai Reporting The Annual Reports document the following: i 1. A summary of past year activities, including where applicable, specific Not quantities achieved and summaries of enforcement actions. Reviewed i 2. A description of the effectiveness of each program component. Not Reviewed 3. Planned activities and changes for the next reporting period, for each Not program component or activity. Reviewed Not j 4. Fiscal analysis. Reviewed _ Comments: Not Reviewed during this audit. NCS000407_Mount Holly MS4 Audit_20210524 Page 6 of 22 Staff' ; 6t0 ipp°-edb Kimberly Sturgis, Stormwater Coordinator (l�Y� e� it, ep Roles David Johnson, Utilities Director Derek Dixon, Site inspector The permittee defined goals and objectives of the Local Public Education and And No --- Outreach Program based on community wide issues. Comments: No documentation. The permittee maintained a description of the target pollutants and/or stressors and No --- iCa��rm Pollutant likely sources. Comments: The City did not maintain a description of target pollutants and/or stressors. 11 3°0� The permittee identified, assessed annually and updated the description of the target Target Audiences audiences likely to have significant storm water impacts and why they were selected. No --- Comments: No documentation of annual assessment or updating. 111.132 ftesldeniial The permittee described issues, such as pollutants, the likely sources of those and IndustriaV pollutants, potential impacts, and the physical attributes of stormwater runoff in No --- Commercial Issues their education/outreach program. Comments: No documentation. The permittee promoted and maintained an internet web site designed to convey the G lGd��L�U�Y}l©611 Yes 2 Weio Site program's message. Comments: The City maintained an internet website with public education and outreach materials. The website is published in all stormwater educational documents. HAM The permittee distributed stormwater educational material to appropriate target The PU.Ri9llty Education --- Materials groups. Comments: No documentation. 11-°2 The permittee promoted and maintained a stormwater hotline/helpline for the Hotline/HelpYes ��e purpose of public education and outreach. 2 Comments: The City maintained a hotline on the website for the purpose of Public Education and Outreach. 10°6°2.h The permittee's outreach program, including those elements implemented locally or Public Education through a cooperative agreement, included a combination of approaches designed to Partial 2 and Outreach reach the target audiences. Program For each media, event or activity, including those elements implemented locally or through a cooperative agreement the permittee estimated and recorded the extent No --- of exposure. Comments: The City maintained the website and Facebook page. No documentation for extent of exposure. NCS000407_Mount Holly MS4 Audit_20210524 Page 7 of 22 2 h f h IT, t�-1Yt�tofd� Kimberly Sturgis, Stormwater Coordinator ��9�s�, Pitle,,Rate David Johnson, Utilities Director Derek Dixon, Site inspector qqp}��j.�5qq,,p`ap5���i£ r k"."Y F 9 6b •ice. ttarC.�ea V61 F 90 GiDMOpuMV The permittee included and promoted volunteer opportunities designed to promote No --- nww6ment ongoing citizen participation. re FaM Comments: No documentation. M&,haniIslinIf6v The provided and promoted a mechanism for public involvement that permittee No --- Public- provides for input on stormwater issues and the stormwater program. Comments: The City maintained a Stormwater Committee made of citizens. No documentation of frequency or topics of meetings. 011 C.2R.0 The and maintained a hotline/helpline for the purpose of public � permittee promoted Yes 2 E,�o�ll°na/Mellp Lin involvement and participation. FM—Ments: The City maintained a hotline on the website for the purpose of Public Involvement and Participation. NCS000407_Mount Holly MS4 Audit_20210524 Page 8 of 22 �t�t 9nWycefedr,._ Kimberly Sturgis, Stormwater Coordinator (Warfie, Tittle, David Johnson, Utilities Director Rol e) ` Derek Dixon, Site inspector � }: ffiq _ `� �� ,zr a E.. �.ie� ��'���3x5-✓a�.��. x t! �,�„ � _ := .: .,..' �C �..�., z _..��r6e5�C S'�� :.: <.c" _ pppp pp IDDE;'Pragrim The permittee maintained a written IDDE Program. No --- if yes, the written program includes provisions for program assessment and Not evaluation and integrating program. Applicable Comments: No documentation. The permittee maintained an IDDE ordinance or other regulatory mechanism(s) that provides the legal authority to prohibit illicit connections and discharges to the MS4. Yes 3 Legal AuthIoritles If yes, the ordinance applies throughout the corporate limits of the permittee. II I [Permit Part I.D] Yes 3 s Comments: The City has maintained an IDDE Ordinance since 2006 within the City limits. II.ED.�ne The permittee maintained a current map showing major outfalls and receiving StOi'M �e�er Yes 5 stem Map V � streams. i Comments: The City has maintained a map with all major outfalls. j The permittee maintained a program for conducting dry weather flow field Dry#fe�t�rj flQtn9 observations in accordance with written procedures. No e. Programs Comments: No documentation of dry weather flow program being maintained. QI.L72—e The permittee maintained written procedures for conducting investigations of hivestig,cation identified illicit discharges. Partial 7 G?iocceAres ` Comments: The City has a list of procedures for conducting an IDDE investigation. IIII.D.If For each case of an illicit discharge or potential illicit discharge, the permittee documented and tracked the f `track and following: Dact neat Investigations. 1. The date(s) the illicit discharge was observed Yes 7 2. The results of the investigation Yes 7 3. Any follow-up of the investigation Yes 7 4. The date the investigation was closed Yes 7 Comments: The City has an IDDE response sheet that documents all aspects of the IDDE investigation. NCS000407_Mount Holly MS4 Audit_20210524 Page 9 of 22 SF. .e1 LID s4"•+ -e di. :+ L er- _ e� 1{ Ee11�� The permittee implemented and documented a training program for appropriate municipal staff who, as part of their normal job responsibilities, may come into Partial 4 contact with or otherwise observe an illicit discharge or illicit connection. Comments: Only training records are from 2019 and 2020. y The permittee informed public employees of hazards associated with illegal aa9►�a�rat�trE discharges and improper disposal of waste. Partial 4 The informed businesses of hazards associated with illegal discharges and permittee No _ improper disposal of waste. The informed the general public of hazards associated with illegal permittee No discharges and improper disposal of waste. Comments: annual training was conducted for employees, only two years have documented training. No documentation for educational materials being delivered to businesses or the general public. The permittee promoted, publicized, and facilitated a reporting mechanism for the 2 public Rep6KJl 8 _. public to report illicit discharges. Partial rt The permittee promoted, publicized, and facilitated a reporting mechanism for staff Partial 2 3 to report illicit discharges. ,� Y The established and implemented response procedures for citizen permittee No requests/reports. Comments: The City maintained a hotline for the public and staff to call to report an illicit discharge. No documentation of written procedures when a report is received. AN_, R, The permittee implemented a mechanism to track the issuance of notices of violation h$f and enforcement actions administered by the permittee. No --- If yes, the mechanism includes the ability to identify chronic violators for No ___ sk' rWEs' initiation of actions to reduce noncompliance. Comments: The City tracked all IDDE reports/complaints within a spreadsheet. NCS000407_Mount Holly MS4 Audit_20210524 Page 10 of 22 �P-anutwn Pi t1� 3 �Q�7l�j7C1>>re m 1cF; ICU 0 nVfa�.i,Q0a 0— Staff lmemleitu4d> Kimberly Sturgis, Stormwater Coordinator wme',yiftcibole) David Johnson, Utilities Director Derek Dixon, Site inspector i �1+4 Y�$08141v�! 4.JGYUXAA�i�d> $ -�„ £ Y� >`. - A qS�P r.`S�,SYtl.'s'.Y`�"9ci.. - .$kON i R - `3 10a�a The permittee maintained a current inventory of facilities and operations owned FaciRV linventor and operated by the permittee with the potential for generating polluted Yes 5 stormwater runoff. Comments: The City maintained a map of all municipally owned facilities. The facilities with potential to pollute need to be identified on a separate list within the map. The permittee maintained and implemented an 0&M program for municipally operation and owned and operated facilities with the potential for generating polluted No --- Maintenance JOR& fil) stormwater runoff. for Facilities If yes, the 0&M program specifies the frequency of inspections. Not _-- Applicable i If yes, the 0&M program specifies the frequency of routine maintenance Not I I requirements. Applicable e_ If yes, the permittee evaluated the C&M program annually and updated it as Not necessary. Applicable __ f Comments: No documentation. j 81.6.2.c Sp Respoonse The permittee had written spill response procedures for municipal operations. No --- Procedures Comments: No documentation. OLGAPac9 stFeats, The permittee evaluated existing and new BMPs that reduce polluted stormwater Roa(,Y, and Ribl`ac- runoff from municipally -owned streets, roads, and public parking lots within its Partial 6 Vlavl!d g Lots corporate limits annually. If yes, the permittee evaluated the effectiveness of existing and new BMPs based on cost and the estimated quantity of pollutants removed. Partial 6 Comments: The City maintained a street sweeping schedule downtown and for problematic areas. The hours the sweeper was run each week is recorded. The permittee maintained and implemented an O&M program for the stormwater Offim for CatcGii sewer system including catch basins and conveyance systems that it owns and No --- Ocasing and ���ys4oIs _ maintains. Comments: No documentation of written 0&M program for conveyances. tOe�oo� The permittee maintained a current inventory of municipally -owned or operated Rli'ucturat structural stormwater controls installed for compliance with the permittee's post- Yes 5 Storiin@PSatev Controls construction ordinance. NCS000407_Mount Holly MS4 Audit_20210524 Page 11 of 22 '"t. _ "a N ITRI, e W-1 EVI Comments: The City maintained a map of all municipally owned facilities. The facilities with potential to pollute need to be identified on a separate list within the map. lifer The permittee maintained and implemented an 0&M program for municipally - O&M for Structural owned or maintained structural stormwater controls installed for compliance with No -- stormw:ER@e Contr®is. the permittee's post -construction` ordinance. If yes, then: The 0&M program specified the frequency of inspections and routine Not Y h maintenance requirements. Applicable - The permittee documented inspections of all municipally -owned or maintained Not structural stormwater controls. Applicable The permittee inspected all municipally -owned or maintained structural Not stormwater controls in accordance with the schedule developed by permittee. Applicable The permittee maintained all municipally -owned or maintained structural Not stormwater controls in accordance with the schedule developed by permittee. Applicable The permittee documented maintenance of all municipally -owned or Not maintained structural stormwater controls. Applicable - r Comments: No documentation of 0&M program. Inspections have been conducted on a routine basis. The permittee ensured municipal employees are properly trained in pesticide, pesticide, Herbicide herbicide and fertilizer application management. Yes � FertiWer and i Application The permittee ensured contractors are properly trained in pesticide, herbicide and Not Manage Iment fertilizer application management. Applicable -_ I The ensured all permits, certifications, and other measures for permittee Yes 8 applicators are followed. Comments: The City has three employees who are certified pesticide/herbicide applicators. The permittee implemented an employee training program for employees involved % in implementing pollution prevention and good housekeeping practices. partial 4 Comments: The City has trainings for 2019 and 2020. F,4 The permittee described and implemented measures that prevent or minimize contamination of stormwater runoff from all areas used forvehicle and equipment No -- iipimeM:£Ieaniing cleaning. Comments: No Documentation. NCS000407_Mount Holly MS4 Audit_20210524 Page 12 of 22 Facility Narne: Date and Time of Site Visit: City of Mount Holly Public Works May 25, 2021 at 9:00 am Facility Address: Facility Type (Vehicle Maintenance, Landscaping, etc.): 218 Adrian St. Vehicle and equipment maintenance and storage Mount Holly, NC 28120 Name of MS4 inspector(s) evaluated: Most Recent MS4 Inspection (List date and name of inspector): Derek Dixon None Nclm (s) and Ti$le(s) of lFacillity Present During $he Site vilat; Narne Title Facility Manager —_ Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific? No, the facility does not have a SWPPP. What type of stormwater training do facility employees receive? How often? Staff receive the illicit discharge and spill response training annually. i lnspeaor Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? The inspector has no MS4 specific training. i I I Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? No, the facility has been operating without a State Stormwater Permit. Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping? Yes. llnspectiora Pr�c�c rapes Does the M54 inspector's process include the use of a checklist or other standardized form? No. Does the MS4 inspector's process include taking photos? No. Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)? Not applicable. NCS000407_Mount Holly MS4 Audit_20210524 Page 13 of 22 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? Yes, the facility contact walked the site during the inspection. Inspection Results Did the facility inspection result in any corrective actions to be implemented? if so, for what issue(s)? Yes, the facility will need to apply for a State Stormwater Permit. The general permit number will be NCG080000 due to vehicle f maintenance. i If compliance corrective actions were identified, what timeline for correction/follow-up was provided? The facility needs to apply for coverage under NCG080000 as soon as possible. Notes/Comments/Recommendations This facility inspection became a technical assistance inspection to educate the City about the proper procedures and processes that should be used during an inspection. - i I i I NCS000407_Mount Holly MS4 Audit_20210524 Page 14 of 22 q! od(,� F uviPmat6aOm lio i1VtIju 1, k(r4rl Fa((J UK x [Ml oro Facility Name: Date and Time of Site Visit: City of Mount Holly Waste Water Treatment Plan (WWTP) May 25, 2021 at 10:00 am Facility Address: Facility Type (Vehicle Maintenance, Landscaping, etc.): -201 Broome St. Waste Water Treatment Mount Holly, NC 28120 Name of MS4 inspector(s) evaluated: Most Recent MS4 Inspection (Date and Entity): Derek Dixson None f Mavnn(s) and TiNe( ) of Facility Repv senteative(s) Present MirinS the site Visit: Name Title Doug Facility Supervisor rFadility Ducumentation/Training fDoes the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific? Yes. i I j What type of stormwater training do facility employees receive? How often? f The facility staff receive spill prevention and response and IDDE identification training annually. j i fins nct®r -9rainin Knowledge What type of stormwater training does the MS4 inspector receive? How often? None. i — ` Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? No. I Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping? Yes. QBIspe gi©n Procedures Does the MS4 inspector's process include the use of a checklist or other standardized form? No. Does the MS4 inspector's process include taking photos? No. Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)? No. NCS000407_Mount Holly MS4Audit_20210524 Page 15 of 22 rDese MS4 inspector's process include walking the entire facility and inspecting all points of discharge? 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? Yes, the facility supervisor inspected the site along with the MS4 inspector. lnspection Results Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)? It is recommended to construct secondary containment around totes that are not inside or under cover. If compliance corrective 'actions were identified, what timeline for correction/follow-up was provided? No timeline was provided to have the repairs corrected. Dotes/Coanments/Recomnit,ndations This facility inspection became a technical assistance inspection to educate the City about the proper procedures and processes that should be used during an inspection. !I I NCS000407_Mount Holly MS4 Audit_20210524 Page 16 of 22 Facility Name: Date and Time of Site Visit: City of Mount Holly Fire Department May 25, 2021 at 11:00 am Facility Address: Facility Type (Vehicle Maintenance, Landscaping, etc.): 433 Killian Ave Fire Department Mount Holly, NC 28120 Name of MS4 inspector(s) evaluated: Most Recent MS4 Inspection (List date and name of inspector): Derek Dixson None (s) indl Title-(s) of Fac ffity Plepres 'nt Present nurlhg the Site Visit: Name Title Facility Documentation%Training Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific? No, the facility does not require a SWPPP. What type of stormwater training do facility employees receive? How often? The staff receive spill response training and IDDE training annually. i 6r'«pe�toF`i'��i��ir�g®C�nz��rs6edge What type of stormwater training does the MS4 inspector receive? How often? None. Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? Not applicable. Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping? Yes. Inspection PrOPOCA41NI's Does the M54 inspector's process include the use of a checklist or other standardized form? No. Does the MS4 inspector's process include taking photos? No. Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)? Not applicable. NCS000407_Mount Holly MS4 Audit_20210524 Page 17 of 22 Does the IVIS4 inspector's process include walking the entire facility and inspecting all points of discharge? Did the IVIS4 inspector miss any obvious areas of concern? If so, explain: Does the IVIS4 inspector's process include presenting the inspection findings to the facility contact? 77 Inspection Results Did the facility inspection result in any corrective actions to be implemented? If so, for what-issue(s)? If compliance corrective actions were identified, what timeline for correction/follow-up was provided? Not @pplicable. NC3OOO4O7_K8nuntHolly MS4Audit_2OZlOSZ4 Page l8cf22 Outfall ID Number: Woodland Avenue Outfall Outfall Location: Receiving Water: 300 Woodland Avenue Mount Holly, NC 28120 Dutchman's Creek Most Recent Outfall Inspection/Screening (Date): Unknown Days Since Last Rainfall: Inches: 13 0.25 Name of MS4 Inspector(s) evaluated: Derek Dixson Date and Time of Site Visit: May 25, 2021 at 11:30 Outfall Description (Pipe Material/Diameter, Culvert, etc.): 36" RCP Is Flow Present? If So, Describe (Color, Approximate Flow Rate, Sheen, Odor, Floatables/Debris, etc.): No flow at the time of the inspection. Inspector Training/I 6owledge What type of stormwater training does the MS4 inspector receive? How often? None. Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations? Yes. Does the inspector's process include the use of a checklist or other standardized form? Yes. Does the inspector's process include taking photos? Yes. Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they? No, this outfall recently had maintenance preformed. NCS000407_Mount Holly MS4 Audit_20210524 Page 19 of 22 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' sae donducted? If so, for what reason? Yes, routine inspection. NCS000407_Mount Holly MS4 Audit_20210524 Page 20 of 22 Site Name: Date and Time of Site Visit: Tuckaseege Park Wetland May 25, 2021 at 10:40 am Site Address: SCM Type: 165 Broome St. Engineered Wetland Mount Holly, NC 28120 Most Recent MS4 Inspection (Include Date and Entity): I None Name of MS4 Inspector(s) evaluated: Most Recent MS4 Enforcement Activity (Include Date): Derek Dixson None ( €` arne(s) any' T !Je() of sKe Glepresw ative(s) Present Duping the Site Visit: Name Title -- - ------ - ---- Site Documentation . - — _ - -- -- -- - Does the site have an operation and maintenance plan? Yes. C Does the site have records of annual inspections? Are they performed by a qualified individual? Yes. Training/knowledge What type of stormwater training does the MS4 inspector receive? How often? None. I Did the MS4 inspector appear knowledgeable about MS4 requirements for post -construction site runoff controls? Yes. r 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. Does the MS4 inspector's process include taking photos? Yes. Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections? No. NCS000407_Mount Holly MS4 Audit_20210524 Page 21 of 22 easure, ' 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? No. Cho o6Aance/Enfokemen What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in? No actions. If compliance issues were identified, what timeline for correction/follow-up was provided? Not applicable. NCS000407_Mount Holly MS4 Audit_20210524 Page 22 of 22