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Home My WebLink AboutNCS000331_DOD FB-DPW MS4 Audit Report_20210625MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) PROGRAM AUDIT REPORT NPDES PERMIT NO. NCS000331 DOD Fort Bragg, NORTH CAROLINA 2175 Reilly Road, Stop A Fort Bragg, NC 28310-5000 Audit Date: May 18 — May 19, 2021 Report Date: June 25, 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 MS4 Permit Audit Report Fort Bragg, NC: NPDES Permit No. NCS000331 (This page intentionally left blank) Audit Date: May 18 — May 19, 2021 MS4 Permit Audit Report Fort Bragg, NC: NPDES Permit No. NCS000331 TABLE OF CONTENTS AuditDetails..................................................................................................................................................1 PermitteeInformation..................................................................................................................................2 SupportingDocuments..................................................................................................................................3 Program Implementation, Documentation & Assessment...........................................................................4 Illicit Discharge Detection and Elimination (IDDE)........................................................................................8 Post -Construction Site Runoff Controls....................................................................................................111 Pollution Prevention and Good Housekeeping for Municipal Operations..................................................16 Site Visit Evaluation: Municipal Facility No. 1.............................................................................................19 Site Visit Evaluation: Municipal Facility No. 2.............................................................................................21 Site Visit Evaluation: MS4 Outfall No. 1......................................................................................................23 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1............................................25 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 2............................................27 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. Audit Date: May 18 — May 19, 2021 ii MS4 Permit Audit Report Fort Bragg, NC: NPDES Permit No. NCS000331 This page intentionally left blank Audit Date: May 18 — May 19, 2021 MS4 Permit Audit Report Fort Bragg, NC: NPDES Permit No. NCS000331 I Audit ID Audit Date(s): NCSO 0331—Fort Bragg MS4 Audit_20210518 May 18 — May 19, 2021 I Minimum Control Measures Evaluated: 0 Program Implementation, Documentation & Assessment ❑ Public Education & Outreach ❑ Public Involvement & Participation 0 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 0 Post -Construction Site Runoff Controls ® Pollution Prevention and Good Housekeeping for Municipal Operations ❑ Total Maximum Daily Loads (TMDLs) Field Site Visits: 0 Municipal Facilities. Number visited: 2 0 MS4 Outfalls. Number visited: 1 ❑ Construction Sites. Number visited: Choose an item. 0 Post-Construction,Stormwater Runoff Controls. Number visited: 2 ❑ Other: Number visited: Choose an item. ❑ Other: Number visited: Choose an item. Mike Lawyer, Env. Program Consultant DEMLR, FRO Penny Markle, Env. Specialist DEMLR, FRO Lauren Garcia, Env. Specialist DEMLR, RRO Audit Report Author: Date: Signatu"V- #� Audit Report Author: Signa Date ::34vle Audit Date(s): May 18 — May 19, 2021 Page 1 of 29 MS4 Permit Audit Report Fort Bragg, NC: NPDES Permit No. NCS000331 MS4 Permittee Name: Permit Effective Date: Permit Expiration Date: Fort Bragg — Directorate of Public Works 4/1/16, 4/1/21(ext.) 3/31/21, 9/30/21(ext.) D City, State, ZIP: Fort Bragg, NC 28310 ate of Last MS4 Inspection/Audit: N/A I Co-permittee(s), if applicable: N/A Permit Owner of Record: Fort Bragg — Directorate of Public Works; Monica A. Stephenson, Director Lee Ward, Chief Bill DeCarmine, Env. Protection Specialist Ellie Cardenal, Env. Scientist Barron Feit, Chief Aaron Brown, Chief Richard Akers, Supervisor, Roads/Grounds Bruce A. Langston, Compliance Team Manager Kathryn Fernandez, PM, Water & Tanks Chris Lamson, Water Quality Support See Permit DPW, Water Management Section DPW, Water Management Section DPW, Water Management Section DPW, Environmental Compliance Branch DPW, Environmental Division DPW DPW DPW, Environmental Compliance Branch DPW, Environmental Compliance Branch Audit Date(s): May 18 — May 19, 2021 Page 2 of 29 MS4 Permit Audit Report Fort Bragg, NC: NPDES Permit No. NCS000331 p irt�ng DQcumefit s ?It "`;"';`' h�-.:. 1 r ,� xy I ,� `�, '* h Y � 'z ' e N y,'"""x,��-, ?k ,,� ,.� \'�^'!� '`C� ri��t yn;. '�".'' r'��'..,y.'C ..... Org Chart d' Prior 2 Fort Bragg SWMP March 2020 Prior 3 2019 — 2020 Annual Report Prior 4 Regulation 200-1 Fort Bragg Environmental Program Prior 5 IDDE Binder Reviewed During Audit 6 Cantonment SW Map Prior 7 MacKall Stormwater Photo Prior 8 Patriot Point Stormwater Photo Prior 9 Fort Bragg Master Stormwater Pollution Prevention Plan Prior 10 Fort Bragg SCM Inspection & Maintenance Manual Prior 11 Fort Bragg Monitoring Plan Prior 12 Fort Bragg SCM Inspection Report Prior 13 Fort Bragg ECO/ECA Environmental Compliance Guide During 14 Preventative Maintenance Tasks & Checklist During 15 Environmental Compliance Checklist Form 2919 During 16 Base -wide Operation & Maintenance Program Reviewed During Audit Audit Date(s): May 18 — May 19, 2021 Page 3 of 29 MS4 Permit Audit Report Fort Bragg, NC: NPDES Permit No. NCS000331 Lee Ward, Bill DeCarmine, Barron Feit The permittee maintained adequate funding and staffing to implement and manage Yes 1 the provisions of the Stormwater Plan and meet all requirements of the permit. The Stormwater Plan identifies a specific position(s) responsible for the overall Yes 1 coordination, implementation, and revision to the Plan. Responsibilities for all components of the Stormwater Plan are documented and Yes 1 position(s) assignments provided. The permittee is current on payment of invoiced administering and compliance Yes NA monitoring fees (see stormwater e-payments on DEMLR MS4 web page). Comments (Briefly describe funding mechanism, number of staff, etc.) Water Management Section (WMS) contains 6-7 staff who are responsible for MS4 program implementation, outfall monitoring, GIS mapping, etc. Several positions within the WMS have several responsibilities. The O-chart could provide more specific responsibilities by position description. There is also a Compliance Assessment Team (CAT) responsible for unit inspections, secondary containment, and road maintenance. Funding is complicated because WMS funding comes from several places. Specific funding can also only be allocated for specific uses. WMS was not able to provide any information about annual budgets or money allocation. However, they consider themselves to be adequately funded. The WMS annual work plan is used to determine funding priorities. The permittee evaluated the performance and effectiveness of the program Yes 3 components at least annually. If yes, the permittee used the results of the evaluation to modify the program Yes 3 I components as necessary to accomplish the intent of the Stormwater Program. Did the permitted MS4 discharges cause or contribute to non -attainment of an No 3 applicable water quality standard? If yes, did the permittee expand or better tailor its BMPs accordingly to address Not NA the non -attainment? Applicable Audit Date(s): May 18 — May 19, 2021 Page 4 of 29 MS4 Permit Audit Report Fort Bragg, NC: NPDES Permit No. NCS000331 Comments Annual Reports evaluating the effectiveness of the program have been submitted as required. No modifications necessary. Monitoring conducted in year 1 (2016/17) showed no exceedances of cut-off concentrations, however monitoring continued voluntarily in years 2 and 3 (also with no exceedances). Monitoring not conducted in years 4 or 5 as allowed in the permit. The permittee kept the Stormwater Plan up to date. I Yes Not The permittee notified DEMLR of any updates to the Stormwater Plan. Applicable Comments (Indicate the date of latest Stormwater Plan and describe the nature of any updates, if applicable). WMS has not needed to make recent changes to the Stormwater Plan. The permittee kept an up-to-date version of its Stormwater Plan available to the Yes Division and the public online. 2 NA The online materials included ordinances, or other regulatory mechanisms, or a list identifying the ordinances, or other regulatory mechanisms, providing the legal Yes 4 authority necessary to implement and enforce the requirements of the permit. Comments (Note what materials are available online) Due to cyber security measures, website was shut down approximately 2 years ago. Prior to that, staff with the WMS maintained the website with information on the base's Stormwater Plan. Did DEMLR require a modification to the Stormwater Plan? I No I 2 If yes, did the permittee complete the modifications in accordance with the I Not I NA established deadline? Applicable Comments (Note date of DEMLR notification, modifications required, and date modifications were completed, as applicable) DEMLR did not require modifications to the stormwater plan. Are any control measures implemented by an entity other than the permittee? I No I --- Not If yes, is there a written agreement in place? Applicable Comments (List the specific control measures implemented by others that do not have adequate written agreements, if applicable) DEMLR is responsible for implementing Post -Construction Site Runoff Controls and Construction Site Runoff Controls. The permittee maintained written procedures for implementing the six minimum I Yes I 2,9 control measures. Audit Date(s): May 18 — May 19, 2021 Page 5 of 29 MS4 Permit Audit Report Fort Bragg, NC: NPDES Permit No. NCS000331 Written procedures identified specific action steps, schedules, resources and Procedures Yes 2,9 responsibilities for implementing the six minimum measures. Comments (List the specific minimum measures that do not have adequate written procedures, if applicable) The written procedures were contained in the SWMP and in the base wide SWPPPs. WMS also maintains an IDDE Binder, which was provided for review during the audit. II�I�A The permittee maintained documentation of all program components including, but program not limited to, inspections, maintenance activities, educational programs, Yes 2,9 DQcurn1#anon implementation of BMPs, enforcement actions etc., on file for a period of five years. Comments (List the specific program components that do not have adequate documentation on file and why, if applicable) The permittee submitted annual reports to the Department within twelve months from the effective date of the permit (See Section III.B. for the annual reporting Yes 3 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 3 The Annual Reports included appropriate information to accurately describe the progress, status, and results of the permittee's Stormwater Plan, including, but not limited the following: 1._ A detailed description of the status of implementation of the Stormwater Plan as a whole. This will include information on development and implementation of each major component of the Stormwater Plan for the past year and Yes 3 schedules and plans for the year following each report. 2. An adequate description and justification of any proposed changes to'the Stormwater Plan. This will include descriptions and supporting information for Not the proposed changes and how these changes will impact the Stormwater Applicable _ Plan (results, effectiveness, implementation schedule, etc.). 3. Documentation of any necessary changes to programs or practices for assessment of management measures implemented through the Stormwater Not Applicable --- Plan. 4. A summary of data accumulated as part of the Stormwater Plan throughout the year along with an assessment of what the data indicates in light of the Yes 3 Stormwater Plan. 5. An assessment of compliance with the permit, information on the establishment of appropriate legal authorities, inspections, and enforcement Yes 3 actions. Comments (Note dates that annual reports cover under current permit and generally describe report deficiencies, if any) Annual Reports from 2016, 2017, 2018, 2019 and 2020 were submitted. The Annual Reports document the following: 1. A summary of past year activities, including where applicable, specific Yes quantities achieved and summaries of enforcement actions. Audit Date(s): May 18 — May 19, 2021 Page 6 of 29 MS4 Permit Audit Report Fort Bragg, NC: NPDES Permit No. NCS000331 2. A description of the effectiveness of each program component. I Yes I 3 3. Planned activities and changes for the next reporting period, for each I Yes I 3 program component or activity. 4. Fiscal analysis. I No I 3 Comments (Note dates that annual reports cover under current permit and generally describe report deficiencies, if any) While there is no specific documentation in the Annual Reports regarding a fiscal analysis, MS4 staff relayed that they are adequately funded through Congress. Audit Date(s): May 18 — May 19, 2021 Page 7 of 29 MS4 Permit Audit Report Fort Bragg, INC: NPDES Permit No. NCS000331 Lee Ward, Bill DeCarmine, Richard Akers, Bruce Langston, Kathryn Fernandez, Chris Lamson The permittee maintained a written IDDE Program. Yes 1 5 If yes, the written program includes provisions for program assessment and Yes 5 evaluation and integrating program. Comments (Note any deficiencies) Permittee's IDDE Program in conjunction with SWMP & Annual Reports serves as program assessment and evaluation. Permittee maintains an internal Access database for inspections including dry weather inspections. The permittee maintained an IDDE ordinance or other regulatory mechanism(s) that Yes 4 provides the legal authority to prohibit illicit connections and discharges to the MS4. If yes, the ordinance applies throughout the corporate limits of the permittee. [Permit Part I.D] Yes 4 Comments DOD -wide Code, contracted housing rules Directorate of Public Works relies on military code for enforcement. Army Reg. 200-1 covers all environmental programs. The permittee maintained a current map showing major outfalls* and receiving Yes 6,7,8 streams. Comments Map shows outfalls subject to monitoring. A table with all outfalls including pipe material, diameter, etc. is also maintained. *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. The permittee maintained a program for conducting dry weather flow field Yes 11 observations in accordance with written procedures. Comments (Generally summarize program, including frequency of observations and # or % of outfalls screened) Field crews visually inspect outfalls and complete a dry -weather inspection form. Special attention is given to outfalls containing flow when no rain has occurred within 72 hours and/or odors/discolored water is detected. Approximately 5% of outfalls are inspected each month with goal of inspecting all outfalls once per year. Audit Date(s): May 18 — May 19, 2021 Page 8 of 29 MS4 Permit Audit Report Fort Bragg, NC: NPDES Permit No. NCS000331 The per maintained written procedures for conducting investigations of Investigation Yes 11 identified illicit discharges. Procedafres Comments (Generally describe what procedures are documented) Provided during the audit. For each case of an illicit discharge or potential illicit discharge, the permittee documented and tracked the following: 1. The date(s) the illicit discharge was observed I Yes I 15 2. The results of the investigation I Yes I 15 3. Any follow-up of the investigation I Yes I 15 4. The date the investigation was closed I Yes I 15 Comments (Note whether a standard inspection form is utilized to capture consistent information and a tracking mechanism is used) Fort Bragg Spill Report Form, Facilities Engineering Work Request (for any structural issues), Excel Database il_D:2.1 f`mployee The permittee implemented and documented a training program for appropriate Training municipal staff who, as part of their normal job responsibilities, may come into Yes 13 contact with or otherwise observe an illicit discharge or illicit connection. Comments (Generally describe the staff training program, including frequency and which staff are trained) Environmental Compliance Officer/Environmental Compliance Assistant Course; 20-hour initial, 8-hour annual refresher; 1,180 students completed training in FY 19/20. The permittee informed public employees of hazards associated with illegal I - - Yes discharges and improper disposal of waste. The permittee informed businesses of hazards associated with illegal discharges and Yes --- improper disposal of waste. The permittee informed the general public of hazards associated with illegal Yes --- discharges and improper disposal of waste. Comments (Note how each sector was informed, if applicable) Brochures, website (currently shut down due to Cyber Security), Paraglide newspaper; shown during audit Audit Date(s): May 18 — May 19, 2021 Page 9 of 29 MS4 Permit Audit Report Fort Bragg, NC: NPDES Permit No. NCS000331 The permittee promoted, publicized, and facilitated a reporting mechanism for the Yes --- public to report illicit discharges. The permittee promoted, publicized, and facilitated a reporting mechanism for staff Yes --- to report illicit discharges. The permittee established and implemented response procedures for citizen Yes --- req u ests/re ports. Comments (Generally describe reporting mechanisms and how promoted/publicized/facilitated/established) 911 or hotline, published on brochure The permittee implemented a mechanism to track the issuance of notices of violation Yes 4 and enforcement actions administered by the permittee. If yes, the mechanism includes the ability to identify chronic violators for Yes 4 initiation of actions to reduce noncompliance. Comments (Generally describe the established tracking mechanism, if applicable) - The permittee is not involved in enforcement. "Enforcement" actions are administered by the Garrison Commander, Unit Commander, or equivalent. Audit Date(s): May 18 — May 19, 2021 Page 10 of 29 MS4 Permit Audit Report Fort Bragg, NC: NPDES Permit No. NCS000331 Lee Ward, Bill DeCarmine Implementation (check all that apply): ❑ The permittee implements the components of this minimum measure. M The permittee relies upon another entity to implement the components of this minimum measure: DEMLR ❑ 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-1) —15A NCAC 213.0212 ❑ Water Supply Watershed II (WS-II) —15A NCAC 2B .0214 ❑ Water Supply Watershed III (WS-III) —15A NCAC 213.0215 ❑ Water Supply Watershed IV (WS-IV) —15A NCAC 213.0216 ❑ 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 26 .0235 ❑ Tar -Pamlico River Basin Nutrient Sensitive (NSW) Management Strategy —15A NCAC 2B .0258 ❑ Randleman Lake Water Supply Watershed Nutrient Management Strategy-15A NCAC 213.0251 ❑ Universal Stormwater Management Program —15A NCAC 2H .1020 Ordinance(s) (check all that apply): The permittee utilizes the following ordinances and/or regulatory authority to fulfill post construction minimum measure program requirements throughout the MS4 permitted area (check all that apply): ❑ DEQ model ordinance ❑ MS4 designed post -construction practices that meet or exceed 15A NCAC 02H .1000. ❑ DEQ approved comprehensive watershed plan ❑ DEQ approved ordinance for a deemed -compliant Program (see list above) Instructions: For MS4s not implementing a S.L. 2006-246 deemed -compliant program, complete only the Permit Citation section below. For MS4s implementing a S.L. 2006-246 deemed -compliant program, complete the Session Law 2006-246 section below. If the MS4 does not implement a deemed -compliant program throughout the entire MS4 permitted area, then complete the Permit Citation section below for the permitted area(s) not covered under the S.L. 2006-246 deemed -compliant program. Audit Date(s): May 18 — May 19, 2021 Page 11 of 29 MS4 Permit Audit Report Fort Bragg, NC: NPDES Permit No. NCS000331 The permittee implements deemed -compliant Program requirements in accordance with the applicable 15A NCAC rules. Not Applicable --- The permittee implements deemed -compliant Program requirements throughout, the entire MS4 area (If not, also complete the Permit Citation section below.) Not Applicable The permittee applies deemed -compliant Program requirements to all federal, state and local government projects within the permitted MS4 area who do not Not Applicable --- have their own NPDES stormwater permit. The permittee included deemed -compliant Program reporting in their MS4 Annual Reports. Not Applicable The permittee included deemed -compliant Program implementation in their Stormwater Management Plan. Not Applicable ___ Comments DEMLR is responsible for implementing Post -construction Site Runoff Controls. The permittee maintained an ordinance or other regulatory mechanism designed to meet the objectives of the Post -Construction Site Runoff Controls Stormwater Not Applicable --- Management Program. If yes, the ordinance applies throughout the corporate limits of the permittee (Verify permit coverage area listed in Part LD of permit and modify Not --- accordingly). Y)• Applicable The permittee has the authority to review designs and proposals for new development and redevelopment to determine whether adequate stormwater Yes --- control measures will be installed, implemented, and maintained. The permittee has the authority to request information such as stormwater plans, inspection reports, monitoring results, and other information deemed necessary to evaluate compliance with the Post -Construction Stormwater Management Yes --- Program. The permittee has the authority to enter private property for the purpose of inspecting at reasonable times any facilities, equipment, practices, or operations Yes --- related to stormwater discharges. Comments (If the permittee relies upon another entity, specifically note the legal authority that allows that entity to implement the program within the MS4 area) At this time, DEMLR is responsible for implementing Post -construction Site Runoff Controls. However, WMS is involved in the review of designs and proposals and performs inspections and manages maintenance activities. DOD MS4s that do not already review, approve and enforce post -construction permit applications within their own jurisdictions are required to develop and implement a Post -Construction program by October 1, 2023. The permittee utilizes strategies which include SCMs appropriate for the MS4. I Yes I --- Audit Date(s): May 18 — May 19, 2021 Page 12 of 29 MS4 Permit Audit Report Fort Bragg, NC`. NPDES Permit No. NCS000331 SCMs comply with 15A NCAC 02H .1000. Yes I --- Comments WMS is involved in the review of designs and proposals. They require permitted SCMs to follow NCAC requirements. The permittee conducted site plan reviews of all new development and redeveloped sites that disturb greater than or equal to one acre (including sites Yes --- that disturb less than one acre that are part of a larger common plan of development or sale). If yes, the site plan reviews addressed how the project applicant meets the I --- Yes performance standards. If yes, the site plan reviews addressed how the project will ensure long-term I --- Yes maintenance. Comments WMS is involved in the review of designs and proposals. All projects go through review by DPW/WMS before they are submitted to DEMLR for approval. Comments Shown at audit. The permittee maintained an inventory of projects with post -construction structural stormwater control measures installed and implemented at new Yes --- development and redeveloped sites. The inventory included both public and private sector sites located within the permittee's corporate limits that are covered by its post -construction ordinance Yes --- requirements. The permittee provided mechanisms such as recorded deed restrictions and Not protective covenants that ensure development activities will maintain the project --- Applicable consistent with approved plans. Comments DEMLR is responsible for implementing Post -construction Site Runoff Controls. The permittee implemented or required an operation and maintenance plan for Yes 2 the long-term operation of the SCMs required by the program. The operation and maintenance plan required the owner of each SCM to perform I I Yes 2 and maintain a record of annual inspections of each SCM. Annual inspection of permitted structural SCMs are required to be performed by a I Yes I 2 qualified professional. Audit Date(s): May 18 — May 19, 2021 Page 13 of 29 MS4 Permit Audit Report Fort Bragg, NC: NPDES Permit No. NCS000331 Comments DEMLR issues the SCM permits, which have 0&M requirements. O&M is included in the SWMP. SCMs with individual permits are inspected semi-annually. All other SCMs are inspected annually. The permittee conducted and documented inspections of each project site covered under performance standards, at least one time during the permit term (Verify this Yes 10,12 is a permit condition in Part II.F.2.g of permit and modify accordingly). Before issuing a certificate of occupancy or temporary certificate of occupancy, the permittee conducted a post -construction inspection to verify that the permittee's performance standards have been met or a bond is in place to guarantee Not completion (Verify this is a permit condition in Part II.F.2.g of permit and modify Applicable accordingly. The permittee developed and implemented a written inspection program for SCMs installed pursuant to the post -construction program (Verify this is a permit Yes 10,12 condition in Part II.F.2.g of permit and modify accordingly. The permittee documented and maintained records of inspections. I Yes 1 10,12 The permittee documented and maintained records of enforcement actions. Not Applicable Comments SCMs with individual permits are inspected semi-annually. All other SCMs are inspected annually. Enforcement activities are handled by DEMLR. The permittee made available through paper or electronic means, ordinances, post -construction requirements, design standards checklists, and other materials appropriate for developers. Not Note: New materials may be developed by the permittee, or the permittee may use Applicable materials adopted from other programs and adapted to the permittee's new development and redevelopment program. Comments (If the permittee has adopted materials from other programs, indicate here which materials they are using) DEMLR is responsible for implementing Post -construction Site Runoff Controls. The permittee tracked the issuance of notices of violation and enforcement actions. If yes, the tracking mechanism included the ability to identify chronic violators for initiation of actions to reduce noncompliance. Comments DEMLR is responsible for implementing Post -construction Site Runoff Controls. Not Applicable Not Applicable Audit Date(s): May 18 — May 19, 2021 Page 14 of 29 MS4 Permit Audit Report Fort Bragg, NC: NPDES Permit No. NCS000331 u+ir o The permittee fully complies with post construction program requirements on its Not _ New Develo men# Applicable P own publicly funded construction projects. p Comments DEMLR is responsible for implementing Post -construction Site Runoff Controls. Does the MS4 have areas draining to Nutrient Sensitive Waters (NSW) pursuant to I Not 15A NCAC 02H .0150? Applicable If yes, does the permittee use SCMs that reduce nutrient loading in order to I Not meet local program requirements. Applicable If yes, does the permittee also still incorporate the stormwater controls Not required for the project's density level. Applicable If yes, does the permittee also require documentation where it is not feasible to Not use SCMs that reduce nutrient loading. Applicable Comments (Provide reference for local requirements) I DEMLR is responsible for implementing Post -construction Site Runoff Controls. The permittee ensured that the design volumes of SCMs take into account the Not runoff at build out from all surfaces draining to the system. Applicable Where "streets" convey stormwater, the permittee designed SCMs to be sized to Not treat and control stormwater runoff from all surfaces draining to the SCM including Applicable streets, driveways, and other impervious surfaces. Comments DEMLR is responsible for implementing Post -construction Site Runoff Controls. Audit Date(s): May 18 — May 19, 2021 Page 15 of 29 MS4 Permit Audit Report Fort Bragg, NC: NPDES Permit No. NCS000331 Lee Ward, Bill DeCarmine, Richard Akers, Bruce Langston, Kathryn Fernandez, Chris Lamson IhG2.a The permittee maintained a current inventory of facilities and operations owned. ��cilitt Inventory.;. and operated by the permittee with the potential for generating polluted Yes 9 stormwater runoff. Comments (Note number of facilities, typical inventory data and any facilities that are not inventoried that should be) 5,852 facilities are included with the potential to contribute to stormwater pollution. The inventory is maintained using Real Property System, included in GIS mapping. Industrial facilities are broken down in the SWPPP. Operation & maintenance Division is separate from DPW/WMS. Hazardous waste sites are inspected by DPW and the Haz Waste employees. The permittee maintained and implemented an 0&M program for municipally owned and operated facilities with the potential for generating polluted Yes 16 stormwater runoff. If yes, the 0&M program specifies the frequency of inspections. I Yes I 16 If yes, the 0&M program specifies the frequency of routine maintenance Yes 16 I requirements. If yes, the permittee evaluated the 0&M program annually and updated it as Yes 16 necessary. Comments Base -wide O&M Program applies to all facilities. There is a Facility Manager's Handbook with identified responsibilities. Preventative Maintenance Program through Operations and Maintenance Division. Checklist for storm drain preventative maintenance including specific tasks. Report form completed to note any deficiencies. Any needed repairs go through Richard Akers. The permittee had written spill response procedures for municipal operations. I Yes 1 13 Comments ECO/ECA Environmental Compliance Guide. II.G.2.d Streets,` The permittee evaluated existing and new BMPs that reduce polluted stormwater Roads,'and Public runoff from municipally -owned streets, roads, and public parking lots within its Yes 13,14,15 corporate limits annually. Audit Date(s): May 18 — May 19, 2021 Page 16 of 29 MS4 Permit Audit Report Fort Bragg, NC: NPDES Permit No. NCS000331 If yes, the permittee evaluated the effectiveness of existing and new BMPs Yes based on cost and the estimated quantity of pollutants removed. Comments Facilities maintain spill kits, which are assessed. If inspectors find any issues, they are reported and corrected immediately. 13,14,15 The permittee maintained and implemented an O&M program for the stormwater 13,14,15, sewer system including catch basins and conveyance systems that it owns and Yes 16 maintains. Comments (Briefly describe O&M program) Storm Drain PM Program, provided during the audit. ILG.2. The permittee maintained a current inventory of municipally -owned or operated 13,14,15, Structural structural stormwater controls installed for compliance with the permittee's post- Yes 16 stoe,m,f'w-atei.tonit,ols�l°I construction ordinance. Comments (Describe inventory information and number of controls in inventory) Included in the Storm Drain PM Program and 0&M Program. 11 G 2:h The permittee maintained and implemented an O&M program for municipally- 13,14,15, NI O&for Structural;. owned or maintained structural stormwater controls installed for compliance with Yes_ 16 stormwater Controls ; the permittee's post -construction ordinance. If yes, then: The 0&M program specified the frequency of inspections and routine Yes 13,14,15, maintenance requirements. 16 The permittee documented inspections of all municipally -owned or maintained Yes 13,14,15, structural stormwater controls. 16 The permittee inspected all municipally -owned or maintained structural I Yes 113,14,15, I stormwater controls in accordance with the schedule developed by permittee. 16 The permittee maintained all municipally -owned or maintained structural Yes 13,14,15, stormwater controls in accordance with the schedule developed by permittee. 1 1 16 The permittee documented maintenance of all municipally -owned or I Yes 113,14,15, maintained structural stormwater controls. 16 Comments Included in the O&M Program, provided during the audit. I ILG.2.� I The permittee ensured municipal employees are properly trained in pesticide, I I ___ I Yes herbicide and fertilizer application management. Audit Date(s): May 18 — May 19, 2021 Page 17 of 29 MS4 Permit Audit Report Fort Bragg, NC: NPDES Permit No. NCS000331 The permittee ensured contractors are properly trained in pesticide, herbicide and Yes --- fertilizer application management. The permittee ensured all permits, certifications, and other measures for Yes applicators are followed. Comments DPW staff must maintain Federal license for pesticide, herbicide, and fertilizer application. Contractors are state licensed. The permittee implemented an employee training program for employees involved in implementing pollution prevention and good housekeeping practices. Yes 13 Comments ECO/ECA training 1I.4.2k The permittee described and implemented measures that prevent or minimize llehicl�Q dnd contamination of stormwater runoff from all areas used for vehicle and equipment Yes 13 Equipment Cleaning '', cleaning. Comments Central vehicle washing, training provided by Facility Manager. Oil/water separators utilized at motor pools where only light washing with approved detergents is allowed. Audit Date(s): May 18 — May 19, 2021 ' Page 18 of 29 MS4 Permit Audit Report Fort Bragg, NC: NPDES Permit No. NCS000331 Facility Name: 16th MP Motor Pool Facility Address: Bldg #2-2428 Name of MS4 inspector(s) evaluated: Joshua Timm Date and Time of Site Visit: May 19, 2021; 9:37am—10:23am Facility Type (Vehicle Maintenance, Landscaping, etc.): Vehicle Maintenance Most Recent MS4 Inspection (List date and name of inspector): April 2021; Joshua Timm Name I Title I Josua Timm; CWOII Jared Leach I IEnv. Compliance Inspector; ECO I Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific? Yes, site -specific spill prevention plan What type of stormwater training do facility employees receive? How often? ECO/ECA Training; 20-hour initial, 8-hour annual refresher What type of stormwater training does the MS4 inspector receive? How often? ECO/ECA Training, 40-hour Hazwoper, RCRA; annually. Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? Yes, relayed knowledge about visual inspections of drains, proper fluid management/storage, etc. Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping? Yes Does the MS4 inspector's process include the use of a checklist or other standardized form? Yes, Form 2919 Does the MS4 inspector's process include taking photos? Yes, if on -going issues; generally no photos due to security reasons Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)? Yes Audit Date(s): May 18 — May 19, 2021 Page 19 of 29 MS4 Permit Audit Report Fort Bragg, NC: NPDES Permit No. NCS000331 Audit Date(s): May 18 — May 19, 2021 Page 20 of 29 MS4 Permit Audit Report Fort Bragg, NC: NPDES Permit No. NCS000331 Facility Name: Simmons Airfield (Hangers) Facility Address: Simmons Army Airfield Name of MS4 inspector(s) evaluated: Bruce Langston Date and Time of Site Visit: May 19, 2021; 10:40am—11:16am Facility Type (Vehicle Maintenance, Landscaping, etc.): Airfield Activities Most Recent MS4 Inspection (Date and Entity): February 2020 Name I Title Doug Smith, Katie Gibbons, Jimmy Saunders Does the facility have a Stormwater Pollution Prevention Plan Yes, site -specific spill prevention plan Env. Compliance Inspectors, ECO PPP) or similar document? Is it facility -specific? What type of stormwater training do facility employees receive? How often? ECO/ECA Training; 20-hour initial, 8-hour annual refresher What type of stormwater training does the MS4 inspector receive? How often? ECO/ECA Training, 40-hour Hazwoper, RCRA; annually , Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? Yes, relayed knowledge about spill prevention, materials management, etc. Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping? Yes Does the MS4 inspector's process include the use of a checklist or other standardized form? Yes, Form 2919, wash rack checklist Does the MS4 inspector's process include taking photos? Yes, if on -going issues; generally, no photos due to security reasons Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)? Yes, spill plan reviewed/updated annually Audit Date(s): May 18 — May 19, 2021 Page 21 of 29 MS4 Permit Audit Report Fort Bragg, NC: NPDES Permit No. NCS000331 Audit Date(s): May 18 — May 19, 2021 Page 22 of 29 MS4 Permit Audit Report Fort Bragg, NC: NPDES Permit No. NCS000331 Outfall ID Number: Combined outfalls 20, 21 & 76 Outfall Location: Adjacent to trail off Gruber Road Receiving Water: Little Cross Creek Most Recent Outfall Inspection/Screening (Date): November 2020 Days Since Last Rainfall: Inches: May 12, 2021 0.10" Name of MS4 Inspector(s) evaluated: Bill DeCarmine Date and Time of Site Visit: May 19, 2021; 1:36pm—1:54pm Outfall Description (Pipe Material/Diameter, Culvert, etc.): 54" RCP & 18" RCP Is Flow Present? If So, Describe (Color, Approximate Flow Rate, Sheen, Odor, Floatables/Debris, etc.): No flow at time of site visit What type of stormwater training does the MS4 inspector receive? How often? ECO/ECA Training; annually Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations? Yes, relayed knowledge regarding oil sheen, odor, etc. Does the inspector's process include the use of a checklist or other standardized form? Yes Does the inspector's process include taking photos? Only if issues are observed Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they? No Audit Date(s): May 18 — May 19, 2021 Page 23 of 29 MS4 Permit Audit Report Fort Bragg, NC: NPDES Permit No. NCS000331 Did the outfall inspection result in any work orders or maintenance requests? If so, for what issue(s)? No Will a follow-up outfall inspection be conducted? If so, for what reason? No Staff with DDC-4C (contract employees) conduct visual checks monthly and notify WMS staff for follow-up if issues are observed. Audit Date(s): May 18 — May 19, 2021 Page 24 of 29 MS4 Permit Audit Report Fort Bragg, NC: NPDES Permit No. NCS000331 Site Name: M012 (311 ESC COF) Site Address: Intersection of Lane & Transportation Drive Name of MS4 Inspector(s) evaluated: Bill DeCarmine Date and Time of Site Visit: May 19, 2021; 2:OOpm — 2:22pm SCM Type: Infiltration Basin (grassed bottom) Most Recent MS4 Inspection (Include Date and Entity): Approximately 6 months ago Most Recent MS4 Enforcement Activity (Include Date): NA Titl Barron Felt I Chief, DPW Env. Compliance Branch Leeward I Chief, DPW Water Management Section Does the site have an operation and maintenance plan? Yes, base -wide 0&M Plan Does the site have records of annual inspections? Are they performed by a qualified individual? Yes What type of stormwater training does the MS4 inspector receive? How often? NSCU BMP Inspections & Maintenance Certification, annual re -certification Did the MS4 inspector appear knowledgeable about MS4 requirements for post -construction site runoff controls? Yes Did the MS4 inspector appear knowledgeable about post -construction BMPs (general purpose/function, components, 0&M requirements, etc.)? Yes 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? As needed if issues are observed Audit Date(s): May 18 — May 19, 2021 Page 25 of 29 MS4 Permit Audit Report Fort Bragg, NC: NPDES Permit No. NCS000331 Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and reco Yes Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge? Yes IDid 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? Yes What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in? NA If compliance issues were identified, what timeline for correction/follow-up was provided? NA SCM in need of mowing and trash removal, which is scheduled for near term. annual inspections Audit Date(s): May 18 — May 19, 2021 Page 26 of 29 MS4 Permit Audit Report Fort Bragg, NC: NPDES Permit No. NCS000331 Site Name: 8016 Site Address: Souter Street parking lot Name of MS41 Bill DeCarmine s) evaluated: Date and Time of Site Visit: May 19, 2021; 2:35pm — 2:45pm SCM Type: Wet Pond Most Recent MS4 Inspection (Include Date and Entity): February 2021 Most Recent MS4 Enforcement Activity (Include Date): NA Barron Felt I Chief, DPW Env. Compliance Branch Lee Ward I Chief, DPW Water Management Section Does the site have an operation and maintenance plan? Yes, base -wide 0&M Plan Does the site have records of annual inspections? Are they performed by a qualified individual? Yes What type of stormwater training does the MS4 inspector receive? How often? NCSU BMP Inspections & Maintenance Certification, annual re -certification Did the MS4 inspector appear knowledgeable about MS4 requirements for post -construction site runoff controls? Yes Did the MS4 inspector appear knowledgeable about post -construction BMPs (general purpose/function, components, C&M requirements, etc.)? Yes 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? As needed if issues are observed Audit Date(s): May 18 — May 19, 2021 Page 27 of 29 MS4 Permit Audit Report Fort Bragg, NC: NPDES Permit No. NCS000331 Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections? Yes 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? Yes What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in? NA Pond in need of minor maintenance with respect to tree growth around edge of pond and algae in forebay. M54 inspector acknowledged maintenance needs. Audit Date(s): May 18 — May 19, 2021 Page 28 of 29 MS4 Permit Audit Report Fort Bragg, NC: NPDES Permit No. NCS000331 APPENDIX A: SUPPORTING DOCUMENTS SUPPORTING DOCUMENTATION IS ON FILE IN THE NCDEQ PUBLIC LASERFICHE PORTAL Audit Date(s): May 18 — May 19, 2021 Page 29 of 29