4_NCS000442_MS4 Gap Analysis Report_20210708

Brown AND .
Caldwell
5430 Wade Park Boulevard, Suite 200
Raleigh, NC 27607
T: 919.233.9178
Prepared for: City of Rocky Mount
Project Title: Rocky Mount MS4 Gap Analysis
Project No.: 156340
Technical Memorandum
Subject: MS4 Gap Analysis Report
Date: June 16, 2021, 2021
To: Scott Miles, City of Rocky Mount
From: Victoria Blackwell, Task Order Manager
Copy to: Stephanie Hanses, Contract Manager
Prepared by: uf- z
Victoria Blackwell, Task Order Manager
Reviewed by:
Stephanie Hanses, Contract Manager
Limitations:
Technical Memorandum
This document was prepared solely for the City of Rocky Mount in accordance with professional standards at the time the services were performed
and in accordance with the contract between Rocky Mount and Brown and Caldwell dated February 4, 2021. This document is governed by the
specific scope of work authorized by Rocky Mount; it is not intended to be relied upon by any other party except for regulatory authorities
contemplated by the scope of work. We have relied on information or instructions provided by Rocky Mount and other parties and, unless otherwise
expressly indicated, have made no independent investigation as to the validity, completeness, or accuracy of such information.

MS4 Gap Analysis Report
Table of Contents
Listof Figures............................................................................................................................................................ ii
Listof Tables..............................................................................................................................................................
ii
Section1: Introduction.............................................................................................................................................
1
Section2: Data Gathering........................................................................................................................................
2
Section 3: Results of the MS4 Self Audit................................................................................................................
2
Section 4: Pollution Prevention and Good Housekeeping Evaluation..................................................................
7
4.1 Municipal Facility Inventory Evaluation...........................................................................................................
7
4.2 Municipal Facility Visits....................................................................................................................................8
4.3 Observations.....................................................................................................................................................
8
4.3.1 Spill Kits and Spill Response............................................................................................................
8
4.3.2 Waste Storage....................................................................................................................................
9
4.3.3 Inlet Protection: ................................................................................................................................
1-1-
4.4 Recommendations.........................................................................................................................................12
Section5: Next Steps.............................................................................................................................................13
References..............................................................................................................................................................13
Attachment A: DEQ Phase II Audit Template.......................................................................................................
A-1
Attachment B: Meeting and Site Visit Summaries..............................................................................................
B-1
Attachment C: Pollution Prevention and Good Housekeeping Field Audit Template ........................................
C-1
Attachment D: Municipally Owned Facilities for PPGH Program........................................................................D-5
List of Figures
Figure 4-1. Spill response signage.......................................................................................................................... 9
Figure 4- 2. Improper Waste Oil Storage...............................................................................................................10
Figure 4-3. Improper Dumpster Storage...............................................................................................................11
Figure4-4. Inlet Obstruction..................................................................................................................................12
List of Tables
Table 3-1. High Priority MS4 Program Recommendations................................................................................... 3
Table 3-2. Medium Priority MS4 Program Recommendations.............................................................................. 4
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Tech Memo Subject
Table 3-3. Low Priority Program Recommendations.............................................................................................. 5
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Section 1: Introduction
The City of Rocky Mount (City) was issued its current individual Phase II Municipal Separate Storm Sewer
System (MS4) Permit (Permit No. NCS000442) by the North Carolina Department of Environmental Quality
(DEQ) Division of Energy, Mineral, and Land Resources (DEMLR) on February 20, 2017. In response to a U.S.
Environmental Protection Agency (EPA) compliance initiative in North Carolina, DEQ began audits of Phase II
MS4 permittees in 2019. The City audit is scheduled to occur sometime in calendar year 2021.
At that time, the City will be expected to demonstrate compliance with the requirements of the current MS4
permit. It is anticipated that the audit will be conducted using a standard template with a series of questions
as presented in the DEQ Draft Phase II Permit Audit Template (North Carolina DEQ, 2019) (shown in
Attachment A). As a part of the audit, DEQ will request supporting documentation, conduct City staff
interviews, and perform site visits with City staff.
The purpose of this report is to evaluate the City's current MS4 program documents and operations, outline
the requirements in the City's MS4 permit and the audit template, and assess the City MS4 program. Brown
and Caldwell (BC) conducted a gap analysis process which included a request for information from the City
about current program operations, records, and procedures; and interviews with City staff responsible for
implementing or supporting components of the MS4 permit. The term gap in this process refers to: 1) areas
identified by BC that are either explicitly cited in the NPDES MS4 permit or 2) elements identified within the
DEQ Phase II MS4 Audit template that require additional documentation and/or procedural updates by the
City to be in compliance. Based on a review of the data, materials, and observations gathered through this
effort, BC identified gaps in the current MS4 program and developed recommended actions to address
those gaps. In general, the key observations from the gap analysis are:
• Documentation for current program operations and procedures should be strengthened. Key programs
required by the permit should be well documented to demonstrate compliance with permit
requirements.
• Records associated with maintenance and inspection activities should be maintained in such a way that
chronic violators and areas of repeat issues can easily be identified and addressed.
• A process for enforcement of notices of violations (NOVs) should be developed to address hazards to the
stormwater system and compliance with the MS4 permit.
This report also evaluates the existing municipal Pollution Prevention and Good Housekeeping (PPGH)
program. BC reviewed the City's existing inventory of municipal facilities to identify sites with significant
potential for pollution. The evaluation included assessing property use based on aerial imagery and then by
conducting facility inspections. Results of this effort are detailed further in Section 4 of this report. Some key
observations from this aspect of the gap analysis included:
There is a need for standardized procedures and defined expectations for municipally owned facilities to
meet PPFH permit requirements especially associated with spill prevention and spill response
preparedness.
• The Stormwater Management Division should clearly define responsibilities and coordinate with owning
departments for implementation at their facilities. Once responsibilities are outlined and agreed upon,
the Stormwater Management Department should provide templates and guidance documents for how
facilities should carry out and document heir identified responsibilities.
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Section 2: Data Gathering
Data included in this report were provided by the City based on the current program. In January and February
2021, City staff provided example work products, standard operating procedures (SOPs), forms, and data
related to activities covered by the MS4 permit, including:
• Public Education, Outreach, and Involvement
• Illicit Discharge Detection and Elimination (IDDE)
• Stormwater Control Measure (SCM) and Erosion & Sediment Control (E&SC) Design and Construction
• SCM Inspections and Maintenance
• Pollution Prevention and Good Housekeeping and Industrial Inspections
Asset Inspections and Maintenance
Following a review of the provided data, BC conducted interviews with staff from the Stormwater
Management Division who have responsibilities relevant to the MS4 permit requirements. City staff
responsible for one or more permit requirements were invited to discuss the processes and procedures they
use to implement the identified permit requirements. A schedule of all meetings held, including a list of
attendees, topics, and meeting summaries is presented in Attachment B.
The results of the data review, division and departmental interviews, and site visits were compiled and
analyzed for compliance gaps. Emphasis was placed on standard procedures (including whether SOPs and
standard templates/checklists have been developed), and documentation/reporting mechanisms.
For the PPGH program review, a list of City -owned facilities was generated from the 2019-2020 City Property
Schedule. From this list, sites were classified based on the type of activities that could be conducted on -site.
Sites that included activities with potential to cause significant pollution to the stormwater system were
considered for field visits by BC staff for further evaluation. Five sites were selected for field visits and were
assessed based on the field form and discussions with City staff at each facility that can be found in
Attachment C.
Section 3: Results of the MS4 Self Audit
The following section is organized based on the DEQ Phase II Audit template (Attachment A) and City
programs that implement elements of the MS4 permit. The audit template includes questions about each
area of the permit, from procedures and protocols to reporting and tracking, to verify program
implementation. The audit template allows "Yes", "No", "Partial", and "Not Applicable" responses. A "Yes"
indication denotes a program element that appears to be compliant with the permit requirement or audit
question, while a "No" denotes the lack of compliance. A "Partial" indication denotes a program element
that meets a portion of the permit requirement or audit question ."No" and "Partial" responses represent a
program gap for the purpose of this report. Tables 3-1,3-2 and 3-3 1 includes a summary of program
recommendations to address the gaps identified. Recommendations are provided for program elements that
are rated either "No" or "Partial" on the DEQ Phase II Audit template (Attachment A). High priority
recommendations include those permit areas that do not currently have program documentation to
represent the actions of the program. The program elements listed in Table 3-1 represent the program
elements that are recommended to be addressed in the near term (within 1 year). Each of the program
elements also require coordination throughout the department that elevates the priority.
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II.D.2.a IDDE Program
II.D.2.d Dry Weather Flow Program
II.D.2.f I Tracking and Document Investigations
II.D.2.g Employee Training
II.D.2.i Public Reporting Mechanism
II.D.2.j Enforcement
Illicit Discharge Detection and Elimination
The City should develop a written program document that outlines goals/objectives, program process steps, and provision for
The permittee maintained a written IDDE Program. program assessment and evaluation. The written plan should include schedules for required activities, references to SOPs detailing
If yes, the written program includes provisions for program assessment and evaluation and integrating program. how to complete required activities, reporting and documentation procedures, enforcement procedures, and training requirements
where necessary.
The permittee maintained a program for conducting dry weather flow field observations in accordance with written The city's ditch work crews conductvisual inspections duringtheir normal maintenance activities and report observances in daily
procedures. activity reports. The City should formalize and document this activity as a part of the dry weather screening program and provide
trainingto all personnel who will engage with dry -weather screening.
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
2. The results of the investigation
3. Any follow-up of the investigation
4. The date the investigation was closed
Investigation tracking documentation includes the date the illicit discharge was observed and the results of the investigation. The
City should also include any follow-up to the initial investigation and the close-out date of the investigation to the tracking
documentation.
The permittee implemented and documented a training program for appropriate municipal staff who, as part of their The City held a training session in February 2020 that included many supervisory staff. The City should plan to provide consistent,
normal job responsibilities, may come into contact with or otherwise observe an illicit discharge or illicit connection. ongoing IDDE training opportunities for staff included in executing the IDDE program.
During department interviews, staff indicated thatthe response and directingfor public complaints is a known process for identifying
The permittee established and implemented response procedures for citizen requests/reports. the appropriate City contact to forward the request and following up as necessary. Documenting the response procedure and making
it available to staff that receive public calls would change to a "Yes" status.
The permittee implemented a mechanism to track the issuance of notices of violation and enforcement actions
administered by the permittee.
If yes, the mechanism includes the ability to identify chronic violators for initiation of actions to reduce
noncompliance.
Pollution Prevention and Good Housekeeping
The City maintains a list for illicit discharge violations catalogued by site location. The City should build in a mechanism in the
current tracking document to capture chronic violators in noncompliance.
The inventory is maintained by the Risk Management and Facilities Management Department. The current City inventory list is
The permittee maintained a current inventory of facilities and operations owned and operated by the permittee with maintained according to insured City property and likely includes all properties with high and medium potential to cause significant
II. G.2.a Facility Inventory the potential for generating polluted stormwater runoff. pollution. The City should devise a comprehensive facility inventory list specific to stormwater pollution prevention to confirm
whether all municipal sites are accounted for; this may include a review of the current list and all municipal properties identified by
the County Property Appraiser's Office.
II. G.2.b,c
II.G.2.d
The permittee maintained and implemented an 0&M program for municipally owned and operated facilities with the
potential forgenerating polluted stormwater runoff.
If yes, the 0&M program specifies the frequency of inspections.
Operation and Maintenance (0&M) for facilities If yes, the 0&M program specifies the frequency of routine maintenance requirements.
If yes, the permittee evaluated the 0&M program annually and updated it as necessary.
The permittee had written spill response procedures for municipal operations.
The City should develop an inspection and maintenance program for municipal facilities and operations that have been determined
to have significant potential for generating polluted stormwater runoff. The program should include inspection frequencies, routine
maintenance requirements, procedures to update the facility and operations inventory and identification of properties with potential
to cause significant pollution, and annual assessment of program performance. It is recommended that the development of this plan
is completed in coordination with owning departments to identify roles and responsibilities, as well as document existing and
ongoing practices.
The City should develop a spill response procedure for municipal operations and facilities. It is recommended that the development
of this plan is completed in coordination with owning departments to identify roles and responsibilities, as well as document existing
and ongoing practices.
The permittee evaluated existing and new BMPs that reduce polluted stormwater runoff from municipally -owned
Streets, Roads, and Public Parking Lots streets, roads, and public parking lots within its corporate limits annually. The City currently performs streets, roads, and public parking maintenance in the form of leaf/yard waste collection, street sweeping,
mowing, and inlet cleaning. The City should include annual evaluation of effectiveness of Best Management Practices (BMPs)
Maintenance
If yes, the permittee evaluated the effectiveness of existing and new BMPs based on cost and the estimated quantity utilized in municipally owned streets, roads, and public parking lots.
of pollutants removed.
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Audit/Permit Section Program Element
Program Requirement
II.G.2.f MS4 Conveyance System Inspection and The permittee maintained and implemented an 0&M program forthe stormwater sewer system including catch
Maintenance basins and conveyance systems that it owns and maintains.
II.G.2.j Staff Training The permittee implemented an employee training program for employees involved in implementing pollution
prevention and good housekeeping practices.
II.G.2.k Vehicle and Equipment cleaning The permittee described and implemented measures that prevent or minimize contamination of stormwater runoff
from all areas used forvehicle and equipment cleaning.
Program Recommendations and Suggested Improvements
The City currently performs maintenance activities on conveyance systems and ditches. Maintenance responsibilities are shared
among City construction crews, ditch maintenance crews, and contractors as needed. The City should develop an inspection and
maintenance program document that includes the MS4 including catch basins and the conveyance system.
The City should develop required training for employees on pollution prevention and good housekeeping practices, specifically spill
prevention, storm drain maintenance, and avoiding polluted runoff.
The City should develop guidance for vehicle and equipment washing and maintenance practices that prevent stormwater pollution.
Table 3-2 lists the medium priority recommendations. These program elements have been classified as medium priority as they require a more consistent and time intensive effort to complete (e.g. program implementation and post
construction site runoff controls design). Medium priority is also assigned to program elements that maintain partial documentation and robust program activity in alignment with permit requirements (e.g. public education and
outreach).
Audit/Permit Section
II.A.1
II.A.2
Program Element
Staffing and Funding
Program Requirement
Program Implementation
Program Recommendations and Suggested Improvements
The permittee maintained adequate funding and staffing to implement and manage the provisions of the Stormwater The Stormwater Management Plan should identify specific roles responsible forthe overall coordination, implementation, and
Plan and meet all requirements of the permit. updates to the Plan; responsibilities for all components of the Stormwater Management Plan (SWMP) should be documented and
position(s) assignments provided.
The Stormwater Plan identifies a specific position(s) responsible for the overall coordination, implementation, and
revision to the Plan.
Responsibilities for all components of the Stormwater Plan are documented and position(s) assignments provided.
Stormwater Plan Implementation and Evaluation I The permittee evaluated the performance and effectiveness of the program components at least annually.
II.A.3 ' Stormwater Management Plan (SWMP)
The permittee kept the Stormwater Plan up to date.
The permittee notified DEMLR of any updates to the Stormwater Plan.
The permittee maintained written procedures for implementing the six minimum control measures.
Procedures Written procedures identified specific action steps, schedules, resources and responsibilities for implementing the
six minimum measures.
Public Education and Outreach
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The City should perform an annual staffing evaluation to determine resources needed to operate the MS4 in compliance with the
current permit.
The City should conduct an annual review to evaluate the performance and effectiveness of the stormwater division at meeting the
MS4 permit requirements. Any changes to the SWMP that result should be reported to DEMLR.
The City should update the SWMP to reflectthe current permit. DEQ templates are available to aid in Plan updates
https://files.nc.gov/ncdeg/Energy%20Mineral%20and%20Land%20Resources/Stormwater/MS4 Documents/2021-SWMP-
Tem plate-20210309.docx
The City should submit the updated SWMP to DEMLR.
The City currently performs inspection, maintenance, reporting, and enforcement activities. The City should develop and implement a
written plan incorporating goals/objectives and evaluations for each of the following program areas:
• IDDE Plan
• MS4 0&M Plan
The written plan should include schedules for required activities, references to SOPs detailing how to complete required activities,
reporting and documentation procedures, enforcement procedures, and training requirements where necessary.
Note that typically SCM 0&M Plan would be included as a part of the written procedures, however because the City does not
currently operate municipally owned SCMs a written procedure is not applicable.
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Audit/Permit Section Program Element
Program Requirement
The permittee defined goals and objectives of the Local Public Education and Outreach Program based on
community wide issues.
The permittee maintained a description of the target pollutants and/orstressors and likely sources.
11. B. 2.a -d Goals, Objectives, Target Pollutants, Target
The permittee identified, assessed annually and updated the description of the target audiences likely to have
Audiences
significant storm water impacts and why they were selected.
The permittee described issues, such as pollutants, the likely sources of those pollutants, potential impacts, and the
physical attributes of stormwater runoff in their education/outreach program.
11.B.2.H Public Education and Outreach Program
For each media, event or activity, including those elements implemented locally or through a cooperative agreement
the permittee estimated and recorded the extent of exposure.
Post -Construction Site Runoff Controls Design
The operation and maintenance plan required the owner of each SCM to perform and maintain a record of annual
II.F.2f Mechanism to Require Long-term Operation and
inspections of each SCM.
Maintenance
Annual inspection of permitted structural SCMs are required to be performed by a qualified professional.
The permittee tracked the issuance of notices of violation and enforcement actions.
II.F.2i Enforcement
If yes, the tracking mechanism included the ability to identify chronic violators for initiation of actions to reduce
noncompliance.
Program Recommendations and Suggested Improvements
The City should maintain a document that records the defined goals and objectives, a description of target pollutants and sources
the program is designed to address, target audiences likely to have significant stormwater impact, and why they were selected. These
details were provided verbally during the public education and involvement department interview. This information maybe recorded
within the SWMP or an external City document.
The City gets outreach and exposure reports from their membership with the Clean Water Education Partnership (CWEP) about
regional activities, butthe City should document City -specific outreach activities. A common log should be maintained of
attendance/exposure at City sponsored public education and outreach events. The City should also document and log activity and
exposure from Keep America Beautiful (KAB) programming.
Current private SCMs are about 50% compliant with required annual inspections. The City should develop a plan to achieve and
maintain 100% compliance which includes confirmation of current property owners contact information, tracking annual inspection
responses, and follow-up with non -responders and failed inspections. The City should also employ the available enforcement
mechanisms to aid in achieving compliance, if necessary.
The City is not currently enforcing non-compliance for required annual SCM inspections. The City should employ enforcement
activities to aid in achieving compliance. Enforcement activities should be tracked with the ability to identify chronic violators.
Table 3-3 lists the low priority recommendations. Program elements where no gaps were identified are listed in this table as well as those that can be addressed by utilizing existing DEQ templates (e.g. program implementation). The
table also includes low priority items that require minimal program updates to maintain permit compliance (e.g. construction site runoff controls).
Audit/Permit Section Program Element Program Requirement Program Recommendations and Suggested Improvements
Program Implementation
II.A.4 Availability of Stormwater Plan The permittee kept an up-to-date version of its Stormwater Plan available to the Division and the public online. The City should maintain the updated SWMP on the stormwater website
The permittee maintained documentation of all program components including, but not limited to, inspections, The City should maintain documentation of all program components including, but not limited to, inspections, maintenance
III.A Program Documentation maintenance activities, educational programs, implementation of BMPs, enforcement actions etc., on file for activities, educational programs, implementation of BMPs, enforcement actions etc., on file for a period of five years. Specific areas
period of five years. of the program requiring strengthened documentation are noted in sections below.
111.13 Annual Report Submittal The Annual Reports included appropriate information to accurately describe the progress, status, and results of the The City should use the current DEQ annual report template.
permittee's Stormwater Plan, including, but not limited the following: httos://deci.nc.gov/about/divisions/energy-mineral-and-land-resources/stormwater/stormwater-program/nodes-ms4-1
The Annual Reports document the following:
1. A summary of past year activities, includingwhere applicable, specific quantities achieved and summaries The City currently uses the DEQ annual report template; there appearto be some inconsistency with the annual template and the
of enforcement actions. DEQ audit template. According to the audittemplate questions, he City's annual reporting should include a detailed description of
IV. B Annual Reporting 2. A description of the effectiveness of each program component. the state of implementation of the Stormwater Plan including schedules and plans forthe year following the report. The City's annual
reporting should also describe effectiveness of each program component and a summary and trend of data including assessment of
3. Planned activities and changes forthe next reporting period, for each program component or activity. whatthe data means for implementation of the SWMP
4. Fiscal analysis.
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Audit/Permit Section Program Element
No gaps were identified for this program area.
II.E.3 I Construction Site Runoff Controls
'No gaps were identified for this program area.
Program Requirement
Public Involvement and Outreach
Program Recommendations and Suggested Improvements
Construction Site Runoff Controls
The permittee provides and promotes a means for the public to notify the appropriate authorities of observed erosion Public calls/complaints about erosion and sedimentation problems typically get routed to City Hall byway of the general public
and sedimentation problems (e.g., promoting the existence of the DEQ DEMLR "Stop Mud" hotline). works phone number. The City should promote the stormwater helpline as the appropriate reporting mechanism for observed erosion
and sedimentation problems for consistency in the stormwater hotline use.
Post -Construction Site Runoff Controls Design
TMDLs
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Section 4: Pollution Prevention and Good Housekeeping
Evaluation
This section describes the methods used to screen the City's existing facility inventory to determine select
sites for PPGH evaluations, the methods used to perform field evaluations of the select sites, and to provide
the observations and recommendations from the PPGH evaluation. The facility inventory has been
established by the Property Management department to identify properties leased or owned by the City. BC
categorized the inventory to assess the priority level (high, medium or low) of each site based on the
operations performed at the site and proximity to waterways that could increase the potential to cause
stormwater pollution. The Facility inventory is included in Attachment D.
At this time, the owning department of each facility has been designated as the responsible party for facility
maintenance activities and operations, and the Stormwater Management Division has maintained minimal
coordination with those facilities. The City has not established a written inspection and maintenance
program that coordinates with facilities, identified routine requirement for, inspections and maintenance
activities, roles and responsibilities for both owning departments and Stormwater Management Division, or
an annual program assessment procedure.
City facilities with industrial permits are responsible for developing and maintaining their own site -specific
Stormwater Pollution Prevention Plans (SWPPPs), as required in their industrial permits. The stormwater
engineer has begun consulting with owning departments of the NPDES permitted facilities for their spill
procedures and spill preparedness.
The City provided BC an inventory of City owned facilities from the Property Management Department. From
this list, sites were classified based on the type of activities and operations that are conducted on -site. Once
classified, sites were catalogued as either low, medium, or high priority. Field visits were completed on a
select number of sites that conducted high pollution potential operations (e.g. vehicle maintenance and
fueling).
4.1 Municipal Facility Inventory Evaluation
The purpose of municipal facility evaluation was to identify municipal facilities that have the potential to
generate polluted stormwater runoff. This includes facilities that pose a potential risk of stormwater pollution
based on the types of activities performed on -site. A list of municipal facilities was generated from the 2019-
2020 City Property Schedule for this evaluation. While likely comprehensive for sites with a potential to
generate polluted stormwater runoff, it is recommended that the City review this list with a comprehensive
list of municipal properties from a source such as the County Property Appraiser's Office.
Activities that are considered a potential risk of pollution to the stormwater system include:
• Vehicle repair/ maintenance
• Vehicle/ equipment washing
• Fueling
• Pesticide, herbicide, and fertilizer storage
• Deicing material storage
• Bulk material storage
• Potential for high waste generation, including facilities caring for animals
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NPDES Permitted
Sites were classified based on the type of activities that are typically conducted on -site. BC relied on site
activity descriptions from City staff in this effort. Once classified, sites were given a generalized pollution
potential risk level of Low, Medium, or High (see Attachment D).
4.2 Municipal Facility Visits
From the inventory of City -owned facilities, five sites were selected for field visits to evaluate existing site
procedures for understanding of and adherence to good housekeeping practices to protect the stormwater
system. The five sites selected for field evaluation were:
• Environmental Services Center
• Wastewater Treatment Plant
• Fleet Maintenance Complex
• Fire Station # 1
• Animal Service Unit
Site visits were performed to determine common housekeeping challenges between facilities, operations,
and City staff practices. The field team was comprised of both BC and City of Rocky Mount staff. The team
completed a field evaluation form for each facility. A blank copy of the field form can be found in Appendix C.
Upon arrival at each facility, the team met with the facility operator(s) to discuss typical activities and
response procedures that occur on -site. While touring the facility, the team focused on activities identified
during the initial discussion, verifying that the specific structural components were in place for each activity.
During site visits the ream also discussed protocols and re
4.3 Observations
Based on field inspections, there are a few inconsistencies in the implementation of good housekeeping
requirements between facilities. The purpose of this section is to outline the procedures and observations to
aid in the adoption of a consistent approach across facilities to establish the good housekeeping program.
4.3.1 Spill Kits and Spill Response
The most common observation made across all facilities was the appropriate placement, stocking, and
labeling of spill kits. Individual spill kits should be easy to locate and in close proximity to any high spill
potential activity, such as fueling stations, maintenance areas, bulk liquid/waste oil storage, and waste
receptacles. Spill kits should contain fresh absorbents and should be checked for inventory on a set
schedule. Signage should be posted where spill kits are located with instructions on handling a spill and who
to call if a spill occurs. Figure 4-1 shows an example of appropriate signage for a fueling station.
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Figure 4-1. Spill response signage
In addition to having spill kits accessible, some facilities did not have a written procedure for spill response.
Spill response training should be offered by the City for municipally owned facility staff.
4.3.2 Waste Storage
Another observation made during the field visits was inconsistencies in waste storage. Spent oil or other
liquid waste should be stored in appropriately labeled containers, including secondary containment. These
containers should be securely covered to prevent stormwater runoff. If temporary basins or containers are
used for liquid waste, they should be immediately transferred to the appropriate waste area once the activity
is complete. Waste containers should be inspected regularly for signs of corrosion or other indicators that a
spill may occur in the future. Opaque containers should have a level gauge or overflow structure to prevent
overfilling. Double -walled containers can also be used as secondary containment to further prevent spills. As
discussed in Section 4.3.2, areas with liquid waste storage should have at least one spill kit within close
proximity.
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Figure 4-2. Improper Waste Oil Storage
All City -owned facilities possess dumpsters for solid waste storage. Some dumpsters were observed to be
overfilled, which led to trash being blown out of the container. Solid waste storage containers, such as
dumpsters, should be covered to properly contain the waste and reduce the mixing of stormwater runoff and
solid waste leachate. Dumpsters should be located in an area that is accessible for routine pick up and
should be placed on stable, even ground.
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Figure 4-3. Improper Dumpster Storage
4.3.3 Inlet Protection:
Some areas were observed to be lacking inlet protection in high runoff areas. This led to some inlets being
obstructed with sediment and trash. Protective filter socks or similar device should be used when inlets are
located in areas with high potential for runoff. This prevents pollution downstream and reduces the
frequency of maintenance within the MS4. The City could engage in an inlet inspection schedule that would
allow for inlets to receive maintenance/cleaning before they become obstructed. Additionally, during the
field audits, a washing station was observed in close proximity to an inlet. Guidance should be provided
about what activities/operations can be safely completed in close proximity to stormwater inlets.
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MS4 Gap Analysis Report
x
4.4 Recommendations
�..
Figure 4-4. Inlet Obstruction
From this evaluation the following recommendations have been developed for the PPGH compliance:
• Site Pollution Prevention Plans. The City does not maintain facility specific 0&M plans or site -specific
spill response procedures and need to be developed for municipal facilities owned and operated by the
City that have significant potential for generating polluted stormwater runoff. BC recommends that the
Stormwater Management Division should coordinate with facilities to establish spill response plans for
identified facilities and operations.
• Spill Response. The City does not maintain spill response procedures; these need to be developed for
municipal facilities and operations. The City should coordinate with facilities to establish spill response
procedures for identified municipal operations that include guidance on maintaining adequate spill kits.
• Waste Storage. The City does not provide requirements for waste storage (e.g. bulk used oil) that would
aid in pollution prevention. The City should provide training or information on practices and level and/or
containment mechanisms for waste oil.
• Inlet Protection. Some inlets were clogged and/or surrounded by debris or in line with operations that
could cause pollution to the stormwater sewer. The City should provide guidance and an
inspection/maintenance interval to ensure inlet protection.
• NPDES Permitting. Based on preliminary discussion with DEQ, it was noted by Jeanette Powell (MS4
Program Coordinator) that most municipal fleet maintenance facilities are subject to the NCGO80000
permit and that the regional office staff make that specific determination for a facility. The City does not
currently have an industrial permit for its fleet maintenance facility. The City is not obligated to initiate
the permitting process; the State would make the designation and follow though the permitting process
and the City should be aware of this potential industrial permit designation.
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MS4 Gap Analysis Report
Section 5: Next Steps
The assessments and recommendations provided in this report are presented to prepare City for the
upcoming MS4 audit. The City can use these as a means to fill gaps in the implementation of the existing
stormwater permit.
References
North Carolina Department of Environmental Quality. "Draft Phase II MS4 Audit Template." 2019.
https://files.nc.P-ov/ncdeq/Energy%20Mineral%20and%2OLand%2OResources/Stormwater/MS4 Documents/Phase-Il-
MS4-Audit-Report-TEMPLATE. DOCX (July 1, 2020).
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MS4 Gap Analysis Report
Attachment A: DEQ Phase II Audit Template
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MS4 Gap Analysis Report
Program Implementation, Documentation, & Assessment
Staff Interviewed:
(Name, Title, Role)
Permit Citation
Program Requirement
Status
Supporting
Doc No.
II.A.1
The permittee maintained adequate funding and staffing to implement and manage
Staffing and
the provisions of the Stormwater Plan and meet all requirements of the permit.
Partial
Funding
The Stormwater Plan identifies a specific position(s) responsible for the overall
coordination, implementation, and revision to the Plan.
No
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
monitoring fees (see stormwater e-payments on DEMLR MS4 web page).
Yes
---
Comments (Briefly describe funding mechanism, number of staff, etc.)
During department interviews, staff indicated a need for staffing support particularly the maintenance and repair crews for the
sewer conveyance systems.
The 2014 SWMP does not include an indication or description of persons responsible for the implementation and maintenance of the
SWMP.
II.A.2 Stormwater
The permittee evaluated the performance and effectiveness of the program
Plan
components at least annually.
No
---
Implementation
and Evaluation
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
applicable water quality standard?
Yes
---
If yes, did the permittee expand or better tailor its BMPs accordingly to
Not
address the non -attainment?
Applicable
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MS4 Gap Analysis Report
Program Implementation, Documentation, & Assessment
Comments
II.A.3
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.
Not
Applicable
Comments (Indicate the date of latest Stormwater Plan and describe the nature of any updates, if applicable).
II.A.4 Availability
The permittee kept an up-to-date version of its Stormwater Plan available to the
of the Stormwater
Division and the public online.
No
---
Plan
The online materials included ordinances, or other regulatory mechanisms, or a list
identifying the ordinances, or other regulatory mechanisms, providing the legal
Yes
---
authority necessary to implement and enforce the requirements of the permit.
Comments (Note what materials are available on line)
I.
I & II.A.3 I.A.S
Not
Stormwater Plan
Did DEMLR require a modification to the Stormwater Plan?
Applicable
---
Modifications
If yes, did the permittee complete the modifications in accordance with the
Not
established deadline?
Applicable
Comments (Note date of DEMLR notification, modifications required, and date modifications were completed, as applicable)
II.A.6 Sharing
Responsibility
Are any control measures implemented by an entity other than the permittee?
Yes
---
If yes, is there a written agreement in place?
Yes
---
Comments (List the specific control measures implemented by others that do not have adequate written agreements, if
applicable)
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Program Implementation, Documentation, & Assessment
II.A.7
The permittee maintained written procedures for implementing the six minimum
Written
control measures.
Partial
---
Procedures
Written procedures identified specific action steps, schedules, resources and
responsibilities for implementing the six minimum measures.
Partial
---
Comments (List the specific minimum measures that do not have adequate written procedures, if applicable)
Written procedures are inconsistently maintained across the six minimum control measures. Areas that need specific work on
written procedures are addressed in the sections below.
Ill A
The permittee maintained documentation of all program components including, but
Program
not limited to, inspections, maintenance activities, educational programs,
Partial
---
Documentation
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)
Documentation is inconsistently maintained across the six minimum control measures. Areas that need specific work on written
procedures are addressed in the sections below.
111.113
The permittee submitted annual reports to the Department within twelve months
Annual Report
from the effective date of the permit (See Section 111.8. for the annual reporting
Yes
---
Submittal
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
---
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
Partial
---
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
Plan.
Applicable
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
Partial
---
Stormwater Plan.
5. An assessment of compliance with the permit, information on the
establishment of appropriate legal authorities, inspections, and enforcement
Yes
---
actions.
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MS4 Gap Analysis Report
Program Implementation, Documentation, & Assessment
Comments (Note dates that annual reports cover under current permit and generally describe report deficiencies, if any)
The latest annual report (2020) appears to use the DEQ template. There is a narrative addition option in the annual reporting
format that would allow for adding the additional detail listed as "Partial"
IV.B
Annual Reporting
The Annual Reports document the following:
1. A summary of past year activities, including where applicable, specific
quantities achieved and summaries of enforcement actions.
Yes
---
2. A description of the effectiveness of each program component.
No
---
3. Planned activities and changes for the next reporting period, for each
program component or activity.
No
---
4. Fiscal analysis.
Yes
---
Comments (Note dates that annual reports cover under current permit and generally describe report deficiencies, if any)
Public Education and Outreach
Staff Interviewed:
(Name, Title, Role)
Permit Citation
Program Requirement
Status
Supporting
Doc No.
11.6.2.a
The permittee defined goals and objectives of the Local Public Education and
Goals and
Outreach Program based on community wide issues.
Partial
---
Objectives
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Public Education and Outreach
Comments (Generally describe process for establishing goals/objectives)
Staff interviews indicated that the goals exist, and objectives exists. The "Partial" status acknowledges the verbal understanding of
goals and objectives. These should be formalized in a written document to achieve a "Yes".
II.B.2.b
The permittee maintained a description of the target pollutants and/or stressors and
Target Pollutants
likely sources.
No
---
Comments (List target pollutants, note any that are missing or not appropriate)
II.B.2.c
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.
Yes
---
Comments (Describe any changes made, if applicable)
II.B.2.d Residential
The permittee described issues, such as pollutants, the likely sources of those
and Industrial/
pollutants, potential impacts, and the physical attributes of stormwater runoff in
Yes
---
Commercial Issues
their education/outreach program.
Comments (Generally describe the residential/industrial/commercial issues addressed)
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MS4 Gap Analysis Report
Public Education and Outreach
I I. B.2.e
The permittee promoted and maintained an internet web site designed to convey the
Informational
program smessage.
Yes
---
Web Site
Comments (list web page address and general contents, or attach screen shot of landing page)
II.B.2.f
Public Education
The permittee distributed stormwater educational material to appropriate target
---
Materials
groups.
Yes
Comments (List distributed materials and quantity, message, distribution mechanism, target audience for each if not included in
program documentation/annual reporting)
II.B.2.g
The permittee promoted and maintained a stormwater hotline/helpline for the
Hotline/Help Line
purpose of public education and outreach.
Yes
---
Comments (Note hotline contact information and method(s) for advertising it)
II.B.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
Yes
---
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
Partial
---
of exposure.
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Public Education and Outreach
Comments (Generally describe approaches, extent of exposure. Note any cooperating entities, agreements and scope of services,
or reference comments in Section II.A.6. above.)
Staff interviews described receiving extent of exposure documentation from membership with the Clean Water Education
Partnership (CWEP) and Keep America Beautiful (KAB) initiatives. The City should maintain a log of recorded events and exposure
City sponsored events.
Additional
Comments:
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Public Involvement and Participation
Staff Interviewed:
(Name, Title, Role)
Permit Citation
Program Requirement
Status
Supporting
Doc No.
II.C.2.a Volunteer
Community
The permittee included and promoted volunteer opportunities designed to promote
Involvement
ongoing citizen participation.
Yes
Program
Comments (Note opportunities promoted and date(s) of volunteer events)
II.C.2.b
Mechanism for
The permittee provided and promoted a mechanism for public involvement that
Public
provides for input on stormwater issues and the stormwater program.
Yes
Involvement
Comments (Note mechanism(s) for input and how promoted)
II.C.2.c
The permittee promoted and maintained a hotline/helpline for the purpose of public
Hotline/Help Line
involvement and participation.
Yes
---
Comments (Note hotline contact information and how it is promoted)
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Public Involvement and Participation
Additional
Comments:
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Illicit Discharge Detection and Elimination (IDDE)
Staff Interviewed:
(Name, Title,
Role)
Permit Citation
Program Requirement
Status
Supporting
Doc No.
II.D.2.a
IDDE Program
The permittee maintained a written IDDE Program.
No
---
If yes, the written program includes provisions for program assessment and
evaluation and integrating program.
No
---
Comments (Note any deficiencies)
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
---
II.D.2.b
Legal Authorities
If yes, the ordinance applies throughout the corporate limits of the permittee.
[Permit Part I.D]
Yes
--
Comments
II.D.2.c
The permittee maintained a current map showing major outfalls* and receiving
Storm Sewer
Yes
---
System Map
streams.
Comments
*Major outfalls are discharges from > 36" diameter pipes or drainage areas of > 50 acres. In areas zoned for industrial activity, major outfalls
are > 12" or drainage area > 2 acres.
II.D.2.d
The permittee maintained a program for conducting dry weather flow field
Dry Weather Flow
observations in accordance with written procedures.
Partial
---
Program
During department interviews staff indicated that ditch crews were currently conducting dry weather screening activities during
ditch maintenance. Formalizing these actions into a written plan and documentation.
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Illicit Discharge Detection and Elimination (IDDE)
II.D.2.e
The permittee maintained written procedures for conducting investigations of
Investigation
identified illicit discharges.
Yes
---
Procedures
Comments (Generally describe what procedures are documented)
II.D.2.f
For each case of an illicit discharge or potential illicit discharge, the permittee documented and tracked the
Track and
following:
Document
Investigations
1. The date(s) the illicit discharge was observed
Yes
---
2. The results of the investigation
Yes
---
3. Any follow-up of the investigation
No
---
4. The date the investigation was closed
No
---
Comments (Note whether a standard inspection form is utilized to capture consistent information and a tracking mechanism is
used)
II.D.2.9 Employee
The permittee implemented and documented a training program for appropriate
Training
municipal staff who, as part of their normal job responsibilities, may come into
Partial
---
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)
The City conducted a training for certain staff in 2020. To move from "Partial" to "Yes" the City should create a plan that identifies
staff that need training and provide regular opportunities for identified staff to be trained and that training to be documented.
II.D.2.h
The permittee informed public employees of hazards associated with illegal
Public Education
discharges and improper disposal of waste.
Yes
---
The permittee informed businesses of hazards associated with illegal discharges and
improper disposal of waste.
Yes
---
The permittee informed the general public of hazards associated with illegal
discharges and improper disposal of waste.
Yes
---
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Illicit Discharge Detection and Elimination (IDDE)
Comments (Note how each sector was informed, if applicable)
II.D.2.i
The permittee promoted, publicized, and facilitated a reporting mechanism for the
Public Reporting
public to report illicit discharges.
Yes
--
Mechanism
The permittee promoted, publicized, and facilitated a reporting mechanism for staff
to report illicit discharges.
Yes
The permittee established and implemented response procedures for citizen
requests/reports.
Partial
--
Comments (Generally describe reporting mechanisms and how promoted/publicized/facilitated/established)
During department interviews, staff indicated that the response and directing for public complaints is a known process for
identifying the appropriate City contact to forward the request and following up as necessary. Documenting the response
procedure and making it available to staff that receive public calls would change to a "Yes" status.
II.D.2.i
The permittee implemented a mechanism to track the issuance of notices of violation
Enforcement
and enforcement actions administered by the permittee.
Yes
If yes, the mechanism includes the ability to identify chronic violators for
initiation of actions to reduce noncompliance.
No
--
Comments (Generally describe the established tracking mechanism, if applicable)
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Construction Site Runoff Controls
Staff Interviewed:
(Name, Title, Role)
Program Delegation Status:
❑ The permittee has a delegated Sediment and Erosion Control Program and implements the North Carolina
Sedimentation Pollution Control Act (SPCA) of 1973 components of this minimum measure (complete the permit
citation and SPCA citation sections).
❑ The permittee does not have a delegated Sediment and Erosion Control Program and relies on DEMLR to comply
with the North Carolina Sedimentation Pollution Control Act (SPCA) of 1973 components of this minimum measure
(complete only the permit citation section).
Permit Citation
Program Requirement
Status
Supporting
Doc No.
II.E.3 Construction
Site Runoff Controls
The permittee provides and promotes a means for the public to notify the
(NPDES Permit No.
appropriate authorities of observed erosion and sedimentation problems (e.g.,
Partial
-
NCS000435]
promoting the existence of the DEQ DEMLR "Stop Mud" hotline).
Comments (Describe how provided and promoted)
During department interviews, staff indicated that calls are sometimes routed from other departments as opposed to calls coming
directly to the stormwater helpline. The City should advertise the helpline as the appropriate contact for erosion and sedimentation
problems.
SPCA Citation
Delegated Program Requirement
Status
Supporting
Doc No.
§ 113A-60 Local
erosion and
The permittee has adopted an ordinance or other regulatory mechanism to enforce
sedimentation
the erosion and sedimentation control program.
Yes
control programs (a)
If yes, the ordinance meets or exceeds the minimum requirements of the
SPCA.
Yes
If yes, the ordinance applies throughout the corporate limits of the permittee.
[Permit Part I.D]
Yes
Comments (Provide regulatory mechanism reference or Supporting Documentation number)
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Construction Site Runoff Controls
§ 113A-60 Local
erosion and
The permittee collects a fee paid by each person who submits an erosion and
sedimentation
sedimentation control plan.
Yes
--
control programs (d)
Comments (indicate the fee amount, if applicable)
§ 113A-60 Local
Has any person initiated a land -disturbing activity (within the permittee's
erosion and
jurisdiction) for which an erosion and sedimentation control plan is required in the
No
--
sedimentation
absence of an approved plan?
control programs (e)
If yes, the permittee has notified the North Carolina Sedimentation Control
Not
Commission of all such cases.
Applicable
Has the permittee determined that a person engaged in a land -disturbing activity
has failed to comply with an approved erosion and sedimentation control plan?
No
If yes, has the permittee referred any such matters to the North Carolina
Not
Sedimentation Control Commission for inspection and enforcement?
Applicable
Comments
§ 113A-61 Local
The permittee reviews each erosion and sedimentation control plan submitted to
approval of erosion
them and notifies the person submitting the plan that it has been approved,
Yes
and sedimentation
approved with modification, or disapproved within 30 days of receipt.
control plans
The permittee only approves an erosion and sedimentation control plan upon
determining that it complies with all applicable State and local regulations.
Yes
The permittee has disapproved of an erosion and sedimentation control plan in
order to protect riparian buffers along surface waters.
No
If yes, the permittee notified the Director of the Division of Energy, Mineral,
Not
and Land Resources within 10 days of the disapproval.
Applicable
Comments
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Construction Site Runoff Controls
§ 113A-61.1
The certificate of approval of each erosion and sedimentation control plan
Inspection of land-
approved by the permittee includes a notice of the right to inspect.
Yes
--
disturbing activity;
notice of violation
The permittee provides for inspection of land -disturbing activities to ensure
(a)
compliance with the SPCA and to determine whether the measures required in an
Yes
--
erosion and sedimentation control plan are effective.
Comments
§ 113A-61.1
When the permittee determines that a person engaged in land -disturbing activity
Inspection of land-
has failed to comply with the SPCA, the Permittee immediately issues a notice of
Yes
--
disturbing activity;
violation upon that person.
notice of violation
(c)
Each notice of violation issued by the permittee specifies the date by which the
--
person must comply.
Yes
Each notice of violation issued by the permittee informs the person of the actions
that need to be taken to comply.
Yes
--
Comments
113A-64 Penalties
Does the permittee issue civil penalties as part of the erosion and sedimentation
program?
Yes
--
Comments (indicate when/why a civil penalty is issued, and the amount, if applicable)
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MS4 Gap Analysis Report
Post -Construction Site Runoff Controls
Staff Interviewed:
(Name, Title, Role)
Implementation (check all that apply):
❑x The permittee implements the components of this minimum measure.
❑ The permittee relies upon another entity to implement the components of this minimum measure: N/A
❑ 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 2B .0212
❑ Water Supply Watershed 11 (WS-11) — 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 (HOW) — 15A NCAC 2H .1006
❑ Freshwater Outstanding Resource Waters (ORW) — 15A NCAC 2H .1007
❑ Neuse River Basin Nutrient Sensitive (NSW) Management Strategy — 15A NCAC 2B .0235
❑x Tar -Pamlico River Basin Nutrient Sensitive (NSW) Management Strategy — 15A NCAC 2B .0258
❑ Randleman Lake Water Supply Watershed Nutrient Management Strategy — 15A NCAC 2B .0251
❑ Universal Stormwater Management Program — 15A NCAC 2H .1020
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):
❑x DEQ model ordinance
❑ MS4 designed post -construction practices that meet or exceed 15A NCAC 02H .1000.
❑ DEQ approved comprehensive watershed plan
❑x 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.
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Post -Construction Site Runoff Controls
Session Law 2006-
Program Requirement
Status
supporting
246
Doc No.
Deemed -Compliant
The permittee implements deemed -compliant Program requirements in
Program(s)
accordance with the applicable 15A NCAC rules.
Yes
---
The permittee implements deemed -compliant Program requirements throughout
the entire MS4 area (If not, also complete the Permit Citation section below.)
Yes
---
The permittee applies deemed -compliant Program requirements to all federal,
state and local government projects within the permitted MS4 area who do not
Yes
---
have their own NPDES stormwater permit.
The permittee included deemed -compliant Program reporting in their MS4
Annual Reports.
The permittee included deemed -compliant Program implementation in their
Stormwater Management Plan.
Yes
---
Comments
Permit Citation
Program Requirement
Status
Supporting
Doc No.
II.F.2.a
The permittee maintained an ordinance or other regulatory mechanism designed
Legal Authority
to meet the objectives of the Post -Construction Site Runoff Controls Stormwater
Yes
---
Management Program.
If yes, the ordinance applies throughout the corporate limits of the permittee
(Verify permit coverage area listed in Part I.D of permit and modify
Yes
---
accordingly).
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)
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Post -Construction Site Runoff Controls
II.F.2.b
Stormwater Control
The permittee utilizes strategies which include SCMs appropriate for the MS4.
Yes
---
Measures (SCMs)
SCMs comply with 15A NCAC 02H .1000.
Yes
---
Comments
II.F.2.c
The permittee conducted site plan reviews of all new development and
Plan Reviews
redeveloped sites that disturb greater than or equal to one acre (including sites
that disturb less than one acre that are part of a larger common plan of
Yes
---
development or sale).
If yes, the site plan reviews addressed how the project applicant meets the
performance standards.
Yes
---
If yes, the site plan reviews addressed how the project will ensure long-term
maintenance.
Yes
---
Comments
II.F.2.d
The permittee maintained an inventory of projects with post -construction
Inventory of Projects
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.
Comments
II.F.2.e
The permittee provided mechanisms such as recorded deed restrictions and
Deed Restrictions
protective covenants that ensure development activities will maintain the project
Yes
---
and Protective
consistent with approved plans.
Covenants
Comments
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Post -Construction Site Runoff Controls
II.F.2.f
The permittee implemented or required an operation and maintenance plan for
Mechanism to
the long-term operation of the SCMs required by the program.
Yes
---
Require Long-term
Operation and
The operation and maintenance plan required the owner of each SCM to perform
Maintenance
and maintain a record of annual inspections of each SCM.
Yes
---
Annual inspection of permitted structural SCMs are required to be performed by a
qualified professional.
Partial
---
Comments
During department interviews, staff indicated that only 50 percent of permitted SCMs are providing documentation for compliance
with annual inspections. Making a plan to achieve compliance with the remaining SCM owners and enforcing noncompliance
II.F.2.g
The permittee conducted and documented inspections of each project site covered
Inspections of
under performance standards, at least one time during the permit term (Verify this
Not
Structural
is a permit condition in Part II.F.2.g of permit and modify accordingly).
Applicable
Stormwater Control
Before issuing a certificate of occupancy or temporary certificate of occupancy, the
Measures
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
No
---
condition in Part II.F.2.g of permit and modify accordingly.
The permittee documented and maintained records of inspections.
Yes
---
The permittee documented and maintained records of enforcement actions.
No
---
Comments
II.F.2.h
The permittee made available through paper or electronic means, ordinances,
Educational
post -construction requirements, design standards checklists, and other materials
Materials and
appropriate for developers.
Training for
Note: New materials may be developed by the permittee, or the permittee may use
Yes
---
Developers
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)
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MS4 Gap Analysis Report
Post -Construction Site Runoff Controls
II.F.2.i Enforcement
The permittee tracked the issuance of notices of violation and enforcement
actions.
No
---
If yes, the tracking mechanism included the ability to identify chronic violators
for initiation of actions to reduce noncompliance.
No
---
Comments
II.F.3.b
The permittee fully complies with post construction program requirements on its
New Development
own publicly funded construction projects.
Yes
---
Comments
II.F.3.c
Does the MS4 have areas draining to Nutrient Sensitive Waters (NSW) pursuant to
Nutrient Sensitive
15A NCAC 02H .0150?
Yes
---
Waters
If yes, does the permittee use SCMs that reduce nutrient loading in order to
meet local program requirements.
Yes
---
If yes, does the permittee also still incorporate the stormwater controls
required for the project's density level.
Yes
---
If yes, does the permittee also require documentation where it is not feasible
Not
to use SCMs that reduce nutrient loading.
Applicable
Comments (Provide reference for local requirements)
II.F.3.d
The permittee ensured that the design volumes of SCMs take into account the
Design Volume
runoff at build out from all surfaces draining to the system.
Yes
---
Where "streets" convey stormwater, the permittee designed SCMs to be sized to
treat and control stormwater runoff from all surfaces draining to the SCM including
Yes
---
streets, driveways, and other impervious surfaces.
Comments
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MS4 Gap Analysis Report
Pollution Prevention and Good Housekeeping for Municipal Operations
Staff Interviewed:
(Name, Title, Role)
Permit Citation
Program Requirement
Status
Supporting
Doc No.
II.G.2.a
The permittee maintained a current inventory of facilities and operations owned
Facility Inventory
and operated by the permittee with the potential for generating polluted
Partial
---
stormwater runoff.
Comments (Note number of facilities, typical inventory data and any facilities that are not inventoried that should be)
The City maintains a list of properties leased or owned by the City which likely captures most high and medium priority sites for
generating polluted stormwater runoff. Because this list is maintained by the Property Management department it is based on
insurance thresholds. Cross referencing this list with property ownership records should provide a complete list of parcels o wned by
the City.
II.G.2.b
The permittee maintained and implemented an O&M program for municipally
Operation and
owned and operated facilities with the potential for generating polluted
No
---
Maintenance (O&M)
stormwater runoff.
for Facilities
If yes, the 0&M program specifies the frequency of inspections.
No
---
If yes, the 0&M program specifies the frequency of routine maintenance
requirements.
No
---
If yes, the permittee evaluated the O&M program annually and updated it as
No
---
necessary.
Comments
II.G.2.c
Spill Response
The permittee had written spill response procedures for municipal operations.
No
---
Procedures
Comments
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MS4 Gap Analysis Report
Pollution Prevention and Good Housekeeping for Municipal Operations
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
---
Parking Lots
corporate limits annually.
Maintenance
If yes, the permittee evaluated the effectiveness of existing and new BMPs
based on cost and the estimated quantity of pollutants removed.
No
--
Comments
II.G.2.f
The permittee maintained and implemented an O&M program for the stormwater
O&M for Catch
sewer system including catch basins and conveyance systems that it owns and
Partial
---
Basins and
Conveyance Systems
maintains.
Comments (Briefly describe O&M program)
The C&M program conducts regular maintenance activity on the sewer system; the City should document the program goals and
metrics.
II.G.2.g
The permittee maintained a current inventory of municipally -owned or operated
Structural
structural stormwater controls installed for compliance with the permittee's post-
Not
Stormwater Controls
construction ordinance.
Applicable
Comments (Describe inventory information and number of controls in inventory)
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MS4 Gap Analysis Report
Pollution Prevention and Good Housekeeping for Municipal Operations
II.G.2.h
The permittee maintained and implemented an O&M program for municipally -
O&M for Structural
owned or maintained structural stormwater controls installed for compliance with
Not
Stormwater Controls
the permittee's post -construction ordinance. If yes, then:
Applicable
The 0&M program specified the frequency of inspections and routine
Not
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
Comments
See section II.G.2g.
II.G.2.11
The permittee ensured municipal employees are properly trained in pesticide,
Pesticide, Herbicide
herbicide and fertilizer application management.
Yes
and Fertilizer
Application
The permittee ensured contractors are properly trained in pesticide, herbicide and
Management
fertilizer application management.
Yes
The permittee ensured all permits, certifications, and other measures for
applicators are followed.
Yes
--
Comments
II.G.2J
The permittee implemented an employee training program for employees involved
Staff Training
in implementing pollution prevention and good housekeeping practices.
No
---
Comments
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MS4 Gap Analysis Report
Pollution Prevention and Good Housekeeping for Municipal Operations
II.G.2.k The permittee described and implemented measures that prevent or minimize
Vehicle and contamination of stormwater runoff from all areas used for vehicle and equipment No --
Equipment Cleaning I cleaning.
Comments
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MS4 Gap Analysis Report
Total Maximum Daily Loads (TMDLs)
Staff Interviewed:
(Name, Title, Role)
Program Status:
❑x The permittee is not subject to an approved TMDL (skip the rest of this section).
❑ The permittee is subject to an approved TMDL for: name of parameter(s) and date(s) approved
There ❑ is ❑ is not a Waste Load Allocation (WLA) in the approved TMDL (If there is a WLA, then complete items H.H.1-5
below. If there is not a WLA, skip to item II.H.6 below)
Permit Citation
Program Requirement
Status
Supporting
Doc No.
II.H.3 TMDLs
Within 12 months of final TMDL approval, the permittee's annual reports included
a description of existing programs, controls, partnerships, projects and strategies to
Not
address impaired waters.
Applicable
Within 12 months of final TMDL approval, the permittee's annual reports provided
a brief explanation as to how the programs, controls, partnerships, projects and
Not
strategies address impaired waters.
Applicable
Comments
II.H.4 TMDLs
Within 24 months of final TMDL approval, the permittee's annual reports included
an assessment of whether additional structural and/or non-structural BMPs are
Not
necessary to address impaired waters.
Applicable
Within 24 months of final TMDL approval, the permittee's annual reports included
a brief explanation as to how the programs, controls, partnerships, projects and
Not
strategies address impaired waters.
Applicable
Comments
II.H.5 TMDLs
Within 36 months of final TMDL approval, the permittee's annual reports included
a description of activities expected to occur and when activities are expected to
Not
occur.
Applicable
Comments
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Total Maximum Daily Loads (TMDLs)
II.H.6 TMDLs
If there is no Waste Load Allocation in the approved TMDL, the permittee
evaluated strategies and tailored and/or expanded BMPs within the scope of the
Not
six minimum measures to enhance water quality recovery strategies in the
Applicable
watershed(s) to which the TMDL applies.
The permittee described strategies and tailored and/or expanded BMPs in their
Not
Stormwater Management Plan and annual reports
Applicable
Comments
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MS4 Gap Analysis Report
Attachment B: Meeting and Site Visit Summaries
Brown... Caldwell
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MS4 Gap Analysis Report
Meeting Topics
Staff
Melissa Wright
Public Education and Outreach & Public Involvement
Stephane Collins
Meeting 1
and Participation Programs (including call center for
Kelly Cook
hotline/helpline)
Scott Miles
Donald Perry (cc)
Scott Miles
Steve Spruill
Meeting 2
IDDE
Chris Pridgen
Donald Perry(cc)
Scott Miles
Meeting 3
Construction Site Runoff Controls and Post-
Allen Goff
Construction Site Runoff Controls
Bill Pridgen
Meeting4 I PPGH
Donald Perry (cc)
Scott Miles
Steve Spruill
Bill Pridgen
Michael Baughn
Donald Perry (cc)
Site
Staff
Date
Address
Site Visit 1
Environmental Services
Cameron Privott
April 7
1221 Thorpe Road.
Site Visit 2
Wastewater Treatment Plant
James Costello
3030 Treatment Plant Rd.
106 E. Grand Ave
Site Visit 3
Fleet Maintenance Complex
Michael Shaw
Site Visit 4
Fire Station 1
William Hale
105 Rowe Dr.
Site Visit 5
Animal Shelter
Boykin
1017 N. Church St.
Brown -.Caldwell
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MS4 Gap Analysis Report
Attachment C: Pollution Prevention and Good
Housekeeping Field Audit Template
Brown... Caldwell
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MS4 Gap Analysis Report
General Evaluation Info
Facility Name:
Facility Address:
Date/Time:
Weather Description:
Inspector Name:
Facility/City Staff Present:
Good Housekeeping Categories (check all that apply):
❑ Bulk Material Storage ❑ NPDES Permitted ❑ Fueling
❑ Vehicle Washing ❑ Animal Waste ❑ Vehicle Maintenance
❑ Waste Management ❑ Other ❑ Other
Inspection Components
Comments
SWPPP or other Stormwater Plans
Is there an approved SWPPP or other stormwater
plan on site?
Does the SWPPP include a site map, potential
sources of pollution, and control measures/ BMPs
Does the SWPP contain inspection and
maintenance procedures?
Does the SWPPP identify a pollution prevention
team (responsible for ensuring the plan is followed
and facilitating corrective action)?
Does the SWPPP contain a spill response plan?
Does the SWPPP identify employee training
requirements? May include RCRA, SPCC, or spill
response training. Have employees received this
training?
Waste Management
Are waste containers covered? Are waste remaining
in containers?
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MS4 Gap Analysis Report
Inspection Components
Comments
Has waste been properly disposed?
General Housekeeping
Are storm drains free of debris and properly
labeled?
Are materials stored away from high traffic areas?
Are any routine inspections performed for
stormwater Pollution prevention?
Are any checklists or records maintained for good
housekeeping activities?
Are spill response procedures accessible and
known?
Are spill response kits accessible and
maintained/stocked?
Any pesticide/herbicides/fertilizers used on site
(i.e. for landscaping efforts)?
Vehicle Maintenance, Fueling, and Washing
Are there designated areas for maintenance
activities? Do these areas drain into the sanitary
sewer? Are there spill kits available nearby?
Are fueling stations designated and are the stations
properly labeled? Are spill kits available nearby?
Are washing areas designated and are there BMPs
to prevent pollution to the MS4?
Material Storage
Are bulk materials and chemicals covered or stored
in secondary containment?
Are bulk material containers labeled?
How are bulk materials transferred and handled?
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MS4 Gap Analysis Report
Inspection Components
Comments
Hazardous Waste Management
Are all hazardous materials properly labeled (in
compliance with OSHA standards)?
Are all hazardous materials stored in a way that is
protected from stormwater runoff?
Are spill kits available near the hazardous waste
storage area?
Other general notes and observations:
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MS4 Gap Analysis Report
Attachment D: Municipally Owned Facilities for PPGH
Program
Brown -.Caldwell
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Final RM MS4 Gap Analysis Report

MS4 Gap Analysis Report
Name
Pollution Preventionand
Address
Good Housekeeping Inventory
Use of asset
List
Category
Pollution
Potential
Admin. Bldg & City Hall
331 S. Franklin St.
City Hall/Adm. Offices
None - Office
Low
Administrative Building
3031 TreaRtdment Plant
Building/equip/offices
NPDES
Medium
Amoco fibers
1245 Atlantic Ave
Generator
None
Low
Athletic Stadium
1400 N Church St
Football field with 5000 stadium
seats
None
Low
Booster Pump
2080 S.Halifax Road
Station equipment
None - Pump Station
Low
Booster Station
3120 N. Church St
Station
None
Low
BTW Community center
747 Pennsylvania Ave
Center/offices
None - Office
Low
BTW Gym
720 Carolina Ave
Gym
None
Low
Bus Station
111 Coast Line Street
Bus Station
None
Low
Cheesecake Factory
6792 Corporation
Parkway
Generators
None
Low
Children's Museum/Art Center
270 Gay St.
Imperial Center
None
Low
City Hall
331 S. Church St
Generators
None
Low
CityWharehouse/Stemmary
bid
720-724 Albemarle Ave
Warehouse/offices
Vehicle Washing/Maintenance
High
Communications Tower
1255 Thorpe Road
City communications bldg
None - Office
Low
Denton Rd Pool
1434 Denton St.
Pool & bath house
None
Low
Draka Industries
2151 N. Church St
Generator
None - Office
Low
Electric Substation #1
1590 River Dr.
Substation 1
None - Power Station
Low
Electric Substation #10-11
540 Old Mill
Substation 10
None - Power Station
Low
Electric Substation #12
2825 Benvenue Rd
Substation 12
None - Power Station
Low
Electric Substation #14
6671 Goldrock Rd
Substation 14
None - Power Station
Low
Electric Substation #2
416 Rocky Street
Substation 2
None - Power Station
Low
Electric Substation #3
810 Leggett Street
Substation 3
None - Power Station
Low
Electric Substation #4
1211 Atlantic Ave.
Substation 4
None - Power Station
Low
Electric Substation #5
1251 Thorpe Road
Substation 5
None - Power Station
Low
Electric Substation #6
813 S. Wesleyan Blvd
Substation 6
None - Power Station
Low
Electric Substation #7
200 Sutton Rd.
Substation 7
None - Power Station
Low
Electric Substation #8 & POD
810 Greyson Rd.
Substation 8
None - Power Station
Low
Electric Substation #9
251 English Road
Substation 9
None - Power Station
Low
Electric Substation &
Generators
3031 Treatment Plant
Rd.
Substation & Gen
NPDES
Low
Elevated water tank
3031 TreaRtdment Plant
Watertank
NPDES
Low
Enviromental Serv.Office &
shop
1221 Thorpe Road
Office and shop
Bulk Material Storage
High
Fire Prevention Complex
404 S.Church St.
Fire Prevention & Museum
Vehicle Washing/ Maintenance
Medium
Main Fire Station
101 S. George Street
Station 1
Fueling; Vehicle Washing/
Maintenance
High
Fire Station
824 S. Grace Street
Station 2
Vehicle Washing
Medium
Fire Station
900 Springfield Rd.
Station 5
Vehicle Washing
Medium
Fire Station
900 S.Winstead Ave
Station #3
Vehicle Washing
Medium
Fire Station
105 Rowe Dr.
Station #6
Fueling; Vehicle Washing
High
Fire Station 4
2054 Fenner Road
Fire Station 4
Vehicle Washing
Medium
Fire Station 7
9914 NC-4
Fire Station 7
Vehicle Washing
Medium
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MS4 Gap Analysis Report
Name
Pollution Preventionand
Address
Good Housekeeping Inventory
Use of asset
List
Category
Pollution
Potential
Fleet Maintenance Garage
106 E.Grand Ave.
Fleet Garage/offices
Fueling; Vehicle Washing/
Maintenance
High
Judical Center & Court Room
301 Cokey Rd.
Court Room & Offices
None - Office
Low
Lift Station
3031TreaRta entPlant
Liftstation
NPDES
Low
MBM Foods
2217 Centura Hwy
Generators
None
Low
McLane
7253 N Carolina 48
Generators
None
Low
Merita Bakery
2551 N.Church St.
Generators
None
Low
MLK1r. Park
800 E. Virginia St.
Martin Luther King Park
None - Park
Low
Theatre
367 N. Franklin St.
Theater
None
Low
OIC & Offices for Comm. Ctr
406 E. Virginia St.
old BTW complex
None - Office
Low
Old Braswell Liabrary
344 Falls Road
Imperial Ctr classrooms
None
Low
Owens/Brockway
6941 Corporation
Parkway
Generators
None
Low
Parks Maintenance Offices
726 Albemarle Ave
Parks Maintenance
None - Equipment Storage
Low
PG&W offices
628 Albermarie Ave
Office & Equipment
None
Low
Poppie International
6610 Corporation Pkwy
Generators
None
Low
Progress point of delivery
520 Old Mill Road
point of delivery
None - Power Station
Low
Retail Outlets & Fire Stations
various locations
Generators (small)
None
Low
RM Wilson Gym
301 Hill St.
Offices & Gym
None - Office
Low
Sewer Lift Station/Merta
Bakery
2681 N. Church St
Lift Station
None
Low
South RM Community Center
719 Recreation Or
S. Rocky Mount Comm
None - Park
Low
Sports Complex
600 Independence Or
sports complex-4 buildings
None - Park
Low
Street and Stormwater bldg.
208 E. Grand Ave.
Street Dept. Admin.
None - Office
Low
Sunset Ave. Water Plant
1660 Sunset Ave.
Generators
NPDES
Low
Sunset Park
1550 River Road
Sunset Park
None - Park
Low
Tar River Water Pit.
4489 Leaston Rd.
Generators
NPDES
Low
Tietex International
500 Airport Rd.
Generators
None
Low
Stith-Talbers Park
210 Spruce St.
Stith park & ball fields
None - Park
Low
Train Station
101 CoastLine St.
Train Station/offices
None
Low
Transformer shop & pole yard
1251 Thorpe Road
Electric utility work site
Bulk Material Storage
High
Unican Industries
400 Jeffries Rd.
Generators
None
Low
Waste transfer Station
1181-1221 Thorpe Road
Environment. Services comp.
Bulk Material Storage
Medium
Wastewater Treatment Plant
3031 TreaRtdment Plant
Other structures & Processes
NPDES
Medium
Water Plant
4489 Leaston Rd.
Outside structures & processes
NPDES
Low
Water Plant
4489 Leaston Rd.
Water Plant
NPDES
Medium
Water Plant
1660 Sunset Ave.
Water Plant
NPDES
Medium
WaterTank
175 Red Iron Rd
Tank
None - WaterTank
Low
WaterTank
600 Airport Road
Tank
None-WaterTank
Low
WaterTank
572 N. Old Carriage Rd
Tank
None - WaterTank
Low
WaterTank
688 Paul St.
Tank
None - WaterTank
Low
WaterTank-Marigold
431 Branch St.
Tank
None - WaterTank
Low
Weaver Bldg
281/293 Hammond
Office Bldg/meter,billing
None - Office
Low
Senior Center (YMCA) Bldg
427 S Church St
Senior Center
None
Low
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MS4 Gap Analysis Report
Name
Pollution Prevention
Address
and Good Housekeeping Inventory
Use of asset
List
Category
Pollution
Potential
Fire Logistics Facility
180 Cokey Rd
Fire Station Support
Fueling; Vehicle Washing /
Maintenance
Low
Sewer Lift Station
INC 97E
Lift Station
None
Low
Sunset Park Tennis Court
760 N. Taylor St
Tennis Courts
None - Park
Low
West Corporation
1960 Stone Rose Or
Generator
None
Low
Transfer Station
1201 Thorpe Road
Solid Waste transfer
Bulk Material Storage
Low
Animal Shelter (New Location)
1017 N. Church St.
Animal Shelter & Office
Animal waste
Low
MLKJr. Park
800 E. Virginia St.
Park
None - Park
Low
Business Services Center
224 S. Franklin St.
Office Space
None - Office
Low
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Final RM MS4 Gap Analysis Report