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HomeMy WebLinkAboutNCS000396_Goldsboro Self Audit_20211027 MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) PROGRAM AUDIT REPORT CITY SELF AUDIT PER NOTICE OF DEFICIENCY NPDES PERMIT NO. NCS000396 GOLDSBORO, NORTH CAROLINA 200 NORTH CENTER STREET GOLDSBORO, NC 27530 Audit Date: OCT XX, 2021 Report Date: 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 Audit Date(s): OCTOBER 26 2021 Page 1 of 11 Public Education and Outreach Staff Interviewed: (Name, Title, Role) Marty Anderson, City Engineer Matthew Lassiter, Civil Engineer Permit Citation Program Requirement Status Supporting Doc No. II.B.2.a Goals and Objectives The permittee defined goals and objectives of the Local Public Education and Outreach Program based on community wide issues. Yes --- Comments (Generally describe process for establishing goals/objectives) Goals and objectives are established based on the frequency and type of problems we see within the City of Goldsboro. Our primary issue from a stormwater perspective is flooding as the City is adjacent to the Neuse River and is low-lying. Our construction projects within the City also present us the need for post-construction stormwater measures, while our dense business districts present a need for abating target pollutants which may result from these businesses. These issues mirror the MS4 permit requirements, and our objective and priorities for the stormwater program change to suit the City as it continues to develop. II.B.2.b Target Pollutants The permittee maintained a description of the target pollutants and/or stressors and likely sources. Yes --- Comments (List target pollutants, note any that are missing or not appropriate) A list of target pollutants and their sources can be found in tables 3.1 and 3.2 of the Stormwater Management Plan. This also provides a list of allowable and not allowable discharges. II.B.2.c Target Audiences The permittee identified, assessed annually and updated the description of the target audiences likely to have significant storm water impacts and why they were selected. Yes --- Comments (Describe any changes made, if applicable) This is performed annually as part of the Neuse River Nutrient Management Strategy. Audit Date(s): OCTOBER 26 2021 Page 2 of 11 Public Education and Outreach II.B.2.d Residential and Industrial/ Commercial Issues 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. Yes --- Comments (Generally describe the residential/industrial/commercial issues addressed) The CWEP addresses these issues in their literature For an example of Goldsboro’s outreach information, see attached IDDE letter with list of businesses it was sent to. II.B.2.e Informational Web Site The permittee promoted and maintained an internet web site designed to convey the program’s message. Yes --- Comments (list web page address and general contents, or attach screen shot of landing page) https://www.goldsboronc.gov/engineering/ https://www.goldsboronc.gov/engineering/stormwater-management/ Provides links to our code, as well as the NCDEQ (North Carolina Department of Environmental Quality) erosion control website, the CWEP (Clean Water Education Partnership) website, and the Phase II NPDES (National Pollutant Discharge Elimination System) program. II.B.2.f Public Education Materials The permittee distributed stormwater educational material to appropriate target groups. Yes --- Comments (List distributed materials and quantity, message, distribution mechanism, target audience for each if not included in program documentation/annual reporting) Educational material is done primarily with brochures at the City offices, as well as via dispersement through CWEP. Audit Date(s): OCTOBER 26 2021 Page 3 of 11 Public Education and Outreach II.B.2.g Hotline/Help Line The permittee promoted and maintained a stormwater hotline/helpline for the purpose of public education and outreach. Yes --- Comments (Note hotline contact information and method(s) for advertising it) There is a “contact the engineering department” form on the Engineering departments website. On the Stormwater Management website: Hotline/Helpline - 919-734-8674 Report Erosion and Sediment to the state - 1-866-786-7683 Report problems with the City’s stormwater system (Public Works) - 919-739-7415 II.B.2.h Public Education and Outreach Program The permittee’s outreach program, including those elements implemented locally or through a cooperative agreement, included a combination of approaches designed to reach the target audiences. Yes --- 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. Yes --- 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.) The totals of the brochures taken are noted, and the CWEP releases annual performance metrics for their outreach programs. Audit Date(s): OCTOBER 26 2021 Page 4 of 11 Public Education and Outreach Additional Comments: Audit Date(s): OCTOBER 26 2021 Page 5 of 11 Public Involvement and Participation Staff Interviewed: (Name, Title, Role) Marty Anderson, City Engineer Matthew Lassiter, Civil Engineer Permit Citation Program Requirement Status Supporting Doc No. II.C.2.a Volunteer Community Involvement Program The permittee include d and promoted volunteer opportunities designed to promote ongoing citizen participation. Yes --- Comments (Note opportunities promoted and date(s) of volunteer events) Along with CWEP’s statewide programs and events, Goldsboro also advertised a Spring Litter Pick up the beginning of each May. II.C.2.b Mechanism for Public Involvement The permittee provided and promoted a mechanism for public involvement that provides for input on stormwater issues and the stormwater program. Yes --- Comments (Note mechanism(s) for input and how promoted) There is a “contact the engineering department” form on the Engineering departments website. On the Stormwater Management website: Hotline/Helpline - 919-734-8674 Report Erosion and Sediment to the state - 1-866-786-7683 Report problems with the City’s stormwater system (Public Works) - 919-739-7415 II.C.2.c Hotline/Help Line The permittee promoted and maintained a hotline/helpline for the purpose of public involvement and participation. Yes --- Comments (Note hotline contact information and how it is promoted) There is a “contact the engineering department” form on the Engineering departments website. On the Stormwater Management website: Hotline/Helpline - 919-734-8674 Report Erosion and Sediment to the state - 1-866-786-7683 Report problems with the City’s stormwater system (Public Works) - 919-739-7415 Audit Date(s): OCTOBER 26 2021 Page 6 of 11 Public Involvement and Participation Additional Comments: Audit Date(s): OCTOBER 26 2021 Page 7 of 11 Construction Site Runoff Controls Staff Interviewed: (Name, Title, Role) Marty Anderson, City Engineer Matthew Lassiter, Civil Engineer 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 [NPDES Permit No. NCS000435] The permittee provides and promotes a means for the public to notify the appropriate authorities of observed erosion and sedimentation problems (e.g., promoting the existence of the DEQ DEMLR “Stop Mud” hotline). Yes --- Comments (Describe how provided and promoted) The stop the mud hotline is referenced on our engineering website. There are also several means to contact the Engineering Department or Public Works: There is a “contact the engineering department” form on the Engineering departments website. On the Stormwater Management website: Hotline/Helpline - 919-734-8674 Report Erosion and Sediment to the state - 1-866-786-7683 Report problems with the City’s stormwater system (Public Works) - 919-739-7415 SPCA Citation Delegated Program Requirement Status Supporting Doc No. § 113A-60 Local erosion and sedimentation control programs (a) The permittee has adopted an ordinance or other regulatory mechanism to enforce the erosion and sedimentation control program. Not Applicable --- If yes, the ordinance meets or exceeds the minimum requirements of the SPCA. Not Applicable --- If yes, the ordinance applies throughout the corporate limits of the permittee. [Permit Part I.D] Not Applicable --- Audit Date(s): OCTOBER 26 2021 Page 8 of 11 Construction Site Runoff Controls Comments (Provide regulatory mechanism reference or Supporting Documentation number) § 113A-60 Local erosion and sedimentation control programs (d) The permittee collects a fee paid by each person who submits an erosion and sedimentation control plan. Not Applicable --- Comments (indicate the fee amount, if applicable) § 113A-60 Local erosion and sedimentation control programs (e) Has any person initiated a land-disturbing activity (within the permittee’s jurisdiction) for which an erosion and sedimentation control plan is required in the absence of an approved plan? Not Applicable --- If yes, the permittee has notified the North Carolina Sedimentation Control Commission of all such cases. Not 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? Not Applicable --- If yes, has the permittee referred any such matters to the North Carolina Sedimentation Control Commission for inspection and enforcement? Not Applicable --- Comments § 113A-61 Local approval of erosion and sedimentation control plans The permittee reviews each erosion and sedimentation control plan submitted to them and notifies the person submitting the plan that it has been approved, approved with modification, or disapproved within 30 days of receipt. Not Applicable --- The permittee only approves an erosion and sedimentation control plan upon determining that it complies with all applicable State and local regulations. Not Applicable --- The permittee has disapproved of an erosion and sedimentation control plan in order to protect riparian buffers along surface waters. Not Applicable --- If yes, the permittee notified the Director of the Division of Energy, Mineral, and Land Resources within 10 days of the disapproval. Not Applicable --- Comments Audit Date(s): OCTOBER 26 2021 Page 9 of 11 Construction Site Runoff Controls § 113A-61.1 Inspection of land- disturbing activity; notice of violation (a) The certificate of approval of each erosion and sedimentation control plan approved by the permittee includes a notice of the right to inspect. Not Applicable --- The permittee provides for inspection of land-disturbing activities to ensure compliance with the SPCA and to determine whether the measures required in an erosion and sedimentation control plan are effective. Not Applicable --- Comments . § 113A-61.1 Inspection of land- disturbing activity; notice of violation (c) When the permittee determines that a person engaged in land-disturbing activity has failed to comply with the SPCA, the Permittee immediately issues a notice of violation upon that person. Not Applicable --- Each notice of violation issued by the permittee specifies the date by which the person must comply. Not Applicable --- Each notice of violation issued by the permittee informs the person of the actions that need to be taken to comply. Not Applicable --- Comments § 113A-64 Penalties Does the permittee issue civil penalties as part of the erosion and sedimentation program? Not Applicable --- Comments (indicate when/why a civil penalty is issued, and the amount, if applicable) Audit Date(s): OCTOBER 26 2021 Page 10 of 11 Total Maximum Daily Loads (TMDLs) Staff Interviewed: (Name, Title, Role) Marty Anderson, City Engineer Matthew Lassiter, Civil Engineer Program Status: ☐ The permittee is not subject to an approved TMDL (skip the rest of this section). ☒ The permittee is subject to an approved TMDL for: Nitrogen in the Neuse River Basin, est. 7/25/1999 There ☐ is ☒ is not a Waste Load Allocation (WLA) in the approved TMDL (If there is a WLA, then complete items II.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 address impaired waters. Not 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 strategies address impaired waters. Not 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 necessary to address impaired waters. Not 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 strategies address impaired waters. Not 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 occur. Not Applicable --- Audit Date(s): OCTOBER 26 2021 Page 11 of 11 Total Maximum Daily Loads (TMDLs) Comments 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 six minimum measures to enhance water quality recovery strategies in the watershed(s) to which the TMDL applies. Yes --- The permittee described strategies and tailored and/or expanded BMPs in their Stormwater Management Plan and annual reports Yes --- Comments Nitrogen Export is still accounted for under the Neuse River Rules and remains at 3.6 lb/ac/yr maximum. The stormwater management plan directs developers to NCDEQ for direction regarding SCM’s, their design requirements, and their efficiency.