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HomeMy WebLinkAboutNCS000438_Spring Lake Self Audit_20220214 MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) PROGRAM SELF AUDIT REPORT NPDES PERMIT NO. NCS000438 Spring Lake, NORTH CAROLINA 300 Ruth Street Self Audit Date: 20220201 North Carolina Department of Environmental Quality Division of Energy, Mineral & Land Resources Stormwater Program 512 N. Salisbury Street, 9th floor 1612 Mail Service Center Raleigh, NC 27699-1612 MS4 Permit Self Audit Report Spring Lake, NC: NPDES Permit No. NCS000438 Audit Date: 20220208 i (This page intentionally left blank) MS4 Permit Self Audit Report Spring Lake, NC: NPDES Permit No. NCS000438 Audit Date: 20220208 ii TABLE OF CONTENTS Audit Details .................................................................................................................................................. 1 Permittee Information .................................................................................................................................. 2 Supporting Documents ................................................................................................................................. 3 Program Implementation, Documentation & Assessment ........................................................................... 4 Public Education and Outreach ..................................................................................................................... 8 Public Involvement and Participation ......................................................................................................... 11 Construction Site Runoff Controls .............................................................................................................. 13 Total Maximum Daily Loads (TMDLs) ......................................................................................................... 16 Appendix………………………………………………………………………………………………………………………………….18 DISCLAIMER This audit consists of an evaluation of program compliance with the issued permit and implementation of the approved Stormwater Management Plan. This audit report does not include a review of all program components, and program deficiencies in addition to those noted may be present. The permittee is required to assess program progress and permit compliance, and to implement the approved Stormwater Management Plan in accordance with the issued permit. MS4 Permit Self Audit Report Spring Lake, NC: NPDES Permit No. NCS000438 Audit Date: 20220208 iii This page intentionally left blank MS4 Permit Self Audit Report Spring Lake, NC: NPDES Permit No. NCS000438 Audit Date(s): 20220208 Page 1 of 18 Audit Details Audit ID Number: NCS000438_SpringLake MS4 Self Audit_20220201 Audit Date(s): 02/01/2022 Minimum Control Measures Evaluated: ☒ Program Implementation, Documentation & Assessment ☒ Public Education & Outreach ☒ Public Involvement & Participation ☐ Illicit Discharge Detection & Elimination ☐ Construction Site Runoff Controls – No delegated Sediment and Erosion Control Program ☒ Construction Site Runoff Controls – Delegated Sediment and Erosion Control Program ☐ Post-Construction Site Runoff Controls ☐ Pollution Prevention and Good Housekeeping for Municipal Operations ☒ Total Maximum Daily Loads (TMDLs) Field Site Visits: ☐ Municipal Facilities. Number visited: 1 ☐ MS4 Outfalls. Number visited: Choose an item. ☐ Construction Sites. Number visited: Choose an item. ☐ Post-Construction Stormwater Runoff Controls. Number visited: Choose an item. ☐ Other: ________________________________. Number visited: Choose an item. ☐ Other: ________________________________. Number visited: Choose an item. Inspector(s) Conducting Audit Name, Title Organization Deanna Rosario- Stormwater Administrator Town of Spring Lake Audit Report Author: Signature__________________________________________ Date: 20220208 Audit Report Author: Signature__________________________________________ Date MS4 Permit Self Audit Report Spring Lake, NC: NPDES Permit No. NCS000438 Audit Date(s): 20220208 Page 2 of 18 Permittee Information MS4 Permittee Name: Town of Spring Lake Permit Effective Date: 02/19/2017 Permit Expiration Date: 02/20/2022 City, State, ZIP: Spring Lake NC 28390 Date of Last MS4 Inspection/Audit: July 15, 2021 Co-permittee(s), if applicable: Permit Owner of Record: Primary MS4 Representatives Participating in Audit Name, Title Organization Deanna Rosario- Stormwater Administrator Town of Spring Lake MS4 Receiving Waters Waterbody Classification Impairments Jumping Run Creek C None Muddy Creek C none Tank Creek/McDuffie Creek C none Lower Little River C none Young Lake and unnamed creek C none MS4 Permit Self Audit Report Spring Lake, NC: NPDES Permit No. NCS000438 Audit Date(s): 20220208 Page 3 of 18 Supporting Documents Item Number Document Title When Provided (Prior to/During/After) 1 NOTICE OF VIOLATION (NOV-2021-PC-0530) Town of Spring Lake NPDES MS4 Permit No. NCS000438 Cumberland County during MS4 Permit Self Audit Report Spring Lake, NC: NPDES Permit No. NCS000438 Audit Date(s): 20220208 Page 4 of 18 Program Implementation, Documentation & Assessment Staff Interviewed: (Name, Title, Role) Deanna Rosario, Stormwater Administrator- manages all aspects of the MS4 program- performed self audit as requested in NOV-2021-PC-0530 Permit Citation Program Requirement Status Supporting Doc No. II.A.1 Staffing and Funding The permittee maintained adequate funding and staffing to implement and manage the provisions of the Stormwater Plan and meet all requirements of the permit. Yes --- The Stormwater Plan identifies a specific position(s) responsible for the overall coordination, implementation, and revision to the Plan. Yes --- Responsibilities for all components of the Stormwater Plan are documented and position(s) assignments provided. Yes --- 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.) Funded by stormwater fee in yearly property tax bill of 33.00 per ERU. Stormwater program is staffed by one full time administrator supplemented by other water department personnel as needed. II.A.2 Stormwater Plan Implementation and Evaluation The permittee evaluated the performance and effectiveness of the program components at least annually. Yes --- If yes, the permittee used the results of the evaluation to modify the program components as necessary to accomplish the intent of the Stormwater Program. Yes --- Did the permitted MS4 discharges cause or contribute to non-attainment of an applicable water quality standard? No --- If yes, did the permittee expand or better tailor its BMPs accordingly to address the non-attainment? Not Applicable --- Comments MS4 Permit Self Audit Report Spring Lake, NC: NPDES Permit No. NCS000438 Audit Date(s): 20220208 Page 5 of 18 Program Implementation, Documentation & Assessment II.A.3 Keeping the Stormwater Plan Up to Date The permittee kept the Stormwater Plan up to date. Yes --- The permittee notified DEMLR of any updates to the Stormwater Plan. Yes --- Comments (Indicate the date of latest Stormwater Plan and describe the nature of any updates, if applicable). II.A.4 Availability of the Stormwater Plan The permittee kept an up-to-date version of its Stormwater Plan available to the Division and the public online. Partial --- The online materials included ordinances, or other regulatory mechanisms, or a list identifying the ordinances, or other regulatory mechanisms, providing the legal authority necessary to implement and enforce the requirements of the permit. Partial --- Comments (Note what materials are available on line) The town website is being updated to a new provider, all pertinent information will be transferred over by the end of March 2022 II.A.3 & II.A.5 Stormwater Plan Modifications Did DEMLR require a modification to the Stormwater Plan? No --- If yes, did the permittee complete the modifications in accordance with the established deadline? Choose an item. --- 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? Choose an item. --- Comments (List the specific control measures implemented by others that do not have adequate written agreements, if applicable )The State administers the Construction site erosion control portion of the MS4 permit II.A.7 Written Procedures The permittee maintained written procedures for implementing the six minimum control measures. Partial --- 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) IDDE and Good Housekeeping programs are currently being updated to be more facility specific and more comprehensive MS4 Permit Self Audit Report Spring Lake, NC: NPDES Permit No. NCS000438 Audit Date(s): 20220208 Page 6 of 18 Program Implementation, Documentation & Assessment III. A Program Documentation The permittee maintained documentation of all program components including, but not limited to, inspections, maintenance activities, educational programs, implementation of BMPs, enforcement actions etc., on file for a period of five years. Partial --- Comments (List the specific program components that do not have adequate documentation on file and why, if applicable) All files prior to October 2018 were lost when Florence flooded the facility that the Stormwater Management office was located in. We were able to partially reconstruct past files with copies saved at DEQ and from one of the SCM inspecting companies. III.B Annual Report Submittal The permittee submitted annual reports to the Department within twelve months from the effective date of the permit (See Section III.B. for the annual reporting period specific to this MS4). Yes --- 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 schedules and plans for the year following each report. Yes --- 2. An adequate description and justification of any proposed changes to the Stormwater Plan. This will include descriptions and supporting information for the proposed changes and how these changes will impact the Stormwater Plan (results, effectiveness, implementation schedule, etc.). Yes --- 3. Documentation of any necessary changes to programs or practices for assessment of management measures implemented through the Stormwater Plan. Yes --- 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 Stormwater Plan. Yes --- 5. An assessment of compliance with the permit, information on the establishment of appropriate legal authorities, inspections, and enforcement actions. Yes --- Comments (Note dates that annual reports cover under current permit and generally describe report deficiencies, if any) 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. Yes --- 3. Planned activities and changes for the next reporting period, for each program component or activity. Yes --- MS4 Permit Self Audit Report Spring Lake, NC: NPDES Permit No. NCS000438 Audit Date(s): 20220208 Page 7 of 18 Program Implementation, Documentation & Assessment 4. Fiscal analysis. Yes --- Comments (Note dates that annual reports cover under current permit and generally describe report deficiencies, if any) MS4 Permit Self Audit Report Spring Lake, NC: NPDES Permit No. NCS000438 Audit Date(s): 20220208 Page 8 of 18 Public Education and Outreach Staff Interviewed: (Name, Title, Role) Deanna Rosario, Stormwater Administrator- manages all aspects of the MS4 program 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. Partial --- Comments (Generally describe process for establishing goals/objectives) Basic description of the program is on file, currently reviewing and expanding the program after a two year break due to COVID in cooperation with CWEP and Cumberland County Green Schools. Annual events include Creek Week, Cumberland County Schools Earth Day outreach, and booths at town events as they are being scheduled. 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) CWEP has been keeping their target pollutant outreach materials updated and we have been using social media to repost them and to create handouts for town events. 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) Target audiences are students at Lillian Black ES, Manchester ES, and Spring Lake MS as well as children at the parks and recreation center and townspeople at events. MS4 Permit Self Audit Report Spring Lake, NC: NPDES Permit No. NCS000438 Audit Date(s): 20220208 Page 9 of 18 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) School age children are taught that “just one” piece of trash or pollutant is added to the other “just ones” to create a huge mess, and that they are able to make a big impact on their community by taking care of their own “just ones”. An expansion of this idea to reach out to the larger community is planned for the next clean up event and for Creek Week. 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) Spring Lake North Carolina (townofspringlake.com) Being updated as soon as the main website is finished being reconstructed II.B.2.f Public Education Materials The permittee distributed stormwater educational material to appropriate target groups. Partial --- Comments (List distributed materials and quantity, message, distribution mechanism, target audience for each if not included in program documentation/annual reporting) Creating or obtaining material for clean up events, restaurants, auto shops and car washes, etc through CWEP 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) Hotline Number is 910-985-1804, email is stormwater@townofspringlake.com, both are listed on the Spring Lake homepage as well as on our facebook and twitter pages. II.B.2.h 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 --- MS4 Permit Self Audit Report Spring Lake, NC: NPDES Permit No. NCS000438 Audit Date(s): 20220208 Page 10 of 18 Public Education and Outreach 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. 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.) We keep a headcount of all people in attendance at educational events, or participants who stop by our section of town events. Additional Comments: MS4 Permit Self Audit Report Spring Lake, NC: NPDES Permit No. NCS000438 Audit Date(s): 20220208 Page 11 of 18 Public Involvement and Participation Staff Interviewed: (Name, Title, Role) Deanna Rosario, Stormwater Administrator- manages all aspects of the MS4 program Permit Citation Program Requirement Status Supporting Doc No. II.C.2.a Volunteer Community Involvement Program The permittee included and promoted volunteer opportunities designed to promote ongoing citizen participation. Yes --- Comments (Note opportunities promoted and date(s) of volunteer events) Recruiting for the town’s Appearance and Sustainability Committee, (ongoing) Calls for volunteers on facebook, twitter, and town webpage for events (when events are scheduled) 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) Email, stormwater@townofspringlake.com Twitter Spring Lake NC Stormwater (@SLSW12) / Twitter facebook (1) Spring Lake Stormwater Department | Facebook town website www.townofspringlake.com phone 910-985-18004 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) Hotline is on the town webpage, facebook, and twitter pages. MS4 Permit Self Audit Report Spring Lake, NC: NPDES Permit No. NCS000438 Audit Date(s): 20220208 Page 12 of 18 Public Involvement and Participation Additional Comments: As we come out of the worst of COVID we are restarting prior public involvement events, and working to create new ones, such as the first Creek Week event in Spring Lake in March 2022 I also set up the format for adopting drains, streets, and parks, awaiting final approval or amendment at board level. MS4 Permit Self Audit Report Spring Lake, NC: NPDES Permit No. NCS000438 Audit Date(s): 20220208 Page 13 of 18 Construction Site Runoff Controls Staff Interviewed: (Name, Title, Role) Deanna Rosario, Stormwater Administrator- manages all aspects of the MS4 program 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). Partial --- Comments (Describe how provided and promoted) Local reporting methods are listed online, however, we will be expanding that to include DEQ level hotlines. 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 --- 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 --- MS4 Permit Self Audit Report Spring Lake, NC: NPDES Permit No. NCS000438 Audit Date(s): 20220208 Page 14 of 18 Construction Site Runoff Controls 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. Choose an item. --- 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? Choose an item. --- 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. Choose an item. --- Comments § 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 . MS4 Permit Self Audit Report Spring Lake, NC: NPDES Permit No. NCS000438 Audit Date(s): 20220208 Page 15 of 18 Construction Site Runoff Controls § 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) MS4 Permit Self Audit Report Spring Lake, NC: NPDES Permit No. NCS000438 Audit Date(s): 20220208 Page 16 of 18 Total Maximum Daily Loads (TMDLs) Staff Interviewed: (Name, Title, Role) Deanna Rosario, Stormwater Administrator- manages all aspects of the MS4 program 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: 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 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. Choose an item. --- 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. Choose an item. --- 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. Choose an item. --- 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. Choose an item. --- 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. Choose an item. --- MS4 Permit Self Audit Report Spring Lake, NC: NPDES Permit No. NCS000438 Audit Date(s): 20220208 Page 17 of 18 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. Choose an item. --- The permittee described strategies and tailored and/or expanded BMPs in their Stormwater Management Plan and annual reports Choose an item. --- Comments MS4 Permit Self Audit Report Spring Lake, NC: NPDES Permit No. NCS000438 Audit Date(s): 20220208 Page 18 of 18 Appendix A-