NCS000423_Concord NOD-2022-PC-0023_20220304

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
BRIAN WRENN
Director
CERTIFIED MAIL 7020 3160 0000 3277 7890
RETURN RECEIPT REQUESTED
NORTH CAROLINA
Environmental Quality
February 24, 2022
City of Concord
Attention: Lloyd William Payne, Jr., City Manager
P.O. Box 308
Concord, North Carolina 28026-0308
CERTIFIED MAIL 7020 3160 0000 3277 7906
RETURN RECEIPT REQUESTED
City of Concord
Attention: Jeff Corley, Director of Water Resources
P.O. Box 308
Concord, North Carolina 28026-0308
Subject: NOTICE OF DEFICIENCY (NOD-2022-PC-0023)
City of Concord
NPDES MS4 Permit No. NCS000423
Cabarrus County
Dear Mr. Payne and Mr. Corley:
On February 8, 2022, staff from the North Carolina Department of Environmental Quality (DEQ) conducted a
compliance audit of subject National Pollutant Discharge Elimination System (NPDES) Municipal Separate
Storm Sewer System (MS4) Permit. The audit identified minor deficiencies with the specific components of
the MS4 permit that were reviewed, as provided in the attached DEQ MS4 Permit Compliance Audit Report.
This report lists and describes the deficiencies with certain components of the MS4 permit, which constitutes
a violation of the Clean Water Act and is grounds for enforcement action.
In accordance with Part VI of the permit and DEQ policy, a new 5-year MS4 permit will be issued in response to the
audit. To address the MS4 Permit Deficiencies, the City of Concord is required to complete the following actions:
1. Respond in writing within thirty (30) calendar days from the date of receipt of this notice to acknowledge
these requirements and the intent to comply.
2. Self -evaluate the permit components that were not reviewed by DEQ for compliance and submit the
results within one hundred twenty (120) calendar days from the date of receipt of this letter. The Part II
of the MS4 Phase II Audit Template on the DEQ stormwater web site can be used for this purpose. The
specific sections that should be self -audited include:
a. Section E: Construction Site Runoff Controls;
b. Section F: Post -Construction Site Runoff Controls;
c. Section H: Total Maximum Daily Loads.
^ North Carolina Department of Environmental Quality. Division of Energy, Mineral and Land Resources
z: ,...ar• Mooresville. Regional Office 1 610 East Center Avenue. Suite 301 Mooresville, North Carolina 28115 D E
u;;irtc:.s: Aea t'
rnsrnnenemenmronmanra smr �'�✓ 704.603.1699

3. Develop a Stormwater Management Plan (SWMP) which details specific actions, measurable goals, and
implementation timelines to bring the stormwater management program into compliance with NPDES
MS4 requirements over the new 5-year permit term. The SWMP must be documented utilizing the DEQ
Phase II MS4 SWMP Template. The SWMP must address all known compliance deficiencies including, at a
minimum, the items detailed in the DEQ MS4 program Audit Report and City of Concord self -audit. The
permittee shall submit the SWMP to DEQ for review and commentwithin one hundred twenty (120)
calendar days from the date of receipt of this letter.
4. Submit an NPDES MS4 permit application within thirty (30) days of receiving written DEQ concurrence
that the submitted draft SWMP documents a compliant stormwater management program. A new 5-year
NPDES MS4 permit will be public noticed along with the submitted SWMP.
5. Respond to comments on the Draft Final SWMP and submit a signed Final SWMP for DEQ approval and
final permit issuance. The final DEQ-approved SWMP shall become an enforceable component of the
NPDES MS4 permit and an Annual Self -Assessment Template that corresponds to the approved SWMP
will be provided.
Required documentation shall be submitted via e-mail to Jeanette. [e-mail], or to:
DEQ-DEMLR Stormwater Program
Attention: Jeanette Powell
1612 Mail Service Center
Raleigh, NC 27699-1612
If the City of Concord fails to meet the aforementioned requirements and/or submits a significantly
noncompliant Draft SWMP, DEQ may proceed with enforcement. As is stated in Part V, Section A.1(c) of the
permit:
Under state law, a daily civil penalty of not more than twenty-five thousand dollars ($25,000) per
violation may be assessed against any person who violates or fails to act in accordance with the terms,
conditions, or requirements of a permit [North Carolina General Statute 143-215.6A]. Please note that
compliance with the requirements of this NOD and/or issuance of civil or criminal penalties levied by
DEQ does not preclude the EPA from carrying out its own enforcement case against the permittee.
Thank you for your attention to this matter. Should you have any questions, please contact Jesse McDonnell
at [phone] or [e-mail], or the MS4 Program Coordinator at
Jeanette. [e-mail].
Sincerely,
Zahid S. Khan, CPM, CPESC, CPSWQ
Regional Engineer
Land Quality Section
Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental Quality Division of Energy, i;Mineral arui Lend Resources
;Mooresville Regional Office 610 East Center Avenue. Suite 30t ! ;Mooresville. North Carolina 28115
704.£i63.1 �qa

Enclosures: DEQ MS4 Permit Compliance Audit Report
CC:
Jeff Corley, [e-mail]
DEMLR Stormwater Program Supervisor
[e-mail], DEMLR MS4 Program Coordinator
DEMLR NPDES MS4 Permit Laserfiche File
;North Carolina Dc:parttnent of Environmental Quality. Division of Energy, Mineral and Land Resources
Mooresville Regional Office 1 610 East Center Avenue Suite 3DI Mooresville. North Carolina 28115
asr.,nn,oa, ni=..•��,:,eai~n� �r+�"� i0I1.b63.1ti99

l'AUNUPAL SEPARATE STORM SEWER SYSTEVM (WIM)
PROGRAM QUDDIT REPORT
NPOES PERM Y HO. NCS000423
Concord, NORTH CAROLINA
635 Alfred Brown Jr. Ct.
Concord, North Carolina 28025
udk Date: February 8, 2022
Report Date. Febp ary 24, 2022
North Carolina Depavtmont of 'Environmental Qraality
Division of Energy Mineral Land Resources Stoyffivvater Program
512 N. Salisbury Street, 9th floor
IG12 Mail Service Center
Raleigh, NC 27699-IG12

(This page intentionally left blank)
NCS000423 Concord MS4 Audit 20220224

TABLE OF CONTENTS
AuditDetails.........................................................................................................
Permittee Information.........................................................................................
List of Supporting Documents..............................................................................
Program Implementation, Documentation & Assessment ..................................
Public Education and Outreach............................................................................
Public Involvement and Participation..................................................................
Illicit Discharge Detection and Elimination (IDDE)...............................................
Pollution Prevention and Good Housekeeping for Municipal Operations...........
Site Visit Evaluation: Municipal Facility No. 1......................................................
Site Visit Evaluation: Municipal Facility No. 2......................................................
Site Visit Evaluation: MS4 Outfall No. 1...............................................................
Site Visit Evaluation: MS4 Outfall No. 2...............................................................
.......................................1
....................................... 2
....................................... 3
.......................................4
.......................................7
.......................................8
....................................... 9
.....................................11
.......................... .......13
.....................................15
.....................................16
.....................................17
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 Storm water
Management Plan in accordance with the issued permit.
NCS000423 Concord MS4 Audit 20220224

This page intentionally left blank
NCS000423 Concord MS4 Audit 20220224 iii

Audit Details
Audit ID Number:
Audit Date(s):
NCS000423—Co n cord MS4 Audit_20220224
February 8-9, 2022
Minimum Control Measures Evaluated:
® Program Implementation, Documentation & Assessment
® Public Education & Outreach
® Public Involvement & Participation
I• 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: 2
® MS4 Outfalls. Number visited: 2
❑ Construction Sites. Number visited: ("inec ie, :ar)
❑ Post -Construction Stormwater Runoff Controls. Number visited:._;
❑ Other: Number visited: h ccc>_ <, ... .
❑ Other: Number visited: %_:o;:7a a s t - M.
Inspector(s) Conducting Audit
Name, Title
Oreanization
Jesse McDonnell, Environmental Specialist
North Carolina Department of Environmental Quality
Zahid Khan, Regional Engineer
North Carolina Department of Environmental Quality
Audit Report Author:
Date:
Signature
f 0 2L,
Audit Report Author:
Date
Signature
NCS00423_Concord MS4 Audit_20220224
4
Page 1 of 17

Permittee Information
MS4 Permittee Name:
City of Concord
Permit Effective Date:
February 20, 2017
Permit Expiration Date:
February 19, 2022
Mailing Address: P.O. Box 308
Concord, North Carolina 28026-0308
Date of Last
MS4 Inspection/Audit:
April 16, 2014
Co-permittee(s), if applicable:
Not Applicable
Permit Owner of Record:
Lloyd W. Payne, City Manager
Primary MS4 Representatives Participating in Audit
Name, Title
Oreanization
Jeff Corley, Water Resource Director
City of Concord
Crystal Scheip, Water Resource Project
Manger
City of Concord
MS4 Receiving Waters
Waterbody
Classification
Impairments
Rocky River
C
Benthos, Turbidity, Copper
Coddle Creek
C
pH, Fish Community, Benthos, Turbidity
Irish Buffalo Creek
C
Fecal Coliform
Threemile Creek
C
None
Afton Run
C
None
Wolf Meadows Branch
C
None
Cold Water Creek
C
None
Unnamed Tributary to Cold Water Creek
C
Chlorophyll a
Funderburks Lake
C
None
NCS00423_Concord MS4 Audit_20220224 Page 2 of 17

List of Supporting Documents
Item
Number
Document Title
When Provided
(Prior to/During/Afteri
1
IDDE Program (revised December 2021)
Prior to
2
Operation and Maintenance Plan for Municipally Owned and Operated Facilities
Prior to
3
Stormwater Control Measures Operation and Maintenance Plan
Prior to
4
Responsible Staff Spreadsheet
Prior to
5
Outfall Map
Prior to
6
City of Concord Illicit Discharge Detection and Elimination (IDDE) Ordinance
Prior to
7
Current Stormwater Management Plan
During
8
Draft Stormwater Management Plan
Prior to
9
City of Concord Stormwater Website
https://concordnc.gov/Departments/Stormwater
Prior to
10
City of Concord 2017 Annual Report
During
11
City of Concord 2018-2021 Annual Report
During
12
Public Education and Outreach Goals and Objectives
During
13
Description of Target Pollutants and Target Audiences
During
14
Public Education and Outreach master List
During
15
Outreach Logs (two logs)
During
16
Image of Tracking System
During
17
Good Housekeeping and IDDE Training Videos
During
18
0&M for Conveyance System
During
19
Map of all SCM
During
20
Inspections of Municipal Owned SCM
During
21
Repair Report Post Inspection
During
22
2021 Employee Training Records
During
23
Spill Response Procedures
During
24
Stormwater Management Advisory Committee Agenda
During
25
Pesticide Applicator List
During
26
Previous IDDE Program
During
27
Street Sweeping Records
After
NCS00423_Concord MS4 Audit_20220224 Page 3 of 17

Program Implementation, Documentation & Assessment
Staff Interviewed:
Jeff Corley, Water Resource Director
(Name, Title, Role)
Crystal Scheip, Water Resource Project Manger
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.
No
---
Funding
The Stormwater Plan identifies a specific position(s) responsible for the overall
Partial
4
coordination, implementation, and revision to the Plan.
Responsibilities for all components of the Stormwater Plan are documented and
Partial
4
position(s) assignments provided.
The permittee is current on payment of invoiced administering and compliance
Yes
BIMS
monitoring fees (see Stormwater e-payments on DEMLR MS4 web page).
Comments: The permittee has a stormwater budget of about $6 million a year. There are 19 full time staff and 3-part time staff who
assist with the stormwater program; however, no staff member is fully dedicated to the stormwater. Supporting document No. four
describes the staff and their associated responsibilities.
II.A.2 Stormwater
The permittee evaluated the performance and effectiveness of the program
Plan
components at least annually.
No
---
Implementation
If yes, the permittee used the results of the evaluation to modify the program
Not
and Evaluation
components as necessary to accomplish the intent of the Stormwater Program.
Applicable
Did the permitted MS4 discharges cause or contribute to non -attainment of an
No
---
applicable water quality standard?
If yes, did the permittee expand or better tailor its BMPs accordingly to address
Not
the non -attainment?
Applicable
Comments: No documentation for annual review of the program was provided.
II.A.3
Keeping the
The permittee kept the Stormwater Plan up to date.
Partial
7,8
Stormwater Plan
Up to Date
The permittee notified DEMLR of any updates to the Stormwater Plan.
Not
Applicable
Comments: The permittee provided a draft Stormwater Management Plan (SWMP) and the current SWMP. The
current plan was
drafted in December 2019. No documentation of annual review was provided.
The permittee kept an up-to-date version of its Stormwater Plan available to the
Yes
Division and the public online.
9
NCS00423_Concord MS4 Audit_20220224 Page 4 of 17

Program Implementation, Documentation & Assessment
II.A.4 Availability
The online materials included ordinances, or other regulatory mechanisms, or a list
of the Stormwater
identifying the ordinances, or other regulatory mechanisms, providing the legal
Yes
9
Plan
authority necessary to implement and enforce the requirements of the permit.
Comments: The permittee has maintained a well -organized webpage including the ordinance and other requirements of the permit.
II.A.3 & II.A.5
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: No documentation of modifications being required.
11.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?
Not
Applicable
Comments: The permittee relies on the North Carolina Department of Environmental Quality (NCDEQ) to conduct erosion and
sediment control inspections.
ll.A.7
The permittee maintained written procedures for implementing the six minimum
Partial
7
Written
control measures.
Procedures
Written procedures identified specific action steps, schedules, resources and
No
---
responsibilities for implementing the six minimum measures.
Comments: The current SWMP has action items to implement each measure. These actions items are not specific and do not
provide specific procedures.
111. A
The permittee maintained documentation of all program components including, but
Program
not limited to, inspections, maintenance activities, educational programs,
Partial
1-27
Documentation
implementation of BMPs, enforcement actions etc., on file fora period of five years.
Comments: The permittee has maintained documentation for most of the minimum control measures. There are a few minor areas
where documentation is insufficient, lacking, or not maintained.
111.E
The permittee submitted annual reports to the Department within twelve months
Annual Report
from the effective date of the permit (See Section III.B. for the annual reporting
Yes
10
Submittal
period specific to this MS4).
The permittee submitted subsequent annual reports every twelve months from the
Yes
11
scheduled date of the first annual report submittal.
The Annual Reports included appropriate information to accurately describe the progress, status, and results
of the permittee's Stormwater Plan, including, but not limited the following:
1. A detailed description of the status of implementation of the Stormwater Plan
as a whole. This will include information on development and implementation
Not
of each major component of the Stormwater Plan for the past year and
Reviewed
schedules and plans for the year following each report.
NCS00423 Concord MS4 Audit 20220224 Page 5 of 17

Program Implementation, Documentation & Assessment
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
Reviewed
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
Reviewed
Plan.
4. A summary of data accumulated as part of the Stormwater Plan throughout
the year along with an assessment of what the data indicates in light of the
Not
Reviewed
Stormwater Plan.
5. An assessment of compliance with the permit, information on the
establishment of appropriate legal authorities, inspections, and enforcement
Not
Reviewed
actions.
Comments: The permittee submitted annual reports for the years 2017-2020 through the online BIMS portal. The 2021 annual
report was a narrative report.
IV.B
Annual Reporting
The Annual Reports document the following:
1. A summary of past year activities, including where applicable, specific
Not
quantities achieved and summaries of enforcement actions.
Reviewed
2. A description of the effectiveness of each program component.
Not
Reviewed
3. Planned activities and changes for the next reporting period, for each
Not
program component or activity.
Reviewed
4. Fiscal analysis.
Not
Reviewed
Comments: This section was not reviewed during this audit.
NCS00423_Concord MS4 Audit_20220224 Page 6 of 17

Public Education and Outreach
Staff Interviewed:
Jeff Corley, Water Resource Director
(Name, Title, Role)
Crystal Scheip, Water Resource Project Manger
Permit Citation
Program Requirement
Status Supporting '
Doc No.
Il.B.2.a
The permittee defined goals and objectives of the Local Public Education and
Yes 12
Goals and
Outreach Program based on community wide issues.
Objectives
Comments: The permittee has a list of educational goals and objectives.
II.B.2.b
The permittee maintained a description of the target pollutants and/or stressors and
Yes
13
Target Pollutants
likely sources.
Comments: The permittee maintained a description of target pollutants and their likely sources.
II.B.2.c
The permittee identified, assessed annually and updated the description of the target
No
---
Target Audiences
audiences likely to have significant storm water impacts and why they were selected.
Comments: No documentation.
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
14
Commercial Issues
their education/outreach program.
Comments: The permittee used various education and outreach methods to convey pollutants and their likely sources.
II.B.2.e
The permittee promoted and maintained an internet web site designed to convey the
Yes
9
Informational
program's message.
Web Site
Comments: The permittee maintained and promoted a website to convey the programs message.
Ii.B.2.f
The permittee distributed stormwater educational material to appropriate target
Yes
15
Public Education
Materials
groups.
Comments: The permittee distributed a variety of education materials over multiple different media platforms.
II.B.2.e
The permittee promoted and maintained a stormwater hotline/helpline for the
Hotline/Help Line
purpose of public education and outreach.
Yes
9
Comments: The permittee maintained a general stormwater hotline for all minimum control measures.
11.B.2.h
Public Education
The permittee's outreach program, including those elements implemented locally or
and Outreach
through a cooperative agreement, included a combination of approaches designed to
Yes
15
Program
reach the target audiences.
For each media, event or activity, including those elements implemented locally or
through a cooperative agreement the permittee estimated and recorded the extent
Yes
15
of exposure.
Comments: The permittee used multiple outreach approaches including, YouTube, Medium, Facebook, Nextdoor, email, and paper
documents provided during outreach. Internet based media is specific for the City of Concord with much of the material created by
the permittee.
NCS00423_Concord MS4 Audit_20220224 Page 7 of 17

Public Involvement and Participation
Staff Interviewed:
Jeff Corley, Water Resource Director
(Name, Title, Role)
Crystal Scheip, Water Resource Project Manger
Permit Citation
Program Requirement Status supporting
Doc Na.
II.C.Z.a Volunteer
Community
The permittee included and promoted volunteer opportunities designed to promote Yes 9
Involvement
ongoing citizen participation.
Program
Comments: The permittee has multiple volunteer opportunities available on the website. These opportunities include Storm Drain
Marking, Clean -A -Creek, and Adopt -A -Stream programs.
II.C.2.b
Mechanism for
The permittee provided and promoted a mechanism for public involvement that
Yes
24
Public
provides for input on stormwater issues and the stormwater program.
Involvement
Comments: The permittee has public meetings with time for stormwater related questions or comments. There is also a
stormwater advisory board that holds public meetings to discuss all things stormwater related.
II.C.2.c
The permittee promoted and maintained a hotline/helpline for the purpose of public
Hotline/Help Linel
involvement and participation.
Yes
9
Comments: The permittee maintained a general stormwater hotline for all minimum control measures.
NCS00423_Concord MS4 Audit_20220224 Page 8 of 17

Illicit Discharge Detection and Elimination (IDDE)
Staff Interviewed:
Jeff Corley, Water Resource Director
(Na
(Name, Title,
Crystal Scheip, Water Resource Project Manger
Permit Citation
Program Requirement status supporting
Doc No.
II.D.2.a
IDDE Program
The permittee maintained a written IDDE Program. Yes 1,26
If yes, the written program includes provisions for program assessment and
Yes 1,26
evaluation and integrating program.
Comments: The permittee maintained a written program to address Illicit Discharge Detection and Elimination.
The permittee maintained an IDDE ordinance or other regulatory mechanism(s) that
Yes
6
t1.D.2.b
provides the legal authority to prohibit illicit connections and discharges to the M54.
Legal Authorities
If yes, the ordinance applies throughout the corporate limits of the permittee.
Yes
6
(Permit Part I. DJ
Comments: The permittee maintained an ordinance for IDDE that provided adequate legal authority through their corporate limits.
ILD.2.c.
The permittee maintained a current map showing major outfalls and receiving
Storm Sewer
Yes
5
System Map
streams.
Comments: The permittee maintains a map of major outfalls.
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
1
Program
Comments: The permittee has written procedures for a Dry Weather Flow program; however, the procedures are not implemented.
II.D.2.e
The permittee maintained written procedures for conducting investigations of
Investigation
identified illicit discharges.
Yes
1
Procedures
Comments: The permittee maintained procedures for conducting illicit discharges investigations. The procedures need to be
updated with the current tracking system.
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 dates) the illicit discharge was observed
Yes
16
2. The results of the investigation
Yes
16
3. Any follow-up of the investigation
Yes
16
4. The date the investigation was closed
Yes
16
Comments: The permittees tracking system records date of observation, investigation, follow-up and date closed.
NCS00423_Concord MS4 Audit_20220224 Page 9 of 17

Illicit Discharge Detection and Elimination (IDDE)
II.D.2.R 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
Yes
22
contact with or otherwise observe an illicit discharge or illicit connection.
Comments: The permittee maintained an annual IDDE and Good Housekeeping training for all City Staff.
II.D.2.h
The permittee informed public employees of hazards associated with illegal
Public Education
discharges and improper disposal of waste.
Yes
22
The permittee informed businesses of hazards associated with illegal discharges and
improper disposal of waste.
Yes
15
The permittee informed the general public of hazards associated with illegal
discharges and improper disposal of waste.
Yes
15
Comments: The permittee informed all staff of hazards associated with illegal dumping and waste disposal during annual trainings.
The permittee also provided the general public and businesses with information about illicit discharges on multiple media
platforms.
II.D.2.i
The permittee promoted,
p p ,publicized, and facilitated a reporting mechanism for the
Public Reporting
public to report illicit discharges.
Yes
9
Mechanism
The permittee promoted, publicized, and facilitated a reporting mechanism for staff
Yes
17
to report illicit discharges.
The permittee established and implemented response procedures for citizen
requests/reports.
Yes
1
Comments: The permittee maintained a hotline for public reporting along with procedures as to how to address the complaint. The
permittee maintained an internal reporting number for City of Concord staff.
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
16
If yes, the mechanism includes the ability to identify chronic violators for
initiation of actions to reduce noncompliance.
Yes
16
Comments: While the permittee has not issued a NOV at this time, they do possess the ability to track NOV and any enforcement.
The permittee's goal is to gain compliance from the public voluntarily instead of through the use of NOV or enforcements.
NCS00423_Concord MS4 Audit_20220224 Page 10 6f 17

Pollution Prevention and Good Housekeeping for Municipal Operations
Staff Interviewed:
Jeff Corley, Water Resource Director
(Name, Title, Role)
Crystal Scheip, Water Resource Project Manger
Permit Citation
Program Requirement Status supporting'
Doc Na.
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 Yes 2
stormwater runoff.
Comments: The permittee maintained a list of owned, operated, or maintained facilities with the potential to pollute.
II.G.2.b
The permittee maintained and implemented an 0&M program for municipally
Operation and
owned and operated facilities with the potential for generating polluted
Yes
2
Maintenance (O&M)
stormwater runoff.
for Facilities
If yes, the 0&M program specifies the frequency of inspections.
Yes
2
If yes, the 0&M program specifies the frequency of routine maintenance
Yes
2
requirements.
If yes, the permittee evaluated the O&M program annually and updated it as
Yes
2
necessary.
Comments: The permittee maintained an Operation and Maintenance (O&M) prograrn that is specific to different types of
operation or storage at each facility. Inspection frequency is dependent on type of activity done at each facility. The O&M program
needs to be more specific regarding frequency of inspection.
II.G.2.c
Spill Response
The permittee had written spill response procedures for municipal operations.
Yes
23
Procedures
Comments: The permittee maintains a spill response policy that discusses what should and should not be done in the event of a
spill.
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
27
Parking Lots
corporate limits annually.
Maintenance
If yes, the permittee evaluated the effectiveness of existing and new BMPs
Yes
27
based on cost and the estimated quantity of pollutants rernoved.
Comments: The permittee owns and utilizes two street sweepers that are active 5 days a week. The trucks are tracked by load and
miles driven.
II.G.2.f
The permittee maintained and implemented an 0&M program for the stormwater
O&M for Catch
sewer system including catch basins and conveyance systems that it owns and
Yes
18
Basins and
maintains.
Conveyance Systems
Comments: The permittee maintained an 0&M program for catch basins and conveyance system of periodic inspections and rain
event inspection. Street weeping is also a part of this maintenance program.
NCS00423_Concord MS4 Audit_20220224 Page 11 of 17

Pollution Prevention and Good Housekeeping for Municipal Operations
II.G.2.d
The permittee maintained a current inventory of municipally -owned or operated
Structural
structural stormwater controls installed for compliance with the permittee's post-
Yes
19
Stormwater Controls
construction ordinance.
Comments: The permittee maintains a map of all SCM owned, operated, and maintained by the City of Concord.
II.G.2.e
The permittee maintained and implemented an 0&M program for municipally -
O&M for Structural
owned or maintained structural stormwater controls installed for compliance with
Yes
3
Stormwater Controls
the permittee's post -construction ordinance. If yes, then:
The C&M program specified the frequency of inspections and routine
Yes
3
maintenance requirements.
The permittee documented inspections of all municipally -owned or maintained
Yes
20
structural stormwater controls.
The permittee inspected all municipally -owned or maintained structural
stormwater controls in accordance with the schedule developed by permittee.
Yes
20
The permittee maintained all municipally -owned or maintained structural
Yes
21
stormwater controls in accordance with the schedule developed by permittee.
The permittee documented maintenance of all municipally -owned or
maintained structural stormwater controls.
Yes
21
Comments: The permittee maintained an 0&M program for all SCMs owned by the City of Concord. The permittee contracts the
annual inspections to a third -party group.
II.G.2.f
The permittee ensured municipal employees are properly trained in pesticide,
Pesticide, Herbicide
herbicide and fertilizer application management.
Yes
25
and Fertilizer
Application
The permittee ensured contractors are properly trained in pesticide, herbicide and
Management
fertilizer application management.
Yes
25
The permittee ensured all permits, certifications, and other measures for
applicators are followed.
Yes
25
Comments: The permittee ensures that personnel who apply fertilizer, herbicide, or pesticide are properly licensed and trained.
II.G.2.g
The permittee implemented an employee training program for employees involved
Staff Training
in implementing pollution prevention and good housekeeping practices.
Yes
22
Comments: The permittee maintained an annual training program involving IDDE and Pollution Precent and Good Housekeeping.
II.G.2.h
The permittee described and implemented measures that prevent or minimize
Vehicle and
contamination of stormwater runoff from all areas used for vehicle and equipment
Yes
22
Equipment Cleaning
cleaning.
Comments: The permittee has two wash bays connected to the sanitary sewer that are used to wash all vehicles and equipment,
discussed during the annual training.
NCS00423_Concord MS4 Audit_20220224 Page 12 of 17

Site Visit Evaluation: Municipal Facility No. 1
Facility Name:
Alfred M. Brown Operation Center
Date and Time of Site Visit:
February 9, 2022, at 9:00 am
Facility Address:
635 Alfred Brown Jr. Court, Concord
Facility Type (Vehicle Maintenance, Landscaping, etc.):
Public Works Facility
Name of MS4 inspector(s) evaluated:
Josh Legg
Most Recent MS4 Inspection (List date and name of inspector):
January 12, 2022
Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name
Title
Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific?
Yes, the facility has a site -specific document.
What type of stormwater training do facility employees receive? How often?
The staff receive annual training that all City of Concord employees receive discussing IDDE and good housekeeping.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
The inspector is SCM inspector certified and participates in annual training provided by the City of Concord.
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
Yes.
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Yes.
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form?
Yes.
Does the MS4 inspector's process include taking photos?
Yes.
Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)?
No.
Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge?
Yes.
Did the MS4 inspector miss any obvious areas of concern? If so, explain:
No.
Does the MS4 inspector's process include presenting the inspection findings to the facility contact?
Yes, the report will be sent to the appropriate personnel following the inspection.
Inspection Results
Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)?
No.
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
Not applicable.
NCS00423 Concord MS4 Audit 20220224 Page 13 of 17

I Site Visit Evaluation: Municipal Facility No. 1 1
Notes/Comments/Recommendations
During the site inspection, it was discussed that the facility does not have a stormwater permit as the primary SIC code is exempt.
After further investigation, if the primary activity at this facility is for emergency services, the activity is exempt from stormwater
permitting requirements. However, it is encouraged that the facility obtain coverage under NCG080000 because emergency service
vehicles are not the only equipment maintained at this facility.
NCS00423_Concord MS4 Audit_20220224 I Page 14 of 17

Site MSK EVAAAon a M "nWPM Feacfflty No. 2
Facility Name:
Date and Time of Site Visit:
Coddle Cree Water Treatment Plant
February 9, 2022, at 1:20 PM
Facility Address:
Facility Type (Vehicle Maintenance, Landscaping, etc.):
6935 Davidson Highway, Concord
Water Treatment Plant
Name of MS4 inspector(s) evaluated:
Most Recent MS4 Inspection (Date and Entity):
Josh Legg
January 10, 2022
Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name
Title
ObservationsFacility
Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific?
Yes, the facility has a site -specific document.
What type of stormwater training do facility employees receive? How often?
The staff receive annual training that all City of Concord employees receive discussing IDDE and good housekeeping.
f
Inspector Training/Knowledge
What type of stormwater training does the M54 inspector receive? How often? I
The inspector is SCM inspector certified and participates in annual training provided by the City of Concord.
—
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
Yes.
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Yes.
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form?
Yes.
Does the MS4 inspector's process include taking photos?
Yes.
Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)?
No.
Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge?
Yes.
Did the M54 inspector miss any obvious areas of concern? If so, explain:
No.
Does the MS4 inspector's process include presenting the inspection findings to the facility contact?
Yes, the report will be sent to the appropriate personnel following the inspection.
Inspection Results
Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)?
Yes. Three things needed repaired. A drainage channel was eroded, sediment has accumulated within the parking lot and sediment
has accumulated within the small settling basin.
If compliance corrective actions were identified, what timeline for correction/folloav-up was provided?
No specific timeline was discussed.
NCS00423 Concord MS4 Audit_20220224 Page 15.of 17

Site Visit Evaluation: MS4 Outfall No.1
Outfall ID Number:
Date and Time of Site Visit:
0-62
February 9, 2022, 10:35 am
Outfall Location:
Outfall Description (Pipe Material/Diameter, Culvert, etc.):
Morris Burn Drive SW, Concord
Two 48" RCP.
Receiving Water:
Is Flow Present? If So, Describe (Color, Approximate Flow Rate,
Unknown tributary to Rocky River
Sheen, Odor, Floatables/Debris, etc.):
Yes, flow is present. Flow is clear and free from solids, odor,
sheen, etc.
Most Recent Outfall Inspection/Screening (Date):
December 14, 2021
Days Since Last Rainfall:
Inches:
Two days
-0.72"
Name of MS4 Inspector(s) evaluated:
Jason Auman
Observations
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
The inspector participates in annual IDDE, and good housekeeping training provided by the City of Concord.
Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations?
Yes.
Inspection Procedures
Does the inspector's process include the use of a checklist or other standardized form?
Yes.
Does the inspector's process include taking photos?
Yes.
Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they?
No.
Inspection Results
Did the outfall inspection result in any work orders or maintenance requests? If so, for what issue(s)?
No.
Will a follow-up outfall inspection be conducted? If so, for what reason?
Yes, regular periodic reinspection.
NCS00423_Concord MS4 Audit_20220224 Page 16 of 17

Site Visit Evaluation: MS4 Outfall No. 2
Outfall ID Number:
Date and Time of Site Visit:
0-55
February 9, 2022, at 11:00 am
Outfall Location:
Outfall Description (Pipe Material/Diameter, Culvert, etc.):
Fawn Ridge Road NW, Concord
56" CMP
Receiving Water:
Is Flow Present? If So, Describe (Color, Approximate Flow Rate,
Unknown Tributary to Rocky River
Sheen, Odor, Floatables/Debris, etc.):
Yes, flow is present. Flow is clear and free from solids, odor,
sheen, etc.
Most Recent Outfall Inspection/Screening (Date):
December 2, 2022
Days Since Last Rainfall:
Inches:
Two days
0.72"
Name of MS4 Inspector's):
Jason Auman
Observations
Inspector Training/Knowledge
What type of stormwater training does the M54 inspector receive? How often?
The inspector participates in annual IDDE, and good housekeeping training provided by the City of Concord.
Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations?
Yes.
Inspection Procedures
Does the inspector's process include the use of a checklist or other standardized form? Obtain copy.
Yes.
Does the inspector's process include taking photos?
Yes.
Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they?
No.
Inspection Results
Did the outfall inspection result in any work orders or maintenance requests? If so, for what issue(s)?
Yes, outfall FES is rusted and needs to repair.
Will a follow-up outfall inspection be conducted? if so, for what reason?
Yes, regular periodic reinspection.
NCS00423_Concord MS4 Audit_20220224
Page 17 of 117

D o D (n o (�
j n S rt
D +S -
a O S* q N
m — O (D
y 0 0 0 O iD (D •
Q =4 Q (D 0
w3 �2,
v ( Q a
m
� � CO) CD w
-• o a
O 3 O
(D �< 3
3 O (D •
N C
(D
a (D
O N
C
D u,
1 n
D C.
a
n
D Z
D
•
v
O ❑ ❑
O
0 Q. CD< N
m
m
]00 3277 7906
]❑❑n�'
C
? m
a
A m 0
. m
r
'D
o j
3
0 i
1
L
c
N
� I
z
Cl)
0
N
0
o
0
C
(a
1
7020 3160 0000 3277 7890
N
J z Cal
CDc C
ru 3 a —
Q
l:(J N
LJ QI
[] �D
C ®_
® 0
m(D C
M ci W
C3 (D
w co
d�l
ru ` C
ap
..0
oo(�cr
m m 0 -
0 moo 0
0 0 K Ka . m
:13 0 Si q -�
(NOD � � CMD 0 m
4
N IL
N
0 a
m
m a
m
El El 0O❑❑
CD(c � � a (O O
❑ ❑
Dn
°D 0-a0
0
rZ W
) p
ZZ (0-)Q
X 7l
o � m
Q
o S(D N
Fn; m
0 O T D
00
N=
n n
C,) z c z
O�
CD
Q
'"' Q c (D w
on
a N L7
o
(np �w j
N* Q N
N
(D N S 0. N
O O:
'O W (D Q Q.
(D
ro �7
77 w vo)
N)oo 0
v,° Qo
(n'n
3 c (D
m
�7
v
m
(D
0 m
cn

R 02 2022
`O
Lrl
—0
La DE.NR:DEILILk
�Rnoreection
`9i.,,,, OM" m
7
Q
(D
T
CD
O O M n CD
0 m � o 'a
mc)��v
m
� �
C
r m 7
m �a
m
0 m (D
co
fl.
m
cn w cn
o
m
C
a
N
�o-
is
0
((D U) O
uU)
_ c')cW C�
Z ov
o Qo cn
G( m
o w =
v
o:
N ■ ■ ..^
�I fDa moor-nff. .o..m D nm D D`+
� ,^cn�oo�-��'•��3��R3
W m.•o m omw am w oQcga�w y 9c^o^ �.
G
a2,o��F,�aomnm �37na 'p'• �S°o?�'<°.
G=.'o^o -ma �'e-'.a3c^i m min m na
���wa2�•�� d.�2SE
Q'
y nmM �� o•o 0
m WOdv m�
m �mo
�..Q 3 �•a c� `��mm ii_'' mm o`^° o^ m'`-�E-Ci
« =.
w •oww
A
nmc� �.�.. •o w Q
v oo cai c• 2, ui m cG
S
lb ■ W
3 �S_•m'om yuo'o ' :r
Q'
�Hc)"nao c� gda �•m y''mmm'ti�coi�
T.
M. m
�• v����m n3�v�5m� mom•-o^�J•`o°m• -`° (�D
o �mw_7Na a: c^mi S. ,3 Ny wa m-FY
� wmE.
�.m
n�o- ck•QU1 o•m lw a. � y �ma �..•
W u ^ ^ w CSC i N
m ■ ■ ■ ■ u W u u
(D maa
mom o m..,,om �•c c)�c m 7. y^c p �m j Q
W a•mo�'`-°9omm >>�n� mm onm
3nvo=i �.� n. van.
wm,m 32i tip m'3n m5 ID
v Lo_�i, o� �.� ®®R 3 --. K• 9 Q.
N y-W
(Ta9c.
2.
O G
,n oT1 •T �ao o . N L. 3 S �' a V5N a
v o�� � f one• '� �•v�i � mQ
01
o v fD
,b ■ N
V G G o `< � N
0 FD' fn cS ^
9 wQw,.c' ME as i'i- =1- W-
d 3s•�,c �'-mmcw,y"'m w•-ic'i^}m `-'.o m,o `�
5 m�-�n^'cm^ioc. c')co�m��'mm yn•2 w�o`'�`�,,��
go
gnow�-u'3 mma' m�.Nyo�-+,'ooR (D
i`-'mmw`�o'm
a.2'o ;mo a:° mn•v+•s mA re
3 v o o m m y „Nw )" c o n� = SD fD N i•F
• 'ci o c is o' H c-v m .o.. } m o• a m a Si
N „}, „, ^ _ �p ,w� p
O
cn
MAR 04 2022
R- I,
UtiV1,�-UtIVILV,
Land Oualih,
0 0 m 0
0 m z 0
r m
M c)
r m
m X
z>
n m
W co
q
m
W
0
C
W
7
O
CD
cn
v
(D
O
m
D
v
O.
a
(D
O
v)
II1
Q
a
5
N
0-
0
X
r
0
RJ
O
U^
W
W
C
�r
Id 0
■