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Home My WebLink AboutNCS000248_Greensboro NPDES MS4 Phase I_Self-Audit TemplateSigned_20220513MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) PHASE I PROGRAM SELF -AUDIT REPORT NPDES PERMIT NO. NCS000248 CITY OF GREENSBORO, NORTH CAROLINA P.O. Box 3136 Greensboro, NC 27402 Self -Audit Date: April 5, 2022 — May 13, 2022 Report Date: May 13, 2022 Greensboro Self -Audit Certification By my signature below, I certify, under penalty of law, that I am a Duly Authorized Representative* and this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. Name: Taiwo Jaiyeoba Title: City Manager Signature: 0 1 V `j Date: Okot�� * A Duly Authorized Representative can be the Mayor, City Manager, or an authorized person or position. To be authorized, a Delegation of Signature Authority Form signed by the Mayor or City Manager must be on file with the Department. NCS000248 Greensboro 2022 MS4 Self -Audit TABLE OF CONTENTS Self -Audit Details...........................................................................................................................................1 PermitteeInformation..................................................................................................................................2 Listof Supporting Documents.......................................................................................................................3 Program Implementation, Documentation & Assessment...........................................................................5 Public Education and Outreach.....................................................................................................................7 Public Involvement and Participation...........................................................................................................9 Illicit Discharge Detection and Elimination (IDDE)......................................................................................10 Construction Site Runoff Controls...............................................................................................................12 Post -Construction Site Runoff Controls......................................................................................................13 Pollution Prevention and Good Housekeeping for Municipal Operations..................................................17 Program to Monitor and Evaluate Stormwater Discharges to Municipal Systems.....................................20 Water Quality Assessment and Monitoring................................................................................................22 Site Visit Evaluation: Municipal Facility No. 1.............................................................................................23 Site Visit Evaluation: Municipal Facility No. 2.............................................................................................25 Site Visit Evaluation: MS4 Outfall No. 1......................................................................................................27 Site Visit Evaluation: MS4 Outfall No. 2......................................................................................................29 Site Visit Evaluation: Construction Site No. 1..............................................................................................31 Site Visit Evaluation: Construction Site No. 2..............................................................................................33 Site Visit Evaluation: Post -Construction Stormwater Control Measure No.1............................................35 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 2............................................37 Appendix A: Supporting Documents DISCLAIMER This audit consists of an evaluation of program compliance with the issued permit and implementation of the approved Stormwater Management Plan. This audit report does not include a review of all program components, and program deficiencies in addition to those noted may be present. The permittee is required to assess program progress and permit compliance, and to implement the approved Stormwater Management Plan in accordance with the issued permit. NCS000248 Greensboro 2022 MS4 Self -Audit iii Self -Audit Details Audit ID Number: Self -Audit Date(s): NCS000248_Greensboro 2022 MS4 Self -Audit April 5, 2022 - May 13, 2022 Minimum Control Measures Evaluated: ® Program Implementation, Documentation & Assessment ® Public Education & Outreach ® Public Involvement & Participation ® Illicit Discharge Detection & Elimination ® Construction Site Runoff Controls ® Post -Construction Site Runoff Controls ® Pollution Prevention and Good Housekeeping for Municipal Operations ® Program to Monitor and Control Pollutants ® Water Quality Assessment & Monitoring Field Site Visits: ® Municipal Facilities. Number visited: 2 ® MS4 Outfalls. Number visited: 2 ® Construction Sites. Number visited: 2 ® Post -Construction Stormwater Runoff Controls. Number visited: 2 ❑ Other: Number visited: Choose an item. ❑ Other: Number visited: Choose an item. Auditors Name Title David Phlegar Stormwater Management Division Manager Virginia Spillman Assistant Director, Water Resources Audit Report Author David Phlegar Date U D /� Ckc I �l X S Signature Name Stormwater Management Division Manager Title Audit Report Author Date Signature Name Title NCS000248_Greensboro 2022 MS4 Self -Audit Page 1 of 39 Audit Report Author Name Date Title Signature Audit Report Author Name Date Title Signature Permittee Information MS4 Permittee Name: City of Greensboro Permit Effective Date: October 10, 2018 Permit Expiration Date: October 9, 2023 Mailing Address: P.O. Box 3136, Greensboro, NC 27402-3136 Date of Last MS4 Inspection/Audit: September 11-13, 2007 Permit Owner of Record: City of Greensboro Primary MS4 Representatives Participating in Audit Name Title David Phlegar Stormwater Management Division Manager Laine Roberts Public Education Coordinator Debbie Shoffner Water Quality Analyst Ray Johnson Stormwater Operations Supervisor Cass Heaton Chief of Sediment and Erosion Control Johnnie Hill Stormwater Engineering Supervisor Virginia Spillman Assistant Director, Water Resources Elea Reyna Ocampo Water Quality Specialist Blake Strumbel Water Quality Analyst NCS000248 Greensboro 2022 MS4 Self -Audit Page 2 of 39 List of Supporting Documents Item Number Document Title Document Format (web link, e- file, etc.) 01 Ordinance Section 30-12-7 (Stormwater Management) pdf 02 Stormwater Management Plan pdf 03 Stormwater Quality Management Program Plan Annual Reports (five most recent fiscal years) pdf 04 DEMLR Stormwater ePayments verification (screenshot) pdf 05 Spills and Concerns (SAC) Database Instruction Manual pdf 06 Example of recent correspondence with regional DEQ office regarding a fish kill pdf 07 Small Polluters Program: Standard Operating Procedures pdf 08 Stormwater Program webpage and "Get Involved" (Public Education and Outreach) webpage (screenshots) pdf 09 Examples of Public Education and Outreach materials (general stormwater educational material) pdf 10 City Contact Center webpage, "Report Water Pollution" web form, and "GSO Collects" smartphone app webpage (screenshots) pdf 11 Examples of public outreach approaches designed to reach the target audiences pdf 12 Memorandum of Understanding (MOU) between Stormwater SMART (Piedmont Triad Regional Council and example extent of exposure for public outreach pdf 13 Examples of volunteer opportunities designed to promote ongoing citizen participation pdf 14 Examples of opportunities for public input on stormwater issues and the stormwater program pdf 15 City of Greensboro webpage providing information on MS4 permit and how public may request copy of SWMP pdf 16 City of Greensboro Land Development Ordinance Section 30-12-7.3 (Illicit Discharges and Improper Disposal) pdf 17 City of Greensboro Land Development Ordinance Section 30-12-7.6 (Enforcement) pdf 18 City of Greensboro Illicit Discharge Detection and Elimination (IDDE) Program Plan (Standard Operating Procedures) pdf 19 City of Greensboro Administrative Procedures for Completing an Enforcement Action ("Enforcement SOP") pdf 20 City of Greensboro NPDES Outfall Screening Program Standard Operating Procedures pdf 21 Example City staff attendance logs for IDDE and small polluter training pdf 22 Example call summaries for IDDE investigation, follow up, and enforcement pdf 23 Official letter from NCDEQ-DEMLR delegating continued administration of SPCA 1973 to City of Greensboro Erosion and Sediment Control Program pdf NCS000248_Greensboro 2022 MS4 Self -Audit Page 3 of 39 24 Erosion and Sediment Control Plan submittal procedure — public funding or power of eminent domain (screenshot) pdf 25 City of Greensboro Land Development Ordinance Section 30-12-3 (Water Supply Watersheds and Other Watershed Districts) pdf 26 City of Greensboro Land Development Ordinance Section 30-13-5 (Engineered Stormwater Controls) pdf 27 Example approved design plans with inspection and maintenance requirements specified pdf 28 Private SCM Inspection Program — Standard Operating Procedures pdf 29 Example SCM inspection reports by qualified professionals pdf 30 Example final plat indicating maintenance responsibility pdf 31 Example meeting agenda for Triad Real Estate and Building Industry Coalition (TREBIC) pdf 32 NCDEQ Stormwater Design Manual (table of contents) pdf 33 Standard Operating Procedures: Pollution Prevention and Good Housekeeping— Municipal Facilities Inspection and Maintenance Program pdf 34 City Owned SCM Inspection Program Standard Operating Procedures pdf 35 City of Greensboro Municipal Separate Storm Sewer System Operation and Maintenance Plan pdf 36 Pollution Prevention Plan: City of Greensboro Transfer Station SPPP pdf 37 Pollution Prevention Plan: City of Greensboro Parks & Recreation Maintenance Facility pdf 38 City of Greensboro — Municipal Vehicle/Equipment Washing Standard Operating Procedures pdf 39 Standard Operating Procedures: Pollution Prevention and Good Housekeeping— Education and Outreach Program pdf 40 Staff Training Tracking Information for Pollution Prevention and Good Housekeeping xIsx 41 Training Video Views for Pollution Prevention and Good Housekeeping pdf 42 Industrial Facility Inventory xIsm 43 Stormwater Industrial Facilities Inspection Program — Standard Operating Procedures pdf 44 Example compliance letter and correspondence with DEMLR for industrial facility pdf 45 City of Greensboro NPDES Permit Program Water Quality Assessment and Monitoring Plan pdf 46 Fixed Interval Monitoring Program: Standard Operating Procedures pdf 47 Description of Water Quality Index (WQI) Database and Data Warehouse pdf NCS000248_Greensboro 2022 MS4 Self -Audit Page 4 of 39 Program Implementation, Documentation & Assessment Staff Interviewed: David Phlegar, Stormwater Management Division Manager (Name, Title, Role) Permit Citation Program Requirement Status supporting Doc No. II.A. 01; Program The permittee maintained adequate legal mechanisms, such as regulations, List of Supporting Implementation ordinances, policies and procedures to implement all provisions of the Stormwater Yes Documents Management Plan (SWMP). (pages 3&4 of this document) The permittee implemented provisions of the Stormwater Management Plan and evaluated the performance and effectiveness of the program components annually. Yes 02,03 The permittee maintained written procedures for implementing the six minimum control measures, which identify specific action steps, schedules, resources and Yes 02 responsibilities. The permittee is current on payment of invoiced administering and compliance monitoring fees (see stormwater e-payments on https://deq.nc.gov/sw). Yes 04 Comments The legal authorities for the City to implement and enforce its Stormwater Program are established through Section 30-12-7 (Stormwater Management) of the City's Land Development Ordinance. The resources provided in the List of Supporting Documents consist of policies and procedures established by the City to implement and enforce its stormwater management program in accordance with and under the legal authority of the City's Stormwater Management Ordinance. The City's Stormwater Management Plan describes written procedures for implementing the minimum control measures as required by the City's Phase I MS4 permit, and the City's Annual Reporting is the primary means by which the City evaluates the performance and effectiveness of the program components. Ill. Program The permittee maintained documentation of all program components including, but List of Supporting Documentation not limited to inspections, maintenance activities, educational programs, monitoring Yes Documents and sampling, implementation of BMPs, enforcement actions and other stormwater (pages 3&4 activities. of this document) Documentation is kept on -file by the permittee for a period of five (5) years. Yes 02 The permittee's Stormwater Management Plan is reviewed and updated as necessary, but at least on an annual basis. Yes 02 Comments Documentation of all program components is described in the individual minimum measures within this self -audit report. Please refer to those sections for detailed information as well as the List of Supporting Documents. IV•B• The permittee submitted annual reports to the Department by October 31st of each 03 and Annual Reporting calendar year for the previous fiscal years activities (from July V to June 30th). Yes DEMLR records The Annual Reports included appropriate information to accurately describe the progress, status, and results of the permittee's Stormwater Management Plan, including, but not limited the following: NCS000248_Greensboro 2022 MS4 Self -Audit Page 5 of 39 Program Implementation, Documentation & Assessment a. A detailed description of the status of implementation of the Stormwater Management Plan. This includes information on development and Yes 02,03 implementation of each major component of the Stormwater Management Plan for the past year and schedules and plans for the year following each report. b. A description and justification of any proposed changes to the Stormwater Management Plan. This includes descriptions and supporting information for the Yes 02,03 proposed changes and how these changes will impact the Stormwater Management Plan (results, effectiveness, implementation schedule, etc.). c. Documentation of any necessary changes to programs or practices for assessment of management measures implemented through the Stormwater Yes 02,03 Management Plan. d. A summary of data accumulated as part of the Stormwater Management Plan Yes 02,03 throughout the year along with an assessment of what the data indicates. e. An assessment of compliance with the permit, information on the establishment Yes 02,03 of appropriate legal authorities, inspections, and enforcement actions. f. Discussion of program funding. Yes 02,03 Comments All information is on file and submitted annually. IV.D. The Permittee maintained a record of any illicit discharge that reaches waters of the Other Information state and may cause or contribute to a violation of the water quality standards or Yes os constitute an imminent threat to health or the environment. The record includes dates, identification of possible responsible parties, causes, and Yes os any action taken by the permittee or the responsible party. Discharges that constitute an imminent threat to health or the environment were reported within 24 hours by phone or e-mail to the Division Regional Office during yes 06 business hours, or to the NC Division of Emergency Management State Operations Center hotline outside of business hours. Comments Records of illicit discharges are maintained in the Spills and Concerns (SAC) database. The City's SAC Database Instruction Manual describes the function of the database and includes numerous screenshots illustrating the types of information that is recorded and how information is input. The Stormwater Program is in regular contact with the NCDEQ regional office on spills/discharges and other water quality related concerns. The referenced supporting document includes an example of recent correspondence with the regional office regarding a fish kill. Additional Program documentation is complete. Comments: NCS000248 Greensboro 2022 MS4 Self -Audit Page 6 of 39 Public Education and Outreach Staff Interviewed: Laine Roberts, Public Education Coordinator (Name, Title, Role) Permit Citation Program Requirement Status Supporting Doc No. II.B.2.a. Target Pollutants The permittee described the target pollutants and target pollutant sources that the Yes oz & Sources public education program is designed to address and why they are an issue. Comments Target pollutants and sources are addressed in the City's Stormwater Management Plan and through the City's Public Education and Outreach Program. II.B.2.b. The permittee described the target audiences likely to have significant Stormwater Target Audiences impacts and why they were selected. Yes 02,07 Comments Target audiences are described in the City's Stormwater Management Plan and are addressed through the City's Public Education and Outreach Program. In addition, the City's Small Polluters Program SOP identifies small polluters (e.g., auto shops, landscapers, painters, restaurants, etc.) that are targeted as part of the City's IDDE program. I I. B.2.c. Informational The permittee promoted and maintained an internet web site designed to convey the Web Site program's message. Yes 08 Comments Public information on the City's Education and Outreach program is provided at www.greensboro-nc.gov/stormwater. There is a webpage dedicated to the City's Public Education and Outreach program where anyone can submit a public education request at www.greensboro-nc.gov/departments/water-resources/get-involved. II.B.2.d. Public Education The permittee distributed general stormwater educational material to appropriate Materials target groups as likely to have a significant stormwater impact. Yes 09 Comments The City has distributed many educational materials in multiple languages through its Education and Outreach program and reports metrics on audiences reached/number of participants in its annual reporting. The referenced supporting document provides select examples of general stormwater educational materials and is not exhaustive. II.B.2.e. The permittee promoted and maintained a stormwater hotline(s) or helpline(s) for Stormwater the public to request information about stormwater, public involvement & Yes 10 Hotline participation, and to report illicit connections & discharges, etc. Comments There are multiple avenues for the public to request information and report stormwater issues, including the City's online "Report Water Pollution" form (www.greensboro-nc.gov/waterpollution) and the City's Contact Center which receives input and inquiries via phone (336-373-CITY), email (see Contact Center webpage), and live chat (www.greensboro-nc.gov/departments/contact- center). In 2018 the City launched the "GSO Collects" smartphone app to provide the public direct access to Field Operations staff for trash, recycling, proper disposal of household hazardous waste, and general issues and inquires. Public Education The permittee's outreach program, including those elements implemented locally or through a cooperative agreement, include a combination of approaches designed to Yes ii & Outreach reach the target audiences. NCS000248_Greensboro 2022 MS4 Self -Audit Page 7 of 39 Public Education and Outreach Program Implementation For each media, event or activity, including those elements implemented locally or through a cooperative agreement, the permittee estimated and recorded the extent Yes 12 of exposure. Comments The City's Public Education and Outreach Program includes a wide variety of approaches to reach target audiences. Examples include social media posts, partnerships with Stormwater SMART, seasonal tabling events throughout the year, radio and television ads, newspapers, bill inserts, activities with local schools and libraries, and more. The referenced supporting document provides select examples illustrating a combination of approaches and is not exhaustive. In addition, the City's annual reporting provides information on BMPs for public education and outreach including activities and analytics (e.g., number of events, number of individuals reached, etc.) The City has an agreement with Stormwater SMART for outreach/education support and a Memorandum of Understanding (MOU) is provided in the supporting documents. The partnership is continuing and an updated MOU is currently being routed through the City for signatures. In addition, an example summary of public education and outreach activities documenting the extent of exposure is also provided for 2021-2022 (to date); please note that this list is not exhaustive. Additional The City's annual stormwater management program report cites statistics from the educational program, Comments: website analytics, hotline calls, etc. NCS000248_Greensboro 2022 MS4 Self -Audit Page 8 of 39 Public Involvement and Participation Staff Interviewed: Laine Roberts, Public Education Coordinator (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 Yes 13 Involvement ongoing citizen participation. Program Comments In addition to the Adopt -a -Stream program (www.greensboro-nc.gov/adoptastream), the City promotes public engagement via NextDoor, Facebook, Instagram, and Twitter. Also, bill inserts, newsletters, local newspaper advertisements (including in Spanish), plus special events and community programs. The referenced supporting document provides select examples of volunteer opportunities and is not exhaustive. 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 13,14 Involvement Comments Opportunities for public input and involvement are provided every two weeks at City Council meetings; input and opportunities for public engagement are also received via social media, NextDoor, during the permit renewal process, at public events, from the website, and via emails to City officials that are routed to the Stormwater Program. The referenced supporting document provides select examples of general public involvement opportunities and is not exhaustive. II.C.2.c. The permittee promoted and maintained a hotline/helpline for the public to request Hotline/Help Line information about stormwater, public involvement & participation, and to report Yes 10 illicit connections & discharges, etc. Comments See'11.13.2.e. Stormwater Hotline' in Public Education and Outreach minimum measure for more information. II.C.2.d. The permittee made the most recent Stormwater Management Plan available for Public Comment public review and comment. Yes 1s Comments Information on the City's SWMP, including how to request the most recent version, is provided via the Stormwater Program webpage at www.greensboro-nc.gov/stormwater. II.C.2.e. The permittee complied with State, Tribal and local public notice requirements when Public Notice implementing the public involvement / participation program. Yes 13 Comments The referenced supporting document provides select examples of means through which the City issues public notices and is not exhaustive. Additional _t Program is continually seeking new opportunities to increase public involvement and engagement in the Comments: stormwater program and improve water quality. NCS000248_Greensboro 2022 MS4 Self -Audit Page 9 of 39 Illicit Discharge Detection and Elimination (IDDE) Staff Interviewed: Debbie Shoffner, Water Quality Analyst (Name, Title, Ray Johnson, Stormwater Operations Supervisor Role) Permit Citation Program Requirement Status Supporting Doc No. II.D.2.a. Legal Authorities The permittee maintained adequate ordinances or other legal authorities to prohibit 16, 17, 1s, illicit connections and discharges and enforce the approved IDDE Program. Yes 19 Comments Prohibition and enforcement of illicit connections and discharges and the City's IDDE Program are made possible through Section 30-12-7.3 (Illicit Discharges and Improper Disposal) and Section 30-12-7.6 (Enforcement) of the City's Land Development Ordinance as well as the City's IDDE Program Plan (SOP) and Enforcement SOP. II.D.2.b. MS4 Mapping The permittee maintained a current map showing major outfalls and receiving Yes streams. 02,20 Comments The City updates the map of major outfalls and receiving streams annually, if needed, in the SWMP. There is also a screenshot of the dashboard in the City's NPDES Outfall Screening SOP. II.D.2.c. Dry Weather Flow The permittee maintained written procedures and/or Standard Operating Procedures Yes (SOPs) for detecting and tracing the sources of illicit discharges. 1s, 20 Program The permittee maintained written procedures and/or Standard Operating Procedures (SOPS) for removing the sources or reporting the sources to the State to be properly Yes la, 20 permitted. The permittee maintained written procedures and/or SOPS that specify a timeframe for monitoring and how many outfalls and the areas that are to be targeted for Yes 20 inspections. Comments The City maintains an IDDE Program Plan (SOP) and NPDES Outfall Screening SOP which provide written procedures for detecting, tracing, removing, and reporting the sources of illicit discharges. The Outfall Screening SOP specifies that all major outfalls should be inspected at least once per permit cycle, and that specific outfalls may be prioritized based on citizen reports and concerns. Further, the Inspection Dashboard (illustrated in the Outfall Screening SOP) notifies the inspector of the current status of each outfall to help them identify and prioritize outfalls for inspection. *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. Employee Training The permittee conducted training for appropriate municipal staff on detecting and Yes 18,21 reporting illicit connections and discharges. Comments The City's IDDE Program Plan (SOP) describes municipal staff training for illicit connection and discharge detection and reporting. The example training attendance logs included in the supporting documents provide an example of staff participation in training for IDDE and small polluters. NCS000248_Greensboro 2022 MS4 Self -Audit Page 10 of 39 Illicit Discharge Detection and Elimination (IDDE) II.D.2.e. The permittee maintained and publicized reporting mechanism(s) for the public to Public Reporting t report illicit connections and discharges. Yes io Comments There are multiple avenues for the public to report potential illicit connections and discharges, including the City's online "Report Water Pollution" form (www.greensboro-nc.gov/waterpollution) and the City's Contact Center which can be reached via phone (336-373-CITY), email (see Contact Center webpage), or live chat (www.greensboro-nc.gov/departments/contact-center). In 2018 the City launched the "GSO Collects" smartphone app to provide the public direct access to Field Operations staff for trash, recycling, and general issues and inquires — the "Report an Issue" feature can be used to direct requests to the relevant supervisor. II.D.2.f. The permittee documented the date of investigations, any enforcement action(s) or Documentation remediation that occurred. Yes os, i9, 2z Comments The City maintains a Spills and Concerns (SAC) database to track reports/complaints including the manner in which the report was received, initial investigations, observations including photos, and follow-up actions including enforcement. The City's SAC Database Instruction Manual provides detailed instructions on how to use the database including numerous screenshots of the database. The City's IDDE Program Plan (SOP) also outlines investigation and reporting procedures including referencing the Enforcement article of the City's Land Development Ordinance (30-12-7.6 Enforcement) and the City's Enforcement SOP. Two examples of call reports are provided in the Supporting documents to demonstrate how the City documents investigations, remediation, and enforcement for spills. Additional The Small Polluters Program (supporting document 07) meets the objective of identifying and targeting Comments: specific pollution sources and audiences that may have the potential to contribute to impaired water quality. NCS000248—Greensboro 2022 MS4 Self -Audit Page 11 of 39 Construction Site Runoff Controls Staff Interviewed: Cass Heaton, Chief of Sediment and Erosion Control (Name, Title, Role) Program Delegation Status: The permittee has a delegated Sediment and Erosion Control Program to implement the North Carolina Sedimentation Pollution Control Act (SPCA) of 1973 and Chapter 4 of Title 15A of the North Carolina Administrative Code. The delegated or authorized Sediment and Erosion Control Program effectively meets the NPDES MS4 MEP standard for Construction Site Runoff Controls by permitting and controlling development activities disturbing one or more acres of land surface and those activities less than one acre that are part of a larger common plan of development as authorized under the Sediment Pollution Control Act of 1973 and Chapter 4 of Title 15A of the North Carolina Administrative Code. Permit Citation Program Requirement Status Supporting Doc No. II.E.2.a. The permittee implements a delegated program in compliance with the Sediment Delegated SPCA Pollution Control Act of 1973 and Chapter 4 of Title 15A of the North Carolina Yes 23 Program Administrative Code within the city's jurisdictional area. Comments (Note date of last SPCA delegated program review by NCDEQ-DEMLR staff and result) The City's Erosion and Sediment Control Program was reviewed by NCDEQ-DEMLR on December 14, 2021. On February 22, 2022 the Sedimentation Control Commission voted to continue delegation of the SPCA of 1973 to the City of Greensboro. A letter announcing DEMLR's decision is provided in the supporting documents and is dated February 24, 2022. II.E.2.c. The permittee provided and promoted a means for the public to notify the Reporting appropriate authorities of observed erosion and sedimentation problems. Yes io Mechanism Comments The primary means for the public to report erosion and sedimentation concerns is the City Contact Center (336-373-CITY). From there, calls are directed to the appropriate program and staff. Input on erosion and sedimentation issues is also received from numerous avenues including reports from internal City staff (phone calls, emails), the GSO Collects app, and social media. II.E.2.d. The permittee coordinated the approval of the construction site runoff control with Coordination with DEMLR for new development and redevelopment projects to be built within the Yes 24 DEMLR permittee's planning jurisdiction by entities with eminent domain authority. Comments The City's Erosion and Sediment Control Plan submittal system incorporates a prompt: "Is this site using any public funding, or does the applicant have the power of eminent domain?" If "yes" is selected, the applicant is directed to submit the plan to NCDEQ for review and approval. Additional Comments: NCS000248 Greensboro 2022 MS4 Self -Audit Page 12 of 39 Post -Construction Site Runoff Controls Staff Interviewed: Virginia Spillman, Assistant Director, Water Resources (Name, Title, Role) Johnnie Hill, Engineering Supervisor Program Implementation (check all that apply): ® The permittee implements the components of this minimum measure. ❑ The permittee relies upon another entity to implement the components of this minimum measure: list name of entity ® The permittee implements the following Qualifying Alternative Program(s), which meet NPDES MS4 post -construction requirements in the areas where they are implemented and in compliance with the specific program requirements as provided in 15A NCAC and noted below: ❑ Water Supply Watershed I (WS-1) —15A NCAC 213.0212 (Eff. March 1, 2019 15A NCAC 02B .0620 - .0624) ❑ Water Supply Watershed II (WS-11) —15A NCAC 213.0214 (Eff. March 1, 2019 15A NCAC 02B .0620 - .0624) ® Water Supply Watershed III (WS-III) —15A NCAC 2B .0215 (Eff. March 1, 2019 15A NCAC 02B .0620 - .0624) ® Water Supply Watershed IV (WS-IV) —15A NCAC 213.0216 (Eff. March 1, 2019 15A NCAC 02B .0620 - .0624) ❑ Freshwater High Quality Waters (HQW) —15A NCAC 2H .1006 ❑ Freshwater Outstanding Resource Waters (ORW) —15A NCAC 2H .1007 ❑ Neuse River Basin Nutrient Sensitive (NSW) Management Strategy —15A NCAC 2B .0235 ❑ 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 Regulatory Authority: The permittee utilizes the following ordinances and/or regulatory authority to fulfill post construction minimum measure program requirements (check all that apply): ❑ DEQ model ordinance ® MS4 designed post -construction practices that meet or exceed 15A NCAC 02H .1000 ❑ DEQ approved comprehensive watershed plan ❑ DEQ approved Qualifying Alternative Program listed above Program Requirement Status Supporting Doc No. 02H .1017 Qualifying The permittee implements the Qualifying Alternative Program requirements Yes 01 Alternative checked above in accordance with the applicable 15A NCAC rules. Program(s) The permittee cumulatively implements the Qualifying Alternative Program 01(see 30- requirements checked above throughout the entire MS4 permitted area. YeS 12-7.113) If response is no or partial, the permittee implements MS4 post construction requirements in accordance with 15A NCAC 02H .1017(3) — Not Applicable (14) throughout the balance of the MS4 permitted area. NCS000248—Greensboro 2022 MS4 Self -Audit Page 13 of 39 Post -Construction Site Runoff Controls Comments Please see Ordinance Section 30-12-7. The Ordinance can be accessed online at http://online.encodeplus.com/regs/greensboro- nc/. Permit Citation Program Requirement Status Supporting Doc No. II.F.2.a. The permittee maintained an ordinance or similar regulatory mechanism that 01 (see 30- Legal Authority authorizes a program to address stormwater runoff from new development and Yes 12-7.213); 25 (see 30- redevelopment to the extent allowable under State law. 12-3.4) Comments Provisions in Ordinance Section 30-12-3.4 address the applicability of the Stormwater Program. II.F.2.b. 25 (see 30- Stormwater Control The permittee maintains strategies that include a combination of structural and/or Yes 12-3.6); 26 Measures (SCMs) non-structural SCMs in concurrence with the legal authorities above (II.F.2.a.). (see 30-13- 5.1) 25 (see 30- The permittee provides a mechanism to require long-term operation and Yes 12 3JUD); maintenance of structural SCMs. 26 (see 30- 13-5.2); 27 The permittee requires annual inspection reports of permitted structural SCMs Yes 25 (see 30- 12-3.7d); performed by a qualified professional. 28,29 The permittee implements SCM requirements that are at least as stringent as the minimum requirements in 15A NCAC 02H .1000. Yes 25 Comments Inspection of SCMs is a requirement that is implemented through multiple avenues including City ordinances (see specific references above), specification of inspection and maintenance requirements on approved design plans (see example in supporting documents), and through the City's Private SCM Inspection SOP. The Stormwater Management Division performs inspections for public and privately owned SCMs within the City limits. Inspections are tracked using RAIN database (see Private SCM Inspection SOP for RAIN screenshots). The supporting documents include several examples of SCM inspection reports performed by qualified professionals. II.F.2.c. The permittee provides mechanisms such as recorded deed restrictions, plats, Deed Restrictions and/or protective covenants so that development activities maintain the project Yes 26 (see 30- 13-5.4); 30 and Protective consistent with approved plans. Covenants Comments The plat recordation requirements associated with SCMs is detailed in Ordinance Section 30-13-5.4. The recorded plat includes applicable items such as the owner's maintenance statement, engineer's certification of quality control, access and maintenance easements, and built upon area limits. NCS000248 Greensboro 2022 MS4 Self -Audit Page 14 of 39 Post -Construction Site Runoff Controls II.F.2.d. 30; 26 (see Operation and The developer provides the permittee with an operation and maintenance plan for 30-13-5.1, Maintenance Plans the stormwater system, indicating the operation and maintenance actions that 30-13-5.2, shall be taken, specific quantitative criteria used for determining when those 30-13-5.3); actions shall be taken, and who is responsible for those actions. Yes 25 (see 30- 12-3.7C2, 30-12- 3.7D, and 30-12- 3.6D; 27 26 (see 30- 13-5.5); 25 The plans clearly indicate the steps that shall be taken and who shall be responsible (see 30-12- for restoring a stormwater system to design specifications if a failure occurs. Yes 3.6D, 30- 12-3.7C2, and 30-12- 3.7D); 27 26 (see Ord The plans include a legally enforceable acknowledgment by the responsible party. Yes 30-13-5.4 and 30-13- 5.3); 27,30 26 (see 30- 13-5.2); 25 Development is maintained consistent with the requirements in the approved (see plans. Yes 30-12-3.7E and 30-12- 3.6) 25 (see Modifications to those plans must be / are approved by the Permittee. Yes 30-12-3.6 and 30-12- 3.7C3) Comments Operation and maintenance requirements are detailed in multiple sections of the Ordinance as noted above. The Ordinance requires that SCM be designed per the State's SCM Manual which includes an 0&M schedule. The O&M schedule specific to the SCM is included on the approved Technical Review Committee (TRC) plan. Additionally, the O&M requirements are documented on the final plat and recorded at the Register of Deeds. Further Ordinance sections as noted above include requirements to submit plans for approval for any new development, which includes changes or additions to previously approved plans. This process is led by the TRC Committee of which Water Resources is a member. II.F.2.e. Educational Materials and The permittee provided educational materials and training for developers. Yes 31 Training Comments Training is provided directly to engineers through ongoing plan review feedback. The Stormwater Management Division website includes a tab for "Developers and Contractors" (www.greensboro-nc.gov/departments/water-resources/developers-and- contractors) that includes links to regulations (i.e., Ordinance), standards (i.e., manuals and specifications) and outside resources (i.e., precipitation data, watershed maps, etc.). The City also regularly participates in local developer organization meetings (including TREBIC) and provides presentations, training, and program updates. NCS000248_Greensboro 2022 MS4 Self -Audit Page 15 of 39 Post -Construction Site Runoff Controls II.F.4. The permittee applies additional requirements to projects draining to SA waters by Sensitive Receiving requiring SCMs that result in the highest degree of fecal coliform die -off and Not Waters controls sources of fecal coliform to the maximum extent practicable in accordance Applicable with 15A NCAC 02H .1017(9) The permittee applies additional requirements to projects draining to Trout waters by requiring SCMs that avoid a sustained increase in receiving water temperature Not Applicable in accordance with 15A NCAC 02H .1017(9) The permittee implements an approved locally implemented Nutrient Management Strategy that addresses post -construction runoff and the provisions yes 1(see 30- 2 -7.2); 32 of that Strategy fulfill the MS4 post -construction requirement. Comments The Ordinance requires projects to meet the requirements of the Stormwater Management Manual which references the State SCM Manual and includes appropriate strategies for nutrient removal. II.F.S. The permittee meets the requirements of the post -construction program for 25 (see 30- Permittee Projects construction projects that are performed by, or under contract for, the permittee. Yes 12-3.4 and 30-12-3.6) Comments As noted in Ordinance Section 30-12-3.4, the regulations are applicable to all projects in the City limits and City -owned projects are not exempted in 30-12-3.48. All City capital projects go through construction and/or TRC plan review processes conducted by the City. II.F.6. 25 (see 30- SCM Design Volume The permittee requires that the water quality design volume of SCMs account for Yes 12-3.6 and the runoff at build out from all surfaces draining to the system. 30-12- 3.7A), 32 Comments The Ordinance requires all projects to meet the requirements of the Stormwater Management Manual which references the State SCM Manual and includes requirements for design volume calculations. II.F.7. The permittee fulfills the post -construction minimum control measure Linear requirements for non-NCDOT linear transportation projects if they are designed, Transportation constructed, and conveyed as set forth in 15A NCAC 02H .1001(1)(c): Projects (i) Constructed to NCDOT standards and in accordance with the NCDOT BMP 25 (see 30- Toolbox; Yes 12-3.4A2) (ii) Conveyed to NCDOT or other public entity and regulated in accordance with that entity's NPDES MS4 Permit; and (iii) The project is not part of a common plan of development. Comments Linear transportation projects (i.e., sidewalks, roadways, and road widening) are reviewed and stormwater impacts are required to meet the City's stormwater regulations to the maximum extent practicable. If it is determined that the projects cannot meet the City's more stringent regulations, the project must still comply with minimum federal and state regulations (i.e., NCDOT standards and BMP Toolbox). Additional Comments: NCS000248 Greensboro 2022 MS4 Self -Audit Page 16 of 39 Pollution Prevention and Good Housekeeping for Municipal Operations Staff Interviewed: Elea Reyna Ocampo, Water Quality Specialist (Name, Title, Role) Laine Roberts, Public Education Coordinator Blake Strumbel, Water Quality Analyst Ray Johnson, Stormwater Operations Supervisor Permit Citation Program Requirement status Supporting Doc No. II.G.2.a. The permittee maintained an inventory of municipal facilities and operations Municipal Facility owned and operated by the permittee that have been determined by the Yes 33 Inventory permittee to have significant potential or generating polluted stormwater runoff. The permittee maintained an inventory of municipally -owned structural SCMs. Yes 34 Comments The City's inventory of municipal facilities, which also assigns a risk rank based on the potential for generating polluted runoff, is provided in the City's Pollution Prevention and Good Housekeeping SOP and is reviewed at least once every permit cycle and updated as needed. In addition, the City's inventory of municipally -owned SCMs is included in the City -Owned SCM SOP and is reviewed at least once every permit cycle and updated as needed. II.G.2.b. The permittee implemented an inspection and maintenance program for facilities Inspection and and operations owned and operated by the permittee for potential sources of Yes 33, 34, 3s Maintenance for polluted runoff, including stormwater controls and conveyance systems. Municipal Facilities The inspection program evaluates pollutant sources, documents deficiencies, plans corrective actions, implements appropriate controls, and documents the Yes 33 accomplishment of corrective actions. The maintenance program includes maintenance activities and procedures aimed at preventing or reducing pollutants generated from municipal facilities and Yes 33 operations. Comments The City's Pollution Prevention and Good Housekeeping SOP describes the City's inspection and maintenance program for City - owned facilities. The City -Owned SCM SOP describes inspection and maintenance protocols for municipally -owned SCMs. Inspection and maintenance of municipal stormwater conveyance systems is described in the City's MS4 Operation and Maintenance Plan. The City's maintenance program for municipal facilities and operations as documented in the Pollution Prevention and Good Housekeeping SOP provides clear procedures for inspections, follow-up, corrective actions, and documentation to prevent or reduce pollution, including a sample inspection form, letter template, sample inspection report, and contact/follow-up log. II.G.2.c. The permittee maintained and implemented Site Pollution Prevention Plans for Site Pollution municipal facilities owned and operated by the permittee that have been Prevention Plans for determined by the permittee to have significant potential for generating polluted Yes 36, 37 Municipal Facilities stormwater runoff that has the goal of preventing or reducing pollutant runoff. Comments The City maintains and implements Site Pollution Prevention Plans for the City of Greensboro Transfer Station and the City of Greensboro Parks and Recreation Maintenance Facility as required. NCS000248_Greensboro 2022 MS4 Self -Audit Page 17 of 39 Pollution Prevention and Good Housekeeping for Municipal Operations II.G.2.d. The permittee maintained spill response procedures for municipal facilities and Spill Response operations owned and operated by the permittee that have been determined by Procedures for the permittee to have significant potential for generating polluted stormwater Yes 36,37 Municipal Facilities runoff. Comments The Site Pollution Prevention Plans for the City of Greensboro Transfer Station and the City of Greensboro Parks and Recreation Maintenance Facility clearly document spill response procedures for those facilities as required. II.G.2.e. The permittee described measures that prevent or minimize contamination of the Vehicle and stormwater runoff from all areas used for vehicle and equipment cleaning, Yes 38 Equipment Cleaning including fire stations that have more than three fire trucks and ambulances. Areas The permittee performs all cleaning operations indoors, covers the cleaning operations, ensures wash water drains to the sanitary sewer system, collects wash Yes 38 water and stormwater run-on from the cleaning areas and provides treatment or recycling, or other equivalent measures The permittee, if sanitary sewer is not available to the facility and cleaning operations take place outdoors, ensures wash water drains to an SCM for treatment, or else the cleaning operations take place on or drain directly to grassed Yes 38 or graveled areas to prevent point source discharges of wash water into the storm drains or surface waters. The permittee, where cleaning operations cannot be performed as described above and when operations are performed in the vicinity of a storm drainage collection system, covers the drain(s) with a portable drain cover during cleaning activities, Yes 38 and any excess standing water is removed and properly handled prior to removing the drain cover. The permittee facilities that have three or fewer fire trucks and ambulances attempt to comply with the above requirements; however, those that cannot Yes 38 comply with these requirements due to existing limitations incorporate structural measures during facility renovation to the extent practicable. Comments The City's Municipal Vehicle/Equipment Washing SOP describes procedures for preventing or minimizing polluted runoff from municipal vehicle and equipment cleaning areas and includes appropriate procedures for indoor and outdoor washing. The vehicle/equipment washing SOP also references other relevant City documents including the City's MS4 Operation and Maintenance Plan, PP/GH training video, Hugh Medford SWPPP, Greensboro Transit Agency SWPPP, and White Street Landfill SWPPP. II.G.2.f. Streets, Roads and The permittee implements BMPs to reduce polluted stormwater runoff from Public Parking Lot municipally -owned streets, roads, and public parking lots within the corporate Yes 3S Maintenance limits. Comments The City's MS4 Operation and Maintenance Plan describes procedures and references relevant SOP documents for reducing or minimizing polluted stormwater runoff from municipally -owned streets, roads, and parking lots. NCS000248_Greensboro 2022 MS4 Self -Audit Page 18 of 39 Pollution Prevention and Good Housekeeping for Municipal Operations n.G.2.s. The permittee maintained and implemented an inspection and maintenance Inspection and program for structural stormwater control measures (SCMs) owned and operated Yes 34,35 Maintenance for by the municipality. Municipal SCMs and MS4 The permittee maintained and implemented an inspection and maintenance program for the municipal storm sewer system (including catch basins, the Yes 35 conveyance system and SCMs). Comments The City -Owned SCM SOP describes the City's inspection and maintenance program for municipally -owned SCMs; this is also referenced in the City's MS4 Operation and Maintenance Plan. The City's MS4 Operation and Maintenance Plan describes the City's inspection and maintenance program for the MS4 and references other relevant SOP documents. II.G.2.h. Staff Training The permittee maintained a training plan that indicates when, how often and who Yes 39, 40, 41 is required to be trained and what they are to be trained on. The permittee implemented a training plan that indicates when, how often, and who is required to be trained and what they are to be trained on. Yes 39, 40, 41 Comments The City's Pollution Prevention and Good Housekeeping Education and Outreach SOP describes the City's training plan including who, when, and how often. Training is provided via a number of methods including online training courses, new employee training programs, and site -specific training. The City maintains a Good Housekeeping Program Training Tracking spreadsheet to record number of staff trained on Pollution Prevention and Good Housekeeping each year by department. In addition, the List of Supporting Documents includes example summary analytics (i.e., number of video views) for internal good housekeeping and pollution prevention training. Additional Comments: NCS000248_Greensboro 2022 MS4 Self -Audit Page 19 of 39 Program to Monitor and Evaluate Stormwater Discharges to Municipal Systems Staff Interviewed: Blake Strumbel, Water Quality Analyst (Name, Title, Role) Permit Citation Program Requirement Status supporting Doc No. II.H.2.a. The permittee maintained an inventory of permitted hazardous waste treatment, Industrial Facility disposal, and recovery facilities, industrial facilities that are subject to Section 313 Yes 42,43 Inventory of Title III of the Superfund Amendments and Reauthorization Act of 1986 (SARA). The permittee maintained an inventory of industrial facilities identified with an industrial activity (as defined in 40 CFR 122.26) permitted to discharge storm water Yes 42,43 to the permittee's MS4. Comments Screenshots of the database can be found in the SOP The City maintains a comprehensive Industrial Facility Inventory which classifies facilities by type (e.g., NPDES permitted, TRI, No Exposure, etc.), includes inspection dates and permit numbers, and also identifies facilities which are considered "high risk." II.H.2.b. Inspection Program The permittee identified priorities and inspection procedures. At a minimum, Yes 43 priority facilities include those identified above (subsection II.H.2.a). Comments The City maintains a Stormwater Industrial Facilities Inspection Program SOP which describes priorities and inspection procedures. The SOP describes inspection methods, frequency, staff training, step-by-step procedures based on facility type, documentation procedures, enforcement, and records management. II.H.2.c. The permittee evaluated control measures implemented at permitted hazardous Industrial Facility waste treatment, disposal, and recovery facilities, industrial facilities that are Evaluation subject to Section 313 of Title III of the Superfund Amendments and Reauthorization Act of 1986 (SARA). Yes 43 For the purpose of this permit, the Permittee is authorized to inspect the permitted hazardous waste treatment disposal, and recovery facilities as an authorized representative of the Director. The permittee evaluated control measures implemented at industrial facilities identified with an industrial activity permitted to discharge storm water to the permittee's MS4. Yes 43 For the purposes of this permit industrial activities shall mean all permitted industrial activities as defined in 40 CFR 122.26. For permitted industrial facilities, the permittee established procedures for Yes 43 reporting deficiencies and non-compliance to the permitting agency. Where compliance with an existing industrial stormwater permit does not result in adequate control of pollutants to the MS4, the permittee recommends and Yes 44 documents the need for permit modifications or additions to the permit issuing authority. The permittee evaluated control measures implemented at industrial facilities Yes 43,18 identified as an illicit discharge under the IDDE Program. NCS000248 Greensboro 2022 MS4 Self -Audit Page 20 of 39 Program to Monitor and Evaluate Stormwater Discharges to Municipal Systems I Comments The City's Stormwoter Industrial Facilities Inspection Program SOP includes established procedures to address these permit requirements. The SOP includes an example inspection form, letter templates (multiple examples depending on severity of deficiencies), and screenshots describing data entry into the City's database for tracking and follow-up. The Industrial Facilities SOP also references a number of other relevant guides and SOPS. An example compliance letter and correspondence with DEMLR is provided to demonstrate the City's actions when compliance with an existing industrial stormwater permit does not result in adequate control of pollutants to the MS4. Additional Comments: NCS000248_Greensboro 2022 MS4 Self -Audit Page 21 of 39 Water Quality Assessment and Monitoring Staff Interviewed: Debbie Shoffner, Water Quality Analyst (Name, Title, Role) Blake Strumbel, Water Quality Analyst Permit Citation Program Requirement Status Supporting Doc No. 11.1.2.a. The permittee maintained a Water Quality Assessment and Monitoring Plan. Yes 45 Water Quality Assessment and The Water Quality Assessment and Monitoring Plan includes a schedule for Monitoring Plan Yes 45 implementing the proposed assessment and monitoring activities. Comments The City maintains and implements a Water Quality Assessment and Monitoring Plan which is reviewed annually and updated as needed. The Plan describes monitoring methods, types, parameters, locations, and frequency, as well as analytical methods, quality assurance and recordkeeping procedures, and data evaluation methods. 11.1.2.b. The permittee maintained and implemented the Water Quality Assessment and Water Quality Monitoring Plan submitted to DEMLR. Yes 45,03 Monitoring The Division waived the requirement to maintain a Water Quality Assessment and Not Monitoring Plan. Applicable Comments The City maintains and implements a Water Quality Assessment and Monitoring Plan which is reviewed annually and updated as needed. Additional In addition to the Water Quality Assessment and Monitoring Plan, the City maintains an SOP for its fixed Comments: interval sampling (FIS) program (supporting document 46). Water quality data are used by the City to develop a WQI score for the City's streams. A summary of the City's WQI database (supporting document 47) including screenshots is provided in the Supporting documents. NCS000248_Greensboro 2022 MS4 Self -Audit Page 22 of 39 Site Visit Evaluation: Municipal Facility No. 1 Facility Name: Date and Time of Site Visit: Hugh Medford Municipal Operations Center (NCG080799) April 27, 2022, 1:30 pm Facility Address: Facility Type (Vehicle Maintenance, Landscaping, etc.): 401 Patton Avenue, Greensboro, NC 27406 Vehicle Maintenance Areas, Field Operations (NCG080799) Name of M54 inspector(s) evaluated: Most Recent MS4 Inspection (List date and name of inspector): Blake Strumbel December 8, 2020 (City of Greensboro Stormwater Management Division) Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit: Name Title Richard Lovett Environmental Services Support Manager Lorien Deaton Environmental Compliance Specialist Observations Facility Documentation/Training Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific? Yes. What type of stormwater training do facility employees receive? How often? Training includes stormwater pollution prevention and spill prevention and is completed annually. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Initial training consists of reviewing pertinent documents and hands-on field training. Additional training takes place as applicable. (See the industrial inspections SOP for more information.) Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? Yes. The inspector was familiar with the site's general permit and applied that knowledge during both the document review and the site walk. 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. An inspection report was used that included items applicable to the NPDES permit. 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)? Yes. NCS000248_Greensboro 2022 MS4 Self -Audit Page 23 of 39 Site Visit Evaluation: Municipal Facility No. 1 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. Inspection Results Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)? No corrective actions were necessary. Minor recommendations were made, and a final inspection letter was sent to DEMLR per operational procedures. If compliance corrective actions were identified, what timeline for correction/follow-up was provided? N/A Notes/Comments/Recommendations NCS000248_Greensboro 2022 MS4 Self -Audit Page 24 of 39 Site Visit Evaluation: Municipal Facility No. 2 Facility Name: Date and Time of Site Visit: City of Greensboro Solid Waste Transfer Station 4/28/2022 at 9:OOAM Facility Address: Facility Type (Vehicle Maintenance, Landscaping, etc.): 6310 Burnt Poplar Rd, Greensboro, NC 27409 Solid Waste Facility Name of MS4 inspector(s) evaluated: Most Recent MS4 Inspection (Date and Entity): Elea Reyna Ocampo 2/13/2019 by the City of Greensboro Stormwater Management Department Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit: Name Title Richard Lovett Environmental Services Support Manager Lorien Deaton Environmental Compliance Specialist Observations Facility Documentation/Training Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific? This facility does not have an industrial stormwater permit. However, the City of Greensboro Stormwater Department created a Pollution Prevention Plan for the facility in accordance with Section G, 2(d). What type of stormwater training do facility employees receive? How often? Facility personnel receive annual pollution prevention and spill prevention training. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? All water quality staff undergo "on -boarding" training which entails reviewing the Standard Operating Procedures for conducting a facility inspection. Once the SOP has been reviewed, new employees accompany senior staff members on a handful of facility inspections before conducting visits on their own. Additional training sessions are held by the staff member overseeing the inspection program. These trainings are held as needed, and can cover a wide variety of topics including revisions to general industrial stormwater permits, updates to the active facility spreadsheet, interesting situations encountered during a previous inspection, etc. Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? Yes. Although the facility does not have an NPDES permit, Elea ensured that activities and control measures on -site were in compliance with Part G of the City's Stormwater Permit, as well as the requirements listed in the facility's Spill Prevention, Control, and Countermeasures Plan. Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping? Yes. Elea assists in oversight of the Pollution Prevention and Good Housekeeping portion of the City's Stormwater Permit and was able to apply her knowledge over the course of the facility inspection. Inspection Procedures Does the MS4 inspector's process include the use of a checklist or other standardized form? Yes. Elea utilized the "Inspection Checklist/Report" documents created for conducting good housekeeping inspections. NCS000248_Greensboro 2022 MS4 Self -Audit Page 25 of 39 Site Visit Evaluation: Municipal Facility No. 2 Does the MS4 inspector's process include taking photos? Yes. Elea took photos of the Site's industrial activity areas, stormwater conveyance system, and material storage areas. Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)? Yes. Elea reviewed the Pollution Prevention Plan and found no deficiencies. 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. Elea informed Richard and Lorien at the end of the inspection that no deficiencies in the site's good housekeeping procedures were discovered. Inspection Results Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)? No corrective actions were necessary. If compliance corrective actions were identified, what timeline for correction/follow-up was provided? N/A Notes/Comments/Recommendations NCS000248_Greensboro 2022 MS4 Self -Audit Page 26 of 39 Site Visit Evaluation: MS4 Outfall No. 1 Outfall ID Number: Date and Time of Site Visit: P1024776 4/27/2022 2:40pm Outfall Location: Outfall Description (Pipe Material/Diameter, Culvert, etc.): Near 296 Edwardia Dr. 42" RCP outlet w/ headwall (4.5' from invert to top of headwall) Receiving Water: Is Flow Present? If So, Describe (Color, Approximate Flow Rate, Sheen, Odor, Floatables/Debris, etc.): South Buffalo 1 No flow. Some algae staining. Most Recent Outfall Inspection/Screening (Date): 11/17/2017 Days Since Last Rainfall: Inches: 8 0.4 Name of MS4 Inspector(s) evaluated: Devin Lattimore Observations Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? As referenced in the SOP, field training is performed with senior staff until deemed proficient. This includes review of the water pollution identification field guide, the outfall SOP, and GIS infrastructure software (for tracing purposes). Training is performed during onboarding and ongoing as needed. 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(Survey123) Does the inspector's process include taking photos? Yes (uploaded to Survey123) 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? Not at this time. Notes/Comments/Recommendations NCS000248_Greensboro 2022 MS4 Self -Audit Page 27 of 39 I Site Visit Evaluation: MS4 Outfall No. 1 The outfall was located downstream of an adjacent concrete mixing plant. NCS000248_Greensboro 2022 MS4 Self -Audit Page 28 of 39 Site Visit Evaluation: MS4 Outfall No. 2 Outfall ID Number: Date and Time of Site Visit: P1013069 4/27/2022 3:20 pm Outfall Location: Outfall Description (Pipe Material/Diameter, Culvert, etc.): Behind 1808 Huntington Rd. 36" RCP Receiving Water: Is Flow Present? If So, Describe (Color, Approximate Flow Rate, Sheen, Odor, Floatables/Debris, etc.): North Buffalo 2 Subbasin Low flow, no odor, no color. Traced upstream and lost flow between structures. Appears to be groundwater intrusion. Did Most Recent Outfall Inspection/Screening (Date): find a contractor pressure washing nearby but water didn't 12/21/2016 appear to reach the stormwater system. Days Since Last Rainfall: Inches: 8 0.4 Name of MS4 Inspector(s) evaluated: Kenneth Taylor Observations Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? As referenced in the SOP, field training is performed with senior staff until deemed proficient. This includes review of the water pollution identification field guide, the outfall SOP, and GIS infrastructure software (for tracing purposes). Training is performed during onboarding and ongoing as needed. 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(Survey123) Does the inspector's process include taking photos? Yes (uploaded to Survey123) 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? Not at this time. Notes/Comments/Recommendations NCS000248_Greensboro 2022 MS4 Self -Audit Page 29 of 39 I Site Visit Evaluation: MS4 Outfall No. 2 1 NCS000248_Greensboro 2022 MS4 Self -Audit Page 30 of 39 Site Visit Evaluation: Construction Site No. 1 Site/Project Name: Date and Time of Site Visit: Interstate Industrial Park at 215 E. A Drive 5/4/2022 1:50pm Site/Project Address: Operator: 215 E. A Drive Koury Ventures Limited Partnership Project Type Greensboro, NC 27406 (Commercial, Industrial, Residential, CIP, Road, etc.): Industrial NCG Permit ID Number: NCG Permit ID Number: NCC213994 NCC213994 Recent Enforcement Actions (Include Date): Name of MS4 Inspector(s) evaluated: None Mark Cain Name(s) and Title(s) of Site Representative(s) Present During the Site Visit: Name Title Josh Clapp Superintendent Observations Site Documentation/Training Does the site have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it site -specific? Yes, it is included in the E&SC plan set. Does the site have approved erosion and sedimentation control plans onsite? Are they representative of current site conditions? Yes. What type of stormwater training do site employees receive? How often? Unknown. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Inspector receives regular training through WRRI and NCDEO, DEMLR. Did the MS4 inspector appear knowledgeable about MS4 and NCG010000 requirements for construction sites? Yes. Did the MS4 inspector appear knowledgeable about erosion and sedimentation control/stormwater pollution prevention BMPs? Yes. Inspection Procedures Does the MS4 inspector's process include the use of a checklist? Yes. Does the MS4 inspector's process include taking photos? Yes. NCS000248_Greensboro 2022 MS4 Self -Audit Page 31 of 39 Site Visit Evaluation: Construction Site No. 1 Does the MS4 inspector's process include reviewing approved plans (erosion and sedimentation control and/or SWPPP)? Yes, the inspector familiarizes himself with the SWPP and E&SC plans prior to beginning the inspections, and refers to the plan as needed during the inspection. Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge? Yes. Did the MS4 inspector miss any obvious violations? If so, explain: No. The inspector noted all violations and maintenance concerns. Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing? Yes, the inspector sends the financially responsible party an inspection report. Does the MS4 inspector's process include providing construction stormwater educational materials to the site contact? The inspector provides educational materials such as standard design details as needed. Compliance/Enforcement What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in? No enforcement at this time. A non-compliance inspection report was issued noting minor maintenance issues and the need for additional stabilization. If compliance issues were identified, what timeline for correction/follow-up was provided? 30 days. Notes/Comments/Recommendations The inspector spoke with the superintendent at the beginning and end of the inspection, and sent an inspection report to the owner and superintendent following the inspection. NCS000248_Greensboro 2022 MS4 Self -Audit Page 32 of 39 Site Visit Evaluation: Construction Site No. 2 Site/Project Name: Date and Time of Site Visit: Woodland Heights of Greensboro, Phase 2 5/4/2022 2:45pm Site/Project Address: Operator: 132 Wolftrail Rd. Woodland Heights West, LLC Project Type Greensboro, NC 27406 (Commercial, Industrial, Residential, CIP, Road, etc.): Multi -family residential (apartments) NCG Permit ID Number: NCG Permit ID Number: NCC204497 NCC204497 Recent Enforcement Actions (Include Date): Name of MS4 Inspector(s) evaluated: Notice of Violation issued 10/24/2021 Mark Cain Name(s) and Title(s) of Site Representative(s) Present During the Site Visit: Name I Title None present at the time of inspection. I N/A. Observations Site Documentation/Training Does the site have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it site -specific? Yes, it is included in the E&SC plan set. Does the site have approved erosion and sedimentation control plans onsite? Are they representative of current site conditions? This site has an approved E&SC plan, but we were unable to locate a site copy at the time of the inspection. Inspector did have our copy with him. What type of stormwater training do site employees receive? How often? Unknown. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Inspector receives regular training through WRRI and NCDEQ, DEMLR. Did the MS4 inspector appear knowledgeable about MS4 and NCG010000 requirements for construction sites? Yes. Did the MS4 inspector appear knowledgeable about erosion and sedimentation control/stormwater pollution prevention BMPs? Yes. Inspection Procedures Does the MS4 inspector's process include the use of a checklist? Yes. Does the MS4 inspector's process include taking photos? NCS000248_Greensboro 2022 MS4 Self -Audit Page 33 of 39 Site Visit Evaluation: Construction Site No. 2 Yes. Does the MS4 inspector's process include reviewing approved plans (erosion and sedimentation control and/or SWPPP)? Yes, the inspector familiarizes himself with the SWPP and E&SC plans prior to beginning the inspections, and refers to the plan as needed during the inspection. Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge? Yes. Did the MS4 inspector miss any obvious violations? If so, explain: No. The inspector noted all of the same violations that I noted. Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing? Yes, the inspector sends the financial responsible part and other site contacts an inspection report after each inspection. Does the MS4 inspector's process include providing construction stormwater educational materials to the site contact? Yes, as needed. Compliance/Enforcement What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in? Non-compliance inspection report and NOV issued. If compliance issues were identified, what timeline for correction/follow-up was provided? 2 weeks. Notes/Comments/Recommendations This site had several issues including concrete being washed out in various places on the site in addition to erosion control maintenance concerns and lack of stabilization. The inspector called the site superintendent at the time of inspection to discuss the issues he found. A notice of violation was issued. NCS000248_Greensboro 2022 MS4 Self -Audit Page 34 of 39 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1 Site Name: Date and Time of Site Visit: The Reserve at Greenwood 5/5/2022 11:00 am Site Address: SCM Type: 519 Carolwill Drive Wet Detention Pond Greensboro, NC 27455 Most Recent MS4 Inspection (Include Date and Entity): 5/17/2021(Stormwater Management staff) Name of MS4 Inspector(s) evaluated: Most Recent MS4 Enforcement Activity (Include Date): Elea Reyna Ocampo N/A Name(s) and Title(s) of Site Representative(s) Present During the Site Visit: Name Title None present at the time of inspection. Observations Site Documentation Does the site have an operation and maintenance plan? Yes. Does the site have records of annual inspections? Are they performed by a qualified individual? Yes. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? --NC State University/NC Cooperative Extension —Certified Stormwater SCM Inspection & Maintenance Professional (renewed every three years) --On-the-job training, as well as new employee training Did the MS4 inspector appear knowledgeable about MS4 requirements for post -construction site runoff controls? Yes. Did the MS4 inspector appear knowledgeable about post -construction BMPs (general purpose/function, components, O&M requirements, etc.)? Yes. Inspection Procedures Does the MS4 inspector's process include the use of a checklist or other standardized form? What format? Yes. Refer to SOP for privately owned SCMs. Does the MS4 inspector's process include taking photos? Yes. Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections? Yes. NCS000248_Greensboro 2022 MS4 Self -Audit Page 35 of 39 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1 Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge? Yes. Did the MS4 inspector miss any obvious operation and maintenance deficiencies? If so, explain: No. Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing? Yes. Compliance/Enforcement What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in? The owner/responsible party will receive a letter (inspection report) with required maintenance items. If compliance issues were identified, what timeline for correction/follow-up was provided? The owner/responsible party has 90 days to complete any required maintenance items. Notes/Comments/Recommendations NCS000248_Greensboro 2022 MS4 Self -Audit Page 36 of 39 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 2 Site Name: Date and Time of Site Visit: Treybrooke Village Apartments 5/5/2022 12:00pm Site Address: SCM Type: 520 Teakwood Drive Bioretention Area (Grassed) Most Recent MS4 Inspection (Include Date and Entity): Greensboro, NC 27406 2/15/2021 (Stormwater Management staff) Name of MS4 Inspector(s) evaluated: Most Recent M54 Enforcement Activity (Include Date): Debbie Shoffner N/A Name(s) and Title(s) of Site Representative(s) Present During the Site Visit: Name Title None present at the time of inspection. Observations Site Documentation Does the site have an operation and maintenance plan? Yes. Does the site have records of annual inspections? Are they performed by a qualified individual? Yes. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? --NC State University/NC Cooperative Extension —Certified Stormwater SCM Inspection & Maintenance Professional (renewed every three years) --On-the-job training, as well as new employee training Did the MS4 inspector appear knowledgeable about MS4 requirements for post -construction site runoff controls? Yes. Did the MS4 inspector appear knowledgeable about post -construction BMPs (general purpose/function, components, 0&M requirements, etc.)? Yes. Inspection Procedures Does the MS4 inspector's process include the use of a checklist or other standardized form? What format? Yes. Refer to SOP for privately owned SCMs. Does the MS4 inspector's process include taking photos? Yes. Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections? Yes. NCS000248 Greensboro 2022 MS4 Self -Audit Page 37 of 39 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 2 Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge? Yes. The inspection process consisted of a thorough investigation of all parts of the SCM, including inlets, outlets, etc. Did the MS4 inspector miss any obvious operation and maintenance deficiencies? If so, explain: No. Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing? Yes. Compliance/Enforcement What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in? The owner/responsible party will receive a letter (inspection report) with required maintenance items. If compliance issues were identified, what timeline for correction/follow-up was provided? The owner/responsible party has 90 days to complete any required maintenance items. Notes/Comments/Recommendations NCS000248_Greensboro 2022 MS4 Self -Audit Page 38 of 39 APPENDIX A: SUPPORTING DOCUMENTS NCS000248_Greensboro 2022 MS4 Self -Audit Page 39 of 39