02_NCS000564_GAP Analysis_20220915

:i WithersRavenel
Our People. Your Success.
MEMORANDUM
To: Brian Bray -Public Works Director, Town of Wendell
CC: Daryl Hales - Public Works Superintendent, Town of Wendell
From: Lars R. Hagen Jr., Kathleen Balaze, Katherine Knight - WithersRavenel
Date: April 7, 2020
Project: Town of Wendell Stormwater Consultation, WR Job No. 02190728.01
Subject: Gap Analysis Executive Summary
Background
In 2019, the North Carolina Department of Environmental Quality (DEQ) in conjunction with the
Environmental Protection Agency (EPA), began National Pollutant Discharge Elimination System (NPDES)
Permit Compliance Audits of Phase II Municipal Separate Storm Sewer System (MS4) communities in North
Carolina. The MS4 program is intended to protect water quality by preventing pollution from entering the
storm sewer system, which leads directly to surface waters of the state. Many communities in the initial
audits received Notices of Violation for permit noncompliance, constituting violation of the Clean Water Act
and grounds for enforcement action. The audits have been incorporated as a regular part of the NPDES
permit renewal process, which occurs every 5 years. As a Phase II community the Town of Wendell will be
subject to an audit performed by the DEQ, which is currently scheduled for 2022. The Town of Wendell
retained WithersRavenel to provide consultation in preparation for the audit.
The NPDES Permit requires MS4 Stormwater Program implementation provisions as well as specific
program components called the "Six Minimum Measures". These components include:
• Public Education and Outreach
• Public Involvement and Participation
• Illicit Discharge Detection and Elimination (IDDE)
• Construction Site Runoff Control
• Post -Construction Site Runoff Control
• Pollution Prevention and Good Housekeeping for Municipal Operations (PPGH)
Approach
WithersRavenel completed a Pre -Audit Gap Analysis of the Town of Wendell's MS4 Stormwater Program
to compare the current program to NPDES Phase II MS4 Permit requirements. Attached is the Gap Analysis
Matrix detailing the individual permit requirements by section, status, actions currently performed by the
Town and others, and additional actions to address.
This memorandum summarizes the findings of the Gap Analysis and highlights significant outstanding permit
requirements that should be addressed as part of the Town's MS4 Stormwater Program.
Current M5;4 Starmwatpr Praarar
At this time the MS4 Stormwater Program is overseen by the Director of Public Works who is also
responsible for oversight of the Public Works Department. Day to day program implementation of the MS4
Stormwater Program is also carried out by the Superintendent with the support of all Public Works
Department employees. Together they maintain the stormwater network, address stormwater work orders,
facilitate Public Education and Outreach activities, and perform MS4 Stormwater Program administrative
duties. The Town intends to hire a stormwater professional by July of 2020 who will assume responsibility
for many of these duties.
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r: WithersRavenel Town of Wendell Gap Analysis Executive Summary
Our People. Your Success.
Permit requirements that are currently performed include: advertisement of a stormwater hotline (the
general public works phone number), stormwater employee training, and some inspections. Additional
permit requirements are performed or partially implemented, but are not formally documented. Stormwater
program documentation and is primarily documented in Accela, a work order tracking system.
The Town relies on several partners to implement other components of the MS4 Stormwater Program.
Portions of the Public Education and Outreach minimum measure are contracted to the Clean Water
Education Partnership (CWEP). The Town relies on the State Sedimentation and Erosion Control Program,
delegated to Wake County, for Construction Site Runoff Control. Site plan reviews for Post -Construction
Site Runoff Control are conducted by Wake County and AMT.
Required Actions
While strides have been made to move forward, the Town needs to take action and commit additional
resources to the MS4 Stormwater Program to meet permit requirements. Detailed permit requirements and
action items are listed in the attached Gap Analysis matrix. Following is a summary of major tasks that
should be addressed by the MS4 Stormwater Program.
Stormwater Management Plan
The Town has an existing Stormwater Management Program (SWMP) document that was submitted with
the permit renewal application in 2017. Although the SWMP covers all of the "Six Minimum Measures" for
permit compliance, there are no best management practices (BMPs) for program implementation or
measurable goals with implementation timelines. A new Stormwater Management Plan (SWMP) should be
developed to reflect the proposed changes to the MS4 Stormwater Program. Once the SWMP has been
revised, it should be published online.
MS4 Mapping
The Town recently obtained a geographic information system (GIS) map with locations of receiving waters
and stormwater infrastructure. However, major outfalls are not identified and there appear to be some data
gaps in the mapping, especially around the areas of new development. The MS4 Map should be updated to
identify major outfalls (including conveyance type, material, shape and size) and to include recently
constructed stormwater infrastructure. In anticipation of future permit requirements, it is recommended
that any new mapping includes additional information such as material and flow direction, as well as the
locations of private and municipal -owned stormwater control measures (SCMs).
Ordinance Updates/Stakeholder Meetin4
An interlocal agreement is in place with Wake County to implement Construction and Post -Construction
Runoff Control portions of the permit. A stakeholder meeting including the Town of Wendell, Wake County,
and the State is recommended for review of the interlocal agreement as well as ordinances. This meeting
should include discussion of the responsibilities of each party and development of best management
practices for reporting and documenting enforcement. It is recommended that a full ordinance review is
conducted, however at a minimum, the following ordinances should be reviewed and updated:
• Illicit Discharge Ordinance - UDO Section 6.5.Q should be revised to provide for authority to
enforce, specifically in cases of illicit discharges
• Consider addition of a pet waste litter prohibition
*This list of ordinances is neither meant to be exhaustive nor a full ordinance review
Community Involvement
The Public Involvement and Participation minimum measure requires opportunities for community
involvement in stormwater issues. It is recommended that additional venues for community interaction are
developed to include:
• Develop a stormwater advisory board for public input on stormwater issues
• Develop additional volunteer opportunities such as an ado pt-a-stream /catch basin or storm drain
marking programs
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:r WithersRavenel Town of Wendell Gap Analysis Executive Summary
Our People. Your Success.
Program Documents
Each of the "Six Minimum Measures" requires development of program documents such as standard
operating procedures (SOPs), Inspections and Maintenance (I&M) manuals, and tracking mechanisms for
documentation. The following documents should be created or updated as supplements to the MS4
Stormwater Plan for implementation of the program:
• Create tracking and documentation mechanisms for the BMPs developed in the new SWMP
• Revise list of responsible parties for program implementation (an example list can be found in DEQ
SWMP template)
• Perform a fiscal analysis to determine the adequacy of current budget for the MS4 Stormwater
Program and include in the Annual Self -Assessment
• Update the Town stormwater webpage to include the following:
o Updated links
o Town stormwater ordinances
o Phase 11 MS4 program information
o The State Stop Mud hotline _
o The new SWMP
• Update lists in the SWMP that document the Town's receiving waters, target pollutants, target
audiences, and stormwater issues
• Create the following IDDE documents:
o Dry weather flow inspections SOP that identifies priority outfalls and documents a method
for completing inspections of all major outfalls within the permit cycle
o Investigation SOP that includes:
■ A method to investigate suspected illicit discharges
■ An IDDE-specific tracking mechanism with dates, the results of the investigation,
any follow-up of the investigation, and the date the investigation was closed to help
identify chronic violators
• Create an inventory of private and municipal -owned post -construction SCMs
• Create post -construction SCM inspection SOPS and enforce requirement of yearly inspections
• Create the following PPGH documents:
o Inventory of municipal facilities with the potential to pollute stormwater
o PPGH I&M Plans for municipal facilities with the potential to pollute stormwater and
municipally -owned SCMs
o PPGH SOPS
■ Street/parking lot maintenance, street sweeping, and leaf pickup SOPs
■ Vehicle and equipment maintenance and cleaning SOPs
■ Spill response/spill kit use SOPs
o Proactive PPGH I&M Plan for the storm sewer system
Employee Training
The NPDES Permit requires training of municipal employees for several of the "Six Minimum Measures".
Continue to perform current training and documentation and expand the program to include all of the
following training requirements:
• Hotline training for the hotline operator
• IDDE training for employees who may encounter illicit discharges (continue)
• Spill response training for employees who handle polluting materials and/or respond to spill
response calls
• PPGH, pesticides/herbicides/fertilizer, and general stormwater awareness training for municipal
employees who handle polluting materials and perform vehicle/equipment maintenance and
cleaning
SCM inspections training for employees who conduct inspections
The above serves as a summary of major tasks/action items required by the NPDES permit. Please refer to
the attached Gap Analysis for a detailed list of each permit requirement.
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