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Home My WebLink AboutNCS000240_NOC and Audit Report_20220930ROY COOPER Governor ELIZABETH S. BISER Secretary BRIAN WRENN Director NORTH CAROLINA Environmental Quality September 30, 2021 CERTIFIED MAIL 7021 2720 0000 1254 6025 RETURN RECEIPT REQUESTED City of Charlotte Attn: Steve Jadlocki, Water Quality Administrator 600 E. Fourth Street Charlotte, North Carolina 28202 Subject: NOTICE OF COMPLIANCE (NOC-2023-PC-0930) City of Charlotte NPDES MS4 Permit No. NCS000240 Mecklenburg County Dear Mr. Jadlocki: On September 13rh, 2022 through September 150h, 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. 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. As such, the permittee 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) Develop a Stormwater Management Plan (SWMP) which details specific actions, measurable goals, and implementation timelines for the stormwater management program over the new 5-year permit term. The SWMP must be documented utilizing the DEQ Phase 11 MS4 SWMP Template. The permittee shall submit the SWMP to DEQ for review and comment within one hundred twenty (120) calendar days from the date of receipt of this letter. (3) Submit an NPDES MS4 permit application for whichever comes first: a. At least one hundred eighty (180) days prior to permit expiration, or b. Within thirty (30) days of receiving written DEQ concurrence that the submitted SWMP documents a compliant stormwater management program and the MS4 should submit the application including a signed Final Draft SWMP. A new 5-year NPDES MS4 permit will be public noticed along with the Draft Final SWMP. (4) 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 D _E Q„ North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources ll�t//t Asheville Regional Office 1 2090 U.S. Highway 70 1 Swannanoa, North Carolina 28778 or :emGi opi u.wom.oww:np 828.296.4500 / 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 Isaiah.Reed(@ncdenr.gov or to: DEQ-DEMLR Stormwater Program Attn: Isaiah Reed 1612 Mail Service Center Raleigh, NC 27699-1612 Thank you for your attention to this matter. Should you have any questions, please contact me at 1 saiah. Reed (o) n cde n r. gov. i Sincerely, ,.—� � saiah Reed, PE, CPSW _' MS4CEC1 MS4 Program Coordinator Enclosures: DEQ MS4 Permit Compliance Audit Report CC: Angela Charles angela.charles@charlottenc.gov Mike Davis mike.davis@charlottenc.gov Jordan Miller Iordan.miller@charlottenc.gav Craig Miller craig.miller0charlottenc.gov DEMLR Stormwater Program Supervisor DEMLR NPDES MS4 Permit Laserfiche File ef D _E Q North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources Asheville Regional Office 1 2090 U.S. Highway 70 1 Swannanoa, North Carolina 28778 828.296.4500 MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) PROGRAM AUDIT REPORT NPDES PERMIT NO. NCS000240 CHARLOTTE, NORTH CAROLINA 600 East Fourth Street Charlotte, North Carolina 28202 Audit Date: September 13-15, 2022 Report Date: September 30, 2022 North Carolina Department of Environmental Quality Division of Energy, Mineral & Land Resources Stormwater Program 512 N. Salisbury Street, 9th floor 1612 Mail Service Center Raleigh, NC 27699-1612 (This page intentionally left blank) NC5000240 CharlotteM54Audit 20220930 TABLE OF CONTENTS AuditDetails..................................................................................................................................................1 PermitteeInformation..................................................................................................................................2 List of Supporting Documents.......................................................................................................................3 Program Implementation, Documentation & Assessment...........................................................................4 Illicit Discharge Detection and Elimination(IDDE)........................................................................................5 Site Visit Evaluation: Municipal Facility No. 1...............................................................................................6 Site Visit Evaluation: Municipal Facility No. 2...............................................................................................7 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. NCS000240 CharlotteMS4Audit 20220930 ii This page intentionally left blank NCS000240 Charlotte MS4 Audit 20220930 iii Audit Details Audit ID Number: Audit Date(s): NCS000240_Charlotte MS4 Audit_20220930 September 13, 14, and 15, 2022 Minimum Control Measures Evaluated: ® Program Implementation, Documentation & Assessment ❑ Public Education & Outreach ❑ Public Involvement & Participation ® Illicit Discharge Detection & Elimination ❑ Construction Site Runoff Controls — No delegated Sediment and Erosion Control Program ❑ Construction Site Runoff Controls— Delegated Sediment and Erosion Control Program ❑ Post -Construction Site Runoff Controls ❑ Pollution Prevention and Good Housekeeping for Municipal Operations ❑ Total Maximum Daily Loads (TMDLs) Field Site Visits: ® Municipal Facilities. Number visited: 2 ❑ MS4Outfalls. Number visited: Choose an item. ❑ Construction Sites. Number visited: Choose an item. ❑ Post -Construction Stormwater Runoff Controls. Number visited: Choose an item. ❑ Other: . Number visited: Choose an item. ❑ Other: . Number visited: Choose an item. Inspector(s) Conducting Audit Name, Title Organization Isaiah Reed, Environmental Engineer NCDEQ Audit Report Author: Date: Signature NCS000240_Charlotte MS4 Audit_20220930 Page 1 of 7 Permittee Information MS4 Permittee Name: City of Charlotte Permit Effective Date: October 10, 2018 Permit Expiration Date: October 9, 2023 Mailing Address: 600 E. 41h Street. Charlotte, NC 28202 Date of Last MS4 Inspection/Audit: May 22, 2017 Co-permittee(s), if applicable: N/A Permit Owner of Record: Paul Wiebke, Asst. Director of Public Works Steve Jadlocki, Water Quality Administrator Primary MS4 Representatives Participating in Audit Name, Title Organization Day 1 (9/13/2022) Robbey Zink, Regulatory Division Manager City of Charlotte Jordan Miller, SWQ Program Manager City of Charlotte Jay Wilson, EC Administrator City of Charlotte Gurveer Uppal, PLSO Administrator City of Charlotte Sharnelle Currence, WQ Educator City of Charlotte Rebecca Deal, L-TS Supervisor City of Charlotte Kruti Desai, Deputy Manager City of Charlotte Mike Davis, SW Director City of Charlotte Andrew Decristofaro, WQ Program Specialist City of Charlotte Craig Miller, MS4 Permit Supervisor City of Charlotte Jason Hunt, Watershed Planner City of Charlotte Steve Jadlocki, WQAdministrator City of Charlotte Joel Nipper, WQ Modeler City of Charlotte Day 2 (9/14/2022) Craig Miller, MS4 Permit Supervisor City of Charlotte Steve Jadlocki, WQAdministrator City of Charlotte Andrew Decristofaro, WQ Program Specialist City of Charlotte Jordan Miller, SWQ Program Manager City of Charlotte Catherine Crigler, City Stormwater Asset Inventory. City of Charlotte Hannah Meeler, County Stormwater Env. Sp. III Mecklenburg County John Thao, County Stormwater Env. Sp. III Mecklenburg County Ryan Spidel, County Env. Supervisor Mecklenburg County NCS000240_Charlotte MS4 Audit_20220930 Page 2 of 7 List of Supporting Documents Item Number Document Title When Provided (Prior to/During/After) 1 CLT SWMP FY21 Prior 2 CLT Annual Rpt FY2021 Prior 4 SWPCO Ordinance Prior 5 SWPCO Ordinance (Chapter 18) Prior 6 FY-2022 Staff Training for IDDE During 7 CLT WQ Monitoring SOP Prior 8 Industrial Facility SOP Prior 9 Municipal Facility Inspection SOP Prior 10 PCSO Private Projects SOP Prior 11 Public Education SOP Prior 12 Public Involvement SOP Prior 13 Outfall inspection Procedure Prior 14 CLT SWPCO ENF Guide 2021 Prior 15 CLT IDDE Manual 2.1 Prior NCS000240_Charlotte MS4 Audit_20220930 Page 3 of 7 Program Implementation, Documentation & Assessment Staff Interviewed: All in attendance Day 1 (Name, Title, Role) Permit Citation Program Requirement Status supporting Doc No. II.A.1 The Permittee Maintained adequate legal mechanisms to implement all provisions of Adequate Legal the of the Stormwater Management Plan. Yes q Mechanism The permittee is current on payment of invoiced administering and compliance monitoring fees (see stormwater e-payments on DEMLR MS4 web page). Yes BIMS II.A.2 Stormwater Plan The permittee evaluated the performance and effectiveness of the program Implementation components at least annually. Yes 2 and Evaluation II.A.3 Keeping the The permittee kept the Stormwater Plan up to date. Yes 1 Stormwater Plan Up to Date See The permittee notified DEMLR of any updates to the Stormwater Plan. Yes NCDEQ LF Did DEMLR require a modification to the Stormwater Plan? No II.A.4 Written The permittee maintained written procedures for implementing the six minimum 7,8,9,10, Procedures control measures. Yes 11,12, 14,15 IDDE written program effectively exists throughout a series of different documents. Locating the program in a single written program was discussed during the audit. NCS000240_Charlotte MS4 Audit_20220930 Page 4 of 7 Illicit Discharge Detection and Elimination (IDDE) Staff Interviewed: All in attendance Day 2 (Name, Title, Role) Permit Citation Program Requirement Status Supporting Doc No. II.D.2.a Maintain The permittee maintained appropriate legal Authorities. Yes 5 appropriate legal authorities Accidental discharge" language in the ordinance and potential caveats were discussed. II.D.2.b Maintain a Storm Software Sewer System The permittee maintained a map system including major outfalls. Partial demonstrate Base Map of d during the Major MS4 audit. Outfalls. Stormwater system map does not specifically identify major outfalls and industrial areas. II.D.2.c Maintain written The permittee maintained written procedures and SOPS for detecting and tracing procedures and/or Illicit discharges. yes 13, 14, 15 SOPS for IDDE. II.D.2.c The permittee maintained written procedures or SOPS for dry weather flow Dry weather flow Yes 15 inspections. inspections II.D.2.d The permittee conducted IDDE training for appropriate municipal staff. Yes 6 Employee Training Training conducted annually. II.D.2.e Website Maintain a public The permittee and publicized a reporting mechanism for the public to report examined reporting illicit connections and discharges. Yes during the mechanism audit. Website data examined during the audit. Publications also include N, Social Media, and handouts. II.D.2.f Investigation Documentation tracking The permittee documented dates of investigations Yes software was examined during the audit. Documentati The permittee documented enforcement actions Yes on examined during the audit. Cityworks tracking software and methods were discussed during the audit. NCS000240_Charlotte MS4 Audit_20220930 Page 5 of 7 Site Visit Evaluation: Municipal Facility No. 1 Facility Name: Central Yard Date and Time of Site Visit: September 15, 2022 Facility Address: 829 Louise Avenue Facility Type (Vehicle Maintenance, Landscaping, etc.): Public Works Name of MS4 inspector(s) evaluated: Juliana Holly, Environmental Specialist Most Recent MS4 Inspection (Date and Entity): May 5, 2022 Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit: Name Title Tim Lawrence, Facility/Shop Manager Manager 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? Annual stormwater training. (per General Permit) Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Annual stormwater training. 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)? Yes 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 M54 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)? Revision and evaluation of monitoring practices. Comments: "No discharge" was reported for outfalls observed discharging during the inspection. NCS000240_Charlotte MS4 Audit_20220930 Page 6 of 7 Site Visit Evaluation: Municipal Facility No. 2 Facility Name: Northwest CDOT Date and Time of Site Visit: September 15, 2022 Facility Address: 4411 Northpointe Industrial Blvd Facility Type (Vehicle Maintenance, Landscaping, etc.): CDOT Street Name of MS4 inspector(s) evaluated: Juliana Holly, Environmental Specialist Most Recent M54Inspection (List date and name of inspector): No evaluated Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit: Name Title Kelvin Miller Facility Manager 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? Annual Stormwater training. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Annual Stormwater training. 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)? Yes 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 Comments: SWPPP contents and monitoring documentation was discussed. NCS000240_Charlotte MS4 Audit_20220930 Page 7 of 7