HomeMy WebLinkAboutNCS000240_Corrected NOC_20221010ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
BRIAN WRENN NORTH CAROLINA
Director Environmental Quality
October 10, 2022
CERTIFIED MAIL 7022 0410 0002 1249 5407
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 13i11, 2022 through September 15th, 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 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
of the NPDES MS4 permit.
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
�i„eaepvourvn
o ma„vi p,.mry 828296.4500
Required documentation shall be submitted via e-mail to Isaiah. Reed ftcdenr 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
lsaiah.Reed(@ncdenr.gov.
Sincerely,
i
Isaiah Reed, PE, CPSWQ, MS4CECI
MS4 Program Coordinator
Enclosures: DEQ MS4 Permit Compliance Audit Report
CC:
Angela Charles angela charlesftcharlottenc.gov
Mike Davis mike.davisPcharlottenc.gov
Jordan Miller Jordan niiller0charlottenc.gov
Craig Miller craig.miller@@charlottenc.gov
DEMLR Stormwater Program Supervisor
DEMLR NPDES MS4 Permit Laserfiche File
D_E Q North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
Asheville Regional Office 12090 U.S. Highway 70 1 Swannanoa, North Carolina 28778
noa.0 cnaourvn
oan:,un.mmrreom.�ma�.nry 828.296.4800
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)
NCS000240 CharlotteMS4Audit 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 Storm water
Management Plan in accordance with the issued permit.
NCS000240 CharlotteMS4Audit 20220930 ii
This page intentionally left blank
NCS000240 Charlotte MS4 Audit 20220930 Hi
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
M Illicit Discharge Detection & Elimination
❑ Construction Site Runoff Controls — No delegated Sediment and Erosion Control Program
❑ Construction Site Runoff Controls — Delegated Sediment and Erosion Control Program
❑ Post -Construction Site Runoff Controls
❑ Pollution Prevention and Good Housekeeping for Municipal Operations
❑ Total Maximum Daily Loads (TMDLs)
Field Site Visits:
® Municipal Facilities. Number visited: 2
❑ MS4 Outfalls. Number visited: 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
Organization
Isaiah Reed, Environmental Engineer
NCDEQ
Audit Report Autho
Date:
Signature10
1-20�vZ
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 MS4lnspection/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 SWMPFY21
Prior
2
CLT Annual Rpt FY2021
Prior
4
SWPCOOrdinance
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
maintained written procedures for implementing the six minimumProcedures
------------
7,8,9,30,
jThetplermittee
ol measures.
ves
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 s
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
is
inspections
inspections.
II.D.2.d
The permittee conducted IDDE training for appropriate municipal staff.
ves
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
P g
illicit connections and discharges.
g
Yes
during the
mechanism
audit.
Website data examined during the audit. Publications also include TV, 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):
Mays, 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 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)?
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 MS4 Inspection (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