HomeMy WebLinkAboutNCS000466_NOD_20231004 ROY COOPER 4yi
Governor t
ELIZABETH S.BISER
Secretary
WILLIAM E.TOBY VINSON,JR NORTH CAROLINA
Intenm Director Environmental Quality j
October 4,2023
CERTIFIED MAIL 9589 0710 5270 0731 7982 59
RETURN RECEIPT REQUESTED
Town of Hillsborough
Attn: Eric Peterson,Town Manager
101 E.Orange St.
Hillsborough,NC 27278
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Subject: NOTICE OF DEFICIENCY(NOD-2023-PC-0504)
Town of Hillsborough
NPDES MS4 Permit No. NCS600466
Orange County
Dear Mr. Peterson:
On August 30,2023,staff from the North Carolina Department of Environmental Quality(DEQ)conducted a
compliance audit of subject National Pollutant Discharge Elimination System(NPDES)Municipal Separate Storm
Sewer System(MS4)Permit. The audit identified minor deficiencies with the specific components of the MS4
permit that were reviewed,as provided in the attached DEQ MS4 Permit Compliance Audit Report. This report lists
and describes the deficiencies with certain components of the MS4 permit,which constitutes a violation of the Clean
Water Act and is grounds for enforcement action.
In accordance with Part VI of the permit and DEQ policy,a new 5-year MS4 permit will be issued in response to the
audit. 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 II 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 of the
NPDES MS4 permit and an Annual Self-Assessment Template that corresponds to the approved SWMP
will be provided.
North Carolina Department of Environmental Quality I Division of Energy.Mineral and Land Resources
512 North Salisbury Street 1 1612 Mail Service Center I Raleigh,North Carolina 2 76 9 9-1612
eroaTM�aouw.
•o•A^•^ r^�mmua�M 919.707.9200
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Notice of Deficiency i
Town of Hillsborough
October 4,2023
Page 2 of 2
Required documentation shall be submitted via e-mail to Isaiah.Reedgdeq.nc.eov,or to:
DEQ-DEMLR Stormwater Program
Attn: Isaiah Reed
1612 Mail Service Center
Raleigh,NC 27699-1612
If the MS4 fails to meet the aforementioned requirements and/or submits a significantly noncompliant Draft S WMP,
DEQ may proceed with enforcement. As is stated in Part V, Section A.1(c)of the permit:
Under state law, a daily civil penalty ofnot more than twenty-five thousand dollars($25,000)per violation
may be assessed against any person who violates or fails to act in accordance with the terms, conditions,
or requirements of a permit[North Carolina General Statute 143-215.6A]. Please note that compliance
with the requirements of this NOD and/or issuance of civil or criminal penalties levied by DEQ does not
preclude the EPA from carrying out its own enforcement case against the permittee.
Thank you for your attention to this matter. Should you have any questions,please contact Isaiah Reed at(828)
2964618 or Isaiah.reedAdeg.nc.¢ov.
Sincerely,
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Isaiah Reed,PE,CPS MS4CECI
MS4 Program Coordinator
North Carolina Department of Environmental Quality
Enclosures:
DEQ MS4 Program Audit Report(August 30,2023,Town of Hillsborough)
EC: Terry Hackett, Tenn.Hackett(iDhillsborouehne.Eov
Bill Denton,Regional Engineer,Bill.Denton@deq.nc.Qov
Isaiah Reed, MS4 Program,Isaiah.Reed(a deq.nc.eov
DEMLR NPDES MS4 Permit Laserfiche File
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MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM AUDIT REPORT
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NPDES PERMIT NO. NCS000466
HILLSBOROUGH, NORTH CAROLINA
101 E Orange Street
Audit Date: August 30, 2023
Report Date: September 25, 2023
North Carolina Department of Environmental Quality f
Division of Energy, Mineral & Land Resources Stormwater Program
512 N. Salisbury Street,9th floor
1612 Mail Service Center
Raleigh, NC 27699-1612
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NCS000466_Hillsbo rough MS4Audit_20230830 i
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TABLE OF CONTENTS
AuditDetails..................................................................................................................................................1
PermitteeInformation ..................................................................................................................................2
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Listof Supporting Documents.......................................................................................................................3
Program Implementation, Documentation &Assessment...........................................................................4
Public Education and Outreach.....................................................................................................................7
Public Involvement and Participation...........................................................................................................8
Illicit Discharge Detection and Elimination IDDE 9
Pollution Prevention and Good Housekeeping for Municipal Operations..................................................11
Site Visit Evaluation: Municipal Facility No. 1.............................................................................................13
Site Visit Evaluation: Municipal Facility No. 2.............................................................................................14
Site Visit Evaluation: MS4 Outfall No. 1......................................................................................................15
Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1............................................16
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.
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NCS000466_Hillsborough MS4 Audit_20230830 iii
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Audit Details
Audit ID Number: Audit Date(s): I,
NCS000466_Hillsborough MS4 Audit_20230830 August 30,2023
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 j
® Pollution Prevention and Good Housekeeping for Municipal Operations
❑ Total Maximum Daily Loads(TMDLs)
Field Site Visits:
® Municipal Facilities. Number visited:2
® MS4Outfalls. Number visited: I
❑ Construction Sites.Number visited:Choose an item.
® Post-Construction Stormwater Runoff Controls. Number visited: 1
❑ Other: Number visited:Choose an item.
❑ Other: . Number visited:Choose an item.
Inspector(s)Conducting Audit
Name.Title Organization
Isaiah Reed, MS4 Program Coordinator NCDEQ
Paul Clark,Water Supply Watershed NCDEQ
Audit Report Auth Date:
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Signature 16/L,/2a 2`3
NCS000466_Hillsborough MS4 Audit_20230830 Page 1 of 16
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Permittee Information
M54 Permittee Name: Permit Effective Date: Permit Expiration Date:
City of Hillsborough 2/20/2017 2/19/2022
Mailing Address: Date of Last MS4 Inspection/Audit:!
Post Office Box 429 Hillsborough None
Co-permittee(s),if applicable:
None
Permit Owner of Record:
Eric J. Peterson,Town Manager
Primary MS4 Representatives Participating in Audit
Name,Title Organization
Terry Hackett,Stormwater& Engineering
Town of Hillsborough
Services Manager
Heather Fisher,Stormwater Program
Town of Hillsborough
Coordinator
Matt Efird,Asst.Town Manager Town of Hillsborough
MS4 Receiving Waters
Waterbodv Classification Impairments
Eno River WS-V;NSW
Sevenmile Creek WS-II;HQW,NSW,CA
NCS000466_Hillsborough MS4 Audit_20230830 Page 2 of 16
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List of Supporting Documents
Item When Provided
Number Document Title
(Prior to/During/After)
1 2019 Draft SWMP
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2 Interlocal Agreement
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3 Agreement with CWEP
4 SOPs for Public Education and Public Involvement
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5 Green Infrastructure Quarterly Report
6 Public Education Handouts
7 Spreadsheet of Public Outreach data
8 Spreadsheet of Public Involvement data
9 Engage Hillsborough data spreadsheet
10 IDDE Written Program
11 IDDE Ordinance
12 Screenshot of infrastructure Map(showing attributes table)
13 IDDESOP
14 Inventory of Municipal Facilities
15 0&M Plan for pollution prevention and good housekeeping.
16 Municipally owned SCM inventory
17 Comprehensive O&M Plan for SCMs
18 Applicator License.
NC5000466_Hillsborough MS4 Audit_20230830 Page 3 of 16
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Program Implementation, Documentation &Assessment
Staff Interviewed: Terry Hackett,Stormwater&Engineering Services Manager
(Name,Title,Role) Heather Fisher,Stormwater Program Coordinator
Supporting
Permit Citation Program Requirement Status Doc No.
II.A.1 The permittee maintained adequate funding and staffing to implement and manage
Staffing and yes
the provisions of the Stormwater Plan and meet all requirements of the permit.
Funding
The Stormwater Plan identifies a specific position(s) responsible for the overall yes 1
coordination, implementation,and revision to the Plan.
Responsibilities for all components of the Stormwater Plan are documented and yes 1
position(s)assignments provided.
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The permittee is current on payment of invoiced administering and compliance yes BIMS
monitoring fees(see Stormwater e-payments on DEMLR MS4 web page).
No currently approved SWMP on file.Adding new staff soon.$75 a year Residential Unit.$I50-$12900 for
Industrial/Commercial.
II.A.2 Stormwater The permittee evaluated the performance and effectiveness of the program j
Plan yes CO Files
Implementation components at least annually.
and Evaluation If yes,the permittee used the results of the evaluation to modify the program Not
components as necessary to accomplish the intent of the Stormwater Program. Reviewed
Did the permitted MS4 discharges cause or contribute to non-attainment of an None
applicable water quality standard? No Known
If yes, did the permittee expand or better tailor its BMPs accordingly to address Not
the non-attainment? Applicable
No in-stream monitoring conducted.
II.A.3
Keeping the The permittee kept the Stormwater Plan up to date. Partial --- If
Stormwater Plan
Up to Date
The permittee notified DEMLR of any updates to the Stormwater Plan. No ---
SWMP updated but not submitted since 2019.
I I.A.4 Availability The permittee kept an up-to-date version of its Stormwater Plan available to the
of the Stormwater Division and the public online. yes Website
Plan
The online materials included ordinances,or other regulatory mechanisms, or a list
identifying the ordinances, or other regulatory mechanisms, providing the legal Yes Website
authority necessary to implement and enforce the requirements of the permit.
SWMP,Ordinance,Annual Reports.
Did DEMLR require a modification to the Stormwater Plan? No ---
NCS000466_H ills borough MS4 Audit_20230830 Page 4 of 16
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Program Implementation, Documentation & Assessment
II.A.3&II.A.S j
If yes,did the permittee complete the modifications in accordance with the Not
Stormwater Plan Applicable
Modifications
established deadline.
One SWMP submitted for approval in 2019.
II.A.6 Sharing
Responsibility Are any control measures implemented by an entity other than the permittee? Yes 2,3
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If yes, is there a written agreement in place? Yes 2,3
Orange County implements the Construction Site Stormwater program.Agreement with CWEP.
II.A.7
The permittee maintained written procedures for implementing the six minimum
Written control measures. partial
Procedures �
Written procedures identified specific action steps,schedules, resources and Not
responsibilities for implementing the six minimum measures. Reviewed
Written program maintained for IDDE. Other written program maintained as parts of SOPS and O&M Plans.
Ill A The permittee maintained documentation of all program components including,but
Program not limited to, inspections,maintenance activities,educational programs, Yes ---
Documentation implementation of BMPs,enforcement actions etc.,on file for a period of five years.
111.13 The permittee submitted annual reports to the Department within twelve months
Annual Report from the effective date of the permit(See Section 11LB.for the annual reporting Yes ---
Submittal period specific to this MS4).
The permittee submitted subsequent annual reports every twelve months from the Not
scheduled date of the first annual report submittal. Reviewed
The Annual Reports included appropriate information to accurately describe the progress,status,and results
of the permittee's Stormwater Plan,including, but not limited the following:
1. A detailed description of the status of implementation of the Stormwater Plan
as a whole.This will include information on development and implementation Not
of each major component of the Stormwater Plan for the past year and Reviewed
schedules and plans for the year following each report.
2. An adequate description and justification of any proposed changes to the
Stormwater Plan.This will include descriptions and supporting information for Not
the proposed changes and how these changes will impact the Stormwater Reviewed
Plan (results, effectiveness,implementation schedule,etc.).
3. Documentation of any necessary changes to programs or practices for
assessment of management measures implemented through the Stormwater Not
Reviewed
Plan.
4. A summary of data accumulated as part of the Stormwater Plan throughout
the year along with an assessment of what the data indicates in light of the Not
Reviewed
Stormwater Plan.
5. An assessment of compliance with the permit, information on the
establishment of appropriate legal authorities, inspections,and enforcement Not
Reviewed
actions.
NCS000466_Hillsborough Ms4Audit_20230830 Page 5 of 16
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Program Implementation, Documentation & Assessment
III
IV.B
Annual Reporting The Annual Reports document the following:
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1. A summary of past year activities, including where applicable,specific Not
quantities achieved and summaries of enforcement actions. Reviewed
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2. A description of the effectiveness of each program component. Not --
Reviewed
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3. Planned activities and changes for the next reporting period,for each Not
program component or activity. Reviewed
4. Fiscal analysis. Not
Reviewed
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Public Education and Outreach
Staff Interviewed: Terry Hackett,Stormwater& Engineering Services Manager
(Name,Title,Role) Heather Fisher,Stormwater Program Coordinator ,
Permit Citation Program Requirement Status supporting
Doc No.
II.B.2.a
The permittee defined goals and objectives of the Local Public Education and
Goals and Yes 1
Objectives Outreach Program based on community wide issues.
SWMP not approved,but outlines goals.
II.B.2.b The permittee maintained.a description of the target pollutants and/or stressors and _
No _
Target Pollutants likely sources.
Social Media is used for target pollutant outreach,but program is not outlined.
II.B2.c The permittee identified,assessed annually and updated the description of the target partial 5
Target Audiences audiences likely to have significant storm water impacts and why they were selected.
Surveys conducted after"Green Infrastructure"event.
11.6.2.d Residential The permittee described issues,such as pollutants,the likely sources of those
and Industrial/ pollutants,potential impacts,and the physical attributes of Stormwater runoff in Partial 5
Commercial Issues their education/outreach program.
11.B.2.e
The permittee promoted and maintained an internet web site designed to convey the
Informational Yes Website
program's message.
Web Site
Hillsboroughnc.gov
II.B.2.f
Public Education The permittee distributed stormwater educational material to appropriate target yes 6
Materials groups.
Handouts brochures/flyers at social events.Billing inserts(occasionally).No regularly scheduled billing inserts.Magnets and
rulers handed out at events.
II.B.2.g The permittee promoted and maintained a stormwater hotline/he Ipline for the
Hotline/Help Line purpose of public education and outreach. Yes Website
11.B.2.h The permittee's outreach program, including those elements implemented locally or
Public Education through a cooperative agreement, included a combination of approaches designed to Yes 7
and Outreach reach the target audiences.
Program
For each media, event or activity,including those elements implemented locally or
through a cooperative agreement the permittee estimated and recorded the extent Yes 7
of exposure.
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Public Involvement and Participation
Staff Interviewed: Terry Hackett,Stormwater&Engineering Services Manager
(Name,Title,Role) Heather Fisher,Stormwater Program Coordinator
Permit Citation Program Requirement Status supporting
Doc No.
II.C.2.a Volunteer
Community The permittee included and promoted volunteer opportunities designed to promote
Involvement ongoing citizen participation. Yes 8
Program
Creek Week,Garden club bioretention(participation not tracked). Litter Pickup(as requested),adopt an SCM,Invasive Species
removal.
II.C.2.b
Mechanism for The permittee provided and promoted a mechanism for public involvement that
Partial --
Public provides for input on stormwater issues and the stormwater program.
Involvement
No formal advisory committee.Engage Hillsborough(planned to be quarterly).No regularly scheduled meetings.
II.C2.c The permittee promoted and maintained a hotline/helpline forthe purpose of public Yes Website
Hotline/Help Line involvement and participation.
Contact information exists on the website.It is recommended that a hotline be provided far the specifically stated purpose in
each MCM.
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Illicit Discharge Detection and Elimination (IDDE)
Staff Interviewed: Terry Hackett,Stormwater&Engineering Services Manager
(Name,Title, Heather Fisher,Stormwater Program Coordinator
Role)
Supporting
Permit Citation Program Requirement Status Doc No
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II.D.2.a
IDDE Program The permittee maintained a written IDDE Program. Yes 10
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If yes,the written program includes provisions for program assessment and Not
evaluation and integrating program. Reviewed
The permittee maintained an IDDE ordinance or other regulatory mechanism(s)that
Yes 11
II.D.2.b provides the legal authority to prohibit illicit connections and discharges to the MS4.
Legal Authorities If yes,the ordinance applies throughout the corporate limits of the permittee.
Yes 11
[Permit Part I.D]
IDDE applied in ETJ.
II.D.2.c i
The permittee maintained a current map showing major outfalls and receiving yes 12
Storm Sewer
System Map streams.
Map not fully connected.Attributes not complete.
II.D.2.d The permittee maintained a program for conducting dry weather flow field
Dry Weather Flow Partial 13
Program
observations in accordance with written procedures.
5%of outfalls inspected a year.Inspection reports need to cover more information.
II.D.2.e
The permittee maintained written procedures for conducting investigations of
Investigation res 10
Procedures identified illicit discharges.
II.D.2.f For each case of an illicit discharge or potential illicit discharge,the permittee documented and tracked the
Track and following:
Document
Investigations 1. The date(s)the illicit discharge was observed Yes ---
2. The results of the investigation Yes ---
3. Any follow-up of the investigation Yes ---
4. The date the investigation was closed Yes ---
II.D.2.¢Employee The permittee implemented and documented a training program for appropriate
Training municipal staff who,as part of their normal job responsibilities, may come into No ---
contact with or otherwise observe an illicit discharge or illicit connection.
Not been successful implementing training program for Police Dep.
II.D.2.h The permittee informed public employees of hazards associated with illegal
Public Education Partial ---
discharges and improper disposal of waste.
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Illicit Discharge Detection and Elimination (IDDE)
The permittee informed businesses of hazards associated with illegal discharges and
improper disposal of waste. Partial i
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The permittee informed the general public of hazards associated with illegal Partial
discharges and improper disposal of waste.
II.D.2.i The permittee promoted,publicized,and facilitated a reporting mechanism for the I
Public Reporting Yes Website
public to report illicit discharges.
Mechanism
The permittee promoted, publicized,and facilitated a reporting mechanism for staff
Yes ---
to report illicit discharges.
The permittee established and implemented response procedures for citizen Yes 13
requests/reports.
II.D.2.1 The permittee implemented a mechanism to track the issuance of notices of violation Not Enforcement and enforcement actions administered by the permittee. Applicable ___
If yes,the mechanism includes the ability to identify chronic violators for Not
initiation of actions to reduce noncompliance. Applicable
NCS000466_Hillsborough Ms4Audit_20230830 Page 10 of 16 '
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Pollution Prevention and Good Housekeeping for Municipal Operations
Staff Interviewed: Terry Hackett,Stormwater& Engineering Services Manager
(Name,Title, Role) Heather Fisher,Stormwater Program Coordinator ',
Permit Citation Program Requirement Status supposing
Doc No.
II.G.2.a The permittee maintained a current inventory of facilities and operations owned
Facility Inventory and operated by the permittee with the potential for generating polluted Yes 14 i
stormwater runoff.
II.G.2.b The permittee maintained and implemented an 0&M program for municipally
Operation and owned and operated facilities with the potential for generating polluted Yes SWPPP
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Maintenance(O&M) stormwater runoff.
for Facilities
If yes,the 0&M program specifies the frequency of inspections. Yes 15
If yes,the O&M program specifies the frequency of routine maintenance
Yes
requirements. �
If yes,the permittee evaluated the 0&M program annually and updated it as
Yes ---
necessary.
Facilities are inspected annually.
II.G.2.c
Spill Response The permittee had written spill response procedures for municipal operations. Yes ---
Procedures
SPRP maintained in the SWPPP on site.
II.G.2.d Streets, The permittee evaluated existing and new BMPs that reduce polluted stormwater
Roads,and Public runoff from municipally-owned streets,roads,and public parking lots within its Yes Annual
Parking Lots corporate limits annually. Report
Maintenance If yes,the permittee evaluated the effectiveness of existing and new BMPs Annual
based on cost and the estimated quantity of pollutants removed. Yes Report
Evaluation documented in the Annual report.
II.G.2.f
O&M for Catch The permittee maintained and implemented an O&M program for the stormwater
Basins and sewer system including catch basins and conveyance systems that it owns and Yes is
Conveyance Systems maintains.
II.G.2.e The permittee maintained a current inventory of municipally-owned or operated
Structural structural stormwater controls installed for compliance with the permittee's post- Yes 17
Stormwater Controls construction ordinance.
NCS000466_Hillsborough MS4 Audit_20230830 Page 11 of 16
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Pollution Prevention and Good Housekeeping for Municipal Operations
II.G.2.h The permittee maintained and implemented an C&M program for municipally-
O&M for Structural owned or maintained structural stormwater controls installed for compliance with Yes ---
Stormwater Controls the permittee's post-construction ordinance. If yes,then:
The 0&M program specified the frequency of inspections and routine Not
maintenance requirements. Reviewed ---
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The permittee documented inspections of all municipally-owned or maintained Not
structural stormwater controls. Reviewed
The permittee inspected all municipally-owned or maintained structural Not
stormwater controls in accordance with the schedule developed by permittee. Reviewed
The permittee maintained all municipally-owned or maintained structural Not
stormwater controls in accordance with the schedule developed by permittee. Reviewed
The permittee documented maintenance of all municipally-owned or Not
maintained structural stormwater controls. Reviewed
II.G.2.i The permittee ensured municipal employees are properly trained in pesticide,
Pesticide,Herbicide Yes 18
herbicide and fertilizer application management.
and Fertilizer
Application The permittee ensured contractors are properly trained in pesticide, herbicide and
Management Yes 18
fertilizer application management.
The permittee ensured all permits,certifications,and other measures for
No ---
applicators are followed.
II.G.2.j The permittee implemented an employee training program for employees involved
Staff Training Partial ---
in implementing pollution prevention and good housekeeping practices.
One in-person training this permit cycle.No regularly scheduled training.
II.G.2.k The permittee described and implemented measures that prevent or minimize
Vehicle and contamination of stormwater runoff from all areas used for vehicle and equipment Yes is
Equipment Cleaning cleaning.
NCS000466_Hillsborough MS4 Audit_20230830 Page 12 of 16
Site Visit Evaluation: Municipal Facility No. 1
Facility Name: Date and Time of Site Visit:
Hillsborough Wastewater Treatment Plant August 31, 2023
Facility Address: Facility Type(Vehicle Maintenance,Landscaping,etc.):
355 Elizabeth Brady Road WWTP
Name of MS4 inspector(s)evaluated: Most Recent MS4 Inspection(List date and name of inspector):
Heather Fisher Not reviewed
Name(s)and Title(s)of Facility Representative(s)Present During the Site Visit:
Name Title
Jeff Mahagan Utilities Director
Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan(SWPPP)or similar document?Is it facility-specific?
Not requested during inspection.
What type of stormwater training do facility employees receive?How often?
No regular training documented.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive?How often?
No regular training documented.
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
Yes.
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Yes.
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form?
Yes.
Does the MS4 inspector's process include taking photos?
Yes.
Does the MS4 inspector's process include reviewing the facility's SWPPP(or similar document)?
No.
Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge?
Yes.
Did the MS4 inspector miss any obvious areas of concern?If so,explain:
No.
Does the MS4 inspector's process include presenting the inspection findings to the facility contact?
Yes.
Inspection Results
Did the facility inspection result in any corrective actions to be implemented?If so,for what issue(s)?
Yes.See comments below.
If compliance corrective actions were identified,what timeline for correction/follow-up was provided?
To be determined by the permittee.
Notes/Comments/Recommendations
Items discussed during the inspection include:Secondary containment for Caustic storage, removal/relocation of aeriation
equipment not currently in use, and barrels from prior process stored on site still containing product.
NCS000466_Hillsborough MS4 Audit_20230830 Page 13 of 16
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Site Visit Evaluation: Municipal Facility No. 2
Facility Name: Date and Time of Site Visit:
Public Works Facility August 31,2023
Facility Address: Facility Type(Vehicle Maintenance,Landscaping,etc.):
719 Dimmocks Mill Road Public Works
Name of MS4 inspector(s)evaluated: Most Recent MS4 Inspection(Date and Entity):
Heather Fisher Not reviewed
Name(s)and Title(s)of Facility Representative(s)Present During the Site Visit:
Name Title
Dustin Hill Public Works Manager
Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP)or similar document?Is it facility-specific?
No.
What type of stormwater training do facility employees receive?How often?
No regular training documented.
Inspector Training/Knowledge
What type of stormwater training does the M54 inspector receive? How often?
No regular training documented.
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
Yes.
Did the M54 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)?
N/A
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.
If compliance corrective actions were identified,what timeline for correction/follow-up was provided?
N/A
Notes/Comments/Reco m m end ations
Items discussed during the inspection include: Proper storage of herbicides and proper inspection of fuel storage.
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Site Visit Evaluation: MS4 Outfall No. 1
Outfall ID Number: Date of Site Visit:
666 August 31,2023
Outfall Location: Outfall Description(Pipe Material/Diameter,Culvert,etc.):
Margaret Lane RCP j
Receiving Water: Is Flow Present?If So, Describe(Color,Approximate Flow Rate,
Unnamed tributary of Eno River Sheen,Odor,Floatables/Debris,etc.):
Most Recent Outfall Inspection/Screening(Date):
Not reviewed Yes."Trickle".
Days Since Last Rainfall: Inches:
Not reviewed N/A
Name of MS4lnspector(s)evaluated:
Heather Fisher
Observations
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
Annual SW Training.
Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations?
Yes. i
Inspection Procedures
Does the inspector's process include the use of a checklist or other standardized form? I
Yes.
Does the inspector's process include taking photos?
Yes.
Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues?If so,what were they?
No.
Inspection Results
Did the outfall inspection result in any work orders or maintenance requests?If so,for what issue(s)?
No.
Will a follow-up outfall inspection be conducted?If so,for what reason?
Yes.Routine.
NCS000466_Hillsborough M54 Audit_20230830 Page 15 of 16
I
Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1
Site Name: Date of Site Visit:
Forest Ridge SCM August 31, 2023
Site Address: SCM Type:
Fiori Hill Drive Wet Pond
Most Recent MS4 Inspection(Include Date and Entity):
Not reviewed
Name of M541nspector(s)evaluated: Most Recent MS4 Enforcement Activity(Include Date):
Heather Fisher None
Name(s)and Title(s)of Site Representative(s)Present During the Site Visit:
Name Title i
None.
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?
Not Reviewed.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive?How often?
Annual SW Training.
Did the MS4 inspector appear knowledgeable about M54 requirements for post-construction site runoff controls? j
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.
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?
As Needed.
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?
Not determined on site.
If compliance issues were identified,what timeline for correction/follow-up was provided?
To be determined by MS4 staff.
NCS000466_HiIIsborough MS4 Audit_20230830 Page 16 of 16