The URL can be used to link to this page

Home My WebLink AboutNCS000426_Hickory EPA Audit Report_20181213 CITY OF HICKORY, NC MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) PROGRAM INSPECTION REPORT HICKORY, NORTH CAROLINA 76 North Center Street Hickory, NC 28601 Inspection Date: December 12, 2018 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 U.S. Environmental Protection Agency, Region IV Sam Nunn Atlanta Federal Center 61 Forsyth Street SW Atlanta, GA 30303‐8963 MS4 Inspection Report Hickory, NC: NPDES Permit No. NCS000426 Inspection Date: December 12, 2018 i (This page intentionally left blank) MS4 Inspection Report Hickory, NC: NPDES Permit No. NCS000426 Inspection Date: December 12, 2018 ii TABLE OF CONTENTS Inspection Details .......................................................................................................................................... 1 Permittee Information .................................................................................................................................. 2 Supporting Documents ................................................................................................................................. 2 Program Implementation, Documentation, & Assessment .......................................................................... 3 Illicit Discharge Detection and Elimination (IDDE) ........................................................................................ 7 Post‐Construction Site Runoff Controls Program Implementation Status .... Error! Bookmark not defined. Post‐Construction Site Runoff Controls ...................................................................................................... 10 Pollution Prevention and Good Housekeeping for Municipal Operations ................................................. 14 Site Visit Evaluation: MS4 Outfall No. 1 ...................................................................................................... 17 Site Visit Evaluation: MS4 Outfall No. 2 ...................................................................................................... 19 Site Visit Evaluation: Municipal Facility No. 1 ............................................................................................. 25 Site Visit Evaluation: Municipal Facility No. 2 ............................................................................................. 28 Appendix A: Supporting Documents Appendix B: Photograph Log This inspection consisted of an evaluation of program compliance with the issued permit and implementation of the approved Stormwater Management Plan. This inspection report does not include a review of all program components. There may be additional program deficiencies in addition to those noted. 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. MS4 Inspection Report Hickory, NC: NPDES Permit No. NCS000426 Inspection Date: December 12, 2018 iii This page intentionally left blank MS4 Inspection Report Hickory, NC: NPDES Permit No. NCS000426 Inspection Date: December 12, 2018 Page 1 of 30 Inspection Details Inspection ID Number: SW‐NCS000426‐12/12/2018 Inspection Date(s): December 12, 2018 Minimum Control Measures Evaluated: ☒Program Implementation ☐Public Education & Outreach ☐Public Involvement and Participation ☒Illicit Discharge Detection & Elimination ☐Construction Site Runoff Controls ☒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: 2 ☐Construction Sites. Number visited: 0 ☒ Post‐Construction Stormwater Runoff Controls. Number visited: 2 ☐ Other: ________________________________. Number visited: 0 ☐ Other: ________________________________. Number visited: 0 Inspector(s) Conducting Inspection Name, Title Organization Sean Ireland, Stormwater Enforcement Workgroup Lead EPA Region 4 Jake Albright, EPA Contractor PG Environmental Collin Mummert, EPA Contractor PG Environmental Jeanette Powell, MS4 Program Coordinator North Carolina Dept of Environmental Quality (NCDEQ), Division of Energy, Mineral, and Land Resources (DEMLR) Alaina Morman, Environmental Specialist NCDEQ, DEMLR Brandon Wise, Environmental Specialist NCDEQ, DEMLR Chris Graybeal Environmental Specialist NCDEQ, DEMLR James Moore, Environmental Specialist NCDEQ, DEMLR Lily Kay, Environmental Specialist NCDEQ, DEMLR Seth Titley, Environmental Specialist NCDEQ, DEMLR Thad Valentine, Environmental Specialist NCDEQ, DEMLR Inspection Report Author: Jake Albright Signature__________________________________________ Date: March 12, 2019 Inspection Report Author: Collin Mummert Signature__________________________________________ Date: March 12, 2019 MS4 Inspection Report Hickory, NC: NPDES Permit No. NCS000426 Inspection Date: December 12, 2018 Page 2 of 30 Permittee Information MS4 Permittee Name: City of Hickory, NC (hereinafter, the City) NPDES Permit Number: NCS000426 (hereinafter, the Permit) MS4 Permittee Address: 76 North Center Street, Hickory, NC 28601 Date of Last MS4 Inspection/Audit: N/A Co‐permittee(s), if applicable: N/A Primary MS4 Representatives Participating in Inspection Name, Title Organization Kyle Butler City of Hickory, Engineering Kelly Winkler City of Hickory, Engineering Rick Patton City of Hickory, Engineering Eric Geitner City of Hickory, Engineering Kevin Greer City of Hickory, Public Services Drew Foy City of Hickory, Public Services Keith Rhyne City of Hickory, Northeast Wastewater Treatment Plant MS4 Receiving Waters Waterbody Impairments Horseford Creek, 11‐54‐(0.5) and 11‐54‐(3) 303(d) (IR=5): Ecological/Biological Integrity Benthos Falling Creek, 11‐60 303(d) (IR=5): Ecological/Biological Integrity Benthos Clark Creek (Shooks Lake), 11‐129‐5‐(0.3)b 303(d) (IR=5): Ecological/Biological Integrity Benthos Note: This list only includes waterbodies with 303(d) impairments that receive discharges from the permitted MS4. Note that NC DEQ’s 2016 303(d) list was used for reference, as the 2018 list was still in draft version. Supporting Documents Number Document Title Provided Prior to/During/After Inspection: 1 City of Hickory Stormwater Organizational Chart Prior to Inspection 2 2018 Stormwater Management Program Assessment Prior to Inspection 3 City of Hickory Phase II Stormwater Ordinance Prior to Inspection 4 City of Hickory Phase II Administrative Manual Prior to Inspection 5 City of Hickory Stormwater Plan Review Checklist Prior to Inspection 6 City of Hickory Municipal Properties Inventory During Inspection Note: Refer to Appendix A: Supporting Documents for copies of the above documents. These supporting documents do not represent all MS4 program documentation provided to the inspection team by City representatives. EPA Region 4 maintains all documentation provided to the inspection team by City representatives. Additionally, the photographs contained in Appendix B: Photograph Log and referenced throughout this report do not represent all photographs taken by the inspection team during the inspection. EPA Region 4 maintains all photographs taken by the inspection team. Region 4. MS4 Inspection Report Hickory, NC: NPDES Permit No. NCS000426 Inspection Date: December 12, 2018 Page 3 of 30 Program Implementation, Documentation, & Assessment Permit Citation Program Requirement Status Supporting Doc No. II.A.1 Staffing and Funding The permittee maintained adequate funding and staffing to implement and manage the provisions of the Stormwater Plan and meet all requirements of the permit. Partial ‐‐ The Stormwater Plan identifies a specific position(s) responsible for the overall coordination, implementation, and revision to the Plan. No 1 Responsibilities for all components of the Stormwater Plan are documented and position(s) assignments provided. No 1 The permittee is current on payment of invoiced administering and compliance monitoring fees. Yes ‐‐ Comments The City had not developed or implemented a written Stormwater Plan and was not meeting all of the requirements of the Permit. The City’s 2018 stormwater budget was approximately $270,000, which covered 1.5 full‐time equivalent (FTE) staff, seasonal leaf collection, and a limited number of storm drain repairs. The City provided an organizational chart identifying positions associated with the MS4 program. City representatives noted that the City’s previous MS4 Program Administrator departed unexpectedly at the end of 2017. A lot of the historical information pertaining to the program has been difficult to locate, and in some cases, needed to be recreated or was lost. II.A.2 Stormwater Plan Implementation and Evaluation The permittee evaluated the performance and effectiveness of the program components at least annually. Partial 2 If yes, the permittee used the results of the evaluation to modify the program components as necessary to accomplish the intent of the Stormwater Program. No ‐‐ Did the permitted MS4 discharges cause or contribute to non‐attainment of an applicable water quality standards? ‐‐ ‐‐ If yes, did the permittee expand or better tailor its BMPs accordingly? ‐‐ ‐‐ Comments The City provided a stormwater program assessment for 2018; however, City representatives stated it was the first one submitted “in a while.” The inspection team did not assess non‐attainment or evaluate for any water quality standards. II.A.3 Keeping the Stormwater Plan Up to Date The permittee kept the Stormwater Plan up to date. No ‐‐ The permittee notified DEMLR of any updates to the Stormwater Plan. n/a ‐‐ Comments (indicate the date of latest Stormwater Plan and describe the nature of any updates, if applicable). The City had not developed a written Stormwater Plan. MS4 Inspection Report Hickory, NC: NPDES Permit No. NCS000426 Inspection Date: December 12, 2018 Page 4 of 30 Program Implementation, Documentation, & Assessment Permit Citation Program Requirement Status Supporting Doc No. II.A.4 Availability of the Stormwater Plan The permittee kept an up‐to‐date version of its Stormwater Plan available to the Division and the public online. No ‐‐ The online materials included ordinances, or other regulatory mechanisms, or a list identifying the ordinances, or other regulatory mechanisms, providing the legal authority necessary to implement and enforce the requirements of the permit. Yes 3, 4 Comments The City had not developed a written Stormwater Plan. However, the City’s website included links to the City’s Phase II Stormwater Ordinance and an associated Phase II Administrative Manual (see II.D.2.b Legal Authorities below). II.A.5 Stormwater Plan Modifications Did DEMLR require a modification to the Stormwater Plan? n/a ‐‐ If yes, did the permittee complete the modifications in accordance with the established deadline? n/a ‐‐ Comments The City had not developed a written Stormwater Plan. II.A.6 Sharing Responsibility Are any control measures implemented by an entity other than the permittee? Yes ‐‐ If yes, is there a written agreement in place? Yes ‐‐ Comments The City maintains agreements with the Western Piedmont Council of Governments (COG) for public education and outreach on stormwater impacts. The City also contracts with the COG for geographic information system (GIS) support and maintenance of the City’s infrastructure map. II.A.7 Written Procedures The permittee maintained written procedures for implementing the six minimum control measures. No ‐‐ Written procedures identified specific action steps, schedules, resources and responsibilities for implementing the six minimum measures. No ‐‐ Comments The City had not developed a Stormwater Plan or other written procedures for implementing the six minimum control measures. III. A Program Documentation The permittee maintained documentation of all program components including, but not limited to, inspections, maintenance activities, educational programs, implementation of BMPs, enforcement actions, etc., on file for a period of five years. No ‐‐ Comments The City lacked documentation relating to their stormwater program (e.g., limited documentation of inspections, no illicit discharge detection and elimination forms, no training records). Due to the staff turnover (referenced in II.A.1 above), the City’s Stormwater Administrators are in the process of recompiling and inventorying stormwater program records prior to 2017. The City documents maintenance activities through its VC3 complaint software system and a separate work order system. MS4 Inspection Report Hickory, NC: NPDES Permit No. NCS000426 Inspection Date: December 12, 2018 Page 5 of 30 Program Implementation, Documentation, & Assessment Permit Citation Program Requirement Status Supporting Doc No. III.B Annual Report Submittal The permittee submitted annual reports to the Department within twelve months from the effective date of the permit. Yes 2 The permittee submitted subsequent annual reports every twelve months from the scheduled date of the first submittal. n/a ‐‐ The Annual Reports included appropriate information to accurately describe the progress, status, and results of the permittee’s Stormwater Plan, including, but not limited to 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 of each major component of the Stormwater Plan for the past year and schedules and plans for the year following each report. Partial 2 2. An adequate description and justification of any proposed changes to the Stormwater Plan. This will include descriptions and supporting information for the proposed changes and how these changes will impact the Stormwater Plan (results, effectiveness, implementation schedule, etc.). Partial 2 3. Documentation of any necessary changes to programs or practices for assessment of management measures implemented through the Stormwater Plan. Partial 2 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 Stormwater Plan. Partial 2 5. An assessment of compliance with the permit, information on the establishment of appropriate legal authorities, inspections, and enforcement actions. Yes 2 6. A summary of past year activities, including where applicable, specific quantities achieved and summaries of enforcement actions. Yes 2 7. A description of the effectiveness of each program component. No 2 8. Planned activities and changes for the next reporting period, for each program component or activity. Yes 2 9. Fiscal analysis. Yes 2 MS4 Inspection Report Hickory, NC: NPDES Permit No. NCS000426 Inspection Date: December 12, 2018 Page 6 of 30 Program Implementation, Documentation, & Assessment Permit Citation Program Requirement Status Supporting Doc No. Comments The City provided the 2018 MS4 annual report (2018 report) to the inspection team prior to the inspection. The 2018 report provides an assessment of the MS4 program; however, the City has not developed a Stormwater Plan to compare against the annual report. The 2018 report was the first annual report required under the current Permit (issued in February 2017). NC DEQ representatives indicated during the inspection that there were no records of annual reports submitted by the City over the last several years. City representatives indicated that the most recent annual reports in the City’s file prior to 2018 were from 2009 and 2010. The 2018 report includes brief descriptions of the six minimum control measures and identifies the main focus for improving the City’s stormwater program as developing a Stormwater Management Program Plan (SWMP or Stormwater Plan) once a new state template is released in 2019. The 2018 report does not include any explanations on the effectiveness of the City’s stormwater program. The 2018 report cites a total annual budget of $270,274, which the City indicated was spent on staffing, leaf collection, and storm drain repairs. MS4 Inspection Report Hickory, NC: NPDES Permit No. NCS000426 Inspection Date: December 12, 2018 Page 7 of 30 Illicit Discharge Detection and Elimination (IDDE) Permit Citation Program Requirement Status Supporting Doc No. II.D.2.a IDDE Program The permittee maintained a written IDDE Program. No ‐‐ If yes, the written program includes provisions for program assessment and evaluation. n/a ‐‐ Comments The City had not developed written procedures for implementing an IDDE Program. II.D.2.b Legal Authorities The permittee maintained an IDDE ordinance or other regulatory mechanism(s) that provides the legal authority to prohibit illicit connections and discharges to the MS4. Yes 3 If yes, the ordinance applies throughout the corporate limits of the permittee. [Permit Part I.D] Yes 3 Comments The City’s Phase II Stormwater Ordinance, which was developed in accordance with a state‐provided template, was provided prior to the inspection and is available through the City’s website. The ordinance provides the legal authority for the City to prohibit illicit connections and discharges to the MS4 and declares illicit discharges and illicit connections to be public nuisances. II.D.2.c Storm Sewer System Map The permittee maintained a current map showing major outfalls and receiving streams. Partial ‐‐ Comments The City has an agreement with the COG to maintain the City’s GIS‐based infrastructure map. The infrastructure map identifies receiving streams, outfalls, conveyances, and other aspects of the City’s MS4 infrastructure. The infrastructure is organized in map layers and are equipped with querying functionality. The map also includes a description of condition for some MS4 assets. The City’s infrastructure map also included assets, such as pipes, that were not owned by the City (e.g., privately‐owned); however, the inspection team had concerns that the GIS did not include information that clearly indicated which entity owned which assets. The City reported having 1,361 outfalls within corporate limits in the 2018 report; however, the City has not developed a specific inventory noting which ones would be classified as major outfalls. The map includes all pipe ends, but is missing ditches and ditch discharge points. II.D.2.d Dry Weather Flow Program The permittee maintained a program for conducting dry weather flow field observations in accordance with written procedures. No ‐‐ Comments The City does not conduct dry weather screening or maintain written procedures for dry weather screening activities. II.D.2.e Investigation Procedures The permittee maintained written procedures for conducting investigations of identified illicit discharges. No ‐‐ Comments City representatives stated that they conduct illicit discharge investigations on a reactive basis through complaints entered into the VC3 system. The City has not developed written procedures for illicit discharge investigations. MS4 Inspection Report Hickory, NC: NPDES Permit No. NCS000426 Inspection Date: December 12, 2018 Page 8 of 30 Illicit Discharge Detection and Elimination (IDDE) Permit Citation Program Requirement Status Supporting Doc No. II.D.2.f Track and Document Investigations For each case of an illicit discharge or potential illicit discharge, the permittee documented and tracked the following: 1. The date(s) the illicit discharge was observed No ‐‐ 2. The results of the investigation No ‐‐ 3. Any follow‐up of the investigation No ‐‐ 4. The date the investigation was closed No ‐‐ Comments City representatives indicated that information regarding complaints and work orders specific to illicit discharge investigations may be available within the VC3 system, but the ability to query that information would depend on the quality of the data inputs. The VC3 system includes a dropdown menu for categorizing a complaint; however, there is no specific category for stormwater or illicit discharges. City representatives explained that the number of illicit discharge instances reported in the 2018 MS4 annual report is only reflective of the number of illegal dumping reports. City representatives were able to generate a printout of “sewer spills” (i.e., sanitary sewer overflows); however, the City was unable to verify that all of the spills impacted stormwater or made it to a receiving water. II.D.2.g Employee Training The permittee implemented and documented a training program for appropriate municipal staff who, as part of their normal job responsibilities, may come into contact with or otherwise observe an illicit discharge or illicit connection. No ‐‐ Comments The City does not implement a training program for municipal staff on IDDE or other stormwater‐related topics other than training conducted at facilities covered under NCDEQ Industrial Stormwater General Permits (see the Site Visit Evaluation for Municipal Facility No. 2 below). II.D.2.h Public Education The permittee informed public employees of hazards associated with illegal discharges and improper disposal of waste. No ‐‐ The permittee informed businesses of hazards associated with illegal discharges and improper disposal of waste. No ‐‐ The permittee informed the general public of hazards associated with illegal discharges and improper disposal of waste. No ‐‐ Comments City representatives explained that the City’s approach to eliminating illicit discharges was primarily reactive and dependent on complaints. The City does not routinely educate employees, businesses, or the public on illicit discharges, but the City does issue press releases for sanitary sewer overflow events that reach surface waters. MS4 Inspection Report Hickory, NC: NPDES Permit No. NCS000426 Inspection Date: December 12, 2018 Page 9 of 30 Illicit Discharge Detection and Elimination (IDDE) Permit Citation Program Requirement Status Supporting Doc No. II.D.2.i Public Reporting Mechanism The permittee promoted, publicized, and facilitated a reporting mechanism for the public to report illicit discharges. Yes ‐‐ The permittee promoted, publicized, and facilitated a reporting mechanism for staff to report illicit discharges. Yes ‐‐ The permittee established and implemented citizen request response procedures. Yes ‐‐ Comments The City tracks all public complaints in the City’s VC3 system, which routes the complaint to the applicable City department based on the categorization (filled out by the individual making the complaint). City employees that witness issues report the issues to dispatch. Dispatch then files the complaint in the VC3 system. Once a complaint is received, the applicable City department has 24 hours to respond. If a team of municipal employees is assigned for remediation, the City uses hardcopy work orders to track the status of work performed. A work order needs to be accomplished and closed out prior to the City closing the complaint in the VC3 system. City representatives indicated that hardcopy work orders would only be generated if a public works team was dispatched to remediate an issue. II.D.2.j Enforcement The permittee implemented a mechanism to track the issuance of notices of violation and enforcement actions administered by the permittee. No ‐‐ If yes, the mechanism includes the ability to identify chronic violators for initiation of actions to reduce noncompliance. No ‐‐ Comments The City does not implement a mechanism for tracking enforcement actions, as the City has never taken any stormwater‐related enforcement actions. The City’s stormwater ordinance provides the legal authority to institute penalties, fines, and withholding of a certificate of occupancy. Section 5.3 of the City’s Phase II Stormwater Ordinance describes an enforcement response plan for stormwater violations; however, the ordinance does not define the enforcement escalation process for repeat offenders or significant illicit discharges. MS4 Inspection Report Hickory, NC: NPDES Permit No. NCS000426 Inspection Date: December 12, 2018 Page 10 of 30 Post‐Construction Site Runoff Controls Permit Citation Program Requirement Status Supporting Doc No. II.F.2.a Legal Authority The permittee maintained an ordinance or other regulatory mechanism designed to meet the objectives of the Post‐Construction Site Runoff Controls Stormwater Management Program. Yes 3, 4 If yes, the ordinance applies throughout the corporate limits of the permittee. [Permit Part I.D] Yes 3 The permittee has the authority to review designs and proposals for new development and redevelopment to determine whether adequate stormwater control measures will be installed, implemented, and maintained. Yes 3, 4 The permittee has the authority to request information such as stormwater plans, inspection reports, monitoring results, and other information deemed necessary to evaluate compliance with the Post‐Construction Stormwater Management Program. Yes 3, 4 The permittee has the authority to enter private property for the purpose of inspecting at reasonable times any facilities, equipment, practices, or operations related to stormwater discharges. Yes 3 ,4 Comments The City’s Phase II Stormwater Ordinance and Administrative Manual authorizes the City to review plans, request information, and enter private property to conduct inspections of post‐construction stormwater control measures (SCMs). The City developed their Phase II Stormwater Ordinance and Administrative Manual in accordance with NCDEQ, DEMLR templates. II.F.2.c Plan Reviews The permittee conducted site plan reviews of all new development and redeveloped sites that disturb greater than or equal to one acre (including sites that disturb less than one acre that are part of a larger common plan of development or sale). Yes 5 If yes, the site plan reviews addressed how the project applicant meets the performance standards. Yes 5 If yes, the site plan reviews addressed how the project will ensure long‐term maintenance. Yes 5 Comments The Engineering Department is responsible for reviewing site plans for adherence to post‐construction stormwater control design and performance standards. The City provided a Stormwater Plan Review Checklist prior to the inspection. City representatives said they often participate in pre‐application meetings with developers, which includes discussions on stormwater management system concept plans. The stormwater permit application submittals checklist included in the City’s Phase II Administrative Manual includes requirements for developers to submit design drawings, as‐builts, and operation and maintenance (O&M) manuals prior to the City issuing a certificate of occupancy. MS4 Inspection Report Hickory, NC: NPDES Permit No. NCS000426 Inspection Date: December 12, 2018 Page 11 of 30 Post‐Construction Site Runoff Controls Permit Citation Program Requirement Status Supporting Doc No. II.F.2.d Inventory of Projects The permittee maintained an inventory of projects with post‐construction structural stormwater control measures installed and implemented at new development and redeveloped sites. Partial ‐‐ The inventory included both public and private sector sites located within the permittee’s corporate limits that are covered by its post‐construction ordinance requirements. Partial ‐‐ Comments The City is currently using historical plans and the county’s Intergov plan review database to develop an inventory of all public and private projects with or requiring post‐construction SCMs. At the time of the inspection, the City had developed an inventory spreadsheet for all construction projects dating back to 2015. The City also maintained a separate inventory of post‐construction SCMs constructed prior to 2010. The City’s Stormwater Administrators indicated that their goal was to develop a complete inventory dating back to 2007 (when the Phase II Stormwater Ordinance was adopted) and map all post‐construction SCMs built for projects with greater than 1 acre of land disturbance. The City’s current inventory appropriately includes all current construction projects requiring post‐construction SCMs. II.F.2.e Deed Restrictions and Protective Covenants The permittee provided mechanisms such as recorded deed restrictions and protective covenants that ensure development activities will maintain the project consistent with approved plans. Partial 3 Comments Sections 3.2(C) and 3.3(F) of the City’s Phase II Stormwater Ordinance require an enforceable restriction on property usage that conveys with the property, such as recorded deed restrictions or protective covenants, prior to the approval of a stormwater permit, to ensure that future development and redevelopment on both high‐density and low‐density projects maintains the site consistent with approved project plans. City representatives stated that SCMs are bonded during the construction process as a means to ensure proper installation. City representatives stated that they have the ability to collect maintenance bonds, but the City has not done that. The City plans to implement long‐term maintenance bonds on future projects. II.F.2.f Mechanism to Require Long‐ term Operation and Maintenance The permittee implemented or required an operation and maintenance plan for the long‐term operation of the SCMs required by the program. Partial 3, 4 The operation and maintenance plan required the owner of each SCM to perform and maintain a record of annual inspections of each SCM. Yes 3, 4 Annual inspection of permitted structural SCMs are required to be performed by a qualified professional. Yes 3, 4 Comments The City’s Phase II Stormwater Ordinance provides a mechanism for the City to require long‐term maintenance agreements and annual inspections from SCM owners. Additionally, as defined in Section 5.1 of the Phase II Administrative Manual, developers are required to submit a SCM O&M manual to the City prior to the City issuing a stormwater permit or certificate of occupancy. The City is able to issue continuous long‐term maintenance bonds. The City has not historically used them, but the City plans to use them going forward. The City has retained a limited number of submitted inspection reports; however, without an inventory of all post‐construction SCMs within corporate limits, it is currently impossible for the City to determine how many are not submitting reports. Further, the City is not implementing the necessary oversight and enforcement to ensure reports are submitted when required. MS4 Inspection Report Hickory, NC: NPDES Permit No. NCS000426 Inspection Date: December 12, 2018 Page 12 of 30 Post‐Construction Site Runoff Controls Permit Citation Program Requirement Status Supporting Doc No. II.F.2.g Inspections The permittee conducted and documented inspections of each project site covered under performance standards, at least one time during the permit term. No ‐‐ Before issuing a certificate of occupancy or temporary certificate of occupancy, the permittee conducted a post‐construction inspection to verify that the permittee’s performance standards have been met or a bond is in place to guarantee completion. No ‐‐ The permittee documented and maintained records of inspection findings. No ‐‐ The permittee documented and maintained records of enforcement actions. n/a ‐‐ Comments The City does document SCM inspections. At the time of the inspection, the City was still developing an inventory of all post‐ construction SCMs within corporate limits and could not determine whether the City had conducted inspections of each project site covered under performance standards. At the time of the inspection, the City had not taken any enforcement actions against post‐ construction SCM owners. II.F.2.h Educational Materials and Training for Developers The permittee made available through paper or electronic means, ordinances, post‐ construction requirements, design standards checklists, and other materials appropriate for developers. Note: New materials may be developed by the permittee, or the permittee may use materials adopted from other programs and adapted to the permittee’s new development and redevelopment program. Yes 4 Comments (If the permittee has adopted materials from other programs, indicate here which materials they are using) Section 3.1 of the City’s Phase II Administrative Manual includes a link to the NC DEQ Stormwater Best Practice (BMP) Manual (Design Manual) and describes that the latest edition of the Design Manual shall be used for the design of any SCMs that are part of the project design submittal. Additionally, as described in Section 5.1 of the Phase II Administrative Manual, the City has standard forms for SCM owners to submit prior to issuance of a stormwater permit and certificate of occupancy. These forms are available in the City’s Engineering Department and on the City’s website. II.F.2.i Enforcement The permittee tracked the issuance of notices of violation and enforcement actions. No ‐‐ If yes, the tracking mechanism included the ability to identify chronic violators for initiation of actions to reduce noncompliance. n/a ‐‐ Comments The City had not taken enforcement actions against owners of post‐construction SCMs and did not have a mechanism for tracking such enforcement actions. MS4 Inspection Report Hickory, NC: NPDES Permit No. NCS000426 Inspection Date: December 12, 2018 Page 13 of 30 Post‐Construction Site Runoff Controls Permit Citation Program Requirement Status Supporting Doc No. II.F.3.d Nutrient Sensitive Waters Pursuant to 15A NCAC 02H .0150, for areas draining to Nutrient Sensitive Waters, the permittee used SCMs that reduce nutrient loading in order to meet local program requirements n/a ‐‐ If yes, the permittee also still incorporated the stormwater controls required for the project's density level. n/a ‐‐ Documentation shall be provided where it is not feasible to use stormwater control measures (SCMs) that reduce nutrient loading. In areas where the Department has approved a Nutrient Sensitive Water Urban Stormwater Management Program, the provisions of that program fulfill the nutrient loading reduction requirement. n/a ‐‐ Comments City representatives indicated that there are no areas within the City’s corporate limits that drain to Nutrient Sensitive Waters. II.F.3.e Design Volume The permittee ensured that the design volumes of SCMs take into account the runoff at build out from all surfaces draining to the system. Yes ‐‐ Where “streets” convey stormwater, the permittee designed SCMs to be sized to treat and control stormwater runoff from all surfaces draining to the SCM including streets, driveways, and other impervious surfaces. Yes ‐‐ Comments The City’s Phase II Stormwater Ordinance and Phase II Administrative Manual follow the Design Manual, which requires the design volume of SCMs to consider the runoff at build out from all surfaces draining to the system. City representatives stated that they evaluate design volume and impervious area served by SCMs during the plan review process. MS4 Inspection Report Hickory, NC: NPDES Permit No. NCS000426 Inspection Date: December 12, 2018 Page 14 of 30 Pollution Prevention and Good Housekeeping for Municipal Operations Permit Citation Program Requirement Status Supporting Doc No. II.G.2.a Facility Inventory The permittee maintained a current inventory of facilities and operations owned and operated by the permittee with the potential for generating polluted stormwater runoff. Partial 6 Comments The City maintains a list of all municipal facilities within corporate limits as part of the GIS‐based map. The map identifies all City‐ owned properties (approximately 400), including five City‐owned facilities covered under Industrial Stormwater General Permits. The City has not identified potential sources of stormwater pollution at municipal sites other than those covered under Industrial Stormwater General Permits. The City provided the inspection team with a list of all municipal facilities during the inspection. II.G.2.b Operation and Maintenance (O&M) for Facilities The permittee maintained and implemented an O&M program for municipally owned and operated facilities with the potential for generating polluted stormwater runoff. No ‐‐ If yes, the O&M program specifies the frequency of inspections. n/a ‐‐ If yes, the O&M program specifies the frequency of routine maintenance requirements. n/a ‐‐ If yes, the permittee evaluated the O&M program annually and updated it as necessary. n/a ‐‐ Comments The City had not developed a written O&M program for municipal facilities. The City has also not inspected any municipal facilities. The City representatives indicated that all inspections and maintenance activities are reactive, driven by complaints, and are not documented. II.G.2.c Spill Response Procedures The permittee had written spill response procedures for municipal operations. No ‐‐ Comments The City had not developed written spill response procedures as part of the MS4 program. City representatives stated that facility‐ specific plans were included in the SWPPP’s developed for facilities covered under an Industrial Stormwater General Permit. II.G.2.d Streets, Roads, and Public Parking Lots Maintenance The permittee evaluated, based on cost and the estimated quantity of pollutants removed, existing and new BMPs annually that reduce polluted stormwater runoff from municipally‐owned streets, roads, and public parking lots within its corporate limits. Yes ‐‐ Comments The City employs three street sweeping crews that run five days a week. The City’s street sweepers track miles swept through GIS. The City calculates quantity of debris/pollutants removed through disposal load tickets. MS4 Inspection Report Hickory, NC: NPDES Permit No. NCS000426 Inspection Date: December 12, 2018 Page 15 of 30 Pollution Prevention and Good Housekeeping for Municipal Operations Permit Citation Program Requirement Status Supporting Doc No. II.G.2.e O&M for Catch Basins and Conveyance Systems The permittee maintained and implemented an O&M program for the stormwater sewer system including catch basins and conveyance systems that it owns and maintains. No ‐‐ Comments The City does not maintain and implement an O&M program for the storm sewer system. The City’s inspections and maintenance activities are primarily triggered by complaints. The City conducts inspections of catch basins in areas susceptible to flooding following storm events, which are documented through work orders. II.G.2.f Structural Stormwater Controls The permittee maintained a current inventory of municipally‐owned or operated structural stormwater controls installed for compliance with the permittee’s post‐ construction ordinance. No ‐‐ Comments City representatives indicated that if a City‐owned SCM incorporates an outfall, that outfall should be included on the City’s map. However, the SCMs themselves are not mapped. The City is working on developing an inventory of all construction projects completed within corporate limits that included or will include post‐construction SCMs prior to mapping these elements. II.G.2.g O&M for Structural Stormwater Controls The permittee maintained and implemented an O&M program for municipally‐owned or maintained structural stormwater controls installed for compliance with the permittee’s post‐construction ordinance. No ‐‐ The O&M program specified the frequency of inspections and routine maintenance requirements. No ‐‐ The permittee documented inspections of all municipally‐owned or maintained structural stormwater controls. No ‐‐ The permittee inspected all municipally‐owned or maintained structural stormwater controls in accordance with the schedule developed by permittee. No ‐‐ The permittee documented maintenance of all municipally‐owned or maintained structural stormwater controls. No ‐‐ The permittee maintained all municipally‐owned or maintained structural stormwater controls in accordance with the schedule developed by permittee. No ‐‐ Comments The City does not conduct routine maintenance on City‐owned SCMs, other than occasional landscaping; maintenance practices are not typically tied to the specific requirements of a particular practice. The City has not documented any inspections or long‐term maintenance activities conducted. MS4 Inspection Report Hickory, NC: NPDES Permit No. NCS000426 Inspection Date: December 12, 2018 Page 16 of 30 Pollution Prevention and Good Housekeeping for Municipal Operations Permit Citation Program Requirement Status Supporting Doc No. II.G.2.h Pesticide, Herbicide and Fertilizer Application Management The permittee ensured municipal employees are properly trained. Yes ‐‐ The permittee ensured contractors are properly trained. n/a ‐‐ The permittee ensured all permits, certifications, and other measures for applicators are followed. Yes ‐‐ Comments City representatives stated that pesticides were applied only by City employees with applicator licenses. The City does not employ private contractors for pesticide application. II.G.2.i Staff Training The permittee implemented an employee training program for employees involved in implementing pollution prevention and good housekeeping practices. No ‐‐ Comments The City has not implemented an employee training program for all employees involved with implementing pollution prevention and good housekeeping practices. II.G.2.j Vehicle and Equipment Cleaning The permittee described and implemented measures that prevent or minimize contamination of stormwater runoff from all areas used for vehicle and equipment cleaning. Partial ‐‐ Comments City representatives indicated that vehicle washing at the Public Works Facility is either conducted in the large indoor truck wash or at the outdoor wash pad, which drains to a detention pond BMP (spray down only; see the Site Visit Evaluation for Municipal Facility No. 2 below). City representatives also stated that fire department vehicles are washed at Fire Station No. 5. During the site visit to Fire Station No. 5, staff indicated that they occasionally wash vehicles outdoors using a pressure washer (see the Site Visit Evaluation for Municipal Facility No. 1 below). MS4 Inspection Report Hickory, NC: NPDES Permit No. NCS000426 Inspection Date: December 12, 2018 Page 17 of 30 Site Visit Evaluation: MS4 Outfall No. 1 Outfall ID Number: N/A Date and Time of Site Visit: 12/12/2018, 1:16 PM Outfall Location: 632 4th Street NW Hickory, NC 28601 Outfall Description (Pipe Material/Diameter, Culvert, etc.): 24” (estimate) corrugated metal pipe Receiving Water: Tributary of Cripple Creek Is Flow Present? If So, Describe (Color, Approximate Flow Rate, Sheen, Odor, Floatables/Debris, etc.): None Most Recent Outfall Inspection/Screening (Date): None. Refer to II.D.2.d above Days Since Last Rainfall: 2 (snow/rain event on 12/10/2018; snow still present on ground) Inches: 0.42 Name of MS4 Inspector(s): Kyle Butler, Kelly Winkler, and Eric Geitner were identified as the City representatives who would be conducting MS4 inspections. The City did not conduct a formal outfall inspection in conjunction with this site visit. See the notes below for more detail. Observations Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? City staff responsible for implementing the MS4 program had not received formal IDDE training. The City did not conduct a formal outfall inspection in conjunction with this site visit. See the notes below for more detail. Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations? City staff present during the site visit had general stormwater knowledge, but none had formal IDDE training. Inspection Procedures Does the inspector’s process include the use of a checklist or other standardized form? Obtain copy. No – the City had not developed or implemented an outfall inspection checklist/form. Does the inspector’s process include taking photos? No – the City did not have a dry weather screening program (refer to II.D.2.d above). Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they? N/A – the City did not conduct a formal outfall inspection in conjunction with this site visit. See the notes below for more detail. Inspection Results Did the outfall inspection result in any work orders or maintenance requests? If so, for what issue(s)? No – the purpose of the site visit was to investigate an apparent potential illicit discharge (noticeable odor observed) identified in the City’s GIS as occurring when the outfall was originally mapped between 2009 and 2010. No discharge was observed during the site visit. The City was unable to provide any historical work orders or maintenance requests to show that the City followed up on the problem. Will a follow‐up outfall inspection be conducted? If so, for what reason? Unknown – City representatives did not indicate if the outfall would be formally inspected at a later date. The City does not currently implement a dry weather screening program (refer to II.D.2.d above). MS4 Inspection Report Hickory, NC: NPDES Permit No. NCS000426 Inspection Date: December 12, 2018 Page 18 of 30 Site Visit Evaluation: MS4 Outfall No. 1 Notes/Comments/Recommendations At the time of the inspection, the City did not have a dry weather screening program (refer to II.D.2.d above). This site visit was conducted to demonstrate to City representatives how to conduct a dry weather outfall inspection and to assess the condition of the outfall(s). The outfall was a 24‐inch (estimated) corrugated metal pipe located along the west bank of a tributary to Cripple Creek (refer to Appendix B, Photographs 1 and 2). The outfall appeared to be in good condition at the time of the site visit. The drainage area encompassed a portion of Oakwood Cemetery directly west of the outfall, with an upgradient drainage ditch and catch basin collecting the majority of stormwater runoff (refer to Appendix B, Photograph 3). The inspection team also identified a sanitary sewer line running parallel to Cripple Creek adjacent to the MS4 outfall (refer to Appendix B, Photograph 4), which may be the source of the noticed odor at the outfall in the City’s illicit discharge classification from 2009 to 2010. There was no odor present at the time of the site visit. MS4 Inspection Report Hickory, NC: NPDES Permit No. NCS000426 Inspection Date: December 12, 2018 Page 19 of 30 Site Visit Evaluation: MS4 Outfall No. 2 Outfall ID Number: N/A Date and Time of Site Visit: 12/12/2018, 1:46 PM Outfall Location: 701 1st Street NW Hickory, NC 28601 Outfall Description (Pipe Material/Diameter, Culvert, etc.): 6” (estimate) metal pipe with broken PVC elbow attachment Receiving Water: Cripple Creek Is Flow Present? If So, Describe (Color, Approximate Flow Rate, Sheen, Odor, Floatables/Debris, etc.): Occasional flow was noticed coming from the outfall. The water was clear with no sheen, odor, or debris. Most Recent Outfall Inspection/Screening (Date): None. Refer to II.D.2.d above Days Since Last Rainfall: 2 (snow/rain event on 12/10/2018; snow still present on ground) Inches: 0.42 Name of MS4 Inspector(s): Kyle Butler, Kelly Winkler, and Eric Geitner were identified as the City representatives who would be conducting MS4 inspections. The City did not conduct a formal outfall inspection in conjunction with this site visit. See the notes below for more detail. Observations Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? City staff responsible for implementing the MS4 program had not received formal IDDE training. The City did not conduct a formal outfall inspection in conjunction with this site visit. See the notes below for more detail. Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations? City staff present during the site visit had general stormwater knowledge, but none had formal IDDE training. Inspection Procedures Does the inspector’s process include the use of a checklist or other standardized form? Obtain copy. No – the City did not have a dry weather screening program (refer to II.D.2.d above) and had not developed or implemented an outfall inspection checklist/form. Does the inspector’s process include taking photos? No – the City did not have a dry weather screening program (refer to II.D.2.d above). Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they? N/A – the City did not conduct a formal outfall inspection in conjunction with this site visit. See the notes below for more detail. Inspection Results Did the outfall inspection result in any work orders or maintenance requests? If so, for what issue(s)? No – the purpose of the site visit was to investigate an apparent potential illicit discharge (observed flow) identified in the City’s GIS as occurring when the outfall was originally mapped between 2009 and 2010. The inspection team observed occasional flow from the outfall; however, the inspection team identified the flow was from a sump pump from underneath the adjacent YMCA building (see the notes below for more detail). MS4 Inspection Report Hickory, NC: NPDES Permit No. NCS000426 Inspection Date: December 12, 2018 Page 20 of 30 Site Visit Evaluation: MS4 Outfall No. 2 Will a follow‐up outfall inspection be conducted? If so, for what reason? Unknown – City representatives did not indicate if the outfall would be formally inspected at a later date. The City does not currently implement a dry weather screening program (refer to II.D.2.d above). Notes/Comments/Recommendations At the time of the inspection, the City did not have a dry weather screening program (refer to II.D.2.d above). This site visit was conducted to demonstrate to City representatives how to conduct a dry weather outfall inspection and to assess the condition of the outfall(s). The outfall was a 6‐inch (estimated) metal pipe with a broken PVC elbow. The pipe identified as the outfall was located along the south bank of Cripple Creek just upstream of the bridge walkway (refer to Appendix B, Photograph 5). There were multiple outfalls upstream and downstream of the identified outfall along both the north and south banks of Cripple Creek (refer to Appendix B, Photograph 6). During the site visit, the inspection team observed periodic flow from the outfall (refer to Appendix B, Photograph 7). After speaking with maintenance personnel on‐site at the YMCA adjacent to the outfall, the inspection team determined that the outfall is connected to a sump pump in the boiler room of the YMCA building. Groundwater collects in the French drain surrounding the YMCA property and is pumped to Cripple Creek through the outfall. The inspection team concluded that this was the likely explanation for the noticed flow that led to the illicit discharge complaint between 2009 and 2010; however, the City did not have any follow up documentation after the original observation. MS4 Inspection Report Hickory, NC: NPDES Permit No. NCS000426 Inspection Date: December 12, 2018 Page 21 of 30 Site Visit Evaluation: Post‐Construction Stormwater Control Measure No. 1 Site Name: Bioretention Facility at 256 10th Avenue NE Date and Time of Site Visit: 12/12/2018, 2:11 PM Site Address: 256 10th Avenue NE Hickory, NC 28601 SCM Type: Bioretention Most Recent MS4 Inspection (Include Date and Entity): None (see II.F.2.g above) Name of MS4 inspector(s): Kyle Butler, City of Hickory Kelly Winkler, City of Hickory Eric Geitner, City of Hickory Most Recent MS4 Enforcement Activity (Include Date): None (see II.F.2.i above) Name(s) and Title(s) of Site Representative(s) Present During the Site Visit: Name Title N/A N/A Observations Site Documentation Does the site have an operation and maintenance plan? The MS4 inspectors did not have an O&M plan available for the site visit. The MS4 inspectors did not contact a facility representative to inquire about an O&M plan. Does the site have records of annual inspections? Are they performed by a qualified individual? The City did not have any records of previous inspections (see II.F.2.g above). Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? The MS4 inspectors do not participate in routine training, but had participated in a SCM training in recent weeks, prior to the EPA inspection. Did the MS4 inspector appear knowledgeable about MS4 requirements for post‐construction site runoff controls? The MS4 inspectors showed a general knowledge of the MS4 requirements for post‐construction and stated that they refer to NC DEQ’s SCM manual for guidelines and best practices. However, all requirements of the Permit were not being implemented (e.g., performing routine oversight inspections, enforcing annual inspections for SCM owners). Did the MS4 inspector appear knowledgeable about post‐construction BMPs (general purpose/function, components, O&M requirements, etc.)? The MS4 inspectors were familiar with the general purpose, function, and components of the SCM; however, the MS4 inspectors did not review the SCM design specifications, O&M plans, or as‐builts during the inspection. The MS4 inspectors do not formally document oversight activities, such as inspections. Inspection Procedures Does the MS4 inspector’s process include the use of a checklist or other standardized form? What format? No. Does the MS4 inspector’s process include taking photos? No. Does the MS4 inspector’s process include reviewing the site’s operation and maintenance plan and records of annual inspections? No. The site did not have an O&M plan available for review during the inspection. The City also did not have any records of annual inspections for this SCM. Additionally, the MS4 inspectors did not use the SCM design specification or as‐builts to conduct the inspection. MS4 Inspection Report Hickory, NC: NPDES Permit No. NCS000426 Inspection Date: December 12, 2018 Page 22 of 30 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? Partial. In this case, the drainage area to the SCM was limited and easily accessible. There is one outfall from the SCM, which discharges to the City’s MS4. The MS4 inspectors did not observe the nearest receiving water. Did the MS4 inspector miss any obvious operation and maintenance deficiencies? If so, explain: It was unclear to the inspection team whether there were operational deficiencies with the SCM since the City did not have the design specifications and as‐builts available for review. The inspection team noted potential deficiencies (see the notes below for more detail); however, the MS4 inspectors did not document the potential deficiencies identified by the inspection team with an inspection report and/or photographs to ensure follow‐up with the facility owner. Does the MS4 inspector’s process include presenting the inspection findings to the site contact in writing? No. A facility contact was not present during the site visit. The MS4 inspectors did not document any observations to provide to a facility contact at a later time. Compliance/Enforcement What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in? None. The MS4 inspectors did not document any observed areas of concern for further communication with the facility owner. If compliance issues were identified, what timeline for correction/follow‐up was provided? None. The MS4 inspectors did not document any observed areas of concern for further communication with the facility owner. Notes/Comments/Recommendations The SCM is a bioretention facility located on the south side of an office building at 256 10th Avenue NE, north of 9th Avenue Drive NE (refer to Appendix B, Photograph 8). A 24‐inch (estimated) plastic pipe was placed within the SCM at the east end, which the MS4 inspectors described as a “level spreader” (refer to Appendix B, Photograph 9). The level spreader diverted stormwater influent between the north and south sections of the SCM (refer to Appendix B, Photograph 10). The outfall structure at the west end of the SCM discharged into the City’s MS4 (refer to Appendix B, Photograph 11). The inspection team noted the following potential maintenance needs. Because City representatives were unable to provide design specifications, O&M requirements, or as‐builts for the SCM, the inspection team was unable to verify that these observations definitively constituted maintenance needs. While the MS4 inspectors generally agreed with these observations, they did not document them with photographs and/or an inspection report: 1. It was unclear whether the level spreader (refer to Appendix B, Photograph 9) at the east end of the SCM was part of the initial design specifications. Recommendation to MS4 inspectors: review the SCM design specifications to determine if the level spreader should have been installed. 2. Based on signs of preferential flow through the SCM (refer to Appendix B, Photograph 12), it was evident that the level spreader was not evenly discharging water across the bioretention basin. This suggests that large areas of the basin no longer evenly infiltrate stormwater as it was likely designed. Recommendation to MS4 inspectors: review the SCM design specifications to ensure the level spreader is installed and operating according to the original design. 3. The vegetation in the SCM was mature (the SCM was approximately 15 years old) and had potentially surpassed the useful life for effectiveness (refer to Appendix B, Photograph 12). Recommendation to MS4 inspectors: review the SCM design specifications to ensure the vegetation is appropriate and effective. If the vegetation’s useful life has been exceeded, the vegetation needs to be replaced. 4. The cover to the outfall structure was supported by four bricks, one at each of the four corners (refer to Appendix B, Photograph 11). It is unlikely the SCM was designed and approved in this fashion. Recommendation to MS4 inspectors: review the SCM design specifications to confirm the outlet structure is installed according to the original design and ensure required maintenance is completed. MS4 Inspection Report Hickory, NC: NPDES Permit No. NCS000426 Inspection Date: December 12, 2018 Page 23 of 30 Site Visit Evaluation: Post‐Construction Stormwater Control Measure No. 2 Site Name: Stanford Park Detention Pond Date and Time of Site Visit: 12/12/2018, 2:35 PM Site Address: 1094 13th Avenue NE Hickory, NC 28601 SCM Type: Detention Pond Most Recent MS4 Inspection (Include Date and Entity): None (see II.F.2.g above) Name of MS4 inspector(s): Kyle Butler, City of Hickory Kelly Winkler, City of Hickory Eric Geitner, City of Hickory Most Recent MS4 Enforcement Activity (Include Date): None (see II.F.2.i above) Name(s) and Title(s) of Site Representative(s) Present During the Site Visit: Name Title N/A N/A Observations Site Documentation Does the site have an operation and maintenance plan? The MS4 inspectors did not have an O&M plan available for this site visit. The MS4 inspectors did not contact the facility representative to inquire about an O&M plan. Does the site have records of annual inspections? Are they performed by a qualified individual? The City does not have any records of previous inspections (see II.F.2.g above). Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? The MS4 inspectors do not participate in routine training, but had participated in a SCM training in recent weeks, prior to the EPA inspection. Did the MS4 inspector appear knowledgeable about MS4 requirements for post‐construction site runoff controls? The MS4 inspectors showed a general knowledge of the MS4 requirements for post‐construction and stated that they refer to NC DEQ’s SCM manual for guidelines and best practices. However, all requirements of the Permit were not being implemented (e.g., performing routine oversight inspections, enforcing annual inspections for SCM owners). Did the MS4 inspector appear knowledgeable about post‐construction BMPs (general purpose/function, components, O&M requirements, etc.)? The MS4 inspectors were familiar with the general purpose, function, and components of the SCM; however, the MS4 inspectors did not review the SCM design specifications, O&M plans, or as‐builts during the inspection. The MS4 inspectors do not formally document oversight activities, such as inspections. Inspection Procedures Does the MS4 inspector’s process include the use of a checklist or other standardized form? What format? No. Does the MS4 inspector’s process include taking photos? No. MS4 Inspection Report Hickory, NC: NPDES Permit No. NCS000426 Inspection Date: December 12, 2018 Page 24 of 30 Site Visit Evaluation: Post‐Construction Stormwater Control Measure No. 2 Does the MS4 inspector’s process include reviewing the site’s operation and maintenance plan and records of annual inspections? No. The MS4 inspectors did not have an O&M plan available for review during the inspection. The City did not have any records of annual inspections. Additionally, the MS4 inspectors did not use SCM design specification or as‐builts while conducting the inspection. Does the MS4 inspector’s process include walking the entire site and inspecting all points of discharge? No. The MS4 inspectors did not inspect the point of discharge to receiving waters. Did the MS4 inspector miss any obvious operation and maintenance deficiencies? If so, explain: It was unclear to the inspection team whether there were operational deficiencies with the SCM, since the City did not have the design specifications and as‐builts available for review. The inspection team identified potential deficiencies (see the notes below for more detail); however, the MS4 inspectors did not document the potential deficiencies identified by the inspection team with an inspection report and/or photographs to ensure follow‐up with the facility owner. Does the MS4 inspector’s process include presenting the inspection findings to the site contact in writing? No. A facility contact was not present during the inspection. The MS4 inspectors also did not document any observations to provide to a facility contact at a later time. Compliance/Enforcement What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in? None. The MS4 inspectors did not document any observed areas of concern for further communication with the facility owner. If compliance issues were identified, what timeline for correction/follow‐up was provided? None. The MS4 inspectors did not document any observed areas of concern for further communication with the facility owner. Notes/Comments/Recommendations The SCM is a detention pond located at the northern‐most portion of Stanford Park (refer to Appendix B, Photograph 13). City representatives indicated that the drainage area for the SCM consists of the northern parking lot areas, the Stanford Skate Park east of the SCM, and the Highland Recreation Center building (refer to Appendix B, Photograph 14). The outfall structure, located at the west end of the SCM, discharges off‐site to an unnamed tributary of Falling Creek northwest of the SCM (refer to Appendix B, Photographs 15 and 16). The emergency spillway from the detention pond is at the northeast corner of the SCM and discharges towards the unnamed tributary of Falling Creek outside of the northern perimeter of the facility (refer to Appendix B, Photographs 17 and 18). The inspection team observed a small pile of material (refer to Appendix B, Photograph 16) adjacent to the outfall structure. Because City representatives were unable to provide design specifications, O&M requirements, or as‐builts for the SCM, the inspection team was unable to verify whether the small pile was a designed feature of the SCM. The MS4 inspectors were unsure of the recommended maintenance and recognized that they should review the design specifications to determine the function, if any, of the small pile. The MS4 inspectors did not document their findings with photographs and/or an inspection report. MS4 Inspection Report Hickory, NC: NPDES Permit No. NCS000426 Inspection Date: December 12, 2018 Page 25 of 30 Site Visit Evaluation: Municipal Facility No. 1 Facility Name: City of Hickory Fire Station No. 5 Date and Time of Site Visit: 12/12/2018, 3:10 PM Facility Address: 1425 21st Street Drive SE Hickory, NC 28601 Facility Type (Vehicle Maintenance, Landscaping, etc.): Vehicle Maintenance and Equipment Storage Name of MS4 inspector(s): Kyle Butler, City of Hickory Kelly Winkler, City of Hickory Eric Geitner, City of Hickory Most Recent MS4 Inspection (Date and Entity): None (see II.G.2.g above) Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit: Name Title Steve Moore Fire Chief Observations Facility Documentation/Training Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility‐specific? No. The facility does not have a SWPPP or similar document. What type of stormwater training do facility employees receive? How often? Facility employees do not currently receive stormwater training. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? The MS4 inspectors have received limited general stormwater training in the past but not on a routine basis, and not specifically related to pollution prevention and good housekeeping at municipal facilities. Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? No. The MS4 inspectors stated that the City does not conduct routine inspections of municipal facilities that are not covered under Industrial Stormwater General Permits. Additionally, the MS4 inspectors have not identified potential pollutant sources or developed and implemented any tools for doing so. Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping? Partial. The MS4 inspectors were able to identify some pollution prevention and good housekeeping issues at the facility but did not identify and document all areas of concern observed by the inspection team (see the notes below for more detail). It was the first time the MS4 inspectors had inspected the facility. Inspection Procedures Does the MS4 inspector’s process include the use of a checklist or other standardized form? Obtain copy. No. Does the MS4 inspector’s process include taking photos? No. Does the MS4 inspector’s process include reviewing the facility’s SWPPP (or similar document)? N/A – the facility does not have a SWPPP. MS4 Inspection Report Hickory, NC: NPDES Permit No. NCS000426 Inspection Date: December 12, 2018 Page 26 of 30 Site Visit Evaluation: Municipal Facility No. 1 Does the MS4 inspector’s process include walking the entire facility and inspecting all points of discharge? No. The MS4 inspectors had not previously inspected the facility. The MS4 inspectors mainly focused on pollution source control. This site visit was in‐part conducted for the inspection team to demonstrate to City representatives how to properly inspect the entire facility, including all points of discharge from the facility and associated receiving waters. Did the MS4 inspector miss any obvious areas of concern? If so, explain: Yes. See the notes section below for more details. Since the City does not conduct routine inspections, the site visit was conducted in‐part to educate City staff on what to look for and how to perform a comprehensive inspection. Does the MS4 inspector’s process include presenting the inspection findings to the facility contact? The MS4 inspectors indicated that any findings and associated action items would be reported to the Fire Chief, who would then assign a team for remediation. The Fire Chief was on‐site to confirm this line of communication; however, the MS4 inspectors did not complete formal documentation of the corrective actions noted during the site visit. Inspection Results Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)? The MS4 inspector did not conduct a full, documented inspection of the facility and will need to revisit the site in order to do so. The MS4 inspector also did not document the need for any corrective actions. If compliance corrective actions were identified, what timeline for correction/follow‐up was provided? The MS4 inspectors verbally reported issues to the Fire Chief during the visit and indicated that corrective actions identified by the inspection team would be addressed as soon as possible; however, the MS4 inspectors did not formally document the corrective actions. Notes/Comments/Recommendations The inspection team observed the following while visiting the City of Hickory Fire Station No. 5. The MS4 inspector did not document the areas of concern and only verbally indicated that the site would take corrective actions. 1. The inspection team observed fire department representatives using a fire hose to clear snow and debris from the driveway. All the flow was directed towards the stormwater drain in the southeast corner of the parking lot (refer to Appendix B, Photographs 19 and 20). Grit was observed at the discharge point from the stormwater drain directly south of the driveway as a result of the outflow (refer to Appendix B, Photograph 21). The nearest receiving water, an unnamed tributary of Clark Creek, was located more than 200 feet downgradient from the discharge point. It was unclear whether the discharge flowed to the unnamed tributary of Clark Creek or infiltrated shortly before making it to the stream bank (refer to Appendix B, Photograph 22). 2. The eastern maintenance garage is equipped with a catch basin for used oil (refer to Appendix B, Photograph 23) and a pump system that directs used oil to indoor storage tanks that are located inside secondary containment (refer to Appendix B, Photograph 24). 3. Fire department representatives indicated that they typically conduct vehicle washing outdoors on a driveway using a pressure washer and degreaser (refer to Appendix B, Photographs 25 and 26). 4. Barrels containing, or once containing, hydraulic fluid and motor oil were stored along the south side of the eastern maintenance garage without cover or secondary containment (refer to Appendix B, Photographs 27, 28, 29, and 30). 5. Petroleum product staining was observed on the impervious surface upgradient from a storm drain in the southeast corner of the driveway (refer to Appendix B, Photographs 31 and 32). 6. A sheen was observed on top of stormwater collected in the southeast portion of the facility, directly east of the eastern maintenance garage (refer to Appendix B, Photograph 33). Stormwater collected in the southeast corner of the facility appeared to be discharging off‐site through an opening in the cement barrier surrounding the impervious driveway (refer to Appendix B, Photographs 34 and 35). MS4 Inspection Report Hickory, NC: NPDES Permit No. NCS000426 Inspection Date: December 12, 2018 Page 27 of 30 Site Visit Evaluation: Municipal Facility No. 1 7. The inspection team observed a channel in the snow indicating that stormwater was bypassing the catch basin in the southwest corner of the facility (refer to Appendix B, Photograph 36). The channel led directly towards an abandoned detention pond that may discharge to downgradient receiving water (refer to Appendix B, Photographs 37 and 38). It was unclear what the pond’s previous purpose was. Recommendation: While on site, the inspection team discussed implementing best management practices including cleanup of discarded barrels and equipment, washing vehicles indoors, and ensuring vehicles are not leaking petroleum products when brought on‐site. To prevent illicit discharges, the inspection team noted that runoff from driveway maintenance activities should not be directed towards the on‐site stormwater discharge points. The inspection team also noted that the City should include all stormwater discharge points and on‐site outfalls on the City’s map. These areas of concern would likely have been noticed and addressed if the City was conducting regular inspections of the facility. The MS4 inspectors discussed solutions to the areas of concern with the acting Fire Chief prior to concluding the site visit. Through routine inspections, the MS4 inspectors should asses the facility for stormwater pollution sources, documenting findings, and working with the Fire Chief to ensure the findings are addressed. MS4 Inspection Report Hickory, NC: NPDES Permit No. NCS000426 Inspection Date: December 12, 2018 Page 28 of 30 Site Visit Evaluation: Municipal Facility No. 2 Facility Name: City of Hickory Public Works Facility Date and Time of Site Visit: 12/12/2018, 4:28 PM Facility Address: 945 15th Avenue NW Hickory, NC 28601 Facility Type (Vehicle Maintenance, Landscaping, etc.): Vehicle Maintenance and Equipment Storage Name of MS4 inspector(s): Kyle Butler, City of Hickory Kelly Winkler, City of Hickory Eric Geitner, City of Hickory Most Recent MS4 Inspection (Date and Entity): None (see II.G.2.g above) Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit: Name Title Brad Abernathy Steve Miller Fleet Manager Assistant Public Services Director Observations Facility Documentation/Training Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility‐specific? Yes (covered under a facility‐specific Industrial Stormwater General Permit). Facility representatives were unfamiliar with the SWPPP, which was outdated, and had difficulty locating it. The SWPPP was not being implemented. What type of stormwater training do facility employees receive? How often? Facility employees do not currently receive stormwater training or perform training related to their Industrial Stormwater General Permit. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? The MS4 inspectors received limited general stormwater training in the past but not on a routine basis and not specifically related to pollution prevention and good housekeeping at municipal facilities. Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? No. The MS4 inspectors stated that they assumed inspection and training requirements were being met through the Industrial Stormwater General Permit; however, facility representatives did not have any inspection reports or training records. Facility representatives were generally unaware of the industrial permit and were not implementing its requirements. Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping? Partial. The MS4 inspectors were able to identify some pollution prevention and good housekeeping issues at the facility but did not identify and document all areas of concern observed by the inspection team (see the notes below for more detail). Inspection Procedures Does the MS4 inspector’s process include the use of a checklist or other standardized form? Obtain copy. No. Does the MS4 inspector’s process include taking photos? No. Does the MS4 inspector’s process include reviewing the facility’s SWPPP (or similar document)? No. The MS4 inspectors do not perform oversight inspections of the facility, and facility representatives were unaware that the facility had industrial permit coverage and a SWPPP. MS4 Inspection Report Hickory, NC: NPDES Permit No. NCS000426 Inspection Date: December 12, 2018 Page 29 of 30 Site Visit Evaluation: Municipal Facility No. 2 Does the MS4 inspector’s process include walking the entire facility and inspecting all points of discharge? No. See the notes section below for more details. Since the City has not been conducting routine inspections and training, the site visit was in‐part conducted to demonstrate to City representatives and facility personnel how to properly inspect the entire facility, including all points of discharge from the facility. Did the MS4 inspector miss any obvious areas of concern? If so, explain: Yes. See the notes section below for more details. Since the City has not conducted routine inspections, the site visit was conducted in‐part to educate City staff on what to look for and how to perform a comprehensive inspection. Does the MS4 inspector’s process include presenting the inspection findings to the facility contact? The MS4 inspectors indicated that any findings and associated action items would be reported to the facility managers, who would then assign a team for remediation. The facility representatives confirmed this line of communication; however, the MS4 inspectors did not formally document the corrective actions noted during the site visit. Inspection Results Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)? The MS4 inspectors did not conduct a full, documented inspection of the facility. As such, the MS4 inspector did not document the need for any corrective actions. The MS4 inspectors will need to follow up with facility personnel to ensure the facility is meeting the requirements of the Industrial Stormwater General Permit. If compliance corrective actions were identified, what timeline for correction/follow‐up was provided? The MS4 inspectors verbally indicated that the facility would address the corrective actions identified by the inspection team as soon as possible; however, the MS4 inspectors did not formally document the needed corrective actions. Notes/Comments/Recommendations Following discussions with the inspection team, the MS4 inspectors indicated that their future inspection process for facilities covered under Industrial Stormwater General Permits will consist of reviewing routine inspection and training records required for compliance under the facility‐specific Industrial Stormwater General Permits. However, following a review of the on‐site records at the City of Hickory Public Works Facility, it was clear that the facility was not conducting routine inspections and training. Therefore, the site visit was conducted to demonstrate to the MS4 inspectors and on‐site personnel how to properly inspect the entire facility and all points of discharge. The inspection team observed the following during the site visit. The MS4 inspectors did not document the areas of concern and only verbally indicated that the facility would implement the corrective actions. 1. A used oil storage tank was on the west side of the main fleet garage without secondary containment. The storage tank was not double‐walled (refer to Appendix B, Photograph 39). The volume of petroleum storage available at this site suggested that a Spill Prevention, Control, and Countermeasure (SPCC) plan is necessary. 2. There is an indoor truck wash in the southwest corner of the facility (refer to Appendix B, Photograph 40). City representatives indicated that all wastewater from the truck wash is captured and discharged to the sanitary sewer system. 3. Uncovered dumpsters were observed in the southern parking lot (refer to Appendix B, Photograph 41) and the northern equipment storage area (refer to Appendix B, Photograph 42). One large uncovered dumpster located in the northern equipment storage area was over filled (refer to Appendix B, Photograph 43). 4. There was a trailer equipped with a spray barrel parked, uncovered, in the southeast corner of the facility (refer to Appendix B, Photograph 44). City representatives indicated that the spray barrel is used for pesticide application. 5. An outdoor truck wash and sediment collection pad in the northeast corner of the facility (refer to Appendix B, Photographs 45 and 46) feeds into a detention pond adjacent to the pad (refer to Appendix B, Photograph 47). The outflow from the detention pond is piped underneath the northern equipment storage area to the stormwater discharge point in the northwest corner of the facility. Facility representatives stated that the truck wash is primarily used to hose out dirty truck beds, exposing the detention pond to dirt/sediment and oil and grease. MS4 Inspection Report Hickory, NC: NPDES Permit No. NCS000426 Inspection Date: December 12, 2018 Page 30 of 30 Site Visit Evaluation: Municipal Facility No. 2 6. There is a salt and equipment storage building located between the southern (upgradient) parking lot and the northern (downgradient) equipment storage area. The salt stockpile was covered; however, at the time of the site visit, there was salt collected on the uncovered driveway directly north of the facility (refer to Appendix B, Photograph 48). 7. The northwest corner of the facility contains a detention pond, which is surrounded by uncovered and uncontained sediment stockpiles showing evidence of runoff and sediment transport directly towards the pond (refer to Appendix B, Photographs 49, 50, and 51). The detention pond collects runoff from the northern equipment storage area. 8. The inspection team observed that the detention pond in the northwest corner of the facility was overgrown with vegetation (refer to Appendix B, Photograph 49). City representatives were unsure of the last time the pond was maintained. City representatives stated that they were unaware of any available design specifications and suggested the pond was installed ad‐hoc many years ago. It was recommended that the MS4 inspectors or facility personnel reassess the design, integrity, and function of the detention pond and reconstruct and/or maintain it, as appropriate. 9. Multiple members of the inspection team noticed a sewage‐like odor coming from the stormwater discharge point located in the northwest corner of the facility (refer to Appendix B, Photographs 52 and 53). The catch basins in the southern (upgradient) parking lot and ponds in the northern equipment storage area were all piped to this discharge point. Recommendation: Facility personnel will need to work with the MS4 inspectors to meet the inspection and training requirements of the MS4 and Industrial Stormwater General Permits, in addition to updating the SWPPP. While on site, the inspection team discussed the implementation of BMPs for pollution prevention and good housekeeping. The detention ponds in the northern equipment storage area may require maintenance. The MS4 inspectors and facility personnel should review the design plans to ensure the ponds are operating according to design specifications. The MS4 inspectors should conduct further investigation into the source of the odor at the MS4 outfall to determine its source and take any necessary corrective actions. The MS4 inspectors should investigate the effectiveness of the truck wash BMP located in the northeast corner of the facility. It was unclear how representative sampling could be conducted at the facility. It is recommended that City representatives consider how such sampling will adhere to the requirements of the Industrial Stormwater General Permit.