HomeMy WebLinkAboutNCS000435_Asheville Self Audit_20190726MS4 Permit Audit Report
Asheville, NC: NPDES Permit No. NCS000435
Audit Date: April 3, 2019
MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM AUDIT REPORT
NPDES PERMIT NO. NCS000435
Asheville, NORTH CAROLINA
PO Box 7148
Asheville, NC 28802
Audit Date: April 3, 2019
Report Date: July 24, 2019
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
MS4 Permit Audit Report
Asheville, NC: NPDES Permit No. NCS000435
Audit Date: April 3, 2019
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MS4 Permit Audit Report
Asheville, NC: NPDES Permit No. NCS000435
Audit Date: April 3, 2019
TABLE OF CONTENTS
Audit Details 1
Permittee Information 2
Supporting Documents 3
Public Education and Outreach 4
Public Involvement and Participation 9
Post-Construction Site Runoff Controls 13
Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1 17
Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 2
19
Appendix A: Supporting Documents 21
Appendix B: Photograph Log 22
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.
MS4 Permit Audit Report
Asheville, NC: NPDES Permit No. NCS000435
Audit Date: April 3, 2019
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MS4 Permit Audit Report
Asheville, NC: NPDES Permit No. NCS000435
Audit Date: April 3, 2019
Audit Details
Audit ID Number:
NCS000435_Asheville
MS4 Audit_2019
Audit Date(s):
Minimum Control Measures Evaluated:
⬜ Program Implementation, Documentation & Assessment
⬜ Public Education & Outreach
⬜ Public Involvement & Participation
⬜ Illicit Discharge Detection & Elimination
⬜ Construction Site Runoff Controls - No delegated Sediment and Erosion Control Program
⬜ Construction Site Runoff Controls - Delegated Sediment and Erosion Control Program
⬜ Post-Construction Site Runoff Controls
⬜ Pollution Prevention and Good Housekeeping for Municipal Operations
⬜ Total Maximum Daily Loads (TMDLs)
Field Site Visits:
⬜ Municipal Facilities. Number visited: ____
⬜ MS4 Outfalls. Number visited: ____
⬜ Construction Sites. Number visited: ____
⬜ Post-Construction Stormwater Runoff Controls. Number visited: _____
⬜ Other: ___________________________ . Number visited: ______
⬜ Other: ___________________________. Number visited: ______
Inspector(s) Conducting Audit
Name, Title Organization
McCray Coates, Stormwater Division Manager City of Asheville, Public Works Department
Nancy Watford, Stormwater Supervisor City of Asheville, Development Services Department
Monte Clampett, Construction Coordinator City of Asheville, Development Services Department
Keisha Lipe, Stormwater Quality Specialist City of Asheville, Public Works Department
Audit Report Author:
Signature
Date:
7/25/19
Audit Report Author:
Signature
Date
7/25/19
MS4 Permit Audit Report
Asheville, NC: NPDES Permit No. NCS000435
Audit Date: April 3, 2019
Permittee Information
MS4 Permittee Name:
City of Asheville
Permit Effective Date:
February 17, 2017
Permit Expiration Date:
February 16, 2022
City, State, ZIP:
Asheville, NC 28802
Date of Last MS4 Inspection/Audit:
September 27 & 28, 2018
Co-permittee(s), if applicable:
Permit Owner of Record: City of Asheville
Primary MS4 Representatives Participating in Audit
Name, Title Organization
McCray Coates, Stormwater Division Manager City of Asheville, Public Works Department
Keisha Lipe, Stormwater Quality Specialist City of Asheville, Public Works Department
Nancy Watford, Stormwater Supervisor City of Asheville, Development Services Department
Monte Clampett, Construction Coordinator City of Asheville, Development Services Department
MS4 Receiving Waters
Waterbody Classification Impairments
French Broad River C Benthos (from Mud Creek to NC 146)
Ross Creek B Benthos (I-240 to backwaters of Lake Kenilworth)
Smith Mill Creek C Benthos (from source to French Broad River)(Draft 303d
2018)
South Hominy Creek C Benthos (from Warren Creek to Hominy Creek)
Note: Only waterbodies with 303(d) impairments that receive discharges from the Asheville MS4 are listed here.
MS4 Permit Audit Report
Asheville, NC: NPDES Permit No. NCS000435
Audit Date: April 3, 2019
Supporting Documents
Item
Number Document Title When Provided
(Prior to/During/After)
1 Educational Material handouts During
2 Environmental Quality Institute Contract & Spreadsheet During
3 Illicit Discharge Detection and Elimination Brochure During
4 Stormwater Management Plan (used also as Annual Report) During
5 Stormwater, Soil Erosion and Sedimentation Control, Illicit Discharge and
Connection Ordinance During
6 Plan Review Checklist During
7 City of Asheville Operation & Maintenance Agreement During
8 O & M Database Spreadsheet During
9 City of Asheville SCM During
10 Pre-Con & SW Closeout Documents During
11 Stormwater Services Operation and Maintenance Inspection Report During
12 Lowes Inspection Report During
13 Wal-Mart Inspection Report During
14 Wal-Mart follow up letter During
15 City of Asheville Fees & Charges Manual See pg 4 for permit fees, See Pg 69 for
SW Utility fee. After - Updated 7/1/2019
16 Post Construction SCM Inspection SOP During
MS4 Permit Audit Report
Asheville, NC: NPDES Permit No. NCS000435
Audit Date: April 3, 2019
Public Education and Outreach
Staff Interviewed:
(Name, Title, Role)
Keisha Lipe, Stormwater Quality Specialist, Leads the Public Education and Outreach Efforts;
McCray Coates, Stormwater Division Manager, Oversees the NPDES program;
Nancy Watford, Stormwater Supervisor, Oversees the development review of development plans by
engineers and contractors related to stormwater requirements and flooding requirements;
Monte Clampett, Stormwater Construction Coordinator, Point contact for contractors and engineers
during construction phase for private development
Permit Citation Program Requirement Status Supporting
Doc No.
II.B.2.a
Goals and Objectives
The permittee defined goals and objectives of the Local Public Education and
Outreach Program based on community wide issues. Partial 4
Comments (Generally describe process for establishing goals/objectives)
The City has adequate personnel to perform the Public Education and Outreach Program. The Stormwater Quality Specialist leads
the efforts for the City.
The City of Asheville performs a public education and outreach program currently through local schools and various organizations.
Currently the program includes providing basic messages regarding clean water and actions people can do at home to prevent
stormwater pollution.
At community meetings, the city discusses what stormwater is and explains ways the City is working to promote stormwater
programs in order to improve water quality and nuisance flooding.
Educational material is also provided on the City’s website.
The City targets issues brought to our attention by the community, examples of this would be the proper way to dispose of pet
waste, proper methods to utilize fertilizer and illicit discharge education.
The City promotes Stream Cleanup programs and partners with local non profit organizations to gather the trash removed from the
streams.
The City tracks the number of attendants at specific events that stormwater staff attends.
Recommendation:
The City will better define target pollutants and associated target audiences in the Stormwater Management Plan (SWMP).
II.B.2.b
Target Pollutants
The permittee maintained a description of the target pollutants and/or stressors
and likely sources. Partial 2
Comments (List target pollutants, note any that are missing or not appropriate)
Public Education and Outreach targets include used oil, antifreeze and batteries, car washing, household hazardous waste, grass
clippings and other yard waste, pet waste, and sedimentation. Brochures are handed out at community events. These specific
items have been targeted as concerns from previous resident and illicit discharge complaints to staff. City Staff has targeted
business and residential property owners previously related to these items.
The City of Asheville has a contract with Environmental Quality Institute (EQI) for the testing of six stream site samples within the
City. EQI has been developing an on-going water quality database of Western North Carolina watersheds. The purpose of the
research is to continue and expand the long-term monitoring of stream sites within Buncombe County. The cost is being shared by
the Buncombe County Soil & Water Conservation District (SWCD), Metropolitan Sewerage District (MSD) and the City of Asheville
Stormwater Services. The major focus of the monitoring is to identify problem areas as well as areas with high water quality that
need to be maintained and to monitor areas where water quality improvement projects will be taking place. This contract with
MS4 Permit Audit Report
Asheville, NC: NPDES Permit No. NCS000435
Audit Date: April 3, 2019
EQI, offers technical assistance through laboratory analysis of samples and statistical data analysis of monitoring results.
Volunteers take these samples through EQI Guidelines.
Public Education and Outreach
The overall goal of the proposed research is to assess the present water quality of representative streams and rivers within the City
of Asheville. Specific objectives include:
➢ Analyze water samples from six sites in Asheville for eight chemical parameters monthly, with this contract it brings
the total number of sites being tested in Buncombe County to 47;
➢ Analyze the data statistically for trends between sites (spatial) and trends within sites over time (temporal); and
➢ Use the results of the analyses to assess the ability of streams to support their various current, intended, and
potential uses.
EQI laboratory analyzes all samples for the following parameters: pH, ammonia-nitrogen, nitrate-nitrogen, orthophosphate, total
suspended solids, alkalinity, turbidity, and conductivity.
Recommendation:
The City has added a list of targeted audience and pollutants in the SWMP that is being developed.
II.B.2.c
Target Audiences
The permittee identified, assessed annually and updated the description of the
target audiences likely to have significant stormwater impacts and why they were
selected.
Yes ---
Comments (Describe any changes made, if applicable)
The City of Asheville target audiences are youth groups and residential property owners. Youth groups were chosen in order to
educate them early as they can help educate their parents. Residential property owners were selected because of the large impact
they can have on stormwater in the community.
As issues arise, staff provided educational materials to address those specific items. An example would be the proper disposal of
pet waste, a brochure was developed to address these concerns following concerns from citizens about proper methods to dispose
of pet waste.
The City has signage located at newly constructed public stormwater control measures to interact with the public that utilize the
areas.
The City provides a stormwater website that provides information as it relates to the stormwater program.
MS4 Permit Audit Report
Asheville, NC: NPDES Permit No. NCS000435
Audit Date: April 3, 2019
II.B.2.d Residential
and Industrial/
Commercial Issues
The permittee described issues, such as pollutants, the likely sources of those
pollutants, potential impacts, and the physical attributes of stormwater runoff in
their education/outreach program.
Partial ---
Comments (Generally describe the residential/industrial/commercial issues addressed)
The city’s education/outreach program for property owners has focused on the following pollutants:
● Car washing
● Pet waste
● Use of lawn and garden products
● Leaves
These pollutants were selected because they can harm fish and wildlife population, foul drinking water supplies, kill native
vegetation, and make recreational areas unsafe. Questions have occured from citizens related to these activities as well.
The city has targeted residential property owners for these items.
Recommendation--The City should identify industrial/commercial educational materials tailored for those specific uses.
Public Education and Outreach
II.B.2.e
Informational
Web Site
The permittee promoted and maintained an internet web site designed to convey
the program’s message. Yes ---
Comments (list web page address and general contents, or attach screen shot of landing page)
Stormwater Services continues to maintain an educational stormwater website:
http://www.ashevillenc.gov/Departments/StormwaterServicesUtility.aspx, and a City related blog. The website provides
information about the program and also the importance of clean water to the citizens of Asheville. The City also provides
information related to flood protection measures. The City reviews the website quarterly and provides updates as necessary.
The City provides links that show the approximate location of the Stormwater outfalls. This information can be found on our
MapAsheville GIS website. Contact information is provided on the website along with the City’s hotline number.
The City’s Stormwater Website provides program information, the City’s Stormwater Capital Improvement Projects, as well as City
Staff Contact information.
II.B.2.f
Public Education
Materials
The permittee distributed stormwater educational material to appropriate target
groups. Yes ---
MS4 Permit Audit Report
Asheville, NC: NPDES Permit No. NCS000435
Audit Date: April 3, 2019
Comments (List distributed materials and quantity, message, distribution mechanism, target audience for each if not included in
program documentation/annual reporting)
The City performs stormwater outreach at various events. Stormwater activities are utilized at events where the target audience is
school aged children. City staff seeks out opportunities to partner in various events to promote stormwater education. Below are
some examples:
Stormwater Staff participated in Buncombe County Employability Seminar and Asheville Outlets (Touch a?) Truck events and
distributed the following brochures:
➢ Help Protect Our Water;
➢ Pet Waste;
➢ Illicit Discharge Detection & Elimination
Stormwater Staff sent a letter to provide flooding information to property owners located within an area that is more subjected to
flooding. The letter included:
➢ Information on preparing for a flood;
➢ Recommended permanent flood protection measures;
➢ Information about flood insurance policies; and
➢ How to protect natural floodplain functions
Stormwater Staff went into schools and lead tours at our water treatment plants. During each of the tours and school visits
students were given booklets inside a bag with information on how to help protect our water.
Stormwater projects, operations and activities are promoted on the City’s blog.
Public Education and Outreach
For 2017-18 the outreach program touched:
Activity Estimated Number of Exposure
Water Education Tours w/activity 236
Repetitive Flooding Letter 173
Merrimon Ave Baptist Preschool 30
Buncombe County Workforce Program 300
Asheville Outlets Truck Event 2,000
New Belgium Sustainability Event 25
Vance Elementary Events 157
YWCA Event 70
MS4 Permit Audit Report
Asheville, NC: NPDES Permit No. NCS000435
Audit Date: April 3, 2019
II.B.2.g
Hotline/Help Line The permittee promoted and maintained a stormwater hotline/helpline for the
purpose of public education and outreach. Yes ---
Comments (Note hotline contact information and method(s) for advertising it)
The City provides a customer service line 828-251-1122 for citizens to report illicit discharge and accidental discharge after normal
business hours and weekends. The city maintains a helpline 828-232-4567 during normal business hours for citizens to call with
questions or report illicit discharge. Both numbers are promoted on brochures mailed to citizens and on the City website. The City
also has a stormwater email address made available to the public for general questions related to stormwater.
The City implemented a duty officer program that has someone on call 24-7 to respond to calls.
The City has an Asheville App which is a tool to allow citizens to report issues related to stormwater and other items. This tool
provides a way for citizens to take a picture of the issue and send to the appropriate City staff member.
The Development Services Department also has a “plan reviewer of the day” phone line 828-259-5460 to address stormwater and
permitting questions, as well as an email stormwater@ashevillenc.gov that is available on the website.
II.B.2.h
Public Education and
Outreach Program
The permittee’s outreach program, including those elements implemented locally
or through a cooperative agreement, included a combination of approaches
designed to reach the target audiences.
Yes ---
For each media, event or activity, including those elements implemented locally
or through a cooperative agreement the permittee estimated and recorded the
extent of exposure.
Yes ---
Comments (Generally describe approaches, extent of exposure. Note any cooperating entities, agreements and scope of
services, or reference comments in Section II.A.6. above.)
The City looks for opportunities to work with citizens to promote stormwater initiatives and provide further education to them.
Below is a list of activities and outreach events performed the past year. The City leads many of the efforts and is asked to assist in
others through our various partners. Some of these events consists of active tours to promote interactions with participants, other
have staff handing out materials while interacting with citizens at events open to the general public. The City also works closely
with local schools to promote stormwater initiatives within the teachers curriculum. The following are examples of the City’s
outreach efforts this past year:
Activity Estimated Number of Exposure
Water Education Tours w/activity 236
Repetitive Flooding Letter 173
Kids in the Creek Event 318
Buncombe County Fall & Spring Field Days 1,700
Merrimon Ave Baptist Preschool 30
Buncombe County Workforce Program 300
Asheville Outlets Truck Event 2,000
School Career Day (Enka, Haw Creek, Erwin Middle) 1,280
New Belgium Sustainability Event 25
Vance Elementary Events 157
YWCA Event 70
The City’s Sanitation Division has a Zero Waste AVL campaign that encourages Asheville residents to send less trash to the landfill
by recycling. The City has set a goal of 50% waste reduction by 2035. This is promoted on the City website and in social media.
The City also partners with local non profits to perform stormwater stenciling programs to raise awareness of clean water to our
community.
MS4 Permit Audit Report
Asheville, NC: NPDES Permit No. NCS000435
Audit Date: April 3, 2019
The City post educational signage beside publicly funded Stormwater Control Measure projects promoting the stormwater efforts.
Additional
Comments:
Public Involvement and Participation
Staff Interviewed:
(Name, Title,
Role)
Keisha Lipe, Stormwater Quality Specialist, Leads the Public Education and Outreach Efforts;
McCray Coates, Stormwater Division Manager, Oversees the NPDES program;
Nancy Watford, Stormwater Supervisor, Oversees the development review of development plans by
engineers and contractors related to stormwater requirements and flooding requirements;
Monte Clampett, Stormwater Construction Coordinator, Point contact for contractors and engineers during
construction phase for private development
Permit Citation Program Requirement Status Supporting
Doc No.
II.C.2.a Volunteer
Community
Involvement
Program
The permittee included and promoted volunteer opportunities designed to promote
ongoing citizen participation. Yes ---
MS4 Permit Audit Report
Asheville, NC: NPDES Permit No. NCS000435
Audit Date: April 3, 2019
Comments (Note opportunities promoted and date(s) of volunteer events)
The City of Asheville partners with Asheville Greenworks to provide Adopt-a-Street Program. Groups and organizations are
encouraged to help reduce litter by participating in Asheville’s Adopt-A-Street program. Participants agree to pick up litter from
their adopted street at least six times per year. Greenworks provides groups with bags, vests, gloves, and pick-up sticks. The City of
Asheville provides garbage pickup and signs on the street to recognize the litter reduction efforts. This year 18 new streets were
adopted bringing the total of adopted streets to 235.
The City of Asheville partners with RiverLink to provide Adopt-a-Stream program. This is a hands-on way for local residents and
businesses to get actively involved in improving the water quality of the French Broad River Watershed. This very flexible program
gives the tools and knowledge to make a difference in our watershed by cleaning up local streams. Participants are required a
minimum of two cleanups per year and report any water related issues/problems to RiverLink. The City of Asheville provides
garbage pickup and signs to RiverLink to install on the streams to recognize the litter reduction efforts. This year three new teams
joined the program bringing the total to 18 adopted streams.
The City has a Flood Damage Reduction Task Force that consists of citizens from both the County and City to discuss flood
mitigation efforts that are ongoing. The task force meets on an as needed basis.
The City of Asheville partners with Mountain True and RiverLink to provide storm drain stenciling in our community. The city
provides the stenciling equipment to Mountain True and RiverLink, they organize and provide the volunteers. With this partnership
approximately 153 storm drains have been stenciled this fiscal year.
City Staff will visit with community groups or professional organizations to discuss our stormwater program. Often times
stormwater staff will meet with small residential groups to discuss specific stormwater questions or concerns. Stormwater staff will
also attend larger professional conferences to highlight what Asheville is doing related to stormwater or flood control efforts.
Stormwater staff trains other City employees on the importance of stormwater quality and also works with them on specific items
to identify within their work area and throughout the City.
II.C.2.b
Mechanism for
Public
Involvement
The permittee provided and promoted a mechanism for public involvement that
provides for input on stormwater issues and the stormwater program. Partial ---
Comments:
The City provides a stormwater e-mail (stormwater@ashevillenc.gov) and phone number 828-232-4567 in which the public can
provide input and report on stormwater issues.
Staff from the stormwater division often meet with citizens to discuss their specific concerns or questions related to stormwater
issues. City Staff attends public events to promote stormwater and receive comments from citizens.
City staff’s contact information is available on the stormwater website as well.
Citizens can also report issues or concerns on the City of Asheville App.
Social media is also used to post stormwater projects and activities.
Community meetings are held to gain input on stormwater issues related to capital improvement projects.
MS4 Permit Audit Report
Asheville, NC: NPDES Permit No. NCS000435
Audit Date: April 3, 2019
Recommendation:
Develop guidelines and procedures on a new mechanism for the public to provide input on stormwater issues and the stormwater
program.
II.C.2.c
Hotline/Help Line
The permittee promoted and maintained a hotline/helpline for the purpose of public
involvement and participation. Yes ---
Comments (Note hotline contact information and how it is promoted)
The City provides a customer service line 828-251-1122 for citizens to report illicit discharge and accidental discharge after normal
business hours and weekends. The city maintains a helpline 828-232-4567 during normal business hours for citizens to call with
questions or report illicit discharge. Both numbers are promoted on brochures mailed to citizens and on the City website. The City
also has a stormwater email address made available to the public for general questions related to stormwater.
The City implemented a duty officer program that has someone on call 24-7 to respond to calls.
The City has an Asheville App which is a tool to allow citizens to provide information related to stormwater issues. This tool
provides a way for citizens to take a picture of the issue and send to the appropriate city staff member.
The Development Services Department also has a plan reviewer of the day phone line 828-259-5460 to address stormwater
questions, as well as an email stormwater@ashevillenc.gov that is available on the website.
Additional
Comments:
MS4 Permit Audit Report
Asheville, NC: NPDES Permit No. NCS000435
Audit Date: April 3, 2019
Post-Construction Site Runoff Controls
Staff Interviewed:
(Name, Title, Role)
McCray Coates, Stormwater Division Manager, Oversees the NPDES program;
Nancy Watford, Stormwater Supervisor, Oversees the interactions with engineers and contractors related
to stormwater requirements and flooding requirements;
Monte Clampett, Stormwater Construction Coordinator, Point contact for contractors and engineers
Implementation (check all that apply):
⬜ The permittee implements the components of this minimum measure.
⬜ The permittee relies upon another entity to implement the components of this minimum measure: name of entity
⬜ The permittee implements the following deemed-compliant program(s), which meet NPDES MS4 post-construction
requirements for the areas where implemented and in compliance with the specific program requirements as provided in
15A NCAC and noted below (Complete Session Law 2006-246 section below):
⬜ Water Supply Watershed I (WS-I) – 15A NCAC 2B .0212
⬜ Water Supply Watershed II (WS-II) – 15A NCAC 2B .0214
⬜ Water Supply Watershed III (WS-III) – 15A NCAC 2B .0215
⬜ Water Supply Watershed IV (WS-IV) – 15A NCAC 2B .0216
⬜ Freshwater High Quality Waters (HQW) – 15A NCAC 2H .1006
⬜ Freshwater Outstanding Resource Waters (ORW) – 15A NCAC 2H .1007
⬜ Neuse River Basin Nutrient Sensitive (NSW) Management Strategy – 15A NCAC 2B .0235
⬜ Tar-Pamlico River Basin Nutrient Sensitive (NSW) Management Strategy – 15A NCAC 2B .0258
⬜ Randleman Lake Water Supply Watershed Nutrient Management Strategy – 15A NCAC 2B .0251
⬜ Universal Stormwater Management Program – 15A NCAC 2H .1020
Ordinance(s) (check all that apply):
The permittee utilizes the following ordinances and/or regulatory authority to fulfill post construction minimum measure
program requirements throughout the MS4 permitted area (check all that apply):
⬜ DEQ model ordinance
⬜ MS4 designed post-construction practices that meet or exceed 15A NCAC 02H .1000.
⬜ DEQ approved comprehensive watershed plan
⬜ DEQ approved ordinance for a deemed-compliant Program (see list above)
Instructions:
For MS4s not implementing a S.L. 2006-246 deemed-compliant program, complete only the Permit Citation section below.
For MS4s implementing a S.L. 2006-246 deemed-compliant program, complete the Session Law 2006-246 section below. If the
MS4 does not implement a deemed-compliant program throughout the entire MS4 permitted area, then complete the Permit
Citation section below for the permitted area(s) not covered under the S.L. 2006-246 deemed-compliant program.
Session Law 2006-
246 Program Requirement Status Supporting
Doc No.
MS4 Permit Audit Report
Asheville, NC: NPDES Permit No. NCS000435
Audit Date: April 3, 2019
Post Construction Site Runoff Controls
Deemed-Compliant
Program(s)
The permittee implements deemed-compliant Program requirements in
accordance with the applicable 15A NCAC rules. N/A ---
The permittee implements deemed-compliant Program requirements
throughout the entire MS4 area (If not, also complete the Permit Citation section
below.)
N/A ---
The permittee applies deemed-compliant Program requirements to all federal,
state and local government projects within the permitted MS4 area who do not
have their own NPDES stormwater permit.
N/A ---
The permittee included deemed-compliant Program reporting in their MS4
Annual Reports. N/A
The permittee included deemed-compliant Program implementation in their
Stormwater Management Plan. N/A ---
Comments
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 5
If yes, the ordinance applies throughout the corporate limits of the
permittee (Verify permit coverage area listed in Part I.D of permit and modify
accordingly).
Yes 5
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 5
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 5
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 5
Comments (If the permittee relies upon another entity, specifically note the legal authority that allows that entity to
implement the program within the MS4 area)
City Unified Development Ordinance 7-12-2, which is attached, is the regulatory mechanism for the City to meet the objectives of
the Post Construction program. The ordinance applies throughout the city’s jurisdiction. The City actively reviews development
plans in accordance with the ordinance. The permittee can enter private property for inspections as necessary.
II.F.2.b
Stormwater Control
Measures (SCMs)
The permittee utilizes strategies which include SCMs appropriate for the MS4. Yes ---
SCMs comply with 15A NCAC 02H .1000. Yes ---
MS4 Permit Audit Report
Asheville, NC: NPDES Permit No. NCS000435
Audit Date: April 3, 2019
Post-Construction Site Runoff Controls
Comments
The City requires the new development and redevelopment to meet the requirement of the stormwater ordinance. This requires
the use of appropriate SCM as approved by the city. The City utilizes the NCDEQ Stormwater Control Manual and Credit
Document as our Stormwater Manual establishing regulatory requirements.
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 6
If yes, the site plan reviews addressed how the project applicant meets the
performance standards. Yes ---
If yes, the site plan reviews addressed how the project will ensure long-
term maintenance. Yes 7
Comments
The site plans must meet City standards. For all SCM, an operations and maintenance agreement is required to address the long-
term maintenance of the device. A copy of a sample O and M agreement is linked to Supporting Document Item #10.
Recommendations:
Since the City of Asheville Development Services Department has moved to digital review, we are planning to update the
checklist, submittal requirements, and platting process to improve the review and have the applicant state how they are meeting
the requirements and long term maintenance, within the next year.
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.
Yes 8
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.
Yes ---
Comments
The City maintains an inventory of the SCM’s within the City’s Jurisdiction. A copy of the O&M Spreadsheet is attached.
In addition the City maintains a GIS map of all Post Construction SCMs. .
http://avl.maps.arcgis.com/apps/SimpleViewer/index.html?appid=cb97ebcc115a4d0ab83cbb0752e2ea10
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.
Yes ---
Comments
The City of Asheville requires Operation and Maintenance agreements to be recorded as part of the project closeout process. The
City uses this O&M agreement to ensure the post construction SCM is maintained and functions as designed. The City also
maintains a hard copy of the agreement and an electronic listing of each BMP which includes the location, owner and a running
list of the dates of inspections.
MS4 Permit Audit Report
Asheville, NC: NPDES Permit No. NCS000435
Audit Date: April 3, 2019
Post-Construction Site Runoff Controls
Recommendations:
Over the next year the City is looking to improve the final platting process, including improvement to requirements access,
maintenance and permanent drainage easements for stormwater infrastructure and post construction SCMs to meet the City and
NCDEQ Stormwater Control Manual. The Operation and Maintenance Agreements will also be reviewed and updated to include
the Plat page and book of the final plat, as well as include additional requirements to O&M Agreement to meet the requirements
of the NCDEQ Stormwater Manual (specifically referencing Operation and Maintenance Plan and annual reports maintained by
owner).
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. Yes ---
The operation and maintenance plan required the owner of each SCM to perform
and maintain a record of annual inspections of each SCM. Yes ---
Annual inspection of permitted structural SCMs are required to be performed by a
qualified professional. Yes ---
Comments
An Operation & Maintenance Agreement is recorded for each SCM constructed within the City Limits. The owner is required to
have the SCM inspected annually by a qualified professional and send a copy of the report to the CIty. The CIty performs random
inspection on post-construction SCM’s. Section 7-12-2 of the City UDO requires the O&M Agreement and annual reporting (See
Supporting Document 5)
II.F.2.g
Inspections of
Structural
Stormwater Control
Measures
The permittee conducted and documented inspections of each project site
covered under performance standards, at least one time during the permit term
(Verify this is a permit condition in Part II.F.2.g of permit and modify accordingly).
Partial ---
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(Verify this is a permit condition in Part II.F.2.g of permit
and modify accordingly.
Yes ---
The permittee developed and implemented a written inspection program for
SCMs installed pursuant to the post-construction program (Verify this is a permit
condition in Part II.F.2.g of permit and modify accordingly.
Yes ---
The permittee documented and maintained records of inspections. Yes 9
The permittee documented and maintained records of enforcement actions. Yes ---
Comments
The City receives inspection reports required of the O and M agreements from professionals hired to inspect & review private
SCM’s. For those that we have not received from the property owner, the City reviews periodically and sends out letters of issues
identified. The City reviews the site and approves the SCM’s prior to issuing a certificate of occupancy. For any sites that have not
been finalized, prior to a CO issuance, a Bond is required.
The City has an SOP for post-construction SCM inspections.
The City partners with RiverLink, a non-profit, to perform the inspections of municipal owned SCM’s.(See attachment 10)
Recommendations
The City will develop procedures to conduct site inspections of all SCM during the permit cycle.
MS4 Permit Audit Report
Asheville, NC: NPDES Permit No. NCS000435
Audit Date: April 3, 2019
MS4 Permit Audit Report
Asheville, NC: NPDES Permit No. NCS000435
Audit Date: April 3, 2019
Post-Construction Site Runoff Controls
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 5, 6 & 7
Comments (If the permittee has adopted materials from other programs, indicate here which materials they are using)
The documents including ordinance, checklists, post-construction requirements, and design standards are available through the
City of Asheville Website. These include applicant checklists, City of Asheville UDO, City of Asheville Standard Specifications and
Details Manual, and close-out documents. These are also available in the Permit Application Center, and upon request for staff.
Any project that requires post-construction stormwater controls is required to attend a pre-construction meeting. At this
meeting the plan reviewer supplies the post-construction requirements, inspection requirements, and close-out documentation.
See Supporting Documents 5, 6 and 7.
II.F.2.i Enforcement
The permittee tracked the issuance of notices of violation and enforcement
actions. Yes ---
If yes, the tracking mechanism included the ability to identify chronic
violators for initiation of actions to reduce noncompliance. Yes ---
Comments
The City tracks all Notice of Violation through our inspection software. Also a list of all issued NOV’s are sent to the State monthly
to be tracked as well. The City also reviews the State list as necessary.
II.F.3.b
New Development
The permittee fully complies with post construction program requirements on its
own publicly funded construction projects. Yes ---
Comments
The City complies with the post construction requirements for projects that require SCM’s. The City follows the same application
and review process as private sector developers per City ordinance.
II.F.3.c
Nutrient Sensitive
Waters
Does the MS4 have areas draining to Nutrient Sensitive Waters (NSW) pursuant to
15A NCAC 02H .0150? N/A ---
If yes, does the permittee use SCMs that reduce nutrient loading in order to
meet local program requirements. N/A ---
If yes, does the permittee also still incorporate the stormwater controls
required for the project's density level. N/A ---
If yes, does the permittee also require documentation where it is not
feasible to use SCMs that reduce nutrient loading. N/A ---
Comments (Provide reference for local requirements)
II.F.3.d
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
Stormwater Plan reviewers require and confirm that the design volumes of SCMs for runoff at full buildout. We require pre and
post impervious areas be shown and designated on the plan, and for subdivisions track total impervious as the sub-division is built
out. For major subdivisions, we require maximum impervious surface per lot noted on the plat.
MS4 Permit Audit Report
Asheville, NC: NPDES Permit No. NCS000435
Audit Date: April 3, 2019
Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1
Site Name:
Lowe’s Smokey Park Hwy
Date and Time of Site Visit:
2/27/2019 1:28pm
Site Address:
95 Smokey Park Hwy
Asheville, NC 28806
SCM Type:
Dry Pond
Most Recent MS4 Inspection (Include Date and Entity):
1/24/2019
Name of MS4 Inspector(s) evaluated:
Toby Shelton
Most Recent MS4 Enforcement Activity (Include Date):
Name(s) and Title(s) of Site Representative(s) Present During the Site Visit:
Name Title
McCray Coates Stormwater Division Manager
Nancy Watford Stormwater Supervisor
Monte Clampett Construction Coordinator
Observations
Site Documentation
Does the site have an operation and maintenance plan?
Yes, Recorded 1/11/2008
Deed Book: 4510 Deed Book Page: 716-717
Does the site have records of annual inspections? Are they performed by a qualified individual?
Yes, dated 1/24/2019. Performed by: Timothy Ormond, P.E HydroCycle Engineering, PC
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
North Carolina Stormwater SCM Inspection & Maintenance Certification. Recertification is every 3 years. Certified Erosion,
Sediment and Stormwater Inspector through Envirocert International. Recertification is every 2 years. Trenching and Shoring
Designated Competent Person. OSHA Confined Space trained. Recertification is every year.
Did the MS4 inspector appear knowledgeable about MS4 requirements for post-construction site runoff controls?
Yes, Toby Shelton has been certified in SCM inspections since 2010.
MS4 Permit Audit Report
Asheville, NC: NPDES Permit No. NCS000435
Audit Date: April 3, 2019
Did the MS4 inspector appear knowledgeable about post-construction BMPs (general purpose/function, components, O&M
requirements, etc.)?
Yes. He took note of not only the SCM proper but also the surrounding area making note of ground cover maintenance,
groundhog holes, litter control. He also took note of the fence surrounding the area as well as the gates leading into the SCM.
Inspection Procedures
Does the MS4 inspector’s process include the use of a checklist or other standardized form? What format?
Inspectors have a standard BMP Inspection form that is provided to them as a digital fillable form, or hardcopy. The fillable form
is in a google form that once the report is finalized it is saved, populates the post-construction inspection report spreadsheet with
link to the report.
City of Asheville Stormwater Services Operation and Maintenance Inspection Report (attachment 15)
Does the MS4 inspector’s process include taking photos?
Yes, inspector takes pictures of items of concern or not in compliance with Operation and Maintenance Plan and SCM
Construction requirements based on the date of installation.
Does the MS4 inspector’s process include reviewing the site’s operation and maintenance plan and records of annual inspections?
Yes, inspector reviews Operation and Maintenance Agreement and, at a minimum, the most recent annual report provided by the
owner/engineer.
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?
The Inspector reviewed all points of discharge associated with the post-construction stormwater controls for the site. The
inspector did not walk the entire property, only reviewed the SCM’s and all points of discharge. The inspector found no issues
that would prompt him to go further up the system to perform any investigations.
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, Inspection report is sent to site contact.
Compliance/Enforcement
What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in?
No enforcement actions were identified.
Any maintenance needs are communicated through the inspection report with a timeline for compliance, where the inspector will
conduct a follow-up inspection. At that point if maintenance noted was not conducted a Notice of Violation is sent to the owner.
If compliance issues were identified, what timeline for correction/follow-up was provided?
Notes/Comments/Recommendations
Supporting document #12
MS4 Permit Audit Report
Asheville, NC: NPDES Permit No. NCS000435
Audit Date: April 3, 2019
Recommendations:
Moving forward, City staff will modify the SOP for post construction site inspection walking the entire site to visually inspect for
any issues.
MS4 Permit Audit Report
Asheville, NC: NPDES Permit No. NCS000435
Audit Date: April 3, 2019
Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 2
Site Name:
Walmart Airport Rd
Date and Time of Site Visit:
2/27/2019 2:29pm
Site Address:
60 Airport Rd
ASheville, NC 28704
SCM Type:
Wet Detention, Bio-retention, Level Spreader (not included in
original O&M Agreement but included on approved plans)
Most Recent MS4 Inspection (Include Date and Entity):
8/31/2018
Name of MS4 Inspector(s) evaluated:
Toby Shelton
Most Recent MS4 Enforcement Activity (Include Date):
Name(s) and Title(s) of Site Representative(s) Present During the Site Visit:
Name Title
McCray Coates Stormwater Division Manager
Nancy Watford Stormwater Supervisor
Monte Clampett Construction Coordinator
Observations
Site Documentation
Does the site have an operation and maintenance plan?
Yes, recorded 5/5/2009
Deed Book: 4690, Deed Book Page: 1636-1648
Does the site have records of annual inspections? Are they performed by a qualified individual?
Yes, dated 8/31/2019. Performed by: Timothy Ormond, P.E HydroCycle Engineering, PC
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
North Carolina Stormwater SCM Inspection & Maintenance Certification. Recertification is every 3 years. Certified Erosion,
Sediment and Stormwater Inspector through Envirocert International. Recertification is every 2 years. Trenching and Shoring
Designated Competent Person. OSHA Confined Space trained. Recertification is every year.
Did the MS4 inspector appear knowledgeable about MS4 requirements for post-construction site runoff controls?
Yes, Toby Shelton has been certified in SCM inspections since 2010.
MS4 Permit Audit Report
Asheville, NC: NPDES Permit No. NCS000435
Audit Date: April 3, 2019
Did the MS4 inspector appear knowledgeable about post-construction BMPs (general purpose/function, components, O&M
requirements, etc.)?
Yes. He took note of not only the SCM proper but also the surrounding area making note of ground cover maintenance,
groundhog holes, litter control, etc.
Inspection Procedures
Does the MS4 inspector’s process include the use of a checklist or other standardized form? What format?
Inspector has a standard BMP Inspection form that is provided to them as a digital fillable form, or hardcopy. The fillable form is
in a google form that once the report is finalized it is saved, populates the post-construction inspection report spreadsheet with
link to the report.
City of Asheville Stormwater Services Operation and Maintenance Inspection Report
Does the MS4 inspector’s process include taking photos?
Yes, inspector takes pictures of items not in compliance with Operation and Maintenance Plan and SCM Construction
requirements based on the date on installation.
Does the MS4 inspector’s process include reviewing the site’s operation and maintenance plan and records of annual inspections?
Yes, inspector reviews Operation and Maintenance Agreement and at a minimum the most recent annual report provided by the
owner/engineer.
Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 2
Does the MS4 inspector’s process include walking the entire site and inspecting all points of discharge?
The Inspector reviewed all points of discharge associated with the post-construction stormwater controls for the site. The
inspector did not walk the entire property, only reviewed the SCM’s and all points of discharge.
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, Inspection report is sent to site contact.
Compliance/Enforcement
What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in?
The inspection report notes that the level spreader cap is missing and needs additional maintenance. Level spreader was not
inspected on 3rd party inspection report apparently because it was not included in the original O&M agreement although it is
shown on the approved plans. The City has requested that a new O&M agreement be submitted for recording that includes the
level spreader.
If compliance issues were identified, what timeline for correction/follow-up was provided?
A certified letter will be sent to the owner noting the deficiencies and they will be given 30 days from the receipt of the letter to
have the issue corrected or to contact the CIty for an extension of time if needed.
Notes/Comments/Recommendations
MS4 Permit Audit Report
Asheville, NC: NPDES Permit No. NCS000435
Audit Date: April 3, 2019
Supporting documents #13 and #14
Recommendations:
Moving forward, City staff will modify the SOP for post construction site inspection which will include walking the entire site to
visually inspect for any issues.
MS4 Permit Audit Report
Asheville, NC: NPDES Permit No. NCS000435
Audit Date: April 3, 2019
APPENDIX A: SUPPORTING DOCUMENTS
See page 7 - Supporting documents page with links to the documents.
MS4 Permit Audit Report
Asheville, NC: NPDES Permit No. NCS000435
Audit Date: April 3, 2019
APPENDIX B: PHOTOGRAPH LOG
See page 7 - Supporting documents page with links to the documents with
photographs.