NCS000423_COMPLIANCE_20130206

STORMWATER DIVISION CODING SHEET
M54 PERMITS
PERMIT NO.
� CSob 0 9,0-
DOC TYPE
❑FINAL PERMIT
❑ ANNUAL REPORT.
APPLICATION
❑VCOMPLIANCE
❑ OTHER
DOC DATE
❑ O�-DOb�D�O
YYYYMMDD

AENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Pat McCrory Charles Wakild, P. E.
Governor Director
February 6, 2013
John Skvarla
Secretary
RECEIVED
DIVISION OF WATER QUALITY
Doug Miller FEB 12 2013
Project Engineer 5WP SECTION
Alfred M. Brown Operations Center MOORESVILLE REGIONAL OFFICE
850 Warren C. coleman Blvd.
Concord, North Carolina 28026-0308
Subject: Evaluation of the City of Concord's Stormwater Management Program,
Stormwater Permit No. NCS000423
Dear Mr. Miller:
The North Carolina Department of Environment and Natural Resources (NCDENR), Division of
Water Quality (DWQ) conducted an audit of the City's Stormwater Management Program on December
5, 2012. DWQ was represented by Bill Diuguid and Mike Randall, from the DWQ Stormwater
Permitting Unit, and Samar Bou-ghazale from the Mooresville Regional Office.
The compliance evaluation is conducted to evaluate the City's compliance with the requirements
of Section 402(p) of the Clean Water Act (CWA), 33 U.S.C. § 1342(p), the regulations promulgated there
under at 40 Code of Federal Regulations Part 122.26, and the North Carolina National Pollutant
Discharge Elimination System (NPDES) Permit No. NCS000423.
The staff was very helpful during the audit and should be commended on the initiatives they've
taken to managing stormwater under the conditions of the City's permit.
The staff provided a brief description of the storm sewer system, identified the receiving streams,
and whether or not the receiving streams are impaired and any associated water quality issues. The staff
also provided a brief description of the City's Public Education and Outreach Program, Public
Involvement and Participation Program, Illicit Discharge Detection and Elimination Program, Sediment
and Erosion Control Program, Post -Construction Program, and Pollution Prevention and Good
Housekeeping program.
The City's Public Education and Outreach Program is based on community wide issues. Staff
provided a brief description of the target audiences and target pollutants as well as the likely sources of
those pollutants and their impacts. The City maintains an internet web site designed to convey the
program's message, distributes stormwater educational material to appropriate target groups, and
promotes and maintains a stormwater hotlinelhelpline.
1':9I!8nd¢.7nd St,;:�nwalei E3r;:•ch
?7 L.,.If c<•r;i e'" "er. Za'^ ali, No.:h �,arolina 2r, jP'317
IL J' 514 N i'imhnz: i76f .
Phcav 5 i a-R07' "'u: 1.I'AX: '9_a':• 6494 • ,.,.nin0: 5n ,i,:e'
Ir, ;1101 11NY. J
(Me
4orth Carolina
Aldlifla f dh,6 y,

Doug Miller
February 6, 2013
Page 2 of 4
The Public Involvement and Participation Program includes volunteer opportunities and other
mechanisms designed to promote ongoing public involvement.
The City maintains an IDDE ordinance that provides the City with adequate legal authority to
prohibit illicit connections and discharges. The City maintains a current map showing major outfalls and
receiving streams, conducts dry weather flow field observations in accordance with a written procedure
for detecting and removing the sources of illicit discharges. The City maintains written procedures for
conducting investigations of identified illicit discharges, tracks investigations and document when illicit
discharges are observed, and tracks the results of the investigation and any follow-up of the investigation.
The City relies on the State for the Sediment and Erosion Control Program.
The City maintains an ordinance that provides the City with adequate legal authority to meet the
objectives of the Post -Construction Program, The City has the authority to review designs and proposals
for new development, request information, and enter private property to conduct inspections. The City
adopted the DWQ BMP Design Manual and conducts site plan reviews of all development within the city
and require BMPs where greater than one acre is graded and impervious are created, or where more than
20,000 sf of new impervious is created. The site plan reviews address how the project applicant meets the
performance standards and how the project will ensure long-term maintenance.
_The City maintains a current inventory of facilities and operations owned and operated by the
City (with the potential for generating polluted stormwater runoff). The City also maintains and
implements a SWPPP for their public works program. The SWPPP includes a site description and site
plan that show drainage areas, stormwater and sanitary piping, manholes, cleanouts, drains, inlets,
outfalls, oil water separators, and stormwater control devices. The SWPPP identifies industrial activities
and facilities, storage practices, best management practices, secondary containment requirements,
structural BMPs, erosion and sediment controls, procedures for spill response, loading and unloading,
vehicle and equipment maintenance, waste handling and disposal, and employee training requirements.
Recommendations
Recommendations represent practlees that should be considered to improve the overall
effectiveness to improve stormwater management.
DWQ recommends the City maintain copies of materials used in the training. The City should
ensure that they identify and maintain records on who needs to be trained, what they need to be trained
on, and when they need to be trained.
The SWPPP provides excellent procedures for activities such as spill response, loading and
unloading, vehicle and equipment maintenance, waste handling and disposal. DWQ recommends the City
complete the process of developing one or two page procedures for those activities as well as other
activities with the potential for the potential for generating polluted stormwater runoff.

Doug Miller
February 6, 2013
Page 3 of 4
For example, the City should have SOPS that document inspections of:
Structural stormwater control devices with a specific frequency (i.e., annual, quarterly, etc.) to
ensure the devices are accessible and free of debris, oil and grease, the perimeter is free of any
bare soil, erosion, or gullies, inlet/outlet pipes and/or devices clear and undamaged, the
embankments are in good condition and free of unplanted shrubs or trees, grass cover is healthy,
forebay areas are in good condition, rip rap is not displaced, and the devices are otherwise
maintained and functioning properly.
Oil Water Separators (OWS) with a specific frequency (i.e., annual, quarterly, etc.) to ensure they
are accessible, the area is free of signs of overflow, all drains are free flowing with no water back-
up, all drains are free from obstruction, the discharge is free of visible signs of oil or debris,
appropriate warnings are posted about the proper use of the OWS, and the OWS are otherwise
maintained and functioning properly.
Tanks and containers stored outside with a specific frequency (i.e., annual, quarterly, weekly,
etc.) to ensure secondary containment is free of accumulated water and free of any debris, cracks,
holes, or evidence of leaks, secondary containment drain valves are maintained in the closed
position unless the facility is draining the secondary containment, drain logs are being.
maintained, tanks and containers are in good condition and properly marked, free of rust, pits or
deterioration or evidence of leaks, tank supports free of rust, damage, or deterioration, and that
tank and container storage areas are in good condition.
• Areas where activities are conducted outside and where material handling equipment, industrial
machinery and/or equipment and vehicles are stored outside to ensure the areas are free of any
visible residuals or signs of spills.
• Catch basins and inlets to ensure they are in good condition, trash and debris, floatables,
pollutants, and oil and grease.
• Solid waste containers to ensure they are in good condition and of sufficient size to contain all
materials, have lids and are free of recyclable materials, hazardous materials, tires, liquids, and
leaks, and labeled "Prohibited - No Hazardous Waste, No Recyclable Materials, No Liquids."
• Roof areas to ensure they are free of any particulate matter or visible deposits of residuals from
roof stacks and/or vents.
• Loading/unloading and material storage areas to ensure they are designed to minimize storm
water run-on and run-off, the areas are free of any visible residuals or signs of spills and spill kits
and drain covers are readily available.
Similar documented inspections should be maintained for streets, parking lots, right-of-ways,
catch basins, inlets, open channels, culverts, conveyance systems and drainage structures. Streets,
parking lots, right-of-ways, catch basins, inlets, open channels, culverts, conveyance systems and
drainage structures should be inspected to ensure they continue to be in good condition and free of trash
and debris, floatables, pollutants, oil and grease to the maximum extent practicable.
In reviewing the permit requirements for the City's fleet maintenance, the facility takes the SIC
from the type of vehicle most frequently service or which brings in the most revenue. City records

Doug Miller
February 6, 2013
Page 4 of 4
indicate that public safety, SIC code is 92, is the primary activity. While this code does not require the
separate permit, the City should review the State's general permit, NCG080000, to assess if the City is
implementing appropriate best management practices for vehicle maintenance activities under their
overall MS4 permit for pollution prevention and good housekeeping.
Discrepancies
Discrepancies are findings that would not likely cause a Notice of Violation, a fine, or other
enforcement action. Discrepancies are normally a result of poor management practices, failure to follow
Standard Operating Procedures, minor differences of interpretation or administration oversights or where
compliance could not be determined at the time of the audit.
Notice of Non -Compliance
A Notice of Non -Compliance is any finding that could result in a Notice of Violation, a fine or
other enforcement action if corrective action is not taken. The State did not identify any findings that
could result in a Notice of Violation, a fine or other enforcement action if corrective action is not taken.
Notice of Violation
A Notice of Violation is any permit noncompliance. The State did not identify any findings that
would result in a Notice of Violation, a fine or other enforcement action.
Should you have any questions related to this audit please feel free to contact me at
[e-mail] or at 919-807-6374 or Bill Diuguid at bill.diuguid c7ncdenr.gov or at 919-807-
6369.
Sincerely,
,;� - -� �,-Zu
Mike Randall
cc: Stormwater Permitting Unit files
Samar Bou-ghazale, Mooresville Regional Office