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Home My WebLink AboutNCS000250_NCDOT MS4 AUDIT REPORT_20190923MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) PROGRAM AUDIT REPORT NPDES PERMIT NO. NCS000250 NORTH CAROLINA DEPARTMENT OF TRANSPORTATION 1 S. Wilmington Street Raleigh, NC 27601 Audit Date: September 23 — 25, 2019 Report Date: February 5, 2020 North Carolina Department of Environmental Quality Division of Energy, Mineral & Land Resources Stormwater Program 512 N. Salisbury Street, 9th floor 1612 Mail Service Center Raleigh, NC 27699-1612 (This page intentionally left blank) NCS000250 NCDOTMS4Audit 20190923 TABLE OF CONTENTS AuditDetails........................................................................................ Permittee Information........................................................................ List of Supporting Documents............................................................. Program Implementation, Documentation & Assessment ................. Illicit Discharge Detection and Elimination Program (IDDEP).............. Post -Construction Site Runoff Controls .............................................. Construction Site Runoff Controls........................................................ Industrial Activities............................................................................... Internal Education and Involvement Program ..................................... External Public Education and Involvement Program .......................... ResearchProgram................................................................................ Appendix A: Supporting Documents Appendix B: Industrial Facility Inspection Reports Appendix C: Construction Site Inspection Reports 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. NCS000250_NCDOT MS4 Audit_20190923 ii This page intentionally left blank NCS000250 NCDOT MS4 Audit 20190923 iii Audit Details Audit ID Number: Audit Date(s): NCS000250_NCDOT MS4 Audit_20190923 09/23/19 — 09/25/19 Minimum Control Measures Evaluated: ® Program Implementation, Documentation & Assessment ® Education & Involvement ® Research Program M Illicit Discharge Detection & Elimination ® 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: Choose an item. ❑ MS4 Outfalls. Number visited: Choose an item. M Construction Sites. Number visited: Choose an item. ❑ Post -Construction Stormwater Runoff Controls. Number visited: Choose an item. ❑ Other: Number visited: Choose an item. ❑ Other: Number visited: Choose an item. Inspector(s) Conducting Audit Name, Title Or¢anization Jeanette Powell, MS4 Program Coordinator NCDEQ-DEMLR Alaina Morman, Compliance Specialist NCDEQ-DEMLR Lauren Garcia, Permit Specialist NCDEQ-DEMLR Robert Patterson NCDEQ-DWR Audit Report Author: Jeane a Powell, CPSWQ Date: February 5, 2020 Signature NCS0002SO—NCDOT MS4 Audit_20190923 Page 1 of 34 Permittee Information MS4 Permittee Name: North Carolina Department of Transportation (NCDOT) Permit Effective Date: October 1, 2015 Permit Expiration Date: September 30, 2020 Mailing Address: 1501 Mail Service Center, Raleigh NC 27699-1501 Date of Last MS4 Inspection/Audit: November 29, 2016 Co-permittee(s), if applicable: N/A Permit Owner of Record: James H. Trogdon, III Primary MS4 Representatives Participating in Audit Name, Title Omanization 9 23 9 24 9 25 Amy Chapman (via phone) DWR X Ben DeWit REU State Field Operations Engineer X Joe Dunnehoo Hydraulics, Engineer III X X X Mark Gallo Hydraulics Transportation Engineering Associate X Melanie Gardner AECOM Senior Environmental Scientist/PM X Jeremy Goodwin REU State Erosion Control and Roadside Management Engineer X X X David Harris REU State Roadside Environmental Engineer X X X Meghan Ingram REU Engineering Technician III X X X Matt Lauffer Assistant State Hydraulics Engineer X Brian Lipscomb Hydraulics, Engineer III X X X Michelle Mayfield AECOM Senior Program Scientist X X Andy McDaniel Hydraulics Engineering Supervisor III X X X Stephen Morgan State Hydraulics Engineer X X Ryan Mullins Hydraulics Engineer III X X X Dan O'Connor REU Engineer X X X Robert Patterson NCDWR-TPB X X X Derek Smith REU Engineer X Steve Sykes Hydraulics Engineer III X X Chad Wilson AECOM Engineering Technician X MS4 Receiving Waters Waterbodv Classification Impairments Statewide NCS000250_NCDOT MS4 Audit_20190923 Page 2 of 34 List of Supporting Documents Item Number Document Title When Provided (Prior to/During/After) 1 2018 Annual Report Prior 2 NCDOT Roles and Responsibilities Prior 3 Jacksonville Supplemental Municipal Agreement Prior 4 1-77 Mobility Partners Agreement Prior 5 Field Guide for Post -Construction Stormwater BMPs During 6 Vegetation Management Manual During 7 Field Inventory Procedures (FIP) Manual After 8 Outfall Identification Guidelines After 9 Illicit Discharge Detection & Elimination Program Field Report Form After 10 Stormwater Pollution: What's Our Connection Brochure After 11 NCDOT Highway Stormwater Program Poster After 12 Illegal Discharge Brochure After 13 Compost Seeding Retrofit Credit Approval After 14 BMP Toolbox After 15 NCDOT Hydraulics Retrofit Site Selection (ROSS) Program geospatial tool During 16 Stormwater Control Management System (SCMS) tool During 17 Stormwater Control Inspection and Maintenance Manual After 18 09/29/14 BMP Toolbox and Post Construction Stormwater Controls (PCSP) Guidance Document Approval After 19 Post Construction Stormwater Controls (PCSP) Guidance Document After 20 Field Guide for Post -Construction Stormwater Best Management Practices During NC5000250_NCDOT MS4 Audit_20190923 Page 3 of 34 21 Example Inspection and Maintenance In Person Training Documentation After 22 Example Inspection and Maintenance Training Webinar Documentation After Additional Supporting Documents Continued: The following presentations, documents, forms and links were requested by DEMLR on 09/25/2019 and provided by NCDOT on 10/09/2019: 23. Power Point Presentations (presented by NCDOT during audit) a. Highway Stormwater Program Overview b. Construction Program c. Stormwater Outfall Inventory and Prioritization Program (SOIP) d. Retrofit Program e. Post -Construction Stormwater Program (PCSP) f. BMPToolbox g. BMP Inspection & Maintenance Program h. Vegetation Management Program i. Illicit Discharge Detection & Elimination Program (IDDEP) j. Industrial Activities Program k. Internal Education Program I. External Education Program m. Research Program 24. O-Chart of Responsible Parties 25. Vision Business Plan 26. List of Borrow Pits/Waste Piles 27. Escalation of Construction Site Deficiencies 28. Standard Contract Language for NCG010000 Requirements 29. FIP Procedures Manual 30. Outfall Identification Guidelines 31. ROSS Capabilities 32. Compost Reseeding Agreement 33. PCSP Approval Letter 34. Summary of Approved Retrofit Credits 35. LOS Status Summary NCS000250_NCDOT MS4 Audit_20190923 Page 4 of 34 36. Example Training Documentation 37. Example Webinar Documentation 38. IDDE Brochure 39. SPPPTemplate 40. List of SPPPs & SPCC Components 41. List of Industrial Facility Reviews 42. Internal Education Plan 43. External Education Plan 44. SCM Inspection and Maintenance Manual 45. Industrial and Roadway Maintenance Activities BMP Guidance Manual (IRMA) 46. Research Plan - QAPP 47. Spill Response Survey 48. Borrow Pit/Waste Pile Reclamation Plan 49. Borrow Pit Discharge Management Plan 50. Approved Jordan Lake Guided Reduction of Excess Environmental Nutrients (GREEN) Program 51, Approved Falls Lake GREEN Program Forms 52. DOT construction inspection form 53. ICA form 54. Daily pesticide application form 55. IDDEP field report form Links 56. TIP list: https:/twvvw.ncdot.govriinitiatives-policies/transportation/stip/Pagestdefauft.aspx 57. Online Project Tracking: https://apps.ncdot.govAraffictravel/progloc/default.aspx 58. Borrow Pit Discharge Guidance: https://connect.nedot.gov/resources/roadsidetPages/Field-Operations- Documents.aspx 59. PCSP Manual: https://connect.ncdot.gov/resources/hydro/Pages/HSPProgramPages.aspx?PGM=PCSP 60. Example O-Chart for Division Staff: https://apps.ncdot.gov/dot/directory/authenticated/ToC.aspx 61. ESC Design and Construction Manual: https://connect. nodot.gov/resources/roadside/So!Waterpocuments/Erosion°%20and%20SedimeM%2OControl%2ODesign %20and%20Construction %20Man ua I. pdf 62. Research Program: https://connect.ncdot.gov/projectsiresearoh/Pages/defaultaspx 63. Connect NCDOT: https://connectncdot.gov/resoufceslhydro/Pages/Hrghway.Stormwater Program.aspx NCS000250_NCDOT MS4 Audit_20190923 Page 5 of 34 64. Review of Erosion and Sedimentation Control Program Delegation to the NCDOT Division of Highways (Nov.4, 2019): https://fiies.nc.gov/ncdeq,Energy%20Mineral%20and%20Land%20Resources/Land%20Resources/Sedimentation%20Co ntroi%20Commissioiv20 f 9-scc-mee tings/nov-0-2019/2019-NC-DOT-Annual-Revie w-Report-Nov-25-2019. pdf NCS000250_NCDOT MS4 Audit_20190923 Page 6 of 34 Program Implementation, Documentation & Assessment Staff Interviewed: See Page 2 (Name, Title, Role) 09/23/2019 Attendees Permit Citation Program Requirement Status supporting Doc No. III.A.1. The permittee provided DEMLR with an annual report consisting of a program Program summary and assessment. Yes 1 Assessment If yes, the report(s) included the status of each component of the permit, proposed changes to the stormwater management program or implementation schedule, a summary of illicit connection and illegal dumping reports and inspections, identification of efforts to improve water quality or reduce Yes 1 degradation as a result of NCDOT activities, and successes, failures and milestones/accomplishments of the program. The permittee submitted the annual assessment report to DEMLR no later than October 31 of each year for the reporting period from July 1 through June 30. Yes 1 The permittee maintained a copy of each annual program assessment report on file for a period of five years. Yes 1 Comments The permittee has submitted routine annual reports as required. Annual reports are developed utilizing a standardized process that includes meeting with responsible parties, identifying accomplishments and deficiencies, implementing process improvement, project prioritization and developing program considerations for the following year. The resulting reports include the required program summary and assessment. III.A.2. Implementation of the stormwater Pollution Prevention Plan (SPPP) at each industrial Program facility includes documentation of all monitoring, measurements, inspections, Yes 39, 40, Assessment maintenance activities and training provided to employees. 41 Such documentation is kept on -site for a period of five years. Yes App. B Such documentation is made available to DEMLR immediately upon request. Yes --- Comments NCDOT industrial activities covered under this permit include ferry terminals, vehicle maintenance areas, and mining activities which are typically covered under NCG020000, NCG080000 and NCG560000. Eight maintenance facilities and eight construction projects were inspected (See Appendices B and C, respectively). Each inspected site had appropriate documentation available. III.A.3 Monitoring qualitative and analytical monitoring is documented and records maintained. Yes App. B&C These reports are made available to DEMLR upon request. Yes _- NCS000250_NCDOT MS4 Audit_20190923 Page 7 of 34 Program Implementation, Documentation & Assessment The permittee retains records of all monitoring information, including all calibration and maintenance records and all original strip chart recordings for continuous monitoring instrumentation, and copies of all reports required by this permit for a Not period of at least 5 years from the date of the sample, measurement, report or Applicable application. Comments The current permit requires qualitative monitoring for industrial stormwater outfalls. The Inspected industrial facilities maintained appropriate documentation. No analytical monitoring is specifically required in the permit. III.A.4 Training Performed in conjunction with a SPPP requirement is documented and App' maintained at the facility as part of the SPPP. Y Yes B & C Comments NCDOT industrial activities covered under this permit include ferry terminals, vehicle maintenance areas and mining activities which would typically be permitted under NCG020000 and NCG080000. Eight maintenance facilities and eight construction projects were inspected statewide (See Appendices Band C, respectively). Each inspected site had appropriate training and documentation available, with the exception of one construction site (see Buncombe County Construction Inspection_20190625). III.A.S The permittee maintained a list of positions responsible for implementing the 1, 2, 24, Duties & provisions of this permit including central office staff and divisional staff. Yes 25 Responsibilities If yes, the list includes positions, work addresses and phone numbers and a brief description of their responsibilities and/or duties, training and qualifications Yes -- applicable to this permit. If yes, where more than one position is listed, one is named as primary contact and others are listed in the order in which they will assume responsibility as Not alternates. Applicable If yes, the list is available upon request. Yes --- Comments Responsible parties are identified by their roles and responsibilities, and are identified by both position and title. All listed parties present clearly understood their roles and responsibilities. III.B.1. sPPPs The permittee updated existing Industrial facility SPPPs on an annual basis. Yes App. B The permittee developed and implemented SPPPs for proposed/new industrial facilities prior to the beginning of discharges from each operation of the industrial Not activity. Applicable If yes, the permittee updated the SPPPs on an annual basis. Not Applicable If yes, the permittee provided secondary containment prior to the beginning of Not discharges from the operation of the industrial activity. Applicable NCS000250_NCDOT MS4 Audit_20190923 Page 8 of 34 Program Implementation, Documentation & Assessment The permittee performs annual SPPP review and update at each facility. The permittee has over 200 industrial facilities which include maintenance yards, remote storage areas, equipment depots, a rail maintenance yard, a ferry maintenance shipyard, ferry terminals, and an asphalt plant. Maintenance yards can include areas for highway, bridge, roadside environmental, traffic services, and vehicle and equipment maintenance. The Resident Engineer ensures that appropriate permits are in place and there is a SPPP Team at each facility. The permittee has a standard SPPP Template which is comprehensive, includes annual plan review and team member consultations, and integrates SPCC requirements where applicable. A SPPP binder is maintained on site at each facility. Multiple staff training opportunities are employed including videos, IRMA, Level 1 and 2 NCDOT certification, SPPP/SPCC web site, etc. Tasks and completion dates are tracked electronically. Maintenance yard reviews are performed each permit term and include identifying improvements/updates to the SPPP. Unique projects include contractual requirements for compliance. Additional The permittee has established the stormwater program leadership within the Hydraulics and Roadside Comments: Environmental Units, with significant support and implementation throughout the 14 Regions/Highway Divisions. Program funding and budgeting has been a priority and the program is well established. An annual program review and visioning process keeps the program relevant, focused and moving forward. The administration of the program is well documented and correlated to permit requirements. Because of the statewide scope of this permit and significant number of sites and facilities covered, a random sample of industrial and construction projects were inspected for compliance with MS4 permit requirements. In general, the permit is well implemented, documented and routinely assessed for compliance. See Supporting Documents: 1, 2, 23, 24, 25, 39, 40, 41, Appendix B NC5000250_NCDOT MS4 Audit_20190923 Page 9 of 34 Illicit Discharge Detection and Elimination Program (IDDEP) Staff Interviewed: See Page 2 (Name, Title, Role) 09/24/19 Attendees Permit Citation Program Requirement Status supporting Doc No. The permittee implements an Illicit Discharge Detection and Elimination Program to bje cti)ive Objective detect illicit discharges, spills and illegal dumping into the NCDOT transportation Yes 7-9, 12, separate storm sewer system (T54). 29 Comments The permittee implements a comprehensive IDDE program that includes outreach and engagement of field staff, the public and contractors to identify and report illegal dumping and illicit discharges. The permittee performs inspections, outfall screening and maintains standardized reporting/documentation, investigations, and tracking. II.A.b. a Training Program The permittee provided annual training for appropriate staff and contractors. Partial 7, 9-12, 38 If yes, training includes identification and reporting of illicit discharges and illegal dumping. Yes 38,55 Comments The permittee implements an annual IDDE train -the -trainer program for team leaders/supervisors, and also provides appropriate information to staff and contractors who may observe and report illegal dumping and/or illicit discharges during routine work activity. Training for field staff and some contractors is provided via the use of standardized inspections and Feld reporting forms; and providing various flyers, posters and brochures at DOT's industrial facilities and Division offices. DOT industrial facility staff receive IDDE training in conjunction with routine SPPP-SPCC training, which is based upon EPA and Center for Watershed Protection guidance. The IDDE protocols are summarized in the permittee's Illegal Discharge Brochure, FIP Manual and IDDEP Field Report Form. The permittee performed inspections for illicit discharges to the stormwater drainage system and illegal dumping activities when performing other work on the NCDOT Yes 7 II.A.b. b system. Inspections If yes, inspections are documented when illicit discharges are verified. Yes 9 Comments NCDOT maintenance and construction workers continuously observe roadways and facilities during routine work related activities. Observation of a potential illegal dumping or illicit discharge activity is documented on a standard NCDOT IDDE Field Report form. Semi-annual outfall inspections, which include IDDE components, are performed at DOT's industrial facilities. Issues are reported to Stormwater Operations Management for follow-up, or referral to NCDEQ if originating outside of NCDOT jurisdictional area. Stormwater Operations Management maintains an IDDEP tracking spreadsheet and Geodatabase, which was viewed during the audit. NCS000250_NCDOT MS4 Audit_20190923 Page 10 of 34 Illicit Discharge Detection and Elimination Program (IDDEP) II.A.b. c Standard The permittee maintained a standard reporting format for all complaints and reports Reporting Format of illicit discharges. Yes 9 Comments The permittee utilizes a standard IDDE Field Report form and maintains a standard point of contact for reporting and tracking illegal dumping and illicit discharges. II.A.b. c The permittee maintained a standard contact for all complaints and reports of illicit Standard Contact discharges. FY7es9 Comments The permittee maintains a standard point of contact in Stormwater Operations Management for reporting and tracking illegal dumping and illicit discharges. The contact information is clearly presented on the IDDE Field Report form and web page. The permittee also maintains an online Citizen Action Reporting System (CARS) which includes an automated check for NCDOT response. II.A.b. d The permittee investigated all reports of illicit discharges or illegal dumping. ng. Yes - Comments The standard protocol is for DOT supervisory personnel to investigate, complete the required form, and provide it to the Roadside Environmental Unit -Environmental Operations Section for inclusion in the tracking database and Geodatabase tools, and referral to NCDEQ if warranted. The tracking database and Geodatabase tools were demonstrated during the audit. II.A.b. d to The permittee reported verified illicit discharges to the ap propriate NCDENR Regional NCDEQ Office within 30 days of verification. Yes "' Comments The permittee refers verified illicit discharges originating from outside the permittees jurisdictional area to NCDEQ within thirty(30) days of verification, typically via email. Urgent issues are referred via telephone. Resolution of referred issues is not tracked by the permittee once they are referred to NCDEQ. The permittee does not have authority to directly address issues originating outside the public right-of-way / NCDOT property. Tracking a Tracking The permittee maintained a tracking database for reports of illicit discharges. Yes --- --- Comments The Roadside Environmental Unit -Environmental Operations Section maintains the IDDE tracking database. This database was demonstrated during the audit. NCS000250_NCDOT M54 Audit_20190923 Page 11 of 34 Illicit Discharge Detection and Elimination Program (IDDEP) Additional NCDOT maintenance staff and construction inspectors include IDDE and reporting as part of their routine Comments: duties. Chronic dumping sites are addressed through law enforcement and encroachments are referred to NCDEQ regional offices for response. Litter management has been privatized. IDDE standard protocols are implemented, tracked and evaluated periodically. A tracking database and geodatabase are implemented. A hazardous spill survey was completed to identify discrepancies in procedures/implementation between Divisions. For vehicle accidents, the individual causing a spill is responsible for cleanup. Unique projects include contractual requirements for compliance. In general, the IDDEP is well established and well documented. See Supporting Documents: 1, 3, 4, 7-12, 23, 29, 38, 55 NCS000250_NCDOT NIS4 Audit_20190923 Page 12 of 34 Post -Construction Site Runoff Controls Staff Interviewed: See Page 2 (Name, Title, Role) 09/23/19 Attendees Permit Citation Program Requirement Status Supporting Doc No. II.B.l.b. a The permittee maintained a GIS-based implicit stormwater outfall inventory which Outfall Inventory includes outfalls from primary and secondary roadways. Yes 7, 8, 29,30 Comments The permittee has constructed an implicit outfall GIS layer based on the intersection of roadways with streams and also includes industrial facility outfalls on a separate layer. Cross -agency verified GIS layers provide consistent high resolution geospatial stream layers. The inventory includes DOT roads only; local and federal roads are not included. An outfall is defined in the permit as a point where the MS4 (TS4) discharges to WOTUS. The implicit outfall and industrial facility outfall inventory GIS layers were demonstrated during the audit. II.B.l.b. b Annual Inventory The permittee annually updated the outfall inventory to include implicit outfalls Update from newly completed construction projects. Yes 7, 8, 29 Comments The inventory is updated annually by the Roadside Environmental Unit -Environmental Operations Section. Updates include new roads and stream data from the Environmental Sensitivity Map (ESM) and mapping grade GPS. The ESM/ATLAS includes cross - agency verified high resolution GIS stream layers which will provide geospatial consistency. The implicit outfall and industrial facility outfall inventory GIS layers were demonstrated during the audit. II.B.i.b, c NCDOT Industrial The permittee annually updated the outfall inventory to include changes or Outfalls additions to previously inventoried NCDOT industrial facilities. Yes 7, 8, 29 Comments The permittee maintains a GIS layer for industrial facility outfalls, which is updated annually by the Roadside Environmental Unit - Environmental Operations Section. The GIS layer was demonstrated during the audit. II.B.1.b. d Field Outfall Inventory Procedure The permittee maintained a field outfall inventory p ry procedure. Yes 7, 8, 29,30 NCS000250 NCDOT MS4 Audit_20190923 Page 13 of 34 Post -Construction Site Runoff Controls The annual reports document implementation of the outfall inventory procedure, Yes 1 identify future priority areas, and define a schedule for implementing the procedure within the identified priority areas. Comments The permittee's Field Inventory Procedures (FIP) Manual and Outfall Identification Guidelines document protocols, tools and procedures for collection and storage of physical data about the NCDOT stormwater system. The permittee, in conjunction with NCDEQ, identified priority areas for field verified inventory of outfalls (Falls and Jordan Lake watersheds and DWR 511 Watershed Action Plan areas). The annual reports include outfall inventory data and considerations for the following year's activities. 11.8.2.b. a ID Retrofits The permittee identified a minimum of fourteen (14) potential retrofits* per year. Yes 15 Comments The permittee identifies the required number of potential retrofits per year. II.13.2.16. b 13,15, Retrofit The permittee maintained a program to implement retrofits. Yes 31, 32, Implementation 34 The permittee completed (or is on track to complete) a total of seventy (70) 1,15,16, retrofits over the 5-year period of this permit. Yes 32 Retrofits are appropriate for the identified pollutants of concern. Yes 14-16, 32,34 The permittee included the number of retrofits completed in the annual report. Yes 1 Comments The permittee averages the number of retrofits per year over the life of the permit and is on track to complete the required 70 retrofits for this permit term. Over the course of all four permits, a total of 280 retrofits is required. The permittee has completed construction of 277 retrofits to date and currently has 14 in design. Per a prior agreement with NCDEQ the installation of a BMP associated with a new construction project cannot be counted as a retrofit. Retrofits that have been installed and subsequently removed to accommodate a new construction project are still included in the retrofit inventory, but are tagged as removed. Retrofits are targeted to address sensitive watersheds and impaired waters, removal of multiple pollutants, and BMP solutions that are appropriate for the location. The permittee employs the NCDOT Hydraulics Retrofit Site Selection (ROSS) Program geospatial tool, online Stormwater Control Management System (SCMS) tool, and online BMP Toolbox to implement this program (demonstrated during the audit). The permittee also partners with municipalities and organizations to install BMPs outside of the public right-of-way where warranted. Those partnerships are established through a documented MOA/Encroachment Agreement. See Supporting Documents: 1, 7, 8, 13, 14, 15, 16, 23, 29, 30, 31, 32, 34 The permittee maintained a stormwater BMP Toolbox to provide design guidance for post -construction stormwater control measures. Yes 14,19 NCS000250_NCDOT MS4 Audit_20190923 Page 14 of 34 Post -Construction Site Runoff Controls The BMP Toolbox includes appropriate uses/anticipated applications and design 11.B.3.b. a criteria. Yes 14,19 BMP Toolbox Proprietary BMPs are evaluated in keeping with DEMLR requirements for 13,18, permitting new stormwater technologies. Yes 32,34 Comments The permittee maintains a Stormwater BMP Toolbox in an online format to aid in the siting, design and construction of stormwater BMPs. The permittee does not employ proprietary BMPs that have not been tested and approved. NCDEQ staff have approved retrofit credits for specific practices/devices. II.B.3.b.(b) Toolbox Updates The permittee evaluated new BMP types or design components for potential 13, 34, updates to the BMP Toolbox. Yes 46, 50, 51 The permittee updated the BMP Toolbox to include new information (BMP types or design components). Yes 14 Comments The permittee continuously evaluates new BMPs through the Research Program and includes appropriate BMPs in the Toolbox. 11.6.3.b. c The permittee submitted new guidance on proposed BMPs to DEMLR for approval 13,18, DEMLR Approval prior to implementation. 32, 34, Yes 46, 50, 51 Comments The permittee primarily adds new BMPs to the toolbox once they have been evaluated through the Research Program. NCDEQ staff reviewed and approved the BMP Toolbox and PCSP Guidance Document. 11.B.4.b. a Needs Evaluation The permittee evaluated new BMPs included in the BMP Toolbox or otherwise 14, 17, needed for inspection and maintenance needs. Yes 23, 46, 62 If yes, the evaluation included consideration of the BMP type, typical siting 14,17, conditions, and expected function. Yes 23,46 Comments The permittee evaluates new BMPs through the Research Program to determine design, operation and maintenance criteria prior to inclusion in the BMP Toolbox and implementation. II.B.4.b. b The permittee maintained written procedures outlining the inspection and 17 19, BMP Inspection & maintenance requirements for various types of stormwater BMPs. Yes ' 20, 44 Maintenance Manual If yes, the written procedures outline the regular inspection frequency, and include an inspection checklist, "how-to" instructions for regular maintenance, evaluation and reporting procedures for non -routine maintenance, and an Yes 17, 20 inspection and maintenance tracking mechanism. If yes, the permittee updates the Manual to address needed changes to inspection and maintenance techniques as modifications are needed. Yes 17 NC5000250 NCDOT MS4 Audit_20190923 Page 15 of 34 Post -Construction Site Runoff Controls Comments The permittee maintains an SCM Inspection and Maintenance Manual which includes standard documentation of inspections and maintenance in the online Stormwater Control Management System (SCMS), maintenance requirements for various BMPs, inspection frequencies, level of service ratings, etc. The manual was last updated in May of 2015. 11.B.4.b. c 16, 17, BMP Inspection & The permittee implemented a BMP Inspection and Maintenance Program. Yes 19, 20, Maintenance 35,44 Program If yes, the program includes annual training for appropriate NCDOT staff and 20, 21, contractors. Partial 22, 36, 37 Comments The permittee implements a documented and tracked BMP Inspection and Maintenance Program and supplies staff with a Field Guide for Post -Construction Stormwater Best Management Practices which addresses common issues and is readily deployed in the field due to its pocket size. Tools provide general guidance and information on performing and documenting inspections and maintenance. New staff receive a full day of training. Existing staff receive annual/refresher training. Training events are documented by agenda and program attendee roster. However, documentation of specific annual and refresher training for staff was not tracked and full participation in webinar training events is not tracked, although registrants/logins are. II.B.4.b. d BMP Inspection & The permittee made BMP Inspection and Maintenance Program information Maintenance available to DEMLR upon request. Yes --- Information Comments The permittee readily provided the requested information. II.B.S.b. a 5, 14, 16, PCSP Program The permittee implemented a Post -Construction Stormwater Program (PCSP) to 18, 19, control runoff from new NCDOT development and redevelopment. Yes 50, 51, 59 If yes, the PCSP defined implementation of the approved NCDOT BMP Toolbox and post -construction stormwater control measures. Yes --- Comments The permittee implements a post -construction stormwater program to regulate stormwater from new NCDOT development and redevelopment for new built upon area. The program is implemented for two project types (roadway and non -roadway) and includes appropriate work flows for each type, planning measures to minimize impacts, appropriate design measures, a BMP decision support matrix, and integrated project delivery. Tools include Guidelines for Drainage Studies and Hydraulic Design, the BMP Toolbox, a project -specific Stormwater Management Plan, and SCMS. The permittee also employs a merger process for regulatory agencies to concurrently participate in optimal solution development and an Integrated Project Delivery initiative to integrate PCSP and stormwater management decisions earlier in the process. NCS000250_NCDOT MS4 Audit_20190923 Page 16 of 34 Post -Construction Site Runoff Controls II.B.S.b.(b) 13, 18, PCSP Revision The permittee submitted updates and/or revisions to DEMUR for approval prior to 32, 33, Approval implementation. Yes 34, 50, 51 Comments The permittee has routinely engaged NCDEQ in the update/revision process through joint review/comments from DEMUR and DWR prior to implementation. II.B.6.b. a The permittee continued to consult with North Carolina Department of Agriculture Pest Control and Consumer Services (NCDA&CS) and North Carolina State University (NCSU), as needed, in selecting appropriate pest control methods and implementation Yes 6,54 practices. The permittee maintained and updated the NCDOT Roadside Vegetation Management Manual (RVMM) as new methods and practices are adopted by Yes 6,54 NCDOT. Comments The permittee provides annual training for personnel and contractors, and materials are limited to those approved by EPA and NCDA through central purchasing. Statewide training and certification is based upon NCSU and NC Vegetation Management Association manuals and guidance. The NCDA licensing system is relied upon, which notifies staff and tracks certification requirements. The permittee pays for licensing and continuing education for certified applicators. The Vegetation Management Manual has been updated twice, most recently in November 2017. Specific measures have included invasive species management and control, as well as selection of appropriate ground covers to minimize routine maintenance activities. Researchers provide quarterly reports. However, ongoing consultation/coordination is not specifically tracked/documented. The permittee restricted pesticide and fertilizer usage to those materials approved by EPA/NCDA&CS. Yes 54 The permittee used pesticide and fertilizer in accordance with label restrictions. Yes 54 Comments Products are limited to those approved by EPA and NCDA through central purchasing. Central purchasing only bids approved products and has inventory controls in place. Only certified applicators may access and apply chemicals. II.B.6.b. c The permittee provided annual training for vegetation management personnel and Vegetation contractors, or requires equivalent training for contractors. Partial --- Management Training If yes, the training consists of appropriate uses and applications of pest control methods used by NCDOT Yes --- If yes, the training is designed to increase awareness of proper mowing techniques, release of biological and chemical agents, appropriate spill response, the correct use and handling of products and the potential for water quality Yes --- impacts NC5000250_NCD0T MS4 Audit 20190923 Page 17 of 34 I Post -Construction Site Runoff Controls I The permittee limits materials to those approved by EPA and NCDA through central purchasing. Statewide training and certification is based upon NCSU and NC Vegetation Management Association manuals and guidance. The NCDA licensing system is relied upon, which notifies staff and tracks certification and continuing education requirements directly. The permittee pays for licensing and continuing education for certified applicators. The permittee does not specifically track training and certification of individual staff, but relies upon NCDAs tracking system. Staff are required to carry their certification card at all times. This space intentionally left blank NCS000250_NCDOT MS4 Audit_20190923 Page 18 of 34 Post -Construction Site Runoff Controls Additional The permittee implements a post -construction stormwater program to regulate stormwater from new NCDOT Comments: development and redevelopment for new built upon area. The program is implemented for two project types (roadway and non -roadway) and includes appropriate work flows for each type, planning measures to minimize impacts, appropriate design measures, a BMP decision support matrix, and integrated project delivery. Tools include Guidelines for Drainage Studies and Hydraulic Design, the BMP Toolbox, a project -specific Stormwater Management Plan, and SCMS. The permittee also employs a merger process for regulatory agencies to concurrently participate in optimal solution development and an Integrated Project Delivery initiative to integrate PCSP and stormwater management decisions earlier in the process. The post -construction stormwater program encompasses a number of components: Outfall Inventory The permittee maintains a GIS database of implicit outfalls with a separate layer for industrial facility outfalls. Standard procedures and guidance on outfall identification are in place. Retrofits The retrofit program is well established and is on track to implement the required number of retrofits by the end of the permit term. The permittee employs the NCDOT Hydraulics Retrofit Site Selection (ROSS) Program geospatial tool, online Stormwater Control Management System (SCMS) tool, and online BMP Toolbox to implement this program (demonstrated during the audit). BMP Toolbox The online NCDOT BMP Toolbox aids in the siting, design and construction of stormwater BMPs. The permittee does not employ proprietary BMPs that have not been tested and approved. The BMP Toolbox continues to be developed and includes appropriate devices from the Research Program. The permittee should work with the NCDEQ to better define "proprietary" devices and the associated NCDEQ approval process, as the two agencies employ different definitions of "proprietary". BMP Inspection & Maintenance The permittee employs the SCM Inspection and Maintenance Manual, online Stormwater Control Management System (SCMS), and Field Guide for Post -Construction Stormwater Best Management Practices to establish standardized inspections and maintenance. The permittee should work on better documenting specific annual and refresher training for staff, including participation in webinars rather than just login. Pest Control & Vegetation Management The permittee provides annual training for personnel and contractors, and materials are limited to EPA and NCDA approved chemicals available through central purchasing. The NCDA licensing system is relied upon, which notifies staff and tracks certification requirements. The Vegetation Management Manual has been updated twice, most recently in November 2017. Specific measures have included invasive species management and control, as well as selection of appropriate ground covers to minimize routine maintenance activities. Researchers provide quarterly reports. However, ongoing consultation/coordination is not specifically tracked/documented. It is recommended that the permittee include verification of staff NCDA certification and continuing education requirements as part of the annual VIP review process for relevant staff, rather than rely solely on the NCDA tracking system and individual staff accountability. Consultations with NCDA and NCSU should be documented. See Supporting Documents: 1, 5-8, 13-23, 29-37, 44, 46, 50, 51, 54, 59, 62 NCS000250_NCDOT MS4 Audit_20190923 Page 19 of 34 Construction Site Runoff Controls Staff Interviewed: See Page 2 (Name, Title, Role) 09J23/19 Attendees Program Delegation Status: ® The permittee has a delegated Sediment and Erosion Control Program and implements the North Carolina Sedimentation Pollution Control Act (SPCA) of 1973 components of this minimum measure (complete the permit citation and SPCA citation sections). ❑ The permittee does not have a delegated Sediment and Erosion Control Program and relies on DEMLR to comply with the North Carolina Sedimentation Pollution Control Act (SPCA) of 1973 components of this minimum measure (complete only the permit citation section). Permit Citation Program Requirement Status Supporting Doc No. II.C.l.a. Sediment & Erosion The permittee controls development activities disturbing one or more acres of land 64, Control Program surface, including activities by NCDOT contractors. Yes App C The permittee requires construction site operators to implement appropriate 64, erosion and sediment control practices. Yes App. C The permittee requires site inspection and enforcement of control measures. Yes 64, App. C The permittee has established requirements for construction site operators to control waste that may cause adverse impacts to water quality such as discarded 64, building materials, concrete truck washout, chemicals, litter, and sanitary waste at Yes App. C construction sites. Comments The permittee implements a delegated program that is reviewed by NCDEQ annually. The program status is reported to the Sedimentation Control Commission annually. The program delegation includes plan review and approval, self -inspection, and a standard enforcement/escalation process. The permittee requires contractors to perform weekly inspections and performs monthly inspections to ensure compliance. NCGO10000 requirements for ground cover and waste management are included in standard contract language for all construction projects. See comments at end of this section. NCS000250_NCDOT MS4 Audit 20190923 Page 20 of 34 Construction Site Runoff Controls II.C.i.b.i. The permittee implements the NCDENR Division of Energy, Mineral and Land Delegated Program Resources Erosion and Sediment Control Program delegated to NCDOT by the 64, Implementation Sedimentation Control Commission in February, 1991, and as maybe subsequently C amended. IApp. If yes, this program includes procedures for public input, sanctions to ensure compliance, requirements for construction site operators to implement appropriate erosion and sediment control practices, review of site plans which Yes 27, 64, incorporates consideration of potential water quality impacts, and procedures App. C for site inspection and enforcement of control measures. Comments The permittee implements a compliant program with standardized requirements and sanctions. See recommendations at the end of this section. II.C.i.b.ii. The permittee incorporated the applicable requirements of NCG010000, the North NCG010000 Carolina General Permit to Discharge Stormwater under the National Pollutant Implementation Discharge Elimination System associated with construction activities issued August 3, 2011 and as may be subsequently amended, into its delegated Erosion and Sediment Control Program, pursuant to "NCDOT Applicable Requirement from Yes 28 NPDES General Permit No. NCG010000 for Construction Activities and Guidance for Complying with Those Applicable Requirements" in the memorandum dated June 9, 2014 or as updated. Comments Applicable requirements are addressed through standardized language in the contract special provisions. II.C.2.b. a Sediment & Erosion The permittee implements erosion and sediment control measures on all non - Control for Borrow commercial borrow pit and waste pile projects. Yes 48,49 Pits/Waste Piles If yes, the measures are in keeping with the erosion and sediment control 48, 49, program established by the North Carolina Sedimentation Control Commission. Yes 64 Comments The permittee implements an approved Borrow Pit/Waste Pile Reclamation Plan and Borrow Pit Discharge Management Plan. NCS000250_NCDOT MS4 Audit_20190923 Page 21 of 34 Construction Site Runoff Controls II.C.2.b. b Reclamation Plans The permittee implements the approved reclamation plan on all non-commercial for Borrow borrow pit/waste pile projects. Yes 48,49 Pits/Waste Piles If yes, the reclamation measures are in keeping with the reclamation program established by the North Carolina Mining and Energy Commission. yes 48, 49 Comments The permittee implements an approved Borrow Pit/Waste Pile Reclamation Plan and Borrow Pit Discharge Management Plan. II.C.2.b. c Borrow Pit The permittee implements the Borrow Pit Discharge Management Program in Discharge coordination with DEMLR. Yes 48,49 Management Program If yes, this process consists of the following tasks: • Implement appropriate management measures to treat borrow pit wastewater for given conditions. • Implement an inspection and maintenance program. Yes 48,49 • Maintain training material and instruct field personnel overseeing borrow pit operations. • Evaluate and implement appropriate new/innovative technologies. Comments The permittee implements an approved Borrow Pit/Waste Pile Reclamation Plan and Borrow Pit Discharge Management Plan. II.C.3 Borrow Pit Discharge The permittee provides DEMLR with a list of all new and completed construction Management and borrow pit/waste pile activities subject to this permit upon request. Yes 26 Program Comments The permittee maintains a list of current borrow pits/waste piles. NCS000250_NCDOT MS4 Audit_20190923 Page 22 of 34 Construction Site Runoff Controls Additional The permittee implements a delegated program that is reviewed by NCDEQ and reported to the Sedimentation Comments: Control Commission (SCC) annually. The SCC reviewed and reauthorized the permittee's delegated program on November 4, 2019. NCGO10000 requirements for ground cover and waste management are included in standard contract language for all construction projects. The permittee also implements an approved Borrow Pit/Waste Pile Reclamation Plan and Borrow Pit Discharge Management Plan. Per the 2019 Review of Erosion and Sedimentation Control Program Delegation report, it is recommended that the permittee evaluate and implement appropriate protocols for required plan revisions, designated concrete washout areas, construction site fuel tank storage and containment, and maintenance of measure sin inactive project areas. Per inspection of specific sites, as provided in Appendix C, it is recommended that: • The REU ESC/Stormwater report form be updated to clearly indicate when a project is not in compliance with NCG010000. Construction site inspectors should also be familiar with MS4 and SPCC requirements for housekeeping, fuel storage, preventive maintenance, etc. See Buncombe County Construction Inspection_20190625. • Concrete washout pits should be lined and required reporting to NCDEQ should be documented. See Guilford County Construction Inspection_20190816. • All areas on site should be inspected and documented, including staging and parking areas. Forms could be more clear and issues should be photo -documented. See McDowell County Construction Inspection_20190603 and Wake County Construction Inspection_20190812. See Supporting Documents: 1, 23, 26 — 28, 48, 49, 52, 53, 58, 61, 64, Appendix C NCS000250_NCDOT MS4 Audit_20190923 Page 23 of 34 Industrial Activities Staff Interviewed: See Page 2 (Name, Title, Role) 09/24/19 Attendees Permit Citation Program Requirement Status supporting Doc No. II.D.i.b. Facility SPPPs The permittee maintained a site specific Stormwater Pollution Prevention Plan (SPPP) for each covered facility with an industrial activity. yes 39-41 If yes, the permittee implemented a site specific Stormwater Pollution Prevention Plan (SPPP) for each facility with an industrial activity. Yes 39 41 The permittee developed the SPPP for new activities or facilities prior to operation. Yes 39-01 The permittee identified new activities and facilities in the annual report, including Not a brief description and location information. Applicable Comments NCDOT industrial activities covered under this permit include ferry terminals, vehicle maintenance areas and mining activities which would typically be permitted under NCG020000 and NCGO80000. The permittee maintains a list of these facilities and reviews/updates SPPPs on an annual basis. Eight maintenance facilities were inspected statewide (See Appendix B). Each inspected site had appropriate training and documentation available. II.D.2.a. SPPP Requirements The SPPPs meet the minimum requirements for Stormwater Pollution Prevention Plans for Industrial Activities (see permit). yes 39-41 Comments The permittee utilizes a standard SPPP template to develop a site -specific SPPP for each industrial facility. Eight maintenance facilities were inspected statewide (See Appendix B). Each inspected site had an appropriate SPPP and associated documentation available. Additional The permittee has over 200 industrial facilities which include maintenance yards, remote storage areas, Comments: equipment depots, a rail maintenance yard, a ferry maintenance shipyard, ferry terminals, and an asphalt plant. Maintenance yards can include areas for highway, bridge, roadside environmental, traffic services, and vehicle and equipment maintenance. A random sample of eight facilities were inspected during the audit (see Appendix B). The Resident Engineer ensures that appropriate permits are in place and there is a SPPP Team at each facility. The permittee has a standard SPPP Template which is comprehensive, includes annual plan review and team member consultations, and integrates SPCC requirements where applicable. A SPPP binder is maintained on site at each facility. See Supporting Documents: 1, 23, 39-41, 45, 47, Appendix B NCS000250_NCDOT MS4 Audit_20190923 Page 24 of 34 Internal Education and Involvement Program Staff Interviewed: See Page 2 (Name, Title, Role) 09/24/19 Attendees Permit Citation Program Requirement Status supporting Doc No. II.E.1.b. a The permittee provided, or required contractors to have equivalent training in lieu of Pollution NCDOT-provided training, annual stormwater pollution awareness training for Prevention appropriate NCDOT personnel and contractors involved in construction and Yes i, 42 Awareness maintenance activities. Training for If yes, training included general stormwater awareness, NPDES stormwater permit Construction NCG010000 implementation, identification of stormwater pollution potential, Workers appropriate spill response actions and contacts for reporting spills and illicit Yes 1,42 discharges/illegal dumping Comments The permittee implements a comprehensive internal education program that includes topics such as the importance of stormwater quality, spill control, chemical application, illicit discharges, illegal dumping, research results, etc. The program also includes training materials and tools. The program is documented in the Internal Education Plan and reported in Table 5 of the Annual Report. II.E.1.b. b The permittee maintained a program of annual stormwater pollution awareness Pollution training for appropriate NCDOT maintenance staff. NCDOT may require contractors Yes 1,42 Prevention to have equivalent training in lieu of NCDOT-provided training. Awareness If yes, training included general stormwater awareness, identification of Training for stormwater pollution potential and appropriate contacts for reporting spills and Yes 1,42 Maintenance illicit discharges /illegal dumping. Workers The permittee maintained an ongoing awareness program for Adopt -A -Highway volunteers and prison inmate laborers. Yes 43 Comments The permittee implements a comprehensive internal education program that includes topics such as the importance of stormwater quality, spill control, chemical application, illicit discharges, illegal dumping, research results, etc. The program also includes training materials and tools. The program is documented in the Internal Education Plan and reported in Table 5 of the Annual Report. The permittee provides an ongoing awareness program for Adopt -A -Highway volunteers under the External Education Plan evaluated in the next section of this audit report. The permittee has discontinued prison inmate labor due to excessive costs. II.E.l.b. c Pollution The permittee provided annual Stormwater Pollution Prevention Plan training for 10, il, Prevention appropriate NCDOT staff. Yes 42, App. B Awareness If yes, training included general stormwater pollution awareness, site -specific Training for Stormwater Pollution Prevention Plan awareness, and reporting/documentation Yes App. B NCDOT Staff procedures. Comments Multiple staff training opportunities are employed including videos, IRMA, Level 1 and 2 NCDOT, SPPP/SPCC web site, etc. Eight industrial facilities were inspected as part of this audit, and all had appropriate SPPPs, training and documentation (see Appendix B). NCS000250_NCDOT MS4 Audit_20190923 Page 25 of 34 Internal Education and Involvement Program 14, 16, The permittee provided training to appropriate NCDOT personnel on implementation 17,19, II.E.l.b. d of post -construction BMPs. NCDOT may require contractors to have equivalent Yes 20, 36, BMP training in lieu of NCDOT-provided training. 87 44 Implementation 45 Training If yes, training was in keeping with the Toolbox, Inspection and Maintenance Manual, and the Post -Construction Stormwater Program. Yes --- Comments The permittee maintains a Stormwater BMP Toolbox in an online format to aid in the siting, design and construction of stormwater BMPs. The permittee maintains an SCM Inspection and Maintenance Manual which includes standard documentation of inspections and maintenance in the online Stormwater Control Management System (SCMS), maintenance requirements for various BMPs, inspection frequencies, level of service ratings, etc. The manual was last updated in May of 2015. The permittee implements a documented and tracked BMP Inspection and Maintenance Program and supplies staff with a Field Guide for Post - Construction Stormwater Best Management Practices which addresses common issues and is readily deployed in the field due to its pocket size. Tools provide general guidance and information on performing and documenting inspections and maintenance. New staff receive a full day of training. Existing staff receive annual/refresher training. Training events are documented by agenda and program attendee roster. However, documentation of specific annual and refresher training for staff was not tracked and full participation in webinar training events is not tracked, although registrants/logins are. II.E.S.b. a The permittee maintained the Internal Education and Involvement Plan. Yes 42 Education and Involvement Plan If yes, the plan includes the requirements for the Internal Education and Involvement Program as listed above. Yes 42 Comments The permittee implements a comprehensive internal education program that includes topics such as the importance of stormwater quality, spill control, chemical application, illicit discharges, illegal dumping, research results, etc. the program also includes training materials and tools. The Internal Education Plan was last updated in September of 2019. II.B.2.e informational The permittee promoted and maintained an internet web site designed to convey the Web Site program's message. Yes --- Comments (list web page address and general contents, or attach screen shot of landing page) The permittee's NCDOT Stormwater Management Program web page includes comprehensive information including general stormwater awareness, prevention and reporting. https.lwww. ncdot. gov/initiatives-policies/environmental/storm water/Pages/default. aspx II.B.2.f Public Education The permittee distributed stormwater educational material to a p appropriate target Materials groups. Yes 1, 42, 43 Comments The permittee implements a comprehensive internal and external education program, both of which are designed to address all permit requirements for education. NCS000250_NCDOT MS4 Audit_20190923 Page 26 of 34 Internal Education and Involvement Program II.B.2.e The permittee promoted and maintained a stormwater hotline/helpline for the Hotline/Help Line purpose of public education and outreach. Yes 10 Comments The permittee's Stormwater Management Program landing page includes general stormwater awareness information and a mechanism to report illicit discharges and illegal dumping. The NCDOT main page includes a one -click reporting mechanism for drainage and other issues as well as a one -click mechanism to ask NCDOT a question, which is routed to the appropriate contact for response. Information is also circulated in brochures placed at highway rest stops. II.B.2.h The permittee's outreach program, including those elements implemented locally or Public Education through a cooperative agreement, included a combination of approaches designed to Yes 1, 42, 43 and Outreach reach the target audiences. Program For each media, event or activity, including those elements implemented locally or through a cooperative agreement the permittee estimated and recorded the extent Partial --- of exposure. Comments The permittee's internal education program includes a broad variety of education and outreach which includes, posters, brochures, training, certifications, webinars, conferences, manuals, guidance documents, etc. Internal training is tracked and documented. External training is evaluated in the following section. Additional Comments: The permittee implements and documents a comprehensive internal training and education program. A variety of resources are utilized including Level I — II certifications, webinars, AASTO training, conferences, posters, guidance manuals, flip/pocket guides, etc. Staff training/education is tracked in the online Learning Management System or in training logs. See Supporting Documents: 1, 10, 11, 14, 16, 17, 19, 20, 21, 22, 23, 36, 37, 42, 43, 44, 45 NCS000250_NCDOT MS4 Audit_20190923 Page 27 of 34 External Public Education and Involvement Program Staff Interviewed: See Page 2 (Name, Title, Role) 09/24/19 Attendees Permit Citation Program Requirement Status supporting Doc No. II.E.2.b. a External Education The permittee maintained the External Education and Involvement Plan. Yes 1,43 & Involvement Plan If yes, the plan included the requirements for the measurable goals. Yes --- Comments The permittee's External Education Plan (EEP) was last updated April 2015. The plan addresses permit requirements to educate the public, maintain diverse materials and encourage public involvement. Activities performed under the EEP are documented in the annual report. II.E.2.b. b The permittee provided stormwater pollution prevention awareness information to Pollution the general public. 1,10, Prevention Yes 11,43 Awareness Comments The permittee provides a variety of classroom presentations, and displays informational brochures at rest areas, welcome centers and the state fair. The permittee maintains stormwater awareness and reporting information on various web pages including Stormwater Management Program, Adopt -A -Highway, Sponsor -A -Highway, Swat -A -Litterbug, Educator Resources, HSP Connect, etc. II.E.2.b. c The permittee maintained a public education webs ite to document NCDOT pollution Public Education prevention programs and promote stormwater quality. Yes --- Web Site If yes, the website included information on stormwater, water quality, stormwater projects and activities, and ways to contact stormwater management program Yes --- staff. Comments The permittee maintains stormwater awareness and reporting information on various web pages including Stormwater Management Program, Adopt -A -Highway, Sponsor -A -Highway, Swat -A -Litterbug, Educator Resources, HSP Connect, etc. II.E.2.b. d Educational The permittee worked with DEQ and other agencies to promote and distribute public education materials. E T--- Partnerships Comments The permittee works with other entities to promote stormwater awareness and distribute educational materials. The permittee maintains partnerships and working relationships with the Office of Educational Initiatives, Little Alamance Creek Partnership, Clean Jordan Lake, etc. NCS000250_NCD0T MS4 Audit_20190923 Page 28 of 34 External Public Education and Involvement Program II.E.2.b. e Public The permittee continued the Adopt -a -Highway Program. Additional programs may Involvement also be developed. Yes --- Programs Comments The Adopt -A -Highway program has been maintained continuously since its inception in 1988, with the goals of removing litter from roadsides and educating the public about the importance of proper trash disposal. Over 120,000 participants, including 4,700 civic and community groups across the state, have joined the program to clean up 2-mile segments of local highways four times per year. The program covers approximately 9,000 road miles and typically removes 3.5M pounds of trash per year. Additional The permittee implements a variety of public engagement and education activities including Adopt -A - Comments: Highway, Sponsor -A -Highway, Swat -A -Litterbug, resources for the Education Initiatives Program that engages students, and brochures disseminated at rest areas, welcome centers and the state fair. It is recommended that the permittee track the extent of activities, which could include tracking inventory through orders/printing and distribution at individual locations. See Supporting Documents; 1, 10, 11, 23, 43, 63 NCS000250_NCDOT MS4 Audit_20190923 Page 29 of 34 Research Program Staff Interviewed: See Page 2 (Name, Title, Role) 09/24/19 Attendees Permit Citation Program Requirement Status supporting Doc No. II.F.2.a. Research Plan The permittee maintained a Research Plan. Yes 45 If yes, the Plan is in keeping with the guidelines established by the Federal Highway Administration (FHWA) Evaluation and Management of Highway Runoff Water Quality Manual (FHWA-PD-96-032) and FHWA's National Highway Runoff Yes --- and Data Methodology Synthesis (FHWA-EP-03-054, or any updates. If yes, the Plan includes a description of the Research Program and process for requesting funding. Yes If yes, the Plan includes a process that identifies research needs in order to improve program areas. Yes --- Comments The permittee implements an extensive research program in keeping with the permit requirements and FHWA guidelines. The Quality Assurance Project Plan and Highway Stormwater Program Research Plan Term IV (2015-2020) establish the program, processes and analysis, as well as identified potential funding sources. II.F.2.b. Research Plan The permittee submitted modifications to the NCDOT Research Plan to DEMLR. Not Submittal Applicable Comments II.F.2.c. Research Plan The permittee continued to perform and sponsor research to fulfill the Research Plan. Yes --- Implementation Comments. The permittee develops and implements a research plan for each permit term. NCS000250_NCDOT MS4 Audit_20190923 Page 30 of 34 Research Program Additional The permittee implements a comprehensive applied research program which includes identification of Comments: industry needs and emerging issues, periodic meetings with and reports from researchers, ranking of proposals by committee, etc. The research guides development of the permittee's BMP Toolbox, including design, operation and maintenance requirements. Research is tracked/cataloged in the STORMDATA database. See Supporting Documents: 1, 23, 46, 62 NCS000250_NCDOT MS4 Audit_20190923 Page 31 of 34 APPENDIX A: SUPPORTING DOCUMENTS THE SUPPORTING DOCUMENTS LISTED ON PAGES 2-5 CAN BE FOUND IN THE NCDEQ DWR LASERFICHE PORTAL WaterResourcesIDEMLR - Stormwaterlindividual Permits INCS000250INCS000250_2019 MS4 Audit Files jAppendix A Supporting Documentation NCS000250_NCDOT MS4 Audit_20190923 Page 32 of 34 APPENDIX B: INDUSTRIAL FACILITY INSPECTION REPORTS THE FOLLOWING INSPECTION REPORTS CAN BE FOUND IN THE NCDEQ DWR LASERFICHE PORTAL WoterResourceslDEMLR- Stormwaterllndividual Permits INCS000250 INCS000250 2019 MS4 Audit Files jAppendix 8Industrial Facility Inspection Reports Inspection Date Site Inspected 06/03/2019 Marion Maintenance Yard 07/01/2019 Wake County Maintenance Storage Yard (Sheep Farm) 08/12/2019 Cumberland Division Maintenance Yard 08/16/2019 Forsyth County Maintenance Yard 08/22/2019 New Hanover County Maintenance Facility 09/11/2019 Division 10 Maintenance Yard 10/04/2019 Mann's Harbor Ferry Maintenance Facility 10/08/2019 Capital Yard Maintenance Facility NCS000250_NCDOT M54 Audit_20190923 Page 33 of 34 APPENDIX C: CONSTRUCTION SITE INSPECTION REPORTS THE FOLLOWING INSPECTION REPORTS CAN BE FOUND IN THE NCDEQ DWR LASERFICHE PORTAL WaterResourceslDEMLR- Stormwaterlindividual Permits INCS0002501NC5000250 2019 MS4 Audit FileslAppendix CConstruction Site Inspections County Inspection Date Project Inspected Beaufort 05/16/2019 Bridge 249 on S.R. 1336 Martin 05/16/2019 NC 125 Williamston Bypass Buncombe 06/25/2019 1-26Interchange Guilford 08/16/2019 Macy Grove Road Extension Columbus 08/27/2019 US-74/76Interchange New Hanover 08/27/2019 1 Military Cutoff Road Extension Durham 08/28/2019 East End Connector Moore 09/12/2019 Bridge 63 on NC 22 NCS000250_NCDOT MS4 Audit_20190923 Page 34 of 34