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HomeMy WebLinkAboutNCS000434_Requested Documentation_20191202In response to your request for documents for the upcoming Compliance Audit scheduled for December 17, 2019 and December 18, 2019 dated November 12, 2019 following by a telephone conversation clarifying components of the request on November 18, 2019 145317 DC NNO. In 1970, the expenditure by the United States government in meeting the 6 minimum requirements in its infancy was on the order of $4.2981 per mile. In 2019, the expenditure is $24.8679 per mile to basically apply the 6 minimum measures across the United States. In Archdale, the current expenditure in our jurisdiction is $106,656.19 per mile. Our current cumulative since inception has been $848,896.4346 per jurisdictional mile over the last 13 years. Therefore, City of Archdale is at $111,529.01 where 4.3691% is administrative and directives from the Federal Government and State Government. The inclusive pdf transmitted digitally includes: 1) Electronic E-Mail Requesting Documentation dated Friday November 15, 2019, 1 page 2) Printout of electronic request dated November 12, 2019, 2 pages 3) Photograph of UNANNOUCED Compliance Audit Documentation, 2 Binders (SWMP) 4) Index of Unannounced Compliance Documentation Consistent with 12 page Stormwater Management Plan Guidance Document (SWMP) 5) Procedure for Updating UNANNOUNCED Compliance Audit Documentation, Revision 4-29-2019, 3 pages (SWMP) 6) Long Term Planning Document, 30-Plan since inception of ACE Integrated Stormwater Management Program. (SWMP) 7) Annual Report 2019 and 2020 Draft previously submitted to Jeanette Powell, 4 pages a. From: Powell, Jeanette <Jeanette.Powell@ncdenr.gov> Sent: Monday, September 9, 2019 11:08 AM To: DJ Seneres <dseneres@archdale-nc.gov> Subject: Automatic reply: [External] City of Archdale Annual Report - 2019 b. I am currently out of the office assisting with Ocracoke recovery efforts. I have limited access to email, but will do my best to respond to your message as soon as possible. If you need immediate assistance, please contact Paul Clark at 919.707.3640. c. Thanks, 8) Organization Chart, 1 page 9) Working Stormwater Map of City of Archdale —Daily Operations a. Green — Stormwater Devices in City of Archdale b. Yellow — Decks, Additions, Sign Construction c. White — Erosion Control Construction d. Blue — Outfall crossings greater than 12-inches e. Purple — Health Assessment of Waterway Current Results f. Blue Line — 6.02 Miles of Jurisdictional Waterway, Muddy Creek and Caroway Creek DJ Seneres From: Sent: To: Subject: Attachments: Good Morning Mr. Seneres, Wise, Brandon L <brandon.wise@ncdenr.gov> Friday, November 15, 2019 9:29 AM DJ Seneres Archdale (NCS00434) Audit NCS000434_Document Request_20191112.pdf I have attached our official request for the documentation required for the audit of your stormwater permit coming up. You are best that was saved for last so we are looking at the week of December 16th. I am guessing that it will be a two day (or maybe 1 and half day) audit. If you could get the documents to me in the next week or so and also let me know which days work the best for the audit that would be great. Let me know if you have any questions. Thank You, Brandon L. Wise Environmental Specialist - Stormwater Specialist Division of Energy, Mineral, and Land Resources North Carolina Department of Environmental Quality 336.776.9660 Office Brandon.Wise@ncdenr.gov 450 Hanes Mill Road Suite 300 Winston-Salem, NC 27105 `--Nothing Compares-,, Email Cor res(JC•l7Cence f0 and From 1/Saddress !S subject to fhe VCrtll (.%iro(ina 'lublic Pecord�3 %avl and ivav b C?iSC/OSP.(i "G (hird Qaities. 1 ROY COOPER core.,701' MICHAEL S. REGAN secretury S. DANIEL SMITH Dir'eclor City of Archdale Attn: D.J. Seneres, Stormwater Manager 307 Balfour Drive Archdale, North Carolina 27263 NORff'i CAROLINA Environmental Quality November 12, 2019 Subject: COMPLIANCE AUDIT — DOCUMENTATION REQUEST City of Archdale NPDES MS4 Permit No. NCS000434 Guilford & Randolph Counties Dear Permit Holder: The Department of Environmental Quality (DEQ) will be performing a National Pollutant Discharge Elimination System (NPDES) Municipal Separate Storm Sewer System (MS4) Permit Compliance Audit for the subject permit the week of December 16" (please let us know which days that week would be preferred). The audit is expected to take at least two (2) full days. DEQ will determine the scope of the compliance audit based on a review of provided documentation, and a draft agenda will be provided once the scope of the audit has been determined. Please submit the following pen -nit information within seven (7) calendar days: • Current Stormwater Management Plan (SWMP) • Most recent Annual Report • Organizational Chart and a description of stormwater program responsibilities for each party • Map of the MS4 permitted area with receiving waters • Formal agreements with outside entities that implement MS4 Program components All submitted documentation will become a permanent record of the compliance audit. Additional information may be requested prior to, during and/or following the compliance audit. Documentation shall be submitted via e-mail to Brandon. Wise@ncdenr.gov, or to: NCDEQ-DEMLR Stormwater Program Attn: Brandon Wise, Stormwater Specialist 450 West Hanes Mill Road, Suite 300 Winston-Salem, NC 27105 Please ensure that appropriate MS4 staff will be available during the audit to answer questions and provide program implementation, record keeping and compliance information. Please also arrange for an appropriate meeting room that will accommodate your staff, 3 staff members from DEQ, and access to any electronic tools routinely utilized to implement the MS4 Program (e.g. databases, GIS, etc.). D EQ�� oenanmrnr or rnwmmmmw au,nry North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources Winston-Salem Regional Office 1 450 Hanes Mill Road, Suite 300 1 Winston-Salem, North Carolina 27103 336.776.9800 Should you have any questions regarding the scheduled MS4 Permit Compliance Audit, please feel free to contact Brandon Wise at Brandon.Wise@ncdenr.gov or (336) 776-9660. Sincerely, , Brafrdon Wise Stormwater Specialist Land Quality Section Winston-Salem Regional Office cc: Jeanette Powell, DEMLR MS4 Program Coordinator Alain Morman, DEMLR Stormwater Compliance & Enforcement DEMLR NPDES MS4 Permit Laserfiche U u ORGANIZATIONAL CHART- MS4 PRE -AUDIT NPDES PERMIT NCS000434 MAY 15, 2017 NPDES PERMIT NCS000434 DRAFT 2019 NCG01 PERMIT APRIL 1, 2019 FINANCIAL DETAIL SHEETS 50-500 STO RM WATE R ANNUAL NPDES REPORT s l PUBLIC EDUCATION AND OUTREACH PUBLIC INVOLVEMENT AND PARTICIPATION ILLICIT DISCHARGE AND ELIMINATION CONSTRUCTION SITE RUNOFF CONTROL POST -CONSTRUCTION SITE RUNOFF POLLUTION PREVENTION AND GOOD , .. HOUSEKEEPING' PROGRAMS-____J APTE't�15 STORMWATER MANAGEMENT,��� 1 CHAPTER 17 FLOOD DAMAGE PREVENTION I Procedure for Updating UNANNOUNCED Compliance Audit Documentation Revision 4-29-2019 TAB 1— Organizational Chart — MS4 Pre -Audit a) Organizational Chart shall be requested annually from Human Resources, this shall occur each year, the current organizational chart was modified when the Public Works Director retired December 13, 2018 to adjust for re -assignment of duties within the Public Works b) Following the April 11, 2019 MS4 Phase II Permitting Fundamentals Workshop and the April 24, 2019 Annual Erosion and Sedimentation Control Workshop, in addition to the issuance of the April 1, 2019 version of the NCG01 Permit, the current version of the Phase II MS4 Audit Template for Permits Issued Prior to 2019 (or current edition) shall be filled out by the Stormwater Program Manager or his designee. This document shall be maintained as the basis for future NPDES Permits and an annual assessment of the Stormwater Plan (SP) TAB 2 — National Pollutant Discharge Elimination System NCS000434 effective February 20, 2017 a) The National Pollutant Discharge Elimination System Permit signed on March 15, 2017 shall be changed out upon receipt of a new permit issued by the State of North Carolina Department of Environmental Quality, Division of Energy, Mineral and Land Resources. TAB 3-2019 Draft NPDES Phase II MS4 Permit Template a) The National Pollutant Discharge Elimination System Permit draft shall be changed out upon receipt of a new version issued by the State of North Carolina Department of Environmental Quality, Division of Energy, Mineral and Land Resources TAB 4 — 2019 North Carolina Construction General Permit— NCG01 a) The North Carolina Construction General Permit shall be changed out upon receipt of a new version issued by the State of North Carolina Department of Environmental Quality, Division of Energy, Mineral and Land Resources TAB 5 — Financial Detail Sheets 50-500 and Sustainable Financing of ACE Integrated Stormwater Program a) Chapter 14 — An Ordinance to Establish a Stormwater Utility for the City of Archdale. Change out when ordinance is changed by Council Action. No changes have occurred since inception of the program on January 2, 2018. b) Update annual summary of expenses since inception of the program outlining meeting the 6 minimum requirements of the current MS4 Permit. Raw data for summary sheet can be found on the City of Archdale server: a. Shared Folder ( CH-FSI) (S:)\CAFR\Audit Report by Year b. Shared Folder (\CH-FSI) (S:)\Planning\Population Estimates from State Office of Budget and Management\2010's\Year c) Insert summary page from each Annual Audit Stormwater Fund d) Maintain previous five years of expenditures — Each year request a Detail Expenditure Inquiry from Finance; Remove the oldest detail sheet and shred; Add the latest detail sheet requested, thus having 5-years of information available for review by audit personnel meeting the requirements of 5-year retention. TAB 6 — NPDES Annual Report a) Maintain previous five years of Annual NPDES Reports — 2 page summary; Each year print out the previous Annual Report — Jan -Dec; Remove oldest report and shred; Add the newest report, thus having 5 years of information available for review by audit personnel meeting the requirements of 5 year retention b) Print latest version of NC Surface Water Classification for the City of Archdale from the Department of Environmental Quality website (https://ncdenr.maps.arcgis com/apps/webappviewer/index html; id=6el25ad7628f494694e25 9c80dd64265) — Query > Archdale, NC US currently establishing a 5.89 mile reach with a 1.155 sinuosity consisting of 12 segments from origin at northwest corner of the city limits to eastern boundary of city limits TAB 7 Public Education and Outreach a) Maintain summary sheets of previous five years of contracted education and outreach from a minimum of one entity as well as current efforts during current year; Remove oldest report and shred; Add the newest report, thus having 5 years of information available for review by audit personnel meeting the requirements of 5 year retention. TAB 8 Public Involvement and Participation a) Maintain a representative number of Minutes of the Stormwater Advisory Board. Remove the oldest meeting minutes and shred; Add the newest printout, thus having a minimum of 3 calendar years of information available for review by audit personnel meeting the requirements of 5 year retention. b) In addition, telephone conversations and site visits are available through current edition of Microsoft Outlook used by personnel of the City of Archdale. Since inception, the ACE Integrated Stormwater Management Program averages 545.45 telephone calls on the order 15 to 30 minutes per telephone call and a minimum of 234.64 site visits evaluating IDDE and maintenance of stormwater conveyances. This frequency equates to a minimum of 5% of the City annually. This plan has not changed since inception of the program on January 2, 2008 TAB 9 Illicit Discharge and Elimination Program a) Since Inception, the ACE Integrated Stormwater Management Program follows up on a minimum of 5% of the conveyances in the city annually since inception. This documentation is stored in the current version of Microsoft Outlook. Each inquiry related to a call involves using technology to camera the conveyance associated with the investigation. Public Works personnel will access a minimum of one point for review of the subsurface system. Typically, camera work has only revealed root intrusion of separation of pipe joints. No illicit connections have been discovered to date. b) Update Contingency Plan for City of Archdale's Wastewater Collection System, as provided by Public Works. c) Update Wastewater Spill Response Procedure, as provided by Public Works d) Update Illicit Discharge Detection and Elimination; A Guidance Manual for Program Development and Technical Assessments —2004 Edition; Use Guide if requirements exceed contact Guil-Rand Fire Department of City of Archdale sampling capability TAB 10 — Construction Site Runoff Control a) Maintain latest audit results by State of North Carolina, Department of Environmental Quality, Division of Energy, Mineral and Land Resources; Current Audit report January 2, 2017 b) Maintain copy of current year Certificate of Plan Approvals c) All digital drawings maintained on City of Archdale servers TAB 11- Post -Construction Site Runoff a) Request copy of GIS Attribute Table for inclusion in manual b) Visual Map available on computer through GIS access TAB 12 — Pollution Prevention and Good Housekeeping a) Maintain a current copy of Flagger Training, NPDES, and IDDE Sign -In; Due to 9.62 average length of employment of 71 out 91 employees, annual review is a refresher course for personnel employed by City of Archdale b) Request copies of checklists prepared by Department Heads concerning potential stormwater impacts due to operations at site; Note the City does not own any facilities which have a significant impact to water quality; Regular visual inspections around the 8 buildings meets these requirements TAB 13 — Chapter 15 Stormwater Management Ordinance a) Update Ordinance when required. There has been no modification of the Stormwater Model Ordinance suggested by the State of North Carolina since inception on January 2, 2008. TAB 14—Chapter 17 Flood Damage Prevention a) Update Ordinance when required. There has been no modification of this ordinance since re - adoption on January 2, 2008 with the new FIRM Maps in effect. L 1 N:� je r Y 117 y 733 lie h. 1 ! r } k a aol 3 J �• 2-4 wj Jrw;'.a5�tpd.yn+wM irtl�'�'h: �r"' DRAFT to$ 0S./ ?. f. 19 ANNUAL NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM PERMIT NCS00434 REPORT - 2020 (Revised July 27, 2016) Currently, the City of Archdale is located in both Randolph County and Guilford County. The current area and population in Randolph County is 11,733 and Z73 square miles; Guilford County is 372 and 0.92 square miles. [Total is 12,105 and 8.65 square miles] SECTION A: PROGRAM IMPLEMENTATION The City of Archdale currently maintains adequate funding and staffing of the individual components of the ACE Integrated Stormwater Management Plan authorized by the City Council of Archdale during it's regular session on December 18, 2007 upon the recommendations of the then newly established Stormwater Advisory Board - which also acts as a specific conduit for citizen interaction, participation, and involvement - and the current Stormwater Water Program Manager establishing initial authority from the Clean Water Act of 1972. As part of the program, Mr. D. J. Seneres, PE, PWLF conducts a minimum of an annual stop gap analysis using the State Representative, Ms. Jeanette Powell, as a sounding board for upcoming changes related to a long time goal of spreadsheet column generated reporting in a standardized template originating from a Local Government Information Model (LGIM). This stop -gap analysis involves discussing each of the permit requirements establishing compliance has been met for the year. Each year additional concepts are modified to enhance the already existing program. No modifications of the initial ACE Integrated Stormwater Management Plan has occurred since the inception of the program. Current letters approved by the City Attorney for violations indicate that the maximum fine may be up to $51,575. Of course, the biggest challenge continues to be the integration of software and resolving incompatibility issues between sources. SECTION B: PUBLIC EDUCATION AND OUTREACH Through partnerships with the Piedmont Triad Water Quality Partnership, Stormwater Smart Program, City of Archdale Creekside Park, and local schools, public education and outreach continue to be ever present and typically addresses a minimum of four categories. Recognizing the most prolific pollutant in the city is sediment transport, the sediment and erosion control program is an integral part of the stormwater management. Information concerning the program is provided on the dedicated section of the website but the most significant part of the dissemination of information comes from one on one discussions with the citizens of Archdale. The Stormwater Program Manager spends considerable time one on one describing introductions of pollutants into our water system as violations of the Clean Water Act of 1972 and the consequenses of knowingly violating the Environmental Protection Agency guidance. Since inception, 737 permits have been issued with an estimated total of 401.45 acres disturbed (an average of 0.54 acres per site). SECTION C: PUBLIC INVOLVEMENT AND PARTICIPATION The Stormwater Advisory Board which meets a minimum of four times a year with the ability to call special meetings continues to address changes associated with the Environmental Protection Agency guidance and the State of North Carolina guidance. The Bush Hill Heritage Festival acts as our largest gathering each year to provide information. With a minimum reported interaction of 11,585 people, we estimate that we annually reinforce the importance of the ACE Integrated Stormwater Management Plan to approximately 95.70 percent of our population. Flyers are available all year round in the main lobby of City Hall, the Stormwater Program Managers' office, and other locations as the opportunity presents itself. The Stormwater Program Manager maintains his personal cell phone as a Hotline for citizens in addition to the Customer Service number. Because the City of Archdale is a relatively small municipality, all activities related to environmental stewardship can always be associated with an overall improvement of the system. Over the years, through education and outreach, citizens call in when they notice inconsistencies in conflict with the ACE Integrated Stormwater Management Plan and the overall charge of the Clean Water Act of 1972. SECTION D: ILLICIT DISCHARGE DETECTION AND ELIMINATION (IDDE) Our best quantitative measure to date is no recorded repeat calls associated with the same act and our most reported IDDE offense is concentrated flow from downspout gutters directed perpendicular to a lot line. Since inception, we take advantage of dry weather during daily rounds to identify sources of flow as well as reports from citizens. The City of Archdale continues to foster good communication between upper management as related to the pollution prevention and environmental stewardship. SECTION E: CONSTRUCTION SITE RUNOFF CONTROLS SECTION F: POST -CONSTRUCTION SITE RUNOFF CONTROLS As indicated earlier in the report, the delegation of the Sediment and Erosion Control is an integral part of our ACE Integrated Stormwater Management Plan. The clear advantage we have is that sites are seen a minimum of five days a week during daily rounds. A current map of the 31 Stormwater Control Measures in the city shows an even distribution along the main corridor of U. S. 311 South — North and South Main Street in Archdale, North Carolina. Based on this current assessment 223.48 acres or 4.03% of the jurisdictional area are designated as SCIVI's. SECTION G: POLLUTION PREVENTION AND GOOD HOUSEKEEPING FOR MUNICIPAL OPERATIONS Public Works Department coordinate regularly with the Stormwater Program Manager. However, typical sources of pollutants that exists for most municipalities do not exist for Archdale. We do not have a Vehicle Fleet Maintenance Facility, Transfer Station, Waste Treatment Facility, or Water Treatment Facility. These types of facilities are outsourced through contracts. We do however, educate personnel on through Human Resources on Personal Protection Equipment and MSDS Uses of Chemicals and storage on site when applicable. SECTION H: TOTAL MAXIMUM DAILY LOADS (TMDLs) No current TMDL exist currently. Currently, there are no waterways in the corporate city limits on the impaired waters list. As indicated above, Third Party inspections is a strategy designed to to expand the efficiency of the program SECTION I: ELECTRONIC REPORTING OF REPORTS [G.S. 143-215.1] Templates continue to be modified for reporting as guidelines continue to change.in accordance with Section A through Section I of our current permit. All raw data is contained on the servers of the City of Archdale as maintained by the Information Technology Manager. ANNUAL NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM PERMIT NCS00434 REPORT-2019 (Revised July 27, 2016) Currently, the City of Archdale is located in both Randolph County and Guilford County. The current area and population in Randolph County is 11,733 and 7.73 square miles; Guilford County is 372 and 0.92 square miles. [Total is 12,105 and 8.65 square miles] SECTION A: PROGRAM IMPLEMENTATION The City of Archdale currently maintains adequate funding and staffing of the individual components of the ACE Integrated Stormwater Management Plan authorized by the City Council of Archdale during it's regular session on December 18, 2007 upon the recommendations of the then newly established Stormwater Advisory Board - which also acts as a specific conduit for citizen interaction, participation, and involvement - and the current Stormwater Water Program Manager establishing initial authority from the Clean Water Act of 1972. As part of the program, Mr. D. J. Seneres, PE, PWLF conducts a minimum of an annual stop gap analysis using the State Representative, Ms. Jeanette Powell, as a sounding board for upcoming changes related to a long time goal of spreadsheet column generated reporting in a standardized template originating from a Local Government Information Model (LGIM). This stop -gap analysis involves discussing each of the permit requirements establishing compliance has been met for the year. Each year additional concepts are modified to enhance the already existing program. No modifications of the initial ACE Integrated Stormwater Management Plan has occurred since the inception of the program. Current letters approved by the City Attorney for violations indicate that the maximum fine may be up to $51,575. Of course, the biggest challenge continues to be the integration of software and resolving incompatibility issues between sources. SECTION B: PUBLIC EDUCATION AND OUTREACH Through partnerships with the Piedmont Triad Water Quality Partnership, Stormwater Smart Program, City of Archdale Creekside Park, and local schools, public education and outreach continue to be ever present and typically addresses a minimum of four categories. Recognizing the most prolific pollutant in the city is sediment transport, the sediment and erosion control program is an integral part of the stormwater management. Information concerning the program is provided on the dedicated section of the website but the most significant part of the dissemination of information comes from one on one discussions with the citizens of Archdale. The Stormwater Program Manager spends considerable time one on one describing introductions of pollutants into our water system as violations of the Clean Water Act of 1972 and the consequenses of knowingly violating the Environmental Protection Agency guidance. Since inception, 730 permits have been issued with an estimated total of 399.25 acres disturbed (an average of 0.54 acres per site). SECTION C: PUBLIC INVOLVEMENT AND PARTICIPATION The Stormwater Advisory Board which meets a minimum of four times a year with the ability to call special meetings continues to address changes associated with the Environmental Protection Agency guidance and the State of North Carolina guidance. The Bush Hill Heritage Festival acts as our largest gathering each year to provide information. With a minimum reported interaction of 11,585 people, we estimate that we annually reinforce the importance of the ACE Integrated Stormwater Management Plan to approximately 95.70 percent of our population. Flyers are available all year round in the main lobby of City Hall, the Stormwater Program Managers' office, and other locations as the opportunity presents itself. The Stormwater Program Manager maintains his personal cell phone as a Hotline for citizens in addition to the Customer Service number. Because the City of Archdale is a relatively small municipality, all activities related to environmental stewardship can always be associated with an overall improvement of the system. Over the years, through education and outreach, citizens call in when they notice inconsistencies in conflict with the ACE Integrated Stormwater Management Plan and the overall charge of the Clean Water Act of 1972. SECTION D: ILLICIT DISCHARGE DETECTION AND ELIMINATION (IDDE) Our best quantitative measure to date is no recorded repeat calls associated with the same act and our most reported IDDE offense is concentrated flow from downspout gutters directed perpendicular to a lot line. Since inception, we take advantage of dry weather during daily rounds to identify sources of flow as well as reports from citizens. The City of Archdale continues to foster good communication between upper management as related to the pollution prevention and environmental stewardship. SECTION E: CONSTRUCTION SITE RUNOFF CONTROLS SECTION F: POST -CONSTRUCTION SITE RUNOFF CONTROLS As indicated earlier in the report, the delegation of the Sediment and Erosion Control is an integral part of our ACE Integrated Stormwater Management Plan. The clear advantage we have is that sites are seen a minimum of five days a week during daily rounds. A current map of the 31 Stormwater Control Measures in the city shows an even distribution along the main corridor of U. S. 311 South — North and South Main Street in Archdale, North Carolina. Based on this current assessment 223.48 acres or 4.03% of the jurisdictional area are designated as SCM's. SECTION G: POLLUTION PREVENTION AND GOOD HOUSEKEEPING FOR MUNICIPAL OPERATIONS Public Works Department coordinate regularly with the Stormwater Program Manager. However, typical sources of pollutants that exists for most municipalities do not exist for Archdale. We do not have a Vehicle Fleet Maintenance Facility, Transfer Station, Waste Treatment Facility, or Water Treatment Facility. These types of facilities are outsourced through contracts. We do however, educate personnel on through Human Resources on Personal Protection Equipment and MSDS Uses of Chemicals and storage on site when applicable. SECTION H: TOTAL MAXIMUM DAILY LOADS (TMDLs) No current TMDL exist currently. Currently, there are no waterways in the corporate city limits on the impaired waters list. As indicated above, Third Party inspections is a strategy designed to to expand the efficiency of the program SECTION I: ELECTRONIC REPORTING OF REPORTS [G.S. 143-215.11 Templates continue to be modified for reporting as guidelines continue to change.in accordance with Section A through Section I of our current permit. All raw data is contained on the servers of the City of Archdale as maintained by the Information Technology Manager. Mw