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Home My WebLink AboutNCS000434_Archdale MS4 AUDIT REPORT_20200217MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) PROGRAM AUDIT REPORT NPDES PERMIT NO. NCS000434 ARCHDALE, NORTH CAROLINA 307 BALFOUR DRIVE, ARCHDALE, NC 27263 Audit Date: 12/17/2019 Report Date: 02/17/2020 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) NCS000434 Archdale MS4 Audit 20200217 TABLE OF CONTENTS AuditDetails..................................................................................................................................................1 PermitteeInformation..................................................................................................................................2 Listof Supporting Documents.......................................................................................................................3 Program Implementation, Documentation & Assessment...........................................................................4 Public Education and Outreach.....................................................................................................................8 Public Involvement and Participation.........................................................................................................11 Illicit Discharge Detection and Elimination(IDDE)......................................................................................13 Construction Site Runoff Controls..............................................................................................................16 Site Visit Evaluation: MS4 Outfall No. 1......................................................................................................19 Site Visit Evaluation: MS4 Outfall No. 2......................................................................................................21 Site Visit Evaluation: Construction Site No. 1.............................................................................................23 Site Visit Evaluation: Construction Site No. 2.............................................................................................2S Appendix A: Supporting Documents 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. NCS000434 Archdale MS4 Audit 20200217 ii This page intentionally left blank NCS000434 Archdale MS4 Audit 20200217 Audit Details Audit ID Number: Audit Date(s): NCS000434_Archdale MS4 Audit_20200217 December 17, 2019 Minimum Control Measures Evaluated: ❑X Program Implementation, Documentation & Assessment ❑X Public Education & Outreach ❑X Public Involvement & Participation ❑X Illicit Discharge Detection & Elimination ❑ Construction Site Runoff Controls - No delegated Sediment and Erosion Control Program ❑X 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. ❑X MS4 Outfalls. Number visited: 2 ❑X Construction Sites. Number visited: 2 ❑ 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 Organization Brandon Wise, Stormwater Specialist NCDEQ- Winston-Salem Regional Office Zac Lentz, Associate Regional Engineer NCDEQ- Winston-Salem Regional Office Kimberley Turney, Environmental Specialist NCDEQ- Winston-Salem Regional Office Audit Report Author: - Date: March 5, 2020 Signature Audit Report Author: Date Signature NCS000434_Archdale MS4 Audit_20200217 Page 1 of 28 Permittee Information MS4 Permittee Name: City of Archdale Permit Effective Date: 04/10/2017 Permit Expiration Date: 02/16/2022 Mailing Address: PO Box 14068, Archdale, NC 27263 Date of Last MS4 Inspection/Audit: N/A Co-permittee(s), if applicable: N/A Permit Owner of Record: Zeb Holden, City Manager Primary MS4 Representatives Participating in Audit Name, Title Organization D. J. Seneres, Stormwater Program Manager City of Archdale Danica Heflin, Environmental Programs Coordinator Stormwater SMART (Piedmont Triad Regional Council) Matthew Wells, Planning Administrator City of Archdale Duncan Walser, Planning Technician City of Archdale MS4 Receiving Waters Waterbody Classification Impairments Muddy Creek of Cape Fear Basin WS-IV: Mile Branch of Cape Fear Basin WS-IV: Uwharrie River of Yadkin PeeDee Basin WS-III NCS000434_Archdale MS4 Audit_20200217 Page 2 of 28 List of Supporting Documents Item When Provided Number Document Title (Prior to/During/After) 01 2019 Annual Report Prior to 02 Requested Documents Prior to 03 City of Archdale SW Website Prior to 04 2018-2014 Annual Reports During 05 Illicit Discharge Detection and Elimination Program During 06 Good Housekeeping Program During 07 Stormwater Program Ordinance During 08 Erosion and Sediment Control Ordinance During 09 Stormwater SMART Webpage After 10 Stormwater SMART Report During NCS000434_Archdale MS4 Audit_20200217 Page 3 of 28 Program Implementation, Documentation & Assessment Staff Interviewed: D.J. Seneres, Stormwater Program Manager (Name, Title, Role) Permit Citation Program Requirement Status Supporting Doc No. II.A.1 The permittee maintained adequate funding and staffing to implement and manage Staffing and Yes 02 the provisions of the Stormwater Plan and meet all requirements of the permit. Funding The Stormwater Plan identifies a specific position(s) responsible for the overall Yes 02 coordination, implementation, and revision to the Plan. Responsibilities for all components of the Stormwater Plan are documented and No 02 position(s) assignments provided. The permittee is current on payment of invoiced administering and compliance Yes N/A monitoring fees. Comments City of Archdale has one full time stormwater employee, Stormwater Manager D.J. Seneres. However, all 71 city employees are trained and involved in stormwater. The organizational chart and other materials do not dictate which employees are responsible for which components, it is seen that the stormwater manager is over the entire program but other components of the stormwater plan are completed by other employees. Funding comes from an enterprise fund along with a stormwater utility. II.A.2 Stormwater The permittee evaluated the performance and effectiveness of the program 01, 02, Plan components at least annually. Yes 04 Implementation and Evaluation If yes, the permittee used the results of the evaluation to modify the program Yes 01, 02, components as necessary to accomplish the intent of the Stormwater Program. 04 Did the permitted MS4 discharges cause or contribute to non -attainment of an Yes 01, 02, applicable water quality standard? 04 If yes, did the permittee expand or better tailor its BMPs accordingly to address Yes 01, 02, the non -attainment? 04 Comments City of Archdale performed internal audits to evaluate the effectiveness of the program at a minimum of once annually. City was having some issues with first flush affecting the water quality standards. Are currently in the process of addressing the issue and coming up with ways to reduce the impacts. NCS000434_Archdale MS4 Audit_20200217 Page 4 Of 28 Program Implementation, Documentation & Assessment I I.A.3 Keeping the The permittee kept the Stormwater Plan up to date. No N/A Stormwater Plan Up to Date The permittee notified DEMLR of any updates to the Stormwater Plan. Applicable tN/A Comments No true stormwater plan exists for the City of Archdale. A Stormwater Management Plan (SWMP) is mentioned in received documentation as being the two binders that were provided. However, these binders act as records with large amounts of pictures and information. The SWMP should document how the city will implement the program and the required six minimum measures. II.A.4 Availability The permittee kept an up-to-date version of its Stormwater Plan available to the of the Stormwater Division and the public online. No N/A Plan The online materials included ordinances, or other regulatory mechanisms, or a list identifying the ordinances, or other regulatory mechanisms, providing the legal Partial N/A authority necessary to implement and enforce the requirements of the permit. Comments There is no version of a Stormwater Plan available online or the most recent stormwater report. While ordinances can be found online via the City of Archdale website they are not found on the stormwater website. II.A.3 & II.A.5 Stormwater Plan Did DEMLR require a modification to the Stormwater Plan? No N/A Modifications If yes, did the permittee complete the modifications in accordance with the Not N/A established deadline? Applicable Comments II.A.6 Sharing Responsibility Are any control measures implemented by an entity other than the permittee? Yes 01 If yes, is there a written agreement in place? Yes 01 Comments Stormwater SMART does the public education and outreach for all Archdale. Stormwater SMART is a partnership between county and municipal governments designed to provide the general public with education regarding stormwater pollution, water quality issues, and water conservation. The Stormwater SMART program was created by the Piedmont Triad Regional Council. II.A.7 The permittee maintained written procedures for implementing the six minimum Written control measures. Partial 05, 06 Procedures Written procedures identified specific action steps, schedules, resources and responsibilities for implementing the six minimum measures. Partial 05,06 Comments There are written procedures for IDDE and for Good Housekeeping however the other minimum control measures do not have any written procedures. NCS000434_Archdale MS4 Audit_20200217 Page 5 of 28 Program Implementation, Documentation & Assessment III. A The permittee maintained documentation of all program components including, but Program not limited to, inspections, maintenance activities, educational programs, Partial N/A Documentation implementation of BMPs, enforcement actions etc., on file for a period of five years. Comments City of Archdale had large database of previous 5 years' activities and inspections. These records are kept in the binders supplied for audits, along with some inspection records kept with Mr. Seneres. There was no documented SWMP available. 111.13 The permittee submitted annual reports to the Department within twelve months Annual Report from the effective date of the permit (See Section 111.B. for the annual reporting Yes 01,04 Submittal period specific to this MS4). The permittee submitted subsequent annual reports every twelve months from the scheduled date of the first annual report submittal. Yes 01,04 The Annual Reports included appropriate information to accurately describe the progress, status, and results of the permittee's Stormwater Plan, including, but not limited the following: 1. A detailed description of the status of implementation of the Stormwater Plan as a whole. This will include information on development and implementation of each major component of the Stormwater Plan for the past year and Partial 01,04 schedules and plans for the year following each report. 2. An adequate description and justification of any proposed changes to the Stormwater Plan. This will include descriptions and supporting information for Not the proposed changes and how these changes will impact the Stormwater Applicable 01,04 Plan (results, effectiveness, implementation schedule, etc.). 3. Documentation of any necessary changes to programs or practices for assessment of management measures implemented through the Stormwater Not Applicable 01, 04 Plan. 4. A summary of data accumulated as part of the Stormwater Plan throughout the year along with an assessment of what the data indicates in light of the Not Applicable 01, 04 Stormwater Plan. 5. An assessment of compliance with the permit, information on the establishment of appropriate legal authorities, inspections, and enforcement Partial 01,04 actions. Comments Reports for 2018 and 2019 were submitted. Some general data on the assessment of the program since implementation was available but annual data was not available. IV.B Annual Reporting The Annual Reports document the following: 1. A summary of past year activities, including where applicable, specific quantities achieved and summaries of enforcement actions. Partial 01,04 2. A description of the effectiveness of each program component. Partial 01,04 3. Planned activities and changes for the next reporting period, for each Partial 01,04 program component or activity. NCS000434_Archdale MS4 Audit_20200217 Page 6 of 28 Program Implementation, Documentation & Assessment 4. Fiscal analysis. I Partial 1 01,04 Comments The 2019 Annual Report was acknowledged as meeting requirements. However, there is no 2018 Annual Report. Additional While it was evident during the audit that the program had been implemented and Mr. Seneres was Comments: performing regular inspections and involved in all aspects of the program, the general documentation and reports were lacking. While in the requested documentation it was stated that the SWMP is essentially the supplied two binders, these binders are not considered a proper Stormwater Management Plan. These binders are a great supply of records and examples of materials distributed. However, only the IDDE and Good Housekeeping programs feature any written procedures. There are no written procedures -for the other minimum measures. NCS000434_Archdale MS4 Audit_20200217 Page 7 Of 28 Public Education and Outreach Staff Interviewed: D.J. Seneres, Stormwater Program Manager (Name, Title, Role) Danica Heflin, Environmental Programs Coordinator (Stormwater SMART) Permit Citation Program Requirement Status Supporting Doc No. The permittee defined goals and objectives of the Local Public Education and 01, 09, I I. B.2.a Goals and Yes Outreach Program based on community wide issues. 10 Objectives Comments Permittee relies on Stormwater SMART from the Piedmont Triad Regional Council to maintain all public education requirements. Goal to attend Bush Hill Annual Festival is only listed goal outside of the Stormwater SMART goals defined in the Stormwater SMART annual reports. II.B.2.b The permittee maintained a description of the target pollutants and/or stressors and Target Pollutants likely sources. Yes 03 Comments Target pollutants are the general targets kept by Stormwater SMART. The pollutants are: litter, trash, pet waste, yard waste, pesticides, household chemicals, and vehicle maintenance. These are all appropriate. Sediment should be added as a target pollutant. Development is present in the City of Archdale. Therefore, the potential exists for sediment pollution to be impacting stormwater runoff in the city. II.B.2.c The permittee identified, assessed annually and updated the description of the target No N/A Target Audiences audiences likely to have significant storm water impacts and why they were selected. Comments Stormwater SMART does update changes. However, no documentation is available to show updated targets. NCS000434_Archdale MS4 Audit_20200217 Page 8 of 28 Public Education and Outreach II.B.2.d Residential The permittee described issues, such as pollutants, the likely sources of those and Industrial/ pollutants, potential impacts, and the physical attributes of stormwater runoff in Yes 03,09 Commercial Issues their education/outreach program. Comments Websites for both City of Archdale and Stormwater SMART covered different areas of pollutant sources based on the type of area. The websites include the potential activities that could be seen as sources of pollutants, which may not be thought of as a typical source of pollution by the general public. Some materials are created for a more business centric approach as well. 11. B.2.e The permittee promoted and maintained an internet web site designed to convey the Informational program's message. Yes 03, 09 Web Site Comments https://www. archdale-nc.gov/archdale-stormwater-management/ (This website is maintained as part of the City of Archdale web page. The website includes general requirements of the permit, along with links to the Stormwater SMART pages for more information when needed. The stormwater department does not maintain any other web pages. However, Stormwater SMART and City of Archdale do maintain a social media presence. I I. B.2.f The permittee distributed stormwater educational material to appropriate target Public Education Yes 10 Materials groups. Comments Stormwater SMART maintains a yearly database of all events attended and what materials were distributed at the events. City of Archdale also keeps examples of materials handed out. 11.B�.2 The permittee promoted and maintained a stormwater hotline/helpline for the Hotline/Help Line purpose of public education and outreach. No N/A Comments The City of Archdale informed NCDEQ the hotline for stormwater is D.J. Seneres' cell phone number. However, upon review of the materials supplied to DEQ during the audit, along with review of the City of Archdale stormwater page, there is no reference to a hotline. II.B.2.h The permittee's outreach program, including those elements implemented locally or through a cooperative agreement, included a combination of approaches designed to Yes 10 reach the target audiences. NCS000434_Archdale MS4 Audit_20200217 Page 9 of 28 Public Education and Outreach Public Education and Outreach For each media, event or activity, including those elements implemented locally or Program through a cooperative agreement the permittee estimated and recorded the extent Yes 10 of exposure. Comments The majority of outreach is performed by Stormwater SMART, and records of outreach and expected exposure is reviewed in the stormwater SMART annual reports. This includes television spots, radio spots, volunteer events, meetings, and different fairs and festivals. Additional Public education and outreach is well put together and is the general program implemented by Stormwater Comments: SMART and the Piedmont Triad Regional Council. The City of Archdale needs to ensure that materials are specific to their community. During the audit, NCDEQ was informed that Mr. Seneres' cell number would act as a hotline if this is to be the case, then it needs to be promoted on materials and the website as the hotline for all citizens to call should an issue arise. NCS000434_Archdale MS4 Audit_20200217 Page 10 of 28 Public Involvement and Participation Staff Interviewed: D.J. Seneres, Stormwater Program Manager (Name, Title, Role) Danica Heflin, Environmental Programs Coordinator (Stormwater SMART) Permit Citation Program Requirement Status supporting Doc No. II.C.2.a Volunteer Community The permittee included and promoted volunteer opportunities designed to promote Yes N/A Involvement ongoing citizen participation. Program Comments Volunteer opportunities are provided at events like: Bush Hill Festival, Creek Week, Randolph Creek Week, E-Cycling Event, and other events at Creekside Park. Approximately 100 people were at the creek week and counts are kept for all interaction at different events. II.C.2.b Mechanism for The permittee provided and promoted a mechanism for public involvement that Public provides for input on stormwater issues and the stormwater program. Yes 03 Involvement Comments Input can be given in person at city hall or at the comment section at the bottom of the website. However, the best way to provide input is through the stormwater advisory board meetings which are promoted at the bottom of the webpage. II.C.2.c The permittee promoted and maintained a hotline/helpline for the purpose of public Hotline/Help Line involvement and participation. No 03 Comments See II.B.2.g. NCS000434_Archdale MS4 Audit_20200217 Page 11 of 28 Public Involvement and Participation Additional Stormwater SMART is an important partner in this minimum measure. The City of Archdale is required to Comments: ensure a written procedure for implementing the requirements is documented. NCS000434_Archdale MS4 Audit_20200217 Page 12 of 28 Illicit Discharge Detection and Elimination (IDDE) Staff Interviewed: D.J. Seneres, Stormwater Program Manager (Name, Title, Matthew Wells, Planning Administrator Role) Permit Citation Program Requirement Status Supporting Doc No. I I. D.2.a IDDE Program The permittee maintained a written IDDE Program. Yes 05 If yes, the written program includes provisions for program assessment and Yes 01,05 evaluation and integrating program. Comments The IDDE Program is reviewed as part of the annual internal audit of the City's stormwater program. The permittee maintained an IDDE ordinance or other regulatory mechanism(s) that II.D.2.b provides the legal authority to prohibit illicit connections and discharges to the MS4. Yes 07 Legal Authorities If yes, the ordinance applies throughout the corporate limits of the permittee. [Permit Part I.D] Yes 07 Comments Chapter 15, Article VII of the City of Archdale code covers all Illicit Discharge Ordinances. I I. D.2.c The permittee maintained a current map showing major outfalls and receiving Storm Sewer Yes 05 System Map streams. Comments Mapping includes all required outfalls and streams. There is no distinction between residential and industrial outfalls in the city. Therefore, all outfalls of 12" or greater size are mapped. II.D.2.d The permittee maintained a program for conducting dry weather flow field Dry Weather Flow Yes 05 observations in accordance with written procedures. Program Comments Outfalls are broken into quadrants in the city, and the quadrants are visited regularly. During these quadrant visits the permittee does visual inspections to ensure there are not obvious issues with the outfalls, if issues are observed they are documented and tracked in Outlook and in the mapping system. Dry weather screenings occur as weather allows. Inspections are documented and kept track of in the mapping system. Previous inspection information can be gathered by this system. NCS000434_Archdale MS4 Audit_20200217 Page 13 of 28 Illicit Discharge Detection and Elimination (IDDE) I I. D.2.e The permittee maintained written procedures for conducting investigations of Investigation Yes 05 identified illicit discharges. Procedures Comments (Generally describe what procedures are documented) Emergency spills are handled by 911 or proper agency. Non -emergency spills are handled by documenting all information, city staff then visit the site, collect samples of the spilled material, attempt to locate and address the spill, take picture and return to ensure Ithe visit is documented. —It should be noted that while other aspects of IDDE are mentioned in the written procedures there are no specific written procedures on what the response should be. It is noted in the written procedures that if an illegal discharge is found, then follow IDDE. However, the IDDE written procedures do not include actions specifically for illegal connections. II.D.2.f For each case of an illicit discharge or potential illicit discharge, the permittee documented and tracked the Track and following: Document Investigations 1. The date(s) the illicit discharge was observed Yes 05 2. The results of the investigation Yes 05 3. Any follow-up of the investigation Yes 05 4. The date the investigation was closed Yes 05 Comments The permittee tracks information on illicit discharges through Microsoft Outlook. II.D.2.g Employee The permittee implemented and documented a training program for appropriate Training municipal staff who, as part of their normal job responsibilities, may come into Yes 05 contact with or otherwise observe an illicit discharge or illicit connection. Comments All city employees receive annual training and training on IDDE is part of this training. Training is documented through sign in sheets. II.D.2.h The permittee informed public employees of hazards associated with illegal Public Education discharges and improper disposal of waste. Yes 05 The permittee informed businesses of hazards associated with illegal discharges and improper disposal of waste. Yes 05 The permittee informed the general public of hazards associated with illegal discharges and improper disposal of waste. Yes 05 Comments Public employees receive auxiliary training and IDDE is included in this training. This training is given to target audiences that may be subjected to higher risk of IDDE. Currently the main sector associated with IDDE is the restaurant sector. All grease traps are reviewed by public works inside of the city. The permittee meets with all new business owners to ensure that they are informed of their requirements to follow the requirements of the City's stormwater plan. It should be noted that during the audit the permittee stated that a large part of the communication with the general public is through UNC's commercial stormwater diagram. NCS000434_Archdale MS4 Audit_20200217 Page 14 of 28 Illicit Discharge Detection and Elimination (IDDE) II.D.2.i The permittee promoted, publicized, and facilitated a reporting mechanism for the Public Reporting No 05 public to report illicit discharges. Mechanism The permittee promoted, publicized, and facilitated a reporting mechanism for staff Yes 05 to report illicit discharges. The permittee established and implemented response procedures for citizen Yes 05 requests/reports. Comments As stated before Mr. Seneres' number was reported to be the hotline however it is not promoted or publicized in any materials or on the website. The city hall number is available on a majority of the distributed materials and online. City employees have Mr. Seneres' number to call for reporting of illicit discharges. When a report is received, a site visit is performed and an inspection report is created and kept in Microsoft Outlook with details and picture. Notes are kept on the complaint this way, including when completed. II.D.2.i The permittee implemented a mechanism to track the issuance of notices of violation Enforcement and enforcement actions administered by the permittee. Yes N/A If yes, the mechanism includes the ability to identify chronic violators for Yes N/A initiation of actions to reduce noncompliance. Comments Tracking is done via reports and inspections in Microsoft Outlook. Chronic violators can be found by communicating with the planning department and city manager based on violators address. Additional The IDDE program has written procedures for all parts of the program. Tracking and maintaining inspection Comments: information should be serviced in a platform that supports use by multiple staff members. NCS000434_Archdale MS4 Audit_20200217 Page 15 of 28 Construction Site Runoff Controls Staff Interviewed: D.J. Seneres, Stormwater Program Manager (Name, Title, Role) Matthew Wells, Planning Administrator Program Delegation Status: ❑X 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.E.3 Construction Site Runoff Controls The permittee provides and promotes a means for the public to notify the (NPDES Permit No. appropriate authorities of observed erosion and sedimentation problems (e.g., Partial --- NCS000435] promoting the existence of the DEQ DEMLR "Stop Mud" hotline). Comments (Describe how provided and promoted) There is no dedicated hotline for sediment or erosion issues. However, citizens can notify the city through the city hall main number which is posted on the city web page. SPCA Citation I Delegated Program Requirement I Status I Supporting Doc No. § 113A-60 Local The permittee has adopted an ordinance or other regulatory mechanism to enforce erosion and Yes 08 sedimentation the erosion and sedimentation control program. control programs (a) If yes, the ordinance meets or exceeds the minimum requirements of the Yes 08 SPCA. If yes, the ordinance applies throughout the corporate limits of the permittee. Yes 08 [Permit Part I.D] Comments (Provide regulatory mechanism reference or Supporting Documentation number) City of Archdale Code of Ordinances Chapter 16 provides for the control of soil erosion and sedimentation. § 113A-60 Local erosion and The permittee collects a fee paid by each person who submits an erosion and Yes N/A sedimentation sedimentation control plan. control programs (d) NCS000434_Archdale MS4 Audit_20200217 Page 16 of 28 Construction Site Runoff Controls Comments The city collects a $200 plan review fee with a $15 per additional acre fee. The $200 fee is required for all reviews; therefore, this covers the first acre. 113A-60 Local Has any person initiated a land -disturbing activity (within the permittee's erosion and jurisdiction) for which an erosion and sedimentation control plan is required in the No N/A sedimentation absence of an approved plan? control programs (e) If yes, the permittee has notified the North Carolina Sedimentation Control Not Commission of all such cases. Applicable N/A Has the permittee determined that a person engaged in a land -disturbing activity No N/A has failed to comply with an approved erosion and sedimentation control plan? If yes, has the permittee referred any such matters to the North Carolina No N/A Sedimentation Control Commission for inspection and enforcement? Comments The permittee informed NCDEQ during the audit that the City has a majority of small projects with good compliance. It should be noted that when visiting a construction site later in the day (Construction Site #2), it was discovered that, according to the plan supplied to NCDEQ, the construction was not in compliance with the approved plan. § 113A-61 Local The permittee reviews each erosion and sedimentation control plan submitted to approval of erosion them and notifies the person submitting the plan that it has been approved, Yes --- and sedimentation approved with modification, or disapproved within 30 days of receipt. control plans The permittee only approves an erosion and sedimentation control plan upon determining that it complies with all applicable State and local regulations. Yes --- The permittee has disapproved of an erosion and sedimentation control plan in order to protect riparian buffers along surface waters. No --- If yes, the permittee notified the Director of the Division of Energy, Not Mineral, and Land Resources within 10 days of the disapproval. Applicable --- Comments IThe City of Archdale has a 7-day turnaround, with a current count of 19 active projects. A required pre -submittal meeting typically removes issues and reduces disapprovals. § 113A-61.1 Inspection of land- The certificate of approval of each erosion and sedimentation control plan disturbing activity; approved by the permittee includes a notice of the right to inspect. Yes 08 notice of violation (a) The permittee provides for inspection of land -disturbing activities to ensure compliance with the SPCA and to determine whether the measures required in an Partial 08 erosion and sedimentation control plan are effective. Comments The permittee inspects the sites and sites are typically looked at weekly. The inspections are documented in Outlook and include time on site, date, and a brief description. There is no standard inspection form completed or provided to the customer. NCS000434_Archdale MS4 Audit_20200217 Page 17 of 28 Construction Site Runoff Controls § 113A-61.1 When the permittee determines that a person engaged in land -disturbing activity Inspection of land- has failed to comply with the SPCA, the Permittee immediately issues a notice of No --- disturbing activity; violation upon that person. notice of violation Each notice of violation issued by the permittee specifies the date by which the Not (c) person must comply. Applicable Each notice of violation issued by the permittee informs the person of the actions Not that need to be taken to comply. Applicable --- Comments No NOVs or compliance violations were written. The inspector informed any site of small violations to be fixed prior to leaving the site which avoided violations. It should be noted that both sites visited during the audit were considered non -compliant by NCDEQ inspectors and should have had compliance violations written for both sites. A notice of violation could have been issued for Construction Site #1. 113A-64 Penalties Does the permittee issue civil penalties as part of the erosion and sedimentation program? Yes 07,08 Comments The permittee has the authority to issue civil penalties in City Code of Ordinances Chapter 16, Article 1, Section 16-19. Additional NCDEQ noted that the construction stormwater program had been implemented well and reviews were done Comments: by the planning department. NCDEQ observed issues when it came to the actual site inspections and the lack of non-compliance reports written by the City of Archdale. Two construction sites were visited in the afternoon as part of the construction site runoff controls and both sites were considered non -compliant by NCDEQ, with Construction Site #1 needing a Notice of Violation due to off -site sedimentation. NCS000434_Archdale MS4 Audit_20200217 Page 18 of 28 ISite Visit Evaluation: MS4 Outfall No. 1 Outfall ID Number: Date and Time of Site Visit: McDonald's on Main 12/17/2019 @ 1340 Outfall Location: Outfall Description (Pipe Material/Diameter, Culvert, etc.): McDonald's at the intersection of Balfour and Main. Outfall 2 x 12" Concrete discharges from a retention cell. Receiving Water: Is Flow Present? If So, Describe (Color, Approximate Flow Rate, Muddy Creek (Class WS-IV; * of Cape Fear) Sheen, Odor, Floatables/Debris, etc.): Flow was present. Most Recent Outfall Inspection/Screening (Date): Color: None observed 12/9/2019 Sheen: None observed Odor: Slight trash -like odor Floatables: No floatables in current flow however some in outfall Days Since Last Rainfall: Inches: 0 0.61 Approximate Flow Rate: Slow/Negligible Name of MS4 Inspector(s) evaluated: D.J. Seneres Observations Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Inspector has SWIT credentials, PE, and NCSU SCM inspector certified. Inspector also informed NCDEQ that he attended all training offered by NCDEQ related to stormwater. Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations? Yes. MS4 inspector inspected all areas that fed the outfalls and the post construction measure that the outfall discharged from. Inspector walked the site with the manager of the McDonald's so that he could point out issues observed. Inspection Procedures Does the inspector's process include the use of a checklist or other standardized form? No. Does the inspector's process include taking photos? No photos were taken during this inspection. A photo was taken of the outfall at the previous inspection. Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they? No. NCS000434_Archdale MS4 Audit_20200217 Page 19 of 28 Site Visit Evaluation: MS4 Outfall No. 1 Inspection Results Did the outfall inspection result in any work orders or maintenance requests? If so, for what issue(s)? Yes. The inspector informed the manager that a there was a larger than usual amount of oil staining in the parking lot where typically the parking lot was maintained with a de -greaser. Inspector recommended that engineer should come out and review the outfall where some spalling was noted in the concrete outfalls. Inspector also noted the debris and slight overgrowth that was present in the rock at the outfall. Will a follow-up outfall inspection be conducted? If so, for what reason? Yes. To ensure that de -greaser will be used to clean parking lot. Notes/Comments/Recommendations Inspection was performed with the manager of McDonald's which is always recommended so that all issues can be immediately given to owner and fixed in a reasonable amount of time. Inspector also looked at all storm drains that feed the outfalls and ensured they were not clogged and did not contain debris or floatables. Inspector also noted a few areas that needed to be addressed by the landscaping crew during the inspection. NCDEQ recommends photographing any issues that were given to the manager to address as way of ensuring issues are actually addressed in the future. No photos were taken of the outfall or of any areas that were noted by the inspector. NCS000434_Archdale MS4 Audit_20200217 Page 20 of 28 Site Visit Evaluation: MS4 Outfall No. 2 Outfall ID Number: Date and Time of Site Visit: Bradford Downs 12/17/2019 @ 1530 Outfall Location: Outfall Description (Pipe Material/Diameter, Culvert, etc.): Bradford Lane Culvert 2 x 6' Corrugated Metal Culvert Receiving Water: Is Flow Present? If So, Describe (Color, Approximate Flow Rate, Culvert for Unnamed Tributary of Muddy Creek (Class WS-IV; * Sheen, Odor, Floatables/Debris, etc.): of Cape Fear) Flow was present: Color: Slight brown color typical of stream after a rain Most Recent Outfall Inspection/Screening (Date): 7/26/2019 Sheen: None observed Odor: None observed Floatables: None observed in flow however some caught on bank Flow: Consistent flow approximately 1' deep in culvert Days Since Last Rainfall: Inches: 0 0.61 Name of MS4 Inspector(s): D.J. Seneres Observations Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Inspector has SWIT credentials, PE, and NCSU SCM inspector certified. Inspector also informed NCDEQ that he attended all training offered by NCDEQ related to stormwater. Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations? Yes. Inspector looked at all aspects of stormwater coming out of the culvert and NCDEQ was informed that during inspections of lower flow the culvert is walked through to inspect the entire outfall. Inspection Procedures Does the inspector's process include the use of a checklist or other standardized form? Obtain copy. No. Does the inspector's process include taking photos? No photos were taken during this inspection. A photo was taken of the outfall at the previous inspection. Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they? No. NCS000434_Archdale MS4 Audit_20200217 Page 21 of 28 Site Visit Evaluation: MS4 Outfall No. 2 Inspection Results Did the outfall inspection result in any work orders or maintenance requests? If so, for what issue(s)? No. Will a follow-up outfall inspection be conducted? If so, for what reason? No. Notes/Comments/Recommendations Inspector noted that secondary culvert contains about 1-2' of sediment in it and is used as an overflow. It appeared as though the secondary culvert had been used recently based on observations during the inspection. NCS000434_Archdale MS4 Audit_20200217 Page 22 of 28 Site Visit Evaluation: Construction Site No. 1 Site/Project Name: Date and Time of Site Visit: Diamonds Keep or Royal Pines S/D 12/17/2019 @ 1430 Site/Project Address: Operator: Royal Pines Subdivision Keystone Homes Leyland Terrace Project Type (Commercial, Industrial, Residential, CIP, Roadway, etc.): Residential NCG Permit ID Number: Disturbed Acreage: COA-2019-003 13.2 Recent Enforcement Actions (Include Date): No enforcement. Name of MS4 Inspector(s) evaluated: D.J. Seneres Name(s) and Title(s) of Site Representative(s) Present During the Site Visit: Name Title D.J. Seneres Observations Site Documentation/Training Does the site have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it site -specific? Site apparently has approved E&SC plan that also includes coverage by NCG010000 however this was not available on site and inspector did not ask for or look for the plan on site. Does the site have approved erosion and sedimentation control plans onsite? Are they representative of current site conditions? Plans were not seen by NCDEQ employees and the inspector did not ask for any plans. The plans provided to NCDEQ by City of Archdale planning were inadequate and were not representative of the current conditions. What type of stormwater training do site employees receive? How often? Unknown. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Inspector has SWIT credentials, PE, and NCSU SCM inspector certified. Inspector also informed NCDEQ that he attended all training offered by NCDEQ related to stormwater. Did the MS4 inspector appear knowledgeable about MS4 and NCG010000 requirements for construction sites? No. Inspector did not review plans and ignored a majority of the site for a perimeter walk around. Inspector did not make comments on groundcover requirements around perimeter of site. Did the MS4 inspector appear knowledgeable about erosion and sedimentation control/stormwater pollution prevention BMPs? No. Inspector was continually speaking about the 1" rain requirement for construction stormwater. This was referring to the requirement of construction measures to contain the rainfall, however this is not 1" requirement, the requirement is the measures must control a 10-year storm event, which in this part of North Carolina is in exceedance of 1" (NOAA Atlas 14 Point Precipitation Frequency Estimates). Inspector also said turbidity was leaving the site but was not bypassing measures when there was obvious failure of silt fence at the area of concern which would be a bypass of measures. NCS000434_Archdale MS4 Audit_20200217 Page 23 of 28 Site Visit Evaluation: Construction Site No. 1 Inspection Procedures Does the MS4 inspector's process include the use of a checklist? Inspector carried a copy of NCDEQ's sediment inspection checklist with him but was not actively using it for the inspection. Does the MS4 inspector's process include taking photos? Some photos were taken at the area where sediment was reaching surface water. Does the MS4 inspector's process include reviewing approved plans (erosion and sedimentation control and/or SWPPP)? No. Inspector carried a small (not -detailed) copy of the plan for the original E&SC plan that was closed out and no longer the active plan. Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge? No. Inspector looked at one point of discharge and did not look at one discharge point although the inspection walked around the basin from which the discharge was coming from. Did the MS4 inspector miss any obvious violations? If so, explain: Yes. Sediment was leaving the site via bypass of the silt fence at the area where inspector mentioned a turbidity problem, a large linear path of —10' at the perimeter had no groundcover, sediment was reaching surface waters at the discharge point from a second basin, inspector did not ask for inspection reports or copy of plans that should have been on site, inspector/keystone mentioned an area not included on the current plans as being undisturbed however a gas tank and trash was actively being stored on the "undisturbed" property, the disturbance was outside of limits of disturbance according to the plans given to NCDEQ by City of Archdale planning, three roll -off containers were being stored along Radiant Path which were within the 50' buffer of storm drains along with one leaking paint that was not noted by the inspector, according to plans given to NCDEQ another construction basin was located on site however this area was not inspected while on -site so it is unknown if this basin was present or being maintained, concrete was observed being washed out directly onto the ground rather than in a designed and designated washout. Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing? Based on what was observed prior to going to the site the inspection report is a one sentence report of what was seen, who was met with, and when documented in the inspectors Outlook calendar. Findings are given verbally at the end of the inspection. Does the MS4 inspector's process include providing construction stormwater educational materials to the site contact? Inspector discusses the issues and why they need to be addressed while on site. Compliance/Enforcement What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in? Inspector told site contact that he was compliant just needed to address the issue observed. It is in the NCDEQ inspector's opinion that the site should have been non -complaint and told that a follow-up inspection will be performed to ensure compliance is met. If compliance issues were identified, what timeline for correction/follow-up was provided? Inspector told the site contact to get people on site as soon as possible and that he would be back tomorrow. Notes/Comments/Recommendations NCS000434_Archdale MS4 Audit_20200217 Page 24 of 28 Site Visit Evaluation: Construction Site No. 1 Site should have been put under non-compliance. Multiple issues were not addressed by the inspector; however, even with the issues that were addressed this should have been enough to call the site non -compliant with a report written up and a timeline to address the situation given in writing. During the inspection the inspector asked for a redesign from the design engineer to address the issues observed, this is not asking for the correct information/requirements. The plan supplied to NCDEQ by City of Archdale planning was also not adequate based on the NCDEQ design manual or NCG01 requirements. The plan appeared to show that in multiple locations the active site conditions were observed to be outside of the limits of disturbance. Site Visit Evaluation: Construction Site No. 2 Site/Project Name: Date and Time of Site Visit: Dairi-O 12/17/2019 @ 1550 Site/Project Address: Operator: 10301 Main Street Fourth Elm Construction Project Type (Commercial, Industrial, Residential, CIP, Roadway, etc.): Commercial NCG Permit ID Number: Disturbed Acreage: Told <1 by inspector, plan says 1.921 acres Recent Enforcement Actions (Include Date): No enforcement. Name of MS4 Inspector(s) evaluated: D.J. Seneres Name(s) and Title(s) of Site Representative(s) Present During the Site Visit: Name Title D.J. Seneres Observations Site Documentation/Training Does the site have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it site -specific? Site apparently has approved E&SC plan that also includes coverage by NCG010000 however this was not available on site and inspector did not ask for or look for the plan on site. Does the site have approved erosion and sedimentation control plans onsite? Are they representative of current site conditions? Plans were not seen by NCDEQ employees and the inspector did not ask for any plans. The plans provided to NCDEQ by City of Archdale planning were inadequate. What type of stormwater training do site employees receive? How often? Unknown. Inspector Training/Knowledge NCS000434_Archdale MS4 Audit_20200217 Page 25 of 28 Site Visit Evaluation: Construction Site No. 2 What type of stormwater training does the MS4 inspector receive? How often? Inspector has SWIT credentials, PE, and NCSU SCM inspector certified. Inspector also informed NCDEQ that he attended all training offered by NCDEQ related to stormwater. Did the MS4 inspector appear knowledgeable about MS4 and NCGO10000 requirements for construction sites? No. Inspector did not review plans and ignored a majority of the site for a perimeter walk around. Inspector did not make comments on groundcover requirements around perimeter of site Did the MS4 inspector appear knowledgeable about erosion and sedimentation control/stormwater pollution prevention BMPs? No. Inspector was continually speaking about the 1" rain requirement for construction stormwater. This was referring to the requirement of construction measures to contain the rainfall, however this is not 1" requirement, the requirement is the measures must control a 10-year storm event, which in this part of North Carolina is in exceedance of 1" (NOAA Atlas 14 Point Precipitation Frequency Estimates). Inspector also said there was no sign of sediment loss offsite however one of the discharge points was not inspected and another culvert along Tarheel Drive showed signs of being impacted by sediment. Inspection Procedures Does the MS4 inspector's process include the use of a checklist? Obtain copy. Inspector carried a copy of NCDEQ's sediment inspection checklist with him but was not actively using it for the inspection. Does the MS4 inspector's process include taking photos? Not at this site. Does the MS4 inspector's process include reviewing approved plans (erosion and sedimentation control and/or SWPPP)? No. Inspector informed DEQ that since he visited the sites frequently and he knew the plans. Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge? No. Inspector walked the perimeter of the site however did not inspect the main discharge point where the basin on site discharged. Inspector also did not look at any storm drains that were not along the perimeter. Did the MS4 inspector miss any obvious violations? If so, explain: Yes. Sediment was reaching the culvert under the driveway north of the site on Tarheel Drive, inspector did not document the sediment and stated the homeowner lets him know if issues occur. Site conditions do not match the plans that were given to DEQ as an area not listed as being in the disturbance was very clearly disturbed on site. A decently sized area on the east (Tarheel Drive) side of the site was also still disturbed with no protection from sediment leaving the site and reaching the stormwater inlets along Tarheel Drive. There were multiple locations of concrete washout being discharged directly onto the ground and near storm drains. Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing? Based on what was observed prior to going to the site the inspection report is a one sentence report of what was seen, who was met with, and when documented in the inspectors Outlook calendar. Does the MS4 inspector's process include providing construction stormwater educational materials to the site contact? Inspector discusses the issues and why they need to be addressed while on site. Compliance/Enforcement What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in? None. NCS000434_Archdale MS4 Audit_20200217 Page 26 of 28 Site Visit Evaluation: Construction Site No. 2 it compliance issues were iaentmea, wnat timeline for correction/toiiow-up was p None identified. Notes/Comments/Recommendations Site should have been put under non-compliance. When compared to the approved plans provided by the City of Archdale planning department there is an entrance on Rand Boulevard that is not depicted and should require a revision to the plan. The plan also shows erosion and sediment control measures outside of the disturbed area. A large stockpile was located on site directly up gradient from not only the sediment basin but also the discharge of the sediment basin. Diversion berm is not properly installed on site as one of the berm discharges into the sediment basin at the same location as the skimmer. Inspector did not look at any of the internal stormwater drains during the inspection as the majority of the inspection was spent along the exterior of the site. Large section along Tarheel Drive without silt fence was observed and inspector informed DEQ that it was approved to use curbing (approximately 4 inches above grade) as the measure to retain sediment on site. This should not have been approved as curbing is not a measure. NCS000434_Archdale MS4 Audit_20200217 Page 27 of 28 APPENDIX A: SUPPORTING DOCUMENTS Please Note: Copy of report sent to City of Archdale does not include city supplied documents. 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