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HomeMy WebLinkAboutNCS000584_Lexington MS4 AUDIT REPORT_20200819MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) PROGRAM AUDIT REPORT NPDES PERMIT NO. NCS000584 CITY OF LEXINGTON, NORTH CAROLINA 28 West Center Street Lexington, North Carolina 27292 Audit Date: July 23, 2020 Report Date: August 19, 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) NCS000584_City of Lexington MS4 Audit_20200819 TABLE OF CONTENTS AuditDetails..................................................................................................................................................1 PermitteeInformation..................................................................................................................................2 Listof Supporting Documents.......................................................................................................................3 Program Implementation, Documentation & Assessment...........................................................................4 PublicEducation and Outreach.....................................................................................................................6 Public Involvement and Participation...........................................................................................................8 Illicit Discharge Detection and Elimination (IDDE)........................................................................................9 Pollution Prevention and Good Housekeeping for Municipal Operations..................................................11 Site Visit Evaluation: Municipal Facility No. 1.............................................................................................13 Site Visit Evaluation: Municipal Facility No. 2.............................................................................................14 Site Visit Evaluation: MS4 Outfall No. 1......................................................................................................15 Appendix 13: Photos 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 Storm water Management Plan in accordance with the issued permit. NCS000584_City of Lexington MS4 Audit_20200819 ii This page intentionally left blank NCS000584_City of Lexington MS4 Audit_20200819 Audit Details Audit ID Number: Audit Date(s): NCS000584_City of Lexington MS4 Audit_20200723 July 23, 2020 Minimum Control Measures Evaluated: ® Program Implementation, Documentation & Assessment ® Public Education & Outreach ® Public Involvement & Participation ® Illicit Discharge Detection & Elimination ❑ Construction Site Runoff Controls— No delegated Sediment and Erosion Control Program ❑ Construction Site Runoff Controls — Delegated Sediment and Erosion Control Program ❑ Post -Construction Site Runoff Controls ® Pollution Prevention and Good Housekeeping for Municipal Operations ❑ Total Maximum Daily Loads (TMDLs) Field Site Visits: ® Municipal Facilities. Number visited: 2 ® MS4 Outfalls. Number visited: 1 ❑ 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. fnspector(s) Conduct+ng Audit . .; Name, Title Organization Isaiah Reed, Environmental Specialist NCDEQ (Asheville Regional Office) Zachary Lentz, Assistant Regional Engineer NCDEQ (Winston Salem Regional Office) Audit Report Autho Date: Signature Audit Report Author: ;: ;� �- "" Date .- 7 c� J2 0 `3 ` Sf nature 111; g V r� NCS000584_City of Lexington MS4 Audit_20200730 Page I of 20 Permittee Information MS4 Permittee Name: City of Lexington Permit Effective Date: November 11, 2016 Permit Expiration Date: November 11, 2021 Mailing Address: 28 West Center Street. Lexington, NC 27292 Date of Last MS4 Inspection/Audit: None Co-permittee(s), if applicable: Permit Owner of Record: Clark Newell Primary MS4 Representatives Participating in Audit Name, Title Organization Roger Jones, Water Resources City of Lexington Tom Johnson, Water Resources Director City of Lexington Chip Vanderzee, Public Services Director City of Lexington Terra Greene, City Manager City of Lexington Danica Heflin, SMART Coordinator PTRC Blane Houck, Environmental Specialist NCDEQ Zachary Lentz, Assistant Regional Engineer NCDEQ Isaiah Reed, Environmental Specialist NCDEQ MS4 Receiving Waters Waterbody Classification Impairments Swearing Creek C 303(d), Ecological/Biological Integrity of Benthos Rat Spring Branch C None Tar Creek C None North Potts Creek (Michaels Branch) C None Abbotts Creek C Ecological/Biological Integrity of Benthos Abbotts Creek WS-V, B 303(d), Fecal Coliform, Copper, Nutrients, Ecological/Biological Integrity of Fish and Benthos, Ecological/Biological Integrity of Benthos NCS000584_City of Lexington MS4 Audit_20200730 Page 2 of 20 List of Supporting Documents Item Number Document Title When Provided (Prior to/During/After) 1 Stormwater Management Plan (June 2018) Prior to 2 BIMS SWMPA Prior to 3 2017 Report Prior to 4 2018-2019 Report Prior to 5 2016-2017 Fiscal Year Annual Report During 6 Stormwater Ordinance Prior to 7 List of City owned facilities Prior to 8 Pesticide License During 9 Illicite Discharge Report After 10 2019 Audit Summary Prior to NCS000584_City of Lexington MS4 Audit_20200730 Page 3 of 20 Program Implementation, Documentation & Assessment Staff Interviewed: Roger Jones, Public Services Manager (Name, Title, Role) Tom Johnson, Water Resources Director Chip Vanderzee, Public Services Director Terra Greens, City Manager Danica Heflin, Environmental Programs Coordinator. Permit Citation Program Requirement Status Supporting Doc No. II.A.3 The permittee maintained adequate funding and staffing to implement and manage Staffing and the provisions of the Stormwater Plan and meet all requirements of the permit. No -"" Funding The Stormwater Plan identifies a specific position(s) responsible for the overall coordination, implementation, and revision to the Plan. No --- Responsibilities for all components of the Stormwater Plan are documented and position(s) assignments provided. No --- The permittee is current on payment of invoiced administering and compliance monitoring fees (see stormwater e-payments on DEMLR MS4 web page). Yes --- The SWMP has not been updated to include current staffing designations. II.A.4 The permittee evaluated the performance and effectiveness of the program 2, 3 and Stormwater Plan components at least annually. Yes 4 Implementation and Evaluation If yes, the permittee used the results of the evaluation to modify the program 1 components as necessary to accomplish the intent of the Stormwater Program. Partial Did the permitted MS4 discharges cause or contribute to non -attainment of an No --- applicable water quality standard? If yes, did the permittee expand or better tailor its BMPs accordingly to address No --- the non -attainment? Not contribution to water quality standards were documented. II.A.5 Keeping the The permittee kept the Stormwater Plan up to date. No --- Stormwater Plan Up to Date The permittee notified DEMLR of any updates to the Stormwater Plan. No --- The SWMP available during the audit is from 2018 and has not been maintained. 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 -"" Plan The online materials included ordinances, or other regulatory mechanisms, or a list See identifying the ordinances, or other regulatory mechanisms, providing the legal Yes commen authority necessary to implement and enforce the requirements of the permit. is Lexingto 7nc.gov City Services NCS000584_City of Lexington MS4 Audit_20200730 Page 4 of 20 Program Implementation, Documentation & Assessment II.A.3 & II.A.5 Not Stormwater Plan Did DEIVILR require a modification to the Stormwater Plan? Applicable Modifications If yes, did the permittee complete the modifications in accordance with the Not established deadline? Applicable --- No SWMP submitted. II.A.6 Sharing Responsibility Are any control measures implemented by an entity other than the permittee? Yes --- If yes, is there a written agreement in place? No --- Piedmont Triad Regional Council (PTRC) implements Public Outreach and Public Involvement in Lexington, but an agreement does not exist between PTRC and the City of Lexington. ll.A.7 The permittee maintained written procedures for implementing the six minimum Written control measures. No --- Procedures Written procedures identified specific action steps, schedules, resources and No --- responsibilities for implementing the six minimum measures. Drafts of written procedures have been produced but the permittee did not maintain any written procedures. Ill. A The permittee maintained documentation of all program components including, but Program not limited to, inspections, maintenance activities, educational programs, Partial 10 Documentation implementation of BMPs, enforcement actions etc., on file for a period of five years. Not all program components have been implemented throughout the permit term. 1111.13 The permittee submitted annual reports to the Department within twelve months 2,3, and Annual Report from the effective date of the permit (See Section 111.8. for the annual reporting Yes 4 Submittal period specific to this MS4). The permittee submitted subsequent annual reports every twelve months from the 2, 3, and scheduled date of the first annual report submittal. Yes 4 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 Not of each major component of the Stormwater Plan for the past year and Reviewed 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 Reviewed 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 Reviewed --- 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 Reviewed --- Stormwater Plan. NCS000584_City of Lexington MS4 Audit_20200730 Page 5 of 20 Program Implementation, Documentation & Assessment 5. An assessment of compliance with the permit, information on the establishment of appropriate legal authorities, inspections, and enforcement Not Reviewed --- actions. IV.B Annual Reporting The Annual Reports document the following: 1. A summary of past year activities, including where applicable, specific Not --- quantities achieved and summaries of enforcement actions. Reviewed 2. A description of the effectiveness of each program component. Not Reviewed 3. Planned activities and changes for the next reporting period, for each Not program component or activity. Reviewed 4. Fiscal analysis. Not Reviewed SWMPAs have been documented each year. Public Education and Outreach Staff Interviewed: Danica Heflin, Environmental Programs Coordinator. (Name, Title, Role) Roger Jones, Public Services Manager Permit Citation Program Requirement Supporting Status Doc No. 11.B.2.a The permittee defined goals and objectives of the Local Public Education and Goals and Outreach Program based on community wide issues. Partial 5 Objectives Goals are defined in the annual report submitted to the City of Lexington, but no agreement is in place. II.B.2.b The permittee maintained a description of the target pollutants and/or stressors and Partial 3 Target Pollutants likely sources. Goals are defined in the annual report submitted to the City of Lexington, but no agreement is in place. II.B.2.c The permittee identified, assessed annually and updated the description of the target Partial --- Target Audiences audiences likely to have significant storm water impacts and why they were selected. Goals are defined in the annual report submitted to the City of Lexington, but no agreement is in place. 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 Partial --- Commercial Issues their education/outreach program. Goals are defined in the annual report submitted to the City of Lexington, but no agreement is in place. 11.B.2.e The permittee promoted and maintained an internet web site designed to convey the See Informational Partial commen Web Site program's message. is Lexingtonnc.gov Public Services NCS000584_City of Lexington MS4 Audit_20200730 Page 6 of 20 Public Education and Outreach 11.B.2.f The permittee distributed stormwater educational material to appropriate target See Public Education Partial commen Materials groups. is PTRC Website. 11.6.2.E The permittee promoted and maintained a stormwater hotline/helpline for the See Hotline/Help Line Yes commen purpose of public education and outreach. is PTRC Website. 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 4 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 No 4 of exposure. Outreach was documented in 2017-2019. No agreement exists between City of Lexington and PTRC for this Minimum control measure to be implemented on the City's behalf. NCS000584_City of Lexington MS4 Audit_20200730 Page 7 of 20 Public Involvement and Participation Staff Interviewed: Danica Heflin, Environmental Programs Coordinator. (Name, Title, Role) Roger Jones, Public Services Manager Permit Citation Program Requirement Status supporting Doc No. II.C.2.a Volunteer Community The permittee included and promoted volunteer opportunities designed to promote Involvement Yes 4 ongoing citizen participation. Program Outreach and community involvement are documented in the 2018/2019 annual report. II.C.2.b Mechanism for The permittee provided and promoted a mechanism for public involvement that See Public provides for input on stormwater issues and the stormwater program. Yes commen Involvement is Lexingtonnc.gov II.C.2.c The permittee promoted and maintained a hotline/helpline for the purpose of public Hotline/Help Line involvement and participation. No --- Hotline specifically designed for involvement has not been maintained on the permittees website. NCS000584_City of Lexington MS4 Audit_20200730 Page 8 of 20 Illicit Discharge Detection and Elimination (IDDE) Staff Interviewed: Roger Jones, Public Services Manager (Name, Title, Tom Johnson, Water Resources Director Role) Chip Vanderzee, Public Services Director Terra Greens, City Manager Permit Citation Program Requirement Status Supporting Doc No. II.D.2.a IDDE Program The permittee maintained a written IDDE Program. No If yes, the written program includes provisions for program assessment and No ___ evaluation and integrating program. A draft written program is in development but not maintained. The permittee maintained an IDDE ordinance or other regulatory mechanism(s) that 6 provides the legal authority to prohibit illicit connections and discharges to the MS4. Yes II.D.2.b Legal Authorities If yes, the ordinance applies throughout the corporate limits of the permittee. Yes 6 [Permit Part I.D] II.D.2.c The permittee maintained a current map showing major outfalls and receiving No ___ Storm Sewer streams. System Map A maintained outfall map was not available at the time of the audit. II.D.2.d The permittee maintained a program for conducting dry weather flow field No --- Dry Weather Flow observations in accordance with written procedures. Program The permittee has begun a dry weather field observations program that began in March 2020. II.D.2.e The permittee maintained written procedures for conducting investigations of Investigation identified illicit discharges. NO ___ Procedures No written procedure has been maintained. 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 dates) the illicit discharge was observed Yes 9 2. The results of the investigation Yes 9 3. Any follow-up of the investigation Yes 9 4. The date the investigation was closed No --- The permittee documented 21DDE events which are ongoing. NCS000584_City of Lexington MS4 Audit_20200730 Page 9 of 20 Illicit Discharge Detection and Elimination (IDDE) II.D.2.g Employee Training The permittee implemented and documented a training program for appropriate municipal staff who, as part of their normal job responsibilities, may come into No --- contact with or otherwise observe an illicit discharge or illicit connection. IDDE Training has not been implemented. Covid statement is available for 2020. II.D.2.h Public Education The permittee informed public employees of hazards associated with illegal discharges and improper disposal of waste. No __- The permittee informed businesses of hazards associated with illegal discharges and No --- improper disposal of waste. The permittee informed the general public of hazards associated with illegal discharges and improper disposal of waste. No --- been implemented. Covid statement is available for 2020. IDDE Training has not II.13.2.i Public Reporting The permittee promoted, publicized, and facilitated a reporting mechanism for the public to report illicit discharges. Yes Website Mechanism The permittee promoted, publicized, and facilitated a reporting mechanism for staff No --- to report illicit discharges. The permittee established and implemented response procedures for citizen No requests/reports. SOP for IDDE is still in draft form. II—D_2J Enforcement The permittee implemented a mechanism to track the issuance of notices of violation and enforcement actions administered by the permittee. Not Applicable --- If yes, the mechanism includes the ability to identify chronic violators for initiation of actions to reduce noncompliance. Not Applicable AIAM/) Iff11�11 NCS000584_City of Lexington MS4 Audit_20200730 Nage iu or zu Pollution Prevention and Good Housekeeping for Municipal Operations Staff Interviewed: Roger Jones, Public Services Manager (Name, Title, Role) Tom Johnson, Water Resources Director Chip Vanderzee, Public Services Director Terra Greens, City Manager Permit Citation Program Requirement Status Supporting Doc No. II.G.2.a The permittee maintained a current inventory of facilities and operations owned Facility Inventory and operated by the permittee with the potential for generating polluted Yes 7 stormwater runoff. II.G.2.b The permittee maintained and implemented an O&M program for municipally Operation and owned and operated facilities with the potential for generating polluted No --- Maintenance (O&M) stormwater runoff. for Facilities If yes, the O&M program specifies the frequency of inspections. No --- If yes, the O&M program specifies the frequency of routine maintenance No --- requirements. If yes, the permittee evaluated the O&M program annually and updated it as No --- necessary. The O&M Plan is in draft form and has not been maintained and implemented. II.G.2.c Spill Response The permittee had written spill response procedures for municipal operations. No --- Procedures Draft Spill Response Procedures is available. II.G.2.d Streets, The permittee evaluated existing and new BMPs that reduce polluted stormwater Roads, and Public runoff from municipally -owned streets, roads, and public parking lots within its No --- Parking Lots corporate limits annually. Maintenance If yes, the permittee evaluated the effectiveness of existing and new BMPs No --- based on cost and the estimated quantity of pollutants removed. No annual evaluation of municipally owned infrastructure has been documented. II.G.2.f The permittee maintained and implemented an O&M program for the stormwater O&M for Catch sewer system including catch basins and conveyance systems that it owns and No --- Basins and maintains. Conveyance Systems O&M Plan is in draft form. II.G.2.d The permittee maintained a current inventory of municipally -owned or operated Structural structural stormwater controls installed for compliance with the permittee's post- Not Applicable Stormwater Controls construction ordinance. The City does not currently own/operate a structural Stormwater Control Measure. NCS000584_City of Lexington MS4 Audit_20200730 Page 11 of 20 Pollution Prevention and Good Housekeeping for Municipal Operations II.G.2.e The permittee maintained and implemented an O&M program for municipally - O&M for Structural owned or maintained structural stormwater controls installed for compliance with No --- Stormwater Controls the permittee's post -construction ordinance. If yes, then: The O&M program specified the frequency of inspections and routine No --- maintenance requirements. The permittee documented inspections of all municipally -owned or maintained No --- structural stormwater controls. The permittee inspected all municipally -owned or maintained structural No --- stormwater controls in accordance with the schedule developed by permittee. The permittee maintained all municipally -owned or maintained structural stormwater controls in accordance with the schedule developed by permittee. No --- The permittee documented maintenance of all municipally -owned or No --- maintained structural stormwater controls. No O&M Plan is maintained for the permittee. II.G.2.f The permittee ensured municipal employees are properly trained in pesticide, Yes 8 Pesticide, Herbicide herbicide and fertilizer application management. and Fertilizer Application The permittee ensured contractors are properly trained in pesticide, herbicide and Management g fertilizer application management. Yes --- The permittee ensured all permits, certifications, and other measures for Yes - -- applicators are followed. II.G.2.g The permittee implemented an employee training program for employees involved Staff Training in implementing pollution prevention and good housekeeping practices. No --- No documented training. II.G.2. The permittee described and implemented measures that prevent or minimize Vehicle and contamination of stormwater runoff from all areas used for vehicle and equipment No --- Equipment Cleaning cleaning. Draft O&M covers vehicle equipment cleaning. NCS000584_City of Lexington MS4 Audit_20200730 Page 12 of 20 Site Visit Evaluation: Municipal Facility No. 1 Facility Name: Public Works Date and Time of Site Visit: July 23, 2020 2:00pm Facility Address: 310 South Talbert St Facility Type (Vehicle Maintenance, Landscaping, etc.): Vehicle Maintenance/Landscaping Name of MS4 inspector(s) evaluated: Most Recent MS4 Inspection (List date and name of inspector): Roger Jones September 26, 2019 Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit: Name Title Roger Jones Public Services Director Observations Facility Documentation/Training Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific? No What type of Stormwater training do facility employees receive? How often? Specific Training has not been implemented. Inspector Training/Knowledge What type of Stormwater training does the MS4 inspector receive? How often? Specific Training has not been implemented. Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? Yes Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping? Yes Inspection Procedures Does the MS4 inspector's process include the use of a checklist or other standardized form? Yes Does the MS4 inspector's process include taking photos? Yes Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)? N/A Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge? Yes Did the MS4 inspector miss any obvious areas of concern? If so, explain: No Does the MS4 inspector's process include presenting the inspection findings to the facility contact? Yes Inspection Results Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)? No NCS000584_City of Lexington MS4 Audit_20200730 Page 13 of 20 Site Visit Evaluation: Municipal Facility No. 2 Facility Name: Date and Time of Site Visit: Wastewater Treatment Plant July 23, 2020 3:15pm Facility Address: Facility Type (Vehicle Maintenance, Landscaping, etc.): 500 Glendale Road Wastewater Treatment Plant Name of MS4 inspector(s) evaluated: Most Recent MS4 Inspection (Date and Entity): Roger Jones July 12, 2019 Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit: Name Title Tom Johnson Water Resources Director Observations Facility Documentation/Training Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific? Yes What type of stormwater training do facility employees receive? How often? Specific Training has not been implemented. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Specific Training has not been implemented. Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? Yes Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping? Yes Inspection Procedures Does the MS4 inspector's process include the use of a checklist or other standardized form? Yes Does the MS4 inspector's process include taking photos? Yes Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)? No Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge? Yes Did the MS4 inspector miss any obvious areas of concern? If so, explain: Yes. One area where biosolids had been pushed outside of the containment area. Does the MS4 inspector's process include presenting the inspection findings to the facility contact? Yes Inspection Results Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)? No If compliance corrective actions were identified, what timeline for correction/follow-up was provided? Not discussed. NCS000584_City of Lexington MS4 Audit_20200730 Page 14 of 20 Site Visit Evaluation: MS4 Outfall No. 1 Outfall ID Number: Date and Time of Site Visit: None Given July 23, 2020 2:50pm Outfall Location: Outfall Description (Pipe Material/Diameter, Culvert, etc.): Corner of Fairview Dr. and Kirkwood Ave. Metal Pipe Receiving Water: Is Flow Present? If So, Describe (Color, Approximate Flow Rate, Undetermined Sheen, Odor, Floatables/Debris, etc.): Flow is present. Appears clear. Most Recent Outfall Inspection/Screening (Date): Not evaluated Days Since Last Rainfall: Inches: Not reviewed N/A Name of MS4 Inspector(s) evaluated: Roger Jones Observations Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Specific Training has not been implemented. Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations? Yes Inspection Procedures Does the inspector's process include the use of a checklist or other standardized form? Yes Does the inspector's process include taking photos? Yes Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they? No Inspection Results Did the outfall inspection result in any work orders or maintenance requests? If so, for what issue(s)? Not determined. Will a follow-up outfall inspection be conducted? If so, for what reason? Yes. Routine. Notes/Comments/Recommendations NCS000584_City of Lexington MS4 Audit_20200730 Page 15 of 20 APPENDIX B: PHOTOGRAPH LOG Public Works Facility NCS000584_City of Lexington MS4 Audit_20200730 rarc -LU Vehicle Washing Area at Public Works Facility NCS000584_City of Lexington MS4 Audit_20200730 Page 17 of 20 WWI �, ' � yG e,+`?.\�. ` k }■.� ��, , R _ ■� `'.� � � O 1 11 .,�. �i+. � fHy] � �_, •,�1���, r. `�Y-..t.� �. - $h sf •fit z ) '� �ti4 1t� e '� R i '.WT \ . ,� �� �„ i � _ ,� '�A'� ,. .t L.l,�{ �•h' �I 1�r..'. � y■ p J '1�!�b' � fwy, ��!'� _ i � _. -- '�:.tR ♦ � `�3�,,, �:p \ Y ! + 1 �1. �, y +K � � l K:o `+t., ? �''�lit*'��t ..j 1 . . +ry a � � , � try ~=a a },,{� • t�pp * " a i 41 jy� 3—, � :. ��� ■ : `` �,^' to � 4 ,..Ebr r y ".r-gFfy Wastewater Treatment Plant NCS000584_City of Lexington MS4 Audit_20200730 Page 19 of 20 Biosolids overspill at WWTP NCS000584_City of Lexington MS4 Audit_20200730 Page 20 of 20