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HomeMy WebLinkAboutNCS000587_GapAnalysisSummary_20200917NoWithersRavenel Our People. Your Success. MEMORANDUM To: Mark Taylor - Public Works Director, City of Statesville CC: Raymond Allen - Stormwater Maintenance Technician From: Lars R. Hagen Jr., Kathleen Balaze, Katherine Knight - WithersRavenel Date: July 17, 2020 Project: City of Statesville Stormwater Consultation, WR Job No. 02190843 Subject: Gap Analysis Executive Summary Background In 2019, the North Carolina Department of Environmental Quality (DEQ) in conjunction with the Environmental Protection Agency (EPA), began National Pollutant Discharge Elimination System (NPDES) Permit Compliance Audits of Phase II Municipal Separate Storm Sewer System (MS4) communities in North Carolina. The MS4 program is intended to protect water quality by preventing pollution from entering the storm sewer system, which leads directly to surface waters of the state. Most communities in the initial audits received Notices of Violation for permit noncompliance, constituting violation of the Clean Water Act and grounds for enforcement action. The audits have been incorporated as a regular part of the NPDES permit renewal process, which occurs every 5 years. As a Phase II community the City of Statesville will be subject to an audit performed by the DEQ, which is currently scheduled for this year. The City of Statesville retained WithersRavenel to provide consultation in preparation for the audit. The NPDES Permit requires MS4 Stormwater Program implementation provisions as well as specific program components called the "Six Minimum Measures". These components include: • Public Education and Outreach • Public Involvement and Participation • Illicit Discharge Detection and Elimination (IDDE) • Construction Site Runoff Control • Post -Construction Site Runoff Control • Pollution Prevention and Good Housekeeping for Municipal Operations (PPGH) Approach WithersRavenel completed a Pre -Audit Gap Analysis of the City of Statesville's MS4 Stormwater Program to compare the current program to NPDES Phase II MS4 Permit requirements. Attached is the Gap Analysis Matrix detailing the individual permit requirements by section, status, actions currently performed by the City and others, and additional actions to address. This memorandum summarizes the findings of the Gap Analysis and highlights significant outstanding permit requirements that should be addressed as part of the City's MS4 Stormwater Program. Current MS4 Stormwater Program At this time the MS4 Stormwater Program is overseen by the Stormwater Program Manager, a position that was created in 2019, following implementation of a City stormwater fee. The position of Stormwater Program Manager is currently vacant, but is being backfilled. The 5-member total stormwater staff maintains the stormwater network, addresses stormwater work orders, facilitates public outreach and involvement activities, and continues to develop and perform MS4 Stormwater Program administrative duties. 115 MacKenan Drive I Cary, NC 27511 t: 919.469.3340 1 f: 919.467.6008 1 www.withersravenel.com I License No. C-0832 Asheville I Cary I Greensboro I Pittsboro I Raleigh I Wilmington :0 WithersRavene[ City of Statesville Gap Analysis Executive Summary Our Pec,ie Your Su[[es _ Permit requirements that are performed or partially performed include: completion of the 2018 and 2019 annual reports, public education and outreach, employee training, advertisement of a stormwater hotline, inspections, and maintenance of a webpage. Not all of these items fully satisfy permit requirements; please refer to the gap analysis for all permit requirements. Prior to 2019, many of the stormwater program activities were not formally documented. Currently, program documentation and tracking primarily takes place through logging in Excel with a plan to transition to Hiperweb. Several partners implement other components of the MS4 Stormwater Program. The City relies on the State Sedimentation and Erosion Control Program, delegated to Iredell County, for Construction Site Runoff Control. Site plan reviews for Post -Construction Site Runoff Control were formerly conducted by the Public Works Director and are currently conducted by stormwater staff. Several reviews have recently been completed with support from WithersRavenel. ?eauired Actionr- While strides have been made to move forward, the City needs to take action and commit additional resources to the MS4 Stormwater Program to meet permit requirements. Detailed permit requirements and action items are listed in the attached Gap Analysis matrix. Following is a summary of major tasks that should be addressed by the MS4 Stormwater Program. Stormwater Management Plan The City has an existing Stormwater Management Plan (SWMP) document that was submitted with the permit application in 2016. Although the SWMP covers all of the "Six Minimum Measures" for permit compliance, all of the best management practices (BMPs) have not been implemented. There are also missing requirements such as identification of specific residential and commercial/industrial issues to target. Jewell Engineering is preparing an updated SWMP. The new SWMP should reflect the proposed changes to the MS4 Stormwater Program. Once the SWMP has been developed, it should be published online. The City has contracted ESP, a consultant, to perform geographic information system (GIS) mapping of the City's stormwater system and at this time it is estimated that 50% of outfalls are mapped. The MS4 Map should identify the City's stormwater network, major outfalls, receiving waters, and privately -owned and publicly -owned stormwater control measures (SCMs). The City has indicated SCMs approved after July 2019, when the Post -Construction Ordinance took effect, will be added to the stormwater map. Any additional public or privately -owned SCMs within the City should be identified for inspections. In anticipation of future permit requirements, it is recommended that any new mapping includes additional information such as pipe size, material, contributing drainage area, and flow direction. In order to be compliant with permit requirements, the City must identify and inspect all outfalls and SCMs by the end of the permit cycle in 2021. Plan Reviews The City has recently adopted a post -construction stormwater control ordinance, but does not have an enforcement tracking mechanism. Portions of the ordinance such as requiring plans to meet the State Minimum Design Criteria and deed restrictions are not yet enforced. Plan reviews were previously performed by the Public Works Director and are currently performed by stormwater staff. It is recommended that an assessment of the plan review program be performed during a funding and financial analysis to determine the appropriate time and resource commitments necessary to meet this permit requirement, whether internally or by a third -party. Page 2 of 4 :0 WithersRavene[ City of Statesville Gap Analysis Executive Summary Our People. Your Sutces _ Employee Training The NPDES Permit requires training of municipal employees for several of the "Six Minimum Measures". The City should continue to perform current training and documentation and expand the program to include all of the following training requirements: • Hotline training for the hotline operator (continue) • IDDE training for employees who may encounter illicit discharges (continue) • Spill response training for employees who handle polluting materials and/or respond to spill response calls (continue) • PPGH, pesticides/herbicides/fertilizer, and general stormwater awareness training for municipal employees who handle polluting materials and perform vehicle/equipment maintenance and cleaning (continue) • SCM inspections training for employees who conduct inspections (continue) The Post -Construction Runoff ordinance was recently updated, but additional items may be required. It is recommended that a full ordinance review is conducted with review by DEQ, however at a minimum, the following ordinances should be reviewed and updated: • Illicit Discharge Ordinance - a draft ordinance has been created and had its first reading at City Council • Consider addition of a pet waste litter prohibition *This list of ordinances is neither meant to be exhaustive nor a full ordinance review Education and Community Involvement The Public Education and Outreach and Public Involvement and Participation minimum measures require opportunities for education and community involvement in stormwater issues. Specific residential and commercial stormwater issues should be identified and targeted for education. It is recommended that additional venues for community interaction are developed to include volunteer opportunities such as an adopt-a-stream/catch basin or storm drain marking programs. Program Documents Each of the "Six Minimum Measures" requires development of program documents such as standard operating procedures (SOPs), Inspections and Maintenance (I&M) manuals, and tracking mechanisms for documentation. The following documents should be created or updated as supplements to the MS4 Stormwater Plan for implementation of the program: • Create tracking and documentation mechanisms for the BM Ps developed in the new SWMP • Create a list of responsible parties for program implementation (an example list can be found in DEQ SWMP template) • Perform a fiscal analysis to determine the adequacy of current budget for the MS4 Stormwater Program and include in the Annual Self -Assessment • Create a list of target pollutants, target audiences, and known stormwater issues for three high - priority issues (an example list can be found in DEQ SWMP template) • Create a list of watersheds in protection (if any) • Update the City stormwater webpage to include the following: o The state Stop Mud hotline o The new SWMP, when complete • Create the following IDDE documents: o Dry weather flow inspections SOP that identifies priority outfalls and documents a method for completing inspections of all major outfalls within the permit cycle o Investigation SOP that includes: ■ A method to investigate suspected illicit discharges Page 3 of 4 ::W i thersRave n e l City of Statesville Gap Analysis Executive Summary Our People. Your Success. ■ An IDDE-specific tracking mechanism with dates, the results of the investigation, any follow-up of the investigation, and the date the investigation was closed to help identify chronic violators Create an inventory of private and municipal -owned post -construction SCMs Create post -construction SCM inspection SOPS and enforce requirement of yearly inspections Create the following PPGH documents: o Inventory of municipal facilities with major outfalls and receiving streams identified o PPGH O&M Plans for municipal facilities and municipal -owned SCMs o PPGH SOPS ■ Street/parking lot maintenance, street sweeping, and leaf pickup SOPs ■ Vehicle and equipment maintenance and cleaning SOPs ■ Spill response/spill kit use SOPs o Proactive PPGH O&M Plan for the storm sewer system The above serves as a summary of major tasks/action items required by the NPDES permit. Please refer to the attached Gap Analysis for a detailed list of each permit requirement. Page 4 of 4 City of Statesville Stormwater Program Gap Analysis Status Regulatory Program Program Requirement (Ycs/No/ NPDES Phase 2 Permit MWel—ed by �ncl party Additional Actions Needed Effective Permit No. NC5000587 e 11/11/16 within the City of Statesville Jurisdictional Address gap analysis items before permit expires and the 2020 State Area. Expires 11/10/2021. DEQ Audit scheduled for 2020 audit is performed I. Permit Coverage Maintain a narrative description of the program, a table that A SWMP was submitted with the 2016 permit application identifies each best management practice frequency of which meets some, but not all permit requirements such as Jewell Engineering is in the process of updating the A new SWMP may be required to be developed in conjunction with I.I. Stormwater Management Plan implementation the BMP, the measurable goals for each BMP, MP, the implementation Partial responsible parties and identification of specific residential SWMP the audit process schedule, funding and the responsible person or position for and commercial/industrial issues to target implementation An IDDE ordinance has been drafted, however it allows Recent communication with DEMLR has indicated that non - 1.9. Non-Stormwater Flow Evaluation Determine if non-Stormwater flows significantly impact water Partial discharges from non-commercial car washing and street wash commercial car washing and street wash water are not considered quality water acceptable discharges. The City should review acceptable discharges with DEMUR and determine which to allow II. A Program Implementation Section 8.05 of the Statesville Code of Ordinances covers A.I. Legal Authority Maintain legal authority for implementing the Stormwater Partial stormwater management. A draft IDDE ordinance has been As the draft IDDE ordinance has not been adopted, recommend a Management Plan through ordinance, regulations, or policies developed but not yet adopted therefore the City does not complete ordinance review and update with review by DEMLR have all of the required authority Perform yearly program financial evaluation in conjunction with The annual DEMLR SWMPA has been completed with basic Perform a yearly financial evaluation to supplement the annual self A.2. Plan Evaluation annual self -assessment Partial information regarding staffing and budget, but an evaluation assessment of financials has not been recorded The stormwater program has 5 positions, and the Stormwater A.3. Funding and Personnel Maintain adequate funding, identify specific positions and Partial Program Manager position is currently being backfilled. The Perform a yearly financial evaluation to determine if the program is responsibilities for program implementation program is funded through a Stormwater utility, but a still adequately funded by the Stormwater utility complete program budget analysis has not been performed Document and assess Stormwater Management Plan performance An annual report was prepared for 2018 and 2019 using the Include an assessment of data collected on BMP performance and A.4/5. Assess and Update Plan and update when necessary Yes state template and documents program status for the year document proposed changes to the Stormwater Management Plan but limited assessment or updates to the plan have occurred during yearly self -assessments II. "Six Minimum Measures" B. Public Education and Outreach The City had an extensive public education effort about the implementation of the stormwater utility fee, but minimal B.I. Objectives Distribute educational materials and perform citizen outreach Partial outreach on other aspects of Stormwater since then. The Revise and update the written public education and outreach plan 2016 SWMP documents a plan for Public Education and and implement for general Stormwater education Outreach on stormwater impacts but it is not apparent that this program has been implemented B.2. BMPs and Measurable Goals Goals of program based on three high -priority community -wide Specific goals and objectives identifying and targeting three Develop goals for the public education program and a list of three B.2.a. Identify Goals and Objectives issues NO issues have not been developed high -priority community -wide stormwater issues based on target pollutants, target audiences, and known stormwater issues The 2016 SWMP identifies increasing urbanization and the B.21. Identify Target Pollutants Maintain a list of target pollutants and likely sources Yes resulting sediment, chemicals, and debris as target pollutant sources Review existing target pollutant sources and revise as necessary B.2.c. Target Audiences Identify target audiences for stormwater education and assess annuall yes The2016 SWMP identifies the general public and businesses as the target audiences for the program Review existing target audiences and revise as necessary Residential and Commercial/Industrial Identify a minimum of three residential and three Specific residential and commercial/industrial issues have not Develop a list of three residential and three commercial/industrial Issues Issue commercial/industrial issues and target for public education and No been formally identified or documented stormwater issues based on target pollutants, target audiences, and outreach known stormwater issues Identify watersheds in protection and describe in public education The 2016 SWMP does not identify specific watersheds in Evaluate Statesville M54 Permit area to determine if any watersheds B.2.e. Watershed Protection and outreach measures NO protection in protection, then develop public education and outreach materials to target the identified watersheds The stormwater division has a webpage, however this Add additional information to the web page including the State "Stop B.2.f. Web Site Maintain and update a website with stormwater issues Partial webpage is still under construction and has limited Mud" hotline and updated SWMP when completed educational material at this time B.2.g. Distribute Public Education and Distribute educational materials and perform citizen outreach and A stormwater management brochure was included as a utility Develop additional educational materials specific to target Outreach Materials assess the materials Yes bill insert and the Stormwater Department set-up an audiences/issues after identified and distribute u educational booth at the City Halloween event B.2.h. Stormwater Hotline Maintain and promote a stormwater hotline/helpline and provide Yes The City has established a stormwater hotline and conducted Document calls and the resulting actions employee training for hotline one hotline operator training to date 6.2.i. Develop and Document Program Document and assess the effectiveness of the Public Education partial The program is documented in the Annual Report However, Continue to document program activities. Assess public education and Outreach Program there has not been assessment of program effectiveness and outreach BMPs in future annual self -assessments Prepared for STORMWATBR DIVISION July 2020 Prepared by A■ WithersRavenel r. t)ur People. Your Success. City of Statesville Stormwater Program Gap Analysis Status Regulatory P,ogram� Program Requirement (Yes/No/ Currently Performed by City of Statesville Currently Performed by 3,d] Part, ddiri ... I Actions Needed C. Public Partici a[ion/Involvement Comply with applicable State, Tribal, and local public notice The State requires public comment on new permits, which Update the written public participation/involvement program and C.1. Objectives requirements. Provide opportunities for public involvement and Yes will be issued following the audit. The City has a Stormwater document mechanisms for evaluating the effectiveness of the participation Advisory Commission which provides public input on stormwater issues program. Continue to comply with public notice requirements during Program development C.2. BMPs and Measurable Goals C.2.a. Public Review and Comment of Conduct one public meeting per permit term for comment and Public meetings were held regarding the implementation of Hold a public meeting for comment and review of SWMP prior to the Stormwater Plan review of Stormwater Management Plan No the SW utility, but have not been held for review and end of the permit term. Recommend holding the meeting to review comment on SWMP the SWMP developed through the audit process Provide and promote volunteer opportunities for citizen City staff stated that storm drain stenciling has been done as Provide additional volunteer opportunities, such as stream/litter clean participation avolunteer activity in the past ups, and document The Stormwater Advisory Commission was created in December 2016 and is comprised of residents and individuals Continue to hold and document Stormwater Advisory Commission C.2.c. Public Involvement Provide a mechanism for public input on stormwater issues Yes with business interests in the City of Statesville with a meetings. Offer opportunities for the general public to have input mission to help evaluate the development of a stormwater through public meetings or through updates to City Council utility C.2.d. Stormwater Hotline Maintain and promote a stormwater hotline/helpline and provide Yes The City has established a stormwater hotline and conducted Publicize the hotline on the stormwater webpage and document calls employee training for hotline one hotline operator training to date and the resulting actions D. Illicit Discharge Detection and Elimination (IDDE) At this time the City has not implemented an IDDE program, but has contracted mapping of the stormwater system, and D.1. Objectives Implement and enforce an IDDE Program within 60 months of the Partial begun to generate a written IDDE program. According to the Develop a plan to implement a complete IDDE program prior to the start of the permit current permit, the City has until the end of the current end of the permit term in November 2021 permit cycle in November 2021 to implement a complete program D.2. BMPs and Measurable Goals Prohibit, through ordinance or other regulatory mechanism, non- An IDDE ordinance has been drafted and has had a first D.2.a. IDDE Ordinance storm water discharges into the storm sewer system and No reading by the City Council, but it has not been adopted at As the draft IDDE ordinance has not been adopted, recommend a implement appropriate enforcement procedures and actions this time. The draft ordinance gives the City the authority to complete ordinance review and update with review by DEMLR prohibit illicit discharges and implement penalties for violators Maintain a storm sewer system map that shows the location of all At this time, a storm sewer system map does not exist, but Identify major outfalls, receiving waters, conveyance type, material, D.2.b. Storm Sewer Map major outfalls, receiving waters, conveyance type, material, shape Partial the City has contracted with an engineering firm to perform ESP has identified an estimated 50%of outfalls shape and size. Continue to update the map as new development and and size storm sewer system mapping re -development occurs and if additional outfalls are identified Develop and implement a written dry weather outlet field At this time, major outfalls have not been identified and a dry After major outfalls are identified, develop a dry weather outlet D.2.c. Dry Weather Flow Detection screening program NO weather flow screening program has not been developed screening program so that each outfall is inspected at least once per permit term and "hot spots" are inspected more frequently The City utilizes the EPA "Illicit Discharge Detection and Develop and implement a written program for investigation of Elimination: A Guidance Manual for Program Development Update the written IDDE program and document how HiperWeb or D.2.d. Illicit Discharge Detection Program potential illicit discharges Partial and Technical Assessments' document as a guide for illicit tracking spreadsheets will be used for IDDE-specific tracking City -specific discharge detection, but a program does not exist Track all investigations and document suspected illicit discharge The City currently uses an Excel sheet to document Document how HiperWeb or tracking spreadsheets will be used for D.2.e. Documentation dates, the results of the investigation, any follow-up of the Partial investigations in conjunction with storm sewer system IDDE-specific tracking with dates, results of the investigation, follow - investigation, and the date the investigation was closed maintenance, and going forward will utilize HiperWeb up, the date the investigation was closed, and enforcement actions The City has performed training for general stormwater D.2.f. Employee Training Develop, implement, and document an employee training program Yes awareness, IDDE, and GHPP for approximately 20 Continue to perform and document IDDE-specific employee training for employees who may encounter illicit discharges employees. The City plans to perform additional training for GHPP inspections D.2.g. Public Education Develop public education materials for the hazards of illegal No The City does not have public education materials covering Develop IDDE specific public education materials and distribute discharges and improper disposal of waste the hazards of illegal discharges or improper disposal of waste D.2.h. Public Reporting Mechanism Develop, publicize, and document a mechanism for the public to Yes The City has established a stormwater hotline and conducted Document calls and the resulting actions report illicit discharges one hotline operator training to date D.2.i. Septic Systems Develop written procedures to identify and report failing septic NO Iredell County permits septic systems and the City does not Develop a SOP for identifying and reporting failing septic systems and systems to the County Health Department have an inspections and reporting SOP train appropriate employees D.2.1. Sanitary Sewer Overflows Develop written procedures to notify the system operator of NO The City does not have an SOP for reporting sanitary sewer Develop a SOP for identifying and reporting sanitary sewer overflows sanitary sewer overflows and sewer leaks overflows or sewer leaks and sewer leaks and train appropriate employees Develop and document an enforcement tracking mechanism to The City currently uses an Excel sheet to document Document how HiperWeb or tracking spreadsheets will be used for D.2.k. Enforcement help identify chronic violators Partial investigations in conjunction with storm sewer system IDDE-specific tracking with dates, results of the investigation, follow - maintenance, and going forward will utilize HiperWeb up, the date the investigation was closed, and enforcement actions While the Fire Department has procedures for spill/dumping response and individual facilities have spill response Develop written procedures for spill/dumping response and train D.2.I. Spill Response Develop written procedures for spill/dumping response No procedures in accordance with required SWPPs, there are no appropriate employees written procedures on file for general stormwater response to spills/dumping Prepared for CITY of ��� STORMWATBR DIVISION July 2020 Prepared by A■ WithersRavenel r. t)�r People. Your Success. City of Statesville Stormwater Program Gap Analysis Status Program Requirement (Yes/No/ Currently Performed by City of Statesville Currently Performed by 31rd Party Additional Actions Needed E. Construction Site Runoff Control The permittee may rely on another entity for the Sedimentation A draft interlocal agreement with Iredell County is in the The City relies on Iredell County for Construction Site Maintain the written agreement on file for the upcoming 2020 audit, E.I. Delegation and Erosion Control Program Partial process of being finalized Runoff Control and an interlocal agreement is being document sediment/erosion control letters and follow-up (e.g. finalized situation remedied, forwarded to the state for follow-up, etc.) E.2. NCG010000 permit The General Permit establishes construction site runoff control Yes Construction site runoff control is established through the N/A requirements general permit The City stormwater hotline or the State "StopMud" hotline E.3. Public Reporting Mechanism Develop, publicize, and document a mechanism for the public to Partial could be used to report sedimentation and erosion control Advertise the stormwater and/or State "Stop Mud" hotline on the report sedimentation and erosion control issues issues, but a sediment and erosion control -specific reporting stormwater web page mechanism does not exist F. Post -Construction Runoff Control The City has recently implemented the appropriate Implement and enforce a Post -Construction Site Runoff Control ordinances but does not have an enforcement tracking Establish best practices and tracking mechanisms for the post- F.l.Objectives Program within 24 months of the start of the permit Partial mechanism, plan reviews were previously performed by the construction site runoff control program, including developing an Public Works Director and are currently performed by the enforcement tracking mechanism stormwater group F.2. BMPs and Measurable Goals Develop and implement ordinance to give the authority to review Stormwater Ordinance (Section 8.05 of the UDO) was revised F.2.a. Post -Construction Ordinance designs for new/re-development and perform inspections Yes and effective July 1, 2019. The revised ordinance gives necessa authori N/A While the stormwater ordinance references the NCDEQ F.2.6. Adopt NCDEQ Manual Adopt the NCDEQ stormwater Design Manual, or meet or exceed Partial Stormwater Design Manual for SCM design criteria, it is Document how reviewed plans meet the Minimum Design Criteria in the requirements in the manual unclear if previous plan reviews required SCMs to meet the the NCDEQ Stormwater Design Manual criteria UDO Section 8.05 is applicable to development or redevelopment that disturbs more than 1 acre or adds more Conduct site plan reviews for new/re-development for sites that than 20,000 SF impervious cover and makes assistance with WithersRavenel previously assisted the City with plan Document plan reviews and standards, determine if funding and F.2.c. Plan Reviews disturb greater than one acre Yes review and approval/disapproval a duty of the Stormwater reviews and the development of a review checklist, but staffing are adequate to continue plan reviews by the Public Works Administrator. Plan reviews were previously performed by the stormwater group currently performs reviews Director or outside firm the Public Works Director and are currently performed by the stormwater group The City Planning Department maintains an inventory of post- Review the existing inventory and supplement as needed. Update the construction SCMs with approximately 7 total, but it is stormdsinclude locations of public and privately- system map to F.2.d. SCM Inventory Maintain an inventory of post -construction SCMs Partial unclear if it is complete. The City has indicated SCMs ownepost-constructionewer Update the inventory as new SCMs approved after the July 2019 adoption of the Post- are developed Construction Ordinance will be added to the map Impose or require recorded deed restrictions and protective The City Ordinance requires deed recordation and protective F.2.e. Deed Restrictions and Protective cove pment activities will maintain the pants that ensure development Partial covenants to ensure low and high -density sites are consistent Require deed recordation and covenants for new projects Covenants project consistent with approved plans with approved plans, however the ordinance has not been enforced The recently revised ordinance requires O&M agreements for Require O&M plans for structural SCMs and require SCM owners structural SCM,, that SCM, are maintained to function as Develop a tracking mechanism for annual inspection reports received F.2.f. SCM O&M to perform and submit a record of annual inspections Yes intended and that owners submit an annual inspection report from SCM owners prepared by a licensed engineer using forms supplied by the City F.2.g. Inspections Inspect each project site before issuing a certificate of occupancy Yes No inspections have been performed to date, but City staff Inspect all SCMs prior to the end of the permit term and document and at least once per permit term and document has been recently trained for inspections Publicize ordinances, post -construction requirements, and design Draft of City stormwater ordinance is published on Link stormwater-specific ordinances on the stormwater webpage and F.2.h. Educational Materials for Developers standards for developers Partial stormwater webpage but final adopted ordinance has not update Municode with revised ordinance. Plan and document been posted and municode reference has not been updated developer publicity and education Develop and document an enforcement tracking mechanism to Develop a Post -Construction Runoff Control -specific tracking F.2.1. Enforcement help identify chronic violators No Enforcement actions have not been required as of yet mechanism with dates, the violation, follow-up, the date the violation was resolved, and enforcement actions Prepared for CITY of ��� STORMWATER DIVISION July 2020 Prepared by A■ WithersRavenel r. air People. Your Success. City of Statesville Stormwater Program Gap Analysis G. Pollution Prevention and Good Housekeeping Status (Yes/No/ Currently Performed by City of Statesville Currently Performed by 3,d Party Additional Actions Needed for Municipal Operations (PPGH) Implement and enforce a PPGH Program including employee While some PPGH activities have been completed, a formal Update the written PPGH program and document mechanisms for G.1. Objectives training within 60 months of the start of the permit Partial program is not in place, however the city has until March evaluating the effectiveness of the program 2021 to build a full program to be in compliance G.2. BMPs and Measurable Goals G.2.a. Inventory of Municipal Facilities Maintain an inventory of municipal -owned facilities and operations Yes The City maintains a Google Earth Map and list of municipal Update the inventory when necessary, and continue to assess with the potential to pollute stormwater and assess annually facilities annually. Recommend adding the locations to the M54 map Maintain a map that shows municipal -owned facilities and identify The City maintains a Google Earth Map and list of municipal Add identification of outfalls and receiving streams for each facility to G.2.b. Municipal Facility Map stormwater outfalls and receiving streams Partial facilities, but no outfalls are identified the inventory. Update the inventory when necessary, and continue to assess annually. Recommend adding the locations to the M54 map Develop operations and maintenance (O&M) and document O&M plans are under development, but are not finalized. Develop O&M plans for municipal facilities with potential to pollute G.2.c. O&M Plans for Municipal Facilities programs for municipal -owned facilities and operations that No There have been limited facility inspections which are stormwater, complete inspections of all facilities and continue to specify frequency of inspections and routine maintenance documented in HiperWeb document While the Fire Department has procedures for spill/dumping Develop and implement written spill response procedures for response and some individual facilities have spill response Develop written procedures for spill response in municipal operations G.2.d. Spill Response municipal operations No procedures in accordance with required SWPPs, there are no and train appropriate employees written procedures on file for general stormwater response to spills/dumping in municipal operations Develop BMPs to reduce pollution to stormwater from municipal- The City has some street sweeping capabilities and a leaf Develop written BMPs for municipal streets, roads, and parking lot G.2.e. Street, Road, and Parking owned streets, roads, and parking including street sweeping and Partial collection program but does not have formal BMPs or maintenance including developing and implementing a street Maintenance leaf pickup maintain records sweeping program and leaf pickup, include metrics for evaluation of the ro ram effectiveness Develop and document an O&M program for the storm sewer There is not a written O&M plan for the storm sewer system, Develop and follow a written O&M plan for proactive stormwater G.2.f. O&M Plan for Stormwater System system including catch basins and conveyances NO although maintenance of the storm sewer system does occur system maintenance, such as a schedule for catch basin and conveyance cleaning Maintain a map that shows the locations of municipal -owned and The City has three SCMs at the regional airport and one at a Determine if the City owns any additional SCMs, map and perform G.2.g. Municipal SCM Map operated SCMs, their outfalls, and receiving waters No park but there may be additional unknown municipal -owned inspections for all identified municipal SCMs SCMs at this time Develop and document O&M programs for municipal -owned The City has three SCMs at the regional airport and one at a Determine if the City owns any additional SCMs, map and perform G.2.h. O&M Plans for Municipal SCMs SCMs that specify frequency of inspections and routine No park but there are no other known municipal -owned SCMs at inspections for all identified municipal SCMs maintenance and document inspections this time Approximately 20 employees attended the Regional Develop, implement, and document an employee training program Stormwater Partnership of the Carolinas' Municipal Staff Continue to train employees and document. Develop a written plan G.2.i. Employee Training for employees who will implement PPGH measures Partial Training in Spill Response, Illicit Discharges, and Good for employee training as of the SWMP Housekeeping in 2019. Additional City and site specific part stormwater training is being planned at this time G.2.j. Vehicle and Equipment Cleaning q Develop BMPs to prevent stormwater pollution from vehicle and Partial While the City has BMPs for vehicle and equipment cleaning, Develop written BMPs for municipal vehicle and equipment cleaning equipment cleaning they are not documented in writing include metrics for evaluation of the program effectiveness Tailor BMPs to enhance water quality recovery strategies in the Tailor BMPs and d Stormwater Management Plan n to address lanthos H. Impaired Waters watersheds of impaired waters and describe the BMPs in the No BMPs have not been explicitly tailored to impaired waters. impairments turbidity, fecal coliform and annual report I. TMDLs Comply with Total Maximum Daily Load (TMDL) requirements N/A Currently no TMDL Waste Load Allocations (WLA) for Comply with any TMDL requirements that may exist in the future stormwater in the City Pet waste management (can be achieved through litter ordinance); There is no ordinance relating to pet waste management. 'Fecal coliform on -site domestic wastewater treatment (can be coordinated with No Septic systems are regulated by Iredell County, but there is Amend or adopt a litter ordinance prohibiting pet waste and establish County Health Department) not a procedure in place for coordinate between the City and a procedure for communication regarding failing septic systems County 'Publish Plan Online Publish the plan and related ordinances online Partial Ordinances are published on online Publish the Stormwater Management Plan on the Stormwater webpage 'Not in current permit, will be required next permit cycle Prepared for CITY of ��� STORMWATER DIVISION July 2020 Prepared by A■ WithersRavenel r. air People. Your Success. City of Statesville Stormwater Program Gap Analysis Regulatory Program Program Requirement (yes/N./ 'unrerruy III. Pro ram AssessmeMllllllll Currently Performed by 3rd Party Additional Actions Needed The annual reports prepared by the City demonstrate that minimal documentation of some program components is Document all program components with more thorough 111.1. Plan Implementation Document all program components and retain records for 5 years Partial performed and City staff indicate annual reports are kept for documentation that is accessible and maintained by all stormwater at least 5 years. However, not all program components are employees and retain records for 5 years implemented and therefore not documented Annual reports have been prepared by City staff and Review the Stormwater Plan annually and submit reports to the submitted to the DEQ. The DEMLR online annual Continue to perform annual -self assessments, develop the written 111.2. Plan Review DEQ Partial "Stormwater Management Program Assessment' was Stormwater Management Plan and evaluate program components completed in 2019 as well. Not all program components have annually been evaluated as not all have been fully implemented IV. Reporting and Record Keeping The City keeps records of service requests, training and education, "Hot Lists", inspection/maintenance logs, and Continue developing program documentation for all program W.I. Record Keeping Document all program components and retain records for 5 years Partial current development projects. Not all program components have been documented as not all have been fully components. in, No sampling or measurements, as described in permit, have Once storm sewer inspection begins, record inspection information, IV.2. Recording Results Describes requirements for monitoring and inspection records No been performed. including individual performing inspection, and determine if any sampling is necessary. IV.3. Annual Reporting Review the Stormwater Plan annually and submit reports to theortin Yes An annual report was prepared for 2018 and 2019 using DEQ, describes reporting g requirements BIMs IVA. 24-Hour Reporting Report non-compliance that constitutes an imminent threat to No Non-compliance that would require reporting has not been Develop an SOP for determining reportable events and report non - health or the environment within 24 hours to the DEQ discovered compliance when identified and train appropriate employees Prepared for CITY of ��� STORMWATBR DIVISION July 2020 Prepared by A■ WithersRavenel r. t)�r People. Your Success.