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.