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HomeMy WebLinkAboutNCS000542_Henderson Self Assessment_20210105/► _COM Imagine it. ME Delivered. To: Clark Thomas Director of Engineering City of Henderson NC CC: Ian Harshbarger, Logan Tyndall Memorandum AECOM 1600 Perimeter Park Morrisville, NC 27560 aecom.com Project name: City of Henderson MS4 Support Project ref: 60598295 From: Melanie Gardner and Sujit Ekka Date: August 15, 2019 Subject: Self -Assessment of Existing Stormwater Program and Gap Analysis The goal of this memorandum is to identify compliance gaps between the City of Henderson's (also referred as "COH" or the "City" hereafter) current stormwater program and the requirements identified in the City's NPDES permit NCS000542 issued February 20, 2017. This gap analysis will be used to identify program development recommendations including specific program area recommendations, and a schedule to maintain compliance with the NPDES permit. The summary below details the program gaps organized by program area as listed in Part II of the permit. The program status terminology used in this memorandum is defined as: - Gap: Currently, this measurable goal is not in compliance, and there are no ongoing efforts to attain the goals either. - Under Development: Currently, this measurable goal is not in compliance, but City is taking steps towards attaining compliance. - In Progress/Ongoing: The measurable goal is currently in compliance, but continuous action is needed. - Complete: The measurable goal is in compliance, and no further action is needed. The measurable goals presented in this memorandum are specific to the City permit while the audit template covers a broader assessment of the program. Section A: Program Implementation, Documentation, and Assessment This section of the permit requires that the City implement, manage, and oversee all provisions of its stormwater plan to control the discharge of pollutants from its municipal storm sewer system (MS4) to the maximum extent practical. The program implementation is subject to a voluntary assessment and the City has contracted with AECOM to conduct this assessment. The City has limited funds and staff to manage and implement the provisions of the stormwater plan. However, a feasibility study for developing a stormwater utility is being conducted. Annual evaluation of the performance and effectiveness of program components is currently not being conducted and is identified as a gap. In addition, the stormwater plan needs to be updated, which is identified as a gap. Memo City of Henderson MS4 Support Section B: Public Education and Outreach BMP Measurable Goal COH Program Status/Gap a. Goals and Objectives Defined goals and objectives of Gap - Needs to be established the Local Public Education and Outreach Program based on community wide issues. b. Describe target Maintain a description of the Gap - Needs to be established pollutants and/or target pollutants and/or stressors stressors and likely sources. c. Describe target Maintain a description of the Gap — Information likely known audiences target audiences likely to have but needs to be documented significant storm water impacts and why they were selected. d. Describe residential and Describe issues, such as Gap - Needs to be established industrial/commercial pollutants, likely sources of issues those pollutants, impacts, and the physical attributes of stormwater runoff, in their education/outreach program. e. Informational Web Site Promote and maintain an Gap — Stormwater information internet web site designed to can be added to existing website convey the program's message. in short-term and dedicated stormwater pages will be incorporated into COH's pending rebranded website. f. Distribute public Distribute stormwater Ongoing - Need to expand education materials to educational material to educational materials and identified target appropriate target groups. expand target audience per audiences and user Instead of developing its own SCM item c. above. groups. For example, materials, the permittee may rely schools, homeowners on Public Education Outreach COH has provided some public and/or businesses. materials supplied by the state, stormwater education outreach and/or other entities through a for the Leadership Vance cooperative agreement, as program for business leaders available, when implementing its and Science, Technology, own program. Engineering, and Mathematics (STEM) school program. AECOM 2/9 Memo City of Henderson MS4 Support Section B: Public Education and Outreach. continued BMP Measurable Goal COH Program Status/Gap g. Maintain Hotline/Help Promote and maintain a Gap — need to identify existing line stormwater hotline/helpline for COH office number as a the purpose of public education stormwater hotline/help line and and outreach. protocol for directing inquiries to Engineering staff for response/follow-up. h. Implement a Public The permittee's outreach Gap — Need to define and Education and Outreach program, including those implement program, and Program elements implemented locally or document extent of audience through a cooperative reached via all outreach events. agreement, shall include a combination of approaches designed to reach the target audiences. For each media, event or activity, including those elements implemented locally or through a cooperative agreement the permittee shall estimate and record the extent of exposure. Section C: Public Involvement and Participation BMP Measurable Goal COH Program Status/Gap a. Volunteer Community Include and promote volunteer Gap - Needs to be established Involvement Program opportunities designed to promote ongoing citizen participation. b. Mechanism for Public Provide and promote a Gap - Needs to be established involvement mechanism for public involvement that provides for input on stormwater issues and the stormwater program. c. Hotline/Help line Promote and maintain a Gap — Can combine with Public hotline/helpline for public Education and Outreach hotline involvement and participation. effort. Section D: Illicit Discharge Detection and Elimination (IDDE) BMP Measurable Goal COH Program Status/Gap AECOM 3/9 Memo City of Henderson MS4 Support DRAFT BMP Measurable Goal COH Program Status/Gap a. Maintain an Illicit Discharge Detection and Elimination Program b. Maintain adequate legal authorities Maintain a written Illicit Discharge Detection and Elimination Program, including provisions for program assessment and evaluation and integrating program. Maintain an Illegal Discharge Detection and Elimination (IDDE) ordinance or other regulatory mechanism that provides the legal authority to prohibit illicit connections and discharges. c. Maintains Storm Sewer Maintain a current map showing System Map of Major major outfalls and receiving Outfalls streams. d. Implement a program to detect dry weather flows Maintain a program for conducting dry weather flow field observations in accordance with written procedures. Gap — Need to identify components of program and means to assess, evaluate and integrate IDDE program details. Completed. City of Henderson IDDE Ordinance is available under Subtitle C, Chapter 16, Division 3, Section 16-37.8. Under development — COH interns currently mapping where roads cross water bodies. Next step is to map Stormwater Discharge Outfalls (SDOs) in Cartegraph. Gap — Needs to be established e. Investigate sources of Maintain written procedures for Gap — While investigations are identified illicit discharges conducting investigations of performed, assumption is that no identified illicit discharges. written procedure has been developed. f. Track and document investigations of illicit discharges g. Provide Employee Training For each case the permittee shall track and document 1) the date(s) the illicit discharge was observed; 2) the results of the investigation; 3) any follow-up of the investigation; and 4) the date the investigation was closed. Implement and document a training program for appropriate municipal staff, who as part of their normal job responsibilities, may come into contact with or otherwise observe an illicit discharge or illicit connection. Gap - While investigations are performed, details are not tracked or documented. Gap — Needs to be established AECOM 4/9 Memo City of Henderson MS4 Support Section D: Illicit Discharge Detection and Elimination (IDDE), continued BMP Measurable Goal COH Program Status/Gap h. Provide Public Education Inform public employees, Gap — This can be worked into businesses, and the general Clark's existing presentation public of hazards associated used for STEM program and with illegal discharges and Leadership Vance or may be improper disposal of waste. part of a new outreach effort. i. Provide a public Promote, publicize, and facilitate Gap — Needs to be established reporting mechanism a reporting mechanism for the public and staff to report illicit discharges and establish and implement citizen request response procedures. j. Enforcement of the IDDE Implement a mechanism to track Gap — Needs to be established ordinance the issuance of notices of violation and enforcement actions as administered by the permittee. This mechanism shall include the ability to identify chronic violators for initiation of actions to reduce noncompliance. Section E: Construction Site Runoff Controls BMP Measurable Goal COH Program Status/Gap a. Implement the delegated Comply with the Sediment Ongoing. City is implementing Sediment and Erosion Pollution Control Act of 1973 and the delegated ESC program as Control Program Chapter 4 Title 15A of the published in Chapter 23A of the NCAC. City ordinance. b. Control construction site Meet NCG010000 permit Ongoing. City is requiring waste requirements construction sites to meet NCG010000 permit requirements for private developments as well as City construction projects. c. Establish a notification Setup a hotline or similar system Gap -Although the Engineering system for public to front desk number is open for report ESC problems public to call it is not advertised clearly as a hotline to report ESC problems. AECQM 5/9 Memo City of Henderson MS4 Support Section F: Post -Construction Site Runoff Controls BMP Measurable Goal COH Program Status/Gap; a. Adequate Legal Maintain through ordinance, or Completed -City of Henderson Authorities other regulatory mechanism, Stormwater Management adequate legal authorities Ordinance is available under designed to meet the objectives Subtitle C, Chapter 16, Division of the Post -Construction Site 3-Stormwater Management. Runoff Controls Stormwater . Management program. b. Strategies including Meet post -construction In Progress. City reviews the site appropriate SCMs stormwater runoff control plans to ensure it is an requirements. appropriate SCM for controlling runoff from the proposed development. c. Plan reviews Conduct plan reviews for all new Ongoing. City conducts plan and redevelopment sites that review for all new developments. disturb greater than or equal to one acre (including sites that disturb less than one acre that are part of a larger common plan of development or sale). d. Inventory of projects with Maintain an inventory of projects Under developments. City is post -construction SCMs with post -construction SCMs currently collecting stormwater installed at new development infrastructure and SCM data in and redevelopment sites that are ArcGIS Online. located within City's corporate limits and covered by the post - construction ordinance requirements. e. Deed restrictions and Provide mechanisms such as Completed. City ordinance protective covenants recorded deed restrictions and Section 16-37.5 requires protective covenants that ensure covenants and agreements prior development activities will to issuance of post -construction maintain project consistent with stormwater permit. approved plans. f. Long-term operation and Implement or require an Gap -No annual inspections of maintenance of SCMs operation and maintenance plan permitted structural SCMs are for SCMs. O&M Plan requires performed by a qualified the SCM owner to have a professional. No operation and qualified professional perform maintenance plans were and maintain records of annual available for the SCMs. inspections. AECOM 6/9 Memo City of Henderson MS4 Support Section F: Post -Construction Site Runoff Controls, continued DRAFT BMP Measurable Goal COH Program Status/Gap g. Inspections Conduct and document Ongoing. While the ordinance inspections of each project site provides the process and site at least one during the permit visits have been conducted, the term. records of inspection findings and enforcement actions have Before issuing a certificate of only been recorded since 2017 occupancy, conduct a post- for construction sites. construction inspection to verify that the permittee's performance standards are met or a bond is in place for guaranteed completion. Maintain records of inspections findings and enforcement actions. h. Educational materials Provide post -construction Completed. Developing and training for requirements, design standards community is referred via City developers and other materials for website to the NCDEQ developers and designers. Stormwater Manual in addition to the guidance available through City ordinance. i. Enforcement Track issuance of notice of Ongoing. NOVs and violations and enforcement enforcement notices are tracked actions. Tracking mechanism through Cartegraph, an ESRI° should be able to identify chronic software. violators. Section G: Pollution Prevention and Good Housekeeping BMP Measurable Goal COH Program Status/Gap a. Inventory of municipally Maintain a current inventory of Complete — only facilities are the owned or operated facilities and operations owned Wastewater Treatment Plant facilities and operated by the permittee (WWTP) and Operations Center with the potential for generating polluted stormwater runoff. AECOM 7/9 Memo DRAFT City of Henderson MS4 Support Section G: Pollution Prevention and Good Housekeeping, continued BMP Measurable Goal COH Program Status/Gap b. Operation and Maintain and implement, Gap — need to develop Maintenance (O&M) for evaluate annually and update as comprehensive Stormwater Plan municipally owned or necessary an O&M program for and include O&M details therein operated facilities municipal owned and operated for sand filters at Operations facilities with the potential for Center and other SCMs. generating polluted stormwater runoff. The O&M program shall specify the frequency of inspections and routine maintenance requirements. c. Spill Response Maintain written spill response Gap. A spill response procedure Procedures procedures for municipally needs to be developed. owned or operated facilities. d. Streets, roads, and Evaluate existing and new BMPs Gap. City staff or designee will public parking lots annually that reduce polluted need to review plans and scout maintenance stormwater runoff from BMPs that have been built in city municipally -owned streets, roads limits. and public parking lots within their corporate limits. The permittee must evaluate the effectiveness of these BMPs haspd on cost and the estimated quantity of pollutants removed. e. Operation and Maintain and implement an O&M Gap. City does not have an Maintenance (O&M) for program for the stormwater active O&M program for the municipally -owned or sewer system including catch stormwater drainage system. maintained catch basins basins and conveyance systems and conveyance systems that it owns and maintains. f. Identify structural Maintain a current inventory of In Progress. Interns currently stormwater controls municipally -owned or operated gathering stormwater system structural stormwater controls data. installed for compliance with the permitee's post -construction ordinance. AECOM 8/9 Memo City of Henderson MS4 Support Section G: Pollution Prevention and Good Housekeeping, continued BMP Measurable Goal COH Program Status/Gap g. O&M for municipally- Maintain and implement an O&M Gap — Needs to be established owned or maintained program for municipally -owned structural stormwater or maintained structural controls stormwater controls. The O&M program shall specify the frequency of inspections and routine maintenance requirements installed for compliance with the permittee's post -construction ordinance. h. Pesticide, Herbicide and Ensure municipal employees In Progress. While municipal Fertilizer Application and contractors are properly employees are licensed a Management trained and all permits, program - needs to be certifications, and other established for training measures for applicators are contractors. followed. i. Staff training Implement an employee training Gap — Needs to be established program for employees involved in implementing pollution prevention and good housekeeping practices. j. Prevent or Minimize Describe and implement Gap — Wash pad that discharges Contamination of measures to prevent or minimize to WWTP not operational and Stormwater Runoff from contamination of the stormwater needs to be repaired. Currently all areas used for Vehicle runoff from all areas used for vehicles are rinsed of mud and and Equipment Cleaning vehicle and equipment cleaning. discharge goes to stormwater system. Section H: TMDLs This section requires the City to comply with requirements of an approved TMDL. Nutbush Creek which originates within the City of Henderson is listed on the 2018 303(d) list as impaired for benthos and fish community. There is no approved TMDL within the City, part of the City is in the Tar -Pamlico River Basin, and a TMDL for nutrients in the Tar River was approved by NCDEQ in 1995. There was no stormwater waste load allocation in the TMDL. In absence of a TMDL within the jurisdictional limits of the City, this section is deemed compliant. In addition to reviewing the permit conditions and their current state of compliance, the NCDEQ audit template for Phase II MS4s was also completed and is attached as an appendix to this memorandum. Attachment: NCDEQ Phase I I MS4 Audit Template AECOM 9/9