NCS000502_Trinity MS4 AUDIT REPORT_20210324

MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM AUDIT REPORT
NPDES PERMIT NO. NCS000502
City of Trinity, NORTH CAROLINA
PO Box 50
Trinity, NC 27370
Audit Date: March 23, 2021
Report Date: March 24, 2021
North Carolina Department of Environmental Quality
Division of Energy, Mineral & Land Resources Stormwater Program
512 N. Salisbury Street, 9th floor
1612 Mail Service Center
Raleigh, NC 27699-1612

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NCS000502_The City of Trinity MS4 Audit_20210323

TABLE OF CONTENTS
AuditDetails..................................................................................................................................................1
PermitteeInformation..................................................................................................................................2
Listof Supporting Documents.......................................................................................................................3
Program Implementation, Documentation & Assessment...........................................................................4
PublicEducation and Outreach.....................................................................................................................7
Public Involvement and Participation...........................................................................................................8
Illicit Discharge Detection and Elimination (IDDE)........................................................................................9
Pollution Prevention and Good Housekeeping for Municipal Operations..................................................11
DISCLAIMER
This audit consists of an evaluation of program compliance with the issued permit and implementation of
the approved Stormwater Management Plan. This audit report does not include a review of all program
components, and program deficiencies in addition to those noted may be present. The permittee is
required to assess program progress and permit compliance, and to implement the approved Storm water
Management Plan in accordance with the issued permit.
NCS000502_The City of Trinity MS4 Audit_20210323 ii

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NCS000502_The City of Trinity MS4 Audit_20210323

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Audit ID Number:
Audit Date(s):
NCS000502_City of Trinity MS4 Audit_20210323
March 23, 2021
Minimum Control Measures Evaluated:
® Program Implementation, Documentation & Assessment
® Public Education & Outreach
® Public Involvement & Participation
® Illicit Discharge Detection & Elimination
❑ Construction Site Runoff Controls - No delegated Sediment and Erosion Control Program
❑ Construction Site Runoff Controls - Delegated Sediment and Erosion Control Program
❑ Post -Construction Site Runoff Controls
® Pollution Prevention and Good Housekeeping for Municipal Operations
❑ Total Maximum Daily Loads (TMDLs)
Field Site Visits:
❑ Municipal Facilities. Numbervisited: Choose an item.
❑ MS4 Outfalls. Number visited: Choose an item.
❑ Construction Sites. Number visited: Choose an item.
❑ Post -Construction Stormwater Runoff Controls. Number visited: Choose an item.
❑ Other: Number visited: Choose an item.
❑ Other: Number visited: Choose an item.
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Zac Lentz, EIT, Assistant Regional Engineer
NCDEQ- DEMLR: WSRO
Levi Hiatt, EIT, Assistant Regional Engineer
NCDEQ-DEMLR: WSRO
Blane Houck, Environmental Specialist
NCDEQ- DEMLR: WSRO
Audit Report Author:
Date:
3 juv i l-)
Signature
Audit Report Autho :
Date
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Signature -
NCS000502_City of Trinity MS4 Audit_20210323 Page 1 of 12

Permittee Information
MS4 Permittee Name:
City of Trinity
Permit Effective Date:
October 1, 2005
Permit Expiration Date:
October 1, 2010
Mailing Address: PO Box 50, Trinity, NC 27370
Date of Last MS4 Inspection/Audit:
N/A
Co-permittee(s), if applicable: N/A
Permit Owner of Record: Debbie Hinson — City Manager
Primary MS4 Representatives Participating in Audit
Name, Title
Organization
Marc Allred, Planning Director/Code Enforcement
City of Trinity
Danica Heflin, Environmental Programs Coordinator
Piedmont Triad Regional Council — Stormwater SMART
Katie Balaze, Staff Professional
Withers-Ravenel
Rodney Johnson, Utility & Public Works
City of Trinity
MS4 Receiving Waters
Waterbody
Classification
Impairments
Little Uwharrie River
WS-III
None
Uwharrie River
WS-III
None
Hunts Fork
C
Benthos (Nar, AL, FW)
North Hamby Creek
C
Benthos (Nar, AL, FW)
NCS000502_City of Trinity MS4 Audit_20210323 Page 2 of 12

List of Supporting Documents
Item
Number
Document Title
When Provided
(Prior to/During/After)
1
City of Trinity Website (www.trinity-nc.gov)
Prior to
2
Piedmont Triad Regional Council Agreement
Prior to
3
Colonial Village Wet Pond Wet Conditions Inspection Report
Prior to
4
Trinity Stormwater Ordinance
Prior to
5
Official Stormwater Map
Prior to
6
Trinity Operation and Maintenance Plan
Prior to
7
Trinity Connection Newsletter
After
8
Trinity Steeplegate Village Low Density Stormwater Deed Restriction
Prior to
9
Stormwater SMART 2019-2020 Annual Report
Prior to
10
NCS000502_City of Trinity MS4 Audit_20210323 Page 3 of 12

Program Implementation, Documentation & Assessment
Staff interviewed:
Marc Allred, Planning Director/Code Enforcement, City of Trinity
(Name, Title, Role)
Danica Heflin, Environmental Programs Coordinator of Stormwater SMART
Katie Balaze, Staff Professional of Withers Ravenel
Permit Citation
Program Requirement
Status
Supporting
Doc No.
II.A.S
The permittee maintained adequate funding and staffing to implement and manage
No
---
Staffing and
the provisions of the Stormwater Plan and meet all requirements of the permit.
Funding
The Stormwater Plan identifies a specific position(s) responsible for the overall
No
---
coordination, implementation, and revision to the Plan.
Responsibilities for all components of the Stormwater Plan are documented and
No
---
position(s) assignments provided.
The permittee is current on payment of invoiced administering and compliance
Not
monitoring fees (see stormwater e-payments on DEMLR MS4 web page).
Reviewed
---
Comments: The audit and recent Stormwater Management Program Assessments (SWMPA) appear to indicate that there is
inadequate staffing and funding for the program. The permittee has not maintained or implemented a Stormwater Plan.
II.A.4 Stormwater
The permittee evaluated the performance and effectiveness of the program
Partial
See
Plan
components at least annually.
comment
Implementation
If yes, the permittee used the results of the evaluation to modify the program
No
---
and Evaluation
components as necessary to accomplish the intent of the Stormwater Program.
Did the permitted MS4 discharges cause or contribute to non -attainment of an
Not
applicable water quality standard?
Reviewed
---
If yes, did the permittee expand or better tailor its BMPs accordingly to address
Not
the non -attainment?
Applicable
---
Comments: SWMPA's were submitted for 2019, and 2020, but there was no Stormwater Plan to modify.
II.A.2 & 111.1
The permittee kept the Stormwater Plan up to date.
No
---
Keeping the
Stormwater Plan
The permittee notified DEMLR of any updates to the Stormwater Plan.
Not
Applicable
---
Up to Date
Comments: The permittee has not maintained or implemented a Stormwater Plan.
111.1 Availability of
The permittee kept an up-to-date version of its Stormwater Plan available to the
No
---
the Stormwater
Division and the public online.
Plan
The online materials included ordinances, or other regulatory mechanisms, or a list
identifying the ordinances, or other regulatory mechanisms, providing the legal
Yes
1
authority necessary to implement and enforce the requirements of the permit.
Comments A copy of the City of Trinity Stormwater Ordinance is available online. Ordinances - City of Trinity, NC (trinity-nc.gov) The
permittee has not maintained or implemented a Stormwater Plan.
111.3 Stormwater
Did DEMLR require a modification to the Stormwater Plan?
No
---
Plan Modifications
If yes, did the permittee complete the modifications in accordance with the
Not
established deadline?
Applicable
---
Comments No modifications were required by DEMLR.
1.4 Sharing
Are any control measures implemented by an entity other than the permittee?
Yes
2
Responsibility
If yes, is there a written agreement in place?
Partial
2
NCS000502_City of Trinity MS4 Audit_20210323 Page 4 of 12

Program Implementation, Documentation & Assessment
Comments: The permittee has a written agreement with the Piedmont Triad Regional Council (PTRC) Storm water SMART program
to aid them with Public Outreach and Education, for Public Involvement and Participation, or for any other MCM, such as IDDE and
Good Housekeeping training for municipal employees. Despite a clear history of this entity working with the permittee, an
agreement was not in place before 2020.
II.A.1
The permittee maintained written procedures for implementing the six minimum
No
---
Written
control measures.
Procedures
Written procedures identified specific action steps, schedules, resources and
No
---
responsibilities for implementing the six minimum measures.
Comments: Written procedures were neither developed nor maintained.
111.1 & IV.1
The permittee maintained documentation of all program components including, but
Program
not limited to, inspections, maintenance activities, educational programs,
Partial
1,3
Documentation
implementation of BMPs, enforcement actions etc., on file for a period of five years.
Comments: The documents supplied show that elements of the minimum measures have been implemented, but there are serious
deficiencies in documentation that must be addressed for compliance.
111.2 & IV
The permittee submitted annual reports to the Department within twelve months
Annual Report
from the effective date of the permit (See Section III.B. for the annual reporting
Not
Reviewed
---
Submittal
period specific to this MS4).
The permittee submitted subsequent annual reports every twelve months from the
Partial
---
scheduled date of the first annual report submittal.
The Annual Reports included appropriate information to accurately describe the progress, status, and results
of the permittee's Stormwater Plan, including, but not limited the following:
1. A detailed description of the status of implementation of the Stormwater Plan
as a whole. This will include information on development and implementation
Yes
---
of each major component of the Stormwater Plan for the past year and
schedules and plans for the year following each report.
2. An adequate description and justification of any proposed changes to the
Stormwater Plan. This will include descriptions and supporting information for
Partial
---
the proposed changes and how these changes will impact the Stormwater
Plan (results, effectiveness, implementation schedule, etc.).
3. Documentation of any necessary changes to programs or practices for
assessment of management measures implemented through the Stormwater
Not
Reviewed
---
Plan.
4. A summary of data accumulated as part of the Stormwater Plan throughout
the year along with an assessment of what the data indicates in light of the
Not
Reviewed
---
Stormwater Plan.
5. An assessment of compliance with the permit, information on the
establishment of appropriate legal authorities, inspections, and enforcement
Not
Reviewed
actions.
Comments: SWMPA's have been submitted for 2019 and 2020.
NCS000502_City of Trinity MS4 Audit_20210323 Page 5 of 12

Program Implementation, Documentation & Assessment
III
The Annual Reports document the following:
Annual Reporting
1. A summary of past year activities, including where applicable, specific
Not
---
quantities achieved and summaries of enforcement actions.
Reviewed
2. A description of the effectiveness of each program component.
Not
Reviewed
3. Planned activities and changes for the next reporting period, for each
Not
program component or activity.
Reviewed
---
4. Fiscal analysis.
Not
Reviewed
Comments: SWMPA's have been submitted for 2019 and 2020.
Additional
While it is clear that the permittee has a Stormwater Program and have implemented each minimum measure
Comments:
to some degree, the overall lack of documentation, particularly the Stormwater Management Plan, must be
corrected to achieve compliance with the permit.
NCS000502_City of Trinity MS4 Audit_20210323 Page 6 of 12

Public Education and Outreach
Staff Interviewed: Marc Allred, Planning Director/Code Enforcement, City of Trinity
(Name, Title, Role) Danica Heflin, Environmental Programs Coordinator of Stormwater SMART
Katie Balaze, Staff Professional of Withers Ravenel
Supporting
Permit Citation Program Requirement Status Doc No.
11.B.1
The permittee defined goals and objectives of the Local Public Education and see
No
Goals and Comments
Outreach Program based on community wide issues.
Objectives
Comments: The permittee worked with Stormwater SMART for this measure but lacks documentation showing that goals and
objectives were defined for this specific community.
II.BD.1.b
The permittee maintained a description of the target pollutants and/or stressors and
Partial
see
Target Pollutants
likely sources.
Comments
Comments: The permittee's website includes videos addressing target pollutants. It is unclear if these have been maintained
throughout the permit cycle.
The permittee identified, assessed annually, and updated the description of the
II.D.1.e
target audiences likely to have significant storm water impacts and why they were
No
---
Target Audiences
selected.
Comments: Documentation of annual target audience consideration has not been provided.
11.B.1.c & II.D.1.d
The permittee described issues, such as pollutants, the likely sources of those
Residential and
pollutants, potential impacts, and the physical attributes of stormwater runoff in
Partial
see
Comments
Industrial/
their education/outreach program.
Commercial Issues
Comments: The permittee's website includes videos addressing target pollutants. It is unclear if these have been maintained
throughout the permit cycle.
11.B.2.b
The permittee promoted and maintained an internet web site designed to convey the
see
Informational
program's message.
Yes
comments
Web Site
Comments: trinity-nc.gov > Government > Departments > Stormwater
11.B.2.c & d
The permittee distributed Stormwater educational material to appropriate target
Partial
7
Public Education
Materials
groups.
Comments: Materials were available on the website and through Storm water SMART programming. Educational materials were for
either a general audience or school children; consideration of particular target groups has not been demonstrated.
II.E.2 Hotline/Help
The permittee promoted and maintained a Stormwater hotline/helpline for the
No
Line
purpose of public education and outreach.
Comments: Stormwater SMART could be reached for educational opportunities, but this was not clear on the permittee's website.
II.B.1.b & II.B.2.a
The permittee's outreach program, including those elements implemented locally or
Public Education
through a cooperative agreement, included a combination of approaches designed to
Partial
8
and Outreach
reach the target audiences.
Program
For each media, event or activity, including those elements implemented locally or
through a cooperative agreement the permittee estimated and recorded the extent
Partial
8
of exposure.
Comments: The Stormwater SMART annual report shows a variety of approaches used for outreach as well as estimated extent of
exposure.
Additional
Much of this measure is implemented by Stormwater SMART. Despite a clear history of this entity working
Comments:
with the permittee, an agreement was not in place before 2020.
NCS000502_City of Trinity MS4 Audit_20210323 Page 7 of 12

Public Involvement and Participation
Staff Interviewed:
Marc Allred, Planning Director/Code Enforcement, City of Trinity
(Name, Title, Role)
Danica Heflin, Environmental Programs Coordinator of Stormwater SMART
Katie Balaze, Staff Professional of Withers Ravenel
Permit Citation
Program Requirement Status Supporting
poc No.
II.C.2.c Volunteer
Community
The permittee included and promoted volunteer opportunities designed to promote see
Involvement
Yes
ongoing citizen participation. comments
Program
Comments: The permittee's website shows ongoing volunteer opportunities for citizen participation, and Stormwater SMART's
annual report shows additional opportunities that have been provided.
II.C.1.a & II.C.2.a
The permittee provided and promoted a mechanism for public involvement that
Mechanism for
Public
provides for input on stormwater issues and the stormwater program.
No
Involvement
Comments: Stormwater SMART provided a web form for input, but this was not clear on the permittee's website.
II.E.2
The permittee promoted and maintained a hotline/helpline for the purpose of public
No
Hotline/Help Line
involvement and participation.
Comments: Stormwater SMART provided a web form for input, but this was not clear on the permittee's website.
Additional
Much of this measure is implemented by Stormwater SMART. Despite a clear history of this entity working
Comments:
with the permittee, an agreement was not in place before 2020. Ongoing volunteer opportunities are shown
on the permittee's website: trinity-nc.gov> Government > Departments > Stormwater> Cleanup
NCS000502_City of Trinity MS4 Audit_20210323 Page 8 of 12

Illicit Discharge Detection and Elimination (IDDE)
Staff Interviewed: Marc Allred, Planning Director/Code Enforcement, City of Trinity
(Name, Title, Role) Katie Balaze, Staff Professional of Withers Ravenel
Rodney Johnson, Utility & Public Works, City of Trinity
Permit Citation Program Requirement
Status Supporting
poc No.
II.D.2.a
The permittee maintained a written IDDE Program.
No ---
IDDE Program
If yes, the written program includes provisions for program assessment and
Not
evaluation and integrating program.
---
Applicable
Comments: Despite evidence of an IDDE Program, no supporting documentation was provided.
The permittee maintained an IDDE ordinance or other regulatory mechanism(s) that
Yes
4
II.D.1.c & II.D.2.b
provides the legal authority to prohibit illicit connections and discharges to the MS4.
Legal Authorities
If yes, the ordinance applies throughout the corporate limits of the permittee.
Not
[Permit Part I.D]
Reviewed
---
II.D.1d & II.D.2.c
The permittee maintained a current map showing major outfalls* and receiving
Partial
5
Storm Sewer
System Map
streams.
Comments: Per the permittee, 43% of the outfalls have been mapped.
*Major outfalls are discharges from > 36" diameter pipes or drainage areas of? 50 acres. In areas zoned for industrial activity, major outfalls
are > 12" or drainage area > 2 acres.
II.D.2.d
The permittee maintained a program for conducting dry weather flow field
Dry Weather Flow
observations in accordance with written procedures.
NO
---
Program
II.D.2.d
The permittee maintained written procedures for conducting investigations of
Investigation
identified illicit discharges.
NO
---
Procedures
IV.3
For each case of an illicit discharge or potential illicit discharge, the permittee documented and tracked the
Track and
following:
Document
1. The date(s) the illicit discharge was observed
No
---
Investigations
2. The results of the investigation
No
---
3. Any follow-up of the investigation
No
---
4. The date the investigation was closed
No
---
II.D.2.e Employee
The permittee implemented and documented a training program for appropriate
Training
municipal staff who, as part of their normal job responsibilities, may come into
No
---
contact with or otherwise observe an illicit discharge or illicit connection.
Comments: While there were recent trainings documented, no elements of a training program were documented.
II.D.1.e & II.D.2.f
The permittee informed public employees of hazards associated with illegal
No
---
Public Education
discharges and improper disposal of waste.
The permittee informed businesses of hazards associated with illegal discharges and
No
---
improper disposal of waste.
The permittee informed the general public of hazards associated with illegal
see
discharges and improper disposal of waste.
Yes
I
I comments
Comments: The permittee's website includes videos addressing target pollutants trinity-nc.gov> Government> Departments >
Stormwater> IDDE
NCS000502_City of Trinity MS4 Audit_20210323 Page 9 of 12

Illicit Discharge Detection and Elimination (IDDE)
II.D.2.g
The permittee promoted, publicized, and facilitated a reporting mechanism for the
Yes
see
Public Reporting
public to report illicit discharges.
comments
Mechanism
The permittee promoted, publicized, and facilitated a reporting mechanism for staff
No
---
to report illicit discharges.
The permittee established and implemented response procedures for citizen
No
---
requests/reports.
Comments: trinity-nc.gov > Government > Departments > Stormwater> Report an Illicit Discharge
II.D.2.b
The permittee implemented a mechanism to track the issuance of notices of violation
No
---
Enforcement
and enforcement actions administered by the permittee.
If yes, the mechanism includes the ability to identify chronic violators for
initiation of actions to reduce noncompliance.
No
---
Additional
Despite evidence of an IDDE Program, no supporting documentation was provided, and the permittee appears
Comments:
to lack a tracking mechanism.
NCS000502_City of Trinity MS4 Audit_20210323 Page 10 of 12

Pollution Prevention and Good Housekeeping for Municipal Operations
Staff Interviewed:
Marc Allred, Planning Director/Code Enforcement, City of Trinity
(Name, Title, Role)
Katie Balaze, Staff Professional of Withers Ravenel
Rodney Johnson, Utility & Public Works, City of Trinity
Permit Citation
Program Requirement
Status
Supporting
Doc No.
II.G.2.b
The permittee maintained a current inventory of facilities and operations owned
Facility Inventory
and operated by the permittee with the potential for generating polluted
Yes
6
stormwater runoff.
II.G.2.a
The permittee maintained and implemented an 0&M program for municipally
Operation and
owned and operated facilities with the potential for generating polluted
No
6
Maintenance (O&M)
stormwater runoff.
for Facilities
If yes, the 0&M program specifies the frequency of inspections.
Not
Applicable
---
If yes, the 0&M program specifies the frequency of routine maintenance
Not
requirements.
Applicable
---
If yes, the permittee evaluated the O&M program annually and updated it as
Not
necessary.
Applicable
Comments: A recent document to develop a program has been started, but the program has not been fully developed.
II.G.2.a
Spill Response
The permittee had written spill response procedures for municipal operations.
No
---
Procedures
II.G.2.b Streets,
The permittee evaluated existing and new BMPs that reduce polluted stormwater
Roads, and Public
runoff from municipally -owned streets, roads, and public parking lots within its
No
---
Parking Lots
corporate limits annually.
Maintenance
If yes, the permittee evaluated the effectiveness of existing and new BMPs
Not
based on cost and the estimated quantity of pollutants removed.
Applicable
---
II.G.2.b
O&M for Catch
The permittee maintained and implemented an O&M program for the stormwater
Basins and
sewer system including catch basins and conveyance systems that it owns and
No
---
Conveyance
maintains.
Systems
II.G.2.b
The permittee maintained a current inventory of municipally -owned or operated
Structural
structural stormwater controls installed for compliance with the permittee's post-
No
---
Stormwater
construction ordinance.
Controls
NCS000502_City of Trinity MS4 Audit_20210323 Page 11 of 12

Pollution Prevention and Good Housekeeping for Municipal Operations
II.G.2.a
The permittee maintained and implemented an O&M program for municipally -
O&M for Structural
owned or maintained structural stormwater controls installed for compliance with
No
6
Stormwater
the permittee's post -construction ordinance. If yes, then:
Controls
The O&M program specified the frequency of inspections and routine
Not
maintenance requirements.
Applicable
---
The permittee documented inspections of all municipally -owned or maintained
Not
structural stormwater controls.
Applicable
---
The permittee inspected all municipally -owned or maintained structural
Not
stormwater controls in accordance with the schedule developed by permittee.
Applicable
---
The permittee maintained all municipally -owned or maintained structural
Not
stormwater controls in accordance with the schedule developed by permittee.
Applicable
---
The permittee documented maintenance of all municipally -owned or
Not
maintained structural stormwater controls.
Applicable
---
II.G.2.c
The permittee ensured municipal employees are properly trained in pesticide,
Pesticide, Herbicide
herbicide and fertilizer application management.
NO
"""
and Fertilizer
Application
The permittee ensured contractors are properly trained in pesticide, herbicide and
Management
fertilizer application management.
NO
___
The permittee ensured all permits, certifications, and other measures for
No
---
applicators are followed.
II.G.2c
The permittee implemented an employee training program for employees involved
Staff Training
in implementing pollution prevention and good housekeeping practices.
NO
"""
Comments: While there were recent trainings documented, no elements of a training program were documented.
II.G.2.a
The permittee described and implemented measures that prevent or minimize
Vehicle and
contamination of stormwater runoff from all areas used for vehicle and equipment
No
---
Equipment Cleaning
cleaning.
Additional
None
Comments:
NCS000502_City of Trinity MS4 Audit_20210323 Page 12 of 12