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Home My WebLink AboutNCS000413_Phase-II-MS4-Audit-Report-Kannapolis_20210413MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) PROGRAM AUDIT REPORT NPDES PERMIT NO. NCS000413 KANNAPOLIS, NORTH CAROLINA 401 Laureate Way Kannapolis, NC 28081 Audit Date: February 2021 Report Date: February 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 MS4 Permit Audit Report Kannapolis, NC: NPDES Permit No. NCS000413 (This page intentionally left blank) Audit Date: February 2021 MS4 Permit Audit Report Kannapolis, NC: NPDES Permit No. NCS000413 TABLE OF CONTENTS Audit Details ......................................... Permittee Information ......................... Supporting Documents ........................ Construction Site Runoff Controls ....... Post -Construction Site Runoff Controls Total Maximum Daily Loads (TMDLs) .. Appendix A: Supporting Documents Appendix B: Photograph Log .......................................................................................................1 ....................................................................................................... 2 ....................................................................................................... 3 ....................................................................................................... 4 ....................................................................................................... 7 .....................................................................................................13 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 Stormwater Management Plan in accordance with the issued permit. Audit Date: February 2021 MS4 Permit Audit Report Kannapolis, NC: NPDES Permit No. NCS000413 (This page intentionally left blank) Audit Date: February 2021 MS4 Permit Audit Report Kannapolis, NC: NPDES Permit No. NCS000413 Audit Details Audit ID Number: Audit Date(s): NCS000413_Kannapolis MS4 Audit_2021.02 February 2021 Minimum Control Measures Evaluated: ❑ Program Implementation, Documentation & Assessment ❑ Public Education & Outreach ❑ Public Involvement & Participation ❑ Illicit Discharge Detection & Elimination ❑X Construction Site Runoff Controls — No delegated Sediment and Erosion Control Program ❑ Construction Site Runoff Controls — Delegated Sediment and Erosion Control Program ❑X Post -Construction Site Runoff Controls ❑ Pollution Prevention and Good Housekeeping for Municipal Operations ❑X Total Maximum Daily Loads (TMDLs) Field Site Visits: ❑ Municipal Facilities. Number visited: 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. Inspector(s) Conducting Audit Name, Title Organization J.P. Johns, Civil/Water Resource Leader Woolpert Brian Bates, Project Director Woolpert Rebecca Coulter, Phase Manager Woolpert Audit Report Author: Date: 8CAW February 15, 2021 Signature uuJJ . Audit Report Author: Date Signature Audit Report Author: Date Signature Audit Date(s): February 2021 Page 1 of 14 MS4 Permit Audit Report Kannapolis, NC: NPDES Permit No. NCS000413 Permittee Information MS4 Permittee Name: City of Kannapolis Permit Effective Date: Permit Expiration Date: February 20,2017 February 19, 2022 City, State, ZIP: Kannapolis, NC, 28081 Date of Last MS4 Inspection/Audit: November 17-18, 2020 Co-permittee(s), if applicable: N/A Permit Owner of Record: Wilmer Melton, III Primary MS4 Representatives Participating in Audit Name, Title Organization Scott Kaufhold City Engineer City of Kannapolis — Engineering (Public Works) Catherine Bolick Civil Engineer I City of Kannapolis — (Public Works) Brent Yost Senior Engineering Technician Rich Burris Engineering Technician Jamie Pope Engineering Technician Misty Tutt Civil Engineer II Waterbody Irish Buffalo Creek (from Kannapolis Water Supply Dam To Rocky River) Cold Water Creek (source to 0.5 miles downstream of Rowan SR 1221) Cold Water Creek (Lake Fisher) Cold Water Creek (Dam at Lake Fisher to Irish Buffalo Creek) UT to Cold Water Creek (source to 0.7 miles downstream Rowan/ Cabarrus line) UT to Cold Water Creek (Lake Concord) UT to Cold Water Creek (Dam at Lake Concord to Cold Water Creek) Three Mile Branch Coddle Creek (0.2 miles upstream NC 73 to Rocky River) Afton Run (source to Coddle Creek) City of Kannapolis — Engineering (Public Works) City of Kannapolis — Engineering (Public Works) City of Kannapolis — Engineering (Public Works) City of Kannapolis — Engineering (Public Works) MS4 Receiving Waters Stream Index/ Classification 13-17-9-(2) 13-17-9-4-(0.5) WS-IV 13-17-9-4-(1) WS-IV; CA 13-17-9-4-(1.5) C Impairments N/R N/R N/R N/R 13-17-9-4-2-(1) WS-IV N/R 13-17-9-4-2-(2) WS-IV; CA Chlorophyll a (40µg/L,AL, NC) 13-17-9-4-2-(3) 1 C I N/R 13-17-9-4-5 C N/R 13-17-6-(5.5) C Benthos (Nar, AL, FW) 13-17-6-6 1 C N/R Audit Date(s): February 2021 Page 2 of 14 MS4 Permit Audit Report Kannapolis, NC: NPDES Permit No. NCS000413 Supporting Documents Item When Provided Number Document Title (Prior to/During/After) Annual Reports 2006 through 2020 Prior to Audit 02 Charlotte -Mecklenburg Stormwater Design Manual [January 1, 2014] Prior to Audit City of Kannapolis Ordinance — Article V. Stormwater Utility, Control and 03 Prior to Audit Management 04 City of Kannapolis Unified Development Ordinance Article 9 Prior to Audit Illicit Discharge Detection and Elimination (IDDE) Program Procedures Manual 05 Prior to Audit [August 2020] 06 NC DEQ Stormwater Design Manual Prior to Audit 07 City of Kannapolis Unified Development Ordinance Article 4 Prior to Audit Audit Date(s): February 2021 Page 3 of 14 MS4 Permit Audit Report Kannapolis, NC: NPDES Permit No. NCS000413 Construction Site Runoff Controls Staff Interviewed: Brent Yost, Senior Engineering Technician (Name, Title, Role) Rich Burris, Engineering Technician Jamie Pope, Engineering Technician Catherine Bolick, Civil Engineer I Program Delegation Status: ❑ The permittee has a delegated Sediment and Erosion Control Program and implements the North Carolina Sedimentation Pollution Control Act (SPCA) of 1973 components of this minimum measure (complete the permit citation and SPCA citation sections). ❑x The permittee does not have a delegated Sediment and Erosion Control Program and relies on DEMLR to comply with the North Carolina Sedimentation Pollution Control Act (SPCA) of 1973 components of this minimum measure (complete only the permit citation section). Permit Citation Program Requirement Status Supporting Doc No. II.E.3 Construction Site Runoff Controls The permittee provides and promotes a means for the public to notify the (NPDES Permit No. appropriate authorities of observed erosion and sedimentation problems (e.g., NCS0004351 promoting the existence of the DEQ DEMLR "Stop Mud" hotline). Comments (Describe how provided and promoted) The City relies on the NC Department of Environment and Natural Resources Sediment and Erosion Control Program and DWQ general stormwater permit along with the NC General Construction Permit for its construction activities to meet this minimum control measure. The City receives calls from the public regarding construction items. These calls are logged into CityWorks (since approximately November 2018) and then the City addresses the concerns accordingly. The City checks the sediment and erosion control issue to determine if it is necessary to call the State or another involved party. The City handles projects that are less than one (1) acre, so in the case of these problems, the City addresses it. If an erosion and sediment control problem persists after the City assists in corrective actions, then the State is contacted. When the State becomes involved the City is no longer included in corrective actions. For new development the City meets on -site during the pre -conference to go over City maintained items. The engineer for a project lets the City know when the State has approved plans. The City then familiarizes itself with the sediment and erosion control plans. Poorly maintained sediment and erosion controls are noted in City inspections. A hold is put on permits for projects that are less than one (1) acre (non-DEQ projects) to get items corrected. The City acts as the "eyes for the State". When sediment and erosion control issues are noticed on DEQ projects, the City tries to step in. In certain cases, the State has stepped in when they were called upon after things escalated. It was noted that third party inspections are not always done thoroughly. There is high turnover seen with the third -party inspectors at some construction sites and, in some cases, major issues are repetitively not being noted. SPCA Citation Delegated Program Requirement Status Supporting Doc No. Audit Date(s): February 2021 Page 4 of 14 MS4 Permit Audit Report Kannapolis, NC: NPDES Permit No. NCS000413 Construction Site Runoff Controls 113A-60 Local erosion and The permittee has adopted an ordinance or other regulatory mechanism to enforce Not --- the erosion and sedimentation control program. Applicable sedimentation control programs (a) If yes, the ordinance meets or exceeds the minimum requirements of the Not SPCA. Applicable If yes, the ordinance applies throughout the corporate limits of the permittee. Not [Permit Part I.D] Applicable Comments (Provide regulatory mechanism reference or Supporting Documentation number) The City relies on the NC Department of Environment and Natural Resources Sediment and Erosion Control Program so this section does not apply. § 113A-60 Local erosion and The permittee collects a fee paid by each person who submits an erosion and Not sedimentation sedimentation control plan. Applicable control programs (d) Comments (indicate the fee amount, if applicable) The City relies on the NC Department of Environment and Natural Resources Sediment and Erosion Control Program so this section does not apply. § 113A-60 Local Has any person initiated a land -disturbing activity (within the permittee's erosion and jurisdiction) for which an erosion and sedimentation control plan is required in the Not Applicable sedimentation absence of an approved plan? control programs (e) If yes, the permittee has notified the North Carolina Sedimentation Control Not Commission of all such cases. Applicable Has the permittee determined that a person engaged in a land -disturbing activity Not has failed to comply with an approved erosion and sedimentation control plan? Applicable If yes, has the permittee referred any such matters to the North Carolina Not Sedimentation Control Commission for inspection and enforcement? Applicable Comments The City relies on the NC Department of Environment and Natural Resources Sediment and Erosion Control Program so this section does not apply. § 113A-61 Local The permittee reviews each erosion and sedimentation control plan submitted to approval of erosion them and notifies the person submitting the plan that it has been approved, Not Applicable and sedimentation approved with modification, or disapproved within 30 days of receipt. control plans The permittee only approves an erosion and sedimentation control plan upon Not determining that it complies with all applicable State and local regulations. Applicable The permittee has disapproved of an erosion and sedimentation control plan in Not order to protect riparian buffers along surface waters. Applicable If yes, the permittee notified the Director of the Division of Energy, Not Mineral, and Land Resources within 10 days of the disapproval. Applicable -- Audit Date(s): February 2021 Page 5 of 14 MS4 Permit Audit Report Kannapolis, NC: NPDES Permit No. NCS000413 Construction Site Runoff Controls Comments The City relies on the NC Department of Environment and Natural Resources Sediment and Erosion Control Program so this section does not apply. § 113A-61.1 Inspection of land- The certificate of approval of each erosion and sedimentation control plan Not disturbing activity; approved by the permittee includes a notice of the right to inspect. Applicable notice of violation (a) The permittee provides for inspection of land -disturbing activities to ensure compliance with the SPCA and to determine whether the measures required in an Not Applicable erosion and sedimentation control plan are effective. Comments The City relies on the NC Department of Environment and Natural Resources Sediment and Erosion Control Program so this section does not apply. § 113A-61.1 When the permittee determines that a person engaged in land -disturbing activity Inspection of land- has failed to comply with the SPCA, the Permittee immediately issues a notice of Not Applicable disturbing activity; violation upon that person. notice of violation Each notice of violation issued by the permittee specifies the date by which the Not (c) person must comply. Applicable Each notice of violation issued by the permittee informs the person of the actions Not that need to be taken to comply. Applicable Comments The City relies on the NC Department of Environment and Natural Resources Sediment and Erosion Control Program so this section does not apply. 113A-64 Penalties Does the permittee issue civil penalties as part of the erosion and sedimentation Not program? Applicable Comments (indicate when/why a civil penalty is issued, and the amount, if applicable) The City relies on the NC Department of Environment and Natural Resources Sediment and Erosion Control Program so this section does not apply. Additional Overall, it appears that the City is in compliance with this minimum control measure since the City relies on the Comments: NC Department of Environment and Natural Resources Sediment and Erosion Control Program to implement this program. Audit Date(s): February 2021 Page 6 of 14 MS4 Permit Audit Report Kannapolis, NC: NPDES Permit No. NCS000413 Post -Construction Site Runoff Controls Staff Interviewed: Misty Tutt, Civil Engineer II (Name, Title, Role) Scott Kaufhold, City Engineer Rich Burris, Engineering Technician Jamie Pope, Engineering Technician Catherine Bolick, Civil Engineer I Implementation (check all that apply): 0 The permittee implements the components of this minimum measure. ❑ The permittee relies upon another entity to implement the components of this minimum measure: N/A 0 The permittee implements the following deemed -compliant program(s), which meet NPDES MS4 post -construction requirements for the areas where implemented and in compliance with the specific program requirements as provided in 15A NCAC and noted below (Complete Session Low2006-246 section below): ❑ Water Supply Watershed I (WS-1) —15A NCAC 213.0212 ❑X Water Supply Watershed 11 (WS-11) —15A NCAC 26 .0214 Coddle Creek. ❑X Water Supply Watershed III (WS-III) —15A NCAC 26 .0215 Irish Buffalo Creek [Kannapolis Lake (Cannon Lake)] ❑X Water Supply Watershed IV (WS-IV) —15A NCAC 213.0216 Unnamed Tributary to Cold Water Creek, Lake Conrad, Cold Water Creek (Lake Fisher) ❑ Freshwater High Quality Waters (HQW) —15A NCAC 2H .1006 ❑ Freshwater Outstanding Resource Waters (ORW) —15A NCAC 2H .1007 ❑ Neuse River Basin Nutrient Sensitive (NSW) Management Strategy —15A NCAC 2B .0235 ❑ Tar -Pamlico River Basin Nutrient Sensitive (NSW) Management Strategy —15A NCAC 2B .0258 ❑ Randleman Lake Water Supply Watershed Nutrient Management Strategy —15A NCAC 2B .0251 ❑ Universal Stormwater Management Program —15A NCAC 2H .1020 Ordinance(s) (check all that apply): The permittee utilizes the following ordinances and/or regulatory authority to fulfill post construction minimum measure program requirements throughout the MS4 permitted area (check all that apply): ❑X DEQ model ordinance The City's ordinance is modeled after this. ❑X MS4 designed post -construction practices that meet or exceed 15A NCAC 02H .1000. The City uses the NC DENR Manual of BMPs so it should be assumed this meets these regulations. ❑ DEQ approved comprehensive watershed plan 0 DEQ approved ordinance for a deemed -compliant Program (see list above) This is included in the Unified Development Ordinance Article 4. Instructions: For MS4s not implementing a S.L. 2006-246 deemed -compliant program, complete only the Permit Citation section below. For MS4s implementing a S.L. 2006-246 deemed -compliant program, complete the Session Law 2006-246 section below. If the MS4 does not implement a deemed -compliant program throughout the entire MS4 permitted area, then complete the Permit Citation section below for the permitted area(s) not covered under the S.L. 2006-246 deemed -compliant program. Audit Date(s): February 2021 Page 7 of 14 MS4 Permit Audit Report Kannapolis, NC: NPDES Permit No. NCS000413 Post -Construction Site Runoff Controls Session Law 2006- Program Requirement Status supporting 246 Doc No. Deemed -Compliant The permittee implements deemed -compliant Program requirements in Program(s) accordance with the applicable 15A NCAC rules. Yes The permittee implements deemed -compliant Program requirements throughout the entire MS4 area (If not, also complete the Permit Citation section below.) No* U/ The permittee applies deemed -compliant Program requirements to all federal, state and local government projects within the permitted MS4 area who do not Not Reviewed --- have their own NPDES stormwater permit. The permittee included deemed -compliant Program reporting in their MS4 Annual Reports. No* 01 The permittee included deemed -compliant Program implementation in their Stormwater Management Plan. No* 01 Comments During the Audit with the City, they were unaware if they were running a deemed -compliant program, though it was determined that the City of Kannapolis does drain to Water Supply Watersheds, WS-11, III, and IV. This was further reviewed after the Audit and the City of Kannapolis UDO, Article 4 was found to have a section that covers Watershed Protection Overlay Districts (Section 4.16). The provisions of this ordinance apply within the areas designated overlay districts on the City's Official Zoning Map. Further requirements for Watershed Overlay Districts are provided in UDO, Article 4 Section 4.16. The City's SWMP was reviewed prior to the Audit and no information on a deemed -compliant Program was included. This is not something that is required by their current permit to include in the SWMP, but as the SWMP is being updated, information will be added. *The phrase "Deemed -Compliant Program" is not stated anywhere in the City's current Permit. The City does not include specific in their SWMP or include "deemed -compliant Program" reporting in their MS4 Annual Reports. Permit Citation Program Requirement Status supporting Doc No. II.F.2.a The permittee maintained an ordinance or other regulatory mechanism designed Legal Authority to meet the objectives of the Post -Construction Site Runoff Controls Stormwater Yes 04 Management Program. If yes, the ordinance applies throughout the corporate limits of the permittee (Verify permit coverage area listed in Part I.D of permit and modify Yes --- accordingly). The permittee has the authority to review designs and proposals for new development and redevelopment to determine whether adequate stormwater Yes 04 control measures will be installed, implemented, and maintained. The permittee has the authority to request information such as stormwater plans, inspection reports, monitoring results, and other information deemed necessary to evaluate compliance with the Post -Construction Stormwater Management Yes 04 Program. Audit Date(s): February 2021 Page 8 of 14 MS4 Permit Audit Report Kannapolis, NC: NPDES Permit No. NCS000413 Post -Construction Site Runoff Controls The permittee has the authority to enter private property for the purpose of inspecting at reasonable times any facilities, equipment, practices, or operations Yes 04 related to stormwater discharges. Comments (If the permittee relies upon another entity, specifically note the legal authority that allows that entity to implement the program within the MS4 area) The City's LIDO includes the post -construction program goals. The City utilizes the NCDENR Manual of Stormwater Best Management Practices as the basis for decisions about stormwater permits and about the design, implementation and performance of structural and non-structural stormwater BMPs. The LIDO also includes the administration and procedures related to the post - construction program and allows the City to have the authority to review designs and proposals, enter, inspect, monitor, maintain, repair, and reconstruct structural BMPs. II.F.2.b 03, 04, Stormwater Control The permittee utilizes strategies which include SCMs appropriate for the MS4. Yes 06 Measures (SCMs) SCMs comply with 15A NCAC 02H .1000. Yes 03, 04, 06 Comments The City's LIDO includes the documents to reference for stormwater control measures (SCMs). The City utilizes the Charlotte Mecklenburg Storm Water Design Manual for the methodology of computing peak flows, runoff volumes, and discharge capacities for storm events and stormwater management facilities. In any case where the Charlotte Mecklenburg Storm Water Design Manual and the NCDENR Manual of Stormwater Best Management Practices have conflicting design standards, the State BMP requirements apply. It is assumed that since the City utilizes the NCDENR Manual of Stormwater Best Management Practices, that it complies with 15A NCAC 02H .1000. The City's LIDO also states that for high -density projects "General engineering design criteria for all projects shall be in accordance with 15A NCAC2H.1008(c), as explained in the Design Manual." II.F.2.c The permittee conducted site plan reviews of all new development and Plan Reviews redeveloped sites that 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 Yes --- development or sale). If yes, the site plan reviews addressed how the project applicant meets the performance standards. Yes --- If yes, the site plan reviews addressed how the project will ensure long-term maintenance. Yes --- Comments The City conducts site plan review to address the site performance standards and review the maintenance associated with stormwater controls. Documents are provided online on the Stormwater Forms page for Stormwater Collection System Maintenance Requirements and Guidelines for Stormwater Maintenance Agreement. Plans are reviewed by the different departments of the City and there are several back and forth iterations during the review and edit process. Plans can receive conditional approval until they get approval from the State and a pre -conference is held. Some review work is also completed by a contracted company. Audit Date(s): February 2021 Page 9 of 14 MS4 Permit Audit Report Kannapolis, NC: NPDES Permit No. NCS000413 Post -Construction Site Runoff Controls II.F.2.d The permittee maintained an inventory of projects with post -construction Inventory of Projects structural stormwater control measures installed and implemented at new Yes 05 development and redeveloped sites. The inventory included both public and private sector sites located within the permittee's corporate limits that are covered by its post -construction ordinance Yes 05 requirements. Comments The City maintains an inventory of post -construction structural stormwater controls installed and implemented at new development and redeveloped sites in their MS4 area. This is currently stored in a spreadsheet, though an effort is currently in process to update the information in a geographic information system (GIS) database. II.F.2.e The permittee provided mechanisms such as recorded deed restrictions and Deed Restrictions protective covenants that ensure development activities will maintain the project Yes 04 and Protective consistent with approved plans. Covenants Comments The City's Ordinance contains language regarding deed restrictions and responsibilities are recorded to ensure activities will maintain the project as described in the approved plans. The operation and maintenance agreement is signed by the owner and kept with the deed (in most cases). II.F.2.f The permittee implemented or required an operation and maintenance plan for Mechanism to the long-term operation of the SCMs required by the program. Yes --- Require Long-term Operation and The operation and maintenance plan required the owner of each SCM to perform Maintenance and maintain a record of annual inspections of each SCM. Yes --- Annual inspection of permitted structural SCMs are required to be performed by a qualified professional. Yes --- Comments The City provides information on what is required for stormwater operation and maintenance agreement documents on the Stormwater Forms webpage. There are also maintenance and inspection forms online that provide a list of maintenance items related to the specific structural control, an area to indicate if the maintenance item is satisfactory or unsatisfactory, and an area for other comments or actions required. The inspections are required to be completed annually and to be completed by a registered North Carolina Professional Engineer, Professional Land Surveyor, or Landscape Architect. II.F.2.g The permittee has developed and implemented a written inspection program for Inspections of structural stormwater controls to ensure that all stormwater control measures Structural meet the permittee's performance standards and are being maintained pursuant to Partial --- Stormwater Control the maintenance agreement. Measures The permittee documented and maintained records of inspections. Yes --- The permittee documented and maintained records of enforcement actions. No --- Audit Date(s): February 2021 Page 10 of 14 MS4 Permit Audit Report Kannapolis, NC: NPDES Permit No. NCS000413 Post -Construction Site Runoff Controls Comments The City has implemented an inspection program, though this program is not formally documented. The City sends letters to property owners annually to remind them that their annual inspections are due. Structural control owners are responsible for conducting the inspections and sending in the inspection results and maintenance form to the City documenting what was done. The City is considering conducting their own inspections due to the low return rate of inspection forms. The City currently inspects structural control measures informally. Returned inspection forms are maintained for record, though not all structural controls are currently maintained annually. Enforcement actions have not currently been taken regarding owners not submit their annual inspection. II.F.2.h The permittee made available through paper or electronic means, ordinances, Educational post -construction requirements, design standards checklists, and other materials Materials and appropriate for developers. 02, 03, Training for Note: New materials may be developed by the permittee, or the permittee may use Yes 04 Developers materials adopted from other programs and adapted to the permittee's new development and redevelopment program. Comments (if the permittee has adopted materials from other programs, indicate here which materials they are using) The City has relevant Ordinances available online and in these, the design manuals utilized are referenced. The City has the UDO that references the Charlotte Mecklenburg Stormwater Design Manual methodology for calculating peak flows, runoff volumes, and discharge capacities. When Charlotte Mecklenburg's Stormwater Design Manual and the NCDENR Manual of BMPs conflict, the State BMP requirements apply. The NCDENR Manual of BMPs has a list of the acceptable stormwater treatment practices allowed by the State. II.F.2.i Enforcement The permittee tracked the issuance of notices of violation and enforcement Not actions. Applicable If yes, the tracking mechanism included the ability to identify chronic violators Not for initiation of actions to reduce noncompliance. Applicable Comments This currently reads as not applicable because the City has not issued any notice of violations (NOVs) or enforcement actions. If they were to issue any enforcement actions these should be documented in CityWorks. II.F.3.b The permittee fully complies with post construction program requirements on its New Development own publicly funded construction projects. Yes --- Comments The City complies with post construction program requirements on its own publicly funded construction projects. Audit Date(s): February 2021 Page 11 of 14 MS4 Permit Audit Report Kannapolis, NC: NPDES Permit No. NCS000413 Post -Construction Site Runoff Controls II.F.3.c Does the MS4 have areas draining to Nutrient Sensitive Waters (NSW) pursuant to Nutrient Sensitive 15A NCAC 02H .0150? No --- Waters If yes, does the permittee use SCMs that reduce nutrient loading in order to Not meet local program requirements. Applicable If yes, does the permittee also still incorporate the stormwater controls Not required for the project's density level. Applicable If yes, does the permittee also require documentation where it is not feasible to Not use SCMs that reduce nutrient loading. Applicable Comments (Provide reference for local requirements) According to the map tools on the NCDENR webpage, the City of Kannapolis does not drain to any nutrient sensitive waters (NSW). II.F.3.d The permittee ensured that the design volumes of SCMs take into account the Design Volume runoff at build out from all surfaces draining to the system. Yes --- Where "streets" convey stormwater, the permittee designed SCMs to be sized to treat and control stormwater runoff from all surfaces draining to the SCM including Yes --- streets, driveways, and other impervious surfaces. Comments The City ensures design volumes of stormwater control measures take into account the runoff at build out from all surfaces draining to the system. The City also ensures that streets, driveways, and other impervious surfaces are considered in the design size of stormwater control measures for treating stormwater runoff. Additional Overall, it appears that the City is partially out of compliance for this minimum control measure. Though the Comments: appropriate legal authority is in place and plan reviews are being performed, the City is not fully implementing the requirements for long-term operation and maintenance of SCMs. Though the process for annual inspections of SCMs begins, it is not fully carried out to ensure that annual inspection results and maintenance forms are received. Audit Date(s): February 2021 Page 12 of 14 MS4 Permit Audit Report Kannapolis, NC: NPDES Permit No. NCS000413 Total Maximum Daily Loads (TMDLs) Staff Interviewed: Scott Kaufhold, City Engineer (Name, Title, Role) Catherine Bolick, Civil Engineer I Program Status: ❑x The permittee is not subject to an approved TMDL (skip the rest of this section). ❑ The permittee is subject to an approved TMDL for: N/A There ❑ is ❑ is not a Waste Load Allocation (WLA) in the approved TMDL (If there is a WLA, then complete items H.H.1-5 below. If there is not a WLA, skip to item II.H.6 below) Permit Citation Program Requirement Status Supporting Doc No. II.H.3 TMDLs Within 12 months of final TMDL approval, the permittee's annual reports included a description of existing programs, controls partnerships, projects and strategies to p g p g p p' p j g Not Applicable address impaired waters. Within 12 months of final TMDL approval, the permittee's annual reports provided a brief explanation as to how the programs, controls, partnerships, projects and Not Applicable strategies address impaired waters. Comments The City is currently not subject to an approved TMDL. The City should be aware of future approved TMDLs to determine if they are responsible for any permit requirements. II.H.4 TMDLs Within 24 months of final TMDL approval, the permittee's annual reports included an assessment of whether additional structural and/or non-structural BMPs are Not Applicable necessary to address impaired waters. Within 24 months of final TMDL approval, the permittee's annual reports included a brief explanation as to how the programs, controls, partnerships, projects and Not Applicable strategies address impaired waters. Comments The City is currently not subject to an approved TMDL. The City should be aware of future approved TMDLs to determine if they are responsible for any permit requirements. II.H.5 TMDLs Within 36 months of final TMDL approval, the permittee's annual reports included a description of activities expected to occur and when activities are expected to Not Applicable occur. Comments The City is currently not subject to an approved TMDL. The City should be aware of future approved TMDLs to determine if they are responsible for any permit requirements. II.H.6 TMDLs If there is no Waste Load Allocation in the approved TMDL, the permittee evaluated strategies and tailored and/or expanded BMPs within the scope of the Not six minimum measures to enhance water quality recovery strategies in the Applicable watershed(s) to which the TMDL applies. The permittee described strategies and tailored and/or expanded BMPs in their Not Stormwater Management Plan and annual reports Applicable -- Audit Date(s): February 2021 Page 13 of 14 MS4 Permit Audit Report Kannapolis, NC: NPDES Permit No. NCS000413 I Total Maximum Daily Loads (TMDLs) Comments The City is currently not subject to an approved TMDL. The City should be aware of future approved TMDLs to determine if they are responsible for any permit requirements. Additional Since the City is not currently subject to an approved TMDL there are no additional comments. The City should Comments: be aware of future approved TMDLs to determine if they are responsible for any permit requirements. 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