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Home My WebLink AboutNCS000402_Mebane MS4 AUDIT REPORT_20210702MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) PROGRAM AUDIT REPORT NPDES PERMIT NO. NCS000402 The City of Mebane, NORTH CAROLINA 109 E. Washington Street Mebane, NC 27302 Audit Date: June 22, 2021 Report Date: July 2, 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 (This page intentionally left blank) NCS000402_The City of Mebane MS4 Audit_20210622 TABLE OF CONTENTS AuditDetails..................................................................................................................................................1 PermitteeInformation..................................................................................................................................2 Listof Supporting Documents.......................................................................................................................3 Program Implementation, Documentation & Assessment...........................................................................5 Illicit Discharge Detection and Elimination (IDDE)........................................................................................9 Post -Construction Site Runoff Controls......................................................................................................11 Pollution Prevention and Good Housekeeping for Municipal Operations..................................................16 Site Visit Evaluation: Municipal Facility No. 1.............................................................................................19 Site Visit Evaluation: Municipal Facility No. 2.............................................................................................21 Site Visit Evaluation: MS4 Outfall No. 1......................................................................................................23 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1............................................25 Appendix A: Supporting Documents Appendix B: Photograph Log 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. NCS000402_The City of Mebane MS4 Audit_20210622 This page intentionally left blank NCS000402_The City of Mebane MS4 Audit_20210622 Audit Details Audit ID Number: Audit Date(s): NCS000402_City of Mebane MS4 Audit_20210622 June 22-23, 2021 Minimum Control Measures Evaluated: 0 Program Implementation, Documentation & Assessment ❑ Public Education & Outreach ❑ Public Involvement & Participation 0 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 0 Post -Construction Site Runoff Controls 0 Pollution Prevention and Good Housekeeping for Municipal Operations ❑ Total Maximum Daily Loads (TMDLs) Field Site Visits: 0 Municipal Facilities. Number visited: 2 ❑X MS4 Outfalls. Number visited: 1 ❑ Construction Sites. Number visited: Choose an item. 0 Post -Construction Stormwater Runoff Controls. Number visited: 1 ❑ Other: Number visited: Choose an item. ❑ Other: Number visited: Choose an item. Inspector(s) Conducting Audit Name, Title Organization Levi Hiatt, Assistant Regional Engineer NCDEQ— DEMLR: WSRO Zachary Lentz, Assistant Regional Engineer NCDEQ— DEMLR: WSRO Kimberly Turney, Environmental Specialist I NCDEQ— DEMLR: WSRO Blane Houck, Environmental Specialist I NCDEQ— DEMLR: WSRO Audit Report Author: Date: Signature Audit Report thor: Date Z�2 I Signature Audit Repor Author: Date 0-7 1 6 ; 9A Signature V Audit Report Author: Date 0 7 A �g 0— Signature'--- NCS000402—City of Mebane MS4 Audit_20210622 Page 1 of 29 Permittee Information MS4 Permittee Name: Permit Effective Date: Permit Expiration Date: The City of Mebane February 20, 2017 February 19, 2022 Mailing Address: 106 E Washington Street Date of Last MS4 Inspection/Audit: Mebane, NC 27302 January 31, 2018 Co-permittee(s), if applicable: Not applicable. Permit Owner of Record: Chris Rollins, City Manager Primary MS4 Representatives Participating in Audit Name, Title Organization Preston Mitchell, Assistant City Manager The City of Mebane Josh Johnson, PE, Vice President, Head of Engineering Alley, Williams, Carmen &King (AWCK) Phil Ross, Stormwater Coordinator Alley, Williams, Carmen & King (AWCK) Chuck Smith, Public Works Director The City of Mebane Cy Stober, Development Director The City of Mebane Kyle Smith, PE, Utilities Director The City of Mebane Franz Holt, PE, City Engineer The City of Mebane Waterbody Lower Back Creek Haw Creek Mill Creek Mill Creek Little Haw Creek Moadams Creek Lake Michael MS4 Receiving Waters Classification WS-V; NSW WS-V; NSW WS-II; HQW, NSW WS-II; HQW, NSW, CA WS-V; NSW WS-V; NSW WS-II; HQW, NSW Impairments Fish Tissue Mercury (Nar, FC, NC) Fish Tissue Mercury (Nar, FC, NC) Fish Tissue Mercury (Nar, FC, NC) Fish Tissue Mercury (Nar, FC, NC) Fish Tissue Mercury (Nar, FC, NC) Turbidity (50 NTU, AL, FW miles) Fish Tissue Mercury (Nar, FC, NC) NCS000402_City of Mebane MS4 Audit_20210622 Page 2 of 29 List of Supporting Documents Item Number Document Title When Provided (Prior to/During/After) 1 Mebane Final Permit NCS000402 - Revised Prior 2 Mebane CSWMP Report 2021 - Revised Prior 3 City of Mebane Stormwater Webpage (https://www.cityofinebane.com/city_hall/departments/planning_and_z oning/stormwater management) Prior 4 2016 Mebane NPDES Phase II Stormwater Annual Report Prior 5 2017 Mebane NPDES Phase II Stormwater Annual Report Prior 6 2018-19 Mebane NPDES Phase II Stormwater Annual Report Prior 7 2019-20 Mebane NPDES Phase II Stormwater Annual Report Prior 8 DEMLR e-Payment Website (https://deq.nc.gov/about/divisions/energy-mineral-and-land- resources/stormwater/stormwater-program/stormwater-epayments) Prior 9 Annual Stormwater Operation and Maintenance Report Cover Sheet Prior 10 Mebane SCM Inspection Log Prior 11 IDDE Tracking Sheet Prior 12 505 Collington Farms IDDE NOV Prior 13 139 Stoneham Drive IDDE NOD Prior 14 Mebane Illicit Discharge Ordinance Prior 15 MS4 Map Package Prior 16 Mebane 2020 IDDE Program Update Prior 17 Mebane IDDE-PPGH Training 2017 Prior 18 2015 Mebane Sign -in Sheet Prior 19 2016 Mebane Sign -in Sheet Prior NCS000402_City of Mebane MS4 Audit_20210622 Page 3 of 29 20 2017 Mebane Sign -in Sheet Prior 21 IDDE Brochure Prior 22 AWCK Educational Events 19-20 Prior 23 AWCK Educational Events 18-19 Prior 24 City of Mebane — AWCK Engineering Contract Prior 25 Phase II Post Construction Ordinance Adopted Prior 26 Stormwater Overview — Mebane 2020 Prior 27 Mebane 0&M Plan 2017 Prior 28 Public Works Stormwater Inspection Report 6-9-2021 After 29 Compass Pointe File Prior 30 Stormwater Review Scans Prior 31 City of Mebane SCM Maintenance Program Prior 32 Mebane Fire Department #3 SW Facility Inspection 6-17/2021 After 33 2021 Mebane Fire Department #3 SCM Device 121, 121A, 122, 123 Inspection REPORT 6-17-2021 After 34 Mebane Fire Department # 3 Stormwater File After NCS000402—City of Mebane MS4 Audit_20210622 Page 4 of 29 Program Implementation, Documentation & Assessment Staff Interviewed: Josh Johnson, Vice President and Head Engineer AWCK, Stormwater Engineer for the City of Mebane (Name, Title, Role) Phillip Ross, Stormwater Coordinator AWCK, Stormwater Coordinator and Inspector for the City of Mebane Permit Citation Program Requirement Status Supporting poc No. II.A.1 The permittee maintained adequate funding and staffing to implement and manage Staffing and the provisions of the Stormwater Plan and meet all requirements of the permit. Yes --- Funding The Stormwater Plan identifies a specific position(s) responsible for the overall Partial 2 coordination, implementation, and revision to the Plan. Responsibilities for all components of the Stormwater Plan are documented and Yes 2 position(s) assignments provided. The permittee is current on payment of invoiced administering and compliance Yes 8 monitoring fees (see stormwater e-payments on DEMLR MS4 web page). The annual reports do not state whether the provided funding for stormwater services was adequate or not. However, during the meeting, the permittee stated that there were no deficiencies with the current funding and staffing to implement and manage the SWMP and meet all requirements of the permit. Upon further inspection of the provided documents, this statement appears to be currently valid. The SWMP does not specifically state the positions responsible for the overall coordination, implementation, and revision of the Plan, but it does list responsibilities for all components of the SWMP with the respective position assignments. Furthermore, according to DEMLRs e-payment website, the permittee is current on payment of fees. II.A.2 Stormwater The permittee evaluated the performance and effectiveness of the program Partial 4, 5, 6, 7 Plan components at least annually. Implementation and Evaluation If yes, the permittee used the results of the evaluation to modify the program Not components as necessary to accomplish the intent of the Stormwater Program. Applicable --- 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 --- The permittee has submitted SWMPA's as required during the permit cycle. However, the performance and effectiveness of the program components were not evaluated in the Annual Reports, nor were the effects of MS4 discharges on water quality. II.A.3 Keeping the The permittee kept the Stormwater Plan up to date. Partial 2 Stormwater Plan Up to Date The permittee notified DEMLR of any updates to the Stormwater Plan. Not Applicable --- NCS000402_City of Mebane MS4 Audit_20210622 Page 5 of 29 Program Implementation, Documentation & Assessment Program components were not updated due to the lack of evaluating the performance and effectiveness of the program components in the annual reports. However, the permittee revised the SWMP in 2021 to update the names of the personnel responsible for the different SWMP components. II.A.4 Availability The permittee kept an up-to-date version of its Stormwater Plan available to the of the Stormwater Division and the public online. No 3 Plan The online materials included ordinances, or other regulatory mechanisms, or a list identifying the ordinances, or other regulatory mechanisms, providing the legal Yes 3 authority necessary to implement and enforce the requirements of the permit. The permitee's Stormwater Management webpage includes links to view the City's Post Construction Ordinance, Storm Sewer Design Manual, Illicit Discharge Ordinance, and Riparian Buffer Protection Ordinance. However, a link to view the SWMP could not be found on the webpage. II.A.3 & II.A.S Stormwater Plan Did DEMLR require a modification to the Stormwater Plan? No --- Modifications If yes, did the permittee complete the modifications in accordance with the Not established deadline? Applicable No record from DEMLR or the permittee indicate that a modification to the Stormwater Plan was required by DEMLR. ll.A.6 Sharing Responsibility Are any control measures implemented by an entity other than the permittee? Yes 2 If yes, is there a written agreement in place? Partial 24 The permittee utilizes PTRC-s Storm water SMART program to fulfill the Public Education and Outreach and Public Involvement and Participation MCMs, but a formal agreement is not in place. The permittee also utilizes A WCK for on -call city engineering services. A contract is in place for these services. Furthermore, DEMLR implements Construction Site Runoff. No agreement is in place for this program, which is typical. ll.A.7 The permittee maintained written procedures for implementing the six minimum 2 Written control measures. Partial Procedures Written procedures identified specific action steps, schedules, resources and 2 responsibilities for implementing the six minimum measures. Partial It is unclear if the written procedures for implementing the six minimum control measures were maintained. Written procedures identifying specific action steps, resources, and responsibilities for implementing the six minimum measures were included in the SWMP, but the schedules for doing so were not. 111. A The permittee maintained documentation of all program components including, but 4, 5, 6, 7, Program not limited to, inspections, maintenance activities, educational programs, Yes 8, 10, 11, Documentation implementation of BMPs, enforcement actions etc., on file for a period of five years. 12,13 NCS000402_City of Mebane MS4 Audit_20210622 Page 6 of 29 Program Implementation, Documentation & Assessment A summary of the educational activities and the approximate number of persons impacted through those activities were provided in the Annual Reports. An annual inspection report was also provided for a wet detention pond in Mebane and a SCM inspection log showing the different SCMs that were inspected during 2019-2021. A tracking sheet was also provided that displayed Illicit Discharges detected, the enforcement type, if any, that was issued for that illicit discharge, and if that issue was resolved. An example of a Notice of Violation and Notice of Discharge was provided. It was noted during the meeting and inspections that a tracking mechanism to track maintenance activities was not in place. 1111.113 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 Yes 4, 5, 6, 7 Submittal period specific to this MS4). The permittee submitted subsequent annual reports every twelve months from the Yes 4, 5, 6, 7 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 Partial 4, 5, 6, 7 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 Not 4, 5, 6, 7 the proposed changes and how these changes will impact the Stormwater Applicable pp 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 Applicable Not 4, 5, 6, 7 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 Yes 4, 5, 6, 7 Stormwater Plan. 5. An assessment of compliance with the permit, information on the establishment of appropriate legal authorities, inspections, and enforcement Partial 4, 5, 6, 7 actions. The Annual Reports summarize what actions were taken during the past year related to what is described in the SWMP. However, the Annual Reports do not list schedules and plans for the year following the reports. The Annual reports also do not describe, justify, or document any changes made to programs or practices listed in the SWMP. However, the Annual Reports do list summaries of data accumulated as part of the SWMP but fails to assess compliance with the permit. The Annual Reports also briefly mention some inspections, specifically for illicit discharges. IV.B Annual Reporting The Annual Reports document the following: 1. A summary of past year activities, including where applicable, specific Yes 4, 5, 6, 7 quantities achieved and summaries of enforcement actions. 2. A description of the effectiveness of each program component. No 4, 5, 6, 7 3. Planned activities and changes for the next reporting period, for each No 4, 5, 6, 7 program component or activity. NCS000402_City of Mebane MS4 Audit_20210622 Page 7 of 29 Program Implementation, Documentation & Assessment 4. Fiscal analysis. No 4, 5, 6, 7 The annual reports mainly summarize what has been done during the past year to fulfill the items listed in the SWMP. The effectiveness of each program or activity was not evaluated in the Annual Reports, nor was the budget that is provided for the stormwater program. Furthermore, the Annual Reports only stated possible improvements for some program areas but did not list a planned improvement or change that would be put in place. Additional The Annual Reports are meant to be used as a current assessment of the SWMP and its implementation. The Comments: Annual Reports should also describe the effectiveness of the SWMP and any changes that need to be made, as well as any changes that were made during the previous year. Please revise the way in which the Annual Reports are conducted, so that they provide an update on how well the SWMP is being implemented and how well the components of the SWMP are working for the permittee. NCS000402_City of Mebane MS4 Audit_20210622 Page 8 of 29 Illicit Discharge Detection and Elimination (IDDE) Staff Interviewed: Josh Johnson, Vice President and Head Engineer AWCK, Stormwater Engineer for the City of Mebane (Name, Title, Phillip Ross, Stormwater Coordinator AWCK, Stormwater Coordinator and Inspector for the City of Mebane Role) Permit Citation Program Requirement Status Supporting Doc No. II.D.2.a IDDE Program The permittee maintained a written IDDE Program. Partial 4, 5, 6, 7, 14 If yes, the written program includes provisions for program assessment and evaluation and integrating program. Yes 14 The permittee maintained an IDDE ordinance or other regulatory mechanism(s) that II.D.2.b provides the legal authority to prohibit illicit connections and discharges to the MS4. Yes 14 Legal Authorities If yes, the ordinance applies throughout the corporate limits of the permittee. [Permit Part I.D] Yes 14 II.D.2.c Storm Sewer The permittee maintained a current map showing major outfalls* and receiving 4, 5, 6, 7, System Map streams. Partial 15 II.D.2.d Dry Weather Flow The permittee maintained a program for conducting dry weather flow field Partial 16,17 Program observations in accordance with written procedures. A general outline for conducting dry weather flow field observations was described within the Illicit Discharge and Elimination Program documents. However, no evidence was presented to suggest that adequate recordkeeping and tracking was implemented for dry weather flow screenings. As provided in the annual reports, the outfall map has not been updated as needed. Furthermore, the permittee should better evaluate the IDDE program and list the areas that need improvement as well as the areas that were improved from the previous year. II.D.2.e Investigation The permittee maintained written procedures for conducting investigations of 17, 18, Procedures identified illicit discharges. Partial 19, 20 Evidence was presented to suggest that general procedures for conducting investigations of identified illicit discharges were outlined during employee training events, as well as the annual reports. Among the presented documents, dedicated procedures for investigating illicit discharges, specific to the permittee, were not located. II.D.2.f For each case of an illicit discharge or potential illicit discharge, the permittee documented and tracked the Track and following: Document Investigations 1. The dates) the illicit discharge was observed Yes 11 2. The results of the investigation Yes 11 3. Any follow-up of the investigation Yes 11 NCS000402_City of Mebane MS4 Audit_20210622 Page 9 of 29 Illicit Discharge Detection and Elimination (IDDE) 4. The date the investigation was closed Yes 11 II.D.2.g 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 Partial 17,18,19 contact with or otherwise observe an illicit discharge or illicit connection. Evidence was presented to suggest that, over the course of the permit cycle, training events took place in which municipal staff members were generally made aware of illicit discharges or illicit connections. However, a dedicated training program was not outlined. II.D.2.h The permittee informed public employees of hazards associated with illegal 18,19, 20, Public Education discharges and improper disposal of waste. Yes 21 The permittee informed businesses of hazards associated with illegal discharges and 4, 5, 6, 7, improper disposal of waste. Yes 21 The permittee informed the general public of hazards associated with illegal 4, 5, 6, 7, discharges and improper disposal of waste. Yes 21 The permittee informed municipal employees through a series of training events. Both the general -public and businesses were informed via brochures and outreach events. Il.D.2.i The permittee promoted, publicized, and facilitated a reporting mechanism for the Partial 3, 22, 23 Public Reporting public to report illicit discharges. Mechanism The permittee promoted, publicized, and facilitated a reporting mechanism for staff Partial 17, 18, to report illicit discharges. 19 The permittee established and implemented response procedures for citizen No --- requests/reports. General reporting procedures for municipal employees were described during training events, and a helpline, found on the program's website, was promoted during several public outreach events. However, no direct response procedures were established, outlined, or described. Additionally, it was described that tracking procedures were not set in -place for citizen complaints of illicit discharges that did not lead to the issuance of a violation. II.D.2.j The permittee implemented a mechanism to track the issuance of notices of violation Yes 11 Enforcement and enforcement actions administered by the permittee. .If yes, the mechanism includes the ability to identify chronic violators for Yes 11 initiation of actions to reduce noncompliance. The permittee developed and maintained a database that detailed notices of violation and enforcement actions issued during the permit cycle, to include the identification of violators and resolution of enforcement actions. NCS000402_City of Mebane MS4 Audit_20210622 Page 10 of 29 Post -Construction Site Runoff Controls Staff Interviewed: Josh Johnson, Vice President and Head Engineer AWCK, Stormwater Engineer for the City of Mebane (Name, Title, Role) Phillip Ross, Stormwater Coordinator AWCK, Stormwater Coordinator and Inspector for the City of Mebane Cy Stober, Development Director, The City of Mebane Implementation (check all that apply): ❑ The permittee implements the components of this minimum measure. ❑ The permittee relies upon another entity to implement the components of this minimum measure: ❑X 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 Law 2006-246 section below): ❑ Water Supply Watershed I (WS-1) —15A NCAC 2B .0212 ❑X Water Supply Watershed II (WS-11) —15A NCAC 213.0214 ❑ Water Supply Watershed III (WS-III) —15A NCAC 2B .0215 ❑ Water Supply Watershed IV (WS-IV) —15A NCAC 213.0216 ❑ Freshwater High Quality Waters (HOW) —15A NCAC 2H .1006 ❑ Freshwater Outstanding Resource Waters (ORW) —15A NCAC 2H .1007 ❑X 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 ❑X MS4 designed post -construction practices that meet or exceed 15A NCAC 02H .1000. ❑ DEQ approved comprehensive watershed plan ❑ DEQ approved ordinance for a deemed -compliant Program (see list above) Inctri irtinnc- 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. NCS000402—City of Mebane MS4 Audit_20210622 Page 11 of 29 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 25 The permittee implements deemed -compliant Program requirements throughout the entire MS4 area (If not, also complete the Permit Citation section below.) No 25 The permittee applies deemed -compliant Program requirements to all federal, state and local government projects within the permitted MS4 area who do not Yes 25 have their own NPDES stormwater permit. The permittee included deemed -compliant Program reporting in their MS4 Annual Reports. No --- The permittee included deemed -compliant Program implementation in their Stormwater Management Plan. No --- The WS-11 program did not appear to be included in the Stormwater Management Plan. The commentary on the Program included in the MS4 Annual Reports is general, nearly identical from year to year, and provides very little information on the Program for that year. 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 25 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 1,25 accordingly). The permittee has the authority to review designs and proposals for new development and redevelopment to determine whether adequate stormwater Yes 25 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 Yes 25 evaluate compliance with the Post -Construction Stormwater Management Program. The permittee has the authority to enter private property for the purpose of inspecting at reasonable times any facilities, equipment, practices, or operations Yes 25 related to stormwater discharges. The ordinance has only a few items different from the model ordinance and appears to be reviewed regularly to assure clarity. II.F.2.b Stormwater Control The permittee utilizes strategies which include SCMs appropriate for the MS4. Yes 26,29 Measures (SCMs) SCMs comply with 15A NCAC 02H .1000. Yes 26,29 NCS000402_City of Mebane MS4 Audit_20210622 Page 12 of 29 Post -Construction Site Runoff Controls The guidance provided to plan designers and plan reviews documented by the permittee show that SCMs are implemented in compliance with the permit and applicable regulations. 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 29,30 development or sale). If yes, the site plan reviews addressed how the project applicant meets the performance standards. Yes 29 If yes, the site plan reviews addressed how the project will ensure long-term maintenance. Yes 29 Plan reviews were conducted as deemed necessary through the Planning Department. Reviews assured the projects met the requirements of the design manual and ordinance, thereby addressing performance standards and long-term maintenance. 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 10 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 10 requirements. The permittee maintains an inventory of SCM's with inspection information included. II.F.2.e The permittee provided mechanisms such as recorded deed restrictions and Deed Restrictions 25, 26, and Protective protective covenants that ensure development activities will maintain the project Yes 29 Covenants consistent with approved plans. The permittee can and does appear to utilize deed restrictions, protective covenants, and performance security with surety, cash escrow, etc. 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 25,29 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 25,29 Annual inspection of permitted structural SCMs are required to be performed by a qualified professional. Yes 25,29 The ordinance specifies that the O&M plans are required and that SCMs must be inspected annually by qualified professionals. The Compass Pointe example documentation shows that these plans are in fact required and include annual inspection requirements. The permittee conducted and documented inspections of each project site covered under performance standards, at least one time during the permit term (Verify this Yes 10 is a permit condition in Part II.F.2.g of permit and modify accordingly). NCS000402_City of Mebane MS4 Audit_20210622 Page 13 of 29 Post -Construction Site Runoff Controls Before issuing a certificate of occupancy or temporary certificate of occupancy, the permittee conducted a post -construction inspection to verify that the permittee's performance standards have been met or a bond is in place to guarantee Yes 25,29 completion (Verify this is a permit condition in Part II.F.2.g of permit and modify II.F.2.g accordingly. Inspections of The permittee developed and implemented a written inspection program for SCMs Structural installed pursuant to the post -construction program (Verify this is a permit Partial 31 Stormwater Control condition in Part II.F.2.g of permit and modify accordingly. Measures The permittee documented and maintained records of inspections. Yes 29 The permittee documented and maintained records of enforcement actions. Not Applicable An SCM program exists, but it does not show how the permittee will conduct post -construction inspections and assure that the inspections are conducted once per permit cycle. The permittee reported that this program had no enforcement actions, stating that the structure of the program results in compliance. Nearly all SCM's have been inspected already during this permit cycle. 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. Yes 26 Training for Note: New materials may be developed by the permittee, or the permittee may use Developers materials adopted from other programs and adapted to the permittee's new development and redevelopment program. The permittee indicated that these items are provided to developers as their projects reach Planning/TRC. II.F.2.i Enforcement The permittee tracked the issuance of notices of violation and enforcement No --- actions. If yes, the tracking mechanism included the ability to identify chronic violators Not for initiation of actions to reduce noncompliance. Applicable The permittee reported that this program had no violations or enforcement actions, stating that the structure of the program results in compliance. II.F.3.b The permittee fully complies with post construction program requirements on its 25, 32, New Development own publicly funded construction projects. Yes 33,34 Publicly funded facilities and projects appear to be compliant with program requirements. II.F.3.c Does the MS4 have areas draining to Nutrient Sensitive Waters (NSW) pursuant to Nutrient Sensitive 15A NCAC 02H .0150? Yes --- Waters If yes, does the permittee use SCMs that reduce nutrient loading in order to Yes 25,26 meet local program requirements. If yes, does the permittee also still incorporate the stormwater controls Yes 25,26 required for the project's density level. NCS000402_City of Mebane MS4 Audit_20210622 Page 14 of 29 Post -Construction Site Runoff Controls If yes, does the permittee also require documentation where it is not feasible to use SCMs that reduce nutrient loading. Yes 25,26 II.F.3.d The permittee ensured that the design volumes of SCMs take into account the Choose Design Volume runoff at build out from all surfaces draining to the system. an item. 25,26 Where "streets" convey stormwater, the permittee designed SCMs to be sized to Choose treat and control stormwater runoff from all surfaces draining to the SCM including 25,26 streets, driveways, and other impervious surfaces. an item. The ordinance, stormwater documents for designers, and TRC/Planning process as described during the audit show that runoff at buildout, including runoff from streets, is considered in design of the SCMs. Additional The permittee's post -construction program appears to involve a thorough review process through TRC and to Comments: result in structures and practices consistent with the ordinance and guidance documents. Improvements should be made to documenting program planning and evaluation. NCS000402_City of Mebane MS4 Audit_20210622 Page 15 of 29 Pollution Prevention and Good Housekeeping for Municipal Operations Staff Interviewed: Josh Johnson, Vice President and Head Engineer AWCK, Stormwater Engineer for the City of Mebane (Name, Title, Role) Chuck Smith, Public Works Director, City of Mebane Kyle Smith, Utilities Director, City of Mebane Permit Citation Program Requirement Status SupportingDoc No. II.G.2.a 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 27 stormwater runoff. The 2017 0&M plan lists 13 municipal facilities and 15 wastewater pump stations. A summary of the facilities, potential areas and items of concern impacting storm water pollution, and best management practices was listed. II.G.2.b The permittee maintained and implemented an O&M program for municipally Operation and owned and operated facilities with the potential for generating polluted Partial 27 Maintenance (O&M) stormwater runoff. for Facilities If yes, the O&M program specifies the frequency of inspections. Yes 27 If yes, the O&M program specifies the frequency of routine maintenance Yes 27 requirements. If yes, the permittee evaluated the 0&M program annually and updated it as 4, 5, 6, 7, necessary. No 27 The 2017 0&M plan addresses inspections and routine maintenance for municipally owned and operated facilities. In some cases, the frequency listed is as needed or when issues are observed. In other instances, it is listed as weekly, monthly, or every two months. However, the O&M plan has not been updated since 2017 and does not appear to have been evaluated per the annual reports. II.G.2.c Spill Response The permittee had written spill response procedures for municipal operations. Partial --- Procedures A spill response plan for each municipally owned facility was not found in the Stormwater Plan. Furthermore, the Spill Response procedures posted at the Public Works Facility were general, included guidance on how to prevent spills, and did not adequately demonstrate the necessary procedures to respond to a spill. II.G.2.d 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 Yes 10 Parking Lots corporate limits annually. Maintenance If yes, the permittee evaluated the effectiveness of existing and new BMPs based on cost and the estimated quantity of pollutants removed. Yes --- Plans for SCMs are reviewed prior to construction through the Planning Department/TRC and are later inspected by engineering staff post construction. All SCMs appear to have been inspected by the permittee at least once during the permit cycle. NCS000402_City of Mebane MS4 Audit_20210622 Page 16 of 29 Pollution Prevention and Good Housekeeping for Municipal Operations II.G.2.e 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 Partial 27 Conveyance Systems maintains. The O&M plan states its goal is to prevent or reduce pollutant runoff from municipally owned facilities and their operations, identify potential sources of stormwater pollution at the facilities, recommend BMPs, and provide for periodic review. However, the O&M plan has not been updated since 2017 and does not appear to have been evaluated per the annual reports. II.G.2.f The permittee maintained a current inventory of municipally owned or operated Structural structural stormwater controls installed for compliance with the permittee's post- Yes 27 Stormwater Controls construction ordinance. The 2017 O&M plan lists 13 municipal facilities and 15 wastewater pump stations. A summary of the facilities, potential areas and items of concern impacting stormwater pollution, and best management practices was listed. II.G.2.g The permittee maintained and implemented an 0&M program for municipally O&M for Structural owned or maintained structural stormwater controls installed for compliance with Partial 27 Stormwater Controls the permittee's post -construction ordinance. If yes, then: The O&M program specified the frequency of inspections and routine 27 maintenance requirements. Yes The permittee documented inspections of all municipally owned or maintained 10 structural stormwater controls. Yes The permittee inspected all municipally owned or maintained structural stormwater controls in accordance with the schedule developed by permittee. Yes 10 The permittee maintained all municipally owned or maintained structural 27,28 stormwater controls in accordance with the schedule developed by permittee. Partial The permittee documented maintenance of all municipally owned or 28 maintained structural stormwater controls. Partial Maintenance activities of municipally owned or maintained structural SCMs were only documented in inspection reports. There was no tracking mechanism to document when maintenance activities were completed. Furthermore, the O&M plan has not been updated since 2017 and does not appear to have been evaluated per the annual reports. II.G.2.h The permittee ensured municipal employees are properly trained in pesticide, Pesticide, Herbicide herbicide and fertilizer application management. Yes 27 and Fertilizer Application The permittee ensured contractors are properly trained in pesticide, herbicide and Management fertilizer application management. Yes 27 The permittee ensured all permits, certifications, and other measures for applicators are followed. Yes 27 The landscaping coordinator is properly trained and holds the pesticide, herbicide, and fertilizer applicator license. They maintain their certification and are responsible for training and supervising the applicators that work under their license. NCS000402_City of Mebane MS4 Audit_20210622 Page 17 of 29 Pollution Prevention and Good Housekeeping for Municipal Operations II.G.2.i The permittee implemented an employee training program for employees involved --- Staff Training in implementing pollution prevention and good housekeeping practices. Partial The training program is implemented by Storm water Smart. However, training has not occurred since 2017. II.G.2.j The permittee described and implemented measures that prevent or minimize Vehicle and contamination of stormwater runoff from all areas used for vehicle and equipment Yes 27 Equipment Cleaning cleaning. Runoff flows through wash bays into an oil/water separator, and then to a separate sanitary sewer line. NCS000402_City of Mebane MS4 Audit_20210622 Page 18 of 29 Site Visit Evaluation: Municipal Facility No. 1 Facility Name: Date and Time of Site Visit: Mebane Public Works Department June 23, 2021 9:15 am Facility Address: Facility Type (Vehicle Maintenance, Landscaping, etc.): 636 Corregidor St, Mebane, NC 27302 Vehicle Maintenance/Storage Name of MS4 inspector(s) evaluated: Most Recent MS4 Inspection (List date and name of inspector): Phill Ross June 9, 2021 by Phil Ross Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit: Name Title Kyle Smith Utilities Director Observations Facility Documentation/Training Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific? No. What type of stormwater training do facility employees receive? How often? None. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Stormwater BMP Inspection and Maintenance Certification. Renewed every 3 years. Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? Partially. The MS4 inspector appears knowledgeable about some of the permit requirements for pollution prevention and good housekeeping, such as parking lot maintenance, identifying stormwater runoff controls, and preventing contamination of stormwater runoff from Vehicle Maintenance Areas. However, the MS4 inspector should be more familiar with the O&M plans, spill prevention plans, and employee training programs for municipally owned facilities. Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping? Partially. The MS4 inspector easily identified areas that could be a potential problem in contaminating stormwater runoff from the facility. However, the MS4 inspector should also check the O&M plan for the facility as well as the employee training program to ensure the 0&M plan is being followed and that employees are properly trained for pollution prevention and good housekeeping. Inspection Procedures Does the MS4 inspector's process include the use of a checklist or other standardized form? Yes. Does the MS4 inspector's process include taking photos? Yes. Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)? Not applicable. NCS000402_City of Mebane MS4 Audit_20210622 Page 19 of 29 Site Visit Evaluation: Municipal Facility No. 1 Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge? Partially. The M4 inspector failed to inspect the discharge point for an area where mulch was being stockpiled. Did the MS4 inspector miss any obvious areas of concern? If so, explain: The MS4 inspector failed to inspect the discharge point for an area where mulch was being stockpiled. Does the MS4 inspector's process include presenting the inspection findings to the facility contact? Yes. The MS4 inspector requires the facility contact to attend the inspection. Inspection Results Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)? Yes. Silt fence needed to be placed around a stockpile area (Figure 1). If compliance corrective actions were identified, what timeline for correction/follow-up was provided? The MS4 inspector gave the facility 30 days to address the issues. Notes/Comments/Recommendations The MS4 inspector did not check to see if the facility had a SWPPP. This should be done for all facilities. It is also recommended that the MS4 inspector inspect the discharge point for the area where the mulch is being stockpiled (Figure 2). There was enough mulch being stored in this area that an NPDES Industrial Stormwater Permit may be required under NCG240000. NCS000402_City of Mebane MS4 Audit_20210622 Page 20 of 29 Site Visit Evaluation: Municipal Facility No. 2 Facility Name: Date and Time of Site Visit: Mebane Waste Treatment Plant June 23, 2021, 10:15 am Facility Address: Facility Type (Vehicle Maintenance, Landscaping, etc.): 626 Corregidor St, Mebane, NC 27302 Treatment Plant Name of MS4 inspector(s) evaluated: Most Recent MS4 Inspection (Date and Entity): Phil Ross June 9, 2021, Phil Ross Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit: Name Title Tony Bowes Facility Assistant Observations Facility Documentation/Training Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific? Yes, this facility has a facility specific SWPPP. What type of stormwater training do facility employees receive? How often? Unknown. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Stormwater BMP Inspection and Maintenance Certification. Renewed every 3 years. Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? Partially. The MS4 inspector appears knowledgeable about some of the permit requirements for pollution prevention and good housekeeping, such as parking lot maintenance, identifying stormwater runoff controls, and preventing contamination of stormwater runoff from critical areas. However, the MS4 inspector should be more familiar with the O&M plans, spill prevention plans, and employee training programs for municipally owned facilities. Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping? Partially. The MS4 inspector easily identified areas that could be a potential problem in contaminating stormwater runoff from the facility. However, the MS4 inspector should also check the O&M plan for the facility as well as the employee training program to ensure the O&M plan is being followed and that employees are properly trained for pollution prevention and good housekeeping. Inspection Procedures Does the MS4 inspector's process include the use of a checklist or other standardized form? Yes. Does the MS4 inspector's process include taking photos? Yes. Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)? Partially. The MS4 inspector briefly reviewed the SWPPP. NCS000402_City of Mebane MS4 Audit_20210622 Page 21 of 29 Site Visit Evaluation: Municipal Facility No. 2 Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge? Yes. Did the MS4 inspector miss any obvious areas of concern? If so, explain: No. Does the MS4 inspector's process include presenting the inspection findings to the facility contact? Yes. Inspection Results Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)? Yes, some additional rip rap was needed at outfall 3 (Figure 3), and a gutter pipe extension was needed at one of the roof drains (Figure 4). If compliance corrective actions were identified, what timeline for correction/follow-up was provided? The MS4 inspector gave the facility 30 days to address the issues. Notes/Comments/Recommendations It is recommended that the MS4 inspector take a more detailed look through the SWPPP when performing inspections to further ensure it is being implemented. It is also recommended that the MS4 inspector keep a tracking sheet of maintenance activities that are to be followed -up on. NCS000402_City of Mebane MS4 Audit_20210622 Page 22 of 29 Site Visit Evaluation: MS4 Outfall No. 1 Outfall ID Number: Date and Time of Site Visit: Outfall on Briarwood Drive June 23, 2021, 11:10 am Outfall Location: Outfall Description (Pipe Material/Diameter, Culvert, etc.): Approximate Coordinates: 36.084144,-79.290497 24" RCP Storm Sewer Outlet Receiving Water: Is Flow Present? If So, Describe (Color, Approximate Flow Rate, Sheen, Odor, Floatables/Debris, etc.): Unnamed Tributary Leading to Moadams Creek No flow was present at the time of the inspection. Most Recent Outfall Inspection/Screening (Date): Days Since Last Rainfall: Inches: Unknown Unknown Name of MS4 Inspector(s) evaluated: Josh Johnson Observations Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Unknown. Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations? Yes. Inspection Procedures Does the inspector's process include the use of a checklist or other standardized form? No. Does the inspector's process include taking photos? Yes. Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they? No. NCS000402_City of Mebane MS4 Audit_20210622 Page 23 of 29 Site Visit Evaluation: MS4 Outfall No. 1 Inspection Results Did the outfall inspection result in any work orders or maintenance requests? If so, for what issue(s)? The culvert directly adjacent to this outfall had a partial blockage due to some woody debris. A work order was requested to clear the debris. Will a follow-up outfall inspection be conducted? If so, for what reason? A follow-up inspection will be conducted to see if the debris was removed. NCS000402_City of Mebane MS4 Audit_20210622 Page 24 of 29 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1 Site Name: Date and Time of Site Visit: Compass Pointe Stormwater Retention Pond June 23, 2021 11:30 am Site Address: SCM Type: Approximate Coordinates: 36.066254,-79.303294 Retention Pond Most Recent MS4 Inspection (Include Date and Entity): October 13, 2020 - Stoltzfus Engineering, Inc. Name of MS4 Inspector(s) evaluated: Most Recent MS4 Enforcement Activity (Include Date): Josh Johnson, Phil Ross None. Observations Site Documentation Does the site have an operation and maintenance plan? No. An Operation and Maintenance agreement is in place between the owner of the site and the City of Mebane, but no evidence was suggested that there was an Operation and Maintenance plan specific to this site. Does the site have records of annual inspections? Are they performed by a qualified individual? According to the Mebane SCM Inspection Log, this retention pond was inspected in 2019 by Phil Ross, in which this retention pond failed the inspection. There were two other inspections done in 2020. An inspection was performed on April 22, 2020 by G2 Design, P.A. in which the pond failed inspection again. The last inspection was performed on October 13, 2020 by Stoltzfus Engineering, Inc., in which the pond passed inspection. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Phil Ross is certified in Stormwater BMP Inspection and Maintenance that is renewed every 3 years. Did the MS4 inspector appear knowledgeable about MS4 requirements for post -construction site runoff controls? Yes. Did the MS4 inspector appear knowledgeable about post -construction BMPs (general purpose/function, components, O&M requirements, etc.)? Yes. Inspection Procedures Does the MS4 inspector's process include the use of a checklist or other standardized form? What format? Yes. Standardized form. Does the MS4 inspector's process include taking photos? Yes. Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections? The MS4 inspector's process includes reviewing the most recent inspection record. Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge? Yes. NCS000402_City of Mebane MS4 Audit_20210622 Page 25 of 29 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1 Did the MS4 inspector miss any obvious operation and maintenance deficiencies? If so, explain: No. Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing? Yes. Compliance/Enforcement What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in? No enforcement actions resulted from this inspection. If compliance issues were identified, what timeline for correction/follow-up was provided? There were no compliance issues found during this inspection. Notes/Comments/Recommendations The inspector should also review the SCM's Operation and Maintenance plan prior to the inspection (provided there is one), to ensure that it is being implemented. NCS000402_City of Mebane MS4 Audit_20210622 Page 26 of 29 APPENDIX A: SUPPORTING DOCUMENTS NCS000402_City of Mebane MS4 Audit_20210622 Page 27 of 29 APPENDIX B: PHOTOGRAPH LOG Figure 1 - Silt Fence needed around Stockpile Area at the Public Works Facility Figure 2 - Mulch Stockpile Area at the Public Works Facility NCS000402_City of Mebane MS4 Audit_20210622 Page 28 of 29 Figure 3 - Additional Riprap Needed at SDO 003 located at the WWTP Figure 4 — Gutter Pipe Extension needed to Prevent Erosion at Building Corner at the WWTP NCS000402_City of Mebane MS4 Audit_20210622 Page 29 of 29 - 31 LO 6T� Al W R91 tli I