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Home My WebLink AboutNCS000396_Goldsboro AUDIT REPORT_20210730 MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) PROGRAM AUDIT REPORT NPDES PERMIT NO. NCS000396 GOLDSBORO, NORTH CAROLINA WAYN E COUNTY Audit Date:June 30, 2021 Report Date: July 30, 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) NCS000396 Goldsboro MS4 Audit 20210630 I 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......................................................................................................13 Pollution Prevention and Good Housekeeping for Municipal Operations.................................................19 Site Visit Evaluation: Municipal Facility No. 1.............................................................................................22 Site Visit Evaluation: MS4 Outfall No. 1......................................................................................................24 Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1............................................26 Appendix A:Supporting Documents 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. NCS000395 Goldsboro MS4 Audit 20210630 ii This page intentionally left blank NCS000396_Goldsboro MS4 Audit_20210630 iii Audit Details Audit ID Number: Audit Date(s): NCS000396 Goldsboro MS4 Audit_20230630 June 30,2021 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. Number visited: 1 ® MS4 Outfalls. Number visited: 1 ❑ Construction Sites. Number visited:Choose an item. ® Post-Construction Stormwater Runoff Controls. Number visited: 1 ❑ Other: Number visited:Choose an item. ❑ Other: Number visited:Choose an item. Inspectors Conducting Audit Name,Title Organization Alaina Morman, Environmental Specialist NC DEQ Michelle Evans, Permittee Outreach Coordinator NC DEQ Audit Report Author: / ,� Date Signature dfA.4.t j d_ !21( TwAA ILtn -7- JU' oc�_l NCS000396_Goldsboro MS4 Audit_20210630 Page 1 of 28 Permittee Information MS4 Permittee Name: Permit Effective Date: Permit Expiration Date: City of Goldsboro February 20, 2017 February 19,2022 Mailing Address: Date of Last MS4 Inspection/Audit: P.O. Drawer A,Goldsboro, NC 27530 N/A Co-permittee(s),if applicable: N/A Permit Owner of Record: Timothy Salmon, City Manager Primary MS4 Representatives Participating in Audit Name Title,Organization Marty Anderson, PE,CFM City Engineer,Goldsboro Matthew Lassiter, PE Civil Engineer,Goldsboro Jonathan Perry Project Manager,Goldsboro Richard(Rick)Fletcher Director of Public Works,Goldsboro MS4 Receiving Waters Waterbodv Classification Impairments Big Ditch C; NSW N/A Stoney Creek C;NSW Benthos(Nar,AL, FW) Howell Creek C;NSW N/A Reedy Branch C;NSW N/A Billy Branch C; NSW N/A Old Mill Branch (Mills Pond) C;Sw;NSW N/A Borden Field Ditch C;NSW N/A Little River B;C;NSW N/A (depending on section) Neuse River C; NSW N/A NCS000396_Goldsboro MS4 Audit_20210630 Page 2 of 28 List of Supporting Documents Item When Provided Document Title Number (Prior to/During/After) Stormwater Management Program for Nitrogen Control in the Neuse River 1 Prior to Basin(2/2003) 2 Payment History from BIMS Database Prior to 3 MS4 Program Responsibilities for Staff Positions Prior to 4 Outfall Discharge Points map Prior to 5 MS4 Stormwater Implementation Agreements Prior to 6 Dry Weather Flow Screening Program Prior to 7 Illicit Discharge Inspection Worksheet Prior to 8 Chap 54 Stormwater Management Utility Prior to 9 M54 0&M Addendum to the SWMP Prior to 30 Dry Extended Detention Basin 0&M Agreement Prior to 11 0&M for Municipal SCMs Prior to 12 Inspection Reports for SCM at Goldsboro Fire Department Prior to 13 Inspection Reports for SCMs at W.A. Foster Center Prior to 14 SWMP Assessment Letter from Consultant During 15 Annual Neuse NSW Program Report Cover Letter During 16 Annual IDDE Program Assessment Letter from Consultant During 17 SCM Inspection Report and Cover Letter During 18 Post-Construction Permit Issuance Documentation During 19 Excerpt from Stormwater Permitting Spreadsheet After 20 City of Goldsboro SCM List After NCS000396_Goldsboro MS4 Audit_20210630 Page 3 of 28 21 Educational Poster During 22 IDDE Letter sent to Businesses with Address List After 23 IDDE Staff Training Presentation After 24 IDDE Staff Training Roster After 25 Outfall Inventory Field Sheet—BD36 During 26 List of Goldsboro Facilities and Operations After 27 Streets and Stormwater Bi-Weekly Report After 28 Street Sweeper Routes Map After 29 Wallet Reference Card During 30 Facility Inspection Report—Biosolids Compost Facility During 31 Good Housekeeping Staff Training Presentation After 32 PP&GH Staff Training Roster After 33 Post-Construction Permit File for Circle K SW Wetland After NCS000396_Goldsboro MS4 Audit_20210630 Page 4 of 28 Program Implementation, Documentation & Assessment Staff Interviewed: Matthew Lassiter and Marty Anderson Permit Citation Program Requirement Status supporting Doc 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 08 Funding The Stormwater Plan identifies a specific position(s)responsible for the overall Yes 01 coordination,implementation,and revision to the Plan. Responsibilities for all components of the Stormwater Plan are documented and Partial 03 position(s)assignments provided. The permittee is current on payment of invoiced administering and compliance Yes 02 monitoring fees. Comments The city has a stormwater management utility which went into effect July 1,2017.The utility currently covers:equipment, personnel,materials for projects,and pays for the consulting engineer. Staff responsible for stormwater management are as follows: • Engineering Department handles post-construction/NSW plan reviews;inspects BMPs/SCMs;and consists of 2 construction inspectors, 1 GIs analyst,and 2 engineers • Planning Department handles WSW impervious area tracking spreadsheet • Public Works Department handles SCM and outfall maintenance;IDDE program implementation; PP&GH program implementation;and there are 23 staff between the Streets Crew and stormwater Crew Supporting document 01 was submitted as the city's MS4 stormwater Management Plan.The document says the implementation of the stormwater management program is the responsibility of the City Manager.Supporting document 03 generally lists responsibilities for other permit components,but needs to be more detailed. II.A.2 The permittee evaluated the performance and effectiveness of the program Stormwater Plan Yes 14 components at least annually. Implementation and Evaluation If yes,the permittee used the results of the evaluation to modify the program Yes 14 components as necessary to accomplish the Intent of the Stormwater Program. Did the permitted MS4 discharges cause or contribute to non-attainment of an ___ applicable water quality standard? No If yes,did the permittee expand or better tailor its BMPs accordingly to address Not the non-attainment? Applicable Comments The city meets annually with Bill Sabata(consulting engineer)to evaluate the program components. NCS000396 Goldsboro MS4 Audit_20210630 Page 5 of 28 Program Implementation, Documentation & Assessment II.A.3 Keeping the The permittee kept the Stormwater Plan up to date. No --- Stormwater Plan Up to Date The permittee notified DEMLR of any updates to the Stormwater Plan. Not Applicable Comments The city's SWMP was last amended in February of 2003.A 2010 version was drafted but never finalized. II.A.4 The permittee kept an up-to-date version of its Stormwater Plan available to the Availability of the Division and the public online. Partial — Stormwater Plan The online materials included ordinances, or other regulatory mechanisms,or a list identifying the ordinances,or other regulatory mechanisms, providing the legal Yes -- authority necessary to implement and enforce the requirements of the permit. Comments The city's SWMP can be found on the Engineering Department's website: https://www.goldsboronc.gov/engineering/. The zoning ordinance can be accessed on the Planning Department's website:https://www.goldsboronc.gov/planning/zoning- code/. The entire Unified Development Ordinance can be accessed here: https,.//codelibrary.am legal.com/codes/goldsboro/latest/overview. 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 Comments II.A.6 Sharing Are any control measures implemented by an entity other than the permittee? Yes — Responsibility If yes, is there a written agreement in place? Yes -- Comments The city contracts with the Clean Water Education Partnership for Public Education and Outreach services(spending approximately $2-3,000 per year).No contract or implementation agreement could be procured, but we received copies of some of the materials provided by the Partnership. (see supporting document 21) E&SC plan reviews are handled by the state Sediment Program.The city has record of all approvals on their own server and verifies E&SC plan approvals before issuing site plan approval(part of the site plan review process). NCS000396_Goldsboro MS4 Audit_20210630 Page 6 of 28 Program Implementation, Documentation &Assessment IIA.7 The permittee maintained written procedures for implementing the six minimum Written control measures. No --- Procedures Written procedures identified specific action steps,schedules,resources and ___ responsibilities for implementing the six minimum measures. No Comments The city was not aware of any written procedures or SOPS for implementing the six MCMs.The city did provide their"Dry Weather Flow Screening Program"which is a supplement to Section 3.3 of the SWMP and does contain more specific how-to guidance. Ill.A The permittee maintained documentation of all program components including, but Program not limited to, inspections, maintenance activities,educational programs, Partial --- Documentation implementation of BMPs,enforcement actions etc.,on file for a period of five years. Comments The city does a good job documenting some program components.Of the MCMs that were audited,the city has good overall post- construction documentation and staff training documentation. However,there are shortcomings in the documentation of other MCMs,like knowing the number of educational materials distributed and the number of people reached by educational programs, for example. Ill_B The permittee submitted annual reports to the Department within twelve months Annual Report from the effective date of the permit. Yes -- Submittal The permittee submitted subsequent annual reports every twelve months from the scheduled date of the first annual report submittal. Yes 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 of each major component of the Stormwater Plan for the past year and Yes 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 the proposed changes and how these changes will impact the Stormwater Yes 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 Yes --- 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 --- Stormwater Plan. S. An assessment of compliance with the permit,information on the establishment of appropriate legal authorities,inspections, and enforcement 7Ye -- actions. NCS000396 Goldsboro MS4 Audit_20210630 Page 7 of 28 Program Implementation, Documentation & Assessment Comments The city submitted SWMPAs through BIMS for all of the years in the current permit term.SWMPAs can be accessed through the public Laserfiche portal.The DEQ Nonpoint Source Planning Branch confirmed that the city has also been submitting the annual reports required as part of the Neuse NSW program. IV.B Annual Reporting The Annual Reports document the following: 1. A summary of past year activities,including where applicable,specific Yes — quantities achieved and summaries of enforcement actions. 2. A description of the effectiveness of each program component. Yes — 3. Planned activities and changes for the next reporting period,for each Yes program component or activity. - 4. Fiscal analysis. Yes -- Comments Submission of the online BIMS SWMPA satisfies the annual reporting requirements, per Part IV.B.3. Additional Comments: NCS000396_Goldsboro MS4 Audit_20210630 Page 8 of 28 Illicit Discharge Detection and Elimination (IDDE) Staff Interviewed: Matthew Lassiter, Marty Anderson,and Rick Fletcher Permit Citation Program Requirement Status Supporting Doc No. II.D.2.a IDDE Program The permittee maintained a written IDDE Program. Partial 01 If yes,the written program includes provisions for program assessment and No --- evaluation and integrating program. Comments Section 3 of the city's SWMP discusses the IDDE Program. However,this document has not been updated since 2003 and does not reflect current procedures or program expectations. II.D.2.b The permittee maintained an IDDE ordinance or other regulatory mechanism(s)that Legal Authorities provides the legal authority to prohibit illicit connections and discharges to the MS4. Yes --- If yes,the ordinance applies throughout the corporate limits of the permittee. Yes — Comments The IDDE ordinance is Section 6.6 in the city's unified development ordinance(LIDO).The link to the ordinance is here: https://www.goldsboronc.gov/wp-content/uploads/UDO-Section-6-2019.pdf.The ordinance section can also be accessed from the city's Planning Department website under"Zoning Code"—https://www.goldsboronc.gov/planning/zoning-code/. II.D.2.c The permittee maintained a current map showing major outfalls'and receiving Storm Sewer Yes 04 System Map streams. Comments It should be documented in the SWMP which department is responsible for maintaining the different types of GIS data.It was unclear if the Public Works Department is responsible for entering IDDE information into the GIs database,or if Engineering handles everything. II.D.2.d The permittee maintained a program for conducting dry weather flow field Dry Weather Flow observations in accordance with written procedures. Partial 06, 16 Program Comments The Dry Weather Flow Screening Program was last updated in January 2013.The Engineering Department was responsible for this program until the Public Works Department took over in 2018. The expectation listed in the program is that the city will conduct dry weather screening on 4 outfalls a quarter,3 of which should be located in priority areas of Big Ditch or Stoney Creek West. However,according to the IDDE program assessment done by a private consultant,31 dry weather inspections were conducted in fiscal year 2019-2020. NCS000396_Goldsboro MS4 Audit_20210630 Page 9 of 28 Illicit Discharge Detection and Elimination (IDDE) II.D.2.e Investigation The permittee maintained written procedures for conducting investigations of g identified illicit discharges. Partial Ol,O6 Procedures Comments With regard to investigations,the IDDE section of the LIDO only says who is authorized to conduction inspections,but does not say how to conduct those inspections.The Dry Weather Flow Screening Program says the inspector will"attempt to track the suspected illicit discharge to its source"and directs the reader to Section 3.3 in the SWMP.Section 3.3 of the SWMP states that the General Services Department is responsible for"planning a systematic field investigation to minimize the amount of resources required to identify the source"and then proceeds to list several field methods that may be used,including site investigation and dye testing, as an example. None of the documents addressing IDDE contain clear,detailed procedures for how to conduct an investigation. 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 date(s)the illicit discharge was observed No 2. The results of the investigation No -- 3. Any follow-up of the investigation No -- 4. The date the investigation was closed No -- Comments The city stated that up until outfall screening was transferred to Public Works in 2018, no illicit discharges were reported or observed.However,there is no formal tracking system to show that no illicit discharges were observed. Public Works staff was not able to provide any formal documentation either, but there was apparently one illicit discharge in fiscal year 2019-2020 according to the IDDE program assessment done by a private consultant.The city did provide an illicit discharge inspection worksheet (supporting document 07)that it should be using to document reported or observed discharges. II.D.2.g The permittee implemented and documented a training P p g program for appropriate Employee Training municipal staff who,as part of their normal job responsibilities, may come into Partial 23,24 contact with or otherwise observe an illicit discharge or illicit connection. Comments Certain staff from different departments are required to attend annual IDDE training.The notable exception is Parks and Rec staff. DELL recommends that Parks and Rec staff be included in the IDDE training since they may come into contact with or observe an illicit discharge through theirjob duties. The SWMP does not specify what topics will be addressed in the training or how frequently the training will be conducted;it only states that,"The General Services Department will be responsible for coordinating personnel training...:'The SWMP also does not state which departments'staff are required to attend the training. II.D.2.h The permittee informed public employees of hazards associated with illegal Public Education discharges and improper disposal of waste. Yes 23 The permittee informed businesses of hazards associated with illegal discharges and Yes 22 improper disposal of waste. NCS000396—Goldsboro MS4 Audit_20210630 Page 10 of 28 Illicit Discharge Detection and Elimination (IDDE) The permittee informed the general public of hazards associated with illegal Yes 21 discharges and improper disposal of waste. Comments City staff are informed through the annual training. At least once during the permit term,commercial establishments are sent a letter informing them of the illicit discharge ordinance. The Clean Water Education Partnership provides flyers/posters for public distribution. II.D.2.i The permittee promoted,publicized,and facilitated a reporting mechanism for the Public Reporting public to report illicit discharges. Partial Mechanism The permittee promoted,publicized,and facilitated a reporting mechanism for staff Partial to report illicit discharges. The permittee established and implemented response procedures for citizen requests/reports. Yes --- Comments None of the city web pages(Engineering, Planning, Public Works)explains what an illicit discharge is. DEQ recommends adding an online illicit discharge education component,which could include posting a digital version of the educational materials received from CWEP. On the city website's main landing page,there's a link to"Citizen Request/311"where anyone can report non-emergency issues. The person filling out the form has four options to choose from in determining the type of request,and illicit discharge reports could fall under"General Request," 'Public Works/Maintenance Request,"or"Water Questions." None of the options available explicitly targets spills or illicit discharges,though.There is also the ChatBot feature on every page where people can ask questions or report issues. Public Works has its own hotline that is available 24/7.After-hours calls are answered by a private answering service,whereupon the call is directed to whoever is on-call for the applicable Public Works division.Answering service staff sometimes make judgement calls on the severity of issues called in.Answering service staff do not receive IDDE training. DEQ recommends that answering service staff be included in IDDE training or have a training customized for them. City staff are just expected to send issues up the chain and eventually the concern will get to the stormwater division supervisor. The city has response procedures in place, but none of them are documented. II.D.2.I The permittee implemented a mechanism to track the issuance of notices of violation Enforcement and enforcement actions administered by the permittee. No _ If yes,the mechanism includes the ability to identify chronic violators for initiation of actions to reduce noncompliance. No Comments The city does not have a mechanism in place to track the issuance of NOVs and enforcement actions.Staff said that there have not been any IDDE problems,especially none that warranted enforcement action. NCS000396_Goidsboro MS4 Audit_20210630 Page 11 of 28 Illicit Discharge Detection and Elimination (IDDE) Additional Comments: NCS000396_Goldsboro MS4 Audit_20210630 Page 12 of 28 Post-Construction Site Runoff Controls Staff Interviewed: Matthew Lassiter and Marty Anderson 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: ® 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 ❑ Water Supply Watershed II (WS-11)-15A NCAC 2B.0214 ❑ Water Supply Watershed III(WS-III)—15A NCAC 213.0215 ® Water Supply Watershed IV(WS-IV)—15A NCAC 213.0226 ❑ 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): ❑DEQ model ordinance ❑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) 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 01 The permittee implements deemed-compliant Program requirements throughout the entire MS4 area. Yes 01 NCS000396_Goldsboro MS4 Audit_20230630 Page 13 of 28 Post-Construction Site Runoff Controls The permittee applies deemed-compliant Program requirements to all federal, state and local government projects within the permitted MS4 area who do not Yes 01 have their own NPDES stormwater permit. The permittee included deemed-compliant Program reporting in their MS4 Annual Reports. Yes The permittee included deemed-compliant Program implementation in their Stormwater Management Plan. Yes 02 Comments The city was designated to implement the Neuse Nutrient Strategy in 1998. Section 6.5 of the LIDO covers stormwater management for new development:https://www.goldsboronc.gov/wp-content/uploads/UDO-Section-6-2019.pdf. 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 --- Management Program. If yes,the ordinance applies throughout the corporate limits of the permittee. Yes --- The permittee has the authority to review designs and proposals for new development and redevelopment to determine whether adequate stormwater Yes --- 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 --- 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 --- related to stormwater discharges. Comments LIDO Section 6.5 covers post-construction requirements. The LIDO applies throughout the city's corporate limits and in the ETJ per LIDO Section 1.3.The SWMP(supporting document 01)and LIDO cite Section 96 of the code of ordinances as the legal authority to enter private property for the purposes of SCM inspections. However,after asking Planning Department staff,that citation is no longer accurate as of 2005.They instead pointed to Chapter 54,Section 54.03(B)(2)for inspection authority. DEQ recommends updating the LIDO and SWMP to list the correct authority. II.F.2.b Stormwater Control The permittee utilizes strategies which include SCMs appropriate for the MS4. Yes 01 Measures(SCMs) SCMs comply with 15A NCAC 02H .1000. Yes 01 Comments UDO Section 6.5.11 also outlines allowable SCMs. NCS000396_Goldsboro MS4 Audit_20210630 Page 14 of 28 Post-Construction Site Runoff Controls 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 Yes 01, 19, that disturb less than one acre that are part of a larger common plan of 33 development or sale). If yes,the site plan reviews addressed how the project applicant meets the Yes 01 performance standards. If yes,the site plan reviews addressed how the project will ensure long-term Yes 10, 33 maintenance. Comments A stormwater permit application must be accompanied by deed restrictions, protective covenants,and maintenance agreements. The city also requires bonds if an SCM cannot be completed at the time of construction due to weather or other circumstances. 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 20 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 --- requirements. Comments 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 18 and Protective consistent with approved plans. Covenants Comments Section 5.5.15(b)of the LIDO discusses the requirement that all SCMs have deed restrictions and protective covenants. II.F.2.f The permittee implemented or required an operation and maintenance plan for Mechanism to Yes Ol Require tong-term the long-term operation of the SCMs required by the program. Operation and Maintenance The operation and maintenance plan required the owner of each SCM to perform and maintain a record of annual inspections of each SCM. Yes 10,33 Annual inspections of permitted structural SCMs are required to be performed by a No qualified professional. NCS000396_Goldsboro MS4 Audit_20210630 Page 15 of 28 Post-Construction Site Runoff Controls Comments The 0&M documents used by the city have different inspection frequencies,ranging from monthly to quarterly. However, none of the 0&M agreements state that a qualified professional must conduct the inspections.There also does not appear to be any language in the UDO requiring inspections to be conducted by a qualified professional.The staff with the city that conduct inspections are required to obtain the SCM Inspection and Maintenance Certification through NC State University, but that requirement is not in the UDO or SWMP. The city does not track if inspections are conducted by the permittee.The city conducts its own annual SCM inspections. II.F.2.a The permittee conducted and documented inspections of each project site covered Inspections under performance standards,at least one time during the permit term. Yes 01,17 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 01 completion. The permittee documented and maintained records of inspections. Yes 17 The permittee documented and maintained records of enforcement actions. Yes 17 Comments Once the inspection has been conducted,the city mails the inspection report and inspection fee invoice with a formal cover letter. At the time of the audit,the inspection fee was$100.The city lists any deficiencies or needed corrections in the cover letter and provides a follow-up inspection date.The city has not issued any monetary fines or penalties,or undertaken any other serious enforcement action, up to this point. II.F.2.h Educational The permittee made available through paper or electronic means,ordinances, Materials and post-construction requirements,design standards checklists,and other materials Yes — Training for appropriate for developers. Developers Comments Some materials are available on the Engineering and Planning Departments websites.The city directs developers to DEQ's maintenance requirements, but there is no link to the state's Stormwater Design Manual. All new development comes through the Planning Department and the other departments then do their respective reviews of the plans.The city uses the Energov system to track department approvals on projects. II.F.2.1 The permittee tracked the issuance of notices of violation and enforcement Enforcement actions. No If yes,the tracking mechanism included the ability to identify chronic violators Not _ for initiation of actions to reduce noncompliance. Applicable NC5000396_Goldsboro M54 Audit_20210630 Page 16 of 28 Post-Construction Site Runoff Controls Comments There is no formal tracking system for violations or deficiencies. II.F3.b The permittee fully complies with post construction program requirements on its New Development own publicly funded construction projects. Yes Comments UDO Section 1.6 states that the UDO affects every building and use. II.F.3.c Does the MS4 have areas draining to Nutrient Sensitive Waters(NSW)pursuant to Nutrient Sensitive 15A NCAC 02H .0150? Yes 01 Waters If yes,does the permittee use SCMs that reduce nutrient loading in order to Yes 01 meet local program requirements. If yes,does the permittee also still incorporate the stormwater controls Yes 01 required for the project's density level. If yes,does the permittee also require documentation where it is not feasible to Not use SCMs that reduce nutrient loading. Applicable Comments The city has not encountered a situation where an SCM was unable to be installed.They will need to develop documentation(a form or something)for this purpose in case a situation arises in the future. II.F3.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 UDO Section 6.5.15(d)(a) requires design volumes to account for the runoff from all surfaces draining into the system. Neuse NSW Program Requirement Status supporting Requirements Doc No. The local program approved a stormwater plan for all proposed development projects not excluded under Item(4)of this Rule. Note:To the extent permitted by federal and state law,a local program does not Yes of review a development project proposed by a State or federal entity for the 15A NCAC 02B requirements of this Rule. .0711(3)(a)—(f) The permittee has a plan to ensure maintenance of SCMs is implemented to Yes 01 comply with this Rule for the life of the development. The permittee has a plan to ensure enforcement and compliance with the Yes --- provisions in Item(5)of this Rule for the life of the development. NCS000396_Goldsboro MS4 Audit_20210630 Page 17 of 28 Post-Construction Site Runoff Controls The permittee has a public education program to inform citizens how to reduce nutrient pollution and to inform developers about the nutrient requirements set Yes 01 forth in Item(5)of this Rule. The permittee has a mapping program that includes major components of the municipal separate storm sewer system,waters of the State,land use types,and Partial --- location of sanitary sewers. The permittee has a program to identify and remove illegal discharges. Yes 01,06 Comments The city was designated to implement the Neuse Nutrient Strategy in 1998. Section 6.5 of the UDO covers stormwater management for new development: https://www.goldsboronc.gov/wp-content/uploads/UDO-Section-6-2019.pdf. The city has mapped outfalls, but not the entire storm sewer system. Extensive storm sewer system mapping was started this year. Additional Comments: NCS000396_Goldsboro MS4 Audit_20210630 Page 18 of 28 Pollution Prevention and Good Housekeeping for Municipal Operations Staff Interviewed: Matthew Lassiter, Marty Anderson,and Rick Fletcher Permit Citation Program Requirement Status supporting Doc No. I I.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 26 stormwater runoff. Comments II.G.2.b The permittee maintained and implemented an 0&M program for municipally Operation and owned and operated facilities with the potential for generating polluted No --- Maintenance (O&M) stormwater runoff. for Facilities If yes,the O&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 There is no written program. Matthew Lassiter has started doing inspections and requesting copies of inspections from separately permitted properties. 11.6.2.c Spill Response The permittee had written spill response procedures for municipal operations. Partial Procedures Comments Some facilities have their own SPCC plans,but there are not documented spill response procedures for municipal operations generally. II.G.2.d The permittee evaluated existing and new BMPs that reduce polluted stormwater Streets, Roads,and runoff from municipally-owned streets, roads,and public parking lots within its Yes 27 Public Parking Lots corporate limits annually. Maintenance If yes,the permittee evaluated the effectiveness of existing and new BMPs Yes 27 based on cost and the estimated quantity of pollutants removed. Comments NCS000396_Goldsboro MS4 Audit_20210630 Page 19 of 28 Pollution Prevention and Good Housekeeping for Municipal Operations II.G.2.f 0&M for Catch The permittee maintained and implemented an O&M program for the stormwater 09,27, Basins and sewer system including catch basins and conveyance systems that it owns and Partial 28 Conveyance Systems maintains. Comments There is an 0&M supplement to the SWMP,but it does not address how the city will meet the goals and objectives listed within.At this point,most maintenance is reactive.The city does have certain routes/sections mapped out that it uses for street sweeping, curb and gutter maintenance,and weed prevention. II.G.2.d The permittee maintained a current inventory of municipally-owned or operated Structural structural stormwater controls installed for compliance with the permittee's post- Yes 20 Stormwater controls construction ordinance. Comments Yes,the city owns two SCMs:a dry pond at the Harris Street Fire Station and a dry pond and swale at the Recreation Center. II.G.2.e 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 Partial --- stormwater Controls the permittee's post-construction ordinance. If yes,then: The 0&M program specified the frequency of inspections and routine No --- maintenance requirements. The permittee documented inspections of all municipally-owned or maintained Yes 12, 13 structural stormwater controls. The permittee inspected all municipally-owned or maintained structural stormwater controls in accordance with the schedule developed y ed b permittee. No The permittee maintained all municipally-owned or maintained structural stormwater controls in accordance with the schedule developed by permittee. No The permittee documented maintenance of all municipally-owned or No --- maintained structural stormwater controls. Comments There is no written C&M program,so there is no documented schedule of when inspections and maintenance need to be performed. However,inspections are being conducted.Jonathan Perry inspects the two city-owned SCMs along with the privately- owned SCMs.The inspection reports have a spot where maintenance needs can be marked as completed, but that section is not completed on any of the reports.A recommendation going forward:document when maintenance actions have been completed. II.G.2.f The permittee ensured municipal employees are properly trained in pesticide, Pesticide, Herbicide herbicide and fertilizer application management. Yes and Fertilizer Application The permittee ensured contractors are properly trained in pesticide, herbicide and Not Management fertilizer application management. Applicable The permittee ensured all permits,certifications,and other measures for Yes applicators are followed. NCS000396 Goldsboro MS4 Audit_20210630 Page 20 of 28 Pollution Prevention and Good Housekeeping for Municipal Operations Comments There is a subset of Public Works staff(4 or 5 people)that are licensed through NCDA. Everyone else sprays under that handful of licenses. Most of the chemicals used are pre-mixed,otherwise a licensed staff member supervises mixing until they feel confident the unlicensed staff person is properly trained. No contractors are used. II'G'2'g The permittee implemented an employee training program for employees involved Staff Training in implementing pollution prevention and good housekeeping practices. TPartial 31,32 Comments Not all city staff,or even Public Works staff,are required to attend the training. For example, Parks and Rec staff are not currently required to attend any stormwater training.All staff working in,or operating out of,a municipal facility that has the potential for generating polluted stormwater runoff should receive general stormwater awareness training and PP&GH training specific to their operation/facility. II.G.2.h The permittee described and implemented measures that prevent or minimize Vehicle and contamination of stormwater runoff from all areas used for vehicle and equipment Partial 31 Equipment Cleaning cleaning. Comments Vehicle and equipment cleaning protocols are not documented outside of the PP&GH presentation that's given annually. At the Public Works facility,large/heavy equipment is cleaned in a wash bay that is connected to sanitary sewer. Additional Comments: NCS000396_Goldsboro MS4 Audit_20210630 Page 21 of 28 Site Visit Evaluation: Municipal Facility No. 1 Facility Name: Date and Time of Site Visit: Public Works Facility June 30,2021 at—4:00 PM Facility Address: Facility Type(Vehicle Maintenance,Landscaping,etc.): 1601 Clingman Street vehicle maintenance, equipment and material storage Name of MS4 inspector(s)evaluated: Most Recent MS4 Inspection(List date and name of inspector): Matthew Lassiter May 2021 Name(s)and Titles)of Facility Representative(s)Present During the Site Visit: Name Title Marty Anderson City Engineer Observations Facility Documentation/Training Does the facility have a Stormwater Pollution Prevention Plan(SWPPP)or similar document?Is it facility-specific? Yes,the facility has a SWPPP.This facility is covered under general industrial stormwater permit NCGO8 via certificate of coverage NCG080665. What type of stormwater training do facility employees receive?How often? Certain city staff receive annual IDDE and PP&GH training.See supporting documents 24 and 32. Not all staff that use or work at the facility receive training. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive?How often? The inspector is a professional civil engineer who has been with the city for approximately 7 months. He has attended the IDDE and PP&GH annual training presented by an outside consultant. Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? Partially.The city does not have a documented O&M program,so the inspector operated off general knowledge and the annual training. Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping? The inspector is new to doing facility inspections,but knew most areas of concern to be aware of. Inspection Procedures Does the MS4 inspector's process include the use of a checklist or other standardized form? Yes,there is a standardized form(see supporting document 30), however the inspector didn't bring it along to do the inspection. Does the MS4 inspector's process include taking photos? Photos are taken if there are problems that need to be documented. Does the MS4 inspector's process include reviewing the facility's SWPPP(or similar document)? The inspector looked through the SWPPP.Since he is new, he is still familiarizing himself with the NCG08 requirements. NCS000396_Goldsboro MS4 Audit_20210630 Page 22 of 28 Site Visit Evaluation: Municipal Facility No. 1 Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge? The inspector now knows to walk the entire perimeter of the facility,along with internal areas,and inspect all points of discharge. Did the MS4 inspector miss any obvious areas of concern?If so,explain: There were around ten 55-gallon drums that needed capped and labeled or removed from the facility.Additionally,one of the spill kits inspected was full of water and didn't appear to have been opened in a while. Does the MS4 inspector's process include presenting the inspection findings to the facility contact? No findings were presented to the facility contact while we were on site. Inspection Results Did the facility inspection result in any corrective actions to be implemented?If so,for what issue(s)? No,aside from needing to resolve the 55-gallon drum issue. If compliance corrective actions were identified,what timeline for correction/follow-up was provided? N/A Notes/Comments/Recommendations NCS000396_Goldsboro MS4 Audit_20210630 Page 23 of 28 Site Visit Evaluation: MS4 Outfall No. 1 Outfall ID Number: Date and Time of Site Visit: BD36 June 30, 2021 around 3:30 PM Outfall Location: Outfall Description(Pipe Material/Diameter,Culvert,etc.): near the intersection of Beech Street and Kornegay Street 24" RCP Receiving Water: Is Flow Present?If So,Describe(Color,Approximate Flow Rate, Big Ditch Sheen,Odor, Floatables/Debris,etc.): Most Recent Outfall Inspection/Screening(Date): Yes, light flow but no illicit discharge indicators. February 22,2018 Days Since Last Rainfall: Inches: 3 days(June 271h) 0.30 Name of MS4lnspector(s)evaluated: Chad Edge,deputy director for Public Works,has been inventorying/inspecting the outfalls. Mr. Edge was unavailable for the site visit. Matthew Lassiter and Marty Anderson were present,so the site visit was used as an educational opportunity. Observations Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive?How often? Mr.Edge is not listed as having attended the IDDE training presented by an outside consultant,so it is unclear what stormwater training he has received. Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations? As stated above,the site visit was used as an educational opportunity since Mr. Edge was unable to attend. Inspection Procedures Does the inspector's process include the use of a checklist or other standardized form? Yes,but one was not brought to the site. Does the inspector's process include taking photos? No.A camera is not listed as basic equipment needed for dry weather flow screening and taking photos is not written as part of the screening process,according to supporting document 06. Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues?If so,what were they? There were no illicit discharge indicators or maintenance issues at the outfall. NCS000396_Goldsboro MS4 Audit_20210630 Page 24 of 28 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)? No. Will a follow-up outfall inspection be conducted?If so,for what reason? N/A Notes/Comments/Recommendations NCS000396_Goldsboro MS4 Audit_20210630 Page 25 of 28 Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1 Site Name: Date and Time of Site Visit: Circle K Store#2706788 June 30, 2021 around 3:00 PM Site Address: SCM Type: 2707 North William Street stormwater wetland Most Recent MS4 Inspection(Include Date and Entity): too new for an annual inspection Name of MS4 Inspector(s)evaluated: Most Recent MS4 Enforcement Activity(Include Date): Jonathan Perry N/A Name(s)and Title(s)of Site Representative(s)Present During the Site Visit: Name Title No one associated with the site was present. Observations Site Documentation Does the site have an operation and maintenance plan? Yes.See supporting document 33. Does the site have records of annual inspections?Are they performed by a qualified individual? No annual inspections have been conducted because the site just got its CO in December. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive?How often? Jonathan Perry does the SCM inspections, but did not attend this one. However,he does have the SCM Inspection and Maintenance Certification through NC State University.His certification number is 3045. Did the MS4 inspector appear knowledgeable about MS4 requirements for post-construction site runoff controls? We were not able to observe Mr. Perry's post-construction knowledge. Did the MS4 inspector appear knowledgeable about post-construction BMPs(general purpose/function,components,0&M requirements,etc.)? We were not able to observe Mr. Perry's post-construction knowledge. Inspection Procedures Does the MS4 inspector's process include the use of a checklist or other standardized form?What format? Yes,the city uses standardized inspection forms.See supporting document 17. Does the MS4 inspector's process include taking photos? No. Photos not documented in inspections for other SCMs, either. NCS000396_Goldsboro MS4 Audit_20210630 Page 26 of 28 Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1 Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections? Not able to say. Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge? Not able to say. Did the MS4 inspector miss any obvious operation and maintenance deficiencies?If so,explain: There were no obvious operation and maintenance deficiencies. Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing? Yes,inspection reports are sent with cover letters to the property owner.See supporting document 17. Compliance/Enforcement What,if any,enforcement actions(verbal warnings, NOV,etc.)did the inspection result in? N/A If compliance issues were identified,what timeline for correction/follow-up was provided? N/A Notes/Comments/Recommendations Notes: We reviewed the as-built plans in the office and took a physical, paper copy out to the site with us for reference. It is unclear what documentation Jonathan references when doing inspections. Matthew Lassiter and Marty Anderson were present but did not bring the form to do the inspection. It was noted that the city does not conduct final SCM inspections prior to issuing the stormwater permit and signing off on the CO. NCS000396_Goldsboro MS4 Audit_20210630 Page 27 of 28 APPENDIX A: SUPPORTING DOCUMENTS All supporting documentation cited in this report can be accessed from the Division of Energy, Mineral, and Land Resources' online Laserfiche repository at the following link: https:Hedocs.deq.nc.gov/W aterResources/Browse.aspx?d bid=0&sta rtid=1882780 NCS000396_Goldsboro MS4 Audit 20210630 Page 28 of 28