HomeMy WebLinkAboutNCS000438_Spring Lake Self Audit_20220214
MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM SELF AUDIT REPORT
NPDES PERMIT NO. NCS000438
Spring Lake, NORTH CAROLINA
300 Ruth Street
Self Audit Date: 20220201
North Carolina Department of Environmental Quality
Division of Energy, Mineral & Land Resources Stormwater Program
512 N. Salisbury Street, 9th floor
1612 Mail Service Center
Raleigh, NC 27699-1612
MS4 Permit Self Audit Report
Spring Lake, NC: NPDES Permit No. NCS000438
Audit Date: 20220208 i
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MS4 Permit Self Audit Report
Spring Lake, NC: NPDES Permit No. NCS000438
Audit Date: 20220208 ii
TABLE OF CONTENTS
Audit Details .................................................................................................................................................. 1
Permittee Information .................................................................................................................................. 2
Supporting Documents ................................................................................................................................. 3
Program Implementation, Documentation & Assessment ........................................................................... 4
Public Education and Outreach ..................................................................................................................... 8
Public Involvement and Participation ......................................................................................................... 11
Construction Site Runoff Controls .............................................................................................................. 13
Total Maximum Daily Loads (TMDLs) ......................................................................................................... 16
Appendix………………………………………………………………………………………………………………………………….18
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.
MS4 Permit Self Audit Report
Spring Lake, NC: NPDES Permit No. NCS000438
Audit Date: 20220208 iii
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MS4 Permit Self Audit Report
Spring Lake, NC: NPDES Permit No. NCS000438
Audit Date(s): 20220208
Page 1 of 18
Audit Details
Audit ID Number:
NCS000438_SpringLake MS4 Self Audit_20220201
Audit Date(s):
02/01/2022
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: Choose an item.
☐ Construction Sites. Number visited: Choose an item.
☐ Post-Construction Stormwater Runoff Controls. Number visited: Choose an item.
☐ Other: ________________________________. Number visited: Choose an item.
☐ Other: ________________________________. Number visited: Choose an item.
Inspector(s) Conducting Audit
Name, Title Organization
Deanna Rosario- Stormwater Administrator Town of Spring Lake
Audit Report Author:
Signature__________________________________________
Date:
20220208
Audit Report Author:
Signature__________________________________________
Date
MS4 Permit Self Audit Report
Spring Lake, NC: NPDES Permit No. NCS000438
Audit Date(s): 20220208
Page 2 of 18
Permittee Information
MS4 Permittee Name:
Town of Spring Lake
Permit Effective Date:
02/19/2017
Permit Expiration Date:
02/20/2022
City, State, ZIP: Spring Lake NC 28390
Date of Last MS4 Inspection/Audit:
July 15, 2021
Co-permittee(s), if applicable:
Permit Owner of Record:
Primary MS4 Representatives Participating in Audit
Name, Title Organization
Deanna Rosario- Stormwater Administrator Town of Spring Lake
MS4 Receiving Waters
Waterbody Classification Impairments
Jumping Run Creek C None
Muddy Creek C none
Tank Creek/McDuffie Creek C none
Lower Little River C none
Young Lake and
unnamed creek C none
MS4 Permit Self Audit Report
Spring Lake, NC: NPDES Permit No. NCS000438
Audit Date(s): 20220208
Page 3 of 18
Supporting Documents
Item
Number Document Title When Provided
(Prior to/During/After)
1 NOTICE OF VIOLATION (NOV-2021-PC-0530) Town of Spring Lake
NPDES MS4 Permit No. NCS000438 Cumberland County during
MS4 Permit Self Audit Report
Spring Lake, NC: NPDES Permit No. NCS000438
Audit Date(s): 20220208
Page 4 of 18
Program Implementation, Documentation & Assessment
Staff Interviewed:
(Name, Title, Role)
Deanna Rosario, Stormwater Administrator- manages all aspects of the MS4 program- performed self audit
as requested in NOV-2021-PC-0530
Permit Citation Program Requirement Status Supporting
Doc No.
II.A.1
Staffing and
Funding
The permittee maintained adequate funding and staffing to implement and manage
the provisions of the Stormwater Plan and meet all requirements of the permit. Yes ---
The Stormwater Plan identifies a specific position(s) responsible for the overall
coordination, implementation, and revision to the Plan. Yes ---
Responsibilities for all components of the Stormwater Plan are documented and
position(s) assignments provided. Yes ---
The permittee is current on payment of invoiced administering and compliance
monitoring fees (see stormwater e-payments on DEMLR MS4 web page). Yes ---
Comments (Briefly describe funding mechanism, number of staff, etc.)
Funded by stormwater fee in yearly property tax bill of 33.00 per ERU.
Stormwater program is staffed by one full time administrator supplemented by other water department personnel as needed.
II.A.2 Stormwater
Plan
Implementation
and Evaluation
The permittee evaluated the performance and effectiveness of the program
components at least annually. Yes ---
If yes, the permittee used the results of the evaluation to modify the program
components as necessary to accomplish the intent of the Stormwater Program. Yes ---
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
the non-attainment?
Not
Applicable ---
Comments
MS4 Permit Self Audit Report
Spring Lake, NC: NPDES Permit No. NCS000438
Audit Date(s): 20220208
Page 5 of 18
Program Implementation, Documentation & Assessment
II.A.3
Keeping the
Stormwater Plan
Up to Date
The permittee kept the Stormwater Plan up to date. Yes ---
The permittee notified DEMLR of any updates to the Stormwater Plan. Yes ---
Comments (Indicate the date of latest Stormwater Plan and describe the nature of any updates, if applicable).
II.A.4 Availability
of the Stormwater
Plan
The permittee kept an up-to-date version of its Stormwater Plan available to the
Division and the public online. Partial ---
The online materials included ordinances, or other regulatory mechanisms, or a list
identifying the ordinances, or other regulatory mechanisms, providing the legal
authority necessary to implement and enforce the requirements of the permit.
Partial ---
Comments (Note what materials are available on line)
The town website is being updated to a new provider, all pertinent information will be transferred over by the end of March 2022
II.A.3 & II.A.5
Stormwater Plan
Modifications
Did DEMLR require a modification to the Stormwater Plan? No ---
If yes, did the permittee complete the modifications in accordance with the
established deadline?
Choose
an item. ---
Comments (Note date of DEMLR notification, modifications required, and date modifications were completed, as applicable)
II.A.6 Sharing
Responsibility Are any control measures implemented by an entity other than the permittee? Yes ---
If yes, is there a written agreement in place? Choose
an item. ---
Comments (List the specific control measures implemented by others that do not have adequate written agreements, if
applicable )The State administers the Construction site erosion control portion of the MS4 permit
II.A.7
Written
Procedures
The permittee maintained written procedures for implementing the six minimum
control measures. Partial ---
Written procedures identified specific action steps, schedules, resources and
responsibilities for implementing the six minimum measures. Partial ---
Comments (List the specific minimum measures that do not have adequate written procedures, if applicable)
IDDE and Good Housekeeping programs are currently being updated to be more facility specific and more comprehensive
MS4 Permit Self Audit Report
Spring Lake, NC: NPDES Permit No. NCS000438
Audit Date(s): 20220208
Page 6 of 18
Program Implementation, Documentation & Assessment
III. A
Program
Documentation
The permittee maintained documentation of all program components including, but
not limited to, inspections, maintenance activities, educational programs,
implementation of BMPs, enforcement actions etc., on file for a period of five years.
Partial ---
Comments (List the specific program components that do not have adequate documentation on file and why, if applicable)
All files prior to October 2018 were lost when Florence flooded the facility that the Stormwater Management office was located in.
We were able to partially reconstruct past files with copies saved at DEQ and from one of the SCM inspecting companies.
III.B
Annual Report
Submittal
The permittee submitted annual reports to the Department within twelve months
from the effective date of the permit (See Section III.B. for the annual reporting
period specific to this MS4).
Yes ---
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
schedules and plans for the year following each report.
Yes ---
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
Plan (results, effectiveness, implementation schedule, etc.).
Yes ---
3. Documentation of any necessary changes to programs or practices for
assessment of management measures implemented through the Stormwater
Plan.
Yes ---
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
Stormwater Plan.
Yes ---
5. An assessment of compliance with the permit, information on the
establishment of appropriate legal authorities, inspections, and enforcement
actions.
Yes ---
Comments (Note dates that annual reports cover under current permit and generally describe report deficiencies, if any)
IV.B
Annual Reporting The Annual Reports document the following:
1. A summary of past year activities, including where applicable, specific
quantities achieved and summaries of enforcement actions. Yes ---
2. A description of the effectiveness of each program component. Yes ---
3. Planned activities and changes for the next reporting period, for each
program component or activity. Yes ---
MS4 Permit Self Audit Report
Spring Lake, NC: NPDES Permit No. NCS000438
Audit Date(s): 20220208
Page 7 of 18
Program Implementation, Documentation & Assessment
4. Fiscal analysis. Yes ---
Comments (Note dates that annual reports cover under current permit and generally describe report deficiencies, if any)
MS4 Permit Self Audit Report
Spring Lake, NC: NPDES Permit No. NCS000438
Audit Date(s): 20220208
Page 8 of 18
Public Education and Outreach
Staff Interviewed:
(Name, Title, Role)
Deanna Rosario, Stormwater Administrator- manages all aspects of the MS4 program
Permit Citation Program Requirement Status Supporting
Doc No.
II.B.2.a
Goals and
Objectives
The permittee defined goals and objectives of the Local Public Education and
Outreach Program based on community wide issues. Partial ---
Comments (Generally describe process for establishing goals/objectives)
Basic description of the program is on file, currently reviewing and expanding the program after a two year break due to COVID
in cooperation with CWEP and Cumberland County Green Schools.
Annual events include Creek Week, Cumberland County Schools Earth Day outreach, and booths at town events as they are
being scheduled.
II.B.2.b
Target Pollutants
The permittee maintained a description of the target pollutants and/or stressors and
likely sources. Yes ---
Comments (List target pollutants, note any that are missing or not appropriate)
CWEP has been keeping their target pollutant outreach materials updated and we have been using social media to repost them
and to create handouts for town events.
II.B.2.c
Target Audiences
The permittee identified, assessed annually and updated the description of the target
audiences likely to have significant storm water impacts and why they were selected. Yes ---
Comments (Describe any changes made, if applicable)
Target audiences are students at Lillian Black ES, Manchester ES, and Spring Lake MS as well as children at the parks and
recreation center and townspeople at events.
MS4 Permit Self Audit Report
Spring Lake, NC: NPDES Permit No. NCS000438
Audit Date(s): 20220208
Page 9 of 18
Public Education and Outreach
II.B.2.d Residential
and Industrial/
Commercial Issues
The permittee described issues, such as pollutants, the likely sources of those
pollutants, potential impacts, and the physical attributes of stormwater runoff in
their education/outreach program.
Yes ---
Comments (Generally describe the residential/industrial/commercial issues addressed)
School age children are taught that “just one” piece of trash or pollutant is added to the other “just ones” to create a huge mess,
and that they are able to make a big impact on their community by taking care of their own “just ones”. An expansion of this
idea to reach out to the larger community is planned for the next clean up event and for Creek Week.
II.B.2.e
Informational
Web Site
The permittee promoted and maintained an internet web site designed to convey the
program’s message. Yes ---
Comments (list web page address and general contents, or attach screen shot of landing page)
Spring Lake North Carolina (townofspringlake.com)
Being updated as soon as the main website is finished being reconstructed
II.B.2.f
Public Education
Materials
The permittee distributed stormwater educational material to appropriate target
groups. Partial ---
Comments (List distributed materials and quantity, message, distribution mechanism, target audience for each if not included in
program documentation/annual reporting)
Creating or obtaining material for clean up events, restaurants, auto shops and car washes, etc through CWEP
II.B.2.g
Hotline/Help Line The permittee promoted and maintained a stormwater hotline/helpline for the
purpose of public education and outreach. Yes ---
Comments (Note hotline contact information and method(s) for advertising it)
Hotline Number is 910-985-1804, email is stormwater@townofspringlake.com, both are listed on the Spring Lake homepage as
well as on our facebook and twitter pages.
II.B.2.h The permittee’s outreach program, including those elements implemented locally or
through a cooperative agreement, included a combination of approaches designed to
reach the target audiences.
Yes ---
MS4 Permit Self Audit Report
Spring Lake, NC: NPDES Permit No. NCS000438
Audit Date(s): 20220208
Page 10 of 18
Public Education and Outreach
Public Education
and Outreach
Program
For each media, event or activity, including those elements implemented locally or
through a cooperative agreement the permittee estimated and recorded the extent
of exposure.
Yes ---
Comments (Generally describe approaches, extent of exposure. Note any cooperating entities, agreements and scope of services,
or reference comments in Section II.A.6. above.)
We keep a headcount of all people in attendance at educational events, or participants who stop by our section of town events.
Additional
Comments:
MS4 Permit Self Audit Report
Spring Lake, NC: NPDES Permit No. NCS000438
Audit Date(s): 20220208
Page 11 of 18
Public Involvement and Participation
Staff Interviewed:
(Name, Title, Role)
Deanna Rosario, Stormwater Administrator- manages all aspects of the MS4 program
Permit Citation Program Requirement Status Supporting
Doc No.
II.C.2.a Volunteer
Community
Involvement
Program
The permittee included and promoted volunteer opportunities designed to promote
ongoing citizen participation. Yes ---
Comments (Note opportunities promoted and date(s) of volunteer events)
Recruiting for the town’s Appearance and Sustainability Committee, (ongoing)
Calls for volunteers on facebook, twitter, and town webpage for events (when events are scheduled)
II.C.2.b
Mechanism for
Public
Involvement
The permittee provided and promoted a mechanism for public involvement that
provides for input on stormwater issues and the stormwater program. Yes ---
Comments (Note mechanism(s) for input and how promoted)
Email, stormwater@townofspringlake.com
Twitter Spring Lake NC Stormwater (@SLSW12) / Twitter
facebook (1) Spring Lake Stormwater Department | Facebook
town website www.townofspringlake.com
phone 910-985-18004
II.C.2.c
Hotline/Help Line
The permittee promoted and maintained a hotline/helpline for the purpose of public
involvement and participation. Yes ---
Comments (Note hotline contact information and how it is promoted)
Hotline is on the town webpage, facebook, and twitter pages.
MS4 Permit Self Audit Report
Spring Lake, NC: NPDES Permit No. NCS000438
Audit Date(s): 20220208
Page 12 of 18
Public Involvement and Participation
Additional
Comments:
As we come out of the worst of COVID we are restarting prior public involvement events, and working to
create new ones, such as the first Creek Week event in Spring Lake in March 2022
I also set up the format for adopting drains, streets, and parks, awaiting final approval or amendment at
board level.
MS4 Permit Self Audit Report
Spring Lake, NC: NPDES Permit No. NCS000438
Audit Date(s): 20220208
Page 13 of 18
Construction Site Runoff Controls
Staff Interviewed:
(Name, Title, Role)
Deanna Rosario, Stormwater Administrator- manages all aspects of the MS4 program
Program Delegation Status:
☐ The permittee has a delegated Sediment and Erosion Control Program and implements the North Carolina
Sedimentation Pollution Control Act (SPCA) of 1973 components of this minimum measure (complete the permit
citation and SPCA citation sections).
☒ The permittee does not have a delegated Sediment and Erosion Control Program and relies on DEMLR to comply
with the North Carolina Sedimentation Pollution Control Act (SPCA) of 1973 components of this minimum measure
(complete only the permit citation section).
Permit Citation Program Requirement Status Supporting
Doc No.
II.E.3 Construction
Site Runoff Controls
[NPDES Permit No.
NCS000435]
The permittee provides and promotes a means for the public to notify the
appropriate authorities of observed erosion and sedimentation problems (e.g.,
promoting the existence of the DEQ DEMLR “Stop Mud” hotline).
Partial ---
Comments (Describe how provided and promoted)
Local reporting methods are listed online, however, we will be expanding that to include DEQ level hotlines.
SPCA Citation Delegated Program Requirement Status Supporting
Doc No.
§ 113A-60 Local
erosion and
sedimentation
control programs (a)
The permittee has adopted an ordinance or other regulatory mechanism to enforce
the erosion and sedimentation control program.
Not
Applicable ---
If yes, the ordinance meets or exceeds the minimum requirements of the
SPCA.
Not
Applicable ---
If yes, the ordinance applies throughout the corporate limits of the permittee.
[Permit Part I.D]
Not
Applicable ---
Comments (Provide regulatory mechanism reference or Supporting Documentation number)
§ 113A-60 Local
erosion and
sedimentation
control programs (d)
The permittee collects a fee paid by each person who submits an erosion and
sedimentation control plan.
Not
Applicable ---
MS4 Permit Self Audit Report
Spring Lake, NC: NPDES Permit No. NCS000438
Audit Date(s): 20220208
Page 14 of 18
Construction Site Runoff Controls
Comments (indicate the fee amount, if applicable)
§ 113A-60 Local
erosion and
sedimentation
control programs (e)
Has any person initiated a land-disturbing activity (within the permittee’s
jurisdiction) for which an erosion and sedimentation control plan is required in the
absence of an approved plan?
Not
Applicable ---
If yes, the permittee has notified the North Carolina Sedimentation Control
Commission of all such cases.
Choose
an item. ---
Has the permittee determined that a person engaged in a land-disturbing activity
has failed to comply with an approved erosion and sedimentation control plan?
Not
Applicable ---
If yes, has the permittee referred any such matters to the North Carolina
Sedimentation Control Commission for inspection and enforcement?
Choose
an item. ---
Comments
§ 113A-61 Local
approval of erosion
and sedimentation
control plans
The permittee reviews each erosion and sedimentation control plan submitted to
them and notifies the person submitting the plan that it has been approved,
approved with modification, or disapproved within 30 days of receipt.
Not
Applicable ---
The permittee only approves an erosion and sedimentation control plan upon
determining that it complies with all applicable State and local regulations.
Not
Applicable ---
The permittee has disapproved of an erosion and sedimentation control plan in
order to protect riparian buffers along surface waters.
Not
Applicable ---
If yes, the permittee notified the Director of the Division of Energy,
Mineral, and Land Resources within 10 days of the disapproval.
Choose
an item. ---
Comments
§ 113A-61.1
Inspection of land-
disturbing activity;
notice of violation
(a)
The certificate of approval of each erosion and sedimentation control plan
approved by the permittee includes a notice of the right to inspect.
Not
Applicable ---
The permittee provides for inspection of land-disturbing activities to ensure
compliance with the SPCA and to determine whether the measures required in an
erosion and sedimentation control plan are effective.
Not
Applicable ---
Comments
.
MS4 Permit Self Audit Report
Spring Lake, NC: NPDES Permit No. NCS000438
Audit Date(s): 20220208
Page 15 of 18
Construction Site Runoff Controls
§ 113A-61.1
Inspection of land-
disturbing activity;
notice of violation
(c)
When the permittee determines that a person engaged in land-disturbing activity
has failed to comply with the SPCA, the Permittee immediately issues a notice of
violation upon that person.
Not
Applicable ---
Each notice of violation issued by the permittee specifies the date by which the
person must comply.
Not
Applicable ---
Each notice of violation issued by the permittee informs the person of the actions
that need to be taken to comply.
Not
Applicable ---
Comments
§ 113A-64 Penalties Does the permittee issue civil penalties as part of the erosion and sedimentation
program?
Not
Applicable ---
Comments (indicate when/why a civil penalty is issued, and the amount, if applicable)
MS4 Permit Self Audit Report
Spring Lake, NC: NPDES Permit No. NCS000438
Audit Date(s): 20220208
Page 16 of 18
Total Maximum Daily Loads (TMDLs)
Staff Interviewed:
(Name, Title, Role)
Deanna Rosario, Stormwater Administrator- manages all aspects of the MS4 program
Program Status:
☒ The permittee is not subject to an approved TMDL (skip the rest of this section).
☐ The permittee is subject to an approved TMDL for: name of parameter(s) and date(s) approved
There ☐ is ☐ is not a Waste Load Allocation (WLA) in the approved TMDL (If there is a WLA, then complete items II.H.1-5
below. If there is not a WLA, skip to item II.H.6 below)
Permit Citation Program Requirement Status Supporting
Doc No.
II.H.3 TMDLs Within 12 months of final TMDL approval, the permittee’s annual reports included
a description of existing programs, controls, partnerships, projects and strategies to
address impaired waters.
Choose
an item. ---
Within 12 months of final TMDL approval, the permittee’s annual reports provided
a brief explanation as to how the programs, controls, partnerships, projects and
strategies address impaired waters.
Choose
an item. ---
Comments
II.H.4 TMDLs Within 24 months of final TMDL approval, the permittee’s annual reports included
an assessment of whether additional structural and/or non-structural BMPs are
necessary to address impaired waters.
Choose
an item. ---
Within 24 months of final TMDL approval, the permittee’s annual reports included
a brief explanation as to how the programs, controls, partnerships, projects and
strategies address impaired waters.
Choose
an item. ---
Comments
II.H.5 TMDLs Within 36 months of final TMDL approval, the permittee’s annual reports included
a description of activities expected to occur and when activities are expected to
occur.
Choose
an item. ---
MS4 Permit Self Audit Report
Spring Lake, NC: NPDES Permit No. NCS000438
Audit Date(s): 20220208
Page 17 of 18
Total Maximum Daily Loads (TMDLs)
Comments
II.H.6 TMDLs If there is no Waste Load Allocation in the approved TMDL, the permittee
evaluated strategies and tailored and/or expanded BMPs within the scope of the
six minimum measures to enhance water quality recovery strategies in the
watershed(s) to which the TMDL applies.
Choose
an item. ---
The permittee described strategies and tailored and/or expanded BMPs in their
Stormwater Management Plan and annual reports
Choose
an item. ---
Comments
MS4 Permit Self Audit Report
Spring Lake, NC: NPDES Permit No. NCS000438
Audit Date(s): 20220208
Page 18 of 18
Appendix A-