NCS000498_Audit Report_20220624

MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM AUDIT REPORT
NPDES PERMIT NO. NCS000498
MORGANTON, NORTH CAROLINA
305 E Union Street.
Audit Date: June 21, 2022
Report Date: June 24, 2022
North Carolina Department of Environmental Quality
Division of Energy, Mineral & Land Resources Stormwater Program
512 N. Salisbury Street, 9th floor
1612 Mail Service Center
Raleigh, NC 27699-1612

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NC5000498_Morganton M84 Audit_20220621

TABLE OF CONTENTS
AuditDetails..................................................................................................................................................1
PermitteeInformation..................................................................................................................................2
Listof Supporting Documents.......................................................................................................................4
Program Implementation, Documentation & Assessment...........................................................................5
Illicit Discharge Detection and Elimination(IDDE)........................................................................................8
Pollution Prevention and Good Housekeeping for Municipal Operations.................................................10
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.
NCS000498_Morganton MS4 Audit_20220621 ii

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NC5000498_Morganton M54 Audit_20220621 iii

Audit Details
Audit ID Number:
Audit Date(s):
NCS000498_Morganton MS4 Audit_20220621
June 20, 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
M Pollution Prevention and Good Housekeeping for Municipal Operations
❑ Total Maximum Daily Loads (TMDLs)
Field Site Visits:
❑ Municipal Facilities. Number visited: Choose an item.
❑ MS4 Outfalls. Number visited: Choose an item.
❑ Construction Sites. Number visited: Choose an item.
❑ Post -Construction Stormwater Runoff Controls. Number visited: Choose an item.
❑ Other: Number visited: Choose an item.
❑ other: Number visited: Choose an item.
Inspector(s) Conducting Audit
Name. Title
Organization
Isaiah Reed, Environmental Engineer
NCDEQ
Mack Granger, Environmental Specialist
NCDEQ
Audit Report Author,
Date:
Signature
40-1v/a
Audit Report Author:
Date:
Signature
NCS000498_Morganton MS4 Audit_20220621 Page 1 of 11

Permittee Information
MS4 Permittee Name:
City of Morganton
Permit Effective Date:
2/20/2017
Permit Expiration Date:
2/19/2022
Mailing Address:
305 E Union Street.
Morganton, North Carolina 28655
Date of Last MS4 Inspection/Audit:
N/A
Co-permittee(s), if applicable:
Permit Owner of Record:
Ronnie Thompson, Mayor
Primary MS4 Representatives Participating in Audit
Name, Title
Organization
Wade Griffith, Senior Planner
City of Morganton
Mario Sclarandis, Engineer
City of Morganton
Phillip Lookadoo, Director of Dev. And
Design.
City of Morganton
Tim Arney, Pretreatment Coordinator
City of Morganton
Eli Self, Wastewater Superintendent
City of Morganton
Scott Stewart, Street Superintendent
City of Morganton
Michael Chapman, Director of Public Works
City of Morganton
Bryan Fish, Director of Parks and
Recreation
City of Morganton
Stephen Fox, GIS Analyst
City of Morganton
Jeff Waycaster, Garage Supervisor
City of Morganton
Michael Berley, Project Designer
City of Morganton
MS4 Receiving Waters
Waterbodv
Classification
Impairments
Catawba River
WS-IV
Hunting Creek
WS-IV
Fiddlers Run
WS-IV
East Prong
WS-IV
Warrior Fork
WS-IV;CA (Critical Area)
Wilson Creek
WS-IV
Canoe Creek
WS-IV
NCS000498_Morganton MS4 Audit_20220621 Page 2 of 11

Little Silver Creek
WS-Iv
Silver Creek
WS-Iv
Bailey's Fork
WS-Iv
Pee Dee Branch
WS-Iv
NCS000498_Morganton MS4 Audit_20220621 Page 3 of 11

List of Supporting Documents
Item
Number
Document Title
When Provided
(Prior to/During/After)
1
2010 SWMP
Prior
2
Agreement with the Council of Governments
During
3
Complaint Log
During
4
Outfall Map
Prior
5
Pesticide Licenses
After
6
Nuisance Ordinance
Prior
NC5000498_Morganton MS4 Audit_20220621 Page 4 of 11

Program Implementation, Documentation & Assessment
Staff Interviewed:
Mario Sclarandis, Engineer
(Name, Title, Role)
Phillip Lookadoo, Director of Development and Design
Wade Griffith, Senior Planner
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.
No
Funding
The Stormwater Plan identifies a specific position(s) responsible for the overall
coordination, implementation, and revision to the Plan.
No
1
Responsibilities for all components of the Stormwater Plan are documented and
position(s) assignments provided.
No
1
The permittee is current on payment of invoiced administering and compliance
monitoring fees (see stormwater e-payments on DEMLR M54 web page).
Yes
BIMS
SWMP written in 2010 has not been maintained/updated. Names/designations contained in SWMP are no longer accurate. No
annual review documented.
II.A.2 Stormwater
The permittee evaluated the performance and effectiveness of the program
Plan
components at least annually.
No
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
applicable water quality standard?
No
---
If yes, did the permittee expand or better tailor its BMPs accordingly to address
Not
the non -attainment?
Applicable
No annual evaluation documented.
II.A.3
Keeping the
The permittee kept the Stormwater Plan up to date.
No
1
Stormwater Plan
Up to Date
The permittee notified DEMLR of any updates to the Stormwater Plan.
Not
Applicable
SWMP not kept up to date.
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
.--
Plan
The online materials included ordinances, or other regulatory mechanisms, or a list
identifying the ordinances, or other regulatory mechanisms, providing the legal
Partial
Website
authority necessary to implement and enforce the requirements of the permit.
City webpage links to Municode for Ordinance availability.
NCS000498_Morganton MS4 Audit_20220621 Page 5 of 11

Program Implementation, Documentation & Assessment
II.A.3 & II.A.S
Stormwater Plan
Did DEMLR require a modification to the Stormwater Plan?
Not
Applicable
Modifications
If yes, did the permittee complete the modifications in accordance with the
Not
established deadline?
Applicable
II.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?
Yes
---
Council of Governments is contracted to perform Public Education/Outreach and Public Involvement/Participation.
II.A.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
Written procedures not maintained for all MCMs.
IllA
The permittee maintained documentation of all program components including, but
Program
not limited to, inspections, maintenance activities, educational programs,
partial
3
Documentation
implementation of BMPs, enforcement actions etc., on file for a period of five years.
The activities which are documented are kept on file.
111.13
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
BIMS
Submittal
period specific to this MS4).
The permittee submitted subsequent annual reports every twelve months from the
scheduled date of the first annual report submittal.
Yes
BIMS
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
Not
of each major component of the Stormwater Plan for the past year and
Reviewed
...
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
the proposed changes and how these changes will impact the Stormwater
Reviewed
...
Plan (results, effectiveness, implementation schedule, etc.).
3. Documentation of any necessary changes to programs or practices for
assessment of management measures implemented through the Stormwater
Not
Plan.
Reviewed
4. A summary of data accumulated as part of the Stormwater Plan throughout
the year along with an assessment of what the data indicates in light of the
Not
Stormwater Plan.
Reviewed
NCS000496_Morganton MS4 Audit_20220621 Page 6 of 11

Program Implementation, Documentation & Assessment
5. An assessment of compliance with the permit, information on the
establishment of appropriate legal authorities, inspections, and enforcement
Not
Reviewed
actions.
IV.B
Annual Reporting
The Annual Reports document the following:
1. A summary of past year activities, including where applicable, specific
Not
quantities achieved and summaries of enforcement actions.
Reviewed
2. A description of the effectiveness of each program component.
Not
Reviewed
3. Planned activities and changes for the next reporting period, for each
Not
program component or activity.
Reviewed
4. fiscal analysis.
Not
Reviewed
NCS000498_Morganton MS4 Audit_20220621 Page 7 of 11

Illicit Discharge Detection and Elimination (IDDE)
Staff Interviewed:
Mario Sclarandis, Engineer
(Name, Title,
Phillip Lookadoo, Director of Development and Design
Role)
Wade Griffith, Senior Planner
Tim Arney, Pretreatment Coordinator
Michael Chapman, Director of Public Works
Permit Citation
Program Requirement Status supporting
Doc No.
II.D.2.a
IDDE Program
The permittee maintained a written IDDE Program. No ---
If yes, the written program includes provisions for program assessment and Not
evaluation and integrating program. Applicable
No written IDDE Program.
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.
Partial
6
Legal Authorities
If yes, the ordinance applies throughout the corporate limits of the permittee.
Not
[Permit Part I.D]
Applicable
A Nuisance Ordinance has been modified to include some applicable language, but an IDDE ordinance has not been developed.
II.D.2.c
The permittee maintained a current map showing major outfalls'" and receiving
Storm Sewer
No
4
System Map
streams.
Map created in 2021 and still contains several potential/possible major outfalls. Map is still being developed.
II.D.2.d
The permittee maintained a program for conducting dry weather flow field
Dry Weather Flow
observations in accordance with written procedures.
No
-•-
Program
No dry weather flow program has been established.
II.D.2.e
The permittee maintained written procedures for conducting investigations of
Investigation
identified illicit discharges.
No
---
Procedures
No written procedure for IDDE has been developed.
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
Yes
3
2. The results of the investigation
Yes
3
3. Any follow-up of the investigation
Yes
3
4. The date the investigation was closed
No
---
Incomplete spreadsheet tracking system is currently in -use.
NCS000498_Morganton MS4 Audit_20220621 Page 8 of 11

Illicit Discharge Detection and Elimination (IDDE)
II.13.2.¢ Employee
The permittee implemented and documented a training p p g program for appropriate
Training
municipal staff who, as part of their normal job responsibilities, may come into
No
---
contact with or otherwise observe an illicit discharge or illicit connection.
No Training program has been developed and maintained.
II.13.2.1h
The permittee informed public employees of hazards associated with illegal
Public Education
discharges and improper disposal of waste.
No
---
The permittee informed businesses of hazards associated with illegal discharges and
improper disposal of waste.
No
The permittee informed the general public of hazards associated with illegal
discharges and improper disposal of waste.
No
II.D.2.i
The permittee promoted, publicized, and facilitated a reporting mechanism for the
Public Reporting
public to report illicit discharges.
Yes
Website
Mechanism
The permittee promoted, publicized, and facilitated a reporting mechanism for staff
to report illicit discharges.
Yes
Website
The permittee established and implemented response procedures for citizen
requests/reports.
NO
https://www. morgantonnc. gov/
II.0.2.0
The permittee implemented a mechanism to track the issuance of notices of violation
Enforcement
and enforcement actions administered by the permittee.
Partial
3
If yes, the mechanism includes the ability to identify chronic violators for
Not
initiation of actions to reduce noncompliance.
Applicable
tworq.net.
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Pollution Prevention and Good Housekeeping for Municipal Operations
Staff Interviewed:
Mario Sclarandis, Engineer
(Name, Title, Role)
Phillip Lookadoo, Director of Development and Design
Wade Griffith, Senior Planner
Tim Arney, Pretreatment Coordinator
Michael Chapman, Director of Public Works
Scott Stewart, Street Superintendent
Jeff Waycaster, Garage Supervisor
Permit Citation
Program Requirement
Status Supporting
Doc 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
No ---
stormwater runoff.
No inventory has been treated/maintained.
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
No operation and maintenance plan has been developed and maintained.
II.G.2.c
Spill Response
The permittee had written spill response procedures for municipal operations.
No
---
Procedures
No written spill response procedure has been developed.
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
No
---
Parking Lots
corporate limits annually.
Maintenance
If yes, the permittee evaluated the effectiveness of existing and new BMPs
Not
based on cost and the estimated quantity of pollutants removed.
Applicable
No evaluation documented.
II.G.2.f
The permittee maintained and implemented an O&M program for the stormwater
O&M for Catch
sewer system including catch basins and conveyance systems that it owns and
No
---
Basins and
Conveyance Systems
maintains.
No operation and maintenance plan has been developed.
NCS000498_Morganton MS4 Audit_20220621 Page 10 of 11

Pollution Prevention and Good Housekeeping for Municipal Operations
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-
No
___
Stormwater Controls
construction ordinance.
II.G.2.e
The permittee maintained and implemented an C&M program for municipally -
O&M for Structural
owned or maintained structural stormwater controls installed for compliance with
No
---
Stormwater Controls
the permittee's post -construction ordinance. If yes, then:
The O&M program specified the frequency of inspections and routine
Not
maintenance requirements.
Applicable
---
The permittee documented inspections of all municipally -owned or maintained
Not
structural stormwater controls.
Applicable
---
The permittee inspected all municipally -owned or maintained structural
Not
stormwater controls in accordance with the schedule developed by permittee.
Applicable
The permittee maintained all municipally -owned or maintained structural
Not
stormwater controls in accordance with the schedule developed by permittee.
Applicable
The permittee documented maintenance of all municipally -owned or
Not
maintained structural stormwater controls.
Applicable
---
No operation and maintenance plan has been developed and maintained.
II.G.2.f
The permittee ensured municipal employees are properly trained in pesticide,
Pesticide, Herbicide
herbicide and fertilizer application management.
Yes
5
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
Not
applicators are followed.
Applicable
Applicable staff are licensed applicators.
II.G.2.9
The permittee implemented an employee training program for employees involved
Staff Training
in im lementin
p g pollution prevention and good housekeeping practices.
No
A training program has not been developed for municipal staff focused on pollution prevention and good housekeeping.
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
Yes
---
Equipment Cleaning
cleaning.
Municipally owned vehicles are washed at carwashes or at the wastewater treatment plant where wash -water is able to enter
the POTW system.
NCS000498_Morganton MS4 Audit_20220621 Page 11 of 11