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HomeMy WebLinkAboutNCS000245_NOC and Audit Report_20220930ROY COOPER Governor ELIZABETH S. BISER Secretary BRIAN WRENN Director NORTH CAROLINA Environmental Quality September 30, 2022 CERTIFIED MAIL 7021 2720 0000 1254 6032 RETURN RECEIPT REQUESTED City of Raleigh Attn: Whit Wheeler One Exchange Plaza Raleigh, North Carolina 27601 Subject: NOTICE OF COMPLIANCE (NOC-2023-PC-0930) City of Raleigh NPDES MS4 Permit No. NCS000245 Wake County Dear Mr. Wheeler: On August 23-d, 2022 through August 25th, 2022, staff from the North Carolina Department of Environmental Quality (DEQ) conducted a compliance audit of subject National Pollutant Discharge Elimination System (NPDES) Municipal Separate Storm Sewer System (MS4) Permit. The audit identified minor deficiencies with the specific components of the MS4 permit that were reviewed, as provided in the attached DEQ MS4 Permit Compliance Audit Report. In accordance with Part VI of the permit and DEQ policy, a new 5-year MS4 permit will be issued in response to the audit. As such, the permittee is required to complete the following actions: (1) Respond in writing within thirty (30) calendar days from the date of receipt of this notice to acknowledge these requirements and the intent to comply. (2) Develop a Stormwater Management Plan (SWMP) which details specific actions, measurable goals, and implementation timelines for the stormwater management program over the new 5-year permit term. The SWMP must be documented utilizing the DEQ Phase 11 MS4 SWMP Template. The permittee shall submit the SWMP to DEQ for review and comment within one hundred twenty (120) calendar- days from the date of receipt of this letter. (3) Submit an NPDES MS4 permit application for whichever comes first: a. At least one hundred eighty (180) days prior to permit expiration, or b. Within thirty (30) days of receiving written DEQ concurrence that the submitted SWMP documents a compliant stormwater management program and the MS4 should submit the application including a signed Final Draft SWMP. A new 5-year NPDES MS4 permit will be public noticed along with the Draft Final SWMP. (4) Respond to comments on the Draft Final SWMP and submit a signed Final SWMP for DEQ approval and final permit issuance. The final DEQ-approved SWMP shall become an enforceable component D _E Q�� North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources Asheville Regional Office 1 2090 U.S. Highway 70 1 Swannanoa, North Carolina 28778 828.296.4500 of the NPDES MS4 permit and an Annual Self -Assessment Template that corresponds to the approved SWMP will be provided. Required documentation shall be submitted via e-mail to Isaiah.Reed(@ncdenr.gov or to: DEQ-DEMLR Stormwater Program Attn: Isaiah Reed 1612 Mail Service Center Raleigh, NC 27699-1612 Thank you for your attention to this matter. Should you have any questions, please contact me at Isaiah ReedOncdenr.gov. Sincerely Isaiah Reed, PE, CPSWQ, MS4CEC1 MS4 Program Coordinator Enclosures: DEQ MS4 Permit Compliance Audit Report CC: Wayne Miles wayne.miles(@raleighnc.gov DEMLR Stormwater Program Supervisor DEMLR NPDES MS4 Permit Laserfiche File er D_E Q'� North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources Asheville Regional Office 1 2090 U.S. Highway 70 1 Swannanoa, North Carolina 28778 oew..aoomoo.nry 828.296.4500 MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) PROGRAM AUDIT REPORT NPDES PERMIT NO. NCS000245 RALEIGH, NORTH CAROLINA One Exchange Plaza Raleigh, North Carolina 27601 Audit Date: August 23-25 2022 Report Date: September 30, 2022 North Carolina Department of Environmental Quality Division of Energy, Mineral & Land Resources Stormwater Program 512 N. Salisbury Street, 9' floor 1612 Mail Service Center Raleigh, NC 27699-1612 (This page intentionally left blank) NC5000245_Raleigh M54 Audit_20220930 TABLE OF CONTENTS AuditDetails.................................................................................................................................... PermitteeInformation.................................................................................................................... List of Supporting Documents......................................................................................................... Program Implementation, Documentation & Assessment............................................................. Illicit Discharge Detection and Elimination(IDDE).......................................................................... Site Visit Evaluation: Municipal Facility No. 1................................................................................. Site Visit Evaluation: Municipal Facility No. 2................................................................................. Site Visit Evaluation: Construction Stormwater Site No. 1............................................................. 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. NCS000245_Raleigh MS4 Audit_20220930 ii This page intentionally left blank NC5000245_Raleigh M54 Audit_20220930 iii Audit Details Audit ID Number: Audit Date(s): NCS000245_Raleigh MS4 Audit_20220930 August 23, 24, and 25, 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: 2 ® MS4Outfalls. Number visited: 1 ❑ 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 Or¢anization Isaiah Reed, Environmental Engineer NCDEQ Lauren Garcia, Environmental Specialist NCDEQ Audit Report Author: Date: Signature NCS000245_Raleigh MS4 Audit_20220930 Page 1 of 11 Permittee Information MS4 Permittee Name: City of Raleigh Permit Effective Date: October 10, 2018 Permit Expiration Date: October 9, 2023 Mailing Address: One Exchange Plaza. Raleigh, North Carolina 27601 Date of last MS4 Inspection/Audit: January 15, 2016 Co-permittee(s), if applicable: N/A Permit Owner of Record: Whit Wheeler Primary MS4 Representatives Participating in Audit Name, Title Organization Day 1(8/23/2022) _ Barbara Moranta, Engineering Supervisor City of Raleigh Heather Dutra, Water Quality Manager City of Raleigh Carmela Teichman, Water Quality Educator City of Raleigh Joyce Gaffney, Environmental Specialist City of Raleigh Stephen Jelteman, Engineer City of Raleigh Justin Harcum, Sr. Engineer City of Raleigh Mani Kumar, Stormwater Administrator City of Raleigh Scott Bryant, Stormwater Administrator City of Raleigh Ariel Bushel, Communications Analyst City of Raleigh Ben Brown, Stormwater Administrator City of Raleigh Lauren Witherspoon, Engineering Supervisor City of Raleigh Matthew Hunt, Business Services Manager City of Raleigh Wayne Miles, Stormwater Program Manager City of Raleigh Zachary Poole, Engineering Specialist City of Raleigh Day 2(8/24/2022) Heather Dutra, Water Quality Manager City of Raleigh Carmela Teichman, Water Quality Educator City of Raleigh Zachary Poole, Engineering Specialist City of Raleigh Stephen Jelteman, Engineer City of Raleigh Justin Harcum, Sr. Engineer City of Raleigh Brad Stuart, Engineer City of Raleigh Wayne Miles, Stormwater Program Manager City of Raleigh NCS000245_Raleigh MS4 Audit_20220930 Page 2 of 11 List of Supporting Documents Item Number Document Title When Provided (Prior to/During/After) 1 Raleigh M54SWMP Prior 2 Stormwater Program Webpage Prior 3 2021 Annual Report Prior 4 Unified Development Ordinance Prior 5 IDDE Ordinance Prior 6 Training PPT Prior 7 Industrial Facility Plan Prior 8 Education, Outreach, and Public Involvement Plan Prior 9 Illicit Discharge Detection and Elimination Plan Prior 10 Pollution Prevention and Good Housekeeping Plan Prior 11 WQAssessment and Monitoring Plan Prior 12 SCM Inspections Program Plan Prior NCS000245_Raleigh MS4 Audit_20220930 Page 3 of 11 Program Implementation, Documentation & Assessment Staff Interviewed: All in attendance Day 1 (Name, Title, Role) Permit Citation Program Requirement Status supporting Doc No. II.A.1 The Permittee Maintained adequate legal mechanisms to implement all provisions of Adequate Legal the of the Stormwater Management Plan. Yes 4 Mechanism The permittee is current on payment of invoiced administering and compliance monitoring fees (see stormwater e-payments on DEMLR MS4 web page). Yes BIMS II.A.2 Stormwater Plan The permittee evaluated the performance and effectiveness of the program Implementation components at least annually. Yes 3 and Evaluation II.A.3 Keeping the The permittee kept the Stormwater Plan up to date. Yes 1 Stormwater Plan Up to Date See The permittee notified DEMLR of any updates to the Stormwater Plan. Yes NCDEQ LF Did DEMLR require a modification to the Stormwater Plan? No II.A.4 Written The permittee maintained written procedures for implementing the six minimum 7, g, 9, Procedures control measures. Yes 10,11, 12 Website reviewed during audit. NCS000245_Raleigh MS4 Audit_20220930 Page 4 of 11 Illicit Discharge Detection and Elimination (IDDE) Staff Interviewed: All in attendance Day 2 (Name, Title, Role) Permit Citation Program Requirement Stat supporting Doc us No. II.D.2.a Maintain The permittee maintained appropriate legal Authorities. Yes 4 appropriate legal authorities Ordinance last used for enforcement in 2018. 1441nvestigations in 2022. (Ordinance section 13-5008) II.D.2.b Maintain a Storm Software Sewer System The permittee maintained a map system including major outfalls. Yes demonstrate Base Map of d during the Major MS4 audit. Outfalls. Mapping software reviewed during the audit. II.D.2.c Maintain written The permittee maintained written procedures and SOPS for detecting and tracing procedures and/or Illicit discharges. Yes 9 SOPS for IDDE. II.D.2.c The permittee maintained written procedures or SOPS for dry weather flow Dry weather flow Yes 2 inspections. inspections II.D.2.d The permittee conducted IDDE training for appropriate municipal staff. Yes 6 Employee Training II.D.2.e Website Maintain a public The permittee and publicized a reporting mechanism for the public to report illicit examined reporting connections and discharges. Yes during the mechanism audit. Methods of publications were examined during the audit. II.D.2.f Investigation Documentation tracking The permittee documented dates of investigations Yes software was examined during the audit. Documentati The permittee documented enforcement actions Yes on examined during the audit. Tracking software and methods were discussed during the audit. NCS000245_Raleigh MS4 Audit_20220930 Page 5 of 11 Illicit Discharge Detection and Elimination (IDDE) Additional Recommendations: Comments: It is recommended that an increased frequency of IDDE specific training be considered for appropriate IDDE staff. It is recommended that IDDE reporting data include open/closed dates specifically. Documentation for several IDDE investigations were discussed during the audit. NCS000245_Raleigh MS4 Audit_20220930 Page 6 of 11 Site Visit Evaluation: Municipal Facility No. 1 Facility Name: Central Operations Facility Date and Time of Site Visit: August 25, 2022 Facility Address: 2550Operations Way Raleigh 27604 Facility Type (Vehicle Maintenance, Landscaping, etc.): Public Works Name of MS4 inspector(s) evaluated: Stephen Jeltema Most Recent MS4 Inspection (Date and Entity): Not Evaluated Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit: Name Title Victor Avila Operator Observations Facility Documentation/Training Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific? Yes What type of stormwater training do facility employees receive? How often? Annual Stormwater training. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Stormwater training every 3 years. Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? Yes Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping? Yes Inspection Procedures Does the MS4 inspector's process include the use of a checklist or other standardized form? Yes Does the MS4 inspector's process include taking photos? Yes Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)? Yes Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge? Yes Did the MS4 inspector miss any obvious areas of concern? If so, explain: No Does the MS4 inspector's process include presenting the inspection findings to the facility contact? Yes Inspection Results Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)? Modifications to PM&GH practices relating to the NCG080000 requirements. Comments: NCS000245_Raleigh MS4 Audit_20220930 Page 7 of 11 Site Visit Evaluation: Municipal Facility No. 1 During the site visit, secondary containment status of generators on site was discussed. As well as spill prevention measures in the fueling areas. NCS000245_Raleigh MS4 Audit_20220930 Page 8 of 11 Site Visit Evaluation: Municipal Facility No. 2 Facility Name: Date and Time of Site Visit: Go Raleigh Operations facility August 25, 2022 Facility Address: Facility Type (Vehicle Maintenance, Landscaping, etc.): 4104 Poole Road Vehicle Maintenance Raleigh 27601 Name of MS4 inspector(s) evaluated: Most Recent MS4 Inspection (List date and name of inspector): Stephen Jeltema No evaluated Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit: Name Title Benjamin Goldstein Primary Contact Observations Facility Documentation/Training Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific? Yes. What type of stormwater training do facility employees receive? How often? Annual stormwater training. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Storm water training every 3 years. Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? Yes Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping? Yes Inspection Procedures Does the MS4 inspector's process include the use of a checklist or other standardized form? Yes Does the MS4 inspector's process include taking photos? Yes Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)? Yes Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge? Yes Did the MS4 inspector miss any obvious areas of concern? If so, explain: No Does the MS4 inspector's process include presenting the inspection findings to the facility contact? Yes Inspection Results Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)? No Comments: SWPPP contents and monitoring documentation was discussed. NCS000245_Raleigh MS4 Audit_20220930 Page 9 of 11 Site Visit Evaluation: Construction Site No. 1 Site/Project Name: Date and Time of Site Visit: Go Raleigh Parking August 25, 2022 Site/Project Address: Operator: 4104 Poole Road Not evaluated Raleigh 27601 Project Type (Commercial, Industrial, Residential, CIP, Roadway, etc.): NCG Permit ID Number: Disturbed Acreage: Not Evaluated —4 Recent Enforcement Actions (Include Date): None Name of MS4lnspector(s) evaluated: Lauren Witherspoon Name(s) and Title(s) of Site Representative(s) Present During the Site Visit: Name Title None Observations Site Documentation/Training Does the site have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it site -specific? Yes Does the site have approved erosion and sedimentation control plans onsite? Are they representative of current site conditions? Yes What type of stormwater training do site employees receive? How often? Not evaluated Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Stormwater Training every3 years. Did the MS4 inspector appear knowledgeable about MS4 and NCG010000 requirements for construction sites? Yes Did the MS4 inspector appear knowledgeable about erosion and sedimentation control/stormwater pollution prevention BMPs? Yes Inspection Procedures Does the MS4 inspector's process include the use of a checklist? Yes Does the MS4 inspector's process include taking photos? Yes Does the MS4 inspector's process include reviewing approved plans (erosion and sedimentation control and/or SWPPP)? Yes Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge? Yes Did the MS4 inspector miss any obvious violations? If so, explain: No Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing? Not Evaluated NCS000245_Raleigh MS4 Audit_20220930 Page 10 of 11 Site Visit Evaluation: Construction Site No. 1 Does the MS4 inspector's process include providing construction stormwater educational materials to the site contact? Not evaluated Compliance/Enforcement What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in? None If compliance issues were identified, what timeline for correction/follow-up was provided? N/A NC5000245_Raleigh MS4 Audit_20220930 Page 11 of 11