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Home My WebLink AboutNCS000400_Jamestown Audit Report_20230622MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) PROGRAM AUDIT REPORT NPDES PERMIT NO. NCS000400 JAMESTOWN, NORTH CAROLINA Jamestown, NC 27282 Audit Date: June 7, 2023 Report Date: June 22, 2023 North Carolina Department of Environmental Quality Division of Energy, Mineral & Land Resources Stormwater Program 512 N. Salisbury Street, 6th floor 1612 Mail Service Center Raleigh, NC 27699-1612 (This page intentionally left blank) NCS000400_Jamestown MS4 Audit Report_20230622 TABLE OF CONTENTS AuditDetails..................................................................................................................................................1 PermitteeInformation..................................................................................................................................2 SupportingDocuments..................................................................................................................................3 Program Implementation, Documentation & Assessment...........................................................................5 Illicit Discharge Detection and Elimination (IDDE)........................................................................................8 Post -Construction Site Runoff Controls......................................................................................................10 Pollution Prevention and Good Housekeeping for Municipal Operations..................................................15 Site Visit Evaluation: Municipal Facility No. 1.............................................................................................17 Site Visit Evaluation: Municipal Facility No. 2.............................................................................................19 Site Visit Evaluation: MS4 Outfall No. 1................................................................................•.....................21 Site Visit Evaluation: MS4 Outfall No. 2......................................................................................................23 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1............................................25 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 2..............................................27 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. NCS000400_Jamestown MS4 Audit Report_20230622 ii This page intentionally left blank NCS000400 Jamestown MS4 Audit Report_20230622 Audit Details Audit ID Number: Audit Date(s): NCS000400 Jamestown MS4 Audit_20230607 June 7, 2023 Minimum Control Measures Evaluated: N Program Implementation, Documentation & Assessment ❑ Public Education & Outreach ❑ Public Involvement & Participation N 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 N Post -Construction Site Runoff Controls N Pollution Prevention and Good Housekeeping for Municipal Operations ❑ Total Maximum Daily Loads (TMDLs) Field Site Visits: N Municipal Facilities. Number visited: 2 N MS4 Outfalls. Number visited: 3 ❑ Construction Sites. Number visited: C"loose an iter; N Post -Construction Stormwater Runoff Controls. Number visited: 2 ❑ Other: Number visited: Choose are item, ❑ Other: Number visited: Choose an iie:ii, Inspectors) Conducting Audit Name, Title Organization Paul Clark, Water Supply Watershed Protection Coordinator DEMLR Audit Report Author: Date: Signature_ Audit Report Author: Date Signature NCS000400 Jamestown MS4 Audit Report_20230622 1 of 28 Permittee Information MS4 Permittee Name: Permit Effective Date: Permit Expiration Date: Town of Jamestown February 20, 2017 February 19, 2022 City, State, ZIP: Date of Last MS4 Inspection/Audit: Jamestown, NC 27282 Co-permittee(s), if applicable: Permit Owner of Record: Matthew Johnson, Town Manager Primary MS4 Representatives Participating in Audit Name, Title Organization Matthew Johnson Town Manager Paul Blanchard Public Utilities Director Lindsey Lengyel Blue Stream Environmental Jason Pegram Assistant Public Services Director MS4 Receiving Waters Waterbody Classification Impairments Deep River — WS-IV, (17-3.3) Supporting (NA) High Point Lake Dam to Guilford Co SR1334 Deep River — Guilford Co SR1334 to Oakdale Cotton Mills WS-IV, CA (17-3.7) NA Dam _ Deep River — Oakdale Cotton Mills Dam to Randleman WS-IV, CA (17-4) NA Lake Dam WS-IV, 17-5-(1) Bull Run — NA Source to 0.5 mile upstream of mouth Bull Run — WS-IV, CA 17-5-(2) NA 0.5 mile upstream of mouth to Deep River NCS000400_Jamestown MS4 Audit Report_20230622 2 of 28 Supporting Documents Item When Provided Document Title Number (Prior to/During/After) 1 2016 SWMP Prior 2 IDDE Glovebox Guide Reduced Prior 3 IDDE Grate Concern Pocket Guide Prior Land Development Ordinance- Illicit Discharge and Connections section Prior 4 https:Hlibrary. m unicode.com/nc/J*a mestown/codes/Iand_deveIopment_ord ina nce?nodeld=LADEORTOJANOCA ARTI9WAPROR S81LDI 5 Water Supply Watershed Protection Ordinance serves as Post Construction Prior Stormwater Ordinance - https://library.municode.com/nc/)amestown/codes/land_development_ordina nce?nodeld=LADEORTOJANOCA ARTI9WAPROR S3ST 6 Piedmont Triad Regional Council - Stormwater Smart (PTRC) reports - Prior https://www.ptrc.org/services/regional-plan n ing/stormwater-smart/a bout- us/docu ments-resources/-folder-460#docan2216_1592_1307 7 Piedmont Triad Regional Council — Stormwater Educational Videos - Prior https://www. ptrc.org/services/regional-plann ing/stormwater-smart/about- us/stormwater-educational-videos 8 Jamestown —Annual Comprehensive Financial Report for fiscal year ended June Prior 30, 2022 - 9 Guilford County/Jamestown agreement on Erosion and Sedimentation Control Prior Prior 10 Organizational chart_2022 11 Jamestown Stormwater Map 2023 During During 12 Organizational Chart detailed_2023 13 Stormwater Smart bill Rusty Outfall Contract 2022 with PO Technical Review Committee Process Image During 14 During 15 During 16 Technical Review Committee Inventory During 17 17_O&M on Magnolia-7-3-2018_conditionally approved During 18 SCM Inspection Documentation - Jamestown SCMs - OneDrive (live.com) During NCS000400_Jamestown MS4 Audit Report_20230622 3 of 28 19 MOU Jamestown and PTRC SW Smart 2021 2024 — During 20 MOU Jamestown and PTRC SW Smart Mass Media 2021 2024 — During 21 Storm complaint list -IDDE tracking spreadsheet (includes only complaints does not include Russell Saxon work) During 22 Jamestown Stormwater Education website: https://www.jamestown- nc.gov/my-government/storm-water- During 23 Jamestown staff pesticide, herbicide, fertilizer application certificates Spill Response Policy and Forms Clipboard During 24 Pollution Prevention Clipboard After 25 After 26 Lindsey Lengyel email message partial documentation explanation After 27 DEMLR — stormwater epayments website confirmed Jamestown current on Before payment 28 Jamestown NPDES MS4 Annual Reports During 29 East Fork of the Deep River TMDL (3/4/2004) — Fecal Coliform, Turbidity and Haw River TMDL (1/11/05) — Fecal Coliform, Turbidity Before 30 Paul Blanchard email message partial documentation explanation After NCS000400—Jamestown MS4 Audit Report_20230622 4 of 28 Program Implementation, Documentation & Assessment Staff Interviewed: Matthew Johnson, Jamestown Town Manager (Name, Title, Role) Paul Blanchard, Public Utilities Director Jason Pegram, Assistant Public Utilities Director Lindsey Lengyel, Blue Stream Environmental Permit Citation Program Requirement Status Supporting Doc No. II.A.1 The permittee maintained adequate funding and staffing to implement and Staffing and Funding manage provisions of the Stormwater Plan and meet all requirements of permit. Yes 1,8 The Stormwater Plan identifies specific position(s) responsible for the overall coordination, implementation, and revision to the Plan. Yes 1 Responsibilities for all components of the Stormwater Plan are documented and position(s) assignments provided. Yes 1 The permittee is current on payment of invoiced administering and compliance monitoring fees (see stormwater e-payments on DEMLR MS4 web page). Yes 27 Comments (Briefly describe funding mechanism, number of staff, etc.) Currently, stormwater is funded from different municipal programs. For example, sanitary sewer fees funds IDDE and street department. Beginning July 1, 2023, Jamestown will be creating new stormwater department. Following this change, all stormwater funding will be in one program and not in several different programs. This change will also include stormwater utility that will generate revenue. SWMP identifies positions responsible for certain tasks. Checked DEMLR — stormwater epayments website to confirm Jamestown is current on payment. II.A.2 Stormwater The permittee evaluated the performance and effectiveness of the program Plan Implementation components at least annually. Yes 28 and Evaluation If yes, the permittee used the results of the evaluation to modify the program components as necessary to accomplish the intent of the Stormwater Yes Program. Did the permitted MS4 discharges cause or contribute to non -attainment of an applicable water quality standard? No 29 If yes, did the permittee expand or better tailor its BMPs accordingly to Not address the non -attainment? Applicable Comments Annual report is used for program effectiveness and evaluation. In addition, Stormwater Smart (SS) does public education and public involvement minimum measures and SS also does public education for other minimum measures. SS annual reports include evaluation of public education aspect of several minimum measures. DEQ recommends more specific evaluation of minimum measures that are not covered in SS annual report because BIMS annual report is generic. East Fork of the Deep River TMDL (3/4/2004) — Fecal Coliform, Turbidity and Haw River TMDL (1/11/05) — Fecal Coliform, Turbidity. These TMDLs cover areas different than waters impacted by Jamestown. II.A.3 The permittee kept the Stormwater Plan up to date. No 1 NCS000400 Jamestown MS4 Audit Report_20230622 5 of 28 Program Implementation, Documentation & Assessment Keeping the Stormwater Plan Up The permittee notified DEMLR of any updates to the Stormwater Plan. Not Applicable to Date II.A.4 Availability of The permittee kept an up-to-date version of its Stormwater Plan available to the the Stormwater Plan Division and the public online. No - The online materials included ordinances, or other regulatory mechanisms, or a list identifying the ordinances, or other regulatory mechanisms, providing legal Partial 4,5 authority necessary to implement and enforce the requirements of the permit. Comments Stormwater Plan needs to be updated. For example, Matthew Johnson was still listed as Director of Planning (p. 3), some examples used in some of minimum measures are over ten years old (see pages 6,8) and some post construction stormwater requirements need to be updated (p. 18). Jamestown plans to put SWMP on website as part of the stormwater budget and other changes. Land Development Ordinance --Illicit Discharge and Connections section: https://library.municode.com/nc/jamestown/codes/land_development_ordinance?nodeld=LADEORTOJANOCA_ART19WAPROR_S8 ILDI. Water Supply Watershed Protection Ordinance serves as Post Construction Stormwater Ordinance - https://library.municode.com/nc/jamestown/codes/land_development_ordinance?nodeld=LADEORTOJANOCA_ART19WAPROR_S3 ST -_-- 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 II.A.6 Sharing Responsibility Are any control measures implemented by an entity other than the permittee? Yes 1 If yes, is there a written agreement in place? Yes i 9, 14, 19 Comments Jamestown contracts with Guilford County Planning Department to approve and inspect Jamestown Erosion and Sedimentation control program. Jamestown is member of Piedmont Triad Water Quality Partnership that shares costs to implement stormwater management surface water quality and watershed protection public education. This includes Stormwater Smart (SS). Jamestown contracts with SS. SS does public education and public involvement minimum measures and SS also does public education for other minimum measures. Jamestown also contracts with Russell Saxon sewer outfall service to conduct dry weather screening and detect and address illicit discharges. II.A.7 The permittee maintained written procedures for implementing the six minimum Written Procedures control measures. Partial 1 Written procedures identified specific action steps, schedules, resources, and responsibilities for implementing the six minimum measures. Partial 1,24 Ill. A The permittee maintained documentation of all program components including, Program but not limited to, inspections, maintenance activities, educational programs, Partial -- Documentation implementation of BM Ps, enforcement actions etc., on file for period of five years. NCS000400_Jamestown MS4 Audit Report_20230622 6 of 28 I Program Implementation, Documentation & Assessment Comments SWMP identifies general goals for each minimum measure. Public education and public involvement documentation handled by Piedmont Triad Water Quality Partnership — Stormwater Smart. IDDE written procedures are more detailed in SWMP. Some PP&GH —spill response guidance in doc. No. 25. III_B Annual Report Submittal IV.B Annual Reporting The permittee submitted annual reports to the Department within twelve months from the effective date of the permit (See Section 111.B. for the annual reporting Yes 28 period specific to this MS4). The permittee submitted subsequent annual reports every twelve months from Yes 28 the scheduled date of the first annual report submittal. The Annual Reports included appropriate information to accurately describe the progress, status, and results of the permittee's Stormwater Plan, including, but not limited the following: 1. A detailed description of the status of implementation of the Stormwater Plan as a whole. This will include information on development and Yes implementation of each major component of the Stormwater Plan for the past year and schedules and plans for the year following each report. 2. An adequate description and justification of any proposed changes to the Stormwater Plan. This will include descriptions and supporting information Yes for the proposed changes and how these changes will impact the Stormwater Plan (results, effectiveness, implementation schedule, etc.). 3. Documentation of any necessary changes to programs or practices for assessment of management measures implemented through the Yes Stormwater 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 Yes in light of the Stormwater Plan. 5. An assessment of compliance with the permit, information on the establishment of appropriate legal authorities, inspections, and Yes enforcement actions. 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. I Yes 3. Planned activities and changes for the next reporting period, for each Yes program component or activity. 4. Fiscal analysis. I Yes Comments Jamestown use BIMS SWMPA to meet annual reporting requirements. 28 28 28 28 28 28 28 28 28 NCS000400_Jamestown MS4 Audit Report_20230622 7 of 28 Illicit Discharge Detection and Elimination (IDDE) Staff Interviewed: Matthew Johnson, Jamestown Town Manager (Name, Title, Role) Paul Blanchard, Public Utilities Director Jason Pegram, Assistant Public Utilities Director Lindsey Lengyel, Blue Stream Environmental Permit Citation Program Requirement Status Supporting Doc No. II.D.2.a IDDE Program The permittee maintained a written IDDE Program. Yes 1 If yes, the written program includes provisions for program assessment and evaluation and integrating program. Partial 1 Comments SWMP includes written program. Annual report provides some evaluation, but because annual report is long and general evaluation could be improved. The permittee maintained an IDDE ordinance or other regulatory mechanism(s) that II.D.2.b provides the legal authority to prohibit illicit connections and discharges to the MS4. Yes 4 Legal Authorities If yes, the ordinance applies throughout the corporate limits of the permittee. Yes 4 [Permit Port I.D] II.D.2.c The permittee maintained a current map showing major outfalls* and receiving Storm Sewer Yes 11 streams. System Map II.D.2.d -- - The permittee maintained a program for conducting dry weather flow field Dry Weather Flow Yes 1,14 observations in accordance with written procedures. Program II.D.2.e The permittee maintained written procedures for conducting investigations of Investigation Yes 1,14 identified illicit discharges. Procedures Comments Person calls with complaint. Jamestown investigates. Results are compiled in a spreadsheet. Russell Saxon -contracts with Jamestown to do IDDE. He inspects the sanitary sewer collection system and the stormwater collection system. Russell contacts Jamestown if there is a problem and often resolves problems himself. II.D.2.f For each case of an illicit discharge or potential illicit discharge, permittee documented and tracked following: Track and Document 1. The date(s) the illicit discharge was observed Partial 21 Investigations 21 2. The results of the investigation Partial 21 3. Any follow-up of the investigation Partial 21 4. The date the investigation was closed Partial NCS000400 Jamestown MS4 Audit Report_20230622 8 of 28 Illicit Discharge Detection and Elimination (IDDE) Comments Jamestown tracks outside/citizen complaints in spreadsheet (item no. 21), but needs to also track Russell Saxon work on the same or a similar spreadsheet. This would help track repeat offenders. II.D.2.g Employee The permittee implemented and documented a training program for appropriate Training municipal staff who, as part of their normal job responsibilities, may come into Yes 2, 3, 6, 7 contact with or otherwise observe an illicit discharge or illicit connection. Comments Piedmont Triad Regional Council Stormwater Smart provides IDDE, PP&GH training as well as general public education and public involvement. II.D.2.1h The permittee informed public employees of hazards associated with illegal 2, 3, 6, 7 Public Education discharges and improper disposal of waste. Yes The permittee informed businesses of hazards associated with illegal discharges and 2, 3, 6, 7 improper disposal of waste. Yes The permittee informed the general public of hazards associated with illegal 2, 3, 6, 7 discharges and improper disposal of waste. Yes Comments Piedmont Triad Regional Council Stormwater Smart provides IDDE, PP&GH training as well as general public education and public involvement. See the most recent email message with links to educational materials. II.D.2.1 The permittee promoted, publicized, and facilitated a reporting mechanism for the 4,21 Public Reporting public to report illicit discharges. Yes Mechanism The permittee promoted, publicized, and facilitated a reporting mechanism for staff 4, 21 • to report illicit discharges. Yes The permittee established and implemented response procedures for citizen 4,21 requests/reports. Yes Comments Telephone line alerts all public services staff and person on call. Call operations manager directs concern to the appropriate person. Jamestown has information on their website. PTRC also has number on their website and if concern is Jamestown related, it is directed there. People can also email concerns. 11.I3.2.1 The permittee implemented a mechanism to track the issuance of notices of violation Enforcement and enforcement actions administered by the permittee. Yes If yes, the mechanism includes the ability to identify chronic violators for initiation of actions to reduce noncompliance. Yes Comments Jamestown has only had one noncompliant entity (Alberdingk Boley). Details are shown in Item no. 21. Illicit discharge ordinance has the information about right to enter, inspections, violations, enforcements. NCS000400 Jamestown MS4 Audit Report_20230622 9 of 28 I Post -Construction Site Runoff Controls I Staff Interviewed: Matthew Johnson, Jamestown Town Manager (Name, Title, Role) Paul Blanchard, Public Utilities Director Jason Pegram, Assistant Public Utilities Director Lindsey Lengyel, Blue Stream Environmental 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: name of entity ❑ 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 213.0212 ❑ Water Supply Watershed II (WS-11) —15A NCAC 213.0214 ❑ Water Supply Watershed III (WS-III) —15A NCAC 26 .0215 ® Water Supply Watershed IV (WS-IV) —15A NCAC 213.0216 ❑ 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 26 .0235 ❑ Tar -Pamlico River Basin Nutrient Sensitive (NSW) Management Strategy —15A NCAC 2B .0258 ❑ Randleman Lake Water Supply Watershed Nutrient Management Strategy —15A NCAC 26 .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) Instructions: For MS4s not implementing a S.L. 2006-246 deemed -compliant program, complete only the Permit Citation section below. For MS4s implementing a S.L. 2006-246 deemed -compliant program, complete the Session Law 2006-246 section below. if the MS4 does not implement a deemed -compliant program throughout the entire MS4 permitted area, then complete the Permit Citation section below for the permitted orea(s) not covered under the S.L. 2006-246 deemed -compliant program. NCS000400_Jamestown MS4 Audit Report_20230622 10 of 28 Post -Construction Site Runoff Controls Session Law 2006- Program Requirement Status supporting 246 Doc No. Deemed -Compliant The permittee implements deemed -compliant Program requirements in Program(s) accordance with the applicable 15A NCAC rules. Yes 5 The permittee implements deemed -compliant Program requirements throughout the entire M54 area (If not, also complete the Permit Citation section below.) Yes 5 The permittee applies deemed -compliant Program requirements to all federal, state and local government projects within the permitted MS4 area who do not Yes 5 have their own NPDES stormwater permit. The permittee included deemed -compliant Program reporting in their MS4 Annual Reports. Yes 28 The permittee included deemed -compliant Program implementation in their Stormwater Management Plan. Yes 1,s Comments Annual report covers post construction reporting. Permit Citation Program Requirement Status supporting Doc No. II.F.2.a The permittee maintained an ordinance or other regulatory mechanism designed 5 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 5 (Verify permit coverage area listed in Part l: D of permit and modify Yes accordingly). The permittee has the authority to review designs and proposals for new 5 development and redevelopment to determine whether adequate stormwater Yes control measures will be installed, implemented, and maintained. 5 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 i Yes Program. The permittee has the authority to enter private property for the purpose of 5 inspecting at reasonable times any facilities, equipment, practices, or operations Yes related to stormwater discharges. II.F.2.b 5 Stormwater Control The permittee utilizes strategies which include SCMs appropriate for the MS4. Yes Measures (SCMs) 1,5 SCMs comply with 15A NCAC 02H .1000. No Comments Jamestown follows the DEQ-DEMLR — Stormwater Manual. Water Supply Watershed Protection ordinance needs to be updated (i.e., references to DWQ manual) NCS000400_Jamestown MS4 Audit Report_20230622 12 of 28 Post -Construction Site Runoff Controls II.F.2.c The permittee conducted site plan reviews of all new development and 5,15,16 Plan Reviews redeveloped sites that disturb greater than or equal to one acre (including sites Yes that disturb less than one acre that are part of a larger common plan of development or sale). If yes, the site plan reviews addressed how the project applicant meets the 5,15,16 performance standards. Yes If yes, the site plan reviews addressed how the project will ensure long-term Yes 5,15,16 maintenance. Comments Application first goes to Planning, Public Works, and Admin. Each of the three groups reviews. Public Works reviews for standard components, request calculations for different features, hydraulic for piping components. Anna Hawryluk (Planning Director) receives and numbers application and distributes to reviewers. PD assembles reviewers' comments and provide to applicant. Upon resubmittal, all reviewers examine comments, reconvene, and notify applicant if/when approved. After approval, sign off on development clearance certificate allows applicant to get building permit from Guilford County to apply for sewer and water permits. Erosion/sed review concurrent with Jamestown review and county does not approve until Jamestown issues the development clearance. II.F.2.d The permittee maintained an inventory of projects with post -construction 15,16,18 Inventory of Projects structural stormwater control measures installed and implemented at new Yes development and redeveloped sites. The inventory included both public and private sector sites located within the 15,16,18 permittee's corporate limits that are covered by its post -construction ordinance Yes requirements. Comments Each project has a folder with different pieces. ILF.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 5 and Protective consistent with approved plans. Covenants Comments This is in the post construction ordinance — see 19.25-3. II.F.2.f The permittee implemented or required an operation and maintenance plan for 5 Mechanism to the long-term operation of the SCMs required by the program. Yes Require Long-term _ Operation and The operation and maintenance plan required the owner of each SCM to perform 5,17 Maintenance and maintain a record of annual inspections of each SCM. Yes Annual inspection of permitted structural SCMs are required to be performed by a 5,17 qualified professional. Yes NCS000400_Jamestown MS4 Audit Report_20230622 12 of 28 Post -Construction Site Runoff Controls II.F.2.e The permittee conducted and documented inspections of each project site covered 18 Inspections of under performance standards, at least one time during the permit term (Verify this Yes Structural is a permit condition in Part II.F.2.g of permit and modify accordingly). Stormwater Control Before issuing a certificate of occupancy or temporary certificate of occupancy, the 18 Measures 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 completion( Verify this is a permit condition in Part II.F.2.g of permit and modify accordingly. The permittee developed and implemented a written inspection program for SCMs 18 installed pursuant to the post -construction program (Verify this is a permit Yes condition in Part II.F.2.g of permit and modify accordingly. 18 The permittee documented and maintained records of inspections. Yes 18 The permittee documented and maintained records of enforcement actions. Yes Comments Jamestown inspects all SCMs. When the project is nearing completion, Jamestown communicates with county about erosion/sed control, receives as-builts, and engineers' certification. Jamestown -Public Works inspects site. If minor problem, Planning Director only holds bond. Jamestown generally only holds Certificate of Occupancy with more serious problems. II.F.2.1h The permittee made available through paper or electronic means, ordinances, Educational post -construction requirements, design standards checklists, and other materials Materials and Training for appropriate for developers. Note: New materials may be developed by the permittee, or the permittee may use Yes 5,22 Developers materials adopted from other programs and adapted to the permittee's new development and redevelopment program. NCS000400 Jamestown MS4 Audit Report_20230622 13 of 28 Post -Construction Site Runoff Controls II.F.2.1 Enforcement The permittee tracked the issuance of notices of violation and enforcement Not actions. Applicable If yes, the tracking mechanism included the ability to identify chronic violators Not for initiation of actions to reduce noncompliance. Applicable II.F.3.b The permittee fully complies with post construction program requirements on its 5,18,22 New Development own publicly funded construction projects. Yes II.F.3.c Does the MS4 have areas drainingto Nutrient Sensitive Waters NSW (NSW) to Not Nutrient Sensitive 15A NCAC 02H .0150? Applicable Waters Not If yes, does the permittee use SCMs that reduce nutrient loading in order to meet local program requirements. Applicable If yes, does the permittee also still incorporate the stormwater controls Not required for the project's density level. Applicable If yes, does the permittee also require documentation where it is not feasible to Not use SCMs that reduce nutrient loading. Applicable Comments Jamestown will add column(s) for violations, enforcement, etc when needed. Jamestown has not been identified as having to implement Jordan Lake rules II.F.3.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 5 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 5 streets, driveways, and other impervious surfaces. Comments They follow the DEQ-DEMLR-Stormwater Manual and reference manual on the Jamestown stormwater education website. NCS000400_Jamestown MS4 Audit Report_20230622 14 of 28 Pollution Prevention and Good Housekeeping for Municipal Operations Staff Interviewed: Matthew Johnson, Jamestown Town Manager (Name, Title, Paul Blanchard, Public Utilities Director Role) Jason Pegram, Assistant Public Utilities Director Lindsey Lengyel, Blue Stream Environmental Permit Citation Program Requirement Status Supporting Doc No. II.G.2.a The permittee maintained a current inventory of facilities and operations owned 1 Facility Inventory and operated by the permittee with the potential for generating polluted Yes stormwater runoff. II.G.2.b The permittee maintained and implemented an 0&M program for municipally 1 Operation and owned and operated facilities with the potential for generating polluted Partial Maintenance stormwater runoff. (O&M) for Partial 1 Facilities If yes, the O&M program specifies the frequency of inspections. If yes, the O&M program specifies the frequency of routine maintenance Partial 1 requirements. If yes, the permittee evaluated the O&M program annually and updated it as Partial 1,26 necessary. Comments Jamestown needs to better document O&M program and document inspections. It could use form like that used for spill response reporting (item no. 24). Some documentation is provided on email message. II.G.2.c Spill Response The permittee had written spill response procedures for municipal operations. Partial 24 Procedures Comments There is spill response information included in the SWMP, they need to include that info at each facility II.G.2.d Streets, The permittee evaluated existing and new BMPs that reduce polluted stormwater 1,14,26 Roads, and Public runoff from municipally owned streets, roads, and public parking lots within its Partial Parking Lots corporate limits annually. Maintenance If yes, the permittee evaluated the effectiveness of existing and new BMPs 1,14,26 based on cost and the estimated quantity of pollutants removed. Partial Comments Goals mentioned in SWMP and evaluated generally in annual report. Every March, they inspect all the inlets and track yearly. II.G.2.f O&M for Catch The permittee maintained and implemented an O&M program for the stormwater Basins and sewer system including catch basins and conveyance systems that it owns and Yes 1,14 Conveyance maintains. Systems II.G.2.i; The permittee maintained a current inventory of municipally -owned or operated Structural structural stormwater controls installed for compliance with the permittee's post- Yes 18 Stormwater construction ordinance. Controls NCS000400_Jamestown M54 Audit Report_20230622 15 of 28 Pollution Prevention and Good Housekeeping for Municipal Operations Comments Goals mentioned in SWMP and evaluated generally in annual report. Every March, they inspect all the inlets and track yearly. II.G.2.h The permittee maintained and implemented an O&M program for municipally- 18 O&M for owned or maintained structural stormwater controls installed for compliance with Yes Structural the permittee's post -construction ordinance. If yes, then: Stormwater The O&M program specified the frequency of inspections and routine Yes 18 Controls maintenance requirements. Yes 18 The permittee documented inspections of all municipally -owned or maintained structural stormwater controls. The permittee inspected all municipally -owned or maintained structural 18 Yes stormwater controls in accordance with the schedule developed by permittee. The permittee documented maintenance of all municipally -owned or Yes 18 maintained structural stormwater controls. II.G.2.11 The permittee ensured municipal employees are properly trained in pesticide, 23 Pesticide, herbicide and fertilizer application management. Yes Herbicide and Fertilizer The permittee ensured contractors are properly trained in pesticide, herbicide, and Not Application fertilizer application management. Applicable Management The permittee ensured all permits, certifications, and other measures for 23 applicators are followed. Yes Comments Certifications shared during the audit. II.G.2.j The permittee implemented an employee training program for employees involved Staff Training in implementing pollution prevention and good housekeeping practices. Yes 6,7 II.G.2.k 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 26 Equipment cleaning. Cleaning Additional Public works facility has vehicle washing pad. It collects waste wash water and Comments goes to sanitary sewer (oil and water separator part of the unit). There is a similar unit inside the building as well. NCS000400_Jamestown MS4 Audit Report_20230622 16 of 28 Site Visit Evaluation: Municipal Facility No. 1 Facility Name: Public Services Facility Date and Time of Site Visit: June 7, 2023 Facility Address: 5005 Harvey Road Facility Type (Vehicle Maintenance, Landscaping, etc.): Public Services — Vehicle Storage, maintenance, etc. Name of MS4 inspector(s) evaluated: Jonathan Knight Most Recent MS4 Inspection (list date and name of inspector): June 5, 2023 Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit: Name Title Paul Blanchard Public Utilities Director Observations Facility Documentation/Training Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific? No What type of stormwater training do facility employees receive? How often? Annual training developed by Stormwater Smart. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Annual training developed by Stormwater Smart. 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? No NCS000400_Jamestown MS4 Audit Report_20230622 17 of 28 Site Visit Evaluation: Municipal Facility No. 1 Does the MS4 inspector's process include taking photos? No Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)? No Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge? No Did the MS4 inspector miss any obvious areas of concern? If so, explain: DEQ inquired about two floor drains inside building. Inspector said that they drained to stream. DEQ said this was a concern and Jamestown will take measures to plug drains. Does the MS4 inspector's process include presenting the inspection findings to the facility contact? No Inspection Results Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)? DEQ said this was a concern and Jamestown will take measures to plug drains. If compliance corrective actions were identified, what timeline for correction/follow-up was provided? NCS000400_Jamestown MS4 Audit Report_20230622 18 of 28 Site Visit Evaluation: Municipal Facility No. 2 Facility Name: Date and Time of Site Visit: Parks and Recreation June 7, 2023 Facility Address: Facility Type (Vehicle Maintenance, Landscaping, etc.): 7203 East Fork Road Parks and Recreation Equipment Storage Name of MS4 inspector(s) evaluated: Most Recent MS4 Inspection (Date and Entity): Scott Coakley June 5, 2023 Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit: Name Title Public Utilities Director Paul Blanchard Observations Facility Documentation/Training Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific? No What type of stormwater training do facility employees receive? How often? Annual training developed by Stormwater Smart. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Annual training developed by Stormwater Smart. 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? No NCS000400_Jamestown MS4 Audit Report_20230622 19 of 28 Site Visit Evaluation: Municipal Facility No. 2 Does the MS4 inspector's process include taking photos? No Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)? No Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge? All stormwater flows offsite via overland flow, no discharge points. 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? No Inspection Results Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)? No If compliance corrective actions were identified, what timeline for correction/follow-up was provided? NCS000400_Jamestown MS4 Audit Report_20230622 20 of 28 Site Visit Evaluation: MS4 Outfall No. 1 Outfall ID Number: Date and Time of Site Visit: June 7, 2023 Outfall Location: Outfall Description (Pipe Material/Diameter, Culvert, etc.): 702 West Main Street 60 inch reinforced concrete Receiving Water: Is Flow Present? If So, Describe (Color, Approximate Flow Rate, Arnold 1 Koontz Lake (High Point Lake) Sheen, Odor, Floatables/Debris, etc.): Most Recent Outfall Inspection/Screening (Date): June 5, 2023 Days Since Last Rainfall: Inches: Raining today Name of MS4 Inspector(s) evaluated: Paul Blanchard Observations Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Annual training developed by Stormwater Smart. As a PE, he also takes continual education credits. Finally, he says that sewer training has some overlap with stormwater, so that is also helpful. Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations? Yes Inspection Procedures Does the inspector's process include the use of a checklist or other standardized form? No Does the inspector's process include taking photos? No Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they? No NCS000400_Jamestown MS4 Audit Report_20230622 21 of 28 I Site Visit Evaluation: MS4 Outfall No. 1 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? No NCS000400 Jamestown MS4 Audit Report_20230622 22 of 28 Site Visit Evaluation: MS4 Outfall No. 2 Outfall ID Number: Date and Time of Site Visit: June 7, 2023 Outfall Location: Outfall Description (Pipe Material/Diameter, Culvert, etc.): 112 Royal Road 36 inch reinforced concrete Receiving Water: Is Flow Present? If So, Describe (Color, Approximate Flow Rate, Intermittent stream into Bull Run Creek Sheen, Odor, Floatables/Debris, etc.): Most Recent Outfall Inspection/Screening (Date): June 5, 2023 Days Since Last Rainfall: Inches: Raining today Name of MS4 Inspector(s): Paul Blanchard Observations Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Annual training developed by Stormwater Smart. As a PE, he also takes continual education credits. Finally, he says that sewer training has some overlap with stormwater, so that is also helpful. Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations? Yes Inspection Procedures Does the inspector's process include the use of a checklist or other standardized form? No Does the inspector's process include taking photos? No Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? if so, what were they? No NCS000400_Jamestown MS4 Audit Report_20230622 23 of 28 Site Visit Evaluation: MS4 Outfall No. 2 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? No NCS000400_Jamestown MS4 Audit Report_20230622 24 of 28 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1 Site Name: Date and Time of Site Visit: Gardner Hill Station June 7, 2023 Site Address: 1001 Gardner Hill Drive Name of MS4 Inspector(s) evaluated: Lindsey Lengyel, Blue Stream Environmental Name(s) and Title(s) of Site Representative(s) Present Name Site Documentation Does the site have an operation and maintenance plan? Yes — it is on site plan. SCM Type: stormwater Wet pond Most Recent M54 Inspection (Include Date and Entity): March 21, 2023 Most Recent MS4 Enforcement Activity (Include Date): the Site Visit: Observations Does the site have records of annual inspections? Are they performed by a qualified individual? Yes Inspector Train What type of stormwater training does the MS4 inspector receive? How often? State certified SCM inspector who attends recertification updates when needed. Title Did the MS4 inspector appear knowledgeable about MS4 requirements for post -construction site runoff controls? Yes Did the MS4 inspector appear knowledgeable about post -construction BMPs (general purpose/function, components, O&M requirements, etc.)? Yes Inspection Procedures Does the MS4 inspector's process include the use of a checklist or other standardized form? What format? Yes Does the MS4 inspector's process include taking photos? Yes NCS000400_Jamestown MS4 Audit Report_20230622 25 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? This was done prior to visit. 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 operation and maintenance deficiencies? If so, explain: No Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing? Yes Compliance/Enforcement What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in? NA If compliance issues were identified, what timeline for correction/follow-up was provided? NA Notes/Comments/Recommendations The outlet is not able to be checked from the edge, so it is checked every five years using a kayak, unless there is a problem in which case it is checked more frequently. NCS000400_Jamestown MS4 Audit Report_20230622 26 of 28 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 2 Site Name: Date and Time of Site Visit: Jordan Creek Townhomes June 7, 2023 Site Address: SCM Type: 100 Jordan Ridge Way Wet pond Most Recent MS4 Inspection (Include Date and Entity): March 21, 2023 Name of MS4 Inspector(s) evaluated: Lindsey Lengyel, Blue Stream Environmental Most Recent MS4 Enforcement Activity (Include Date): Name(s) and Title(s) of Site Representative(s) Present During the Site Visit: Name Title Observations Site Documentation Does the site have an operation and maintenance plan? Yes — it is on site plan. Does the site have records of annual inspections? Are they performed by a qualified individual? Yes Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? State certified SCM inspector who attends recertification updates when needed. Did the M54 inspector appear knowledgeable about MS4 requirements for post -construction site runoff controls? Yes NCS000400_Jamestown MS4 Audit Report_20230622 27 of 28 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 2 Did the MS4 inspector appear knowledgeable about post -construction BMPs (general purpose/function, components, O&M requirements, etc.)? Yes Inspection Procedures Does the MS4 inspector's process include the use of a checklist or other standardized form? What format? Yes Does the MS4 inspector's process include taking photos? Yes Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections? This was done prior to visit. 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 operation and maintenance deficiencies? If so, explain: No Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing? Yes Campliance/Enforcement What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in? NA If compliance issues were identified, what timeline for correction/follow-up was provided? NA Notes/Comments/Recommendations Following pond discharge, there is a 30-foot long filter strip. There were three aerators in the wet pond. These are not required. The main concern is that they don't generate sedimentation in pond. NCS000400_Jamestown MS4 Audit Report_20230622 28 of 28