HomeMy WebLinkAboutNCS000485_(Signed) MS4 Audit_20230808 MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM AUDIT REPORT
NPDES PERMIT NO. NCS000485
Town of Nashville, NORTH CAROLINA
499 South Barnes Street
Nashville, NC, 27856
Audit Date: 07/19/2023
Report Date: 08/08/2023
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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NCS000485_Nashville MS4 Audit_20230714 i
TABLE OF CONTENTS
AuditDetails..........................................................,............................................ ...... .,. ..............,............. 1
Permittee Information............................ ...... .... .... ... .. . . . . .... ..................._..............................,„ 2
Listof Supporting DocurnentS.................................................................. ........ ............. ..... .... ... ...... 3
Program Implementation, Documentation&Assessment........................................___.......................,.. 4
Public Education and Outreach... .......... ..... ... .... ... . ..... ... ............................................................... 8
Public Involvement and Participation ..........__...................„......................,..Error! bookmark,not defined.
Illicit Discharge Detection and Elimination (IDDE) ........................................ ........... .............................. 11
Construction Site Runoff Controls..................................................................Error! Bookmark not defined.
Post-Construction Site Runoff Controls..... ....................................... ....... ....Erro r! Bookmark not defined.
Pollution Prevention and Good Housekeeping for Municipal Operations................................................. 14
Total Maximum Daity Loads (TM Us).............................................................Error! Bookmark not defined.
Site Visit Evaluation- Municipal Facility No. 1 ................... ...... ...... ..... .... .... .... .............................. 18
Site Visit Evaluation. Municipal Facility No- 2 ............____........___...._............................................... 20
Site Visit Evaluation. M54 Outfall No. ............................................................... ............ ...................... 22
Site Visit Evaluation- MS4 Outfall No, 2 ...................... ..... ..... .................... ........................................... 25
Site Visit Evaluation.Construction Site No. J., ....... ...... ...Error!Bookmark not defined.
Site Visit Evaluation.Construction Site No, 2.................................................Errar1 Boakrnark not defined.
Site Visit Evaluation. Post-Construction Storm water Control Measure No. i....,,_. .............................„ 27
Site Visit Evaluation, Post-Construction Storm water Control Measure No. 2............... ... .. .. ...... 29
Appendix A. Supporting Documents
Appendix B. Photograph Log
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 Storm water
Management Plan in accordance with the issued permit.
NCS000485 Nashville MS4 Audit 20230719 ii
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NCS000485_Nashville MS4 Audit 20230719 HI
Audit Details
Audit ID Numbe►: Audit Date(s):
NCS000485_Nashville MS4 Audit_20230719 7/19/2023
Minimum Control Measures Evaluated:
® Program Implementation, Documentation&Assessment
® Public Education&Outreach
❑ Public Involvement&Participation
® Illicit Discharge Detection&Elimination
❑ Construction Site Runoff Controls—No delegated Sediment and Erosion Control Program
❑ Construction Site Runoff Controls—Delegated Sediment and Erosion Control Program
❑ Post-Construction Site Runoff Controls
® Pollution Prevention and Good Housekeeping for Municipal Operations
❑ Total Maximum Daily Loads(TMDLs)
Field Site Visits:
® Municipal Facilities. Number visited: 1
® MS4 Outfalls. Number visited: 1
❑ Construction Sites. Number visited: Choose an item.
® Post-Construction Stormwater Runoff Controls. Number visited: 1
❑ Other: Number visited:Choose an item.
❑ Other: Number visited:Choose an item.
Inspectors?Conducting Audit
Name,Title Organization
Thad valentine, Environmental Senior Specialist NCDEQ-Division of Energy,Mineral,and Land Resources
Celina Amaya,environmental Specialist II NCDEQ-Division of Energy, Mineral,and Land Resources
Audit Report Author: Date:
�r
Signature
Audit Report Author: Da e
Signature
NCS000485_Nashville MS4 Audit_20190719 Page 1 of 32
Permittee Information
MS4 Permittee Name: Permit Effective Date: Permit Expiration Date:
Town of Nashville February 20, 2017 February 19,2022
Mailing Address:449 South Barnes Street Date of Last MS4 Inspection/Audit:
Nashville,NC 27856 March 28, 2018
Co-permittee(s),if applicable:
N/A
Permit Owner of Record:
Primary MS4 Representatives Participating in Audit
Name.'title Organization
Lee Brown—Public Works Director Town of Nashville
Walter Manning—Environmental Programs Town of Nashville
Superintendent
MS4 Receiving Waters
Waterbodv Classification Impairments
NCS000485_Nashville MS4 Audit_20190719 Page 2 of 32
List of Supporting Documents
Item When Provided
Number Document Title (Prior to/During/After)
1 Stormwater Management Plan(Pg.8) During.
2 2018 Annual Report After
3 2021 Annual Report Before
4 2022 Annual Report During
5. 2023 Annual Report During
6 Pesticide, Herbicide and fertilizer license After
7 Don't Flush Flier After
8 2nd Don't flush Flier After
NCS000485 Nashville M54 Audit 20190719 Page 3 of 32
Program Implementation, Documentation &Assessment
Staff Interviewed: Lee Brown, Public Works Director
(Name,Title,Role) Walter Manning, Environmental Programs Superintendent
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
Partial
coordination,implementation,and revision to the Plan.
Responsibilities for all components of the Stormwater Plan are documented and
position(s)assignments provided. No
The permittee is current on payment of invoiced administering and compliance
Yes
monitoring fees(see stormwater e-payments an DEMLR MS4 web page).
Comments
$45,000 is available for stormwater projects and another$20,000 is applied to street sweeping.All this comes from the General
Fund, annually(this year specifically), There is an additional$500 that has been dedicated to public education&outreach
No full-time employees(FTE)dedicated solely to stormwater but there are five employees that are partially dedicated to stormwater
as a part of their position.
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
Comments
The performance and effectiveness of the program has not been evaluated.
The Town is not aware of any discharges that contributed to non-attainment of water quality standards
NCS000485_Nashville MS4 Audit_20190719 Page 4 of 32
Program Implementation, Documentation & Assessment
II.A.3
Keeping the The permittee kept the Stormwater Plan up to date. No
Stormwater Plan
Up to Date
The permittee notified DEMLR of any updates to the Stormwater Plan. Not
Applicable
Comments
The stormwater plan was not kept up to date and no notifications were necessary
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.
Plan
The online materials included ordinances,or other regulatory mechanisms,or a list Choose
identifying the ordinances,or other regulatory mechanisms, providing the legal
an item.
authority necessary to implement and enforce the requirements of the permit.
Comments
The permittee did not maintain and up-to-date version of the stormwater plan available to the public on it's website
II.A.3&II.A.S
Stormwater Plan Did DEMLR require a modification to the Stormwater Plan? No
Modifications
If yes,did the permittee complete the modifications in accordance with the Not
established deadline? Applicable
Comments
No modifications were required
II.A.6 Sharing
Responsibility Are any control measures implemented by an entity other than the permittee? No
If yes, is there a written agreement in place? Not
Applicable
Comments
None of the six minimum measures required are implemented by anyone other the Town of Nashville employees
Ii.A.7 The permittee maintained written procedures for implementing the six minimum
Written
control measures.
Procedures
Written procedures identified specific action steps,schedules, resources and Not
responsibilities for implementing the six minimum measures. Applicable
Comments
No procedures have been developed or implemented for identifying and implementing the six minimum measures
NCS000485 Nashville MS4 Audit 20190719 Page 5 of 32
Program Implementation, Documentation &Assessment
Ill.A 7ned
tee maintains documentation of all program components including, but
Program to,inspections, maintenance activities,educational programs, Partial 3,4,5
Documentation ation of BMPs,enforcement actions etc.,on file for a period of five years.
Comments
The only documentation available for the stormwater program other than the stormwater management plan is the yearly
annual reports
111.13 The permittee submitted annual reports to the Department within twelve months
Annual Report from the effective date of the permit(See Section M.B.for the annual reporting Yes 2
Submittal period specific to this MS4).
The permittee submitted subsequent annual reports every twelve months from the
Yes 3,4,5
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 implementation
Na ---
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 for Not
the proposed changes and how these changes will impact the Stormwater Applicable ---
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 No ---
Plan.
4. A summary of data accumulated as part of the Stormwater Plan throughout
the year along with an assessment of what the data indicates in light of the No ---
Stormwater Plan.
5. An assessment of compliance with the permit,information on the
establishment of appropriate legal authorities,inspections,and enforcement No
actions.
Comments
Annual reports were submitted to the State yearly,but with much of the requested information missing and marked incorrectly.
Me
Annual Reporting The Annual Reports document the following:
1. A summary of past year activities,including where applicable,specific
No ..�
quantities achieved and summaries of enforcement actions.
2. A description of the effectiveness of each program component. No ---
3. Planned activities and changes for the next reporting period,for each
program component or activity. No '--
NCS000485 Nashville MS4 Audit_20190719 Page 6 of 32
Program Implementation, Documentation & Assessment
4. Fiscal analysis. No
Comments
The annual reports have been submitted as required since the permit went into effect but with many of the requirements marked as
not applicable or with no response at all. The annual reports are used to assess the weakness and strengths of the program and the
lack of information each year is a clear indication that the program has not been implemented.
Additional The Town of Nashville needs to establish a structured way of funding the stormwater program and providing
Comments: sufficient staff that would be required to run a successful stormwater program.
The performance and effectiveness of the program should be evaluated annually to maintain and improve the
program and update it annually,or when significant changes have been made.Any significant changes should
be shared with the State and the Towns website should post those changes when they are made.That effort
should be documented.
The Town of Nashville(TON)should monitor all personnel using herbicide, pesticide and fertilizers that are
licensed and ensure that licenses are up to date.That should be documented.
The Town should develop and implement the six minimum control measures of the permit,to include action
steps,schedules, resources,and responsibilities for the plan.
The Town should document and maintain all components of the program in a way that can be accessed and
tracked by any new employees. Maintenance and inspections should be tracked thoroughly and in a way that
they can be easily tracked,and all problems,complaints and enforcement should be documented from
beginning to end (from discovery to resolution)while documenting all aspects of any action.This includes
how a situation was resolved and what was done to insure it doesn't happen again.
NCS000485 Nashville MS4 Audit 20190719 Page 7 of 32
Public Education and Outreach
Staff Interviewed: Lee Brown, Public Works Director
(Name,Title,Role) Walter Manning, Environmental Programs Superintendent
Permit Citation Program Requirement Status Supporting
Doc No.
11.8.2.a
Goals and The permittee defined goals and objectives of the Local Public Education and
No
objectives Outreach Program based on community wide issues. """
Comments
The Town of Nashville(TON) has not implemented a plan to define goals and objectives for educating the public and provide
outreach programs to aid with identifying community issues.
11.B.2.b The permittee maintained a description of the target pollutants and/or stressors and
Target Pollutants likely sources. No
Comments
Identify the Towns most dominant pollutants and provide a list of the sources that produce them.
II.B.2.c
The permittee identified,assessed annually,and updated the description of the
Target Audiences target audiences likely to have significant storm water impacts and why they were No
selected.
Comments
The Town has not identified, assessed annually,or updated the description of target audiences likely to have significant stormwater
impact.
NCS000485_Nashville MS4 Audit_20190719 Page 8 of 32
Public Education and Outreach
II.B.2.d Residential The permittee described issues,such as pollutants,the likely sources of those
and Industrial/ pollutants, potential impacts,and the physical attributes of stormwater runoff in
Commercial Issues their education/outreach program.
Comments
The pollutants and likely sources of pollutants and their potential impacts were not presented in any educational/outreach
programs.
II.B.2.e The permittee promoted and maintained an internet web site designed to convey the
Informational
program's message.
Web Site
Comments
The programs message has not been promoted on the Town's website.
II.B.2.f The permittee distributed stormwater educational material to appropriate target
Public Education Nr.
Materials groups.
Comments
The Town should develop educational materials for target groups and distribute those materials.The Town does have educational
flyers for fats,oils and grease that are handed out at some events.
II-13.2. The permittee promoted and maintained a stormwater hotline/helpline for the
Hotline/Help Line purpose of public education and outreach.
Comments
The Town doesn't have a hotline/helpline.
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.
NCS0004$5_Nashville MS4 Audit_20190719 Page 9 of 32
Public Education and Outreach
Public Education
and Outreach For each media,event or activity,including those elements implemented locally or
Program through a cooperative agreement the permittee estimated and recorded the extent No
of exposure.
Comments
There isn't an outreach program that includes a combination of approaches to reach target audiences,and they are not utilizing
Town events to distribute information.
Additional
Comments: The permittee should identify the most common stormwater issues and target pollutants along with their
sources to establish their objectives for educating and addressing the Town's stormwater concerns. By using
public comments and complaints and Town employee field observations,the Town can begin to identify
target audiences and pollutants to accomplish that goal.The Town should develop an outreach program that
would employ various methods of distributing educational material to include public and employee
hotline/helpline and informational webpages,that would begin to provide the permittee a way to reach the
various residential,commercial,and industrial communities the Town serves.
NCS000485_Nashville MS4 Audit_20190719 Page 10 of 32
Illicit Discharge Detection and Elimination (IDDE)
Staff Interviewed: lee Brown, Public Works Director
(Dame,Title, Walter Manning,Environmental Programs Superintendent
Role)
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. �ppllcable
Comments(Note any deficiencies)
The Elicit Discharge Detection and Elimination program (IDDE)was not implemented.
The permittee maintained an IDDE ordinance or other regulatory mechanism(s)that
No
II.D.2.b provides the legal authority to prohibit illicit connections and discharges to the MS4.
Legal Authorities If yes,the ordinance applies throughout the corporate limits of the permittee. Not
[Permit Part I-D] Applicable
Comments
The Town has not implemented a Town ordinance for IDDE.
II.D.2.c The permittee maintained a current map showing major outfalls*and receiving
Storm Sewer x
streams.
System Map
Comments
They have an only have an open ditches map within the Town Limits.
*Major outfalls are discharges from>36"diameter pipes or drainage areas of>So acres. In areas zoned for industrial activity,major outfalls
are>12"or drainage area>2 acres.
II.D.2.d
Dry Weather Flow The permittee maintained a program for conducting dry weather flow field
ry .
observations in accordance with written procedures.
Program
Comments
The Town has not performed any dry weather screening.
NCS000485_Nashville MS4 Audit_20190719 Page 11 of 32
Illicit Discharge Detection and Elimination (IDDE)
II.D.2.e
Investigation The permittee maintained written procedures for conducting investigations of No -
Procedures
identified illicit discharges.
Comments
The Town has not developed any illicit discharge procedures
II.D.2.f For each case of an illicit discharge or potential illicit discharge,the permittee documented and tracked the
Track and following:
Document
Investigations 1. The date(s)the illicit discharge was observed No
2. The results of the investigation No
3. Any follow-up of the investigation No
4. The date the investigation was closed No
Comments
The Town does not have any documentation of illicit discharges or potential illicit discharge
II.D.2.jt 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.
Comments
The training program was not implemented or documented.
II.D.2.h The permittee informed public employees of hazards associated with illegal
Public Education discharges and improper disposal of waste. Partial
The permittee informed businesses of hazards associated with illegal discharges and
Partial
improper disposal of waste.
The permittee informed the general public of hazards associated with illegal
discharges and improper disposal of waste. No
Comments
The permittee has not informed public employees,businesses or the general public of hazards associated with illegal
discharges.The permittee does have brochures for oil,grease
NCS000485_Nashville MS4 Audit 20190719 Page 12 of 32
Illicit Discharge Detection and Elimination (IDDE)
II.D.2.i The permittee promoted, publicized, and facilitated a reporting mechanism for the
Public Reporting public to report illicit discharges. No
Mechanism
The permittee promoted,publicized,and facilitated a reporting mechanism for staff
No
to report illicit discharges.
The permittee established and implemented response procedures for citizen
No
requests/reports.
Comments(Generally describe reporting mechanisms and how promoted/publicized/facilitated/established)
ll.Q.2.1 The permittee implemented a mechanism to track the issuance of notices of violation
Enforcement No
and enforcement actions administered by the permittee.
If yes,the mechanism includes the ability to identify chronic violators for
No
initiation of actions to reduce noncompliance.
Comments(Generally describe the established tracking mechanism,if applicable)
- They do not have an ordinance related to this in order to issue notices of violation.
Additional
Comments: The Town must develop and implement the required Illicit Discharge Detection and Elimination program
(IDDE)as required by the permit.This includes written procedures for conducting and identifying IDDE's with
certain information tracked and documented and the development of storm sewer map showing the location
of all major outfall within the Town limits. List all the waters of the State that receive runoff from those
discharges.
The Town is also required to provide for an ordinance that prohibits non-stormwater discharges, unless
allowed in the permit and implement a plan to detect and address non-stormwater discharges along with all
other requirements of this program.
The permittee should train all public employees,businesses and the general public of the hazards associated
with IDDE's with reporting mechanism,response procedures and enforcement procedures for serious or
chronic violators.
NCS000485 Nashville MS4 Audit 20190719 Page 13 of 32
Pollution Prevention and Good Housekeeping for Municipal Operations
Staff Interviewed: Lee Brown,Public Works Director
(Name,Title,Role) Walter Manning,Environmental Programs Superintendent
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.
Comments
The permittee should have a list of facilities and operations that have the potential for generating polluted stormwater runoff
II.G.2.b The permittee maintained and implemented an O&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 0&M program specifies the frequency of inspections. No
If yes,the O&M program specifies the frequency of routine maintenance
requirements. No
If yes,the permittee evaluated the 0&M program annually and updated it as Not
necessary. Applicable
Comments
The O&M plans were not implemented
II.G. .c
Spill Response The permittee had written spill response procedures for municipal operations. No
Procedures
Comments
No spill procedures were written for the municipal operations
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 partial
Parking Lots corporate limits annually.
Maintenance If yes,the permittee evaluated the effectiveness of existing and new BMPs
No
based on cost and the estimated quantity of pollutants removed.
NCS000485 Nashville MS4 Audit_20190719 Page 14 of 32
Pollution Prevention and Good Housekeeping for Municipal Operations
Comments
The Town documented the loads of street debris swept,in tons,that were taken to the municipal solid waste facility.
The Town did not document and use that information to evaluate future cost and effectiveness of that portion of the
program
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 N�
Basins and
maintains.
Conveyance Systems
Comments
The stormwater sewer system did not have a O&M program implemented
II.G.2.g 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.
Comments
The Town did not inventory municipal owned and operated stormwater controls for compliance with the post construction ordinance
and requirements
II.G.2.h The permittee maintained and implemented an O&M program for municipally-
O&M for Structural owned or maintained structural stormwater controls installed for compliance with
Stormwater Controls the permittee's post-construction ordinance. If yes,then:
The O&M program specified the frequency of inspections and routine y
maintenance requirements.
The permittee documented inspections of all municipally-owned or maintained
iY.
structural stormwater controls.
The permittee inspected all municipally-owned or maintained structural
stormwater controls in accordance with the schedule developed by permittee.
The permittee maintained all municipally-owned or maintained structural
stormwater controls in accordance with the schedule developed by permittee.
The permittee documented maintenance of all municipally owned or Y
maintained structural stormwater controls.
Comments
The Town does not have 0&M programs for municipal owned or maintained structural stormwater controls
II.G.2.1 The permittee ensured municipal employees are properly trained in pesticide,
herbicide and fertilizer application management.
NCS000485 Nashville MS4 Audit 20190719 Page 15 of 32
Pollution Prevention and Good Housekeeping for Municipal Operations
Pesticide,Herbicide The permittee ensured contractors are properly trained in pesticide,herbicide and
and Fertilizer fertilizer application management. Not
Application Applicable
Management
The permittee ensured all permits,certifications,and other measures for
applicators are followed. No
Comments
Town employees were licensed/certified for pesticide, herbicide and fertilizer application management.The permittee
does not have a documented procedure for tracking the license/certificates to insure they are up-to-date
II.G.2.j The permittee implemented an employee trainin p pg program for employees involved
Staff Training No
in implementing pollution prevention and good housekeeping practices.
Comments
A pollution prevention and good housekeeping program was not provided to employees involved with the implementation of
pollution prevention and good housekeeping practices.
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 No
Equipment Cleaning cleaning.
Comments
The municipal facility has an NCG080000 permit that is not being followed.The municipal facility that has the NCG080000 permit
could not find any of the information for the permit that was available at the 2017 MS4 audit
NCS000485_Nashville MS4 Audit_20190719 Page 16 of 32
Pollution Prevention and Good Housekeeping for Municipal Operations
Additional The permittee must maintain a list of facilities and operations owned by the permittee,along with"site
Comments: Specific"O&M plans for each,that have the potential to generate polluted stormwater runoff.inspection
frequency and routine maintenance frequency should be included in the O&M plan along with an
evaluation and updates of the plan done annually.Spill response procedures should be included at all
municipal operations
An evaluation of all existing and new BMP's for municipally owned streets,roads and parking lots should be
performed yearly and an O&M program for the stormwater conveyance system,including catch basins,
should be maintained.
The Town must maintain a current inventory of municipally owned and operated structural stormwater
controls,each with an O&M plan,installed for compliance with the permittees post construction
ordinance.The O&M plans should include documentation of inspection frequency,routine maintenance
schedules and maintenance provided for maintained structural stormwater controls.
All municipal employees and contractors must be properly trained in pesticide,herbicide and fertilizer
application and management and the Town must track and document license expiration dates to insure
they are up-to-date.The permittee also insures,through inspections and documentation,that all
application requirements of pesticide,herbicide and fertilizer,are followed
The permittee must evaluate existing and new BMP's to reduce polluted stormwater runoff and to help
evaluate future BMP needs,for coming years.Future maintenance and funding requirements can be
evaluated using this and other,documentation requirements
Town employees at all municipal facilities or with duties that may potentially generate or bring them in
contact with polluted stormwater runoff should be trained in pollution prevention and good housekeeping
on an annual basis.The training should be documented by a signature from each of the trainees.
The municipal facility is required by their NCGo80000 permit to take samples,provide training and maintain
records.The permit must be implemented
NCS000485_Nashville M54 Audit_20190719 Page 17 of 32
Site Visit Evaluation: Municipal Facility No. 1
Facility Name: Date and Time of Site Visit:
Public Works Operations Center 7/19/2023 1:00 pm
Facility Address: Facility Type(Vehicle Maintenance,Landscaping,etc.):
730 South Smith Street Equipment storage and maintenance.
Nashville, NC 27856
Name of MS4 inspector(s)evaluated: Most Recent MS4 Inspection(List date and name of inspector):
Walter Manning N/A
Name(s)and Title(s)of Facility Representative(s)Present During the Site Visit:
Name Title
Lee Brown Public Works Director
Walter Manning Environmental Programs Superintendent
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?
None.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive?Now often?
Certified Stormwater Compliance Professional-annually
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
No.
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
No.
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form?
No.
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.
NCS000485_Nashville MS4 Audit_20190719 Page 18 of 32
Site Visit Evaluation: Municipal Facility No. 1
Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge?
No.
Did the M54 inspector miss any obvious areas of concern?If so,explain:
No.
Does the M54 inspector's process include presenting the inspection findings to the facility contact?
No.
Inspection Results
There was no stormwater pollution prevention plan(SP3)at the facility and the employees have no stormwater training and
the MS4 Inspector hasn't done the required annual inspections and hasn't been trained on how to perform a MS4 inspection
The facility employees and the MS4 inspector need training for inspections and preventive maintenance and good housekeeping
Town should develop a site specific checklist for performing those inspections.
The SP3 was not developed and the program was not implemented
The facility has an NC608 permit that was active at the 2017 MS4 audit,is not being followed.The previous documentation with
SP3,Training and Inspections cannot be found and has not been followed.
We walked the facility with the supervisor&Town employees and found Oil and fuel leaks beneath equipment and machinery
on both concrete and exposed earth.An old waste oil tank with degraded secondary containment was also observed.
Corrective actions:
Remove contaminated soils from spills and properly contain and dispose of them in the appropriate waste facility.All
this should be documented as follows:where it was found/on what date,who found the spill/leak,how it was cleaned
up,with the date along with how much was removed,how it was stored,when it was disposed and which qualified
facility disposed of it.All this and more should be documented and kept in the SP3
- Clean up spills on concrete areas to prevent them from leaking off the concrete and into the soil and fixed the leaks. If it
takes time to fix the problem,then capture the leak and properly dispose of that material.
Provide a working secondary containment around the old waste oil tank or remove it from the site.
If compliance corrective actions were identified,what timeline for correction/follow-up was provided?
Immediate action was recommended.
Notes/Comments/Recommendations
The NCG08 permit for this facility should be in place with employee training completed and a stormwater management Plan
developed and implemented within 90 days
Develop and Implement the stormwater management plan
Re-established and implemented the requirements of the NCG08
NCS000485 Nashville M54 Audit 20190719 Page 19 of 32
Site Visit Evaluation: Municipal Facility No. 2
Facility Name: Date and Time of site Visit:
Facility Address: Facility Type(Vehicle Maintenance,Landscaping,etc.):
Name of MS4 inspector(s)evaluated: Most Recent MS4 Inspection(Date and Entity):
Name(s)and Title(s)of Facility Representative(s)Present During the Site Visit:
Name Title
Lee Brown Public Works Director
Walter Manning Environmental Programs Superintendent
Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan(SWPPP)or similar document?Is it facility-specific?
What type of stormwater training do facility employees receive?How often?
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive?How often?
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
Did the M54 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form?
Does the MS4 inspector's process include taking photos?
Does the MS4 inspector's process include reviewing the facility's SWPPP(or similar document)?
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Site Visit Evaluation: Municipal Facility No. 2
Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge?
Did the MS4 inspector miss any obvious areas of concern?If so,explain:
Does the MS4 inspector's process include presenting the inspection findings to the facility contact?
Inspection Results
Did the facility inspection result in any corrective actions to be implemented?If so,for what issue(s)?
If compliance corrective actions were identified,what timeline for correction/follow-up was provided?
Notes/Comments/Recommendations
NCS000485 Nashville MS4 Audit 20190719 Page 21 of 32
Site Visit Evaluation: MS4 Outfall No. 1
Outfall ID Number: Date and Time of Site Visit:
No ID provided/assigned. 7/19/2023 10:40 am
Outfall Location: Outfall Description(Pipe Material/Diameter,Culvert,etc.):
Laurel Springs Drive 48 inch Reinforced Concrete Pipe(RCP)with a rip rap wash pad.
Approximately two years old.
The smaller original pipe is still in{dace and functional.
Receiving Water: Is Flow Present?If So,Describe(Color,Approximate Flow Rate,
Peppermint Branch Sheen,Odor,Floatable/Debris,etc.):
Most Recent Outfall Inspection/Screening(Date):
No flow.
N/A
Days Since Last Rainfall: Inches:
Approximately 07/12/2023 Approximately
.5 inches
Name of MS4 Inspector(s)evaluated:
Walter Manning
Observations
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive?How often?
Web based training(The American Stormwater Institute)Onetime Certificate
Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations?
No MS4 stormwater outfall inspections have ever been done
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?
N/A
NCS000485_Nashville MS4 Audit_20190719 Page 22 of 32
Site Visit Evaluation: MS4 Outfall No. 1
Inspection Results
Did the outfall inspection result in any work orders or maintenance requests?If so,for what issue(s)?
No
Will a follow-up outfall inspection be conducted?If so,for what reason?
No
Notes/Comments/Recommendations
Get formal MS4 training for the inspection of stormwater outfalls
- Document the location of the pipe,the pipe size and pipe construction
- Inspect for cracks,compromises to the pipe structure, blockages,etc.
- Check the pH of the water and conductivity.
- Conduct a visual inspection and note any significant changes from the previous inspection.
NCS000485 Nashville MS4 Audit 20190719 Page 23 of 32
Site Visit Evaluation: MS4 Outfall No. 1
NCS000485_Nashville MS4 Audit_20190719 Page 24 of 32
Site Visit Evaluation: MS4 Outfall No. 2
Outfall ID Number: Date and Time of Site Visit:
Outfall location: Outfall Description(Pipe Material/Diameter,Culvert,etc.):
Receiving Water: Is Flow Present?if So,Describe(Color,Approximate Flow Rate,
Sheen,Odor,Floatables/Debris,etc.):
Most Recent Outfall Inspection/Screening(Date):
Days Since Last Rainfall: Inches:
Name of MS4 Inspector(s):
Observations
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive?How often?
Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations?
Inspection Procedures
Does the inspector's process include the use of a checklist or other standardized form?Obtain copy.
Does the inspector's process include taking photos?
Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues?If so,what were they?
NCS000485 Nashville MS4 Audit 20190719 Page 25 of 32
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)?
Will a follow-up outfall inspection be conducted?If so,for what reason?
Notes/Comments/Recommendations
IF
NCS000485_Nashville MS4 Audit_20190719 Page 26 of 32
Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1
Site Name: Date and Time of Site Visit:
SCM (Located behind Walmart along Eastern Ave) 7/19/2023 1:45 pm
Site Address: SCM Type:
1205 Eastern Ave, Nashville,NC 27856 Information not provided.
Most Recent M54 Inspection(Include Date and Entity):
N/A
Name of MS4 Inspector(s)evaluated: Most Recent MS4 Enforcement Activity(Include Date):
Walter Manning N/A
Name(s)and Title(s)of Site Representative(s)Present During the Site Visit:
Name Title
Lee Brown Public Works Director
Walter Manning Environmental Programs Superintendent
Observations
Site Documentation
Does the site have an operation and maintenance plan?
Ownership along with operation and maintenance is conducted by Walmart.
Does the site have records of annual inspections?Are they performed by a qualified individual?
No.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive?How often?
None.
Did the MS4 inspector appear knowledgeable about MS4 requirements for post-construction site runoff controls?
Certified Stormwater Compliance Professional—annually.
Did the MS4 inspector appear knowledgeable about post-construction BMPs(general purpose/function,components,O&M
requirements,etc.)?
No.
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form?What format?
No.
Does the MS4 inspector's process include taking photos?
No.
Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections?
No.
NCS000485 Nashville MS4 Audit 20190719 Page 27 of 32
Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1
Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge?
No.
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?
No.
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
Notes/Comments/Recommendations
Minor erosion was noted along Eastern Ave where there is a lack of ground cover.
Minor invasive species in the pond.There appears to be previous treatment of invasive species and vegetation
management.
NCS000485_Nashville M54 Audit_20190719 Page 28 of 32
Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 2
Site Name: Date and Time of Site Visit:
Site Address: SCM Type:
Most Recent M54 Inspection(include Date and Entity):
Name of MS4 Inspector(s)evaluated: Most Recent M54 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?
Does the site have records of annual inspections?Are they performed by a qualified individual?
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive?How often?
Did the MS4 inspector appear knowledgeable about MS4 requirements for post-construction site runoff controls?
Did the MS4 inspector appear knowledgeable about post-construction BMPs(general purpose/function,components,O&M
requirements,etc.)?
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form?what format?
Does the MS4 inspector's process include taking photos?
Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections?
NCS000485 Nashville MS4 Audit_20190719 Page 29 of 32
Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 2
Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge?
Did the M54 inspector miss any obvious operation and maintenance deficiencies?If so, explain:
Does the M54 inspector's process include presenting the inspection findings to the site contact in writing?
Compliance/Enforcement
What,if any,enforcement actions(verbal warnings, NOV,etc.)did the inspection result in?
If compliance issues were identified,what timeline for correction/follow-up was provided?
Notes/Comments/Recommendations
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APPENDIX A: SUPPORTING DOCUMENTS
NCS000485_Nashville MS4 Audit_20190719 Page 31 of 32
APPENDIX B: PHOTOGRAPH LOG
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