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HomeMy WebLinkAboutNCS000436_NOD and Audit Report_20230621 d_S TArEo- ROY COOPER - �P Governor 1� CO� ELIZABETH S.BISER �, •� Secretary DOUGLAS R.ANSEL NORTH CAROLINA Interim Director Environmental Quality i June 21,2023 CERTIFIED MAIL 7022 0410 0002 1249 5421 RETURN RECEIPT REQUESTED City of Thomasville Attn: Michael Brandt,City Manager Post Office Box 368 Thomasville, North Carolina 27361 Subject: NOTICE OF DEFICIENCY(NOD-2023-PC-0138) City of Thomasville NPDES MS4 Permit No.NCS000436 Davidson County Dear Mr.Brandt: On April 24,2023,staff from the North Carolina Department of Environmental Quality(DEQ)conducted a compliance audit of the subject National Pollutant Discharge Elimination System(NPDES)Municipal Separate Storm Sewer System(MS4) Permit. The audit identified minor deficiencies with the specific components of the MS4 permit that were reviewed,as provided in the attached DEQ MS4 Permit Compliance Audit Report. This report lists and describes the deficiencies with certain components of the MS4 permit,which constitutes a violation of the Clean Water Act and is grounds for enforcement action. In accordance with Part VI of the permit and DEQ policy,a new 5-year MS4 permit will be issued in response to the audit. As such,the permittee is required to complete the following actions: 1. Respond in writing within thirty(30)calendar days from the date of receipt of this notice to acknowledge these requirements and the intent to comply. 2. Develop a Stormwater Management Plan(SWMP)which details specific actions,measurable goals,and implementation timelines for the stormwater management program over the new 5-year permit term. The SWMP must be documented utilizing the DEQ Phase 11 MS4 SWMP Template. The permittee shall submit the SWMP to DEQ for review and comment within one hundred twenty(120)calendar days from the date of receipt of this letter. 3. Submit an NPDES MS4 permit application for whichever comes first: a. At least one hundred eighty(180)days prior to permit expiration, or b. Within thirty(30)days of receiving written DEQ concurrence that the submitted SWMP documents a compliant stormwater management program and the MS4 should submit the application including a signed Final Draft SWMP. A new 5-year NPDES MS4 permit will be public noticed along with the Draft Final SWMP. 4. Respond to comments on the Draft Final SWMP and submit a signed Final SWMP for DEQ approval and final permit issuance. The final DEQ-approved SWMP shall become an enforceable component of the NPDES MS4 permit and an Annual Self-Assessment Template that corresponds to the approved SWMP will be provided. North Carolina Department of Environmental Quality I Division of Energy.Mineral and Land Resources 512 North Salisbury Street 1 1612 Mail Service Center I Raleigh,North Carolina 2 76 9 9-1612 rvoAn,csaourw O 919.707.9200 City of Thomasville Notice of Deficiency June 21,2023 Page 2 of 2 Required documentation shall be submitted via e-mail to Isaiah.reedna,ncdenr.gov,or to: DEQ-DEMLR Stonnwater Program Attn: Isaiah Reed 1612 Mail Service Center Raleigh,NC 27699-1612 If the MS4 fails to meet the aforementioned requirements and/or submits a significantly noncompliant Draft SWMP, DEQ may proceed with enforcement. As is stated in Part V,Section A.1(c)of the permit: Under state law, a daily civil penalty of not more than twenty five thousand dollars ($25,000)per violation may be assessed against any person who violates or fails to act in accordance with the terms, conditions, or requirements of a permit[North Carolina General Statute 143-215.6A]. Please note that compliance with the requirements of this NOD and/or issuance of civil or criminal penalties levied by DEQ does not preclude the EPA from carrying out its own enforcement case against the permittee. Thank you for your attention to this matter. Should you have any questions,please contact the MS4 Program Coordinator at(828)296-4618 or at Isaiah.reed(a)ncdenr. oovv. Sincerely, Isaiah Reed,PE, SWQ,MS4CECI MS4 Program Coordinator North Carolina Department of Environmental Quality Enclosures: DEQ MS4 Program Audit Report(April 24,2023,City of Thomasville) CC: Tamera Eplin Tamera.eplinCalncderingov Daryl Poole Daryl.pooleRthomasville-nc.g_ov Phil Ross PRoss0awck.com Isaiah Reed Isaiah.Reeditncdenr.gov DEMLR MS4 Program Coordinator DEMLR NPDES MS4 Permit Laserfiche File i i i MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) PROGRAM AUDIT REPORT NPDES PERMIT NO. NCS000436 i THOMASVILLE, NORTH CAROLINA 525 Turner Street. Audit Date: April 24, 2023 Report Date: June 21, 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 (This page intentionally left blank) NCS000436 Thomasville MS4 Audit 20230424 i 1 TABLE OF CONTENTS AuditDetails..................................................................................................................................................1 PermitteeInformation ..................................................................................................................................2 Listof Supporting Documents.......................................................................................................................3 Program Implementation, Documentation &Assessment...........................................................................4 PublicEducation and Outreach.....................................................................................................................7 Public Involvement and Participation...........................................................................................................8 Illicit Discharge Detection and Elimination (IDDE)........................................................................................9 Pollution Prevention and Good Housekeeping for Municipal Operations..................................................11 Site Visit Evaluation: Municipal Facility No. 1.............................................................................................13 Site Visit Evaluation: Municipal Facility No. 2.............................................................................................14 Site Visit Evaluation: MS4 Outfall No. 1......................................................................................................15 Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1............................................16 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. NCS000436 Thomasville MS4 Audit 20230424 ii This page intentionally left blank NCS000436 Thomasville MS4 Audit 20230424 iii Audit Details Audit ID Number: Audit Date(s): NCS000436—Thomasville MS4 Audit_20230424 April 24,2023 Minimum Control Measures Evaluated: N Program Implementation, Documentation &Assessment N Public Education&Outreach N 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 ❑ Post-Construction Site Runoff Controls N Pollution Prevention and Good Housekeeping for Municipal Operations ❑ Total Maximum Daily Loads(TMDIs) Field Site Visits: N Municipal Facilities. Number visited:2 N MS4Outfalls. Number visited: 1 ❑ Construction Sites. Number visited:Choose an item. N Post-Construction Stormwater Runoff Controls.Number visited:Choose an item. ❑ Other: Number visited:Choose an item. ❑ Other: Number visited:Choose an item. Inspector(s)Conducting Audit Name.Title Orsanization Isaiah Reed, Environmental Engineer NCDEQ Audit Rep Date:::L:w-o /J Signature (P/'? ( Audit Report Author: Date: Signature NCS000436—Thomasville MS4 Audit_20230424 Page 1 of 16 Permittee Information M54 Permittee Name: Permit Effective Date: Permit Expiration Date: City of Thomasville 2/20/2017 2/19/2022 Mailing Address: Date of Last M54Inspection/Audit: Post Office Box 368 3/25/2014 Thomasville, NC 27361 Co-permittee(s),if applicable: N/A Permit Owner of Record: Michael M. Brandt, City Manager Primary M54 Representatives Participating in Audit Name,Title Organization Daryl Poole, Public Works Director City of Thomasville Phil Ross AWCK Josh Johnson AWCK Danica Heflin, Environmental Coordinator Piedmont Triad Regional/Stormwater Smart M54 Receiving Waters Waterbodv Classification Impairments North Hamby Creek C Impaired Hanks Branch C None known Hunts Fork C Impaired Jimmys Creek C None known Kennedy Mill Creek C None known NCS000436_Thomasville MS4 Audit_20230424 Page 2 of 16 i I List of Supporting Documents Item When Provided j Document Title Number (Prior to/During/After) 1 Annual Report After 2 Last Approved SWMP After 3 Agreement between AWCK and Thomasville After 4 Written IDDE Program After 5 PTRC Activity Report After 6 PTRC Outreach Material After 7 PTRC Agreement During 8 Initial PTRC Agreement After 9 PTRC Annual Report After I 10 Stormwater Ordinance After 11 Outfall Map Screenshot After 12 List of Major Outfalls After 13 Sign In Sheet for stormwater training After 14 Inventory of Municipal Facilities During 15 Municipal Facilities 0&M Plan After 16 Spill Response Poster After 17 Inventory of SCMs During 18 O&M Plan After 19 Applicator License During NCS000436_Thomasville M54 Audit_20230424 Page 3 of 16 Program Implementation, Documentation &Assessment Staff Interviewed: Daryl Poole,Public Works Director (Name,Title,Role) Josh Johnson,AWCK Phil Ross,AWCK 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. Yes 1 Funding The Stormwater Plan identifies a specific position(s) responsible for the overall yes 2 coordination,implementation,and revision to the Plan. Responsibilities for all components of the Stormwater Plan are documented and yes 2 position(s)assignments provided. The permittee is current on payment of invoiced administering and compliance yes BIMS monitoring fees(see stormwater e-payments on DEMLR MS4 web page). SW fee of$1 per month.$114,627 in 2022. No fulltime SW staff.AWCK contracted to assist with program implementation.AWCK do field inspections and paperwork. II.A.2 Stormwater The permittee evaluated the performance and effectiveness of the program Not Plan components at least annually. Reviewed 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 No applicable water quality standard? If yes,did the permittee expand or better tailor its BMPs accordingly to address Not the non-attainment? Applicable II.A.3 Keeping the The permittee kept the Stormwater Plan up to date. Yes 2 Stormwater Plan Up to Date The permittee notified DEMLR of any updates to the Stormwater Plan. No --- No updates submitted between 2017 to 2023 Permit renewal. II.A.4 Availability The permittee kept an up-to-date version of its Stormwater Plan available to the of the Stormwater Division and the public online. No --- Plan The online materials included ordinances, or other regulatory mechanisms, or a list identifying the ordinances,or other regulatory mechanisms, providing the legal Partial --- authority necessary to implement and enforce the requirements of the permit. No Stormwater page on the website. NCS000436_Thomasville MS4 Audit_20230424 Page 4 of 16 i Program Implementation, Documentation & Assessment II.A.3&II.A.S j 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 I 11.A.6 Sharing Responsibility Are any control measures implemented by an entity otherthan the permittee? Yes 3,7 j If yes, is there a written agreement in place? Yes 3,7 202112022 Agreement.Review agreement language. II.A.7 The permittee maintained written procedures for implementing the six minimum partial 4 Written control measures. Procedures Written procedures identified specific action steps,schedules, resources and Partial 4 responsibilities for implementing the six minimum measures. IDDE Written Program(dated).Public Outreach.Post-Construction. III_A The permittee maintained documentation of all program components including,but Program not limited to, inspections, maintenance activities,educational programs, Not Reviewed Documentation implementation of BMPs,enforcement actions etc., on file for a period of five years. 111.131 The permittee submitted annual reports to the Department within twelve months Not Annual Report from the effective date of the permit(See Section 111.B.for the annual reporting Reviewed Submittal period specific to this MS4). The permittee submitted subsequent annual reports every twelve months from the Not scheduled date of the first annual report submittal. Reviewed The Annual Reports included appropriate information to accurately describe the progress,status,and results of the permittee's Stormwater Plan, including, but not limited the following: 1. A detailed description of the status of implementation of the Stormwater Plan as a whole.This will include information on development and implementation Not of each major component of the Stormwater Plan for the past year and Reviewed schedules and plans for the year following each report. 2. An adequate description and justification of any proposed changes to the Stormwater Plan.This will include descriptions and supporting information for Not the proposed changes and how these changes will impact the Stormwater Reviewed Plan(results,effectiveness, implementation schedule, etc.). 3. Documentation of any necessary changes to programs or practices for assessment of management measures implemented through the Stormwater Not Reviewed 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 Not Reviewed Stormwater Plan. 5. An assessment of compliance with the permit, information on the establishment of appropriate legal authorities, inspections,and enforcement Not Reviewed actions. NCS000436_Thomasville MS4 Audit_20230424 Page 5 of 16 Program Implementation, Documentation &Assessment IV.B Annual Reporting The Annual Reports document the following: 1. A summary of past year activities,including where applicable,specific Not quantities achieved and summaries of enforcement actions. Reviewed 2. A description of the effectiveness of each program component. Not Reviewed 3. Planned activities and changes for the next reporting period,for each Not program component or activity. Reviewed 4. Fiscal analysis. Not Reviewed Annual Reports not reviewed during the audit. NC5000436_Thomasville M54 Audit_20230424 Page 6 of 16 i i Public Education and Outreach Staff Interviewed: Daryl Poole,Public Works Director (Name,Title,Role) Josh Johnson,AWCK Phil Ross,AWCK f Danica Heflin,Piedmont Triad Regional/Stormwater Smart Permit Citation Program Requirement Status supporting Doc No. 11.B.2.a The permittee defined goals and objectives of the Local Public Education and Goals and Yes 5 Objectives Outreach Program based on community wide issues. Goals and objectives outlined in compliance report document provided by PTRC. 11.B.2.b The permittee maintained a description of the target pollutants and/or stressors and Yes 5 Target Pollutants likely sources. I Target pollutants identified in PTRC report and outreach material. II.B.2.c The permittee identified, assessed annually and updated the description of the target No --- Target Audiences audiences likely to have significant storm water impacts and why they were selected. Regular evaluation of target audience not documented. 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 Yes 5 Commercial Issues their education/outreach program. 11.B.2.e The permittee promoted and maintained an internet web site designed to convey the Informational No --- Web Site program's message. City webpage does not currently link to PTRC page. 11.B.2.f The permittee distributed stormwater educational material to appropriate target Public Education Partial --- Materials groups. Outreach material distribution methods are for general public with no directed outreach documented. Hotli.a The permittee promoted and maintained a stormwater hotline/helpline for the Hotline/Help Line purpose of public education and outreach. ves 6 Hotline to PTRC is in outreach material. 11.B.2.h The permittee's outreach program,including those elements implemented locally or Public Education through a cooperative agreement, included a combination of approaches designed to Yes 6 and Outreach reach the target audiences. Program For each media,event or activity, including those elements implemented locally or through a cooperative agreement the permittee estimated and recorded the extent Yes 9 of exposure. NCS000436_Thomasville MS4 Audit_20230424 Page 7 of 16 t Public Involvement and Participation Staff Interviewed: Daryl Poole,Public Works Director (Name,Title,Role) Josh Johnson,AWCK Phil Ross,AWCK Danica Heflin,Piedmont Triad Regional/Stormwater Smart Permit Citation Program Requirement Status supporting Doc No. II.C.2.a Volunteer Community The permittee included and promoted volunteer opportunities designed to promote Yes Involvement ongoing citizen participation. S Program Volunteer opportunities during Covid. Litter Sweeps(semi-annually). Participation.Clothing swap(prevents problematic disposal practices).Seed packet distribution(no participation tracked).Adopt a street program. II.C.2.b Mechanism for The permittee provided and promoted a mechanism for public involvement that Yes 1 Public provides for input on Stormwater issues and the Stormwater program. Involvement Public Services Comity(monthly). Once per permit cycle they do a publicized stormwater public input meeting(once per permit cycle). II.C.2.c The permittee promoted and maintained a hotline/helpline for the purpose of public Partial -- Hotline/Help Line involvement and participation. The phone number is listed in the outreach material. NCS000436_Thomasville MS4 Audit_20230424 Page 8 of 16 i I I Illicit Discharge Detection and Elimination (IDDE) Staff Interviewed: Daryl Poole,Public Works Director (Name,Title, Josh Johnson,AWCK Role) Phil Ross,AWCK Permit Citation Program Requirement Status supporting Doc No. II.D.2.a IDDE Program The permittee maintained a written IDDE Program. Yes 4 If yes,the written program includes provisions for program assessment and Yes 4 evaluation and integrating program. Written program provided during the audit. The permittee maintained an IDDE ordinance or other regulatory mechanism(s)that Yes 10 II.D.2.b provides the legal authority to prohibit illicit connections and discharges to the M54. Legal Authorities If yes,the ordinance applies throughout the corporate limits of the permittee. Yes 10 [Permit Part I.D] No NOVs issued yet.No NOV Template available. II.D.2.c The permittee maintained a current map showing major outfalls*and receiving Storm Sewer Yes 11 System Map streams. Outfall screening spreadsheet presented during the audit. II.D.2.d The permittee maintained a program for conducting dry weather flow field Dry Weather Flow Yes 4 observations in accordance with written procedures. Program Written program does not specify outfall inspection numbers or percentage. II.D.2.e The permittee maintained written procedures for conducting investigations of Investigation ves 4 Procedures identified illicit discharges. AWCK perform dry-weather screening.City of Thomasville would issue the NOV. 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 Not --- Reviewed 2. The results of the investigation Not Reviewed 3. Any follow-up of the investigation Not Reviewed 4. The date the investigation was closed Not Reviewed II.D.2.1;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 13 and 4 contact with or otherwise observe an illicit discharge or illicit connection. Virtual training for Public Works and Utilities.Annually for City staff. More participation with virtual program. NC5000436_Thomasville M54 Audit_20230424 Page 9 of 16 Illicit Discharge Detection and Elimination (IDDE) II.D.2.h The permittee informed public employees of hazards associated with illegal Public Education Yes 14 and 4 discharges and improper disposal of waste. The permittee informed businesses of hazards associated with illegal discharges and yes 6 improper disposal of waste. The permittee informed the general public of hazards associated with illegal Yes 6 discharges and improper disposal of waste. II.D.2.i The permittee promoted, publicized,and facilitated a reporting mechanism for the Public Reporting Partial Website public to report illicit discharges. Mechanism The permittee promoted, publicized,and facilitated a reporting mechanism for staff yes 14 to report illicit discharges. The permittee established and implemented response procedures for citizen Partial 2 requests/reports. IDDE reporting mechanism on website experiencing problems. II.D.2.1 The permittee implemented a mechanism to track the issuance of notices of violation Not Enforcement and enforcement actions administered by the permittee. Applicable ___ If yes,the mechanism includes the ability to identify chronic violators for Not initiation of actions to reduce noncompliance. Applicable NCS000436_Thomasville M54 Audit_20230424 Page 10 of 16 i Pollution Prevention and Good Housekeeping for Municipal Operations Staff Interviewed: Daryl Poole,Public Works Director (Name,Title, Role) Josh Johnson,AWCK I Phil Ross,AWCK j 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 Yes 14 stormwater runoff. List provided during the audit. 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 Yes 15 Maintenance(O&M) stormwater runoff. for Facilities If yes,the 0&M program specifies the frequency of inspections. Yes 15 If yes,the 0&M program specifies the frequency of routine maintenance Yes 15 requirements. If yes,the permittee evaluated the 0&M program annually and updated it as No 15 necessary. I Plan not review and updated annually. II.G.2.c Spill Response 7Thermittee had written spill response procedures for municipal operations. Yes 16 Procedures Spill response posters posted at all high priority facilities. II.G.2.d Streets, The permittee evaluated existing and new BMPs that reduce polluted stormwater Roads,and Public unoff from municipally-owned streets, roads, and public parking lots within its No -- Parking Lots corporate limits annually. Maintenance If yes,the permittee evaluated the effectiveness of existing and new BMPs No --- based on cost and the estimated quantity of pollutants removed. So SOP or O&M Plan outlining the street cleaning and parking lot cleaning processes. II.G.2.f The permittee maintained and implemented an 0&M program for the stormwater O&M for Catch sewer system including catch basins and conveyance systems that it owns and No --- Basins and maintains. Conveyance Systems No O&M Plan exists for Thomasville. II.G.2.e The permittee maintained a current inventory of municipally-owned or operated Structural structural stormwater controls installed for compliance with the permittee's post- Yes 17 Stormwater Controls construction ordinance. Inventory of 1. NC5000436 Thomasville M54 Audit 20230424 Page 11 of 16 i Pollution Prevention and Good Housekeeping for Municipal Operations 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 Yes 18 Stormwater Controls the permittee's post-construction ordinance. If yes,then: The O&M program specified the frequency of inspections and routine Not maintenance requirements. Reviewed The permittee documented inspections of all municipally-owned or maintained Not structural stormwater controls. Reviewed The permittee inspected all municipally-owned or maintained structural Not stormwater controls in accordance with the schedule developed by permittee. Reviewed --- The permittee maintained all municipally-owned or maintained structural Not stormwater controls in accordance with the schedule developed by permittee. Reviewed The permittee documented maintenance of all municipally-owned or Not maintained structural stormwater controls. Reviewed II.G.2.i The permittee ensured municipal employees are properly trained in pesticide, Pesticide,Herbicide herbicide and fertilizer application management. Yes 19 and Fertilizer Application The permittee ensured contractors are properly trained in pesticide, herbicide and Not Management fertilizer application management. Applicable The permittee ensured all permits,certifications, and other measures for Yes 19 applicators are followed. Estimates using 30 gallons of roundup a year.Just Herbicides. 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 13 Pollution prevention and good housekeeping training given during the IDDE training. 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 partial --- Equipment Cleaning cleaning. Cleaning bays used for washing vehicles at Public Works.No SOP for vehicle washing. NCS000436_Thomasville MS4 Audit_20230424 Page 12 of 16 i I I Site Visit Evaluation: Municipal Facility No. 1 Facility Name: Date and Time of Site Visit: Thomasville Wastewater Treatment Plant April 25,2023 10am Facility Address: Facility Type(Vehicle Maintenance, Landscaping,etc.): j 110 Optimist Park Road WWTP Name of M54 inspector(s)evaluated: Most Recent MS4 Inspection(List date and name of inspector): Phil Ross April 17,2023 Name(s)and Title(s)of Facility Representative(s) Present During the Site Visit: Name Title Allen Beck Operator Observations Facility Documentation/Training Does the facility have a Stormwater Pollution Prevention Plan(SWPPP)or similar document?Is it facility-specific? Yes. What type of stormwater training do facility employees receive?How often? Annual Stormwater Training. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive?How often? Stormwater Training every 2 years. Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? Yes. Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping? Yes. Inspection Procedures Does the M54 inspector's process include the use of a checklist or other standardized form? Yes. Does the M54 inspector's process include taking photos? Yes. Does the MS4 inspector's process include reviewing the facility's SWPPP(or similar document)? Yes. Does the M54 inspector's process include walking the entire facility and inspecting all points of discharge? Yes. Did the MS4 inspector miss any obvious areas of concern? If so,explain: No. Does the M54 inspector's process include presenting the inspection findings to the facility contact? Yes. NCS000436_ThomasviIle M54 Audit_20230424 Page 13 of 16 Site Visit Evaluation: Municipal Facility No. 2 Facility Name: Date of Site Visit: Public Works April 25,2023 Facility Address: Facility Type(Vehicle Maintenance,Landscaping,etc.): 525 Turner Street Public Works Name of MS4 inspector(s)evaluated: Most Recent MS4 Inspection(Date and Entity): Phil Ross November 9.2022 Name(s)and Title(s)of Facility Representative(s) Present During the Site Visit: Name Title Daryl Poole Public Work Director Observations Facility Documentation/Training Does the facility have a Stormwater Pollution Prevention Plan (SWPPP)or similar document? Is it facility-specific? Yes. What type of stormwater training do facility employees receive?How often? Annual Stormwater Training. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Stormwater Training every 2 years. Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? Yes. Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping? Yes. Inspection Procedures Does the MS4 inspector's process include the use of a checklist or other standardized form? Yes. Does the MS4 inspector's process include taking photos? Yes. Does the MS4 inspector's process include reviewing the facility's SWPPP(or similar document)? Yes. Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge? Yes. Did the 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? Yes. NC5000436_Thomasville MS4 Audit_20230424 Page 14 of 16 i Site Visit Evaluation: MS4 Outfall No. 1 Outfall ID Number: Date of Site Visit: No Identifier April 25,2023 Outfall Location: Outfall Description(Pipe Material/Diameter,Culvert,etc.): 110 Optimist Park Road CMP 36" I Receiving Water: Is Flow Present?If So, Describe(Color,Approximate Flow Rate, Not Reviewed Sheen,Odor,Floatables/Debris,etc.): No Most Recent Outfall Inspection/Screening(Date): April 17,2023 Days Since Last Rainfall: Inches: Not evaluated N/A Name of MS4lnspector(s)evaluated: Phil Ross Observations Inspector Training/Knowledge What type of stormwater training does the M54 inspector receive? How often? Yes,Stormwater Training every 2 years. 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? Yes. Does the inspector's process include taking photos? Yes. Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues?If so,what were they? No. 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? Yes,Routine. NC5000436_Thomasville M54 Audit_20230424 Page 15 of 16 f Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1 Site Name: Date and Time of Site Visit: Sheetz and Mod Wash SCM April 25,2023 Site Address: SCM Type: 1810 Liberty Drive Bio Retention Most Recent MS4 Inspection(Include Date and Entity): April 17,2023 Name of MS4 Inspector(s)evaluated: Most Recent MS4 Enforcement Activity(Include Date): Phil Ross N/A Name(s)and Title(s)of Site Representative(s)Present During the Site Visit: Name Title None Observations Site Documentation Does the site have an operation and maintenance plan? Yes. Does the site have records of annual inspections?Are they performed by a qualified individual? No records review conducted on site. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive?How often? Stormwater Training every 2 years. Did the MS4 inspector appear knowledgeable about 1VIS4 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. Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections? Yes. Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge? Yes. Did the MS4 inspector miss any obvious 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? Not Evaluated. Compliance/Enforcement What, if any,enforcement actions(verbal warnings, NOV,etc.) did the inspection result in? None. NCS000436_Thomasville MS4 Audit_20230424 Page 16 of 16