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
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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
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MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM AUDIT REPORT
NPDES PERMIT NO. NCS000436
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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
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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
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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
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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
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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
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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
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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
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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.
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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
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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
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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
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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
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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
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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
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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"
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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
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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