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Home My WebLink AboutNCS000402_Audit Report_20180131_Mebane_20180206LV Energy. Mineral & Land Resources ENVIRONMENTAL QUALITY February 6, 2018 Montrena Hadley, Planning Officer City of Mebane 102 S. Fifth Street Mebane, NC 27302 Subject: MS4 Compliance Evaluation City of Mebane Permit No. NCS000402 Dear Ms. Hadley: ROY COOPER Governor MICHAEL S. REGAN .SecrelmV WILLIAM E. (TOBY) VINSON, JR. Interim Director The North Carolina Department of Environment Quality (NCDEQ), Division of Energy, Mineral and Land Resources (DEMLR), conducted a Municipal Separate Storm Sewer System (MS4) Compliance Evaluation of the City of Mebane on January 31, 2018. The compliance evaluation is conducted to evaluate the City's compliance with the requirements of Section 402(p) of the Clean Water Act (CWA), 33 U.S.C. § 1342(p), the regulations promulgated there under at 40 Code of Federal Regulations Part 122.26, and the North Carolina National Pollutant Discharge Elimination System (NPDES) Permit No. NCS000402. I appreciate the staff willingness to work with DEQ during the compliance evaluation. Attached is the inspection report. Overall, the staff should be commended on the initiatives they've taken to managing stormwater under the conditions of the City's permit. If you have any questions concerning this matter please feel free to contact me at (919) 807- 6369 or robert.patterson@ncdenr.gov. Sincerely, Robert D. Patterson, PE Environmental Engineer Stormwater Program ec: Chris Rollins - Mebane Kyle Smith, PE - AWCK NCS000402 File Winston-Salem Regional Office Rachel Hart — EPA Region 4 State of North Carolina Environmental Quality I Energy, Mineral and Land Resources 512 N. Salisbury Street 11612 Mail Service Center I Raleigh, North Carolina 27699-1612 9t9 707 9200 NCDEQ MS4 Audit Overview The North Carolina Department of Environment Quality (NCDEQ), Division of energy Mineral and Land Resources (DEMLR), conducted a Municipal Separate Storm Sewer System (MS4) Compliance Evaluation of the City of Mebane on January 31, 2018. The compliance evaluation is conducted to evaluate the City's compliance with the requirements of Section 402(p) of the Clean Water Act (CWA), 33 U.S.C. § 1342(p), the regulations promulgated there under at 40 Code of Federal Regulations Part 122.26, and the North Carolina National Pollutant Discharge Elimination System (NPDES) Permit No. NCS000402. We appreciate the staff's willingness to work with DEQ during the compliance evaluation. DEQ Stormwater Compliance Evaluation Team • See attached agenda City of Mebane Staff • See attached agenda Purpose of the Compliance Evaluation The purpose of the Compliance Evaluation was for training, routine program compliance evaluation, stronger coordination and working relationship with the State and regulated entity, provide a better understanding of the state's expectations, provide an opportunity to clarify any misunderstandings, improved State's knowledge of the City's stormwater program, and to facilitate a more effective program. Contract Operations/Partnerships Alley, Williams, Carmen & King, Inc. (AWCK) — overall stormwater program implementation Piedmont Triad Regional Council — Public Education & Outreach and Public Involvement & Participation NCDEQ-DEMLR Winston-Salem Regional Office — Construction Stormwater Runoff Sites Visited • See attached agenda — compliant with permit Documents Reviewed ✓ Permit ✓ Current Stormwater Management Program ✓ 2016 Annual Report ✓ Inventory of public operations and/or activities ✓ Inspection procedures/checklist for public operations and/or activities ✓ Inspection records ✓ Staff training records ✓ Educational materials ✓ Stormwater Ordinance ✓ SCM Inventory ✓ IDDE records January 31, 2018 Mebane Audit Page 1 of 2 NCDEQ MS4 Audit POSITIVE FINDINGS Positive Findings are initiatives staff has taken to establish and maintain a sustainable program to maintain compliance and to strengthen its programs including 1) a commitment to sustainability, 2) continuing to be engaged and collaborate with regulatory agencies, stake holders, other departments and citizen's groups, 3) a strong commitment to Asset Management including identifying assets, tracking levels of service, and performing inspection and maintenance of assets, 4) identifying program requirements, records management, written policies, standard operating procedures, checklists, 5) regular program assessments and 6) continual process improvement. The public works facility was very well managed to reduce or eliminate potential pollutant exposure to stormwater. The City owned post - construction SCMs visited at the fire station were well maintained. VIOLATIONS Violations of the Clean Water Act and is grounds for enforcement action; for permit termination, revocation and reissuance, or modification; or denial of permit coverage upon renewal application. • No conditions of violation were noted. NON-COMPLIANCE Findings that could result in a Notice of Violation, a fine or other enforcement action if corrective action is not taken. • No conditions of non-compliance were noted. DEFICIENCIES Finding that is a result of poor management practices, failure to follow Standard Operating Procedures, or minor differences of interpretation or administration oversights. Findings identified as a deficiency would not likely cause a Notice of Violation, a fine, or other enforcement action. 1. Develop a process to better document public involvement events and initiatives. 2. Two solid waste dumpsters at the public works yard were not labeled; and should be covered to minimized pollutant exposure to stormwater. DISCREPANCIES Findings where compliance could not be determined at the time of the audit. • No discrepancies were noted. RECOMMENDATIONS Recommendations should be considered to improve the overall stormwater program. 1. Consider participating in the MS6 program. January 31, 2018 Mebane Audit Page 2 of 2 e6aite Positively Charming NPDES MS4 Stormwater Permit Audit Agenda January 31, 2018 • Attendees: o City of Mebane ■ Chris Rollins, Assistant City Manager ■ Wayne Pore, Public Works Director ■ Cy Stober, Development Director ■ Montrena Hadley, Planning officer ■ Franz Holt, City Engineer ■ Kyle Smith, Assistant City Engineer ■ Josh Johnson, Stormwater Engineer ■ Lindsey Lengyel, Stormwater Smart Educator o NC DEM LR Stormwater Program ■ Robert Patterson, Environmental Engineer • Agenda: a Introductions o Background o Stormwater Program Discussion ■ Post Construction Development ■ Watershed Protection ■ Construction Site Runoff Controls. ■ Riparian Buffer Protection ■ Public Education ■ Public Involvement o Lunch o Stormwater Program Discussion (Continued) ■ Illicit Discharge Detection and Elimination ■ Pollution Prevention and Good Housekeeping o Site Visits ■ Public Works ■ Assorted Post Construction Stormwater Control Measures o Wrap Up (City Hall or at site) CITY OF MEBANE 106 E. Washineton StJ Mebane. NC 27302 0 919 563 5901 919 563 9506 City of Mebane NPDES Phase II Stoirmwater Program January 31, 2017 Alley, Williams, Carmen, and King, Inc. • Introductions and Roles • Background • Stormwater Program Overview • Specific Programs • Post Construction Development. • Watershed Protection. • Construction Site Runoff Controls. • Riparian Buffers. • Public Education. • Public Involvement. • Lunch • Illicit Discharge Detection and Elimination. • Pollution Prevention & Good Housekeeping. • Site Visits. • Wrap -Up Phase II Post -Construction • Does not apply to projects disturbing less than 1 acre. • Low Density Projects • 24% or less built upon area • 30' Buffer for perennial and Rules take precedence) • High Density Projects or no more than 2 dwelling units per acre intermittent surface waters (Jordan Lake • Greater than 24% built upon area or more than 2 dwelling units per acre • Treat the runoff from the first one inch of rain (First Flush) • Discharge treated water at a rate <_ pre -development rate for the yr - 24 hour Storm • Discharge treated water between 48-120 hours • Achieve 85% average annual removal of total suspended solids • 30' Buffer for perennial and intermittent surface waters. (Jordan Lake Rules take precedence) Stormwater Post Construction • Process Overview. • Stormwater Administrative Manual. • Overall Map of SCM's. • Overall List of SCM's. • Property Owner responsible for maintenance &inspection. • Storm Drainage Design Manual. • All projects, regardless of size. Structural BMP's . - r in Mebane} •r . - v P — x.K- 72"7' '�•�r'+"'� _ Ashbury Pond .w ..,. WSW _ � � � 'Y-�'+" - ..{mac,• L ' r T3 . ,T•,. r•jL, � �'1.1'i•['i '.:A 0 �� ..�+L .• Gip" � r. ; � 1'y ~! •''.{L � 'ro-�'k�,^ � , ti •r �.a: .b Y��R. -• �' �tw _. to �'. - � � _ - e 8y. . y �, r'�p,L�} : _. �� .. - '� �• Southern Season V. MFD Food Lion - WSW R. Pond Bioretention ,: Basin Watershed Protection • Process Overview. • Incorporated into Phase 2 Process. •Different standards. • BUA Calculation must be done for both Phase 2 and WSW. • Grandfathering is totally different. • No minimum disturbance. • City responsible for inspections, Property Owner responsible for maintenance. Construction Site Stormwater Runoff • Regulated through NC DEQ's Erosion Control Program or through a locally delegated Erosion Control Program. Riparian Buffer Protection • Jordan Lake Buffers. • The first 30' along all streams is to remain in a natural state, from 30'-50' from the stream is to remain vegetated. • Uses inside of the buffer are highly regulated. • Existing uses are exempt unless the use is changed. • Applies to USGS and NRCS Soil Survey Maps. • Buffer rule applies to all new development projects &existing development sites. • SWITC. • Process of Review. • Buffer Authorizations. a Ir * +AL -0 dlW i { qL } f Zone managed ; vegetation i r Zone undisturbed rest vegetation Stream or Pond r • so ' Riparian Buffers Can: • Protect stream structure • Enhance the aquatic environment • Reduce sediment and phosphorus from surface runoff • Reduce nitrate -nitrogen from groundwater before it discharges to the stream • Overall, research indicates most buffer functions approach a maximum at or above 100 feet and start to diminish at different rates as buffers widths get more narrow* • Reduction in the 50 ft. width requirement could significantly reduce the effectiveness in N removal (less treatment area) and sediment removal (particularly on lands with higher slopes).* *According to research published by NC State University Rainfall ti.. Public Education and Outreach Public Involvement and Participation • Stormwater SMART, program within Piedmont Triad Regional Council :} ..o te School "presentations areLorin F60 ' • Civic groups A Fairs and festivals Libraries Public meetings • Enviroscape • Rain garden in a bottle • The incredible journey • Macroinvertebrate mayhem • Water quality, ask the bugs! • Soil splash • Public Education Plan — Reviewed Annually What is an Illicit Discharge? An illicit discharge is any discharge within an MS4 permitted municipality that is not entirely composed of stormwater, excluding permitted discharges and fire fighting related discharges. 1RdzcC1E: iia P repo � i ��cl�on I Correct Ouianection Illicit Discharge Detection and Elimination • Program Overview • Ordinance • Mapping in first permit cycle. • Ongoing Streamwalks • Training • N OV's • Reported • SSO's • Public Education • Stormwater doesn't go to WWTR Permitted Discharges • Waterline flushing • Landscape irrigation • Diverted stream flows • Rising ground waters • Uncontaminated ground water infiltration (as defined at 40 CFR 35.2005(20)) • Uncontaminated pumped ground water • Discharges from potable water sources • Foundation drains • Air conditioning condensation • Flows from emergency fire fighting • Springs • Footing drains • Water from crawl space pumps • Lawn watering • Individual residential car washing • Flows from riparian habitats and wetlands • Dechlorinated swimming pool discharges • Street wash water • Other non-stormwater discharges for which a valid NPDES discharge permit has been approved and issued by the State of North Carolina and provided that any such discharges to the municipal separate storm sewer system shall be authorized by The City of Mebane. 2016-2017 Illicit Discharges 'y t qY There were no known -P illicit discharges in Mebane in 2016. There was one illicit discharge reported in 2017. P�rNAr#SSOrPr�rrtS � OR fhC tFJre SFPr$ in YGVF 17fd- foifowdiraicrio�u ar kti7n'urr rabsJ3 amd$wncR �f �ri�x� 5rd+kS, �ndrn3dt cAnrs wcn Y gst storm �rx+rts. - weso mrn $term drains 'tCrn efrfinY. Pollution Prevention and Good Housekeeping for Municipal Operations • Overview • All Facilities Inspected • Especially high risk facilities • Including public works and recreation facilities • O&M Plans • Annual Training • At Public Works but for all City employees • Street Sweeping • Every street with C&G approximately every 3 months • Pesticide Applicators licensed & trained Questions?