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Home My WebLink AboutNCS000485_MS4 Inspection Report_20180328K`1 Energy, Mineral and Land Resources ENVIRONMENTAL QUALITY April 3, 2018 Jamey Baines Town of Nashville PO Box 987 Nashville, NC 27856 Subject: MS4 Compliance Inspection Notice of Non -Compliance Permit No. NCS000485 Dear Mr. Baines: ROY COOPER Governor MICHAEL S. REGAN Secretary 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 Inspection of Town of Nashville on March 28, 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 subject North Carolina National Pollutant Discharge Elimination System (NPDES) Permit. We appreciate the staff willingness to work with DEQ during the compliance inspection. Attached is the inspection report, which includes the actions and deadlines required to address identified areas of non-compliance, deficiencies, and discrepancies. Also attached is information (model ordinance, example stormwater management plan, etc.) to assist you with addressing these deficiencies. 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: NCS000485 File Brian Hassell —Town of Nashville Rick Riddle — DEMLR Central Office Stormwater Thad Valentine — DEMLR Raleigh Regional Office Rachel Hart — EPA Region 4 State of North Carolina I Environmental Quality I Energy, Mineral and Land Resources 1612 Mail Service Center 1 512 N. Salisbury St. I Raleigh, NC 27699 919 707 9200 T MS4 COMPLIANCE INSPECTION/AUDIT GENERAL INFORMATION Audit Date: 3/28/2018 Permit No: NCS000485 permittee: TOWII of Nashville NCDEQ Staff Present: Thad Valentine - RRO Robert Patterson - CO Rick Riddle - CO Municipal Staff Present: Brian Hassell - Planning & Development Director Jamey Baines - Director of Public Utilities CONTRACT OPERATIONS/PARTNERSHIPS Stocks Engineering for reviewing post -construction engineered plans PROGRAMS & DOCUMENTS REVIEWED Interagency agreements or partnerships O Legal authorities/ordinances Stormwater Management Plan O Annual Report -2017 report provided during inspection Stormwater Staff Org. Chart & Budget -started sw utility fee last year MS4 & SCM Inventory Pesticide, Herbicide, and Fertilizer (PHF) Controls Other Current permit issued 2017; Performed site visits of the Town's public works yard, and 3 privately owned post -construction SCMs: Walmart [2 wetlands], Boice-Willis medical office [2 bioretention], & Nash Crossing [1 regional wetpond] Public Education & Outreach Satisfactory QUnsatisfactory QN/A QNot Reviewed Great involvement with school kids about the environment need to add info to website including education materials, hotline/helpline, etc. recommend CWEP or similar partnership for brochures, radio/tv ads, etc. recommend providing sw outreach during Town events like the Blooming Festival and in utility mailings Public Involvement & Participation Satisfactory ID Unsatisfactory ®N/A ONot Reviewed annual enviro. camp for kids, designing a retrofit at elem. school to fix erosion issue and use for education need to add info to website including how to participate and the hotline/helpline Page 1 of 3 Rev. 2018Jan7 MS4 COMPLIANCE INSPECTION/AUDIT IDDE Satisfactory Unsatisfactory ® N/A ()Not Reviewed none reported; training staff especially on sso's need to document training (who, what, when) need to maintain a storm drainage map of at least the major outfalls asap but no later than July 1, 2018 need to implement a written IDDE program need to adopt & implement IDDE ordinance asap but no later than July 1, 2018 Post -construction SW Satisfactory S Unsatisfactory ® N/A ® Not Reviewed Sites visited were mostly in compliance, with some routine maintenance needed by the owners. need to better document annual inspections of SCMs, need to adopt & implement post -construction ordinance asap but no later than July 1, 2018 Construction SW eSatisfactory ®Unsatisfactory ON/A ®Not Reviewed NCDEQ RRO implements this PPGH for Municipal Operations e Satisfactory O Unsatisfactory O N/A O Not Reviewed Good drainage maint. SOP & log; participating in Soil & Water Conservation grant to remove snags/trash from Stoney Creek; grant for repairing major sw pipe to Stoney Crk. Using utility cloud to map over the next year. Public works yard was well maintained; great vehicle wash bay that goes to ss. Need to document training and remove some of the scrap equipment. TMDLs Satisfactory ®Unsatisfactory ON/A Q. Not Reviewed within the Tar -Pam NSW, but not a named community Evaluation & Monitoring of Industrial SW Discharges to MS4 OSatisfactory OUnsatisfactory ON/A ONot Reviewed Water Quality Assessment & Monitoring O Satisfactory ® Unsatisfactory e N/A ® Not Reviewed Page 2 of 3 Rev. 201 ghn7 MS4 COMPLIANCE INSPECTION/AUDIT ADDITIONAL INFO/COMMENTS Currently in the third permit term. This appears to be the first MS4 inspection performed by NCDEQ of this permittee. Implementation of post -construction requirements, public education & outreach, public participation & involvement, and PPGH is acted on well, but need to better document. The Town needs to develop a written stormwater management plan asap, but no later than September 1, 2018. Increased documentation and record keeping is needed in general. Need to provide annual reports by October 31 that covers the preceding fiscal year July -June. Please submit to NCDEQ Stormwater Program the items with an " * " as they are finalized by the Town. robert.patterson@ncdenr.gov The NCDEQ— Stormwater Program will review this audit information, and will provide the permittee with a draft and/or final MS4 Audit Report that may include the following compliance items: Notice of Violation. Any permit noncompliance constitutes a violation 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. Notice of non-compliance: A finding that could result in a Notice of Violation, a fine or other enforcement action if corrective action is not taken. Discrepancies: A finding that would not likely cause a Notice of Violation, a fine, or other enforcement action. Discrepancies are normally a result of poor management practices, failure to follow installation Standard Operating Procedures, minor differences of interpretation or administration oversights. Discrepancies can also be findings where compliance could not be determined Identify any repeat deficiencies Recommendations represent practices that should be considered to improve the overall effectiveness to improve stormwater management Page 3 of 3 Rev. 201 ghn7