HomeMy WebLinkAboutNCS000481_Maiden EPA Audit Report_20181213
TOWN OF MAIDEN, NC
MUNICIPAL SEPARATE STORM
SEWER SYSTEM (MS4) PROGRAM
INSPECTION REPORT
MAIDEN, NORTH CAROLINA
19 North Main Avenue
Maiden, NC 28650
Inspection Date: December 13, 2018
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
U.S. Environmental Protection Agency, Region IV
Sam Nunn Atlanta Federal Center
61 Forsyth Street SW
Atlanta, GA 30303‐8963
MS4 Inspection Report
Maiden, NC: NPDES Permit No. NCS000481
Inspection Date: December 13, 2018 i
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MS4 Inspection Report
Maiden, NC: NPDES Permit No. NCS000481
Inspection Date: December 13, 2018 ii
TABLE OF CONTENTS
Inspection Details .......................................................................................................................................... 1
Permittee Information .................................................................................................................................. 2
Supporting Documents ................................................................................................................................. 2
Program Implementation, Documentation, & Assessment .......................................................................... 3
Illicit Discharge Detection and Elimination (IDDE) ........................................................................................ 6
Post‐Construction Site Runoff Controls Program Implementation Status .... Error! Bookmark not defined.
Post‐Construction Site Runoff Controls ........................................................................................................ 9
Pollution Prevention and Good Housekeeping for Municipal Operations ................................................. 12
Site Visit Evaluation: Municipal Facility No. 1 ............................................................................................. 15
Site Visit Evaluation: Municipal Facility No. 2 ............................................................................................. 18
Site Visit Evaluation: Municipal Facility No. 3 ............................................................................................. 21
Appendix A: Supporting Documents
Appendix B: Photograph Log
This inspection consisted of an evaluation of program compliance with the issued permit and
implementation of the approved Stormwater Management Plan. This inspection report does not include
a review of all program components. There may be additional program deficiencies in addition to those
noted. 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.
MS4 Inspection Report
Maiden, NC: NPDES Permit No. NCS000481
Inspection Date: December 13, 2018 iii
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MS4 Inspection Report
Maiden, NC: NPDES Permit No. NCS000481
Inspection Date: December 13, 2018 Page 1 of 28
Inspection Details
Inspection ID Number:
SW‐NCS000481‐12/13/2018
Inspection Date(s):
December 13, 2018
Minimum Control Measures Evaluated:
☒Program Implementation
☐Public Education & Outreach
☐Public Involvement and Participation
☒Illicit Discharge Detection & Elimination
☐Construction Site Runoff Controls
☒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: 3
☐MS4 Outfalls. Number visited: 0
☐Construction Sites. Number visited: 0
☒ Post‐Construction Stormwater Runoff Controls. Number visited: 2
☐ Other: ________________________________. Number visited: 0
☐ Other: ________________________________. Number visited: 0
Inspector(s) Conducting Inspection
Name, Title Organization
Sean Ireland, Stormwater Enforcement Workgroup Lead EPA Region 4
Jake Albright, EPA Contractor PG Environmental
Collin Mummert, EPA Contractor PG Environmental
Jeanette Powell, MS4 Program Coordinator North Carolina Dept of Environmental Quality (NCDEQ),
Division of Energy, Mineral, and Land Resources (DEMLR)
Angela Lee, Environmental Specialist NCDEQ, DEMLR
Alaina Morman, Environmental Specialist NCDEQ, DEMLR
Brandon Wise, Environmental Specialist NCDEQ, DEMLR
Isaiah Reed, Environmental Specialist NCDEQ, DEMLR
Inspection Report Author: Jake Albright
Signature__________________________________________
Date:
March 12, 2019
Inspection Report Author: Collin Mummert
Signature__________________________________________
Date:
March 12, 2019
MS4 Inspection Report
Maiden, NC: NPDES Permit No. NCS000481
Inspection Date: December 13, 2018 Page 2 of 28
Permittee Information
MS4 Permittee Name:
Town of Maiden, NC (hereinafter, the Town)
NPDES Permit Number:
NCS000481 (hereinafter, the Permit)
MS4 Permittee Address:
19 N. Main Avenue, Maiden, NC 28650
Date of Last MS4 Inspection/Audit:
N/A
Co‐permittee(s), if applicable:
N/A
Primary MS4 Representatives Participating in Inspection
Name, Title Organization
Blake Wright, Planning Director Town of Maiden
MS4 Receiving Waters
Waterbody Impairments
Clark Creek (Shooks Lake), 11‐129‐5‐(0.3)b 303(d) (IR=5): Ecological/Biological Integrity Benthos
Maiden Creek, 11‐129‐5‐7‐2‐(3) 303(d) (IR=5): Ecological/Biological Integrity Benthos
Note: This list only includes waterbodies with 303(d) impairments that receive discharges from the permitted MS4. Note
that NC DEQ’s 2016 303(d) list was used for reference, as the 2018 list was still in draft version.
Supporting Documents
Number Document Title Provided Prior to/During/After
Inspection:
1 Town of Maiden MS4 Organizational Chart Prior to inspection
2 Town of Maiden Unified Development Ordinance, Chapter 17 Phase II
Stormwater Appendix B Prior to Inspection
3 2018 Stormwater Management Program Assessment Prior to Inspection
4 Municipal Facilities Inventory Prior to Inspection
Note: Refer to Appendix A: Supporting Documents for copies of the above documents. These supporting documents do not
represent all MS4 program documentation provided to the inspection team by Town representatives. EPA Region 4
maintains all documentation provided to the inspection team by Town representatives. Additionally, the photographs
contained in Appendix B: Photograph Log and referenced throughout this report do not represent all photographs taken by
the inspection team during the inspection. EPA Region 4 maintains all photographs taken by the inspection team
MS4 Inspection Report
Maiden, NC: NPDES Permit No. NCS000481
Inspection Date: December 13, 2018 Page 3 of 28
Program Implementation, Documentation, & Assessment
Permit Citation Program Requirement Status Supporting
Doc No.
II.A.1
Staffing and
Funding
The permittee maintained adequate funding and staffing to implement and manage the
provisions of the Stormwater Plan and meet all requirements of the permit. No ‐‐
The Stormwater Plan identifies a specific position(s) responsible for the overall
coordination, implementation, and revision to the Plan. No 1
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
monitoring fees. Yes ‐‐
Comments
The Town had not developed or implemented a written Stormwater Plan. The Town provided an organizational chart for Town
representatives within the program; however, the organizational chart does not identify representative’s roles and responsibilities.
The Planning director was unaware of what the MS4 program budget was or should be.
II.A.2
Stormwater
Plan
Implementation
and Evaluation
The permittee evaluated the performance and effectiveness of the program
components at least annually. No ‐‐
If yes, the permittee used the results of the evaluation to modify the program
components as necessary to accomplish the intent of the Stormwater Program. n/a ‐‐
Did the permitted MS4 discharges cause or contribute to non‐attainment of an
applicable water quality standards? ‐‐ ‐‐
If yes, did the permittee expand or better tailor its BMPs accordingly? ‐‐ ‐‐
Comments
The Town has submitted annual reports to NC DEQ in the past; however, the Town does not have a formalized/written Stormwater
Plan to evaluate. The inspection team dd not assess non‐attainment or evaluate for any water quality standards as part of the
inspection.
II.A.3
Keeping the
Stormwater
Plan Up to Date
The permittee kept the Stormwater Plan up to date. No ‐‐
The permittee notified DEMLR of any updates to the Stormwater Plan. No ‐‐
Comments (indicate the date of latest Stormwater Plan and describe the nature of any updates, if applicable).
The Town had not developed a written Stormwater Plan.
MS4 Inspection Report
Maiden, NC: NPDES Permit No. NCS000481
Inspection Date: December 13, 2018 Page 4 of 28
Program Implementation, Documentation, & Assessment
Permit Citation Program Requirement Status Supporting
Doc No.
II.A.4
Availability of
the Stormwater
Plan
The permittee kept an up‐to‐date version of its Stormwater Plan available to the
Division and the public online. No ‐‐
The online materials included ordinances, or other regulatory mechanisms, or a list
identifying the ordinances, or other regulatory mechanisms, providing the legal
authority necessary to implement and enforce the requirements of the permit.
Yes 2
Comments
The Town had not developed a written Stormwater Plan. The Town’s website included a link to the Town’s Phase II stormwater
ordinance (see II.D.2.b Legal Authorities below).
II.A.5
Stormwater
Plan
Modifications
Did DEMLR require a modification to the Stormwater Plan? n/a ‐‐
If yes, did the permittee complete the modifications in accordance with the
established deadline? n/a ‐‐
Comments
The Town had not developed a written Stormwater Plan.
II.A.6 Sharing
Responsibility Are any control measures implemented by an entity other than the permittee? Yes ‐‐
If yes, is there a written agreement in place? Yes ‐‐
Comments
The Town maintains an agreement with the Western Piedmont Council of Governments (COG) for public education and outreach on
stormwater impacts. The COG also supports the Town’s work order system and infrastructure map through a geographic
information system (GIS). The Town also has an agreement with Catawba County Environmental Health for septic tank permitting
and inspections.
II.A.7
Written
Procedures
The permittee maintained written procedures for implementing the six minimum
control measures. No ‐‐
Written procedures identified specific action steps, schedules, resources and
responsibilities for implementing the six minimum measures. No ‐‐
Comments
The Town had not developed a Stormwater Plan or other written procedures for implementing the six minimum control measures.
III. A
Program
Documentation
The permittee maintained documentation of all program components including, but not
limited to, inspections, maintenance activities, educational programs, implementation
of BMPs, enforcement actions, etc., on file for a period of five years.
No ‐‐
Comments
The Town documents all maintenance activities, not just for stormwater, through its GIS work order system and infrastructure map;
however, the Town lacked documentation relating to the stormwater program (e.g., no documentation for annual inspections other
than those received from Apple for their SCMs, no record of illicit discharge detection and elimination activities, no record of
stormwater education activities).
MS4 Inspection Report
Maiden, NC: NPDES Permit No. NCS000481
Inspection Date: December 13, 2018 Page 5 of 28
Program Implementation, Documentation, & Assessment
Permit Citation Program Requirement Status Supporting
Doc No.
III.B
Annual Report
Submittal
The permittee submitted annual reports to the Department within twelve months from
the effective date of the permit. Yes 3
The permittee submitted subsequent annual reports every twelve months from the
scheduled date of the first submittal. n/a ‐‐
The Annual Reports included appropriate information to accurately describe the progress, status, and results of
the permittee’s Stormwater Plan, including, but not limited to 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
of each major component of the Stormwater Plan for the past year and
schedules and plans for the year following each report.
Partial 3
2. An adequate description and justification of any proposed changes to the
Stormwater Plan. This will include descriptions and supporting information for
the proposed changes and how these changes will impact the Stormwater Plan
(results, effectiveness, implementation schedule, etc.).
No ‐‐
3. Documentation of any necessary changes to programs or practices for
assessment of management measures implemented through the Stormwater
Plan.
No ‐‐
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
Stormwater Plan.
Partial 3
5. An assessment of compliance with the permit, information on the establishment
of appropriate legal authorities, inspections, and enforcement actions. Partial 3
6. A summary of past year activities, including where applicable, specific quantities
achieved and summaries of enforcement actions. Partial 3
7. A description of the effectiveness of each program component. No ‐‐
8. Planned activities and changes for the next reporting period, for each program
component or activity. No ‐‐
9. Fiscal analysis. No ‐‐
Comments
The Town provided the 2017‐2018 MS4 annual report prior to the inspection and provided the 2016‐2017 MS4 annual report
during the inspection. Note that the Town completed the 2016‐2017 report under a previous version of the permit. The reports
include brief descriptions of the six minimum control measures and initiatives during each year; however, the reports lacked detail
regarding the effectiveness of each program element and planned changes to the MS4 program. Further, the Town does not have a
written Stormwater Plan to evaluate and update. The Town’s summary of MS4 activities did not always include specific quantities
achieved other than the quantity of salt applied to roadways. During the inspection, the Planning Director indicated that he was
unsure what the total annual budget identified in the 2017‐2018 annual report was representative of, and that it may only include
funds used for outside consulting. The Town had not calculated a comprehensive and accurate annual budget for the MS4 program
at the time of the inspection.
MS4 Inspection Report
Maiden, NC: NPDES Permit No. NCS000481
Inspection Date: December 13, 2018 Page 6 of 28
Illicit Discharge Detection and Elimination (IDDE)
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
evaluation. n/a ‐‐
Comments
The Town had not developed written procedures for implementing an IDDE Program. The Town had developed an Illicit Discharge
Hotline Incident Tracking Sheet to be used by Town employees but had not implemented it.
II.D.2.b
Legal
Authorities
The permittee maintained an IDDE ordinance or other regulatory mechanism(s) that
provides the legal authority to prohibit illicit connections and discharges to the MS4. Yes 2
If yes, the ordinance applies throughout the corporate limits of the permittee.
[Permit Part I.D] Yes 2
Comments
The Town provided their Phase II Stormwater Ordinance (Maiden Town Ordinances, Chapter 17, Appendix B) prior to the
inspections, which is also available through the Town’s website.
II.D.2.c
Storm Sewer
System Map
The permittee maintained a current map showing major outfalls and receiving streams. Partial ‐‐
Comments
The Town has an agreement with the COG to maintain a GIS‐based infrastructure map. The map identifies receiving streams and
outfalls; however, the Town has only inventoried seven outfalls associated with municipal facilities covered under NCDEQ Industrial
Stormwater General Permits. The Planning Director indicated that other major outfalls may be present on the map; however, the
Town does not have an inventory of all major outfalls. Additionally, the Town only mapped non‐pipe conveyances, such as ditches,
at culverts that pass underneath roads. The Town’s maps do not explicitly identify any outfalls or discharge points associated with
ditches.
II.D.2.d
Dry Weather
Flow Program
The permittee maintained a program for conducting dry weather flow field observations
in accordance with written procedures. No ‐‐
Comments
The Town had not conducted dry weather screening or maintain written procedures for dry weather field activities.
II.D.2.e
Investigation
Procedures
The permittee maintained written procedures for conducting investigations of identified
illicit discharges. No ‐‐
Comments
The Planning Director stated that the Town conducts illicit discharge investigations on a reactive basis and has not developed
written procedures for illicit discharge investigations.
MS4 Inspection Report
Maiden, NC: NPDES Permit No. NCS000481
Inspection Date: December 13, 2018 Page 7 of 28
Illicit Discharge Detection and Elimination (IDDE)
Permit Citation Program Requirement Status Supporting
Doc No.
II.D.2.f
Track and
Document
Investigations
For each case of an illicit discharge or potential illicit discharge, the permittee documented and tracked the
following:
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 Planning Director provided the inspection team with an Illicit Discharge Hotline Incident Tracking Sheet template prior to the
inspection, which identifies the observation date, describes the results of the investigation, details any follow‐up investigations, and
identifies the date the investigation was closed. However, the Planning Director indicated that the Town employees have never
used the document.
II.D.2.g
Employee
Training
The permittee implemented and documented a training program for appropriate
municipal staff who, as part of their normal job responsibilities, may come into contact
with or otherwise observe an illicit discharge or illicit connection.
Partial ‐‐
Comments
While onsite, the Town provided examples of sign‐in sheets for self‐administered pollution prevention training for staff at municipal
facilities covered under Industrial Stormwater General Permits (i.e., the Public Works Facility and Wastewater Treatment Plant).
However, the Town representatives indicated that not all municipal staff who may encounter illicit discharges have received
training, including individuals in the Finance Department who would be first to receive illicit discharge complaint calls.
II.D.2.h
Public
Education
The permittee informed public employees of hazards associated with illegal discharges
and improper disposal of waste. No ‐‐
The permittee informed businesses of hazards associated with illegal discharges and
improper disposal of waste. No ‐‐
The permittee informed the general public of hazards associated with illegal discharges
and improper disposal of waste. No ‐‐
Comments
The Planning Director explained that the Town’s approach to eliminating illicit discharges was primarily reactive. The Town had not
developed or implemented a program for educating public employees, businesses, and the general public about hazards associated
with illicit discharges and the improper disposal of waste.
MS4 Inspection Report
Maiden, NC: NPDES Permit No. NCS000481
Inspection Date: December 13, 2018 Page 8 of 28
Illicit Discharge Detection and Elimination (IDDE)
Permit Citation Program Requirement Status Supporting
Doc No.
II.D.2.i
Public
Reporting
Mechanism
The permittee promoted, publicized, and facilitated a reporting mechanism for the
public to report illicit discharges. Partial ‐‐
The permittee promoted, publicized, and facilitated a reporting mechanism for staff to
report illicit discharges. No ‐‐
The permittee established and implemented citizen request response procedures. Partial ‐‐
Comments
The Town receives all complaints from the public via phone by the Town’s Finance Department, who relays the complaint to the
applicable responder. The Planning Director indicated that complaints relating to stormwater would either be relayed directly to his
office or to the Public Works Department. If a work order is required, the Finance Department inputs the information into the GIS‐
linked work order system, which sends the address to the Public Works Department. The department that receives the work order
is determined by the Finance Department based on the interpretation of the individual receiving the initial complaint (there are no
set categories for work orders and no specific training provided to users). The Town does not promote or publicize the reporting
mechanism as a means for reporting potential illicit discharges or other stormwater‐related issues.
II.D.2.j
Enforcement
The permittee implemented a mechanism to track the issuance of notices of violation
and enforcement actions administered by the permittee. No ‐‐
If yes, the mechanism includes the ability to identify chronic violators for initiation of
actions to reduce noncompliance. No ‐‐
Comments
The Town has not implemented a mechanism for tracking enforcement actions, as the Town has not taken any stormwater‐related
enforcement actions to date. The Town’s stormwater ordinance does not include an enforcement response plan or mechanism for
enforcement other than identifying illicit discharges as forms of nuisance.
MS4 Inspection Report
Maiden, NC: NPDES Permit No. NCS000481
Inspection Date: December 13, 2018 Page 9 of 28
Post‐Construction Site Runoff Controls
Permit Citation Program Requirement Status Supporting
Doc No.
II.F.2.a
Legal Authority
The permittee maintained an ordinance or other regulatory mechanism designed to
meet the objectives of the Post‐Construction Site Runoff Controls Stormwater
Management Program.
Yes 2
If yes, the ordinance applies throughout the corporate limits of the permittee.
[Permit Part I.D] Yes 2
The permittee has the authority to review designs and proposals for new development
and redevelopment to determine whether adequate stormwater control measures will
be installed, implemented, and maintained.
Yes 2
The permittee has the authority to request information such as stormwater plans,
inspection reports, monitoring results, and other information deemed necessary to
evaluate compliance with the Post‐Construction Stormwater Management Program.
Yes 2
The permittee has the authority to enter private property for the purpose of inspecting
at reasonable times any facilities, equipment, practices, or operations related to
stormwater discharges.
Yes 2
Comments
The Town’s Phase II Stormwater Ordinance (Maiden Town Ordinances, Chapter 17, Appendix B) authorizes the Town to review
plans, request information, and enter private property to conduct inspections of post‐construction stormwater control measures
(SCMs). The Town developed the stormwater ordinance in accordance with the state template.
II.F.2.c
Plan Reviews
The permittee conducted site plan reviews of all new development and redeveloped
sites that disturb greater than or equal to one acre (including sites that disturb less than
one acre that are part of a larger common plan of development or sale).
Yes ‐‐
If yes, the site plan reviews addressed how the project applicant meets the
performance standards. Yes ‐‐
If yes, the site plan reviews addressed how the project will ensure long‐term
maintenance. Yes ‐‐
Comments
The Planning Director is responsible for reviewing site plans. The most recent SCM installed in the Town was installed in 2018 at the
Town’s Police Department. The Town has not had a privately‐owned SCM (or any other SCM) installed since about 2015‐2016, prior
to the current Planning Director’s employment. The Town’s stormwater ordinance requires site owners to complete an operation
and maintenance (O&M) agreement prior to the Town issuing a permit for development or redevelopment requiring a post‐
construction SCM.
II.F.2.d
Inventory of
Projects
The permittee maintained an inventory of projects with post‐construction structural
stormwater control measures installed and implemented at new development and
redeveloped sites.
No ‐‐
The inventory included both public and private sector sites located within the
permittee’s corporate limits that are covered by its post‐construction ordinance
requirements.
No ‐‐
Comments
The Town does not maintain an inventory of all publicly‐ and privately‐owned post‐construction SCMs within the corporate limits.
The Planning Director stated that, to the best of his knowledge, there are seven post‐construction SCMs within the permitted area,
including six privately‐owned SCMs (five of which are at a single facility) and one publicly‐owned SCM at the Town’s Police
Department.
MS4 Inspection Report
Maiden, NC: NPDES Permit No. NCS000481
Inspection Date: December 13, 2018 Page 10 of 28
Post‐Construction Site Runoff Controls
Permit Citation Program Requirement Status Supporting
Doc No.
II.F.2.e
Deed
Restrictions
and Protective
Covenants
The permittee provided mechanisms such as recorded deed restrictions and protective
covenants that ensure development activities will maintain the project consistent with
approved plans.
Yes 2
Comments
Sections 302(C) and 303(E) of the Town’s Phase II Stormwater Ordinance require an enforceable restriction on property usage that
runs with the land, such as recorded deed restrictions or protective covenants, prior to the approval of a stormwater permit. This
ensures that future development and redevelopment on both high‐density and low‐density projects maintains the site consistent
with approved project plans.
II.F.2.f
Mechanism to
Require Long‐
term
Operation and
Maintenance
The permittee implemented or required an operation and maintenance plan for the
long‐term operation of the SCMs required by the program. No 2
The operation and maintenance plan required the owner of each SCM to perform and
maintain a record of annual inspections of each SCM. n/a 2
Annual inspection of permitted structural SCMs are required to be performed by a
qualified professional. Yes 2
Comments
The Town’s Phase II Stormwater Ordinance (Maiden Town Ordinances, Chapter 17, Appendix B) provides the Town authority to
require SCM owners to enter a formal agreement with the Town guaranteeing long‐term maintenance and inspections. The
stormwater ordinance also provides authority to require persons responsible for maintenance of any SCM to submit to the Town an
inspection report from a qualified, registered North Carolina professional engineer, surveyor, or landscape architect performing
services only in their area of competence. However, the Town has not required SCM owners to develop O&M plans. The Planning
Director indicated that one SCM owner (GKN Driveline) has not submitted any annual inspection reports to date and that the Town
has not taken any enforcement in response. The Planning Director stated that Apple (a different SCM owner) was implementing the
O&M requirements, including submitting annual reports, on their own (i.e., without an O&M agreement or routine oversight by the
Town).
II.F.2.g
Inspections
The permittee conducted and documented inspections of each project site covered
under performance standards, at least one time during the permit term. No ‐‐
Before issuing a certificate of occupancy or temporary certificate of occupancy, the
permittee conducted a post‐construction inspection to verify that the permittee’s
performance standards have been met or a bond is in place to guarantee completion.
No ‐‐
The permittee documented and maintained records of inspection findings. No ‐‐
The permittee documented and maintained records of enforcement actions. n/a ‐‐
Comments
The Planning Director has previously conducted visual inspections of privately‐owned SCMs; however, the Planning Director did not
document those inspections. The Town utilizes maintenance agreements with SCM owners that require the owners to have their
SCMs inspected annually by a qualified individual and for the associated inspection reports to be mailed to the Town. The Planning
Director stated that the Town receives some, but not all inspection reports and has not followed up or otherwise pursued obtaining
the missing reports. At the time of the inspection, the Town had not taken any enforcement actions against SCM owners.
MS4 Inspection Report
Maiden, NC: NPDES Permit No. NCS000481
Inspection Date: December 13, 2018 Page 11 of 28
Post‐Construction Site Runoff Controls
Permit Citation Program Requirement Status Supporting
Doc No.
II.F.2.h
Educational
Materials and
Training for
Developers
The permittee made available through paper or electronic means, ordinances, post‐
construction requirements, design standards checklists, and other materials appropriate
for developers.
Note: New materials may be developed by the permittee, or the permittee may use
materials adopted from other programs and adapted to the permittee’s new
development and redevelopment program.
Partial 2
Comments (If the permittee has adopted materials from other programs, indicate here which materials they are using)
The Town’s Phase II Stormwater Ordinance (Maiden Town Ordinances, Chapter 17, Appendix B; available on the Town’s website)
requires stormwater treatment practices be designed, constructed, and maintained in accordance with the criteria and
specifications in NCDEQ’s Stormwater Design Manual. Other than referencing the NCDEQ Stormwater Design Manual in the
stormwater ordinance, the Town does not provide training or educational material to developers regarding the proper design and
maintenance of post‐construction SCMs. The Planning Director stated that the Town conducts pre‐construction meetings on a case‐
by‐case basis for projects that the Town regards as significant. He stated these meetings include discussion of stormwater
requirements.
II.F.2.i
Enforcement
The permittee tracked the issuance of notices of violation and enforcement actions. No ‐‐
If yes, the tracking mechanism included the ability to identify chronic violators for
initiation of actions to reduce noncompliance. n/a ‐‐
Comments
The Town has not taken enforcement actions against SCM owners and did not have a mechanism for tracking enforcement actions.
II.F.3.d
Nutrient
Sensitive
Waters
Pursuant to 15A NCAC 02H .0150, for areas draining to Nutrient Sensitive Waters, the
permittee used SCMs that reduce nutrient loading in order to meet local program
requirements
n/a ‐‐
If yes, the permittee also still incorporated the stormwater controls required for the
project's density level. n/a ‐‐
Documentation shall be provided where it is not feasible to use stormwater control
measures (SCMs) that reduce nutrient loading. In areas where the Department has
approved a Nutrient Sensitive Water Urban Stormwater Management Program, the
provisions of that program fulfill the nutrient loading reduction requirement.
n/a ‐‐
Comments
The Planning Director stated that there are no areas within the Town’s corporate limits that drain to Nutrient Sensitive Waters.
II.F.3.e
Design Volume
The permittee ensured that the design volumes of SCMs take into account the runoff at
build out from all surfaces draining to the system. Yes 2
Where “streets” convey stormwater, the permittee designed SCMs to be sized to treat
and control stormwater runoff from all surfaces draining to the SCM including streets,
driveways, and other impervious surfaces.
Yes 2
Comments
The Town’s Phase II Stormwater Ordinance (Maiden Town Ordinances, Chapter 17, Appendix B) references the NCDEQ Design
Manual, which requires the design volume of SCMs to consider the runoff at build out from all surfaces draining to the system. The
Planning Director stated that he reviews the design volume and impervious area served by SCMs during the plan review process.
MS4 Inspection Report
Maiden, NC: NPDES Permit No. NCS000481
Inspection Date: December 13, 2018 Page 12 of 28
Pollution Prevention and Good Housekeeping for Municipal Operations
Permit Citation Program Requirement Status Supporting
Doc No.
II.G.2.a
Facility
Inventory
The permittee maintained a current inventory of facilities and operations owned and
operated by the permittee with the potential for generating polluted stormwater runoff. Partial 4
Comments
The Town maintains a list of the seven municipal facilities within the MS4 service area; however, the Town has made no
determinations regarding which of the facilities had the potential to generate polluted stormwater runoff. Two of the facilities were
covered under Industrial Stormwater General Permits: the Public Works Facility and the Wastewater Treatment Plant.
II.G.2.b
Operation and
Maintenance
(O&M) for
Facilities
The permittee maintained and implemented an O&M program for municipally owned
and operated facilities with the potential for generating polluted stormwater runoff. No ‐‐
If yes, the O&M program specifies the frequency of inspections. n/a ‐‐
If yes, the O&M program specifies the frequency of routine maintenance
requirements. n/a ‐‐
If yes, the permittee evaluated the O&M program annually and updated it as
necessary. n/a ‐‐
Comments
The Town has not developed a written O&M program for municipal facilities. The Planning Director also stated that he has not
inspected the municipal facilities. On‐site personnel at facilities covered under an Industrial Stormwater General Permit conducted
a limited number of inspections, but not at the required frequency. For example, Town staff had documentation for just two
inspections of the wastewater treatment plant since 2015.
II.G.2.c
Spill Response
Procedures
The permittee had written spill response procedures for municipal operations. No ‐‐
Comments
The Town has not developed written spill response procedures other than those included in the SWPPP developed for the Town’s
wastewater treatment plant.
II.G.2.d
Streets, Roads,
and Public
Parking Lots
Maintenance
The permittee evaluated, based on cost and the estimated quantity of pollutants
removed, existing and new BMPs annually that reduce polluted stormwater runoff from
municipally‐owned streets, roads, and public parking lots within its corporate limits.
No ‐‐
Comments
The Town did not evaluate BMP’s based on pollutant removal. The Town does not conduct street sweeping.
MS4 Inspection Report
Maiden, NC: NPDES Permit No. NCS000481
Inspection Date: December 13, 2018 Page 13 of 28
Pollution Prevention and Good Housekeeping for Municipal Operations
Permit Citation Program Requirement Status Supporting
Doc No.
II.G.2.e
O&M for Catch
Basins and
Conveyance
Systems
The permittee maintained and implemented an O&M program for the stormwater sewer
system including catch basins and conveyance systems that it owns and maintains. No ‐‐
Comments
The Planning Director indicated that the Town conducts storm sewer system maintenance, including cleaning of catch basins and
conveyance systems, on an as‐needed basis. The Town tracks work orders for requested storm sewer system maintenance
generated by public requests or complaints through the Town’s GIS; however, the work orders are not classified such that the Town
can query the system to identify the work orders related to stormwater.
II.G.2.f
Structural
Stormwater
Controls
The permittee maintained a current inventory of municipally‐owned or operated
structural stormwater controls installed for compliance with the permittee’s post‐
construction ordinance.
No ‐‐
Comments
The Town does not have an inventory of municipally‐owned structural stormwater controls.
II.G.2.g
O&M for
Structural
Stormwater
Controls
The permittee maintained and implemented an O&M program for municipally‐owned or
maintained structural stormwater controls installed for compliance with the permittee’s
post‐construction ordinance.
No ‐‐
The O&M program specified the frequency of inspections and routine maintenance
requirements. No ‐‐
The permittee documented inspections of all municipally‐owned or maintained
structural stormwater controls. No ‐‐
The permittee inspected all municipally‐owned or maintained structural stormwater
controls in accordance with the schedule developed by permittee. No ‐‐
The permittee documented maintenance of all municipally‐owned or maintained
structural stormwater controls. No ‐‐
The permittee maintained all municipally‐owned or maintained structural stormwater
controls in accordance with the schedule developed by permittee. No ‐‐
Comments
The Town has not developed an O&M program for municipally‐owned or maintained structural stormwater controls.
II.G.2.h
Pesticide,
Herbicide and
Fertilizer
Application
Management
The permittee ensured municipal employees are properly trained. Yes ‐‐
The permittee ensured contractors are properly trained. n/a ‐‐
The permittee ensured all permits, certifications, and other measures for applicators are
followed. Yes ‐‐
MS4 Inspection Report
Maiden, NC: NPDES Permit No. NCS000481
Inspection Date: December 13, 2018 Page 14 of 28
Pollution Prevention and Good Housekeeping for Municipal Operations
Permit Citation Program Requirement Status Supporting
Doc No.
Comments
At the time of the inspection, the Town’s Street Superintendent was the only municipal employee trained and certified for pesticide
application. All pesticides were stored indoors at the Town’s Public Works Facility. The Town does not employ private contractors
for pesticide application.
II.G.2.i
Staff Training
The permittee implemented an employee training program for employees involved in
implementing pollution prevention and good housekeeping practices. Partial ‐‐
Comments
The Town has only conducted self‐guided training (PowerPoint and video instruction) for employees at municipal facilities covered
under Industrial Stormwater General Permits. Staff at the wastewater treatment plant and the Public Works Facility participated in
training in November 2018; however, it was unclear when the training was given prior to November 2018. The Town provided
training to employees at other municipal facilities on pollution prevention and good housekeeping practices.
II.G.2.j
Vehicle and
Equipment
Cleaning
The permittee described and implemented measures that prevent or minimize
contamination of stormwater runoff from all areas used for vehicle and equipment
cleaning.
Partial ‐‐
Comments
The Planning Director indicated that the Town conducts most municipal vehicle washing inside the vehicle wash bay at the Public
Works Facility (see the Site Visit Evaluation for Municipal Facility No. 1 below). He explained that the fire department conducted
vehicle washing indoors at Fire Station No. 2; however, a facility representative was not present during the site visit to Fire Station
No. 2 to confirm that all vehicle washing is conducted indoors (see the Site Visit Evaluation for Municipal Facility No. 3 below).
MS4 Inspection Report
Maiden, NC: NPDES Permit No. NCS000481
Inspection Date: December 13, 2018 Page 15 of 28
Site Visit Evaluation: Municipal Facility No. 1
Facility Name:
Town of Maiden Public Works Facility
Date and Time of Site Visit:
12/13/2018, 12:10 PM
Facility Address:
113 W Main Street
Maiden, NC 28650
Facility Type (Vehicle Maintenance, Landscaping, etc.):
Vehicle Maintenance and Equipment Storage
Name of MS4 inspector(s):
Blake Wright, Planning Director, Town of Maiden
Most Recent MS4 Inspection (Date and Entity):
None (see II.G.2.g above)
Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name Title
Billy Price Director of Public Works
Micah Beal Street Superintendent
Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility‐specific?
Yes, but pollutant sources and BMPs are not defined. Further, the SWPPP did not include any spill response plan or procedures for
the on‐site storage tanks (four 1,000‐gallon gas and diesel tanks, one approximately 275‐gallon kerosene tank).
What type of stormwater training do facility employees receive? How often?
The Street Superintendent is the only facility employee who has received stormwater training. He completed self‐administered
training in November 2018. The inspection team observed a signed record of completion.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
The Planning Director does not receive routine training. He reviewed training materials related to general pollution prevention and
good housekeeping when he was hired. The Planning Director has distributed these materials to other employees at the facility to
be used as part of their industrial permit implementation.
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
No. The Planning Director has not conducted inspections at the municipal facilities and has not identified facilities and operations
outside of the two facilities covered under NCDEQ Industrial Stormwater General Permits that need to implement pollution
prevention and good housekeeping practices. The MS4 inspector has only distributed stormwater training materials related to
Industrial Stormwater General Permit to a limited number of Town staff.
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Partial. The MS4 inspector was able to identify some pollution prevention and good housekeeping issues at the facility but did not
identify and document all areas of concern observed by the inspection team (see the notes below for more detail).
Inspection Procedures
Does the MS4 inspector’s process include the use of a checklist or other standardized form? Obtain copy.
No.
Does the MS4 inspector’s process include taking photos?
No.
MS4 Inspection Report
Maiden, NC: NPDES Permit No. NCS000481
Inspection Date: December 13, 2018 Page 16 of 28
Site Visit Evaluation: Municipal Facility No. 1
Does the MS4 inspector’s process include reviewing the facility’s SWPPP (or similar document)?
No. The Town does not conduct stormwater pollution prevention and good housekeeping inspections at municipal facilities. The
site visit was conducted to demonstrate to the Planning Director and facility representatives how to properly conduct a stormwater
pollution prevention and good housekeeping inspection.
Does the MS4 inspector’s process include walking the entire facility and inspecting all points of discharge?
No. The Town does not conduct stormwater pollution prevention and good housekeeping inspections at municipal facilities. The
site visit was conducted to demonstrate to the Planning Director and facility representatives how to properly conduct a stormwater
pollution prevention and good housekeeping inspection.
Did the MS4 inspector miss any obvious areas of concern? If so, explain:
This site visit was conducted to demonstrate to the Planning Director and facility representatives how to conduct a stormwater
pollution prevention and good housekeeping inspection; therefore, all areas of concern identified by the inspection team were
discussed with Town representatives as they were observed.
Does the MS4 inspector’s process include presenting the inspection findings to the facility contact?
The Planning Director indicated that he would report any findings and associated action items to the Director of Public Works or
Street Superintendent, who would then assign corrective actions; however, the Planning Director did not formally document the
corrective actions noted during the site visit.
Inspection Results
Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)?
The Planning Director did not conduct a documented inspection of the facility. As such, the Planning Director did not document the
need for any corrective actions. He will need to follow up with facility personnel to ensure the requirements of the MS4 and
Industrial Stormwater General Permit are being met, including the need for analytical monitoring and development of a Spill
Prevention, Control, and Countermeasure (SPCC) plan. See the notes section below for more details.
If compliance corrective actions were identified, what timeline for correction/follow‐up was provided?
The MS4 inspector verbally indicated that the facility would address any corrective actions identified by the inspection team as
soon as possible; however, the MS4 inspector did not document the areas of concern or associated corrective actions.
Notes/Comments/Recommendations
Following discussions with the inspection team, the Planning Director indicated that, in the future, the MS4 inspection process for
facilities covered under Industrial Stormwater General Permits shall consist of a review of routine inspection and training records
required for compliance under the facility‐specific Industrial Stormwater General Permits. Based on the inspection records on file
that the inspection team reviewed, on‐site personnel had been conducting quarterly inspections of the outfall since 2017. The
Planning Director does not provide oversight (i.e., for the MS4 program) in addition to the inspections conducted by on‐site
personnel in compliance with the Industrial Stormwater General Permit. The site visit was conducted to demonstrate to the
Planning Director and on‐site personnel how to properly inspect the entire facility, including all discharge points. The inspection
team observed the following during the site visit. The Planning Director took notes on the identified areas of concern; however, he
did not complete a formal inspection report.
1. There was an uncovered dumpster in the northwest corner of the vehicle maintenance building at the front of the
property, directly southeast and upgradient from the catch basin identified as Catch Basin 1 on the SWPPP’s facility map
(refer to Appendix B, Photograph 1).
2. There was no spill kit or spill kit materials present in the immediate vicinity of the fueling station, which consisted of two
1,000‐gallon diesel tanks, two 1,000‐gallon gasoline tanks, and one approximately 275‐gallon kerosene tank (refer to
Appendix B, Photographs 2, 3, 4, and 5). Facility personnel indicated that they store spill kit materials in the adjacent
garage. At the time of the site visit, the facility did not have a SPCC plan.
3. Evidence of erosion and channelization was observed upgradient of the facility’s outfall (to a tributary of Maiden Creek) in
the northwest corner of the facility (refer to Appendix B, Photograph 6). The inspection team observed one rill running
MS4 Inspection Report
Maiden, NC: NPDES Permit No. NCS000481
Inspection Date: December 13, 2018 Page 17 of 28
Site Visit Evaluation: Municipal Facility No. 1
south to north along the western edge of the facility (refer to Appendix B, Photograph 7) and one rill running east to west
from the access road adjacent to the northern‐most vehicle storage building (refer to Appendix B, Photograph 8). In
addition to stormwater runoff from the facility, the outfall is connected to catch basins in the area around an abandoned
railroad line running along the eastern perimeter of the facility.
4. A pile of construction aggregate was present in the unnamed tributary of Maiden Creek immediately downstream of the
MS4 outfall. The inspection team observed a gray film in Maiden Creek (refer to Appendix B, Photograph 9). Facility
personnel could not identify the origin of the construction aggregate. Facility personnel also indicated that the MS4 outfall
constantly discharges; Town representatives assumed this was due to groundwater intrusion. In addition to stormwater
runoff from the facility, the outfall also receives stormwater runoff from the abandoned railroad running along the eastern
perimeter of the facility.
5. Electrical materials, including wires and junction boxes, were stored uncovered and uncontained on impervious surfaces
throughout the facility (refer to Appendix B, Photographs 10, 11, and 12). All stormwater collected on the facility’s
impervious surfaces drains to the MS4 outfall in the northwest corner of the facility.
6. An indoor vehicle washing bay was in the vehicle maintenance building at the front of the property. Facility personnel
confirmed that the bay drains to an oil and water separator prior to discharging to the sanitary sewer system (refer to
Appendix B, Photograph 13). Facility personnel also indicated that they have never conducted maintenance (i.e., pumping
out) to clear the drain and separator of built‐up oil or grit. The maintenance garage is also equipped with a catch basin to
collect used oil (refer to Appendix B, Photograph 14).
7. The Town does not conduct monitoring at the facility’s outfall. The facility’s Industrial Stormwater General Permit indicates
that the facility uses approximately 75 gallons of oil per month. According to the requirements of the Industrial
Stormwater General Permit program, facilities that have vehicle maintenance activities on‐site and use more than 55
gallons of new motor oil and/or hydraulic fuel per month shall perform analytical monitoring.
Recommendations:
1. The Planning Director should work with facility personnel to ensure the inspection and training requirements of the MS4
and Industrial Stormwater General Permits are being met. Recent inspection and training records are present; however,
they have not historically been completed on a routine basis.
2. Facility personnel should review the requirements of the facility‐specific Industrial Stormwater General Permit to determine
whether the facility needs to develop an SPCC plan and if the facility needs to conduct analytical monitoring.
3. While on‐site, the inspection team discussed the implementation of best management practices for pollution prevention
and good housekeeping, including covering on‐site dumpsters and disposing of them when full, covering electrical materials
that are stored on‐site for an extended period, and storing spill kit materials near the fueling station.
4. The Planning Director should work with facility personnel to address sources of sediment loading to the unnamed tributary
of Maiden Creek, such as the observed rills and channelization.
5. The Planning Director should work with facility personnel to identify the source of the construction aggregate in the
unnamed tributary to Maiden Creek and consider remediation if the aggregate is not supposed to be present.
These areas of concern would likely have been noticed and addressed if the facility had been conducting regular inspections by
trained inspectors. The Planning Director discussed potential solutions to the areas of concern with facility personnel prior to
concluding the site visit.
MS4 Inspection Report
Maiden, NC: NPDES Permit No. NCS000481
Inspection Date: December 13, 2018 Page 18 of 28
Site Visit Evaluation: Municipal Facility No. 2
Facility Name:
Town of Maiden Wastewater Treatment Plant
Date and Time of Site Visit:
12/13/2018, 1:35 PM
Facility Address:
2090 W Finger Street, Ext.
Maiden, NC 28650
Facility Type (Vehicle Maintenance, Landscaping, etc.):
Wastewater Treatment Plant
Name of MS4 inspector(s):
Blake Wright, Planning Director, Town of Maiden
Most Recent MS4 Inspection (Date and Entity):
None (see II.G.2.g above)
Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name Title
Billy Price Director of Public Works
Tim Hendrick Wastewater Treatment Plant Superintendent
Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility‐specific?
Yes, a facility‐specific SWPPP has been developed in accordance with the Industrial Stormwater General Permit.
What type of stormwater training do facility employees receive? How often?
The Wastewater Treatment Plant Superintendent and plant operators completed self‐administered stormwater training using
PowerPoint course materials and videos in November 2018. The wastewater treatment plant maintained signed records of the
training completion on‐site. Prior to the November 2018 training, the facility had not conducted training since 2015.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
The Planning Director has not received routine training. He reviewed training materials related to general pollution prevention and
good housekeeping when he was hired and has distributed these materials to employees at the facility to be used as part of their
industrial permit implementation.
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
No. The Planning Director has not conducted inspections at municipal facilities and has not identified facilities and operations
outside of the two covered under industrial permits that need to implement pollution prevention and good housekeeping practices.
The MS4 inspector has only distributed stormwater training materials related to Industrial Stormwater General Permit to a limited
number of Town staff.
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Partial. The MS4 inspector was able to identify some pollution prevention and good housekeeping issues at the facility but did not
identify and document all areas of concern observed by the inspection team (see the notes below for more detail).
Inspection Procedures
Does the MS4 inspector’s process include the use of a checklist or other standardized form? Obtain copy.
No.
Does the MS4 inspector’s process include taking photos?
No.
MS4 Inspection Report
Maiden, NC: NPDES Permit No. NCS000481
Inspection Date: December 13, 2018 Page 19 of 28
Site Visit Evaluation: Municipal Facility No. 2
Does the MS4 inspector’s process include reviewing the facility’s SWPPP (or similar document)?
No. The Town has not conducted stormwater pollution prevention and good housekeeping inspections at municipal facilities. The
site visit was conducted to demonstrate to the Planning Director and facility representatives how to properly conduct a stormwater
pollution prevention and good housekeeping inspection.
Does the MS4 inspector’s process include walking the entire facility and inspecting all points of discharge?
No. The Town has not conducted stormwater pollution prevention and good housekeeping inspections at municipal facilities. The
site visit was conducted to demonstrate to the Planning Director and facility representatives how to properly conduct a stormwater
pollution prevention and good housekeeping inspection.
Did the MS4 inspector miss any obvious areas of concern? If so, explain:
This site visit was conducted to demonstrate to the Planning Director and facility representatives how to conduct a stormwater
pollution prevention and good housekeeping inspection; therefore, all areas of concern identified by the inspection team were
discussed with Town representatives as they were observed.
Does the MS4 inspector’s process include presenting the inspection findings to the facility contact?
The Planning Director indicated that he would report any findings and associated action items to the superintendent, who would
then assign corrective actions; however, the Planning Director did not formally document the corrective actions noted during the
site visit.
Inspection Results
Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)?
The Planning Director did not conduct a documented inspection of the facility. As such, the Planning Director did not document the
need for any corrective actions. He will need to follow up with facility personnel to ensure the facility is meeting the requirements
of the MS4 and Industrial Stormwater General Permit requirements. See the notes section below for more details.
If compliance corrective actions were identified, what timeline for correction/follow‐up was provided?
The MS4 inspector verbally indicated that the facility would address the corrective actions identified by the inspection team as soon
as possible; however, the MS4 inspector did not document the areas of concern or associated corrective actions.
Notes/Comments/Recommendations
The facility was a 1 million gallon per day (MGD) wastewater treatment plant. Following discussions with the inspection team, the
Planning Director indicated that, in the future, the MS4 inspection process for facilities covered under Industrial Stormwater
General Permits shall consist of reviewing routine inspection and training records required for compliance under the facility‐specific
Industrial Stormwater General Permits. Based on the inspection records on file, on‐site personnel completed a visual inspection on
November 15, 2018, in accordance with the facility‐specific SWPPP. However, the previous inspection was conducted in 2015. The
inspection team observed the following during the site visit. The Planning Director took notes regarding the areas of concern;
however, he did not complete a formal inspection record.
1. A fuel tank for the on‐site generator is stored on the south side of the front office building and vehicle storage garage
(refer to Appendix B, Photograph 15). The facility’s SWPPP indicates that the fuel tank is double‐walled. The fuel tank is
stored near a catch basin at the southwest corner of the building (refer to Appendix B, Photograph 16), which is piped to
one of the facility’s five stormwater outfalls. There were no spill kit materials present in the vicinity of the fuel tank at the
time of the site visit.
2. On‐site personnel load the sludge tanker trailer from the transfer tank and aerobic digesters at the southwest corner of
the facility (refer to Appendix B, Photograph 17). There is a five‐gallon bucket stored near the loading station that
personnel place underneath the connection during the loading process to catch drips. On‐site personnel also indicated that
they place absorbent pads underneath of the connection during the loading process to further prevent pollutants from
reaching the impervious surface.
3. A used pump and other sewage treatment equipment was stored outside the equipment storage building in the northwest
corner of the facility (refer to Appendix B, Photograph 18). There were multiple pieces of equipment stored in the
MS4 Inspection Report
Maiden, NC: NPDES Permit No. NCS000481
Inspection Date: December 13, 2018 Page 20 of 28
Site Visit Evaluation: Municipal Facility No. 2
stormwater gutter, which flowed downgradient towards Stormwater Outfall No. 2, as identified on the facility map (refer
to Appendix B, Photographs 19, 20, and 21).
4. There were four connected plastic barrels stored adjacent to Stormwater Outfall No. 2 (refer to Appendix B, Photograph
22). On‐site personnel indicated that they used these barrels in the past to support aerators on the pavement during
washing. On‐site personnel indicated they now perform washing above the aeration tanks instead of on the impervious
surface.
5. The five stormwater outfalls for the facility discharge to a conveyance ditch along the northern facility perimeter (refer to
Appendix B, Photograph 23). There is a floodplain separating the drainage ditch from the receiving water to the north,
which on‐site personnel indicated floods frequently (last flooding event was three weeks prior to the site visit). The
Planning Director indicated that the ditch was not included on the Town’s MS4 GIS‐based map as a conveyance or a water
of the state.
Recommendations:
1. The Planning Director should work with facility personnel to ensure the facility is meeting the inspection and training
requirements of the MS4 and Industrial Stormwater General Permits. Recent inspection and training records are present;
however, they have not been historically completed on a routine basis.
2. While on‐site, the inspection team discussed the implementation of best management practices for pollution prevention
and good housekeeping, including storing spill kit materials near the on‐site fuel tank, avoiding storaging equipment along
the stormwater gutters, and washing any materials used for wastewater treatment operations within containment.
3. The Planning Director should evaluate whether the drainage ditch along the northern perimeter of the facility is considered
waters of the state and consider adding it to the Town’s GIS infrastructure map as a receiving water, if not already
identified as such.
These areas of concern would have been noticed and addressed if trained inspectors were conducting regular inspections of the site..
The Planning Director discussed potential solutions to the areas of concern with facility personnel prior to concluding the site visit.
MS4 Inspection Report
Maiden, NC: NPDES Permit No. NCS000481
Inspection Date: December 13, 2018 Page 21 of 28
Site Visit Evaluation: Municipal Facility No. 3
Facility Name:
Town of Maiden Fire Station No. 2
Date and Time of Site Visit:
12/13/2018, 2:36 PM
Facility Address:
5911 Startown Road
Maiden, NC 28650
Facility Type (Vehicle Maintenance, Landscaping, etc.):
Vehicle Maintenance and Equipment Storage
Name of MS4 inspector(s):
Blake Wright, Planning Director, Town of Maiden
Most Recent MS4 Inspection (Date and Entity):
None (see II.G.2.g above)
Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name Title
N/A N/A
Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility‐specific?
No, the facility does not have a SWPPP or similar document.
What type of stormwater training do facility employees receive? How often?
Facility employees have not received stormwater training.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
The Planning Director has not received routine training. He reviewed training materials related to general pollution prevention and
good housekeeping when he was hired and has distributed these materials to employees at the facility to be used as part of their
industrial permit implementation.
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
No. The Planning Director has not conduct inspections at municipal facilities and has not identified facilities and operations outside
of the two covered under industrial permits that need to implement pollution prevention and good housekeeping practices. The
MS4 inspector has only distributed stormwater training materials related to Industrial Stormwater General Permit to a limited
number of Town staff.
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Partial. The Planning Director was able to identify some pollution prevention and good housekeeping issues at the facility but did
not identify and document all areas of concern observed by the inspection team (see the notes below for more detail).
Inspection Procedures
Does the MS4 inspector’s process include the use of a checklist or other standardized form? Obtain copy.
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)?
N/A – the facility does not have a SWPPP.
MS4 Inspection Report
Maiden, NC: NPDES Permit No. NCS000481
Inspection Date: December 13, 2018 Page 22 of 28
Site Visit Evaluation: Municipal Facility No. 3
Does the MS4 inspector’s process include walking the entire facility and inspecting all points of discharge?
No. The Planning Director has not provided MS4 oversight of the facility and has not been conducting routine inspections. The site
visit was conducted primarily to demonstrate to the Planning Director how to properly inspect the entire facility.
Did the MS4 inspector miss any obvious areas of concern? If so, explain:
No. This site visit was conducted to demonstrate to the Planning Director how to complete a proper inspection of the facility;
therefore, the inspection team discussed all areas of concern they identified with the Planning Director.
Does the MS4 inspector’s process include presenting the inspection findings to the facility contact?
The Planning Director indicated that he would report any findings and associated action items to the Fire Chief, who would then
assign corrective actions. However, there were no representatives from the fire department were present during the site visit to
confirm this. The Planning Director did not formally document the corrective actions noted during the site visit.
Inspection Results
Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)?
The Planning Director did not conduct a documented inspection of the facility. As such, he did not document the corrective actions.
See the notes section below for more details.
If compliance corrective actions were identified, what timeline for correction/follow‐up was provided?
The Planning Director verbally indicated that the facility would address the corrective actions identified by the inspection team as
soon as possible; however, he did not formally document the needed corrective actions.
Notes/Comments/Recommendations
The Town of Hickory Fire Station No. 2 is not covered under an Industrial Stormwater General Permit. The site visit was conducted
primarily to demonstrate to the Planning Director how to properly inspect the entire facility. The inspection team observed the
following during the site visit. The Planning Director took notes regarding the identified areas of concern; however, he did not
complete a formal inspection report.
1. The Planning Director did not bring a map into the field showing the direction of stormwater flow onsite, the location of
stormwater inlets, or where runoff discharged from the facility (i.e., off‐site or into the Town’s MS4).
2. Two catch basins are located along the driveway entrance to the facility. The catch basin at the intersection of the facility
driveway and Elbow Road captures stormwater from the northern perimeter of the facility and drains back into the Town’s
MS4 (refer to Appendix B, Photographs 24 and 25). The catch basin at the split in the driveway directly west of the
northern parking lot (refer to Appendix B, Photograph 26) collects stormwater from the parking lot and surrounding area
directly north of the fire station building. The catch basin directly west of the northern parking lot drains to an outfall
structure on the west side of the driveway (refer to Appendix B, Photograph 27). The outfall structure discharges to a flat
plane where stormwater pools prior to draining directly west towards the post‐construction SCM at the Apple Data Center
(refer to Appendix B, Photographs 28 and 29). Stormwater discharged from the outfall exits the facility underneath the
fence surrounding western perimeter (refer to Appendix B, Photograph 30) and flows to a low spot in the drainage ditch
surrounding the Apple SCM. The Town does not know the specific pollutant sources impacting these areas since the Town
has not evaluated the facility as part of the pollution prevention and good housekeeping program.
3. An uncovered dumpster and a rusted storage container were stored at the top of the hill directly west of the fire station
building (refer to Appendix B, Photograph 31). Based on the topography of the facility, it appeared that stormwater from
this area would flow to the Apple SCM off‐site to the west.
4. Three barrels containing or once containing pollutants were stored without secondary containment directly west of the
fire station building (refer to Appendix B, Photograph 32). The labels indicated that the barrels contained, or previously
contained, finishing products, including “HC Sealer” and “NGR Stain” (refer to Appendix B, Photograph 33). The barrels
were stored adjacent to a stack of wooden pallets and an uncovered dumpster, which provided another potential pollutant
source.
MS4 Inspection Report
Maiden, NC: NPDES Permit No. NCS000481
Inspection Date: December 13, 2018 Page 23 of 28
Site Visit Evaluation: Municipal Facility No. 3
5. The Planning Director thought that all fire department vehicles were washed inside the garage at Fire Station No. 2 (refer
to Appendix B, Photograph 34), which is equipped with an underlying trench drain that discharges to the sanitary sewer
(refer to Appendix B, Photograph 35). A facility representative was not present to confirm this.
Recommendations:
1. The Planning Director should bring a facility map with pertinent stormwater runoff and discharge information into the field
as a reference while conducting inspections.
2. While on‐site, the inspection team discussed the implementation of best management practices for pollution prevention
and good housekeeping, including keeping on‐site dumpsters covered, emptying dumpsters when they have reached
capacity, and removing discarded materials such as chemical storage barrels and wooden pallets as soon as possible.
3. The Planning Director should consider following up with Fire Department representatives to confirm that all Fire
Department vehicle washing occurs indoors at this facility and not outdoors at another facility.
These areas of concern would have been noticed and addressed if trained inspectors were conducting regular inspections of the site.
MS4 Inspection Report
Maiden, NC: NPDES Permit No. NCS000481
Inspection Date: December 13, 2018 Page 24 of 28
Site Visit Evaluation: Post‐Construction Stormwater Control Measure No. 1
Site Name:
Police Department Detention Pond (Publicly‐Owned)
Date and Time of Site Visit:
12/13/2018, 3:16 PM
Site Address:
400 E Main Street
Maiden, NC 28650
SCM Type:
Detention Pond
Most Recent MS4 Inspection (Include Date and Entity):
None (See II.F.2.g above)
Name of MS4 inspector(s):
Blake Wright, Planning Director, Town of Maiden
Most Recent MS4 Enforcement Activity (Include Date):
None (see II.F.2.i above)
Name(s) and Title(s) of Site Representative(s) Present During the Site Visit:
Name Title
N/A N/A
Observations
Site Documentation
Does the site have an operation and maintenance plan?
The site did not have an O&M plan available. The MS4 inspector did not believe that the site had an O&M plan. The MS4 inspector
did not contact the facility representative to inquire about an O&M plan.
Does the site have records of annual inspections? Are they performed by a qualified individual?
There were no records of previous inspections (see II.F.2.g above).
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
The Planning Director attended the NC State University post‐construction SCM training and state MS4 outreach meetings. He has
not participated in other routine training.
Did the MS4 inspector appear knowledgeable about MS4 requirements for post‐construction site runoff controls?
Partial. The Planning Director is responsible for reviewing all post‐construction SCM plans in accordance with the Town’s
stormwater ordinance and the NCDEQ Stormwater BMP Manual. However, he does not maintain an inventory of post‐construction
SCMs within Town limits and does not provide formal oversight of public or private SCMs to ensure long‐term O&M.
Did the MS4 inspector appear knowledgeable about post‐construction BMPs (general purpose/function, components, O&M
requirements, etc.)?
Partial. The Planning Director was familiar with the general purpose, function, and components of the SCM; however, he did not
review the SCM design specifications, O&M plans, or as‐builts as part of the inspection.
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. The MS4 inspector did not have an O&M plan available for review during the inspection. The Town did not have any records of
annual inspections. Additionally, the Planning Director did not have access to the SCM design specification or as‐builts during the
inspection.
MS4 Inspection Report
Maiden, NC: NPDES Permit No. NCS000481
Inspection Date: December 13, 2018 Page 25 of 28
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. The Town does not have a process or program for SCM inspections. This site visit was conducted to demonstrate to the
Planning Director how to properly inspect an SCM and assess the discharge point.
Did the MS4 inspector miss any obvious operation and maintenance deficiencies? If so, explain:
Yes. The Planning Director was unable to identify operational deficiencies within the SCM, in part because he did not have the
design specifications and as‐builts available.
Does the MS4 inspector’s process include presenting the inspection findings to the site contact in writing?
No. The Town does not have a routine process or program for SCM inspections. There was not a facility contact present during the
site visit. The Planning Director did not document any observations to provide to a facility contact at a later time.
Compliance/Enforcement
What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in?
None. The Planning Director did not document any observed areas of concern for further communication with the facility contact.
The SCM was completed in October 2018 and appeared to be in good working condition.
If compliance issues were identified, what timeline for correction/follow‐up was provided?
None. The Planning Director did not document any areas of concern for further communication with the facility contact. The SCM
was completed in October 2018 and appeared to be in good working condition.
Notes/Comments/Recommendations
The SCM is a detention pond located on the south side of the Police Department building at 400 East Main Street (refer to Appendix
B, Photograph 36). The detention pond contains two influent structures, one in the northwest corner of the SCM (refer to Appendix
B, Photograph 37) and one in the northeast corner of the SCM (refer to Appendix B, Photograph 38), with an outfall structure and
emergency spillway in the southwest corner (refer to Appendix B, Photograph 39). The SCM receives influent from catch basins
located at the southeast, northeast, northwest, and southwest corners of the Police Department building (refer to Appendix B,
Photographs 40, 41, 42, and 43, respectively), in addition to two catch basins in the parking lot north of the Police Department
building (refer to Appendix B, Photographs 44 and 45).
Because Town representatives were unable to provide design specifications, O&M requirements, or as‐builts for the SCM, the
inspection team was unable to determine if the SCM required maintenance. The Planning Director indicated that construction of
the SCM was completed in early October 2018. The SCM appeared to be in good working condition at the time of the site visit. The
Town does not currently provide oversight of post‐construction SCMs at municipal facilities; therefore, the site visit was conducted
primarily to demonstrate to the Planning Director how to properly conduct an inspection to ensure long term O&M. The inspection
team raised concerns about sheet flow entering the SCM from the parking lot on the south side of the Police Department building
and transporting sediment and gravel into the pond. Gravel can be seen lining the north edge of the SCM in Appendix B,
Photograph 36.
Recommendations:
1. The Planning Director should work with the Police Department representatives to develop a long‐term O&M plan for the
on‐site SCM, and ensure routine inspections are being conducted by a qualified professional.
2. The Planning Director should ensure that design specifications, as‐builts, and long‐term O&M plans are available and
referenced for the purposes of successfully conducting routine inspections.
3. The Planning Director should ensure the SCM and associated discharge point at this facility is inventoried within the Town’s
MS4 map.
MS4 Inspection Report
Maiden, NC: NPDES Permit No. NCS000481
Inspection Date: December 13, 2018 Page 26 of 28
Site Visit Evaluation: Post‐Construction Stormwater Control Measure No. 2
Site Name:
GKN Detention Pond (Privately‐Owned)
Date and Time of Site Visit:
12/13/2018, 3:43 PM
Site Address:
1848 GKN Way
Newton, NC 28658
SCM Type:
Detention Pond
Most Recent MS4 Inspection (Include Date and Entity):
None (See II.F.2.g above)
Name of MS4 inspector(s):
Blake Wright, Planning Director, Town of Maiden
Most Recent MS4 Enforcement Activity (Include Date):
None (see II.F.2.i above)
Name(s) and Title(s) of Site Representative(s) Present During the Site Visit:
Name Title
N/A N/A
Observations
Site Documentation
Does the site have an operation and maintenance plan?
There was no O&M plan available at the time of the site visit. The MS4 inspector did not contact the facility representative to
inquire about an O&M plan.
Does the site have records of annual inspections? Are they performed by a qualified individual?
There were no records of previous inspections (see II.F.2.g above) and the MS4 inspector (the Town’s Stormwater Administrator)
indicated that GKN has not submitted any inspection reports to the municipality.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
The Planning Director attended the NC State University post‐construction SCM training as well as state MS4 outreach meetings. He
has not participated in other routine training.
Did the MS4 inspector appear knowledgeable about MS4 requirements for post‐construction site runoff controls?
Partial. The Planning director is responsible for reviewing all post‐construction SCM plans in accordance with the Town’s
stormwater ordinance and the NC DEQ Stormwater BMP Manual. However, he does not maintain an inventory of post‐construction
SCMs within Town limits and does not provide formal oversight of public or private SCMs to ensure long‐term O&M.
Did the MS4 inspector appear knowledgeable about post‐construction BMPs (general purpose/function, components, O&M
requirements, etc.)?
Partial. The Planning Director was familiar with the general purpose, function, and components of the SCM; however, he did not
review the SCM design specifications, O&M plans, or as‐builts as part of the inspection.
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. There was no O&M plan available for review during the inspection and the site has not submitted any annual inspections to the
Town. Additionally, the Planning Director did not have access to the SCM design specification or as‐builts during the inspection.
MS4 Inspection Report
Maiden, NC: NPDES Permit No. NCS000481
Inspection Date: December 13, 2018 Page 27 of 28
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?
The Town does not have a routine process or program for SCM inspections. In this case, the Planning Director walked the perimeter
of the SCM, looked at the discharge structure, but did not inspect the receiving water because it was behind a fence and difficult to
access.
Did the MS4 inspector miss any obvious operation and maintenance deficiencies? If so, explain:
The Planning Director was unable to identify operational deficiencies within the SCM, since he did not have the design
specifications and as‐builts available for review.
Does the MS4 inspector’s process include presenting the inspection findings to the site contact in writing?
No. The Town does not have a routine process or program for SCM inspections. There was not a facility contact present during the
site visit. The Planning Director did not document any observations to provide to a facility contact at a later time.
Compliance/Enforcement
What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in?
None. The Planning Director took notes during the site visit but did not formally document areas of concern to provide to a facility
contact at a later time.
If compliance issues were identified, what timeline for correction/follow‐up was provided?
None. The Planning Director took notes during the site visit but did not formally document areas of concern to provide to a facility
contact at a later time.
Notes/Comments/Recommendations
The SCM is a detention pond located southeast of the GKN Driveline facility at 1848 GKN Way. The detention pond is split into an
upper forebay (refer to Appendix B, Photograph 46) and lower detention area (refer to Appendix B, Photograph 47), and contains
an outfall structure in the southeast corner of the detention area (refer to Appendix B, Photograph 48). The outfall structure
discharges outside of the berm encompassing the detention pond to a flat plane directly west of the receiving water (refer to
Appendix B, Photographs 49 and 50). Stormwater from the discharge point drains through the fenced perimeter of the GKN
Driveline facility to a tributary of Pinch Gut Creek (refer to Appendix B, Photograph 51). Two influent pipes located above the
northwest corner of the detention pond (refer to Appendix B, Photographs 52 and 53) drain to a stormwater ditch along the
western perimeter of the SCM, which bypasses the northern (upper) portion of the upper forebay (refer to Appendix B,
Photograph 54). Stormwater conveyed through the drainage ditch along the western perimeter of the detention pond discharges to
the SCM at a point within the southern (lower) half of the upper forebay (refer to Appendix B, Photograph 55). The influent point
also receives stormwater conveyed through a series of drainage ditches directly west of the GKN Driveline driveway (refer to
Appendix B, Photographs 56 and 57).
To date, GKN has not submitted annual inspection reports to the Town. The inspection team noted the following potential
maintenance needs. Because design specifications, O&M requirements, and as‐builts for the SCM were unavailable at the time of
the site visit, the inspection team was unable to verify that these observations explicitly constituted maintenance needs. While the
Planning Director recognized these observations as potential deficiencies, he did not document them with photographs and/or an
inspection report.
1. Sections within the upper and lower forebays lacked vegetation and were completely bare (refer to Appendix B,
Photographs 46 and 47). The inspection team noted the presence of vehicle tracks in the lower forebay, indicating sections
of the detention pond may have been recently dug up and re‐graded without re‐planting vegetation.
2. The area surrounding the outfall structure at the southeast corner of the SCM was overgrown. The outfall structure was
also missing its concrete top and grate (refer to Appendix B, Photograph 48).
3. The current configuration of influent flow to the SCM completely bypasses the northern (upper) portion of the upper
forebay. The point in which influent drains to the detention area is below the invert of much of the forebay (refer to
Appendix B, Photograph 46). As a result, only about 50 percent of the upper forebay appeared like it would be used under
most conditions. It was unclear if the pond was designed like this or if the pond needed to be regraded.
MS4 Inspection Report
Maiden, NC: NPDES Permit No. NCS000481
Inspection Date: December 13, 2018 Page 28 of 28
Site Visit Evaluation: Post‐Construction Stormwater Control Measure No. 2
4. Rip rap and matting previously placed at the influent point within the southern (lower) portion of the upper forebay, which
receives all inflow from stormwater ditches upgradient of the SCM, has been either washed away or degraded, exposing
bare rock and soil (refer to Appendix B, Photograph 55).
Recommendations:
1. The Planning Director should consider reviewing the design specifications, as‐builts, and long‐term O&M plan (if one exists)
to determine if all elements of the post‐construction SCM at the GKN Driveline facility have been built according to design.
2. The Planning Director should consider following up with GKN to determine why GKN has not submitted annual inspection
reports for the SCM to the Town.
3. The Planning Director may consider implementation of enforcement actions against GKN if he can verify that the SCM is in
need of maintenance. GKN’s failure to submit annual inspection reports can be used as a supplement to any enforcement
actions taken.
4. In order to be able to implement enforcement actions effectively, the Planning Director should work with other Town
representatives to adopt mechanisms for enforcement, including an enforcement response plan, into the Town’s
stormwater ordinance or Stormwater Plan.
5. As good practice, the Planning Director should ensure that all post‐construction SCMs, public or private, and associated
discharge points are inventoried in the Town’s MS4 map.