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NCS000478_Laurel Park MS4 AUDIT REPORT_20190826
MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) PROGRAM AUDIT REPORT NPDES PERMIT NO. NCS000478 Town of Laurel Park, North Carolina 441 White Pine Drive Laurel Park, North Carolina 28739 Audit Date: August 12, 2019 Report Date: August 26, 2019 North Carolina Department of Environmental Quality Division of Energy, Mineral & Land Resources Stormwater Program 512 N. Salisbury Street, 9th floor 1612 Mail Service Center Raleigh, NC 27699-1612 (This page intentionally left blank) NCS000478 Laurel Park MS4 Audit 20190826 TABLE OF CONTENTS AuditDetails..................................................................................................................................................1 PermitteeInformation..................................................................................................................................2 Listof Supporting Documents.......................................................................................................................3 Program Implementation, Documentation & Assessment...........................................................................4 Public Education and Outreach.....................................................................................................................8 Public Involvement and Participation.........................................................................................................11 Illicit Discharge Detection and Elimination(IDDE)......................................................................................13 Construction Site Runoff Controls.................................................................. Error! Bookmark not defined. Post -Construction Site Runoff Controls......................................................... Error! Bookmark not defined. Pollution Prevention and Good Housekeeping for Municipal Operations..................................................16 Total Maximum Daily Loads(TMDLs)............................................................. Error! Bookmark not defined. Site Visit Evaluation: Municipal Facility No. 1.............................................................................................19 Site Visit Evaluation: Municipal Facility No. 2................................................ Error! Bookmark not defined. Site Visit Evaluation: MS4 Outfall No. 1......................................................................................................21 Site Visit Evaluation: MS4 Outfall No. 2......................................................... Error! Bookmark not defined. Site Visit Evaluation: Construction Site No. 1................................................. Error! Bookmark not defined. Site Visit Evaluation: Construction Site No. 2................................................. Error! Bookmark not defined. Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1Error! Bookmark not defined. Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 2Error! Bookmark not defined. Appendix A: Supporting Documents Appendix B: Photograph Log DISCLAIMER This audit consists of an evaluation of program compliance with the issued permit and implementation of the approved Stormwater Management Plan. This audit report does not include a review of all program components, and program deficiencies in addition to those noted may be present. The permittee is required to assess program progress and permit compliance, and to implement the approved Stormwater Management Plan in accordance with the issued permit. NCS000478 Laurel Park MS4 Audit 20190826 ii This page intentionally left blank NCS000478 Laurel Park MS4 Audit 20190826 Hi Audit Details Audit ID Number: Audit Date(s): NCS000478_Town of Laurel Park MS4 Audit_20190821 August 12, 2019 Minimum Control Measures Evaluated: ® Program Implementation, Documentation & Assessment ® Public Education & Outreach ® Public Involvement & Participation ® Illicit Discharge Detection & Elimination ❑ Construction Site Runoff Controls — No delegated Sediment and Erosion Control Program ❑ Construction Site Runoff Controls — Delegated Sediment and Erosion Control Program ❑ Post -Construction Site Runoff Controls A Pollution Prevention and Good Housekeeping for Municipal Operations ❑ Total Maximum Daily Loads (TMDLs) Field Site Visits: ® Municipal Facilities. Number visited: 1 © MS4 Outfalls. Number visited: 1 ❑ Construction Sites. Number visited: Choose an item. ❑ Post -Construction Stormwater Runoff Controls. Number visited: Choose an item. ❑ Other: Number visited: Choose an item. ❑ Other: Number visited: Choose an item. Inspector(s) Conducting Audit Name, Title Organization Isaiah Reed, Environmental Specialist DEMLR Author Audit Repj Date: Signatureort CJ 'Z6 - ( Audit Report Author: Date Signature NCS000478—Town of Laurel Park MS4 Audit_20190826 Page 1 of 22 Permittee Information MS4 Permittee Name: Town of Laurel Park Permit Effective Date: February 20, , Permit Expiration Date: February 19, 2022 Mailing Address: Date of Last MS4 Inspection/Audit: N/A Co-permittee(s), if applicable: N/A Permit Owner of Record: Primary MS4 Representatives Participating in Audit Name, Title Organization Andrew Griffin, Public Works Director Town of Laurel Park Christopher Todd, Town Manager Town of Laurel Park Natalie Berry, Project Engineer Henderson County MS4 Receiving Waters Waterbodv Classification Impairments Shaw Creek WS-IV None Echo Lake and Briar Lake WS-IV None Brightwater Branch WS-IV,B None Finley Creek B None North Fork Big Willow Creek C;Tr None Tony's Creek B None Wash Creek B None NCS000478_Town of Laurel Park MS4 Audit_20190826 Page 2 of 22 List of SupportingDocuments Item Number.: Document Title When Provided (Prior to/During/After) 1 Sign -In Sheet During 2 New Resident Information Packet During 3 Stormwater Phase II Post -Construction Annual Inspection Requirements During 4 Water Supply Watershed Operation and Maintenance Inspection Report During 5 Storm Water Operation and Maintenance Inspection Report During 6 Water Supply Watershed Annual Inspection Requirements During 7 Local Water Supply Watershed Management Permit During 8 MS4 Map During 9 Town of Laurel Park Quarterly Newsletter During 10 Chapter 8, Article XXXV Stormwater Management Ordinance Prior to 11 Agreement for Stormwater & Water Supply Watershed Enforcement & Admin. Assistance Prior to 12 BMP Summary Prior to 13 Stormwater Management Program Assessment Prior to 14 2010 SWMP Report Prior to 15 Training Certifications Priorto NCS000478_Town of Laurel Park MS4 Audit_20190826 Page 3 of 22 Program Implementation, Documentation & Assessment Staff Interviewed: Christopher Todd, Town Manager (Name, Title, Role) Andrew Griffin, Public Works Director Permit Citation Program Requirement Status supporting Doc No. II.A.1 The permittee maintained adequate funding and staffing to implement and manage Staffing and the provisions of the Stormwater Plan and meet all requirements of the permit. ves Funding The Stormwater Plan identifies a specific position(s) responsible for the overall coordination, implementation, and revision to the Plan. No 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 (see Stormwater e-payments on DEMLR MS4 web page). Yes The permittee did not maintain, update, or review the Stormwater Management Plan II.A.2 Stormwater The permittee evaluated the performance and effectiveness of the program Plan components at least annually. Partial 13 Implementation and Evaluation 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. Partial --- Did the permitted MS4 discharges cause or contribute to non -attainment of an applicable water quality standard? No If yes, did the permittee expand or better tailor its BMPs accordingly to address Not the non -attainment? Applicable The Program assessment (last documented was 2018) was used as a way of documenting a partial annual evaluation. NCS000478_Town of Laurel Park MS4 Audit_20190826 Page 4 of 22 Program Implementation, Documentation & Assessment IIA.3 Keeping the The permittee kept the Stormwater Plan up to date. No Stormwater. Plan Up to Date The permittee notified DEMLR of any updates to the Stormwater Plan. No --- The permittee did not maintain, update, or review the Stormwater Management Plan. II.A.4 Availability The permittee kept an up-to-date version of its Stormwater Plan available to the of the Stormwater Division and the public online. No Plan The online materials included ordinances, or other regulatory mechanisms, or a list identifying the ordinances, or other regulatory mechanisms, providing the legal Partial - authority necessary to implement and enforce the requirements of the permit. Website has ordinance, but not the SWMP. II.A.3 &iII.A.5 Stormwater Plan Did DEMLR require a modification to the Stormwater Plan? Not Reviewed Modifications If yes, did the permittee complete the modifications in accordance with the Not established deadline? Applicable 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 The Post construction Stormwater Program is implemented by Henderson County. IIII.A.7.7 The permittee maintained written procedures for implementing the six minimum Written control measures. No Procedures Written procedures identified specific action steps, schedules, resources and responsibilities for implementing the six minimum measures. No The permittee did not maintain, update, or review the Stormwater Management Plan and associated written procedures. NCS000478_Town of Laurel Park MS4 Audit_20190826 Page 5 of 22 Program Implementation, Documentation & Assessment III_A -. The permittee maintained documentation of all program components including, but Program not limited to, inspections, maintenance activities, educational programs, No --- Documentation implementation of BMPs, enforcement actions etc., on file for a period of five years. III_B The permittee submitted annual reports to the Department within twelve months Annual Report from the effective date of the permit (See Section 111.B. for the annual reporting No --- Submittal period specific to this MS4). The permittee submitted subsequent annual reports every twelve months from the scheduled date of the first annual report submittal. No The Annual Reports included appropriate information to accurately describe the progress, status, and results of the permittee's Stormwater Plan, including, but not limited the following: 1. A detailed description of the status of implementation of the Stormwater Plan as a whole. This will include information on development and implementation of each major component of the Stormwater Plan for the past year and No --- schedules and plans for the year following each report. 2. An adequate description and justification of any proposed changes to the Stormwater Plan. This will include descriptions and supporting information for the proposed changes and how these changes will impact the Stormwater No --- Plan (results, effectiveness, implementation schedule, etc.). 3. Documentation of any necessary changes to programs or practices for assessment of management measures implemented through the Stormwater No --- Plan. 4. A summary of data accumulated as part of the Stormwater Plan throughout the year along with an assessment of what the data indicates in light of the No --- Stormwater Plan. S. An assessment of compliance with the permit, information on the establishment of appropriate legal authorities, inspections, and enforcement No --- actions. No documented annual reports have been submitted. IV.B Annual Reporting The Annual Reports document the following: 1. A summary of past year activities, including where applicable, specific quantities achieved and summaries of enforcement actions. No --- 2. A description of the effectiveness of each program component. No --- 3. Planned activities and changes for the next reporting period, for each program component or activity. No NCS000478_Town of Laurel Park MS4 Audit_20190826 Page 6 of 22 Program Implementation, Documentation & Assessment 4. Fiscal analysis. 7 No No documented annual reports have been submitted. Additional Comments: NCS000478_Town of Laurel Park MS4 Audit_20190826 Page 7 of 22 Public Education and Outreach Staff Interviewed: Christopher Todd, Town Manager (Name, Title, Role) Andrew Griffin, Public Works Director Permit Citation Program Requirement :Status Supporting, Doc No. II.B.2.a Goals and The permittee defined goals and objectives of the Local Public Education and Objectives No --- Outreach Program based on community wide issues. No Stormwater Management Plan has been maintained and updated to include a current list of defined goals. II.B.2.b The permittee maintained a description of the target pollutants and/or stressors and Target Pollutants likely sources. yes 2 and 9 The "New Resident Packet" and Newsletter presented at the time of the audit contain some information on target pollutants. II.B.2.c The permittee identified, assessed annually and updated the description of the target Target Audiences audiences likely to have significant storm water impacts and why they were selected. No The Stormwater Program has not been maintained and kept up to date. NCS000478_Town of Laurel Park MS4 Audit_20190826 Page 8 of 22 Public Education and Outreach II.6.2.d Residential The permittee described issues, such as pollutants, the likely sources of those and Industrial/ pollutants, potential impacts, and the physical attributes of stormwater runoff in yes 2 and 9 Commercial Issues their education/outreach program. The "New Resident Packet" and Newsletter presented at the time of the audit contain some information on pollutant sources. `.11.B.2.e Informational The permittee promoted and maintained an internet web site designed to convey the Web Site program'smessage. No --- https://www.laurelpark.org/ The Town website does not have a section for the stormwater program. 11.B.2.f Public Education The permittee distributed stormwater educational material to appropriate target 1: yes 2 and 9 Materials groups. The newsletter goes to all residents and property owners in the town Laurel park. New residents also receive a welcome packet with some information on stormwater as well. II.B.2.Q The permittee promoted and maintained a stormwater hotline/helpline for the Hotline/Help Line purpose of public education and outreach. Partial 2 and 9 A number is made available through the newsletter and information packet, but not specifically identified as the hotline for stormwater complaints. NCS000478_Town of Laurel Park MS4 Audit_20190826 Page 9 of 22 Public Education and Outreach II.B.2.h The permittee's outreach program, including those elements implemented locally or Public Education through a cooperative agreement, included a combination of approaches designed to No --- and Outreach reach the target audiences. Program For each media, event or activity, including those elements implemented locally or through a cooperative agreement the permittee estimated and recorded the extent No --- of exposure. No documented public outreach was available other than the newsletter and information packet. Additional The program would benefit from more outreach focused directly on stormwater pollution prevention. Comments: The program would benefit from outreach directed specifically at businesses and not just land owners, due to the likelihood of leased businesses. NCS000478_Town of Laurel Park MS4 Audit_20190826 Page 10 of 22 Public Involvement and Participation Staff Interviewed: Christopher Todd, Town Manager (Name, Title, Role) Andrew Griffin, Public Works Director Permit Citation Program Requirement .Status Supporting DOC No. II.C.2.a Volunteer Community The permittee included and promoted volunteer opportunities designed to promote Involvement Yes --- ongoing citizen participation. Program Town staff hold a semi-annual "litter pickup" which usually has 8-20 volunteers. II.C.2.b Mechanism for The permittee provided and promoted a mechanism for public involvement that Public provides for input on stormwater issues and the stormwater program. No Involvement No specific element identified for this purpose. II.C.2.c The permittee promoted and maintained a hotline/helpline for the purpose of public Hotline/Help Line involvement and participation. Yes The Laurel Park website links to the Friends of Laurel Park website which has information on upcoming community events and volunteer opportunities. NCS000478_Town of Laurel Park MS4 Audit_20190826 Page 11 of 22 IPublic Involvement and Participation Additional The Town Comments: exposure). would benefit from better documenting the public involvement (such as hours NCS000478_Town of Laurel Park MS4 Audit_20190826 Page 12 of 22 Illicit Discharge Detection and Elimination (IDDE) Staff Interviewed: Christopher Todd, Town Manager (Name, Title, Andrew Griffin, Public Works Director Role) Permit Citation Program Requirement Status supporting" DouNo.. 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 Choose evaluation and integrating program. an item. No Stormwater Management Program has been maintained. The permittee maintained an IDDE ordinance or other regulatory mechanism(s) that II.D.2.b provides the legal authority to prohibit illicit connections and discharges to the MS4. yes 10 Legal Authorities If yes, the ordinance applies throughout the corporate limits of the permittee. [Permit Part I.D] Yes 10 II.D.2.c The permittee maintained a current map showing major outfalls and receiving Storm Sewer Partial 8 System Map streams. The map presented does not distinguish major outfalls, and does not clearly depict all receiving streams. II.D.2.d Dry Weather Flow The permittee maintained a program for conducting dry weather flow field No observations in accordance with written procedures. --- Program No dry weather field observation program has been implemented. NCS000478_Town of Laurel Park MS4 Audit_20190826 Page 13 of 22 Illicit Discharge Detection and Elimination (IDDE) ILD.2.e The permittee maintained written procedures for conducting investigations of Investigation identified illicit discharges. Partial --- Procedures While some written procedures are available, no written procedure was maintained specifically for stormwater discharge. II.D.2.f For each case of an illicit discharge or potential illicit discharge, the permittee documented and tracked the Track and following: Document Investigations 1. The date(s) the illicit discharge was observed No --- 2. The results of the investigation No --- 3. Any follow-up of the investigation No --- 4. The date the investigation was closed No --- No tracking system was available at the time of the audit. II.D.2.¢ 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 Yes 15 contact with or otherwise observe an illicit discharge or illicit connection. II.D.2.h The permittee informed public employees of hazards associated with illegal Public Education discharges and improper disposal of waste. Yes 2 and 9 The permittee informed businesses of hazards associated with illegal discharges and improper disposal of waste. Yes 2 and 9 The permittee informed the general public of hazards associated with illegal discharges and improper disposal of waste. Yes 2 and 9 The program would benefit from information directed specifically at businesses and not just land owners, due to the likelihood of leased businesses. NCS000478_Town of Laurel Park MS4 Audit_20190826 Page 14 of 22 Illicit Discharge Detection and Elimination (IDDE) II.D.2.i The permittee promoted, publicized, and facilitated a reporting mechanism for the Public Reporting public to report illicit discharges. No --- Mechanism The permittee promoted, publicized, and facilitated a reporting mechanism for staff to report illicit discharges. No --- The permittee established and implemented response procedures for citizen requests/reports. No Outreach material and website do not specifically provide a mechanism for reporting illicit discharge. The permittee implemented a mechanism to track the issuance of notices of violation Not Enforcement and enforcement actions administered by the permittee. Applicable --- If yes, the mechanism includes the ability to identify chronic violators for Not initiation of actions to reduce noncompliance. Applicable The permittee has not issued any notices of violation. Additional A focused effort to inform the public about what illicit discharge is, and how to report it, would result in a Comments: more thorough and productive illicite discharge, detection and elimination program. NCS000478_Town of Laurel Park MS4 Audit_20190826 Page 15 of 22 Pollution Prevention and Good Housekeeping for Municipal Operations Staff Interviewed: Christopher Todd, Town Manager (Name, Title, Role) Andrew Griffin, Public Works Director Permit Citation Program Requirement Status supporting Doc No. , II.G.2.a The permittee maintained a current inventory of facilities and operations owned `Facility Inventory and operated by the permittee with the potential for generating polluted No --- stormwater runoff. II.G.2.b The permittee maintained and implemented an 0&M program for municipally Operation and owned and operated facilities with the potential for generating polluted No ... Maintenance .(O&M) stormwater runoff. for Facilities If yes, the 0&M program specifies the frequency of inspections. Not Applicable If yes, the O&M program specifies the frequency of routine maintenance Not requirements. Applicable If yes, the permittee evaluated the 0&M program annually and updated it as Not necessary. Applicable No O&M program has been maintained for municipal facilities. II.G.2.c Spill Response The permittee had written spill response procedures for municipal operations. Not Procedures Reviewed II.G.2.d Streets, The permittee evaluated existing and new BMPs that reduce polluted stormwater Roads, and Public runoff from municipally -owned streets, roads, and public parking lots within its No --- corporatelimits annually. NCS000478_Town of Laurel Park MS4 Audit_20190826 Page 16 of 22 Pollution Prevention and Good Housekeeping for Municipal Operations Parking Lots Maintenance permittee evaluated the effectiveness of existing and new BMPs 7basesd Not .-- cost and the estimated quantity of pollutants removed. applicable No review was documented. II.G.2.f O&M for Catch The permittee maintained and implemented an O&M program for the stormwater Basins and sewer system including catch basins and conveyance systems that it owns and No --- Conveyance Systems maintains. ILG.Z.e The permittee maintained a current inventory of municipally -owned or operated Structural structural stormwater controls installed for compliance with the permittee's post- No Stormwater Controls constructionordinance. No inventory was available at the time of the audit. II.G.2.d The permittee maintained and implemented an C&M program for municipally - O&M for Structural owned or maintained structural stormwater controls installed for compliance with No Stormwater Controls the permittee's post -construction ordinance. If yes, then: 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. Na The permittee inspected all municipally -owned or maintained structural stormwater controls in accordance with the schedule developed by permittee. No The permittee maintained 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 II.G.2.f The permittee ensured municipal employees are properly trained in pesticide, Pesticide, Herbicide herbicide and fertilizer application management. Yes 15 and Fertilizer Application The permittee ensured contractors are properly trained in pesticide, herbicide and Management fertilizer application management. Yes NC5000478_Town of Laurel Park MS4 Audit_20190826 Page 17 of 22 :Pollution Prevention and Good Housekeeping for Municipal Operations The permittee ensured all permits, certifications, and other measures for applicators are followed. ves II.G.2.g The permittee implemented an employee training program for employees involved Staff Training in implementing pollution prevention and good housekeeping practices. Yes 15 II.G.2h The permittee described and implemented measures that prevent or minimize Vehicle and contamination of stormwater runoff from all areas used for vehicle and equipment No Equipment Cleaning cleaning. Additional Comments: NCS000478_Town of Laurel Park MS4 Audit_20190826 Page 18 of 22 Site Visit Evaluation: Municipal Facility No. 1 Facility Name: Public Works Department Date and Time of Site Visit: August 12, 2019 Facility Address: 500 Toms Drive Facility Type (Vehicle Maintenance, Landscaping, etc.): Public Works Name of MS4 inspector(s) evaluated: Andrew Griffin, Public Works Director Most Recent MS4 Inspection (List date and name of inspector): N/A .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. What type of stormwater training do facility employees receive? How often? No training specific to stormwater. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Certification training, no specific schedule. Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? No. Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping? Yes. Inspection Procedures Does the MS4 inspector's process include the use of a checklist or other standardized form? 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 NCS000478_Town of Laurel Park MS4 Audit_20190826 Page 19 of 22 Site Visit Evaluation: Municipal Facility No. 1 Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge? No. Did the MS4 inspector miss any obvious areas of concern? If so, explain: No. Does the MS4 inspector's process include presenting the inspection findings to the facility contact? No. Inspection Results Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)? Yes. Will be providing follow up information later. If compliance corrective actions were identified, what timeline for correction/follow-up was provided? N/A Notes/Comments/Recommendations The facility inspection was largely a discussion about how to properly implement an inspection program in the future. No regular stormwater inspections had been documented at the facility. NCS000478_Town of Laurel Park MS4 Audit_20190826 Page 20 of 22 Site Visit Evaluation: MS4 Outfall No. 1 Outfall ID Number: Date and Time of Site Visit: No specific number given for the outfall. August 12, 2019 Outfall Location: Outfall Description (Pipe Material/Diameter, Culvert, etc.): Shaw's Creek Farm Road. Various. Location where several stormwater conveyances meet at a stream crossing. Receiving Water: Is Flow Present? If So, Describe (Color, Approximate Flow Rate, Shaw Creek (WS-IV) Sheen, Odor, Floatables/Debris, etc.): None observed Most Recent Outfall Inspection/Screening (Date): None Days Since Last Rainfall: Inches: Not Evaluated Name of MS4lnspector(s) evaluated: Andrew Griffin, Public Works Director Observations Inspector Training/Knowledge: What type of stormwater training does the MS4 inspector receive? How often? Certification Training. No specific schedule. Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations? Yes. Inspection Procedures Does the inspector's process include the use of a checklist or other standardized form? No. Does the inspector's process include taking photos? No. Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they? No. NCS000478_Town of Laurel Park MS4 Audit_20190826 Page 21 of 22 Site VisitEvaluation: MS4 Outfall No. 1 Inspection Results Did the outfall inspection result in any work orders or maintenance requests? If so, for what issue(s)? No. Will a follow-up outfall inspection be conducted? If so, for what reason? No. Notes/Comments/Recommendations The inspection was mainly a discussion concerning future inspections, inspection purpose, and illicit discharge. NCS000478_Town of Laurel Park MS4 Audit_20190826 Page 22 of 22