NCS000250_NCDOT Buncombe Co Construction Inspection_20190625

MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM AUDIT REPORT
NPDES PERMIT NO. NCS000250
Buncombe County, NORTH CAROLINA
Construction Site in Asheville, NC
Audit Date: June 25, 2019
Report Date: June 25, 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
NCS0002S0 Marion MS4 Audit 20190603

Audit Details
Audit ID Number:
Audit Date(s):
NCS000250_ MS4 Audit_20190603
June 25, 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
❑ Pollution Prevention and Good Housekeeping for Municipal Operations
❑ Total Maximum Daily Loads (TMDLs)
Field Site Visits:
❑ Municipal Facilities. Number visited: Choose an Item.
❑ MS4 Outfalls. Number visited: Choose an item.
© Construction Sites. Number visited: 1
❑ 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
Orzanization
Isaiah Reed, Environmental Specialist
NCDEQ
Audit Report Author•
Date:::
Signatur
/J p
Audit Report Author:
Date
Signature
NCS000250_Marion MS4 Audit_20190625 Page 1 of 4

Site Visit Evaluation: Construction Site No. 1
Site/Project Name:
Date and Time of Site Visit:
1-26 NC-191 interchange
June 25, 2019
Site/Project Address:
Operator:
35.545185,-82.60489
NCDOT
Project Type (Commercial, Industrial, Residential, CIP, Roadway,
etc.):
Roadway
Permit ID Number:
Disturbed Acreage:
NCS000250
11
Recent Enforcement Actions (Include Date):
N/A
Name of MS4lnspector(s) evaluated:
Reid Whitehead
Name(s) and Title(s) of Site Representative(s) Present During the
Site Visit::
Name
Title
Jody Lawrence
Resident Engineer (NCDOT)
Ben DeWit
State Field Operations Engineer (NCDOT)
Reid Whitehead
Operations Engineer (NCDOT)
Rhonda Jessee
CEI (V&M)
Tom Veazey
Assistant Resident Engineer (NCDOT)
Observations
Site Documentation/Training
Does the site have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it site -specific?
Yes, Site Plan
Does the site have approved erosion and sedimentation control plans onsite? Are they representative of current site conditions?
Yes
What type of stormwater training do site employees receive? How often?
Mr. Whitehead receives training related to his CPESC, but NCDOT does not administer specific training. Other staff on site,
including Ms. Jessee receive training every 3 years related to NCDOT certifications.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
Just training related to CPESC.
Did the MS4 inspector appear knowledgeable about MS4 and NCGO10000 requirements for construction sites?
No. While he was familiar with the ESC requirements, he was not familiar with the overall responsibility of the MS4 inspector.
Did the MS4 inspector appear knowledgeable about erosion and sedimentation control/stormwater pollution prevention BMPs?
Yes
Audit Date(s): June 25, 2019 Page 1 of 2

Site Visit Evaluation: Construction Site No. 1
Inspection Procedures
Does the M54 inspector's process include the use of a checklist?
Notes taken during inspection. Then filling out report later.
Does the M54 inspector's process include taking photos?
Yes
Does the MS4 inspector's process include reviewing approved plans (erosion and sedimentation control and/or SWPPP)?
Yes
Does the M54 inspector's process include walking the entire site and inspecting all points of discharge?
Walking areas of interest.
Did the MS4 inspector miss any obvious violations? If so, explain:
No
Does the M54 inspector's process include presenting the inspection findings to the site contact in writing?
Yes. Report sent to Engineer on site. Not directly to contractors.
Does the MS4 inspector's process include providing construction stormwater educational materials to the site contact?
No. Only verbal, On -The -Job Training.
Compliance/Enforcement
What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in?
Jeanette Powell will determine.
If compliance issues were identified, what timeline for correction/follow-up was provided?
Jeanette Powell will determine.
Notes/Comments/Recommendations
The NCDOT, Roadside Environmental Unit, Erosion & Sedimentation / Stormwater report did not have a specific way of informing
the operator, or DOT staff on site that the site was "Not Compliant" with the permit. It instead has a grading scale 0-10. A 6 or
below on this scale results in an "immediate corrective action". I inquired if Mr. Whitehead had issued any "immediate corrective
actions" in 2019. And while his reports do reflect issues including the need for maintenance, and other issues included in the
permit, he has not issued an "immediate corrective action" in 2019.
It is my recommendation that the report be modified to more clearly inform contractors and operators when they are not in
compliance with the NCG01.
The inspector was not familiar with all responsibilities of the MS4 inspector concerning construction sites (housekeeping, fuel
storage, preventative maintenance.
The inspector, and on -site representatives, do not have a set schedule or plan for training during the year. Those inspectors without
the CPESC all said that they receive training during the renewal process for the NCDOT erosion control certification every 3 years.
Audit Date(s): June 25, 2019 Page 2 of 2

MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM AUDIT REPORT
NPDES PERMIT NO. NCS000250
Buncombe County, NORTH CAROLINA
Construction Site in Asheville, NC
Audit Date: June 25, 2019
Report Date: June 25, 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
NCS000250 Marion MS4Audit 20190603