NCS000495_OTHER_20130506

STORMWATER DIVISION CODING SHEET
MS4 PERMITS
PERMIT NO.
/Vc 0 (J o �qJ
DOC TYPE
[I FINAL PERMIT
fl ANNUAL REPORT
❑ APPLICATION
VOMPLIANCE
THER
DOC DATE
❑ � � 3 n,5 c� t�
YYYYMMDO

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Pat McCrory Charles Wakild, P. E. John Skvarla
Governor Director Secretary
May 6, 2013
Heather Keefer ,1 ; tl
CFM, Environmental Specialist
QY ` %
Town of Holly Springs / I
Engineering Department, f
P.O. Box 8 1
Holly Springs, North Carolina 27540
Subject: Evaluation of the Town of Holly Springs' Stormwater Management Program,
Stormwater Permit No. NCS000495
Dear Ms. Keefer:
The North Carolina Department of Environment and Natural Resources (NCDENR), Division of
Water Quality (DWQ) conducted an audit of the Town's Stormwater Management Program on February
26, 2013. DWQ was represented by Bill Diuguid and Mike Randall, from the DWQ Stormwater
Permitting Unit.
The compliance evaluation is conducted to evaluate the Town's compliance with the
requirements of Section 402(p) of the Clean Water Act (CWA), 33 U.S.C. § 1342(p), the regulations
promulgated there under at 40 Code of Federal Regulations Part 122.26, and the North Carolina National
Pollutant Discharge Elimination System (NPDES) Permit No. NCS000495.
The staff was very helpful during the audit and should be commended on the initiatives they've
taken to managing stormwater under the conditions of the Town's permit.
The staff provided a description of the storm sewer system, identified the receiving streams, and
whether or not the receiving streams are impaired and any associated water quality issues. The staff also
provided a description of the Town's Public Education and Outreach Program, Public Involvement and
Participation Program, Illicit Discharge Detection and Elimination Program, Sediment and Erosion
Control Program, Post -Construction Program, and Pollution Prevention and Good Housekeeping
program.
The Town's Public Education and Outreach Program is based on community wide issues. Staff
provided a description of the target audiences and target pollutants as well as the likely sources of those
pollutants and their impacts. The Town maintains an internet web site designed to convey the program's
message, distributes stormwater educational material to appropriate target groups, and promotes and
maintains a stormwater hotline/helpline.
Wet}ands and Stormwater Branch
1617 Mail Service Center, Raleigh, North Carolina 27699.1617
Location: 512 N. Salisbury St Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service; 1-877-623.6J48
Internet: www.ncwalerqualily.org !
NorthCarofina
;Vatura!!y
An Eq ual Opportunity 1 AlSrrnalive Aclion Employer

Heather Keefer
May b, 2013
Page 2 of 3
The Public Involvement and Participation Program includes volunteer opportunities and other
mechanisms designed to promote ongoing public involvement.
The Town maintains an IDDE ordinance that provides the Town with adequate legal authority to
prohibit illicit connections and discharges. The Town maintains a current map showing major outfalls and
receiving streams, conducts dry weather flow field observations in accordance with a written procedure
for detecting and removing the sources of illicit discharges. The Town maintains written procedures for
conducting investigation` of identified illicit discharges, tracks investigations and document when illicit
discharge "observed, and tracks the results of the investigation and any follow-up of the investigation.
The Town implements a delegated Sediment and Erosion Control Program.
The Town maintains an ordinance that provides the Town with adequate legal authority to meet
the objectives of the Post -Construction Program. The Town has the authority to review designs and
proposals for new development, request information, and enter private property to conduct inspections.
The Town adopted the DWQ BMP Design Manual and conducts site plan reviews of all development
within the Town. The site plan reviews address how the project applicant meets the performance
standards and how the project will ensure long-term maintenance.
The Town maintains a current inventory of facilities and operations owned and operated by the
Town (with the potential for generating polluted stormwater runoff). The Town also maintains and
implements a SWPPP for their public works program. The SWPPP includes a site description and site
plan that show drainage areas, stormwater and sanitary piping, manholes, cleanouts, drains, inlets,
outfalls, oil water separators, and stormwater control devices. The SWPPP identifies industrial activities
and facilities, storage practices, best management practices, secondary containment requirements,
structural BMPs, erosion and sediment controls, procedures for spill response, loading and unloading,
vehicle and equipment maintenance, waste handling and disposal, and employee training requirements.
Positive Findin,s
The Town maintains an excellent system to track and follow up on Post -Construction Projects,
IDDE, and construction process. The Town also maintains an excellent mapping system, equal or better
to any in the state. The mapping system supports both immediate and future needs of the community.
From what we were able to observe the streets, parking lots, and stormwater system were in excellent
condition — free of trash and debris, floatables, pollutants, oil and grease.
Also worthy of noting was the number of Structural Best management Practices (BMP) that have
been found to be in compliance —of some 150 BMPs inspected only 5 were reported to be out of
compliance. The Town had initiated corrective action of the few that were out of compliance.
Finally, the SWPPP provides excellent procedures for activities such as spill response, loading
and unloading, vehicle and equipment maintenance, waste handling, and disposal.
Also, the Town does participate in the Clean Water Education Partnership (CWEP).
Recommendations
Recommendations represent practices that should be considered to improve the overall
effectiveness to improve stormwater management.

Heather Keefer
May 6, 2013
Page 3 of 3
While it appeared that the Public Works facility had all the material available for spill response,
DWQ recommends that the Public Works facility put together an actual "Spill Kit." The spill kit should
be stocked with absorbent material, gloves and other appropriate personal protective equipment. Often
facilities will use the spill kit container for proper management of spill residual following the cleanup of a
spill.
Please note the State has provided a sample turnover folder for municipal operations that can be
down loaded at: http://Vortal.ncdenr.orp,/web/wq/ws/sLt/npdessw, The documents include:
• The State Compliance Check List
• MS4 Turnover Folder Sections
• MS4 Sample Spill Report
• Sample Best Management Practices for MS4s and Industrial Activities
• OWS Inspection Record
• General Site Condition Inspection Checklist
• Solid Waste Containers Inspection Checklist
• Tanks and Containers Inspection Checklist
• Sample Training Record and Power Point Presentation
• EPA and OSHA Regulatory Training Citations
• Monitoring Report and Guidance
Discrej2ancies
Discrepancies are findings that would not likely cause a Notice of Violation, a fine, or other
enforcement action. Discrepancies are normally a result of poor management practices, failure to follow
Standard Operating Procedures, minor differences of in or administration oversights or where
compliance could not be determined at the time of the audit.
Notice of Non -Compliance
A Notice of Non -Compliance is any finding that could result in a Notice of Violation, a fine or
other enforcement action if corrective action is not taken. The State did not identify any findings that
could result in a Notice of Violation, a fine or other enforcement action if corrective action is not taken.
Notice of Violation
A Notice of Violation is any permit noncompliance. The State did not identify any findings that
would result in a Notice of Violation, a fine or other enforcement action. '
Should you have any questions related to this audit please feel free to contact me at
[e-mail] or at 919-807-6374 or Bill Diuguid at [e-mail] or at 919-807-
6369.
Sincerely,
Mike Randall
cc: Stormwater Permitting Unit files
Mike Mitchell, EPA Region IV
Danny Smith, Raleigh Regional Office

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