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HomeMy WebLinkAboutNCS000413_Deficiency Response Table_20210413Section Description Status DEQ Comment City of Kannapolis Response II.A.2 Stormwater The permittee evaluated the performance and effectiveness of Self -audits have been conducted yearly through the This element was noted to have a status of "Partial". The City has included in the SWMP that they will prepare, certify, and Plan Implementation Partial submit the Annual Self -Assessment to NCDEQ prior to August 31st each year. The self -assessment period will include their fiscal and Evaluation the program components at least annually. BIMS portal. year (July 1 - June 30). [BMP #11.2 in Table 12 of SWMP] II.A.3 Keeping the The City submitted a SWMP at the beginning of each This element was noted to have a status of "Partial". The City has included in the SWMP that they will update the SWMP as Stormwater Plan Up The permittee kept the Stormwater Plan up to date. Partial permit cycle. If nothing changed, the SWMP was not determined by the City or NCDEQ or Annually going forward. The update will be completed by October 31st each year. Updates to Date updated yearly. The City has a 2016 SWMP and to the SWMP will be documented in the SWMP Revisions table (Table 1). [BMP #11.3 in Table 12 of SWMP] submitted an updated 2020 SWMP. The permittee kept an up-to-date version of its Stormwater The City has updated the SWMP to state that the latest version of the SWMP, using the NCDEQ template, will be uploaded onto No the City's website by no later than May 15, 2021. The web address will be included in the subsequent Annual Report. [BMP Plan available to the Division and the public online. #11.4 in Table 12 of SWMP] The Unified Development Ordinance (UDO) and the City ordinances are available on the Code Enforcement webpage of the City's website (link below). This webpage includes a link to Municode and to the City's UDO. The City's UDO is also available through the Planning webpage. Article 4 and Article 9 of the UDO refer to items covered under the NPDES Stormwater Permit. II.A.4 Availability of The online materials included ordinances, or other regulatory Online materials could not be located. These items have been present on the City's website and no further actions will be taken on this unless notified by NCDEQ. the Stormwater Plan mechanisms, or a list identifying the ordinances, or other No The City is in the process of rewriting its UDO. Information on the rewrite is located at: regulatory mechanisms, providing the legal authority necessary https://www.kannapolisnc.gov/Government-Departments/Planning/UDO-Rewrite to implement and enforce the requirements of the permit. https://www.kannapolisnc.gov/Government-Departments/Planning/UDO https://www.kannapolisnc.gov/Government-Departments/Planning/Code-Enforcement [BMP #11.4 in Table 12 of SWMP] Are any control measures implemented by an entity other than Partial The City does not rely on another entity to implement any control measure, with the exception of the Construction Site Runoff the permittee? North Carolina Department of Environmental Quality Controls element. The City relies on NCDEQto conduct Erosion Control services for this control measure. The City does rely on II.A.6 Sharing conducts Erosion Control services for the City. The City assistance for certain BMPs from a private consultant, but the City is still responsible for the overall compliance with permit Responsibility If yes, is there a written agreement in place? No has a private consultant that assists with IDDE and obligations. The City does not rely on 40 CFR Section 122.35 for sharing any responsibility to implement minimum control regular yearly SCM inspections. measures. [BMP #11.6 in Table 12 of SWMP] The permittee maintained written procedures for implementing the six minimum control measures. Partial II.A.7 Written A written SOP was maintained for IDDE but not for all The City of Kannapolis will develop written procedures for implementing each of the six minimum control measures. These Procedures minimum control measures. documents will include specific action steps, schedules, resources, and responsibilities for implementing each minimum control Writing procedures identified specific action steps, schedules, measure. This is scheduled to be completed prior to February 19, 2022. [BMP #11.7 in Table 12 of SWMP] resources and responsibilities for implementing the six No minimum control measures. The permittee maintained documentation of all program III. A Program components including, but not limited to, inspections, Documentation for all minimum control measures The City will ensure that documentation for all minimum control measures are complete and kept on file for a period of at least Documentation maintenance activities, educational programs, implementation Partial were not complete. five years. The City will make documentation available to NCDEQ upon request. [BMP #11.8 in Table 12 of SWMP] of BMPs, enforcement actions etc., on file for a period of five years. Section Description Status DEQ Comment City of Kannapolis Response The permittee defined goals and objectives of the Local Public The City will ensure that goals and objectives of the Public Education and Outreach Program, based on community wide issues, 11.6.2.a Goals and Education and Outreach Program based on community wide No The goals and objective are not clearly defined within will be documented in the Public Education and Outreach Procedures by February 19, 2022. These goals and objectives will be Objectives issues. the SWMP. assessed and revised annually, as necessary. [BMP #13.1 in Table 14 of SWMP] 11.6.2.g Hotline/Help The permittee promoted and maintained a stormwater The City will clarify their stormwater hotline/helpline on their website for the purpose of public education and outreach no later hotline/helpline for the purpose of public education and Partial No Public Education and Outreach hotline is specified. Line than August 1, 2021. This number will also be promoted on outreach material annually. [BMP #13.5 in Table 14 of SWMP] outreach. II.C.2.c Hotline/Help The permittee promoted and maintained a hotline/helpline for The City will clarify their stormwater hotline/helpline on their website for the purpose of public involvement and participation Line the purpose of public involvement and participation. No No documentation. no later than August 1, 2021. [BMP #14.1 in Table 15 of SWMP] The permittee maintained a written IDDE Program. Partial The City has created an IDDE Program Manual in 2020. The City has an IDDE Program Procedures Manual and will update the plan to include illicit discharge close out procedures and II.D.2.a IDDE Program If yes, the written program includes provisions for program The City uses Cityworks to track IDDE and other assessment and evaluation procedures no later than October 1, 2021. The updated procedures will be included as an assessment and evaluation and integrating program. No stormwater violations. attachment in the subsequent Annual Report. [BMP #15.1 in Table 16 of SWMP] The City has the legal authority to prohibit illicit connections and discharges. This is included in the City of Kannapolis Code of Ordinances, Part 2 Code, Chapter 17 Waters and Sewers, Article V Stormwater Utility, Control, and Management, Division 4 Stormwater Control and Management. The City's Ordinance applies to the entire MS4 area. If yes (The permittee maintained an IDDE ordinance or other II.D.2.b Legal regulatory mechanism(s) that provides the legal authority to The North Carolina General Statue Chapter 160A Section 193 also provides that "A city shall have authority to summarily prohibit illicit connections and discharges to the MS4.), the No City Ordinance. remove, abate, or remedy everything in the city limits, or within one mile thereof, that is dangerous or prejudicial to the public Authorities ordinance applies throughout the corporate limits of the health or public safety." permittee. [Permit Part I.D] It is unsure why the audit report stated "No" in response to "...the ordinance applies throughout the corporate limits of the permittee." No further actions will be taken at this time to address this response unless further information is provided by NCDEQ to the City of Kannapolis. The City has maintained a hotline for IDDE online, the II.D.2.i Public The permittee promoted, publicized, and facilitated a reporting website, and social media pages that the community The City will continue to include information on where and how staff should report illicit discharges that are observed during Reporting Mechanism mechanism for staff to report illicit discharges. No can interact and comment about situations they scheduled staff training. [BMP # 15.8 in Table 16 of SWMP] observe. The permittee maintained and implemented an 0&M program for municipally -owned and operated facilities with the potential No for generating polluted stormwater runoff. II.G.2.b Operation lOperation and Maintenance plan is general. Site The City will be creating an Operation and Maintenance plan for each City facility identified in BMP #21.1 of Table 22 in the and Maintenance If yes, the 0&M program specifies the frequency of inspections. No specific Operations and Maintenance was not SWMP. These plans are scheduled to be completed by February 19, 2022. [BMP #21.2 in Table 22 of SWMP] (0&M) for Facilities documented. If yes, the 0&M program specifies the frequency of routine No maintenance requirements. If yes, the permittee evaluated the O&M program annually and updated it as necessary. No Section Description Status DEQ Comment City of Kannapolis Response There is a Spill Cleanup Standard Operating Procedure section in the Water Quality Protection Guidelines and Standard Operating Procedures document that describes what should and should not be done during a spill. Other sections in this II.G.2.c Spill Response The permittee had written spill response procedures for document that discuss specific processes and material handling also address spill cleanup as well. Information on spills is also Procedures municipal operations. No No documentation. included in a training PowerPoint titled Spill Prevention and Response Plan. The City of Kannapolis will review and update these procedures, as necessary, while creating/updating procedures for other minimum control measures by February 19, 2022. [BMP #21.3 in Table 22 of SWMP] The City utilizes Cityworks to document operation and maintenance activities performed on catch basins and conveyance systems that it owns and maintains. Street sweeping is performed regularly (though not scheduled) on City -owned roads. II.G.2.f O&M for The permittee maintained and implemented an O&M program Catch Basins and for the stormwater sewer system including catch basins and No No O&M plan has been created or maintained. The City of Kannapolis will develop a written Operation and Maintenance Plan to define stormwater sewer system related Conveyance Systems conveyance systems that it owns and maintains. resources and organization, responsibilities, policies, and general procedures by January 1, 2022. The plan will be included as an attachment to the subsequent Annual Report. [BMP #21.5 in Table 22 of SWMP] 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 - No construction ordinance. If yes, then: The O&M program specified the frequency of inspections and No routine maintenance requirements. The permittee documented inspections of all municipally- The City will create documentation for the Operation and Maintenance program for municipally -owned or maintained II.G.2.e O&M for owned or maintained structural stormwater controls. No Operation and Maintenance plan is general. Site structural stormwater controls installed for compliance with the City's post -construction ordinance by September 1, 2021. The Structural specific Operations and Maintenance was not City will perform scheduled inspections and maintenance based on the timeframes specified in the structural stormwater The permittee inspected all municipally -owned maintainedh stormwater Controls documented. controls Operation and Maintenance program document. Documentation of all inspections and maintenance for structural t the schedule structural stormwater controls in accordance wit No stormwater controls will be maintained. [BMP #21.7 in Table 22 of SWMP] developed by permittee. The permittee maintained all municipally -owned or maintained structural stormwater controls in accordance with the schedule No developed by permittee. The permittee documented maintenance of all municipally owned or maintained structural stormwater controls. No Does the facility have a SWPPP or similar document? Is it facility No*As specific? the City of Kannapolis develops written procedures for implementing each of the six minimum control measures, they will Does the MS4 inspector's process include the use of a checklist No* consider the notes included in the Site Evaluation section of the Audit Report provided by NCDEQ to improve the inspection or other standardized form? process. Where applicable, the City may include checklists or standardized forms, photos, reviewing the facility's SWPPP (if Site Visit Evaluations ( Variety of comments depending on site evaluation applicable), and presenting findings of the inspection to the facility contact (where applicable). The procedure documents are Does the MS4 inspector's process include taking photos? No* location.) Does the MS4 inspector's process include reviewing the facility's No* scheduled to be completed prior to February 19, 2022. SWPPP (or similar document)? Does the MS4 inspector's process include presenting the No* *These actions may not be required at each inspection so are not always considered a deficiency. inspection findings to the facility contact? Section Description I Status I DEQ Comment I City of Kannapolis Response The following items were noted in the City's self assessment of the Construction Site Runoff Controls, Post -Construction Site Runoff Controls, and the Total Maximum Daily Loads. The City has implemented an inspection program, The permittee has developed and implemented a written though this program is not formally documented. The inspection program for structural stormwater controls to City sends letters to property owners annually to ensure that all stormwater control measures meet the Partial remind them that their annual inspections are due. permittee's performance standards and are being maintained Structural control owners are responsible for pursuant to the maintenance agreement. conducting the inspections and sending in the II.F.2.g Inspections of inspection results and maintenance form to the City The City of Kannapolis will develop written inspection program procedures for structural stormwater controls no later than Structural documenting what was done. The City is considering February 19, 2022. Once the procedures are determined, the City will complete inspections and document and maintain Stormwater Control conducting their own inspections due to the low records of the inspections, findings, and enforcement actions. [BMP #20.7 in Table 21 of SWMP] Measures return rate of inspection forms. The City currently inspects structural control measures informally. Returned inspection forms are maintained for record, The pedocumented and maintained records of No though not all structural controls are currently nt actions. enforcement maintained annually. Enforcement actions have not currently been taken regarding owners not submitting their annual inspection.