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Home My WebLink AboutNCS000247_Winston Salem Audit Report_20221006MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) PHASE I PROGRAM AUDIT REPORT NPDES PERMIT NO. NCS000247 CITY OF WINSTON-SALEM, NORTH CAROLINA 101 North Main Street City Hall, Suite 53 Winston-Salem, NC 27101 Audit Date: June 14, 2022 Report Date: October 6, 2022 North Carolina Department of Environmental Quality Division of Energy, Mineral & Land Resources Stormwater Program 512 N. Salisbury Street, 6th floor 1612 Mail Service Center Raleigh, NC 27699-1612 TABLE OF CONTENTS AuditDetaHs....................................................................................................... Permittee linfoirrnaUoin List of SuppoirUing Doc u rin e in ts,,,, 2 Program lrrijpVennentafion, Docurnentaflon & Publk Educaflon and 8 Public involvement and I lHick INscharge Detection and IElliir6natiiairn 14 Construction Site iIunoff Con 17 Post -Construction Site IIIunoff 18 PoHuUon PireveinWin and Good Housekeeping for MunicijC.)ap Prograrn to IMoinirtor and EvaWte Stormwater Discharges to MurficijrW Systems .....................................32 Wa t e ir Qu a a ity Asse s s m e int a in d M o n to iri in g _ .... ........ ....34 Siite Visft Evaluaflciw iftnicijpall 1Facilfty INo.. 1 ............................................................................................. 37 DISCLAIMER 'This audit consists of an evaluation of program compliance with the issued permit and implementation of the approved Storrnwater Management Plan. This audit report does not include a review of all program components, and program d�flciencies in addition to those noted may be present. 71we permittee is required to assess program progress and permit compliance, and to implement the approved Stormwater Management Plan in accordance with the issued permit. NCS000248—Greensboro 2022 MS4 Audit ii Audit Details Audit ID Number: Audit Date(s): NCS000247_Winston Salem 2022 MS4 Self -Audit and Audit Self -Audit 4/7/2022-5/20/2022, Self -Audit Report-5/5/2022 and 5/20/2022 Audit — 6/14/2022 Audit Report—10/6/2022 Minimum Control Measures Evaluated: N Program Implementation, Documentation & Assessment (evaluated during self -audit and onsite audit) N Public Education & Outreach (evaluated during self -audit) N Public Involvement & Participation (evaluated during self -audit) N Illicit Discharge Detection & Elimination (evaluated during self -audit) N Construction Site Runoff Controls (evaluated during self -audit) N Post -Construction Site Runoff Controls (evaluated during self -audit) N Pollution Prevention and Good Housekeeping for Municipal Operations (evaluated during self -audit and onsite audit) N Program to Monitor and Control Pollutants (evaluated during self -audit) N Water Quality Assessment & Monitoring (evaluated during self -audit) Field Site Visits: N Municipal Facilities. Number visited: 1. ❑ MS4 Outfalls. Number visited: ::_` .` ao =terse. ❑ Construction Sites. Number visited: say a ", n. ❑ Post -Construction Stormwater Runoff Controls. Number visited: C1 rose are �tery . ❑ Other: Number visited: ioase are itern, ❑ Other: Number visited: ho ; sp- a Iles . Auditors Note: MS4 Phase I Program Self -Audit Repo rt-N CS000248 has additional information Name Title Paul Clark NCDE , sDL:MLR, Sto mwater Audit Report Author /'/ ,� ...._.-__�... ..... Name Date... � Title CbU(2D1�'97a2 Signature NCS000247_Winston Salem 2022 MS4 Self -Audit Page 1 of 39 List of Supporting Documents - Document Format Item Number Document Title (web link, e- file, etc.) I City of Winston-Salem's l:::Y 2021-2022 Stormwater Management Plan . . . . ....... . . ........... . . . . . . . . . . . . . . . . . . PM::: . .............................................. 2 Stormwater IDS vusuon's IIIDDIfm SOP Manual PM::: -------______ -----____ - ----------- - - - - ----------- -1-1- - ---------------------------------- — -------------- . ............ . . .......... ...... . . ........................................................... An Example of the Stormwater Division's Notice of Violation and Supporting . . ................................. 3 PDF ------- ----- -------- Documentation of Successful Completion ------------- — — ----- . . . . . ........................ . . ........................................................................................................................................................... 4 IBMIPs fair IPubhc Educabonal Goalls and Objecdves PDF — - - ------ --- ---------- 5 --------- Public Educational Outreach Counts " " " " Excel . . . . . . . . . . . ................... 6 Municipal NEW Employee Training Counts ............. Excel ................................... . . . ......... 7 --____ ------- ---- Munibill-.41 Eimpq loyee PF"&Gl and IDII..)E Trainhig Meo Confirrnaflon . . .. . . . ......... . . . . . . . ................ . . ................................................... Excel 8 Stoirrnwater Simairt IFY 2020. 2021 Summary IRepoirt 9 SLurmwdier Smart 2022 invoice PDF 10 Municipal ALL (other than new) Employees Stormwater Training Video Excel NC5000247.-.Wi rns ton Salem 2022 MS4 Seff-Audit Page 2 of 39 List of Supporting Documents - !tern Number Document Title Document Format (web fink, a - file, etc.) 11 Chapter 75, Article I — the City of Winston Salem's IDDE Ordinance PDF 12 , FY 2021-2022 Dry Weather Outfall Screening SOPS and Schedule PDF 13 ------- .......... ---------------------- ----- --- — — - — ..... --_._ The Stormwater Division's IDDE Discharge Master Spreadsheet for FY 2021-2022 ..... Excel _ ....... .... ....... ............................................................ ......... DEMLR's Review Results Letter of the Winston-Salem/Forsyth County Erosion 14 ._......_ Control Program, Dated November 20, 2017 ....—. _. .. __.—. _._._.—. _.—._. PDF Erosion Control Division's Webpage Screen Shot of Pollution Hotline for 15 Reporting Violations PDF ScreenScot of Erosion Contrs Flow -Process for Redirecting Project that use 16 Y Winston-Salem Regional Office PDF 17 inance dinance The City of Winston-Salem's Stormwater Ord PDF .--______ _ " � 'The City of Winston-Salem's ... w,e � � ____._....._ Maintenance Agreement 18 Templates for Homeowner Associations end Single Owner p g s PDF 19 Escrow Agreement Template for Homeowner Associations PDF -------------------- -------------------------------- ------------------- ------------------------------------------------------ The Stormwater Division's Inspection Master List of Municipal Facilities and ....................................................................................................................................... 20 PDF Operations 21 Municipally -owned Stormwater Control Measures (SCMs) Inventory List PDF ......... ......... ......... ......... ....... ....... ........ ......... ......... ......... The Stormwater Division's FY -2020 to 2022 Inspected Municipal and Industrial 22 Facilities and FY 2022-2023 Proposed Facilities to Inspect PDF 23 The Stormwater Division's Industrial and Municipal Inspection Form Template PDF _ Exampled Stormwater Pollution Prevention Plan An Ex of t' Ian _._...._...._ _.._,_..._ 2 4 _........ of Services (Template)l ..... ... _._._._._............. ... PDF -------- ---- -- An Example of a Municipally -owned Spill Response Plan of Fleet Services 25 ____._._._._.__....._._.I__..___..____.....__......_........_____ (Template)_.____.______._-__._.______._.._.____..____.................___....____.__._____._._._..__...._.____.._._.._.._----------._..______.--_-- — PDF ............... 26 Field Operations' MS4 Inspection and Maintenance Program SOPS PDF ------ ...... - ----- --- -.....-----.._ Street Sweeping Log of Municipally -owned Facilities/Parking Lots for FY 2021- ............................................................................................................................ 27 1 Excel 2022 ........ _ ........ ..................... __..................................................... .............. ..................................................................................................................................... _ ................. ......... Reference Lists of Small and Large Quantity Generators (SARA Title III) and Toxic 28 — Release Inventory (Hazardous Waste, Disposal, and Recovery Facilities) ......... ........ ......... ....... ........ ......... ........ ...... ..., .. PDF .. ........., Master List of General and Individual Permitted Industrial Facilities within the 29 Municipal Boundaries of Winston-Salem PDF 30 The Stormwater Division's Industrial Inspection SOP Manual PDF NCS000247_Winston Salem 2022 MS4 Self -Audit Page 3 of 39 List of Supporting Documents- Document Format Item Number Document Title (web link, e- file, etc.) 31 IPHcrl'ty 1 and 2 Vndua'strW and Municipal Facillutiles List, FY 2020 2.023 PDF 32 1 he .Stormwa'ter Division's Water Quahty Assessment and Monitoring Plan PDF 33 11eet Services R6nsjpection O:::ou rn, IMunicipal Site Vrsot Q' va Wation #1 � PDI::: 34 Muddy CreekWWI? Reinspec don is:�crrrn, I'° i.,r lu.ipal SiteVisit n, uutuon #2 � Pual. I 35 IMS4 Site Visiit Evaluation, Outffallll #1 PDF 36 IMS4 Slite VN sit Evaluat'iorn, Oiutffalll #2 .......................................................... ......... PDF 37 Construction Site VWt F'valuafl an 1. _ ......... - ----- ......... PDF ----------------------------------- 38 — .. Construction Site. Visit Evaluation #2. PDF 39 DoHar General SCIM IE.nvaluationi, Post construction Site Visit "I. PDF 40 UNCSA Cerntrall Storage SCIM IEvaluation, Post —construction Sfte Vilsit #2. PDF 41. _ .................................. ..................... ..e ,... WS 'rransAutlhority M UQ Urns ec'dorn I1auall age ___ --- .................................................... — aaaa pf..DF NCS000247_Winston Salem 2022 MS4 Self -Audit Page 4 of 39 Fons!ite ram Implementation, Documentation & Assessment (Evaluated during self -audit and audit) Staff Interviewed: Andrew Allen, Assistant Stormwater Director. Mr. Allen creates and discusses Stormwater Management Plan (Name, Title, Role) (SWMP) requirements to pertinent team members for the upcoming permit year. Mr. Allen is also responsible for conducting an annual program evaluation, gap analysis, and as a result, generation of the next year's SWMP. Permit Citation Program Requirement Status SupporGrog Doc No. II.A.1 The permittee maintained adequate legal mechanisms, such as regulations, Program ordinances, policies and procedures to implement all provisions of the Stormwater Yes Implementation Management Plan (SWMP). II.A.2 The permittee implemented provisions of the Stormwater Management Plan and Program yes Implementation evaluated the performance and effectiveness of the program components annually 11 A' The permittee maintained written procedures for implementing the six minimum Program control measures, which identify specific action steps, schedules, resources and Yes Implementation responsibilities. 15A NCAC 02H The permittee is current on payment of invoiced administering and compliance .0105 monitoring fees (see stormwater e-payments on https://deq.nc.gov1sw). —----- -------------- -—.............__.....................................------ ..... ------- --------.......-- ..............--....... ----- ...-- -- Comments _ - - The permittee ._-...... ... .....-. Ill. A. maintained documentation of all program components including, but Program not limited to, inspections, maintenance activities, educational programs, Yes Documentation implementation of BMPs, enforcement actions and other stormwater activities. Documentation is kept on -file by the permittee for a period of five (5) years. Ye's The permittee's Stormwater Management Plan is reviewed and updated as Yes necessary, but at least on an annual basis. — . . .. ................ .__........................................... __... Comments No major programmatic changes occurred in the City's Stormwater Management Plan from PY 2016 to 2019, thus the annual report did not change, other than the number of completed permit compliance measures. Multiple gap analyses were performed, but only a portion of recommended actions were implemented. Reasons for non -implementation include, but not limited to, resource limitations, staffing, and COVID-19. .---� nnnnnnnnnnnnnnnnrvmwww,w,,w „„,„, yes ,.....�, IV.B. The permittee submitted annual reports to the Department by October 31st of each Annual Reporting calendar year for the previous fiscal years activities (from July 111 to June 30`h). The Annual Reports included appropriate information to accurately describe the progress, status, and results of the permittee's Stormwater Management Plan, including, but not limited the following: NCS000247_Winston Salem 2022 MS4 Self -Audit Page 5 of 39 1112irogiraim knpIllementation, Documentation & Assessiment(Evallluated duringIlf,,. u dit and nsiaudit) a. A detaHed description of the status of irn pllernentafl yin of the StorrnwaterPlan as a whole. includes infforrrnabon on dewreGoparrnernt and wrnpallernentatiion of each Yes major component of the Storrnwat:er° Management Plain for the past, year- and schedules and paans for the year ffoHowinp each report, lb. A description and justification of any proposed dharnges to throe Storrnwater (Management Ilan. This includes descrulrat'Gons and supporting iinff®nrrnatiiorn for the proposed changes arid Ihowtwe these changes wow iH impact the Stoirmwnaaater Nan (resTuadts, effffectGwreness, implementation schedule., etc.). c„ Documentation of any necessary changes to programs or prr"na~-Hoes for assessment of ir'nana enlent measures liinlplleinented tlhrou lhn the Stormwater Yes Management Pfain, d. A suurnrn«ary of data accurnuadated as part of the Storinwater IManagennent t'laan Ye throughout out the year aGong with an assessment of what, t:hne data Gndicates. e.. Ani assessment of corn phance w,ariitlhn the 1peirrrnk, infforrnadon on the estaabhslhrnnernt Yes of appropriate VegaaV authnoidtiies, iinslpecdons, and enforcement actxoins. ff. Il'.)iisciussiion of parograrn funding. Comments Admiittlin lly, the Stormweorater I)'Msilon died neat'ncllude and implement afll proposed changes frorn rnuukiilplle gap analysis ffrorn try 201.E 2019 in the Storinwater Management Pllan. Galp analyses results wnaeire denoted and suuulbirnitted to the correslpa:arndiing iresjponsBWe (party for iirmlplementaflon. 1Reasons for non-iirnpa er"Inentatiion incllude„ (brut not Iliirniited to, resource I' irnkat.lions, staffing, and COVID 19. 9V .l"RW record of an Miicit discharge that reaches waters gaff the Other 9rifor atuoun state and urns cause or contra Ilhna. � a..,ru"Inutte� irrnauintauuaawa� a ba.rte to a vra&ataanrn of the water quuQagity standards or Yea constitute an 'irnirrniinent threat to health or the environment: Ithe record iincludes dates, Werntipiicat'ion of pao:rsilblle respaonsGlblle parties, causes, and Yes any action talkern by the paerrniittee or the ireslpon.sHbie 1pairty. Usclharges that constitute an iirmmnernt tlhnreat to health or the envilironinent were relpoirted within 24 (hours h:ay 1phnorroe or e mail to the II)'i!wr'isiorn Re&naii Office during Yes business hours, or to the NC Il:)liwrlis'Gon of Emergency aana ement State Operations Center hotline outskle of Ibusliness hours. C"oinmen is Me :stornnwater Diiwaiis'ion issues a Il oflce of V/ ollafian (NOV) to the irespaonsiilblle entity ffor'ill1ciit discharges or dumping that reach (or have the 1potentiall to ireaaclh) the City "s IMS4 system or waters of the state. Each NOV states the requiired com phaaince 'iiterns, due date, and 1potentiiall fines, iiff action items are not completed, ii"hne Wriston Saaiern/Foirsyth bounty Errielr arncy Management and/or, Stormwnrateir Division staff notifies WSR: O Re�,:yliionai Office, lip' irrurninent danger to tru.ulbdoc Irwalithn us determined war if dhe National Response Center its notified, IPlease ireference the attached exannlpGe of an iissued NOV and suapalporfing compliance docunientatiion that derrnonspt:rates t,:lhe Storrmwater IC:7iiwaiisioin"s WE process for suaccessffuulllly eliirnlnafing Ipolldutants,to the MS4 and receiving wateirs. NCS000247...,_Wiinston Sallern 2022 I S4 Self Audit: Page 6 of 39 Program Implementation, Documentation & Assessment (Evaluated during self -audit and onsite audit) Additional 1) The Stormwater Division has uploaded the latest version of its Stormwater Management Plan for FY Comments: 2020-2021 for DEQ's reference. Stormwater staff performed a comprehensive overhaul of its Plan with respective work outcomes to be reported to DEQ this upcoming annual report. 2) The Stormwater Division has uploaded its IDDE SOP Plan for DEQ's reference. NCS000247_Winston Salem 2022 MS4 Self -Audit Page 7 of 39 Public Education In Outreach (evAuated duringself-audit) Staff Irntervileweds Vicki! Pigg, Storrnnwwater GOperaflons Analyst, sulperviised the Senior Corrnmurn%ty Educator from November 2.021. (Nairrrne, "Title, IRolle) April 2.022. As of Alp: rill 1.9, 2022„ t1he ,job poslitiio n of See nior Community 11::Au cator ii,s vacant. Peirmi-il. Citation Pirogram Requirement Status upportli n Doc V40. 1 he pneirrnilttee de.scAlbed the target poVlluttants and target poNutant sources that the qargot ;Polllutarnts ''y Yes edu.uea�do n poa:rgrdirn 'k eIa sugn`ne:=d to ao dress and why they are anissue . Sources -----. ................................ _............................................................................. .... __ Comments Sernioir Community Educator maintains a unrna.ster docu.urnent regarding best rnana erneint practkes foir Public li:.Auoatilon and Outreach and Public invowermernt and Participation aetilvll,tiles for the Stormwater Division. VIrnis ddorument includes progirarminnatiic obJectives„ materials and programs developed, aind goalls for the Stormwvateir Division irelated to Public Education, Outreach and Pul'ok Ilnvolvernnennt. This doo.A rnelnt is updated, as needed. p:uirtlheir and oornlplN'Ae details regarding the. selected IBIMIpks for Public Ed /Ou.utireach/Pulb c IInvolveirrient its available in the attached V X 2021q 2022 Stormvwater IManagerrilent Plan and FY 2020 2.021. Annual IReport., This doa:uirment rs called "BIMl.' for Pulb Ed lntiro Goals Objectives. and ire:.*siides here: (&\.Stoirmwwater Educator Education Outreach IPublic iinvolvermeint\SOI1:ls\WordDoos of S0I.1s). Please referenir..e the attached OMP doournnent I°oir VJV; (:Ys review., ---- IIII.B1.1b. Thie peirmilttee descirilbed the target audiences II'ilkeiy to have significant storrnwwateir Yes q'airget Audiences irnpactli.s and why they were selected. ..................... -- ......... C'amInern is Senior CoirmmnunAy IEducatoir evaluates and .slhiifts edu.ue::adoirilall outreach foe:iaals" as needed, to address the needs and requests of the oormrrnuniity. Method beaNnd rnalkiing these changes us documented iin the "I IVIP for Pub Ed Vntiro Goals Objeotives.dorx" aind thiis doculrne".Int lives Ihlelre. (GS \Storlrnwwater Educator E.Aucatioln Outreach Public llnvon velf'r'Ilelnt\° OG )s\Wordll)oos o'i SOPs) Examples of mninoir slhiffing education focus: if we get innore autoirnotive related complaints, we address there with targeted education in the form of handouts oir mailers (oorxnpleted tairgeted mailer 41 2020 to an.utomotive businesses iin the Saieirrn Creek Watershed with English and Spanish iirnforrnation). We have gotten several moire pet waste irelated coinnpiailnts in 2020 and 2.021. and targeted those neighborhoods wwiltth pet waste irellated door haingers and information. We also did severall sooiiall irnedia posts to VNextDooir and F acelboolk to reach other horneownrneirs and residents oonoerined about ppet waste and worked wwiith Stormwaiter SMART (and the commpttee) to choose 1pet waste as one of the innass media outireach toll;irs for the region. &+landouts avaiialble upon request. the . elrmll@pQ?tQ� om ,-,„� ��, qli I� 2.,o p prorrnoted and main-L.ailned an internep wwelb silte designed to convey the Informational � �c," Ipiru.ngirairrn s mrw�ssaga�.. � Well) Site NCS000247_Winston Salem 2022 MS4 Self -Audit Page 8 of 39 Public Education and Outreach (evaluated during self -audit) Comments The Stormwater Division's webpage is located at www.City ofws.org/stormwater. The main topics on Stormwater's website are (and corresponding, supporting minimum measure): 1) Main page — buttons to pay stormwater bill, post construction stormwater, help keep our waterways clean, storm drainage maintenance, info inside bar how to contact City Link 2) Do your part — volunteering information (public involvement and participation information) 3) For businesses — stormwater runoff information for businesses (industrial/commercial BMPs-targeted audience) 4) For residents — stormwater runoff information for residents (public involvement) 5) Fun stuff —kid's activities for educational awareness and growth (targeted audience for public outreach) 6) Capital improvement projects — information about current capital improvement projects (public involvement) 7) Report polluters — how to report polluters (IDDE program component) 8) Staff —staff listing (IDDE and public involvement) 9) Stormwater management — information about stormwater management program (public involvement and participation) 10) Stormwater runoff — information about stormwater runoff (public education and outreach) 11) Stormwater survey (public involvement and participation) 12) Stormwater billing and utility rate — information about stormwater utility fees (public education and outreach) 13) Erosion Control Information: https://www.City ofws.org/733/Erosion-Control (Construction Site Runoff Controls) 14) Drainage Maintenance Related Information: https://www.City ofws.org/1325/Drainage-Maintenance (Municipal Good Housekeeping and Pollution Prevention) m...................................................... ,,,�.�� .... II.B.2.d. Public Education The permittee distributed general stormwater educational material to appropriate Materials target groups as likely to have a significant stormwater impact. ........ --—....._ �..... _ Comments — — Please reference the attached spreadsheet from November 2018 to the current for the number of distributed educational materials. This spreadsheet resides at: G:\Stormwater Educator - Education Outreach Public Involvement\Ed & Outreach Programs Spreadsheet title is "Ed—Outreach—Counts.xlsx" For workload data collected prior to November 2018, staff consults the spreadsheets saved at this location: G:\Stormwater Educator - Education Outreach Public Involvement\Ed & Outreach Programs\Ed & Outreach Counts from Roseann 2010-2018 11.6.2.e. The permittee promoted and maintained a stormwater hotline(s) or helpline(s) for Stormwater the public to request information about stormwater, public involvement & Yes Hotline participation, and to report illicit connections & discharges, etc. .. .. ........................... ._....................... Comments In 2005, City Council commissioned the creation and implementation of a centralized telephone call center/web-based complaint hotline for the citizens of the City of Winston-Salem. Known to the public as City Link, this communication center receives citizen - generated a -mails or telephone calls regarding stormwater-related items within the City. The public can access City Link from the City of Winston-Salem's homepage of https://www.City ofws.org/; the City Link button appears at the top portion of the City's homepage and the City Link contact information appears at the bottom of all City webpages. On the Stormwater Division's homepage on the City website, the City Link contact information is provided at the top of the page. The City Link contact information is shared on every public brochure made available by the Stormwater Division. On May 14, 2021, The City of Winston- Salem added a Chat feature to our City website which enable citizens to communicate via chat with our City Link staff. The Chat icon is in the bottom right hand of the City webpage. The Senior Community Educator receives electronic notifications for presentation requests from City Link or directly from website requests. Illicit discharges are received through the Stormwater Pollution Hotline (336-727-8000), which is operated by City Link. City Link refers all illicit discharge complaints to Stormwater staff, who will investigate these reports within 24 hours. NCS000247—Winston Salem 2022 MS4 Self -Audit Page 9 of 39 Public Education aind OtAreach (evaWated during self -audit) Ipt.113 21. toutreach indudiirng those elem ents ents irmpallernented Vocally or Public Education thnrouglh arcoolperat:iveaareemenit, iiana.lude a corniannation of approaches desiigned tru Outreach reach the target audiences. s Program ...... , _.-__._ � .---- .....-V irn ° lernerctatiora l P Il:or each inned'ia" event or actpiroroty" including those ellermcints tmlpllem�ernte(j Iiooa08y oV, through as coolperadve agr ^anent" the p errnlittee estimated and recorded the extuant Yes of exposure.. Comments AIIII IpuC< he participation and IpuulbHc eduucadon and outreach activities are documented in the Storrnwater DiMsion"s AnlnuuaV Report every year and submitted to NC II)IJ::r , A spreadsheet is also maiintaioned with the irellevaant workload iinfonrmatlon (Vii.st of programs" of attendees, etc.). See attached spreadsheets (for November 2018 onward :\Storinn"wnrater E.Auucator ISduucaflon Outreach Public Invollnremerat\Ed & Outreach Programs, Spreadsheet dtlle us"E.d......Outreach Counts.Asx". U oir data pprior to Noverrnber 2018, plea se see spreadsheets .saved in tlhIs folder° C:\Stornrnwwater IEAucator Education Outreach IPuNic lnnrollverxnent\Ed & Outireadh Prograairns\Ed & Outreach Counts frorn hoseann 2.01.0 2018). ilhe Storm water M°v'Iswon is a Partic�Ipating merrnlraer of Storrnwater SMART, a regional) cornsortuum of INC Piiednrua:anrt cornrrnun'itlie.s that provides storrnwater public education servs ce.s for Iparticipating irnerrnbeirs„ In addition, the Storrnwater Diinriision contributes financially each year to Storrnwater WAFT for the geneiraatio n of edu cationat mater4s and rnedia outreach.. Stormvurater SIIypAIR F submits Vts annuuaV report to consortium irmeminers to document tlheiir activffies/ouutreaclh efforts (.see attached aannuuall reports from Storrmvwater SMARF). Mediia carnpaaligras cormp Ieted by than:^ Stornrrvwater 1Division are documented iin a report from the Vendor with 'the engager rent iresuullts and other mass rmediia ou.utreach effcwts done Iby the Storirnrnrateir 10iiviislion are aH saved here: :\Storrnwvat:er IE:duucator ILducat'ion Outreach Pupahc Ilnvolvement\Maass Medfia.. NCS000247 Winston Salem 2022 MS4 Self -Audit Page 10 of 39 Public Involvement and Participation (Evaluated during self -audit) Staff Interviewed: Vicki Pigg, Stormwater Operations Analyst, supervised the Senior Community Educator from November 2021- (Name, Title, Role) April 2022. As of April 19,2022, the job position of Senior Community Educator is vacant. EPer:m:ittitation _: Program Requirement Status Supporting Doc No. II.C.2.a. Volunteer Community The permittee included and promoted volunteer opportunities designed to promote ongoing citizen participation. Involvement Program NCS000247_Winston Salem 2022 MS4 Self -Audit Page 11 of 39 Public III nvollIve min t airid Participation (IlEvaluated duiring sellf-audit) Comments The City of Winston-Salem has implemented the foilowing prograrns to varioius degrees to promote* volunteer opportunities and ongoing citizen participation: • Creek Week, is a week long series of events geared to engage the public and support water quahty awareness,, lEvents u s;,, a u uy i n cd u G.A. Cr ce k Cu a'ava'l5, Ph Gto C.3 rftest, gu i U-1 eud pa of d lcs a n d naturc ,va, r ks, au n ch a n &I ca rn p re.; e nta tic ris, ;-. co rn m, u r,. ;ty read and book discussion, jpvofess'ional development workshops, hornerowner and resident workshops, special' children and teen's programs at the public hibranes, cornmunrty dean• ups, water centered recreational activities„ and oti,-car interactive prograrns. Cireek 'Week occurs in March and is organized by a cr)mmittree of municipai, county, and non-profit organizations. • Creek Crawls are held witf,,h, local school lasses where the students vsit a nearby cireek to exan-firle the water quality of the stiream using water cluality test kits and visual observations. BentNc rnacroinvertebrates are collected, examined, and r 'iscussed as to [unn an overaH assessirnent of Lhil:,° water quahty (.-)f the sepec.led stre-am. Students are taught Lo coNect water samples and to identify the macroi nverteb rates collected based on provided keys as part of this 'hands on' approach. • The Sturrnwater, Drvision co coordinates the Adopt -A --Stream program with Keep Wuiston-Salern Beautiful to reduce litter, debris, and floatables in our waterways. p lomeowner associations, companies, special interest girciups, fami llies or other interested parties can request to Adopt -A -Stream in their area of interest. linterested parties will comirnft to conducting three dean ups per year and the City will provide signage and debhs removai after each cleanup. Keep Winston-Salem Beautiful also coordinates Aclopt-A Street and Adopt, A Park programs to reduce litter, debris, and floatalbles in our community. • IBig SweeV,.) is conducted every year in October to remove trash and debris from local waterways. • The ('.ureat Arnericain C"Aean Up in Winston Salem is conducted every year in April to ireonrnove trash and debris from docal streets, parks, and waterways. ® The Stormwatir"Ir Mvis'ion coordinates the Storm Drain Marking pirograrn where vohmteer groups place adheswe 'No Diurnping, IDrain.s to Creek' markens or use a provided storm drain rnarking stencil and spray paint on catch basins and other drainage StFUCtUres wiftri The community. Volunteer groups also &tribute door hanger's that contain stormwater educar.ion material infcn-rning citizens about fertilizer i,.use, pet waste and illegal durrilaft within targeted neighborhoods due to the number- of reoccurring fmmplaints. * The Stream Watch in Winston-Salem pro girarn encourages volunteers to visit local WMstoin Salem waterways to make various visual observadons about the habUat and water quaRy. Observaflorrs are Oiared through a paper survey ernaHed back to the stormwater diMsion. Volunteers are provAed with Winston-Salem specific stor-irnwater and stream educational information to hellp gtAde ti,-mrn fl,wough their vistjal observations. Volunteers are encouraged to report any Micit discharges they observe while participating in Stream Watch in Winston-SArrl. Please reference U,ie attadhed spreadsheet for Storrnwater VEflUnteer participation (tor Novernber 2018 onward - (.:\,Stormwater Educator - Educafion 0�,nreach Public Involvement\Ed & Outreach Programs, Spreadsl-u:!et title 'is "Ed_0utreach_Counts,xlsx". For data prior to Novernber 2018, p1rease see spreadshieets saved in Ns folders &\Stormwater lEducator - IE.Auucation Ooutreach Public involvement\Ed & Outreach Prograrns\Ed & Outreach Counts from Roseann 2010-2018). KWSB makitains records of KW'SB sponsored clean ups and shares these with the Stornriwater Division for reporting purposes . . ............ . . . .. . ................. . .. ... .............. . . ...... ........................ . . ............... H.C.2.b. Mechanism for the permAtee provided and promoted a mechanism for public involvement that Y cs Public provi,des for iInputon ctorrnwiite!r icciun and', the stormwater program. firwolvement NCS000247—Winston Salem 2022 MS4 Self -Audit Page 12 of 39 Public Involvement and Participation (Evaluated during self -audit) Comments The City of Winston-Salem has three main mechanisms for public input on stormwater issues as well as soliciting feedback regarding Stormwater's Management Plan; these three mechanisms include City Council Committee meetings, Stormwater Appeals Board, and City Link's'suggestion and comment' service. The City Council (and Public Works Committee) have established open public meetings that citizens are invited to attend to discuss any stormwater-related topic. Public Works Committee meetings are advertised on the City's website and are held the second Tuesday of every month. City Council convenes twice a month - every meeting has an open floor segment, where citizens may voice their stormwater-related concerns. The Stormwater Appeals Board has been created to hear appeals if an owner, developer, engineer or other party disagrees with the decision of Stormwater staff. As of late, the Public Works Committee of the City Council has heard any appeals and carried them to resolution. City Link has instituted a citizen 'suggestion and comment' service request that allows any citizen to submit suggestions or comments, which relates to the Stormwater Management Program. These suggestions or comments are forwarded to the Department Head for review and implementation, if approved. II.C.2.c. The permittee promoted and maintained a hotline/helpline for the public to request information about stormwater, public involvement & participation, and to report des Hotline/Help Line illicit connections & discharges, etc. „ ..,... .. .........- .................. . ..................... ...... -- - — ......... ......... Comments In 2005, City Council commissioned the creation and implementation of a centralized telephone call center/web-based complaint hotline for the citizens of the City of Winston-Salem. Known to the public as City Link, this communication center receives citizen - generated a -mails or telephone calls regarding stormwater-related items illicit within the City. The public can access City Link from the City of Winston-Salem's homepage of https://www.City ofws.org/ or by the chat feature on the City of Winston-Salem's webpage; the City Link button appears at the top portion of the City's homepage and the City Link contact information appears at the bottom of all City webpages. On the Stormwater Division's homepage on the City website, the City Link contact information is provided at the top of the page. The Senior Community Educator receives electronic notifications for presentation requests from City Link or directly from website requests. Illicit discharges are received through the Stormwater Pollution Hotline (336-727-8000), which is operated by City Link. City Link refers all illicit discharge complaints to Stormwater staff, who will investigate.these reports within 24 hours. ILC.2.d. The permittee made the most recent Stormwater Management Plan available for vas Public Comment public review and comment. -------- ---------- - —-------- Comments The current Stormwater Management Plan was posted to the Stormwater Division's webpage in November 2021. One can locate the Stormwater Management Plan at https://www.City ofws.org/DocumentCenter/View/22898/Stormwater-Management-Plan-FY- 2021-2022-pdf II.C.2.e. The permittee complied with State, Tribal and local public notice requirements when Public Notice implementing the public involvement / participation program. ...... ...... Comments The City of Winston-Salem complies with applicable public notice requirements, when implementing its public involvement and participation program. Compliance with 40 CFR 122.34 is achieved by working with the City Secretary's Office, Marketing and Communications and the Community Assistance Specialist for scheduling, advertising, and posting public meetings. -. .- „rv, ��„ ,,,�� Additional Comments: NCS000247_Winston Salem 2022 MS4 Self -Audit Page 13 of 39 1111 it Disd-mrge Detection and Efirnination (III (Evalluated durfing self ,,, audit) Staff Iinta�uviie eat: Il...ad®ntau '..IairYnall' Oairlk, St®irirnnwraauteer Operations Supervisor, oversees, manages, and aeinforc es theStearrnwurater (Nairnea Title, Role) Mviision's IG7DE pro rarm for Iperonrniit co muphance. aaaaaaaSupporting peri�tatlom prDrarra.irerrt Status Doc No ir ��a�x�� aaaaaa� ��a�a�awa�w�� ....• . m�� a �� «��r�� fi � III. _. I`Ihe^ perlrYrurttea-e Imaintained adequate aces or other llegall uthorffies to prolhibit. Legal alkhorhtfiie ulncit connectionsand discharges and the approved ODE:: : ,r��ranrn. Yes ................... . Comments City CouulnciJ adolpted the (:iity's Illpiiciit Discharge Ordinance in September 2005. Currently, the City of Mnnston Saferrn"s IIDIE)E a:.nrdiiinaina:.e its a:.ontainec.-i within Municode, Chapter 75, Article L Storrmwater staff uses U-w duty's Pali DIE: ordiiinaince for regulatory caalrrnpl'iaince to cause illicit discharges and a:a7nrnea::tiaarns frmarrn entering tlha~„ iNJtlS4/ra*a:eMin�p vw'ata:wirs., rIhe proirairminvolves identifying and eIlnmuinad ng %tlficiit substances and irnateriiafsk staff issues Notices of VIollations (114 ) tea U: w offending entity f(.)r permanent resolution of iillllic'it activity. The base file address is, the f e atddre'ss f w• the --------------------- 11.D,2nbr, The 1pe.rlrnuttee r nauntaulned a current irmalp showing major outf«: Hs and receiiviun MS4 IMapping Yesstreams. _......... ................. ............_..__ ........................................... ............................................................. A �. 1 he City's GIIS database its comnprelhelnsiivea the Starmwwater p:.Dlioriis'iein contracts a 1plrofessioniiall engineering firm, 11tDR, to coax ect storennwateeir inventory (e.g., Ipiilpes, structures, rnajor SDOs, eta.) and tine•» corresponding attidbuate data can «a regular bass. A INC licensed surveying firm, IW...A, performs urn field data collection and as.sessrnent services witlh p ill:.)R untegraflng than GIS data into the appiropidate geoda'talbase Mayer (as welI as peirfoirirnnuiin proper CAA/QC data checks). MBA and II p1DIR wind Storirnwater staff) ensure that aallll inventory its collected to the applIcalblle irmajoir stanrnwwateer d°u..: dharge diameter (6 iindi-lies for IresWentW zoned hand use areas .or drainage areas greater (or eetuuall) than att acres Oil 1..2" in uinduustriiM zoned Iand areas or drainage areas greater (or equuall) to two acres. In addition, allll storrnnvnrateir ninfrastruuctuurer within the Ciity's right of way is innaplped and enters t1he l e odatalbase layer, as ws ell, suiince ti-iie pity owwins and operates thnis syste*irn. "rhe Ciity's GI.S data is housed fin its SG:DII: database and operates in the ArdMap:a progrann. Fhe .stormwwateir inventory rnnap can Ibe used to track tine coninectMity of pipes to Pocate illicit discharges. For FY 2021 2022, p- DR Ihias c'onceintirated u nventory reconnaissance actvffies in Lower and fAiddie Creek Suulbvoratershaeds, Upper and Lower IMuuddy Creek .Suulbwnratersheds, portion of Lower Silas Cireek Watershed, and a sea:flo n of LJplpeir IRete:ers Cireelk Watershed. These areas were seilected due tea 1pr'iorutiized impaired segments of.FIW9G::)Ls watersheds and routine watershed innasterpllan uup:adates. Aplproxh- watelly 2,300 major SIDOs were 4-iven.ntoriied, and 1.4 iririfles of s�treairnns were assessed. Aiso, idf..mtii'fiieirf inventory that ineederf uupdating due to °vairiiaaw; capitaa8 Improvement projects, were surveyed and corrected. �m �� ti .. ". _ ..... AILIC�D,•2.�r. ' _. QSt�P's� rhe mittfor detecting rna4ntaiiine;� written procedures and/or Standard Operatpinp Procedures yieatheir Flowg and trading the sources of illpiiciit discharges. �s Program fhe perrYnittee rmnairYtalineu:p written procedures alnd/ear .Standard Operating Procedures (SOPs) fo, rexrnnwdvr ng'the sources or irepor$Vr8g the: sources to the Stn.u'tc, to b .pra'D. perl 1penrmnut'ted. fralr rrnonutorinnu� and how mnanv ouut:fa Hs and the areas �an",, ir�a auto �i�ta q� � uuu or cn uii pa" F� n. h�.: �u�u oouo �� itli�e�Hntaoned writt n rcdces%ures grain �� S that are t6) lia4'* t"arexF'til'�"i fang ( Yes inspections. ......... ......... I ,, .... NCS000247,,,,_Winston SaIern 2022 JVS4 Seif-Auudiit f3a, e 1.4. of 39 Illicit Discharge Detection and Elimination (IDDE) (Evaluated during self -audit) Comments Please reference the attached Item #2, IDDE SOP Manual, for documentation of these above -mentioned BMPs. In addition, please reference the attached document, Item #12 — FY 2021-2022 Dry Weather Outfall Screening SOPS and Schedule that shows this year's timeframe and targeted stream segments for dry weather screening activities. Item #12 is a standalone document from the IDDE SOP Manual but bolsters the City's IDDE program. For this upcoming permit year, Stormwater staff will evaluate FY 2021-2022 water quality data to determine the most impaired stream segments, then create a prioritization list for SDO and stream -walking reconnaissance activities. *Major outfaalls are discharges from .36' diameter pipes or drainage areas of > 50 acres. In areas 2oned for industrial activity, major outfolls are > 12' or drainage area > 2 acres. � .. — - - __ � uP. ., �.,..., ........ ..HHH _ II D.2. Employee Training d The permittee conducted training for appropriate municipal staff on detecting and s reporting illicit connections and discharges. ......... ........-------- --- ....--------- ... _............. ................. .. .......... ..... Comments During FY 2021-2022, the Senior Community Educator, Stormwater Operations Analyst, and the City's Marketing and Communications Department created a new training video that highlights proper pollution prevention & municipal good housekeeping practices for key City operations to eliminate pollutant exposure to the environment. A main topic in this video pertains to recognizing and reporting illicit discharges/dumping activities to Stormwater staff, so more incidents can successfully resolve by Stormwater staff, thanks to 'rank and file' City team members. From November 2021 to March 2022, 2,127 out of 2,354 City employees (90.3%) viewed and passed a confirmation test of Stormwater's new PP & MGH and IDDE training video. II.D.2.e. The permittee maintained and publicized reporting mechanism(s) for the public to YesPublic Reporting report illicit connections and discharges. ............ ..µ_... ......... Comments City Link, the City's centralized citizen reporting center, receives phone calls, emails, social media apps, and Internet inquiries for a myriad of City resource requests. As an option of reporting, citizens can file illicit discharge/dumping claims to City Link. Once a City Link Customer Service Representative intake the complaint, an automated email message (with all pertinent case information) is sent to the Stormwater Operations Supervisor (SOS), Stormwater Operations Analyst, and Assistant Stormwater Director (ASD). Next, the SOS or ASD assigns the service request to a Stormwater Technician (or responds themselves, if staff is busy with their current workload. The City publicizes City Link by using communicative means of the internet, radio, and television - please reference the embedded link below. City Link's contact number is (336) 727-8000. r ,, , Ihl S r1 fu�,,;r%r In addition, Stormwater Division maintains a reporting illicit discharges option on-line at https://www.city ofws.org/817/Report- Polluters. This webpage contains City Link's contact number and general questions to collect illicit discharge information. NCS000247—Winston Salem 2022 MS4 Self -Audit Page 15 of 39 Ifli it: Discharge Detection and Elimination WDE) (EvaIlluated duringtf- i ) IhD.2.f. Documentation The rpermittee documented the date of 'investigations, any enforcernent ac:tlon(s) or Yes remediation -:That occurred. c€smments Stormwwater staff tracks and docurnents every IDDE conilplaiint and iunvest'igatiionony various means,. Rock Solid i.s'the service irequest database that the City uses to intake, track, and manage all IDDE complaints. Vf Storinnwvater staff receives IDDE complaints d'urectlly, these complaints are entered into (bock Sohd.. lEach cataloged servlice request is date and 'Urne starmped by the iresponsible (person; all information cannot be erased, once entered. Rock Solid displays the status of the service request - staff irrnau"nuallly needs to change the status, once compliance 'items have been .suucce.ssfuullly cornpleted. Apart firomi Rock Sohdo every WE investigation has its own electronic fonder on the G� drive and the responding staff irrneinnlber completes an investigation report, which documents the date„ aCA'dres, ocation aarc6 identification �- l , p „ _ _ fieation nunnher, l`wrr�dirng of facts, and result'inp, cornpinance actions to be taken (ifwarranted). All enforcermenrt acdorns are docurnented in the forirnn of a Notice of Viiolatiion (NOV) this enforcernnent inroedi-mniisirn exphcit:ly states what correctiive actions are irequired by the offering party, due date, and potential 'fines, if correc-dve actions are not completed, As a component of the NOV, the offending (party must: submit: remedial docurnnentatiion Q'if apipll'icahle) -to the Stormwvater Division, or a staff mernlbeir must (perform a site inspection to confiirnn successful completion of alll requiired measures. The responding Stormwater staff mernlber(s) documents all successful measures visa photographs, inforrxiation docurnentation in (bock Solid, email, and inspection relports„ Once all measures are confirmed by St:orinnwnrater staff, a successful completion letter is issued to the responsible party.. Lastly, a master Excel spreadsheet tracks all pertiinent iinformadon of each MIDE investigation, nnrMch iincludes resoluflon date„ POCs, inspector, eg:c. - the incident Vocation is mapped on a master CI.S (layer for a geographical reference. The City lids duached this master Excel spreadsheet' for DE(Xs reference. NCS000247 Winston Salem 2022 MS4 Self -Audit Page 16 of 39 Construction Site Runoff Controls (Evaluated during self -audit) Staff interviewed: Matthew Osborne, Erosion Control/Floodplain Program Manager (Name, Title, Role) ,. ro g, Pram Delegation Status: The permittee has a delegated Sediment and Erosion Control Program and implements the North Carolina Sedimentation Pollution Control Act (SPCA) of 1973 and Chapter 4 of Title 15A of the North Carolina Administrative Code. The delegated or authorized Sediment and Erosion Control Program effectively meets the NPDES MS4 MEP standard for Construction Site Runoff Controls by permitting and controlling development activities disturbing one or more acres of land surface and those activities less than one acre that are part of a larger common plan of development as authorized under the Sediment Pollution Control Act of 1973 and Chapter 4 of Title 15A of the North Carolina Administrative Code. Permit Citation Program Requirement Status Supporting Doc No. Ii.E.2.a. Delegated SPCA The permittee implements a delegated program in compliance with the Sediment Program Pollution Control Act of 1973 and Chapter 4 of Title 15A of the North Carolina Yes Administrative Code. _ __ ...... - -------- ------_,------ Comments (Note date of last SPCA delegated program review by NCDEQ-DEMLR staff and result) The most recent delegated program review by NCDEQ-DEMLR staff was July 25, 2017. The result of the delegated program review was a recommendation by NCDEQ-DEMLR staff to continue delegation of the program. 71 .,.,— 1 --r� ,,,,,1,,11,1x,,.w.. ,W1-11. .,.e.<,. .e,..........,... �,.,rvm„ I I. E.2.c. Reporting The permittee provided and promoted a means for the public to notify the yFs Mechanism appropriate authorities of observed erosion and sedimentation problems. ....... Comments - .........-_.....- — - Yes, through information provided on our Erosion Control website (https://www.City ofws.org/733/Erosion-Control). The public can call the City of Winston-Salem's Pollution Hotline at (336) 727-8000 or 311 to report sedimentation discharge claims. Citizens can email City Link at City link@Cityofws.org to report these claims as well. ILE.2.d. -�---- ----- --.....__................__.....----...........-.................-.-..........-------...-_...............—..—_......-- ----.............................................._.....................................__; The permittee coordinated the approval of the construction site runoff control with Coordination with DEMLR for new development and redevelopment projects to be built within the Yes DEMLR permittee's planning jurisdiction by entities with eminent domain authority. ---------- ...................... .... .... Comments Projects with eminent domain authority are referred/forwarded to NCDEQ-DEMLR staff at the Winston-Salem Regional Office by providing a standard comment of referral on plan reviews where Erosion Control staff determine it to be applicable. All projects that receive public funding (from governmental agencies, full or partially funded) are referred/forwarded to NCDEQ-DEMLR staff at the Winston-Salem Regional Office for review and approval. Additional Comments: NCS000247_Winston Salem 2022 MS4 Self -Audit Page 17 of 39 Post -Construction Site RunoffControls (Evaluated durlingself-audit) Staff Interviewed. Doe Fogarty, Stormwa'ter (Engineer. Reviews and approves submitted plains For cornpliance with City `.s pos't- (INairne„'Titlle, (Role) construction ordinance. Ensures all operation and maintenance agreements for SCM.s are properly executed and recorded. Oversees S'tormwater staff (or performs) concerning SCM inspections (private and public) and ensures alppropria'te correspondence to'transmit'ted'to responsible parties. Program Imp iementationn (rfaeck off that o fy)� Z The permprttee iirnplernen'ts the components of this m'iinimurni rneasure. ❑ the perr'n'i'ttee re'lia s upon another ern'ti'ty to prrl�C, k!'mel nt'the u:"«uvB.poneln'ts of this MinXrn'`um measure: n„„r°"ne of entity ❑ 'The perrnit'tee implements 'the 'following Qualifying Alternative Program(s), which meet NPIDES MS4 post -construction requirements in the areas where they are implemented and in compliance with the specific program requirements as provided in 15A NCAC and noted below: ❑ Water Supply Watershed II (WS--I) - 1.5A NCAC 2b .0212 (E'ff. IMarch 1, 2019 15A INCAC 0213 .0620 - „0624) Water Supply Watershed pp (WS- Ill) -15A NCAC 28 .0214 (Eff. March 1.,, 2019.15A NCAC 021a ..0620 - ..0024) ❑ Water .Supply Watershed 1I111 (WS-pii) --1.5A NCAC 2B .0215 (IEff. March 1, 2019 15A INCAC 02B .0pi20 - .0024) ❑ Water Supply Watershed iV (WS-IIV) -- 1.5A NCAC 2B .0210 (E'ff. march 1, 2019 15A INCAC 0215 ,0620 - .0524) f_J Freshwater High Quality Waters (HQ?JV) - 15A NCAC 2H .1006 * Freshwater Outstanding (Resource Waters (ODVRW) - 15A NCAC 2H .1007 r a Ncuse i' ver basin Nutrient Sensitive (NSW) Management nt Strategy .. 15A NCAC 29 .0235 * liar-Pamhco (River I&asiin Nutrient Sensitive (NSW) Management Strategy -15A NCAC 2B .0258 ❑ Randleman make Water Supply Watershed Nutrient Management Strategy -15A NCAC 213 .0251 ❑ Universal Storrnwater Management Program - 15A NCAC 2H .1020 Re ullaltory Authority: The permit9tee uddlize.s the foBiowiir'ng ordinances and/or re ullatory auathorNity to fupfiH post constra.ucfloia rninimuirn measure ppro rairn re(ALsirern°neu°nts (cDma:ac a // that apply): r � DEr"I -ncr •a a rairdir°,ar,,ce JAS4 designed post construction practices that nnee't or exceed 15A NCAC 02.IH A.000 I t1p. Q approved coi npreheinsuve waterslhued ppllan ➢ I[.)IE i, approved Quallifyiind Allteirnatiive Program listed above Program Requirement States Supporting Doc No, IiIC Ciliiiiieu rf tip; the QUdill ;II A: iCi iid iVc Piv lain Ic' UileiiiE ' iJ � � v � � �, � �li��s checked above in accordance with the applicable 15A NCAC rules. NCS000247 Winston Salem 2022 MS4 Self -Audit Page 18 of 39 Post -Construction Site Runoff Controls (Evaluated during self -audit) 02H .1017 The permittee cumulatively implements the Qualifying Alternative Program Qualifying requirements checked above throughout the entire MS4 permitted area. No Alternative If response is no or partial, the permittee implements M 4 post- � .... �, m.a m. P .. Program(s) S4 post- e , 7 construction requirements in accordance with 15A NCAC 02H .1017(3) — Yes 17 (14) throughout the balance of the MS4 permitted area. ........... .... Comments In 2008 with the passage of the Winston Salem stormwater ordinance, Winston Salem began implementing the NPDES MS4 Phase I Post construction stormwater requirements throughout their entire jurisdiction including the water supply watershed protection areas. The post construction requirements and procedures are the same for all areas in Winston Salem, except since the Salem Creek water supply watershed has more stringent impervious cover (built upon area) limits, projects in critical and balance of watershed areas of Salem Creek water supply watershed are identified and reviewed according to more stringent standard. The more stringent Operation and Maintenance agreements, schedules, inspections, etc. associated with NPDES MS4 Phase I program are also enforced within the water supply watershed protection areas of Winston Salem jurisdiction. Permit Citation Program Requirement Status Supporting Doc No. II F.2.a. The permittee maintained an ordinance or similar regulatory mechanism that Legal Authority authorizes a program to address stormwater runoff from new development and Yes 17 redevelopment to the extent allowable under State law. —-------- _.___.._ __._w_ . .__..... Comments The Stormwater Division oversees and enforces the City's post -construction stormwater management program. The City of Winston-Salem has supplemented previous water supply watershed regulations with current post -construction regulations for Class `C' waters in order to address stormwater runoff from new and redeveloped sites. The current Post Construction Stormwater Management ordinance was adopted by the City Council on September 19, 2008, and this ordinance applies to all development within our jurisdictional area (municipal boundary). The City's Post -construction Ordinance can be located at https:Hlibrary.municode.com/nc/winston-salem/codes/code_Of_ordinances?nodeld=PTIIICOOR_CH75STMA_ARTIVPOCOST. .. _.-_.__ _ —_ ...v.. — — — II F.2.b. The permittee maintains strategies that include a combination of structural and/or 1 Stormwater Control Yes non-structural SCMs in concurrence with the legal authorities above (II.F.2.a.). Measures (SCMs) The permittee provides a mechanism to require long-term operation and 17 yes maintenance of structural SCMs. _ ................ _ .. ---- -._..-------- _-------- ----- 1 The permittee requires annual inspection reports of permitted structural SCMs Yes 7 performed by a qualified professional. The permittee implements SCM requirements that are at least as stringent as the Yes 17 minimum requirements in 15A NCAC 02H .1000. NCS000247_Winston Salem 2022 MS4 Self -Audit Page 19 of 39 Post,„Construction Site lf oit l (Evaluated ri self -audit) Comments The City of Wilnstoin Salem's Post Colnstructilorn Storinrnwatelr IManag'ernerrot ordinance provides sizing and performance criteda for water quality and puantilty .SCIMs. the City of Mnstoln--Salem has also adopted the St:at:e's Stormwater Il)esigln and NCDOT i.finear Transportatfiorn Toolbox as technical guuiides for designing structural) SCM.s within its jiuriisdict'ionall area and thus for use in also p;-oviding sizing perforiiancc, critcria, in ".rcmbinat;on .'. ith the Cr,4;r :r:.,._. µrC'5.,,.-ns. The ordinance addresses both lows density and lhigh-density development scenaidos as (regards water quality attenuation. (Low den.sfity develolprru.mrs (less than 24 percent built upon area, or less afro«-arn two dwelling units per an acre) must meet all the Minimum tteMgn Criteria (M10C( of the NC 0WP Stormwater Design Manual -l_ow Density Chapter, to the Imaximu.ulrrn extent practicable. Such ftelrns include but are not limited to recording of stream buffers where applicable and using vegetative conveyances to the maximum extent practicable. High density developments greater than 24 percent built upon .area and snore than two dwelling units per acre) in addition to meedi ng all the lover density (non structural SCM requirements, to the Imaxiilnnu.um extent )practicable, must also (provide structural SCMs. Any SCM or combi n°na'tion off SCMs diroat are k,orwsldelred "Mmary" St;NtPi's per the Stormwater Design Manual and that can be r:ffectwve�y constructed in the Piedmont physiiogralpliroilc re&n may Ilse approved by time Stormwater Engineer or Stormwater Director. In addRiioln, the Post Cons trucdon .Storrnwatelr IManagement ordinance also includes a local rep,uilrernelnt for water quantity standards if a developnnent creates more than 20,000 square feet of new ill riperviiou.us area. lff that its the case a developrnent must either, (a) design structurall SCIMs in order to Inn'itlgate detrirnroerntall downstream effects of flooding and erosiorn in valr'iou.s design storm events, or in heu of Innalnagenrrelnt (provide a "no adverse irnropact downstlrearn study" if indeed a no adverse iirripact situation can be proven. Storlrnwater staff inspect approved water quantity SCIMs (pre 2008 post -construction ordinance adoptiion) as well as the Salem Il...alke Watershed (Water Supply III/ Classification) SC`Ms ore an annual) basis. Next, Stormwater staff informs I.he owners of (record of any deficiefties noted .so that tlliley rrnay be addressed. perat'uon and Mannt:enance Agireernents are Irerfuulred to be approved, recorded and iinnIpllernnented for alll the developments located witMri the Salem Lake Watershed area that require SCM(s) and the owners of such .SCIVis are bound to the terms of that aglreelrnent. SCIMs, within the ('.Ity hrnuits judsdilcdon and approved after the adoption of the post construction orrffinance, must havie an Ctper"at'iorn and Maintenance Agreernent recorded as part of the post construction permit process that is bind°ung on the SCM( owner. The rr:isponslbihty of.SCIM ilrnspecdoln and maintenance is placed on the designated SCMI owlneir„ or Homeowners Assn:»ciadon/Prolperty Owners Association„ as aplplicablle, who has signed the recorded Operation and Maintenance Agreement. The recfuirements For such ilnslpectiolns and maintenance are ou'dined in am Operadon and Maintenance Manual that foams part of the rn � raii � s uu�r'ado n n i �d"� l " :ronQ� inrtcniG"'nt„r�'@"@wan"nr:� Ai;rraerruq.rnt, ii�r^i,,linnlrnbe;n rvroflirmsr"''t„i'n� r;a�rr'L'lfurrat;ua::,nrn n.nf �:in�" �k5 1:a4gilt du "ronr�Pun"u,f�rN for an Cn� narlllti:k''d storlrnwater management syst:elrn, the system roust: The inspected per the ffrerplu,llelncy described fin this agreement by a suitably qualified professional on behalf of the owner.. The owner must keep all records of tlinese inspections and any maintenance act'Mtles that: may have been necessary and submk these records to time Stormwater IUirectolr for (review on an annual basis. The Storlrnwater (Director or, his designee rnay carry out: This own inspection to validate such submitted (records. RII �...rpw Deed Restrictions The perry -dirt -tee provides mechanisms such as recorded deed Ires fictions, plats, and (Protective and/or protective covelnants so that development activlt'ies maint.afin the project Yes Covenants colnsMent: with approved 1pllans. NCS000247 Winston Salem 2022 MS4 Self -Audit Page 20 of 39 Post -Construction Site Runoff Controls (Evaluated during self -audit) Comments The City of Winston-Salem created, adopted, and implemented its post -construction ordinance on September 19, 2008. This ordinance includes comprehensive regulatory procedures in order to ensure compliance. Right of entry drainage and access easements must be granted to the City to inspect, monitor, maintain, repair, or to reconstruct the stormwater management system as necessary and these easements are referenced in the recorded Operation and Maintenance Agreements. Notice of Violations, remedies, and monetary penalties are examples of regulatory tools contained within the post -construction ordinance that the Stormwater Division utilizes as enforcement mechanisms. For further reference, the City's Post -construction Stormwater Control Ordinance (Chapter 75, Article IV) can be located at this link: https:Hlibrary.municode.com/nc/winston- salem/codes/code_of_ordinances?nodeld=PTIIICOOR_CH75STMA_ARTIVPOCOST II.F.2.d The developer provides the permittee with an operation and maintenance plan for Operation and the stormwater system, indicating the operation and maintenance actions that Maintenance Plans Yes 18,1 shall be taken, specific quantitative criteria used for determining when those actions shall be taken, and who is responsible for those actions. The plans clearly indicate the steps that shall be taken and who shall be responsible for restoring a stormwater system to design specifications if a failure occurs and No 18 include a legally enforceable acknowledgment by the responsible party. The plans include a legally enforceable acknowledgment by the responsible party. No 18 Development is maintained consistent with the requirements in the approved 18 plans. Modifications to those plans must be / are approved by the Permittee. Yes 18 NCS000247_Winston Salem 2022 MS4 Self -Audit Page 21 of 39 Post -Construction Site Runoff Contrails (Evaluated during self -audit) Comments SCMsy within the City limits juwuirii.sdicdoirn and approved after the adoption of the 2008 Post -construction Ordinance, must have an Operation and Maintenance Agreement recorded as part of the post construction permit process that is binding on the SCM owner. "rhe responsibility of SCM inspection and maintenance is placed on -the designated SLIM owner, or (Homeowners A " tl rT _.kg. 9^u ."Hera nPdS-o ia^.aftna « �. -ppli b erg Igo, s _..,' recorded Opr� at'r,_v ar, �� a ^te nce Agreement. 'Pie ss c ci as o, o n, .i ,...rv. r; ikha uwou7,� c'-.�z .z „nk�°r"fl tlh �.' d �.. N, r na� .. ��._u. requiirernerrts for such inspections and maintenance are outlined in an Operation and Maintenance Manual that forms (part of the overall Operation and Maintenance Agreement. (Beginning after the ceirtifiication of the as -built drawings for a (permitted storr'nwater rmanagernent system, the system must be inspected per the -frequency described in thus agreement by a suitably qualified professional on behalf of the owner. The owner must keep all records of these inspections and any maintenance activities that may have been necessary and submit these records to the Stormwater Drector -for review on an annual basis. The Stormwaer Urector or hies designee may carry out his own inspection to vallWate such submitted records. Alll structural SCMs approved in accordance with the Post -Construction Stonrmnwater Management ordinance must have a financial surety that meets the requirements of the ordinance proviisiornsa in force prior to permit issuance. For a developer who wanks to remain -the party responsible in perpetuity For the long-term Operadon and Maintenance of the system, a payment into the Cirty"s Catastrophic Faiiluire Fund shall equal four percent of the estimated construcdorn cost of the stormwater management system, verified by submittal of a sealed engineers estiirmate. This pay rent its maintained a City account and is morn-refundabie. Time developer may apply for a loan from -this account if needed to address systeirn deficiencies. For.SCMs that are 'to be owned and operated by a IH OA or POAa then the surety that its required its in the form of an escrow account and escrow agreement.. The developer establishes an escrow account at the time of permitting and deposits 15 1percernt of the estimated construction cost of the stor mwatermanagement system inn'to this account, with 'the II®I0A/P011A to add further funds in the future. An escrow agreement must be approved and recorded during -the permit process, which allows the City access to this escrow account, and its funds if needed should a SCM owner faiill to comply with maintaiiini ng the systern. Materials and the permitttee pirovided educational materials and tira'inir'og for developers. `he's Training NCS000247 Winston Salem 2022 MS4 Self -Audit Page 22 of 39 Post -Construction Site Runoff Controls (Evaluated during self -audit) Comments Multiple training and information sessions were provided by Stormwater Division staff prior to and after the ordinance implementation in 2008. Educational materials provided include a permit application flowchart, example of design calculations and other supplementary information such as Operation and Maintenance Manual templates. These are available on the Stormwater Division's website. The Stormwater Engineer, and if needed, the Stormwater Director, also make themselves regularly available to meet with developers at their request on an individual basis if they need guidance on permit policies and procedures before applying for a permit. The Stormwater Engineer is also a member of the City's Technical Review Committee (TRC) and attends in person meetings held on a weekly and monthly basis to explain the post -construction stormwater management permitting process to applicants looking to develop or redevelop property within the City limits and Salem Lake Watershed. The Stormwater Engineer has on average three such meetings (individual plus TRC combined) on a weekly basis. The Stormwater Engineer fulfills multiple meetings and information requests from developers, owners, and citizens either by phone or e-mail on a weekly basis outside of the in -person meetings. Currently, the Stormwater Director and Stormwater Engineer regularly attend a Developer Forum and Planning Board meeting to inform interested parties regarding the post -construction permitting, potential communal negative impacts, and other pertinent post -construction stormwater management topics. The City maintains a website on the Stormwater Divisions webpage that addresses the City's post -construction permitting process as well as development requirements within the regulated Salem Lake Watershed area. This website is used as an educational tool available to all developers and SCM owners. The website contains items such as, a link to the Post Construction Stormwater Management ordinance, a link to the NC DWR Stormwater Design Manual website, the permit flow chart, a link to the permit application and checklists for submittal, templates for Operation and Maintenance Agreements and Manuals, design examples or SCMs, templates for inspections and annual compliance reports, a link to the electronic review submittal system and also a detailed FAQ section that attempts to address most, if not all of the questions that developers and SCM owners typically have. This website may be found at https://www.city ofws.org/794/Post-Construction-Stormwater-Management. I. F.4. Sensitive Receiving Waters Comments None II.F.S. Permittee Projects Comments The permittee applies additional requirements to projects draining to SA waters by requiring SCMs that result in the highest degree of fecal coliform die -off and Not controls sources of fecal coliform to the maximum extent practicable in accordance "p[iaEal With 15A NCAC 02H .1017(9) The permittee applies additional requirements to projects draining to Trout waters by requiring SCMs that avoid a sustained increase in receiving water temperature¢ AppikakaCe in accordance with 15A NCAC 02H .1017(9) The permittee implements an approved locally implemented Nutrient Management Strategy that addresses post -construction runoff and the provisions of that Strategy fulfill the MS4 post -construction requirement. The permittee meets the requirements of the post -construction program for construction projects that are performed by, or under contract for, the permittee. M NCS000247_Winston Salem 2022 MS4 Self -Audit Page 23 of 39 Post -Construction Site Run - on r ls (Evaluated duric f-audit) SCM 10esigirn opanirnne Fhe paermuttee reci sires ilhat tlhe n� ester quiahty design vollunne of SCIMs account for Yes 11:Ihe irunoff at bu'idd out from adll surfaces drainhig to the systern. 1117 ........ ........ ......... Comments SC ex U . U •6_ u V ., y s 4 y d .V- �U - 0 �Vv .B _t _� ,.w � fur d P�•Ph° V 9 p stage ;:ru,.pW90 064dapk.�V N V„Ncplio4 ka4 �N 119� �q hdu�VVWVI(li@�S r�liQ, V4�� duli�.�U B6n'0.Jfn6.. u.ulia.&oGpr�ON��. ¢sliou.H nlil�'o s4.nJ94�r4V,4'G„4 rya hr mu�:'rrw �e�—a� uAd� �e�euaa un3en"'6'�5 urs na.avosaorn of draiinage delineation pad«ans/rnapas, as a part optdae design docunnents. p� ds tIh IOosi aonsllructiononinion projects , H.F.7 Lineait dine eirmnpteepfrAlliud p m, couon rnuinimuinn control measure requirements or non S� ii Ilurnear tr p� P ject:s rC they are dcsog ned, Transportation � constructed, and conveyed as set ffor h in 15A IMCAC 02H .1001( )(c) Projects (i) Coun.suructed to NCD OT.starndards and M accordance with, the Na_DOT BMP foolboxr es 7 (h) Conveyed to NCD Oii or other public ernt'ity and regulated in accordance with that entity's Np'Ci ES IMS4 Perr ft; and (ddi) Fhe project is not Ipart of a common plan of devedoprment. Comments The City of Win sp:on-Sallern uiiildzes the NCI010'r p._pnear Tiranspaortation BMP'Toollliaox for roads, strolllways, greenways and other Hinear projects., These may include vegetated conveyances and p iurnge pools to the MEP. Additional Comments: NCS000247 Winston Salem 2022 MS4 Self -Audit Page 24 of 39 Pollution Prevention and Good Housekeeping for Municipal Operations (Evaluated during self -audit and onsite audit) Staff Interviewed: j Ladonta Jamal Clark — Stormwater Operations Supervisor (Name, Title, Role) Title: Stormwater Operations Supervisor Role: (Supervisor) Supervising Two Stormwater Technicians and One Stormwater Inspector. Oversees the Pollution Prevention and Good Housekeeping for Municipal Operations/Facilities program. Andrew Allen — Assistant Stormwater Director Keith Huff—Stormwater Director Permit Citation Program Requirement :Status Supporting Doc No. II.G.2.a. The permittee maintained an inventory of municipal facilities and operations Municipal Facility owned and operated by the permittee that have been determined by the ices Inventory permittee to have significant potential or generating polluted Stormwater runoff. The permittee maintained an inventory of municipally -owned structural SCMS. YES -- — — - — ----------------------------------- Comments The Stormwater Inspector and/or the Stormwater Operations Supervisor maintains a comprehensive inventory of municipal facilities and operations. This inventory is very detailed and encompasses pertinent facility/operation information, such as facility contact, last date of inspection, priority ranking, located within a TMDL watershed, etc. The Stormwater Engineer maintains an inventory of structural SCMS that are City -owned. This inventory includes basic information, which encompasses date of installation, location, type of SCM, pollutants treated, possesses an O&M Plan, etc. Thelinkto the exact„soreadsheet is here G:AIndustrial Inspection & Municipal Goodhousekeeping\MGH&PP Program\Municipal Facilities\Master Municipal\Master Municipal.xlsx Last Updated Date: 10/11/2021 of the Master Municipal Facilities/Operations List. Last„Updated Date: 1/3/2022 of inventory of City -owned SCMS II.G.2.b. The permittee implemented an inspection and maintenance program for facilities Inspection and and operations owned and operated by the permittee for potential sources of Maintenance for polluted runoff, including stormwater controls and conveyance systems. Municipal Facilities The inspection program evaluates pollutant sources, documents deficiencies, plans corrective actions, implements appropriate controls, and documents the accomplishment of corrective actions. The maintenance program includes maintenance activities and procedures aimed at preventing or reducing pollutants generated from municipal facilities and , operations. NCS000247—Winston Salem 2022 MS4 Self -Audit Page 25 of 39 PollutionPoflution Prevention aIon Housekeeping -f r Municipal Operations (Evaluated during self -audit and onsite audit) row ernts "fhe Stormwater Division 'inspects and ensures proper maintenance act:dvdties of City -owned facdlides or operations by irneans of the creation and impllementatiion of a .storr iwater 1pnodlution prevention 111 (SPPP) by the resporn.sBiille City entity. The Stormrnaater inrnpr nr z'nrndqurtc 'nu nprfiu' i . ' a nrinritri7 site- air operai'ion5 are o rl r'6 �` V"D r'"U �+a�r"d d1Vtl 'V' C I�U"0 d'Y rV'U'4® 6-�MPP� db ' V' 6� r&€"U U'V'"ed' B"br p'�Irro 6�"r"%�lt@fiY Vb" UPS% 6y V" inspected on an drncreased frequency and/or order. As muniicill facilifles or operations are'rinspect:ed, the inspection results (e.g., Required Aclio ns to be Completed by the racifity) are incorporated into the Stornnwater Din Mon".s master tracking gist. inspections are conducted, recorded, docurnented, and sent to the responsible rnunicipad entity Mth required correctdve actions that need to Use completed. Each site pollution preventdorn plan has a mail nteroarnce schedule of d3MP.s, and the Storrnronrater Inspector monitors BMP cornropdetlon iuy means of site reiinispectdorns and/or submf Led documentation. it he Stormwater inspector tracks the completion of all required BMP actions and schedules sine ireiinspeatdons, if the irespaornsfte municipal entity does not respond witihiirro the specified due date. dnspectdoni form folder is Ihyproerliniked Ihereu G'AlllndUstrW Inspection & Municipal CiegradhouAselkeell°)'ng\dnslpectdon Forrn.s\drndustriiall ln.speation 1Forms Nia ,. o„ mhue lipernnittepal diimeailiinliained and implemented Site Podllutiorn Prevention Plans for IP Site s�piu�tiorn 3 iiee to have sm mfiicarnt . oteintial for jenerati g Prevention IPiairros fair . nfro g Yes o�rrroc.d and operated by the perrrnnttee that arora= determined by the p:as�irirnroii ^� f; y ng Ipa�dduta�ri Municipal PacHitpies st:orrnwater runoff that has the goal of preventing or reducing Ipoillutaint rurmoff. NCS000247_Winston Salem 2022 MS4 Self -Audit Page 26 of 39 Pollution Prevention and Good Housekeeping for Municipal Operations (Evaluated during self -audit and onsite audit) Comments The Stormwater Division inspects and ensures proper maintenance activities of City owned facilities and operations by creation and implementation of stormwater pollution prevention plan (SPPP) by the responsible city entity. If a municipal facility has an NCG permit or possess the size and magnitude of a state -permitted facility, then the created stormwater pollution prevention plan (SPPP) will follow the outline and contain contents of a general stormwater permit. This ensures that larger and/or more complex municipal operations/facilities possess a SPPP that is compliant with permit requirements as well as eliminating pollutant exposure to stormwater. If City -owned facility/operation has the potential to generate pollutants, but not large or complex, the facility is issued an abbreviated SPPP. An abbreviated plan consists of numerous aspects of a permitted -facility SPPP, (e.g., spill response measures, basic facility maps with stormwater discharge outfalls, good housekeeping and preventative maintenance schedule, employee training, etc.), but not all SPPP components (e.g., feasibility study, risk assessment, site maps with topography, etc.). It is the municipal entity's responsibility to implement all provisions of their assigned SPPP, including updating all pertinent information, as site or personnel changes occur. General SPPP templates and inspection -generated material are stored digitally on the Stormwater Division's shared G: drive by Stormwater Inspector or Stormwater Operations Supervisor. The Stormwater Inspector conducts a site inspection to track and monitor the progression of SPPP compliance. When an inspection is completed, the Stormwater Inspector denotes any required actions that facility will need to perform to maintain SPPP compliance; the Stormwater Inspector sends an electronic inspection report to the facility for corrections. As the Stormwater Inspector performs their site inspection, they have access to the facility's current SPPP for comparing site conditions to the Stormwater Division's inspection form. Winston Satenn sendis inspection results/reparts to EQ-Wi stoi,. Salem Regional Office (WS€ O) who acknowledges receipt, Weaver Fertilizer is only facility where i CDEQ and Winston Salem coordinated inspection related activities. Winston Salem, uses, one form for all facility inspections, smaller faciNdes have more "NAs" on the results, Tkuo thirds of all facilities that. have potential to generate poliLsied stormwater runoff have SPPPs. Work conflnUef; in this area, After reviewinS the master m,unicifaal facilitiesorerations_srreadsheetJ Stormwater staff have determined the following breakdown for SPPPs: The number of municipally -owned facilities/operations that possess SPPPs (full or abbreviated) = 58 The number of municipally -owned facilities/operations to be evaluated for potential pollutants and SPPP creation = 25 The number of municipally -owned facilities that possess a spill prevention, control, and countermeasure plan = 3 Stormwater staff have digitalized all inspection forms which are stored at the following; hperlink locations: G:\Industrial Inspection & Municipal Goodhousekeeping\MGH&PP Program\Completed MGH SWPPPs G:\Industrial Inspection & Municipal Goodhousekeeping\MGH&PP Program\Municipal Facilities -..._N. - _- ----- wr 11 G.2.d. The permittee maintains spill response procedures for municipal facilities and Spill Response operations owned and operated by the permittee that have been determined by Procedures for gyres the permittee to have significant potential for generating polluted stormwater Municipal Facilities runoff. NCS000247_Winston Salem 2022 MS4 Self -Audit Page 27 of 39 self -audit and onsiteua lit) Comments All spill response procedures (.SRP) for municipal facilities are included in every site pollution prevention (plan (SPPIP). ln'thne event of a spill, the murniclpall facility wllll be able to use their SIRPs -for innirti ating the effects of said spill. In addition, the responsible entity must keeP 'Glenn SPPO C °,rre inty MrYnurhn EncViiu rs SRPs ind thra c aiVC rF'ShYone tad wn contact Oliprom, A thp S't4ormw itelr inspertnr inspects the facility, hie or she denotes if the responsible entity roust make any needed changes. Prrrnployee:m awareness l.s the Ikey to an effective spill prevention and irespor'ise program.. Spill prevention tralnlnp is a component of the general employee 'training program. IMew personnel area taugll'nt spill prevention practices during the City „s new employee oirilei'itatlr,.aru.. The spill response team gains a sufficient understandlinp of the olpjectives of the spiill prevention pro, rarrn..Spill prever'ntlon trallinling hnighhights previioa.ns spill events„ equipment failures, rerrnedles taken, and newly deve: oped prevention rnneasures„ The Stormwater Spill (Response ➢"enam Leader evaluates the .spill prevention program at least once each year to keep it current. Tti-e_,Vaic;adoin for the foie I'ocatiloin can ..b.p...$falu..p,.d...here'..,lirLtt;, r h °.neilL liinl��; &\: ndausti ll lnspection & Mu.unicipM Good lhouselkeepin \lMG H&IRP l:Irogram'\Comlpleted IMGH SWPPPs G.Alndustrial linspecdoi"7 & Miiuniclpall Gooclhnousekeeping\MGH&l:IP Pro ram Municipall hacllhtles H. w2„e. The permlttee descil imea.sures that prevent or minlirn'ize contamination of the Vehicle avid torrnwater runoff from all areas used for velhiicle and equipment cleaning„ gyres Equiip!n-wint Cleaning including fire stations that have n'iore thiain three flre trucks and an'ibulanceso Areas Fhe permittee performs all cleaniling operatloins indoors, covers the cleaning I operations, eristAires wash water drains to the saniitary sewer system, collects wash 5 water and stormwater, run-oin from the cleaniln,g areas and Iprusvldes treatment or recycliing, or od,-wr equivalent rneasuures rhne permfttee„ if sanitary sewer is not avallalhalle to the facility and cleaning operations take place outdoors„ ensures warn water drains to an SCiM for treatimeu"nt„ or, else the deanling operatlonis take place on or drain direcidly to grassed Yes or graveled areas to prevent point source diiischnar es of wash water into tlhe storrn drains or surface waters. NCS000247_Winston Salem 2022 MS4 Self -Audit Page 28 of 39 Pollution Prevention and Good Housekeeping for Municipal Operations (Evaluated during self -audit and onsite audit) The permittee, where cleaning operations cannot be performed as described above and when operations are performed in the vicinity of a storm drainage collection system, covers the drain(s) with a portable drain cover during cleaning activities, Yes and any excess standing water is removed and properly handled prior to removing the drain cover. The permittee facilities that have three or fewer fire trucks and ambulances attempt to comply with the above requirements; however, those that cannot comply with these requirements due to existing limitations incorporate structural measures during facility renovation to the extent practicable. Comments To mitigate any pollutants from being released into the MS4 or receiving waters from vehicle cleaning activities, all vehicle washing is performed at Fleet Services' Lowery Street location. At that facility, the City of Winston Salem has four wash bays that are connected to oil and water separators — these separators discharge to the sanitary sewer system. One bay is an automatic wash bay that fits vehicles 7 foot and lower. Two of the bays wash high clearance vehicles; the other bay is an automatic wash bay for heavy equipment. All City of Winston Salem employees are advised to use this facility as their main source of vehicle and equipment cleaning, unless employees use a private auto -washing facility that is connected to the sanitary sewer. All fire stations have a stormwater pollution prevention plan; Stormwater staff recommended to the Winston-Salem Fire Department to prevent all wash water from entering the MS4 system during vehicle -washing activities. The WSFD SPPP is located at the following location: G:\Industrial Inspection & Municipal Good housekeeping\MGH&PP Program\Completed MGH SWPPPs\Fire Stations ILG.2.f. Streets, Roads and The permittee implements BMPs to reduce polluted stormwater runoff from Public Parking Lot municipally -owned streets, roads, and public parking lots within the corporate 'Yes Maintenance limits. Comments Winston Salem se;veeps 411 their nvin streets and the four municipal €aCilideS Using brush, water jet and vacuum, Field Operations at City Yard processes an average of 800 service requests annually resulting in over 1,450 work orders each year. These work orders address a wide variety of maintenance tasks from inlet cleaning to ditch reshaping to structural maintenance. If structures have observable structural damage, the structure is placed on a prioritization list for future repair or replacement. Please reference the City's MS4 Inspection, Operation, and Maintenance Plan (I, O, and M) for more detailed information regarding this permit requirement. Stormwater staff prioritized the top four parking lots/facilities for street sweeping activities, based on potential pollutant exportation. These facilities include Fleet Services, Sanitation/Lowery Street car -washing facility, Streets (Field Operations), and the Winston-Salem Transit Authority (WSTA) Maintenance and Parking Facility. These facilities are swept every other week (on average) by the City's Sanitation Department. NCS000247_Winston Salem 2022 MS4 Self -Audit Page 29 of 39 self -audit it at IIGo w „. 'Fhe perimiittee irnairrtained and irrrnplemented ain inspection and maintenance lnspection and program for structural stormwater control measures (SCMs) owned and operated 7rt, I afintenance for I by the municipality. Municipal SCMPs and .................. MS4 The permittee maintained and iiirnpVemented an inspection and maintenance program for the muunicipall storim sewer systern (inctluding catch basins, the conveyance system and SCMs). n� �r�i s ( y it t The Storinnwater Engineer, a IMoirtlhn Carohna licensed 12rofesMonall engiir-iieeir, inspected allll City -owned .si•orinwater coinrtiroll measures (SCI\As) in Novialyuloeir 2021. Admittiinglly„ the Storrnwater DiMsiorn has not performed significant maintenance for its SCIMs„ since (being installled, otheir tlhaui tiraslhn/debiriis ireirnowmall. Reasons for the lack of Mgiruif'icant ma'inteinance activities 'nciuude„ lout Ilirmiited to, insufficient resources, staffing factor, and C VID 1.9., I:::lelld 01peratlon.s at Ciity Yard processes an aveimge of800 service requests aninualVy resulting in over 1,450 work orders each year.. These work orders �:Mdiress a wide wmadety of innaiiini.:enance tasks from 'inllet c; eaning to dl cil—u resl'najpung to structural malintenaince.. if structures have obseirvaWe struct:urA damage,the structure its 1pllaced on a 1piriioritiizatiorn hst for future relpiair or re1paceirnent, iriease reference the Ciity's MS4 inspection„ Operation„ and Maintenance Plain (i, C)d aind M) for irnore de'tallled irnformatiorn regarding thiis perrnit: requirernent. a No'd r':u'nent movid- E, or iC'P,`,'i it rr3, NCS000247_Winston Salem 2022 MS4 Self -Audit Page 30 of 39 Pollution Prevention and Good Housekeeping for Municipal Operations (Evaluated during self -audit and onsite audit) II.G.2.h. The permittee maintained a training plan that indicates when, how often, and who Staff Training Yes - is required to be trained and what they are to be trained on. The permittee implemented a training plan that indicates when, how often, and yes who is required to be trained and what they are to be trained on. Comments In each site pollution prevention plan, there is a section that requires the responsible entity to perform spill response (SR) training. During the site inspection, the Stormwater Inspector audits the facility's current SR documentation and provides training for staff when needed. The SPPP requires SR training be done at least once a year and anytime that there is a new employee that has joined the work force. This type of training is specific to the operation. Also, on the Stormwater Division's inspection form, there is a question where the Inspector denotes if training has been completed. This question reminds the Inspector to confirm training has been completed and properly documented (within the Stormwater Management Strategy section of the municipal/industrial inspection form). The Senior Community Educator and the Stormwater Inspector collaborate and provide educational DVDs that cover multiple pollution prevention topics to pertinent City employees. E €[ucazianal vldeo crwers all Winston Salem employees view dais video with all the different categories. During FY 2021-2022, the Senior Community Educator, Stormwater Operations Analyst, and the City's Marketing and Communications Department created a new training video that highlights proper pollution prevention & municipal good housekeeping practices for key City operations to eliminate pollutant exposure to the environment. A main topic in this video pertains to recognizing and reporting illicit discharges/dumping activities to Stormwater staff, so more incidents can successfully be resolve by Stormwater staff, thanks to 'rank and file' City team members. From November 2021 to March 2022, 2,127 out of 2,354 City employees (90.3%) viewed and passed a confirmation test of Stormwater's new PP & MGH and IDDE training video. This educational video will need to be viewed by all City employees on an annual frequency for maximum memory retention. Additional Citizens can use Cityl-ink to request service for one or more of the different components of the Winston S;;lem Comments: star water system. These service requests are translated into work: carders to be addressed NCS000247_Winston Salem 2022 MS4 Self -Audit Page 31 of 39 F)rogram to Monftor and E.:.vaWate Star eater Discharges iMuniCi Ill Systeims (Evaluated u rfiri said -a a it ) Staff Interviewed: Name: ILadonta Clark "Jalrnai" (IINiame, "ilatfes Role) futl'e: Stolrlrnwnuatelr Operations Supervisor IRa>Ilm:; RSuurwelrwuisorf Superwisilnf fwo Storlrnwnuat:er fuachniiciialns and One Stormwater Inspector. RteslpolnsiiWe'folr adlrniilnilstelriin ; and ensuring fner mNt a-om fI ance withthe. Stormwater R: Msion"s indus'trhfl Bn.sPecdon Program, Permit Citation Program Requirement ruiremelrnt status suppprurtkig WR.RI"4.2. . f�ye perimitt�''a"'. Bnnaiintai ' in M lrY01-.,,, I,_., to � w ............................................ M Y •. ds .0 w r� Wii.a. hazardous orG:n W�uCrcGS�4uw areatme'a oii.y ... �. Irna" �n 'n"welnt�iry i� p�Jel Industrial Facility R osaV" and (recovery ffaciill'itiies indiusrtlriiall faaniiV'itues that are subject to Section 1313 Yes Inventory of'firtua: RRB o0the Su.up:uelrfur7�d arnalbdrnneo°nts and Rea uutanauuozuaRoaurn, aa:a auf1Qreu'.iaRrkf. The 1pelrlrniit'tee maiin'taiined an inventory of ind'ustriall facilities identified wiitfn ail indu.st:lriiall activity (as defined in DLO CfR 12.2.26) Ipervni'tted to &schalrge storm water `yes to the 1perlrn'i'ttee"s MS4. C m ynenis flh e Stolrmwater Mvirsioln maintains a conrilplrelh'nelrnsiive industrial ffaaM'Hilty inventory. Tlhne Stolrrruwater inspector cons"Its tine C Invillrolnmentall Pir'otectiorn Agency's databases (via the Mtelrnet) to obtain appll'Ruablle I'Irndulstriies" within the muln'iaw'ipal boulndaides of Winston Salleirri, tllrirat airs:% subject to SAI'M Title RRR (ii.e.„ RbC11A ffaciil'iitlies) and permitted I'naxardous waste ffaciiViitiles (ii.e.® tlhne toxic release inventory facilities). flhen" the Storrnnwater Mnlpectolr obtallris" active and expired NFI Dll::: n Storlrnwatelr Per'Infni .teQ-Ts froini North Carolina Depalrtlrnnelnt of E.:.Invirolnlrnneintall Quality's wo»welbsite Iltfulin the Cilty hir nits. the St.olrinri water Rlnslpector consults IEFIA".s and DII:.Q's wewelbsilltes annually to maiilntailn a complete and currernt: datalbase. The fille Iloca'tioln 'fbir allll databases is (located. C:AI lrfldustlriialL..ilns� e�.......................... ..................._ p tioln & VMuulniiciilpall Good Inouusekeelpiirn \llndust_Vlrislpect\Ci'ty G:\Illnduustlriall Illnslpection & IMuuln'ic'ilpall Good1hnousa:lkeelpiing\11indust.......Vlrnspect\Oty Ir M r..,:ye....... �"�Ilndu.us'a:ruaRInspectionInspection�c uulrnilawigpall a�ayaud1�r�llusel'�a:::ipiln� Ru�ua�usR IlnsPeot\f::ity 4/1.2/20: '2) Source wnrebsR-tes of FaClltA.JJI�hVB."....and ....state •..:Pa.,!I Rued storrnw ater faa:,ihties Actilve & Expired NPDE: S SiColrmwa'ter P-!!runts deq..nu.gov rM Gathered from USEPA "II'IM R ar:fl iu:ws Search RCRfA LJsiling USE.41A IE:nvilrofnua:ts IRCRkA ILookuulp Illndustidal Rlnfforlrnat'ionvi-vu (updated 4/11/2022) Ilndustriiall Rlnrforrnnatlioln\RCRtA (updated 4/�I.'.t./202'.t.) Rndustriall iu'nfformat'ion\Actiive CoCs (Updated Rir,a°R.2.b Y Ip re sip,:. procedures. T1hna:^ ermlitteorw� i. . riiolrllt ffauiiVilt'ia�s include tinan�entila�elntiff0eiln..� r^a;tioln m0rt a IflfnunlilrinudlfMO" Inspection Program IpYes 1p y those d above in a�„II.ulh�sea-lCioln IIR.R•R..2.a. NCS000247_Winston Salem 2022 MS4 Self -Audit Page 32 of 39 Program to Monitor and Evaluate Stormwater Discharges to Municipal Systems (Evaluated during self -audit) Comments When merging RCRA, TRI, active DEQ stormwater permits, and the City's IDDE lists together, the Stormwater Inspector observes the frequency of each facility's name. The increased frequency of each repeating name shows the scope and magnitude of industrial operations, thus, warranting the heightened priority of the facility to be inspected. As a result, these types of facilities are moved into the top tier for inspection services. After this tiered initial sorting, the Stormwater Inspector uses additional priority -ranking criteria to finalize the industrial inspection list — this criterion includes historical spills, located within a TMDL watershed, analytical monitoring data, and major staff or facility changes. The Stormwater Inspector's goal is to inspect every general or individually stormwater permitted facility once during its permit cycle (every five years) Please note: The Stormwater Inspector performs inspection activities on RCRA or TRI facilities ONLY if the facility has an active general or individual stormwater permit or experiences an illicit discharge. This is due to inspection and entry authority reasons; general (and individual) stormwater permits grant access to local stormwater programs under Section 1-13, if connected to the MS4 as well as Chapter 75, the City of Winston-Salem's Illicit Discharge Ordinance. Otherwise, local, state, and federal regulations do not provide legal authority for entry and inspection by Stormwater staff into RCRA and TRI facilities. The Stormwater Division's Industrial Facilities List (of past inspected facilities from FY 2020-2022 and FY 2022-2023 proposed facilities) is located : G:\Industrial Inspection & Municipal Good housekeeping\Indust_Inspect\City Industrial Information. The Stormwater Division has created and implemented industrial inspection procedures SOPS - these SOPs are located: G:\Industrial Inspection & Municipal Good housekeeping\lndust_lnspect\City Industrial Information\Industrial SOP\Current The permittee evaluated control measures implemented at permitted hazardous Industrial Facility waste treatment, disposal, and recovery facilities, industrial facilities that are Evaluation subject to Section 313 of Title III of the Superfund Amendments and Yes " Reauthorization Act of 1986 (SARA). For the purpose of this permit the Permittee is authorized to inspect the permitted hazardous waste treatment disposal, and recovery facilities as an authorized representative of the Director. The permittee evaluated control measures implemented at industrial facilities identified with an industrial activity permitted to discharge storm water to the Yes permittee's MS4. For the purposes of this permit industrial activities shall mean all permitted industrial activities as defined in 40 CFR 122.26. For permitted industrial facilities, the permittee established procedures for YAS reporting deficiencies and non-compliance to the permitting agency. Where compliance with an existing industrial stormwater permit does not result in adequate control of pollutants to the MS4, the permittee recommends and Yes documents the need for permit modifications or additions to the permit issuing authority. The permittee evaluated control measures implemented at industrial facilities Yes identified as an illicit discharge under the IDDE Program. NCS000247—Winston Salem 2022 MS4 Self -Audit Page 33 of 39 Progiraim to Monitor and Evaluate Storm ter Discharges to MuinicrqpaI Systems (Evaluate during self -audit) ��rrnents I'lhie Storrnnnrater mvision evaluates all impllemented stonrnnwater corntrol measures (SCMs) or Vest management practices (BNIIF'.$) at Tlti, IRCRA, and actiive state-permAted facilities, which have been issued a general or individual storrnnwater permit (this includes all fParrihtips that h m rc xnpripnrrpd an illirit disrhargpl. ff Sf`Ms or RMPs ;arp dppmpd onadequuato or have Balled, the Stormwater lnslpector denotes all irep,uiired action items that the facilirly will need to correct to Ibecorne compliant with their stormwater permit.. The Stc Fmwa'fer lnspector determines the specified due date that the 'facility must'irriplernent all corrective measures, base on the amount and severity of acflon fterxis that are required. The Storrnnnnrater Inspector and/or the Stonrnwater Operations Supervisor creates, establishes, updates, and maunta'ins alll procedures for reporting deficiencies and non -compliiarice to the Winston Salern Regional Office of IOILQ, which are listed in our lndu.',strial lnspecrtion SOP Nllanual. This rniwam.0 vfas updated on April 18, 2022 and located at. G°\Irndu,ustrial luaspec,flon & Muanie°ipM Ooodlhouisekeelping\lndust„_linispect\Cilty Industrial Ilnforrnation\lridustrW SOU'\Current, M additioru, the Storrannrurateir Mv'is'iorn notifies IDEA WSIRO of insufficient measures within exMing state storrnnwater perrnfts via the City's ln.spection Form. When a facility (comrnercW or Mclustriial) releases an illicit discharge, the Storniwater, lnspector performs a conrnprelhnernsive inspection to permanently elirni hate the source or connection of said disclhaire. 'The Stor-un ater lnspector incorporates all inspection documentation Into the irndus idal iinspecflon folder for future refererice, as anrellll as into the master industrial spreadsheet as a ciriteriorn for assessment pidoritiizatiion. NCS000247_Winston Salem 2022 MS4 Self -Audit Page 34 of 39 Comments The Stormwater Operations Supervisor maintains the City's Water Quality Assessment and Monitoring Plan, which was last modified on April 13, 2022. Stormwater staff performs water quality monitoring. The Plan resides at: G:\Techn_Projects_Files\WQAM Plan_ Stormwater staff implement the Water Quality Assessment and Monitoring Plan — the sampling plan schedule is in Section 9: Sam„p„(ink Monitorin.Yearly..Schedu.l.e,,. Stormwater staff has summarized the sampling regime contained within the Water Quality Assessment and Monitoring Sampling Plan and is stored at the following location: G:\Techn_Projects_Files\WQAM Plan_\Sampling Summaries. Fixed Interval Samr)lin Fixed Interval sampling is performed quarterly, in all weather conditions, at 13 sites across Winston-Salem's municipal boundaries. Fixed interval will be carried out on the third week of the first month at the beginning of each quarter. The sites are divided between two receiving streams: Salem Creek and Muddy Creek — both are TMDL watersheds. There are six sites on Salem Creek and seven sites on Muddy Creek. The remaining seven sites are in Mill, Silas, Little, Fiddlers, and Lower South Fork Watersheds. Twenty-four sampling parameters are collected at each site. Most water quality samples are analyzed in a North Carolina certified laboratory, while several parameters are analyzed using an instantaneous water quality meter. There are nineteen parameters that are analyzed in a certified laboratory, which includes Biological Oxygen Demand, Total Cadmium, Total Chromium, Dissolved and Total Copper, Total Lead, Total Nickel, Dissolved and Total Zinc, Total Dissolved Solids (TDS), Nitrate, Nitrite, Ammonia, Total Kjeldahl Nitrogen, Dissolved and Total Phosphorous, Total Suspend Solids (TSS), Turbidity (NTU), and Fecal Coliforms. Field parameters are gathered primarily by a YSI Quatro Pro Plus. This device is used to gather the following five parameters: Temperature (C), Dissolved Oxygen (%), Dissolved Oxygen, Conductivity(µS/L), and pH. As events arise or equipment fails, all parameters may be substituted from YSI meters and Pocket Colorimeters and be collected instead by bottle and taken to Pace Analytical for lab analysis. Total Maximum DaiIy, Load j_DL)_ Currently, the City of Winston-Salem has two TMDL watersheds. These two watersheds are Salem Creek and Muddy Creek Watersheds. TMDL sampling is conducted in five of these watersheds for a total of 22 sites: Upper Salem Creek (six sites), Peters Creek (five sites), Middle Salem Creek (two sites), Lower Salem Creek (two sites), and Brushy Fork (seven sites). Sampling is dependent upon ambient weather conditions, so no fixed schedule exists for sampling within the quarter to achieve desired levels of sampling. All sampling is done in either dry or wet weather conditions, with wet weather being defined as a rain event of greater than 0.10" in the last 72 hours and anything less being defined as dry weather. Ten parameters are collected at each site. Some are lab analyzed while most are field gathered. The four lab analyzed parameters are Fecal Coliforms, Total Suspended Solids (TSS), Ammonia, and Nitrate. These samples are collected in sample bottles and placed on ice before being taken to Pace Analytical Laboratories. Field parameters are gathered primarily by a YSI Quatro Pro Plus. This device is used to gather the following six parameters: Temperature (C), Dissolved Oxygen (%), Dissolved Oxygen, Conductivity(µS/L), Total Dissolved Solids (TDS), and pH. As events arise or equipment fails, all parameters may be substituted from YSI meters and Pocket Colorimeters. Water .. ring D ua...i.t:...M.4n.!.tq....... Water Quality Monitoring (WQM) sampling is performed quarterly at 18 sites in both dry and wet weather conditions across the Winston-Salem municipal boundaries. Because WQM sampling is weather dependent, there is no set time frame for this sampling during the quarter. Fifty percent of WQM samples are expected to be collected during wet weather conditions, which is defined as occurring within 72 hours of a rainfall event amounting to one -tenth of an inch of precipitation or more. Fifty percent of samples are also expected to be collected during dry weather conditions, which is defined as occurring at least 72 hours after a rain event of NCS000247_Winston Salem 2022 MS4 Self -Audit Page 35 of 39 one terntlh of an finch or nnore or wlnien there has been less than one tenth of Ipreo"ipi-°atlon.. "rhe nu..urxnber of samples oWa:rNecLed In dr.y and wet weather ooinditlion.s is reversed for the following quarter of the year to balance the appropidate arnount of data for all silken,. The, 18 sites used for WCI.IM sampling represent data for several different wa:aters»hears within Winston Salernn innuniioilpall L)ourndariies. The ll:aeroentage of sines representing each watershed frorn the total 18 sines are as followers 0 Fiplvpn nPrront oafthe garnlplonc! 0tPs N dmanrpr Smth Fork at Peters Creek Pkwaav and Lower South Fork at (Ad Lr*arunlMta:>n Road) are collected within the Lower South l:ork Muddy Creek: Watershed. D Eleven Percent of the s<arnapHnng sites (FidMers Creek at Teague Road and Fiddler's Creek at Mfflard Road) are collc: cted wwltlhiin the South l:'ork Muddy Creek Watershed. 0 Eleven 1perf;ernt of the sampling sites QMonarcas Creek at l... inin Station Road and M 111 Creek at Reynolda load) are colllected within the Lowey Mlll Creek Watershed. 0 23 taenrernt of the sainnllaliing siit:es (WIll Creek, at Patterson Avenue, Mill Creek at Shattalon Drive, Leak l:::ork at 11ines Bark Soccer Fiek.J, and Le"k N:ork at Motor Road) are: collected °,,viitlhln the KMe Mlll Creek Watershecll.. a 20 (percent of the saiI sines (Siilws, Creek at Il oyalll Drive, Silas Creek at Reynolda V llage, Silas Creek, at yorkshiire road, Little Creek at Old Vineyard (Road„ and Silas Creek at Country Road) are collected within tine Silas Creek Watershed. 0 Five percent of the samilpfing sites (Muddy Creek at Country Club (road) are collected Mthfin the (Lower Muddy Creek Watershed. * Il::inre (percent of the sarnlpl°ung sites (Fleters Crraelk at Hanes Park) are eolller ted wusiitNin the Deters Creek Watershed, * Elie Percent of the samlphing sates (Muddy Creek at ReyniolIda load) are collected within the L)plper (Muddy Creek Watersllned. IDuring W IM sairnlpliing, semen 1po'llutant parameters are co He:ted and irnea.suired by utiil'iiziing either a YSl WaLev QuAty Meterfur temperature, pH, dissolved oxygen, total dli.ssollnaed solids„ and coiIty or by grabbing a water .sarnnlplle that is taken un for laboratory anallys'iis for nitrate and arnmonla. Water Quality .....�� _ermntu- �,, �...., _ u,,,„ ,,�,,� � .. �,,,�.„,�ff, , „ Ills Il 2u�� tlhe q ee irnuanntanned and irnlpllernnerited tll°ue Water Quahty Asses prroent and YesMa.anitorung Plain sullarnniitted to DEIIM LR. M raltoirfi ug The Mviision waived the requirement to 1In a Water Quality Assessment and Munnitaar'iing Plan, ` carers is fll e C'uty of Wiirnston Salem has maintained and irnnlpllernented its Water Qu«all'irty Assessment and Moniitoring l:11an, wMch was subrrniitted to Jeanette Powell on IMay 2.4, 2021., NCS000247 Winston Salem 2022 MS4 Self -Audit Page 36 of 39 Site Visit Evaluation: Municipal Facility No. 1(Evaluated during onsite audit) Facility Name: I Date and Time of Site Visit: Transit Authority June 14, 2022 ..... . ........ . Facility Address: Facility Type (Vehicle Maintenance, Landscaping, etc.). 1060 North Trade Street Vehicle Maintenance with Fueling Services Winston Salem, NC 27101 ........ _ .._......... ................ __.__ __ ............... _ .... .... ... .. _ _.,,.--------- Name of MS4 inspector(s) evaluated: Most Recent MS4 Inspection (List date and name of inspector): LaDonta Jamal Clark Date: April 26, 2021 Inspector: Brandon Wise .............................. ........ ...... A..........., Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit: �...... ......... ............. _ Name Title John Ashford Maintenance and General Manger Observations Facility Documentation/Training -- - ........................................ ----............. SWPPP Does the facility have a Stormwater Pollution Prevention Plan ( ) or similar document? Is it facility -specific? Yes. Transit Authority's NPDES Industrial Stormwater Permit No. NCG080023. It has a site specific SWPP. ...................... ..--------- ----- --- ---------------- ___ .,.. ...... What type of stormwater training do facility employees receive? How often? Yes. Employees conduct walk through of the facility, watch training video (with all different stormwater categories) at least once/year and sign off that training has been completed. Inspector Training/Knowledge .� Tw� .�� er � �.��,u� n.,�,� u,�sr,�� ri�,n� rir,,,, ,,.,.. ..... ... . ,,,,�. ... .,.. What type of stormwater training do facility employees receive? How often? During FY 2021-2022, the Senior Community Educator, Stormwater Operations Analyst, and the City's Marketing and Communications Department created a new training video that highlights proper pollution prevention & municipal good housekeeping practices for key City operations to eliminate pollutant exposure to the environment. A main topic in this video pertains to best management practices for vehicle washing, maintenance, and fueling activities. From November 2021 to March 2022, Transit Authority team members viewed and passed a confirmation test of Stormwater's new PP & MGH and IDDE training video, including all three site supervisors. This educational video is viewed by all City employees on an annual frequency for maximum memory retention. Other than this video training, Transit Authority has not performed site -specific training. What type of stormwater training does the MS4 inspector receive? How yp g p often? Mr. Clark was promoted to the position of Stormwater Inspector in 2012. Mr. Clark was trained in inspection techniques and best professional knowledge by Mr. Andy Allen, the original Stormwater Inspector who oversaw and managed the city's Stormwater Inspection Program from 2004-2007. Mr. Allen created the City's Stormwater Inspection Program in conjunction with NCDENR WSRO staff —specifically, DWR Specialist Rose Pruitt. Mr. Allen's former job position was with the City's Industrial Waste Control Chemist, who inspected industrial facilities for compliance with wastewater regulations. In 2006 when the Stormwater Division was audited by an EPA Contractor, SAIC, the inspection process was refined, as recommended by Mr. Jerry Whitman (SAIC Contractor). Since 2006, the City's Inspection Program has been amended, as needed, to remain compliant. Mr. Allen trained Mr. Clark over the course of a year for a joint inspection regimen of 12 private and public facilities. COVID-19 severely hampered staffs ability to attend in -person training; however, Mr. Allen and Mr. Clark attended almost all Wow Wednesday Stormwater Training Sessions presented by DWR during 2021. In addition, both MS4 Inspectors reviewed and passed the confirmation test from Stormwater's PP and MGH training video. This video will be required to be an annual training event Did the M54 inspector appear knowledgeable about Permit requirements for pollution prevention and good ?....... P PP..,,.. g.r..... .. q............................. P d good housekeeping. Yes. Mr. Clark is well -versed regarding general stormwater permit requirements for PP and MGH practices. During the inspection, Mr. Clark had a hard copy of the NCGO8000 general stormwater permit requirements by comparing onsite conditions to written NCS000247_Winston Salem 2022 MS4 Self -Audit Page 37 of 39 Site Visit Illution: Municipai Facillity No. I (111:vaWated durlingit udiiit Svoi:bl) contents. Missing or deficient luerrNt requilreirnents welre denoted and histed as a Required Action to be completed by the Facility„ Part 5 of the inspection form. IDid the IINPiiS4 irnspeo'p:olr appear knowledgeable about stolrrrnvwater pollution parievention and good houselkeepiing? . N Yes, [Or. Gawk is very knovwned a�d!911:k1 concerning bt.n 7, man' , � ° . k' b z � � a�,errra:;'r�u't� p�r��aa;tu�:a.� nauu d•°u aura otri�.mlrx o(p�il�unre.uns. Mir. �, nanua oa; eaa�n4.3n�lie �. thorough and seeks lalrolbllelrnnatic areas of Ipoteritiiall pollutant exposure to the open elnvillrolnrnielnt. Mr. Clark exarrlllines ardoading/Ioading, waste dilslposal, product storage, autornotilve 1plrocess (e.g.. fueling, storage of wrecked vehielles, etas,.) outdoor processes, alnid dust or pualrtiicuiate geineraflng sources to evaluate the risk exposure tc: rainwater. If ril.slk is idelntif'ied, Mr. Clark provides vwr'llttien doculrnelntat on for requiring corrective IrneaslulreS (aka MI s) to eli nWllnate exposure to stor•rnwatelr. Illn addlltllon, Mir. Clark colnfirinns tlluast indoor fixilAi res (e.g., oill and water separators, collection floor dlra'ilns, eta) are colnlne tee Vlhie salniltalry sewer. n ..............gym, �2,r�. prusPectiorn Procedures ,.,,.w.w_ — — — — oes the MS4 inspector's process iirOude the use of a cineckillist or otpner standardized form? Yes, the Storlrnwwatelr Division ruses a hylblrid Irrnuunicajpall/'urndustlriiaal good uselkeelpiirn , iiru.spnect'ioln for-irn for evalln.uratilrng (private and 1pul:alia:, faa~ htiies olr olperat'iolns. 1 hiis form was Irevilsed iln October 2020 to reflect elrier-al 1perimiit a:ondltlorns as welli as cireafling a unirporm evapuatiion tooll that applies to all facillilties/oPelratiions. Please reference item 2 , which is tune City"s llnspeacfloln Form template that Stormw�ater staff ases'to inspect faciilliltur.s for deterlrnllninp colrnpuharna ........ __ __...-. ......— -- ,..............� "," - ---.-. ....... _ .......... Does tine MS4 ilnspaector•xs process include talking palhotos? Yes„ Mir. Clark attached five photographs hs to his inspection forrnn, wtvlhiici-ii wvelre talken diarin the'inspuea;hon. The 1p1'notos I'nIghllii ht sources of polli utalrllt exposure, exalrmllpa es of deficient Irnleasllures„ etc. While Ir61nfordint IrecitAred actions that'rransit Auul:Iholrilty Irrnuust lrnlpullelrnnelnt to eIliiraiinate pollutant exposure. ....... ....---------..-.-- Doesthe IAS4 insp ector's processnrudcllude review�arlrn m the facility's SWIPPP (or silrxniillalr document)? s per y".. p.nectJolrn S IP" Manllual, the Stolrlrnvwateir Inspector (requests a u;ulrrelrit "s'OI PIRFI firom the Yes. A� er Item •�fi::�0„ 4:11ne l::ilt s Industrial V'Ins, facility PRIOR -to the site finspect'ion. IMr. Clark.Ihad a Transit Authority SWPIPP current copy with Ihilm during 1Jhe 'iln.spaecdon as a technical resource. _ _ ........ __ ....................... .................................. ............... ........ . ,,,, ........... . . — Does the MS4 nrispieetor's process nrncllude walking tine entire facipity and inspecting all points of discharge? Yes, IIMIr, t;':Valrlk uwal'Iked the eritlre faa:illilty area and inspected ally storunnwvatelr diisolhnar e ouutfalllls for any obvious silp ins of pollutants. ---- ®® ,. ,,, ............... ...... ----............................................ ................. ..... ... , u Did the MS4 inspector riniss, any obvious arenas of concern? !If so, expIandrn. No m ... .. ........ ®, .... ..... ®...... .... _ ......... Does thne IVIS4 inspector's process 'irnr.11udle p ireselntioriig the ilnspneetiolrn findings to 11,he facility anolrntaet? Yes, Mir. CValrlk provided Mr. Ashford an Oea1tlrolnic copy of the June 1.4, 2022 inspection form of Tralnsrit Authority. TINs ervnailll was provided onJune 21, 2022. At the elnd of the inspection, Mr. CJalrlk verbally communicated ally Required Actions that Fleet Services ,Ian nee,�d to min vnpc tca $ r oir t hr% urrutj nll iianc rnr rflo n rJ su i ..._. I nspaectiiorn Results Did the facility inspection (result, in alny corrective actions to be implemented? Illf so, for --_-- w e' Final! issue�s)? Yes arc r, Actionsto2rrncorreMc corrective inaeasures � � to Ilse imperrnelnted for achleviing paa:u'Irlrnilt corrnlphalnce. Please reference Pnawrt 5, ek p y y, of Item #41. for spaea,•'ifie siites issues. ---_................................ ...... ___ -.................................................. ........... .. . .... . ... .... . . ................. if compliance colrlrective actions were identified„ what t it nelfine for colrlrectpoln/follPovwr-upi was provided? iMr.. Clark provided a due date of Selptelrrrilhaer 21, 2022 for Mi corrective measures W iae eonrnlpleted. The due date was a:aantiiairned in the unsN.na:c an t"onrnu cover letter, wvri... e Irnrl fnir'�,t ir`nr nir'p'mnr rwar-, s,,;,x of irrn•�f'e!r(.:.n e I�7V Aril ay,j ;it A.Lntlh iLiri1t TGIr'0,®ilrud graa'ffi TIpn^'P�. IIInn G`''p'Irealrmn 9tFrnirn iiirn, of two Irnointlhs was agreed up»oln by Tralnsilt Autlhoidity staff and IMir. (1alrk. lNoll:es/Cornn'ielrnts/IPteeolrnn Innelr-idatihons NCS000247 Winston Salem 2022 MS4 Self -Audit Page 38 of 39 Site Visit Evaluation: Municipal facility No. I (Evaluated during onsite audit) NCS000247_Winston Salem 2022 MS4 Self -Audit Page 39 of 39