NCS000484_Salisbury MS4 AUDIT REPORT_20200221

MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM AUDIT REPORT

NPDES PERMIT NO. NCS000484
SALISBURY, NORTH CAROLINA

303 W. Franklin Street
Salisbury, NC 28144

Audit Date: October 14, 2019

Report Date: January 6, 2020

North Carolina Department of Environmental Quality
Division of Energy, Mineral & Land Resources Stormwater Program
512 N. Salisbury Street, 9th floor
1612 Mail Service Center
Raleigh, NC 27699-1612

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NCS000484_Salisbury MS4 Audit_20200106 ii
TABLE OF CONTENTS
Audit Details .................................................................................................................................................. 1
Permittee Information .................................................................................................................................. 2
List of Supporting Documents ....................................................................................................................... 3
Program Implementation, Documentation & Assessment ........................................................................... 4
Public Education and Outreach ..................................................................................................................... 8
Public Involvement and Participation ......................................................................................................... 11
Post-Construction Site Runoff Controls ...................................................................................................... 13
Pollution Prevention and Good Housekeeping for Municipal Operations ................................................. 18
Site Visit Evaluation: Municipal Facility No. 1 ............................................................................................. 22
Site Visit Evaluation: Municipal Facility No. 2 ............................................................................................. 24
Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1 ............................................ 26
Appendix A: Supporting Documents
Appendix B: Photograph Log

DISCLAIMER
This audit consists of an evaluation of program compliance with the issued permit and implementation of
the approved Stormwater Management Plan. This audit report does not include a review of all program
components, and program deficiencies in addition to those noted may be present. The permittee is
required to assess program progress and permit compliance, and to implement the approved Stormwater
Management Plan in accordance with the issued permit.

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NCS000484_Salisbury MS4 Audit_20200106 Page 1 of 31

Audit Details
Audit ID Number:
NCS000484_Salisbury MS4 Audit_20200106
Audit Date(s):
October 14, 2019
Minimum Control Measures Evaluated:
☒ Program Implementation, Documentation & Assessment
☒ Public Education & Outreach
☒ Public Involvement & Participation
☐ Illicit Discharge Detection & Elimination
☐ Construction Site Runoff Controls – No delegated Sediment and Erosion Control Program
☐ Construction Site Runoff Controls – Delegated Sediment and Erosion Control Program
☒ Post-Construction Site Runoff Controls
☒ Pollution Prevention and Good Housekeeping for Municipal Operations
☐ Total Maximum Daily Loads (TMDLs)

Field Site Visits:
☒ Municipal Facilities. Number visited: 2
☐ MS4 Outfalls. Number visited: Choose an item.
☐ Construction Sites. Number visited: Choose an item.
☒ Post-Construction Stormwater Runoff Controls. Number visited: 1
☐ Other: ________________________________. Number visited: Choose an item.
☐ Other: ________________________________. Number visited: Choose an item.

Inspector(s) Conducting Audit
Name, Title Organization
Brandon Wise, Stormwater Specialist NCDEQ – Winston-Salem Regional Office
Chris Graybeal, Assistant Regional Engineer NCDEQ – Mooresville Regional Office
Kenny Llywelyn, Environmental Specialist II NCDEQ – Mooresville Regional Office

Audit Report Author:

Signature__________________________________________
Date:
January 30, 2020
Audit Report Author:

Signature__________________________________________
Date

NCS000484_Salisbury MS4 Audit_20200106 Page 2 of 31

Permittee Information
MS4 Permittee Name:
City of Salisbury
Permit Effective Date:
02/20/2017
Permit Expiration Date:
02/19/2022
Mailing Address:
PO Box 479, Salisbury, NC 28145
Date of Last MS4 Inspection/Audit:
02/20/2008
Co-permittee(s), if applicable:
N/A
Permit Owner of Record:
Lane Bailey, City Manager
Primary MS4 Representatives Participating in Audit
Name, Title Organization
Chris Tester, Stormwater Project Manager City of Salisbury
Michael Hanna, Stormwater Technician II City of Salisbury

MS4 Receiving Waters
Waterbody Classification Impairments
Grants Creek Class “C” of the Yadkin-PeeDee River Basin
Town Creek Class “C” of the Yadkin-PeeDee River Basin Benthos, Fish Community
Crane Creek Class “C” of the Yadkin-PeeDee River Basin
Jump and Run Branch Class “C” of the Yadkin-PeeDee River Basin
Draft Branch Class “C” of the Yadkin-PeeDee River Basin

NCS000484_Salisbury MS4 Audit_20200106 Page 3 of 31

List of Supporting Documents
Item
Number Document Title When Provided
(Prior to/During/After)
01 Stormwater Management Plan (Dated 11/2/2018) Prior to
02 Stormwater Management Plan (Dated 10/24/2019) After
03 2016 Annual Report Prior to
04 2019 Annual Report After

05 Organizational Chart Prior to

06 Watershed Map Prior to
07 Inspection Checklist After
08 Rowan County Erosion Agreement Prior to
09 City of Salisbury Stormwater Website Prior to
10 CrystalStream™ Technologies O&M Plan During

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Program Implementation, Documentation & Assessment
Staff Interviewed:
(Name, Title, Role)
Michael Hanna, Stormwater Technician II
Chris Tester, Stormwater Project Manager
Permit Citation Program Requirement Status Supporting
Doc No.
II.A.1
Staffing and
Funding
The permittee maintained adequate funding and staffing to implement and manage
the provisions of the Stormwater Plan and meet all requirements of the permit. Yes 01, 02
The Stormwater Plan identifies a specific position(s) responsible for the overall
coordination, implementation, and revision to the Plan. Yes 01, 02,
05
Responsibilities for all components of the Stormwater Plan are documented and
position(s) assignments provided. Yes 01, 02,
05
The permittee is current on payment of invoiced administering and compliance
monitoring fees (see stormwater e-payments on DEMLR MS4 web page). Yes N/A
Comments (Briefly describe funding mechanism, number of staff, etc.)
Stormwater department is made up of 2 full time employees, 1 general engagement person
Funding comes from stormwater fee from both residential and commercial/industrial properties. Fee is $5 per equivalent
residential unit (ERU) which is approximately 2,500 ft2 of impervious surface.
General budget from past year is approximately 1.8 million for all of stormwater.
II.A.2 Stormwater
Plan
Implementation
and Evaluation
The permittee evaluated the performance and effectiveness of the program
components at least annually. Yes 01, 02
If yes, the permittee used the results of the evaluation to modify the program
components as necessary to accomplish the intent of the Stormwater Program. Yes 01, 02
Did the permitted MS4 discharges cause or contribute to non-attainment of an
applicable water quality standard? No N/A
If yes, did the permittee expand or better tailor its BMPs accordingly to address
the non-attainment?
Not
Applicable N/A
Comments

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Program Implementation, Documentation & Assessment
II.A.3
Keeping the
Stormwater Plan
Up to Date
The permittee kept the Stormwater Plan up to date. Yes 01, 02
The permittee notified DEMLR of any updates to the Stormwater Plan. Yes 02
Comments (Indicate the date of latest Stormwater Plan and describe the nature of any updates, if applicable).
Permittee had kept plan up to date for audit period. After audit an updated version of the draft was sent to NCDEQ.
II.A.4 Availability
of the Stormwater
Plan
The permittee kept an up-to-date version of its Stormwater Plan available to the
Division and the public online.
Not
Applicable 09
The online materials included ordinances, or other regulatory mechanisms, or a list
identifying the ordinances, or other regulatory mechanisms, providing the legal
authority necessary to implement and enforce the requirements of the permit.
Partial 01, 02,
09
Comments (Note what materials are available on line)
Current SWMP is in review, plan is to make it available once it is approved in no longer in draft. Latest NPDES annual report if
available online however NCDEQ was unable to locate any information on ordinances or regulatory mechanisms. Ordinances are
not referenced in the SWMP and should be added to a section of the website.
II.A.3 & II.A.5
Stormwater Plan
Modifications
Did DEMLR require a modification to the Stormwater Plan? Not
Applicable N/A
If yes, did the permittee complete the modifications in accordance with the
established deadline?
Not
Applicable N/A
Comments (Note date of DEMLR notification, modifications required, and date modifications were completed, as applicable)
SWMP still in draft. Will be reviewed post audit.
II.A.6 Sharing
Responsibility Are any control measures implemented by an entity other than the permittee? Yes 08
If yes, is there a written agreement in place? Yes 08
Comments (List the specific control measures implemented by others that do not have adequate written agreements, if
applicable) Construction stormwater is implemented by Rowan County environmental services, which is a delegated erosion and
sediment control program by NCDEQ.
II.A.7
Written
Procedures
The permittee maintained written procedures for implementing the six minimum
control measures. Yes 01, 02
Written procedures identified specific action steps, schedules, resources and
responsibilities for implementing the six minimum measures. Yes 01, 02
Comments (List the specific minimum measures that do not have adequate written procedures, if applicable)
Procedures described in SWMP for implementation and regular goals.

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Program Implementation, Documentation & Assessment
III. A
Program
Documentation
The permittee maintained documentation of all program components including, but
not limited to, inspections, maintenance activities, educational programs,
implementation of BMPs, enforcement actions etc., on file for a period of five years.
No N/A
Comments (List the specific program components that do not have adequate documentation on file and why, if applicable)
Documentation is the area where the municipality was weak during the audit. Inspection documentation was lacking along with
documentation outside of the most recent time period.
III.B
Annual Report
Submittal

The permittee submitted annual reports to the Department within twelve months
from the effective date of the permit (See Section III.B. for the annual reporting
period specific to this MS4).
Yes 03, 04
The permittee submitted subsequent annual reports every twelve months from the
scheduled date of the first annual report submittal. Yes 03, 04
The Annual Reports included appropriate information to accurately describe the progress, status, and results
of the permittee’s Stormwater Plan, including, but not limited the following:
1. A detailed description of the status of implementation of the Stormwater Plan
as a whole. This will include information on development and implementation
of each major component of the Stormwater Plan for the past year and
schedules and plans for the year following each report.
No 03
2. An adequate description and justification of any proposed changes to the
Stormwater Plan. This will include descriptions and supporting information for
the proposed changes and how these changes will impact the Stormwater
Plan (results, effectiveness, implementation schedule, etc.).
Not
Applicable N/A
3. Documentation of any necessary changes to programs or practices for
assessment of management measures implemented through the Stormwater
Plan.
Not
Applicable N/A
4. A summary of data accumulated as part of the Stormwater Plan throughout
the year along with an assessment of what the data indicates in light of the
Stormwater Plan.
Partial 03
5. An assessment of compliance with the permit, information on the
establishment of appropriate legal authorities, inspections, and enforcement
actions.
No 03
Comments (Note dates that annual reports cover under current permit and generally describe report deficiencies, if any)
Annual reports lacked a large amount of detail. It is recommended to use the Stormwater Management Program Assessment
(SWMPA) for annual reports. While these reports were put together well and would be useful for the public to read and gain
information the required details were not present.
IV.B
Annual Reporting The Annual Reports document the following:
1. A summary of past year activities, including where applicable, specific
quantities achieved and summaries of enforcement actions. Partial 03
2. A description of the effectiveness of each program component. Partial 03
3. Planned activities and changes for the next reporting period, for each
program component or activity. No 03

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Program Implementation, Documentation & Assessment
4. Fiscal analysis. Partial 03
Comments (Note dates that annual reports cover under current permit and generally describe report deficiencies, if any)
Review of past reports show that they are lacking in technical information required by NCDEQ and the permit. Annual reports
submitted by the City of Salisbury are good reports for the general public but do lack in large amounts of detail.

Additional
Comments:
Annual reports were being sent in on a regular basis, however the reports were a general overview of the
program and not detailed as required by the permit. The SWMPA should be used as it is the preferred
reporting option. Future reports will be required to be more detailed and cover all requirements for the past
year of coverage as detailed in the permit and in this audit.

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Public Education and Outreach
Staff Interviewed:
(Name, Title, Role)
Michael Hanna, Stormwater Technician II
Chris Tester, Stormwater Project Manager
Permit Citation Program Requirement Status Supporting
Doc No.
II.B.2.a
Goals and
Objectives
The permittee defined goals and objectives of the Local Public Education and
Outreach Program based on community wide issues. Yes 01, 02
Comments (Generally describe process for establishing goals/objectives)
Goals of the public education is to reach out to all schools and visit students who are currently in the process of learning about
areas that relate to the goals of the stormwater program. Other goals include visiting the Cheerwine festival annually and to start a
new creek clean-up. Goals are well defined in Table 13 of SWMP.

II.B.2.b
Target Pollutants
The permittee maintained a description of the target pollutants and/or stressors and
likely sources. Yes 01, 02
Comments (List target pollutants, note any that are missing or not appropriate)
Target Pollutants listed: Litter, Sediment, Nitrates, Phosphates, Fecal, Illicit Discharges, Improper Disposal, Illegal Dumping
It is also recommended that although illegal dumping may include this a potential source not directly mentioned should be
household chemicals or oil products, from activities such as mechanical maintenance. Pollutants are described in Table 12 of
SWMP.

II.B.2.c
Target Audiences
The permittee identified, assessed annually and updated the description of the target
audiences likely to have significant storm water impacts and why they were selected. Partial 01, 02
Comments (Describe any changes made, if applicable)
City of Salisbury informed NCDEQ during the audit that their current target is litter due to it being the most likely impact to
stormwater in the city. Recently the Adopt-A-Street program was folded into the stormwater group.
While it was obvious during the audit that pollutants were being reviewed and some had been added recently it should be noted
that documentation is needed to ensure that this is being done annually as it is described in the SWMP.

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Public Education and Outreach
II.B.2.d Residential
and Industrial/
Commercial Issues
The permittee described issues, such as pollutants, the likely sources of those
pollutants, potential impacts, and the physical attributes of stormwater runoff in
their education/outreach program.
Yes 01, 02
Comments (Generally describe the residential/industrial/commercial issues addressed)
As stated previously the main concern and target at the moment is litter. Distributed items and programs of the public education
currently is litter control, whether it is through school education or stream/street clean-ups. It is also recommended to target the
household chemicals/oil products during events targeted at an older crowd as well.

II.B.2.e
Informational
Web Site
The permittee promoted and maintained an internet web site designed to convey the
program’s message. Yes 09
Comments (list web page address and general contents, or attach screen shot of landing page)
https://salisburync.gov/Government/Public-Services/Stormwater
Page has a very good general description of what stormwater is, why it is important, and the fees expected for either residential or
commercial facilities.
The City of Salisbury also maintains a Facebook page where details from all departments in the city can be found for residents.

II.B.2.f
Public Education
Materials
The permittee distributed stormwater educational material to appropriate target
groups. Yes 01, 02,
03
Comments (List distributed materials and quantity, message, distribution mechanism, target audience for each if not included in
program documentation/annual reporting)
The City of Salisbury distributes multiple different types of materials to different type of citizens. The majority of children and
younger citizens receive coloring books with information about stormwater and how to keep it clean along with interactive events
aimed at younger citizens. Older citizens receive pamphlets, flyers, and presentations with more information about different
detailed stormwater issues. NCDEQ does recommend distributing more specific flyers to businesses that may have potential
pollutants (restaurants with grease traps, commercial car washes, etc.)

II.B.2.g
Hotline/Help Line The permittee promoted and maintained a stormwater hotline/helpline for the
purpose of public education and outreach. Yes 09
Comments (Note hotline contact information and method(s) for advertising it)
[phone] Michael’s Number (Also listed as stormwater services number)
All stormwater calls are received in Michael’s office along with both Michael and Chris’ email and phone number available online.
The City of Salisbury customer service workers are also trained in stormwater so they can distribute calls to the correct group or
individuals.

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Public Education and Outreach
II.B.2.h
Public Education
and Outreach
Program

The permittee’s outreach program, including those elements implemented locally or
through a cooperative agreement, included a combination of approaches designed to
reach the target audiences.
Yes 01, 02
For each media, event or activity, including those elements implemented locally or
through a cooperative agreement the permittee estimated and recorded the extent
of exposure.
Yes 01, 02
Comments (Generally describe approaches, extent of exposure. Note any cooperating entities, agreements and scope of services,
or reference comments in Section II.A.6. above.)
Although construction stormwater is performed by another entity the public education aspect of that section is completed by the
City of Salisbury. The stormwater group does many different events that are put on by the city and also does a neighborhood walk
where they will go to individual neighborhoods giving out information material and speaking with the public. The City of Salisbury
keeps track of documents distributed and the amount of people spoken to at events.

Additional
Comments:
While it is obvious that the public education and outreach section of the permit is being done and the
knowledge is present among the City of Salisbury employees it should be noted that some documentation
issues were present. NCDEQ informed the city to ensure they document everything done that interacts with
their stormwater permit. It should also be evaluated that although the website is well put together and has a
very good general description on it, the potential exist for separate pages with a more detailed approach as
well.

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Public Involvement and Participation
Staff Interviewed:
(Name, Title, Role)
Michael Hanna, Stormwater Technician II
Chris Tester, Stormwater Project Manager
Permit Citation Program Requirement Status Supporting
Doc No.
II.C.2.a Volunteer
Community
Involvement
Program
The permittee included and promoted volunteer opportunities designed to promote
ongoing citizen participation. Partial 03, 04,
09
Comments (Note opportunities promoted and date(s) of volunteer events)
Clean up the city, creek week, adopt-a-street, and the opportunity to place the signs on curb inlets.
While these opportunities exist the metric described for promotion of volunteer opportunities is listed as available via the website,
specifically for opportunities to install curb markers. At the time of this audit this information is not available on the website in any
way that is easily accessed.

II.C.2.b
Mechanism for
Public
Involvement
The permittee provided and promoted a mechanism for public involvement that
provides for input on stormwater issues and the stormwater program. Partial 09
Comments (Note mechanism(s) for input and how promoted)
During the audit it was noted that the best mechanism for public involvement was to via the website to contact the stormwater
group. The website does not have any directly referenced way to contact for public involvement. While phone numbers and e-
mails are provided, general appearances of the website are more oriented towards documenting a complaint or issue. While the
website is good and general, a section for potential volunteer opportunities could be created in order to be clearer and more
obvious way for citizens to get involved.

II.C.2.c
Hotline/Help Line
The permittee promoted and maintained a hotline/helpline for the purpose of public
involvement and participation. Partial 09
Comments (Note hotline contact information and how it is promoted)
[phone] – Michael Hanna’s Number (also listed as stormwater services number)
As stated before, contact information is given but the contact information is not associated with volunteer opportunities upon
review of the website. While this information could be given out during events, the general public looking online is not given a clear
way to get information for involvement with stormwater.

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Public Involvement and Participation
Additional
Comments:
Engagement with the community is present and is being done through attendance at different events,
neighborhood walk, and general presence in the community. The issue in public involvement exists in the
ability to promote involvement online as documented in the SWMP. While volunteer or involvement
opportunities may be promoted on social media when available an option to research these opportunities
should be available at all times via the website. The hotline/contact numbers on the website do not lend
themselves to informational calls given the overall description on the website. A required addition to the
website should be a section on volunteer opportunities or ways to get involved with the stormwater group.

NCS000484_Salisbury MS4 Audit_20200106 Page 13 of 31
Post-Construction Site Runoff Controls
Staff Interviewed:
(Name, Title, Role)
Michael Hanna, Stormwater Technician II
Chris Tester, Stormwater Project Manager
Implementation (check all that apply):
☒ The permittee implements the components of this minimum measure.
☐ The permittee relies upon another entity to implement the components of this minimum measure: name of entity
☐ The permittee implements the following deemed-compliant program(s), which meet NPDES MS4 post-construction
requirements for the areas where implemented and in compliance with the specific program requirements as provided in 15A
NCAC and noted below (Complete Session Law 2006-246 section below):
☐ Water Supply Watershed I (WS-I) – 15A NCAC 2B .0212
☐ Water Supply Watershed II (WS-II) – 15A NCAC 2B .0214
☐ Water Supply Watershed III (WS-III) – 15A NCAC 2B .0215
☐ Water Supply Watershed IV (WS-IV) – 15A NCAC 2B .0216
☐ Freshwater High Quality Waters (HQW) – 15A NCAC 2H .1006
☐ Freshwater Outstanding Resource Waters (ORW) – 15A NCAC 2H .1007
☐ Neuse River Basin Nutrient Sensitive (NSW) Management Strategy – 15A NCAC 2B .0235
☐ Tar-Pamlico River Basin Nutrient Sensitive (NSW) Management Strategy – 15A NCAC 2B .0258
☐ Randleman Lake Water Supply Watershed Nutrient Management Strategy – 15A NCAC 2B .0251
☐ Universal Stormwater Management Program – 15A NCAC 2H .1020

Ordinance(s) (check all that apply):
The permittee utilizes the following ordinances and/or regulatory authority to fulfill post construction minimum measure program
requirements throughout the MS4 permitted area (check all that apply):
☒ DEQ model ordinance
☐ MS4 designed post-construction practices that meet or exceed 15A NCAC 02H .1000.
☐ DEQ approved comprehensive watershed plan
☐ DEQ approved ordinance for a deemed-compliant Program (see list above)

Instructions:
For MS4s not implementing a S.L. 2006-246 deemed-compliant program, complete only the Permit Citation section below.
For MS4s implementing a S.L. 2006-246 deemed-compliant program, complete the Session Law 2006-246 section below. If the MS4
does not implement a deemed-compliant program throughout the entire MS4 permitted area, then complete the Permit Citation
section below for the permitted area(s) not covered under the S.L. 2006-246 deemed-compliant program.

NCS000484_Salisbury MS4 Audit_20200106 Page 14 of 31
Post-Construction Site Runoff Controls
Session Law 2006-
246 Program Requirement Status Supporting
Doc No.
Deemed-Compliant
Program(s)
The permittee implements deemed-compliant Program requirements in
accordance with the applicable 15A NCAC rules. Yes 01, 02
The permittee implements deemed-compliant Program requirements throughout
the entire MS4 area (If not, also complete the Permit Citation section below.) Yes 01, 02
The permittee applies deemed-compliant Program requirements to all federal,
state and local government projects within the permitted MS4 area who do not
have their own NPDES stormwater permit.
Yes 01, 02
The permittee included deemed-compliant Program reporting in their MS4 Annual
Reports. No 03
The permittee included deemed-compliant Program implementation in their
Stormwater Management Plan. Yes 01, 02
Comments
Lack of reporting in annual reports discussed in earlier section of audit. Program has well implemented post-construction
requirements.
Permit Citation Program Requirement Status Supporting
Doc No.
II.F.2.a
Legal Authority

The permittee maintained an ordinance or other regulatory mechanism designed
to meet the objectives of the Post-Construction Site Runoff Controls Stormwater
Management Program.
Yes 01, 02
If yes, the ordinance applies throughout the corporate limits of the permittee
(Verify permit coverage area listed in Part I.D of permit and modify
accordingly).
Yes 01, 02
The permittee has the authority to review designs and proposals for new
development and redevelopment to determine whether adequate stormwater
control measures will be installed, implemented, and maintained.
Yes 01, 02
The permittee has the authority to request information such as stormwater plans,
inspection reports, monitoring results, and other information deemed necessary to
evaluate compliance with the Post-Construction Stormwater Management
Program.
Yes 01, 02
The permittee has the authority to enter private property for the purpose of
inspecting at reasonable times any facilities, equipment, practices, or operations
related to stormwater discharges.
Yes 01, 02
Comments (If the permittee relies upon another entity, specifically note the legal authority that allows that entity to implement
the program within the MS4 area)
Permittee covers all permit requirements within city limits themselves.
II.F.2.b
Stormwater Control
Measures (SCMs)

The permittee utilizes strategies which include SCMs appropriate for the MS4. Yes 01, 02
SCMs comply with 15A NCAC 02H .1000. Yes 01, 02

NCS000484_Salisbury MS4 Audit_20200106 Page 15 of 31
Post-Construction Site Runoff Controls
Comments

II.F.2.c
Plan Reviews

The permittee conducted site plan reviews of all new development and
redeveloped sites that disturb greater than or equal to one acre (including sites
that disturb less than one acre that are part of a larger common plan of
development or sale).
Yes 01, 02
If yes, the site plan reviews addressed how the project applicant meets the
performance standards. Yes 01, 02
If yes, the site plan reviews addressed how the project will ensure long-term
maintenance. Yes 01, 02
Comments

II.F.2.d
Inventory of Projects

The permittee maintained an inventory of projects with post-construction
structural stormwater control measures installed and implemented at new
development and redeveloped sites.
Yes 01, 02
The inventory included both public and private sector sites located within the
permittee’s corporate limits that are covered by its post-construction ordinance
requirements.
Yes 01, 02
Comments
Inventory was well put together and had all SCMs in city limits, the single SCM owned by the permittee and all others are private.
II.F.2.e
Deed Restrictions
and Protective
Covenants
The permittee provided mechanisms such as recorded deed restrictions and
protective covenants that ensure development activities will maintain the project
consistent with approved plans.
Yes 01, 02
Comments

II.F.2.f
Mechanism to
Require Long-term
Operation and
Maintenance

The permittee implemented or required an operation and maintenance plan for
the long-term operation of the SCMs required by the program. Yes 01, 02
The operation and maintenance plan required the owner of each SCM to perform
and maintain a record of annual inspections of each SCM. Yes 01, 02
Annual inspection of permitted structural SCMs are required to be performed by a
qualified professional. Yes 01, 02
Comments
O&M plan required is done using a standard template. All designed SCMs have to be done by landscape architect or engineer.
Inspections may be completed by SCM inspector as well.

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Post-Construction Site Runoff Controls
II.F.2.g
Inspections of
Structural
Stormwater Control
Measures

The permittee conducted and documented inspections of each project site covered
under performance standards, at least one time during the permit term Yes 01, 02
Before issuing a certificate of occupancy or temporary certificate of occupancy, the
permittee conducted a post-construction inspection to verify that the permittee’s
performance standards have been met or a bond is in place to guarantee
completion
Yes 01, 02
The permittee developed and implemented a written inspection program for SCMs
installed pursuant to the post-construction program Yes 01, 02
The permittee documented and maintained records of inspections. Yes N/A
The permittee documented and maintained records of enforcement actions. Yes N/A
Comments
Warning letters have been sent but no enforcement actions have been taken.
II.F.2.h
Educational
Materials and
Training for
Developers

The permittee made available through paper or electronic means, ordinances,
post-construction requirements, design standards checklists, and other materials
appropriate for developers.
Note: New materials may be developed by the permittee, or the permittee may use
materials adopted from other programs and adapted to the permittee’s new
development and redevelopment program.
Yes 01, 02
Comments (If the permittee has adopted materials from other programs, indicate here which materials they are using)
Materials for developers are made available during design phase.
II.F.2.i Enforcement
The permittee tracked the issuance of notices of violation and enforcement
actions. Yes N/A
If yes, the tracking mechanism included the ability to identify chronic violators
for initiation of actions to reduce noncompliance. Yes N/A
Comments
Tracking done through City View program.
II.F.3.b
New Development The permittee fully complies with post construction program requirements on its
own publicly funded construction projects. Yes N/A
Comments
Post construction requirements coming into play on new fire stations.

NCS000484_Salisbury MS4 Audit_20200106 Page 17 of 31
Post-Construction Site Runoff Controls
II.F.3.c
Nutrient Sensitive
Waters
Does the MS4 have areas draining to Nutrient Sensitive Waters (NSW) pursuant to
15A NCAC 02H .0150? No 06
If yes, does the permittee use SCMs that reduce nutrient loading in order to
meet local program requirements.
Not
Applicable N/A
If yes, does the permittee also still incorporate the stormwater controls
required for the project's density level.
Not
Applicable N/A
If yes, does the permittee also require documentation where it is not feasible to
use SCMs that reduce nutrient loading.
Not
Applicable N/A
Comments (Provide reference for local requirements)

II.F.3.d
Design Volume The permittee ensured that the design volumes of SCMs take into account the
runoff at build out from all surfaces draining to the system. Yes N/A
Where “streets” convey stormwater, the permittee designed SCMs to be sized to
treat and control stormwater runoff from all surfaces draining to the SCM including
streets, driveways, and other impervious surfaces.
Yes N/A
Comments
Permittee requires master plan to determine the long term goals of development.
Additional
Comments:
Post-construction program was well implemented and city view program made for very well organized
tracking. No enforcement has occurred although warning letters had been sent.

NCS000484_Salisbury MS4 Audit_20200106 Page 18 of 31

Pollution Prevention and Good Housekeeping for Municipal Operations
Staff Interviewed:
(Name, Title, Role)
Michael Hanna, Stormwater Technician II
Chris Tester, Stormwater Project Manager
Permit Citation Program Requirement Status Supporting
Doc No.
II.G.2.a
Facility Inventory
The permittee maintained a current inventory of facilities and operations owned
and operated by the permittee with the potential for generating polluted
stormwater runoff.
Yes 01, 02
Comments (Note number of facilities, typical inventory data and any facilities that are not inventoried that should be)
5 (soon to be 6) fire stations, maintenance facility (NCG08), town creek wastewater treatment (NCG11), civic center, composting
facility (NCG24), customer service center, water treatment plant.
II.G.2.b
Operation and
Maintenance (O&M)
for Facilities

The permittee maintained and implemented an O&M program for municipally
owned and operated facilities with the potential for generating polluted
stormwater runoff.
Yes 01, 02
If yes, the O&M program specifies the frequency of inspections. No 01, 02
If yes, the O&M program specifies the frequency of routine maintenance
requirements. No 01, 02
If yes, the permittee evaluated the O&M program annually and updated it as
necessary. No 01, 02
Comments
While an O&M program existed it did not dictate the frequency of inspections or frequency of maintenance. These requirements
were noted in the SWMP under BMPs however in the same section it was also stated that a separate O&M program should be kept
for municipal facilities. It should be noted that the City of Salisbury did note that regular inspections were being performed
however no documentation was presented.
II.G.2.c
Spill Response
Procedures
The permittee had written spill response procedures for municipal operations. No 01, 02
Comments
Upon inspection of the customer service center it was discovered that there was a 1,500-gallon generator on-site with no Spill
Prevention Control & Countermeasure (SPCC) for the facility. This is required of any facility with an above ground storage of over
1,320-gallons. The City of Salisbury was informed of this and was in the process of evaluating all facilities to ensure any with an
exceedance of 1,320 gallons would obtain the proper SPCC. While risk management existed for the general city spills the lack of a
SPCC at municipal facilities is not covered under this program.

NCS000484_Salisbury MS4 Audit_20200106 Page 19 of 31
Pollution Prevention and Good Housekeeping for Municipal Operations
II.G.2.d Streets,
Roads, and Public
Parking Lots
Maintenance

The permittee evaluated existing and new BMPs that reduce polluted stormwater
runoff from municipally-owned streets, roads, and public parking lots within its
corporate limits annually.
Yes 01, 02
If yes, the permittee evaluated the effectiveness of existing and new BMPs
based on cost and the estimated quantity of pollutants removed. Yes 01, 02
Comments
City maintained two street sweepers. 71.58 tons of pollutants removed in 169 hours of running this year. Averages 2 months to
cover entire city. City street sweeper known as the unicorn and has become a game for citizens to photograph it and send it to the
city.
II.G.2.f
O&M for Catch
Basins and
Conveyance Systems
The permittee maintained and implemented an O&M program for the stormwater
sewer system including catch basins and conveyance systems that it owns and
maintains.
Yes 01, 02
Comments (Briefly describe O&M program)
A catch basin crew exist consisting of a flat bed and people for cleaning the catch basins. Typically dispatched prior to storm events.
Trash collectors for the city are also trained to spot and document potential issues with catch basins during their routes.
II.G.2.g
Structural
Stormwater Controls
The permittee maintained a current inventory of municipally-owned or operated
structural stormwater controls installed for compliance with the permittee’s post-
construction ordinance.
Yes 01, 02
Comments (Describe inventory information and number of controls in inventory)
Single post construction measure installed at customer service center, proprietary underground system with weirs. A second will
be installed at new fire station.

NCS000484_Salisbury MS4 Audit_20200106 Page 20 of 31
Pollution Prevention and Good Housekeeping for Municipal Operations
II.G.2.h
O&M for Structural
Stormwater Controls

The permittee maintained and implemented an O&M program for municipally-
owned or maintained structural stormwater controls installed for compliance with
the permittee’s post-construction ordinance. If yes, then:
Yes 01, 02
The O&M program specified the frequency of inspections and routine
maintenance requirements. Yes 01, 02
The permittee documented inspections of all municipally-owned or maintained
structural stormwater controls. Yes 01, 02
The permittee inspected all municipally-owned or maintained structural
stormwater controls in accordance with the schedule developed by permittee. No 01, 02,
10
The permittee maintained all municipally-owned or maintained structural
stormwater controls in accordance with the schedule developed by permittee.
Not
Applicable
01, 02,
10
The permittee documented maintenance of all municipally-owned or
maintained structural stormwater controls. Partial 01, 02,
10
Comments
City only owns one SCM at the moment and is under agreement with the company that they are to maintain the measure and
ensure proper operation. However, it should be noted that the City should still be required to inspect the measure to ensure it is
working on a regular basis. City should inspect and it is recommended to inspect in between inspections by installation company.
Maintenance was documented by third party however upon inspection some notes were missing about what was done during
maintenance.
II.G.2.i
Pesticide, Herbicide
and Fertilizer
Application
Management

The permittee ensured municipal employees are properly trained in pesticide,
herbicide and fertilizer application management. Yes 01, 02,
03
The permittee ensured contractors are properly trained in pesticide, herbicide and
fertilizer application management. Yes 01, 02,
03
The permittee ensured all permits, certifications, and other measures for
applicators are followed. Yes 01, 02,
03
Comments
1 aquatic license, 2 right-a-way, and 5 ornamental.
II.G.2.j
Staff Training The permittee implemented an employee training program for employees involved
in implementing pollution prevention and good housekeeping practices. Yes 01, 02
Comments
All employees receive training that is specific to their job in the city.
II.G.2.k
Vehicle and
Equipment Cleaning
The permittee described and implemented measures that prevent or minimize
contamination of stormwater runoff from all areas used for vehicle and equipment
cleaning.
Yes N/A

NCS000484_Salisbury MS4 Audit_20200106 Page 21 of 31
Pollution Prevention and Good Housekeeping for Municipal Operations
Comments
Areas of cleaning or maintaining vehicles in the city have drains that run to an oil-water separator that then discharges to sanitary
sewer.
Additional
Comments:
Facilities were mapped and the City of Salisbury kept up with the permitted facilities in municipal limits. The
main concern with this section of the permit is the same as some of the others, documentation was lacking.
Documentation was improving in recent years there was a lack of documentation overall that was addressed
during the audit. NCDEQ recommended to the city to ensure they documented everything they did that had
to do with the permit.

NCS000484_Salisbury MS4 Audit_20200106 Page 22 of 31

Site Visit Evaluation: Municipal Facility No. 1
Facility Name:
City of Salisbury; Fleet Maintenance
Date and Time of Site Visit:
10/14 @ 1225
Facility Address:
519 North Fulton Street, Salisbury, NC 28144
Facility Type (Vehicle Maintenance, Landscaping, etc.):
Vehicle Maintenance, Vehicle Storage

Name of MS4 inspector(s) evaluated:
Michael Hanna

Most Recent MS4 Inspection (List date and name of inspector):
11/19/2018 Keith Redman

Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name Title

Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility-specific?
Yes. Facility has NCG080816 and a SWPPP was created in order to remain in compliance with that permit. SWPPP is lacking in
some detail and the list of potential sources of pollutants could use more details and also should have more sources.
What type of stormwater training do facility employees receive? How often?
Facility employees are trained by stormwater staff annually. Ensure these training records are kept on-site with the SWPPP.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
MS4 inspector receives annual training and is SCM inspector certified.
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
Inspector appeared knowledgeable about permit requirements.
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Inspector appeared knowledgeable about potential hazards a pollutant sources on site. Some potential areas were missed during
the site inspection.
Inspection Procedures
Does the MS4 inspector’s process include the use of a checklist or other standardized form?
No. City did create a checklist after the audit.
Does the MS4 inspector’s process include taking photos?
Yes in problem areas.
Does the MS4 inspector’s process include reviewing the facility’s SWPPP (or similar document)?
NCDEQ requested to review the SWPPP during the inspection. Inspector said it is not reviewed during every inspection.

NCS000484_Salisbury MS4 Audit_20200106 Page 23 of 31
Site Visit Evaluation: Municipal Facility No. 1
Does the MS4 inspector’s process include walking the entire facility and inspecting all points of discharge?
Yes.
Did the MS4 inspector miss any obvious areas of concern? If so, explain:
There were two areas of concern that were not looked at during the inspection. The first was a poorly maintained tank stationed
just outside of the garage doors to the maintenance facility. The tank appeared to be in use and was showing signs of rust on the
tank and the secondary containment around the tank. The second area of concern were two curb inlets along the parking area
across from the main maintenance facility. They were both covered with mats to prevent spillage from reaching the inlets but both
featured staining around the inlets. Stormwater inspectors should look at all of the catch basins/curb inlets on site during
inspections.
Does the MS4 inspector’s process include presenting the inspection findings to the facility contact?
Yes.
Inspection Results
Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)?
Inspector mentioned cleaning up the area near the trash bins.
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
As soon as possible.
Notes/Comments/Recommendations
It was obvious that City of Salisbury employees knew the facility and were completing regular inspections. Outfalls were looked at
along with areas of concern. Inspector spoke with facility employees and spoke with them about any issues or recent spills. The
facility was mainly under cover and inspector spoke about ensuring all drips or spills were cleaned up. The main issue of the
inspection is documentation. The inspector lacked documentation of regular (monthly) inspections of the facility. The SWPPP
documented required annual compliance inspections but did not cover the inspections performed by non-facility employees.

NCS000484_Salisbury MS4 Audit_20200106 Page 24 of 31
Site Visit Evaluation: Municipal Facility No. 2
Facility Name:
Customer Service Center

Date and Time of Site Visit:
10/14 @ 1330

Facility Address:
1415 Martin Luther King Jr. Avenue South
Salisbury, NC 28144
Facility Type (Vehicle Maintenance, Landscaping, etc.):
Offices, Storage, Server Building, Vehicle Maintenance

Name of MS4 inspector(s) evaluated:
Michael Hanna

Most Recent MS4 Inspection (Date and Entity):
N/A

Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name Title

Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility-specific?
No. The facility does not have any sort of stormwater plan. The facility uses less than 55 gallons a month of oil so it does not
trigger the requirement for the NCG08 permit. It was discovered that due to the servers being stored at the site there was a large
1,500-gallon generator on site. This would trigger the requirement for a SPCC and should have been in place as a similar document.
This was not the case during the site visit.
What type of stormwater training do facility employees receive? How often?
Facility employees, specifically in the vehicle maintenance area, receive stormwater training once annually. The training is given by
the MS4 employees and is site specific.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
MS4 inspector receives annual training and is SCM inspector certified.
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
Inspector appeared knowledgeable about permit requirements.
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
MS4 inspector appeared knowledgeable about the general pollution prevention and good housekeeping requirements. The
inspector looked at the inlets, storage area, and the general maintenance area. The issue arose when discussing the large
generator on the western edge of the site. The inspector did not appear knowledgeable about the general requirements when it
came to above ground storage of petroleum products. During the inspection the inspector was unsure about the exact size of the
tank of how often it would be used. While the generator and its built in tank did appear to be in good shape, there were no
measures or spill kits put in place to ensure the spill would be contained should a problem arise.
Inspection Procedures
Does the MS4 inspector’s process include the use of a checklist or other standardized form?
Not during this inspection. The inspector sent NCDEQ a copy of the newly developed checklist after the audit was completed.

NCS000484_Salisbury MS4 Audit_20200106 Page 25 of 31
Site Visit Evaluation: Municipal Facility No. 2
Does the MS4 inspector’s process include taking photos?
For problems noted during the inspection.
Does the MS4 inspector’s process include reviewing the facility’s SWPPP (or similar document)?
No similar document.
Does the MS4 inspector’s process include walking the entire facility and inspecting all points of discharge?
Yes. This facility is the home to the post-construction feature.
Did the MS4 inspector miss any obvious areas of concern? If so, explain:
Generator and above ground storage. It was also pointed out to the inspector to ensure that trash containers are not directly
above curb inlets to prevent leakage into the stormwater system.
Does the MS4 inspector’s process include presenting the inspection findings to the facility contact?
Yes.
Inspection Results
Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)?
Yes. There were some areas in the storage area that needed to be fixed up and have some containers removed. Inspector also
noted that a SPCC would be created and the trash container would be moved to a better location after being informed by NCDEQ.
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
As soon as possible. City of Salisbury began working on SPCC within the week via an e-mail with NCDEQ.

Notes/Comments/Recommendations
While the inspector did inspect the entire site and looked at the two main areas of concern, the storage area and maintenance
stalls, there was a lot missing from this site. The lack of a SWPPP or similar document is an issue however it becomes a much larger
issue given the existence of the above ground storage. As was discussed with the previous site inspection documentation needs to
get better and ensure that when inspections are completed they are documented and kept with the SPCC.

NCS000484_Salisbury MS4 Audit_20200106 Page 26 of 31
Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1
Site Name:
Customer Service Center
Date and Time of Site Visit:
10/14 @ 1315
Site Address:
1415 Martin Luther King Jr. Avenue South
Salisbury, NC 28144
SCM Type:
Proprietary by CrystalStream™ Technologies
Most Recent MS4 Inspection (Include Date and Entity):
3/7/2019 (not by MS4, by CystalStream™ Technologies)
Name of MS4 Inspector(s) evaluated:
Michael Hanna
Most Recent MS4 Enforcement Activity (Include Date):
N/A
Name(s) and Title(s) of Site Representative(s) Present During the Site Visit:
Name Title

Observations
Site Documentation
Does the site have an operation and maintenance plan?
Yes. O&M plan was put together by CrystalStream™ Technologies
Does the site have records of annual inspections? Are they performed by a qualified individual?
Annual inspections are being completed by CrystalStream™ Technologies. No documented inspections performed by MS4
inspectors.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
MS4 inspector receives annual training and is SCM inspector certified.

Did the MS4 inspector appear knowledgeable about MS4 requirements for post-construction site runoff controls?
Yes.
Did the MS4 inspector appear knowledgeable about post-construction BMPs (general purpose/function, components, O&M
requirements, etc.)?
Yes.

Inspection Procedures
Does the MS4 inspector’s process include the use of a checklist or other standardized form? What format?
The inspector for CrystalStream™ Technologies uses a checklist for the inspections and maintenance.
Does the MS4 inspector’s process include taking photos?
Yes. Photos are taken during CrystalStream™ Technologies inspections and during this inspection photos were taken of small issues
in the SCM.

NCS000484_Salisbury MS4 Audit_20200106 Page 27 of 31
Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1
Does the MS4 inspector’s process include reviewing the site’s operation and maintenance plan and records of annual
inspections?
Yes.
Does the MS4 inspector’s process include walking the entire site and inspecting all points of discharge?
Yes.
Did the MS4 inspector miss any obvious operation and maintenance deficiencies? If so, explain:
Yes. Upon review of the O&M plan, it was discovered that for this measure it is to be inspected once every 90 days minimum. It
did not appear this was being done.
Does the MS4 inspector’s process include presenting the inspection findings to the site contact in writing?
Yes, inspector was going to inform CrystalStream™ Technologies that there was an issue with one of the weirs during the
inspection.
Compliance/Enforcement
What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in?
N/A
If compliance issues were identified, what timeline for correction/follow-up was provided?
Weir issue was to be addressed as soon as CrystalStream™ Technologies could get to the measure.
Notes/Comments/Recommendations
With the inspection of the SCM there was a deficiency when it came to inspections being performed by the City of Salisbury. The
city should be completing inspections of the measure outside of the annual inspections and maintenance being performed by
CrystalStream™ Technologies. The O&M for the measure also dictated that the measure should be inspected every 90 days once
construction is complete. There was no documentation for any of these inspections being performed and this should start as soon
as possible. The O&M plan also states a version of an inspection checklist that should be followed.

NCS000484_Salisbury MS4 Audit_20200106 Page 28 of 31

APPENDIX A: SUPPORTING DOCUMENTS

Please Note:
Copy of report sent to City of Salisbury does not include city supplied documents.

NCS000484_Salisbury MS4 Audit_20200106 Page 29 of 31

APPENDIX B: PHOTOGRAPH LOG

Photo 1: Trash area and storage at Salisbury maintenance facility

Photo 2: Inside maintenance bay at Salisbury maintenance facility

NCS000484_Salisbury MS4 Audit_20200106 Page 30 of 31

Photo 3: Internal storage of oil at Salisbury maintenance facility

Photo 4: Covered storage of machinery and materials at Salisbury maintenance facility

NCS000484_Salisbury MS4 Audit_20200106 Page 31 of 31

Photo 5: Waste bin near curb inlet at Salisbury customer service center

Photo 6: Fuel cans being stored outside with underground SCM in the background at Salisbury
customer service center