NCS000456_2021 Audit Report_20210310

MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM AUDIT REPORT
NPDES PERMIT NO. NCS000465
TOWN OF MORRISVILLE, NORTH CAROLINA
100 Town Hall Drive, Morrisville, NC 27560
Audit Date: February 10, 2021
Report Date: March 10, 2021
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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NC5000465 Sown of Morrisville M54 Audit 20210210

TABLE OF CONTENTS
AuditDetails ................ ............................................................ .. .. . .. .. ... .. .. ....... .... ......... 1
PermitteeInformatIon.................... ...... ................,...........,,....,....,,....,.....,..,.,,...,................................. 2
Listof Supporting Documents ............................................ . ... .... ..............., ... ... ........, ........, 3
Program Implementation, Documentation & Assessment .......................... ........ 4
Aladt Discharge Detection and Elimination (IDDE) .... ... ...................................................................... 8
Construction Site Runoff Controls..............................................................................................................11
Pollution Prevention and Goad Housekeeping for Municipal Operations ................................................ 15
Total Maximum Daily Loads(TM DLs) ... ....................... ....................... ........... Error I Bookmark not defined,
Site Visit Evaluation: Municipal Facility No,1............................................................................................ 19
Site Visit Evaluation. MS4 Outfall No. I ..... ..... ..... ..... .............. ....................... .......................................... 21
Site Visit Evaluation- Construction Site No. 1— ...... ... - ...... . ......... ................................................... 23
Site Visit Evaluation. Post -Construction Stormwater Conttol Measure No. lErrorl Bookmark not defined.
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.
NCS000465 Town of Morrisville MS4 Audit 20210210

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MC5000465 Town of Morrisville MS4 Audit_20210210

Audit Details
Audit ID Number: Audit Date(s):
NC5000456_Morrisville MS4 Audit_20210210 02/10/2021
Minimum Control Measures Evaluated:
® Program Implementation, Documentation & Assessment
❑ Public Education & Outreach
❑ Public Involvement & Participation
® Illicit Discharge Detection & Elimination
Cl 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: 1
® MS4 Outfalls. Number visited: 1
® Construction Sites. Number visited: 1
© Post -Construction Stormwater Runoff Controls. Number visited: Choose an item.
❑ Other: Number visited: Choose an item.
❑ Other: Number visited: Choose an item.
Inspector(s) Conducting Audit
Name, Title
nization
Organization
Thad Valentine
DENILR Land Resources
Natalie Norbeq,
DEN#LR Land Resources
Lauren Garcia
DES✓1LR Land Resources
Audit Report Author:
Date:
1
Signature'���L�n
Audit Report Author:
Date:
Signature
Audit Report Author:
Date:
For Natalie
%
,1
NCS000465_Town of Morrisville M54 Audit_20210210 Page 1 of 26

Permittee Information
MS4 Permittee Name: Town of Morrisville
Permit Effective pate:
02/20/2017
Permit Expiration Date:
02/19/2022
Mailing Address:100 Town Hall Drive, Morrisville, NC
27560
Date of Last MS4 Inspection/Audit:
02/10/2021
Co-permittee(s), if applicable: N/A
Permit Owner of Record: Town of Morrisville
Primary MS4 Representatives Participating in Audit
Name, Title
Organization
Catherine Jacobs, Stormwater Engineer
Town of Morrisville
Ben Mills, Stormwater Engineering
Manager
Town of Morrisville
Tony Vitor, Environmental Specialist
Town of Morrisville
Mark Spanioli, Town Engineer
Town of Morrisville
Betsy Pearce, Environmental Consultant
Wake County
Jeevan Neupane, Environmental
Consultant
Wake County
M54 Receiving Waters
Waterbody
Classification
Impairments
Kit Creek
C;NSW & VIS-IV:NSW
N/A
Brier Creek
C;NSVI
PC6
Coles Branch
C:.NS%'V
N/A
Crabtree Creek
C;NSV/ & B;NSW
Poor Biocla>sification/Benthos, PCB
Stirrup Iron Creek
C.NSW
N/A
Indian Creek
C;NSW
N/A
NCS000465_Town of Morrisville MS4 Audit_20210210 Page 2 of 26

List of Supporting Documents
Item When Provided
Number Document Title (Prior to/During/After)
1 Stormwater Program Evaluation and Funding Report During
2
Stormwater Management Plan
Before
3
2019 Annual Report
Before
4
Article 7: Stormwater Management Ordinance
Before
5
Interlocal Agreement
Before
6
SOP Illicit Detection & Elimination
During
7
SOP Dry Weather Flow Monitoring & Detection
During
8
Outfall Map
During
9
New Hire Training Program
During
10
Public Education Brochures
During
11
Wake County NOV
After
12
Wake County Approval Letter
After
13
General Operations & Maintenance Plan for Town of Morrisville Facilitie.
During;
14
SOP Spill Prevention and Reporting
During
15
SCM Inspection Report
D..ring
16
Integrated Pest Management Plan
During
17
Pesticide Licenses
Post
18
PP&GH Powerpoint
Durini;
19
Wake County NOV and Civil Penalty Assessment
After
20
Fire Station 2 O&Nt Plan
After
NCS000465_Town of Morrisville MS4 Audit_20210210 Page 3 of 26

IProgram Implementation, Documentation & Assessment
Staff Interviewed:
Catherine Jacobs; Stormwater Engineer
(Name, Title, Role)
Ben Mills; Stormwater Engineering Manager
Tony Victor; Environmental Specialist
Mark Spanioli; Town Engineer
Permit Citation
Program Requirement
Status
Supporting
Doc No.
II.A.i
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
1
The Stormwater Plan identifies a specific position(s) responsible for the overall
coordination, implementation, and revision to the Plan.
V25
2
Responsibilities for all components of the Stormwater Plan are documented and
position(s) assignments provided.
Yes
2
The permittee is current on payment of invoiced administering and compliance
monitoring fees (see stormwatere-payments on Dl:MLR MS4 web page).
yes
BIN%
Comments (Briefly describe funding mechanism, number of staff, etc.)
Three Stormwater Positions are funded by a sto'rTh 310f utility fee and supplemented by a General Fund. The annual budget is
approximately 5800,000.
Responsibilities are listed on page 10 of the WIMP.
II.A.2 Stormwater The permittee evaluated the performance and effectiveness of the program
Plan Yes 3
components at least annually.
Implementation
and Evaluation If yes, the permittee used the results of the evaluation to modify the program
Yes 3
components as necessary to accomplish the intent of the Stormwater Program.
Did the permitted M54 discharges cause or contribute to non -attainment of an
No
applicable water quality standard?
If yes, did the permittee expand or better tailor its BMPs accordingly to address Not ---
the non -attainment? Applicable
Comments
The Town has submitted an annual report through BINIS since 2018 and used this as the evaluation.
An outside evaluation was performed in 2020. The To,,vn is currently evaluating the results and determining next steps.
There has not been an event that would contribute to a non -attainment of an applicable water quality standard.
NCS000465 Town of Morrisville MS4 Audit_20210210 Page 4 of 26

Program Implementation, Documentation & Assessment
II.A.3
Keeping the
The permittee kept the Stormwater Plan up to date.
Yes
2
Stormwater Plan
Up to Date
The permittee notified DEMLR of any updates to the Stormwater Plan.
Not
--
Applicable
Comments (Indicate the date of latest Stormwater plan and describe the nature of any updates, if applicable).
The SWMP was last updated in 2017. No changes were required. The Town is currently working on updates For the new template in
2021.
II.8.4 Availability
The permittee kept an up-to-date version of its Stormwater Plan available to the
of the Stormwater
Division and the public online.
partial
Online
Plan
The online materials included ordinances, or other regulatory mechanisms, or a list
identifying the ordinances, or other regulatory mechanisms, providing the legal
Yes
4
authority necessary to implement and enforce the requirements of the permit.
Comments (Note what materials are available on line)
The SWMP is not online in its entirety. Pieces of the SWIViP are hyperlinked on the Stormwater Resources Town of Morrisville
Webpage: https://wtivw.townofmorrisville.org/government/departments-services/engineering/stormwater/stormwater-resources.
The SWMP is public record and a hard copy is made available upon request.
The Town should provide a way for the public to access the complete 5VINIP online.
The ordinance is available: hops://user-cjghrl.v.cld.bz/Morrisville-Unified-Development-Ordinance-September-20202. Stormwater
Management is addressed in Article 7.
II.A.3 & II.A.S
Stormwater Plan
Did DEMLR require a modification to the Stormwater Plan?
No
---
Modifications
If yes, did the permittee complete the modifications in accordance with the
Not
established deadline?
Applicable
"-
Comments (Note date of DEMLR notification, modifications required, and date modifications were completed, as applicable)
II.A.6 Sharing
Responsibility
Are any control measures implemented by an entity other than the permittee?
Yes
5
If yes, is there a written agreement in place?
Yes
5
Comments (List the specific control measures implemented by others that do not have adequate written agreements, if
applicable)
Wake County is delegated to implement erosion control. An Interlocal Agreement was provided prior to the audit.
11.A.7
The permittee maintained written procedures for implementing the six minimum
control measures.
partial
6,7
NCS000465 Town of Morrisville MS4 Audit_20210210 Page 5 of 26

Program Implementation, Documentation & Assessment
Written Written procedures identified specific action steps, schedules, resources and
Procedures Partial 6,7
responsibilities for implementing the six minimum measures.
Comments (List the specific minimum measures that do not have adequate written procedures, if applicable)
SOPS were not available for all six measures. Only an SOP for Illicit Discharge Detect on and El,mination and an additional SOP for
Dry Weather Flow Detection were provided during the audit.
The Town should develop procedures for all six minimum control mea�.ur es
Ill. A The permittee maintained documentation of all program components including, but
Program not limited to, inspections, maintenance activities, educational programs, Yes ---
Documentation implementation of BMPs, enforcement actions etc., on file for a period of five years.
Comments (List the specific program components that do not have adequate documentation on file and why, if applicable)
The Town showed SCM and illicit discharge inspection records and maint-nance rr,cord,. during the audit. Wake County provided
erosion control inspection records and associated documents follo-.ving the inspection.
111.E The permittee submitted annual reports to the Department within twelve months
Annual Report from the effective date of the permit (See Section 11i.B. for the annuol reporting Yes 3
Submittal period specific to this MS4).
The permittee submitted subsequent annual reports every twelve months from the Yes 3
scheduled date of the first annual report submittal.
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 Plot
of each major component of the Stormwater Plan for the past year and Applicable -
schedules and plans for the year following each report.
2. An adequate description and justification of any proposed changes to the
Stormwater Plan. This will include descriptions and supporting information for Plot -
the proposed changes and how these changes will impact the Stormwater Applicable
Plan (results, effectiveness, implementation schedule, etc.).
3. Documentation of any necessary changes to programs or practices for
Not
assessment of management measures implemented through the Stormwater ---
Applicable
Plan.
4. A summary of data accumulated as part of the Stormwater Plan throughout
Notthe year along with an assessment of what the data indicates in light of the ---
Applicable
Stormwater Plan.
S. An assessment of compliance with the permit, information on the
Plot
establishment of appropriate legal authorities, inspections, and enforcement
Applicable
actions.
Comments (Note dates that annual reports cover undercurrent permit and generally describe report deficiencies, if any)
The Town submits annual reports through BIMS.
IV.B
Annual Reporting The Annual Reports document the following:
NC5000465 Town of Morrisville M54 Audit_20210210 Page 6 of 26

Program Implementation, Documentation & Assessment
1. A summary of past year activities, including where applicable, specific
Not
quantities achieved and summaries of enforcement actions.
Applicable
2. A description of the effectiveness of each program component.
Not
Applicable
3. Planned activities and changes for the next reporting period, for each
Not
program component or activity.
Applicable
4. FISCaI analysis.
NotApplicable
Comments (Note dates that annual reports cover under current permit and generally describe report deficiencies, if any)
The Town submits annual reports through GINIs.
Additional
Comments.
NCS000465 Town of Morrisville MS4 Audit 20210210
Page 7 of 26

Illicit Discharge Detection and Elimination (IDDE)
Staff Interviewed:
Catherine Jacobs; Stormwater Engineer
(Flame, Title,
Ben Mills; Stormwater Engineering Manager
Role)
Tony Victor; Environmental Specialist
Marls Spanioli; Town Engineer
Permit Citation
Program Requirement
Status
Supporting
Doc No.
II.D.2.a
IDDE Program
The permittee maintained a written IDDE Program.
No
2
If yes, the written program includes provisions for program assessment and
No
---
evaluation and integrating program.
Comments (Note any deficiencies)
Pages 15-16 of the SWMP addressed the IDDE. An IDDE SOP was provided prior to the audit. There are no written provisions for
program assessment and evaluation/integration of the Program. The SWNIP address the Tovin's Objectives, the Unified
Development Ordinance, Napping, etc. The SOP addressed Inspections and Procedures.
The Program should be a separate, comprehensive document. It can be incorporated into the S1411MP, but it must be able to stand
on its own.
The permittee maintained an IDDE ordinance or other regulatory mechanism(s) that
provides the legal authority to prohibit illicit connections and discharges to the MS4.
Yes
�}
II.D.2.b
If yes, the ordinance applies throughout the corporate limits of the permittee.
Legal Authorities
Yes
4
[Permit Part I.D]
Comments
IDDE is addressed in the Unified Development Ordinance in Section 7.6.2. Applicability and Jurisdiction is addressed in Section 7.14:
https-;`/user-cjghrl.v.cid.bz/Niorrisville-Unified-Development-Ordinance-Septeriib; ,r-20202.
H.D.2.c
The permittee maintained a current map showing major outfalls' and receiving
Yes
8
Storm Sewer
System Map
streams.
Comments
The Tom has a comprehensive GIS Mapping System that shows outfallS, receiving str -ams, SCPiIs, Stormwater infrastructure, etc.
'Major outfalls are discharges from > 36"' diameter pipes or drainage areas of > 50 acres. in areas zoned for industrial activity, majoroutfalls
are ? 12" or drainage area > 2 acres.
II.D.2.d
The permittee maintained a program for conducting dry weather flow field
Dry Weather Flow
observations in accordance with written procedures.
Partial
7
Program
Comments (Generally summarize program, including frequency of observations and p or 90 of outfalls screened)
The Town provided a Dry Weather Flow Monitoring & Detection SOP. A farmal pray an) has no; been d=veloped.
Not al, outfalls are inspected annually, All outfalls were inspected in 2019 The Town p=rforms -1p-�t checks quarterly. Approximately
10 are inspected each quarter. All outfalls are inspected every two t :r_e years.
NCS000465 Town of Morrisville MS4 Audit_20210210 Page 8 of 26

Illicit Discharge Detection and Elimination (IDDE)
II.D.2.e
Investigation
The permittee maintained written procedures for conducting investigations of
Procedures
identified illicit discharges.
Yes
6
Comments (Generally describe what procedures are documented)
An IDDE SOP was provided prior to the audit.
II.D.2.f For each case of an illicit discharge or potential illicit discharge, the permittee documented and tracked the
Track and following:
Document
Investigations 1. The date(s) the illicit discharge was observed Yes -.-
2. The results of the investigation Yes ---
3. Any follow-up of the investigation Yes ---
4. The date the investigation was closed Yes ---
Comments (Note whether a standard inspection form is utilized to capture consistent information and a tracking mechanism is
used)
The Town uses an Access Database titled "Concern Tracking" to track IDDE incidents/inspections/complaints.
The process includes an investigation report, a follow-up report and then incidents are tracked in the database. Inspections and
results were shown during the audit.
II.D.2.e Employee
Training
The permittee implemented and documented a training g appropriate
p p g program for ro riots
municipal staff who, as part of their normal job responsibilities, may come into
Yes
9
contact with or otherwise observe an illicit discharge or illicit connection.
Comments (Generally describe the staff training program, including frequency and which staff are trained)
The Town has an IDDE/Stormwater Training Plan. The Plan was provided at the audit. The training includes a powerpoint
presentation and a video. A sign -in sheet was provided during the audit. The po,.verpoint was provided during the audit.
II.0.2.11h
The permittee informed public employees of hazards associated with illegal
Public Education
discharges and improper disposal of waste.
Yes
9
The permittee informed businesses of hazards associated with illegal discharges and
improper disposal of waste.
Yes
10
The permittee informed the general public of hazards associated with illegal
discharges and improper disposal of waste.
Yes
10
Comments (Note how each sector was informed, if applicable)
Public Employees receive Stormwater/IDDE/Pollution Prevention and Good Housekeeping training.
The Town visits businesses/restaurants and hands out brochures addressing stormwater pollution and improper disposal of waste.
The Town has a strong social media presence and attends events like Spring Fest and national Night Out to distribute information
and inform the public. The Town keeps track of how much merchandise is distributed.
IF
NCS000465_Town of Morrisville MS4 Audit_20210210 Page 9 of 26

Illicit Discharge Detection and Elimination (iDDE)
II.U.2.i The permittee promoted, publicized, and facilitated a reporting mechanism for the
Yes Online
Public Reporting public to report illicit discharges.
Mechanism
The permittee promoted, publicized, and facilitated a reporting mechanism for staff Yes Online
to report illicit discharges.
The permittee established and implemented response procedures for citizen
No
requests/reports.
Comments (Generally describe reporting mechanisms and how promotedfpublicized/facilitated/established)
A stormwater hotline is provid:-d online: https://www.townofmorrisville.or=/government/departments-
services/engineering/stormwater. The general public and staff use the hotline for reporting.
There are no formal response procedures for citizen requests/reports; therefore, the Town should develop written procedures. The
Town responds to complaints r nd tracks them in the access database. Sediment complaints are forwarded to Wake County.
II.d.2. The permittee implemented a mechanism to track the issuance of notices of violation
Enforcement Yes
and enforcement actions administered by the permittee.
If yes, the mechanism includes the ability to identify chronic violators for
Yes
initiation of actions to reduce noncompliance.
Comments (Generally describe the established tracking mechanism, if applicable)
The Town tracks inspections and enforcement actions through the Access Database, Concern Tracking. There has only been one
chronic violator, Morrisville Market.
Additional
Comments:
NC5000455_Town of Morrisville MS4 Audit_20210210 Page 10 of 26

Construction Site Runoff Controls
Staff Interviewed:
Betsy Pearce, Environmental Consultant, Wake County
(Name, Title, Role)
Jeevan Neupane, Environmental Consultant, Wake County
Program Delegation Status:
❑ The permittee has a delegated Sediment and Erosion Control Program and implements the North Carolina
Sedimentation Pollution Control Act (SPCA) of 1973 components of this minimum measure (complete the permit
citation and SPCA citation sections).
® The permittee does not have a delegated Sediment and Erosion Control Program and relies on Wake County to
comply with the North Carolina Sedimentation Pollution Control Act (SPCA) of 1973 components of this minimum
measure (complete only the permit citation section).
Permit Citation Program Requirement Status Supporting
Doc No.
II.E.3 Construction
Site Runoff Controls The permittee provides and promotes a means for the public to notify the
[NPDES Permit No. appropriate authorities of observed erosion and sedimentation problems (e.g., Yes Online
NCS0004351 promoting the existence of the DEQ DEMLR "Stop Mud" hotline).
Comments (Describe how provided and promoted)
Contact information is provided on the Wake County Webpage: hops://Urvw.wakegov.com/watershed-management-staff-contact-
information. Maps are provided that show the jurisdictions of each inspector.
It was stated that many erosion complaints are called in to the Town of Morrisville Hotline and are then reported to Wake County
by the Town.
SPCA Citation
Delegated Program Requirement
Status
Supporting
Doc No.
113A-5a Local
erosion and
The permittee has adopted an ordinance or other regulatory mechanism to enforce
Yes
5, Online
sedimentation
the erosion and sedimentation control program.
control programs (a)
If yes, the ordinance meets or exceeds the minimum requirements of the
SPCA.
Yes
--
If yes, the ordinance applies throughout the corporate limits of the permittee.
(Permit Part 1.01
Yes
Online
Comments (Provide regulatory mechanism reference or Supporting Documentation number)
Article 10 in the Wake County Municipal Code address the regulatory mechanism to enforce the erosion and sedimentation control
program. Wake County's EC Program was last audited in 2020 and the ordinance was found to meet the minimum requirements of
the SPCA. Applicability and jurisdiction is also addressed in the Municipal Code.
NCS000465_Town of Morrisville M54 Audit_20210210 Page 11 of 26

Construction Site Runoff Controls
§ 113A-60 Local
erosion and The permittee collects a fee paid by each person who submits an erosion and
Yes Online
sedimentation sedimentation control plan.
control programs (d)
Comments (indicate the fee amount, if applicable)
Wake County charges $250/acre for review and $250/acre for issuance. $500/a:re is charged in total. It is included in Ordinance
1.01 of the Municipal Code.
113A-60 Local Has any person initiated a land -disturbing activity (within the permittee's
erosion and jurisdiction) for which an erosion and sedimentation control plan is required in the Yes it
sedimentation absence of an approved plan?
control programs (e) If yes, the permittee has notified the North Carolina Sedimentation Control
Yes
Commission of all such cases.
Has the permittee determined that a person engaged in a land -disturbing activity Yes ---
has failed to comply with an approved erosion and sedimentation control plan?
If yes, has the permittee referred any such matters to the North Carolina
Yes ---
Sedimentation Control Commission for inspection and enforcement?
Comments
Land disturbing activity without a permit is an automatic NOV from Wake County, Wad z• Cour ty notifi.:.. the RRO Regional Engineer
and the Central Office State Sediment Special st when this occurs.
Sites that are found to be out of compliance are given a non -compliant inspection report and a deadline to address issues. Wake
County notifies DEMLR and DWR is offsite sediment enters a buffer or stream.
Wake County provided an inspection report and NOV post audit.
113A-61 Local The permittee reviews each erosion and sedimentation control plan submitted to
approval of erosion them and notifies the person submitting the plan that it has been approved, Yes 12
and sedimentation approved with modification, or disapproved within 30 days of receipt.
control plans The permittee only approves an erosion and sedimentation control plan upon Yes 12
determining that it complies with all applicable State and local regulations.
The permittee has disapproved of an erosion and sedimentation control plan in
Yes ---
order to protect riparian buffers along surface waters.
if yes, the permittee notified the Director of the Division of Energy, Not
Mineral, and Land Resources within 10 days of the disapproval. Applicable
Comments
Disapproved erosion control plans are revised for approval or they are rejected Any plans that pose a threat to riparian buffers are
revised to protect riparian buffers and approved.
Wake County provided an Approval Letter post -audit.
NCS000465 Town of Morrisville MS4 Audit_20210210
Page 12 of 26

Construction Site Runoff Controls
§ 113A-61.1
Inspection of land-
The certificate of approval of each erosion and sedimentation control plan
disturbing activity;
approved by the permittee includes a notice of the right to inspect.
Yes
12
notice of violation
(a)
The permittee provides for inspection of land -disturbing activities to ensure
compliance with the SPCA and to determine whether the measures required in an
Yes
12
erosion and sedimentation control plan are effective.
Comments
The right to inspect is present in the Approval Letter and in Wake County's UDO. An Approval Letter was provided post -inspection.
Wake County performs regular inspections. Inspection results are performance based. If add,tional measures are needed onsite,
Wake County can require them. Wake County sends a list of NOVs and problem sites to the Town. Wake Count tracks fines on a
spreadsheet.
222 inspections were conducted in 2020.
§113A-61.1
When the permittee determines that a person engaged in land -disturbing activity
Inspection of land-
has failed to comply with the SPCA, the Permittee immediately issues a notice of
Yes
11
disturbing activity;
violation upon that person.
notice of violation -
Each notice of violation issued by the permittee specifies the date by which the
(e)
person must comply.
Yes
11
Each notice of violation issued by the permittee informs the person of the actions
that need to be taken to comply.
Yes
ZI
Comments
Wake County works with contractors to get the site in compliance following a non. :omphance report. The contractor is given a
deadline to address issues. NOVs are issued when necessary.
All PIOVs include a date by which issues must be addressed.
Wake County provided an NOV post -audit.
113A-64 Penalties
Does the permittee issue civil penalties as part of the erosion and sedimentation
program?
Yes
19
Comments (indicate when/why a civil penalty is issued, and the amount, if applicable)
Civil penalties can be issued with an NOV or NOCV. 1 Civil Penalty �+jas issued in 2020 2 h-ive been issued since 2018.
NCS000465_Town of Morrisville MS4 Audit_20210220 Page 13 of 26

Construction Site Runoff Controls
Additional
Comments:
NCS000465 Town of Morrisville MS4 Audit_20210210
Page 14 of 26

Pollution Prevention and Good Housekeeping for Municipal Operations
Staff Interviewed:
Catherine Jacobs; stormwater Engineer
(Name, Title, Role)
Ben Mills; stormwater Engineering Manager
Tony Victor; Environmental specialist
Mark spanioli; Town Engineer
Permit Citation
Program Requirement Status Supporting
Doc No.
II.G.2.a
The permittee maintained a current inventory of facilities and operations owned
Facility Inventory
and operated by the permittee with the potential for generating polluted Yes 13,20
stormwater runoff.
Comments (Note number of facilities, typical inventory data and any facilities that are not inventoried that should be)
More facilities are listed than required. The Town listed all Publrzz Works Maintained Facilities. Of those listed only 2-4 have the
potential for generating polluted stormwater runoff.
The Town needs to work on the list to include only the facilities that generate polluted stormwater runoff, as required under the
conditions of the permit.
The Town provided a maintenance agreement for one of the pubiii: facilities, which is attached.
It is preferred that the MS4 have a full inventory of all municipa,' facilities, inspect them all once per permit term and then inspect
the ones that are identified as having exposure/potential at leas' annually. The new permit language will be more specific about
what is required.
II.G.2.b
The permittee maintained and implemented an O&M program for municipally
Operation and
owned and operated facilities with the potential for generating polluted
partial
13
Maintenance (O&M)
stormwater runoff.
for Facilities
If yes, the O&M program specifies the frequency of inspections.
Yes
If yes, the O&M program specifies the frequency of routine maintenance
requirements.
Mo
--.
If yes, the permittee evaluated the 0&M program annually and updated it as
necessary.
P!o
Comments
The Town provided a spreadsheet of municipally operated facilities. Each grouping of facil-' ies includes a general des,-riptia , of
what kind of maintenance is required and an inspection frequency.
The To,.vn is required to maintain, implement, evaluate annually, and update as necessary,3n OU1 Program for municipal owri-d
and operated facilities with the potential for generating polluted stormwater runoff. The OINI Program should specify t'.--
frequency of inspections and routine maintenance requirement:.
The O&M Program should be a separate comprehensive document. The document can be incorporated into the SWMP, but must
be able to stand alone.
NC5000465_Town of Morrisville M54 Audit_20210210 Page 15 of 26

Pollution Prevention and Good Housekeeping for Municipal Operations
II.G.2.c
Spill Response The permittee had written spill response procedures for municipal operations. Yes 14
Procedures
Comments
An SOP for Spill Prevention and Reporting was provided.
II.G.2.d Streets, The permittee evaluated existing and new BMPs that reduce polluted stormwater
Roads, and Public runoff from municipally -owned streets, roads, and public parking lots within its Yes --
Parking Lots corporate limits annually.
Maintenance if yes, the permittee evaluated the effectiveness of existing and new BMPs
Partial
based on cost and the estimated quantity of pollutants removed.
Comments
The Town shaved maintenance logs and inspection reports during the audit. The Town tracks street sweeping and tonnage.
Showed during audit. A ticket from tonnage was showed at audit. Street sweeping is performed about 6 times per year. The Town
discusses with public works and evaluates if additional street sweeping is needed based on citizen complaints and street/storm
drain conditions.
The Town should work on accurately tracking the tonnage removed and areas covered. The tracking sheets shown at the audit
reported the same yardage removed repeated'y throughout the different areas.
II.G.2.f The permittee maintained and implemented an O&M program for the stormwater
O&M for Catch
sewer system including catch basins and conveyance systems that it owns and No ---
Basins and
maintains.
Conveyance Systems
Comments (Briefly describe O&A4 program)
Catch basins, storm lines, culverts, and ditcr.es are briefly addressed in the spreadsheet of Municipally Operated Facilities. They are
inspected and maintained as needed.
The Town should develop an 0&M Program for the stormwater sever system. The written program should be a separate,
comprehensive document.
II.G.2. I The permittee maintained a current inventory of municipally -owned or operated
Structural Istructural stormwater controls installed for compliance with the permittee's post- Yes ---
Stormwater Controls i construction ordinance.
Comments (Describe inventory information and number of controls in inventory)
SCMs are shown on a GIS map. O&M plans are available for each SCM and examples :Mere shown at the audit
NC5000465 Town of Morrisville MS4 Audit_20210210 Page 16 of 26

Pollution Prevention and Good Housekeeping for Municipal Operations
II.G.2.11
The permittee maintained and implemented an O&M program for municipally -
O&M for Structural
owned or maintained structural stormwater controls installed for compliance with
Yes
---
Stormwater Controls
the permittee's post -construction ordinance. If yes, then:
The O&M program specified the frequency of inspections and routine
maintenance requirements.
Yes
---
The permittee documented inspections of all municipally -owned or maintained
structural stormwater controls.
Yes
is
The permittee inspected all municipally -owned or maintained structural
stormwater controls in accordance with the schedule developed by permittee.
Yes
15
The permittee maintained all municipally -owned or maintained structural
stormwater controls in accordance with the schedule developed by permittee.
Yes
---
The permittee documented maintenance of all municipally -owned or
maintained structural stormwater controls.
Yes
---
Comments
Inspection reports were shown at audit. O&M plans were shown at audit, Inspections follow the schedules in the O&NI plans.
Follow up inspection occur to ensure repairs have been made. Inspections show timeline for repair.
II.G.2.i
The permittee ensured municipal employees are properly trained in pesticide,
Pesticide, Herbicide
herbicide and fertilizer application management.
Yes
16,17
and Fertilizer
The permittee ensured contractors are properly trained in pesticide, herbicide and
Application
Management
fertilizer application management.
Yes
16,17
The permittee ensured all permits, certifications, and other measures for
applicators are followed.
No
Comments
Public Works ensures municipal employees are properly trained in pesticide, herbicide, and fertilizer application.
Public Works ensures contractors are certified, but there is no program in place for inspecting contractors for compliance.
II.G.2.j
The permittee implemented an employee training program for employees involved
Staff Training
in implementing
p g pollution prevention and good housekeeping practices.
Yes
18
Comments
PP&GH Training powerpoint was provided during the audit. A sign -in sheet was provided for the training.
II.G.2.k
The permittee described and implemented measures that prevent or minimize
Vehicle and
contamination of stormwater runoff from all areas used for vehicle and equipment
Not
-
Equipment Cleaning I
cleaning.
Applicable
NCS000465 Town of Morrisville MS4 Audit 20210210
Page 17 of 26

I Pollution Prevention and Good Housekeeping for Municipal Operations I
Comments
The Town uses commercial carwash for vehicles. Maintenance equipment is hosed off in the Public Works Yard.
Fire trucks are washed at the station and water flows into onsite SCMs.
Additional
Comments:
NCS000465 Town of Morrisville M54 Audit_20210210 Page 18 of 26

Site Visit Evaluation: Municipal Facility No.1
Facility Name:
Public Works
Date and Time of Site Visit:
02/10/2021
Facility Address:
Aviation Parkway
Facility Type (Vehicle Maintenance, Landscaping, etc.):
Public Works/Vehicle Maintenance
Name of M54 inspector(s) evaluated:
Tony Victor
Most Recent MS4 Inspection (List date and name of inspector):
02/2020
Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name
Title
N/A
N/A
Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific?
No. The facility should apply for an NCG050000 General Stormwater Permit. It was reportJd the facility uses approx. 150-200
gallons of used oil and various fluids every 90 days.
What type of stormwater training do facility employees receive? How often?
IDDE and PP&GH, Stormwater 101.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
NC State Training/Certifications, DOT Certifications
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
Yes
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Yes
Inspection Procedures
Does the M54 inspector's process include the use of a checklist or other standardized form?
Yes
Does the MS4 inspector's process include taking photos?
Yes
Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)?
No SWPPP onsite
NCS000455_Town of Morrisville MS4 Audit_20210210 Page 19 of 26

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:
Inspector d,d not look inside maintenance shops
Does the MS4 inspector's process include presenting the inspection findings to the facility contact?
Yes
Inspection Results R
Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)?
No
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
�J A
Notes/Comments/Recommendations
The facility should apply for the NCGOSOOOO General Storm;vater permit.
NCS000465 Town of Morrisville MS4 Audit_20210210 Page 20 of 26

Site Visit Evaluation: MS4 Outfall No. 1
Outfall ID Number:
Date and Time of Site Visit:
i0-394
02/10/2021 3:10pm
Outfall Location:
Outfall Description (Pipe Material/Diameter, Culvert, etc.):
Kudrow Land, Hatcher Creek Greenway
36" concrete
Receiving Water:
Is Flow Present? if So, Describe (Color, Approximate Flow Rate,
Unidentified Tributary
Sheen, Odor, Floatables/Debris, etc.):
Water present at outfall, not flowing
Most Recent Outfall Inspection/Screening (Date):
2019
Days Since Last Rainfall:
Inches:
2
Unknown
Name of M54 Inspector(s) evaluated:
Tony Victor
Observations
Inspector Training/Knowledge
What type of stormwater training does the M54 inspector receive? How often?
NC State Stream Determination Training, other NC State Training
Did the M54 inspector appear knowledgeable about illicit discharge indicators and investigations?
Yes
Inspection Procedures
Does the inspector's process include the use of a checklist or other standardized form?
Yes, laptop checklist
Does the inspector's process include taking photos?
Yes
Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they?
No
NCS000465 Town of Morrisville MS4 Audit_20210210 Page 21 of 26

NCS000465 Town of Morrisville MS4 Audit- ,20210210 Page 22 of 26

Site Visit Evaluation: Construction Site No. 1
Site/Project Name:
Tharnberry at Townhall
Date and Time of Site Visit:
02/10/20211:10pm
Site/Project Address:
Aviation Parkway
Operator:
Beazer Homes
Project Type (Commercial, Industrial, Residential, CIP, Roadway,
etc.): Residential
NCG Permit ID Number:
N/A
Disturbed Acreage:
Approx. 20 acres
Recent Enforcement Actions (Include Date):
Maintenance to erosion control measures (Jan 2021)
Name of MS4 Inspector(s) evaluated:
Jeevan Neupane, Wake County
Name(s) and Title(s) of Site Representative(s) Present During the Site Visit:
Name
Title
N/A
NIA
Observations
Site Documentation/Training
Does the site have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it site -specific?
Yes
Does the site have approved erosion and sedimentation control plans onsite? Are they representative of current site conditions?
Yes
What type of stormwater training do site employees receive? How often?
Joint inspection training from Wake County
Inspector Training/Knowledge
What type of Stormwater training does the M54 inspector receive? How often?
ICWA, NCDOT, NC State
Did the MS4 inspector appear knowledgeable about MS4 and NCG010000 requirements for construction sites?
Yes
Did the M54 inspector appear knowledgeable about erosion and sedimentation control/stormwater pollution prevention BMPs?
Yes
NCS000465_Town of Morrisville MS4 Audit_20210210 Page 23 of 26

Site Visit Evaluation: Construction Site No. 1
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist?
Yes
Does the MS4 inspector's process include taking photos?
Yes
Does the MS4 inspector's process include reviewing approved plans (erosion and sedimentation control and/or SWPPP)?
No
Does the MS4 inspector's process include walking the entire site and inspecting all points of d'scharge?
Yes
Did the MS4 inspector miss any obvious violations? If so, explain:
No
Does the MS4 inspector's process include presenting tht inspection findings to the site contact in writing?
Yes, an inspection report
Does the MS4 inspector's process include providing construction stormwater educational materials to the site contact?
No
Compliance/Enforcement
What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in?
Non-compliance inspection report
If compliance issues were identified, what timeline for correction/follow-up was provided?
2 weeks
Notes/Comments/Recommendations
NCS000465 Town of Morrisville MS4 Audit_20210210 Page 24 of 26

APPENDIX A: SUPPORTING DOCUMENTS
NC5000465 Town of Morrisville MS4 Audit 20210210
Page 25 of 26

APPENDIX B: PHOTOGRAPH LOG
NCS000465 Town of Morrisville MS4 Audit_20210210 Page 26 of 26