NCS000442_Rocky Mount MS4 AUDIT REPORT_20210712

MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM AUDIT REPORT
NPDES PERMIT NO. NCS000442
City of Rocky Mount, NORTH CAROLINA
PO Box 1180
Rocky Mount, NC 27802
Audit Date: June 21, 2021
Report Date: July 12, 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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NCS000442_Rocky Mount MS4 Audit_20210712

TABLE OF CONTENTS
AuditDetails..................................................................................................................................................1
PermitteeInformation..................................................................................................................................2
Listof Supporting Documents....................................................................................................................... 3
Program Implementation, Documentation & Assessment...........................................................................4
Illicit Discharge Detection and Elimination(IDDE)........................................................................................8
Construction Site Runoff Controls..............................................................................................................12
Pollution Prevention and Good Housekeeping for Municipal Operations.................................................16
Site Visit Evaluation: Municipal Facility No. 1.............................................................................................19
Site Visit Evaluation: MS4 Outfall No. 1......................................................................................................21
Site Visit Evaluation: Construction Site No. 1.............................................................................................23
Appendix A: Supporting Documents
Appendix 13: 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 Storm water
Management Plan in accordance with the issued permit.
NCS000442_Rocky Mount MS4 Audit_20210712 ii

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NCS000442_Rocky Mount MS4 Audit_20210712 iii

Audit Details
Audit ID Number:
Audit Date(s):
NCS000442_Rocky Mount MS4 Audit_20210712
June 21, 2021
Minimum Control Measures Evaluated:
❑x Program Implementation, Documentation & Assessment
❑ Public Education & Outreach
❑ Public Involvement & Participation
❑X Illicit Discharge Detection & Elimination
❑ Construction Site Runoff Controls — No delegated Sediment and Erosion Control Program
❑x Construction Site Runoff Controls — Delegated Sediment and Erosion Control Program
❑ Post -Construction Site Runoff Controls
❑X Pollution Prevention and Good Housekeeping for Municipal Operations
❑ Total Maximum Daily Loads (TMDLs)
Field Site Visits:
❑X Municipal Facilities. Number visited: 1
❑X MS4 Outfalls. Number visited: 1
❑X 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
Organization
Thad Valentine
DEMLR — Land Quality Section
Lauren Garcia
DEMLR — Land Quality Section
Audit Report Author:
Signature2z
Date:
Audit Report Author:
Date
Signature
-7l 1 2 l2 l
NCS000442_Rocky Mount MS4 Audit_20210712 Page 1 of 26

Permittee Information
MS4 Permittee Name:
City of Rocky Mount
Permit Effective Date:
02/20/2017
Permit Expiration Date:
02/19/2021
Mailing Address: PO Box 1180, Rocky Mount, NC 27802
Date of Last MS4 Inspection/Audit:
09/11/2013
Co-permittee(s), if applicable:
N/A
Permit Owner of Record: Rochelle D. Small -Toney, City Manager
Primary MS4 Representatives Participating in Audit
Name, Title
Organization
Scott Miles, Stormwater Engineer
City of Rocky Mount
Donald Perry, Assistant City Engineer
City of Rocky Mount
Brad Kerr, Director of Public Works
City of Rocky Mount
MS4 Receiving Waters
Waterbody
Classification
Impairments
Tar River
WS-IV; NSW, CA, B;
NSW
Fish Tissue Mercury
Grape Branch
WS-IV; NSW
Fish Tissue Mercury
Maple Creek
WS-IV; NSW
Fish Tissue Mercury
Stoney Creek
C; NSW
Fish Tissue Mercury, Benthos
Goose Branch
C; NSW
Fish Tissue Mercury
Cowlick Branch
C; NSW
Fish Tissue Mercury
Compass Creek
C; NSW
Fish Tissue Mercury
Hornbeam Branch
C; NSW
Fish Tissue Mercury
Gay Branch (Indian Branch)
C; NSW
Fish Tissue Mercury
Buck Swamp
C; NSW
Fish Tissue Mercury
Beech Brach
B: NSW, C; NSW
Fish Tissue Mercury
Little Cokey Swamp
C; NSW
Fish Tissue Mercury
NCS000442_Rocky Mount MS4 Audit_20210712 Page 2 of 26

List of Supporting Documents
Item
Number
Document Title
When Provided
(Prior to/During/After)
1
SWMP
Prior
2
Organizational Charts
Prior
3
Annual Report
Prior
4
GAP Analysis
During
5
CWEP Agreement
Prior
6
IDDE Program
Prior
7
Rocky Mount Stormwater Design Manual
Prior
8
Erosion Control Site Inspection Blank
During
9
BMP Inspection Report
During
10
Illicit Discharge Incident Summary
During
11
Illicit Discharge Tracking Sheet
During
12
Dry Weather Screening Program PowerPoint and Sign In
During
13
IDDE Poster Training
During
14
Brochures
During
15
Local Program Delegation
Prior
16
Letter of Approval
During
17
Erosion Control Inspection Report Example
During
18
Municipal Facility List
During
19
Spill Response Procedures
During
20
Storm Sewer Operation and Maintenance Plan
During
NCS000442_Rocky Mount MS4 Audit_20210712 Page 3 of 26

21
Street Sweeping SOP
During
22
Pesticide Licenses
After
Program Implementation, Documentation & Assessment
Staff Interviewed:
Scott Miles, Stormwater Engineer
(Name, Title, Role)
Donald Perry, Assistant City Engineer
Brad Kerr, Director of Public Works
Permit Citation
Program Requirement
Status
supporting
Doc No.
II.A.1
The permittee maintained adequate funding and staffing to implement and manage
Staffing and
the provisions of the Stormwater Plan and meet all requirements of the permit.
Yes
Funding
The Stormwater Plan identifies a specific position(s) responsible for the overall
coordination, implementation, and revision to the Plan.
Yes
1, L
Responsibilities for all components of the Stormwater Plan are documented and
position(s) assignments provided.
Yes
1,2
The permittee is current on payment of invoiced administering and compliance
monitoring fees (see stormwater e-payments on DEMLR MS4 web page).
Yes
BIMS
Comments (Briefly describe funding mechanism, number of staff, etc.)
The Stormwater Program is funded by a Utility Fee. It was stated the utility fee adequately covers the Program, and the annual
budget is about $5 million.
The Organizational Charts list titles, positions, and responsibilities. The 2004 SWMP does not include an indication or description of
persons responsible for the implementation and maintenance of the SWMP.
II.A.2 Stormwater
The permittee evaluated the performance and effectiveness of the program
Plan
components at least annually.
Yes
3
Implementation
and Evaluation
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.
Partial
1,4
Did the permitted MS4 discharges cause or contribute to non -attainment of an
applicable water quality standard?
No
---
If yes, did the permittee expand or better tailor its BMPs accordingly to address
Not
the non -attainment?
Applicable
NCS000442_Rocky Mount MS4 Audit_20210712 Page 4 of 26

Program Implementation, Documentation & Assessment
Comments
The SWMP has not been revised since 2004. Efforts to revise and create many documents required by the permit began in 2020 and
the SWMP is currently being revised.
A GAP Analysis was conducted by a consultant and the draft findings was provided to the City of Rocky Mount in May. The GAP
analysis identified missing SOPS, Plans and other deficiencies in the Program.
I I.A.3
Keeping the
The permittee kept the Stormwater Plan up to date.
No
1
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 has not been updated since 2004. The SWMP is currently being revised.
II.A.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
---
Plan
The online materials included ordinances, or other regulatory mechanisms, or a list
identifying the ordinances, or other regulatory mechanisms, providing the legal
Yes
Online
authority necessary to implement and enforce the requirements of the permit.
Comments (Note what materials are available on line)
Only a hard copy of the SWMP was available until it was scanned and provided for the audit. The SWMP was posted on the City of
Rocky Mount Stormwater Management Webpage shortly following the audit and is now available online:
https://www.rockymountnc.gov/UserFiles/Servers/Server_230888/File/Departments/`20&%2OServices/Public%2OWorks/Stormwat
er%20Management/StormwaterManagementPlan.pdf
Stormwater Ordinances are available online and are provided in Chapter 8 of the Rocky Mount Municipal Code. Legal Authority is
addressed in Chapter 8, Section 802:
https://library.municode.com/nc/rocky_mount/codes/code_of_ordinances?nodeld=PTIICOOR_APXALADECO_CH8STMA_S804DECO
MASTMABMFA
II.A.3 & II.A.5
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)
DEMLR did not require a modification.
II.A.6 Sharing
Responsibility
Are any control measures implemented by an entity other than the permittee?
Partial
If yes, is there a written agreement in place?
Yes
NCS000442_Rocky Mount MS4 Audit_20210712 Page 5 of 26

Program Implementation, Documentation & Assessment
Comments (List the specific control measures implemented by others that do not have adequate written agreements, if
applicable)
CWEP implements parts of Public Education and Outreach and Public Involvement.
II.A.7
The permittee maintained written procedures for implementing the six minimum
Written
control measures.
Partial
1,6,7
Procedures
Written procedures identified specific action steps, schedules, resources and
responsibilities for implementing the six minimum measures.
Partial
---
Comments (List the specific minimum measures that do not have adequate written procedures, if applicable)
An IDDE Program was provided as a part of the 2004 SWMP. The Program has not been updated since 2004.
A written procedure for Pollution Prevention and Good Housekeeping was not provided.
A written procedure for Construction Site Runoff Control is not required as compliance with the program is determined by the
Central Office ESC Program Auditor.
The City of Rocky Mount does not own any SCMs, therefore a written procedure/SCM O&M plan is not required. However, the city
still is required to maintain an O&M program for non -municipal SCMs. A City of Rocky Mount Stormwater Design Manual was
provided.
The 2004 Stormwater Management Plan includes a section on Public Education that includes a Public Education Action Report and
Plan. The city also Partners with CWEP to implement Public Education and Public Involvement.
The city is within the process of drafting and implementing written procedures for the minimum control measures. These
documents should identify specific action steps, schedules, resources, and responsibilities for implementing the six minimum
measures.
III. A
The permittee maintained documentation of all program components including, but
Program
not limited to, inspections, maintenance activities, educational programs,
Partial
Documentation
implementation of BMPs, enforcement actions etc., on file for a period of five years.8,
11 ,17
Comments (List the specific program components that do not have adequate documentation on file and why, if applicable)
An example of an erosion control site inspection was shown during the audit. An example of a BMP (SCM) inspection report was
shown during the audit. An IDDE Incident Report was shown during the audit. The City began maintaining an illicit discharge
tracking sheet approximately 1 % years ago (2020).
III.B
The permittee submitted annual reports to the Department within twelve months
Annual Report
from the effective date of the permit (See Section 111.B. for the annual reporting
Yes
3
Submittal
period specific to this MS4).
The permittee submitted subsequent annual reports every twelve months from the
scheduled date of the first annual report submittal.
Yes
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
Yes
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
the proposed changes and how these changes will impact the Stormwater
Yes
Plan (results, effectiveness, implementation schedule, etc.).
NCS000442_Rocky Mount MS4 Audit_20210712 Page 6 of 26

Program Implementation, Documentation & Assessment
3. Documentation of any necessary changes to programs or practices for
assessment of management measures implemented through the Stormwater
Yes
Plan.
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
Yes
Stormwater Plan.
5. An assessment of compliance with the permit, information on the
establishment of appropriate legal authorities, inspections, and enforcement
Yes
3
actions.
Comments (Note dates that annual reports cover under current permit and generally describe report deficiencies, if any)
The city submits annual reports through BIMS.
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.
Yes
3
2. A description of the effectiveness of each program component.
Yes
3
3. Planned activities and changes for the next reporting period, for each
program component or activity.
Yes
4. Fiscal analysis.
Yes
Comments (Note dates that annual reports cover under current permit and generally describe report deficiencies, if any)
The city submits annual reports through BIMS.
Additional
Comments:
NCS000442_Rocky Mount MS4 Audit_20210712 Page 7 of 26

Illicit Discharge Detection and Elimination (IDDE)
Staff Interviewed:
Scott Miles, Stormwater Engineer
(Name, Title,
Donald Perry, Assistant City Engineer
Role)
Brad Kerr, Director of Public Works
Permit Citation
Program Requirement Status Supporting
Doc No.
II.D.2.a
IDDE Program
The permittee maintained a written IDDE Program. Yes
If yes, the written program includes provisions for program assessment and
No
evaluation and integrating program.
Comments (Note any deficiencies)
The IDDE Program has not been updated since 2004. It does not include provisions for program assessment and evaluation.
The permittee maintained an IDDE ordinance or other regulatory mechanism(s) that
II.D.2.b
provides the legal authority to prohibit illicit connections and discharges to the MS4.
Yes
Online
Legal Authorities
If yes, the ordinance applies throughout the corporate limits of the permittee.
(Permit Part I.D)
Yes
---
Comments
The IDDE Ordinance is present in Chapter 10, Article 5 of the Rocky Mount Municipal Code. Applicability is addressed in Section 10-
211 of Article 5.
II.D.2.c
The permittee maintained a current map showing major outfalls* and receiving
Storm Sewer
Yes
---
System Map
streams.
Comments
The map is maintained in a GIS Database. Major outfalls are a map layer, but the size of all outfalls are shown in the map.
*Major outfalls are discharges from > 36" diameter pipes or drainage areas of > 50 acres. In areas zoned for industrial activity, major outfalls
are > 12" or drainage area > 2 acres.
NCS000442_Rocky Mount MS4 Audit_20210712 Page 8 of 26

Illicit Discharge Detection and Elimination (IDDE)
II.D.2.d
The permittee maintained a program for conducting dry weather flow field
Dry Weather Flow
observations in accordance with written procedures.
Yes
6, 12
Program
Comments (Generally summarize program, including frequency of observations and # or % of outfalls screened)
Dry weather flow is identified in the 2004 IDDE section of the SWMP as "Field Screening." Field Screening procedures, reporting,
identification and removal are included in this section.
Dry weather screening was not implemented until February 2020. A Dry Weather Screening Training powerpoint was developed to
train ditch crews in how to detect an illicit discharge during ditch maintenance. An Illicit Discharge Detection and Elimination Poster
was also developed to train ditch crews.
The Field Screening Reporting Information includes sampling analysis, like testing for temperature, pH, nitrogen, etc. when illicit
discharge sources cannot be identified; however, it was stated during the outfall site visit that this is not something the City does.
Currently, the City's dry weather screening implementation methods do not match what is listed in the 2004 SWMP.
A formal plan should be developed and consistently implemented.
II.D.2.e
The permittee maintained written procedures for conducting investigations of
Investigation
identified illicit discharges.
Yes
6
Procedures
Comments (Generally describe what procedures are documented)
Included on Pages 27-30 of the SWMP (IDDE Program).
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 dates) the illicit discharge was observed
Yes
2. The results of the investigation
Yes
3. Any follow-up of the investigation
Yes
9
4. The date the investigation was closed
Yes
9
Comments (Note whether a standard inspection form is utilized to capture consistent information and a tracking mechanism is
used)
Illicit discharge events are recorded in an excel spreadsheet. Details for each discharge are recorded in individual word documents.
Results of the investigation are recorded in the spreadsheet and in the work document. Follow-up investigation details are included
in the word document. The date the investigation was closed is included in the word document.
NCS000442_Rocky Mount MS4 Audit_20210712 Page 9 of 26

Illicit Discharge Detection and Elimination (IDDE)
II.13.2.g Employee
The permittee implemented and documented a training program for appropriate
Training
municipal staff who, as part of their normal job responsibilities, may come into
Partial
12,13
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)
An IDDE training program was not drafted and implemented until 2020. The city began implementing dry weather flow inspections
by training ditch crews to perform inspections and identify illicit discharges. The training materials include a poster that targets
IDDE training and a PowerPoint presentation that is used to train ditch crews to conduct dry weather flow inspections and identify
illicit discharges.
The city should modify training to include all appropriate municipal staff who may come into contact or observe an illicit discharge/
illicit connection.
II.D.2.h
The permittee informed public employees of hazards associated with illegal
Public Education
discharges and improper disposal of waste.
Yes
14
The permittee informed businesses of hazards associated with illegal discharges and
improper disposal of waste.
Partial
14
The permittee informed the general public of hazards associated with illegal
discharges and improper disposal of waste.
Yes
14
Comments (Note how each sector was informed, if applicable)
CWEP provides printable material for Rocky Mount to provide to the Public. The Rocky Mount SW Program also creates and
provides brochures. Brochures and printable material are left at libraries and schools. They are also distributed during Stormwater
Awareness Week. Rocky Mount also has a local channel where Stormwater Advertisements are run.
The city does not do any specific stormwater outreach to businesses. However, brochures are distributed in public places.
II.D.2.91
The permittee promoted, publicized, and facilitated a reporting mechanism for the
Public Reporting
public to report illicit discharges.
Yes
Online
Mechanism
The permittee promoted, publicized, and facilitated a reporting mechanism for staff
to report illicit discharges.
Yes
The permittee established and implemented response procedures for citizen
requests/reports.
No
Comments (Generally describe reporting mechanisms and how promoted/publicized/facilitated/established)
Rocky Mount has a stormwater hotline available on the Stormwater management Webpage:
https://www.rockymountnc.gov/departments/public_works/stormwater_management#:-:text=For%20information%2C%20contac
t%20our%20Stormwater,at%20252%2D972%2D1500. City Staff use the hotline or call Scott Miles.
Response procedures for citizen complaints are currently being drafted and will be included in the new SWMP.
NCS000442_Rocky Mount MS4 Audit_20210712 Page 10 of 26

Illicit Discharge Detection and Elimination (IDDE)
II.D.2.1
The permittee implemented a mechanism to track the issuance of notices of violation
Enforcement
and enforcement actions administered by the permittee.
Partial
10
If yes, the mechanism includes the ability to identify chronic violators for
Not
initiation of actions to reduce noncompliance.
Applicable
Comments (Generally describe the established tracking mechanism, if applicable)
The city has never issued an NOV. Information about the NOV would be included in the IDDE tracking Spreadsheet.
An illicit discharge was discovered when ditch crews found dye at an outfall. The discharge was investigated and traced back to a
company called Stretchline. Samples were taken and dye testing was performed to see how dye was getting into the outfall. The
investigation was concluded when no illicit connections were found. There has been no additional observations of dye in the outfall.
An NOV was not issued.
Additional
Comments:
NCS000442_Rocky Mount MS4 Audit_20210712 Page 11 of 26

Construction Site Runoff Controls
Staff Interviewed:
Scott Miles, Stormwater Engineer
(Name, Title, Role)
Donald Perry, Assistant City Engineer
Brad Kerr, Director of Public Works
Program Delegation Status:
❑X 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 DEMLR 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., les
Online
NCS000435] promoting the existence of the DEQ DEMLR "Stop Mud" hotline).
Comments (Describe how provided and promoted)
Rocky Mount has a stormwater notiine available on the Stormwater management Webpage:
https://www.rockymountnc.gov/departments/public_works/stormwater_management#:—:text=For%20information%2C%20contac
t%20our%20Stormwater,at%20252%2D972%2D1500 -ity Staff use the hotline or call Scott Miles
SPCA Citation
I Delegated Program Requirement
Status
Supporting
Doc No.
§ 113A-60 Local
erosion and
The permittee has adopted an ordinance or other regulatory mechanism to enforce
15,
sedimentation
the erosion and sedimentation control program.
Online
control programs (a)
If yes, the ordinance meets or exceeds the minimum requirements of the
15,
SPCA.
Yes
Online
If yes, the ordinance applies throughout the corporate limits of the permittee.
15,
[Permit Part I.D]
Online
Comments (Provide regulatory mechanism reference or Supporting Documentation number)
Sediment and erosion control is included in Chapter 8, Section 801 of the Rocky Mount Municipal Code:
https://library.municode.com/nc/rocky_mount/codes/code_of_ordinances?nodeld=PTIICOOR_APXALADECO_CH8STMA_S801SOER
SECO.
§ 113A-60 Local
erosion and
The permittee collects a fee paid by each person who submits an erosion and
sedimentation
sedimentation control plan.
Yes
control programs (d)
NCS000442_Rocky Mount MS4 Audit_20210712 Page 12 of 26

Construction Site Runoff Controls
Comments (indicate the fee amount, if applicable)
The review is $50/acre.
§ 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
---
sedimentation
absence of an approved plan?
control programs (e)
If yes, the permittee has notified the North Carolina Sedimentation Control
Not
Commission of all such cases.
Applicable
Has the permittee determined that a person engaged in a land -disturbing activity
has failed to comply with an approved erosion and sedimentation control plan?
Yes
---
If yes, has the permittee referred any such matters to the North Carolina
Not
Sedimentation Control Commission for inspection and enforcement?
Applicable
_
Comments
The city has had one incident where a land disturbing activity began without an approved plan. The city required them to install
erosion control measures and the owners are currently working on submitting plans.
The city does not issue NOVs and focusses more on bringing sites back into compliance.
§ 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
---
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
determining that it complies with all applicable State and local regulations.
Yes
16
The permittee has disapproved of an erosion and sedimentation control plan in
Not
order to protect riparian buffers along surface waters.
Applicable
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
A Letter of Approval was provided during the audit. The city provides comments after plan reviews and does not approve plans until
all comments have been addressed. Plan reviews do not take the full 30 days. The city does not issue Letter of Disapproval.
The city should make sure that plan review does not surpass a 30 day review period so that plans are not approved by default.
NCS000442_Rocky Mount MS4 Audit_20210712 Page 13 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
16
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
17
erosion and sedimentation control plan are effective.
Comments
A notice of a right to inspect is included in the Letter of Approval. Inspections are conducted regularly. The city has two erosion
control inspectors.
At this time there at 10 active construction sites in Rocky Mount. Formal inspections are performed once a month and results are
recorded in inspection reports. Sites are informally inspected at least once a week. The results of these inspections are not always
recorded in reports.
§ 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
No
---
disturbing activity;
violation upon that person.
notice of violation
Each notice of violation issued by the permittee specifies the date by which the
Not
(c)
person must comply.
Applicable
Each notice of violation issued by the permittee informs the person of the actions
Not
that need to be taken to comply.
Applicable
Comments
The city does not issue NOVs. The city works with sites to bring them back into compliance.
113A-64 Penalties
Does the permittee issue civil penalties as part of the erosion and sedimentation
program?
No
Comments (indicate when/why a civil penalty is issued, and the amount, if applicable)
The city has never issued a civil penalty. The city works with sites to bring them back into compliance.
NCS000442_Rocky Mount MS4 Audit_20210712 Page 14 of 26

Construction Site Runoff Controls
Additional
Comments:
NCS000442_Rocky Mount MS4 Audit_20210712 Page 15 of 26

Pollution Prevention and Good Housekeeping for Municipal Operations
Staff Interviewed:
Scott Miles, Stormwater Engineer
(Name, Title, Role)
Donald Perry, Assistant City Engineer
Brad Kerr, Director of Public Works
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
stormwater runoff.
Comments (Note number of facilities, typical inventory data and any facilities that are not inventoried that should be)
The city has an excel spreadsheet where all city owned facilities are recorded. The facilities are categorized into high, medium and
low hazards for generating polluted stormwater runoff.
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
No
---
Maintenance (O&M)
stormwater runoff.
for Facilities
If yes, the 0&M program specifies the frequency of inspections.
No
---
If yes, the 0&M program specifies the frequency of routine maintenance
No
---
requirements.
If yes, the permittee evaluated the O&M program annually and updated it as
No
---
necessary.
Comments
The city is currently drafting an operation and maintenance program for municipal owned and operated facilities with the potential
for generating stormwater runoff.
This program should specify the frequency of inspections and routine maintenance requirements.
II.G.2.c
Spill Response
The permittee had written spill response procedures for municipal operations.
Yes
19
Procedures
Comments
Spill response procedures were provided during the audit.
It is recommended that specific contacts be added to the Spill Response Procedures.
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
Partial
20,21
corporate limits annually.
NCS000442_Rocky Mount MS4 Audit_20210712 Page 16 of 26

Pollution Prevention and Good Housekeeping for Municipal Operations
Parking Lots
If yes, the permittee evaluated the effectiveness of existing and new BMPs
Maintenance
No
21
based on cost and the estimated quantity of pollutants removed.
Comments
A street Sweeping SOP was recently drafted. Yard waste is collected weekly. Tonnage and amount collected is included in the
annual report.
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
partial
20
Basins and
Conveyance Systems
maintains.
Comments (Briefly describe O&M program)
An Operation and Maintenance Plan for municipally owned and maintained catch basins and conveyance systems was recently
drafted.
II.G.2.e
The permittee maintained a current inventory of municipally -owned or operated
Structural
structural stormwater controls installed for compliance with the permittee's post-
---
Applicable
Stormwater Controls
construction ordinance.
Comments (Describe inventory information and number of controls in inventory)
There are no city owned SCMs in Rocky Mount. The city does perform inspections of HOA SCMs as a curtesy.
II.G.2.h
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
Not
Applicable
Stormwater Controls
the permittee's post -construction ordinance. If yes, then:
The O&M program specified the frequency of inspections and routine
Not
maintenance requirements.
Applicable
The permittee documented inspections of all municipally -owned or maintained
Not
structural stormwater controls.
Applicable
_
The permittee inspected all municipally -owned or maintained structural
Not
stormwater controls in accordance with the schedule developed by permittee.
Applicable
The permittee maintained all municipally -owned or maintained structural
Not
stormwater controls in accordance with the schedule developed by permittee.
Applicable
The permittee documented maintenance of all municipally -owned or
Not
maintained structural stormwater controls.
Applicable
Comments
There are no city owned SCMs in Rocky Mount.
II.G.2.i
The permittee ensured municipal employees are properly trained in pesticide,
herbicide and fertilizer application management.
Yes
22
NCS000442_Rocky Mount MS4 Audit_20210712 Page 17 of 26

Pollution Prevention and Good Housekeeping for Municipal Operations
Pesticide, Herbicide
The permittee ensured contractors are properly trained in pesticide, herbicide and
Not
and Fertilizer
fertilizer application management.
Applicable
Application
Management
The permittee ensured all permits, certifications, and other measures for
applicators are followed.
Yes
2'L
Comments
Only city employees apply pesticides. Certifications are up to date.
II.G.2.j
The permittee implemented an employee training program for employees involved
Staff Training
in implementing pollution prevention and good housekeeping practices.
No
---
Comments
There is no employee training program for employees involved in implementing pollution prevention and good housekeeping
practices.
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
No
---
Equipment Cleaning
cleaning.
Comments
There is a wash station at the Rocky Mount Fleet Maintenance Facility. Wash water goes to an oil/water separator.
Measures to prevent or minimize contamination of stormwater runoff from areas used for vehicle and equipment cleaning should
be included in the 0&M Plan of facility SWPPP.
Additional
Comments:
NCS000442_Rocky Mount MS4 Audit_20210712 Page 18 of 26

Site Visit Evaluation: Municipal Facility No. 1
Facility Name:
eet Maintenance
Date and Time of Site Visit:
6/21/21; 12:30pm-1:30pm
Facility Address:
106 E Grand St
Facility Type (Vehicle Maintenance, Landscaping, etc.):
Vehicle Maintenance
Name of MS4 inspector(s) evaluated:
Scott Miles, Stormwater Engineer
Most Recent MS4 Inspection (List date and name of inspector):
April 7, 2021
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
What type of stormwater training do facility employees receive? How often?
Facility employees do not receive any formal training. Any training is at the discretion of individual site personnel.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
NC State SCM Training, on the job training, conferences, etc.
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form?
Ye
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
NCS000442_Rocky Mount MS4 Audit_20210712 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 did not make sure drums were capped or properly closed in storage. There were no spill kits observed inside the
maintenance facility. Dumpsters were stored outside without lids, some with large holes, and without bottom caps. A smashed car
was parked outside. No pan or way to contain leaking fluid was placed under the car. Staining was observed throughout the facility.
Oil and other fluids were spilled on the ground of the maintenance facility in several places. A used oil dumpster is stored outside.
Oil boons are placed around it. Waste material has collected around the boons and the boons are damaged. There is waste material
that has collected inside, on and around used oil and other waste storage.
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)?
General good housekeeping requirements.
The facility is not covered under an NCG080000 General Industrial Permit.
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
As soon as possible.
Notes/Comments/Recommendations
The facility should be covered under an NCG08.
NCS000442_Rocky Mount MS4 Audit_20210712 Page 20 of 26

Site Visit Evaluation: MS4 Outfall No. 1
Outfall ID Number:
Date and Time of Site Visit:
Not provided
6/21/21; 2:00 pm — 2:30 pm
Outfall Location:
Outfall Description (Pipe Material/Diameter, Culvert, etc.):
East Thomas and Atlantic Avenue
Gabion Basket Channel
Receiving Water:
Is Flow Present? If So, Describe (Color, Approximate Flow Rate,
Parkers Canal
Sheen, Odor, Floatables/Debris, etc.):
Clear, trickling, no odor of floatables
Trash present
Most Recent Outfall Inspection/Screening (Date):
Nc
Days Since Last Rainfall:
Inches:
6/20/21
Not provided
Name of MS4 Inspector(s) evaluated:
Ditch Crew
Observations
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
Dry weather flow IDDE training
Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations?
Inspection Procedures
Does the inspector's process include the use of a checklist or other standardized form?
Does the inspector's process include taking photos?
As needed
Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they?
No
NCS000442_Rocky Mount MS4 Audit_20210712 Page 21 of 26

Site Visit Evaluation: MS4 Outfall No. 1
Inspection Results
Did the outfall inspection result in any work orders or maintenance requests? If so, for what issue(s)?
No
Will a follow-up outfall inspection be conducted? If so, for what reason?
N/A
Notes/Comments/Recommendations
NCS000442_Rocky Mount MS4 Audit_20210712 Page 22 of 26

Site Visit Evaluation: Construction Site No. 1
Site/Project Name:
NC Wesleyan Synthetic Field
Date and Time of Site Visit:
6/21/21; 1:30 pm —1:45 pm
Site/Project Address:
Bishops Rd
Operator:
Not provided
Project Type (Commercial, Industrial, Residential, CIP, Roadway,
etc.): Commercial
NCG Permit ID Number:
N/A
Disturbed Acreage:
4.2
Recent Enforcement Actions (Include Date):
N/A
Name of M54 Inspector(s) evaluated:
Alan Goff, EC Inspector
Name(s) and Title(s) of Site Representative(s) Present During the
Site Visit:
Name
Title
N/A
Observations
Site Documentation/Training
Does the site have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it site -specific?
N/A
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?
None
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
On the job training
Did the MS4 inspector appear knowledgeable about MS4 and NCGO10000 requirements for construction sites?
Partial
Did the MS4 inspector appear knowledgeable about erosion and sedimentation control/stormwater pollution prevention BMPs?
Yes
NCS000442_Rocky Mount MS4 Audit_20210712 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?
As needed
Does the MS4 inspector's process include reviewing approved plans (erosion and sedimentation control and/or SWPPP)?
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 violations? If so, explain:
Inspector gave the OK for contractor to remove temporary diversions prematurely. The site is in-between contractors, and the site
has not been stabilized. A stockpile is located adjacent to the basin within 50ft. There was no NCG01 COC in the onsite permits box.
Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing?
Yes
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?
Silt fence will need to be repaired/re-installed where applicable. Stockpile should be relocated. Site should be seeded.
If compliance issues were identified, what timeline for correction/follow-up was provided?
Notes/Comments/Recommendations
NCS000442_Rocky Mount MS4 Audit_20210712 Page 24 of 26

APPENDIX A: SUPPORTING DOCUMENTS
NCS000442_Rocky Mount MS4 Audit_20210712 Page 25 of 26

APPENDIX B: PHOTOGRAPH LOG
NCS000442_Rocky Mount MS4 Audit_20210712 Page 26 of 26