NCS000442_Rocky Mount Self Audit_20210805

Technical Memorandum

Limitations:
This document was prepared solely for the City of Rocky Mount in accordance with professional standards at the time the services were performed
and in accordance with the contract between Rocky Mount and Brown and Caldwell dated February 4, 2021. This document is governed by the
specific scope of work authorized by Rocky Mount; it is not intended to be relied upon by any other party except for regulatory authorities
contemplated by the scope of work. We have relied on information or instructions provided by Rocky Mount and other parties and, unless otherwise
expressly indicated, have made no independent investigation as to the validity, completeness, or accuracy of such information.
5430 Wade Park Boulevard, Suite 200
Raleigh, NC 27607

T: 919.233.9178

Prepared for: City of Rocky Mount
Project Title: Rocky Mount MS4 Gap Analysis
Project No.: 156340
Technical Memorandum
Subject: MS4 Gap Analysis Report
Date: June 16, 2021, 2021
To: Scott Miles, City of Rocky Mount
From: Victoria Blackwell, Task Order Manager
Copy to: Stephanie Hanses, Contract Manager

Prepared by:
Victoria Blackwell, Task Order Manager

Reviewed by:
Stephanie Hanses, Contract Manager

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Table of Contents
List of Figures ............................................................................................................................................................ ii
List of Tables .............................................................................................................................................................. ii
Section 1: Introduction ............................................................................................................................................. 1
Section 2: Data Gathering ........................................................................................................................................ 2
Section 3: Results of the MS4 Self Audit ................................................................................................................ 2
Section 4: Pollution Prevention and Good Housekeeping Evaluation .................................................................. 7
4.1 Municipal Facility Inventory Evaluation ........................................................................................................... 7
4.2 Municipal Facility Visits .................................................................................................................................... 8
4.3 Observations ..................................................................................................................................................... 8
4.3.1 Spill Kits and Spill Response ............................................................................................................ 8
4.3.2 Waste Storage .................................................................................................................................... 9
4.3.3 Inlet Protection: ................................................................................................................................ 11
4.4 Recommendations ......................................................................................................................................... 12
Section 5: Next Steps ............................................................................................................................................. 13
References .............................................................................................................................................................. 13
Attachment A: DEQ Phase II Audit Template ....................................................................................................... A-1
Attachment B: Meeting and Site Visit Summaries .............................................................................................. B-1
Attachment C: Pollution Prevention and Good Housekeeping Field Audit Template ........................................ C-1
Attachment D: Municipally Owned Facilities for PPGH Program ........................................................................ D-5

List of Figures
Figure 4-1. Spill response signage .......................................................................................................................... 9
Figure 4- 2. Improper Waste Oil Storage ............................................................................................................... 10
Figure 4-3. Improper Dumpster Storage ............................................................................................................... 11
Figure 4-4. Inlet Obstruction .................................................................................................................................. 12

List of Tables
Table 3-1. High Priority MS4 Program Recommendations ................................................................................... 3
Table 3-2. Medium Priority MS4 Program Recommendations .............................................................................. 4
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Table 3-3. Low Priority Program Recommendations .............................................................................................. 5

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Section 1: Introduction
The City of Rocky Mount (City) was issued its current individual Phase II Municipal Separate Storm Sewer
System (MS4) Permit (Permit No. NCS000442) by the North Carolina Department of Environmental Quality
(DEQ) Division of Energy, Mineral, and Land Resources (DEMLR) on February 20, 2017. In response to a U.S.
Environmental Protection Agency (EPA) compliance initiative in North Carolina, DEQ began audits of Phase II
MS4 permittees in 2019. The City audit is scheduled to occur sometime in calendar year 2021.
At that time, the City will be expected to demonstrate compliance with the requirements of the current MS4
permit. It is anticipated that the audit will be conducted using a standard template with a series of questions
as presented in the DEQ Draft Phase II Permit Audit Template (North Carolina DEQ, 2019) (shown in
Attachment A). As a part of the audit, DEQ will request supporting documentation, conduct City staff
interviews, and perform site visits with City staff.
The purpose of this report is to evaluate the City’s current MS4 program documents and operations, outline
the requirements in the City’s MS4 permit and the audit template, and assess the City MS4 program. Brown
and Caldwell (BC) conducted a gap analysis process which included a request for information from the City
about current program operations, records, and procedures; and interviews with City staff responsible for
implementing or supporting components of the MS4 permit. The term gap in this process refers to: 1) areas
identified by BC that are either explicitly cited in the NPDES MS4 permit or 2) elements identified within the
DEQ Phase II MS4 Audit template that require additional documentation and/or procedural updates by the
City to be in compliance. Based on a review of the data, materials, and observations gathered through this
effort, BC identified gaps in the current MS4 program and developed recommended actions to address
those gaps. In general, the key observations from the gap analysis are:
• Documentation for current program operations and procedures should be strengthened. Key programs
required by the permit should be well documented to demonstrate compliance with permit
requirements.
• Records associated with maintenance and inspection activities should be maintained in such a way that
chronic violators and areas of repeat issues can easily be identified and addressed.
• A process for enforcement of notices of violations (NOVs) should be developed to address hazards to the
stormwater system and compliance with the MS4 permit.
This report also evaluates the existing municipal Pollution Prevention and Good Housekeeping (PPGH)
program. BC reviewed the City’s existing inventory of municipal facilities to identify sites with significant
potential for pollution. The evaluation included assessing property use based on aerial imagery and then by
conducting facility inspections. Results of this effort are detailed further in Section 4 of this report. Some key
observations from this aspect of the gap analysis included:
• There is a need for standardized procedures and defined expectations for municipally owned facilities to
meet PPFH permit requirements especially associated with spill prevention and spill response
preparedness.
• The Stormwater Management Division should clearly define responsibilities and coordinate with owning
departments for implementation at their facilities. Once responsibilities are outlined and agreed upon,
the Stormwater Management Department should provide templates and guidance documents for how
facilities should carry out and document heir identified responsibilities.

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Section 2: Data Gathering
Data included in this report were provided by the City based on the current program. In January and February
2021, City staff provided example work products, standard operating procedures (SOPs), forms, and data
related to activities covered by the MS4 permit, including:
• Public Education, Outreach, and Involvement
• Illicit Discharge Detection and Elimination (IDDE)
• Stormwater Control Measure (SCM) and Erosion & Sediment Control (E&SC) Design and Construction
• SCM Inspections and Maintenance
• Pollution Prevention and Good Housekeeping and Industrial Inspections
• Asset Inspections and Maintenance
Following a review of the provided data, BC conducted interviews with staff from the Stormwater
Management Division who have responsibilities relevant to the MS4 permit requirements. City staff
responsible for one or more permit requirements were invited to discuss the processes and procedures they
use to implement the identified permit requirements. A schedule of all meetings held, including a list of
attendees, topics, and meeting summaries is presented in Attachment B.
The results of the data review, division and departmental interviews, and site visits were compiled and
analyzed for compliance gaps. Emphasis was placed on standard procedures (including whether SOPs and
standard templates/checklists have been developed), and documentation/reporting mechanisms.
For the PPGH program review, a list of City-owned facilities was generated from the 2019-2020 City Property
Schedule. From this list, sites were classified based on the type of activities that could be conducted on -site.
Sites that included activities with potential to cause significant pollution to the stormwater system were
considered for field visits by BC staff for further evaluation. Five sites were selected for field visits and were
assessed based on the field form and discussions with City staff at each facility that can be found in
Attachment C.
Section 3: Results of the MS4 Self Audit
The following section is organized based on the DEQ Phase II Audit template (Attachment A) and City
programs that implement elements of the MS4 permit. The audit template includes questions about each
area of the permit, from procedures and protocols to reporting and tracking, to verify program
implementation. The audit template allows “Yes”, “No”, “Partial”, and “Not Applicable” responses. A “Yes”
indication denotes a program element that appears to be compliant with the permit requirement or audit
question, while a “No” denotes the lack of compliance. A “Partial” indication denotes a program element
that meets a portion of the permit requirement or audit question .”No” and “Partial” responses represent a
program gap for the purpose of this report. Tables 3-1,3-2 and 3-3 1 includes a summary of program
recommendations to address the gaps identified. Recommendations are provided for program elements that
are rated either “No” or “Partial” on the DEQ Phase II Audit template (Attachment A). High priority
recommendations include those permit areas that do not currently have program documentation to
represent the actions of the program. The program elements listed in Table 3-1 represent the program
elements that are recommended to be addressed in the near term (within 1 year). Each of the program
elements also require coordination throughout the department that elevates the priority.
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Table 3-1. High Priority MS4 Program Recommendations
Audit/Permit Section Program Element Program Requirement Program Recommendations and Suggested Improvements
Illicit Discharge Detection and Elimination
II.D.2.a IDDE Program The permittee maintained a written IDDE Program.
If yes, the written program includes provisions for program assessment and evaluation and integrating program.
The City should develop a written program document that outlines goals/objectives, program process steps, and provision for
program assessment and evaluation. The written plan should include schedules for required activities, references to SOPs detailing
how to complete required activities, reporting and documentation procedures, enforcement procedures, and training requirements
where necessary.
II.D.2.d Dry Weather Flow Program The permittee maintained a program for conducting dry weather flow field observations in accordance with written
procedures.
The city's ditch work crews conduct visual inspections during their normal maintenance activities and report observances in daily
activity reports. The City should formalize and document this activity as a part of the dry weather screening program and provide
training to all personnel who will engage with dry-weather screening.
II.D.2.f Tracking and Document Investigations
For each case of an illicit discharge or potential illicit discharge, the permittee documented and tracked the
following:
1. The date(s) the illicit discharge was observed
2. The results of the investigation
3. Any follow-up of the investigation
4. The date the investigation was closed
Investigation tracking documentation includes the date the illicit discharge was observed and the results of the investigation. The
City should also include any follow-up to the initial investigation and the close-out date of the investigation to the tracking
documentation.
II.D.2.g Employee Training The permittee implemented and documented a training program for appropriate municipal staff who, as part of their
normal job responsibilities, may come into contact with or otherwise observe an illicit discharge or illicit connection.
The City held a training session in February 2020 that included many supervisory staff. The City should plan to provide consistent,
ongoing IDDE training opportunities for staff included in executing the IDDE program.
II.D.2.i Public Reporting Mechanism The permittee established and implemented response procedures for citizen requests/reports.
During department interviews, staff indicated that the response and directing for public complaints is a known process for identifying
the appropriate City contact to forward the request and following up as necessary. Documenting the response procedure and making
it available to staff that receive public calls would change to a “Yes” status.
II.D.2.j Enforcement
The permittee implemented a mechanism to track the issuance of notices of violation and enforcement actions
administered by the permittee.
If yes, the mechanism includes the ability to identify chronic violators for initiation of actions to reduce
noncompliance.
The City maintains a list for illicit discharge violations catalogued by site location. The City should build in a mechanism in the
current tracking document to capture chronic violators in noncompliance.
Pollution Prevention and Good Housekeeping
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.
The inventory is maintained by the Risk Management and Facilities Management Department. The current City inventory list is
maintained according to insured City property and likely includes all properties with high and medium potential to cause significant
pollution. The City should devise a comprehensive facility inventory list specific to stormwater pollution prevention to confirm
whether all municipal sites are accounted for; this may include a review of the current list and all municipal properties identified by
the County Property Appraiser’s Office.
II. G.2.b,c 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.
If yes, the O&M program specifies the frequency of inspections.
If yes, the O&M program specifies the frequency of routine maintenance requirements.
If yes, the permittee evaluated the O&M program annually and updated it as necessary.
The City should develop an inspection and maintenance program for municipal facilities and operations that have been determined
to have significant potential for generating polluted stormwater runoff. The program should include inspection frequencies, routine
maintenance requirements, procedures to update the facility and operations inventory and identification of properties with potential
to cause significant pollution, and annual assessment of program performance. It is recommended that the development of this plan
is completed in coordination with owning departments to identify roles and responsibilities, as well as document existing and
ongoing practices.
The permittee had written spill response procedures for municipal operations.
The City should develop a spill response procedure for municipal operations and facilities. It is recommended that the development
of this plan is completed in coordination with owning departments to identify roles and responsibilities, as well as document existing
and ongoing practices .
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.
If yes, the permittee evaluated the effectiveness of existing and new BMPs based on cost and the estimated quantity
of pollutants removed.
The City currently performs streets, roads, and public parking maintenance in the form of leaf/yard waste collection, street sweeping,
mowing, and inlet cleaning. The City should include annual evaluation of effectiveness of Best Management Practices (BMPs)
utilized in municipally owned streets, roads, and public parking lots.
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Table 3-1. High Priority MS4 Program Recommendations
Audit/Permit Section Program Element Program Requirement Program Recommendations and Suggested Improvements
II.G.2.f MS4 Conveyance System Inspection and
Maintenance
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.
The City currently performs maintenance activities on conveyance systems and ditches. Maintenance responsibilities are shared
among City construction crews, ditch maintenance crews, and contractors as needed. The City should develop an inspection and
maintenance program document that includes the MS4 including catch basins and the conveyance system.
II.G.2.j Staff Training The permittee implemented an employee training program for employees involved in implementing pollution
prevention and good housekeeping practices.
The City should develop required training for employees on pollution prevention and good housekeeping practices, specifically spill
prevention, storm drain maintenance, and avoiding polluted runoff.
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. The City should develop guidance for vehicle and equipment washing and maintenance practices that prevent stormwater pollution.

Table 3-2 lists the medium priority recommendations. These program elements have been classified as medium priority as they require a more consistent and time intensive effort to complete (e.g. program implementation and post
construction site runoff controls design). Medium priority is also assigned to program elements that maintain partial documentation and robust program activity in alignment with permit requirements (e.g. public education and
outreach).

Table 3-2. Medium Priority MS4 Program Recommendations
Audit/Permit Section Program Element Program Requirement Program Recommendations and Suggested Improvements
Program Implementation
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.
The Stormwater Management Plan should identify specific roles responsible for the overall coordination, implementation, and
updates to the Plan; responsibilities for all components of the Stormwater Management Plan (SWMP) should be documented and
position(s) assignments provided.
The Stormwater Plan identifies a specific position(s) responsible for the overall coordination, implementation, and
revision to the Plan.
Responsibilities for all components of the Stormwater Plan are documented and position(s) assignments provided.
The City should perform an annual staffing evaluation to determine resources needed to operate the MS4 in compliance with the
current permit.
II.A.2 Stormwater Plan Implementation and Evaluation The permittee evaluated the performance and effectiveness of the program components at least annually. The City should conduct an annual review to evaluate the performance and effectiveness of the stormwater division at meeting the
MS4 permit requirements. Any changes to the SWMP that result should be reported to DEMLR.
II.A.3 Stormwater Management Plan (SWMP)
The permittee kept the Stormwater Plan up to date.
The City should update the SWMP to reflect the current permit. DEQ templates are available to aid in Plan updates
https://files.nc.gov/ncdeq/Energy%20Mineral%20and%20Land%20Resources/Stormwater/MS4_Documents/2021-SWMP-
Template-20210309.docx
The permittee notified DEMLR of any updates to the Stormwater Plan. The City should submit the updated SWMP to DEMLR.
II.A.7 Written Procedures
The permittee maintained written procedures for implementing the six minimum control measures.
Written procedures identified specific action steps, schedules, resources and responsibilities for implementing the
six minimum measures.
The City currently performs inspection, maintenance, reporting, and enforcement activities. The City should develop and implement a
written plan incorporating goals/objectives and evaluations for each of the following program areas:
• IDDE Plan
• MS4 O&M Plan
The written plan should include schedules for required activities, references to SOPs detailing how to complete required activities,
reporting and documentation procedures, enforcement procedures, and training requirements where necessary.
Note that typically SCM O&M Plan would be included as a part of the written procedures, however because the City does not
currently operate municipally owned SCMs a written procedure is not applicable.
Public Education and Outreach
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Table 3-2. Medium Priority MS4 Program Recommendations
Audit/Permit Section Program Element Program Requirement Program Recommendations and Suggested Improvements
II. B. 2.a -d Goals, Objectives, Target Pollutants, Target
Audiences
The permittee defined goals and objectives of the Local Public Education and Outreach Program based on
community wide issues.
The permittee maintained a description of the target pollutants and/or stressors and likely sources.
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.
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.

The City should maintain a document that records the defined goals and objectives, a description of target pollutants and sources
the program is designed to address, target audiences likely to have significant stormwater impact, and why they were selected. These
details were provided verbally during the public education and involvement department interview. This information may be recorded
within the SWMP or an external City document.
II.B.2.H Public Education and Outreach Program 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.
The City gets outreach and exposure reports from their membership with the Clean Water Education Partnership (CWEP) about
regional activities, but the City should document City-specific outreach activities. A common log should be maintained of
attendance/exposure at City sponsored public education and outreach events. The City should also document and log activity and
exposure from Keep America Beautiful (KAB) programming.
Post-Construction Site Runoff Controls Design
II.F.2f Mechanism to Require Long-term Operation and
Maintenance
The operation and maintenance plan required the owner of each SCM to perform and maintain a record of annual
inspections of each SCM.
Annual inspection of permitted structural SCMs are required to be performed by a qualified professional.
Current private SCMs are about 50% compliant with required annual inspections. The City should develop a plan to achieve and
maintain 100% compliance which includes confirmation of current property owners contact information, tracking annual inspection
responses, and follow-up with non-responders and failed inspections. The City should also employ the available enforcement
mechanisms to aid in achieving compliance, if necessary.
II.F.2i Enforcement
The permittee tracked the issuance of notices of violation and enforcement actions.
If yes, the tracking mechanism included the ability to identify chronic violators for initiation of actions to reduce
noncompliance.
The City is not currently enforcing non-compliance for required annual SCM inspections. The City should employ enforcement
activities to aid in achieving compliance. Enforcement activities should be tracked with the ability to identify chronic violators.

Table 3-3 lists the low priority recommendations. Program elements where no gaps were identified are listed in this table as well as those that can be addressed by utilizing existing DEQ templates (e.g. program implementation). The
table also includes low priority items that require minimal program updates to maintain permit compliance (e.g. construction site runoff controls).

Table 3-3. Low Priority Program Recommendations
Audit/Permit Section Program Element Program Requirement Program Recommendations and Suggested Improvements
Program Implementation
II.A.4 Availability of Stormwater Plan The permittee kept an up-to-date version of its Stormwater Plan available to the Division and the public online. The City should maintain the updated SWMP on the stormwater website
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.
The City should maintain 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. Specific areas
of the program requiring strengthened documentation are noted in sections below.
III.B Annual Report Submittal The Annual Reports included appropriate information to accurately describe the progress, s tatus, and results of the
permittee’s Stormwater Plan, including, but not limited the following:
The City should use the current DEQ annual report template.
https://deq.nc.gov/about/divisions/energy-mineral-and-land-resources/stormwater/stormwater-program/npdes-ms4-1
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.
2. A description of the effectiveness of each program component.
3. Planned activities and changes for the next reporting period, for each program component or activity.
4. Fiscal analysis.
The City currently uses the DEQ annual report template; there appear to be some inconsistency with the annual template and the
DEQ audit template. According to the audit template questions, he City's annual reporting should include a detailed description of
the state of implementation of the Stormwater Plan including schedules and plans for the year following the report. The City's annual
reporting should also describe effectiveness of each program component and a summary and trend of data including assessment of
what the data means for implementation of the SWMP
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Table 3-3. Low Priority Program Recommendations
Audit/Permit Section Program Element Program Requirement Program Recommendations and Suggested Improvements
Public Involvement and Outreach
No gaps were identified for this program area.
Construction Site Runoff Controls
II.E.3 Construction Site Runoff Controls The permittee provides and promotes a means for the public to notify the appropriate authorities of observed erosion
and sedimentation problems (e.g., promoting the existence of the DEQ DEMLR “Stop Mud” hotline).
Public calls/complaints about erosion and sedimentation problems typically get routed to City Hall by way of the general public
works phone number. The City should promote the stormwater helpline as the appropriate reporting mechanism for observed erosion
and sedimentation problems for consistency in the stormwater hotline use.
Post-Construction Site Runoff Controls Design
TMDLs
`No gaps were identified for this program area.

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Section 4: Pollution Prevention and Good Housekeeping
Evaluation
This section describes the methods used to screen the City’s existing facility inventory to determine select
sites for PPGH evaluations, the methods used to perform field evaluations of the select sites, and to provide
the observations and recommendations from the PPGH evaluation. The facility inventory has been
established by the Property Management department to identify properties leased or owned by the City. BC
categorized the inventory to assess the priority level (high, medium or low) of each site based on the
operations performed at the site and proximity to waterways that could increase the potential to cause
stormwater pollution. The Facility inventory is included in Attachment D.
At this time, the owning department of each facility has been designated as the responsible party for facility
maintenance activities and operations, and the Stormwater Management Division has maintained minimal
coordination with those facilities. The City has not established a written inspection and maintenance
program that coordinates with facilities, identified routine requirement for, inspections and maintenance
activities, roles and responsibilities for both owning departments and Stormwater Management Division, or
an annual program assessment procedure.
City facilities with industrial permits are responsible for developing and maintaining their own site-specific
Stormwater Pollution Prevention Plans (SWPPPs), as required in their industrial permits. The stormwater
engineer has begun consulting with owning departments of the NPDES permitted facilities for their spill
procedures and spill preparedness.
The City provided BC an inventory of City owned facilities from the Property Management Department. From
this list, sites were classified based on the type of activities and operations that are conducted on-site. Once
classified, sites were catalogued as either low, medium, or high priority. Field visits were completed on a
select number of sites that conducted high pollution potential operations (e.g. vehicle maintenance and
fueling).

4.1 Municipal Facility Inventory Evaluation
The purpose of municipal facility evaluation was to identify municipal facilities that have the potential to
generate polluted stormwater runoff. This includes facilities that pose a potential risk of stormwater pollution
based on the types of activities performed on-site. A list of municipal facilities was generated from the 2019-
2020 City Property Schedule for this evaluation. While likely comprehensive for sites with a potential to
generate polluted stormwater runoff, it is recommended that the City review this list with a comprehensive
list of municipal properties from a source such as the County Property Appraiser’s Office.
Activities that are considered a potential risk of pollution to the stormwater system include:
• Vehicle repair/ maintenance
• Vehicle/ equipment washing
• Fueling
• Pesticide, herbicide, and fertilizer storage
• Deicing material storage
• Bulk material storage
• Potential for high waste generation, including facilities caring for animals
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• NPDES Permitted
Sites were classified based on the type of activities that are typically conducted on-site. BC relied on site
activity descriptions from City staff in this effort. Once classified, sites were given a generalized pollution
potential risk level of Low, Medium, or High (see Attachment D).

4.2 Municipal Facility Visits
From the inventory of City-owned facilities, five sites were selected for field visits to evaluate existing site
procedures for understanding of and adherence to good housekeeping practices to protect the stormwater
system. The five sites selected for field evaluation were:
• Environmental Services Center
• Wastewater Treatment Plant
• Fleet Maintenance Complex
• Fire Station # 1
• Animal Service Unit
Site visits were performed to determine common housekeeping challenges between facilities, operations,
and City staff practices. The field team was comprised of both BC and City of Rocky Mount staff. The team
completed a field evaluation form for each facility. A blank copy of the field form can be found in Appendix C.
Upon arrival at each facility, the team met with the facility operator(s) to discuss typical activities and
response procedures that occur on-site. While touring the facility, the team focused on activities identified
during the initial discussion, verifying that the specific structural components were in place for each activity.
During site visits the ream also discussed protocols and re
4.3 Observations
Based on field inspections, there are a few inconsistencies in the implementation of good housekeeping
requirements between facilities. The purpose of this section is to outline the procedures and observations to
aid in the adoption of a consistent approach across facilities to establish the good housekeeping program.
4.3.1 Spill Kits and Spill Response
The most common observation made across all facilities was the appropriate placement, stocking, and
labeling of spill kits. Individual spill kits should be easy to locate and in close proximity to any high spill
potential activity, such as fueling stations, maintenance areas, bulk liquid/waste oil storage, and waste
receptacles. Spill kits should contain fresh absorbents and should be checked for inventory on a set
schedule. Signage should be posted where spill kits are located with instructions on handling a spill and who
to call if a spill occurs. Figure 4-1 shows an example of appropriate signage for a fueling station.
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Figure 4-1. Spill response signage

In addition to having spill kits accessible, some facilities did not have a written procedure for spill response.
Spill response training should be offered by the City for municipally owned facility staff.
4.3.2 Waste Storage
Another observation made during the field visits was inconsistencies in waste storage. Spent oil or other
liquid waste should be stored in appropriately labeled containers, including secondary containment. These
containers should be securely covered to prevent stormwater runoff. If temporary basins or containers are
used for liquid waste, they should be immediately transferred to the appropriate waste area once the activity
is complete. Waste containers should be inspected regularly for signs of corrosion or other indicators that a
spill may occur in the future. Opaque containers should have a level gauge or overflow structure to prevent
overfilling. Double-walled containers can also be used as secondary containment to further prevent spills. As
discussed in Section 4.3.2, areas with liquid waste storage should have at least one spill kit within close
proximity.
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Figure 4-2. Improper Waste Oil Storage

All City-owned facilities possess dumpsters for solid waste storage. Some dumpsters were observed to be
overfilled, which led to trash being blown out of the container. Solid waste storage containers, such as
dumpsters, should be covered to properly contain the waste and reduce the mixing of stormwater runoff and
solid waste leachate. Dumpsters should be located in an area that is accessible for routine pick up and
should be placed on stable, even ground.
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Figure 4-3. Improper Dumpster Storage
4.3.3 Inlet Protection:
Some areas were observed to be lacking inlet protection in high runoff areas. This led to some inlets being
obstructed with sediment and trash. Protective filter socks or similar device should be used when inlets are
located in areas with high potential for runoff. This prevents pollution downstream and reduces the
frequency of maintenance within the MS4. The City could engage in an inlet inspection schedule that would
allow for inlets to receive maintenance/cleaning before they become obstructed. Additionally, during the
field audits, a washing station was observed in close proximity to an inlet. Guidance should be provided
about what activities/operations can be safely completed in close proximity to stormwater inlets.
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Figure 4-4. Inlet Obstruction
4.4 Recommendations
From this evaluation the following recommendations have been developed for the PPGH compliance:
• Site Pollution Prevention Plans. The City does not maintain facility specific O&M plans or site-specific
spill response procedures and need to be developed for municipal facilities owned and operated by the
City that have significant potential for generating polluted stormwater runoff. BC recommends that the
Stormwater Management Division should coordinate with facilities to establish spill response plans for
identified facilities and operations.
• Spill Response. The City does not maintain spill response procedures; these need to be developed for
municipal facilities and operations. The City should coordinate with facilities to establish spill response
procedures for identified municipal operations that include guidance on maintaining adequate spill kits.
• Waste Storage. The City does not provide requirements for waste storage (e.g. bulk used oil) that would
aid in pollution prevention. The City should provide training or information on practices and level and/or
containment mechanisms for waste oil.
• Inlet Protection. Some inlets were clogged and/or surrounded by debris or in line with operations that
could cause pollution to the stormwater sewer. The City should provide guidance and an
inspection/maintenance interval to ensure inlet protection.
• NPDES Permitting. Based on preliminary discussion with DEQ, it was noted by Jeanette Powell (MS4
Program Coordinator) that most municipal fleet maintenance facilities are subject to the NCG080000
permit and that the regional office staff make that specific determination for a facility. The City does not
currently have an industrial permit for its fleet maintenance facility. The City is not obligated to initiate
the permitting process; the State would make the designation and follow though the permitting process
and the City should be aware of this potential industrial permit designation.
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Section 5: Next Steps
The assessments and recommendations provided in this report are presented to prepare City for the
upcoming MS4 audit. The City can use these as a means to fill gaps in the implementation of the existing
stormwater permit.
References
North Carolina Department of Environmental Quality. “Draft Phase II MS4 Audit Template.” 2019.
https://files.nc.gov/ncdeq/Energy%20Mineral%20and%20Land%20Resources/Stormwater/MS4_Documents/Phase-II-
MS4-Audit-Report-TEMPLATE.DOCX (July 1, 2020).

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Attachment A: DEQ Phase II Audit Template

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Program Implementation, Documentation, & Assessment
Staff Interviewed:
(Name, Title, Role)

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. Partial ---
The Stormwater Plan identifies a specific position(s) responsible for the overall
coordination, implementation, and revision to the Plan. No ---
Responsibilities for all components of the Stormwater Plan are documented and
position(s) assignments provided. No ---
The permittee is current on payment of invoiced administering and compliance
monitoring fees (see stormwater e-payments on DEMLR MS4 web page). Yes ---
Comments (Briefly describe funding mechanism, number of staff, etc.)
During department interviews, staff indicated a need for staffing support particularly the maintenance and repair crews for t he
sewer conveyance systems.

The 2014 SWMP does not include an indication or description of persons responsible for the implementation and maintenance of the
SWMP.
II.A.2 Stormwater
Plan
Implementation
and Evaluation
The permittee evaluated the performance and effectiveness of the program
components at least annually. No ---
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.
Not
Applicable
---
Did the permitted MS4 discharges cause or contribute to non-attainment of an
applicable water quality standard? Yes ---
If yes, did the permittee expand or better tailor its BMPs accordingly to
address the non-attainment?
Not
Applicable
---
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Program Implementation, Documentation, & Assessment
Comments

II.A.3
Keeping the
Stormwater Plan
Up to Date
The permittee kept the Stormwater Plan up to date. No ---
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).

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. No ---
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.
Yes ---
Comments (Note what materials are available on line)

II.A.3 & II.A.5
Stormwater Plan
Modifications
Did DEMLR require a modification to the Stormwater Plan? Not
Applicable
---
If yes, did the permittee complete the modifications in accordance with the
established deadline?
Not
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 ---
If yes, is there a written agreement in place? Yes ---
Comments (List the specific control measures implemented by others that do not have adequate written agreements, if
applicable)

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Program Implementation, Documentation, & Assessment
II.A.7
Written
Procedures
The permittee maintained written procedures for implementing the six minimum
control measures. Partial ---
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)
Written procedures are inconsistently maintained across the six minimum control measures. Areas that need specific work on
written procedures are addressed in the sections below.
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.
Partial ---
Comments (List the specific program components that do not have adequate documentation on file and why, if applicable)
Documentation is inconsistently maintained across the six minimum control measures. Areas that need specific work on written
procedures are addressed in the sections below.
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 ---
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
schedules and plans for the year following each report.
Partial ---
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
---
3. Documentation of any necessary changes to programs or practices for
assessment of management measures implemented through the Stormwater
Plan.
Not
Applicable
---
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 ---
5. An assessment of compliance with the permit, information on the
establishment of appropriate legal authorities, inspections, and enforcement
actions.
Yes ---
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Program Implementation, Documentation, & Assessment
Comments (Note dates that annual reports cover under current permit and generally describe report deficiencies, if any)
The latest annual report (2020) appears to use the DEQ template. There is a narrative addition option in the annual reporting
format that would allow for adding the additional detail listed as “Partial”
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 ---
2. A description of the effectiveness of each program component. No ---
3. Planned activities and changes for the next reporting period, for each
program component or activity. No ---
4. Fiscal analysis. Yes ---
Comments (Note dates that annual reports cover under current permit and generally describe report deficiencies, if any)

Public Education and Outreach
Staff Interviewed:
(Name, Title, Role)

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. Partial ---
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Public Education and Outreach
Comments (Generally describe process for establishing goals/objectives)
Staff interviews indicated that the goals exist, and objectives exists. The “Partial” status acknowledges the verbal understanding of
goals and objectives. These should be formalized in a written document to achieve a “Yes”.

II.B.2.b
Target Pollutants
The permittee maintained a description of the target pollutants and/or stressors and
likely sources. No ---
Comments (List target pollutants, note any that are missing or not appropriate)

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. Yes ---
Comments (Describe any changes made, if applicable)

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 ---
Comments (Generally describe the residential/industrial/commercial issues addressed)

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Public Education and Outreach
II.B.2.e
Informational
Web Site
The permittee promoted and maintained an internet web site designed to convey the
program’s message. Yes ---
Comments (list web page address and general contents, or attach screen shot of landing page)

II.B.2.f
Public Education
Materials
The permittee distributed stormwater educational material to appropriate target
groups. Yes ---
Comments (List distributed materials and quantity, message, distribution mechanism, target audience for each if not included in
program documentation/annual reporting)

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 ---
Comments (Note hotline contact information and method(s) for advertising it)

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 ---
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.
Partial ---
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Public Education and Outreach
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.)

Staff interviews described receiving extent of exposure documentation from membership with the Clean Water Education
Partnership (CWEP) and Keep America Beautiful (KAB) initiatives. The City should maintain a log of recorded events and exposure
City sponsored events.

Additional
Comments:

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Public Involvement and Participation
Staff Interviewed:
(Name, Title, Role)

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. Yes ---
Comments (Note opportunities promoted and date(s) of volunteer events)

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. Yes ---
Comments (Note mechanism(s) for input and how promoted)

II.C.2.c
Hotline/Help Line
The permittee promoted and maintained a hotline/helpline for the purpose of public
involvement and participation. Yes ---
Comments (Note hotline contact information and how it is promoted)

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Public Involvement and Participation
Additional
Comments:

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Illicit Discharge Detection and Elimination (IDDE)
Staff Interviewed:
(Name, Title,
Role)

Permit Citation Program Requirement Status Supporting
Doc No.
II.D.2.a
IDDE Program The permittee maintained a written IDDE Program. No ---
If yes, the written program includes provisions for program assessment and
evaluation and integrating program. No ---
Comments (Note any deficiencies)

II.D.2.b
Legal Authorities
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 ---
If yes, the ordinance applies throughout the corporate limits of the permittee.
[Permit Part I.D] Yes ---
Comments

II.D.2.c
Storm Sewer
System Map
The permittee maintained a current map showing major outfalls* and receiving
streams. Yes ---
Comments

*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.
II.D.2.d
Dry Weather Flow
Program
The permittee maintained a program for conducting dry weather flow field
observations in accordance with written procedures. Partial ---
During department interviews staff indicated that ditch crews were currently conducting dry weather screening activities during
ditch maintenance. Formalizing these actions into a written plan and documentation.
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Illicit Discharge Detection and Elimination (IDDE)
II.D.2.e
Investigation
Procedures
The permittee maintained written procedures for conducting investigations o f
identified illicit discharges. Yes ---
Comments (Generally describe what procedures are documented)

II.D.2.f
Track and
Document
Investigations
For each case of an illicit discharge or potential illicit discharge, the permittee documented and tracked the
following:
1. The date(s) the illicit discharge was observed Yes ---
2. The results of the investigation Yes ---
3. Any follow-up of the investigation No ---
4. The date the investigation was closed No ---
Comments (Note whether a standard inspection form is utilized to capture consistent information and a tracking mechanism is
used)

II.D.2.g Employee
Training The permittee implemented and documented a training program for appropriate
municipal staff who, as part of their normal job responsibilities, may come into
contact with or otherwise observe an illicit discharge or illicit connection.
Partial ---
Comments (Generally describe the staff training program, including frequency and which staff are trained)
The City conducted a training for certain staff in 2020. To move from “Partial” to “Yes” the City should create a plan that identifies
staff that need training and provide regular opportunities for identified staff to be trained and that training to be documen ted.
II.D.2.h
Public Education

The permittee informed public employees of hazards associated with illegal
discharges and improper disposal of waste. Yes ---
The permittee informed businesses of hazards associated with illegal discharges and
improper disposal of waste. Yes ---
The permittee informed the general public of hazards associated with illegal
discharges and improper disposal of waste. Yes ---
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Illicit Discharge Detection and Elimination (IDDE)
Comments (Note how each sector was informed, if applicable)

II.D.2.i
Public Reporting
Mechanism
The permittee promoted, publicized, and facilitated a reporting mechanism for the
public to report illicit discharges. Yes ---
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. Partial ---
Comments (Generally describe reporting mechanisms and how promoted/publicized/facilitated/established)
During department interviews, staff indicated that the response and directing for public complaints is a known process for
identifying the appropriate City contact to forward the request and following up as necessary. Documenting the response
procedure and making it available to staff that receive public calls would change to a “Yes” status.
II.D.2.j
Enforcement
The permittee implemented a mechanism to track the issuance of notices of violation
and enforcement actions administered by the permittee. Yes ---
If yes, the mechanism includes the ability to identify chronic violators for
initiation of actions to reduce noncompliance. No ---
Comments (Generally describe the established tracking mechanism, if applicable)

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Construction Site Runoff Controls
Staff Interviewed:
(Name, Title, Role)

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 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
[NPDES Permit No.
NCS000435]
The permittee provides and promotes a means for the public to notify the
appropriate authorities of observed erosion and sedimentation problems (e.g.,
promoting the existence of the DEQ DEMLR “Stop Mud” hotline).
Partial ---
Comments (Describe how provided and promoted)
During department interviews, staff indicated that calls are sometimes routed from other departments as opposed to calls coming
directly to the stormwater helpline. The City should advertise the helpline as the appropriate contact for erosion and sedimentation
problems.
SPCA Citation Delegated Program Requirement Status Supporting
Doc No.
§ 113A-60 Local
erosion and
sedimentation
control programs (a)
The permittee has adopted an ordinance or other regulatory mechanism to enforce
the erosion and sedimentation control program. Yes ---
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 I.D] Yes ---
Comments (Provide regulatory mechanism reference or Supporting Documentation number)

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Construction Site Runoff Controls
§ 113A-60 Local
erosion and
sedimentation
control programs (d)
The permittee collects a fee paid by each person who submits an erosion and
sedimentation control plan. Yes ---
Comments (indicate the fee amount, if applicable)

§ 113A-60 Local
erosion and
sedimentation
control programs (e)
Has any person initiated a land-disturbing activity (within the permittee’s
jurisdiction) for which an erosion and sedimentation control plan is required in the
absence of an approved plan?
No ---
If yes, the permittee has notified the North Carolina Sedimentation Control
Commission of all such cases.
Not
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? No ---
If yes, has the permittee referred any such matters to the North Carolina
Sedimentation Control Commission for inspection and enforcement?
Not
Applicable
---
Comments

§ 113A-61 Local
approval of erosion
and sedimentation
control plans
The permittee reviews each erosion and sedimentation control plan submitted to
them and notifies the person submitting the plan that it has been approved,
approved with modification, or disapproved within 30 days of receipt.
Yes ---
The permittee only approves an erosion and sedimentation control plan upon
determining that it complies with all applicable State and local regulations. Yes ---
The permittee has disapproved of an erosion and sedimentation control plan in
order to protect riparian buffers along surface waters. No ---
If yes, the permittee notified the Director of the Division of Energy, Mineral,
and Land Resources within 10 days of the disapproval.
Not
Applicable
---
Comments

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Construction Site Runoff Controls
§ 113A-61.1
Inspection of land-
disturbing activity;
notice of violation
(a)
The certificate of approval of each erosion and sedimentation control plan
approved by the permittee includes a notice of the right to inspect. Yes ---
The permittee provides for inspection of land-disturbing activities to ensure
compliance with the SPCA and to determine whether the measures required in an
erosion and sedimentation control plan are effective.
Yes ---
Comments

§ 113A-61.1
Inspection of land-
disturbing activity;
notice of violation
(c)
When the permittee determines that a person engaged in land-disturbing activity
has failed to comply with the SPCA, the Permittee immediately issues a notice of
violation upon that person.
Yes ---
Each notice of violation issued by the permittee specifies the date by which the
person must comply. Yes ---
Each notice of violation issued by the permittee informs the person of the actions
that need to be taken to comply. Yes ---
Comments

§ 113A-64 Penalties Does the permittee issue civil penalties as part of the erosion and sedimentation
program? Yes ---
Comments (indicate when/why a civil penalty is issued, and the amount, if applicable)

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Post-Construction Site Runoff Controls
Staff Interviewed:
(Name, Title, Role)

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: N/A
☐ 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.
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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 ---
The permittee implements deemed-compliant Program requirements throughout
the entire MS4 area (If not, also complete the Permit Citation section below.) Yes ---
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 ---
The permittee included deemed-compliant Program reporting in their MS4
Annual Reports.
The permittee included deemed-compliant Program implementation in their
Stormwater Management Plan. Yes ---
Comments

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 ---
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 ---
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 ---
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 ---
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 ---
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)

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Post-Construction Site Runoff Controls
II.F.2.b
Stormwater Control
Measures (SCMs)

The permittee utilizes strategies which include SCMs appropriate for the MS4. Yes ---
SCMs comply with 15A NCAC 02H .1000. Yes ---
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 ---
If yes, the site plan reviews addressed how the project applicant meets the
performance standards. Yes ---
If yes, the site plan reviews addressed how the project will ensure long-term
maintenance. Yes ---
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 ---
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 ---
Comments

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 ---
Comments

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Post-Construction Site Runoff Controls
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 ---
The operation and maintenance plan required the owner of each SCM to perform
and maintain a record of annual inspections of each SCM. Yes ---
Annual inspection of permitted structural SCMs are required to be performed by a
qualified professional. Partial ---
Comments
During department interviews, staff indicated that only 50 percent of permitted SCMs are providing documentation for complia nce
with annual inspections. Making a plan to achieve compliance with the remaining SCM owners and enforcing noncompliance
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 (Verify this
is a permit condition in Part II.F.2.g of permit and modify accordingly).
Not
Applicable
---
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(Verify this is a permit condition in Part II.F.2.g of permit and modify
accordingly.
Not
Applicable
---
The permittee developed and implemented a written inspection program for SCMs
installed pursuant to the post-construction program(Verify this is a permit
condition in Part II.F.2.g of permit and modify accordingly .
No ---
The permittee documented and maintained records of inspections. Yes ---
The permittee documented and maintained records of enforcement actions. No ---
Comments

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 ---
Comments (If the permittee has adopted materials from other programs, indicate here which materials they are using)

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Post-Construction Site Runoff Controls
II.F.2.i Enforcement

The permittee tracked the issuance of notices of violation and enforcement
actions. No ---
If yes, the tracking mechanism included the ability to identify chronic violators
for initiation of actions to reduce noncompliance. No ---
Comments

II.F.3.b
New Development
The permittee fully complies with post construction program requirements on its
own publicly funded construction projects. Yes ---
Comments

II.F.3.c
Nutrient Sensitive
Waters
Does the MS4 have areas draining to Nutrient Sensitive Waters (NSW) pursuant to
15A NCAC 02H .0150? Yes ---
If yes, does the permittee use SCMs that reduce nutrient loading in order to
meet local program requirements. Yes ---
If yes, does the permittee also still incorporate the stormwater controls
required for the project's density level. Yes ---
If yes, does the permittee also require documentation where it is not feasible
to use SCMs that reduce nutrient loading.
Not
Applicable
---
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 ---
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 ---
Comments

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Pollution Prevention and Good Housekeeping for Municipal Operations
Staff Interviewed:
(Name, Title, Role)

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.
Partial ---
Comments (Note number of facilities, typical inventory data and any facilities that are not inventoried that should be)
The City maintains a list of properties leased or owned by the City which likely captures most high and medium priority sites for
generating polluted stormwater runoff. Because this list is maintained by the Property Managem ent department it is based on
insurance thresholds. Cross referencing this list with property ownership records should provide a complete list of parcels o wned by
the City.
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.
No ---
If yes, the O&M program specifies the frequency of inspections. No ---
If yes, the O&M program specifies the frequency of routine maintenance
requirements. No ---
If yes, the permittee evaluated the O&M program annually and updated it as
necessary. No ---
Comments

II.G.2.c
Spill Response
Procedures
The permittee had written spill response procedures for municipal operations. No ---
Comments

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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 ---
If yes, the permittee evaluated the effectiveness of existing and new BMPs
based on cost and the estimated quantity of pollutants removed. No ---
Comments

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.
Partial ---
Comments (Briefly describe O&M program)
The O&M program conducts regular maintenance activity on the sewer system; the City should document the program goals and
metrics.
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.
Not
Applicable
---
Comments (Describe inventory information and number of controls in inventory)

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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:
Not
Applicable
---
The O&M program specified the frequency of inspections and routine
maintenance requirements.
Not
Applicable
---
The permittee documented inspections of all municipally-owned or maintained
structural stormwater controls.
Not
Applicable
---
The permittee inspected all municipally-owned or maintained structural
stormwater controls in accordance with the schedule developed by permittee.
Not
Applicable
---
The permittee maintained all municipally-owned or maintained structural
stormwater controls in accordance with the schedule developed by permittee.
Not
Applicable
---
The permittee documented maintenance of all municipally-owned or
maintained structural stormwater controls.
Not
Applicable
---
Comments
See section II.G.2g.
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 ---
The permittee ensured contractors are properly trained in pesticide, herbicide and
fertilizer application management. Yes ---
The permittee ensured all permits, certifications, and other measures for
applicators are followed. Yes ---
Comments

II.G.2.j
Staff Training
The permittee implemented an employee training program for employees involved
in implementing pollution prevention and good housekeeping practices. No ---
Comments

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Pollution Prevention and Good Housekeeping for Municipal Operations
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.
No ---
Comments

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Total Maximum Daily Loads (TMDLs)
Staff Interviewed:
(Name, Title, Role)

Program Status:
☒ The permittee is not subject to an approved TMDL (skip the rest of this section).
☐ The permittee is subject to an approved TMDL for: name of parameter(s) and date(s) approved
There ☐ is ☐ is not a Waste Load Allocation (WLA) in the approved TMDL (If there is a WLA, then complete items II.H.1-5
below. If there is not a WLA, skip to item II.H.6 below)
Permit Citation Program Requirement Status Supporting
Doc No.
II.H.3 TMDLs Within 12 months of final TMDL approval, the permittee’s annual reports included
a description of existing programs, controls, partnerships, projects and strategies to
address impaired waters.
Not
Applicable
---
Within 12 months of final TMDL approval, the permittee’s annual reports provided
a brief explanation as to how the programs, controls, partnerships, projects and
strategies address impaired waters.
Not
Applicable
---
Comments

II.H.4 TMDLs Within 24 months of final TMDL approval, the permittee’s annual reports included
an assessment of whether additional structural and/or non-structural BMPs are
necessary to address impaired waters.
Not
Applicable
---
Within 24 months of final TMDL approval, the permittee’s annual reports included
a brief explanation as to how the programs, controls, partnerships, projects and
strategies address impaired waters.
Not
Applicable
---
Comments

II.H.5 TMDLs Within 36 months of final TMDL approval, the permittee’s annual reports included
a description of activities expected to occur and when activities are expected to
occur.
Not
Applicable
---
Comments

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Total Maximum Daily Loads (TMDLs)
II.H.6 TMDLs If there is no Waste Load Allocation in the approved TMDL, the permittee
evaluated strategies and tailored and/or expanded BMPs within the scope of the
six minimum measures to enhance water quality recovery strategies in the
watershed(s) to which the TMDL applies.
Not
Applicable
---
The permittee described strategies and tailored and/or expanded BMPs in their
Stormwater Management Plan and annual reports
Not
Applicable
---
Comments

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Attachment B: Meeting and Site Visit Summaries

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Department/Program Interviews
Meeting Topics Staff
Meeting 1
Public Education and Outreach & Public Involvement
and Participation Programs (including call center for
hotline/helpline)
Melissa Wright
Stephane Collins
Kelly Cook
Scott Miles
Donald Perry (cc)
Meeting 2 IDDE
Scott Miles
Steve Spruill
Chris Pridgen
Donald Perry(cc)
Meeting 3 Construction Site Runoff Controls and Post-
Construction Site Runoff Controls)
Scott Miles
Allen Goff
Bill Pridgen
Donald Perry (cc)
Meeting 4 PPGH
Scott Miles
Steve Spruill
Bill Pridgen
Michael Baughn
Donald Perry (cc)

PPGH Field Audit Visits
Site Staff Date Address
Site Visit 1 Environmental Services Cameron Privott
April 7
1221 Thorpe Road.
Site Visit 2 Wastewater Treatment Plant James Costello 3030 Treatment Plant Rd.
Site Visit 3 Fleet Maintenance Complex Michael Shaw 106 E. Grand Ave
Site Visit 4 Fire Station 1 William Hale 105 Rowe Dr.
Site Visit 5 Animal Shelter Boykin 1017 N. Church St.

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Attachment C: Pollution Prevention and Good
Housekeeping Field Audit Template

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General Evaluation Info
Facility Name:

Facility Address:
Date/Time:

Weather Description:
Inspector Name: Facility/City Staff Present:

Good Housekeeping Categories (check all that apply):
☐ Bulk Material Storage
☐ Vehicle Washing
☐ Waste Management
☐ NPDES Permitted
☐ Animal Waste
☐ Other ________________
☐ Fueling
☐ Vehicle Maintenance
☐ Other _________________

Inspection Components Comments
SWPPP or other Stormwater Plans
Is there an approved SWPPP or other stormwater
plan on site?

Does the SWPPP include a site map, potential
sources of pollution, and control measures/ BMPs

Does the SWPP contain inspection and
maintenance procedures?

Does the SWPPP identify a pollution prevention
team (responsible for ensuring the plan is followed
and facilitating corrective action)?

Does the SWPPP contain a spill response plan?
Does the SWPPP identify employee training
requirements? May include RCRA, SPCC, or spill
response training. Have employees received this
training?

Waste Management
Are waste containers covered? Are waste remaining
in containers?

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Inspection Components Comments
Has waste been properly disposed?
General Housekeeping
Are storm drains free of debris and properly
labeled?

Are materials stored away from high traffic areas?
Are any routine inspections performed for
stormwater Pollution prevention?

Are any checklists or records maintained for good
housekeeping activities?

Are spill response procedures accessible and
known?

Are spill response kits accessible and
maintained/stocked?

Any pesticide/herbicides/fertilizers used on site
(i.e. for landscaping efforts)?

Vehicle Maintenance, Fueling, and Washing
Are there designated areas for maintenance
activities? Do these areas drain into the sanitary
sewer? Are there spill kits available nearby?

Are fueling stations designated and are the stations
properly labeled? Are spill kits available nearby?

Are washing areas designated and are there BMPs
to prevent pollution to the MS4?

Material Storage
Are bulk materials and chemicals covered or stored
in secondary containment?

Are bulk material containers labeled?
How are bulk materials transferred and handled?
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Inspection Components Comments
Hazardous Waste Management
Are all hazardous materials properly labeled (in
compliance with OSHA standards)?

Are all hazardous materials stored in a way that is
protected from stormwater runoff?

Are spill kits available near the hazardous waste
storage area?

Other general notes and observations:

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Attachment D: Municipally Owned Facilities for PPGH
Program

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Pollution Prevention and Good Housekeeping Inventory List
Name Address Use of asset Category Pollution
Potential
Admin. Bldg & City Hall 331 S. Franklin St. City Hall/Adm. Offices None - Office Low
Administrative Building 3031 Treatment Plant
Rd. Building/equip/offices NPDES Medium
Amoco fibers 1245 Atlantic Ave Generator None Low
Athletic Stadium 1400 N Church St Football field with 5000 stadium
seats None Low
Booster Pump 2080 S.Halifax Road Station equipment None - Pump Station Low
Booster Station 3120 N. Church St Station None Low
BTW Community center 747 Pennsylvania Ave Center/offices None - Office Low
BTW Gym 720 Carolina Ave Gym None Low
Bus Station 111 Coast Line Street Bus Station None Low
Cheesecake Factory 6792 Corporation
Parkway Generators None Low
Children's Museum/Art Center 270 Gay St. Imperial Center None Low
City Hall 331 S. Church St Generators None Low
City Wharehouse/Stemmary
bld 720-724 Albemarle Ave Warehouse/offices Vehicle Washing / Maintenance High
Communications Tower 1255 Thorpe Road City communications bldg None - Office Low
Denton Rd Pool 1434 Denton St. Pool & bath house None Low
Draka Industries 2151 N. Church St Generator None - Office Low
Electric Substation #1 1590 River Dr. Substation 1 None - Power Station Low
Electric Substation #10-11 540 Old Mill Substation 10 None - Power Station Low
Electric Substation #12 2825 Benvenue Rd Substation 12 None - Power Station Low
Electric Substation #14 6671 Goldrock Rd Substation 14 None - Power Station Low
Electric Substation #2 416 Rocky Street Substation 2 None - Power Station Low
Electric Substation #3 810 Leggett Street Substation 3 None - Power Station Low
Electric Substation #4 1211 Atlantic Ave. Substation 4 None - Power Station Low
Electric Substation #5 1251 Thorpe Road Substation 5 None - Power Station Low
Electric Substation #6 813 S. Wesleyan Blvd Substation 6 None - Power Station Low
Electric Substation #7 200 Sutton Rd. Substation 7 None - Power Station Low
Electric Substation #8 & POD 810 Greyson Rd. Substation 8 None - Power Station Low
Electric Substation #9 251 English Road Substation 9 None - Power Station Low
Electric Substation &
Generators
3031 Treatment Plant
Rd. Substation & Gen NPDES Low
Elevated water tank 3031 Treatment Plant
Rd. Water tank NPDES Low
Enviromental Serv.Office &
shop 1221 Thorpe Road Office and shop Bulk Material Storage High
Fire Prevention Complex 404 S.Church St. Fire Prevention & Museum Vehicle Washing / Maintenance Medium
Main Fire Station 101 S. George Street Station 1 Fueling; Vehicle Washing /
Maintenance High
Fire Station 824 S. Grace Street Station 2 Vehicle Washing Medium
Fire Station 900 Springfield Rd. Station 5 Vehicle Washing Medium
Fire Station 900 S.Winstead Ave Station #3 Vehicle Washing Medium
Fire Station 105 Rowe Dr. Station #6 Fueling; Vehicle Washing High
Fire Station 4 2054 Fenner Road Fire Station 4 Vehicle Washing Medium
Fire Station 7 9914 NC-4 Fire Station 7 Vehicle Washing Medium
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Pollution Prevention and Good Housekeeping Inventory List
Name Address Use of asset Category Pollution
Potential
Fleet Maintenance Garage 106 E.Grand Ave. Fleet Garage/offices Fueling; Vehicle Washing /
Maintenance High
Judical Center & Court Room 301 Cokey Rd. Court Room & Offices None - Office Low
Lift Station 3031 Treatment Plant
Rd. Lift station NPDES Low
MBM Foods 2217 Centura Hwy Generators None Low
McLane 7253 N Carolina 48 Generators None Low
Merita Bakery 2551 N.Church St. Generators None Low
MLK Jr. Park 800 E. Virginia St. Martin Luther King Park None - Park Low
Theatre 367 N. Franklin St. Theater None Low
OIC & Offices for Comm. Ctr 406 E. Virginia St. old BTW complex None - Office Low
Old Braswell Liabrary 344 Falls Road Imperial Ctr classrooms None Low
Owens/Brockway 6941 Corporation
Parkway Generators None Low
Parks Maintenance Offices 726 Albemarle Ave Parks Maintenance None – Equipment Storage Low
PG&W offices 628 Albermarle Ave Office & Equipment None Low
Poppie International 6610 Corporation Pkwy Generators None Low
Progress point of delivery 520 Old Mill Road point of delivery None - Power Station Low
Retail Outlets & Fire Stations various locations Generators (small) None Low
RM Wilson Gym 301 Hill St. Offices & Gym None - Office Low
Sewer Lift Station/Merita
Bakery 2681 N. Church St Lift Station None Low
South RM Community Center 719 Recreation Dr S. Rocky Mount Comm None - Park Low
Sports Complex 600 Independence Dr sports complex-4 buildings None - Park Low
Street and Stormwater bldg. 208 E. Grand Ave. Street Dept. Admin. None - Office Low
Sunset Ave. Water Plant 1660 Sunset Ave. Generators NPDES Low
Sunset Park 1550 River Road Sunset Park None - Park Low
Tar River Water Plt. 4489 Leaston Rd. Generators NPDES Low
Tietex International 500 Airport Rd. Generators None Low
Stith-Talbers Park 210 Spruce St. Stith park & ball fields None - Park Low
Train Station 101 CoastLine St. Train Station/offices None Low
Transformer shop & pole yard 1251 Thorpe Road Electric utility work site Bulk Material Storage High
Unican Industries 400 Jeffries Rd. Generators None Low
Waste transfer Station 1181-1221 Thorpe Road Environment. Services comp. Bulk Material Storage Medium
Wastewater Treatment Plant 3031 Treatment Plant
Rd. Other structures & Processes NPDES Medium
Water Plant 4489 Leaston Rd. Outside structures & processes NPDES Low
Water Plant 4489 Leaston Rd. Water Plant NPDES Medium
Water Plant 1660 Sunset Ave. Water Plant NPDES Medium
Water Tank 175 Red Iron Rd Tank None - Water Tank Low
Water Tank 600 Airport Road Tank None - Water Tank Low
Water Tank 572 N. Old Carriage Rd Tank None - Water Tank Low
Water Tank 688 Paul St. Tank None - Water Tank Low
Water Tank-Marigold 431 Branch St. Tank None - Water Tank Low
Weaver Bldg 281/293 Hammond Office Bldg/meter,billing None - Office Low
Senior Center (YMCA) Bldg 427 S Church St Senior Center None Low
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Pollution Prevention and Good Housekeeping Inventory List
Name Address Use of asset Category Pollution
Potential
Fire Logistics Facility 180 Cokey Rd Fire Station Support Fueling; Vehicle Washing /
Maintenance Low
Sewer Lift Station NC 97E Lift Station None Low
Sunset Park Tennis Court 760 N. Taylor St Tennis Courts None - Park Low
West Corporation 1960 Stone Rose Dr Generator None Low
Transfer Station 1201 Thorpe Road Solid Waste transfer Bulk Material Storage Low
Animal Shelter (New Location) 1017 N. Church St. Animal Shelter & Office Animal waste Low
MLK Jr. Park 800 E. Virginia St. Park None - Park Low
Business Services Center 224 S. Franklin St. Office Space None - Office Low