NCS000557_Audit Report_20220930

MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM AUDIT REPORT
NPDES PERMIT NO. NCS000557
Zebulon, NORTH CAROLINA
Zebulon, NORTH CAROLINA
450 E Horton Street
Zebulon, NC 27597
Audit Date: August 18, 2022
Report Date: September 30, 2022
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

TABLE Of CONTENTS
AuditDetails ........... .. ..................... .......................................................................................................... t
PermitteeInforrnation.................................................................................................................................. 2
Listof Supporting Documents...................................................................................................................... 3
ProgramImplementation,Documentation & Assessment..........................................................................4
PublicEducation and Outreach.................................................................................................................... 8
Illicit Discharge Detection and EIimination (IDDE)..................................................................................... 11
Pollution Prevention and Good Housekeeping for Municipal Operations ................................................. 14
Site Visit Eva luatIon. Municipal Facility No. 1 ............................................................................... . .... 1$
Site Visit Evaluation. MS4 OutfalI No, I ...................... ................... .............. ........ .............. ...................... 20
Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1........................................... 22
Appendix A. Supporting Documents
Appendix 8- Photograph Log
DISCLAIMER
This audit consists of an evaluation of program compliance with the issued permit and implementation of
the approved Stormwater Management Plan. This audit report does not include a review of all program
components, and program deficiencies in addition to those noted may be present. The permittee is
required to assess program progress and permit compliance, and to implement the approved Stormwater
Management Plan in accordance with the issued permit.
NCS000557 Zebulon MS4 Audit 20220930 Si

Audit Details
Audit ID Number:
Audit Dates):
NCS000557 Zebulon MS4 Audit_20220930
August 18, 2022
Minimum Control Measures Evaluated:
® Program Implementation, Documentation & Assessment
® Public Education & Outreach
❑ Public Involvement & Participation
® Illicit Discharge Detection & Elimination
❑ Construction Site Runoff Controls — No delegated Sediment and Erosion Control Program
❑ Construction Site Runoff Controls — Delegated Sediment and Erosion Control Program
❑ Post -Construction Site Runoff Controls
® Pollution Prevention and Good Housekeeping for Municipal Operations
❑ Total Maximum Daily Loads (TMDLs)
Field Site Visits:
® Municipal Facilities. Number visited: 1
® MS4 Outfalls. Number visited: 1
❑ Construction Sites. Number visited: Choose an item.
® Post -Construction Stormwater Runoff Controls. Number visited: 1
❑ Other: Number visited: Choose an item.
❑ Other: Number visited: Choose an item.
Inspector(s) Conducting Audit
Name. Title
Organization
Thad Valentine
DEQ DEMLR Land Quality Section
Lauren Garcia
DEQ DEMLR Land Quality Section
Audit Report Author:
Date:
Signature
Audit Report Author:
Date
Signature
NCS000557_Zebulon MS4 Audit_20220930 Page 1 of 25

List of Supporting Documents
Item
Number
Document Title
When Provided
(Prior to/During/After)
1
SWMP
2
Stormwater Program PowerPoint
3
Wake County Agreement
4
CWEP Agreement
5
BMP and Measurable Goal Tables
6
IDDE Inspection Example
7
5CM Inspection Example
8
Public Education Ad
9
Brochure Example
10
Public Works SWPPP
11
SPCC Plan
12
Evaluation of Town Owned Properties
13
Pesticide Licenses
14
PP&GH Training Sheet from Safety Meetings
NCS000557 Zebulon MS4 Audit 20220930 Page 3 of 25

Program Implementation, Documentation & Assessment
II.A.3
Keeping the
The permittee kept the Stormwater Plan up to date.
Yes
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 Alan and describe the nature of any updates, if applicable).
The SWMP shows the latest revision was June 2022. There have been no major updates to the SWMP.
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.
No
---
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)
A copy of the SWMP is not available on the webpage. Ordinances are available online but are not linked on the webpage:
https://www.townofzebulon.org/departments/pIanning/documents.
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 to the SWMP.
II.A.6 Sharing
Responsibility
Are any control measures implemented by an entity other than the permittee?
Yes
3,4
If yes, is there a written agreement in place?
Partial
3,4
Comments (List the specific control measures implemented by others that do not have adequate written agreements, if
applicable)
Wake County implements construction stormwater and post -construction stormwater for the Town. The Town also has an
agreement with CWEP for public education and outreach and public involvement and participation. An interlocal agreement is
needed to address post -construction stormwater between Wake County.
II.A.7
The permittee maintained written procedures for implementing the six minimum
Written
control measures.
Yes
1 ' 5
Procedures
Written procedures identified specific action steps, schedules, resources and
responsibilities for implementing the six minimum measures.
Yes
1, 5
Comments Gist the specific minimum measures that do not have adequate written procedures, if applicable)
Written procedures for each minimum control measure are included in the SWMP on pages 5-19. The Town also maintains BMP
and Measurable Goal Tables for each measure.
NCS000557_Zebulon MS4 Audit_20220930 Page 5 of 25

Program Implementation, Documentation & Assessment
4. Fiscal analysis.
*Qs
Comments (Note dates that annual reports cover under current permit and generally describe report deficiencies, if any)
The Town submits annual reports through BIM5.
Additional
Comments:
NCS000557 Zebulon MS4 Audit. 20220930 Page 7 of 25

Public Education and Outreach
II.B.2.d Residential
The permittee described issues, such as pollutants, the likely sources of those
and Industrial/
pollutants, potential impacts, and the physical attributes of stormwater runoff in
}
Commercial Issues
their education/outreach program.
Comments (Generally describe the residential/industrial/commercial issues addressed)
The outreach program is included in Section 7.1.4 of the 5WMP.
11.6.2.e
The permittee promoted and maintained an internet web site designed to convey the
Informational
program's message.
Partial
Web Site
Comments (list web page address and general contents, or attach screen shot of landing page)
The Town does not have a webpage dedicated to stormwater, but they do use the CWEP website and facebook posts to
communicate with residents.
II.B.2.f
The permittee distributed stormwater educational material to appropriate target
Public Education
Yes
8
Materials
groups.
Comments (list distributed materials and quantity, message, distribution mechanism, target audience for each if not included in
program documentation/annual reporting)
During the audit, the Town displayed their stormwater booth with merchandise that is set up at community events. Brochures are
sent to residential houses. Water bill inserts with stormwater information are also mailed to residents.
II.B.2.tt
The permittee promoted and maintained a stormwater hotline/helpline for the
Hotline/Help Line
purpose of public education and outreach.
Partial
Online
Comments (Note hotline contact information and methods) for advertising it)
The Town does not currently have a dedicated hotline for stormwater issues. Complaints are submitted to Public Works. The Public
Works phone number is promoted and there is a webpage that is dedicated to reporting issues, including stormwater:
https://www.townofzebulon.org/report-problem.
NCS000557_Zebulon MS4 Audit_20220930 Page 9 of 25

Illicit Discharge Detection and Elimination (IDDE)
Staff Interviewed:
Mary Duffy, Contracts/Admin Manager —Town of Zebulon
(Name, Title,
Chris Ray, Director of Public Works —Town of Zebulon
Role)
Betsy Pearce, Post -construction Stormwater— Wake County
Carrie Mitchell, Environmental Engineer —Wake County
Permit Citation
Program Requirement Status Supporting
Doc No.
II. D.2.a
IDDE Program
The permittee maintained a written IDDE Program. Yes 1
If yes, the written program includes provisions for program assessment and
Yes 1
evaluation and integrating program.
Comments (Note any deficiencies)
IDDE is included in Section 7.3 of the SWMP. Evaluation of the Program is addressed in Section 7.3.9.
The permittee maintained an IDDE ordinance or other regulatory mechanism(s) that
Yes
Online
II.D.2.b
provides the legal authority to prohibit illicit connections and discharges to the MS4.
Legal Authorities
if yes, the ordinance applies throughout the corporate limits of the permittee.
(Permit Part I. DI
Yes
Online
Comments
The IDDE Ordinance is included in Section 151.65 of the UDO: https:Hcodelibrary.amlega1.com/codes/zebulon/latest/zebuIon_nc/0-
0-0-7923. Authority is included in Section 151.02.
II.D.2.c
The permittee maintained a current map showing major outfalls* and receiving
Storm Sewer
Yes
---
System Map
streams.
Comments
All pipes and outfalls are mapped. The Town provided a binder that contains all stormwater mapping for Zebulon.
*Major outfalls are discharges from > 36" diameter pipes or drainage areas of > So acres. In areas zoned for industrial activity, major outfalls
are > 12" or drainage area > 2 acres.
II.D.2.d
The permittee maintained a program for conducting dry weather flow field
Dry Weather Flow
observations in accordance with written procedures.
Partial
i
Program
Comments (Generally summarize program, including frequency of observations and # or % of outfalls screened)
Dry weather field screening is included in two paragraphs of the SWMP as a part of Section 7.3.5 of the SWMP. It states dry weather
field screening will be conducted as needed. Written procedures for finding the source of illicit discharges and removing /correcting
illicit discharge connections are included in the IDDE section of the SWPPP. The Town's goal is to conduct inspections at atleast 10%
of outfalls annually.
NCS000557_Zebulon MS4 Audit_20220930 Page 11 of 25

Illicit Discharge Detection and Elimination (IDDE)
II.D.2.1
The permittee promoted, publicized, and facilitated a reporting mechanism for the
Yes
Online
Public Reporting
public to report illicit discharges.
Mechanism
The permittee promoted, publicized, and facilitated a reporting mechanism for staff
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)
There is a report a concern webpage on the Town website: https://www.townofzebuIon,org/report-problem. Town employees
usually contact Public Works to report issues.
There are not currently response procedures in place for citizen complaints, but they are usually handled within 48 hours
II.Q.2.1
The permittee implemented a mechanism to track the issuance of notices of violation
Enforcement
and enforcement actions administered by the permittee.
Yes
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 Town is still small enough that complaints and documentation are all maintained manually in the binder. The Town has not yet
needed to issue an NOV and there have been no repeat violators.
Additional
Comments:
NCS000557.Zebulon MS4 Audit 20220930 Page 13 of 25

Pollution Prevention and Good Housekeeping for Municipal Operations
Parking Lots
If yes, the permittee evaluated the effectiveness of existing and new BMPs
Maintenance
based on cost and the estimated quantity of pollutants removed.
Yes
2
Comments
Street sweeping is tracked by hours, miles and debris collected. The Town has doubled in street miles and has used the data
collected to request more of a budget.
HAM
O&M for Catch
The permittee maintained and implemented an O&M program for the stormwater
sewer system including catch basins and conveyance systems that it owns and
F.O
---
Basins and
maintains.
Conveyance Systems
Comments (Briefly describe O&M program)
Pollution Prevention and Good Housekeeping is addressed in Section 7.6 of the SWPPP. There is not a dedicated O&M Program for
stormwater sewer system conveyance systems, but the maintenance and cleaning of these are mentioned in the SWMP.
An 0&M Program for the stormwater sewer system including catch basins should be developed.
II.G.2.¢
The permittee maintained a current inventory of municipally -owned or operated
Structural
structural stormwater controls installed for compliance with the permittee's post-
Yes
7
Stormwater Controls
construction ordinance.
Comments (Describe inventory information and number of controls in inventory)
The Town has two town -owned SCMs. The SCMs information and inspections are kept in binders.
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
Partial
7
Stormwater Controls
the permittee's post -construction ordinance. If yes, then:
The O&M program specified the frequency of inspections and routine
maintenance requirements.
No
---
The permittee documented inspections of all municipally -owned or maintained
structural stormwater controls.
Yes
7
The permittee inspected all municipally -owned or maintained structural
stormwater controls in accordance with the schedule developed by permittee.
Yes
The permittee maintained all municipally -owned or maintained structural
stormwater controls in accordance with the schedule developed by permittee.
Yes
!
The permittee documented maintenance of all municipally -owned or
maintained structural stormwater controls.
Yes
Comments
Dedicated O&M Plans for the SCMs were not available. However, each SCM is inspected annually by an engineer. Other visual
inspection take place and regular maintenance is documented in work orders-
ll'G'2'i
The permittee ensured municipal employees are properly trained in pesticide,
herbicide and fertilizer application management.
Yes
NCS000557_Zebulon MS4 Audit_20220930 Page 15 of 25

Pollution Prevention and Good Housekeeping for Municipal Operations
WC5000557_Zebulon MS4 Audit_20220930 Page 17 of 25

Site Visit Evaluation: Municipal Facility No. 1
Does the MS4 inspector's process include taking photos?
Asneeded
Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)?
Yes
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:
No
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)?
Material was leaching out of the salt storage area. This will need to be addressed.
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
N/A
Notes/Comments/Recommendations
N[S000557—Zebulon MS4 Audit 20220930 Page 19 of 25

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)?
Yes, additional rip rap
Will a follow-up outfall inspection be conducted? If so, for what reason?
No
Notes/Comments/Recommendations
NCS000557 Zebulon MS4 Audit_20220930 Page 21 of 25

Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1
Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge?
Yes
Did the MS4 inspector miss any obvious operation and maintenance deficiencies? If so, explain:
No
Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing?
Yes
Compliance/Enforcement
What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in?
Minor maintenance
If compliance issues were identified, what timeline for correction/follow-up was provided?
N/A
Notes/Comments/Recommendations
NCS000557_Zebulon MS4 Audit_20220930 Page 23 of 25

APPENDIX B: PHOTOGRAPH LOG
NC5000557_Zebulon MS4 Audit_20220930 Page 25 of 25