NCS000246_Corrected NOC_20221010

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
BRIAN WRENN NORTH CAROLINA
Director Environmental Quality
October 10, 2022
CERTIFIED MAIL 7022 0410 0002 1249 5384
RETURN RECEIPT REQUESTED
City of Fayetteville
Attn: Douglas Hewett, City Manager
433 Hay Street
Fayetteville, North Carolina 28301
Subject: NOTICE OF COMPLIANCE (NOC-2023-PC-0930)
City of Fayetteville
NPDES MS4 Permit No. NCS000246
Cumberland County
Dear Mr. Hewett:
On September 20ih, 2022 through September 22nd, 2022, staff from the North Carolina Department of
Environmental Quality (DEQ) conducted a compliance audit of subject National Pollutant Discharge
Elimination System (NPDES) Municipal Separate Storm Sewer System (MS4) Permit. The audit identified
minor deficiencies with the specific components of the MS4 permit that were reviewed, as provided in the
attached DEQ MS4 Permit Compliance Audit Report.
In accordance with Part VI of the permit and DEQ policy, a new 5-year MS4 permit will be issued in response
to the audit. As such, the permittee is required to complete the following actions:
(1) Respond in writing within thirty (30) calendar days from the date of receipt of this notice to
acknowledge these requirements and the intent to comply.
(2) Develop a Stormwater Management Plan (SWMP) which details specific actions, measurable goals,
and implementation timelines for the stormwater management program over the new 5-year
permit term. The permittee shall submit the SWMP to DEQ for review and comment within one
hundred twenty (120) calendar days from the date of receipt of this letter.
(3) Submit an NPDES MS4 permit application for whichever comes first:
a. At least one hundred eighty (180) days prior to permit expiration, or
b. Within thirty (30) days of receiving written DEQ concurrence that the submitted SWMP
documents a compliant stormwater management program and the MS4 should submit the
application including a signed Final Draft SWMP. A new 5-year NPDES MS4 permit will be
public noticed along with the Draft Final SWMP.
(4) Respond to comments on the Draft Final SWMP and submit a signed Final SWMP for DEQ approval
and final permit issuance. The final DEQ-approved SWMP shall become an enforceable component
of the NPDES MS4 permit.
D_E Q North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
Asheville Regional Office 1 2090 U.S. Highway 70 1 Swannanoa, North Carolina 28778
rvovry curouw,
oeoe,uMmmE,e,��m.�uianin 828.296.4800

Required documentation shall be submitted via e-mail to Isaiah.Reed@ncdem gov Or to:
DEQ-DEMLR Stormwater Program
Attn: Isaiah Reed
1612 Mail Service Center
Raleigh, NC 27699-1612
Thank you for your attention to this matter. Should you have any questions, please contact me at
[e-mail].
Sincerely,
Isaiah Reed, PE, CPSWQ, MS4CECI
MS4 Program Coordinator
Enclosures: DEQ MS4 Permit Compliance Audit Repot
CC:
Byron Reeves byronreeves0fayettevillenc.gov
Sheila Thomas-Ambat sheilathomasambat0fayettevillenc gov
DEMLR Stormwater Program Supervisor
DEMLR NPDES MS4 Permit Laserfiche File
If
D_E Q North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
Asheville Regional Office 1 2090 U.S. Highway 701 Swannanoa, North Carolina 28778
o �:m.m�r,J.�eo ma��i"11h 828.296.4500

MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM AUDIT REPORT
NPDES PERMIT NO. NCS000246
FAYETTEVILLE, NORTH CAROLINA
433 Hay Street
Fayetteville, North Carolina 28301
Audit Date: September 20-22 2022
Report Date: September 30, 2022
North Carolina Department of Environmental Quality
Division of Energy, Mineral & Land Resources Stormwater Program
512 N. Salisbury Street, 9' floor
1612 Mail Service Center
Raleigh, NC 27699-1612

(This page intentionally left blank)
NCs000246_Fayetteville Ms4 Audit_20220930

TABLE OF CONTENTS
AuditDetails..................................................................................................................................................1
PermitteeInformation..................................................................................................................................2
List of Supporting Documents.......................................................................................................................3
Program Implementation, Documentation & Assessment...........................................................................4
Illicit Discharge Detection and Elimination(IDDE)........................................................................................5
Site Visit Evaluation: Municipal Facility No. 1...............................................................................................6
Site Visit Evaluation: Municipal Facility No. 2...............................................................................................7
Site Visit Evaluation: Post -Construction Stormwater Measure No. 1...........................................................8
Site Visit Evaluation: MS4 Outfall No. 1........................................................................................................9
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.
NCS000246_Fayetteville MS4 Audit_20220930 ii

This page intentionally left blank
NCS000246_Fayetteville MS4 Audit_20220930

Audit Details
Audit ID Number:
Audit Date(s):
NCS000246_Fayetteville M54 Audit_20220930 7
September 20, 21, and 22 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: 2
M MS4Outfalls. 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
Organization
Isaiah Reed, Environmental Engineer
NCDEQ
Mike Lawyer, Environmental Program Consultant
NCDEQ
Bailey Taylor, Environmental Specialist
NCDEQ
Audit Report Auth
Date:
Signature iz2Z10/1:)470
z
NCS000246_Fayetteville MS4 Audit_20220930 Page 1 of 9

Permittee Information
MS4 Permittee Name:
Permit Effective Date:
Permit Expiration Date:
City of Fayetteville
October 10, 2018
October 9, 2023
Mailing Address:
Date of Last MS4lnspection/Audit:
433 Hay Street. Fayetteville, North Carolina 28301
February 19, 2015
Co-permittee(s), if applicable: N/A
Permit Owner of Record:
Douglas Hewett, City Manager
Primary MS4 Representatives Participating in Audit
Name, Title
Organization
Day 1(9/20/2022)
Byron Reeves, Assistant Public Services
City of Fayetteville
Director
Nick Baggett, Stormwater Inspections
City of Fayetteville
Supervisor
Shauna Haslem, Public Information
City of Fayetteville
Specialist
Sheila Thomas, Public Services Director
City of Fayetteville
Mitch Colvin, Mayor
City of Fayetteville
Ben Stout, SWAB Chair
City of Fayetteville
Deno Hondros, City Council/SW Committee
City of Fayetteville
Chair
Day 2 (9/21/2022)
Byron Reeves, Assistant Public Services
City of Fayetteville
Director
Nick Beggett, Stormwater Inspections
City of Fayetteville
Supervisor
Sheila Thomas, Public Services Director
City of Fayetteville
Shauna Haslem, Public Information
City of Fayetteville
Specialist.
NCS000246_FayetteviIle MS4 Audit_20220930 Page 2 of 9

List of Supporting Documents
Item
Number
Document Title
When Provided
(Prior to/During/After)
1
Chapter23 Ordinance
Prior
2
2021 Annual Report
Prior
3
Stormwater Plan Final July 21
Prior
4
Field Screening SOP
Prior
5
2015 Impaired Stream SOP
Prior
6
2015 Industrial SOP
Prior
7
2015 Water Quality Monitoring SOP
Prior
8
IDDE Training PDF
Prior
NCS000246_Fayetteville MS4 Audit_20220930 Page 3 of 9

Program Implementation, Documentation & Assessment
Staff Interviewed:
All in attendance Day 1
(Name, Title, Role)
Permit Citation
Program Requirement
Status
supporting
Doc No.
II.A.1
The Permittee Maintained adequate legal mechanisms to implement all provisions of
Adequate Legal
the of the Stormwater Management Plan.
Yes
1
Mechanism
The permittee is current on payment of invoiced administering and compliance
monitoring fees (see stormwater e-payments on DEMLR M54 web page).
Yes
BIMS
II.A.2 Stormwater
Plan
The permittee evaluated the performance and effectiveness of the program
Implementation
components at least annually.
Yes
2
and Evaluation
II.A.3
Keeping the
The permittee kept the Stormwater Plan up to date.
Partial
3
Stormwater Plan
Up to Date
The permittee notified DEMLR of any updates to the Stormwater Plan.
No
Did DEMLR require a modification to the Stormwater Plan?
No
II.A.4 Written
The permittee maintained written procedures for implementing the six minimum
Procedures
control measures.
Partial
4,5,6,7
Comments.,
The Stormwater Management Plan has not been signed by the Permit Owner. Submittal process is not documented.
SOPS have been created to function as Written Programs. However, SOPS do not exist for all MCMs.
NCS000246_Fayetteville MS4 Audit_20220930 Page 4 of 9

Illicit Discharge Detection and Elimination (IDDE)
Staff Interviewed:
All in attendance Day 2
(Name, Title,
Role)
Permit Citation
Program Requirement Statu supporting Doc
s No.
II.D.2.a
Maintain
The permittee maintained appropriate legal Authorities. Yes 1
appropriate legal
authorities
Ordinance does not contain violation fees. Fees outline is in a separate document (Fee schedule).
II.D.2.b
Maintain a Storm
Software
Sewer System
The permittee maintained a map system including major outfalls.
Partial
demonstrate
Base Ma of
p
d during the
Major MS4
audit.
Outfal Is.
System map did not include the ability to quantify major outfalls and industrial areas specifically.
II.D.2.c
Maintain written
The permittee maintained written procedures and SOPS for detecting and tracing
procedures and/or
Illicit discharges.
Yes
q
SOPS for IDDE.
II.D.2.c
The permittee maintained written procedures or SOPS for dry weather flow
Dry weather flow
Yes
4
inspections.
inspections
II.D.2.d
The permittee conducted IDDE training for appropriate municipal staff.
Yes
g
Employee Training
II.D.2.e
Website
Maintain a public
The permittee and publicized a reporting mechanism for the public to report illicit
examined
reporting
connections and discharges.
Yes
duringthe
mechanism
audit.
Fay -Fix -It App. Hotline. Brochures, Fayettevillenc.gov
II.D.2.f
Investigation
Documentation
tracking
The permittee documented dates of investigations
Yes
software was
examined
during the
audit.
Documentati
The permittee documented enforcement actions
Yes
on examined
during the
audit.
Cityworks tracking software and methods were discussed during the audit.
Additional
Documentation of several IDDE Investigations were examined during the audit. No major issues with
Comments:
documentation methods were observed.
NCS000246_Fayettevilie MS4 Audit_20220930 Page 5 of 9

Site Visit Evaluation: Municipal Facility No. 1
Facility Name:
Date and Time of Site Visit:
Fayetteville Airport
September 22, 2022
Facility Address:
Facility Type (Vehicle Maintenance, Landscaping, etc.):
400 Airport Road
Airport
Name of MS4 inspector(s) evaluated:
Most Recent MS4 Inspection (Date and Entity):
Josh Robbins
Not Evaluated
Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name
Title
Patricia Campbell
Airport Manager
Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific?
Yes
What type of stormwater training do facility employees receive? How often?
Annual Stormwater training.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
Annual Stormwater training.
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
Yes
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Yes
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form?
Yes
Does the MS4 inspector's process include taking photos?
Yes
Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)?
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)?
Modifications to PM&GH practices relating to the NCG080000 requirements.
Comments:
During the site visit, secondary containment status of generators on site was discussed. As well as spill prevention measures in the
fueling areas.
NCS000246_Fayetteville MS4 Audit_20220930 Page 6 of 9

Site Visit Evaluation: Municipal Facility No. 1
Site Visit Evaluation: Municipal Facility No. 2
Facility Name:
Fayetteville Area System of Transit Bus Garage
Date and Time of Site visit:
September 22, 2022
Facility Address:
455 Grave Street
Fayetteville, NC 28301
Facility Type (Vehicle Maintenance, Landscaping, etc.):
Vehicle Maintenance
Name of MS4 inspector(s) evaluated:
Josh Robbins
Most Recent MS4 Inspection (List date and name of inspector):
No evaluated
Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name
Title
Sidney Small and Daniel Edwards
Bus Maintenance and Solid Waste
Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific?
Yes.
What type of stormwater training do facility employees receive? How often?
Annual Stormwater training.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
Annual Stormwater Training.
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
Yes
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Yes
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form?
Yes
Does the MS4 inspector's process include taking photos?
Yes
Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)?
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)?
No
Comments:
SWPPP contents and monitoring documentation was discussed.
NCS000246_Fayetteville MS4 Audit_20220930 Page 7 of 9

Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1
Site Name:
Date and Time of Site Visit:
Airborne and Special Operations Museum (ASOM) Bio-
September 22, 2022
retention 1
Site Address:
SCM Type:
Hillsboro Street
Bio-retention
Most Recent MS4 Inspection (Include Date and Entity):
Not reviewed
Name of MS4lnspector(s) evaluated:
Most Recent MS4 Enforcement Activity (Include Date):
Danielle Quick
Not reviewed
Name(s) and Title(s) of Site Representative(s) Present During the
Site Visit:
Name
Title
None
None
Observations
Site Documentation
Does the site have an operation and maintenance plan?
Yes
Does the site have records of annual inspections? Are they performed by a qualified individual?
Yes
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
Annual stormwater training.
Did the MS4 inspector appear knowledgeable about M54 requirements for post -construction site runoff controls?
Yes
Did the MS4 inspector appear knowledgeable about post -construction BMPs (general purpose/function, components, 0&M
requirements, etc.)?
Yes
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form? What format?
Yes
Does the MS4 inspector's process include taking photos?
Yes
Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections?
Yes
Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge?
Yes
Did the MS4 inspector miss any obvious operation and maintenance deficiencies? If so, explain:
No
Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing?
Not evaluated on site.
Compliance/Enforcement
What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in?
Inspector reports that the inspection report will be followed by verbal inquiry concerning the landscaping practices.
If compliance issues were identified, what timeline for correction/follow-up was provided?
Landscaping activity has rendered the detention ineffective due to damage to the "cleanout pipes". Landscaping practices were
discussed on site.
NCS000246_Fayetteville MS4 Audit_20220930 Page 8 of 9

Site Visit Evaluation: MS4 Outfall No. 1
Outfall ID Number:
HW6547
Date and Time of Site Visit:
September 22, 2022
Outfall Location:
Hillsboro Street
Outfall Description (Pipe Material/Diameter, Culvert, etc.):
RCP
Receiving Water:
Cross Creek
Is Flow Present? If So, Describe (Color, Approximate Flow Rate,
Sheen, Odor, Floatables/Debris, etc.):
Outfall was submerged.
Most Recent Outfall Inspection/Screening (Date):
Not Reviewed
Days Since Last Rainfall:
Not evaluated
Inches:
I N/A
Name of MS4lnspector(s) evaluated: Carl Almarode
Observations
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
Annual Stormwater training.
Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations?
Yes
Inspection Procedures
Does the inspector's process include the use of a checklist or other standardized form?
Yes
Does the inspector's process include taking photos?
Yes
Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they?
No
Inspection Results
Did the outfall inspection result in any work orders or maintenance requests? If so, for what issue(s)?
No
Will a follow-up outfall inspection be conducted? If so, for what reason?
Yes. Routine.
Notes/Comments/Recommendations
Further investigation showed that the stormwater infrastructure near the outfall may be incorrect on incomplete. Follow-up
evaluation is planned by the permittee.
NCS000246_FayetteviIle MS4 Audit_20220930 Page 9 of 9