NCS000500_Ayden MS4 AUDIT REPORT_20190725

MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM AUDIT REPORT

NPDES PERMIT NO. NCS000500
AYDEN, NORTH CAROLINA

4144 West Avenue
Ayden, NC 28513

Audit Date: 07/23/2019

Report Date: 07/25/2019

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

NCS000500_Ayden MS4 Audit Report_20190723 i

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NCS000500_Ayden MS4 Audit Report_20190723 ii
TABLE OF CONTENTS
Audit Details .................................................................................................................................................. 1
Permittee Information .................................................................................................................................. 2
List of Supporting Documents ....................................................................................................................... 3
Program Implementation, Documentation & Assessment ........................................................................... 4
Illicit Discharge Detection and Elimination (IDDE) ........................................................................................ 8
Post-Construction Site Runoff Controls ...................................................................................................... 11
Pollution Prevention and Good Housekeeping for Municipal Operations ................................................. 16
Site Visit Evaluation: Municipal Facility No. 1 ............................................................................................. 20
Site Visit Evaluation: MS4 Outfall No. 1 ...................................................................................................... 23
Site Visit Evaluation: MS4 Outfall No. 2 ...................................................................................................... 25
Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1 ............................................ 27
Appendix A: Supporting Documents
Appendix B: Photograph Log

DISCLAIMER
This audit consists of an evaluation of program compliance with the issued permit and implementation of
the approved Stormwater Management Plan. This audit report does not include a review of all program
components, and program deficiencies in addition to those noted may be present. The permittee is
required to assess program progress and permit compliance, and to implement the approved Stormwater
Management Plan in accordance with the issued permit.

NCS000500_Ayden MS4 Audit Report_20190723 iii

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NCS000500_Ayden MS4 Audit Report_20190723 Page 1 of 30

Audit Details
Audit ID Number:
NCS000500_Ayden MS4 Audit_20190723
Audit Date(s):
07/23/2019
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: 2
☐ Construction Sites. Number visited: Choose an item.
☒ Post-Construction Stormwater Runoff Controls. Number visited: 1
☒ Other: DEQ-permitted Post-Construction SCM. Number visited: 1
☐ Other: ________________________________. Number visited: Choose an item.

Inspector(s) Conducting Audit
Name, Title Organization
Jeanette Powell, MS4 Program Coordinator NCDEQ-DEMLR
Alaina Morman, Compliance & Enforcement Specialist NCDEQ-DEMLR
Audit Report Author:
Jeanette Powell
Signature
Date:
07/25/2019
Audit Report Author:

Signature__________________________________________
Date

NCS000500_Ayden MS4 Audit Report_20190723 Page 2 of 30

Permittee Information
MS4 Permittee Name:
Town of Ayden
Permit Effective Date:
02/20/2017
Permit Expiration Date:
02/19/2022
Mailing Address:
4144 West Ave, P.O. Box 219, Ayden, NC 28513
Date of Last MS4 Inspection/Audit:
N/A
Co-permittee(s), if applicable:
N/A
Permit Owner of Record:
Steven L. Harrell, Town Manager
Primary MS4 Representatives Participating in Audit
Name, Title Organization
Steven Harrell, Town Manager Town of Ayden
Stephen Smith, Planning Director Town of Ayden
Keith Murphy, Public Works Director & Electrical Superintendent Town of Ayden
Ja’Warren Cooper, Public Works Superintendent Town of Ayden
Shelvin Keys, Public Works Crew Leader Town of Ayden
Rich Moore, Engineer McDavid Associates, Inc.
MS4 Receiving Waters
Waterbody Classification Impairments
Swift Creek (27-97-(0.5) C;Sw;NSW Poor bioclassification, Benthos (Nar, AL, FW)
UTs Swift Creek C;Sw;NSW

NCS000500_Ayden MS4 Audit Report_20190723 Page 3 of 30

List of Supporting Documents
Item
Number Document Title When Provided
(Prior to/During/After)
1 Town of Ayden, NPDES Phase II Stormwater Management Program,
Comprehensive Stormwater Management Plan, July 2010 DAFT
Prior to Audit
2 Town of Ayden Phase II Stormwater Ordinance, Adopted September 8, 2008 Prior to Audit
Nuisance Code Requested
Current Official Zoning Map Requested

NCS000500_Ayden MS4 Audit Report_20190723 Page 4 of 30
Program Implementation, Documentation & Assessment
Staff Interviewed:
(Name, Title, Role)
See MS4 Representatives list, all parties present
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.
Choose
an item. ---
Responsibilities for all components of the Stormwater Plan are documented and
position(s) assignments provided.
Choose
an item. ---
The permittee is current on payment of invoiced administering and compliance
monitoring fees (see stormwater e-payments on DEMLR MS4 web page). Yes ---
The stormwater program is funded through a stormwater utility with a flat fee ( $3.50/$6.00/$10.00 for
residential/commercial/industrial) generating roughly $130,000 per year and general enterprise funds. The permittee has also
successfully obtained grant funding to complete over $6M in capital improvement projects to address inflow and infiltration to
the sanitary sewer system and numerous cross connections.
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? No ---
If yes, did the permittee expand or better tailor its BMPs accordingly to address
the non-attainment?
Not
Applicable ---
The permittee has not developed an annual report or evaluated the program during this permit term.

NCS000500_Ayden MS4 Audit Report_20190723 Page 5 of 30
Program Implementation, Documentation & Assessment
II.A.3
Keeping the
Stormwater Plan
Up to Date
The permittee kept the Stormwater Plan up to date. No 1
The permittee notified DEMLR of any updates to the Stormwater Plan. Not
Applicable ---
The SWMP of record is a July 2010 Draft.
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 ---
The only available SWMP is a July 2010 Draft. It is available upon request, but is not posted on the Town’s web page.
The Phase II Stormwater Ordinance (adopted 09/08/2008) is available on the Town’s stormwater web page, as are other
associated ordinances.

II.A.3 & II.A.5
Stormwater Plan
Modifications
Did DEMLR require a modification to the Stormwater Plan? No ---
If yes, did the permittee complete the modifications in accordance with the
established deadline?
Not
Applicable ---
DEMLR has not required a modification to the SWMP.

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 ---
Erosion and sediment control is performed by the county through an interlocal agreement. A consultant is under contract for
post-construction program implementation including plan review and approval, SCM inspection and compliance management.

II.A.7
Written
Procedures
The permittee maintained written procedures for implementing the six minimum
control measures. No ---
Written procedures identified specific action steps, schedules, resources and
responsibilities for implementing the six minimum measures. No ---
Staff have a fair understanding of what needs to be done. However, the permittee does not have written procedures in place.

NCS000500_Ayden MS4 Audit Report_20190723 Page 6 of 30
Program Implementation, Documentation & Assessment
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.
No ---
Staff were able to discuss inspections, maintenance and enforcement, but there is no documentation.

III.B
Annual Report
Submittal

The permittee submitted annual reports to the Department within twelve months
from the effective date of the permit. No ---
The permittee submitted subsequent annual reports every twelve months from the
scheduled date of the first annual report submittal. No ---
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.
Not
Applicable ---
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.
Not
Applicable ---
5. An assessment of compliance with the permit, information on the
establishment of appropriate legal authorities, inspections, and enforcement
actions.
Not
Applicable ---
There are no annual reports or BIMS SWMPAs for this permit.

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.
Not
Applicable ---
2. A description of the effectiveness of each program component. Not
Applicable ---
3. Planned activities and changes for the next reporting period, for each
program component or activity.
Not
Applicable ---

NCS000500_Ayden MS4 Audit Report_20190723 Page 7 of 30
Program Implementation, Documentation & Assessment
4. Fiscal analysis. Not
Applicable ---
There are no annual reports or BIMS SWMPAs for this permit.
Additional
Comments:
Staff have a working knowledge of many of the SWMP components, but there is a significant
documentation deficiency.

NCS000500_Ayden MS4 Audit Report_20190723 Page 8 of 30
Illicit Discharge Detection and Elimination (IDDE)
Staff Interviewed:
(Name, Title,
Role)
See MS4 Representatives list, all parties present
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.
Not
Applicable ---
There is no written IDDE program

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 ---
Article VII of the 2008 Phase II Ordinance addresses illicit discharges and connections. It applies throughout the area shown on
the current Official Zoning Map, which includes the ETJ. Illicit discharges are handled as a nuisance, with the associated
ordinance language in XXX.

II.D.2.c
Storm Sewer
System Map
The permittee maintained a current map showing major outfalls* and receiving
streams. No ---
The permittee has the ability to develop a GIS map, but does not have one in place.

*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. No ---
The permittee does not proactively perform outfall screening / dry weather flow observations, but does investigate complaints.

NCS000500_Ayden MS4 Audit Report_20190723 Page 9 of 30
Illicit Discharge Detection and Elimination (IDDE)
II.D.2.e
Investigation
Procedures
The permittee maintained written procedures for conducting investigations of
identified illicit discharges. No ---
There is no IDDE program documentation developed.

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 No ---
2. The results of the investigation No ---
3. Any follow-up of the investigation No ---
4. The date the investigation was closed No ---
The permittee has resolved illicit discharges and illegal connections, but there is no formal documentation of these events.

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.
No ---
Staff have not received formal training on IDDE.

II.D.2.h
Public Education

The permittee informed public employees of hazards associated with illegal
discharges and improper disposal of waste. No ---
The permittee informed businesses of hazards associated with illegal discharges and
improper disposal of waste. No ---
The permittee informed the general public of hazards associated with illegal
discharges and improper disposal of waste. No ---
The permittee has not included stormwater in current staff training and does not have a public education and outreach program
to engage businesses and the public.

NCS000500_Ayden MS4 Audit Report_20190723 Page 10 of 30
Illicit Discharge Detection and Elimination (IDDE)
II.D.2.i
Public Reporting
Mechanism
The permittee promoted, publicized, and facilitated a reporting mechanism for the
public to report illicit discharges. No ---
The permittee promoted, publicized, and facilitated a reporting mechanism for staff
to report illicit discharges. No ---
The permittee established and implemented response procedures for citizen
requests/reports. No ---
The permittee accepts reporting from the public and staff, but does not have established or publicized contact protocols and
mechanisms in place.

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. No ---
If yes, the mechanism includes the ability to identify chronic violators for
initiation of actions to reduce noncompliance.
Not
Applicable ---
Staff were aware and could readily converse on enforcement actions, but there were no mechanisms to document or track
enforcement in place. One car wash connection was remedied.

Additional
Comments:
Staff have a working knowledge of many of the IDDE components, but there are significant deficiencies for
documentation, tracking, proactive investigations and reporting.

NCS000500_Ayden MS4 Audit Report_20190723 Page 11 of 30
Post-Construction Site Runoff Controls
Staff Interviewed:
(Name, Title, Role)
See MS4 Representatives list, all parties present
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: McDavid & Associates, Inc.
is contracted to implement the post-construction program.
☐ 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.

NCS000500_Ayden MS4 Audit Report_20190723 Page 12 of 30
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. Not
Applicable ---
The permittee implements deemed-compliant Program requirements throughout
the entire MS4 area (If not, also complete the Permit Citation section below.) Not
Applicable ---
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.
Not
Applicable ---
The permittee included deemed-compliant Program reporting in their MS4 Annual
Reports. Not
Applicable
The permittee included deemed-compliant Program implementation in their
Stormwater Management Plan. Not
Applicable ---
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. 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 ---
Required post-construction ordinance provisions are in the Town’s Phase II Stormwater Ordinance and apply to the area covered
by the Town’s current Official Zoning Map, which includes the ETJ. Enforcement tools include holding Zoning Compliance
Certificate, SWO, and holding other permits. A 125% financial security is required, as is annual inspection reporting. At this time,
the permittee’s consultant performs the SCM inspections rather than have the owner perform and submit an inspection (since
there is only one to date). The county issues the building permit after the Town issues the Zoning Compliance Certificate, so the
Town does not have the ability to hold the Certificate of Occupancy.

The permittee utilizes strategies which include SCMs appropriate for the MS4. Yes ---

NCS000500_Ayden MS4 Audit Report_20190723 Page 13 of 30
Post-Construction Site Runoff Controls
II.F.2.b
Stormwater Control
Measures (SCMs)

SCMs comply with 15A NCAC 02H .1000. Yes ---

The Phase II Ordinance and consulting engineer specifically require practices that reduce nutrient loading.
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 ---

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.
Partial ---
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.
Not
Applicable ---
The permittee has only one site that was subject to permitting to date. There is one site that has a SCM, which was installed
approximately two years ago. While staff knew this information, it was not documented as an inventory. Prior to the MS4
permit, DEQ issued post-construction permits.

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

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 ---

NCS000500_Ayden MS4 Audit Report_20190723 Page 14 of 30
Post-Construction Site Runoff Controls
II.F.2.f
Mechanism to
Require Long-term
Operation and
Maintenance

Annual inspection of permitted structural SCMs are required to be performed by a
qualified professional. Yes ---
The Phase II Ordinance requires annual inspection submittals. At this time, the consulting engineer performs the inspection on
behalf of the Town.

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).
Partial ---
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.
No ---
The permittee documented and maintained records of inspections. No ---
The permittee documented and maintained records of enforcement actions. No ---
The permittee does not have documentation, but inspections are performed periodically. The county issues the Certificate of
Occupancy and the Town does not inspect devices prior to issuance of the CO.

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 Yes ---
The zoning ordinance and subdivision rules contain submittal requirements and is available online.

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.
Not
Applicable ---
Violations have been remedied through engaging the owner, but ot formal documentation or tracking is performed.

NCS000500_Ayden MS4 Audit Report_20190723 Page 15 of 30
Post-Construction Site Runoff Controls
II.F.3.b
New Development The permittee fully complies with post construction program requirements on its
own publicly funded construction projects.
Not
Applicable ---
The permittee has not constructed any facilities that would be subject.

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 ---
Receiving waters are designated as NSW and the permittee requires SCMs that are effective for reducing nutrients.

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

Additional
Comments:
Staff and the contracted consultant have a working knowledge of the post-construction program
components, but there are significant deficiencies for documentation and tracking.

NCS000500_Ayden MS4 Audit Report_20190723 Page 16 of 30

Pollution Prevention and Good Housekeeping for Municipal Operations
Staff Interviewed:
(Name, Title, Role)
See MS4 Representatives list, all parties present
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 ---
Staff were familiar with the facilities that have potential (Operations Center and Splash Pad), but there is no formal inventory or
inspection of all facilities to ensure that potential is correctly identified.

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.
Partial ---
If yes, the O&M program specifies the frequency of inspections. Not
Applicable ---
If yes, the O&M program specifies the frequency of routine maintenance
requirements.
Not
Applicable ---
If yes, the permittee evaluated the O&M program annually and updated it as
necessary.
Not
Applicable ---
The permittee Central Operations facility was in good condition with most exposure adequately managed, but there is no formal
maintenance, program or inspections process in place.

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

NCS000500_Ayden MS4 Audit Report_20190723 Page 17 of 30
Pollution Prevention and Good Housekeeping for Municipal Operations
The permittee is also subject to the federal Spill Prevention, Control and Countermeasure (SPCC) regulations found in 40 CFR 110.
This is due to the amount of fuel stored on site (aggregate above ground storage of 1,320 gallons or more). The permittee should
evaluate compliance with the SPCC regulations. SPCC requirements are also a typical component of the Stormwater Pollution
Prevention Plan (SPPP) for a specific facility.

The secondary containment berm around the bulk fuel tanks does not hold water and does not have a relief valve or pump-out
mechanism. Facility inspections must include inspection of accumulated runoff prior to releasing uncontaminated rainwater
from secondary containment, and the valve must be maintained in the closed position at all times when not specifically
discharging following inspection. Contaminated runoff must be disposed of properly, not discharged.

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.
No ---
If yes, the permittee evaluated the effectiveness of existing and new BMPs
based on cost and the estimated quantity of pollutants removed.
Not
Applicable ---
The permittee has a route for street sweeping and owns a conventional wet jet sweeper. Leaf collection occurs seasonally on a
weekly basis, typically from October to February. Collected material is disposed of at the ER Lewis Landfill.

II.G.2.d (error)
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.
Yes ---
The permittee periodically cleans catch basins and maintains conveyance systems.

II.G.2.e
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.
Partial ---
Staff were familiar with the single device installed, but there was no written inventory.

NCS000500_Ayden MS4 Audit Report_20190723 Page 18 of 30
Pollution Prevention and Good Housekeeping for Municipal Operations
II.G.2.f
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 ---
The permittee does not own or operate any public SCMs.
II.G.2.g
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 ---
Applicators on staff are certified.

II.G.2.h
Staff Training The permittee implemented an employee training program for employees involved
in implementing pollution prevention and good housekeeping practices. No ---
Staff training does not include a stormwater components at this time, but LTAP training may include stormwater components.
Semi-annual staff training could incorporate a stormwater component.

II.G.2.i
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 ---

NCS000500_Ayden MS4 Audit Report_20190723 Page 19 of 30
Pollution Prevention and Good Housekeeping for Municipal Operations
Comments

Additional
Comments:

NCS000500_Ayden MS4 Audit Report_20190723 Page 20 of 30
Site Visit Evaluation: Municipal Facility No. 1
Facility Name:
Town of Ayden Operations Center
Date and Time of Site Visit:
07/23/2019 at 10:30 AM
Facility Address:
4061 East Avenue
Ayden, NC
Facility Type (Vehicle Maintenance, Landscaping, etc.):

Central Operations
Name of MS4 inspector(s) evaluated:
N/A

Most Recent MS4 Inspection (List date and name of inspector):

N/A
Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name Title
See MS4 Representatives list, all parties present
Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility-specific?
There is no SPPP for this facility.
What type of stormwater training do facility employees receive? How often?
None.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
There is no designated inspector at this time.
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
N/A
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
N/A
Inspection Procedures
Does the MS4 inspector’s process include the use of a checklist or other standardized form?
N/A
Does the MS4 inspector’s process include taking photos?
N/A
Does the MS4 inspector’s process include reviewing the facility’s SWPPP (or similar document)?
N/A

NCS000500_Ayden MS4 Audit Report_20190723 Page 21 of 30
Site Visit Evaluation: Municipal Facility No. 1
Does the MS4 inspector’s process include walking the entire facility and inspecting all points of discharge?
N/A
Did the MS4 inspector miss any obvious areas of concern? If so, explain:
N/A
Does the MS4 inspector’s process include presenting the inspection findings to the facility contact?
N/A
Inspection Results
Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)?
During the inspection, the Town Manager directed minor corrections to be made immediately and major corrections to be
addressed.
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
N/A
Notes/Comments/Recommendations
Since there was no SPPP or inspector for this facility, DEQ performed an instructional inspection for the benefit of town staff.
See also Appendix B: Photo Log

General PP/GH items:
• Document routine inspections utilizing a standard form
• Label contents and securely close all containers when not in use
• Close dumpster and trash receptacle lids at all times when not adding or removing waste
• Install and periodically inventory spill kit contents at fueling, chemical mixing and vehicle/equipment maintenance
areas
• Inspect secondary containment prior to releasing accumulated stormwater (see maintenance item below)
• Store outdoor containers in a manner that prevents accumulation of rain water
• Provide secondary containment and centralized storage for large containers that may spill (see maintenance item
below)
• Store flammables in secure flammables cabinets (see maintenance item below)
• Clean up and dispose of materials properly immediately following a spill
• Staff training for pollution prevention and stormwater awareness
• Dispose of items and materials no longer in use

It is also recommended that areas where liquids are stored and transferred have eye wash stations that are routinely inspected
(there are portable, pre-packaged eye wash kits available, they have expiration dates). The maintenance bays should be kept
clean to facilitate identification of new issues (quick dry materials should be cleaned up and disposed of after each spill and
fluids should not accumulate on top of drums).

Facility Maintenance Items:
• The secondary containment system for bulk fuel storage is in need of repair. It does not hold water and there is no
valve or pump-out mechanism in place to release uncontaminated stormwater.
• The vehicle maintenance area should install spill containment for drums and containers of fluids (plastic spill pallets are
commercially available).

NCS000500_Ayden MS4 Audit Report_20190723 Page 22 of 30
Site Visit Evaluation: Municipal Facility No. 1
• Several flammables cabinets are showing signs of metal fatigue and rust. Replacement is recommended.
• One yard inlet is in need of maintenance to remove accumulated solids. Consider installing measures that would reduce
the effort of maintaining this location.

NOTE: THIS FACILITY IS REQUIRED TO APPLY FOR AND OBTAIN A GENERAL NPDES STORMWATER PERMIT FOR VEHICLE
MAINTENANCE AREAS (NCG080000).

NCS000500_Ayden MS4 Audit Report_20190723 Page 23 of 30
Site Visit Evaluation: MS4 Outfall No. 1
Outfall ID Number:
N/A

Date and Time of Site Visit:
07/23/19 at 11:30 AM
Outfall Location:
Boulevard Street across from the Straightway Church

Outfall Description (Pipe Material/Diameter, Culvert, etc.):
24” RCP

Receiving Water:
UT Swift Creek

Is Flow Present? If So, Describe (Color, Approximate Flow Rate,
Sheen, Odor, Floatables/Debris, etc.):

Trickle flow, no discernible stormwater runoff pollution Most Recent Outfall Inspection/Screening (Date):
N/A
Days Since Last Rainfall:

Inches:

Name of MS4 Inspector(s) evaluated:
N/A
Observations
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?

N/A

Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations?
N/A

Inspection Procedures
Does the inspector’s process include the use of a checklist or other standardized form?
N/A
Does the inspector’s process include taking photos?
N/A
Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they?
N/A

NCS000500_Ayden MS4 Audit Report_20190723 Page 24 of 30
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)?
N/A

Will a follow-up outfall inspection be conducted? If so, for what reason?
N/A
Notes/Comments/Recommendations

Since the permittee did not have any inspection protocol, forms or staff, the DEQ performed an instructional inspection. There
were no visible or olfactory indications of stormwater pollution and there many fish present at the outfall.

NCS000500_Ayden MS4 Audit Report_20190723 Page 25 of 30
Site Visit Evaluation: MS4 Outfall No. 2
Outfall ID Number:
N/A

Date and Time of Site Visit:
07/23/2019 At 11:45 AM

Outfall Location:
Intersection of East Ave & Boulevard Street

Outfall Description (Pipe Material/Diameter, Culvert, etc.):
Brick arch

Receiving Water:
UT Swift Creek

Is Flow Present? If So, Describe (Color, Approximate Flow Rate,
Sheen, Odor, Floatables/Debris, etc.):

Dry outfall, no indication of stormwater pollution

Most Recent Outfall Inspection/Screening (Date):
N/A

Days Since Last Rainfall:

Inches:

Name of MS4 Inspector(s):
N/A
Observations
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
N/A

Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations?
N/A

Inspection Procedures
Does the inspector’s process include the use of a checklist or other standardized form? Obtain copy.
N/A

Does the inspector’s process include taking photos?
N/A

Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they?
N/A

NCS000500_Ayden MS4 Audit Report_20190723 Page 26 of 30
Site Visit Evaluation: MS4 Outfall No. 2
Inspection Results
Did the outfall inspection result in any work orders or maintenance requests? If so, for what issue(s)?
N/A

Will a follow-up outfall inspection be conducted? If so, for what reason?
N/A

Notes/Comments/Recommendations

Since the permittee did not have any inspection protocol, forms or staff, the DEQ performed an instructional inspection. There
were no visible or olfactory indications of stormwater pollution and there many fish present at the outfall. Discussion included
the difference between a conveyance and an outfall and the location at which the outfall inspection should occur.

NCS000500_Ayden MS4 Audit Report_20190723 Page 27 of 30
Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1
Site Name:
Pizza Hut
Date and Time of Site Visit:
07/23/2019 at 12:00 PM
Site Address:
134 NC-102
Ayden, NC
SCM Type:
Wet Detention Basin
Most Recent MS4 Inspection (Include Date and Entity):
N/A
Name of MS4 Inspector(s) evaluated:
N/A
Most Recent MS4 Enforcement Activity (Include Date):
N/A
Name(s) and Title(s) of Site Representative(s) Present During the Site Visit:
Name Title
Steven Harrell Town Manager
Rich Moore Engineer
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?
No documentation available, but a qualified engineer has inspected the facility (Rich Moore)
Inspector Training/Knowledge

What type of stormwater training does the MS4 inspector receive? How often?
N/A

Did the MS4 inspector appear knowledgeable about MS4 requirements for post-construction site runoff controls?
Yes
Did the MS4 inspector appear knowledgeable about post-construction BMPs (general purpose/function, components, O&M
requirements, etc.)?
Yes

Inspection Procedures
Does the MS4 inspector’s process include the use of a checklist or other standardized form? What format?
No
Does the MS4 inspector’s process include taking photos?
No

NCS000500_Ayden MS4 Audit Report_20190723 Page 28 of 30
Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1
Does the MS4 inspector’s process include reviewing the site’s operation and maintenance plan and records of annual inspections?
Partial
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:
Woody vegetation should be removed from the shelf and embankment areas
Does the MS4 inspector’s process include presenting the inspection findings to the site contact in writing?
No
Compliance/Enforcement
What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in?
None
If compliance issues were identified, what timeline for correction/follow-up was provided?
N/A
Notes/Comments/Recommendations
The permittee needs to establish formal inspection and documentation protocols. The SCM had been recently mowed, but
woody vegetation was growing along the shelf and embankment. The rest of the device appeared to be in good working order.

NCS000500_Ayden MS4 Audit Report_20190723 Page 29 of 30

APPENDIX A: SUPPORTING DOCUMENTS

NCS000500_Ayden MS4 Audit Report_20190723 Page 30 of 30

APPENDIX B: PHOTOGRAPH LOG