NCS000453_Indian Trail Self Audit Report_20210616

MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM AUDIT REPORT
NPDES PERMIT NO. NCS000453
INDIAN TRAIL, NORTH CAROLINA
315 MATTHEWS-INDIAN TRAIL ROAD
Audit Date: 02/17/2021
Report Date: 03/02/2021
North Carolina Department of Environmental Quality
Division of Energy, Mineral & Land Resources Stormwater Program
512 N. Salisbury Street, 9th floor
1612 Mail Service Center
Raleigh, NC 27699-1612

MS4 Permit Audit Report
Indian Trail, NC: NPDES Permit No. NCS000453
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Audit Date: 02/17/21

MS4 Permit Audit Report
Indian Trail, NC: NPDES Permit No. NCS000453
TABLE OF CONTENTS
AuditDetails..................................................................................................................................................1
PermitteeInformation..................................................................................................................................2
SupportingDocuments................................................................................................................................. 3
Construction Site Runoff Controls................................................................................................................4
Post -Construction Site Runoff Controls........................................................................................................7
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.
Audit Date: 02/17/21 ii

MS4 Permit Audit Report
Indian Trail, NC: NPDES Permit No. NCS000453
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Audit Date: 02/17/21 iii

MS4 Permit Audit Report
Indian Trail, NC: NPDES Permit No. NCS000453
Audit Details
Audit ID Number:
Audit Date(s):
NCS000453_Indian Trail MS4 Audit_2019/2020
March 2, 2021
Minimum Control Measures Evaluated:
❑ Program Implementation, Documentation & Assessment
❑ Public Education & Outreach
❑ Public Involvement & Participation
❑ Illicit Discharge Detection & Elimination
❑X Construction Site Runoff Controls — No delegated Sediment and Erosion Control Program
❑X Construction Site Runoff Controls — Delegated Sediment and Erosion Control Program
❑X 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: Choose an item.
❑ MS4 Outfalls. Number visited: Choose an item.
❑ Construction Sites. Number visited: Choose an item.
❑ Post -Construction Stormwater Runoff Controls. Number visited: Choose an item.
❑ Other: Number visited: Choose an item.
❑ Other: Number visited: Choose an item.
Inspector(s) Conducting Audit
Name, Title
Orsanization
Audit Report Author:
Date:
Signature
Audit Report Author:
Date
Signature
Audit Date(s): 02/17/2021 Page 1 of 12

MS4 Permit Audit Report
Indian Trail, NC: NPDES Permit No. NCS000453
Permittee Information
MS4 Permittee Name: Permit Effective Date: Permit Expiration Date:
Date of Last MS4 Inspection/Audit:
City, State, ZIP:
Co-permittee(s), if applicable:
Permit Owner of Record:
Primary MS4 Representatives Participating in Audit
Name, Title Organization
MS4 Receiving Waters
Waterbody Classification Impairments
Audit Date(s): 02/17/2021 Page 2 of 12

MS4 Permit Audit Report
Indian Trail, NC: NPDES Permit No. NCS000453
Supporting Documents
Item When Provided
Number I Document Title I. (Prior to/During/After)
Post -Construction Storm Water Ordinance
https://www. i n d is ntra i l.org/180/Post-Construction-Sto rmwater-0 rd i n a n ce
2 Unified Development Ordinance
https://www.indiantraii.org/190/Unified-Development-Ordinance
Stormwater Phone Line
3
https://www.indiantraii.org/298/Stormwater-Services
Audit Date(s): 02/17/2021 Page 3 of 12

MS4 Permit Audit Report
Indian Trail, NC: NPDES Permit No. NCS000453
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).
❑X The permittee does not have a delegated Sediment and Erosion Control Program and relies on DEMLR to comply
with the North Carolina Sedimentation Pollution Control Act (SPCA) of 1973 components of this minimum measure
(complete only the permit citation section).
Permit Citation Program Requirement Status
Supporting
Doc No.
II.E.3 Construction
Site Runoff Controls The permittee provides and promotes a means for the public to notify the
(NPDES Permit No. appropriate authorities of observed erosion and sedimentation problems (e.g., .•df Udi
NCS000435) promoting the existence of the DEQ DEMLR "Stop Mud" hotline).
Comments (Describe how provided and promoted)
Town has a stormwater hotline and utilize this for all stormwater and active construction issues. Residents have used this line to
notify Town of erosion issues as well. The Town will start promoting NC DEQ hotline.
SPCA Citation
I Delegated Program Requirement
Status
Supporting
Doc No.
§ 113A-60 Local
The permittee has adopted an ordinance or other regulatory mechanism to enforce
erosion and
Partial
the erosion and sedimentation control program.
sedimentation
control programs (a)
If yes, the ordinance meets or exceeds the minimum requirements of the
Not
SPCA.
Applicable
If yes, the ordinance applies throughout the corporate limits of the permittee.
Not
[Permit Part I.D]
Applicable
Town does have an adopted ordinance that discusses erosion and sedimentation control. Town delegates NCDEQ to permit any
sites greater than an acre.
§ 113A-60 Local
erosion and
The permittee collects a fee paid by each person who submits an erosion and
Not
sedimentation
sedimentation control plan.
Applicable
control programs (d)
Audit Date(s): 02/17/2021 Page 4 of 12

MS4 Permit Audit Report
Indian Trail, NC: NPDES Permit No. NCS000453
Construction Site Runoff Controls
Comments (indicate the fee amount, if applicable)
§ 113A-60 Local
Has any person initiated a land -disturbing activity (within the permittee's
erosion and
jurisdiction) for which an erosion and sedimentation control plan is required in the
No
---
sedimentation
absence of an approved plan?
control programs (e)
If yes, the permittee has notified the North Carolina Sedimentation Control
Not
Commission of all such cases.
Applicable
Has the permittee determined that a person engaged in a land -disturbing activity
Not
has failed to comply with an approved erosion and sedimentation control plan?
Applicable
If yes, has the permittee referred any such matters to the North Carolina
Not
Sedimentation Control Commission for inspection and enforcement?
Applicable
Comments
§ 113A-61 Local
The permittee reviews each erosion and sedimentation control plan submitted to
approval of erosion
them and notifies the person submitting the plan that it has been approved,
Partial
1
and sedimentation
approved with modification, or disapproved within 30 days of receipt.
control plans
The permittee only approves an erosion and sedimentation control plan upon
determining that it complies with all applicable State and local regulations.
Yes
---
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,
Not
Mineral, and Land Resources within 10 days of the disapproval.
Applicable
The Town requires plans for small sites if it feels it's warranted based on location, topography, geography, etc.
§ 113A-61.1
Inspection of land-
The certificate of approval of each erosion and sedimentation control plan
disturbing activity;
approved by the permittee includes a notice of the right to inspect.
Yes
1
notice of violation
(a)
The permittee provides for inspection of land -disturbing activities to ensure
compliance with the SPCA and to determine whether the measures required in an
Partial
erosion and sedimentation control plan are effective.
Per UDO and Post -Construction, any Town representative has the right to inspect any construction activities. Contractors are
also told in preconstruction meetings that the Town will assist the State in onsite inspections, and if we see sites not adhering to
the standards of the State. The State will be notified and also the Contractor.
Audit Date(s): 02/17/2021 Page 5 of 12

MS4 Permit Audit Report
Indian Trail, NC: NPDES Permit No. NCS000453
Construction Site Runoff Controls
§ 113A-61.1
When the permittee determines that a person engaged in land -disturbing activity
Inspection of land-
has failed to comply with the SPCA, the Permittee immediately issues a notice of
Partial
2
disturbing activity;
violation upon that person.
notice of violation
Each notice of violation issued by the permittee specifies the date by which the
(c)
person must comply.
Partial
Each notice of violation issued by the permittee informs the person of the actions
Not
that need to be taken to comply.
Applicable
Please see previous comments. The Town will notify the State if we see site issues that are not meeting State standards. If site is
less than an acre then our UDO allows use to issue fines for non-compliance work.
§ 113A-64 Penalties
Does the permittee issue civil penalties as part of the erosion and sedimentation
program?
Yes
The Town can issue civil penalties for sites permitted by the agency based on existing ordinances.
Audit Date(s): 02/17/2021 Page 6 of 12

MS4 Permit Audit Report
Indian Trail, NC: NPDES Permit No. NCS000453
Post -Construction Site Runoff Controls
Staff Interviewed:
(Name, Title, Role)
Audit Date(s): 02/17/2021 Page 7 of 12

MS4 Permit Audit Report
Indian Trail, NC: NPDES Permit No. NCS000453
Post -Construction Site Runoff Controls
Implementation (check all that apply):
0 The permittee implements the components of this minimum measure.
❑ The permittee relies upon another entity to implement the components of this minimum measure:
❑ 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-1) — 15A NCAC 213.0212
❑ Water Supply Watershed 11 (WS-11) — 15A NCAC 26 .0214
❑ Water Supply Watershed III (WS-III) —15A NCAC 26 .0215
❑ Water Supply Watershed IV (WS-IV) —15A NCAC 213.0216
❑ 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
0 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.
Session Law 2006- supporting
246 Program Requirement Status Doc No.
Audit Date(s): 02/17/2021 Page 8 of 12

MS4 Permit Audit Report
Indian Trail, NC: NPDES Permit No. NCS000453
Post -Construction Site Runoff Controls
Deemed -Compliant
The permittee implements deemed -compliant Program requirements in
Program(s)
accordance with the applicable 15A NCAC rules.
Yes
1
The permittee implements deemed -compliant Program requirements throughout
the entire MS4 area (If not also complete the Permit Citation section below.)
Yes
1
The permittee applies deemed -compliant Program requirements to all federal,
state and local government projects within the permitted MS4 area who do not
Yes
1
have their own NPDES stormwater permit.
The permittee included deemed -compliant Program reporting in their MS4 Annual
Reports.
Yes
1
The permittee included deemed -compliant Program implementation in their
Stormwater Management Plan.
Yes
1
No Comment
Permit Citation
Program Requirement
Status
supporting
Doc No.
II.F.2.a
The permittee maintained an ordinance or other regulatory mechanism designed
Legal Authority
to meet the objectives of the Post -Construction Site Runoff Controls Stormwater
Yes
Management Program.
If yes, the ordinance applies throughout the Indian Trail corporate limits of the
permittee (Verify permit coverage area listed in Part I.D of permit and modify
Yes
1
accordingly).
The permittee has the authority to review designs and proposals for new
development and redevelopment to determine whether adequate stormwater
Yes
1
control measures will be installed, implemented, and maintained.
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
Yes
1
Program.
The permittee has the authority to enter private property for the purpose of
inspecting at reasonable times any facilities, equipment, practices, or operations
Yes
1
related to stormwater discharges.
No Comment
II.F.2.b
Stormwater Control
The permittee utilizes strategies which include SCMs appropriate for the MS4.
Yes
1
Measures (SCMs)
SCMs comply with 15A NCAC 02H .1000.
Yes
1
Audit Date(s): 02/17/2021 Page 9 of 12

MS4 Permit Audit Report
Indian Trail, NC: NPDES Permit No. NCS000453
Post -Construction Site Runoff Controls
Comments
II.F.2.c
The permittee conducted site plan reviews of all new development and
Plan Reviews
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
Yes
1
development or sale).
If yes, the site plan reviews addressed how the project applicant meets the
performance standards.
Yes
1
If yes, the site plan reviews addressed how the project will ensure long-term
Yes
1
maintenance.
No Comment
II.F.2.d
The permittee maintained an inventory of projects with post -construction
Inventory of Projects
structural stormwater control measures installed and implemented at new
Yes
---
development and redeveloped sites.
The inventory included both public and private sector sites located within the
permittee's corporate limits that are covered by its post -construction ordinance
Yes
---
requirements.
Town utilizes a plan review software (Infovision: Evolve) that stores and houses project data. Town also scans and keeps a copy
of all recorded documents stated above.
II.F.2.e
The permittee provided mechanisms such as recorded deed restrictions and
Deed Restrictions
protective covenants that ensure development activities will maintain the project
Yes
1
and Protective
consistent with approved plans.
Covenants
No Comment
II.F.2.f
The permittee implemented or required an operation and maintenance plan for
Mechanism to
the long-term operation of the SCMs required by the program.
Yes
1
Require Long-term
Operation and
The operation and maintenance plan required the owner of each SCM to perform
Maintenance
and maintain a record of annual inspections of each SCM.
Yes
1
Annual inspection of permitted structural SCMs are required to be performed by a
qualified professional.
Yes
1
No Comment
Audit Date(s): 02/17/2021 Page 10 of 12

MS4 Permit Audit Report
Indian Trail, NC: NPDES Permit No. NCS000453
Post -Construction Site Runoff Controls
II.F.2.g
The permittee conducted and documented inspections of each project site covered
Inspections of
under performance standards, at least one time during the permit term (Verify this
Partial
2
Structural
is a permit condition in Part II.F.2.g of permit and modify accordingly).
Stormwater Control
Before issuing a certificate of occupancy or temporary certificate of occupancy, the
Measures
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
Yes
2
completion (Verify this is a permit condition in Part II.F.2.g of permit and modify
accordingly.
The permittee developed and implemented a written inspection program for SCMs
installed pursuant to the post -construction program(Verify this is a permit
Yes
1
condition in Part II.F.2.g of permit and modify accordingly.
The permittee documented and maintained records of inspections.
No
---
The permittee documented and maintained records of enforcement actions.
Yes
---
Site inspections are not documented on paper. Planning Department does not issue a final C/O until both Engineering and
Planning staff provide in writing that their individual inspections are completed and site complies with all Town standards.
II.F.2.h
The permittee made available through paper or electronic means, ordinances,
Educational
post -construction requirements, design standards checklists, and other materials
Materials and
appropriate for developers.
Training for
Note: New materials may be developed by the permittee, or the permittee may use
Yes
---
Developers
materials adopted from other programs and adapted to the permittee's new
development and redevelopment program.
Most documents are available for developers, but Town will be providing in future a checklist type document as guidance.
II.F.2.i Enforcement
The permittee tracked the issuance of notices of violation and enforcement
Partial
---
actions.
If yes, the tracking mechanism included the ability to identify chronic violators
for initiation of actions to reduce noncompliance.
Partial
---
Town does document, but a central database isn't utilize, but will be developed in new SWMP plan.
II.F.3.b
The permittee fully complies with post construction program requirements on its
New Development
own publicly funded construction projects.
Yes
---
No Comment
Audit Date(s): 02/17/2021 Page 11 of 12

MS4 Permit Audit Report
Indian Trail, NC: NPDES Permit No. NCS000453
Post -Construction Site Runoff Controls
II.F.3.c
Does the MS4 have areas draining to Nutrient Sensitive Waters (NSW) pursuant to
Nutrient Sensitive
15A NCAC 02H .0150?
No
---
Waters
If yes, does the permittee use SCMs that reduce nutrient loading in order to
Not
meet local program requirements.
Applicable
_
If yes, does the permittee also still incorporate the stormwater controls
Not
required for the project's density level.
Applicable
If yes, does the permittee also require documentation where it is not feasible to
Not
use SCMs that reduce nutrient loading.
Applicable
No Comment
II.F.3.d
The permittee ensured that the design volumes of SCMs take into account the
Design Volume
runoff at build out from all surfaces draining to the system.
Yes
1
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
Yes
1
streets, driveways, and other impervious surfaces.
No Comment
Audit Date(s): 02/17/2021 Page 12 of 12