NCS000408_City of Graham Audit Report Final_20211015

MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM AUDIT REPORT
NPDES PERMIT NO. NCS000408
The City of Graham, NORTH CAROLINA
PO Drawer 357
Graham, NC 27253
Audit Date: October 6 & 7, 2021
Report Date: October 15, 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

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NCS000408_The City of Graham MS4 Audit_20211015

TABLE OF CONTENTS
AuditDetails..................................................................................................................................................1
PermitteeInformation..................................................................................................................................2
Listof Supporting Documents.......................................................................................................................3
Program Implementation, Documentation & Assessment...........................................................................5
Illicit Discharge Detection and Elimination(IDDE)........................................................................................9
Post -Construction Site Runoff Controls......................................................................................................11
Pollution Prevention and Good Housekeeping for Municipal Operations..................................................16
Site Visit Evaluation: Municipal Facility No. 1.............................................................................................19
Site Visit Evaluation: Municipal Facility No. 2.............................................................................................21
Site Visit Evaluation: MS4 Outfall No. 1......................................................................................................23
Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1............................................25
Appendix A: Supporting Documents
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.
NCS000408_The City of Graham MS4 Audit_20211015

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NCS000408_The City of Graham MS4 Audit_20211015

Audit Details
Audit ID Number:
Audit Date(s):
NCS000408_City of Graham MS4 Audit_20211006
October 6 & 7, 2021
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
❑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: 2
® 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, Title
Organization
Levi Hiatt, Assistant Regional Engineer
NCDEQ— DEMLR: WSRO
Zac Lentz, Assistant Regional Engineer
NCDEQ— DEMLR: WSRO
Blare Houck, Environmental Specialist
NCDEQ—DEMLR: WSRO
Kimberly Turney, Environmental Specialist
NCDEQ—DEMLR: WSRO
Audit Report Author:
Date:
Signature oils'
10/1 5 /Z 1
Audit Report Author:
Date:
10' IS' 2 1
Signature
Audit Report Author:
Date:
10/l 5/aaa i
Signature
Audit Report Author:
Date:
ID 16
Signature i wt
U U
NCS000408_City of Graham MS4 Audit_20211015 Page 1 of 32

Permittee Information
MS4 Permittee Name:
The City of Graham
Permit Effective Date:
February 20,2017
Permit Expiration Date:
February 19, 2022
Mailing Address: P.O. Drawer 357, Graham,
NC27253
Date of Last MS4 Inspection/Audit:
N/A
Co-permittee(s), if applicable:
N/A
Permit Owner of Record:
Aaron Holland, Interim/Assistant City Manager
Primary MS4 Representatives Participating in Audit
Name, Title
Organization
Josh Johnson, PE, Vice President, Head of
Engineering
Alley, Williams, Carmen &King (AWCK)
Phil Ross, Stormwater Coordinator
Alley, Williams, Carmen & King (AWCK)
Aaron Holland, Interim/Assistant City
Manager
The City of Graham
Burke Robertson, Public Works Director
The City of Graham
Justin Snyder, Planning Director
The City of Graham
Cameron West, Planning Staff
The City of Graham
MS4 Receiving Waters
Waterbodv
Classification
Impairments
Haw River
WS-V; NSW
Benthos
Town Branch
WS-V;NSW
Fecal Coliform
County Home Branch (Still House Branch)
WS-V; NSW
N/A
Big Alamance Creek
WS-V; NSW
N/A
Back Creek (Little Creek)
WS-V; NSW
N/A
Little Alamance Creek
WS-V; NSW
Benthic Macro Invertebrates
Bowden Branch (Boyd Creek)
WS-V; NW
N/A
NCS000408_City of Graham MS4 Audit_20211015 Page 2 of 27

List of Supporting Documents
Item
Nu_ tuber'
Document Title
When Provided
(Prior to/During/After)
1
Graham Final Permit 2017
Prior
2
Graham-CSWMP-Report 2017 rev. August 2021
Prior
3
NPDES Phase II Stormwater Annual Report — Graham 2015
Prior
4
NPDES Phase II Stormwater Annual Report —Graham 2016
Prior
5
NPDES Phase II Stormwater Annual Report — Graham 2017
Prior
6
NPDES Phase II Stormwater Annual Report — Graham 19-20
Prior
7
Stormwater ePayments
Prior
8
Collection System 2021 Annual Report
Prior
9
Graham Collection System Audit Report
Prior
10
Graham Stormwater Website Page
Prior
11
Graham Ordinance Website Page
Prior
12
Graham 20201DDE Program Update
Prior
13
Graham O&M Plan 2019 Final Revised
Prior
14
Stormwater Smart— FY21 Summary Report
Prior
15 .
302 Oakgrove Dr IDDE Follow up Letter Final
Prior
16
302 Oakgrove Drice aerial
Prior
17
302 Oakgrove Drive IDDE NOV Letter
Prior
18
302 Oakgrove Drive IDDE Closeout Pics Filling tank with Concrete
Prior
19
2020 Graham Streamwalk data pack
Prior
20
Graham IDDE Tracking Spreadsheet
Prior
NCS000408_City of Graham MS4 Audit_20211015 Page 3 of 27

21
2021 Graham SCM Inspection log
Prior
22
2020 City of Graham SW Inspection Letter
Prior
23
2021 City of Graham SW Inspection Letter— Non Compliance
Prior
24
2021 City of Graham SW Inspection Letter
Prior
25
Stormwater Ordinance from Graham Development Ordinances
Prior
26
MS4 Map Package
Prior
27
IDDE and PPGH Training Documents
Prior
28
Contract — City Engineer & Admin — City of Graham 8-20-07
Prior
29
Graham — City Engineer &AdminSvcs —2003—Signed
After
30
Graham City Council Meeting Minutes —9-4-07— with Engineering Agreement
After
31
2018 Graham Stormwater Assessment
Prior
32
Graham Stream Walk 2017
Prior
33
2021 Virtual IDDE-PPGH Training
After
34
3-3-21 Cherry Creek Calculations Package
After
35
3-3-21Cherry Creek Subdivision MCB-JSJReview
After
36
Watercourse Apt Stormwater 0&M Agreement
Prior
37
AutoZone Bioretention 78 Inspection Report 2020 with Coversheet
After
38
City of Graham SCM Maintenance Program
After
39
Graham Phase 2 Stormwater Spreadsheet
After
40
Stormwater Overview
Prior
NCS000408_City of Graham MS4 Audit_20211015 Page 4 of 27

Program Implementation, Documentation & Assessment
Staff Interviewed:
Josh Johnson, Vice President and Head Engineer AWCK, Stormwater Engineer for the City of Graham
(Name, Title, Role)
Phil Ross, Stormwater Coordinator A WCK, Stormwater Coordinator and Inspector for the City of Graham
Permit Citation
Program Requirement
Status =
supporting
Doc No.
II.A.1
The permittee maintained adequate funding and staffing to implement and manage
Staffing and
the provisions of the Stormwater Plan and meet all requirements of the permit.
Yes
3, 4, 5, 6
Funding
The Stormwater Plan identifies a specific position(s) responsible for the overall
coordination, implementation, and revision to the Plan.
Yes
2
Responsibilities for all components of the Stormwater Plan are documented and
position(s) assignments provided.
Yes
2
The permittee is current on payment of invoiced administering and compliance
monitoring fees (see stormwater e-payments on DEMLR MS4 web page).
Yes
7
Comments (Briefly describe funding mechanism, number of staff, etc.)
The MS4 budgeted $70,000 in 2019-2020 for the stormwater program, an increase from $50,000 earlier in the permit cycle. This was
funded through a flat $2.00 monthly fee from utility users. This fee also funds Grahams Jordan Lake and Little Alomance Creek
programs. The current budget or staffing appears to be adequate to implement and manage the SWMP.
The City of Graham currently has 3 staff dedicated to their stormwater program.
The SWMP lists responsible contacts in relation to daily duties in the City Government but does not specifically identify who is
responsible for the overall coordination, implementation, and revision to the Plan.
The SWMP does list the responsible positions of each BMP for the 6 MCM's.
II.A.2 Stormwater
The permittee evaluated the performance and effectiveness of the program
Plan
components at least annually.
Partial
3, 4, 5, 6
Implementation
and Evaluation
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.
Partial
3, 4, 5, 6
Did the permitted M54 discharges cause or contribute to non -attainment of an
3, 4, 5, 6,
applicable water quality standard?
No
8,9
If yes, did the permittee expand or better tailor its BMPs accordingly to address
Not
the non -attainment?
Applicable
---
Comments
The annual reports evaluate the results of the previous year for Illicit Discharge Detection and Elimination, and Post Construction
Site Runoff Controls and lists a solution for both issues pertaining to the frequency of training, and the lack of annual inspections
performed by the owners of SCM's.
The MS4 experienced multiple sewage overflows of 1000 gallons or more during the current permit cycle. These overflows were
mainly due to stormwater infiltration during heavy rain events and appeared to not of caused or contributed to non -attainment of
an applicable water quality standard.
II.A.3
The permittee kept the Stormwater Plan up to date.
Partial
2
NCS000408_City of Graham MS4Audit_20211015 Page 5 of 27

Program Implementation, Documentation& Assessment
Keepingthe
Stormwater Plan
The permittee notified DEMLR of any updates to the Stormwater Plan.
No
---
Up to Date
Comments (Indicate the date of latest Stormwater Plan and describe the nature of any updates, if applicable).
The contact information listed in the Stormwater Plan was updated in 2021. It appears this was the only update made during the
current permit cycle. DEMLR has no record of this update.
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.
Yes
10
Plan
The online materials included ordinances, or other regulatory mechanisms, or a list
identifying the ordinances, or other regulatory mechanisms, providing the legal
Yes
11
authority necessary to implement and enforce the requirements of the permit.
Comments (Note what materials are available online)
A copy of the Stormwater Plan is available on the Graham Stormwater webpage. A copy of the Code of Ordinances as well as
Developmental Ordinances is available on the Graham Ordinances webpage.
I I.A.3 & I I.A.S
Stormwater Plan
Did DEMLR require 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)
There is no record from DEMLR or the permittee to indicate that a modification to the Stormwater Plan was required.
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?
Partial
28, 29,
30
Comments (List the specific control measures implemented by others that do not have adequate written agreements, if
applicable)
The permittee utilizes PTRC's Stormwater SMART program to fulfil the Public Education and Outreach and Public Involvement and
Participation MCMs, but a formal agreement is not in place.
The permittee also utilizes AWCK for on -call city engineering services. A contract template was provided, but a copy of the final,
signed, copy of the current contract between AWCK and the MS4 was not provided. City Council Meeting Notes from 2007 were
provided that give further insight on AWCK's relationship with the MS4. A signed copy of the contract between the MS4 and AWCK
from 2003 was provided.
Furthermore, DEMLR implements Construction Site Runoff. No agreement is in place for this program, which is typical.
II.A.7
The permittee maintained written procedures for implementing the six minimum
Written
control measures.
Partial
2
Procedures
Written procedures identified specific action steps, schedules, resources and
responsibilities for implementing the six minimum measures.
Partial
2, 12, 13
NCS000408_City of Graham MS4 Audit_20211015 Page 6 of 27

Program Implementation, Documentation & Assessment
Comments (List the specific minimum measures that do not have adequate written procedures, if applicable)
It is unclear if the written procedures for implementing the six MCM's were maintained. Written procedures identifying specific
action steps, resources, and responsibilities for implementing the six minimum measures were included in the SWMP, but the
schedules for doing so were not, specifically forfacility inspections.
III. A
3, 4, 5, 6,
.Program
13, 14,
Documentation
The permittee maintained documentation of all program components including, but
15, 16,
not limited to, inspections, maintenance activities, educational programs,
Partial
17, 18,
implementation of BMPs, enforcement actions etc., on file for a period of five years.
19, 20,
21, 22,
23,24
Comments (List the specific program components that do not have adequate documentation on file and why, if applicable)
Asummary of the educational activities and the approximate number of persons impacted through those activities were provided in
the Annual Report. The 0&M Plan lists the most recent inspections for facilities owned and operated by the City of Graham as of
June 2020. The FV 2021 Mass Media Summary from Stormwater SMART does not list the number of ad impressions from the City of
Graham concerning Public Education and Outreach but does list the approximate number of participants from Graham for their
virtual activities. The tracking information provided for SCM inspections conducted by the City of Graham was only for 2021.
11LB
The permittee submitted annual reports to the Department within twelve months
Annual Report
from the effective date of the permit (See Section III.B. for the annual reporting
Partial
3
Submittal
period specific to this MS4).
The permittee submitted subsequent annual reports every twelve months from the
3, 4, 5, 6,
scheduled date of the first annual report submittal.
Partial
31
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
Partial
3, 4, 5, 6
schedules and plans for the year following each report.
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
Partial
3, 4, 5, 6
Plan (results, effectiveness, implementation schedule, etc.).
3. Documentation of any necessary changes to programs or practices for
assessment of management measures implemented through the Stormwater
No
---
Plan.
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
Partial
3, 4, 5, 6
Stormwater Plan.
5. An assessment of compliance with the permit, information on the
establishment of appropriate legal authorities, inspections, and enforcement
Partial
3, 4, 5, 6
actions.
NCS000408_City of Graham M54 Audit_20211015 Page 7 of 27

Program Implementation, Documentation & Assessment
Comments (Note dates that annual reports cover under current permit and generally describe report deficiencies, if any)
Annual Reports were provided for every year during the current permit cycle, but it is unclear if they were submitted to the Division
every year. The Annual Reports evaluate the results of the previous year for Illicit Discharge Detection and Elimination, Post
Construction Site Runoff Controls, and the budget, and lists possible solutions pertaining to the frequency of training, the lack of
annual inspections performed by the owners of SCM's, and the possible budgetshortage in the future, but does not list a schedule or
plan for implementing those changes during the following year. Furthermore, the implementation and effectiveness of these
proposed changes were not discussed in the Annual Reports. The Annual Reports do list summaries of data accumulated, specifically
for Public Education and Outreach and Post Construction Site Runoff Controls but does not assess what the data indicates in light of
the CSWMP. The Annual Reports also do not assess program compliance with the permit and does not give information pertaining to
the establishment of appropriate legal authorities (except for IDDE), inspections, and enforcement actions.
IV.B
Annual Reporting
The Annual Reports document the following:
1. A summary of past year activities, including where applicable, specific
Partial
3, 4, 5, 6
quantities achieved and summaries of enforcement actions.
2. A description of the effectiveness of each program component.
No
---
3. Planned activities and changes for the next reporting period, for each
partial
3, 4, 5, 6
program component or activity.
4. Fiscal analysis. -
No
---
Comments (Note dates that annual reports cover under current permit and generally describe report deficiencies, if any)
The Annual Report summarizes activities for the post year and lists specific quantities achieved for all MCM's except for Construction
Site Runoff Controls. The Annual Reports do not list any summaries for enforcement actions, nor do they provide a description of the
effectiveness of each program component. The Annual Reports do list planned activities and changes for IDDE, and Post
Construction Site Runoff Controls, and discuss the budget and funding mechanism for the Stormwater Program, but do not analyze
on whether that budget or funding mechanism is currently adequate, nor do they reflect on the effectiveness of the changes
proposed (if any) in the previous report.
Additional
The Annual Reports are meant to be used as a current assessment of the SWMP and its implementation. The
Comments:
Annual Reports should describe the effectiveness of the SWMP and list any changes that need to be made, as
well as changes that have been made during the previous year. The Annual Reports should also better
summarize program impact inspections, maintenance activities, enforcement actions, trainings, etc. for the
previous year. Please revise the way in which the Annual Reports are conducted, so that they clearly provide
an update on how well the SWMP is being implemented, as well as an evaluation on how effective each
SWMP component is working to keep the MS4 in compliance with the permit.
NCS000408_City of Graham MS4 Audit_20211015 Page 8 of 27

Illicit Discharge Detection and Elimination (IDDE)
Staff Interviewed:
Josh Johnson, Vice President and Head Engineer A WCK, Stormwater Engineer for the City of Graham
(Name, Title, Role)
Phil Ross, Stormwater Coordinator A WCK, Stormwater Coordinator and Inspector for the City of Graham
Permit Citation
Program Requirement
Status
supposing
Dac No.
II.D.2.a
IDDE Program
The permittee maintained a written IDDE Program. -
Yes
25
If yes, the written program includes provisions for program assessment and
evaluation and integrating program.
Yes
25
The permittee maintained an IDDE ordinance or other regulatory mechanism(s) that
II.D.2.b
provides the legal authority to prohibit illicit connections and discharges to the MS4.
Yes
25
Legal Authorities
If yes, the ordinance applies throughout the corporate limits of the permittee.
[Permit Part I.D]
Yes
25
II.D.2.c
The permittee maintained a current map showing major outfalls* and receiving
Storm Sewer
Partial
26
System Map
streams.
Comments
The map provided does notstate or show whether the outfalls on the map are major or not.
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
12,27
Program
Comments
A general outline for conducting dry weather flow field observations was described within the Illicit Discharge and Elimination
Program documents. However, no evidence was presented to suggest that adequate recordkeeping and tacking was implemented.
II.D.2.e
The permittee maintained written procedures for conducting investigations of
Investigation
identified illicit discharges.
Yes
20, 32
Procedures
_[I
ILD.2.f
For each case of an illicit discharge or potential illicit discharge, the permittee documented and tracked the
Track and
following:
Document
Investigations
1. The date(s) the illicit discharge was observed
Yes
20
2. The results of the investigation
Yes
20
3. Any follow-up of the investigation
Yes
20
4. The date the investigation was closed
Yes
20
NCS000408_City of Graham MS4 Audit_20211015 Page 9 of 27

Illicit Discharge Detection and Elimination (IDDE)
II.D.2.g Employee
The permittee implemented and documented a training p p g program for appropriate
Training
municipal staff who, as part of their normal job responsibilities, may come into
Yes
27,33
contact with or otherwise observe an illicit discharge or illicit connection.
II.D.2.h
The permittee informed public employees of hazards associated with illegal
Public Education
discharges and improper disposal of waste.
Yes
27,33
The permittee informed businesses of hazards associated with illegal discharges and
Yes
27
improper disposal of waste.
The permittee informed the general public of hazards associated with illegal
discharges and improper disposal of waste.
Yes
27
II.D.2.i
The permittee promoted, publicized, and facilitated a reporting mechanism for the
Public Reporting
public to report illicit discharges.
Partial
27
Mechanism
The permittee promoted, publicized, and facilitated a reporting mechanism for staff
to report illicit discharges.
Partial
27
The permittee established and implemented response procedures for citizen
Partial
27
requests/reports.
Comments
General reporting procedures for municipal employees were described during training events, and a helpline, found on the
program's website, was promoted during several public outreach events. However, no direct response procedures were established,
outlined, or described.
ILD.2.1
The permittee implemented a mechanism to track the issuance of notices of violation
Enforcement
and enforcement actions administered by the permittee.
Yes
20
If yes, the mechanism includes the ability to identify chronic violators for
Yes
20
initiation of actions to reduce noncompliance.
Comments
The permittee developed and maintained a database that detailed notices of violation and enforcement actions issued during the
permit cycle, to include the identification of violators and resolution of enforcement actions.
NC5000408_City of Graham M54 Audit_20211015 Page 10 of 27

Post -Construction Site Runoff Controls
Staff Interviewed: Josh Johnson, Vice President and Head Engineer AWCK, Stormwater Engineer for the City of Graham
(Name, Title, Role) Phil Ross, Stormwater Coordinator AWCK, Stormwater Coordinator and Inspector for the City of Graham
Burke Robertson, Public Works Director for the City of Graham
Cameron West, Planning Staff for the City of Graham
Implementation (check all that apply):
❑ The permittee implements the components of this minimum measure.
❑ The permittee relies upon another entity to implement the components of this minimum measure: N/A
N 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 2B .0214
❑ Water Supply Watershed III (WS-III) —15A NCAC 26.0215
❑ Water Supply Watershed IV (WS-IV) —15A NCAC 2B .0216
❑ Freshwater High Quality Waters (HOW) —15A NCAC 2H .1006
❑ Freshwater Outstanding Resource Waters (ORW)-15A NCAC 2H .1007
N Neuse River Basin Nutrient Sensitive (NSW) Management Strategy-15A NCAC 213.0235
❑ 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 M54 permitted area (check all that apply):
N DEQ model ordinance
N 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.
NCS000408_City of Graham MS4 Audit_20211015 Page 11 of 27

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
25
The permittee implements deemed -compliant Program requirements throughout
the entire MS4 area (If not, also complete the Permit Citation section below.)
Yes
25
The permittee applies deemed -compliant Program requirements to all federal,
state and local government projects within the permitted MS4 area who do not
Yes
25
have their own NPDES stormwater permit.
The permittee included deemed -compliant Program reporting in their MS4 Annual
Reports.
partial
3, 4, 5, 6
The permittee included deemed -compliant Program implementation in their
Stormwater Management Plan.
Yes
2
The NSW program is included in MS4 Annual Reports, but commentary pertaining to it is general in nature and provides very little
information on the Program for a given year.
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
25
Management Program.
If yes, the ordinance applies throughout the corporate limits of the permittee
(Verify permit coverage area listed in Part LD of permit and modify
Yes
1,25
accordingly).
The permittee has the authority to review designs and proposals for new
development and redevelopment to determine whether adequate stormwater
Yes
25
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
yes
evaluate compliance with the Post -Construction Stormwater Management
25
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
25
related to stormwater discharges.
The ordinance is similar to the model ordinance and appears to be reviewed periodically and updated as needed.
II.F.2.b
34, 35,
Stormwater Control
The permittee utilizes strategies which include SCMs appropriate for the M54.
Yes
40
Measures (SCMs)
SCMs comply with 15A NCAC 02H .1000.
Yes
34, 35,
40
The documented plan reviews show that SCMs are implemented per the guidance provided by Graham, which results in compliance
with the permit and applicable regulations.
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
Partial
34,35
that disturb less than one acre that are part of a larger common plan of
development or sale).
NCS000408_City of Graham MS4 Audit_20211015 Page 12 of 27

Post -Construction Site Runoff Controls
If yes, the site plan reviews addressed how the project applicant meets the
performance standards.
Yes
34, 35
If yes, the site plan reviews addressed how the project will ensure long-term
Yes
34, 35
maintenance.
Reviews appear to be conducted as needed through technical review by the Planning Department. Reviews appear to assure that
projects meet requirements, but the stormwater reviews don't appear to be documented in such a way that shows that all required
reviews are conducted.
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
Partial
21
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
21
requirements.
The SCM inspection log functions as an inventory, but only shows inspections from 2021.
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
25,36
and Protective
consistent with approved plans.
Covenants
The permittee appears to utilize several tools during the review process to assure long-term compliance.
II.F2.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
25,36
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
25, 36
Annual inspection of permitted structural SCMs are required to be performed by a
qualified professional.
Yes
25
The ordinance requires 0&M plans and inspection by qualified professionals; the example 0&M agreement shows these
requirements in practice.
II.F.2.e
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
37
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
No
---
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
Partial
38
condition in Part II.F.2.g of permit and modify accordingly.
The permittee documented and maintained records of inspections.
Partial
21
NC5000408_City of Graham M54 Audit_20211015 Page 13 of 27

Post -Construction Site Runoff Controls
The permittee documented and maintained records of enforcement actions.
No
---
The permittee claims to have documented inspections for each project during the current permit term and post -construction
inspections are conducted but has not provided documentation to fully support the claim. An SCM program document has been
provided, but it is unclear that it has been implemented. It does not appear that enforcement actions have been taken despite
instances of non-compliance (not providing annual inspection reports).
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.
Yes
40
Training for
Note: New materials may be developed by the permittee, or the permittee may use
Developers
materials adopted from other programs and adapted to the permittee's new
development and redevelopment program.
The permittee indicated that these items are provided to developers as their projects reach Planning/TRC.
II.F_2JEnforcement
The permittee tracked the issuance of notices of violation and enforcement
No
---
actions.
If yes, the tracking mechanism included the ability to identify chronic violators
Not
for initiation of actions to reduce noncompliance.
Applicable
The permittee reported that this program had no violations or enforcement actions, stating that the structure of the program results
in compliance. It appears enforcement may be necessary for owners of permitted SCMs that fail to meet annual inspection
requirements.
II.F.3.b
The permittee fully complies with past construction program requirements on its
New Development
own publicly funded construction projects.
Yes
25,39
II.F3.c -
Does the MS4 have areas draining to Nutrient Sensitive Waters (NSW) pursuant to
Nutrient Sensitive
15A NCAC 02H .0150?
Yes
2
Waters
If yes, does the permittee use SCMs that reduce nutrient loading in order to
Yes
25,40
meet local program requirements.
If yes, does the permittee also still incorporate the stormwater controls
required for the project's density level.
Yes
25,40
If yes, does the permittee also require documentation where it is not feasible to
Yes
25,40
use SCMs that reduce nutrient loading.
II.F3.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
25, 40
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
25,40
streets, driveways, and other impervious surfaces.
NCS000408_City of Graham MS4 Audit_20211015 Page 14 of 27

Post -Construction Site Runoff Controls
Additional The permittee's post -construction program appears to involve a thorough review process through TRC and to
Comments: result in structures and practices consistent with the ordinance and guidance documents. Improvements
should be made to documenting program planning and evaluation and logging of reviews and inspections
performed by Graham. Enforcement is recommended forSCM owners that do not respond to requests for
annual inspection in a timely manner.
NCS000408_City of Graham MS4 Audit_20211015 Page 15 of 27

Pollution Prevention and Good. Housekeeping for Municipal Operations
Staff Interviewed:
Josh Johnson, Vice President and Head Engineer AWCK, Stormwater Engineer for the City of Graham
(Name, Title, Role)
Phil Ross, Stormwater Coordinator AWCK, Stormwater Coordinator and Inspectorfor the City of Graham
Burke Robertson, Public Works Director for the City of Graham
Permit Citation
Program Requirement Status supporting
Doc No.
II.G.2.a
The permittee maintained a current inventory of facilities and operations owned
5,
Facility Inventory
3, 4, 6,
and operated by the permittee with the potential for generating polluted Yes
13
stormwater runoff.
Comments (Note number of facilities, typical inventory data and any facilities that are not inventoried that should be)
The 2019 O&M plan lists 22 municipal facilities and 7 wastewater pump stations. A summary of the facilities, potential areas/items
of concern impacting storm water pollution, and best management practices were listed. However, any additional municipal facilities
added (if any) was not discussed in the annual reports making it difficult to determine if the inventory was properly updated.
II.G.2.b
The permittee maintained and implemented an O&M program for municipally
Operation and
owned and operated facilities with the potential for generating polluted
Yes
13
Maintenance (O&M)
stormwater runoff.
for Facilities
If yes, the O&M program specifies the frequency of inspections.
No
13
If yes, the O&M program specifies the frequency of routine maintenance
No
13
requirements.
If yes, the permittee evaluated the O&M program annually and updated it as
Partial
13
necessary.
Comment
The 2019 O&M plan addresses previous inspections and routine maintenance for municipally owned and operated facilities but did
not specify when and how often these facilities should be inspected. The plan was not updated annually. The first update occurred in
December2019 and a second updated occurred in June 2020. The plan has not been updated thus far in 2021; the update has
started and is scheduled to be completed in November 2021.
II.G.2.c
Spill Response
The permittee had written spill response procedures for municipal operations.
Partial
---
Procedures
Comments
No evidence was provided to suggest each municipally owned facility had a spill response plan. However, temporary posters stating
actions to be taken in the event of a spill were posted around municipally owned facilities. Spill kits were found in the municipally
owned facilities that were visited, but not all the spill kits were labeled or located in a readily accessible location.
II.G.2.d Streets,
Public
Roads, and Public
Works
Parking Lots
The permittee evaluated existing and new BMPs that reduce polluted stormwater
Stormwa
runoff from municipally owned streets, roads, and public parking lots within its
Yes
Maintenance
corporate limits annually.
ter
Activities
Report
If yes, the permittee evaluated the effectiveness of existing and new BMPs
based on cost and the estimated quantity of pollutants removed.
Partial
---
NCS000408_City of Graham MS4 Audit_20211015 Page 16 of 27

Pollution Prevention and Good Housekeeping for Municipal Operations
Comments
The MS4 utilizes the Mobile 311 program to track municipally owned and operated dumpsters, storm drains, inlets, outlets, etc. The
volume/quantity of debris cleaned up each year is calculated through the Sweeper Program and the Solid Waste collection program.
II.G.2.e
The permittee maintained and implemented an O&M program for the stormwater
O&M for Catch
Basins and
sewer system including catch basins and conveyance systems that it owns and
Partial
13
Conveyance Systems
maintains.
Comments (Briefly describe O&M program)
The 2019 O&M plan states the inspection frequency for some SCMs located on facility grounds owned and operated by the MS4.
II.G.2.f
The permittee maintained a current inventory of municipally -owned or operated
Structural
structural stormwater controls installed for compliance with the permittee's post-
Partial
3, 4, 5, 6,
Stormwater Controls
construction ordinance.
13
Comments (Describe inventory information and number of controls in inventory)
The 2019 O&M plan lists 22 municipal facilities and 7 wastewater pump stations. A summary of the facilities, potential areas/items
of concern impacting stormwater pollution, and best management practices were listed. Some municipally owned and operated
SCMs were listed with the relative facilities, but a complete list was not provided. Furthermore, any additional municipal
facilities/SCMs added (if any) was not discussed in the annual reports making it difficult to determine if the inventory was properly
updated.
II.G.2.R
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
13
stormwater Controls
the permittee's post -construction ordinance. If yes, then:
The O&M program specified the frequency of inspections and routine
Partial
13
maintenance requirements.
The permittee documented inspections of all municipally -owned or maintained
structural stormwater controls.
Partial
21
The permittee inspected all municipally -owned or maintained structural
Not
stormwater controls in accordance with the schedule developed by permittee.
Applicable
The permittee maintained all municipally -owned or maintained structural
Not
stormwater controls in accordance with the schedule developed by permittee.
Applicable
The permittee documented maintenance of all municipally -owned or
maintained structural stormwater controls.
Yes
yes
Comments
The 2019 O&M plan does not specify the frequency, but documents the inspections and maintenance, for municipally owned and
maintained facilities. An SCM inspection log was provided only for 2021. The MS4 utilizes the Mobile 311 program to track
maintenance of municipally owned and operated dumpsters, storm drains, inlets, outlets, etc.
An inspection schedule for municipally owned and maintained structural stormwater controls was not provided.
II.G.2.h
The permittee ensured municipal employees are properly trained in pesticide,
13, 27,
Pesticide, Herbicide
herbicide and fertilizer application management.
Yes
33
and Fertilizer
Application
The permittee ensured contractors are properly trained in pesticide, herbicide and
Management
g
fertilizer application management.
No
---
NCS000408_City of Graham MS4 Audit_20211015 Page 17 of 27

Pollution Prevention and Good Housekeeping for Municipal Operations
The permittee ensured all permits, certifications, and other measures for
13, 27,
applicators are followed.
Yes
33
Comments
Tim Covington, Division of Public Works, manages four staff members who are licensed and trained in pesticide, herbicide, and
fertilizer application management. Mr. Covington is responsible for ensuring licenses and certifications are kept up to date, and that
all permits, certifications, and other measures are followed. -No evidence was provided to suggest that a mechanism was in place to
ensure contractors are properly trained in pesticide, herbicide, and fertilizer application management.
II.G.2.i
The permittee implemented an employee training program for employees involved
14, 27,
Staff Training
in implementing pollution prevention and good housekeeping practices.
Yes
33
Comments
Storm water Smart training did not occur in 2020; it occurred virtually in 2021.
II.G.2.0
The permittee described and implemented measures that prevent or minimize
Vehicle and
contamination of stormwater runoff from all areas used for vehicle and equipment
Yes
13
Equipment Cleaning
cleaning.
Comments
Vehicle and equipment cleaning occurs at the Public Works garage unit. A wash bay is utilized, and flow is piped to an oil/water
separator and then to the sanitary sewer. Maintenance occurs in the garage, and contaminants flow to a floor drain which leads to
the oil/water. separator.
Additional
A log of all municipally owned or operated SCMs should be kept to track the previous inspections within the
Comments:
current permit cycle, and when the next inspection is due. This log should also summarize the any
maintenance activities (if any) that have occurred or need occur. This log will also act as a complete inventory
list. The inspection log provided in the O&M Plan should also be updated to reflect this information for
municipally owned and operated facilities.
NCS000408_City of Graham MS4 Audit_20211015 Page 18 of 27

Site Visit Evaluation: Municipal Facility No.1
Facility Name:
Date and Time of Site Visit:
The City of Graham Public Works
October 7, 2021
10:00 am
Facility Address: -
Facility Type (Vehicle Maintenance, Landscaping, etc.):
105 West Parker Street
Graham, NC27253
Vehicle Maintenance and Landscaping
Name of M54 inspector(s) evaluated:
Most Recent MS4 Inspection (List date and name of inspector):
Phil Ross
September30, 2021
Phil Ross
Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name
Title
Burke Robertson
Public Works Director
Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific?
The facility has a SWPPP. The acting SWPPP appeared to be facility specific but locked a lot of detail. The SWPPP is currently being
revised in order to be in compliance with the new permit issued in July 2021.
What type of stormwater training do facility employees receive? How often?
The facility employees receive annual training through the MS4's IDDE and PPGH program.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
Stormwater BMP Inspection and Maintenance Certification. Renewed every 3 years.
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, however, the MS4 inspector should also be knowledgeable about the spill prevention and response plans for municipal facilities.
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form?
Yes.
Does the M54 inspector's process include taking photos?
Yes.
Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)?
The MS4 inspector's process did not appear to include reviewing the facility's SWPPP.
NCS000408_City of Graham MS4 Audit_20211015 Page 19 of 27

Site Visit Evaluation: Municipal Facility No. 1
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)?
Yes. Not all spill kits were labeled and in a readily available location.
Furthermore, the asphalt in front of the asphalt stockpile should be removed and all asphalt contained in the stockpile area.
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
A timeline of 30-days from receipt of the report is usually given. However, due to certain labor constraints, it may take longer that
normal to address the signage issue.
Notes/Comments/Recommendations
It is recommended that the MS4 inspector looked through the facility SWPPP to ensure it is being implemented. It is also
recommended that the MS4 inspector look through the Spill Prevention and Response Plan (SPRP) for the facility to become familiar
with the plan and ensure that the facility has the necessary resources in place to implement that plan in the event of a spill.
The MS4 inspector should also keep a log of municipal facility inspections that list any maintenance activities that are to be
followed -up on.
The inspection forms used by the MS4 inspector could also be improved. It is recommended that the forms include the name and title
of the facility contact who is present during the inspection, as well as if the facility has a SWPPP and a SPRP and if those plans are
being implemented.
NCS000408_City of Graham MS4 Audit_20211015 Page 20 of 27

Site Visit Evaluation: Municipal Facility No. 2
Facility Name:
Date and Time of Site Visit:
October8, 2021
Graham Wastewater Treatment Plant
11:00 am
Facility Address:
Facility Type (Vehicle Maintenance, Landscaping, etc.):
1204 E Gilbreath St
Treatment Works
Graham, NC27253
Name of MS4 inspector(s) evaluated:
Most Recent MS4 Inspection (Date and Entity):
Phil Ross
September 28, 2021
Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name Title
Multiple Staff
Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific?
The facility had a SWPPP, but it was general in nature.
What type of stormwater training do facility employees receive? How often?
The facility employees receive annual training through the MS4's IDDE and PPGH program.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
Stormwater BMP Inspection and Maintenance Certification. Renewed every 3 years.
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)?
The MS4 inspector's process did not appear to include reviewing the facility's SWPPP.
NCS000408_City of Graham MS4 Audit_20211015 Page 21 of 27

Site Visit Evaluation: Municipal Facility No.'2
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:
Yes. There were two uncovered dumpsters that collect grit and other inorganic material that is filtered from the intake of the
treatment plant.
Does the MS4 inspector's process include presenting the inspection findings to the facility contact?
No. The facility contact stated that they have never received an inspection report from the MS4 inspector, except for the report from
the most recent inspection.
Inspection Results
Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)?
Yes. Erosion had occurred near one of the discharge pipes to where the outfall was half -full of sediment. The sediment must be
cleaned out of the discharge pipe, and the area stabilized.
Also, the dumpsters mentioned above were not covered.
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
Facilities are usually given 30-days to address minor issues.
Notes/Comments/Recommendations
It is recommended that the MS4 inspector look through the facility SWPPP to ensure it is being implemented. It is also recommended
that the MS4 inspector look through the Spill Prevention and Response Plan (SPRP) (if applicable) for the facility to become familiar
with the plan and ensure that the facility has the necessary resources in place to implement that plan in the event of a spill.
The MS4 inspector should also keep a log of municipal facility inspections that list any maintenance activities that are to be
followed -up on.
The inspection forms used by the MS4 inspector could also be improved. It is recommended that the forms include the name and title
of the facility contact who is present during the inspection, as well as if the facility has a SWPPP and a SPRP and if those plans are
being implemented.
,NCS000408_City of Graham MS4 Audit_20211015 Page 22 of 27

Site Visit Evaluation: MS4 Outfall No. 1
Outfall ID Number:
Date and Time of Site Visit:
October7, 2021
36.069841,-79.408436
9:30 am
Outfall Location:
Outfall Description (Pipe Material/Diameter, Culvert, etc.):
West Elm Street and Home Avenue
14 ft CMP
Receiving Water:
Is Flow Present? If So, Describe (Color, Approximate Flow Rate,
Unnamed tributary to Boyd Creek.
Sheen, Odor, Floatables/Debris, etc.):
Low flow present. Clear. Less than S cfs.
Most Recent Outfall Inspection/Screening (Date):
Unknown
Days Since Last Rainfall:
Inches:
Unknown
Name of MS4lnspector(s) evaluated:
Josh Johnson
Observations
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
Unknown.
-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?
No.
Does the inspector's process include taking photos?
No.
Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they?
No.
NCS000408_City of Graham MS4 Audit_20211015 Page 23 of 27

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. The culvert appeared to be partially full of stone that had been washed downstream during the last heavy rain event.
Will follow-up outfall inspection be conducted? If so, for what reason?
Yes. It will take several instances to adequately remove the stone.
NCS000408_City of Graham MS4 Audit_20211015 Page 24 of 27

Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1
Site Name:
Date and Time of Site Visit:
Filterro Tree Boxes
October 7, 2021
9:00 am
Site Address:
SCM Type:
217 S Main St
Tree Box Bioretention Device
Graham, NC27253
Most Recent MS4 Inspection (Include Date and Entity):
Need report from Blane
Name of MS4lnspector(s) evaluated:
Most Recent MS4 Enforcement Activity (Include Date):
Phil Ross
Unknown
Name(s) and Title(s) of Site Representative(s) Present During the Site Visit:
Name
Title
Burke Robertson
Public Works Director
Observations
Site Documentation
Does the site have an operation and maintenance plan?
No. The maintenance for this site is conducted through grounds maintenance, which is performed on a regular basis.
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?
Stormwater BMP Inspection and Maintenance Certification. Renewed every 3 years.
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?
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. The MS4 inspector carries the previous inspection report with them to ensure any issues listed in the previous report have been
addressed.
NCS000408_City of Graham M54 Audit_20211015 Page 25 of 27

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. The MS4 inspector presents the findings to the Public Works director, who then directs the grounds maintenance crew to
address the issues, such as removing trash from the tree boxes.
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?
No compliance issues were identified.
NCS000408_City of Graham MS4 Audit_20211015 Page 26 of 27

APPENDIX A: SUPPORTING DOCUMENTS
NCS000408_City of Graham MS4 Audit_20211015 Page 27 of 27