NCS000405_Gibsonville MS4 AUDT REPORT_20211124

MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM AUDIT REPORT
NPDES PERMIT NO. NCS000405
Town of Gibsonville, NORTH CAROLINA
129 West Main Street
Gibsonville, NC 27249
Audit Date: November 16 & 17, 2021
Report Date: November 24, 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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NCS000405 Town of Gibsonville MS4 Audit 20211124

TABLE OF CONTENTS
AuditDetails..................................................................................................................................................1
PermitteeInformation..................................................................................................................................2
List of 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..................................................15
Site Visit Evaluation: Municipal Facility No. 1.............................................................................................18
Site Visit Evaluation: MS4 Outfall No. 1......................................................................................................20
Site Visit Evaluation: MS4 Outfall No. 2......................................................................................................22
Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1............................................24
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.
NC5000405 Town of Gibsonville MS4 Audit 20211124

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NCs000405 Town of Gibsonville Ms4 Audit 20211124

Audit Details
Audit ID Number:
Audit Date(s):
NCS000405_The Town of Gibsonville_20211116
November 16 & 17, 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
® 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
❑x MS4 Outfalls. Number visited: 1
❑ Construction Sites. Number visited: Choose an item.
® Post -Construction Stormwater Runoff Controls. Number visited: 1
❑ Other: Number visited: Choose an item.
❑ Other: Number visited: Choose an item.
Inspector(s) Conducting Audit
Name. Title
Organization
Levi Hiatt, Assistant Regional Engineer
NCDEQ—DEMLR: WSRO
Zac Lentz, Assistant Regional Engineer
NCDEQ— DEMLR: WSRO
Blane Houck, Environmental Specialist
NCDEQ— DEMLR: WSRO
Kimberly Turney, Environmental Specialist
NCDEQ—DEMLR: WSRO
Brett Bell, Assistant Regional Engineer
NCDEQ— DEMLR: WSRO
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NCS000405_The Town of Gibsonville MS4 Audit_20211124
Page 1 of 27

Permittee Information
MS4 Permittee Name:
Town of Gibsonville
Permit Effective Date:
February 20, 2017
Permit Expiration Date:
February 19, 2022
Mailing Address:
129 West Main Street, Gibsonville, NC 27249
Date of Last M54 Inspection/Audit:
N/A
Co-permittee(s), if applicable:
N/A
Permit Owner of Record:
Ben Baxley, Town 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)
Ben Baxley, Town Manager
The Town of Gibsonville
Rob Elliot, Public Works Director
The Town of Gibsonville
Brandon Parker, Planning Director
The Town of Gibsonville
MS4 Receiving Waters
Waterbodv
Classification
Impairments
Back Creek (Little Creek)
WS-V; NSW
Fish Tissue Mercury (Nar, FC, NC)
Ingle Branch
WS-V; NSW
Fish Tissue Mercury (Nar, FC, NC)
Unnamed Tributary to Back Creek (Little
Creek)
WS-V; NSW
N/A
Unnamed Tributary to Michael Branch
WS-V; NSW
N/A
Michael Branch
WS-V; NSW
Fish Tissue Mercury (Nar, FC, NC)
Unnamed Tributary to Ingle Branch
WS-V; NSW
N/A
Unnamed Tributary to Travis Creek (Cable
Branch)
WS-V; NSW
Fish Tissue Mercury (Nar, FC, NC)
Unnamed Tributary to Travis Creek
WS-V; NSW
Fish Tissue Mercury (Nar, FC, NC)
NCS000405_Town of Gibsonville MS4 Audit_20211124 Page 2 of 25

List of Supporting Documents
Item
Number
Document Title
When Provided
(Prior to/During/After)
1
Gibsonville Final Permit
Prior
2
Gibsonville-CSWMP-Report 2017 rev2021
Prior
3
NPDES Phase 11 Stormwater Annual Report— Gibsonville 2017
Prior
4
NPDES Phase 11 Stormwater Annual Report—Gibsonville 2018
Prior
5
2019-20 Town of Gibsonville NPDES Phase 11 Stormwater Annual Report
Prior
6
2020-21 Town of Gibsonville NPDES Phase 11 Stormwater Annual Report
Prior
7
DEMLR Stormwater ePayments
Prior
8
Gibsonville Stormwater Webpage
Prior
9
Gibsonville Planning and Code Enforcement Webpage
Prior
10
AWCK— TownofGibsonville— EngineeringAgreement- StormwaterServices
Prior
11
Gibsonville IDDE Program 2020
Prior
12
Gibsonville PPGH Report 2019 (O&M Plan)
Prior
13
FY21 Stormwater SMART Annual Report Alamance Davidson—RFS
Prior
14
Gibsonville 2016-2021 Stormwater Smart Annual Reports
Prior
15
Engineered Plastics Inc. IDDE Notice
Prior
16
418 Circle Drive - NOV Letter -June 2014 to Mr - Mrs Fields
After
17
418 Circle Drive - Email Closeout 7-1-14
After
18
Gibsonville IDDE Tracking Spreadsheet
After
19
Avondale Wet Detention Basin Inspection Report Fail- 9-5-2018
After
20
Avondale Wet Detention Basin Inspection Report - Pass 11-2-21
After
NCS000405—Town of Gibsonville MS4 Audit_20211124 Page 3 of 25

21
Gibsonville Stormwater SCM Inspections Log 11-4-21
Prior
22
10 Federal Storage Inspection Report 9-13-2018
After
23
2018-STORMWATERREVIEW SCANS -Gibsonville
Prior
24
2021 Gibsonville PPGH-IDDE Virtual RAINcheck Staff Training
After
25
Gibsonville Pre 2021 - Virtual- Training sign -in sheets
After
26
Graham and Area towns IDDE- PPGH 2O17 training
After
27
Gibsonville Code of Ordinances
After
28
Town of Gibsonville MS4-24x36
Prior
29
Post Construction Ordinance
Prior
30
12-20 Gibsonville Self Storage Response to Comments
After
31
12-20 10 Federal Storage — Gibsonville 21d Submittal
After
32
StormwaterOverview- Gibsonville
Prior
33
10 Federal Self Storage Stormwater O&M Plan — Gibsonville - 11-9-2016
After
34
10 Federal Self Storage —Sand Filter Inspection Report 11-2-2021
After
35
Town of Gibsonville SCM Maintenance Program
Prior
NCS000405_Town of Gibsonville MS4 Audit_20211124 Page 4 of 25

Program Implementation, Documentation & Assessment
Staff Interviewed:
Josh Johnson, Vice President and Head Engineer AWCK, Stormwater Engineer for the Town of Gibsonville
(Name, Title, Role)
Phil Ross, Stormwater Coordinator AWCK, Stormwater Coordinator and Inspectorfor the Town of Gibsonville
Permit Citation
Program Requirement
Status
supposing
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
The MS4 budgeted $33,000 in 2020-2021 for the stormwater program. This was funded through a flat $0.75 monthly fee from utility
users. It was revealed during the meeting that this fee was recently increased to $1.25 to double the budget for the stormwater
program to expand the Stormwater and Storm drainage Maintenance Policy that is to aid in mitigating localized flooding. This fee
also funds the MS4's Jordan Lake program. The current budget or staffing appears to be adequate to implement and manage the
SWMP.
The MS4 currently has 3 main staff that implement the 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 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
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 in that they discuss issues pertaining to some illicit connections, and the lack of annual inspections performed by
the owners of SCM's. However, the annual reports do not provide a solution for the lock of annual inspections performed by the
owners of SCM's.
The MS4 experienced one sanitary sewage overflow in 2021 during the current permit cycle but did not appear to of caused or
contributed to non -attainment of on applicable water quality standard.
II.A.3
The permittee kept the Stormwater Plan up to date.
Partial
2
NCS000405_Town of Gibsonville M54 Audit_20211124 Page 5 of 25

Program Implementation, Documentation &Assessment
Keeping the
Stormwater Plan
The permittee notified DEMLR of any updates to the Stormwater Plan.
No
---
Up to Date
Comments
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
8
Plan
The online materials included ordinances, or other regulatory mechanisms, or a list
identifying the ordinances, or other regulatory mechanisms, providing the legal
Yes
9
authority necessary to implement and enforce the requirements of the permit.
Comments
A copy of the Stormwater Plan is available on the MS4's Stormwater webpage. A copy of the Phase 11 Stormwater Ordinance as well
as the Development Ordinance is available on the MS4's Planning and Code Enforcement webpage.
II.A.3 & II.A.S
Stormwater Plan
Did DEMLR require a modification to the Stormwater Plan?
No
---
Modifications
If yes, did the permittee complete the modifications in accordance with the
Not
established deadline?
Applicable
Comments
There is no record from DEMLR or the MS4 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
3, 4, 5, 6
If yes, is there a written agreement in place?
Yes
10
Comments
The MS4 utilizes PTRC's Storm water SMART program to fulfil the Public Education and Outreach and Public Involvement and
Participation MCMs, but o formal agreement is not in place.
The MS4 also utilizes AWCK for on -call city engineering services. A contract between the two entities is currently in place.
Furthermore, DEMLR implements Construction Site Runoff MCM. 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, 11, 12
Comments
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, 0&M Plan,
and IDDE Program, but the schedules for doing so were not, specifically for facility inspections.
NCS000405_Town of Gibsonville MS4 Audit_20211124 Page 6 of 25

Program Implementation, Documentation & Assessment
Ill.A
3,4,5,6,
Program
12,13,
Documentation
14, 15,
16, 17,
The permittee maintained documentation of all program components including, but
18, 19,
not limited to, inspections, maintenance activities, educational programs,
Partial
20, 21,
implementation of BMPs, enforcement actions etc., on file for a period of five years.
22, 23,
24, 25,
26, 30,
31, 33,
34
Comments
A summary of the educational activities and the approximate number of persons impacted through those activities were provided in
the Annual Report. The O&M Plan lists the most recent inspections for facilities owned and operated by the MS4 as of February
2021.The SW SMART summary reports list the number of people from Gibsonville impacted by events, whether physical or virtual,
from 2018-2021.
111.13
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
Yes
3
Submittal
period specific to this MS4).
The permittee submitted subsequent annual reports every twelve months from the
scheduled date of the first annual report submittal.
yes
3, 4, 5, 6
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
Partial
3, 4, 5, 6
of each major component of the Stormwater Plan for the past year and
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.
NICS000405_Town of Gibsonville MS4 Audit_20211124 Page 7 of 25

Program Implementation, Documentation & Assessment
Comments
Annual Reports were provided for every year during the current permit cycle. 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 discuss certain issues
pertaining to the lack of annual inspections performed by the owners of SCM's, and the possible budget shortage in the future, but
does not adequately address how to prevent these issues during the following year (with the exception of discussing an alternate
funding mechanism for the Stormwater Program). Furthermore, the Annual Reports do not discuss any changes that were made
from the previous year. The Annual Reports do list summaries of data accumulated, specifically for Public Education and Outreach,
Post Construction Site Runoff Controls and Pollution Prevention and Good Housekeeping, but do not assess what the data indicates
in light of the SWMP. The Annual Reports also do not assess program compliance with the permit and do 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
quantities achieved and summaries of enforcement actions.
Partial
3, 4, 5, 6
2. A description of the effectiveness of each program component.
No
---
3. Planned activities and changes for the next reporting period, for each
program component or activity.
Partial
3, 4, 5, 6
4. Fiscal analysis.
No
---
Comments
The Annual Reports summarize activities for the past year and lists specific quantities achieved for all MCM's except for Construction
Site Runoff Controls. The Annual Reports do not list anysummories 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 Storm water 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.
NCS000405_Town of Gibsonville MS4 Audit_20211124 Page 8 of 25

Illicit Discharge Detection and Elimination (IDDE)
Staff Interviewed:
Josh Johnson, Vice President and Head Engineer A WCK, Stormwater Engineerfor the Town of Gibsonville
(Name, Title, Role)
Phil Ross, Stormwater Coordinator A WCK, Stormwater Coordinator and Inspectorfor the Town of Gibsonville
Rob Elliot, Public Works Director for the Town of Gibsonville
Permit Citation
Program Requirement
Status
supporting
Doc No. -
II.D.2.a
IDDE Program
The permittee maintained a written IDDE Program.
Yes
11
If yes, the written program includes provisions for program assessment and
evaluation and integrating program.
Yes
11
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
11,27
Legal Authorities
If yes, the ordinance applies throughout the corporate limits of the permittee.
(Permit Part LD]
Yes
11,27
II.D.2.c
The permittee maintained a current map showing major outfalls*and receiving
Storm Sewer
Partial
28
System Map
streams.
Comments
The map provided does not show the outfall locations or the names of the receiving streams.
II.D.2.d
Dry Weather Flow
The permittee maintained a program for conducting dry weather flow field
Partial
3, 4, 5, 6,
observations in accordance with written procedures.
11
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
11, 24,
Investigation
identified illicit discharges.
Yes
25,26
Procedures
II.D.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
13
2. The results of the investigation
Yes
1S
3. Any follow-up of the investigation
Yes
18
4. The date the investigation was closed
Yes
18
NCS000405_Town of Gibsonville MS4 Audit_20211124 Page 9 of 25

Illicit Discharge Detection and Elimination (IDDE)
II.D.2.e 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
24, 25,
contact with or otherwise observe an illicit discharge or illicit connection.
26
II.D.2.h
The permittee informed public employees of hazards associated with illegal
24, 25,
Public Education
discharges and improper disposal of waste.
Yes
26
The permittee informed businesses of hazards associated with illegal discharges and
improper disposal of waste.
Partial
13,14
The permittee informed the general public of hazards associated with illegal
discharges and improper disposal of waste.
Yes
13,14
Comments
The MS4 utilizes PRTC's Storm water SMART program to implement the Public Education and Public Participation and Involvement
MCMs. It is possible that businesses were informed of the hazards associated with illegal discharges and improper disposal of waste
through this program, but no evidence was provided.
II.D.2.i
The permittee promoted, publicized, and facilitated a reporting mechanism for the
Public Reporting
public to report illicit discharges.
Yes
8
Mechanism
The permittee promoted, publicized, and facilitated a reporting mechanism for staff
24, 25,
to report illicit discharges.
Yes
26
The permittee established and implemented response procedures for citizen
requests/reports.
Partial
---
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 outlined. The
site visit portion of the audit revealed that if an illicit discharge is reported by the public, the Public Works Director is notified. The
Public Works Director will then investigate the illicit discharge and decide on whether to notify AWCK. If AWCK is notified, the
Director and the Inspector will come to a consensus on how to proceed concerning the illicit discharge.
II.D.2.0
The permittee implemented a mechanism to track the issuance of notices of violation
Enforcement
and enforcement actions administered by the permittee.
Yes
18
If yes, the mechanism includes the ability to identify chronic violators for
initiation of actions to reduce noncompliance.
Yes
18
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.
NC5000405_Town of Gibsonville M54 Audit_20211124 Page 10 of 25

Post -Construction Site Runoff Controls
Staff Interviewed: Josh Johnson, Vice President and Head Engineer AWCK, Storm water Engineer for the City of Gibsonville
(Name, Title, Role) Phil Ross, Stormwater Coordinator A WCK, Stormwater Coordinator and inspectorfor the Cityof Gibsonville
Rob Elliot, Public Works Director for the Town of Gibsonville
Implementation (check all that apply):
❑X 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
❑ The permittee implements the following deemed -compliant program(s), which meet NPDES MS4 post -construction
requirements forthe 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-II) —15A NCAC 26 .0214
❑ Water Supply Watershed III (WS-III) —15A NCAC 2B .0215
❑ Water Supply Watershed IV (WS-IV)-15A NCAC 26.0216
❑ Freshwater High Quality Waters (HOW) —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 213 .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):
M 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 2005-246 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 areas) not covered under the S.L. 2006-246 deemed -compliant program.
I Session Law 2006- I I ( supponing
246 l
Program Requirement Status Doc No.
NCS000405—Town of Gibsonville MS4 Audit_20211124 Page 11 of 25

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
29
The permittee implements deemed -compliant Program requirements throughout
the entire MS4 area (If not, also complete the Permit Citation section below.)
Yes
29
The permittee applies deemed -compliant Program requirements to all federal,
state and local government projects within the permitted MS4 area who do not
Yes
29
have their own NPDES stormwater permit.
The permittee included deemed -compliant Program reporting in their MS4 Annual
Reports.
Yes
3, 4, 5, 6
The permittee included deemed -compliant Program implementation in their
Stormwater Management Plan.
Yes
2
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
29
Management Program.
If yes, the ordinance applies throughout the corporate limits of the permittee
(Verify permit coverage area listed in Part I.D of permit and modify
Yes
1,29
accordingly).
The permittee has the authority to review designs and proposals for new
development and redevelopment to determine whether adequate stormwater
Yes
29
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
29
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
29
related to stormwater discharges.
II.F2.b
30, 31,
Stormwater Control
The permittee utilizes strategies which include SCMs appropriate for the MS4.
Yes
32
Measures (SCMs)
SCMs comply with 15A NCAC 02H .1000.
Yes
30, 31,
32
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
30,31
development or sale).
If yes, the site plan reviews addressed how the project applicant meets the
performance standards.
Yes
30, 31
If yes, the site plan reviews addressed how the project will ensure long-term
maintenance.
Yes
30, 31
NCS000405_Town of Gibsonville MS4 Audit_20211124 Page 12 of 25

Post -Construction Site Runoff Controls
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
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.
II.F.2.e
Deed Restrictions
The permittee provided mechanisms such as recorded deed restrictions and
and Protective
protective covenants that ensure development activities will maintain the project
Yes
29,33
Covenants
consistent with approved plans.
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
29,33
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
29, 33
Annual inspection of permitted structural SCMs are required to be performed by a
qualified professional.
Yes
29
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
Yes
21,34
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
Not
performance standards have been met or a bond is in place to guarantee
Reviewed
completion.
The permittee developed and implemented a written inspection program for SCMs
installed pursuant to the post -construction program.
Yes
35
The permittee documented and maintained records of inspections.
Yes
21,34
The permittee documented and maintained records of enforcement actions.
Not
Applicable
Comments
There was no apparent need for enforcement actions pertaining to SCM's.
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
Nate: New materials maybe developed by the permittee, or the permittee may use
Yes
32
Developers
materials adopted from other programs and adapted to the permittee's new
development and redevelopment program.
Comments
The permittee stated that document cited was provided to designers as needed.
II.F.2.1 Enforcement
The permittee tracked the issuance of notices of violation and enforcement
actions.
No
NCS000405_Town of Gibsonville MS4 Audit_20211124 Page 13 of 25

Post -Construction Site Runoff Controls
If yes, the tracking mechanism included the ability to identify chronic violators
Not
for initiation of actions to reduce noncompliance.
Applicable
Comments
There was no apparent need for enforcement actions pertaining to SCM's.
II.F3.b
The permittee fully complies with post construction program requirements on its
New Development
own publicly funded construction projects.
Yes
21,29
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
meet local program requirements.
Yes
29,32
If yes, does the permittee also still incorporate the stormwater controls
required for the project's density level.
Yes
29, 32
If yes, does the permittee also require documentation where it is not feasible to
use SCMs that reduce nutrient loading.
Yes
29, 32
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
29, 32
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
29,32
streets, driveways, and other impervious surfaces.
Additional
The permittee's post -construction program appears to involve a thorough review process through TRC and
Comments:
results in structures and practices consistent with the ordinance and guidance documents.
NCS000405_Town of Gibsonville MS4 Audit_20211124 Page 14 of 25

Pollution Prevention and Good Housekeeping for Municipal Operations
Staff Interviewed:
Josh Johnson, Vice President and Head Engineer AWCK, Stormwater Engineer for the Town of Gibsonville
(Name, Title, Role)
Phil Ross, Stormwater Coordinator A WCK, Stormwater Coordinator and Inspectorfor the Town of Gibsonville
Rob Elliot, Public Works Director for the Town of Gibsonville
Permit Citation
Program Requirement Status supporting
- Doc No. .
II.G.2.a
The permittee maintained a current inventory of facilities and operations owned
Facility Inventory
3, 4, 5, 6,
and operated by the permittee with the potential for generating polluted Yes
12
Stormwater runoff.
Comments
The 2019 0&M plan lists 8 municipal facilities and 5 wastewater stations. A summary of the facilities, potential
areas/items of concern impacting storm water pollution, and best management practices were listed. However, 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 0&M program for municipally
Operation and
owned and operated facilities with the potential for generating polluted
Partial
12
Maintenance (O&M)
stormwater runoff.
for Facilities
If yes, the O&M program specifies the frequency of inspections.
Partial
12
If yes, the O&M program specifies the frequency of routine maintenance
Partial
12
requirements.
If yes, the permittee evaluated the O&M program annually and updated it as
No
12
necessary.
Comment
The 2019 0&M plan addresses inspections and routine maintenance far municipally awned and operated facilities. It states that
municipal facilities should be inspected annually, but does not list an inspection schedule; however, all facilities are inspected twice
monthly as stated during the audit and documented in the city's Harris Server Program and printed inspection/work order reports
book(s). The plan has not been updated annually, an update did not occur in 2020. The 2021 update has started and is scheduled to
be completed by early 2022.
II.G.2.c
Spill Response
The permittee had written spill response procedures for municipal operations.
Yes
---
Procedures
Comments
A spill response plan was found in the public works facility, along with several spill kits. It was stated during the audit that each
facility has a written spill response book and spill kits (where warranted).
II.G.2.d Streets,
The permittee evaluated existing and new BMPs that reduce polluted Stormwater
Roads, and Public
runoff from municipally owned streets, roads, and public parking lots within its
Partial
---
Parking Lots
corporate limits annually.
Maintenance
If yes, the permittee evaluated the effectiveness of existing and new BMPs
based on cost and the estimated quantity of pollutants removed.
No
---
Comments
The MS4 utilizes its Harris Server to track municipally owned and operated dumpsters, storm drains, inlets, outlets, etc. Debris and
pollutants cleaned up each year is documented through work orders, but not calculated or evaluated to determine cost, quantity, or
the effectiveness of those BMPs.
NC5000405_Town of Gibsonville MS4 Audit_20211124 Page 15 of 25

Pollution Prevention and Good Housekeeping for Municipal Operations
II.G.2.e
O&M for Catch
The permittee maintained and implemented an 0&M program for the stormwater
Basins and
sewer system including catch basins and conveyance systems that it owns and
Partial
11,12
Conveyance Systems
maintains.
Comments
The 2019 O&M plan states the inspection frequency as annually for SCMs located on facility grounds owned and operated by the
MS4. The IDDE Program specifies that all outfalls be inspected at least once during the permit cycle. No evidence was provided to
suggest that there is an O&M program for the entire stormwater sewer system. The plan has not been updated annually.
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.
12
Comments
The 2019 O&M plan lists 8 municipal facilities and 6 wastewater stations. A summary of the facilities, potential areas/items of
concern impacting stormwater pollution, and best management practices were listed. However, 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.e
The permittee maintained and implemented an 0&M program for municipally
O&M for Structural
owned or maintained structural stormwater controls installed for compliance with
Partial
12
Stormwater Controls
the permittee's post -construction ordinance. If yes, then:
The 0&M program specified the frequency of inspections and routine
maintenance requirements.
Partial
12
The permittee documented inspections of all municipally -owned or maintained
structural stormwater controls.
Partial
21
The permittee inspected all municipally -owned or maintained structural
stormwater controls in accordance with the schedule developed by permittee.
Yes
---
The permittee maintained all municipally -owned or maintained structural
stormwater controls in accordance with the schedule developed by permittee.
Yes
---
The permittee documented maintenance of all municipally -owned or
maintained structural stormwater controls.
Yes
Comments
The 2019 O&M plan states that all municipally owned and maintained facilities are to be inspected annually and documents the
most recent inspections and maintenance activities for those facilities but failed to demonstrate that these facilities were inspected
annually. An SCM inspection log was provided only for2018 and 2021. However, logs/inspections/work orders for each year have
been documented in the city's Harris Server, printed, and kept in yearly books which were observed during the site visit portion of
the audit. It was stated that each facility and SCM is inspected twice monthly. The MS4 utilizes the Harris Server program to track
maintenance of municipally owned and operated dumpsters, storm drains, inlets, outlets, etc.
II.G.2.h
The permittee ensured municipal employees are properly trained in pesticide,
Pesticide, Herbicide
herbicide and fertilizer application management.
Yes
2,12
and Fertilizer
Application
The permittee ensured contractors are properly trained in pesticide, herbicide and
Management
g
fertilizer application management.
Yes
2,12
NCS000405_Town of Gibsonville MS4 Audit_20211124 Page 16 of 25

Pollution Prevention and Good Housekeeping for Municipal Operations
The permittee ensured all permits, certifications, and other measures for
applicators are followed.
Yes72,12
Comments
Rob Elliott, Public Works Director, manages two staff members who are licensed and trained in pesticide, herbicide, and fertilizer
application management. Mr. Elliott is responsible far ensuring licenses and certifications are kept up to date, and that all permits,
certifications, and other measures are followed. In-service reports located in the Harris Server and printed into the logbooks
document that contractors are properly trained in pesticide, herbicide, and fertilizer application management.
II.G.2.i
The permittee implemented an employee trainingprogram for employees involved
Staff Training
in implementing pollution prevention and good housekeeping practices.
Yes
13,14
Comments
Stormwater Smart training did not occur in 2020; it occurred virtually and in person 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
The inspection log provided in the 0&M Plan should be updated to show all previous inspections and reflect all
Comments:
pertinent information for municipally owned and operated facilities.
NCS000405_Town of Gibsonville MS4 Audit_20211124 Page 17 of 25

Site Visit Evaluation: Municipal Facility No. 1
Facility Name:
Date and Time of Site Visit:
The Town of Gibsonville Public Works
November 17, 2021
8:45 am
Facility Address:
Facility Type (Vehicle Maintenance, Landscaping, etc.):
1236 Springwood Avenue
Gibsonville, NC27249
Vehicle Maintenance and Landscaping
Name of MS4 inspector(s) evaluated:
Most Recent MS4 Inspection (List date and name of inspector):
Phil Ross
November 8, 2021, by Phil Ross
Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name
Title
Rob Elliot
Public Works Director
Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific?
No.
What type of stormwater training do facility employees receive? How often?
Facility Employees receive stormwater training annually on Pollution Prevention and Good Housekeeping and Illicit Discharge
Detection and Elimination.
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)?
Not Applicable.
NCS000405_Town of Gibsonville MS4 Audit_20211124 Page 18 of 25

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)?
No.
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
Not applicable.
Notes/Comments
Some of the spill kits were not easily visible in some areas. It is recommended that signs be installed above the spill kit locations to
clearly demonstrate where spill kits are located.
NCS000405_Town of Gibsonville MS4 Audit_20211124 Page 19 of 25

Site Visit Evaluation: MS4 Outfall No. 1
Outfall ID Number:
Date and Time of Site Visit:
Industrial Outfall Near W. Minneola St. and WhitsettAve.
November 17, 2021
10:30 am
Outfall Location:
Outfall Description (Pipe Material/Diameter, Culvert, etc.):
Approximate Lot and Long: 36.104711,-79.545937
24-inch RCP
Receiving Water:
Is Flow Present? If So, Describe (Color, Approximate Flow Rate,
Unnamed Tributary to Back Creek
Sheen, Odor, Floatables/Debris, etc.):
No, Not Applicable
Most Recent Outfall Inspection/Screening (Date):
November 15, 2021
Days Since Last Rainfall:
Inches:
5 days
0.5
Name of MS4lnspector(s) evaluated:
Phill Ross
Observations
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 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.
NCS000405_Town of Gibsonville MS4 Audit_20211124 Page 20 of 25

Site Visit Evaluation: MS4 Outfall No. 1
Inspection Results
Did the outfall inspection result in any work orders or maintenance requests? If so, for what issue(s)?
No.
Will a follow-up outfall inspection be conducted? If so, for what reason?
No.
NCS000405_Town of Gibsonville MS4 Audit_20211124 Page 21 of 25

Site Visit Evaluation: MS4 Outfall No. 2
Outfall ID Number:
Date and Time of Site Visit:
Residential Outfall at End of Boiling Springs Court
November 17, 2021
10:45 am
Outfall Location:
Outfall Description (Pipe Material/Diameter, Culvert, etc.):
Approximate Lat and Long: 36.070667,-79.555462
24-inch RCP
Receiving Water:
Is Flow Present? If So, Describe (Color, Approximate Flow Rate,
Unnamed Tributary to Back Creek
Sheen, Odor, Floatables/Debris, etc.):
No; Not applicable.
Most Recent Outfall Inspection/Screening (Date):
November 15, 2021
Days Since Last Rainfall:
Inches:
5 days
0.5
Name of MS4lnspector(s) evaluated:
Phil Ross
Observations
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 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.
NCS000405_Town of Gibsonville MS4 Audit_20211124 Page 22 of 25

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)?
No.
Will a follow-up outfall inspection be conducted? If so, for what reason?
No.
NCS000405_Town of Gibsonville MS4 Audit_20211124 Page 23 of 25

Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1
Site Name:
Date and Time of Site Visit:
Courtyards at Ashley Woods Phase 1:
November 17, 2021
North and South Basins
10:00 am
Site Address:
SCM Type:
25 White Birch Ct.
Bioretention
Gibsonville, NC27249
Most Recent MS4 Inspection (Include Date and Entity):
November 2021
Name of MS4lnspector(s) evaluated:
Most Recent MS4 Enforcement Activity (Include Date):
Phil Ross
Not Applicable
Name(s) and Title(s) of Site Representative(s) Present During the Site Visit:
Name
Title
Not applicable.
Not applicable.
Observations
Site Documentation
Does the site have an operation and maintenance plan?
Yes.
Does the site have records of annual inspections? Are they performed by a qualified individual?
Yes.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
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?
Partially. The inspector will look at the previous inspection report before performing the most current inspection.
NCS000405_Town of Gibsonville MS4 Audit_20211124 Page 24 of 25

Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1
Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge?
Yes.
Did the MS4 inspector miss any obvious operation and maintenance deficiencies? If so, explain:
No.
Does the M54 inspector's process include presenting the inspection findings to the site contact in writing?
Yes.
Compliance/Enforcement
What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in?
None.
If compliance issues were identified, what timeline for correction/follow-up was provided?
The inspection revealed that the south basin needed to be reseeded and orsodded due to the number of weeds that had grown in
the basin. This issue will need to be resolved within the next 30-days.
Notes/Comments
The inspection process implemented by the MS4 inspector for all inspection types (Facilities, Outfalls, SCMs, etc.) has greatly
improved from previous inspections.
NCS000405_Town of Gibsonville MS4 Audit_20211124 Page 25 of 25