02_NCS000467_TOWF NPDES MS4 Review and Development Doc_20211208

r
TOWN OF WAKE FOREST
NPDES MS4 PERMIT REVIEW AND DEVELOPMENT
PREPARED FOR:
TOWN OF WAKE FOREST PUBLIC WORKS I STORMWATER MANAGEMENT
PREPARED BY:
WSP
434 FAYETTEVILLE ST, SUITE 1500
RALEIGH, NC 27601
MAY 15, 2020
TOWN of
WAKE FORE57
NC LICENSE # F-0165
a

M
3
W
Table of Contents
C 1 INTRODUCTION
1.1 MS4 Review Process Overview ..................................,....,., 1
1.2 NCDEQ MS4 Audit Preparation . ............................ ....... 2
2
PROGRAM IMPLEMENTATION, DOCUMENTATION &
ASSESSMENT... ... .............................. ......:...:..........::.....:..........
3
2.1 Potential Administrative Updates ....................... _............. 3
2.2 Program Update Opportunities ........................ __............. 4
2.3 Summary Table......................._................................._ . 5
3
PUBLIC EDUCATION & OUTREACH...:...::..:.:....:::......................5
3.1 Potential Administrative Updates ................................. .. 5
3.2 Program Update Opportunities ....,.- .............................__ 6
3.3 Summary Table...............................:................................... 7
4
PUBLIC INVOLVEMENT & PARTICIPATION......::...:...................7
4.1 Potential Administrative Updates ....................................._ 7
4-2 Program Update Opportunities ................... ___ ................ 7
4.3 Summary Table .................................................... ........ ...... 8
5
ILLICIT DISCHARGE DETECTION & ELIMINATION ...................8
5.1 Potential Administrative Updates......................................8
5.2 Program Update Opportunities .....................................
9
5.3 Summary Table ................ _.............. ................................
10
6
CONSTRUCTION SITE RUNOFF CONTROLS ......................:..:.10
6-1 Potential Administrative Updates ................................ __
10
6.2 Program Update Opportunities ........................................
11
6.3 Summary Table ...................... ............................... ____
11
7
POST -CONSTRUCTION SITE RUNOFF CONTROLS.,.....-,...,,11
7.1 Potential Administrative Updates.. ...................................
11
7.2 Program Update Opportunities ...................................... '
12
7.3 Summary Table ................................................... ___ .......
12
8
POLLUTION PREVENTION & GOOD HOUSEKEEPING,,:...-,,..13
8.1 Potential Administrative Updates ...................... ......... ___
13
8.2 Program Update Opportunities ....... ........ ......... ................
13
8.3 Summary Table.. ........................................................
14
9
CONCLUSION_... .................................................. . - _ . - - _ . . _...
14
Town of Wake Forest MS4 Support
PO 2020-00000462 Our Ref. No 194372A
Town of Wake Forest
Appendices
A MS4 DOCUMENT REVIEW SPREADSHEET
B EXAMPLES FROM OTHER MUNICIPALITIES
C FULL LIST OF PRIORITIZATION
D 2017 MS4 COMPLIANCE EVALUATION
WSP
May 2020
Page 11
x
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1 INTRODUCTION
1.1 MS4 REVIEW PROCESS OVERVIEW
The Town of Wake Forest is in year three of their five-year permit cycle and are preparing for an MS4
permit compliance audit in year four, prior to MS4 permit renewal. Per the NCDEQ "MS4-Audit-
Schedule" the Town's permit will expire on 02-19-2022. An audit is scheduled to occur in 2021.
WSP was retained by the Town to review their Stormwater Management Program (SWMP) and to
develop a gap analysis, identifying opportunities for future improvement. The task began with an
external review of available MS4 materials, as well as additional items supplied by Town staff. The
supplied materials included the results of a compliance evaluation conducted by NCDEQ in 2017. A
copy of the written evaluation is included in Appendix D.
Based on this document review, WSP has developed the table provided in Appendix A. This table serves
as a foundation for identifying any gaps in the Town's SWMP. These gaps, and associated opportunities
for improvement, have been assembled and summarized below. As the Town prepares to address these
gaps, it may be beneficial to reference examples from other municipalities. Any items marked with the
symbol below can be clicked on to access relevant examples in Appendix B.
U
Additionally, any items which directly relate to observations during the 2017 compliance evaluation have
been marked with the symbol below. This symbol can be clicked on to access the compliance evaluation
report (Appendix D). Although items mw keel with this svmhol may not be ranked as the highest priority.
the► should he a focus of the program rnoring for ivarcl. siric:e the_r relate to a negative observation during
the 2017 ronlplianc e evaluation.
0
The summary table provided at the end of each section provides a preliminary estimate of resources
required to address each gap. Each subsection below corresponds to one of these gaps and has been
assessed according to three criteria: Cost, Duration, and Urgency. Scores have been assigned ranging
from 1 (lowest) to 5 (highest). These scores have been combined to develop a weighted score, which will
serve as a foundation for prioritization. The ratings provided are a qualitative estimate of cost, duration,
and urgency and are meant to develop a draft list of priorities. Actual cost and schedule estimates may
vary greatly depending on the approach taken by the Town. A full list of prioritization rankings is
included as Appendix C.
An opportunity with a lower assigned score would represent a lower estimated cost, shorter duration, and
lower urgency (not as critical for the pending audit and permit renewal). Higher scores correspond with
higher estimated costs, longer durations, and a higher level of urgency. Examples of each, are provided
below:
Low Cost: Simple SWMP report or website update, such as contact information
High Cost: Development of a new watershed plan (potentially for Tom's Creek)
Low Duration: Simple SWMP report update, such as attaching a section of the Town's UDO
High Duration: Modifying a portion of the Town's UDO, given the assumed due diligence required
Low Urgency: Development of auto specific training materials — not as critical for the audit
High Urgency: Up-to-date reporting procedures or addressing 2017 observations — critical for the audit
Town of Wake Forest MS4 Support WSP
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Town of Wake Forest Page 1

The resultant priority is based on a function of these three variables. The function utilized is described
below along with a tabular summary of the possible trends:
Priority Formula:
[2xUrgency+(6-Cost)+(6-Duration)]
20
Resultant Priority Range: 0.2 —1.0
1.2 NCDEQ MS4 AUDIT PREPARATION
Cost
Duration
Ur enc
Priority
Low
Low
High
Very High
Low
High
High
High
High
Low
High
High
High
High
High
Medium
Low
Low
Low
Medium
Low
High
Low
low
High
Low
Low
Low
High
High
Low
Very Low
As mentioned above, the table in Appendix A summarizes the findings of WSP's existing document
review. The table covers most of the topics/inquiries which may be included by NCDEQ during the audit
process. One of the primary objectives of the audit is to confirm that regulated entities have incorporated
appropriate operating procedures into their program. The SWMP report is intended to be a summary of
the procedures in place, their effectiveness, their reporting metrics and timeline. Not every item and
detail listed in Appendix A needs to be included in the SWMP Report. The actual procedures should be
included as appendices. Proof of implementation (inspection reports, training materials, etc.) should be
easily producible during the audit, but are not necessarily critical for inclusion into the SWMP Report.
Note in particular the list of documents reviewed during the 2017 compliance evaluation (Appendix D;
page 5 of 11).
NCDEQ provides an audit report tenWiatc on their -.% u I1,,rtc which provides a list of desktop review topics
and potential field assessments. If any important topics can not be covered during the audit, due to time
constraints, NCDEQ may require the Town to conduct a self -audit. The general review areas on the audit
report template are as follows:
Minimum Control Measures:
• Program Implementation, Documentation & Assessment
• Public Education & Outreach
• Public Involvement & Participation
• Illicit Discharge Detection & Elimination
• Construction Site Runoff Controls
• Post -Construction Site Runoff Controls
• Pollution Prevention and Good Housekeeping for Municipal Operations
• Total Maximum Daily Loads (TMDLs)
Field Site Visits:
• Municipal Facilities
• MS4 Outfalls
• Construction Sites
• Post -Construction Stormwater Runoff Controls
• Other
Town of Wake Forest MS4 Support WSP
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Town of Wake Forest Pape 2

The SWMP is expected to incorporate a process of implementation, assessment, and adjustment, as
highlighted by the figure below, taken from NC DEMLR's publication "A Sustainable MS4 Program".
Communicate
equlrements nt
r prattiCe or
measures to
appropriate 4U
Develop, correct,
and/or Improve
appropr;ate
practice or
measure
Assess each
practice or
measure
Additionally, page 14 of the same publication provides a list of "written procedures, standard operating
procedures, and checklists" that should be included in, or referenced by, the SWMP report. However, it is
important to note that inclusion in the submitted report will make such practices an enforceable part of the
Town's MS4 permit. Additionally, as part of this cycle of implementation and adjustment, annual reports
are suggested, which describe the status of the program. The annual reports should also provide
justification for any modifications or proposed changes.
The information below presents opportunities for improvement and to address potential gaps in the
Town's MS4 Program. Again, not all of the information needs to be included/detailed in the body of the
SWMP report, but information should be available for presentation during the audit process.
2 PROGRAM IMPLEMENTATION, DOCUMENTATION &
ASSESSMENT
According to NCDEQ's "NPDES MS4 Permitting" webpaae, 35 audits have been conducted during the
past two years.
"The most common deficiencies have been lack of required documentation,
insufficient MS4 mapping, reactive rather than proactive illicit discharge
programs, and poor housekeeping practices at municipal facilities. "
The sections below, highlight opportunities for improvement regarding general program administration.
-1 POTENTIAL ADMINISTRATIVE UPDATES
01, Adding an introduction to the SWMP report could provide an opportunity to highlight past
improvements and core objectives. Additionally, it would be helpful to address the findings of
the 2017 compliance evaluation (non-compliance, deficiencies, discrepancies, and
recommendations).
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Town of Wake Forest page 3

2. The general regulated public entity (RPE) information can he updated for this permit cycle.
Information such as population, land use, and storm sewer service area can be derived directly
from the current GIS database.
3. Similarly, information regarding the receiving streams, watersheds, and sub -basins can be found
online (most likely through the NC DMS website).
Oa. A table including all the individual receiving stream segments within the Town of Wake
Forest (ToWF) would be one way to present this information.
Ob. A sub -section on TMDL and Impaired Streams can be incorporated next. Note that
NCDEQ lists "TMDLs" as an audit review area along with the six minimum measures for
compliance. Fortunately, the Town does not appear to be subject to any Waste Load
Allocation (WLA) regulations. However, it would be beneficial to note the current status
of TMDLs and impaired waters. See section 2.2.1 below.
4. Contact information can be updated for the Town's SWMP. The contact listed should be the
"person responsible for day to day implementation and oversight of the stormwater program".
5. Add discussion in the SWMP report regarding future improvements (per the final gap analysis
and prioritization deliverable). Set reasonable/achievable goals, as NCDEQ will expect the Town
to implement improvements as promised.
6. Provide an updated organization chart.
(97. Include staffing reports, information regarding Capital Improvement Projects, and reporting year
budget for the Town's SWMP. Include a brief assessment of any financial gaps, based on the
identified improvement opportunities and projects.
8. List any contract operations and/or partnerships. As examples, this could include transit services
(GoTriangle) and educational partnerships (Clean Water Education Partnership).
2.2 PROGRAM UPDATE OPPORTUNITIES
1. Ensure that the program covers the following strategies in the SWMP report and satisfies all
water quality restrictions and plans including:
a. Neuse Nutrient Strategy (15A NCAC 02B .0710)
b. Falls Water Supply Nutrient Strategy (15A NCAC 02B .0275)
89 c. Specific TMDLs:
i. NC Statewide Mercury TMDL (all streams, category 4t)
ii. Smith Creek Benthos Impairment (category 5; TMDL required)
iii. Toms Creek Benthos Impairment (category 5; TMDL required)
2. Ensure stormwater outlets are easily accessible.
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Town *1 Wake Forest Page 4

r 2.3 SUMMARY TABLE
The following table presents the prioritization for: Program Implementation, Documentation &
Assessment.
PROGRAM IMPLEMENTATION, DOCUMENTATION & ASSESSMENT
Subsection Cost Duration
I Urgency
PrioriV
I Abbreviated Action
Potential Administrative
Updates
2.1.1
1
2
4
0.85
Add introduction to SWMP report
2.1.2
2
3
5
0.85
Update RPE information
1.1.3a
1
2
4
0.85
Update table of receiving streams
2.1.3b
1
2
4
0.85
Include TMDL information
2.1.4
1
1
5
1
Update contact information
2.1.5
2
2
5
0.9
Discuss future improvements
2.1.6
1
1
5
Provide updated or . chart
2.1.7
2
3
4
0.75 Summarize staffing and budget
2.1.8 1 2
Pro
4
0.85 Include contract operations
_
ram U date O ortunities
2.2.1a
3
4
4
OAS
Neuse nutrient strategy
2.2.1b
3
4
4
0.65
Falls nutrient strategy
2.2.1c
3
4
4
0.65
Addressing all TMDLs
1.2.2
4
3
5
0.75
Ensure access to storm outlets
The highest priorities from this section include providing updated contact information and an updated
organization chart, as well as summarizing the status of the program (past improvements [since 2017], as
well as future improvements). Additionally, accessibility to storm outlets should be a focus of the
program moving forward, since it was mentioned during the 2017 compliance evaluation.
3 PUBLIC EDUCATION & OUTREACH
Often listed as the first of six minimum measures, public education and outreach is critical for
maintaining public cooperation. This cooperation is essential, in terms of direct impacts to water quality,
and indirect support for legislation, funding, and program implementation. Several opportunities for
program improvement are presented below.
3_1 POTENTIAL ADMINISTRATIVE UPDATES
1. BMP objectives can be presented in a tabular format which lists: the description of the BMP,
measurable goal(s), schedule for implementation, and annual reporting metric(s). A ;i37 :e
template is available online, as well as an instructions document. An electronic SWMP Template
is currently under development and will supersede this interim template; while using a similar
format.
p-- 2. The previous SWMP report briefly listed the target audience and target pollutants, but this can be
expanded in more detail and include reasons why each was selected.
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Town of Wake Forest Page 5

3. The town website has a lot of good information on three educational tabs (Stormwater Education
101, Soil & Erosion 101, and Watershed Education). The SWMP report can be updated to
reference these websites and the results from the hotlines/citizen reports. Continue to update the
websites so they can be effectively utilized for public outreach and education.
4. The link for citizen contact on the "Stormwater Education 101" tab is broken, and the "Soil &
Erosion 101" tab lists Carrie's direct line for the "Erosion & Stormwater Hotline". Verify that
these methods of citizen education and reporting are set up as intended. If the volume of calls
starts to increase, it might be helpful to set up an automated directory that filters/directs calls
based on the issue. Continue to advertise SeeClickFix if that is a preferred method of citizen
reporting.
5. The website should be expanded and updated to more clearly address hazardous house waste, pet
waste, septic systems, and vehicle washing. Websites have become increasingly important tools
for education and outreach. Including additional depth/breadth of information could be
advantageous.
32 PROGRAM UPDATE OPPORTUNITIES
I . A long-term goal for this section will be developing a system to keep track of all the public
outreach data. For example, an excel sheet could be put together that includes a log of school
events that details how many students attended, number of promotional items given out, etc. An
inventory of your promotional giveaways, public signs, and displays would be helpful, to
document the content and extent of public outreach.
a. School Outreach
b. Public Signs
c. Displays
d. Commercial Outreach
e. Promotional Giveaways
f. Media Broadcasts
g. Public Newsletters
2. Include a summary of education and outreach events in the SWMP report. The summary should
include the type of events, who attended, why they were selected, and the type of materials
distributed. Additionally, if these are repeattannual events, confirm that they provide a
foundation for repetition and continued outreach.
Town at Wake Forest MS4 Support WSP
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C 3-3 SUMMARY TABLE
The following table presents the prioritization for: Public Education & Outreach
PUBLIC OUTREACH & EDUCATION
Subsection
Cost
Duration I Urgency
Priori
Abbreviated Action
Potential Administrative
U
a
3.1.1
2
2 _
2
3
0.7
OAS
Provide table of BMPs
3.1.2
1
4
_
Target audience and pollutants
3.1.3
1
2
4
0.85
Include website info in SWMP report
3.1.4
1
1
4
0.9
Update links/contacts on website_
3.1.5
2
2
3
0.7 J
U date website waste info
Pro
ram__ U date Opportunities
3.2.1
3
5
5
0.7
Track education/outreach data
3.2.2
2
1 4
L 5
1 0.8 J
Outreach summary in SWMP report
Updating the links and hotline information on the stormwater website is the highest priority for this
section. This is followed by including updated stormwater website information in the SWMP report and
updating the description of target audiences and pollutants listed in the SWMP.
Public involvement and participation are closely intertwined with public education and outreach.
Municipal stormwater programs do not have access to the resources that would be required to constantly
monitor every construction site, clean up every mile of stream, or observe the influent to every storm
drain. As such, involvement of the general public can be crucial for a successful MS4 stormwater
program. The Town of Wake Forest has a great foundation for public involvement. A few opportunities
for additional improvement are listed below.
4.1 POTENTIAL ADMINISTRATIVE UPDATES
1. BMP objectives can be presented in a tabular format which Iists: the description of the BMP,
measurable goal(s), schedule for implementation, and annual reporting metric(s). (See section
3.1.1)
2. Ensure the stormwater hotline is updated in each piece of media to reflect the most current
contact information. Continue to advertise SeeClickFix if that is a preferred method of citizen
reporting.
3. Identify and elaborate on target audiences and key stakeholders which could include but is not
limited to: Homeowner Associations, Educational Associations, Industrial Businesses, and Ethnic
and Economic Groups.
4-2 PROGRAM UPDATE OPPORTUNITIES
1. A long-term goal for this section will be developing/improving a system to keep track of the
public involvement and participation data (stream clean-ups, tree plantings, public meetings,
storm drain stenciling, etc.).
Town of Wake Forest MS4 Support WSP
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Town of Wake Forest Page 7

2. Include a summary of involvement and participation events in the SWMP report. The summary
should include the type of events, who attended, the goal of the event, and the results achieved.
Additionally, if these are repeatlannual events, confirm that they provide a foundation for
repetition and continued outreach.
3. Take advantage of the community's intellectual resources including local volunteer organizations,
the NC Cooperative Extension program, and Clean Water Education Partnership. Hosting
workshops to educate potential volunteer leaders, neighborhood coordinators, and/or business
leaders is one way to build a foundation for this program.
4.3 SUMMARY TABLE
The following table presents the prioritization for: Public Involvement & Participation
Subsection Cost
4.1.1 2
PUBLIC INVOLVEMENT & PARTICIPATION
Duration Urgency Priority Abbreviated Action
.. J
Potenti
2 3 0.7 Provide table of BMPs
4.1.2
1
2
3
0.75
Update stormwater hotline info
4.1.3
2
3
1 4 Ll
0.75
Discuss target audience or groups
Pro
ram U date
Otmortunities
4.2.1
2
3
5
0.85
Track involvement/participation data
4.2.2
2
2
3
5
0.85
Participation summary in SWMP report
4.2.3
4
3
0.6
Utilize intellectual resources
The highest priorities relating to Public Involvement are long-term goals that involve tracking
involvement and participation data and then incorporating a summary of that data into the SWMP report.
ILLICIT DISCHARGE DETECTION & ELIMINATION
Illicit discharge detection and elimination programs are a common source of negative observations during
MS4 permit review audits. NCDEQ expects the municipal SWMPs to maintain a proactive program.
Educating industries and the general public are equally as important as quickly identifying and addressing
illicit discharges. Specific opportunities for the Town of Wake Forest are summarized below.
'I POTENTIAL ADMINISTRATIVE UPDATES
1. BMP objectives can be presented in a tabular format which lists: the description of the BMP,
measurable goal(s), schedule for implementation, and annual reporting metric(s). (See section
% 2. Using the current storm sewer mapping as a foundation, continue to develop and refine a system
to actively maintain GIS data, including:
a. Drainage areas and receiving streams (start large, at the watershed scale)
b. Stormwater Control Measures (SCMs)
c. Major outfalls (especially those discharging to impaired or sensitive waters)
d. Priority areas for IDDE monitoring
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3. Provide a more detailed discussion of the enforcement mechanisms mentioned in the UDO
section 12.5.8. Reference UDO section 16.2.3, as well as the online list of civil penalties for
UDO violations.
�] 4. Provide more detail regarding the procedures to detect and eliminate illicit discharge, and how
O these procedures are implemented, evaluated, and adjusted. This could include a summary of
staff training. The 2017 compliance report mentions a `written IDDE program".
5. Expand upon the procedure for tracing and removing the source of various illicit discharges,
including:
a. Illicit dumping
b. Industrial or business connections
c. Recreational sewage
d. Sanitary sewer overflows
e. Wastewater connections to the storm drain system
6. Include information on the City of Raleigh owned and maintained Sanitary Sewer system and
their efforts to prevent illicit discharge cross connections.
5.2 PROGRAM UPDATE OPPORTUNITIES
1. Develop a system to locate priority illicit discharge areas. The system might initially be based on
land use and prior documented issues.
2. Continue to establish and advertise an illicit discharge reporting mechanism.
3. Utilize and track internal reporting forms for illicit connections, illegal dumping,
industrial/business connections, recreational sewage, and wastewater connections to the storm
drain system.
4. Incorporate "Waste Wizard" into the SWMP and potentially include a link to the webpage from
the stormwater educational site.
5. Build upon current methods of informing citizens and businesses of the hazards associated with
illegal discharge and improper disposal.
6. Create a plan for conducting additional staff training, with regards to detecting and reporting
illicit discharges.
Town of wake Forest MS4 Support WSP
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Town of Wake Forest aa9r 9

53 SUMMARY TABLE
The following table presents the prioritization for: Illicit Discharge Detection & Elimination
ILLICIT DISCHARGE DETECTION & ELIMINATION
Subsection ^ L Cost Duration I Urgency Priority Abbreviated Action
Potential Administrative U dates
5.1.1
2
2
3
0.7
Provide table of BMPs
5.1.2o
3
5
3
0.5
GIS data - DA's & receiving waters
5.1.26
2
3
4
0.75
GIS data -SCMs
5.1.2c
1
2
4
0.85
GIS data - Major Outfalls
5.1.2d
3
3
5
0.8
GIS data - Priority Areas
5.1.3
1
1
4
0.9
Regulatory mechanism in UDO
5.1.4
2
2
5
0.9
Describe IDDE plan & procedures
5.1.5
2
4
4
0.7
Plan for various illicit discharges
5.1.6
1
2
3
0.75
Raleigh SS system procedures
Pro ram
U d to
Opportunities
5.2.1
2
3
4
0.75
Locate priorlty IDDE areas
5.2.2
2
1
5
0.95
IDDE reporting mechanism
5.2.3
1
3
5
0.9
_ 0.9
Create internal reporting forms
5.2.4
1
1
4
Incorporate "Waste Wizard"
5.2.5
3
v 2
_ 4 _
4
1 OAS
1 IDDE info for businesses
5.2.6
4
5
1 0.8 J
Plan for conducting training
The top priorities with regard to IDDE are continuing to advertise utilize a reporting mechanism for illicit
discharges, as well as developing and implementing a written staff training program. The lack of an
IDDE training program was noted as a deficiency during the 2017 compliance evaluation.
6 CONSTRUCTION SITE RUNOFF CONTROLS
Unmanaged construction site runoff can be a detrimental source of sediment in stormwater runoff. The
NCDEQ, state -managed, erosion control program serves as a strong model for delegated municipal
programs. Opportunities for improvement are listed below.
6.1 POTENTIAL ADMINISTRATIVE UPDATES
1. BMP objectives can be presented in a tabular format which lists: the description of the BMP,
measurable goal(s), schedule for implementation, and annual reporting metric(s). (See section
t ) 2. Incorporate UDO guidelines for enforcement policies and mechanisms that ensure compliance in
the SWMP report. Reference UDO section 16.2.1.
3. Improve guidelines for construction waste/debris control BMPs in the SWMP report. Continue to
educate contractors and developers on the importance to water quality. (See section 6.2.1)
Town of wake Forest M34 Support wsfS
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A
4. Determine the best method for the public to notify the Town of Wake Forest regarding erosion
and sedimentation problems. Make sure this method is updated everywhere that it may be
publicly listed.
0 5. Include updated approval numbers of site plan reviews.
BO 6. Create a database to keep track of trainings and certifications for all responsible inspectors and
report those numbers in the SWMP report.
6.2 PROGRAM UPDATE OPPORTUNITIES
1. Evaluate and update the UDO to effectively address all of the topics suggested by NCDEQ,
including but not limited to, proper construction site waste disposal.
2. Continue to conduct internal reviews of the system's effectiveness. Ensure proper training is
available, and track results. Tracking metrics may include NOVs issued, citizen reports, etc.
6.3 SUMMARY TABLE
The following table presents the prioritization for: Construction Site Runoff Controls
CONSTRUCTION SITE RUNOFF CONTROLS
Subsection
Cost
Duration
I Urgency
Priority
I Abbreviated Action
Potential Administrative Updates
6.1.1 2 2 3 Provide table of BMPs
6.1.2
1
1
_
4
_ _0.7 _ _
0.9
UDO guidelines for enforcements
6.1.3
2
5
3
0.55
Guidelines for waste/debris
6.1.4
2
2
5
0.9
E&5C notification system
6.1.5
1
3
4
0.8
1 Approval numbers for site plans
6.1.6
1 3
3
1 5A,
1 0.8
Trainin s & Certificates database
pro rarn 2efte—QEportunities
6.2.1
3 5 1 2 J 0.4
Update UDO per NCDEQguidance_
6.2.2
2 4 L 5 1 0.8
Tracks progress, training, & reviews
Regarding construction site runoff, the top priorities are selectingladvertising a reporting mechanism for
citizens or staff and highlighting the Town's existing erosion control ordinances in the SWMP report.
7 POST -CONSTRUCTION SITE RUNOFF CONTROLS
It is important to update post -construction site runoff guidance according to current water quality
regulations. Located near buffered streams, water supply watersheds, and nutrient sensitive waters, it will
be imperative for the Town to develop a strong program. The program should focus on monitoring
constructed SCMs and enforcing compliance with the program's standards. Specific opportunities for
program improvement are summarized below.
7.1 POTENTIAL ADMINISTRATIVE UPDATES
1. BUT objectives can be presented in a tabular format which lists: the description of the BMP,
measurable goal(s), schedule for implementation, and annual reporting metric(s). (See section
3.1.1)
Town of Wake Foresl MS4 Support
PO. 2020-00000462 Our Ref No. 194372A
Town of Wake Forest

92. Provide additional detail in the SWMP report, from the LIDO, regarding the long-term post -
construction monitoring process, enforcement process, and operation and maintenance of BMPs.
3. Update the SWMP report and UDO to include the additional stormwater control measures
(SCMs) not specifically noted in the referenced NCDEQ manual.
4. Continue developing a database for inspection reports in conjunction with the SCM inventory.
This will facilitate program assessment and tracking any maintenance activities or issues. A
summary from this databased can be included in SWMP report.
(i 5. Update the SWMP report to specifically mention how deed restrictions may be implemented and
how the Neuse buffer rules are to be satisfied.
6. Attach the UDO section that addresses the General Engineering Design Criteria for Low/High
density projects to the SWMP report.
7.2 PROGRAM UPDATE OPPORTUNITIES
1. Update the SWMP and the UDO to address fecal coliform as a target pollutant and include
methods of monitoring and enforcement.
2. Assemble a watershed plan for Toms Creek, in response to the 303(d) listing, and impending
TMDL.
3. Continue to provide and track training for developers, inspectors, contractors, and the general
public to ensure appropriate construction, maintenance, and operation of SCMs
7.3 SUMMARY TABLE
The following table presents the prioritization for: Post -Construction Site Runoff Controls
POST -CONSTRUCTION SITE RUNOFF CONTROLS
Subsection
Cost
Duration
I Urqency
Priority
Abbreviated Action
Potential Administrative
U dates
7.1.1
2
2
3
0.7
Provide table of BMPs
7.1.2
1
2
4
0.85
Monitoring & enforcement process
7.1.3
1
_ 5
3
2
0.5
SCM options listed by NCDEQ
7.1.4
2
5
0.85
Inspection database for SCM's
7.1.5
1
2
1 3
0.75
Deed restrictions and buffer rules
7.1.6
1
1
3
0.8
Low/high density project criteria
Pra ram
U da_te O_ ortunities
7.2.1
2 5
2 0.45
Fecal coliform BMPs/regulations
7.2.2
5 5
2 4
4 0.5
Toms Creek Watershed Plan
7.2.3
5 0.8
Provide and track training
The priority in this section is an administrative update that requires including more detail in the SWMP
report, regarding the long-term post -construction monitoring process, enforcement process, and operation
and maintenance of BMPs. Additionally, it will be crucial to track any training events related to post -
construction runoff, as well as inspection reports and any required maintenance.
Town of Wake Forest MS4 Support WSP
PO 2020.00000462. Our Reif No. 194372A May 2020
Town o' Wake Forest Page 12

8 POLLUTION PREVENTION & GOOD HOUSEKEEPING
Based on guidance provided by NCDEQ, and the results of the 2017 compliance evaluation, pollution
prevention and good housekeeping should be a primary focus for the Town as their audit approaches. The
scope of this minimum measure is quite broad, and relates to both electronic documentation, as well as
field implementation. Several opportunities for program improvement are discussed below.
8.1 POTENTIAL ADMINISTRATIVE UPDATES
1. BMP objectives can be presented in a tabular format which lists: the description of the BMP,
measurable goal(s), schedule for implementation, and annual reporting metric(s). (See section
3.1.1)
2. Provide an updated list of Municipal Operations that discharge into the Town's MS4 and are
impacted by the SWMP Pollution Prevention program. (See section 8.2.1)
3. Assemble examples of any existing stormwater training materials as well as attendance records
and topics. Topics might include proper storm system maintenance, identificationlreporting of
issues, or sources of runoff that are allowable in the stormwater system.
4. Elaborate on the standard procedures for waste disposal and BMPs to ensure proper handling and
minimization of water quality impacts.
8.2 PROGRAM UPDATE OPPORTUNITIES
(71` 1. Compile data on the various town -owned facilities (pet waste stations, hazardous materials
storage, road salt storage, vehicle maintenance facilities) and ensure appropriate procedures are in
place for each. Include an assessment of drainage patterns, and where potential spills or leaks
may enter the stormwater system. Procedures should be evaluated annually. Include a summary
of these facilities and relevant procedures in the SWMP report.
E ; 2. Continue collecting detailed reports of street sweeping, storm drain inspections, pipe cleanouts,
and debris removal. This information is important for assessing the progress of the program, and
for monitoring trends and priority areas.
Q3. Develop and implement a written spill response procedure for municipal operations. Training
appears to be underway. Confirm that a written procedure exists and corresponds with training
material.
O4. Conduct and document annual reviews of town -owned and town -operated facilities.
0 5. Ensure any potentially hazardous materials are properly stored, with secondary containment as
needed, and appropriate labels.
6. Work with town -owned facilities to create staff training material for facility maintenance and
proper application of fertilizer/pesticides. The 2017 report mentions requiring licenses for
pesticide application.
7. Create educational materials geared towards automobile maintenance facilities and train staff
about automobile pollution prevention.
Town of Wake Forest MS4 Support WSP
PO: 2020-00000462 Our Rel No 194372A May 2020
Town of Wake Forest Page 13

8.3 SUMMARY TABLE
The following table presents the prioritization for: Pollution Prevention & Good Housekeeping
POLLUTION PREVENTION & GOOD HOUSEKEEPING
Subsection Cost Duration
I Urgency
Priority
Abbreviated Action
Potential
Administrative
Updates
8.1.1
2
2
3
0.7
Provide table of BMPs
8.1.2
2
2
2
5
0.9
List of Municipal Operations in MS4
8.1.3
1
4
US
Existing stormwater training
8.1.4
1
2
3
0.75
Waste disposal process
Program U date Opportunities
8.2.1
2
3
5
0.85
Town -owned facility data/procedures
8.2.2
2
4
4
0.7
System maintenance data
8.2.3
2
2
3
3
5
0.9
Develop written spill response plan
8.2.4
2
5
0.85
Annual facility reviews
8.2.5
1
5
0.9
Ensure proper material storage
8.2.6
3
3
3
0.6 _
Fertilizer & pesticide training
8.2.7
3
3
2
0.5
Auto repair trainings/materials
Note that a majority of the negative observations from the 2017 compliance evaluation were focused on
Pollution Prevention & Good Housekeeping. This might be partially due to the site inspection at the
Friendship Chapel Operation Facility. It will be very important to ensure all town -owned facilities have
the appropriate operating procedures in place, materials are stored in a safe manner, and staff are trained
to manage the facilities accordingly. Annual reports will be essential moving forward, and should
highlight any areas of concern, or any facility -specific opportunities for improvement. At this point, the
highest priorities are to update the list of the relevant facilities and develop best management practices for
each of them. These BMPs include, but are not limited to, spill response and material storage plans.
9 CONCLUSION
The action items and summary tables included above are intended to provide a foundation for program
improvement. As these improvement opportunities are addressed, the Town's program will be more
prepared for an MS4 audit and for a successful permit renewal process. It is not feasible to fully address
all of the items prior to the audit scheduled for 2021. However, this awareness of the program's status
will be extremely beneficial throughout the process. Prior to the audit, it may be most advantageous to
begin addressing the items assigned the highest priority. The list below summarizes the 29 highest
priority items (0.85-1.00).
Fown of Wake Forest MS4 Supporl
PO: 2020-00000462 Our Ref No. 194372A
Town of Wake Forest

C
Table 1; Top 29 trnprovement Opportunities Ranked by "Priority"
Subsection
Cost
Duration
Urgency
Priority
2.1.4
1
1 _
1
5
1
2.1.6
1
5
1
5.2.2
2
1
5
0.95
2.1.5
_ 2
1
2
1
5
0.9
3.1.4
4
0.9
_
5.1.3
1
1
4 0.9
_ 5.1.4
5.2.3
2
2 1
5
0.9
_
1
3
5
0.9
5.2.4
1
1
4
0.9
6.1.2
1
_
1
4
0.9 '
6.1.4
2
2
5
0.9_
8.1.2
2
2 _
- 5- -
0.9 _
8.2.3
8.2.5
2
2
5
0.9
1
3
5
0.9
2.1.1
1
2
2 _
3
4
0.85
2.1.2
5
0.85
2.1.3a
1
2
4
0.85
2.1.3b
1
2
4
0.85
2.1.8
1
2
4
1 0.85
3.1.2
1
1
2
2
4
0.85
3.1.3
4
0.85
4.2.1
2
3
3
5
0.85
4.2.2
5.1.2c
2
5
0.85
1
2
4
0.85
7.1.2
1
2
3
4
0.85
7.1.4
2
5
0.85
&1.3
1
2
4
0.85
8.2.1
2
3
1 5
1 0.85
8.2.4
2
3
5
0.85
Abbreviated Action _
Update contact information
Provide updated org. chart
IDDE reporting mechanism
Discuss future improvements
Update links/contacts on website
Regulatory mechanism in UDO
Describe IDDE plan & procedures
Create internal reporting forms
Incorporate "Waste Wizard"
UDO guidelines for enforcement_s_
E&SC notification system
List of Municipal Operations In MS4
Develop written spill response plan
Ensure proper material storage
Add introduction to SWMP report
Update RPE information
Update table of receiving streams
Include TMDL information
Include contract operations
Target audience and pollutants
Include website info in SWMP report
Track involvement/participation data
Participation summary in SWMP report
GIS data - Major Outfalls
Monitoring & enforcement process
Inspection database for SCM's
Existing stormwater training
Town -owned facility data/procedures
Annual facility reviews
Note that only 9 of these top 30 are program update opportunities (Subsection x.2.x). The rest are
potential administrative updates (x.l.x). This highlights the cost and duration disparity between program
updates and administrative updates. For administrative updates, the average cost ranking is 1.57 and
average duration ranking is 2.31. For program updates, the average cost ranking is 2.37 and average
duration ranking is 3.48.
As such, a separate table has been provided below, which highlights nine program update opportunities
with the highest priority rankings (0.85-0.95).
ry zUZV-uwVuvoc uur me] rvo iav�rr.
Town of Wake Forest

Table 2: Top 9 Program Update Opportunities Ranked by "Prio ,
Subsection
Cost
Duration
UrQency
Abbreviated Action
5.2.2
2
1
5
0.95
IDDE reporting mechanism
S.2.3
1
3
5
0.9
Create internal reporting forms
5.2.4
1
1
4
0.9
Incorporate "Waste Wizard"
8.2.3
2
2 _ _
5
_
0.9
Develop written spill response plan
8.2.5
1
3
5
0.9
Ensure proper material storage
4.2.1
2
3
3
5
0.85
Track involvement/participation data
4.2.2
2
5
0.85
Participation summary in SWMP report
8.2.1
2
3
1 5
0.85
0.85 j
Town -owned facility data/procedures
8.2.4
2
3
1 5
Annual facility reviews
Finally, depending on the Town's approach, it may be advantageous to focus on action items strictly
based on their "urgency". The table below lists all of the items which were assigned an urgency ranking
of 5. These items represent the areas which are most likely to be identified as shortfalls during the MS4
audit process, including those identified during the 2017 compliance evaluation (marked with an asterisk).
Table 3: Improvement Opportunities with Highest (5) "Urgency"
Subsection
Cost
Duration
Ur en
Priori ty
Abbreviated Action
2.1.2
2
1 3
5
0.85
Update RPE information
2.1.4
1
1
5
1
Update contact information
2.1.5
2
2
5
0.9
Discuss future improvements
2.1.6
1
1
3
5
1
Provide updated org. chart
Ensure access to storm outlets
2.2.2 *
4
5
_ 0.75
0.7
3.2.1
3
5
4
5
Track education/outreach data
3.2.2
2
5
0.8
Outreach summary in SWMP report
4.2.1
2
3
3
5
0.85
Track involvement/participation data
4.2.2
2
5
0.85
Participation summary in SWMP report
5.1.2d *
3
3
5
0.8
0.9
GIS data - Priority Areas
S.1.4*
2
2
5
Describe IDDE plan & procedures
5.2.2
2
1
5
0.95
1 IDDE reporting mechanism
5.2.3
1
3
5
0.
Create internal re orting forms
5.2.6*
2
4
1 5
0.8
0.9
Plan for conducting training
6.1.4
2
2
3
5
E&SC notification system
6.1.6
3
5
0.8
Trainings & Certificates database
6.2.2
2
4
5
0.8
Track progress, training, & reviews
7.1.4
_ 2
2
3
5
0.85
Inspection database for SCM's
7.2.3
4
5
0.8
0.9
Provide and track training
8.1.2
2
2
5
List of Municipal Operations in MS4
8.2.1 *
2
3
5
5
0.85
0.9
Town -owned facility data/procedures
8.2.3*
2
2
Develop written spill response plan
8.2.4*
2
3
5
0.85
0.9
Annual facility reviews
Ensure proper material storage
&2.5*
1
3
"5
Town of Wake Forest M$4 Sapport WSP
PO. 2020.00000462 Our Ref No 1943?2A May 2020
Town of Wake Forest Page 16

There are numerous ways to approach the findings included within this report. The "priority" ranking is
intended to provide an initial overview of the action items which are critical and can be reasonably
achieved without significant investment of time or money. However, it does not represent an exclusive
approach to improvement of the Town's MS4 Stormwater Program. There are several other ways to
analyze the data provided. Ideally, the summaries provided within this report will set a solid foundation
for future improvement and MS4 audit preparation.
town o+ Wake Forest MS4 Support WSP
i:O: 2020-00000462 Our Ref No 194372A May 2C2`J
Town of Wake Forest Page 17

APPENDIX
A MS4 <=
DOCUMENT
REVIEW
SPREADSHEET

Town of Wake Forest MS4 Permit Review
Document Review Summary
May 1S, 2020
TOWN of
WAKE FOREST
Prepared for: Town of Wake Forest Public Works I Prepared by:1 WSP USA Inc.
(Stormwater Management)
Contacts: Monica Sarna contacts: Jon Becker
Carrie Mitchell Everett Gupton
Allison Snyder I Jon May
This document was developed as a first step in reviewing the Town's MS4 program. The organization of this document and the content
included is based on NC DEQ's published list of SWMPA Questions. Each question has been reviewed based on a few key criteria to facilitate a
continuation of this program review and future updates to the SWMP and the SWMP report in preparation for a permit renewal audit, and
eventually a permit renewal application.
Requires Additional Insight (Y, N, or NA) - Yes, No, or Not Applicable
If "Y" is entered into this field, the review team feels that It would be beneficial to collect additional information from the Town's
representative. Specific Questions from WSP are highlighted in l and Responses from the Town of Wake Forest are highlighted in e, r t c r in
the "Notes" Column to the right.
Addressed in 2010 SWMP Report (Y, N, P) - Yes, No, or Partial
If "P" or "N" is entered into this field, the 2010 version of the SWMP report does not provide a sufficient response to the relevant question.
Additional information could be Included to strengthen future versions of the SWMP report. If "N" is entered here, this may be a gap for
future consideration.
Addressed in Supporting Documents (Y, N, P) - Yes, No, or Partial
If "Y" or "P" Is entered into this field, additional documents (besides the 2010 SWMP report) provide information which addresses the
relevant question. This information could be referenced or included in future version of the SWMP report. If "N" is entered here, this may be
a gap for future consideration.
Admin. Update Required (Y or N) - Yes or No
If "Y" is entered into this field, a simple administrative update is likely required for future versions of other SWMP report. For the purposes of
this assessment, an "administrative" update includes text updates only, and no programmatic changes.
Program Update Required (Y or N) - Yes or No
If "Y" is entered Into this field, there is an opportunity for improvement via programmatic changes. Changes may include new volunteer
programs, modifications to the UDO, additional training for inspection staff, revised monitoring procedures, etc.

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APPENDIX
B EXAMPLES o
FROM OTHER
MUNICIPALITIES

APPENDIX
Section 2.1.1
City of Wilmington
Program Implementation Status
The City of Wilmington is pleased to report excellent progress for year 5 compliance with
requirements of NPDES Phase H permit NCS000406. Primary areas of work include:
• Continued implementation of amended ordinances related to Post Construction and Illicit
Discharge BM[Ps.
• Continued mapping of stormwater infrastructure within areas where data is absent.
• Continuation of Public Outreach and Public Participation efforts.
• Continued dry weather flow monitoring.
• Implementation of several key actions of the Bradley and Hewletts Creek Watershed
Restoration Plan, including the installation of a large bioretention area through the
collaborative efforts of plan partners and stakeholders.
Section 2.1.1
City of Charlotte
The City proposes to continue implementing the follo%mg core NPDES stormwater permit
program components as detailed in this SWMP report
1. Public Education and Outreach Profram — Tins program proN ides the general public and

APPENDIX..:1
Section 2.1.3a
Town of Mooresville
Table 2. Town of Mooresville Receiving Waters
River Basin
Receiving Stream Name
Stream
Segment
Water Quality
Classification
TMDL
(Yes/No)
Catawba
Byers Creek
11-8 - 1
WS-IV
No
Byers Creek
11-89-(2)
WS-IV; CA
No
Davidson Creek
11-1o6
WS-N• CA
No
McCrary Creek
11- 1.
WS-IV B• CA
No
Reeds Creek
11-10 - 1
WS-IV B
No
Reeds Creek
11-10 - 2
WS-IV B• CA
No
WorkCreek
11-10
WS-IV B• CA
No
Yadkin pee-
Dee
Back Creek
12-108-21-1- o.
WS-II•H W
No
e Branch
1 - -2
C
No
Rodw River
13-17
C
No
South Fork Withrow
Creek
12-io8-21- -2
C
No
West Branch Rocky
River
13-7-3
C
No
Section 2.1.3b
'ity of Wilmington
TOTAL MAXD4UM DAILY LOADS (TMDLs)
1. Objective
Determine whether a TMDL has been developed and approved or established
by EPA for the receiving water(s) of the MS4 stormwater discharge and/or
downstream waters into which the receiving water directly flows.
b. Develop and implement BMPs to reduce non -point source pollutant loading to
the maximum extent practicable (MEP) if the permittee is or becomes subject
to an approved TMDL with an approved Waste Load Allocation (WLAs)
assigned to stormwater.
If subject to an approved TMDL, the permittee is in compliance with the TMDL
if the permittee complies with the conditions of this permit, including developing
and implementing appropriate BMPs to reduce non -point source pollutant
loading to the maximum extent practicable (MEP).

F's
Section 2. 1.3b
City of Charlotte
Q,
Charlotte Impaired Streams
APPENDIX

APPENDIX
Water Supply Watershed Protection
Mountain Island Lake and Lake Wylie in the Catawba River system are located on the City of
Charlotte's western border. These lakes are classified as WSXV except for the loner portion of
Lake Wylie south of Paw Creek, which has a WS X classification. Approximately 1.5% of the
City of Charlotte's jurisdiction lies in the Mountain Island Lake watershed area and 8.5% lies in
Lake Wylie. both of which fall under Charlotte's water supply watershed protection rules
incorporated into the City's Zoning Ordinance. Table 3-1 pmrides a summary of the water
supply watershed protection ordinances in the City of Charlotte.
Table 3-1: Summary of Existing Water Suooly Watershed Ordinances in the Citv of Charlotte
Une I Built Upon Area 7TLaiuJS m Bn$ere
Mountain Nand Lalse
ProtecW Area 1(PA)
< 24619 - Low Density
a SVe - High Density
50 Feet
100 Feet
Critical Area I (A)
a 6% - Low Density
100 Fee or 100yr. FlaoAplain(—W-Eig-w— is peater)
Cnttcal Area 4 CA4
< 246. - Low Density
100 Feet or 100 im Floodplain whicherner is ater
II Labe'B yHe (above Pax Creek)
Area (PA)
Lc 240. -Low Denuty
:5706i-IfighDansity
40 Feet
100 Feet
Critical Ana (CA)
a 240,: - Low Density
a M - High Density
100 Feet
100 Feet
Lower Lake WAt
Pax C
Protected Area (PA)
S 246. - lAm Density
e 70••: - Density
40 Feet
100 Feet
Critical Area (CA)
5 205: - Low Density
< We - ffich Density
50 Feet
100 Fee*
* For Lauer Lake VVylie Watershed only. buffer width is increased 509. for lots with an mwage slope greater
than or equal to 50%. This applies only to now dwelopment proposed along the labes)wre, and using the htgh-
deusity aption-

C APPENDIX
Section 2.9.7
City of Wilmington
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APPENDIX
Section 2.2, 9 c
City of Charlotte
The TMDL process establishes the allowable loadings of pollutants or other quantifiable
parameters for a water body based on the relationship between pollution sources and in -stream
water quality conditions. The TMDL process is used by States to establish water quality based
controls to reduce pollutants from point and non -point sources and restore and maintain the
quality of the water resources in compliance with applicable standards. In addition to the 303(d)
list, the federal Clean Water Act requires States to submit a report describing how well water
bodies support designated uses (e.g. swimming, aquatic life support, water supply), as well as
likely causes and potential sources of impairment (305(b) list).
For this sub -section, the North Carolina Assessment and Impaired Waters List (2014 303(d) List)
was used to identify the use support ratings of the water bodies in the City as well as those water
bodies not meeting applicable water quality standards and requiring TMDL development. This
information is summarized in Tables 2-1, 2-2, And 2 3. A total of 17 streams with watershed
areas partially or fully in the City andlor City ETJ are identified on the 303(d) list as impaired
and not meeting established water quality standards. Figure 2-1 identifies the locations of these
impaired stream sections in the City. Table 2-3 and Figure 2-2 show the surface waters with an
approved TMDL.
Table 2-3: City of Charlotte Streams with Approved TMDLs
Receiving Stream
Name
WQ
Classification
TMDL Approved
Tll11DL Pollutant of Concern
Irwin Creek
C
March 2002
Fecal Conform
Irwin Creek
C
Fe 2005
Turbidity
Irwin Creek
C
February 1996
Dissolt*ed Oxygen
Lake Wylie
WSTV, B, CA
Febmary 1996
Total Pho horw, Total Nitroen
Little §!M Creek
C
March 2002
Fecal Conform
Little Sugar Creek
C
February 2005
Turbidity

APPENDIX
Section 3.1. 9
City of Charlotte
Table 7-1: BUT Summary Table for the Public Education and Outreach Program.
Bbe
BW Description
Schedule
ears
Responsible
1
1 2
3 1
4
S
Position
Evaluation of
Determine the target pollutants and target pollutant
X
X
X
X
X
Water Quality
target pollutants
sources the public education program is designed to
Program
and target pollutant
address and why they are an issue.
Manager
sources
Evaluation of
Determine the target audiences likely to have
X
X
X
X
X
Water Quality
target audiences
significant stormwater impacts and why they were
Program
selected.
Manager
Informational
Promote and maintain an intemet website designed
X
X
X
X
X
Water Quality
website
to convey the program's message.
Program
Manager
Public education
Maintain and distribute general stormwater
X
X
X
X
X
Water Quality
materials for
educational materials to appropriate target groups
Program
identified user
likely to have a significant stormwater impact.
Manager
groups.
Stormwater
Maintain and promote a stormwater hotline/helpline.
X
X
X
X
X
Water Quality
Hotline/Help line
Program
Manager
Public Education
Implement a multi -faceted program including
X
X
X
X
X
Water Quality
and Outreach
educational materials, presentations, and mass
Program
Program.
media which may include using media channels
Manager
such as newspaper, television, radio advertising, and
social media
c

APPENDIX O
Section 3.1.2
City of Charlotte
7.1.3 Target Audience
The current target audiences for the public education program are listed below with an
explanation about why they are being targeted for educational outreach. These are evaluated
with the development of the subsequent SVIW plans following permit renewal.
This subgroup of the general public has been selected because, as
compared to younger or older generations, they likely have the greatest potential for affecting
stonnwater quality. They represent about 55% of the City's residents and have the greatest
potential for engaging in many target activities such as yard care, disposal practices, pet
ownership, car maintenance, and pollution reporting.
Multi -Family Residential Apartment Complexes: This target audience has been selected because
SSOs are commonly caused by improper grease disposal at multi -family residential apartment
complexes.
Construction Industry: This target audience has been selected because it has the greatest potential
for affecting erosion and sedimentation control at construction sites, which can be a significant
contributor of sediment to the City's waterways.
101
0

APPENDIX
Section 3.2.2
Town of Mooresville
Articles focused on stormwater pollution prevention information or on topics related to
stormwater are published in the Town of Mooresville utility mailing, the Town Voice, several
times per year. Approximately iq,soo residents and businesses receive a copy of the Town Voice
every month and it is also available online at hhn:l ici.mooresville.nc.us/478/Town-Voice-
Newsletter• Stormwater specific article topics are chosen based on citizen reports, complaints
and requests for service as well as information provided by Town of Mooresville staff. see the
table below for the article topics published this year.
Table 62 Stormwater-related articles published in Town afbloores%ille Town Voice Newslener in
fiscal year aas8 (Ju4. a. aims --June go, a048)
Mon
e T c
e on
J y 2o17
Fats, Oils & Grease (Town of
Article includes information a ing citizens to
Mooresville F.O.G program)
never pour grease or used oil into the storm
drains or in the Wund.
August
Car Maintenance and
Artie describesow byproducts of automotive
2017
Stormwater
maintenance can pollute local waters and how
citizens can prevent stormwater pollution while
erfo maintenance on their vehicles.
October
Keep Storm Drains Free of
Article requests help from cluiensmo oring
2017
Debris
storm drams and keeping storm drains from
being blocked by debris.
Decem r
Reporting Illidt Discharges
-Article provides a definition of M discharge,
2017
how to report an Micit discharge, and tips that
can be used to lorevent illicit disch es.
May 2o1
B
Artl a w t a an ow t
can be used to reduce a water utility bill,
conserve water, and reduce potential pollutants
entering the storm drainage system.
Date
Event
Number
Topic of demonstration
Reached
9/6/2018
Environmental
To
General information and an update on the
Protection
stormwater program.
Commission
Meeting
9/28/2017
Citizen's
Approximately
Stormwater Program Specialist discussed
Academy
10 citizens
the six minimum measures detailed in the
Town's NPDES Phase I1 Stormwater
permit and maintenance of Town owned
and maintained stormwater infrastructure.
6/18/2018
Summer Camp
29 summer
Stormwater Program Specialist used the
at Selma Burke
camp attendees
watershed model to demonstrate the
Center
connection between storm drains and
neighboring water bodies. Demonstration
also discussed common sources of
stormwater pollution and how to reduce
stormwater Pollution.

APPENDIX
Section 3.2, 2
City of Charlotte
Hotline Promotion: The City, in cooperation with Mecklenburg County, operates a joint
customer service hotline to receive information about a variety of concerns. Citizens can dial
311 any time of the day (24171365) to report pollution, flooding, blockages to the drainage
system as well as request other CityrCounty services. The City promotes this hotline throughout
all of the activities provided as part of the Stormwater Public Education and Outreach Program.
Messages focus on helping residents understand how to recognize and report sormwater
pollution.
School Presentations: School presentations are provided to students from fast grade through
senior in high school. These presentations are customized to the grade level and provide lessons
that focus on the water cycle, local watersheds, non -point versus point sources of pollution,
water conservation, and pollution prevention.
Public Presentations and Events: Public presentations are provided upon request to a variety of
audiences such as civic clubs, home owner associations, and commercial sectors. Public events
such as community fairs and other events are attended by staff that set up information tables,
provide activities, and distribute brochures and promotional products.
Website: A wide variety of pollution prevention, water quality, and volunteer information is
maintained on the Charlotte -Mecklenburg Storm Water Services (CMSWS) website
http:.':'charmeck.or"tormwateri-Pages/defauh.aspx. This website is promoted through the
promotional and educational materials produced by the City's Stormwater Public Education and
Outreach Program.
Public Education Materials: A wide variety of print media and promotional materials about
water quality and pollution prevention is maintained and provided to the public. This includes
brochures, fact sheets, postcards, booklets and promotional materials such as pens, pet waste
bags, etc. Print media and promotional products are distributed during responses to citizen
requests for service, public events, presentations, and/or through direct mail.

APPENDIX
Section 3.2.2
City of Asheville
Estimated
Number of EaMsure
Water Education Tows w-activity
290
Flood Brochure Mailing
27,000
Repetitive Flooding Letter
143
Rugby Middle School
330
Buncombe County Fall & Spring Field Days
1,200
JCC Grandparents Day Fall Han est
115
Buncombe County workforce Program
200
Enka Middle School Career Day
360
Ira B. Jones Elementary School Career Day
300
Haw Creek Elementary School Career Day
70
City of Asheville Bring Your Son/Daughter to work
24
Green Building Commission Meeting
25
Flood Plan Conference (Speaker)
150
Neighborhood Association Meetings
94
Website & Blog Post
Section 3.2.2
Town of Fuquay-Varina
FY2019
On May 16. 2019, The TOFU Engineering Department hosted a Homebuilder Lunch and Learn
event for education on new NCG01 requirements, erosion control, and waste management on
single lot construction sites. The event was sponsored by the Triangle Delegated Erosion &
Sedimentation Control Programs. Over 100 homebuilders and local program representatives
attended the event.
c.

APPENDIX O
Section 5.1.4
Town of Mooresville
ITable zo: Illicit Discharge Training in fiscal year 2ot8 I
Facility
Date
Departments
Number of
'pained
Employees
Potentially
Exposed to
Training
Public Services
10/26/2017
Engineering, Streets
86
Operations Facility
Maintenance, Water
Sewer Maintenance,
Sanitation
Buildings and
11/1/2017
Buildings and
12
Grounds
Grounds
Maintenance Shop
Maintenance
Water Treatment
11/1/2017
Water Treatment
13
Plant
Plant Staff
Wastewater
11/1/2017 1
Wastewater
18
Treatment Plant
Treatment Plant Staff
Fire Department
11/1/2017
Fire Department
95
Stations
Staff
Section 5.1.6
City of Charlotte
Sanitml} Smsyr Overflows and Septic 31 stems — The City implements a program to reduce
sanitary server overflows including preventative maintenance, inspections, rehabilitation,
cleaning, education/training, mapping. monitoring, data analysis, and rapid response/cleanup. A
"Sewage Spills Matrix" detailing procedures and responsibilities for responding to sewage found
to surface waters is followed by appropriate field personnel.

APPENDIX
Section 6.1.2
City of Charlotte
The Charlotte Soil Erosion and Sedimentation Control ordinance amended and adopted by
council in 2008, serves as the backbone of the program (see Appendix C). Ordinance highlights
include the following requirements:
• An approved soil erosion and sediment control plan for all qualifying land disturbances
of one acre or greater;
• An on -site preconstruction conference prior to the installation of any measures or
commencement of land disturbing activities;
+ Issuance of a grading permit prior to the commencement of land disturbing activities;
• Weekly inspections at a minimum by the permit holder of erosion control measures
depending on sensitivity of receiving waters;
• Inspections by the permit holder of measures after any rainfall event totaling one-half
inch or greater;
• Documentation and maintenance of inspection records performed by the permit holder;
• Maintenance and optimal performance of all measures for the life of the project
performed by the permit holder;
• Requirements for controls to minimize erosion and prevent offsite sedimentation; and
• Enhanced local erosion control requirements which were deemed essential for protecting
sensitive environmental features and were developed based on years of field experience
and observations_
Section 6.1.5
City of Asheville
SEDIMENTATION PLAN REVIEWS
Received
Reviewed
Approved
Disapproved (Insufficient information)
STORMWATER PLAN REVIEWS
Received
Reviewed
Approved
Disapproved (Insufficient information)
Total Disturbed Acres Permitted
TOTAL NUMBER
674
1,002
614
5
TOTAL NUMBER
66
51
42
44
128,150

AF.. -- _.
Section 6.1.6
City of Charlotte
7.4.4.1 Education and Training Materials
The City maintains an education and training program for developers, contractors and other
interested parties within the region_ Although program policies and procedures dictate that self -
inspectors maintain a level of competence necessary to ensure compliance, the City takes a
proactive role in providing local training and handout materials for affected parties.
In a cooperative effort ,%ith Mecklenburg County, the City of Charlotte currently maintains the
Charlotte -Mecklenburg Comfied Site Inspector (CMCSI) training program, utich has to date
provided training to over fire thousand (5,000) individuals since its inception in 2003. CMCSI
is a full day training course that provides attendees with an understanding of the importance of
water resources to our community, the local and state requirements for controlling construction
site runoff, principles of erosion control, common site problems, recommendations for
conducting effective inspections, and a certification exam. The CMCSI program is typically
offered four times per year. When requested, the program is conducted for private parties who
meet certain requirements with regards to number of attendees and provision of materials and
meeting space_
In addition to the CMCSI education program, all developers, builders and responsible parties
receive handouts and materials at the preconstruction meeting and at other times as necessary to
explain ordinance requirements, minimum standards and other relevant information for the
financially responsible party and/or site operators.

APPENDIX
Section 7.1.2
Town of Mooresville
5.6 Mechanism to require long-term operation and maintenance of
Stormwater Control Measures (SCMs)
The Phase II Post Construction and Illicit Discharge and Connection Ordinance requires that all
owners of post construction structural stormwater control measures installed as a requirement
of this ordinance to submit an Operation and Maintenance Agreement to the Stormwater
Program Specialist. The Operation and Maintenance Agreement requires the owner to
continuously operate and maintain the stormwater control and management facilities. The
agreements also detail the important maintenance procedures and inspection activities to be
performed for the specific type of structural stormwater control measure. Owners of these
structural stormwater control measures are also required by the ordinance to submit annual
23
inspection reports performed by a qualified professional as defined by the ordinance. Operation
and maintenance plans and annual inspection reports for Town owned and maintained
stormwater control measures are maintained by the Stormwater Program Specialist. In fiscal
year 2018, 12 new Operation and Maintenance Agreements for Stormwater Control Measures
were recorded with Iredell County Record of Deeds and submitted to the Stormwater Program
Specialist.
Section 7.1.5
City of Wilmington
The follotwg excerpt from the new stormwater ordinance became operational upon adoption City
Council.
The approval of the stor inwater per snit shall requir o an w1fo2 ceable rasnvction on propinly usage
that mns x7th the land, such as recorded deed resn•ictions or protactve covenants, to ensure that
future development and redevelopment maintains the site consistent with the approved project
plans.
Additionally. the new ordinance has provisions to ensure that conveyance of the property does not
terminate the original developer's obligations until a replacement permit has been issued. The
original developer trill be required to record in the deed conveying the property a notice of the
existence of any stormwater de-ices and the purchaser's obligations to maintain and suspect them
and to obtain a permit. There are also specific and detailed special requirements for property
of her associations regarding operation and maintenance of sionms+•ater de-ices, escrotrsng funds
to ensure maintenance and remedies for the City in the event of failed compliance.

APPENDIX
Section 7.1.6
City of Charlotte
75.3 Post -Construction BMP Strategics
BUM strategies for the City's Post -Construction Stormwater Management program consist
mainly of structural stormwater control measures (SCMs) such as sand filters, wet ponds,
wetlands, and bioretention areas. SCMs and design procedures are detailed in a local manual
developed by the City and County_ SCMs are required on projects that have 24% or greater built
upon area as defined by the program. This threshold is reduced to 10-120,o built upon area for
developments disturbing more than an acre and/or adding more than 20,000 sf of built upon area
in sensitive watersheds as defined by the ordinance_ In addition, SCMs roust be designed to:
• Remove 85% of Total Suspended Solids (TSS) for the runoff volume generated from the
first 1-inch of rainfall;
• Control the runoff volume from the 1-year — 24 hour storm event; and
• Control the peak floe from the 10 and 25-year storm events for residential and
commercial development
The program also requires proper operation, maintenance, and inspection of SCMs as discussed
in later sub -sections. Green infrastructure practices such as rain gardens, pervious pavements,
vegetated conveyances, and rain water harvesting are allowed, depending on development needs
Undisturbed natural areas and natural resource protection as well as tree preserx-ation
requirements are part of the program Additional requirements include:
• 700a Total Phosphorus removal in certain watersheds;
• Various buffer requirements and widths from 30 — 200 feet based on stream jurisdictional
determination; and
• Design standards depending on watershed location and sensitivity.
All of these requirements combine to make a much more sound and protective ordinance and
program (see appendix D for more detail)
x
x

APPENDIX
Section 8.1.2
Town of Fuquay-Vafrna
The below table shows a list of municipal facilities within the MS4_
Table 21: FY2019 Municipal Facilities
NO.
Use
1
PARKS
ACTION PARK
2
PARKS
ALSTON RIDGE PARK
3
PARKS
BANKS RD ELEM PARK
4
PARKS
CAROL HOWARD JOHNSON PARK
5
PARKS
CENTENNIAL TRAIL
6
PARKS
DOG PARK
7
UTILITY
EAST REG PUMP STATION
8
PARKS
FALCON PARK
9
WORKS
FIRE STATION 1
10
WORKS
FIRE STATION 2
11
PARKS
FLEMING LOOP PARK
12
PARKS
HONEYCUTT RD PARK
13
UTILITY
KENNETH CRK WWTP INACTIVE
14
PARKS
LIBRARY PARK
15
UTILITY
MILLS RIDGE PUMP STATION
16
PARKS
MINERAL SPRING PARK & ADMIN OFFICES
17
UTILITY
NW REG PUMP STATION
18
WORKS
POLICE DEPARTMENT
19
PARKS
SOUTH PARK
20
UTILITY
TERRIBLE CREEK WWTP
21
WORKS
THE HILL! WATER TANK ! PUBLIC WORKS OPS
22
WORKS
TOWN HALL
23
PARKS
WEST JONES PARK
24
WORKS
I PUBLIC SERVICE CTR - HOLLAND RD
Of the twenty four municipal facilities, only two of the facilities have structural stormwater control measures.
Annual maintenance is performed on a wet pond and a bloretention at the Public Service Center and
another SCM Is under construction at Fleming Loop Park. Town Engineering staff utilizes template
maintenance manuals for inspection frequency and maintenance requirements.

APPENDIX
Section 8.1.2
City of Charlotte
7.6 4 1 NPDES Stormwater Permitted Municipal Facilities Retiew
Twelve (12) City facilities, which are listed in Table 7-14, have been issued NPDES Stormwater
permits (*Note: The airport's permit is a combined stormwater wastewater inditidual permit).
Table 7-14: Municipal Operations with NPDES Stormwater Permits
Municipal Operation
Permit
Number
Certificate or Permit
Coves a Number
Addras
CATS Transit Maintenance
orations Center
NCG080000
NCG080029
901 N Dm idson Street
CATS Bus Maintenance
Operations Facility
NCG080000
NCG080710
3145 S Tryon Street
Heavy Truck Shop, Truck
Wash dr Street Sweepa
Yard
NCG080000
NCG080822
929 Louise Avenue
Heavy Equipment Shop
NCG080000
NCG080940
4600 Sweden Road
Light Vehicle Maintenance
shop
NCG080000
NCG080879
1031 Atando Avenue
12 Street Vehicle Garage
NCG080000
NCG080063
900 W 12th St.
Charlotte -Douglas
International orN
NC0083887
Not applicable
5501 Josh Birmingham Padmay
Irvin Creek WWTP
NCGI10000
NCG110008
4000 Westmont Drive
Mallard Creek VM rP
NCG1i0000
NCGI10114
12400 Highway 29 North
McAlpine Creek WWTP
NCG110000
NCG110010
12701 Lancaster Hwy
McDonnell Creek WWTP
NCG110000
NCG110011
4901 Neck Road
Sugar Creek W % TP
I NCG110000
NCG110012
5301 Closebum Road

APPENDIX
Section 8.2.2
City of Asheville
The City of Asheville's maintenance program consists of leaf and garbage pick-up, yard waste
and brush removal, street sweeping, and storm drain cleaning and maintenance n-ithin the city's
rights of way.
The City of Asheville's Public Works Storms ater staffpenodically cleans and inspects all catch
basins in our maintained system. The Public Works Department upgrades or rehabilitates
existing structures when warranted. Staff also sweep on an annual basis, our target is 3-4 times
per year.
Through this operation the city removed 1,205 tons of material that had the potential to enter the
Stormwater system.
The City of Asheville's Public Works Department operates two vacuum trucks that clean out
storm drainage pipes and structures. The trucks have cleaned and inspected 6,574 drains this
fiscal year. The city operates these trucks on a cycle and inspects and cleans areas on a periodic
basis. The city also operates 3 sweepers to assist n*ith preventing any material from entering into
the storm drainage system. The City of Asheville s Public Works staff also responds to
complaints on storm drains and other drainage structures as needed. The City of Ashm ille's
Public Works Department staff cleans the storm drainage systems on an average of once a year
or as otherwise needed with a vacuum trwk_
Q,

APPENDIX °
C FULL LIST OF o
PRIORITIZATION
m

n
Cost
Duration
Urgency
Prloriti
Abbreviated Action
727
1
2
4
OAS
Add introduction to SWMP report
2
3
5
OAS
Update RPE information
2.1.3a
1
2
4
0.85
Update table of receiving streams
2.1.3b
1
2
4
0.85
Include TMDL information
2.1.4
1
1
5
1
Update contact information
2.1.5
2
2
5
0.9
Discuss future improvements
2.1.6
1
1
5
1
Provide updated org. chart
2.1.7
2
3
4
0.75
Summarize staffing and budget
2.1.8
1
2
4
0.85
Include contract operations
2.2.Ia
3
4
4
0.65
Neuse nutrient strategy
2.2.Ib
3
4
4
0.65
Falls nutrient strategy
2.2.1c
3
4
4
0.65
Addressing all TMDLs
2.2.2
4
3
5
0.75
Ensure access to storm outlets
3.1.1
2
2
3
0.7
Provide table of BMPs
3.1.2
1
2
4
0.85
Target audience and pollutants
3.1.3
1
2
4
0.85
Include website info in SWMP report
3.1.4
1
1
4
0.9
Update links/contacts on website
3.1.5
2
2
3
0.7
Update website waste info
3.2.1
3
5
5
0.7
Track education/outreach data
3.2.2
2
4
5
0.8
Outreach summary in SWMP report
4.1.1
2
2
3
0.7
Provide table of BMPs
4.1.2
1
2
3
0.75
Update stormwater hotline info
4,1.3
2
3
4
0.75
Discuss target audience or groups
4.2.1
2
3
5
OAS
Track involvement/participation data
4.2.2
2
3
5
0.85
Participation summary in SWMP report
4.2.3
2
4
3
0.6
Utilize intellectual resources
5.1.1
2
2
3
0.7
Provide table of BMPs
5.1.2o
3
5
3
0.5
GIS data - DA's & receIv! ng waters
5.1.2b
2
3
4
0.75
GIS data -SCMs
5.1.2c
1
2
4
0.85
GIS data - Major Outfalls
5.1.1d
3
3
5
0.8
GIS data - Priority Areas
5.1.3
1
1
4
0.9
Regulatory mechanism in UDO
5.1.4
2
2
5
0.9
Describe IDDE plan & procedures
5.1.5
2
4
4
0.7
Plan for various illicit discharges
5.1.6
1
2
3
0.75
Raleigh SS system procedures
5.2.1
2
3
4
0.75
Locate priority IDDE areas
5.2.2
2
1
5
0.95
IDDE reporting mechanism
5.2.3
1
3
5
0.9
Create internal reporting forms
5.2.4
1
1
4
0.9
Incorporate "Waste Wizard"
5.2.5
3
4
4
0.65
IDDE info for businesses
5.2.6
2
4
5
0.8
Plan for conducting training
6.1.1
2
2
3
0.7
Provide table of BMPs
6.1.2
1
1
4
0.9
LIDO guidelines for enforcements
6.1.3
2
5
3
0.55
Guidelines for waste/debris
6.1.4
2
2
5
0.9
E&SC notification system

Subsection
cr
Duration
Urgency
Abbreviated Action
6.1.5
1
3
4
0.8
Approval numbers for site plans
6.1.6
3
3
5
0.8
Trainings & Certificates database
6.2.1
3
5
2
0.4
Update UDO per NCDEQ guidance
6.2.2
2
4
5
0.8
Track progress, training, & reviews
7.1.1
2
2
3
0.7
Provide table of BMPs
7.1.2
1
2
4
0.85
Monitoring & enforcement process
7.1.3
1
5
2
0.5
SCM options listed by NCDEQ
7.1.4
2
3
5
0.85
Inspection database for SCM's
7.1.5
1
2
3
0.75
Deed restrictions and buffer rules
7.1.6
1
1
3
0.9
Low/high density project criteria
7.2.1
2
5
2
0.45
Fecal coliform BMPs/regulations
7.2.2
5
5
4
0.5
Toms Creek Watershed Plan
7.2.3
2
4
S
0.8
Provide and track training
8.1.1
2
2
3
0.7
Provide table of BMPs
8.1.2
2
2
5
0.9
List of Municipal Operations in MS4
8.1.3
1
2
4
0.85
Existing stormwater training
8.1.4
1
2
3
0.75
Waste disposal process
8.2.1
2
3
5
0.85
Town -owned facility data/procedures
8.2.2
2
4
4
0.7
System maintenance data
8.2.3
2
2
5
0.9
Develop written spill response plan
8.2.4
2
3
5
0.85
Annual facility reviews
8.2.5
1
3
5
0.9
Ensure proper material storage
8.2.6
3
3
3
0.6
Fertilizer & pesticide training
8.2.7
3
3
2
0.5
Auto repair trainings/materials

APPENDIX
2017 MS4
COMPLIANCE
EVALUATION
Q,

Energy, Mineral &
Land Resources
ENVIRONMENTAL OUAUTY
October 27, 2017
Scott A. Miles, PE, Assistant Town Engineer
Town of Wake Forest
301 S. Brooks St,
Wake Forest, NC 27587-2901
Subject: MS4 Compliance Evaluation
Permit No. NCS000467
Dear Mr. Miles:
ROY COOPER
CiArmeq
MICHAEL S. REGAN
TRACY DAVIS
rh, re uu
The North Carolina Department of Environment Quality (NCDEQ), Division of Energy, Mineral
and Land Resources (DEMLR), conducted a Municipal Separate Storm Sewer System (MS4) Compliance
Evaluation of Town of Wake Forest on August 28, 2017. The compliance evaluation is conducted to
evaluate the City's compliance with the requirements of Section 402(p) of the Clean Water Act (CWA),
33 U.S.C. § 1342(p), the regulations promulgated there under at 40 Code of Federal Regulations Part
122.26, and the North Carolina National Pollutant Discharge Elimination System (NPDES) Permit No.
NCS000467. I appreciate the staff willingness to work with DEQ during the compliance evaluation.
Overall the staff should be commended on the initiatives they've taken to managing stormwater
under the conditions of the Town's permit.
Attached is the final inspection report, which also includes the Town's post -inspection responses
and actions to date to address identified areas of non-compliance, deficiencies, and discrepancies.
If you have any questions concerning this matter please feel free to contact me at [phone]
or [e-mail]
Sincerely,
Robert D. Patterson, PE
Environmental Engineer
Stormwater Program
cc: NCS000467 File
Jeevan Neupane, DEMLR Central Office
Rick Riddle, DEMLR Central Office Stormwater
Thad Valentine, DEMLR Raleigh Regional Office
Rachel Hart — EPA Region 4
'Nothing Compares
551.a0ulN(U1hCJre4ina Emrronnn•ukdQualRti Ltlrrg$ tUncial"landRrv-ut c%
512 N Salisbur j Slwo 10II PlJil Srr Virc CCnlrl Rakich Kn11h l'a1 alma 21bQy 1111)
914 707 4200

CDEQ MS4 Audit I Town of Wake Forest I August 28, 2017
Q
BACKGROUND
The North Carolina Department of Environment Quality (NCDEQ), Division of energy Mineral and Land
Resources (DEMLR), conducted a Municipal Separate Storm Sewer System (MS4) Compliance Evaluation
of the Town of wake Forest on August 28, 2017. The compliance evaluation Is conducted to evaluate
the City's compliance with the requirements of Section 402(p) of the Clean Water Act (CWA), 33 U.S.C. §
1342(p), the regulations promulgated there under at 40 Code of Federal Regulations Part 122.26, and
the North Carolina National Pollutant Discharge Elimination System (NPDES) Permit No. NCS000453.1
appreciate the staff willingness to work with DWQ during the compliance evaluation.
DEQ Stormwater Compliance Evaluation Team
• Jeevan Neupane
• Robert Patterson
• Rick Riddle
• Thad Valentine and
• Mike Randall
Town of Wake Forest Staff
+ Scott M Iles, P.E., Assistant Town Engineer
• Eric Keravuori, P.E., Director of Engineering, and
• Holly Miller, P.E., CPESC, CFM, Assistant Town Engineer
Purpose of the Compliance Evaluation
The purpose of the Compliance Evaluation was for training, routine program compliance evaluation, stronger
coordination and working relationship with the State and regulated entity, provide a better understanding of the
state's expectations, provide an opportunity to clarify any misunderstandings, improved State's knowledge of
the Town of Wake Forest's stormwater program, and to facilitate a more effective program.
Contact information
Scott A. Miles, PE, Assistant Town Engineer
Town of Wake Forest
301 S. Brooks St, Wake Forest, NC 27587-2901
[phone]
[phone] (fax)
[e-mail]
Contract Operations/MOU
City of Raleigh — Bus Service, Water and Waste Water
Wake County— EMS and Fire Department.
8.28.2017 WF Audit Page 1 of 11

DEQ RM Audit I Town of Wake Forest I August 28, 2017
Background Information
Permit Number: NCS000467
Permittee, Town of Wake Forest
Reliance on another entity perform one or more of your permit obligations: Not Applicable
Co -Permit Information: Not Applicable
Interagency Agreements or Stormwater Partnerships: CWEP, City of Raleigh, SWANC, AWA
Stormwater Fee: Not Applicable
Hot Line: 919435-9440
Website Information: https://www.wakeforestnc.gov/environmental-education.aspx
Engineering Department duties include streets/rehab projects, Stormwater/Phase II, Erosion and
Sediment Control, Construction Administration, Environmental Grants, Stream Restoration, Greenway
Construction, Environmental Education, and other duties as required.
Town of Wake forest has had a delegated E&S program since July, 2006. Permits are required for
projects of 1/2 acre or more — SCM are required for sites I acre and above. SCM are designed for the
2/10-yr peak, 85 TSS and N/P reduction. In October, 2007, the Town of Wake Forest was issued an
NPDES M54 Permit, NCS000467, for discharges to receiving waters, Austin Creek, Horse Creek, Sanford
Creek, Smith Creek, Richland Creek, and Toms Creek within the Neuse River Basin. The permit's
limitations and controls cover program implementation, public education and outreach, public
involvement and participation, illicit discharge detection and elimination, construction site runoff
controls, post -construction site runoff controls, pollution prevention and good housekeeping for
municipal operations
The Town of Wake Forest covers 14.3 square miles with populations of 42,000 population.
Watersheds include Richland Creek, Smith Creek, WF reservoir (formerly), Horse Creek (Falls Lake), Toms
Creek (Neuse River).
Municipal Owned Facilities include the Town Hall Complex, a constructed wetland and bio-retention
basin, police station, facilities building, facilities storage building, the Renaissance Center and North
Wake Senior Center, an Operations Center, Joyner Park Maintenance Building Flaherty Park Community
Building, a Community House/Pool and the Alston-Massenburg Community Center.
Water Quality Programs include the E&SC Local program, an NPDES Phase II program, Water Supply
Watershed (WS II) - Wake Forest Reservoir, Falls Lake Watershed- Horse Creek, the Neuse River Riparian
Buffer Protection, Floodplain Protection, Adopt a Stream program and Potential Neuse River
Development Rules.
Sites Visited
Inspection municipal operations: Operations Center
Staff Interviewed: Brent Drendall
8.28.2017 WFAvdit Page 2 of 11

DEQ MS4 Audit I Town of Wake Forest I August 28,2017
/ --ri 1
Az
&2&2017 WFAudlt
TOWN of
WAKE rOREST'
Active Developments
u
Up
Page 3 of 11

DEQ MS4 Audit I Town of Wake Forest I August 28, 2017
0
8.282017 WPAudlt Page 4 of 11

DEQ MS4 Audit I Town of Wake Forest I August 28, Z017
Documents Reviewed
✓ Permit
✓ Current Stormwater Management Program
✓ Annual Report
✓ Inventory of public operations and/or activities
✓ Inspection procedures/checklist for public operations and/or activities
✓ Inspection records
✓ Staff training records
✓ Training Records
✓ Educational materials
✓ Unified Development Ordinance Section 12.5.8
✓ CWEP 2017 Annual Report
✓ SCM Inventory
✓ Construction and Post Construction Inspection Forms
✓ Wake Forest SW110 SWM Checklist
✓ Wake Forest SW200 As Built Certification Form
✓ Wake Forest SCM O&M Agreements
✓ Wake Forest SW210 Annual BMP Certification Form
Explanation of Findings
Findings will be identified as:
1.
Positive Findings: Initiatives staff has taken to establish and maintain a sustainable program
to maintain compliance and to strengthen its programs including 1) a commitment to
sustainability, 2) continuing to be engaged and collaborate with regulatory agencies, stake
holders, other departments and citizen's groups, 3) a strong commitment to Asset
Management Including identifying assets, tracking levels of service, and performing
Inspection and maintenance of assets, 4) identifying program requirements, records
management, written policies, standard operating procedures, checklists, calendars, 5)
regular program assessments and 6) continual process improvement to address deficiencies
and root causes.
2.
Violations: Deficiency that constitutes a violation of the Clean Water Act and is grounds for
enforcement action, permit termination, revocation and reissuance, modiflcation, or denial
of permit coverage upon renewal application.
3.
Non-compliance: A finding that could result In a Notice of Violation, a fine or other
enforcement action if corrective action is not taken.
4.
Deficiency: A finding that Is a result of poor management practices, failure to follow
Standard Operating Procedures, and minor differences of interpretation or administration
oversights. Findings Identified as a deficiency would not likely cause a Notice of Violation, a
fine, or other enforcement action.
5.
Discrepancies: Findings where compliance could not be determined at the time of the audit.
6.
Recommendations: Recommendations should be considered to improve the overall
stormwater program.
Q
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DEQ MS4 Audit I Town of Wake Forest I August 28, 2017
POSITIVE FINDINGS
Positive Findings are initiatives staff has taken to establish and maintain a sustainable program to
maintain compliance and to strengthen its programs including 1) a commitment to sustainability, 2)
continuing to be engaged and collaborate with regulatory agencies, stake holders, other departments
and citizen's groups, 3) a strong commitment to Asset Management including identifying assets, tracking
levels of service, and performing inspection and malntenance of assets, 4) identifying program
requirements, records management, written policies, standard operating procedures, checklists,
calendars, 5) regular program assessments and 6) continual process improvement to address
deficiencies and root causes.
Public Education
The Town of Wake Forest distribute education materials during Town events such as "Meet in the
Street" and "Dirt Days."
The Town of Wake Forest maintains a website that includes SeeClickFix, a reporting tool for Town
including flooding, erosion and educational material hot links.
The Town of Wake Forest also responds to citizen phone calls/emails
The Town of Wake Forest conducts outreach activities that include school visits, adopt a stream, Wake
Forest 411(local cable access, Stormwater 101), partners with the Clean Water Education Partnership
(CWEP), placed signage along streams in parks (Miller Park), and Is active on social media, Facebook,
Twitter, and Town of Wake Forest App.
The Town of Wake Forest has well defined Public Education and Outreach goals and objectives based on
community wide issues, maintains a description of the target pollutants and/or stressors and sources of
pollution, maintains a description of the target audiences likely to have significant storm water impacts,
has identified pollutants, likely sources of those pollutants, impacts, and the physical attributes of
stormwater runoff.
The Town of Wake Forest promotes and maintains a stormwater hotline/helpline for the purpose of
public education and outreach.
Public Participation
The Town of Wake Forest encourages public participation through adopt a stream programs,
Stormwater BMP Education, NC Museum of Science onsite programs, Scout storm drainage stenciling,
the recently adopted Unified Development Ordinance - eliciting input into all aspects of the ordinance
including stormwater and erosion control, Wake Forest Middle School — Future Cities club, responding
to request and questions Hotline/Help Line and engineering department phone calls, SeeClickFix, Social
Media, Town Facebook, Twitter, Town WF App, and the Smith Creek Water Quality Monitoring program
which included 20 monitoring stations, volunteer water quality testing, aquatic insect counts- spring and
fall, stream cleanups- spring and fall, Environmental Education Programs, and buffers restoration
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rDEQ MS4 Audit I Town of Wake Forest I August 28, 2017
Illicit Discharge Detection and Elimination (IDDE)
The Town of Wake Forest has an IDDE Ordinance in place (Unified Development Ordinance Section
12.5.8). The ordinance gives legal authority to enforce IDDE program. Streets maintenance crews
regularly check pipes for any signs of illicit discharge and respond to complaints. The Town of Wake
Forest uses the DEQ SSO form to document illicit discharge investigations.
Employees are expected to report unusual substances in storm drains or streets. IDDE is a partofthe
public education programs and the public reporting mechanism includes SeeClickFix, phone calls, and
emails.
The Town of Wake Forest maintains a written Illicit Discharge Detection and Elimination Program,
Including provisions for program assessment and evaluation and integrating program.
The Town of Wake Forest promotes, publicizes, and facilitates a reporting mechanism for the public
and staff to report illicit discharges and establish and implement citizen request response procedures.
Construction Site Runoff Controls
Compliance with a delegated Sediment and Erosion Control Program effectively meets the maximum extent
practicable (MEP) standard for Construction Site Runoff Controls by permitting and controlling development
activities disturbing one or more acres of land surface and those activities less than one acre that are part of
a larger common plan of development as authorized under the Sediment Pollution Control Act of 1973 and
Chapter 4 of Title 15A of the North Carolina Administrative Code.
Post Construction Runoff
The Town of Wake Forest provides adequate legal authority — Unified Development Ordinance JUDO)
Section 12.5. The Town adopted MCMs that meet or exceed State's requirements. The State SCMs
manual Is referenced in the LIDO as the standard.
The town engineers review plans for compliance to permit requirements. All sites greater than 1 acre
are deemed critical by Stormwater Administrator. In July 2017, there were 8 new plan reviews, 3 new
projects began construction. Budget for annual maintenance must be submitted as part of review (if
maintenance to be performed by Management Company). The Town maintains and inventory of
projects and an excel spreadsheet listing all SCMs within the Town. Currently there are 27 projects with
permanent SCMs In place - requiring annual inspection. Eleven projects under construction that have
permanent SCMs. As part of the ordinance, the O&M agreement must be registered with Wake County
Register of Deeds (Section 12.5.6.1-1). The Town maintains an excel spreadsheet listing all SCMs within
the Town. Annual inspections are due by December 311t - reminder letters mailed In August/September.
Inspections must be performed in accordance with the approved O&M agreement by certified inspector,
PE, or registered Landscape Architect. The Town performs audit to see what projects have not been
performing annual maintenance requirements.
Before issuing a certificate of occupancy or temporary certificate of occupancy, the Town conduct a
post -construction inspection to verify that the performance standards have been met.
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DEQ MS4 Audit I Town of Wake Forest I August 28, 2017
Pollution Prevention/Good Housekeeping
The Town of Wake Forest has identified Town of Wake Forest owned and/or operated facilities.
The Town of Wake Forest has described stormwater sewer system maintenance activities (i.e., parking
lot maintenance, street sweeping, culverts, cleaning curbs and catch basins, storm lines and ditches)
schedules, and inspection procedures for controls to reduce floatables and other pollutants to the Town
of Wake Forest's MS4.
The Town of Wake Forest maintain Spill Response Procedures and maintains records of training.
The Town of Wake Forest maintains streets/roads, including a street sweeping program. The Town tries
to get to each street annually. High use streets are swept monthly if needed. Maintenance is Is tracked
in spreadsheet.
The Town has identified Structural Stormwater Controls throughout their jurisdiction.
The Town has a Pesticide, Herbicide and Fertilizer Application Management Plan. Since 9/11 the Town
has required Parks and Recreation employees to have pesticide license. The Joyner Park Maintenance
Facility has designated area for cleaning equipment --gravel wash pad that is replaced as needed
Site Inspection
Facility Information
Facility Name: Operation Center
Facility Location: Friendship Chapel Road
Facility Contact and Phone No: Mike Barton 919-435-9570
Provide a brief description of the Municipal Operations: Fleet Maintenance, Streets Department
Describe the activities: Vehicle Maintenance and Washing
Training
The facility has developed training program, maintains copies of the materials used in the training,
identified who needs to be trained, what they need to be trained on, and when they need to be trained.
Spill Response
The facility maintains a spill response procedure video. Employees have access to MSDS, personal
protective equipment, spill response kits, and storm drain inlet/outlet protection.
Oil Water Separators
The OWS was accessible, free of signs of overflow, all drains in the oil/water separator appeared to be
free flowing with no water back-up, and all the drains appeared free from obstruction.
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c.
DEQ MS4 Audit I Town of Wake Forest j August 28, 2017
General Site Conditions
Although there were a few signs of residual or past spills and leaks, in general the site was well
maintained. Catch basins and inlets were in good condition and free of trash and debris, floatables,
pollutants, oil and grease and are free of any signs of past spills, releases, or illicit discharges. Solid
waste containers were in good condition and of sufficient size to contain all materials. In general,
materials protected from rainfall, run-on and run-off.
VIOLATIONS
Violations of the Clean Water Act and is grounds for enforcement action; for permit termination,
revocation and relssuance, or modification; or denial of permit coverage upon renewal application.
No conditions of violation were noted.
NON-COMPLIANCE
Findings that could result in a Notice of Violation, a fine or other enforcement action if corrective
action is not taken.
I. The Town of Wake Forrest is required to maintain a current a map showing major outfails and
receiving streams. According to staff, the Stormwater System inventory Map is approximately
80% complete. The Map should have been completed in October 2010. Staff has requested a
proposed budget to finalized existing system by 2020. See also attached Town's Response to
Compliance Audit
DEFICIENCIES
Finding that is a result of poor management practices, faf lure to follow Standard Operating
Procedures, and minor differences of interpretation or administration oversights. Findings identified
as a deficiency would not likely cause a Notice of Violation, a fine, or other enforcement action.
I. The Town of Wake Forrest shall implement and document a training program for appropriate
municipal staff, who as part of their normal job responsibilities, may come into contact with or
otherwise observe an illicit discharge or illicit connection. According to staff, no official training
has taken place, employees are expected to report unusual substances in storm drains or
streets, IDDE Is a part of the public education programs and the public reporting mechanism
includes SeeCiickFix, phone calls, and emails. See also attached Town's Response to
Compliance Audit
2. The Town of Wake Forrest shall maintain and implement, evaluate annually and update as
necessary an Operation and Maintenance (O&M) program for municipal owned and operated
facilities with the potential for generating polluted stormwater runoff. The O&M program shall
specify the frequency of inspections and routine maintenance requirements. The Town of Wake
Forest has not developed written pollution prevention and good housekeeping program for
each facility owned and/or operated by the Town. See also attached Town's Response to
Compliance Audit
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DEQ MS4 Audit I Town of Wake Forest I August 28, 2017
3. The permittee shall have written spill response procedures for municipal operations. The Town
of Wake Forest has not developed written spill response procedures for municipal operations.
See also attached Town's Response to Compliance Audit
4. The Town of Wake Forest has not documented an annual review of facilities owned and/or
operated by the Town of Wake Forest. See also attached Town's Response to Compliance
Audit
5. The Operations Center has not developed an inspection program to minimize/prevent exposure.
Materials or products were stored outside in open containers at the Operation Center on
Friendship Chapel Road. No secondary containment was provided for containers stored outside.
See also attached Town's Response to Compliance Audit
6. Stormwater outlets were not easily accessible. See also attached Town's Response to
Compliance Audit
7. Solid waste containers were not labeled "Prohibited - No Hazardous Waste, No Recyclable
Materials, No Liquids". See also attached Town's Response to Compliance Audit
DISCREPANCIES
Findings where compliance could not be determined at the time of the audit.
The permit identifies a number of allowable incidental non-stormwater flows that do not significantly
Impact water quality, such as water line and fire hydrant flushing, discharges from uncontaminated
potable water sources, air conditioning condensate (commercial/residential), lawn watering, residential
and charity car washing, street wash water, flows from firefighting activities.
1. Staff and the Audit Team could not determine if drains In vehicle maintenance building on
Friendship Chapel Road and the vehicle wash at the facility on Friendship Chapel Road drained
to the stormwater system or to the POTW. See also attached Town's Response to Compliance
Audit
2. The Town must Prevent/Minimize Pollution from vehicle cleaning. The audit team could not
determine if the Operations Center's designated area for vehicle cleaning and washing (and
oil/water separator) is connected to sanitary sewer. See also attached Town's Response to
Compliance Audit
RECOMMENDATIONS
Recommendations should be considered to improve the overall stormwater program.
1. The Town did not have a site plan for the Operations Center showing drainage areas,
stormwater and sanitary piping, manholes, cleanouts, drains, inlets, outfalls, oil water
separators, and stormwater control devices.
2. Staff should continue to maintain a sustainable program to strengthen its stormwater
programs including 1) an organizational commitment to sustainability, 2) continue to
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