NCS000467_Audit Report_20211230

MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM AUDIT REPORT
NPDES PERMIT NO. NCS000467
Wake Forest, NORTH CAROLINA
234 Friendship Chapel Road
Wake Forest
Audit Date: December 1, 2021
Report Date: December 30, 2021
North Carolina Department of Environmental Quality
Division of Energy, Mineral & Land Resources Stormwater Program
512 N. Salisbury Street, 9th floor
1612 Mail Service Center
Raleigh, NC 27699-1612

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NCS000467 Wake Forest M54 Audit 20211230

TABLE OF CONTENTS
Audit....................... ......... __ ....... ..................... ........ .............. ...............
Permittee......... __ ..... ....... .... — ........... ................... ..................................
List of Supporting Documents.,,,.,,...........,....,.,..,.......,......,....................,_..........,..........................,,3
Program Implementation, Occurne ntatia n & Assessment .......................... .................................... 4
PublicEducation andOutreach...—... - ... ... — .... ............. ........................... ............. .......... ..................
Illicit Discharge Detection and Elimination (IDDE) ........... ........ ......... __ ...... .............. ................. ........
Pollution Prevention and Good Housekeeping for M u n ic ipat 0 p ef-alions ................................................. 15
Site Visit Evaluation: Municipal Facility No. I ... ............. ­..­ ... ­­ ........ 19
Site Visit Evaluation: M 54 Outfa 11 No. I .............................................. ....... .............. 21
Site Visit Evaluation: Post-CnnstructfDn Stormwater Control Measure No. 1 ...........................................23
Appendix A. Supporting Documents
Appendix P. Photograph Log
DISCLAIMER
This audit consists of an evaluation of program compliance with the issued permit and implementation of
the approved Stormwater Management Plan. This audit report does not include a review of all program
components, and program deficiencies in addition to those noted may be present. The permittee is
required to assess program progress and permit compliance, and to implement the approved Stormwater
Management Plan in accordance with the issued permit.
NC5000467—Wake Forest MS4 Audit20211230 ii

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NC5000467 Wake forest MS4 Audit 20211230 iii

Audit Details
Audit ID Number:
Audit Date(s):
NC5000467_Wake Forest MS4 Audit_20211230
December 1, 2021
Minimum Control Measures Evaluated:
® Program Implementation, Documentation & Assessment
® Public Education & Outreach
❑ Public Involvement & Participation
® illicit Discharge Detection & Elimination
❑ Construction Site Runoff Controls No delegated Sediment and Erosion Control Program
❑ Construction Site Runoff Controls — Deiegated Sediment and Erosion Control Program
❑ Post -Construction Site Runoff Controls
® Pollution Prevention and Good Housekeeping for Municipal Operations
❑ Total Maximum Daily Loads (TMDLs)
Field Site Visits:
® Municipal Facilities. Number visited: 1
® MS4 Outfalls. Number visited: 1
❑ Construction Sites. Number visited: Choose an item.
® Post -Construction Stormwater Runoff Controls. Number visited: 1
❑ Other: Number visited: Choose an item.
❑ Other: Number visited: Choose an item.
Inspectors) Conducting Audit
Name. Title
Orteanization
Thad Valentine
DEMLR — Land Quality Section
Lauren Garcia
DEMLR — Land Quality Section
Audit Report Author:
Signoture 7&z
Date:
December 30, 2021
Audit Report Author:
Date:
December 30, 2021
Signoture
NCS000467_Wake Forest MS4 Audit_20211230 Page 1 of 26

Permittee Information
MS4 Permittee Name:
Town of Wake Forest
Permit Effective Date:
02/20/2017
Permit Expiration Date:
02/19/2021
Mailing Address: 234 Friendship Chapel Road
Date of Last M54 Inspection/Audit:
08/28/2017
Co-permittee(s), if applicable: N/A
Permit Owner of Record: Kip Padgett, Town Manager
Primary MS4 Representatives Participating in Audit
Name, Title
Organization
Monica Sarna
Stormwater MS4 Coordinator
Allison Snyder
Assistant Town Manager
Steve Meyer
Engineering Construction Inspector
Joe Guckavan
Engineering Director
Carrie Mitchell
Environmental Engineer and Manager
MS4 Receiving Waters
Waterbodv
Classification
Impairment
Horse Creek
WS-IV;NSW
N/A
Richland Creex
WS-IV; NSW and C; NSW
N/A
Spring Branch
C;NSW
N/A
Hatters Branch
C;NSW
N/A
Smith Creek
WS-II; HQW, NSW, CA
Benthos
Austin Creek
C;NSW
N/A
Sanford Creek
C;NSW
N/A
Toms Creek
C;NSW
Benthos
Neuse River
C;NSW, WS-IV; NSW, CA
N/A
NCS000467 wake Forest MS4 Audit_20211230 Page 2 of 26

List of Supporting Documents
Item
Number
Document Title
When Provided
(Prior to/During/After)
1
SWMP
Prior
2
TOWF NPDES MS4 Permit Review and Development Document
During
3
CWEP Agreement
Prior
4
MS4 IDDE SOP
During
5
Annual Stormwater Outreach Overview
During
6
Stormwater MS4 PP&GH SOP
Prior
7
IDDE Monitoring Plan
Prior
8
Public Works Stormwater Maintenance SOP
During
9
Public Facilities Facility Inspection SOP
During
10
Streets and Public Parking Lots Maintenance SOP
During
11
Public Works' Street Sweeping SOP
During
12
IDDE Investigation Example
During
13
Public Outreach and Education SOP
During
14
Outfall Inspection Example
During
15
2017 Stormwater Report
Prior
16
Brochures
During
17
Website View Count Document
During
18
Stormwater Staff Training Powerpoint
During
19
Landscaping Waste Staff Training Powerpoint
During
20
Spiil Kit Training with Sign In Sheet
During
21
List of Public Facilities
During
22
Town of Wake Public Works Facility SWPPP
During
23
O&M Agreement Example
During
24
Pesticide Licenses
During
25
SCM Inspection Example
During
26
Onsite Public Works Facility SWPPP
During
NCS000467_Wake Forest MS4 Audit_20211230 Page 3 of 26

Program Implementation, Documentation & Assessment
Staff Interviewed:
Monica Sarna, Stormwater MS4 Coordinator
(Name, Title, Role)
Allison Snyder, Assistant Town Manager
Steve Meyer, Engineering Construction Inspector
Joe Guckavan, Engineering Director
Carrie Mitchell, Environmental Engineer and Manager
Permit Citation
Program Requirement
Status
Supporting
Doc No.
II.A.2
The permittee maintained adequate funding and staffing to implement and manage
Staffing and
the provisions of the Stormwater Plan and meet all requirements of the permit.
Yes
i
Funding
The Stormwater Plan identifies a specific position(s) responsible for the overall
Yes
1
coordination, implementation, and revision to the Plan.
Responsibilities for all components of the Stormwater Plan are documented and
position(s) assignments provided.
Partial
1
The permittee is current on payment of invoiced administering and compliance
Yes
BIMS
monitoring fees (see stormwater e-payments on DEMCR MS4 web page).
Comments (Briefly describe funding mechanism, number of staff, etc.)
The 2020 2021 budget for the Town's Stormwater Program is $387,500. The Stormwater Program supports 12 positions, and two
additional positions are being added. Public Works employees also p-nvide support to the Program, with separate funding.
Organizational charts are included as pages 11 and 12 of the SWMP. Responsible Positions are provided; however, it is recommended
that responsibilities for all components of the stormwater plan and position assignments be added to the Organizational Charts.
II.A.2 Stormwater
The permittee evaluated the performance and effectiveness of the program
Plan
components at least annually.
Yes
2
Implementation
and Evaluation
If yes, the permittee used the results of the evaluation to modify the program
components as necessary to accomplish the intent of the Stormwater Program.
Yes
2
Did the permitted MS4 discharges cause or contribute to non -attainment of an
applicable water quality standard?
Na
---
If yes, did the permittee expand or better tailor its 8MPs accordingly to address
Not
the non -attainment?
Applicable
Comments
The Town performed a GAP Analysis in 2019 to identify areas of the Program that needed improvement. The Town has been
making necessary improvements since then. Documentation was the biggest change, as well as administrative updates. Training
programs were updated. Spill kits were distributed. Spill response training was developed.
The Town continuously updates the Unified Development Ordinance to meet State requirements.
NCS000467_Wake Forest MS4 Audit_20211230 Page 4 of 26

Program Implementation, Documentation & Assessment
II.A.3
Keeping the
The permittee kept the Stormwater Plan up to date.
Yes
1
Stormwater Plan
Up to Date
The permittee notified DEMLR of any updates to the Stormwater Plan.
Yes
1
Comments (Indicate the date of latest Stormwater Plan and describe the nature of any updates, if applicable).
The SWMP has been updated to fit the new SWMP template and was submitted to the Central Office. Any updates to the SWMP
are documented in the annual reports.
II.A.4 Availability
The permittee kept an up-to-date version of its Stormwater Plan available to the
Of the Stormwater
Division and the public online.
Yes
Online
Plan
The online materials included ordinances, or other regulatory mechanisms, or a list
identifying the ordinances, or other regulatory mechanisms, providing the legal
Yes
Online
authority necessary to implement and enforce the requirements of the permit.
Comments (Note what materials are available on line)
The SWMP is available online on the Town of Wake Forest Stormwater Management Website:
https://www.wakeforestnc.gov/public-works/engineering/stormwater-management/np des - phase -ii
Ordinances are also available.
II.A.3 & II.A.5
Stormwater Plan
Did DEMLR require a modification to the Stormwater Plan?
No
...
Modifications
If yes, did the permittee complete the modifications in accordance with the
Not
established deadline?
Applicable
Comments (Note date of DEMLR notification, modifications required, and date modifications were completed, as applicable)
DEMLR did not require modifications.
II.A.6 Sharing
Responsibility
Are any control measures implemented by an entity other than the permittee?
Yes
3
If yes, is there a written agreement in place?
Yes
3
Comments (List the specific control measures implemented by others that do not have adequate written agreements, if
applicable)
The Town has an agreement with CWEP to handle Public Education and Public Involvement. The Town also provides many
additional educational materials and outreach.
ILA.7
The permittee maintained written procedures for implementing the six minimum
4, 5, 6, 7,
Written
Yes
8, 9, 10,
Procedures
control measures.
11
Written procedures identified specific action steps, schedules, resources and
4, S, 6, 7,
responsibilities for implementing the six minimum measures.
Yes
13, 9, 10,
11,13
NCS000467_Wake Forest MS4 Audit_20211230 Page 5 of 26

Program Implementation, Documentation & Assessment
Comments (List the specific minimum measures that do not have adequate written procedures, if applicable)
The Town provided an IDDE SOP, an Annual Stormwater Outreach Overview, a Public Outreach and Education SOP, a Stormwater
MS4 PP&GH SOP, an IDDE Monitoring Plan, a Public Works Stormwater Maintenance SOP, a Public Facilities Facility Inspection SOP,
a Streets and Public Parking Lots Maintenance SOP, and a Public Works' Street Sweeping SOP with maps.
The Town has developed larger blanket SOP documents for each minimum control measures. Smaller SOPS were also created to
address specific tasks. This is partially due to who is responsible for certain SOPS.
We recommend that the steps taken when responding to an IDDE report be added to the IDDE Monitoring Plan.
Ill. A
The permittee maintained documentation of all program components including, but
Program
not limited to, inspections, maintenance activities, educational programs,
Yes
12,14
Documentation
implementation of BMPs, enforcement actions etc., on file for a period of five years.
Comments (List the specific program components that do not have adequate documentation on file and why, if applicable)
Examples of IDDE, SCM and Outfall Investigations were shown during the audit.
111.E
The permittee submitted annual reports to the Department within twelve months
Annual Report
from the effective date of the permit (See Section 111.B. for the annual reporting
Yes
15
Submittal
period specific to this MS4).
The permittee submitted subsequent annual reports every twelve months from the
scheduled date of the first annual report submittal.
Yes
15
The Annual Reports included appropriate information to accurately describe the progress, status, and results
of the permittee's Stormwater Plan, including, but not limited the following:
1. A detailed description of the status of implementation of the Stormwater Plan
as a whole. This will include information on development and implementation
of each major component of the Stormwater Plan for the past year and
Yes
---
schedules and plans for the year following each report.
2. An adequate description and justification of any proposed changes to the
Stormwater Plan. This will include descriptions and supporting information for
the proposed changes and how these changes will impact the Stormwater
Yes
---
Plan (results, effectiveness, implementation schedule, etc.).
3. Documentation of any necessary changes to programs or practices for
assessment of management measures implemented through the Stormwater
Yes
--
Plan.
4. A summary of data accumulated as part of the Stormwater Plan throughout
the year along with an assessment of what the data indicates in light of the
Yes
Stormwater Plan.
5. An assessment of compliance with the permit, information on the
establishment of appropriate legal authorities, inspections, and enforcement
Yes
---
actions.
Comments (Note dates that annual reports cover undercurrent permit and generally describe report deficiencies, if any)
All annual reports have been submitted through RIMS, except for in 2017. The Town was last audited in 2017 and were not required
to submit an annual report. They submitted a written report.
IV.B
Annual Reporting
The Annual Reports document the following:
NC5000467_Wake Forest MS4 Audit_20211230
Page 6 of 26

Program Implementation, Documentation & Assessment
1. A summary of past year activities, including where applicable, specific
quantities achieved and summaries of enforcement actions.
Yes
2. A description of the effectiveness of each program component.
Yes
3. Planned activities and changes for the next reporting period, for each
program component or activity.
Yes
4. Fiscal analysis.
Yes
Comments (Note dates that annual reports cover undercurrent permit and generally describe report deficiencies, if any)
All annual reports have been submitted through BIMS, except for in 2017. The Town was last audited in 2017 and were not required
to submit an annual report. They submitted a written report.
Additional
Comments:
Strong documentation for minimum control measures and program components.
NCS000467_Wake Forest MS4 Audit_20211230 Page 7 of 26

Public Education and Outreach
Staff Interviewed:
Monica Sarna, Stormwater MS4 Coordinator
(Name, Title, Role)
Allison Snyder, Assistant Town Manager
Steve Meyer, Engineering Construction Inspector
Joe Guckavan, Engineering Director
Carrie Mitchell, Environmental Engineer and Manager
Permit Citation
Program Requirement Status Supporting
Doc No.
II.B.2.a
The permittee defined goals and objectives of the Local Public Education and
Yes 5,13
Goals and
Outreach Program based on community wide issues.
Objectives
Comments (Generally describe process for establishing goals/objectives)
The Town partners with CWEP to implement Public Education and Outreach. The Town also provided a Stormwater MS4 — Public
Outreach and Education SOP and an Annual Stormwater Outreach Overview.
11.6.21
The permittee maintained a description of the target pollutants and/or stressors and
Target Pollutants
likely sources.
Yes
3, S, 13
Comments (List target pollutants, note any that are missing or not appropriate)
CWEP centers campaigns on ""h a Big 6 Stormwater Pollutants": Household waste, auto waste, pesticides/herbicides, yard water.
pet waste and litter.
The biggest Stormwater pollutun: in Wake Forest is sed ment. There is a large amount of development currently in progress.
11.B.2.c
The permittee identified, assessed annually and updated the description of the target
1
Target Audiences
audiences likely to have significant storm water impacts and why they were selected.
Yes
Comments (Describe any changes made, if applicable)
The Town Partners with CWEP to implement th's.
Target audiences are identified in the SWMP and in the Education and Outreach SOP.
CWEP targets a different pollutant annually. Last year's focus was yard waste. The focus for 2021 is litter. Next years' focus will nrs
oil and grease.
Wake Forest targets homeowners and contractors for Stormwater pollution outreach. The Town has deve oped a preconstrur-11,
training that is given to contractors prior to projects starting.
The Town identifies new residents by tracking who orders trash cans and provides new residents with a welcome package that
includes information on stormwater pollution.
NCS000467_Wake Forest MS4 Audit_20211230
Page 8 of 26

Public Education and Outreach
11.B.2.d Residential
The permittee described issues, such as pollutants, the likely sources of those
and Industrial/
pollutants, potential impacts, and the physical attributes of stormwater runoff in
Yes
5, 13
Commercial issues
their education/outreach program.
Comments (Generally describe the residential/industrial/commercial issues addressed)
The Town partners with CWEP to implement this.
The Town maintains a Stormwater 101 Webpage: https://www.wakeforestnc.gov/public-works/engineering/community-
outreach/stormwa ter-edu cation-101
The Town maintains a Social Media SOP that outlines different topics for stormwater outreach.
The Town maintains informational webpages for each of the CWEP Big 6 Pollutants.
11.8.2.e
Informational
The permittee promoted and maintained an internet web site designed to convey the
Yes
5,13
program's message.
Web Site
Comments (list web page address and general contents, or attach screen shot of landing page)
The Town partners with CWEP to implement this.
The Town maintains a Stormwater 101 Webpage: https://www.wakeforestnc.gov/public-works/engineering/community.
outreach/stormwater-education-101
The Town maintains informational webpages for each of the CWEP Big 6 Pollutants.
II.B.2.f
The permittee distributed stormwater educational material to appropriate target
Public Education
Yes
16
Materials
groups.
Comments (List distributed materials and quantity, message, distribution mechanism, target audience for each if not included in
program documentation/annual reporting)
The Town partners with CWEP to implement this.
The Town relies on CEWP for educational graphics. The Town distributes pamphlets and brochures to target audiences.
II.8.2.g
The permittee promoted and maintained a stormwater hotline/helpline for the
Hotline/Help Line
purpose of public education and outreach.
Yes
Online
Comments (Note hotline contact information and method(s) for advertising it)
The Town has created a reporting mechanism called 'SeeClickFix" where residents input their complaint into the system and is able
to track their complaint and receive communications from Town Employees handling the problem.
A hotline number is also provided on the stormwater webpage.
NCS000467_Wake Forest MS4 Audit_20211230 Page 9 of 26

Public Education and Outreach
II.B.2.h
The permittee's outreach program, including those elements implemented locally or
Public Education
through a cooperative agreement, included a combination of approaches designed to
and Outreach
reach the target audiences.
Program
For each media, event or activity, including those elements implemented locally or
through a cooperative agreement the permittee estimated and recorded the extent
*�4
of exposure.
Comments (Generally describe approaches, extent of exposure. Note any cooperating entities, agreements and scope of services,
or reference comments in Section ii.A.6. above.)
The Town partners with CWEP to implement this.
The Town targets new residents and sends welcome packages, holds events and distributes information, and maintains multiple
webpages that address different pollutants.
The Town estimates the number of people who will attend the events by the amount of clicks on to the website.
Additional
Comments:
SeeCLickFix is an exemplary program.
NCS000467_Wake Forest MS4 Audit_20211230 Page 10 of 26

Illicit Discharge Detection and Elimination (IDDE)
Staff Interviewed:
Monica Sarna, Stormwater MS4 Coordinator
(Name, Title,
Allison Snyder, Assistant Town Manager
Role)
Steve Meyer, Engineering Construction Inspector
Joe Guckavan, Engineering Director
Carrie Mitchell, Environmental Engineer and Manager
Permit Citation
Program Requirement
Status supporting
Doc No.
II.D.2.a
IDDE Program
The permittee maintained a written IDDE Program.
Yes 4,7
If yes, the written program includes provisions for program assessment and
evaluation and integrating program.
Yes 4,7
Comments (!Vote any deficiencies)
The Town maintains a Minimum Control Measure IDDE SOP (4) and a written IDDE Plan (7). Provisions for program assessment are
addressed on the last page of the written IDDE Plan (71-
The permittee maintained an IDDE ordinance or other regulatory mechanism(s) that
II.D.2.b
provides the legal authority to prohibit illicit connections and discharges to the MS4.
Yes
Online
Legal Authorities
If yes, the ordinance applies throughout the corporate limits of the permittee.
(Permit Port l.D)
Yes
Comments
Illicit discharges are covered in Chapter 12.5 of the Unified Development Ordinance.
II.D.2.c
The permittee maintained a current map showing major outfalls* and receiving
Storm Sewer
Yes
---
System Map
streams.
Comments
The Town has 156 major outfalls and maintains a GIS map through a program called "New World." New World also functions as an
internal database that contains the outfall information. Inspection reports can be completed in real time in the field. Employees can
access the inspection reports through a phone app. The inspection reports are saved in the New World system.
*Major outfalls are discharges from > 36" diameter pipes or drainage areas of > SD acres. In areas zoned for industrial activity, major outfalls
are > 12" or drainage area > 2 acres.
Ii.D.2.d
The permittee maintained a program for conducting dry weather flow field
Dry Weather Flow
observations in accordance with written procedures.
Yes
4, 7
Program
Comments (Generally summarize program, including frequency of observations and # or % of outfalls screened)
Dry Weather Flow Inspections are addressed on Page 2 of the MCM IDDE SOP (4) and on Pages 1 and 2 of the written IDDE Plan (7).
NCS000467_Wake Forest MS4 Audit_20211230 Page 11 of 26

Illicit Discharge Detection and Elimination (IDDE)
II.D.2.e
The permittee maintained written procedures for conducting investigations of
Investigation
identified illicit discharges.
Yes
4,7
Procedures
Comments (Generally describe what procedures are documented)
The written IDDE Plan (7) was provided prior to the audit. The MCM IDDE SOP was provided during the audit (4).
The Town has developed larger blanket SOP documents for each minimum control measures. Smaller SOPS were also created to
address specific tasks. This is partially due to who is responsible for certain SOPS.
We recommend that written procedures for the steps taken when responding to an IDDE report be added to the IDDE
Monitoring Plan. The IDDE Monitoring Plan outlines what IDDE is and describes different components of the Plan, but does not
provide procedures for conducting and responding to investigations.
II.D.Z.f
For each case of an illicit discharge or potential illicit discharge, the permittee documented and tracked the
Track and
following:
Document
Investigations
1. The date(s) the illicit discharge was observed
Yes
2. The results of the investigation
Yes
---
3. Any follow-up of the investigation
Yes
---
4. The date the investigation was closed
Partial
---
Comments (Note whether a standard inspection form is utilized to capture consistent information and a tracking mechanism is
used)
SeeClickFix is used to track IDDE reports and record inspections. SeeCLickFix automatically provides the location of the
complaints/reports on a GIS map. The Town also maintains a folder for each investigation on an internal server. The folder includes
all information collected during the investigations, any communications, and any investigation results. A word document is created
for each investigation that includes a summary of events, with dates. SeeClickFix can be used to run reports to pull information
about different illicit discharges.
We discussed during the audit that a word template or excel spreadsheet can be developed so dates (illicit discharge observed,
date closed, etc) can be easily understood.
II.D.Z.g Employee
The permittee implemented and documented a training program for appropriate
Training
municipal staff who, as part of their normal job responsibilities, may come into
Yes
18, 19,
contact with or otherwise observe an illicit discharge or illicit connection.
20
Comments (Generally describe the staff training program, including frequency and which staff are trained)
The Town gives a Stormwater Awareness training once per permit cycle and to all new employees. Illicit Discharge Detection and
Elimination is addressed in Part II of the Training. The training also covers spill response procedures and general stormwater
awareness training.
II.D.2.h
The permittee informed public employees of hazards associated with illegal
Partial
18
Public Education
discharges and improper disposal of waste.
The permittee informed businesses of hazards associated with illegal discharges and
16
improper disposal of waste.
Yes
NCS000467_Wake Forest MS4 Audit_20211230 Page 12 of 26

Illicit Discharge Detection and Elimination (IDDE)
The permittee informed the general public of hazards associated with illegal
16 and
discharges and improper disposal of waste.
Yes
online
Comments (Note how each sector was informed, if applicable)
The Town distributes Brochures to businesses. The Town participates in events and distributes educational materials.
The Town identifies new residents by tracking who orders trash cans and provides new residents with a welcome package that
includes information on stormwater pollution.
The Town maintains several webpages that address the CWEP Big 6 Pollutants as well as a Stormwater 101 page for residents.
The Stormwater Training for staff does not address specific hazards associated with illegal discharges and improper disposal of
waste.
II.D.2.i
The permittee promoted, publicized, and facilitated a reporting mechanism for the
Public Reporting
public to report illicit discharges.
Yes
Online
Mechanism
The permittee promoted, publicized, and facilitated a reporting mechanism for staff
Yes
Online
to report illicit discharges.
The permittee established and implemented response procedures for citizen
Partial
Online
requests/reports.
Comments (Generally describe reporting mechanisms and how promoted/publicized/facilitated/established)
The Town developed SeeCLickFix for citizens to report illicit discharges and other complaints. SeeCLickFix automatically shows
complaint locations in a GIS map. Complainants can see responses from the Town through the program.
The Town also has a number on the website that can be called to report illicit discharges. The Town maintains internal reports for
these calls and the complaint will be entered into SeeClickFix by an employee.
We recommend that the steps taken when responding to an IDDE report be added to the IDDE Monitoring Plan.
II.D.2.1
The permittee implemented a mechanism to track the issuance of notices of violation
Enforcement
and enforcement actions administered by the permittee.
Yes
12
If yes, the mechanism includes the ability to identify chronic violators for
initiation of actions to reduce noncompliance.
Yes
12
Comments (Generally describe the established tracking mechanism, if applicable)
The Town uses SeeCLickFix to track repeat violators. Once an IDDE investigation occurs, if action needs to be taken, the Town will
issue and NOV for the spill to be cleaned up.
NCS000467_Wake Forest MS4 Audit_20211230 Page 13 of 26

Illicit Discharge Detection and Elimination (IDDE)
Additional
Comments: Strong IDDE Program
NCS000467_Wake Forest MS4 Audit_20211230 Page 14 of 26

Pollution Prevention and Good Housekeeping for Municipal Operations
Staff Interviewed:
Monica Sarna, Stormwater MS4 Coordinator
(Name, Title, Role)
Allison Snyder, Assistant Town Manager
Steve Meyer, Engineering Construction Inspector
Joe Guckavan, Engineering Director
Carrie Mitchell, Environmental Engineer and Manager
Permit Citation
Program Requirement Status Supporting
Doc No.
II.G.2.a
The permittee maintained a current inventory of facilities and operations owned
Facility Inventory
and operated by the permittee with the potential for generating polluted Yes 21
stormwater runoff.
Comments (Note number of facilities, typical inventory data and any facilities that are not inventoried that should be)
The Town maintains a list of facilities maintained by Public Works. The Town has developed a facility specific SWPPP for the
facilities that are considered high risk for generating polluted stormwater runoff.
II.6.2.b
The permittee maintained and implemented an 0&M program for municipally
Operation and
owned and operated facilities with the potential for generating polluted
Yes
6,9
Maintenance (O&M)
stormwater runoff.
for Facilities
If yes, the O&M program specifies the frequency of inspections.
Yes
6
If yes, the O&M program specifies the frequency of routine maintenance
requirements.
Partial
9
If yes, the permittee evaluated the O&M program annually and updated it as
Yes
---
necessary.
Comments
The MCM Stormwater M54 PP&GH SOP (6) and Public Facilities Facility Inspection SOP (9) states all municipally owned facilities are
inspected on a monthly basis by the Facilities Team. Facilities employees use an App to fill out the inspection report. The reports are
maintained in New World. MS4 inspection occur annually; however, a report or checklist is not used to record the inspection.
The MCM Stormwater MS4 PP&GH SOP (6) and Public Facilities Facility Inspection SOP (6) do not specifically address maintenance
frequency; however, the Facilities Facility Inspection SOP addresses maintenance records. Maintenance records are recorded in an
internal system, Mobile 311, that can be accessed remotely. Mobile 311 is used to record work orders. This system automatically
keeps track of maintenance frequency and will notify users when maintenance is due.
A checklist or inspection report template should be developed for MS4 facility inspections. The frequency of M54 inspections
may need to be included in the MCM MS4 PP&GH SOP.
I I.G.2.c
Spill Response
The permittee had written spill response procedures for municipal operations.
Yes
20,22
Procedures
NCS000467_Wake Forest MS4 Audit_20211230 Page 15 of 26

Pollution Prevention and Good Housekeeping for Municipal Operations
Comments
Spill Response Procedures were provided during the audit. A site -specific Spill Prevention and Response Plan is included in every
high -risk Facility SWPPP.
II.6.2.d Streets,
The permittee evaluated existing and new BMPs that reduce polluted stormwater
Roads, and Public
runoff from municipally -owned streets, roads, and public parking lots within its
Yes
10
Parking Lots
corporate limits annually.
If yes, the permittee evaluated the effectiveness of existing and new BMPs
Maintenance
based on cost and the estimated quantity of pollutants removed.
Partial
10
Comments
Street sweeping is tracked through the Mobile 311 program. Streep sweeping occurs on a monthly basis and is tracked using
mileage.
II.G.2.f
The permittee maintained and implemented an O&M program for the stormwater
O&M for Catch
sewer system including catch basins and conveyance systems that it owns and
Yes
8
Basins and
Conveyance Systems
maintains.
Comments (Briefly describe O&M program)
The Public Works Stormwater Maintenance Procedure was provided prior to the audit. Public Facilities employs a Stormwater
Maintenance Crew responsible for maintenance of the stormwater sewer system. The Crew responds to maintenance complaints
through SeeClickFix, performs daily or weekly inspections, and tracks maintenance through Mobile 311.
II.6.2.rt
The permittee maintained a current inventory of municipally -owned or operated
Structural
structural stormwater controls installed for compliance with the permittee's post-
Yes
Stormwater Controls
construction ordinance.
Comments (Describe inventory information and number of controls in inventory)
An inventory of municipal SCMs are maintained in a GIS map. There are 281 SCMs in Wake Forest, including public and privately
owned. There are 11 Town owned SCMs.
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Pollution Prevention and Good Housekeeping for Municipal Operations
II.G.2.h
The permittee maintained and implemented an 0&M program for municipally -
O&M for Structural
owned or maintained structural stormwater controls installed for compliance with
Yes
8,23
Stormwater Controls
the permittee's post -construction ordinance. If yes, then:
The 0&M program specified the frequency of inspections and routine
maintenance requirements.
Yes
8, 23
The permittee documented inspections of all municipally -owned or maintained
structural stormwater controls.
Yes
8, 23, 25
The permittee inspected all municipally -owned or maintained structural
stormwater controls in accordance with the schedule developed by permittee.
Yes
8,23
The permittee maintained all municipally -owned or maintained structural
stormwater controls in accordance with the schedule developed by permittee.
Yes
8,23
The permittee documented maintenance of all municipally -owned or
maintained structural stormwater controls.
Yes
8,23
Comments
The Public Works Stormwater Maintenance SOP states Town owned SCMs are inspected on an annual basis by a certified employee
and recorded in the New World Application. Maintenance items resulting from the annual inspections are reviewed by the
stormwater engineer. If maintenance will be completed by Town Staff, a work order is developed in Mobile 311. Mobile 311 allows
the stormwater crew to schedule, track and budget for stormwater maintenance.
II.G.2.1
The permittee ensured municipal employees are properly trained in pesticide,
Pesticide, Herbicide
herbicide and fertilizer application management.
Yes
24
and Fertilizer
Application
The permittee ensured contractors are properly trained in pesticide, herbicide and
Management
fertilizer application management.
Yes
19,24
The permittee ensured all permits, certifications, and other measures for
applicators are followed.
Yes
19,24
Comments
Parks and Recreation employees are required to maintain licenses as a part of their job descriptions.
Pesticide licenses were provided during the audit. The Town has developed a Wake Forest Yard Waste Policies Landscaping
Contractors Powerpoint Training. Stormwater inspectors check to make sure contractors have applied product correctly.
11.6.2.i
The permittee implemented an employee training program for employees involved
Staff Training
in implementing pollution prevention and good housekeeping practices.
Yes
22
Comments
There is not a dedicated training program for Pollution Prevention and Good Housekeeping. The Town requires that public
employees who work at one of the facilities that is considered high risk for generating stormwater runoff sign a document stating
that they have read the facility specific SWPPP. This is considered the employee training for PP&GH.
II.G.2.k
The permittee described and implemented measures that prevent or minimize
Vehicle and
contamination of stormwater runoff from all areas used for vehicle and equipment
Yes
22
Equipment Cleaning
cleaning.
NCS000467_Wake Forest MS4 Audit_20211230 Page 17 of 26

Pollution Prevention and Good Housekeeping for Municipal Operations
Comments
A wash bay is present at the Town's Public Works Facility. The wash bay is addressed in the facility specific SWPPP and is inspected
regularly.
Additional
Comments:
NC5000467_Wake Forest M54 Audit_20211230 Page 18 of 26

Site Visit Evaluation: Municipal Facility No. 1
Facility Name:
Public Works Facility
Date and Time of Site Visit:
12/01/2021 2:30 pm
Facility Address:
234 Friendship Chapel Rd
Facility Type (Vehicle Maintenance, landscaping, etc.):
Vehicle Maintenance
Name of MS4 inspector(s) evaluated:
Monica Sarna
Most Recent MS4 Inspection (List date and name of inspector):
2020
Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name
Title
Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific?
Yes. The Town maintains a site specific SWPPP for the Public Works Facility. The Public Works Facility also maintains a SWPPP. They
are separate documents but contain similar information.
What type of stormwater training do facility employees receive? How often?
Town stormwater training once per permit cycle and when newly hired.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
NC State Training; on the job; Town Training
Did the M54 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
Yes
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Yes
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form?
No. We recomend a checklist would be developed for future inspections.
Does the MS4 inspector's process include taking photos?
As needed
Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)?
Yes
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Site Visit Evaluation: Municipal Facility No. 1
Does the M54 inspector's process include walking the entire facility and inspecting all points of discharge?
Partially. We recommend that the entirety of the facility should be viewed during each MS4 inspection, including the outside
yards and storage areas.
Did the MS4 inspector miss any obvious areas of concern? If so, explain:
It was discussed during the audit how facility inspections could be improved in a few areas:
• Include a more in depth viewing of the area where chemicals and used oil is stored. One cap was observed to not be on a
chemical container when viewed.
• Leaking oil and staining was observed in a few areas throughout the outside areas.
• The entire site should be inspected during each MS4 inspection.
• A checklist should be developed for M54 facility inspections.
Does the MS4 inspector's process include presenting the inspection findings to the facility contact?
Yes
Inspection Results
Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)?
No
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
Nu
Notes/Comments/Recommendations
After speaking with facility contacts and reviewing used oil/fluid logs, it was determined the facility should apply for an
NCG080000 General Industrial Permit.
NC5000467_Wake Forest MS4 Audit_20211230
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Site Visit Evaluation: MS4 Outfall No, i
Outfall ID Number:
Date and Time of Site Visit:
A10545
12/01/2021 1:30 pm
Outfall Location:
Outfall Description (Pipe Material/Diameter, Culvert, etc.):
fill Brooks Rd
60" RCP
Receiving Water:
Is Flow Present? If So, Describe (Color, Approximate Flow Rate,
5pr'ng Branch Creek
Sheen, Odor, Floatables/Debris, etc.):
No flow present
Most Recent OutfalI Inspection/Screening (Date):
11/30/2021
Days Since Last Rainfall:
Inches:
7
1/2„
Name of MS4 Inspector(s) evaluated:
Steve Meyer and Monica 5arna
Observations
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
Town training, NC State
Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations?
Yes
Inspection Procedures
Does the inspector's process include the use of a checklist or other standardized form?
Yes — online form in New World
Does the inspector's process include taking photos?
Yes, as needed
Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they?
No
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Site Visit Evaluation: MS4 Outfall No. 1
Inspection Results
Did the outfali inspection result in any work orders or maintenance requests? If so, for what issue(s)?
Vegetation maintenance, kudzu slightly overgrown and a tree is growing close to the outlet pipe
Will a follow-up outfall inspection be conducted? If so, for what reason?
Annual inspection
Notes/Comments/Recommendations
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Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1
Site Name:
North Wake Senior Center
Date and Time of Site Visit:
12/01/2021 1:00 pm
Site Address:
235 E Holder Ave
SCM Type:
Retention Pond
Most Recent MS4 Inspection (Include Date and Entity):
November 2021
Name of MS4 Inspector(s) evaluated:
Monica Sarna
Most Recent MS4 Enforcement Activity (Include Date):
Maintenance
Name(s) and Title(s) of Site Representative(s) Present During the Site Visit:
Name
Title
Michelle Bullard
Public Works Inspector
Observations
Site Documentation
Does the site have an operation and maintenance plan?
Yes
Does the site have records of annual inspections? Are they performed by a qualified individual?
Yes, annual and monthly inspections are recorded in New World. Annual MS4 inspections are performed by an SCM Certified
inspector. Monthly inspections are performed by public works employees.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
NC State SCM Training
Did the MS4 inspector appear knowledgeable about M54 requirements for post -construction site runoff controls?
Yes
Did the MS4 inspector appear knowledgeable about post -construction BMPs (general purpose/function, components, O&M
requirements, etc.)? Yes
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form? What format?
Yes, online form in New World
Does the MS4 inspector's process include taking photos?
Yes, as needed
Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections?
Yes
NCS000467_Wake Forest MS4 Audit_20211230 Page 23 of 26

Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1
Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge?
Yes
Did the MS4 inspector miss any obvious operation and maintenance deficiencies? If so, explain:
Un
Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing?
Ye,, where applicable. The Town inspects Town owned SCMs.
Compliance/Enforcement
What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in?
The site has had some ongoing maintenance issues. It looks like there is some seeping happening at the inlet and a small sink hole
has formed near a concrete joint. There have also been some issues with ground cover along the slopes of the SCM. The Town is
aware of the issues and has been working to have them fixed.
If compliance issues were identified, what timeline for correction/follow-up was provided?
ASAP
Notes/Comments/Recommendations
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APPENDIX A: SUPPORTING DOCUMENTS
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APPENDIX B: PHOTOGRAPH LOG
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