NCS000245_Raleigh MS4 Self-Audit Report_20220427

MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PHASE I PROGRAM SELF-AUDIT REPORT

NPDES PERMIT NO. NCS000245
CITY OF RALEIGH, NORTH CAROLINA

222 West Hargett Street
Raleigh, NC 27601

Self-Audit Date: March 25, 2022 – April 27, 2022

Report Date: April 27, 2022

NCS000245_Raleigh 2022 MS4 Self-Audit ii
* A Duly Authorized Representative can be the Mayor, City Manager, or an authorized person or position.
To be authorized, a Delegation of Signature Authority Form signed by the Mayor or City Manager must
be on file with the Department.

Self-Audit Certification
By my signature below, I certify, under penalty of law, that I am a Duly Authorized Representative* and this
document and all attachments were prepared under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gather and evaluate the information submitted. Based
on my inquiry of the person or persons who manage the system, or those persons directly responsible for
gathering the information, the information submitted is, to the best of my knowledge and belief, true,
accurate, and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations.

Name: S. Wayne Miles, PE

Title: Stormwater Program Manager

Signature:

Date: April 27, 2022

NCS000245_Raleigh 2022 MS4 Self-Audit iii
TABLE OF CONTENTS
Self-Audit Details ........................................................................................................................................... 1
Permittee Information .................................................................................................................................. 3
List of Supporting Documents ....................................................................................................................... 5
Program Implementation, Documentation & Assessment ........................................................................... 7
Public Education and Outreach ................................................................................................................... 10
Public Involvement and Participation ......................................................................................................... 12
Illicit Discharge Detection and Elimination (IDDE) ...................................................................................... 14
Construction Site Runoff Controls .............................................................................................................. 16
Post-Construction Site Runoff Controls ...................................................................................................... 18
Pollution Prevention and Good Housekeeping for Municipal Operations ................................................. 23
Program to Monitor and Evaluate Stormwater Discharges to Municipal Systems .................................... 27
Water Quality Assessment and Monitoring ................................................................................................ 29
Site Visit Evaluation: Municipal Facility No. 1 ............................................................................................. 30
Site Visit Evaluation: Municipal Facility No. 2 ............................................................................................. 32
Site Visit Evaluation: MS4 Outfall No. 1 ...................................................................................................... 34
Site Visit Evaluation: MS4 Outfall No. 2 ...................................................................................................... 36
Site Visit Evaluation: Construction Site No. 1 ............................................................................................. 38
Site Visit Evaluation: Construction Site No. 2 ............................................................................................. 40
Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1 ............................................ 42
Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 2 ............................................ 44
Appendix A: Supporting Documents
Appendix B: Site Visit Evaluation

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.

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Self-Audit Details
Audit ID Number:
NCS000245_Raleigh 2022 MS4 Self-Audit
Self-Audit Date(s): March 25, 2022 – April 27, 2022

Minimum Control Measures Evaluated:
☒ 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
☒ Program to Monitor and Control Pollutants
☒ Water Quality Assessment & Monitoring

Field Site Visits:
☒ Municipal Facilities. Number visited: 2
☒ MS4 Outfalls. Number visited: 2
☒ Construction Sites. Number visited: 2
☒ Post-Construction Stormwater Runoff Controls. Number visited: 2
☐ Other: ________________________________. Number visited: Choose an item.
☐ Other: ________________________________. Number visited: Choose an item.

Auditors
Name Title
Ben Brown Stormwater Administrator
Justin Harcum Sr. Project Engineer
Stephen Jeltema Project Engineer

Audit Report Author
Justin Harcum
___________________________________ __ ___
Name
Sr. Project Engineer
____________________________________ _____
Title

4/27/2022
___________________________________ _____
Date _____________ _____
Signature
Audit Report Author
Stephen Jeltema
___________________________________ __ ___
Name
Project Engineer
_____________________________________ _____
Title

4/27/2022
___________________________________ _____
Date

___________________________________ _____
Signature

NCS000245_Raleigh 2022 MS4 Self-Audit Page 2 of 47

Audit Report Author
Ben Brown
___________________________________ __ ___
Name
Stormwater Administrator
_____________________________________ _____
Title

4/27/2022
___________________________________ _____
Date

___________________________________ _____
Signature
Audit Report Author

___________________________________ __ ___
Name

_____________________________________ _____
Title

___________________________________ _____
Date

___________________________________ _____
Signature

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Permittee Information
MS4 Permittee Name:
City of Raleigh
Permit Effective Date:
October 10, 2018
Permit Expiration Date:
October 9, 2023

Mailing Address:
222 West Hargett Street, Raleigh, NC 27601
Date of Last MS4 Inspection/Audit:
April 2012
Permit Owner of Record: City of Raleigh

Primary MS4 Representatives Participating in Audit
Name Title
Wayne Miles Stormwater Program Manager
Ben Brown Stormwater Administrator
Scott Bryant Stormwater Administrator
Justin Harcum Sr. Engineer
Lauren Witherspoon Engineering Supervisor
Brad Stuart Engineer
Courtney Licata Sr. Engineer
Barbara Moranta Engineering Supervisor
Dan Clinton Sr. Engineer
Don Hickman Transportation Analyst
Carmela Teichman Community Outreach/Education Specialist
Sally Hoyt Engineering Supervisor
Heather Dutra Sr. Engineer
Joyce Gaffney Environmental & Sustainability Specialist
Laura Johnson Sr. Engineering Specialist
Stephen Jeltema Engineer
Zachary Poole Engineering Specialist
Tiffanie Mazanek Communications Analyst
Suzette Mitchell Administrative Support Supervisor
Javier Echaniz Fiscal Analyst
Stephen Leischner Sr. Engineering Specialist
Brian McHouell Engineering Specialist
Pete Duffy Engineering Specialist
Daniel Kirsch Engineering Support Supervisor

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Chris Bridgers Sr. Engineering Specialist
Kevin Boyer Sustainability Consultant

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List of Supporting Documents
Item
Number Document Title Document Format
(web link, e- file, etc.)
1 City of Raleigh Stormwater Management Plan PDF/web link
2 NPDES Stormwater MS4 Permit Annual Report, Rev 3.20.2022 PDF
3 Citywide Spill Response Guidance Document PDF
4 Illicit Discharge Detection and Elimination Plan PDF
5 City of Raleigh Illicit Discharge Ordinance PDF
6 Major Outfalls and Receiving Streams Map, 3/31/2022 PDF
7 Education, Outreach, and Public Involvement Plan PDF
8 Industrial Facility Inspection Program Plan PDF
9 Industrial Facility Inventory PDF
10 Water Quality Assessment and Monitoring Plan PDF
11 Engineering Services Stormwater Management Communications Plan PDF
12 CWEP FY21 Annual Report PDF
13 Unified Development Ordinance, Stormwater Managem ent Web link
14 Stormwater Design Manual Web link
15 Asset Management SCM O&M Plan* PDF
16 Pollution Prevention and Good Housekeeping Program Plan PDF
17 MS4 O&M Plan PDF
18 Pollution Prevention and Good Housekeeping Inventory PDF
19 SW-121 Pollution Prevention and Good Housekeeping Site Inspection SOP PDF
20 SCM Inspections Program Plan PDF

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*Draft final plan has been provided. Asset scoring framework and the resulting business risk exposure calculation is
currently being finalized to prioritize our asset management effort more accurately.

21 Stormwater Program Webpage Web link
22 Municipally-Owned Structural SCM Inventory PDF
23 Operational Definition of MS4 PDF
24 Delegation of Signature Authority Form PDF

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Program Implementation, Documentation & Assessment
Staff Interviewed:
(Name, Title, Role)
Wayne Miles, Stormwater Program Manager, MS4 permit program authorized representative; Ben Brown,
Stormwater Administrator, MS4 permit program manager; Kevin Boyer, Sustainability Consultant, MS4 permit
program support; Scott Bryant, Stormwater Administrator, MS4 permit program manager; Javier Echaniz,
Fiscal Analyst, budget and financial lead; Justin Harcum, Sr. Engineer, MS4 permit program support
Permit Citation Program Requirement Status Supporting
Doc No.
II.A.
Program
Implementation
The permittee maintained adequate legal mechanisms, such as regulations,
ordinances, policies and procedures to implement all provisions of the Stormwater
Management Plan (SWMP).
Yes
1 (Sec. 3,
6, 7, 8); 2
(A); 5, 13
The permittee implemented provisions of the Stormwater Management Plan and
evaluated the performance and effectiveness of the program components annually. Yes 2
The permittee maintained written procedures for implementing the six minimum
control measures, which identify specific action steps, schedules, resources and
responsibilities.
Yes 1
The permittee is current on payment of invoiced administering and compliance
monitoring fees (see stormwater e-payments on https://deq.nc.gov/sw). Yes N/A
Comments: Program schedules, actions and responsibilities are listed in each respective section of the Stormwater Management
Plan with individual program plans and/or SOPs available upon request.

III. A.
Program
Documentation
The permittee maintained documentation of all program components including, but
not limited to, inspections, maintenance activities, educational programs,
implementation of BMPs, enforcement actions and other stormwater activities.
Yes 1, 2
Documentation is kept on-file by the permittee for a period of five (5) years. Yes 1 (Sec.
13)
The permittee’s Stormwater Management Plan is reviewed and updated as
necessary, but at least on an annual basis. Yes
1 (Sec 3,
13), 2
(Sec. A,
K)
Comments: The City’s Stormwater Management Plan was significantly revised and approved during this past reporting cycle.
Inspection, asset, facility, and program documentation are maintained in electronic formats through Cityworks, Excel, GIS, etc.
for a period of five years. Files can be made available upon request.

IV.B.
Annual Reporting

The permittee submitted annual reports to the Department by October 31st of each
calendar year for the previous fiscal year's activities (from July 1st to June 30th). Yes 2
The Annual Reports included appropriate information to accurately describe the progress, status, and results
of the permittee’s Stormwater Management Plan, including, but not limited the following:

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Program Implementation, Documentation & Assessment
a. A detailed description of the status of implementation of the Stormwater Plan as
a whole. This includes information on development and implementation of each
major component of the Stormwater Management Plan for the past year and
schedules and plans for the year following each report.
Yes 2
b. A description and justification of any proposed changes to the Stormwater
Management Plan. This includes descriptions and supporting information for the
proposed changes and how these changes will impact the Stormwater Plan
(results, effectiveness, implementation schedule, etc.).
Yes 2 (Sec. K)
c. Documentation of any necessary changes to programs or practices for
assessment of management measures implemented through the Stormwater
Management Plan.
Yes 2
d. A summary of data accumulated as part of the Stormwater Management Plan
throughout the year along with an assessment of what the data indicates. Partial 2
e. An assessment of compliance with the permit, information on the establishment
of appropriate legal authorities, inspections, and enforcement actions. Yes 2
f. Discussion of program funding. Yes 2 (Sec.
A)
Comments: In response to the recent approval of the Stormwater Management Plan, City staff significantly updated the Annual
Report template to accommodate for reporting metric changes. The Annual Report template is scheduled to be modified prior to
the next reporting cycle to facilitate detailed reporting on the assessment of the metrics.

IV.D.
Other Information The Permittee maintained a record of any illicit discharge that reaches waters of the
state and may cause or contribute to a violation of the water quality standards or
constitute an imminent threat to health or the environment
Yes 2 (Sec.
D)
The record includes dates, identification of possible responsible parties, causes, and
any action taken by the permittee or the responsible party. Yes
2 (Sec.
D); 4
(Sec. 4)
Discharges that constitute an imminent threat to health or the environment were
reported within 24 hours by phone or e-mail to the Division Regional Office during
business hours, or to the NC Division of Emergency Management State Operations
Center hotline outside of business hours.
Yes
3 (Sec.
4), 4
(Sec. 4)
Comments: The Citywide Spill Response Guidance Document (#3) and internal Standard Operating Procedures require notification
of appropriate authorities in the event of a discharge that poses an imminent threat to human health and the environment. IDDE
Staff provide guidance and confirm this notification is completed during each respective illicit discharge investigation. Individual
records are available upon request.

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Program Implementation, Documentation & Assessment
Additional
Comments:
n/a

NCS000245_Raleigh 2022 MS4 Self-Audit Page 10 of 47
Public Education and Outreach
Staff Interviewed:
(Name, Title, Role)
Carmela Teichman, Community Outreach/Education Specialist, education and outreach coordinator; Tiffanie
Mazanek, Communications Analyst, website and communications coordinator; Suzette Mitchell,
Administrative Support Supervisor, stormwater hotline/helpline staff supervisor
Permit Citation Program Requirement Status Supporting
Doc No.
II.B.2.a.
Target Pollutants
& Sources
The permittee described the target pollutants and target pollutant sources that the
public education program is designed to address and why they are an issue . Yes
1 (Sec.
4); 2
(Sec. B);
7; 12
Comments: Per the recent SWMP updates and completion of the Education, Outreach, and Public Involvement Plan, target
pollutants and sources are currently being tracked for this reporting year for all outreach activities. The Clean Water Education
Partnership (CWEP), of which Raleigh is a member, designates a target pollutant annually. Education, Outreach, and Public
Involvement Plan states that all pollutants will be addressed with efforts/events annually. www.nc-cleanwater.com

II.B.2.b.
Target Audiences
The permittee described the target audiences likely to have significant stormwater
impacts and why they were selected. Yes
1 (Sec.
4); 2
(Sec. B);
7; 12;
Comments: Per the recent SWMP updates and completion of the Education, Outreach, and Public Involvement Plan, target
audiences are currently being tracked for this reporting year for all outreach activities. CWEP designates a target audience
annually. www.nc-cleanwater.com

II.B.2.c.
Informational
Web Site
The permittee promoted and maintained an internet web site designed to convey the
program’s message. Yes
1 (Sec.
4); 2
(Sec. B);
11; 21
Comments: www.raleighnc.gov/stormwater

II.B.2.d.
Public Education
Materials
The permittee distributed general stormwater educational material to appropriate
target groups as likely to have a significant stormwater impact. Yes
1 (Sec.
4); 2
(Sec. B);
7
Comments: The approximate number of attendees and outreach materials provided at each event is included in our NPDES
Annual Report.

II.B.2.e.
Stormwater
Hotline
The permittee promoted and maintained a stormwater hotline(s) or helpline(s) for
the public to request information about stormwater, public involvement &
participation, and to report illicit connections & discharges, etc.
Yes
1 (Sec.
4); 2
(Sec. B)

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Public Education and Outreach
Comments: The stormwater hotline [phone]) is included on the City website and on outreach and educational materials
distributed at public events, as documented in the annual report.

II.B.2.f.
Public Education
& Outreach
Program
Implementation
The permittee’s outreach program, including those elements implemented locally or
through a cooperative agreement, include a combination of approaches designed to
reach the target audiences.
Yes
1 (Sec.
4); 2
(Sec. B);
7; 11; 12
For each media, event or activity, including those elements implemented locally or
through a cooperative agreement, the permittee estimated and recorded the extent
of exposure.
Yes
1 (Sec.
4); 2
(Sec. B);
7; 11; 12
Comments: See II.B.2.a, II.B.2.b, and 11.B.2.d comments above.

Additional
Comments:
n/a

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Public Involvement and Participation
Staff Interviewed:
(Name, Title, Role)
Heather Dutra, Sr. Engineer, program supervisor; Joyce Gaffney, Environmental & Sustainability Specialist,
volunteer coordinator; Carmela Teichman, Community Outreach/Education Specialist, education and
outreach coordinator; Tiffanie Mazanek, Communications Analyst, website and communications coordinator;
Suzette Mitchell, Administrative Support Supervisor, stormwater hotline/helpline staff supervisor
Permit Citation Program Requirement Status Supporting
Doc No.
II.C.2.a.
Volunteer
Community
Involvement
Program
The permittee included and promoted volunteer opportunities designed to promote
ongoing citizen participation. Yes
1 (Sec.
5); 2
(Sec. C)
Comments: Volunteer opportunities are promoted through the Stormwater program webpage:
www.raleighnc.gov/stormwater/become-stormwater-volunteer

II.C.2.b.
Mechanism for
Public
Involvement
The permittee provided and promoted a mechanism for public involvement that
provides for input on stormwater issues and the stormwater program. Yes
1 (Sec.
5); 2
(Sec. C);
11
Comments: Stormwater staff engages the Stormwater Management Advisory Commission (SMAC) for public feedback on the
stormwater program and on stormwater issues. SMAC meets monthly, the meetings are open to the public, and public comments
are received. www.raleighnc.gov/stormwater-management-advisory-commission

II.C.2.c.
Hotline/Help Line
The permittee promoted and maintained a hotline/helpline for the public to request
information about stormwater, public involvement & participation, and to report
illicit connections & discharges, etc.
Yes
1 (Sec. 4,
5); 2
(Sec. B,
C)
Comments: The stormwater hotline [phone]) is listed on the City stormwater webpage and on education and outreach
materials distributed at public events.

II.C.2.d.
Public Comment
The permittee made the most recent Stormwater Management Plan available for
public review and comment. Yes
1 (Sec.
5); 2
(Sec. C)
Comments: City of Raleigh provided a period for public comment on the most recent Stormwater Management Plan January 8 –
February 5, 2021. The approved Stormwater Management Plan is posted on the City’s website:
www.raleighnc.gov/SupportPages/stormwater-management-plan
II.C.2.e.
Public Notice
The permittee complied with State, Tribal and local public notice requirements when
implementing the public involvement / participation program. Yes
1 (Sec.
5); 2
(Sec. C)

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Public Involvement and Participation
Comments: The City has a publicly available application posted online to fill vacant positions on the SMAC when they occur.
Vacant positions are filled by City Council appointment.

Additional
Comments:
n/a

NCS000245_Raleigh 2022 MS4 Self-Audit Page 14 of 47
Illicit Discharge Detection and Elimination (IDDE)
Staff Interviewed:
(Name, Title,
Role)
Stephen Jeltema, Engineer, program coordinator; Zachary Poole, Engineering Specialist, field investigations;
Brad Stuart, Engineer, GIS mapping; Suzette Mitchell, Administrative Support Supervisor, stormwater
hotline/helpline staff supervisor; Carmela Teichman, Community Outreach/Education Specialist, education
and outreach coordinator
Permit Citation Program Requirement Status Supporting
Doc No.
II.D.2.a.
Legal Authorities The permittee maintained adequate ordinances or other legal authorities to prohibit
illicit connections and discharges and enforce the approved IDDE Program. Yes
1 (Sec. 3,
6); 2
(Sec. A);
5
Comments
n/a

II.D.2.b.
MS4 Mapping The permittee maintained a current map showing major outfalls and receiving
streams. Yes 6
Comments: The City’s major outfall dataset was updated to match permit definition and receiving streams to include 303(d)
impaired waters as defined by NCDEQ during June-October 2021. Shapefiles and/or a geodatabase are available upon request.

II.D.2.c.
Dry Weather Flow
Program
The permittee maintained written procedures and/or Standard Operating Procedures
(SOPs) for detecting and tracing the sources of illicit discharges. Yes 4 (Secs.
3-5)
The permittee maintained written procedures and/or Standard Operating Procedures
(SOPs) for removing the sources or reporting the sources to the State to be properly
permitted.
Yes
3 (Sec. 3,
4); 4
(Sec. 4);
5
The permittee maintained written procedures and/or SOPs that specify a timeframe
for monitoring and how many outfalls and the areas that are to be targeted for
inspections.
Yes 4 (Sec. 5)
Comments: Within the last two years, staff have moved from prioritization and inspection of all City outfalls based on location to
buffer, land use, pipe size, watershed, and proximity to a sanitary sewer line to inspection of Major Outfalls as defined by the
permit.

II.D.2.d.
Employee Training The permittee conducted training for appropriate municipal staff on detecting and
reporting illicit connections and discharges. Yes
2 (Sec.
D); 4
(Sec. 7);
7; 17
(Sec. 3)
Comments: All staff complete IDDE training using the iLearn platform at time of hire and on a three -year frequency.

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Illicit Discharge Detection and Elimination (IDDE)
II.D.2.e.
Public Reporting
The permittee maintained and publicized reporting mechanism(s) for the public to
report illicit connections and discharges. Yes
1 (Sec.
6); 2
(Sec. B,
D); 4
(Sec. 4)
Comments: The City uses the 919-996-3940 and a workgroup email address: [e-mail] where City staff and
the public and report illicit connections and discharges. These reporting methods are posted on the City stormwater webpage.

II.D.2.f.
Documentation The permittee documented the date of investigations, any enforcement action(s) or
remediation that occurred. Yes
2 (Sec.
D); 4
(Sec. 4)
Comments: Sample IDDE outfall inspection records can be provided upon request to demonstrate documentation.

Additional
Comments:
n/a

NCS000245_Raleigh 2022 MS4 Self-Audit Page 16 of 47

Construction Site Runoff Controls
Staff Interviewed:
(Name, Title, Role)
Lauren Witherspoon, Engineering Supervisor, inspections program manager; Sally Hoyt, Engineering
Supervisor, plan review program manager
Program Delegation Status:
The permittee has a delegated Sediment and Erosion Control Program and implements the North Carolina Sedimentation
Pollution Control Act (SPCA) of 1973 and Chapter 4 of Title 15A of the North Carolina Administrative Code .
The delegated or authorized Sediment and Erosion Control Program effectively meets the NPDES MS4 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.
Permit Citation Program Requirement Status Supporting
Doc No.
II.E.2.a.
Delegated SPCA
Program
The permittee implements a delegated program in compliance with the Sediment
Pollution Control Act of 1973 and Chapter 4 of Title 15A of the North Carolina
Administrative Code.
Yes 13 (Art.
9.4)
Comments: A SPCA delegated program review was completed by NCDEQ-DEMLR staff on March 24, 2022. NCDEQ is
recommending continued delegation to the Sedimentation Control Commission (SCC) on May 19, 2022. Once the SCC
determination is made, we will make the SCC “Decision Letter” available upon request.

II.E.2.c.
Reporting
Mechanism
The permittee provided and promoted a means for the public to notify the
appropriate authorities of observed erosion and sedimentation problems. Yes
1 (Sec.
7); 2
(Sec. B,
E)
Comments: Stormwater hotline [phone]) is posted on the City website and included on outreach and education materials
distributed at public events.

II.E.2.d.
Coordination with
DEMLR The permittee coordinated the approval of the construction site runoff control with
DEMLR for new development and redevelopment projects to be built within the
permittee’s planning jurisdiction by entities with eminent domain authority.
Yes
2 (Sec.
E); 13
(Sec.
1.1.2;
Art.
9.4.1.B)
Comments
n/a

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Construction Site Runoff Controls
I.D.
Implementation in
ETJ
Construction Site Runoff Control requirements are applied in the Permittee’s Extra
Territorial Jurisdictional (ETJ) to the extent allowable under State and local law. Yes
13 (Sec.
1.1.2;
Art. 9.4)
Comments
n/a

Additional
Comments:
n/a

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Post-Construction Site Runoff Controls
Staff Interviewed:
(Name, Title, Role)
Sally Hoyt, Engineering Supervisor, plan review program manager; Laura Johnson, Sr. Engineering Specialist,
SCM inspections program coordinator; Lauren Witherspoon, Engineering Supervisor, inspections program
manager
Program Implementation (check all that apply):
☒ The permittee implements the components of this minimum measure.
☐ The permittee relies upon another entity to implement the components of this minimum measure: n/a
☒ The permittee implements the following Qualifying Alternative Program(s), which meet NPDES MS4 post-construction
requirements in the areas where they are implemented and in compliance with the specific program requirements as provided in
15A NCAC and noted below:
☐ Water Supply Watershed I (WS-I) – 15A NCAC 2B .0212 (Eff. March 1, 2019 15A NCAC 02B .0620 - .0624)
☐ Water Supply Watershed II (WS-II) – 15A NCAC 2B .0214 (Eff. March 1, 2019 15A NCAC 02B .0620 - .0624)
☒ Water Supply Watershed III (WS-III) – 15A NCAC 2B .0215 (Eff. March 1, 2019 15A NCAC 02B .0620 - .0624)
☒ Water Supply Watershed IV (WS-IV) – 15A NCAC 2B .0216 (Eff. March 1, 2019 15A NCAC 02B .0620 - .0624)
☐ Freshwater High Quality Waters (HQW) – 15A NCAC 2H .1006
☐ Freshwater Outstanding Resource Waters (ORW) – 15A NCAC 2H .1007
☒ Neuse River Basin Nutrient Sensitive (NSW) Management Strategy – 15A NCAC 2B .0235
☐ Tar-Pamlico River Basin Nutrient Sensitive (NSW) Management Strategy – 15A NCAC 2B .0258
☐ Randleman Lake Water Supply Watershed Nutrient Management Strategy – 15A NCAC 2B .0251
☐ Universal Stormwater Management Program – 15A NCAC 2H .1020

Regulatory Authority:
The permittee utilizes the following ordinances and/or regulatory authority to fulfill post construction minimum measure program
requirements (check all that apply):
☐ DEQ model ordinance
☐ MS4 designed post-construction practices that meet or exceed 15A NCAC 02H .1000
☐ DEQ approved comprehensive watershed plan
☒ DEQ approved Qualifying Alternative Program listed above

Program Requirement Status Supporting
Doc No.
02H .1017
Qualifying
Alternative
Program(s)
The permittee implements the Qualifying Alternative Program requirements
checked above in accordance with the applicable 15A NCAC rules. Yes
1 (Sec.
8); 13
(Art. 9.2;
9.5)

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Post-Construction Site Runoff Controls
The permittee cumulatively implements the Qualifying Alternative Program
requirements checked above throughout the entire MS4 permitted area.
Yes
1 (Sec.
8); 2
(Sec. F);
13 (Art.
1.1.2,
9.2, 9.5)
If response is no or partial, the permittee implements MS4 post-
construction requirements in accordance with 15A NCAC 02H .1017(3) –
(14) throughout the balance of the MS4 permitted area.
Not
Applicable n/a
Comments: The MS4 permitted area includes the City of Raleigh corporate limits and ETJ. Water supply watershed requirements
only apply within the specific watershed areas.

Permit Citation Program Requirement Status Supporting
Doc No.
I.D.
Implementation in
ETJ
Post-Construction Site Runoff Control requirements are applied in the Permittee’s
Extra Territorial Jurisdictional (ETJ) to the extent allowable under State and local
law.
Yes
1 (Sec. 2,
8); 2
(Sec. F);
13 (Sec.
1.1.2)
Comments
n/a

II.F.2.a.
Legal Authority

The permittee maintained an ordinance or similar regulatory mechanism that
authorizes a program to address stormwater runoff from new development and
redevelopment to the extent allowable under State law. Yes
1 (Sec. 2,
8); 2
(Sec. F);
13 (Art.
9.2, 9.5)
Comments
n/a
II.F.2.b.
Stormwater Control
Measures (SCMs)

The permittee maintains strategies that include a combination of structural and/or
non-structural SCMs in concurrence with the legal authorities above (II.F.2.a.). Yes
1 (Sec.
8); 2
(Sec. F);
14
The permittee provides a mechanism to require long-term operation and
maintenance of structural SCMs. Yes
13 (Art.
9.2); 14
(Sec 1.7);
20
The permittee requires annual inspection reports of permitted structural SCMs
performed by a qualified professional. Yes
13 (Art.
9.2); 14
(Sec.
3.1.4);
20

NCS000245_Raleigh 2022 MS4 Self-Audit Page 20 of 47
Post-Construction Site Runoff Controls
The permittee implements SCM requirements that are at least as stringent as the
minimum requirements in 15A NCAC 02H .1000. Yes
1 (Sec.
8); 13
(Art.
9.2); 14
Comments: The City has historically required compliance with the NCDEQ archived Stormwater Design Manual, which is at least
as stringent as the minimum requirements in 15A NCAC 02H .1000. As of April 1, 2022, applicants can utilize either the archi ved
or current NCDEQ Stormwater Design Manual. Complete adoption of the new NCDEQ Stormwater Design Manual will occur once
the Neuse Model Ordinance becomes effective.

II.F.2.c.
Deed Restrictions
and Protective
Covenants

The permittee provides mechanisms such as recorded deed restrictions, plats,
and/or protective covenants so that development activities maintain the project
consistent with approved plans.
Yes
13 (Art.
9.2.2.G);
14 (Sec
1.7)
Comments: The City requires easements for all jurisdictional SCMs and protective covenants for SCMs that provide shared
compliance between parcels. Stormwater staff is cooperating with the City Attorney’s Office to complete a covenant template for
single-owner SCM(s), which is above and beyond the MS4 permit requirement. A template covenant is available upon request.

II.F.2.d.
Operation and
Maintenance Plans

The developer provides the permittee with an operation and maintenance plan for
the stormwater system, indicating the operation and maintenance actions that
shall be taken, specific quantitative criteria used for determining when those
actions shall be taken, and who is responsible for those actions.
Yes
13 (Art.
9.2.2.D.2
)
The plans clearly indicate the steps that shall be taken and who shall be responsible
for restoring a stormwater system to design specifications if a failure occurs and
include a legally enforceable acknowledgment by the responsible party.
Yes
13 (Art.
9.2.2.D.2
.f)
The plans include a legally enforceable acknowledgment by the responsible party. Partial 13 (Art.
9.2)
Development is maintained consistent with the requirements in the approved
plans. Yes
13 (Art.
9.2.2.G.1
.a)
Modifications to those plans must be / are approved by the Permittee. Partial 13 (Art.
9.2)
Comments: Stormwater staff is seeking cooperation with the City Attorney’s Office to complete a covenant template for single-
owner SCM(s), which is above and beyond the MS4 permit requirement. A template covenant is available upon request. A
specific process for O&M Plan modification after as-built acceptance is not specifically documented. However, all SCM
modifications are subject to a permitting review, which includes review of the O&M.

II.F.2.e.
Educational
Materials and
Training

The permittee provided educational materials and training for developers. Yes
2 (Sec.
F); 7; 11;
21

NCS000245_Raleigh 2022 MS4 Self-Audit Page 21 of 47
Post-Construction Site Runoff Controls
Comments:

The City holds annual post-construction SCM workshops* for property owners and developers, as documented in the Education,
Outreach, and Public Involvement Plan (#7). During the last year, Quarterly Development Stakeholder Meetings were held which
centered around the Stormwater Design Manual Update. Informational pages & resources for developers can be accessed from
the Services area of the City stormwater webpage (https://raleighnc.gov/stormwater) including the following:

www.raleighnc.gov/SupportPages/learn-about-stormwater-design-manual
www.raleighnc.gov/stormwater/stormwater-permitting-and-inspections-requirements
www.raleighnc.gov/SupportPages/stormwater -plan-review
www.raleighnc.gov/zoning-planning-and-development/site-permit-review
www.raleighnc.gov/permits-and-inspections/smaller-site-development
www.raleighnc.gov/SupportPages/stormwater -inspections
www.raleighnc.gov/services/stormwater/submit-stormwater-device-inspection-report

*The post-construction SCM workshop was not held due to the Covid -19 pandemic in 2020 and 2021.
II.F.4.
Sensitive Receiving
Waters

The permittee applies additional requirements to projects draining to SA waters by
requiring SCMs that result in the highest degree of fecal coliform die -off and
controls sources of fecal coliform to the maximum extent practicable in accordance
with 15A NCAC 02H .1017(9)
Not
Applicable ---
The permittee applies additional requirements to projects draining to Trout waters
by requiring SCMs that avoid a sustained increase in receiving water temperature
in accordance with 15A NCAC 02H .1017(9)
Not
Applicable ---
The permittee implements an approved locally implemented Nutrient
Management Strategy that addresses post-construction runoff and the provisions
of that Strategy fulfill the MS4 post-construction requirement.
Yes
13 (Art.
9.2, 9.5);
14
Comments: There are no SA or Trout waters in the City of Raleigh corporate limits or ETJ.

II.F.5.
Permittee Projects

The permittee meets the requirements of the post-construction program for
construction projects that are performed by, or under contract for, the permittee. Yes
13 (Sec
1.1.2,
Art. 9.2);
15
Comments: The provisions of the UDO, including the post-construction requirements in Section 9.2, apply to all entities in the City
corporate limits & ETJ, including those performed by or for the City.

II.F.6.
SCM Design Volume

The permittee requires that the water quality design volume of SCMs account for
the runoff at build out from all surfaces draining to the system. Yes
13 (Art.
9.2); 14
(Sec. 1.6)
Comments
n/a

NCS000245_Raleigh 2022 MS4 Self-Audit Page 22 of 47
Post-Construction Site Runoff Controls
II.F.7.
Linear
Transportation
Projects

The permittee fulfills the post-construction minimum control measure
requirements for non-NCDOT linear transportation projects if they are designed,
constructed, and conveyed as set forth in 15A NCAC 02H .1001(1)(c):
(i) Constructed to NCDOT standards and in accordance with the NCDOT BMP
Toolbox;
(ii) Conveyed to NCDOT or other public entity and regulated in accordance with
that entity’s NPDES MS4 Permit; and
(iii) The project is not part of a common plan of development.
Partial
13 (Sec
1.1.2,
Art. 9.2,
9.5); 15
Comments: City of Raleigh stormwater staff review linear transportation projects undertaken by the City of Raleigh – both
projects that will remain in City ownership and those that will be conveyed to NCDOT. For projects to be conveyed to NCDOT, the
stormwater reviewer confirms that the linear improvements are in accordance with NCDOT standards and the NCDOT BMP
Toolbox. For projects not conveyed to NCDOT, the City’s UDO applies. This current practice will be captured in a new SOP.
Examples of past plan review comments are available upon request.

Additional
Comments:
n/a

NCS000245_Raleigh 2022 MS4 Self-Audit Page 23 of 47

Pollution Prevention and Good Housekeeping for Municipal Operations
Staff Interviewed:
(Name, Title, Role)
Stephen Jeltema, Engineer, program coordinator; Zachary Poole, Environmental Specialist, inspector; Brad
Stuart, Engineer, GIS/inventory support; Barbara Moranta, Engineering Supervisor, MS4 O&M Plan project
manager; Donald Hickman, Transportation Analyst, MS4 maintenance coordinator; Dan Clinton, Sr.
Engineer, asset management coordinator; Courtney Licata, Sr. Engineer, SCM program manager; Carmela
Teichman, Community Outreach/Education Specialist, education and outreach coordinator
Permit Citation Program Requirement Status Supporting
Doc No.
II.G.2.a.
Municipal Facility
Inventory
The permittee maintained an inventory of municipal facilities and operations
owned and operated by the permittee that have been determined by the
permittee to have significant potential or generating polluted stormwater runoff.
Yes 16 (Sec.
2); 18
The permittee maintained an inventory of municipally-owned structural SCMs. Yes
2 (Sec.
G); 15
(Sec. 3);
20; 22
Comments: The Pollution Prevention and Good Housekeeping Inventory has been recently updated to remove City -owned
facilities that are located outside of the City limits (See Document 18). Currently, there are 29 high priority sites, which all have
site-specific Site Pollution Prevention Plans.

In addition, our inventory of municipally-owned structural SCMs has been updated since our annual report. Currently there are
98 City-owned SCMs in our inventory. Of the 98:
• 2 are NCDEQ-required
• 59 regulatory required per the UDO
• 33 are ‘non-regulatory’
• 4 are still under warranty
• There are 17 City-owned regulatory SCMs that cannot be certified because they are not functioning as designed.

II.G.2.b.
Inspection and
Maintenance for
Municipal Facilities

The permittee implemented an inspection and maintenance program for facilities
and operations owned and operated by the permittee for potential sources of
polluted runoff, including stormwater controls and conveyance systems.
Yes
2 (Sec.
G); 16
(Sec.
2.3); 19
The inspection program evaluates pollutant sources, documents deficiencies, plans
corrective actions, implements appropriate controls, and documents the
accomplishment of corrective actions.
Yes
2 (Sec.
G); 16;
19 (Sec.
8.2)
The maintenance program includes maintenance activities and procedures aimed
at preventing or reducing pollutants generated from municipal facilities and
operations.
Yes
3 (Sec.
2); 17
(Sec. 4)

NCS000245_Raleigh 2022 MS4 Self-Audit Page 24 of 47
Pollution Prevention and Good Housekeeping for Municipal Operations
Comments: Facility SPPPs and SWPPPs describe inspection and maintenance activities and procedures specific to each municipal
facility with significant potential to generate polluted stormwater runoff. Individual SPPPs and SWPPPs are available upon
request.

The City has developed Stormwater Pollution Prevention Fact Sheets that provide guidance on best management practices to
minimize impacts to stormwater during operations. These documents have been distributed to City staff and are posted on our
internal employee website. These documents are available upon request.

II.G.2.c.
Site Pollution
Prevention Plans for
Municipal Facilities
The permittee maintained and implemented Site Pollution Prevention Plans for
municipal facilities owned and operated by the permittee that have been
determined by the permittee to have significant potential for generating polluted
stormwater runoff that has the goal of preventing or reducing pollutant runoff .
Yes 16 (Sec.
2.4); 18
Comments: See II.G.2.a comments above. Individual SPPPs and SWPPPs are available upon request.

II.G.2.d.
Spill Response
Procedures for
Municipal Facilities
The permittee maintained spill response procedures for municipal facilities and
operations owned and operated by the permittee that have been determined by
the permittee to have significant potential for generating polluted stormwater
runoff.
Yes
3 (Sec.
3); 16
(Sec. 2.5)
Comments: The Citywide Spill Response Guidance Document includes spill response procedures for City staff and contractors
working at a facility or conducting municipal operations . SPPPs and SWPPPs also include spill response procedures.

II.G.2.e.
Vehicle and
Equipment Cleaning
Areas
The permittee described measures that prevent or minimize contamination of the
stormwater runoff from all areas used for vehicle and equipment cleaning,
including fire stations that have more than three fire trucks and ambulances.
Yes
3 (Sec.
2.1.1);
16 (Sec.
2.6)
The permittee performs all cleaning operations indoors, covers the cleaning
operations, ensures wash water drains to the sanitary sewer system, collects wash
water and stormwater run-on from the cleaning areas and provides treatment or
recycling, or other equivalent measures
Yes
3 (Sec.
2.1.1);
16 (Sec.
2.6)
The permittee, if sanitary sewer is not available to the facility and cleaning
operations take place outdoors, ensures wash water drains to an SCM for
treatment, or else the cleaning operations take place on or drain directly to grassed
or graveled areas to prevent point source discharges of wash water into the storm
drains or surface waters.
Yes
3 (Sec.
2.1.1);
16 (Sec.
2.6)
The permittee, where cleaning operations cannot be performed as described above
and when operations are performed in the vicinity of a storm drainage collection
system, covers the drain(s) with a portable drain cover during cleaning activities,
and any excess standing water is removed and properly handled prior to removing
the drain cover.
Yes
3 (Sec.
2.1.1);
16 (Sec.
2.6)

NCS000245_Raleigh 2022 MS4 Self-Audit Page 25 of 47
Pollution Prevention and Good Housekeeping for Municipal Operations
The permittee facilities that have three or fewer fire trucks and ambulances
attempt to comply with the above requirements; however, those that cannot
comply with these requirements due to existing limitations incorporate structural
measures during facility renovation to the extent practicable.
Yes
3 (Sec.
2.1.1);
16 (Sec.
2.6)
Comments: Most City dedicated wash areas are either indoor or undercover and wash water drains to the sanitary sewer system
or drain to a site SCM. These sites have respective Site Pollution Prevention Plans that describe routine inspection and best
management practices. When cleaning cannot be performed as described above, Stormwater staff regularly provide guidance to
facility staff on best management practices. In addition, all Pollution Prevention and Good Housekeeping inspections include a
question concerning vehicle washing. Currently, Stormwater staff review all plans for new construction and renovations for City
facilities that require a permit by the UDO. Requirements for incorporating structural measures during facility construction and
renovation is scheduled to be included in the updated Design Manual within this permit cycle.

II.G.2.f.
Streets, Roads and
Public Parking Lot
Maintenance

The permittee implements BMPs to reduce polluted stormwater runoff from
municipally-owned streets, roads, and public parking lots within the corporate
limits.
Yes
2 (Sec.
G); 16
(Sec.
2.7); 17
(Sec. 4)
Comments
n/a
II.G.2.g.
Inspection and
Maintenance for
Municipal SCMs and
MS4

The permittee maintained and implemented an inspection and maintenance
program for structural stormwater control measures (SCMs) owned and operated
by the municipality.
Partial
2 (Sec.
G); 15
(Sec. 4,
5)
The permittee maintained and implemented an inspection and maintenance
program for the municipal storm sewer system (including catch basins, the
conveyance system and SCMs).
Yes 2 (Sec.
G); 17
Comments: All jurisdictional City-owned SCMs are routinely inspected throughout the reporting year and are tracked in
Cityworks. Annual inspections required per the UDO are completed by an on-call engineering consulting firm. Individual
inspection and maintenance records are available upon request.

Execution of Service Level Agreements (SLAs) is ongoing with other City Departments to address shared ownership and
maintenance responsibilities, and outstanding SCM maintenance needs. The Parks, Recreation and Cultural Resources and
Transportation Departments have executed SLAs and account for the majority of the City’s jurisdictional SCMs.

NCS000245_Raleigh 2022 MS4 Self-Audit Page 26 of 47
Pollution Prevention and Good Housekeeping for Municipal Operations
II.G.2.h.
Staff Training The permittee maintained a training plan that indicates when, how often, and who
is required to be trained and what they are to be trained on . Yes 7; 16
(Sec. 2);
The permittee implemented a training plan that indicates when, how often, and
who is required to be trained and what they are to be trained on. Yes 2 (Sec.
G)
Comments
n/a
Additional
Comments:
n/a

NCS000245_Raleigh 2022 MS4 Self-Audit Page 27 of 47
Program to Monitor and Evaluate Stormwater Discharges to Municipal Systems
Staff Interviewed:
(Name, Title, Role)
Stephen Jeltema, Engineer, program coordinator; Zachary Poole, Engineering Specialist, inspections
Permit Citation Program Requirement Status Supporting
Doc No.
II.H.2.a.
Industrial Facility
Inventory
The permittee maintained an inventory of permitted hazardous waste treatment,
disposal, and recovery facilities, industrial facilities that are subject to Section 313
of Title III of the Superfund Amendments and Reauthorization Act of 1986 (SARA).
Yes 8 (Sec.
3); 9
The permittee maintained an inventory of industrial facilities identified with an
industrial activity (as defined in 40 CFR 122.26) permitted to discharge storm water
to the permittee’s MS4.
Yes 8 (Sec.
3); 9
Comments: The Toxic Release Inventory Facilities on the Industrial Facility Inventory (#9) are those subject to Section 313 of Title
III of SARA of 1986.

II.H.2.b.
Inspection Program

The permittee identified priorities and inspection procedures. At a minimum,
priority facilities include those identified above in subsection II.H.2.a . Yes
2 (Sec.
H); 8
(Sec. 3,
4)
Comments
n/a
II.H.2.c.
Industrial Facility
Evaluation
The permittee evaluated control measures implemented at permitted hazardous
waste treatment, disposal, and recovery facilities, industrial facilities that are
subject to Section 313 of Title III of the Superfund Amendments and
Reauthorization Act of 1986 (SARA).
For the purpose of this permit, the Permittee is authorized to inspect the permitted
hazardous waste treatment, disposal, and recovery facilities as an authorized representative
of the Director.
Yes
2 (Sec.
H); 8
(Sec. 4);
9
The permittee evaluated control measures implemented at industrial facilities
identified with an industrial activity permitted to discharge storm water to the
permittee’s MS4.
For the purposes of this permit, industrial activities shall mean all permitted industrial
activities as defined in 40 CFR 122.26.
Yes
2 (Sec.
H); 8
(Sec. 4);
9
For permitted industrial facilities, the permittee established procedures for
reporting deficiencies and non-compliance to the permitting agency. Yes
2 (Sec.
H); 8
(Sec. 3,
4)

NCS000245_Raleigh 2022 MS4 Self-Audit Page 28 of 47
Program to Monitor and Evaluate Stormwater Discharges to Municipal Systems
Where compliance with an existing industrial stormwater permit does not result
in adequate control of pollutants to the MS4, the permittee recommends and
documents the need for permit modifications or additions to the permit issuing
authority.
Yes 8 (Sec.
4)
The permittee evaluated control measures implemented at industrial facilities
identified as an illicit discharge under the IDDE Program. Yes 4 (Sec. 2)
Comments: IDDE Program staff also complete the industrial facilities’ inspections and pursue illicit discharges.
Individual facility inspection records are available upon request.

Additional
Comments:
n/a

NCS000245_Raleigh 2022 MS4 Self-Audit Page 29 of 47
Water Quality Assessment and Monitoring
Staff Interviewed:
(Name, Title, Role)
Heather Dutra, Sr. Project Engineer, program supervisor; Joyce Gaffney, Environmental & Sustainability
Specialist, monitoring coordinator
Permit Citation Program Requirement Status Supporting
Doc No.
II.I.2.a.
Water Quality
Assessment and
Monitoring Plan
The permittee maintained a Water Quality Assessment and Monitoring Plan. Yes 2 (Sec. A,
I); 10
The Plan includes a schedule for implementing the proposed assessment and
monitoring activities. Yes 10 (Sec.
2.2)
Comments: The Water Assessment and Monitoring Plan was updated in December 2021 and provided to NCDEQ on December 30,
2021.

II.I.2.b.
Water Quality
Monitoring

The permittee maintained and implemented the Water Quality Assessment and
Monitoring Plan submitted to DEMLR. Yes 2 (Sec. A,
I)
The Division waived the requirement to maintain a Water Quality Assessment and
Monitoring Plan.
Not
Applicable n/a
Comments: NPDES monitoring occurs March, June, September, and December. In addition, City staff complete macroinvertebrate
sampling at 22 sites each year between the months of August and September. Monitoring results can be provided upon request.

Additional
Comments:
n/a

NCS000245_Raleigh 2022 MS4 Self-Audit Page 30 of 47
Site Visit Evaluation: Municipal Facility No. 1
Facility Name:
Raleigh Union Station
Date and Time of Site Visit:
April 6, 2022
8:59 am
Facility Address:
510 W. Martin Street
Raleigh, NC 27601
Facility Type (Vehicle Maintenance, Landscaping, etc.):
Train Station

Name of MS4 inspector(s) evaluated:
Stephen Jeltema
Zachary Poole

Most Recent MS4 Inspection (List date and name of inspector):
January 3, 2022
Justin Harcum, Stephen Jeltema, Zachary Poole
Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name Title
Richard Costello Station Director
Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility-specific?
Yes, the site has a Site Pollution Prevention Plan (SPPP) that covers spill response, routine inspections, stormwater discharge outfall
monitoring, and best management practices and includes a site map. Records were up to date through the first quarter of 2022.
What type of stormwater training do facility employees receive? How often?
Illicit Discharge Detection and Elimination Training, every three years
Pollution Prevention and Good Housekeeping Training, every three years
Annual SPPP training/meeting with Stormwater staff to review SPPP
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
40-hr OSHA HAZWOPER; annual refresher
Stormwater Control Measure Inspection and Maintenance Certification; recertification every three years
Pollution Prevention and Good Housekeeping Training; every three years
Illicit Discharge Detection and Elimination Training; every three years
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
Yes, the inspector discussed requirements throughout the site review.
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Yes, recommendations and guidance were provided throughout the site visit to the Station Director.
Inspection Procedures
Does the MS4 inspector’s process include the use of a checklist or other standardized form?
Yes, a Cityworks Application inspection form is used to document aspects of the inspection. See the inspection report in the
Municipal Facility No. 1 folder.
Does the MS4 inspector’s process include taking photos?
Yes, see the photos in the inspection report in the Municipal Facility No. 1 folder.

Does the MS4 inspector’s process include reviewing the facility’s SWPPP (or similar document)?
Yes, approximately half of the site visit was a review of the SPPP and the most recent records that have been added since the
January site visit.

NCS000245_Raleigh 2022 MS4 Self-Audit Page 31 of 47
Site Visit Evaluation: Municipal Facility No. 1
Does the MS4 inspector’s process include walking the entire facility and inspecting all points of discharg e?
Yes, the entire facility was inspected. Two catch basins are used as proxy to the outfall because the outfall is located on private
property on the opposite side of the railroad tracks.
Did the MS4 inspector miss any obvious areas of concern? If so, explain:
No
Does the MS4 inspector’s process include presenting the inspection findings to the facility contact ?
Yes, see the follow-up summary email in the Municipal Facility No. 1 folder, which is typical of PPGH site inspections at High Priority
sites. The Station Director accompanied the inspectors throughout the site walk and discuss ed site considerations.
Inspection Results
Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)?
Minor maintenance issues were noted during the inspection. These included a slight accumulated of fines/sediment in an area of
the permeable paver system and a rusted dumpster that was recently provided by a third-party contractor.
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
No compliance date was required.
Notes/Comments/Recommendations
Inspectors assisted the Station Director in replacing the storm drain grates of an overflow structure in a bioretention and
repositioning a second storm drain cover at an onsite catch basin.

NCS000245_Raleigh 2022 MS4 Self-Audit Page 32 of 47
Site Visit Evaluation: Municipal Facility No. 2
Facility Name:
Northeast Remote Operations Center
Date and Time of Site Visit:
April 6, 2022
11:09 am
Facility Address:
7702 Burwell Street
Raleigh NC, 27615
Facility Type (Vehicle Maintenance, Landscaping, etc.):
Multi-Use Facility (Vehicle maintenance, fuel dispensing, fuel
storage, vehicle washing, material stockpiling, equipment storage)

Name of MS4 inspector(s) evaluated:
Stephen Jeltema
Zachary Poole

Most Recent MS4 Inspection (Date and Entity):
December 2, 2021
Justin Harcum, Stephen Jeltema, Zachary Poole
Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name Title
Patrick Dickerson Interim Facility Superintendent
Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility-specific?
Yes, the facility has submitted an NOI to NCDEQ and is currently operating under a SWPPP that is site-specific.
What type of stormwater training do facility employees receive? How often?
Illicit Discharge Detection and Elimination Training, every three years
Pollution Prevention and Good Housekeeping Training, every three years
The SWPPP for this site requires annual site-specific SWPPP training as a condition of their pending permit
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
40-hr OSHA HAZWOPER; annual refresher
Stormwater Control Measure Inspection and Maintenance Certification; recertification every three years
Pollution Prevention and Good Housekeeping Training; every three years
Illicit Discharge Detection and Elimination Training; every three years
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
Yes, the inspector discussed requirements throughout the site review.
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Yes, general guidance and recommendations were provided throughout the site walk.
Inspection Procedures
Does the MS4 inspector’s process include the use of a checklist or other standardized form?
Yes, a Cityworks Application inspection form is used to document aspects of the inspection. See the inspection report in the
Municipal Facility No. 2 folder.

NCS000245_Raleigh 2022 MS4 Self-Audit Page 33 of 47
Site Visit Evaluation: Municipal Facility No. 2
Does the MS4 inspector’s process include taking photos?
Yes, see the inspection report in the Municipal Facility No. 2 folder.
Does the MS4 inspector’s process include reviewing the facility’s SWPPP (or similar document)?
Yes, the SWPPP was reviewed with the Interim Facility Superintendent. Records were current through 2020. Records for 2021 and
the first quarter of 2022 need to be located, printed, and included in the SWPPP.
Does the MS4 inspector’s process include walking the entire facility and inspecting all points of discharge?
Yes, the outfalls were inspected.
Did the MS4 inspector miss any obvious areas of concern? If so, explain:
No
Does the MS4 inspector’s process include presenting the inspection findings to the facility contact?
Yes, see attached follow-up summary email, which is typical of PPGH site inspections at High Priority sites. The Interim Facility
Superintendent accompanied the inspectors throughout the site walk and discuss ed site issues and considerations.
Inspection Results
Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)?
Yes, several previously noted issues still require action and were noted during the inspection. Records for 2020 and the first quarter
of 2021 need to be added to the SWPPP and/or made available. The vehicle wash station is still resulting in some residual or excess
wash water flowing across the parking lot and entering the adjacent storm drains during heavy traffic. Several recycle bins still
require cover from rainfall, and confirmation of proper absorbent usage at the fueling location is needed.
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
A summary email was provided requesting a follow-up to be scheduled once the containment curb on the exit bay of the vehicle
wash facility was completed. As a High Priority site, this facility is inspected annually at a minimum.
Notes/Comments/Recommendations
Additional site recommendations included a containment curb on the exit bay of the vehicle wash facility and additional measures
at the above ground fuel tanks to prevent potential impacts to the adjacent storm drain. Stormwater staff recommended that
facility staff reengage their consultant to assist with their continued SWPPP implementation. Stormwater staff stated that they
have conducted at least three separate site visits over the last 12 months and multiple virtual meetings to assist facility staff in
setting up their SWPPP and coordinating with their consultant to assist with implementation.

NCS000245_Raleigh 2022 MS4 Self-Audit Page 34 of 47
Site Visit Evaluation: MS4 Outfall No. 1
Outfall ID Number:
695 (Inspection # 847084)
Date and Time of Site Visit:
March 30, 2022
12:10 pm
Outfall Location:

35.76195, -78.61433
Outfall Description (Pipe Material/Diameter, Culvert, etc.):
Concrete/18”, FES
Receiving Water:
Walnut Creek
Is Flow Present? If So, Describe (Color, Approximate Flow Rate,
Sheen, Odor, Floatables/Debris, etc.):
No flow noted
Most Recent Outfall Inspection/Screening (Date):
February 16, 2022
Days Since Last Rainfall:
> 3 days (3/24/2022)
Inches:
0.60
Name of MS4 Inspector(s) evaluated:
Zachary Poole
Observations
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
40-hr OSHA HAZWOPER; annual refresher
Stormwater Control Measure Inspection and Maintenance Certification; recertification every three years
Illicit Discharge Detection and Elimination Training; every three years
Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations?
Yes
Inspection Procedures
Does the inspector’s process include the use of a checklist or other standardized form?
Yes, staff utilize a Cityworks Application inspection form (see the MS4 Outfall folder).
Does the inspector’s process include taking photos?
Yes (see the completed MS4 Outfall No. 1 Cityworks form in the MS4 Outfall folder).
Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they?
No

NCS000245_Raleigh 2022 MS4 Self-Audit Page 35 of 47
Site Visit Evaluation: MS4 Outfall No. 1
Inspection Results
Did the outfall inspection result in any work orders or maintenance requests? If so, for what issue(s)?
No
Will a follow-up outfall inspection be conducted? If so, for what reason?
No. Outfall is on a routine annual inspection schedule.
Notes/Comments/Recommendations
Erosion was noted downstream of the outfall.

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Site Visit Evaluation: MS4 Outfall No. 2
Outfall ID Number:
4 (Inspection #847081)

Date and Time of Site Visit:
March 30, 2022
1:30 pm
Outfall Location:
35.79625, -79.62476
Outfall Description (Pipe Material/Diameter, Culvert, etc.):
CMP/ 48”, pipe outlet
Receiving Water:
Pigeon House Branch
Is Flow Present? If So, Describe (Color, Approximate Flow Rate,
Sheen, Odor, Floatables/Debris, etc.):
Yes, approximately 5 gallons/min noted.
No color, odor, or sheen noted.
Evidence of regular flow downstream of outfall.
Inspection expanded to include upstream catch basins, which
were confirmed to be dry and without flow. A water quality
screening test was completed. Results showed the flow was
negative for chlorine and other pollutants. Flow attributed to
groundwater infiltration/flow
Most Recent Outfall Inspection/Screening (Date):
2/16/2022
Days Since Last Rainfall:
> 3 days (3/24/2022)
Inches:
0.60
Name of MS4 Inspector(s) evaluated:
Zachary Poole
Observations
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
40-hr OSHA HAZWOPER; annual refresher
Stormwater Control Measure Inspection and Maintenance Certification; recertification every three years
Illicit Discharge Detection and Elimination Training; every three years
Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations?
Yes
Inspection Procedures
Does the inspector’s process include the use of a checklist or other standardized form?
Yes, staff utilize a Cityworks Application inspection form (see the MS4 outfall folder).
Does the inspector’s process include taking photos?
Yes (see the completed MS4 Outfall No. 1 Cityworks form in the MS4 Outfall folder).
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. 2
Inspection Results
Did the outfall inspection result in any work orders or maintenance requests? If so, for what issue(s)?
No
Will a follow-up outfall inspection be conducted? If so, for what reason?
No. Outfall is on a routine annual inspection schedule.
Notes/Comments/Recommendations

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Site Visit Evaluation: Construction Site No. 1
Site/Project Name:
Stony Brook Business Center
Date and Time of Site Visit:
April 4, 2022
12:00 pm
Site/Project Address:
3050 Stony Brook Drive
Raleigh, NC 27604
Operator:
Worthy Holdings, LLC
Bobbitt Design Build
Project Type
(Commercial, Industrial, Residential, CIP, Road, etc.):
Commercial

NCG Permit ID Number:
SPR-0109-2021
Disturbed Acreage:
4.75
Recent Enforcement Actions (Include Date):
Not in Compliance Report (3/24/2022) Name of MS4 Inspector(s) evaluated:
Stephen Leischner, Brian McHouell, & Lauren Witherspoon
Name(s) and Title(s) of Site Representative(s) Present During the Site Visit:
Name Title
n/a n/a
Observations
Site Documentation/Training
Does the site have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it site-specific?
Yes
Does the site have approved erosion and sedimentation control plans onsite? Are they representative of current site conditions?
Yes. Plan includes two phases for erosion and sedimentation control, standard details, and NPDES plan with NCG01 0000 ground
stabilization and material requirements and self-inspection information. Yes, the plan accurately represents the site.
What type of stormwater training do site employees receive? How often?
n/a
Inspector Training/Knowledge

What type of stormwater training does the MS4 inspector receive? How often?
SCM Inspection and Maintenance Certification; recertification every three years.
Certified Erosion, Sediment, & Stormwater Inspector Certification; annual renewal
NCSU Erosion, Sediment, & Turbidity Control Program; annually
DEMLR Local Program Workshop; annually

Did the MS4 inspector appear knowledgeable about MS4 and NCG010000 requirements for construction sites?
Yes. The approved plan sheet includes NCG010000 requirements. The inspector noted construction debris near inlets and lack of
inspection records (requirements of the NCG01 permit).
Did the MS4 inspector appear knowledgeable about erosion and sedimentation control/stormwater pollution prevention BMPs?
Yes

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Site Visit Evaluation: Construction Site No. 1
Inspection Procedures
Does the MS4 inspector’s process include the use of a checklist?
Yes, see the Construction Site No. 1 folder.
Does the MS4 inspector’s process include taking photos?
Yes, see the Construction Site No. 1 folder.
Does the MS4 inspector’s process include reviewing approved plans (erosion and sedimentation control and/or SWPPP)?
Yes. The plan sheet was reviewed throughout the inspection.
Does the MS4 inspector’s process include walking the entire site and inspecting all points of discharge?
Yes, the inspector walked the entire site and inspected the points of discharge.
Did the MS4 inspector miss any obvious violations? If so, explain:
No violations were missed.
Does the MS4 inspector’s process include presenting the inspection findings to the site contact in writing?
Yes, a report will be sent via email, and the Notice of Violation will be sent via certified mail.
Does the MS4 inspector’s process include providing construction stormwater educational materials to the site contact?
Yes, stormwater information is provided during the preconstruction meeting for each site. NCG010000 requirements and specific
site concerns are discussed during this initial site meeting with the site representatives.
Compliance/Enforcement
What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in?
A Notice of Violation was sent via certified mail, see attached.
If compliance issues were identified, what timeline for correction/follow-up was provided?
The Notice of Violation allows ten (10) days from notice to complete the corrective actions.
Notes/Comments/Recommendations
The Notice of Violation is being sent in response to outstanding issues noted in the March 24, 2022, inspection report. In addition, a
slight amount of offsite sediment was noted in the southeast corner of the site.

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Site Visit Evaluation: Construction Site No. 2
Site/Project Name:
Altair
Date and Time of Site Visit:
April 4, 2022
1:00pm
Site/Project Address:
3909 Blue Ridge Road
Raleigh, NC 27612
Operator:
MI Homes
ACG
Project Type
(Commercial, Industrial, Residential, CIP, Road, etc.):
Residential

NCG Permit ID Number:
SPR-0210-2020
Disturbed Acreage:
10.6
Recent Enforcement Actions (Include Date):
Not in Compliance Report (3/24/2022)
In Compliance Report (4/3/2022)

Name of MS4 Inspector(s) evaluated:
Chris Bridgers & Lauren Witherspoon
Name(s) and Title(s) of Site Representative(s) Present During the Site Visit:
Name Title
Tony Long Grading Superintendent
Observations
Site Documentation/Training
Does the site have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it site-specific?
Yes
Does the site have approved erosion and sedimentation control plans onsite? Are they representative of current site conditions?
Yes. Plan includes two phases for erosion and sedimentation control, standard details, and NPDES plan with NCG01 ground
stabilization and material requirements and self-inspection information. The plan was an accurate representation of the current site
conditions.
What type of stormwater training do site employees receive? How often?
n/a
Inspector Training/Knowledge

What type of stormwater training does the MS4 inspector receive? How often?
SCM Inspection and Maintenance Certification; recertification every three years.
Certified Professional in Erosion and Sediment Control Certification; annual renewal
NCSU Erosion, Sediment, & Turbidity Control Program; annual
DEMLR Local Program Workshop; annual

Did the MS4 inspector appear knowledgeable about MS4 and NCG010000 requirements for construction sites?
Yes, he provided information concerning location of on-site inspection book and records.
Did the MS4 inspector appear knowledgeable about erosion and sedimentation control/stormwater pollution prevention BMPs?
Yes, he provided additional information on the phasing of the site and the recent retaining wall impacts to one of the sediment
basins.

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Site Visit Evaluation: Construction Site No. 2
Inspection Procedures
Does the MS4 inspector’s process include the use of a checklist?
Yes, see the Construction Site No. 2 folder.
Does the MS4 inspector’s process include taking photos?
Yes, see photos in the report in the Construction Site No. 2 folder.
Does the MS4 inspector’s process include reviewing approved plans (erosion and sedimentation control and/or SWPPP)?
Yes, the plan was reviewed throughout the inspection.
Does the MS4 inspector’s process include walking the entire site and inspecting all points of discharge?
Yes, the entire site was walked by the inspector, and all outfalls were viewed.
Did the MS4 inspector miss any obvious violations? If so, explain:
No
Does the MS4 inspector’s process include presenting the inspection findings to the site contact in writing?
Yes, the report will be emailed to the financial responsible parties and site contact s.
Does the MS4 inspector’s process include providing construction stormwater educational materials to the site contact?
Yes, stormwater information is provided during the preconstruction meeting for each site. NCG0100000 requirements and specifi c
site concerns are discussed during this initial site meeting with the site representatives.
Compliance/Enforcement
What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in?
The inspector had an onsite discussion with the grading superintendent to discuss the issues discovered during this site visi t. A Not
in Compliance report will be sent via email.
If compliance issues were identified, what timeline for correction/follow-up was provided?
A seven (7) day reinspection deadline was provided in the Not in Compliance report.
Notes/Comments/Recommendations
n/a

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Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1
Site Name:
Hampton Inn & Suites
N-0040-11
Date and Time of Site Visit:
April 4, 2022
1:53pm
Site Address:
3920 Arrow Drive
Raleigh, NC 27612
SCM Type:
Bioretention
Most Recent MS4 Inspection (Include Date and Entity):
Routine Inspection by staff (November 28, 2018)
Annual Certification Inspection (November 16, 2021)
Name of MS4 Inspector(s) evaluated:
Laura Johnson
Most Recent MS4 Enforcement Activity (Include Date):
Annual Certification Report accepted (December 9, 2021)
Name(s) and Title(s) of Site Representative(s) Present During the Site Visit:
Name Title
n/a n/a

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, see the most recent inspection report in the Post-Construction SCM No. 1 folder. Site is current on annual inspections dating
back to 2013. Yes, a qualified individual completed the annual inspection.
Inspector Training/Knowledge

What type of stormwater training does the MS4 inspector receive? How often?
SCM Inspection and Maintenance Certification; recertification every three years
Certified Floodplain Manager; renewal biennial
Illicit Discharge Detection and Elimination Training; every three years

Did the MS4 inspector appear knowledgeable about MS4 requirements for post-construction site runoff controls?
Yes
Did the MS4 inspector appear knowledgeable about post-construction BMPs (general purpose/function, components, O&M
requirements, etc.)?
Yes, she described common issues that are found during inspections and provided information on the SCM components.
Inspection Procedures
Does the MS4 inspector’s process include the use of a checklist or other standardized form? What format?
Yes, a digital fillable form, see the Post-Construction SCM No. 1 folder. Separate inspection forms have been created for each SCM
type.
Does the MS4 inspector’s process include taking photos?
Yes, see the inspection report in the Post-Construction SCM No. 1 folder.

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Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1
Does the MS4 inspector’s process include reviewing the site’s operation and maintenance plan and records of annual inspections?
Yes, prior to and after inspections, the O&M manual, internal inspections, and prior annual certifications are reviewed for site
information and previously noted areas of concern.
Does the MS4 inspector’s process include walking the entire site and inspecting all points of discharge?
Yes
Did the MS4 inspector miss any obvious operation and maintenance deficiencies ? If so, explain:
No
Does the MS4 inspector’s process include presenting the inspection findings to the site contact in writing?
Yes. The site contact is notified if a significant repair is noted or if the device is deemed as not functioning as designed. Comments
on the review of the annual certification submittal by the property owner is provided back to the site contact via email. Fai lure to
submit the annual certification results in a NOV being sent via certified mail.
Compliance/Enforcement
What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in?
None were required.
If compliance issues were identified, what timeline for correction/follow-up was provided?
n/a
Notes/Comments/Recommendations
The inspector noted several minor maintenance items during the site visit including the need to remove unwanted vegetation, s top
herbicide use, and the need to backfill a small hole on the embankment. These maintenance items will be addressed upon
submittal of the annual certification.

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Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 2
Site Name:
Northeast Remote Operations Center
N-0002-12
Date and Time of Site Visit:
April 6, 2022
10:25am
Site Address:
7702 Burwell Street
Raleigh, NC 27615
SCM Type:
Wet Pond
Most Recent MS4 Inspection (Include Date and Entity):
March 29, 2022 (Routine Inspection)
Name of MS4 Inspector(s) evaluated:
Daniel Kirsch
Pete Duffy
Most Recent MS4 Enforcement Activity (Include Date):
Annual Certification Report accepted (March 28, 2022)
Name(s) and Title(s) of Site Representative(s) Present During the Site Visit:
Name Title
Patrick Dickerson Interim Facility Superintendent

Observations
Site Documentation
Does the site have an operation and maintenance plan?
Yes, see the inspection report in the Post-Construction SCM No. 2 folder.
Does the site have records of annual inspections? Are they performed by a qualified individual?
Yes, the most recent inspection report in the Post-Construction SCM No. 2 folder. Site is current on annual inspections dating back
to 2018. Yes, a qualified individual completed the annual inspection.
Inspector Training/Knowledge

What type of stormwater training does the MS4 inspector receive? How often?
SCM Inspection and Maintenance Certification; recertification every three years
Illicit Discharge Detection and Elimination Training; every three years

Did the MS4 inspector appear knowledgeable about MS4 requirements for post-construction site runoff controls?
Yes
Did the MS4 inspector appear knowledgeable about post-construction BMPs (general purpose/function, components, O&M
requirements, etc.)?
Yes
Inspection Procedures
Does the MS4 inspector’s process include the use of a checklist or other standardized form? What format?
Yes, a Cityworks form is utilized and can be completed on a tablet for field use. Each inspection form is specific to the SCM device
type. See the inspection report in the Post-Construction SCM No. 2 folder.
Does the MS4 inspector’s process include taking photos?
Yes, photos are included as part of the Cityworks inspection form. See the Post-Construction SCM No. 2 folder.

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Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 2
Does the MS4 inspector’s process include reviewing the site’s operation and maintenance plan and records of annual inspec tions?
Yes. Currently inspection staff must coordinate with Stormwater Plan Review staff in instances where digital copies have not been
produced.
Does the MS4 inspector’s process include walking the entire site and inspecting all points of discharge?
Yes
Did the MS4 inspector miss any obvious operation and maintenance deficiencies ? If so, explain:
No
Does the MS4 inspector’s process include presenting the inspection findings to the site contact in writing?
The notification process is dependent on the site/facility due to shared ownership and maintenance responsibilities between
departments. Department-specific Service Level Agreements (SLAs) along with coordination with site/facility contacts provide
further guidance on notification of deficiencies. The minor maintenance concerns noted during this inspection will be addressed by
Stormwater staff. All inspections are stored within Cityworks and are available upon request.
Compliance/Enforcement
What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in?
Only minor maintenance issues (undesirable vegetation growth, riser structure leaking) were identified. A conversation with the
Interim Facility Superintendent occurred at time of site visit. Direct follow-up with the contractor by inspections staff is also
scheduled.
If compliance issues were identified, what timeline for correction/follow-up was provided?
Minor maintenance items were noted and will be reviewed at time of the next routine inspection.
Notes/Comments/Recommendations
Maintenance issues that were noted during the inspection included ant hills on the embankment slopes, pine trees and woody
growth beginning to take root in the vegetative shelf, and cattails were noted near the inflow structure.

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APPENDIX A: SUPPORTING DOCUMENTS

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APPENDIX B: SITE VISIT EVALUATION