NCS000249_Durham MS4 Self Audit_202204_plus site evals_20220506

MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PHASE I PROGRAM SELF -AUDIT REPORT
NPDES PERMIT NO. NCS000249
CITY OF DURHAM, NORTH CAROLINA
101 City Hall Plaza, Durham, NC 27701
Self -Audit Date: Sept -Dec, 2021, April 2022
Report Date: May 6, 2022
CITY OF
DURHAM

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: Marvin Williams
Title: Director of Public Works
Signature:
Date: 5/6/2022
* 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.
NCS000249 Durham 2022 MS4 Self -Audit

TABLE OF CONTENTS
Self -Audit Details...........................................................................................................................................1
PermitteeInformation..................................................................................................................................3
Listof Supporting Documents.......................................................................................................................4
Program Implementation, Documentation & Assessment.........................................................................11
Public Education and Outreach...................................................................................................................15
Public Involvement and Participation.........................................................................................................18
Illicit Discharge Detection and Elimination(IDDE)......................................................................................20
Construction Site Runoff Controls..............................................................................................................22
Post -Construction Site Runoff Controls......................................................................................................24
Pollution Prevention and Good Housekeeping for Municipal Operations.................................................30
Program to Monitor and Evaluate Stormwater Discharges to Municipal Systems....................................33
Water Quality Assessment and Monitoring................................................................................................35
Total Maximum Daily Loads(TMDLs).........................................................................................................39
Attachment A. Site Visit Observations
Supporting Documents (provided electronically)
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.
NCS000249 Durham 2022 MS4 Self -Audit iii

Self -Audit Details
Audit ID Number:
Self -Audit Date(s):
NCS000249_Durham 2022 MS4 Self -Audit
September — December 2021
April 5 — May 3, 2022
Minimum Control Measures Evaluated:
❑X Program Implementation, Documentation & Assessment
❑X Public Education & Outreach
❑X Public Involvement & Participation
❑X Illicit Discharge Detection & Elimination
❑X Construction Site Runoff Controls
❑X Post -Construction Site Runoff Controls
❑X Pollution Prevention and Good Housekeeping for Municipal Operations
❑X Program to Monitor and Control Pollutants
❑M Water Quality Assessment & Monitoring
Field Site Visits:
❑X Municipal Facilities. Number visited: 5
❑X MS4 Outfalls. Number visited: 2
❑X Construction Sites. Number visited: 2
❑X Post -Construction Stormwater Runoff Controls. Number visited: 3
❑M Other: Private Industrial Facility . Number visited: 2
❑N Other: Water Quality Monitoring Number visited: 1
❑N Other: IDDE Investigations . Number visited: 2
Auditors
Name
Title
Mark Senior, Amy Hathaway, Don Green
WK Dickson (under contract to the City of Durham)
Durham County Stormwater and Erosion Control Division
Ryan Eaves
Manager
Stormwater Development Review Supervisor (Public
Shea Bolick
Works)
Joseph Smith
Assessment and Monitoring Supervisor (Public Works)
Audit Report Author
Michelle Woolfolk
5/6/2022
Name
Date
Water Quality Manager
, , & Az
(�f/
Title
Signature
Audit Report Author
James Azarelo
5/5/2022
NCS000249_Durham 2022 MS4 Self -Audit Page 1 of 45

Name
Date
IDDE/Inspections Supervisor
Title
S nature
Audit Report Author
Laura Smith
5/6/2022
Name
Date
Public Education Coordinator
Title
Signature
Audit Report Author
Ryan Eaves
05/05/2022
Name
Date
Stormwater and Erosion Control Division Manager
Title
Sign
Audit Report Author
Jennifer Buzun
5/5/2022
Name
Date
Asst. Stormwater Development Review Supervisor
9!��
Title
Si nature
Audit Report Author
John Loperfido
5/5/2022
Name
Date
Asst. Water Quality Manager (EP&C Manager)
iGIL v .
Title
anature
Audit Report Author
William (Bill) Hailey
5/5/2022
Name
Date
SCM Maintenance Program Supervisor
Signature
Title
NCS000249_Durham 2022 MS4 Self -Audit Page 2 of 45

Permittee Information
MS4 Permittee Name:
City of Durham
Permit Effective Date:
October 10, 2018
Permit Expiration Date:
October 9, 2023
Mailing Address:
101 City Hall Plaza, Suite 3000
Durham, NC 27701
Date of Last MS4 Inspection/Audit:
USEPA (2005), USEPA 308 Request (2011)
Permit Owner of Record:
City of Durham, City Council
Primary MS4 Representatives Participating in Audit
Name
Title
Audrey Britton
Environmental Planning & Compliance (EP&C) Coordinator
Barbara (Jennifer) Buzun
Assistant Stormwater Development Review Supervisor
Benita Quick
Street Cleaning Supervisor, Public Works
David Milkereit
EP&C Coordinator
James Azarelo
IDDE/Investigations Supervisor (EP&C Analyst)
John (JV) Loperfido
Assistant Water Quality Manager (EP&C Manager)
John Sandin
Maintenance & Operations Supervisor, Stormwater Maintenance Section
Laura Smith
Public Education Coordinator
Melissa Harrison
EP&C Specialist
Michelle Woolfolk
Water Quality Manager (EP&C Sr Manager)
Mikel Corporaal
EP&C Coordinator
Phillip Powell
Assistant Director of Public Works
Sam Jackson
Engineering Specialist
Sean McKnight
GIS Analyst Supervisor
Terrence King
Maintenance and Operations Manager, Public Works
William (Bill) Hailey
SCM Maintenance Program Supervisor
NCS000249_Durham 2022 MS4 Self -Audit Page 3 of 45

List of Supporting Documents
Item
Number
Document Title
Document Format
(web link, e- file, etc.)
Al
A1_NCS000249 Durham Application and SMP 2017.pdf
PDF
https://www.durhamnc.gov
A2
A2_ NCS000249 Durham SMP-2020.pdf
PDF
https://www.durhamnc.gov
A3
A3_NCS000249 Durham NPDES Annual Report FY2019.pdf
PDF,
https://www.durhamnc.gov
A4
A4_ NCS000249 Durham NPDES Annual Report FY2020.pdf
PDF
https://www.durhamnc.gov
A5
A5_ NCS000249 Durham NPDES Annual Report FY2021.pdf
PDF
https://www.durhamnc.gov
A6
A6_NCS000249 Durham Performance Rev v10.xlsx
MS Excel
A7
A7_NCS000249 Durham Stormwater Dashboard
PDF
A8
A8_NCS000249 Stormwater DataHub Measures
PDF
A9
A10_Letter from NCDEQ regarding Annual Report Schedule
PDF
B1
Pub Ed Database
mdb Access database
B2
Contact Us page 692
png web screenshot
B3
Waterways page 708
png web screenshot
B4
CWEP MOU
PDF
B5
Business Outreach Materials List
Excel file
B6
Database report 2019-2021
png database report
screenshot
B7
SOP Pub Ed
PDF
B8
BusinessOutreachSOP
PDF
B9
STAR BusinessRecognitionProgramSOP
PDF
B10
Databse_screenshot
png database screenshot
NCS000249_Durham 2022 MS4 Self -Audit Page 4 of 45

1311
Outreach Handouts Data
Excel File
B12
Hotline brochure
PDF
B13
Hotline —video
png video screenshot
B14
Facebook_hotline
png Facebook screenshot
C1
SOP Pub Involvement
PDF
C2
EABAgenda_06Jan21
PDF
C3
PA-5-1
PDF
C4
Clerks office public notice
png web screenshot
C5
Public Access to SWMP durhamnc.gov
jpg web screenshot
D1
D1 - Durham Stormwater Management and Pollution Control Ordinance
PDF
D2
D2 - Durham GoMaps
Link
D3
D3 — IDDE Investigations Guidelines (April 2022). pdf
PDF
D4
D4 — Dry Weather Screening Guidelines
PDF
D5
D5 — Dry Weather Screening Annual Plans (folder containing annual plan
documents)
MS Word
D6
D6 — Water Quality Enforcement Guidelines (April 2022).pdf
PDF
D7
D7 — IDDE Staff Training (folder containing sub folders with training documents,
new employee primer, training organizer, and WQ Overview for new hires)
MS Word, MS Powerpoint
D8
D8 -
D9
D9 — Outfall Screening Data 10-10-18 to 4-27-22.xlsx
Excel data file
D10
D10 - Durham Outfall Screening Form 2019 v12.19.19.pdf
PDF
NCS000249_Durham 2022 MS4 Self -Audit Page 5 of 45

E1
E1_ Durham Co enforcement of Sed&Ero in City — 1984.pdf
PDF
E2
E2_Sedimentation CC Minutes 8.22.17_Approved. pdf
PDF
E3
E3_2022-03-31 list of Locally Delegated S&E Programs.pdf
PDF
E4
E4_Joint City -County Memo City and County Stormwater.pdf
PDF
Link
F1
F1_Stormwater Development Review Website
Webpage information, Link
F2
F2_Ordinances (folder)
PDF, MS Word
F3
F3_SCM Tool (folder)
MS Word, MS Excel
F4
F4_City of Durham Falls Lake Annual Report 2020-2021
MS Word, MS Excel and PDF
F5
F5_Reference Guide for Development 2022-02-18.pdf
PDF
F6
F6 Archived State Stormwater BMP Manual.docx
MS Word
F7
F7_Addendum to DEQ Manual — 14March 2021.pdf
PDF
F8
F8_Annual SCM Inspections (folder)
MS Word and PDF
F9
F9_SCM Compliance and Enforcement Guidelines Draft (January 2022)
PDF
F10
F10_SCM 0&M (folder)
PDF
F11
F11_Long-term Storage of SCM Designs (folder)
MS Word and PDF
F12
F12_Resources for SCM Owners (folder)
PDF
F13
F13_O&M SWTAs, CC&Rs, Plats (folder, with subfolders)
PDFs, MS Word
F14
F14_Financial Guarantees for SCM Maintenance (folder)
MS Word
F15
F15_Website_SCM As -Built & BMC(Maintenance) Programs.pdf
PDF
F16
F16_(number intentionally skipped)
F17
F17_Quarterly Seminars.pdf
PDF
NCS000249_Durham 2022 MS4 Self -Audit Page 6 of 45

F18
F18_Contractor Training (folder)
MS Word, PDF
F19
F19_Linear Projects (folder)
F20
F20_2020-2021 Neuse Annual Report (folder)
F21
F21_II.F.5 Permittee Projects (DATA WP1 00714) (folder)
F22
F22_Example Notice of Concern Offense Breach — SCM Maintenance Certifier
Program.pdf
Electronic file, PDF
F23
F23_LTI (22May2019) Ordinance Amendments & Revisions to RGD.pdf
Electronic file, PDF
F24
F24_Stormwater Logbook (Database) (as builts, CDs, site plans, stream ID)
current as of 2021-08-06.xlsx.
Electronic file, MS Excel
F25
F25_SCM Tool (Database)
Must be viewed remotely
with staff
F26
F26_SW Financial Accounts (Database) (current as of 16Aug2021).xls
Electronic file, MS Excel
F27
F27_SCM Performance Guarantees (Database) (current as of 16Aug2021) As
Electronic file, MS Excel
F28
F28_SCM Compliance Tracking (Database)
BMC Compliance Tracking FY 2018.xlsx, FY2019, FY2020, FY2021
Electronic files, MS Excel
F29
F29_Land Development Office (LDO) (Database -output)
(multiple subfolders and documents in PDF and doc format)
Must be viewed remotely,
with staff.
G1
Municipal Facilities and Operations
Excel
G2
Stormwater Inspection Program Guidelines
PDF
G3
Municipal Facility Inspections Oct 2018-Apr 2022
Excel
G4
Facility Compliance Documentation (multiple files in folder)
Word, PDF, Excel
G5
Staff Training (multiple files in folder)
Word, PDF, Excel,
PowerPoint
G6
G6_ City of Durham Operation and Maintenance Plan.pdf
PDF
G7
G7_ SD-2021-06_Drainage System Inspection_18592-low res.pdf
PDF
G8
G8_Street Sweeping Maps (images in folder)
PDF
G9
G9_27.15-
002_SOP_DrainageSystemMaint_Problem_Site_Maint_Rev20200420_Signed.pd
PDF
NCS000249_Durham 2022 MS4 Self -Audit Page 7 of 45

G10
G10 ParkDurham Maintenance Matrix— Revised October 2020.docx
MS Word
G11
G11_RFP 20-0030 Parking Garage Pressure Washing— February 7, 2020.docx
MS Word
H1
H1 - Inventory of SARA T3 Facilities
Excel
H2
H2 - Inventory of NPDES Permitted Facilities
Excel
H3
H3 - Stormwater Inspection Program Guidelines
PDF
H4
H4 - Inspections List Oct 2018-Apr 2022
Excel
I-1
www.durhamwaterquality.org
Web Link
1-2
Ambient Water Chemistry Monitoring Program Quality Assurance Project Plan
PDF
1-3
Ambient Monitoring Plan for Calendar Years 2018-2022 (compiled)
PDF
1-4
Water Quality Web Portal_Userguide
PDF
1-5
2018- 2022 USGSstreamgagesDurham
Excel Spreadsheet
1-6
2018-2022 StaffGaugeSites
Excel Spreadsheet
1-7
2017-2019 U.S. Geological Survey Joint Funding Agreement for Water Resource
Investigations; 2019-2021 U.S. Geological Survey Joint Funding Agreement for
PDF
1-8
Benthic Monitoring Site List_2018-2022
Excel Spreadsheet
1-9
Benthic Macroinvertebrate monitoring study plan for Calendar Years 2018-2022
(compiled)
PDF
1-10
Ambient Site List 2018-2022
—
Excel Spreadsheet
1-11
Evaluation of Pollutants in Street Particulate Matter Collected by a Municipal
Street Sweeping Program in Durham, NC
PDF
1-12
Trend Analysis Summary Sheet for Eno River (2004-2018)
PDF
1-13
New Hope Creek and Little Creek Watershed Assessment Report Final, October
2020
PDF
NCS000249_Durham 2022 MS4 Self -Audit Page 8 of 45

1-14
Standard Operating Procedures for Benthic Macroinvertebrate Community
Monitoring
PDF
1-15
Water Quality Trend Analysis Standard Operating Procedures
PDF
1-16
Standard Operating Procedures for Field Measurements and Observations
PDF
1-17
Standard Operating Procedures for Water Quality Field Meter Calibration and
Maintenance
PDF
1-18
Standard Operating Procedures for Use of Peristaltic Pumps for Sample
Collection
PDF
1-19
Standard Operating Procedures for Sampling Station ID Naming
PDF
1-20
Procedure for Determining Wadeable Stream Discharge with Hand-held current
PDF
meters
Standard Operating Procedures for Water Chemistry Sampling
I-21
PDF
Standard Operating Procedures for Water Sample Filtration
I-22
PDF
Standard Operating Procedures for the Calendar Year Water Quality Summary
I-23
Table
PDF
Assessment and Monitoring Workflow
I-24
PDF
Ambient Sampling Audits 2018-2022
I-25
PDF
Timeline of Ambient Troubleshooting, July 2020 to April 2021
I-26
PDF
Investigation Trigger Levels
I-27
PDF
Laboratory Quality Assurance Split Sampling Study-2020
128
PDF
New Hope Creek & Little Creek Watershed Improvement Plan SCM Inventory
I-29
and Assessment Field Plan, December 2019
PDF
Summary of Existing Stream Sediment Chemistry Data in Durham County, NC
I-30
and Surrounding Counties
PDF
Water Quality Pollution Source Tracking in Sandy Creek Tributary A and Warren
I-31
Creek, Interim Memo - Sandy Creek Tributary A
PDF
Water Quality Pollution Source Tracking in Sandy Creek Tributary A and Warren
I-32
Creek, Interim Memo - Warren Creek
PDF
Ellerbe Creek Beaver Dam Study Report
I-33
PDF
Brier Creek, Lick Creek, and Stirrup Iron Creek Watershed Study (Project 20
I-34
002)- Final Report
PDF
Long Term Streamflow (LTSF) Data folder: field, cross-section, discharge, logger
I-35
data
multiple
NCS000249_Durham 2022 MS4 Self -Audit Page 9 of 45

I-36
(Two documents in pdf) Memorandum of Agreement Among The State of North
Carolina's Division of Water Resources, The Upper Cape Fear River Basin
PDF
1-37
https://www.wunderground.com/dashboard/pws/KNCDURHA385
Web Link
I-38
Weather station data 01/01/2018 to 02/29/2020
Excel Spreadsheet
1-39
http://monitor.unrba.org/
Web Link
I-40
Groundwater/Surface-Water Interactions Along Ellerbe Creek in Durham, North
Carolina, 2016-18
PDF
1-41
Northeast Creek Microbial Source Tracking Study - Final Project Report
PDF
1-42
Duke Trash Survey Report
PDF
1-43
Manure Spill Summary Report for Rocky Branch Creek
PDF
1-44
Ellerbe Creek Watershed Summary Report
PDF
1-45
Third Fork Creek Watershed Summary Report
PDF
1-46
Box Plots & WQI Summaries of Three Sites
PDF
1-47
CY2020 Stream Miles Suitable for Human Contact
PDF
1-48
Modifications to Water Quality Index scoring of dissolved oxygen data to
remove natural seasonal trends
PDF
1-49
Summary of 6-Year Stream Bank Erosion Monitoring Results and Development
of Bank Erosion Rate Curves
PDF
1-50
Standard Operating procedures for Hydrologic Model Storage
PDF
1-51
Root Dendrogeomorphology Analysis and Results
PDF
1-52
Sediment Toxicity Study Sediment Chemistry Data
PDF
1-53
Sediment Toxicity Study Grain Size Analysis
PDF
1-54
Sediment Toxicity Study Midge Deformity Memo
PDF
1-55
2019 Interim Report
PDF
1-56
Long Term Streamflow Monitoring (Project 09-010) Annual Report- CY 2021
PDF
1-57
CY 2019 Report — Long Term Streamflow Monitoring
PDF
NCS000249—Durham 2022 MS4 Self -Audit Page 10 of 45

1-58
Sandy Creek Watershed Study Final Report (draft form from2019)
PDF
1-59
YSI ProPlus Meter Calibration/ Post Check Sheet
PDF
J1
J1-Northeast Creek TMDL Final
PDF
J2
J2-Haw,Deep,etc.TurbidityFecalTMDL
PDF
J3
J3-Northeast Creek TMDL Response Plan —FINAL
PDF
J4
J4-Third Fork Creek TMDL Response Plan —FINAL
PDF
J5
J5-Major Outfalls Maps - TFC & NEC
PDF
J6
J6-Northeast Third Fork Trends 2019-2021
PDF
J7
J7-TMDL Dash boa rd_2020.11.10
Excel Spreadsheet
J8
J8- J8-StormWaterSOP-20220404
PDF
Program Implementation, Documentation & Assessment
Staff Interviewed:
Michelle Woolfolk
(Name, Title, Role)
Manager, Stormwater Quality
City of Durham, Public Works Department, Stormwater & GIS Services Division
Oversees the City's water quality and NPDES Permit program
[e-mail] I Phone: [phone] x30219
Permit Citation
Program Requirement
Status
Supporting
Doc No.
II.A.
The permittee maintained adequate legal mechanisms, such as regulations,
D1, F1,
Program
ordinances, policies and procedures to implement all provisions of the Stormwater
Yes
Implementation
Management Plan (SWMP).
F2, F23-
A3, A4,
The permittee implemented provisions of the Stormwater Management Plan and
AS, A6,
evaluated the performance and effectiveness of the program components annually.
Yes
A7, A8,
J7
NCS000249_Durham 2022 MS4 Self -Audit Page 11 of 45

Program Implementation, Documentation & Assessment
B7, B8,
B9, C1,
D3, D4,
D6, G2G2,
,
The permittee maintained written procedures for implementing the six minimum
H3,
control measures, which identify specific action steps, schedules, resources and
Yes
115, 116,
responsibilities.
117, 118,
119, 120,
121, 122,
123, J8
The permittee is current on payment of invoiced administering and compliance
monitoring fees (see stormwater e-payments on https.Ildeq.nc.govlsw).
Yes
---
Comments
• Legal mechanisms are provided in multiple locations of the city code, as referenced in each section below.
• Procedures to implement the SWMP are implemented as part of the permit and are described in relevant sections below.
• SWMP Program performance and effectiveness are reviewed at monthly to annually. Frequency of program review depends
upon the program. Performance and effectiveness measures are reviewed and updated at least once per permit cycle. Of the
supporting documents provided, some measures are repeated. For example, the "# of pollution sources controlled" appears in
A6, A7 and A8. Some measures are also included in the annual report. (A3, A4, A5)
• Most recent payment made via check on March 11, 2022.
III.
The permittee maintained documentation of all program components including, but
Program
not limited to, inspections, maintenance activities, educational programs, monitoring
A3, A4,
Documentation
and sampling, implementation of BMPs, enforcement actions and other stormwater
Yes
AS ---
activities.
Documentation is kept on -file by the permittee for a period of five (5) years.
Yes
---
The permittee's Stormwater Management Plan is reviewed and updated as
Yes
Al, A2---
necessary, but at least on an annual basis.
Comments
• The retention policy states "Retain in office permanently 1 copy of all annual and biennial reports written by the agency.", and
"Retain in office permanently reports and studies prepared by request of an agency's governing body or a court" which
includes all annual reports and SWMPs, and any other reports prepared for the NPDES Permit or SWMP.
• Records of program components are maintained at City Hall. To the extent possible, records are maintained electronically.
• The SWMP is reviewed annually by supervisors and managers to determine if an update is needed. If an update is needed, a
schedule is developed to prepare the update.
IV.B.
-A3, A4,
Annual Reporting
The permittee submitted annual reports to the Department by October 31st of each
Yes
A5 A10-
'
calendar year for the previous fiscal year's activities (from July 1st to June 30tn)
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:
NCS000249_Durham 2022 MS4 Self -Audit Page 12 of 45

Program Implementation, Documentation & Assessment
a. A detailed description of the status of implementation of the Stormwater
Management Plan. This includes information on development and Yes A3, A4,
implementation of each major component of the Stormwater Management Plan AS
for the past year and schedules and plans for the year following each report.
b. A description and justification of any proposed changes to the Stormwater
Management Plan. This includes descriptions and supporting information for the Yes A3, A4,
proposed changes and how these changes will impact the Stormwater AS
Management Plan (results, effectiveness, implementation schedule, etc.).
c. Documentation of any necessary changes to programs or practices for A3, A4,
assessment of management measures implemented through the Stormwater Yes
A5
Management Plan.
d. A summary of data accumulated as part of the Stormwater Management Plan Yes A3, A4,
throughout the year along with an assessment of what the data indicates. AS
e. An assessment of compliance with the permit, information on the establishment Yes A3, A4,
of appropriate legal authorities, inspections, and enforcement actions. AS
f. Discussion of program funding. Yes A3, S
A4,
Comments
• Annual Reports were delivered as required, with modifications to schedule as described in A10.
• Development and implementation of past year information is contained within the Annual Reports. Schedules and future
plans for the following year are contained within a subset of measures.
• Program assessments are performed annually and summarized in the respective sections of the Annual Reports.
Assessments may be qualitative or quantitative.
• Program funding is summarized annually in the Annual Reports. This includes a summary of the overall Stormwater
Program Fund (from the City Budget Book) and Capital Improvement Program (CIP) budgets.
• Proposed changes to the SWMP are described in the Annual Reports (A3-A5) within each measure, if appropriate.
N.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
D3, D11,
D12, D13
3
D6,
D ,
The record includes dates, identification of possible responsible parties, causes, and
Yes
any action taken by the permittee or the responsible party.
D12,1,
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
133, D11,
business hours, or to the NC Division of Emergency Management State Operations
Yes
D12, D13
Center hotline outside of business hours.
NCS000249_Durham 2022 MS4 Self -Audit Page 13 of 45

Program Implementation, Documentation & Assessment
Comments
• All IDDE investigations are recorded in the IDDE Database (D11, D12, D13). This includes IDDE investigations where it has
been determined that waste material reached waters of the state and may cause or contribute to a violation of the water
quality standards. Procedures are described in guidelines (D3)
• The IDDE database includes information regarding the type of pollutant, the responsible party, each point of contact with
the responsible party, what corrective actions are required, when those actions should be completed, and final disposition
of the investigation. (D3) Procedures for conducting and documenting enforcement are described in D6.
• The IDDE database contains investigations that are responded to by Durham County Emergency Management.
Investigations that are reported to state Emergency Management are recorded in the database (D11, D12, D13)
Additional
Comments:
NCS000249_Durham 2022 MS4 Self -Audit Page 14 of 45

Public Education and Outreach
Staff Interviewed:
Laura Webb Smith
(Name, Title, Role)
Public Information and Communications Analyst
City of Durham, Public Works Department, Stormwater & GIS Services Division
[e-mail] I Phone: [phone], Ext. *30235
Interviewed by Marla Hill (PEQ) and Amy Hathaway, PE (WK Dickson) on October 6, 2021
Permit Citation
Program Requirement Status Supporting
Doc No.
II.B.2.a.
The permittee described the target pollutants and target pollutant sources that the
Target Pollutants
Yes ��---
public education program is designed to address and why they are an issue.
& Sources
Comments
• Target pollutants, their sources and impacts are identified in the City of Durham Stormwater Management Plan (SWMP),
sections 7.2.1-7.2.3; these sections summarize the pollutants, sources and audiences for stormwater education and outreach.
• The SWMP appendix identifies pollutants, sources, and target audiences. The appendix also includes a review of recent water
quality monitoring results and NC Basin Plan Assessments. Appendix B includes Total Maximum Daily Load Response Plan for
Northeast Creek and Third Fork Creek Watersheds and provides watershed -specific discussion of pollutants.
• The Stormwater & GIS Division website (https://durhamnc.gov/692/Stormwater-GIS-Services) and Facebook page (https://www.facebook.com/
durhamncstormwater) both feature advice to homeowners for managing pollutants from private and residential property.
• The website includes business -focused instructions on preventing and cleaning up identified pollutants.
The website includes a pollution prevention page (https:Hdurhamnc.gov/3218/How-to-Prevent-Water-Pollution) that further describes possible
pollutants and provides methods for reporting, including telephone hotline, web -based form, email address.
II.B.2.b.
The permittee described the target audiences likely to have significant Stormwater
Target Audiences
impacts and why they were selected.
Yes
Comments
• Stormwater Management Plan lists target audiences in section 7.2.3
• City of Durham's website lists types of businesses and activities that generate pollutants and that may contribute to
stormwater pollution by leakage or improper disposal (using storm drains). These include waste containment vendors, cleanup
contractors, automotive/vehicle maintenance, directional drilling, construction, landlords, landscaping, mobile vehicle washing,
painters, power (surface) washing, and restaurants (https:Hdurhamnc.gov/3218/How-to-Prevent-Water-Pollution, see section Prevent
Pollution on the Job).
• Website provides guidelines and best practices for target businesses and activities, identifying the pollutants discharged and
proper disposal methods.
Guidance is provided for businesses required to have a NPDES permit or Stormwater Pollution Prevention Plan (SPPP) (https://nc-
durham.civicplus.com/DocumentCenter/View/2907).
I I. B.2.c.
The permittee promoted and maintained an internet web site designed to convey the
Informational
program's message.
Yes
Web Site
NCS000249_Durham 2022 MS4 Self -Audit Page 15 of 45

Public Education and Outreach
Comments
• The City of Durham stormwater website (https:Hdurhamnc.gov/692/stormwater-GIs-services) provides information on pollutants,
pollution sources, and pollution prevention measures (described in II.B.2.a and II.B.2.b, above), regular updates on Division
activities, a semiannual Waterways newsletter, annual State of our Streams reports, annual NPDES reports, watershed
information, development review, stormwater control measure (SCM) maintenance, SCM design/plan review, drainage
problems, flooding, floodplain information, utility fee information, water quality, watershed planning, and implementation
projects, most recent submittal of permit, and annual report on performance data. The most recent posted version of the
SWMP was edited and updated in April 2019.
• Key contacts for assistance or further information are listed by stormwater management category.
• Three methods are provided for residents to report illicit discharge and for pollution prevention assistance — hotline, online
form, and email address.
• Website is designed for ADA accessibility. Details and guidelines on web accessibility are provided (https://durhamnc.gov/4389)
• Website is written to ensure readability at 8th grade level. Consultant auditor confirmed through grade level and readability
analysis. Results as follows: Grade Level: 8; Reading Level: standard / average; Reader's age: 12-14 years old (7th/8th grades)
(https://readabiIityformuIas.com/freetests/six-readability-formuIas.php)
• Website offers translation services for Spanish-speaking residents.
11.B.2.d.
The permittee distributed general stormwater educational material to appropriate
B3, B4,
Public Education
target groups as likely to have a significant stormwater impact.
Yes
135, 1311
Materials
Comments
• The Waterways newsletter is mailed with the July and November water bills. Topics are oriented toward pollution generating
activities such as yard care, car care and pet waste, as well as illicit discharge identification. Volunteer opportunities (e.g.,
stream clean-ups) and updates on stormwater capital projects are also provided.
• Brochures, fact sheets, infographics, and postcards are distributed to pollution -generating sources.
• Printed materials produced by Clean Water Education Partnership (CWEP)1 and distributed by the City of Durham include a full -
color brochure that targets the general public and covers topics such as pet waste, vehicle maintenance, lawn chemicals,
household hazardous waste, litter, and yard waste.
At local festivals and other events, the City uses display materials to educate the general public about water pollution, stormwater
runoff, and the Stormwater Services Division. Targeted message brochures, giveaways promoting the hotline and other messages,
hands-on education models, including the Enviro5capeT", a PlinkoT^" game board, or a storm drain model, are also made available at
public events.
II.B.2.e.
The permittee promoted and maintained a stormwater hotline(s) or helpline(s) for
stormwater
the public to request information about stormwater, public involvement &
yes
Hotline
participation, and to report illicit connections & discharges, etc.
1 The City funds and actively participates in the CWEP steering committee.
NCS000249—Durham 2022 MS4 Self -Audit Page 16 of 45

Public Education and Outreach
Comments
• The City of Durham established a stormwater pollution hotline (919-560-SWIM) for the public to report illicit connections and
discharges. The hotline is promoted on the website, through messages periodically included in the City Manager's Report, and
in the Waterways newsletter distributed twice a year with utility bills.
• The hotline number is imprinted on various items that are distributed at public events, such as reusable straws, badge clips,
pens, ice scrapers, rain gauges, and toys.
• Short videos, posted on YouTube, government channel DTN, and through social media, instruct residents on when to call the
hotline. A one -page brochure on identifying and reporting pollution includes the hotline number and group email address
which the public can use for reporting.
• Stormwater Staff members provide giveaways, handouts, and/or decals for City workers to put in their work vehicles.
Stormwater staff track and log hotline calls from receipt to resolution.
II.13.2.f.
Public Education
The permittee's outreach program, including those elements implemented locally or
B7, 68,
through a cooperative agreement, include a combination of approaches designed to
Yes
B9, 64
& Outreach
reach the target audiences.
Program
Implementation
For each media, event or activity, including those elements implemented locally or
131, 66,
through a cooperative agreement, the permittee estimated and recorded the extent
Yes
1310,
of exposure.
1311, B3-
Comments
• The City of Durham has employed a combination of events, activities, media outreach and written communication to keep the
public informed about the importance of reducing the impact of their activities on stormwater quality. With changes
necessitated by the COVID-19 pandemic, beginning in late March 2020, the number of in -person activities decreased
temporarily, but the media outreach and distribution of written materials continued.
• News releases on events, projects, clean-ups, other stormwater-related information sent to all local media outlets,
neighborhood listservs and individual subscribers. News summaries are published in City Manager's Report.
• Stormwater topics submitted to "Bull City Today" daily news brief featured on social media.
• BMP presentation available on website (https://durhamnc.gov/documentcenter/view/3096) offers specific guidance on reducing the
opportunity for stormwater runoff to be exposed to pollutants through erosion control measures, flood prevention, etc.
• Clean Water Education Partnership (CWEP) Media Campaign — Partially funded by the City of Durham, aims to protect North
Carolina's waterways from stormwater pollution through public education and outreach, including broadcast and online ads, a
cinema campaign, regular website updates, social media posts, an in -person educational outreach program, Spanish -language
newspaper ads and new distance -learning.
• CWEP Annual Report is published to nc-cleanwater.com website.
Additional
The City of Durham has added the following elements to the SOP for public education and outreach.
Comments:
• Pet waste pickup campaign
• Online educator workshops and school presentations
• Newsletter for businesses to highlight pollution prevention best practices
Re-evaluate past methods such as direct mailings and evaluation efforts on businesses currently enrolled in
the recognition program
NCS000249—Durham 2022 MS4 Self -Audit Page 17 of 45

Public Involvement and Participation
Staff Interviewed:
Laura Webb Smith
(Name, Title, Role)
Public Information and Communications Analyst
City of Durham, Public Works Department, Stormwater & GIS Services Division
[e-mail] I Phone: [phone], Ext. *30235
Permit Citation
Program Requirement Status Supporting
Doc No.
II.C.2.a.
Volunteer
The permittee included and promoted volunteer opportunities designed to promote
Community
Yes
Involvement
ongoing citizen participation.
Program
Comments
• The City of Durham maintains a volunteer community involvement program. Example activities include stream clean-ups
(including Big Sweep (held in fall), Creek Week (cancelled 2020 due to COVID-19), and the Adopt -a -Drain program. The clean-
up program has recruited 659 volunteers and removed 16,653 pounds of trash in its last full year of operation. Total number of
drains adopted —164.
• Stormwater personnel work with residents who have participated in green infrastructure programs, including a mechanism to
transfer information and encourage cooperation of new occupants.
• The City of Durham works with Trees Across Durham and Keep Durham Beautiful, which enlist the public's participation in tree
planting and maintenance in public spaces.
• The City of Durham funds residential rain gardens, cisterns, and downspout disconnections through Soil and Water
Conservation District's Community Conservation Assistance Program; the program requires the voluntary cooperation and
involvement of residents.
II.C.2.b.
Mechanism for
The permittee provided and promoted a mechanism for public involvement that
B2, C1,
Public
provides for input on stormwater issues and the stormwater program.
Yes
C2
Involvement
Comments
• The City of Durham establishes, promotes, and maintains a pollution reporting hotline (919-560-SWIM) for public reporting of
illicit discharges. The public may also use a dedicated email address or online form to report illicit discharges.
• Stormwater personnel attend Environmental Affairs Board meetings to get public input on the MS4 permit, answer questions
from the public, make announcements, and make presentations on relevant topics.
• Social media accounts (Facebook, Twitter, YouTube) offer opportunity for the public to offer feedback or ask questions.
• The Stormwater Management Plan and annual reports are on the Stormwater Division website, and public input is encouraged
for inclusion in annual updates.
• The City of Durham follows state and city public notice requirements for rate changes and projects. Permittee complies with
City policy and state law mandates on public hearings, which must be held prior to changes in stormwater utility rates.
• The public is invited to review operational and CIP budgets, which are posted to the Stormwater Division website.
• The City of Durham holds public meetings to solicit public comment from stakeholders when significant changes in stormwater
ordinances are proposed. The Durham City -County Planning Department has a public process for making changes to the
Unified Development Ordinance.
• Permittee uses the City's Equitable Community Engagement Blueprint as a guide to set goals, identify level of engagement,
identify community partners, and develop strategy. (https://www.durhamcommunityengagement.org/equitable_engagement).
NCS000249—Durham 2022 MS4 Self -Audit Page 18 of 45

Public Involvement and Participation
II.C.2.c.
The permittee promoted and maintained a hotline/helpline for the public to request
131, 66,
Hotline/Help Line
information about stormwater, public involvement & participation, and to report
Yes
1312,
illicit connections & discharges, etc.
B13, B14
Comments
• The City of Durham established a stormwater pollution hotline (919-560-SWIM) for the public to report illicit connections and
discharges. The hotline is promoted through messages periodically included in the City Manager's Report and in the
Waterways newsletter distributed twice a year with utility bills.
• The hotline number is imprinted on various items that are distributed at public events, such as reusable straws, badge clips,
pens, ice scrapers, rain gauges, and toys.
• Short videos, posted on YouTube, government channel DTN, and through social media, instruct residents on when to call the
hotline. A one -page brochure on identifying and reporting pollution includes the hotline and the group email address which
the public can use for reporting.
• Stormwater Staff members provide giveaways, handouts, and/or decals for City workers to put in their work vehicles.
• Stormwater personnel track and log hotline calls from receipt to resolution.
II.C.2.d.
The permittee made the most recent Stormwater Management Plan available for
Public Comment
public review and comment.
Yes
Comments
Stormwater Management Plans are posted to the City of Durham's website for public review and comment.
(https://durhamnc.gov/DocumentCenter/View/33415/SW MP-2018-final-small)
II.C.2.e.
The permittee complied with State, Tribal and local public notice requirements when
131, C3,
Public Notice
implementing the public involvement / participation program.
Yes
C4, 136
Comments
• Follow City Policy PA-5-1 to notify residents, businesses, and community groups when any City service, park, road or facility is
affected or unavailable due to extended maintenance, construction or planned events as well as projects that have
other impacts on private property.
• Work with Clerk's Office to follow all State public notice laws.
• The City of Durham uses its Equitable Community Engagement Blueprint as a guide to set goals, identify level of engagement,
identify community partners, and develop Strategy. (https://www.durhamcommunityengagement.org/equitable_engagement).
Additional
The City of Durham holds 2-3 Public Input and Information Sessions for each Watershed Improvement
Comments:
Plan. Stormwater Division staff share plan goals and findings and gather input from residents on
observed water quality issues, community priorities, and locations for potential projects. In -person and
online surveys are part of the sessions. Input gathered from the public is communicated back to
residents through status updates, survey summaries, and future information sessions.
• The City maintains a database of all public involvement encounters. These are logged by Stormwater
Division staff and tracked from receipt to resolution.
• The City altered some public involvement programs during the pandemic and increased use of virtual
platforms. Examples include virtual volunteer training, online Creek Week programs, and virtual
meetings to interact with stakeholders.
• Virtual platforms are in place for use under non -emergency conditions and may increase participation by
members of the public who are unable to attend in -person meetings.
NCS000249_Durham 2022 MS4 Self -Audit Page 19 of 45

Illicit Discharge Detection and Elimination (IDDE)
Staff Interviewed:
Dave Milkereit
(Name, Title,
Environmental Program Compliance Coordinator
Role)
City of Durham, Public Works Department, Stormwater & GIS Services Division
[e-mail]
Interviewed by Mark Senior, PE and Amy Hathaway, PE on October 7, 2021
(Dave resigned from the unit in May, 2022)
Permit Citation
Program Requirement Status Supporting
Doc No.
II.D.2.a.
The permittee maintained adequate ordinances or other legal authorities to prohibit
Legal Authorities
Yes
illicit connections and discharges and enforce the approved IDDE Program.
Comments
The City's Stormwater Management and Pollution Control Ordinance was passed by City Council in November 2006. Section 70-511
of this ordinance prohibits illicit discharges. Section 70-512 prohibits illicit connections. Sections 70-513 through 70-518 additionally
state duties, requirements, and other prohibitions aimed at preventing stormwater pollution. Section 70-538 authorizes the
Director of Public Works (or designee) to administer a stormwater pollution control program and use all of the enforcement
remedies outlined in section 70-540.
II.D.2.b.
The permittee maintained a current map showing major outfalls and receiving
MS4 Mapping
streams.
Yes
Comments
The City maintains geodatasets of surfacewaters and stormwater utility features, including all pipes, inlets, outlets, and other
structures. A public -facing version is available at https:Hmaps.durhamnc.gov/gomaps/. Major outfalls are isolated from their larger
feature dataset through use of a customized spatial join and query process. Internally, staff use a combination of ArcMap (desktop),
ArcGIS Online, and ESRI mobile explorer to prepare datasets, maps, and outfall screening plans.
I I. D.2.c.
The permittee maintained written procedures and/or Standard Operating Procedures
D3/D4,
Dry Weather Flow
(SOPS) for detecting and tracing the sources of illicit discharges.
Yes
D10
Program
The permittee maintained written procedures and/or Standard Operating Procedures
D3/D4/D
(SOPS) for removing the sources or reporting the sources to the State to be properly
Yes
permitted.
6
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
Yes
inspections.
Comments
Written Water Quality Unit procedures for IDDE investigations, dry weather outfall screening, and enforcement were established
prior to the current permit period. Multiple procedures documents were updated or revised during the permit period. The outfall
screening guidance document (D4) incorporates via reference additional annual plans (D5) customized for each screening session.
Annual plans specify screening timeframes, target areas, and goals for staff. Screening goals are additionally formalized for staff in
semiannual job performance documentation. The Water Quality Enforcement Guidelines document (D6) describes methods for
using various enforcement powers and remedies for removal of pollutant sources identified by the IDDE program.
*Major outfalls are discharges from > 36" diameter pipes or drainage areas of > 50 acres. In areas zoned for industrial activity, major outfalls
are > 12" or drainage area > 2 acres.
NCS000249_Durham 2022 MS4 Self -Audit Page 20 of 45

Illicit Discharge Detection and Elimination (IDDE)
II.D.2.d.
The permittee conducted training for appropriate municipal staff on detecting and
Yes
D7/U
Employee Training
reporting illicit connections and discharges.
Comments
IDDE staff, upon start of employment are guided through fundamentals training in investigations, dry weather screening,
inspections, and enforcement (as their role dictates). A New Employee Primer document was created to guide staff to resources for
self -learning and acclimatization. During new employee probationary periods, each new IDDE staff member is also assigned a
Training Organizer document, which outlines tasks and experiences to complete. Investigations refresher training is conducted on
an annual basis for all IDDE staff. Training documentation and content is included in folder D7.
The IDDE supervisor conducts routine field audits of investigations, observing for staff adherence to established procedures and
guidelines as well as to identify areas where training should be provided or reinforced. A recent audit conducted in March 2022 is
included as document D8.
II.D.2.e.
The permittee maintained and publicized reporting mechanism(s) for the public to
Yes
D3
Public Reporting
report illicit connections and discharges.
Comments
The IDDE Investigations Guidelines document (D3) describes multiple reporting mechanisms, which include a publicized pollution
hotline, group email, web submission form, and general Durham City OneCall hotline.
I I. D.2.f.
Documentation
The permittee documented the date of investigations, any enforcement action(s) or
D11/D12
remediation that occurred.
Yes
/D13
Comments
Records of all IDDE investigations, enforcement actions, and corrective actions, are contained within the "IDDE Investigations
Database." This database is only accessible from a computer linked to the City's internal network. Summary outputs of this
database are provided in documents D11, D12, and D13. A guided tour of the live database can be arranged upon request.
Documentation of dry weather screening is provided via summary in document D9. These data are also maintained in a custom
database accessible only from a computer linked to the City's internal network. A guided tour of the live database can be arranged
upon request.
Additional
Comments:
NCS000249_Durham 2022 MS4 Self -Audit Page 21 of 45

Construction Site Runoff Controls
Staff Interviewed:
Jonathan McNeill, Erosion Control Supervisor, CFM, Durham County, Engineering & Environmental Services
(Name, Title, Role)
Ryan Eaves, PE, CFM, CPESC, Stormwater and Erosion Control Division Manager,
[e-mail] I Phone [phone]
[e-mail] I Phone [phone]
Interviewed by Mark Senior, PE (WK Dickson) on October 21, 2021
Program Delegation Status:
The permittee has a delegated Sediment and Erosion Control Program to implement 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 The permittee implements a delegated program in compliance with the
Program Sediment Pollution Control Act of 1973 and Chapter 4 of Title 15A of the Yes
g
E1, E2,
North Carolina Administrative Code within the city's jurisdictional area.
E3
Comments (Note date of last SPCA delegated program review by NCDEQ-DEMLR staff and result)
The City relies on the Durham County locally delegated Erosion and Sediment Control Program to meet the MEP standards for
Construction Site Runoff Controls. An MOU between the City and County is in place and the County program was last reviewed and
approved by the State Sediment Control Commission on 8/22/2017. As of April 19, 2022, Durham County was named the 2022
Outstanding Local Program.
II.E.2.c.
The permittee provided and promoted a means for the public to notify the
B1, 66,
Reporting
appropriate authorities of observed erosion and sedimentation problems.
Yes
B12,
Mechanism
613, 14
Comments
• Durham's website has a hotline and phone number for citizen reporting of observed water quality problems as well as an SOP for
handling and following up on such reports. These reporting mechanisms are included in their public education and outreach.
• City personnel are also trained to identify and report construction site pollution along with other IDDE efforts.(D3,D7)
II.E.2.d.
The permittee coordinated the approval of the construction site runoff control with
Coordination with
DEMLR for new development and redevelopment projects to be built within the
Yes
---
DEMLR
permittee's planning jurisdiction by entities with eminent domain authority.
Comments
• City- and County -owned sites are referred to DEMLR for erosion control permitting. Complaints on these sites are forwarded to
DEMLR, while also being coordinated with the necessary City and County project management staff.
NCS000249_Durham 2022 MS4 Self -Audit Page 22 of 45

Construction Site Runoff Controls
Additional
Comments:
. Lists of submittals to the E&SC program are provided in the NPDES Annual Report (A3, A4, A5).
NCS000249_Durham 2022 MS4 Self -Audit Page 23 of 45

Post -Construction Site Runoff Controls
Staff Interviewed: Jennifer Buzun, PE
(Name, Title, Role) Assistant Stormwater Development Review Supervisor
City of Durham, Public Works Department, Stormwater & GIS Services Division
[e-mail] 1 [phone], ext. *30292
Interviewed by Daryl Hammock, PE, (Assistant Manager, Stormwater Services, City of Charlotte) and Mark
Senior. PE, (WK Dickson) on October 28, 2021
Bill Hailey
SCM Maintenance Program Coordinator
City of Durham, Public Works Department, Stormwater & GIS Services Division
[e-mail] 1 [phone], ext. *30214
Program Implementation (check all that apply):
0 The permittee implements the components of this minimum measure.
❑ The permittee relies upon another entity to implement the components of this minimum measure: list name of entity
0 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-1) —15A NCAC 26 .0212 (Eff. March 1, 2019 15A NCAC 026 .0620 - .0624)
0 Water Supply Watershed II (WS-II) —15A NCAC 26 .0214 (Eff. March 1, 2019 15A NCAC 02B .0620 - .0624)
0 Water Supply Watershed III (WS-III) —15A NCAC 26.0215 (Eff. March 1, 2019 15A NCAC 02B .0620 - .0624)
0 Water Supply Watershed IV (WS-IV) —15A NCAC 213.0216 (Eff. March 1, 2019 15A NCAC 026 .0620 - .0624)
❑ Freshwater High Quality Waters (HQW) —15A NCAC 2H .1006
❑ Freshwater Outstanding Resource Waters (ORW) —15A NCAC 2H .1007
0 Neuse River Basin Nutrient Sensitive (NSW) Management Strategy-15A NCAC 213 .0235
❑ Tar -Pamlico River Basin Nutrient Sensitive (NSW) Management Strategy —15A NCAC 213 .0258
❑ Randleman Lake Water Supply Watershed Nutrient Management Strategy —15A NCAC 2B .0251
❑ Universal Stormwater Management Program —15A NCAC 2H .1020
Note: Additionally, implements Falls Nutrient Strategy for New Development —15A NCAC 026 .0277
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
0 MS4 designed post -construction practices that meet or exceed 15A NCAC 02H .1000
❑ DEQ approved comprehensive watershed plan
0 DEQ approved Qualifying Alternative Program listed above
I I Program Requirement I Status I Supporting I
Doc No.
NCS000249—Durham 2022 MS4 Self -Audit Page 24 of 45

Post -Construction Site Runoff Controls
02H .1017
The permittee implements the Qualifying Alternative Program requirements
A2, F1,
Qualifying
checked above in accordance with the applicable 15A NCAC rules.
Yes
F2, F3,
Alternative
F4, F20,
Program(s)
F25, F28
The permittee cumulatively implements the Qualifying Alternative Program
A2, F1,
requirements checked above throughout the entire MS4 permitted area.
F2, F19,
Yes
F24, F25,
F26, F27,
F28, F29
If response is no or partial, the permittee implements MS4 post -
construction requirements in accordance with 15A NCAC 02H .1017(3) —
Not
Applicable
-
(14) throughout the balance of the M54 permitted area.
Comments
• The City of Durham implements the Post Construction Program as required by SL 2006-246, including the Qualifying
Alternative Programs for Water Supply Watersheds and Neuse River NSW requirements.
• The City implements post -construction requirements throughout the corporate boundary of the City. This is documented in
the City's SWMP, on the City's website (Stormwater Development Review ), in their adopted Stormwater Performance
Standards for Development (verified in Municode ARTICLE X. - STORMWATER PERFORMANCE STANDARDS FOR
DEVELOPMENT I Code of Ordinances I Durham, NC I Municode Library ), and in their Unified Development Ordinance Durham
Unified Development Ordinance (municipal codes) sections 8.5 to 8.7 (June 1, 2021). The City's proper implementation is
evidenced by numerous documents, records, plans, and documents.
• The City tracks local government projects alongside private development projects in its databases, such as the electronic
database containing approved SCMs. The interviewee demonstrated knowledge and evidence that linear projects are
reviewed and approved for construction, and that long term Operation and Maintenance (O&M) inspections are conducted by
City staff.
• The City prepared and submitted the Falls Lake New Development Annual Report and the Neuse River Stormwater
Management Report.
The City has included these programs in their SWMP, and these elements are well -integrated into the program and plan. An
example is the applicability map (figure 7-5) in the Plan and as described in 7.5.7 of the plan.
Permit Citation Program Requirement Status Supporting
Doc No.
II.F.2.a. The permittee maintained an ordinance or similar regulatory mechanism that
Legal Authority authorizes a program to address stormwater runoff from new development and Yes F1, F2
redevelopment to the extent allowable under State law.
Comments
The City of Durham enacted City Code Chapter 70 (verified in Municode) and their Unified Development Ordinance sections 8.5 to
8.7. These are the basis for implementing their Post Construction Stormwater program.
The permittee maintains strategies that include a combination of structural and/or
A2, F1,
non-structural SCMs in concurrence with the legal authorities above (II.F.2.a.).
Yes
F2
NCS000249—Durham 2022 MS4 Self -Audit Page 25 of 45

Post -Construction Site Runoff Controls
Stormwater Control
F3, F5,
Measures (SCMs)
F9, F10 ,
The permittee provides a mechanism to require long-term operation and
Yes
F11, F1
maintenance of structural SCMs.
F13, F25,
F26, F27,
F28
A2, F3,s
The permittee requires annual inspection reports of permitted structural SCM
Yes
F8, F25,
performed by a qualified professional.
F28
F2, F5,
F6, F7,
The permittee implements SCM requirements that are at least as stringent as the
F8, F9,
minimum requirements in 15A NCAC 02H .1000.
Yes
F10, F12,
F13, F22,
F25
Comments
• As detailed in the SWMP, the City oversees implementation of structural stormwater controls that mitigate pollutants of
concern and peak flows as a part of the permitting process for new development and redevelopment. Furthermore, the City
implements stream buffer diffuse flow requirements via ordinance through its Natural Resources Protection Standards
(Unified Development Ordinance Section 8.5). The diffuse flow requirements are typically addressed by installing a level
spreader/vegetated filter strip .
• The City tracks SCMs for developments in an electronic SCM tool database that can export reports. The City uses NCDEQ BMP
manual in combination with a locally tailored addendum containing alterations and enhancements. The City requires plan
submittal, reviews, and approvals prior to SCM construction.
• The City of Durham's 0&M mechanism is clearly described in the SWMP. The process addresses site access, inspection reports,
failure remediation, penalties, and municipal facilities as well.
• The City saves electronic versions of construction plans for new developments on the network server and in a geospatial
database. The City obtains as -built plans for each new development and stores them on the network server for future
reference. SOPS and tools for use by the reviewers have been developed.
• Sealed annual certifications by a qualified professional are required as defined in the SWMP. Detailed procedures for submittal
are described in their Certification Protocol. Notably, the City also has a disciplinary process for certifiers who improperly
certify structural SCMs and provides detailed resources for SCM owners.
• The City's processes for implementation are very thorough and include authorities, enforcement strategies, escalation process,
fines, and several sample forms. Detailed procedures and electronic record storage are provided, as well as internal processes
to ensure timely review of inspection reports. The responsibilities of internal team members and of penalty assessments are
clearly defined. This program appears to be very well documented and laid out.
There have been no recent changes to SCM requirements prescribed by law. The City's ordinances and other program aspects such
as design approaches for SCMs have been reviewed and approved by NCDEQ.
nr7r
Deed Restrictions The permittee provides mechanisms such as recorded deed restrictions, plats, A2, F2,
and Protective and/or protective covenants so that development activities maintain the project Yes F5, F13,
Covenants consistent with approved plans. F14
NCS000249_Durham 2022 MS4 Self -Audit Page 26 of 45

Post -Construction Site Runoff Controls
The City describes a specific approach to provide such mechanisms in the SWMP. Chapter 70 of City code and Chapter 8.7 of the
UDO are in place to support this and to provide even more specificity, including penalties for non-compliance (Municode).
Previously, permittees were required to sign and record Stormwater Facility Agreements (SWFAs) that clearly specified the owner's
responsibilities with regard to SCMs. In 2019 the City Code was amended to remove requirements for SWFAs for any development
project subject to the current ordinance; for new projects, the City relies on the City Code and Stormwater Standards for 0&M
compliance for all development. The City's Reference Guide for Development now requires the Declaration for Covenants,
Conditions & Restrictions for residential developments with owners associations to include specific language for SCM operation,
maintenance and repair with regard to SCMs. Also, all final plats include Stormwater Standard Notes regarding responsibility for
SCM operation, maintenance and reconstruction. Numerous examples of documents associated with restrictions and protective
covenants are provided.
A financial guarantee program for long-term SCM maintenance is administered by the City. Acceptable security instruments include
a Stormwater Facility Replacement Fund Payment (open to all SCM owners), or an Irrevocable Letter of Credit, Assignable
Certificate of Deposit, Bank Cashier's Check, or Performance Bond (open only to non -single-family residential developments)
II.F.2.d. The developer provides the permittee with an operation and maintenance plan for
Operation and the stormwater system, indicating the operation and maintenance actions that
Maintenance Plans shall be taken, specific quantitative criteria used for determining when those Yes F5, F10
actions shall be taken, and who is responsible for those actions.
The plans clearly indicate the steps that shall be taken and who shall be responsible Yes F5, F10,
for restoring a stormwater system to design specifications if a failure occurs. F13
The plans include a legally enforceable acknowledgment by the responsible party. I Yes I F13, F23
Development is maintained consistent with the requirements in the approved F2, F5,
Yes F8, F9,
plans.
F10, F13
Modifications to those plans must be / are approved by the Permittee. I Yes I F8, F1
NCS000249_Durham 2022 MS4 Self -Audit Page 27 of 45

Post -Construction Site Runoff Controls
Comments
• Recorded and approved plats indicate stream buffers and drainage easements, as well as indicating location of SCMs and
responsibility for long term 0&M of SCMs.
• Prior to May 21, 2019, the City executed stormwater facility agreements (SWFAs) with SCM owners; the SWFAs specified
funding, maintenance needs, and other clear, specific, and measurable actions such as annual activities so that devices are
maintained perpetually. Those agreements were amended or updated from time to time as necessitated prior to amendments
being recorded.
• The SWFAs referenced current City manuals and standards such that design improvements and best practices are reflected
with new repairs. The City's Compliance and Enforcement Guidelines provide numerous strategies and approaches to ensure
long term O&M is successful. The agreements specified 0&M will be prioritized among funding needs of the landowner/HOA.
The executed and recorded agreements specified escrow amounts to be held in reserve by the landowner/HOA. This is a very
thorough, clear, specific, and enforceable agreement.
• On May 21, 2019 the City Code was amended to remove requirements for SWFAs for any development project subject to the
current ordinance —this was thoroughly vetted with the City Attorney's Office prior to City Council adoption. For new projects,
the City relies on the City Code and Stormwater Standards for O&M compliance for all development.
• Section 8.2.1 was added to the City's Reference Guide for Development to ensure required language in the Declaration for
Covenants, Conditions & Restrictions for residential developments with Homeowners' Associations. The Stormwater Standard
Notes were also revised accordingly. A Letter to Industry documents these revisions, and the SWMP was amended to include
these changes. For old projects, the SWFAs are still valid.
The City has detailed, thorough, and complete processes for accepting and rejecting inspection reports and managing reports. This
includes a suite of SOPS related to inspections, storage of records, and updating electronic records. This includes a process for City
owned facilities. The City has a process for review and acceptance of as -built drawings.
I I. F.2.e.
Educational
Materials and
The permittee provided educational materials and training for developers.
Yes
F17, F18
Training
Comments
• The interviewee demonstrated strong knowledge of developer training activities. This included conducting a 2-hour developer
training seminar 2-4 times annually, notifying engineers of the training opportunities through established email distribution
lists, offering Professional Development Hours (PDHs), and documenting the attendees through sign -in sheets and attendance -
taking.
• The City also holds pre -construction meetings with the developer, SCM construction contractor, as -built certifying engineer,
and geotechnical engineer (if applicable). During these meetings, aspects of SCM construction and required as -built
documentation are covered
II.F.4.
The permittee applies additional requirements to projects draining to SA waters by
Sensitive Receiving
requiring SCMs that result in the highest degree of fecal coliform die -off and
Not
Waters
controls sources of fecal coliform to the maximum extent practicable in accordance
Applicable
with 15A NCAC 02H .1017(9)
The permittee applies additional requirements to projects draining to Trout waters
by requiring SCMs that avoid a sustained increase in receiving water temperature
Not
Applicable
in accordance with 15A NCAC 02H .1017(9)
The permittee implements an approved locally implemented Nutrient
F2, F20,
Management Strategy that addresses post -construction runoff and the provisions
Yes
F25
of that Strategy fulfill the MS4 post -construction requirement.
NCS000249_Durham 2022 MS4 Self -Audit Page 28 of 45

Post -Construction Site Runoff Controls
Comments
• The City is responsible for implementing 15A NCAC 02B .0235 for the Neuse NSW and is responsible to implement 15A NCAC
02B .0277 for Falls Lake.
• The local program has been approved and annual reports are submitted to NCDEQ.
II.F.S.
F2, F5,
Permittee Projects
The permittee meets the requirements of the post -construction program for
Yes
F8, F21,
construction projects that are performed by, or under contract for, the permittee.
F25
Comments
• Municipal projects go through the same site plan and construction drawing review and approval process that non -municipal
projects do. Long term 0&M inspections are conducted by City Stormwater Development Review staff but corrective actions
are the responsibility of the department who owns the SCM.
I I. F.6.
SCM Design Volume
The permittee requires that the water quality design volume of SCMs account for
Yes
F5, F6,
the runoff at build out from all surfaces draining to the system.
F7
Comments
• The City follows the volume methods contained in the NCDEQ Stormwater Best Management Practices Manual and references
locally tailored coefficients to be used with these methods. Drainage areas and design volumes for SCMs are documented in
the required Stormwater Impact Analysis (SIA). The SIA is intended to determine the need for SCMs, provide justification for
the design of SCMs, and demonstrate how development complies with the requirements as written in the Stormwater
Performance Standards for Development ordinance, which is found in Durham City Code Chapter 70, Article X, Sections 70-736
through 70-749.
II.F.7.
The permittee fulfills the post -construction minimum control measure
Linear
requirements for non-NCDOT linear transportation projects if they are designed,
Transportation
constructed, and conveyed as set forth in 15A NCAC 02H .1001(1)(c):
Projects
(i) Constructed to NCDOT standards and in accordance with the NCDOT BMP
Toolbox;
Yes
F19
(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.
Comments
• For City trail and greenway projects begun after January 2017, when the Linear Transportation and Greenways standards
were first included in the NCDEQ Stormwater BMP Manual, the City uses the NCDOT BMP Toolbox for the assessment and
design of project SCMs.
Additional
Comments:
NCS000249_Durham 2022 MS4 Self -Audit Page 29 of 45

Pollution Prevention and Good Housekeeping for Municipal Operations
Staff Interviewed:
John Sandin, Public Works Supervisor, Stormwater Maintenance
(Name, Title, Role)
City of Durham, Public Works Department
[e-mail] I Phone: [phone]
Interviewed by Mark Senior, PE Amy Hathaway, PE on November 4, 2021
Terrance King, Public Works Maintenance and Operations Manager
City of Durham, Public Works Department
[e-mail] I Phone: [phone]
Interviewed by Mark Senior, PE and Don Green, LEED AP on November 15, 2021
Benita Quick, Public Works Supervisor, Street Cleaning
City of Durham, Public Works Department
[e-mail] I Phone: [phone]
Interviewed by Mark Senior, PE on November 17, 2021
Permit Citation
�
Program Requirement
Status
Supporting
No.
II.G.2.a.
The permittee maintained an inventory of municipal facilities and operations
Municipal Facility
owned and operated by the permittee that have been determined by the
Yes
U_L
Inventory
permittee to have significant potential or generating polluted stormwater runoff.
The permittee maintained an inventory of municipally -owned structural SCMs.
Yes
F25
Comments
• WQ has identified and inventoried 40 municipal facilities and operations meeting the criteria for inclusion in the inspection
program (G1). Each facility is assigned a priority and inspection frequency matching its compliance history and stormwater
contamination risk assessment.
II.G.2.b.
The permittee implemented an inspection and maintenance program for facilities
G2, G3,
Inspection and
and operations owned and operated by the permittee for potential sources of
Yes
Databas
Maintenance for
polluted runoff, including stormwater controls and conveyance systems.
e
Municipal Facilities
The inspection program evaluates pollutant sources, documents deficiencies, plans
G2,
corrective actions, implements appropriate controls, and documents the
Yes
Databas
accomplishment of corrective actions.
e
The maintenance program includes maintenance activities and procedures aimed
at preventing or reducing pollutants generated from municipal facilities and
Yes
'
operations.
Comments
• Procedures for conducting inspections of municipal facilities are detailed in the Stormwater Inspections Program Guidelines
document (G2). The Stormwater Inspections Database (link provided) contains records of all municipal facility inspections
conducted, including details of site conditions and compliance with all applicable stormwater regulations. During the current
permit period, 110 inspections of municipal facilities were conducted (G3).
II.G.2.c.
The permittee maintained and implemented Site Pollution Prevention Plans for
Site Pollution
municipal facilities owned and operated by the permittee that have been
Prevention Plans for
determined by the permittee to have significant potential for generating polluted
Yes
Municipal Facilities
stormwater runoff that has the goal of preventing or reducing pollutant runoff.
NCS000249_Durham 2022 MS4 Self -Audit Page 30 of 45

Pollution Prevention and Good Housekeeping for Municipal Operations
Comments
The folder provided, named "G4— Facility Compliance Documentation," contains all stormwater regulatory documentation for
municipal facilities requiring SPPPs by MS4 permit or by General Permit. Documentation includes employee training, SPPP,
inspection records, and runoff monitoring (where applicable).
II.G.2.d.
The permittee maintained spill response procedures for municipal facilities and
Spill Response
operations owned and operated by the permittee that have been determined by
Procedures for
the permittee to have significant potential for generating polluted stormwater
Yes
Municipal Facilities
runoff.
Comments
Facilities with significant potential for generating polluted stormwater runoff have been identified and are routinely inspected. The
folder provided named "G4 — Facility Compliance Documentation" contains facility SPPPs, which address spill response procedures.
II.G.2.e.
The permittee described measures that prevent or minimize contamination of the
Vehicle and
stormwater runoff from all areas used for vehicle and equipment cleaning,
Yes
A2/G2
Equipment Cleaning
including fire stations that have more than three fire trucks and ambulances.
Areas
The permittee performs all cleaning operations indoors, covers the cleaning
operations, ensures wash water drains to the sanitary sewer system, collects wash
Yes
A2/G2
water and stormwater run-on from the cleaning areas and provides treatment or
recycling, or other equivalent measures
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
Yes
A2/G2
or graveled areas to prevent point source discharges of wash water into the storm
drains or surface waters.
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,
Yes
A2/G2
and any excess standing water is removed and properly handled prior to removing
the drain cover.
The permittee facilities that have three or fewer fire trucks and ambulances
attempt to comply with the above requirements; however, those that cannot
Yes
A2/G2
comply with these requirements due to existing limitations incorporate structural
measures during facility renovation to the extent practicable.
Comments
Cleaning of City equipment and vehicles must be conducted in compliance with the City's MS4 NPDES stormwater permit and City
Code. Approved wash bay facilities plumbed to the sanitary sewer system are identified in document G2 on pages 14-15. Additional
emergency facilities with compliant vehicle washing solutions are identified in the Stormwater Management Plan section 7.7.5
(page 7-54).
II.G.2.f.
Streets, Roads and
The permittee implements BMPs to reduce polluted stormwater runoff from
Public Parking Lot
municipally -owned streets, roads, and public parking lots within the corporate
Partial
G10, G11
Maintenance
limits.
NCS000249—Durham 2022 MS4 Self -Audit Page 31 of 45

Pollution Prevention and Good Housekeeping for Municipal Operations
Comments
• The City maintains a comprehensive GIS layer of the stormwater conveyance system including sizes, materials, condition, and
photos of the various components. The City conducts routine street sweeping using regenerative air sweepers. Maps of regular
routes are attached (G8) Additional sweeping is performed at drinking water and wastewater plants as needed and during
construction activities. Additional sweeping is also performed at the PW Operations Center and the police parking garage.
• The City requires parking garage maintenance contractors to comply with the Stormwater Pollution Control Ordinance (G6,
G11).
II.G.2.g.
The permittee maintained and implemented an inspection and maintenance
F8, F10,
Inspection and
program for structural stormwater control measures (SCMs) owned and operated
Yes
Maintenance for
by the municipality.
F25, F28
Municipal SCMs and
MS4
The permittee maintained and implemented an inspection and maintenance
program for the municipal storm sewer system (including catch basins, the
Yes
G6
conveyance system and SCMs).
Comments
The City maintains detailed documentation regarding the inspection of required public and privately owned SCMs along with
inspection records, required repairs and maintenance, and photographs. Maintenance and repair of the stormwater conveyance
system is tracked and documented using "Cityworks" maintenance and repair software. Most inspection and maintenance are
reactionary based on service requests however the City proactively contracts for inspection of 10% of the catch basins associated
with roadways annually. (G6)
II.G.2.h.
The permittee maintained a training plan that indicates when, how often, and who
Staff Training
is required to be trained and what they are to be trained on.
Yes
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
Comments
Within the provided folder named, "G5 — Staff Training," are staff training records for work groups not connected to an inspected
facility. Each facility folder in "G4- Facility Compliance Documentation" contains the training records for the respective facility.
The Municipal Training Program Guidance document and Training Plans for 2020-2021 and 2021-2022 concern all trained work
groups. An additional master summary of municipal staff training is included in this folder, named "Municipal Training Summary
(2018-2022)."
Training efforts were adversely impacted by Covid restrictions and this was documented in applicable cases.
Additional
Comments:
NCS000249—Durham 2022 MS4 Self -Audit Page 32 of 45

Program to Monitor and Evaluate Stormwater Discharges to Municipal Systems
Staff Interviewed:
Audrey Britton
(Name, Title, Role)
Environmental Planning and Compliance Coordinator
City of Durham, Public Works Department, Stormwater & GIS Services Division
[e-mail]
Interviewed by Mark Senior, PE and Amy Hathaway, PE on October 26, 2021
Permit Citation
Program Requirement
I Status
S pporting
i
Doc No.
The permittee maintained an inventory of permitted hazardous waste treatment,
II.H.2.a.
disposal, and recovery facilities, industrial facilities that are subject to Section
Industrial Facility
313 of Title III of the Superfund Amendments and Reauthorization Act of 1986
Yes
H1
Inventory
(SARA).
The permittee maintained an inventory of industrial facilities identified with an
industrial activity (as defined in 40 CFR 122.26) permitted to discharge storm
Yes
H2
water to the permittee's MS4.
Comments
We have no knowledge of any TSDFs presently operating within the City of Durham. WQ recognizes 6 facilities subject to Sec 313
SARA Title III currently operating within City limits (1-11). WQ recognizes 62 facilities subject to NPDES stormwater permits (or No
Exposure exceptions) currently operating within City limits (1-12). These facilities are inventoried and routinely inspected.
The Stormwater Inspection Program Guidelines document (H3) describes our procedures for identifying these facilities (pg. 10-14).
II.H.2.b.
Inspection Program
The permittee identified priorities and inspection procedures. At a minimum,
Yes
priority facilities include those identified above (subsection II.1-1.2.a).
Comments
The Stormwater Inspection Program Guidelines document (H3) describes our procedures for identifying, prioritizing, and inspecting
industrial facilities. Discussion of our prioritization scheme begins on page 16.
II.H.2.c.
The permittee evaluated control measures implemented at permitted hazardous
Industrial Facility
waste treatment, disposal, and recovery facilities, industrial facilities that are
Evaluation
subject to Section 313 of Title III of the Superfund Amendments and
Reauthorization Act of 1986 (SARA).
Yes
Databas
e
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.
The permittee evaluated control measures implemented at industrial facilities
identified with an industrial activity permitted to discharge storm water to the
permittee's MS4.
Yes
Databas
e
For the purposes of this permit, industrial activities shall mean all permitted industrial
activities as defined in 40 CFR 122.26.
For permitted industrial facilities, the permittee established procedures for
reporting deficiencies and non-compliance to the permitting agency.
Yes
,
NCS000249_Durham 2022 MS4 Self -Audit Page 33 of 45

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
Databas
documents the need for permit modifications or additions to the permit issuing
Yes
e
authority.
The permittee evaluated control measures implemented at industrial facilities
Databas
identified as an illicit discharge under the IDDE Program.
Yes
a/H4
Comments
Complete records of facility inspections, where staff evaluate onsite control measures and stormwater regulatory compliance, are
contained within the Stormwater Inspections Database, a link to which has been provided. During the permit period to date, WQ
has conducted 430 compliance inspections of industrial facilities (1-14).
Procedures for reporting deficiencies and non-compliance to the Raleigh Regional Office are described in the Stormwater Inspection
Program Guidelines document (1­13) on page 4.
Additional
Comments:
NCS000249_Durham 2022 MS4 Self -Audit Page 34 of 45

Water Quality Assessment and Monitoring
Staff Interviewed:
John "J.V." Loperfido, PE, CFM
(Name, Title, Role)
Assistant Water Quality Manager
City of Durham, Public Works Department, Stormwater & GIS Services Division
[e-mail] I Phone: [phone], Ext. *30311
Interviewed by Ted Brown, PE (Biohabitats) on August 20, 2021
Permit Citation
Program Requirement
Status
Supporting
Doc No.
11.1.2.a.
Water Quality
supporti
Assessment and
ngocs
d
Monitoring Plan
The permittee maintained a Water Quality Assessment and Monitoring Plan.
Yes
in
commen
is below
See
supporti
ng docs
The Water Quality Assessment and Monitoring Plan includes a schedule for
implementing the proposed assessment and monitoring activities.
Yes
In
commen
is below
NCS000249_Durham 2022 MS4 Self -Audit Page 35 of 45

Water Quality Assessment and Monitoring
Documents supporting 11.1.2.a include: Al-A5, B2, 11, 12, 14-17, 114-124, 127, 129, 131-134, 136-138, 141, 142, 149, 150, 151, and 158.
Section 7.9 of the City's Stormwater Management Plan (Al, A2) contains the Assessment and Monitoring Plan. Documents enclosed
in this section of the Self -Audit support the details, implementation, and scheduling of the Assessment and Monitoring Plan
contained within the City's Stormwater Management Plan. An overview of how the City's Assessment and Monitoring program is
structured and how it interacts with other permit program areas is provided in document 124.
Monitoring conducted by the City is broken out into several different categories: Ambient, In-Situ/Screening Level, Stormwater
Control Measure, and Special Studies. Ambient monitoring is comprised of chemistry, benthic macroinvertebrate, and hydrology
monitoring. Ambient monitoring is the primary chemistry monitoring conducted by the City (12) and is performed monthly. Data are
quality -assured and stored in a publically-available online Web Portal (11, 14). Standard Operating Procedures (SOPS) are followed
when conducting water quality monitoring (116-119, 121, 122). Monitoring of water quality chemistry is also conducted in partnership
with Upper Cape Fear River Basin Association (136). The City monitors annually for benthic macroinvertebrates and utilizes an SOP
to perform this monitoring (114). Hydrological monitoring conducted by the City includes partnering with U.S. Geological Survey for
stream flow monitoring and rainfall (15, 17). This City also conducts stream flow/stage monitoring (16, 120) and rainfall monitoring
(137, 138). In-Situ/Screening Level monitoring is conducted through the Illicit Discharge Detection and Elimination (IDDE) Program
(see Self -Audit Section II.D.2) and the Outfall Screening Program (see Self -Audit Section II.D.2.c). Stormwater Control Measure
monitoring is also conducted as a part of the monitoring plan (129). Special Studies are the final component to the City's monitoring
plan. Examples of these studies are enclosed (e.g., 131, 132, 133, 134, 141, 142, 149, 151, 158).
The City's Assessment and Monitoring Plan also outlines three core goals and five supplemental goals for conducting assessments.
These goals are largely achieved through the monitoring plans described in the previous paragraph (also see Table 7-14 in Section
7.9 of document A2). In addition to monitoring activities listed above, special studies performed in -the -field and also desktop data
analyses of water quality data contribute to meeting assessment goals. The City's SOPS outline procedures for calculating the
annual Water Quality Summary Tables (123), performing trend analyses (115), assessing field/lab monitoring data to initiate an IDDE
investigation (127), and storing digital models (150). Annual Water Quality Summary Tables (A3-Table 10.4; A4-Table 10.3; A5-Table
10.3), Water Quality Index Scores (132, https://www.durhamnc.gov/4648/State-of-Our-Streams) and loading calculations (A3-Tables
10.6 and 10.7; A4-Tables 10.6, 10.7, 10.8; A5-Table 10.5) are calculated to contribute to the City's Assessment and Monitoring Plan.
11.1.2.b. See
Water Quality supporti
Monitoring ng docs
The permittee maintained and implemented the Water Quality Assessment and
Monitoring Plan submitted to DEMLR. Yes In
commen
is below
The Division waived the requirement to maintain a Water Quality Assessment and Not
Monitoring Plan. Applicable n/a
NCS000249_Durham 2022 MS4 Self -Audit Page 36 of 45

Water Quality Assessment and Monitoring
Comments
Documents supporting 11.1.2.b include: Al-A5, B2, 11, 13-15, 18-113, 125-128, 130-135, 137-159, J6.
Monitoring that was completed covers the four major areas listed in the City's Stormwater Management Plan (Al, A2). Ambient
monitoring implemented included ambient stream (chemistry) monitoring at several ambient sites throughout the City (13, 110).
Data from this monitoring are available at the City's Web Portal database (11). Maintenance in the quality of data collected by the
ambient program was maintained through internal audits (125) and quality checks (14, 126, 128, 159). Benthic macroinvertebrate
monitoring was implemented and described in annual study plans (18, 19). Hydrology monitoring was implemented for monitoring
stream flow (15, 135) and precipitation (137, 138, 15); data are available via these references. In-Situ/Screening Level monitoring was
conducted through the Illicit Discharge Detection and Elimination (IDDE) Program (see Self -Audit Section II.D.2) and Outfall
Screening Program (see Self -Audit Section II.D.2.c). Other studies completed also supported in situ/screening level monitoring (e.g.,
131, 132). Stormwater Control Measure monitoring was also conducted in two studies (113, 133). Several special studies to collect
additional monitoring data were also completed (e.g., 134, 141, 142, 149, 151, 158).
Assessments were completed to meet the three core and five supplemental goals in the City's Stormwater Management Plan (Al,
A2). These goals and the studies and plans that support them are listed below. Maintenance of assessment plans include planned
updates to the City's Water Quality Web Portal (148).
Core Goals:
• to identify illicit discharges to area streams (IDDE and Outfall Screening programs, 127, 131, 132, 141)
• to identify pollution problem areas within the City (Ambient Monitoring, Annual Water Quality Summary Tables, loading
calculations, Water Quality Index Scores, 111, 112, 113, 130-134, 140-143, 146, 149, 151-154)
• to assess compliance with state water quality programs (Ambient Monitoring, Annual Water Quality Summary Tables,
loading calculations, 130-134, 139, 141, 143, 146-149, 151)
Supplemental Goals:
• to identify overall trends to water quality (Ambient Monitoring, Annual Water Quality Summary Tables, loading
calculations, 112, 113, 143, 146, 149, 155-157, J6)
• to evaluate the performance of Stormwater Control Measures (113, 133)
• to determine potential pollution removal credits (Ambient Monitoring, loading calculations, 111, 140)
• to assess the overall quality of streams within the City of Durham (Annual Water Quality Summary Tables, loading
calculations, Water Quality Index Scores, 112, 113, 130, 131, 132, 134, 140-143, 146-158)
• to evaluate the water quality impacts of urban stormwater on area streams (Ambient Monitoring, Annual Water Quality
Summary Tables, loading calculations, Water Quality Index Scores, 111-113, 130-134, 140-159)
Annual assessments for ambient and benthic monitoring were implemented and reported. The Water Quality Summary Table
calculations and assessment are reported in the City's Annual NPDES Stormwater Report for FY19 (A3-Table 10.4), FY20 (A4-Table
10.3), and FY21 (A5-Table 10.3). The Benthic Summary table calculations and assessment are reported in the City's Annual NPDES
Stormwater Report for FY19 (A3-Table 10.5), FY20 (A4-Table 10.4), and FY21 (A5-Table 10.4). Pollutant loading calculations were
performed and are reported in in the City's Annual NPDES Stormwater Report for FY19 (A3-Tables 10.6 and 10.7), FY20 (A4-Tables
10.6, 10.7, 10.8), and FY21 (A5-Table 10.5). Water Quality Index values were reported annually in the Water Quality Summary Table
and with the City's State of Our Streams Report (62, https://www.durhamnc.gov/4648/State-of-Our-Streams).
Additional n/a
Comments:
NCS000249_Durham 2022 MS4 Self -Audit Page 37 of 45

NCS000249_Durham 2022 MS4 Self -Audit Page 38 of 45

Total Maximum Daily Loads (TMDLs)
Staff Interviewed:
John "J.V." Loperfido, PE, CFM
(Name, Title,
Assistant Water Quality Manager
Role)
City of Durham, Public Works Department, Stormwater & GIS Services Division
[e-mail] I Phone: [phone], Ext. *30311
Interviewed by Ted Brown, PE (Biohabitats) on September 1, 2021
Permit Citation
Program Requirement
Status
Supporting
Doc No.
II.J.3.a.
Identify, describe
and map
watershed
Within 12 months the permittee shall prepare a plan that:
---
---
outfalls, and
streams
1. Identifies the watershed(s) subject to an approved TMDL with an approved Waste
J1, J2, J3,
Load Allocation (WLAs) assigned to the permittee.
Yes
J4
2. Includes a description of the watershed(s).
Yes
J3, J4
3. Includes a map of the watershed showing streams & outfalls.
Yes
J5, D2
4. Identifies the locations of currently known major outfalls within its corporate limits
with the potential of contributing to the cause(s) of the impairment to the impaired
Yes
J5, D2
segments, to their tributaries, and to segments and tributaries within the watershed
contributing to the impaired segments.
5. Includes a schedule (not to exceed 6 months) to discover and locate other
unknown major outfalls within its corporate limits that may be contributing to the
cause of the impairment to the impaired stream segments, to their tributaries, and to
Yes
A3-A5, J8
segments and tributaries within the watershed contributing to the impaired
segments.
NCS000249_Durham 2022 MS4 Self -Audit Page 39 of 45

Total Maximum Daily Loads (TMDLs)
Comments
1. The City has TMDLs assigned for two streams, Northeast Creek and Third Fork Creek, documents J1 and J2, respectively. These
TMDLs are document in the City's TMDL Response Plan Documents for these watersheds (J3, J4).
2. Description of watersheds with TMDLs are provided in Section 4.1 of TMDL Response Plans for Northeast Creek (J3) and Third
Fork Creek (J4).
3. A map of the Northeast Creek and Third Fork Creek watersheds with streams and major outfalls are provided in document J5. The
City maintains a webmap (City of Durham GoMaps, D2) that is publically available and maps all public outfalls within the City.
4. A map of the Northeast Creek and Third Fork Creek watersheds with streams and major outfalls are provided in document J5.
These maps identify the outfall by pipe diameter for all major outfalls (>36"). The City maintains a webmap (City of Durham
GoMaps, D2) that is publically available and maps all public outfalls within the City.
5. A process to locate and discover unknown and new major outfalls throughout the city, including in Northeast Creek and Third
Fork Creek, is provided in document J8. This process is also noted in Section 5.2 of the City's NPDES Stormwater Annual Report (See
Section 5.2 in A3-A5).
I I.J.3. b.
Evaluate Existing
Within 12 months the permittee shall prepare a plan that:
---
Measures
1. Shall describe existing measures currently being implemented by the Permittee
designed to achieve the MS4's NPDES WLA and to reduce the TMDL pollutant of
Yes
J3, J4
concern to the MEP within the watershed to which the TMDL applies.
2. Provide an explanation as to how those measures are designed to reduce the
Yes
J3, J4
TMDL pollutant of concern.
3. The Permittee shall continue to implement the existing measures until notified by
Yes
A3-A5
the Division.
Comments
1. Section 6 (Pollution Prevention and Mitigation Measures Currently Being Implemented) of the TMDL Response Plans for
Northeast Creek (J3) and Third Fork Creek (J4) list the existing measures which may reduce the pollutants of concern.
2. Section 6 (Pollution Prevention and Mitigation Measures Currently Being Implemented) of the TMDL Response Plans list the
existing measures (J3 and J4). These measures are divided into two categories for how they reduce the pollutant of concern (POC).
First, some measures prevent the release of the POC from occurring or from reaching the MS4 and stream. Second, some measures
are designed to mitigate an occurrence of the POC once it has occurred. Section 5 of the TMDL Response Plans provides more
information on the physical pathways of the POC to the MS4/stream that the existing measures aim to address.
3. Implementation of existing measures in the TMDL Response Plans are tracked and reported annually in Section 11 of the City's
Annual NPDES Stormwater Report (A3-A5).
I I.J.3.c.
Assessment of
Within 24 months the permittee's plan shall include an assessment of available
Available
monitoring data. Where long-term data is available, this assessment should include
Yes
J6, A3-A5
an analysis of the data to show trends.
Monitoring Data
NCS000249_Durham 2022 MS4 Self -Audit Page 40 of 45

Total Maximum Daily Loads (TMDLs)
Comments
Monitoring data are presented and trends are analyzed annually for the pollutant of concern in TMDL watersheds in Section 11(a)
and 11(b) of the City's Annual NPDES Stormwater Report (A3-A5). Monitoring data and loading calculations from TMDL watersheds
are also presented in Section 10 of the annual reports (A3-A5). Document J6 shows trends of available monitoring data in Northeast
Creek and Third Fork Creek since 2019, coinciding with the City's current MS4 permit and completion of the TMDL Response Plans.
II.J.3.d.
Within 24 months the permittee shall develop a Monitoring Plan for the permittee's
Monitoring Plan
assigned NPDES regulated WLA as specified in the TMDL. The permittee shall
maintain and implement the Monitoring Plan as additional outfalls are identified and
Al, A2,
as accumulating data may suggest. Following any review and comment by the
13, 17, 19,
Division the permittee shall incorporate any necessary changes to monitoring plan
136, 137,
and initiate the plan within 6 months. Modifications to the monitoring plan shall be
Yes
138, 141,
approved by the Division. Upon request, the requirement to develop a Monitoring
149, 151,
Plan may be waived by the Division if the existing and proposed measures are
J3, J4, J8
determined to be adequate to achieve the MS4's NPDES WLA to MEP within the
watershed to which the TMDL applies.
Comments
Monitoring plans for Northeast Creek and Third Fork Creek are available in the TMDL Response Plans for these two watersheds,
documents J3 and J4, respectively. These plans to monitor the pollutants of concern draw upon monitoring outlined in the City's
Stormwater Management Plan (Al, A2) and include: ambient monitoring for chemistry (13) and benthic macroinvertebrates (19),
streamflow monitoring (17), rainfall monitoring (137, 138), and special studies to target sources of bacteria in Northeast Creek (e.g.,
microbial source tracking [141]) and sediment in Third Fork Creek (e.g., bank pin monitoring [149], root dendrogeomorphology [151]).
Please refer to the Assessment and Monitoring Section (Section 1) for more detail on these monitoring efforts. The City also
partners with the Upper Cape Fear River Basin Association to monitor for fecal coliform bacteria at one location in Northeast Creek
(136). The City's Outfall Screening Program (see Section II.D.2.c of the Self -Audit) monitors outfalls throughout the city, including in
Northeast Creek and Third Fork Creek. A process to locate and discover unknown and new major outfalls throughout the city,
including in Northeast Creek and Third Fork Creek, is provided in document J8.
II.J.3.e.
Additional
Within 24 months the permittee shall prepare a plan that:
---
---
Measures
1. Describe additional measures to be implemented by the permittee designed to
achieve the permittee's MS4's NPDES WLA and to reduce the TMDL pollutant of
Yes
J3, J4
concern to the MEP within the watershed to which the TMDL applies.
2. Provide an explanation as to how those measures are designed to achieve the
permittee's MS4's NPDES regulated WLA to the MEP within the watershed to which
Yes
J3, J4
the TMDL applies.
Comments
1. Section 7 (Newly Proposed Pollution Prevention and Mitigation Measures) of the TMDL Response Plans lists the proposed
measures. Table 3, in Section 7, lists the timeline, relative cost, and impact on reducing the POC of these new measures (J3, J4).
These measures are in addition to the six minimum measures.
2. Section 7 (Newly Proposed Pollution Prevention and Mitigation Measures) of the TMDL Response Plans describes how the
proposed measures may reduce the pollutants of concern (J3, J4).
NCS000249_Durham 2022 MS4 Self -Audit Page 41 of 45

Total Maximum Daily Loads (TMDLs)
I I.J.3.f.
Implementation
Within 48 months the permittee shall prepare a plan that:
---
Plan
1. Describe the measures to be implemented within the remainder of the permit
term designed to achieve the MS4's NPDES WLA and to reduce the TMDL pollutant of
Yes
J3, J4
concern to the MEP;
2. Identify a schedule, subject to Division approval, for completing the activities.
Yes
J3, J4
3. Implement the permittee's TMDL plan.
Yes
A3-A5, J-,
Comments
1. Section 7, Table 3 (Newly Proposed Pollution Prevention and Mitigation Measures) of the TMDL Response Plans lists the
proposed measures with timelines for implementing the planned measures (13,14). In order to determine the feasibility of new
measures, these measures listed in Table 3 were evaluated with respect to the cost to implement, the estimated impact on
reducing the pollutant of concern, and the timeline to implement the measure. Other new measures that were considered, but
were not feasible to implement, are listed in Appendix B of the TMDL Response Plans. Thus, the resulting measures in Table 3 are
those that the City is implementing to eliminate the pollutant of concern to the maximum extent practicable. Existing measures that
will continue to be implemented are described in Section 6-Table 2 (13,14).
2. Section 7, Table 3 (Newly Proposed Pollution Prevention and Mitigation Measures) of the TMDL Response Plans lists the
proposed measures with timelines for implementing the planned measures (13,14). Existing measures that will continue to be
implemented are described in Section 6, Table 2 of the TMDL Response Plans.
3. The TMDL Response Plans for Northeast Creek and Third Fork Creek have been implemented by the City. Implementation of
existing and proposed measures is tracked annually in Section 11 of the City's NPDES Stormwater Annual Report (A3-A5). This
section covers both Northeast Creek and Third Fork Creek. Implementation of individual measures is also recorded at the end of the
City's fiscal year on a TMDL Response Plan Dashboard (17)
II.J.3.g.
1. The permittee's plan must outline ways to track progress and report successes
A3-A5,
Incremental
designed to achieve the MS4's NPDES regulated WLA and to reduce the TMDL
yes
Success
pollutant of concern to MEP within the watershed to which the TMDL applies.
J3, J4, J7
Comments
Section 10 and Appendix C of the TMDL Response Plans for Northeast Creek and Third Fork Creek state ways to track success to
achieve the MS4 WLA (13,14). Section 10 describes tracking and reporting related to water quality monitoring data. Appendix C
describes tracking of the implementation of measures to reduce the pollutant of concern. Annual assessments of the
implementation of the TMDL Response Plans are provided in Section 11 of the City's NPDES Stormwater Annual Reports (A3-A5).
These annual updates provide metrics on the implementation of measures to reduce pollutants of concern. Pollutant of concern
load and concentration updates are provided as well. Monitoring data is updated annually in Section 10 of the annual reports. The
status of implementation of individual measures for the TMDL Response Plans is recorded at the end of the City's fiscal year on a
TMDL Response Plan Dashboard (J7).
NCS000249_Durham 2022 MS4 Self -Audit Page 42 of 45

Total Maximum Daily Loads (TMDLs)
II.J.3.h.
1. The permittee shall conduct and submit to the Division an annual assessment of
Reporting
the program designed to achieve the MS4's NPDES WLA and to reduce the TMDL
pollutant of concern to the MEP within the watershed to which the TMDL applies.
Yes
A3-A5, 11
Any monitoring data and information generated from the previous year are to be
submitted with each annual report.
Comments
Annual assessments of the program are provided in Section 11 of the City's NPDES Stormwater Annual Reports (A3-A5). These
annual updates provide metrics on the implementation of measures to reduce the pollutants of concern. Pollutant of concern load
and concentration updates are provided in Section 11 as well. Monitoring data is updated annually in Section 10 of the annual
reports. All monitoring data is available on the City's Water Quality Web Portal (11)
Additional
n/a
Comments:
NCS000249_Durham 2022 MS4 Self -Audit Page 43 of 45

NCS000249_Durham 2022 MS4 Self -Audit Page 44 of 45

NCS000249_Durham 2022 MS4 Self -Audit Page 45 of 45

Site Visit Evaluations
NCS000249 Durham MS4 Site Visit Evaluations

Contents
Site Visit Evaluation: Municipal Facility No. 1.........................................................................................3
Site Visit Evaluation: Municipal Facility No. 2.........................................................................................9
Site Visit Evaluation: Municipal Facility No. 3.......................................................................................17
Site Visit Evaluation: Municipal Facility No. 4.......................................................................................21
Site Visit Evaluation: Municipal Facility No. 5.......................................................................................26
Site Visit Evaluation: Dry Weather Screening and IDDE Investigation — Outfall 1...............................32
Site Visit Evaluation: Dry Weather Screening and IDDE Investigation — Outfall 2 ...............................
34
Site Visit Evaluation: Private Industrial Facility No. 1...........................................................................41
Site Visit Evaluation: Private Industrial Facility No. 2...........................................................................45
Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1.....................................49
Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 2.....................................
54
Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 3.....................................
57
Site Visit Evaluation: Assessment & Monitoring Ambient Stream Monitoring ...................................
61
Site Visit Evaluation: Construction Site No. 1........................................................................................
63
Site Visit Evaluation: Construction Site No. 2........................................................................................
65
Attached:
Investigation Field Audit March 2022
Investigation Field Audit April 2021
NCS000249 Durham MS4 Site Visit Evaluations

Site Visit Evaluation: Municipal Facility No. 1
Facility Name:
Date and Time of Site Visit:
Go Durham Transit
10/19/2021
10:00 - 11:45 AM
Facility Address:
Facility Type (Vehicle Maintenance, Landscaping, etc.):
1907 Fay Street
Bus maintenance
Name of MS4 inspector(s) evaluated:
Most Recent MS4 Inspection (List date and name of inspector):
Audrey Britton
12/8/2020
Audrey Britton; Mikel Corporaal
Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name
Title
Keith Kimrey
Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific? The site has a
notebook with records and are working on new SWMP. COC is out of date and sampling reports are out of date. Missing 3rd quarter
results. Inspector requested up to date versions within 1 week.
What type of stormwater training do facility employees receive? How often?
Training is contracted out including NPDES training. Most of the forms were blank. Last training appeared to be in 2019.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
Audrey noted she received initial field training by her supervisor for inspections and have annual training for good housekeeping
and illicit discharge.
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
Yes, Audrey knew the permit requirements and that the general permit for transportation has recently been moditied and requires
quarterly sampling for monitoring
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Yes, Audrey identified those locations where there is potential for pollution and made sure that proper best management practices
were employed and made suggestions for improvements.
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form?
Yes. This city has a standardized checklist for all industrial site stormwater inspections and the inspector used it properly.
Does the MS4 inspector's process include taking photos?
Yes. The inspector uses photographs to document any issues noted and as reminders for any follow up (see attached)
Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)?
Yes. The inspector requested the stormwater pollution prevention plan and looked through the document for the appropriate
recordkeeping and site plan. It was noted they did not have a recently updated Stormwater plan, monitoring, or training records.
NCS000249 Durham Site Visit Evaluations

Site Visit Evaluation: Municipal Facility No. 1
Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge?
es, the inspector walked the entire site and inspected all the outfalls in detail.
Did the MS4 inspector miss any obvious areas of concern? If so, explain:
e inspector did not miss any obvious potential pollution issues.
Does the MS4 inspector's process include presenting the inspection findings to the facility contact?
—owing the inspection, a brief meeting was conducted to discuss the findings and what the expectations were for follow up
including additional information regarding the missing documentation.
Inspection Results
Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)?
No corrective actions were required other than updating the Stormwater plan and records.
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
The inspector provided specific dates for providing the additional documentation required and for addressing some minor site
issues.
Notes/Comments/Recommendations
• Overall, the inspector did a fine job of inspecting the site and the site is well maintained.
• Inspector was aware of last inspection, what was found needing work and what was requested for that work.
• Obvious weakness was recordkeeping.
• The site is relatively clean, and the stormwater ponds are in good shape and free of any signs of pollution.
• The facility exceeds requirements by having all curb inlets protected by geotextile filters.
• Eroded areas around the stormwater pond have recently been repaired and seeded.
• The inspector recommended that the facility operator have drip pans or oil dry available for leaking vehicles and indicated
they have those in the vehicles and that they look for leaks as part of daily inspections.
• Inspector recommended having one or more notebooks with just the current information available. Past records can be in
different notebooks stored separately to avoid confusion.
• Inspector recommended labeling any empty containers to be disposed of and making sure they are sealed.
NCS000249 Durham Site Visit Evaluations 4

Figure 1. Some liquid containers were unlabeled and not well sealed
Figure 2. Wash water was contained within the bay
NCS000249 Durham Site Visit Evaluations

Figure 3. Most inlets were protected with filters
Figure 4. Waste drums were well labeled with caps over lids
NCS000249 Durham Site Visit Evaluations

Figure 5. SCMs were well maintained
Figure 6. Most liquids had secondary containment
NCS000249 Durham Site Visit Evaluations

Figure 7. Flammable materials were properly stored
Figure 8. Eroded areas were being stabilized with seed and mulch
NCS000249 Durham Site Visit Evaluations 8

Site Visit Evaluation: Municipal Facility No. 2
Facility Name:
Date and Time of Site Visit:
Durham Public Works Operations Center
10/21/2021 1:30 pm —till 4:30pm
Facility Address:
Facility Type (Vehicle Maintenance, Landscaping, etc.):
1100 Martin Luther King
Vehicle Maintenance, Street Maintenance, Water & Sewer
Maintenance
Name of MS4 inspector(s) evaluated:
Most Recent MS4 Inspection (List date and name of inspector):
Jim Azarelo — IDDE Supervisor, Public Works
Facility requires Tier 2 NPDES monitoring - monthly sampling
Anna Smith - Technician, Stormwater and GIS Services
(5/13/2021, 6/3/2020, 2/6/2020, 1/21/2020 by Jim Azarelo)
I Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name
Title
.andin
Public Works Supervisor, Stormwater Maintenance
Tim Segard
Asst. Superintendent, Water and Sewer Maintenance -
IObservations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific?
Yes, but needs updating. John indicated that Jim Fry is in the process of updating the plan. The contact list and spill history need to
be updated. The plan also needs to include the latest general permit.
What type of stormwater training do facility employees receive? How often?
Staff associated with potential impacts to stormwater pollution receive basic stormwater 101 training. The last training recorded in
the facility documentation was in 2019.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
Annual classroom training by supervisor with annual audits. Training includes IDDE.
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Yes, the inspector was idmiliar with the industrial site requirements.
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form?
Yes, ir— inspector uses a standard facility checklist loaded on a taus
Does the MS4 inspector's process include taking photos?
Yes (see attached)
Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)?
Yes, the inspector conducted a thorough review of the SWPPP.
NCS000249 Durham Site Visit Evaluations

Site Visit Evaluation: Municipal Facility No. 2
Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge?
(es, although some portions of the site had to be observed at a distance since they were inaccessible due to proximity to the
adjacent creek.
Did the MS4 inspector miss any obvious areas of concern? If so, explain:
No, the inspector conducted a thorough inspection.
Does the MS4 inspector's process include presenting the inspection findings to the facility contact?
es, findings were presented after the inspection.
Inspection Results
Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)?
Yes, the inspector conveyed areas of concern including a dumpster with rust holes on the bottom, oily parts and solvent cans in the
scrap metal bin that may leak, drums that needed labels, empty spill kits at fuel island, the need to update records in SWPPP, the
need to update spill history, needed training, asphalt tack dripping in one shed and minor equipment leaks under another shed that
equire absorbent and clean-up.
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
No significant threats to water quality were identified so the inspector indicated the listed items would be checked for corrections
at the next scheduled inspection in January or February of 2022.
Notes/Comments/Recommendations
1. Not many spill kits observed —Jim explained that spill kits have been treated as trash cans in the past
so spill materials are stored in a garage bay and used as needed.
2. Since the property floods, how and where tanks and materials are stored is a concern to be
considered in storage practices
3. Some trash cans were full to overflowing
4. Some outfalls could not be observed easily due to fencing but are observed during site inspections
and monitoring
5. Interior liquid storage practices should be evaluated, and secondary containment provided where
leaks from bulk storage may leave the building and reach the stormwater system
6. Since maintenance of oil -water separator at fuel island is handled by the Fleet Services Division,
records were not available — spill kits at fuel island need to be restocked this is the responsibility of
Fleet Services
7. Drain at fuel island says drains to storm water when it does not
NCS000249 Durham Site Visit Evaluations 10

Figure 9. Many inlets are protected with filters
As.
Figure 10. Minor dripping from asphalt tack equipment
NCS000249—Durharn Site Visit Evaluations 11

yq 4`
r I i� -4Af
mil
am""a
Figure 11. Minor oil lead from equipment
i
Tf �
Figure 12. Some oil contaminated parts in scrap metal bin
NCS000249 Durham Site Visit Evaluations 12

Figure 13. Secondary containment provided for bulk storage
Figure 14. Dumpster rusting and lid left open
NCS000249 Durham Site Visit Evaluations 13

ho
Figure 15. Salt barn door damaged so allows exposure
Figure 16. Some containers need labels
NCS000249 Durham Site Visit Evaluations 14

Figure 17. Emergency shutoff easily visible
Figure 18. Inlet grate improperly labeled
NCS000249 Durham Site Visit Evaluations 15

a
Figure 19. Spill kits need to be restocked
NCS000249 Durham Site Visit Evaluations 16
Figure 19. Spill kits need to be restocked
NCS000249 Durham Site Visit Evaluations 16

Site Visit Evaluation: Municipal Facility No. 3
Facility Name:
Date and Time of Site Visit:
Public Works - Fleet Maintenance
October 22, 2021 at 1 PM till 3:30 PM
Facility Address:
Facility Type (Vehicle Maintenance, Landscaping, etc.):
1900 Camden Avenue
Vehicle and Roadway Maintenance
Name of MS4 inspector(s) evaluated:
Most Recent MS4 Inspection (List date and name of inspector):
Audrey Britton
)/1/2021—Audrey Britton and Jim Azarei,
I Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name
Title
..iePnanie iayiL,
n Ferguson
IObservations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific?
Yes, the facility has a site -specific plan, but it needs to be updated. The site plan provided does not include the addition of a salt
barn. The facility had a copy of the latest General Permit. The last sampling event was noted as July 21, 2021. The site has 10
outfalls but 3 are sampled as representative.
What type of stormwater training do facility employees receive? How often?
Stormwater personnel normally provide annual training to facility staff, but no training took place in 2020 due to Covid restrictions
and none had taken place yet in 2021. Staff were unsure how new employees get training.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
Audrey noted they don't have formal training for inspections but receive on the job training and periodic audits from their
supervisor. They also receive annual refresher training for good housekeeping and illicit discharge.
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
Yes, the inspector knew the permit requirements and that the general permit for transportation has recently been modified and
requires quarterly sampling for monitoring The Inspector has a thorough knowledge of inspection procedures and documenting
inspections through the program's database
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Yes, the inspector identified those locations where there is potential for pollution and made sure that proper best management
ractices were employed and made suggestions for improvements
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form?
!s, a standard City checklist for industrial site inspections was used
NCS000249 Durham Site Visit Evaluations 17

Site Visit Evaluation: Municipal Facility No. 3
Does the MS4 inspector's process include taking photos?
Yes, the inspector took photos to document her findings (see attached)
Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)?
Yes, the inspector thoroughly reviewed the facility's SWPPP and discussed any concerns with the facility manager. It was noted that
some of the material needed updating.
Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge?
Yes, the inspector walked the entire site and observed all points of discharge
Did the MS4 inspector miss any obvious areas of concern? If so, explain:
No, the inspector did not miss any obvious potential pollution issues.
Does the MS4 inspector's process include presenting the inspection findings to the facility contact?
Yes, the inspector provided the findings at the conclusion of the inspection
Inspection Results
Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)?
, ne inspector noted that there were no spill kits at the fuel island, that a leak in the biodiesel pump at the fuel islands needed to be
repaired, and that the facility needs to do a better job containing the material leaving the storage barn.
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
The inspector provided the site inspector with dates for updating the SWPPP and addressing the site deficiencies observed.
Notes/Comments/Recommendations
Removal of all aut011IUuve limas aL Lnis facility is contracted out to Noble Oil
The inspector recommended draining fluids vehicle to be salvaged as part of pollution prevention
The facility keeps their scrap dumpsters covered
While the fuel pumps lacked spill kits the facility manager noted that they maintain oil dry stored inside the facility for use when
needed.
The floor drains and vehicle wash area drain to an oil/water separator and then the sanitary sewer system
The SWPPP needs to be updated and signed
The SWPPP calls for periodic inspections and completion of several forms and these need to be performed and documents kept up
to date
NCS000249 Durham Site Visit Evaluations 18

Figure 20. Sand escaping from storage barn
-jw--..a _:z s
Figure 21. Minor leak in biodiesel pump and no spill kits observed at fuel island
NCS000249 Durham Site Visit Evaluations 19

Figure 22. Silt sock and SCM to treat runoff
Figure 23. Silt socks installed at inlets and curb cuts
NCS000249 Durham Site Visit Evaluations 20

Site Visit Evaluation: Municipal Facility No. 4
Facility Name:
Date and Time of Site Visit:
Durham solid waste operation facility
10/28/2021
(Truck Wash & Transfer Station)
9:00 - 11:30 AM
Facility Address:
Facility Type (Vehicle Maintenance, Landscaping, etc.):
1811 Camden Avenue
Solid Waste Services Operations and Vehicle Maintenance
2110 E Club Blvd.
Name of MS4 inspector(s) evaluated:
Most Recent MS4 Inspection (List date and name of inspector):
Audrey Britton
2/9/2021
Audrey Britton and Mikel Corporaal
Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name
Title
Jacquetta Bunch -Truck Wash/Admin Bld.
Sr. Assistant Solid Waste Manager
Muriel Williams - Transfer Station
Facility Manager for Contractor (Hilco/GFL)
I Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific?
Two separate sites are part of the solid waste operation. A City owned truck wash and a City owned waste transfer station with
management contracted out to Hilco/GFL. Both facilities have their own site specific SWPPPs.
What type of stormwater training do facility employees receive? How often?
Facility personnel normally receive annual training but due to Covid restrictions training did not take place in 2020. There was some
training documentation, but it was unclear as to who was receiving training.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
The inspector received onboard training in pollution prevention, good housekeeping, and illicit discharges as well as the job training
and periodic audits conducted by her supervisor. This is supplemented by annual refresher training.
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
Yes, the inspector has a thorough knowledge of both the MS4 and Industrial Permit requirements
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Yes, the inspector well versed regarding all aspects of pollution prevention and good housekeeping
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form?
s, the inspector used Durham's standard industrial site inspection checklist
Does the MS4 inspector's process include taking photos?
es, the inspector used images to document her findings and observations (see attached)
Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)?
Yes, the inspector thoroughly reviewed the SWPPP for both facilities
Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge?
Yes, the inspector walked both sites and observed all outfalls
NCS000249 Durham Site Visit Evaluations 21

Site Visit Evaluation: Municipal Facility No. 4
Did the MS4 inspector miss any obvious areas of concern? If so, explain:
No, the inspector did not miss any obvious potential pollution issues
Does the MS4 inspector's process include presenting the inspection findings to the facility contact?
Yes, the inspector met with the facility representatives at the conclusion of the inspection to discuss her findings
Inspection Results
Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)?
Yes, the following corrective actions were identified
The truck wash site plan does not show where all drains go including drain outside wash bay and inside storage building.
The truck wash floor drain non-stormwater certification and SCM inspection sampling documents were out of date.
Truck wash responsibilities in the SWPPP need to be updated
A dumpster at the truck wash had a plug but was leaking anyway and needed to be repaired or replaced
Lids on trash bins at the truck wash need to be kept closed and damaged/leaking bins replaced
The site plan for the transfer station needs to be updated
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
ne inspector provided the site managers with schedules for corrective actions
Notes/Comments/Recommendations
This is really 2 separate sits under one department/permit: (1) a truck wash and administration building with some storage and (2) a
waste transfer station with household hazardous waste collection. The Transfer station is operated by a contractor — Hilco/GFL
City Stormwater personnel provide monitoring for the truck wash
The truck wash is swept 2x per day according to the manager
It may be possible for the truck wash to obtain a no exposure certification since vehicle washing is the only activity and it is now
contained within a covered structure
The contractor handles monitoring for the transfer station
The transfer station includes sediment bags in most of the inlets for additional pollution control
The hazardous waste receiving area is covered and surrounded by a continuous concrete berm with no drain to contain spills so any
accumulated material must be vacuumed out
NCS000249 Durham Site Visit Evaluations 22

A
Figure 24.Leaking plug at dumpster
Figure 25. Lids left open on trash bins
NCS000249 Durham Site Visit Evaluations 23

Figure 26. Each facility had its own specific SWPPP
Figure 27. Inlets protected with silt screens
NCS000249 Durham Site Visit Evaluations 24

Figure 28. SCMs were observed to be functioning properly
Figure 29. Hazardous waste area covered with perimeter berm to contain spills
NCS000249 Durham Site Visit Evaluations

Site Visit Evaluation: Municipal Facility No. 5
Facility Name:
Date and Time of Site Visit:
South Durham Water Reclamation Facility and Lab
10/26/2021
10am - 2:15pm
Facility Address:
Facility Type (Vehicle Maintenance, Landscaping, etc.):
6605 Farmington Road, Chapel Hill
Wastewater Treatment
Name of MS4 inspector(s) evaluated:
Most Recent MS4 Inspection (List date and name of inspector):
Mikel Corporaal
5/28/2021 by Mikel Corporaal
Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name
Title
Charlie (Charles) Cocker
Superintendent
Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific?
Yes, there is a site specific SWPPP, but it is in the process of being updated to reflect recent substantial facility changes
What type of stormwater training do facility employees receive? How often?
Employees receive site specific onsite training, but last training was in November of 2020. Internal training was documented in the
SWPPP notebook. Emily Rhode with stormwater used to provide the training but she has been replaced with Anna Smith. The
Stormwater group is working on Covid acceptable training alternatives.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
The inspector receives annual refresher training and has several certifications in pollution prevention and SCM inspection.
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
Yes, the inspector is well versed in permit requirements and the inspection of industrial sites.
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Yes, the inspector is very familiar with PPGH.
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form?
es, the inspector uses the City's standard industrial site inspection form and checked all boxes.
Does the MS4 inspector's process include taking photos?
Yes, taking photos is a standard procedure for inspections. See attached
Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)?
Yes, the site's SWPPP was thoroughly reviewed along with the required inspection, monitoring, and training records.
NCS000249 Durham Site Visit Evaluations 26

Site Visit Evaluation: Municipal Facility No. 5
Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge?
Yes, the inspector walked the entire site and observed all outfalls.
Did the MS4 inspector miss any obvious areas of concern? If so, explain:
I did not observe any areas of concern that were not noted by the inspector other than a dumpster that was not checked. It was
later discussed, and the dumpster belongs to the construction contractor and is to be removed shortly.
Does the MS4 inspector's process include presenting the inspection findings to the facility contact?
es, the findings of the SWPPP review and the site inspection were discussed with the facility manager.
Inspection Results
Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)?
Yes, the site plan needs to be updated to reflect recent site modifications and new BMPs; minor erosion was observed and noted
for stabilization; straw much was entering yard inlets and temporary inlet protection was recommended until the areas were fully
stabilized; an exposed open top drum needed to be removed or stored properly.
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
The site was determined to be in compliance with only minor housekeeping and stabilization needs noted.
Notes/Comments/Recommendations
The site has an NPDES Industrial site permit but analytical monitoring is not required for this site since no vehicle maintenance
takes place on site. However, they do conduct and keep qualitative observation records of their outfalls.
The have an equipment cleaning area for their dump trucks which drains back into the wastewater treatment process.
Potential pollution activities occur at several locations, but all these areas are designed to drain back into the treatment works and
not to stormwater.
The site has been under construction for operation modifications. The City inspector noted he issued their contractor, Crowder
Construction an NOV for an illicit discharge as part concrete work. Also has provided notices to correct sediment issues stemming
from the ongoing construction which is now completed with seeding and mulching having been completed.
NCS000249 Durham Site Visit Evaluations 27

Figure 30. Kudos for labeling riparian buffers
Figure 31. Sediment and mulch entering storm drains. Inspector recommended wattles or other temporary
sediment control until fully stabilized.
NCS000249 Durham Site Visit Evaluations 28

Figure 32. Dumpster onsite from construction work but will be removed soon.
Figure 33. Dumpster at screening building is leaking, but area is designed to drain back into the treatment works.
Site manager is considering painting lines to make sure dumpsters are properly located on drain pads.
NCS000249 Durham Site Visit Evaluations 29

Figure 34. Area where trucks are loaded with biosolids. Possible pollution area due to spillage, tracking by trucks,
and windblown dried solids. Area under building slopes and drains to treatment works, but beyond that drains to
storm water. Site manager noted area is swept regularly.
Figure 35. View of biosolids dropping into trucks.
NCS000249 Durham Site Visit Evaluations 30

Figure 36. Open top drum to be removed or stored properly.
NCS000249 Durham Site Visit Evaluations 31

Site Visit Evaluation: Dry Weather Screening and IDDE Investigation — Outfall 1
Outfall ID Number:
Date and Time of Site Visit:
4626
11/3/2021 — 10:45am
Outfall Location:
Outfall Description (Pipe Material/Diameter, Culvert, etc.):
Downstream of CB on Acadia between
18" RCP
Avender and Elgin Streets
Receiving Water:
Is Flow Present? If So, describe (Color, Approximate Flow Rate,
Ellerbe Creek
Sheen, Odor, Floatables/Debris, etc.):
No flow was present
Most Recent Outfall Inspection/Screening (Date):
2 years
Days Since Last Rainfall:
Inches:
0.16
Name of MS4 Inspector(s) evaluated:
Blaine Lary & Melissa Harrison
Observations
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
I he inspectors receive onboarding training in basic stormwater, PPGH, and IDDE. This is supplemented by on-the-job training by a
supervisor. Inspector performance is also periodically audited by their supervisor.
Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations?
Yes, the inspectors had a thorough knowledge of what characteristics would indicate an illicit discharge as well as what
characteristics are naturally occurring such as iron oxidizing bacteria sheens.
Inspection Procedures
Does the inspector's process include the use of a checklist or other standardized form?
Yes, the inspectors conduct their investigations using an SOP that includes daily calibration of their meters and complete a
standardized checklist that includes visual observations and testing of temperature, pH, DO, and conductivity as well as higher
levels of examination. The SOP also calls for the collection of samples for further analysis if established benchmarks are exceeded.
(see images)
Does the inspector's process include taking photos?
Yes, the inspectors take photos of each outfall investigated.
Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they?
No, the inspectors were very through in their examinations.
NCS000249 Durham Site Visit Evaluations

Site Visit Evaluation: Dry Weather Screening and IDDE Investigation — Outfall 1
Inspection Results
Did the outfall inspection result in any work orders or maintenance requests? If so, for what issue(s)?
io, the outfall did not need any maintenance.
Will a follow-up outfall inspection be conducted? If so, for what reason?
i follow up inspection was warranted.
Notes/Comments/Recommendations
The City performs outfall screening on select watersheds each year. This investigation targeted the Ellerbe Creek Watershed.
There were no requests for IDDE investigations on the day of observations however the inspectors explained their IDDE process
should they receive a reported IDDE complaint.
• IDDE reports come in via City employees, a water pollution hotline, the City's general "one -call" system and online
reporting
• The investigation request is assigned to one of the inspectors
• The inspector is required to respond in a fixed time depending on the nature of the suspected IDDE
• The inspector investigates the discharge, determines if it is an illicit discharge and then takes appropriate action to
eliminate the discharge and take enforcement action if necessary, including a Notice of Requirement, Notice of Violation,
and issuance of fines
• The City has a detailed SOP, dated 2014, for conducting IDDE investigations
• Each investigation is assigned a unique number and tracked in a database that goes back to 1996
• They can search the database to determine if there is a history of discharges for a particular location which can be used in
determining any enforcement penalties
• The City as a very thorough and detailed SOP for categorizing violations and determining penalties
• Their system can automatically generate enforcement letters
• Inspectors also have educational materials available to provide to citizens regarding water pollution and illicit discharges
NCS000249 Durham Site Visit Evaluations 33

Site Visit Evaluation: Dry Weather Screening and IDDE Investigation — Outfall 2
Outfall ID Number:
Date and Time of Site Visit:
308-
11/3/2021 — 10:50am
Outfall Location:
Outfall Description (Pipe Material/Diameter, Culvert, etc.):
Downstream of greenway trail near
24" RCP
the intersection of Acadia and Avender Streets
Receiving Water:
Is Flow Present? If So, describe (Color, Approximate Flow Rate,
Ellerbe Creek
Sheen, Odor, Floatables/Debris, etc.):
Flow was present and recorded as a trickle, clear, with no visible
Most Recent Outfall Inspection/Screening (Date):
2 years
sheen, no odor, and minor floatables
Days Since Last Rainfall:
Inches:
Name of MS4 Inspector(s) evaluated:
Blaine Lary & Melissa Harrison
IObservations
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
The inspectors receive onboarding training in basic stormwater, PPGH, and IDDE. This is supplemented by on-the-job training by a
supervisor. Inspector performance is also periodically audited by their supervisor.
Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations?
Yes, the inspectors had a thorough knowledge of what characteristics would indicate an illicit discharge as well as what
characteristics are naturally occurring such as iron oxidizing bacteria sheens.
Inspection Procedures
Does the inspector's process include the use of a checklist or other standardized form?
Yes, the inspectors conduct their investigations using an SOP that includes daily calibration of their meters and complete a
standardized checklist that includes visual observations and testing of temperature, pH. DO, and conductivity as well as higher
levels of examination. The SOP also calls for the collection of samples for further analysis if established benchmarks are exceeded.
(see images)
Does the inspector's process include taking photos?
Yes, the inspectnrs take photos of Pach nutfall investigated
Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they?
o, the inspectors were very through in their examinations
Inspection Results
Did the outfall inspection result in any work orders or maintenance requests? If so, for what issue(s)?
No, the outfall did not need any maintenance.
Will a follow-up outfall inspection be conducted? If so, for what reason?
No follow up inspection was warrantea
Notes/Comments/Recommendations
NCS000249 Durham Site Visit Evaluations

Site Visit Evaluation: Dry Weather Screening and IDDE Investigation — Outfall 2
The City performs outfall screening on select watersheds each year. This investigation targeted the Ellerbe Creek Watershed.
There were no requests for IDDE investigations on the day of observations however the inspectors explained their IDDE process
should they receive a reported IDDE complaint.
• IDDE reports come in via City employees, a water pollution hotline, the City's general "one -call" system and online
reporting
• The investigation request is assigned to one of the inspectors
• The inspector is required to respond in a fixed time depending on the nature of the suspected IDDE
• The inspector investigates the discharge, determines if it is an illicit discharge and then takes appropriate action to
eliminate the discharge and take enforcement action if necessary, including a Notice of Requirement, Notice of Violation,
and issuance of fines
• The City has a detailed SOP, dated 2014, for conducting IDDE investigations
• Each investigation is assigned a unique number and tracked in a database that goes back to 1996
• They can search the database to determine if there is a history of discharges for a particular location which can be used in
determining any enforcement penalties
• The City as a very thorough and detailed SOP for categorizing violations and determining penalties
• Their system can automatically generate enforcement letters
• Inspectors also have educational materials available to provide to citizens regarding water pollution and illicit discharges
Figure 37. Ellerbe Creek Outfall Screening Plan
NCS000249 Durham Site Visit Evaluations 35

1
Figure 38. Daily calibration of test equipment.
Figure 39. GIS mapping showing unique ID's and locations of each outfall.
NCS000249 Durham Site Visit Evaluations 36

--L-_.---
[-
Figure 40. Outfall database information.
Figure 41. Images of each outfall are taken (Outfall1—46262).
NCS000249 Durham Site Visit Evaluations 37

Figure 42. SOP flow chart for outfall screening.
LJI
Y VVCQLIICI </ULIQ11 M,IWVIIIII U IIIVCJII QLIUII I I IUUVIJ
>_35° C
Temperature
H
<6.5 or >8.5
Specific Conductivity
>_1000 s/cm winter / >_800 s/cm summer
Ammonia
Any detectable concentration*
Field Parameters
Chlorine
Any detectable concentration
Detergents
Any detectable concentration
unless stagnant water with no sewage indicators and < 2 m /L
Above are independent of sensory indicators of an illicit discharge observed at an outfall. Such a case will always
trigger an investigation.
Figure 43. Current (2021) triggers for further investigation.
NCS000249 Durham Site Visit Evaluations 38

Fadlity ID
Team
—
Date /� _ y
fK
Time (24 hour) }�i
—
■",t�
I Data#dse entry by r�
Accesslhilky
C41Essihl
Inaccessible (reasor1):
Entry Consent
Nolneeded
Venied
Granted
Granted
flow?
nano
5uspcct pool with polluLant indicators
trickle
Moderate
Substantlal
Submerged/Burled?
N10
Bottom > 50% 310%
Structure Damage
■
Deposits/stains
None
0vtjaII5
ally Algae
Flow Suspect
Othrr(notesl
Pools
afar
PrLSunt?
with or
Description
SeSrerlty
Se ++qe Rancid/Saur
—Faint
odor
res No
PetrolE urn Sulfide
—Easily Detected
�thpr (nb[e5}
,
3—Ne fre from distance
1—Faint In sample hattlq
w
br/Rher
Color
ye.y Na
G
2—Qbuaausinsamplelypttle
Rel
3�- Ohviau5 in outfall flow
1—Slightly Bondy
Turbld�ky
yes Np
See severity
2—cloudy
3— Opaque
1— Fewl5light
5e a Suds
Floatahles (not trash)
Yes No
PeLr um
2— Some, type un known
Other (no ]
3—Some, typeknpwrn
Temperature ('C/
Conduckiu+ty RNSfcm
pF+
DO (-SILT
Ammonia jmgJLJ
DO
Ch ne (nWL)
Detergents (MRAI
Copper mgf L)
Pheno is (mt f L)
Lab Sample?
yrs
aJo
rOroivus discharge
sus RE! Et Discharge
N kLmLlal MscNarge
unlikely Discharge
Figure 44. A checklist for each outfall investigation is completed (Outfall 1 — #46262).
NCS000249 Durham Site Visit Evaluations 39

Figure 45. A checklist for each outfall investigation is completed (Outfall 2 — #30831).
NCS000249 Durham Site Visit Evaluations 40

Site Visit Evaluation: Private Industrial Facility No. 1
Facility Name:
Date and Time of Site Visit:
SCM Metals
11/2/2021 2:00 pm
Facility Address:
Facility Type (Vehicle Maintenance, Landscaping, etc.):
2601 Weck Drive
scrap metal yard
Name of MS4 inspector(s) evaluated:
Most Recent MS4 Inspection (List date and name of inspector):
Mikel Corporaal and Jim Azarelo
4/16/2021 by Charlotte Dawn and Patrick Hogan
Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name
Title
Westley Riscili
Environmental Specialist
Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific?
(es, they have a facility specific SWPPP available online which was last updated on March 8 2021
What type of stormwater training do facility employees receive? How often?
Mr. Riscili indicated they conduct training, but documentation was not included in SWPPP. He indicated they provide classroom
training using a PowerPoint presentation. They train new hires within 2 weeks and others receive annual training. Documentation
of stormwater and wastewater training was found. They train 4 shifts. The PowerPoint used for training was reviewed.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
Mikel has had significant personal training and their supervisor, Jim Azarelo, conducts annual inspector training
Did the MS4 inspector appear knowledgeable about Permit requirements for private industrial sites?
Yes, the inspector had a thorough knowledge of the permit requirements
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Yes, the inspector was knowledgeable of the elements of proper PPGH
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form?
Yes, the inspector uses the City's detailed standard industrial site inspection checklist
Does the MS4 inspector's process include taking photos?
Yes (see attached)
Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)?
Yes, the SWPPP was stored online and was reviewed in detail
NCS000249 Durham Site Visit Evaluations 41

Site Visit Evaluation: Private Industrial Facility No. 1
Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge?
Yes, the entire site and all outfalls were inspected.
Did the MS4 inspector miss any obvious areas of concern? If so, explain:
No, the inspector addressed all identified potential stormwater pollution concerns.
Does the MS4 inspector's process include presenting the inspection findings to the facility contact?
Yes, the inspector sat down with the facility manager for a debriefing following the inspection. A follow up letter was also mailed to
the facility operator
Inspection Results
Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)?
Eroded areas on the site needing stabilization, barrels at one location lacked secondary containment, raw material was exposed to
rainfall and needed to be moved, an eroding channel at 3rd outfall needing stabilization, an apparent area of oil spillage needed
remediation, a possible source of non-stormwater discharge was noted for further investigation by the site manager. A substantial
mount of fugitive dust from manufacturing was observed throughout the site along with copper staining at downspouts.
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
Deadlines for correcting the above deficiencies was set for 12/7/2021. Additional deficiencies were to be remedied as soon as
possible but no later than the next inspection. These included: stabilizing channel erosion; removing accumulated sediment in some
drainage features, inspecting the dust capturing devices to ensure they are working properly along with vacuuming dust from
pavement. Since this facility operates under a State Stormwater Permit, the results were reported to NCDEQ
Notes/Comments/Recommendations
Site has an NPDES industrial permit
• The SWPPP was stored digitally and reviewed on a monitor
• The Inspector noted that cooling tower maintenance often involves harsh chemicals and should be performed to prevent
discharge to the storm sewer system
• It was noted that TSS, zinc and copper seem to have no benchmarks in the industrial permit.
• Lots of metal dust on site. Inspector curious as to why monitoring results do not reflect high metal concentrations. Also, fair
amount of disturbed area and sediment moving around that should result in high TSS which was not evident in the
monitoring data
NCS000249 Durham Site Visit Evaluations 42

Figure 46. Raw material was observed exposed to rainfall
Figure 47. Metal dust was observed on the ground
NCS000249 Durham Site Visit Evaluations 43

Figure 48. Rooftop runoff was staining the grovel
Figure 49. Spill kits present but some drums not on containment pallets
NCS000249—Durharn Site Visit Evaluations 44

Site Visit Evaluation: Private Industrial Facility No. 2
Facility Name:
Date and Time of Site Visit:
Thomas Concrete
11/30/2021, 10:30 AM
Facility Address:
Facility Type (Vehicle Maintenance, Landscaping, etc.):
2722 Angier Ave., Durham
Ready Mix Concrete Plant
Name of MS4 inspector(s) evaluated:
Most Recent MS4 Inspection (List date and name of inspector):
Melissa Harrison
10/14/2019 - Jim Azarelo
Environmental Planning and Compliance Specialist
Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name
Title
oaniel Lentz
Area Safety Manager
Brian Westfall
Facility Manager
Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific?
Yes, site has a site specific SWPPP but portions of it such as responsible person and Site Plan need to be updated — some records
were kept in a notebook and some maintained on-line
What type of stormwater training do facility employees receive? How often?
Basic housekeeping and spill prevention and response training are provided monthly
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
Melissa received onboarding training in basic pollution prevention as well as field training with supervisor. Her work is also
periodically audited by her supervisor.
Did the MS4 inspector appear knowledgeable about Permit requirements for private industrial sites?
(es, Melissa was familiar with the industrial site requirements
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
es, the inspector was familiar with PPGH requirements
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form?
Yes, the inspector utilized the City's standard facility inspection form.
NCS000249 Durham Site Visit Evaluations 45

Site Visit Evaluation: Private Industrial Facility No. 2
Does the MS4 inspector's process include taking photos?
Yes, the inspector documented concerns with photos (see attached)
Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)?
Yes, the inspector thoroughly reviewed the facility's SWPPP and associated documents
Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge?
the Inspector walked the entire site and observed the site's one outfall.
Did the MS4 inspector miss any obvious areas of concern? If so, explain:
The inspector did not miss any obvious areas of concern.
Does the MS4 inspector's process include presenting the inspection findings to the facility contact?
Yes, the inspector discussed her findings during the SWPPP review and throughout the site walk.
Inspection Results
Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)? Yes, needed corrective actions
were identified. These included: a need to update the SWPPP and site plan, a need to produce documents, exceedances of
benchmarks for several parameters, unsealed drums stored outside, lack of secondary containment, a leaking dumpster with the lid
open, discoloration of wet pond,
If compliance corrective actions were identified, what timeline for correction/follow-up was provided? The inspector requested
that missing documents be provided and that corrective actions to be completed in 3 weeks.
Notes/Comments/Recommendations
• SynTerra out of Cary consulting conducts quantitative monitoring and assists with SWPPP documentation
• The facility permit covers both stormwater and wastewater discharges
• Monitoring records demonstrate numerous exceedances of benchmarks and the site is currently in Tier 2
• Fugitive raw and processed materials are present on the ground over much of the facility which will contribute to
stormwater pollution if not properly captured and treated. It appears current BMPs are inadequate based on the
monitoring results
• The facility has shut down vehicle maintenance activities
• Cracks in concrete containment walls were repaired with urethane foam and not concrete
• Recent modifications to the SCMs (wet basins) did not appear to be designed by an engineer or approved by NCDEQ
NCS000249 Durham Site Visit Evaluations 46

Figure 50. Aerial image of facility
Figure 51. SWPPP was reviewed
NCS000249 Durham Site Visit Evaluations 47

f �1. eaa+iti caao.-'°-
PE14�� 8MP
saeL--
Figure 52. Site plan needs to be updated
Figure 53. Large quantities of loose concrete sediment on much of site
NCS000249 Durham Site Visit Evaluations 48

Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1
Site Name:
Date and Time of Site Visit:
Durham Parks & Recreation Office (ATT Phase E)
12/29/2021— 9:OOam
Site Address:
SCM Type:
502 Foster Street, Durham
Dry Pond
Most Recent MS4 Inspection (Include Date and Entity):
March 23, 2021 by Sam Jackson (City of Durham)
Name of MS4 Inspector(s) evaluated:
Most Recent MS4 Enforcement Activity (Include Date):
Sam Jackson
Notice of "minor functional issue" — March 23, 2021— minor
issues to be correct by next inspection
Name(s) and Title(s) of Site Representative(s) Present During the
Site Visit:
Name
Title
N/A — inspector only meets with owner if requested
N/A
Observations
Site Documentation
Does the site have an operation and maintenance plan?
Yes — the SCM is an older one constructed prior to requirements for as -built drawings and maintenance plans but the City has
developed plans for this device
Does the site have records of annual inspections? Are they performed by a qualified individual?
The City maintains record of annual inspections. This site is inspected only by the City Inspector and certified by Shea Bolick, PE, the
SCM inspections supervisor.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
The inspector has been trained in SCM inspection at NCSU and maintains an annual certification. He also has 3 years of experience
in SCM inspection.
Did the MS4 inspector appear knowledgeable about MS4 requirements for post -construction site runoff controls?
Yes, the inspector is very familiar with the NPDES MS4 requirements.
Did the MS4 inspector appear knowledgeable about post -construction BMPs (general purpose/function, components, 0&M
requirements, etc.)?
Yes, the inspector understands the functions of SCMs, their design, and maintenance needs.
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form? What format?
Yes, the City has specific inspection forms for each type of SCM that are used for inspections.
Does the MS4 inspector's process include taking photos?
Yes, the inspector documents his findings using photographs which are incorporated into the report and City data base.
NCS000249 Durham Site Visit Evaluations 49

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, the inspector reviews the SCMs as -built drawings and inspection records prior to the site visit. The inspector is also able to pull
up these records and drawings in the field using a ruggedized computer.
Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge?
Yes, the inspector inspects the entire SCM including the conveyances to and from the SCM.
Did the MS4 inspector miss any obvious operation and maintenance deficiencies? If so, explain:
No, the inspector did not miss any obvious operation or maintenance issues.
Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing?
Yes, the inspector prepares a letter for the SCM owner conveying the results of the inspection as well as any needed corrective
actions including a time frame to complete any corrections.
Compliance/Enforcement
What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in?
There were some minor erosion areas that were recorded as "Minor Functional Issues". The City has 4 levels to describe compliance
issues:
Monitor — pass inspection - for conditions that may be a concern in the future
Minor Functional Issues — pass inspection — for conditions that need to be corrected but do not pose a significant concern to the
function of the SCM
Partially Functional —fail inspection - the SCM failed the inspection and corrective action must be taken within 90 days (unless
major repairs are anticipated to require more than 90 days) and a new inspection report prepared
Not Functional —fail inspection —the SCM failed the inspection and corrective action must be taken within 90 days unless major
repairs are anticipated to require more than 90 days and a new inspection report prepared
If compliance issues were identified, what timeline for correction/follow-up was provided?
This corrective action classification requires the owner to take corrective action prior to the next annual inspection or face an
inspection failure notice. If major issues are identified, the owner is allowed 90 days to take corrective action and have the pond
reinspected.
Notes/Comments/Recommendations
• The inspector noted that they are able to conduct quality assurance inspections (following submittal of an annual inspection
report by a 3rd party) of all required SCMs in their jurisdiction annually
• The City's Stormwater Development Review Section includes: 1 Administrator, a Post Construction Supervisor, 2 SCM po9st
construction inspectors, a plan review section supervisor, and 5 plan reviewers (plus one part time) that both review plans and
inspect SCMs during construction up to final as -built acceptance.
• The City requires that the 0&M manual be attached to the 3rd party annual inspection report
• The City requires 3rd party inspectors to have a certification and be approved by the City
NCS000249 Durham Site Visit Evaluations 50

Figure 54. Inspector can access records and report forms in the field using ruggedized computer
Figure 55. Inspector has access to list of all SCMs and their anniversary date for annual inspections
NCS000249 Durham Site Visit Evaluations 51

Figure 56. Quality assurance inspection form on computer for completion by City Inspector
_ -n � nObu as b�llu.Pnl as bwlt pdf � � � •
La
Q Th�e results Dtthil illplcti—are as follows: I
Iy PASS ( CERTIFIED
f y�
INSPKTON RESULTS
CHECKAPPLICABLE80%: 1F TH15151i TCR.'. -Elil \i•�')IFICATON REPORT OR INITIAL FAILURE II
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TYASAECT50F THEFACIUTY_HOWEVTR.IFAVINi, I INADDRE55EO THESE PROBLEMS WILL IMPAIR THE DEVICE'S LONGi Flo
TERM FUNCTIONAUTY. MINOR PROELFMS SHALL BH NO I FD IN THE O&M MANUAL AS SUCH, MU57 BE ADDRESSED
THROUGH ROUTINE MAATENANCE, AND VERIFIED AT THE NOCT ANNUAL N5P CHON,
FAW (REPAIRS CAN BE COMPLETED WITHIN 90 DAYS)
4NSPECTION FOUND APARE NT PROBLEMS WHICH NEED IMMEDIATE ATTENTION COMPLETE THE REPAIR AND/OR
MAINTENANCE ITEMS INDICATED IN THE SEALED IMPLEM EN TATION SCHEDULE WITHIN 9U DAYS Ol THE DATE OF THIS
RERT PO, RE -INSPECTION AND CERTRICATION PRIOEX OR AT THE 9D DAY INTERVAL WILL FOLLOW EATISFACTORY
COMPLETION OF ALL REPAIRS AND MAINTENANCE ORTS NO I RECEIVED AFTER 90 DAYS WILL AUTOMATICALLY
DEFAULT INTO ERFOACEMENT ACYlOryS.
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Figure 57. Inspection form for completing results and preparing letter are available on the computer
NCS000249 Durham Site Visit Evaluations 52

Figure 58. Dry pond at Parks and Recreation Office
NCS000249 Durham Site Visit Evaluations 53

Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 2
Site Name:
Date and Time of Site Visit:
Villa at Culp Arbor
12/29/2021 — 10:00am
Site Address:
SCM Type:
5002 Niagra Drive
Wet Pond
Most Recent MS4 Inspection (Include Date and Entity):
March 23, 2021 by Sam Jackson (City of Durham)
Name of MS4 Inspector(s) evaluated:
Most Recent MS4 Enforcement Activity (Include Date):
Sam Jackson
N/A as this is the first annual inspection since as -built drawings
were approved and the device accepted by the City
Name(s) and Title(s) of Site Representative(s) Present During the
Site Visit:
Name Title
N/A — inspector only meets with owner if requested N/A
Observations
Site Documentation
Does the site have an operation and maintenance plan?
Yes —the SCM is new and has as -built certified plans along with an 0&M manual.
Does the site have records of annual inspections? Are they performed by a qualified individual?
The City maintains record of all annual inspections as performed by a 3'6 party inspector that must be a PE, LA, or qualified
professional.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
The inspector has been trained in SCM inspection at NCSU and maintains an annual certification. He also has 3 years of experience
in SCM inspection.
Did the MS4 inspector appear knowledgeable about MS4 requirements for post -construction site runoff controls?
Yes, the inspector is very familiar with the NPDES MS4 requirements.
Did the MS4 inspector appear knowledgeable about post -construction BMPs (general purpose/function, components, O&M
requirements, etc.)?
,s, the inspector understands the functions of SCMs, their design, and maintenance needs.
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form? What format?
Yes, the City has specific inspection forms for each type of SCM that are used for inspections.
Does the MS4 inspector's process include taking photos?
Yes, the inspector documents his findings using photographs which are incorporated into the report and City data base.
Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections?
Yes, the inspector reviews the SCMs as -built drawings and inspection records prior to the site visit. The inspector is also able to pull
up these records and drawings in the field using a ruggedized computer.
NCS000249 Durham Site Visit Evaluations 54

Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 2
Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge?
Yes, the inspector inspects the entire SCM including the conveyances to and from the SCM.
Did the MS4 inspector miss any obvious operation and maintenance deficiencies? If so, explain:
No, the inspector did not miss any obvious operation or maintenance issues.
Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing?
Yes, the inspector prepares a letter for the SCM owner conveying the results of the inspection as well as any needed corrective
actions including a time frame to complete any corrections.
Compliance/Enforcement
What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in? There was some minor sediment in a
rip -rap dissipater that was recorded as "Minor Functional Issues". The City has levels to describe compliance issues:
Monitor — pass inspection - for conditions that may be a concern in the future
Minor Functional Issues — pass inspection — for conditions that need to be corrected but do not pose a significant concern to the
function of the SCM
Partially Functional — fail inspection - the SCM failed the inspection and corrective action must be taken within 90 days (unless
major repairs are anticipated to require more than 90 days) and a new inspection report prepared
Not Functional —fail inspection —the SCM failed the inspection and corrective action must be taken within 90 days unless major
repairs are anticipated to require more than 90 days and a new inspection report prepared
If compliance issues were identified, what timeline for correction/follow-up was provided? This corrective action classification
requires the owner to take corrective action prior to the next annual inspection or face an inspection failure notice. If major issues
are identified, the owner is allowed 90 days to take corrective action and have the pond reinspected.
Notes/Comments/Recommendations
• The inspector noted that they are able to conduct quality assurance inspections (following submittal of an annual inspection
report by a 3rd party) of all required SCMs in their jurisdiction annually
• The City's Stormwater Development Review Section includes: 1 Administrator, a Post Construction Supervisor, 2 SCM po9st
construction inspectors, a plan review section supervisor, and 5 plan reviewers (plus one part time) that both review plans and
inspect SCMs during construction up to final as -built acceptance.
• The City requires that the O&M manual be attached to the 3rd party annual inspection report
• The City requires 3rd party inspectors to have a certification and be approved by the City
NCS000249 Durham Site Visit Evaluations 55

Figure 59. Wet pond riser structure
NCS000249 Durham Site Visit Evaluations 56

Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 3
Site Name:
Date and Time of Site Visit:
Dollar General
12/29/2021-11:00am
Site Address:
SCM Type:
3830 Guess Road, Durham
Sand Filter
Most Recent MS4 Inspection (Include Date and Entity):
January 8, 2021 by Sam Jackson (City of Durham)
Name of MS4 Inspector(s) evaluated:
Most Recent MS4 Enforcement Activity (Include Date):
Sam Jackson
The device failed both the 3" party and City QA inspection on
12/20/2019 — reinspected and approved on 2/21/2019
Name(s) and Title(s) of Site Representative(s) Present During the
Site Visit:
Name
Title
N/A — inspector only meets with owner if requested
N/A
Observations
Site Documentation
Does the site have an operation and maintenance plan?
Yes — the SCM an older device with approved construction drawings but was constructed prior to The City adopting requirements
for as -built plans and a maintenance manual at the time of acceptance. However, the 3rd party inspector prepared an O&M manual
as required by the City when none exists.
Does the site have records of annual inspections? Are they performed by a qualified individual?
The City maintains record of all annual inspections as performed by a 3rd party inspector that must be a PE, LA, or qualified
professional.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
The inspector has been trained in SCM inspection at NCSU and maintains an annual certification. He also has 3 years of experience
in SCM inspection.
Did the MS4 inspector appear knowledgeable about MS4 requirements for post -construction site runoff controls?
Yes, the inspector is very familiar with the NPDES MS4 requirements.
Did the MS4 inspector appear knowledgeable about post -construction BMPs (general purpose/function, components, 0&M
requirements, etc.)?
Yes, the inspector understands the functions of SCMs, their design, and maintenance needs.
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form? What format?
Yes, the City has specific inspection forms for each type of SCM that are used for inspections.
Does the MS4 inspector's process include taking photos?
Yes, the inspector documents his findings using photographs which are incorporated into the report and City data base.
NCS000249 Durham Site Visit Evaluations 57

Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 3
Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections?
Yes, the inspector reviews the SCMs as -built drawings and inspection records prior to the site visit. The inspector is also able to pull
up these records and drawings in the field using a ruggedized computer.
Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge?
Yes, the inspector inspects the entire SCM including the conveyances to and from the SCM.
Did the MS4 inspector miss any obvious operation and maintenance deficiencies? If so, explain:
No, the inspector did not miss any obvious operation or maintenance issues.
Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing?
Yes, the inspector prepares a letter for the SCM owner conveying the results of the inspection as well as any needed corrective
actions including a time frame to complete any corrections.
Compliance/Enforcement
What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in? There was some minor sediment in a
rip -rap dissipater that was recorded as "Minor Functional Issues". The City has levels to describe compliance issues:
Monitor — pass inspection - for conditions that may be a concern in the future
Minor Functional Issues — pass inspection — for conditions that need to be corrected but do not pose a significant concern to the
function of the SCM
Partially Functional —fail inspection - the SCM failed the inspection and corrective action must be taken within 90 days (unless
major repairs are anticipated to require more than 90 days) and a new inspection report prepared
Not Functional —fail inspection —the SCM failed the inspection and corrective action must be taken within 90 days unless major
repairs are anticipated to require more than 90 days and a new inspection report prepared.
If compliance issues were identified, what timeline for correction/follow-up was provided? This corrective action classification
requires the owner to take corrective action prior to the next annual inspection or face an inspection failure notice. If major issues
are identified, the owner is allowed 90 days to take corrective action and have the pond reinspected.
Notes/Comments/Recommendations
• The inspector noted that they are able to conduct quality assurance inspections (following submittal of an annual inspection
report by a 3rd party) of all required SCMs in their jurisdiction annually
• The City's Stormwater Development Review Section includes: 1 Administrator, a Post Construction Supervisor, 2 SCM po9st
construction inspectors, a plan review section supervisor, and 5 plan reviewers (plus one part time) that both review plans and
inspect SCMs during construction up to final as -built acceptance.
• The City requires that the O&M manual be attached to the 3rd party annual inspection report
• The City requires 3rd party inspectors to have a certification and be approved by the City
NCS000249 Durham Site Visit Evaluations 58

Figure 60. Inspector has access to all past inspection records and resolutions
Figure 61. Sand filter SCM at Dollar General
NCS000249 Durham Site Visit Evaluations 59

NCS000249 Durham Site Visit Evaluations 60

Site Visit Evaluation: Assessment & Monitoring Ambient Stream Monitoring
Site(s) Visited:
Date and Time of Site Visit(s):
LL3.4LLT2, LL3.4LLC, LC1.11-C, LC2.ORBC, NE2.2NP, NEO.ONE,
02/8/2022 — 8:00 am
NE1.2NE
Receiving Water(s):
Field Parameter(s) Collected:
Sample(s) Collected:
Little Lick Creek, Lick Creek, Northeast Creek
Dissolved Oxygen (%, mg/L)
Ammonia Nitrogen (mg/L)
Sp. Conductivity (µS/cm3)
pH( s.u.)
Antimony (µg/L)
Calcium (µg/L)
Days since Last Rainfall:
Inches:
0.53
Air Temperature (°C)
Fecal Coliform (CFU/ 100ml-)
Turbidity (NTU)
Hardness (mg of CaCO3)
Most Recent Site Visit(s):
01/11/2022
Water Temperature (°C)
Nitrate + Nitrite as N (mg/L)
Magnesium (µg/L)
Total Kjeldahl Nitrogen (mg/L)
Total Phosphorus (mg/L)
Total Suspended Solids (mg/L)
Total & Dissolved Copper (µg/L)
Total & Dissolved Zinc (µg/L)
Name(s) of monitoring team evaluated:
Blaine Lary & Dave Milkereit
IObservations I
Monitor Training/ Knowledge
What type of stormwater training does the monitor receive? How often?
The monitors receive onboarding training in basic stormwater, PPGH, and IDDE. Training specific to monitoring is limited to on-the-
job training by the supervisor and experienced field staff using detailed standard operating procedures. Monitor performance is
annually audited by their supervisor. Field parameters and laboratory results are reviewed for accuracy monthly by the Monitoring
& Assessment Supervisor.
Did the monitor appear knowledgeable about Permit requirements for monitoring?
Yes, monitors were familiar with water quality monitoring requirements outlined in the Permit. Monitors implemented and
completed the monitoring plan for the scheduled sampling event. Monitoring team members also function as illicit discharge
detection and elimination inspectors, and are familiar with characteristics indicative of an illicit discharges as well as what
characteristics are naturally occurring such as iron oxidizing bacteria sheens.
Monitoring Procedures
Does the monitoring process include the use of a checklist or other standardized form?
Yes, monitors conduct calibrations and field work using an SOP that includes daily calibration of their meters and complete all field
work using a standardized field form. This standardized field form includes the collection of standardized physical water quality
parameters at each monitoring station. Collection of samples for laboratory analysis is conducted according to SOPS and an annual
monitoring plan.
Does the monitoring process include quality assurance protocols?
Yes, field blanks and duplicate samples are collected along with regular samples for laboratory analysis. Field meters are calibrated
each sampling day, and a post check is performed after sampling. Chain of custody forms are used to document sample collection
times for submittal.
Does the monitoring team follow good lab practices and sampling procedures?
Yes, Field staff were skilled in the collection of field parameters and samples. New gloves were worn at each site, and staff took
care to avoid any contamination of samples. Sampling was conducted according to an SOP that includes procedures to avoid sample
contamination.
NCS000249 Durham Site Visit Evaluations 61

Site Visit Evaluation: Assessment & Monitoring Ambient Stream Monitoring
Monitoring Results
Did the monitoring result in any investigations or corrective actions? If so, For what issue(s)?
No, but field staff did detail physical and laboratory results that would require notifying the IDDE program as indicators of a
potential illicit discharge.
Notes/Comments/Recommendations
The ambient monitoring program includes the collection of physical and chemical parameters of surface waters. These parameters
are collected at select sites representing water quality in the City. Comprehensive sampling of all sites is conducted on a rotating
odd/even year cycle, with a subset of sites sampled every year. Sampling is usually conducted on the first three Tuesdays of each
month. All sites within a single watershed are sampled on the same day when possible.
• Field staff maintained a monitoring notebook with a pre -trip checklist, site maps, the monitoring plan, and COC forms
which was updated for calendar year 2022.
• Field work was conducted according to detailed SOPS covering the use and calibration of field meters, operation of pumps,
and sampling protocol for the collection of water quality samples.
• Staff maintained monthly and quarterly maintenance logs for meters used.
• Calibration standards were in date and within expected concentrations.
• Samples collected were pre -labeled and grouped by site, bottle preparation was performed on the 4th Tuesday of the prior
month.
• Sampling could not be completed at LC1.1LC due to safety concerns related to electrical utility work and road closures on
the day of the site visit.
• Field sheets and COC forms were reviewed by both team members at the end of the sampling day, prior to submitting
samples.
• Samples were submitted to the South Durham Water Reclamation Facility Water/Wastewater Lab for analysis.
• Field notes, physical parameters, and Laboratory results were maintained in an online web portal accessible to the public.
Data is typically available the following month.
NCS000249 Durham Site Visit Evaluations 62

Site Visit Evaluation: Construction Site No. 1
Site/Project Name:
Date and Time of Site Visit:
55 at the Park (JCN 6080-11)
04/14/2022 10:00 am
Site/Project Address:
Operator:
3500 NC Hwy 55
Pulte Group
Durham, NC
Project Type
(Commercial, Industrial, Residential, CIP, Road, etc.):
Residential - Townhomes
NCG Permit ID Number:
Disturbed Acreage:
NCC203351
20.43
Recent Enforcement Actions (Include Date):
NOV —June 24, 2021
Name of MS4 Inspector(s) evaluated:
Rob Stewart
Not In Compliance — April 4, 2022
Name(s) and Title(s) of Site Representative(s) Present During the
Site Visit:
Name
Title
Zach Chapman
Land Development, Pulte Group
Observations
Site Documentation/Training
Does the site have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it site -specific?
Yes, site specific and included in NPDES box onsite
Does the site have approved erosion and sedimentation control plans onsite? Are they representative of current site conditions?
Yes, plans approved 3/4/2020
What type of stormwater training do site employees receive? How often?
Prior to permit issuance or start of construction, a pre -construction conference is held onsite where stormwater and erosion
control measures are discussed. Further stormwater training is the responsibility of the contractor at their discretion.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
Inspector attends Local Program Workshop annually, participates in the City's annual investigations training, and is Level II NCDOT
ESC Certified since 2015.
Did the MS4 inspector appear knowledgeable about MS4 and NCG010000 requirements for construction sites?
Yes
Did the MS4 inspector appear knowledgeable about erosion and sedimentation control/stormwater pollution prevention BMPs?
Yes
NCS000249 Durham Site Visit Evaluations 63

Site Visit Evaluation: Construction Site No. 1
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist?
Yes, Durham County has an inspection report including a checklist of items.
Does the MS4 inspector's process include taking photos?
Yes, photos are taken when necessary to document compliance concerns. In this instance, photos were taken of inlet protection
failures or those in need of maintenance.
Does the MS4 inspector's process include reviewing approved plans (erosion and sedimentation control and/or SWPPP)?
Yes, inspector reviews plans prior to site visits. Plans are also available electronically via Box.com app on phone or iPad.
Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge?
Yes, the entire site is walked, including the perimeter. Inspector also checks interior measures, and in this case lot measures.
Did the MS4 inspector miss any obvious violations? If so, explain:
No, no obvious violations were missed on this inspection
Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing?
Yes, the inspection report is provided to the site contact via email.
Does the MS4 inspector's process include providing construction stormwater educational materials to the site contact?
When necessary, education materials can be provided to site contacts.
Compliance/Enforcement
What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in?
Inspection resulted in a Not -In -Compliance (NIC) inspection report. The NIC report noted concerns with inlet protection, concrete
washout, and street cleaning.
If compliance issues were identified, what timeline for correction/follow-up was provided?
A compliance date of 4/22/22 was given — 7 calendar days (allowing for 4/15 holiday)
Notes/Comments/Recommendations
The inspector was very knowledgeable about the site, having inspected it since it was permitted in March 2020. He had a good line
of communication with the site contact and was able to share his concerns. The inspector walked the entirety of the site, making
sure to visit the sediment basin and its outfall and check all interior measures, including inlet protection and individual lot controls.
He feels confident the site will be brought into compliance by, if not before, the deadline.
NCS000249 Durham Site Visit Evaluations 64

Site Visit Evaluation: Construction Site No. 2
Site/Project Name:
Date and Time of Site Visit:
Hebron Village (JCN 6262-06)
04/22/2022 12:15 pm
Site/Project Address:
Operator:
4728 Denfield St
Jimmy Robinson, Duke Lazzara
Durham, NC
Keith Greenwood, Level 5 Ventures
Project Type
(Commercial, Industrial, Residential, CIP, Road, etc.):
Residential
NCG Permit ID Number:
Disturbed Acreage:
NCC220278
24.70
Recent Enforcement Actions (Include Date):
NOV — March 4, 2022
Name of MS4 Inspector(s) evaluated:
Jonathan McNeill, CFM
Name(s) and Title(s) of Site Representative(s) Present During the
Site Visit:
Name
Title
None
Observations
Site Documentation/Training
Does the site have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it site -specific?
Yes, plan was onsite
Does the site have approved erosion and sedimentation control plans onsite? Are they representative of current site conditions?
Yes, plans were onsite and implemented onsite.
What type of stormwater training do site employees receive? How often?
Prior to permit issuance or start of construction, a pre -construction conference is held onsite where stormwater and erosion
control measures are discussed. Further stormwater training is the responsibility of the contractor at their discretion.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
Inspector attends Local Programs Workshop annually, Level III NCDOT Certified, Certified Floodplain Manager
Did the MS4 inspector appear knowledgeable about MS4 and NCG010000 requirements for construction sites?
Yes
Did the MS4 inspector appear knowledgeable about erosion and sedimentation control/stormwater pollution prevention BMPs?
Yes
NCS000249 Durham Site Visit Evaluations

Site Visit Evaluation: Construction Site No. 2
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist?
Yes, Durham County has an inspection report with a checklist of items.
Does the MS4 inspector's process include taking photos?
Yes, photos are taken when necessary to document compliance concerns.
Does the MS4 inspector's process include reviewing approved plans (erosion and sedimentation control and/or SWPPP)?
Yes, plans are reviewed prior to site visits and available electronically through Box app on phone or iPad.
Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge?
Yes, inspector walks entirety of the site including perimeter and checks interior measures.
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, a copy of the inspection report is provided to the site contact via email.
Does the MS4 inspector's process include providing construction stormwater educational materials to the site contact?
When necessary, education materials can be provided to site contacts.
Compliance/Enforcement
What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in?
No enforcement actions were necessary.
If compliance issues were identified, what timeline for correction/follow-up was provided?
N/A
Notes/Comments/Recommendations
The site previously received an NOV for clearing prior to installation of erosion control measures per plan. The measures were
swiftly installed with assistance from the inspector, who provided advisory field changes to better control sediment onsite. On this
visit, the measures were functioning properly with groundcover still establishing on slopes of the sediment basins. The inspector
had a good understanding of the site's layout, measures, and potential problem areas. His contacts during the NOV resolution
process will prove invaluable over the course of the site's development should future problems arise.
NCS000249 Durham Site Visit Evaluations 66

NCS000249 Durham Site Visit Evaluations 67

CITY OF
DURHAM
Date: April 27, 2022
To: Melissa Harrison, EP&C Specialist
Signature:
Cc: Michelle Woolfolk, Water Quality Manager
From: Jim Azarelo, IDDE Supervisor
Subject: IDDE Field Investigation Audit
Introduction
Date:
Memo
This writing presents the results of an audit of the City of Durham's Illicit Discharge
Detection and Elimination (IDDE) investigation program for the 2021-2022 fiscal year.
This audit was conducted to evaluate investigation methods and practices used by staff
members in the Stormwater & GIS Services Water Quality Group. The staff member
subject to the field audit must read and sign this document to affirm his or her
understanding of its contents.
At 3:00 p.m. on March 24, 2022 Water Quality received notice from City Water and
Sewer Maintenance that there was a sewage discharge from a residence located at
2408 Chapin St. A W&S crew had already visited the site after receiving a complaint
from an adjacent resident, conducted an investigation, and determined that it was due
to an issue on the private utility side.
At approximately 11:00 a.m. on March 25, 1 accompanied lead investigator Melissa
Harrison while she conducted an investigation into this complaint. Database record
number 22WQ070 was created for this investigation.
Investigation Preparation
Before departing from his home office, Melissa reviewed CityWorks service request
#1330526, which was W&S Maintenance's record of investigation of this matter. She
queried the investigations database for prior history at this location. There was no
relevant site history. She also inspected the GIS webmap for parcel data and other
nearby related investigations.
As this investigation involved a liquid discharge, Melissa brought a Chemetrics kit to test
for pollutant indicators.
She appropriately donned a high -visibility vest and safety shoes for this investigation.
101 City Hall Plaza, Durham, NC 27701 919.560.1200 DurhamNC.gov Follow Us @CityofDurhamNC

Investigation Details
Melissa and I arrived separately to 2408 Chapin St. and parked our vehicles along the
side of the street, which appeared to be safe and low -traffic.
Melissa initially made observations and took photographs of the 2408 parcel from the
street. Trails of liquid could be seen leading from the residential property, across the
adjacent driveway, and into the street. Melissa also noted the odor of wastewater in the
area.
Melissa approached the residence and made contact with the tenant. The tenant called
the homeowner to give notice of our visit. Melissa recorded the names of each of these
individuals. The homeowner granted consent for Melissa to investigate and test the
liquid seeping from the house foundation.
I observed Melissa properly use a Chemetrics kit to collect and test a sample of the
discharge for ammonia. The sample immediately turned a deep orange upon testing,
indicating an ammonia concentration in excess of 10 ppm. Melissa reasonably
concluded that this flow was a residential sewage discharge.
Melissa shared her findings with the tenant and inquired into whether corrective actions
were being taken. The tenant revealed that a plumbing contractor had not yet been
secured to perform work. Melissa asked the tenant to let the homeowner know that
Water Quality would be issuing a formal requirement for repair and remediation.
Investigation Result -
Melissa entered her initial investigation findings into the database at approximately 3:50
p.m. on March 28.
After confirming the identity and contact information for the property owner, Melissa
spoke with them via phone to discuss expectations for diagnosis and repair of the
plumbing issue, in addition to remediation of impacted soils.
On March 30, Melissa hand -delivered a Notice of Requirement to the property owner.
She properly noted the issue as an illicit discharge of sewage from the property. Her
corrective actions specified diagnosis and repair of the issue by a licensed plumber and
remediation as appropriate. She set a reasonable deadline of April 8, 2022.
On April 1, the property owner submitted some meagre evidence of plumbing work
conducted on the premises that Melissa appropriately deemed insufficient as evidence
that the issue was resolved. Melissa replied, requesting evidence in the form of a dye
test or written statement from a licensed plumber. As of April 12, Melissa granted a
reasonable extension of the deadline due to additional hazards identified in the repair
area, causing work delays. Furthermore, City NIS is also enforcing housing code
violations at this residence. NIS officers are coordinating their efforts with Melissa.
This case has not yet been resolved as of the writing of this memo.
101 City Hall Plaza, Durham, NC 27701 919.560.1200 DurhamNC.gov Follow Us @CityofDurhamNC
e

Audit Recommendations
I have no recommendations for Melissa at this time. This investigation was conducted
efficiently and according to all established IDDE guidelines and safety procedures. The
database records for this investigation are complete and sufficiently chronicle all
evidence and actions taken.
I recommend that we discuss and research a convenient and effective means of
cleaning and/or sanitizing our Chemetrics kits in the field (and laboratory, if necessary).
These kits and their contents usually contact unclean liquids, the most common of
which are sewage -laden flows. These exteriors of the kit containers are almost certainly
contaminated and are usually handled ungloved and stored in clean areas of our
laboratory and vehicles.
101 City Hall Plaza, Durham, NC 27701 I 919.560.1200 DurhamNC.gov I Follow Us @Ciittyo© rhamNC