NCS000403_Signed Audit Report_20220708

MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM AUDIT REPORT
NPDES PERMIT NO. NCS000403
ELON, NORTH CAROLINA
104 S Williamson Avenue
Audit Date: June 29, 2022
Report Date: July 8, 2022
North Carolina Department of Environmental Quality
Division of Energy, Mineral & Land Resources Stormwater Program
512 N. Salisbury Street, 9th floor
1612 Mail Service Center
Raleigh, NC 27699-1612

(This page intentionally left blank)
NCS000403 Elon MS4 Audit 20220629

TABLE OF CONTENTS
AuditDetails..................................................................................................................................................1
PermitteeInformation..................................................................................................................................2
List of Supporting Documents.......................................................................................................................3
Program Implementation, Documentation & Assessment...........................................................................4
Illicit Discharge Detection and Elimination(IDDE)........................................................................................7
Post -Construction Site Runoff Controls........................................................................................................9
Pollution Prevention and Good Housekeeping for Municipal Operations.................................................13
Site Visit Evaluation: Municipal Facility No. 1.............................................................................................15
Site Visit Evaluation: MS4 Outfall No. 1......................................................................................................16
Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1............................................17
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.
NCS000403 Elon M54 Audit 20220629 ii

This page intentionally left blank
NCS000403 Elon MS4 Audit 20220629 iii

Audit Details
Audit ID Number:
Audit Date(s):
NCS000403_Elon MS4 Audit_20220629
June 29, 2022
Minimum Control Measures Evaluated:
® Program Implementation, Documentation & Assessment
❑ Public Education & Outreach
❑ Public Involvement & Participation
® Illicit Discharge Detection & Elimination
❑ Construction Site Runoff Controls — No delegated Sediment and Erosion Control Program
❑ Construction Site Runoff Controls — Delegated Sediment and Erosion Control Program
® Post -Construction Site Runoff Controls
® Pollution Prevention and Good Housekeeping for Municipal Operations
❑ Total Maximum Daily Loads (TMDLs)
Field Site Visits:
® Municipal Facilities. Number visited: 1
® MS4Outfalls. Number visited: 1
❑ Construction Sites. Number visited: Choose an item.
M Post -Construction Stormwater Runoff Controls. Number visited: 1
❑ Other: Number visited: Choose an item.
❑ Other: Number visited: Choose an item.
Inspector(s) Conducting Audit
Name, Title
Organization
Isaiah Reed, Environmental Engineer
NCDEQ
Audit Report Author, ;
Date:
Signature
NCS000403_Elon MS4 Audit_20220629 Page 1 of 17

Permittee Information
MS4 Permittee Name: Town of Elon
Permit Effective Date:
2/20/2017
Permit Expiration Date:
2/19/2022
Mailing Address: Post Office Box 595
Elon, North Carolina 27244
Date of Last MS4 Inspection/Audit:
None
Co-permittee(s), if applicable:
Permit Owner of Record:
Richard Roedner, Town Manager
Primary MS4 Representatives Participating in Audit
Name, Title
Oreanization
David Murphy, Asst Public Works Dir.
Town of Elon
Phil Ross, Stormwater Coordinator
AWCK
Josh Johnson, Town Engineer
AWCK
TJ Ingle, Crew Leader
Town of Elon
Richard Roedner, Town Manager
Town of Elon
MS4 Receiving Waters
Waterbodv
Classification
Impairments
Dry Creek
WS-V;NSW
None Listed
Gum Creek
WS-V;NSW
None Listed
Michael Branch
WS-V;NSW
None Listed
Travis Creek
WS-V;NSW
None Listed
Ingle Branch?
WS-V;NSW
None Listed
NCS000403_Elon M54 Audit 20220629 Page 2 of 17

List of Supporting Documents
Item
Number
Document Title
When Provided
(Prior to/During/After)
1
SWMP
Prior
2
IDDE Ordinance
Prior
3
Post Construction Ordinance
Prior
4
Annual Report
Prior
5
IDDE Written Program
Prior
6
Post-C Written Program
Prior
7
Maintenance Written Program
Prior
8
Outfall Map
Prior
9
IDDE Tracking
After
10
Virtual Training Sign -in Sheet
After
11
SCM Inspection Log
After
12
SCM Maintenance Agreement
After
13
Facility Inspection Report
During
14
Pesticide License
After
NCS000403_Elon M54 Audit 20220629 Page 3 of 17

Program Implementation, Documentation & Assessment
Staff Interviewed:
David Murphy, Asst Public Works Dir.
(Name, Title, Role)
Phil Ross, Stormwater Coordinator
Josh Johnson, Town Engineer
TJ Ingle, Crew Leader
Permit Citation
Program Requirement
Status
supporting
Doc No.
II.A.1
The permittee maintained adequate funding and staffing to implement and manage
Staffing and
the provisions of the Stormwater Plan and meet all requirements of the permit.
Yes
---
Funding
The Stormwater Plan identifies a specific position(s) responsible for the overall
coordination, implementation, and revision to the Plan.
Yes
1
Responsibilities for all components of the Stormwater Plan are documented and
position(s) assignments provided.
Yes
1
The permittee is current on payment of invoiced administering and compliance
monitoring fees (see stormwater e-payments on DEMLR M54 web page).
Yes
BIMS
Annual report submitted. Public BIMS portal used for previous annual reports. But a narrative report has been preferred.
II.A.2 Stormwater
The permittee evaluated the performance and effectiveness of the program
Plan
components at least annually.
Partial
4
Implementation
and Evaluation
If yes, the permittee used the results of the evaluation to modify the program
components as necessary to accomplish the intent of the Stormwater Program.
no
Did the permitted MS4 discharges cause or contribute to non -attainment of an
Not
applicable water quality standard?
Reviewed
---
If yes, did the permittee expand or better tailor its BMPs accordingly to address]Not
the non -attainment?
Applicable
An overview of the program components was documented In the annual reports, but an evaluation of the effectiveness has not
been documented. No analytical monitoring done to confirm that no impact has been made to water quality.
II.A.3
Keeping the
The permittee kept the Stormwater Plan up to date.
Partial
1
Stormwater Plan
Up to Date
The permittee notified DEMLR of any updates to the Stormwater Plan.
Yes
---
The annual report documents a review of the components, but an annual evaluation of the SWMP itself is not documented.
II.A.4 Availability
The permittee kept an up-to-date version of its Stormwater Plan available to the
of the Stormwater
Division and the public online.
Yes
Website
Plan
The online materials included ordinances, or other regulatory mechanisms, or a list
identifying the ordinances, or other regulatory mechanisms, providing the legal
Yes
Website
authority necessary to implement and enforce the requirements of the permit.
Townofelon.com
NCS000403_Elon M54 Audit_20220629 Page 4 of 17

Program Implementation, Documentation & Assessment
II.A.3 & II.A.S
Stormwater Plan
Did DEMLR require a modification to the Stormwater Plan?
No
---
Modifications
If yes, did the permittee complete the modifications in accordance with the
Not
established deadline?
Applicable
II.A.6 Sharing
Responsibility
Are any control measures implemented by an entity other than the permittee?
No
---
If yes, is there a written agreement in place?
Yes
---
AWCK implements parts of the program but no agreement exists in which AWCK agrees to implement any MCM on behalf of the
Town of Elon.
II.A.7
The permittee maintained written procedures for implementing the six minimum
Written
Control measures.
Partial
---
Procedures
Written procedures identified specific action steps, schedules, resources and
responsibilities for implementing the six minimum measures.
Partial
A written program exists for IDDE, Post Construction, and Maintenance. These written programs shall be revised to include all
information required by the permit.
III_A
The permittee maintained documentation of all program components including, but
Program
not limited to, inspections, maintenance activities, educational programs,
Yes
Digital/P
Documentation
implementation of BMPs, enforcement actions etc., on file for a period of five years.
aper
III.B
The permittee submitted annual reports to the Department within twelve months
Annual Report
from the effective date of the permit (See Section III.B. for the annual reporting
Yes
---
Submittal
period specific to this MS4).
The permittee submitted subsequent annual reports every twelve months from the
scheduled date of the first annual report submittal.
Yes
._.
The Annual Reports included appropriate information to accurately describe the progress, status, and results
of the permittee's Stormwater Plan, including, but not limited the following:
1. A detailed description of the status of implementation of the Stormwater Plan
as a whole. This will include information on development and implementation
Not
of each major component of the Stormwater Plan for the past year and
Reviewed
schedules and plans for the year following each report.
2. An adequate description and justification of any proposed changes to the
Stormwater Plan. This will include descriptions and supporting information for
Not
the proposed changes and how these changes will impact the Stormwater
Reviewed
Plan (results, effectiveness, implementation schedule, etc.).
3. Documentation of any necessary changes to programs or practices for
assessment of management measures implemented through the Stormwater
Not
Plan.
Reviewed
4. A summary of data accumulated as part of the Stormwater Plan throughout
the year along with an assessment of what the data indicates in light of the
Not
Stormwater Plan.
Reviewed
NCS000403 Elon MS4 Audit 20220629 Page 5 of 17

Program Implementation, Documentation & Assessment
5. An assessment of compliance with the permit, information on the
establishment of appropriate legal authorities, inspections, and enforcement
Not
Reviewed
eviewed
IV.B
Annual Reporting
The Annual Reports document the following:
1. A summary of past year activities, including where applicable, specific
Not
quantities achieved and summaries of enforcement actions.
Reviewed
2. A description of the effectiveness of each program component.
Not
Reviewed
3. Planned activities and changes for the next reporting period, for each
Not
program component or activity.
Reviewed
4. Fiscal analysis.
Not
---
Reviewed
Part of the annual reports for the permit cycle were submitted through B/MS and part of the cycle were submitted as a narrative.
NCS000403 Elon MS4 Audit 20220629 Page 6 of 17

Illicit Discharge Detection and Elimination (IDDE)
Staff Interviewed:
David Murphy, Asst Public Works Dir.
(Name, Title,
Phil Ross, Stormwater Coordinator
Role)
Josh Johnson, Town Engineer
TJ Ingle, Crew Leader
Permit Citation
Program Requirement Status supporting
Doc No.
II.D.2.a
IDDE Program
The permittee maintained a written IDDE Program. Yes 5
If yes, the written program includes provisions for program assessment and
evaluation and integrating program. No ---
The IDDE written program will be modified to include all permit requirements for assessment and evaluation.
The permittee maintained an IDDE ordinance or other regulatory mechanism(s) that
II.D.2.b
provides the legal authority to prohibit illicit connections and discharges to the M34.
Partial
2
Legal Authorities
If yes, the ordinance applies throughout the corporate limits of the permittee.
[Permit Part I.D]
Partial
2
No enforcement procedure is outlined In the ordinance.
II.D2.c
permittee maintained a current map showing major outfalls and receiving
TThre
Storm Sewer
Partial
g
System Mapams.
The map that is currently maintained will be modified to include all information required by the permit.
II.D.2.d
The permittee maintained a program for conducting dry weather flow field
Dry Weather Flow
observations in accordance with written procedures.
No
---
Program
Only documented dry weather flow program was documented in 2022.
II.D.2.e
The permittee maintained written procedures for conducting investigations of
Investigation
identified illicit discharges.
Yes
5
Procedures
II.D.2.f
For each case of an illicit discharge or potential illicit discharge, the permittee documented and tracked the
Track and
following:
Document
Investigations
1. The date(s) the illicit discharge was observed
Yes
9
2. The results of the investigation
Yes
9
3. Any follow-up of the investigation
Yes
9
4. The date the investigation was closed
No
---
Tracking is documented for 1 IDDE events from 2011 and 2012. Additional outreach was discussed.
NCS000403_Elon M54 Audit_20220629 Page 7 of 17

Illicit Discharge Detection and Elimination (IDDE)
II.D.2.g Employee
The permittee implemented and documented a training p p g program for appropriate
Training
municipal staff who, as part of their normal job responsibilities, may come into
Yes
10
contact with or otherwise observe an illicit discharge or illicit connection.
II.D.2.h
The permittee informed public employees of hazards associated with illegal
Public Education
discharges and improper disposal of waste.
Yes
10
The permittee informed businesses of hazards associated with illegal discharges and
Not
improper disposal of waste.
Reviewed
The permittee informed the general public of hazards associated with illegal
Not
discharges and improper disposal of waste.
Reviewed
II.D.2.i
The permittee promoted, publicized, and facilitated a reporting mechanism for the
Public Reporting
public to report illicit discharges.
No
---
Mechanism
The permittee promoted, publicized, and facilitated a reporting mechanism for staff
to report illicit discharges.
Yes
5
The permittee established and implemented response procedures for citizen
requests/reports.
Yes
5
An IDDE reporting number was not clearly identified on the town's website.
II.D.2.0
The permittee implemented a mechanism to track the issuance of notices of violation
Not
Enforcement
and enforcement actions administered by the permittee.
Applicable
---
If yes, the mechanism includes the ability to identify chronic violators for
Not
initiation of actions to reduce noncompliance.
Applicable
No NO V's are documented.
NC5000403_Elon M54 Audit_20220629 Page 8 of 17

I Post -Construction Site Runoff Controls I
Staff Interviewed: David Murphy, Asst Public Works Dir.
(Name, Title, Role) Phil Ross, Stormwater Coordinator
Josh Johnson, Town Engineer
TJ Ingle, Crew Leader
Implementation (check all that apply):
❑ The permittee implements the components of this minimum measure.
® The permittee relies upon another entity to implement the components of this minimum measure: AWCK
❑ The permittee implements the following deemed -compliant program(s), which meet NPDES M54 post -construction
requirements for the areas where implemented and in compliance with the specific program requirements as provided in 15A
NCAC and noted below (Complete Session Law 2006-246 section below):
❑ Water Supply Watershed I (WS-1) —15A NCAC 2B .0212
❑ Water Supply Watershed II (WS-11) —15A NCAC 28.0214
❑ Water Supply Watershed III (WS-III) —15A NCAC 28 .0215
❑ Water Supply Watershed IV (WS-IV) —15A NCAC 2B .0216
❑ Freshwater High Quality Waters (HOW) —15A NCAC 2H .1006
❑ Freshwater Outstanding Resource Waters (ORW) —15A NCAC 2H .1007
❑ Neuse River Basin Nutrient Sensitive (NSW) Management Strategy-15A NCAC 2B .0235
❑ Tar -Pamlico River Basin Nutrient Sensitive (NSW) Management Strategy —15A NCAC 2B .0258
❑ Randleman Lake Water Supply Watershed Nutrient Management Strategy —15A NCAC 2B .0251
❑ Universal Stormwater Management Program —15A NCAC 2H .1020
Ordinance(s) (check all that apply):
The permittee utilizes the following ordinances and/or regulatory authority to fulfill post construction minimum measure program
requirements throughout the MS4 permitted area (check all that apply):
® DEQ model ordinance
❑ MS4 designed post -construction practices that meet or exceed 15A NCAC 02H .1000.
❑ DEQ approved comprehensive watershed plan
❑ DEQ approved ordinance for a deemed -compliant Program (see list above)
Instructions:
For MS4s not implementing a S.L. 2006-246 deemed -compliant program, complete only the Permit Citation section below.
For MS4s implementing a S.L. 2006-246 deemed -compliant program, complete the Session Law 2006-246 section below. If the MS4
does not implement a deemed -compliant program throughout the entire M54 permitted area, then complete the Permit Citation
section below for the permitted area(s) not covered under the S.L. 2006-246 deemed -compliant program.
246Session Law 2006- I Program Requirement I Status I Supp
DocoNong
NCS000403_Elon MS4 Audit_20220629 Page 9 of 17

Post -Construction Site Runoff Controls
Deemed -Compliant
The permittee implements deemed -compliant Program requirements in
Program(s)
accordance with the applicable 15A NCAC rules.
No
---
The permittee implements deemed -compliant Program requirements throughout
the entire MS4 area (If not also complete the Permit Citation section below.)
:No
---
The permittee applies deemed -compliant Program requirements to all federal,
state and local government projects within the permitted MS4 area who do not
No
---
have their own NPDES stormwater permit.
The permittee included deemed -compliant Program reporting in their MS4 Annual
Reports.
No
The permittee included deemed -compliant Program implementation in their
Stormwater Management Plan.
No
---
Permit Citation
Program Requirement
Status
supporting
Doc No.
II.F.2.a
The permittee maintained an ordinance or other regulatory mechanism designed
Legal Authority
to meet the objectives of the Post -Construction Site Runoff Controls Stormwater
Yes
3
Management Program.
If yes, the ordinance applies throughout the corporate limits of the permittee
(Verify permit coverage area listed in Part I.D of permit and modify
Yes
3
accordingly).
The permittee has the authority to review designs and proposals for new
development and redevelopment to determine whether adequate stormwater
Yes
3
control measures will be installed, implemented, and maintained.
The permittee has the authority to request information such as stormwater plans,
inspection reports, monitoring results, and other information deemed necessary to
evaluate compliance with the Post -Construction Stormwater Management
Yes
3
Program.
The permittee has the authority to enter private property for the purpose of
inspecting at reasonable times any facilities, equipment, practices, or operations
Yes
3
related to stormwater discharges.
II.F.2.b
Stormwater Control
The permittee utilizes strategies which include SCMs appropriate for the MS4.
Yes
3,6
Measures (SCMs)
SCMs comply with 15A NCAC 02H .1000.
Yes
3
II.F.2.c
The permittee conducted site plan reviews of all new development and
Plan Reviews
redeveloped sites that disturb greater than or equal to one acre (including sites
that disturb less than one acre that are part of a larger common plan of
Yes
6
development or sale).
If yes, the site plan reviews addressed how the project applicant meets the
performance standards.
Yes
6
If yes, the site plan reviews addressed how the project will ensure long-term
maintenance.
Yes
6
NCS000403_Elon MS4 Audit_20220629 Page 10 of 17

Post -Construction Site Runoff Controls
II.F.2.d
The permittee maintained an inventory of projects with post -construction
Inventory of Projects
structural stormwater control measures installed and implemented at new
Yes
6
development and redeveloped sites.
The inventory included both public and private sector sites located within the
permittee's corporate limits that are covered by its post -construction ordinance
Yes
6
requirements.
II.F.2.e
Deed Restrictions
The permittee provided mechanisms such as recorded deed restrictions and
and Protective
protective covenants that ensure development activities will maintain the project
Yes
12
Covenants
consistent with approved plans.
A notarized BMP Maintenance agreement Is recorded with the register of deeds.
II.F.2.f
The permittee implemented or required an operation and maintenance plan for
Mechanism to
the long-term operation of the SCMs required by the program.
Yes
12
Require Long-term
Operation and
The operation and maintenance plan required the owner of each SCM to perform
Maintenance
and maintain a record of annual inspections of each SCM.
Yes
12
Annual inspection of permitted structural SCMs are required to be performed by a
qualified professional.
Yes
12
II.F.2.e
The permittee conducted and documented inspections of each project site covered
Inspections of
under performance standards, at least one time during the permit term (Verify this
Yes
11
Structural
is a permit condition in Part II.F.2.g of permit and modify accordingly).
Stormwater Control
Before issuing a certificate of occupancy or temporary certificate of occupancy, the
Measures
permittee conducted a post -construction inspection to verify that the permittee's
performance standards have been met or a bond is in place to guarantee
Yes
11
completion(Verify this is a permit condition in Part II.F.2.g of permit and modify
accordingly.
The permittee developed and implemented a written inspection program for SCMs
installed pursuant to the post -construction program(Verify this is a permit
Yes
11
condition in Part II.F.2.g of permit and modify accordingly.
The permittee documented and maintained records of inspections.
Yes
---
The permittee documented and maintained records of enforcement actions.
Not
---
Applicable
II.F.2.h
The permittee made available through paper or electronic means, ordinances,
Educational
post -construction requirements, design standards checklists, and other materials
Materials and
appropriate for developers.
Training for
Note: New materials may be developed by the permittee, or the permittee may use
Yes
Website
Developers
materials adopted from other programs and adapted to the permittee's new
development and redevelopment program.
Townofelon.com
NCS000403_Elon MS4 Audit_20220629 Page 11 of 17

Post -Construction Site Runoff Controls
II.F.2.1 Enforcement
The permittee tracked the issuance of notices of violation and enforcement
Not
actions.
Applicable
If yes, the tracking mechanism included the ability to identify chronic violators
Not
for initiation of actions to reduce noncompliance.
Applicable
II.F.3.b
The permittee fully complies with post construction program requirements on its
Not
New Development
own publicly funded construction projects.
Applicable
II.F3.c
Does the MS4 have areas drainingto Nutrient Sensitive Waters NSW (NSW) pursuant to
Nutrient Sensitive
15A NCAC 02H .0150?
Yes
Waters
If yes, does the permittee use SCMs that reduce nutrient loading in order to
meet local program requirements.
No
If yes, does the permittee also still incorporate the stormwater controls
required for the project's density level.
Yes
If yes, does the permittee also require documentation where it is not feasible to
use SCMs that reduce nutrient loading.
No
Permittee has not required SLM specifically designed for nutrient removal.
II.F3.d
The permittee ensured that the design volumes of SCMs take into account the
Design Volume
runoff at build out from all surfaces draining to the system.
Yes
6
Where "streets" convey stormwater, the permittee designed SCMs to be sized to
treat and control stormwater runoff from all surfaces draining to the SCM including
Yes
6
streets, driveways, and other impervious surfaces.
NCS000403_Elon MS4 Audit_20220629 Page 12 of 17

Pollution Prevention and Good Housekeeping for Municipal Operations
Staff Interviewed:
David Murphy, Asst Public Works Dir.
(Name, Title, Role)
Phil Ross, Stormwater Coordinator
Josh Johnson, Town Engineer
TJ Ingle, Crew Leader
Permit Citation
Program Requirement Status Supporting
Doc No.
II.G.2.a
The permittee maintained a current inventory of facilities and operations owned
Facility Inventory
and operated by the permittee with the potential for generating polluted Partial 7
stormwater runoff.
2019 Elan OM Plan Final
II.G.2.b
The permittee maintained and implemented an 0&M program for municipally
Operation and
owned and operated facilities with the potential for generating polluted
Yes
---
Maintenance (O&M)
stormwater runoff.
for Facilities
If yes, the 0&M program specifies the frequency of inspections.
No
---
If yes, the O&M program specifies the frequency of routine maintenance
requirements.
Yes
---
If yes, the permittee evaluated the 0&M program annually and updated it as
necessary.
No
While some elements are present in the annual report an annual evaluation of the effectiveness of the program is not
documented.
II.G.2.c
Spill Response
The permittee had written spill response procedures for municipal operations.
Partial
Procedures
Spill response is outlined in the O&M Plan.
II.G.2.d Streets,
The permittee evaluated existing and new BMPs that reduce polluted stormwater
Roads, and Public
runoff from municipally -owned streets, roads, and public parking lots within its
Partial
4
Parking Lots
corporate limits annually.
Maintenance
If yes, the permittee evaluated the effectiveness of existing and new BMPs
based on cost and the estimated quantity of pollutants removed.
Yes
4
Annual Report. (Pollution and Prevention).
II.G.2.e
The permittee maintained and implemented an 0&M program for the stormwater
O&M for Catch
Basins and
sewer system including catch basins and conveyance systems that it owns and
Partial
7
Conveyance Systems
maintains.
O&M Program was written in 2021 and has not been maintained throughout the permit term.
II.G.2.f
The permittee maintained a current inventory of municipally -owned or operated
Structural
structural stormwater controls installed for compliance with the permittee's post-
Not
stormwater Controls
construction ordinance.
Applicable
NCS000403_Elon MS4 Audit_20220629 Page 13 of 17

Pollution Prevention and Good Housekeeping for Municipal Operations
II.G.2.d
The permittee maintained and implemented an O&M program for municipally -
O&M for Structural
owned or maintained structural stormwater controls installed for compliance with
Partial
---
stormwater Controls
the permittee's post -construction ordinance. If yes, then:
The C&M program specified the frequency of inspections and routine
maintenance requirements.
NO
The permittee documented inspections of all municipally -owned or maintained
Not
structural stormwater controls.
applicable
---
The permittee inspected all municipally -owned or maintained structural
Not
stormwater controls in accordance with the schedule developed by permittee.
Applicable
The permittee maintained all municipally -owned or maintained structural
Not
stormwater controls in accordance with the schedule developed by permittee.
Applicable
The permittee documented maintenance of all municipally -owned or
Not
maintained structural stormwater controls.
Applicable
---
II.G.2.e
The permittee ensured municipal employees are properly trained in pesticide,
Pesticide, Herbicide
herbicide and fertilizer application management.
Yes
14
and Fertilizer
Application
The permittee ensured contractors are properly trained in pesticide, herbicide and
Management
fertilizer application management.
Yes
The permittee ensured all permits, certifications, and other measures for
applicators are followed.
Yes
---
II.G.2.f
The permittee implemented an employee trainin
P pg program for employees involved
Not
Staff Training
n implementing pollution prevention and good housekeeping practices.
Applicable
Due to pandemic related issues, 2019/2020 there was no training program.
II.G.2.e
The permittee described and implemented measures that prevent or minimize
Vehicle and
contamination of stormwater runoff from all areas used for vehicle and equipment
Yes
Equipment Cleaning
cleaning.
Town Vehicles (Public Works) washed at public works facility.
NCS000403 Elon MS4 Audit 20220629
Page 14 of 17

Site Visit Evaluation: Municipal Facility No. 1
Facility Name:
Date and Time of Site Visit:
Public Works
June 29, 2022 3:OOpm
Facility Address:
Facility Type (Vehicle Maintenance, Landscaping, etc.):
214 Johnson Street
Public Works/Vehicle Maintenance
Name of MS4 Inspector(s) evaluated:
Most Recent MS4 Inspection (List date and name of inspector):
Phil Ross
June 27, 2022
Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name
Title
David Murphy
Assistant Public Works Director
TJ Murphy
Crew Leader
Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific?
No
What type of stormwater training do facility employees receive? How often?
Annual stormwater training.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
SCM inspector program with training every 3 years.
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
Yes
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Yes
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form?
Yes
Does the MS4 inspector's process include taking photos?
Yes
Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)?
No
Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge?
Yes
Did the MS4 inspector miss any obvious areas of concern? If so, explain:
The facility inspection did not include a full evaluation of all areas used to store chemical products. During the inspection we
identified secondary containment issues that had previously gone un-documented.
Does the MS4 inspector's process include presenting the inspection findings to the facility contact?
Yes
Inspection Results
Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)?
Modifications to chemical storage practices.
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
Not evaluated.
NCS000403_Elon M54 Audit_20220629 Page 15 of 17

Site Visit Evaluation: MS4 Outfall No. 1
Outfall ID Number:
Date and Time of Site Visit:
Not Given
June 29, 2022 3:30pm
Outfall Location:
Outfall Description (Pipe Material/Diameter, Culvert, etc.):
Public Works
CMP 36"
Receiving Water:
Is Flow Present? If So, Describe (Color, Approximate Flow Rate,
Michael Branch
Sheen, Odor, Floatables/Debris, etc.):
Standing Water. Clear.
Most Recent Outfall Inspection/Screening (Date):
June 27, 2022
Days Since Last Rainfall:
Inches:
Not evaluated
N/A
Name of MS4lnspector(s) evaluated:
Phil Ross
Observations
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
Storm water training every 3 years.
Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations?
Yes
Inspection Procedures
Does the inspector's process include the use of a checklist or other standardized form?
Yes
Does the inspector's process include taking photos?
Yes
Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they?
No
Inspection Results
Did the outfall inspection result in any work orders or maintenance requests? If so, for what issue(s)?
No
Will a follow-up outfall inspection be conducted? If so, for what reason?
Yes. Routine.
Notes/Comments/Recommendation s
NCS000403_Elon MS4 Audit_20220629 Page 16 of 17

Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1
Site Name:
Date and Time of Site Visit:
Station at Mill Point
June 29,2022
Site Address:
SCM Type:
South Williamson Avenue
Bio-Retention Cell
Most Recent MS4 Inspection (Include Date and Entity):
9/6/18
Name of MS4 Inspector(s) evaluated:
Most Recent MS4 Enforcement Activity (Include Date):
Phill Ross
N/A
Name(s) and Title(s) of Site Representative(s) Present During the Site Visit:
Name
Title
None
Observations
Site Documentation
Does the site have an operation and maintenance plan?
Not evaluated
Does the site have records of annual inspections? Are they performed by a qualified individual?
Not evaluated
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
Stormwater training every three years
Did the MS4 inspector appear knowledgeable about MS4 requirements for post -construction site runoff controls?
Yes
Did the MS4 inspector appear knowledgeable about post -construction BMPs (general purpose/function, components, 0&M
requirements, etc.)?
Yes
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form? What format?
Yes
Does the MS4 inspector's process include taking photos?
Yes
Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections.
Yes
Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge?
Yes
Did the MS4 inspector miss any obvious operation and maintenance deficiencies? If so, explain:
No
Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing?
Yes
NCS000403_Elon MS4 Audit_20220629 Page 17 of 17