NCS000564_Audit Report_20220930

MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM AUDIT REPORT
NPDES PERMIT NO. NCS000564
Wendell, NORTH CAROLINA
15 E Fourth Street
Wendell, NC 27519
Audit Date: June 29, 2022
Report Date: September 30, 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

TABLE OF CONTENTS
AuditDetails.......... ....................... --.............................. ........................................... ............... ...... ..... .,, 1
PermitteeInformation................................................... ......................... ........................ ............ .. 2
Listof Supporting Documents...................................................................................................................... 3
Program Implementation, Documentation & Assessment.......................................................................... 4
Public Involvement and Participation .................................................................................................. 8
Illicit Discharge Detection and Elimination (I DOE) ..................................................................................... 10
Pollution Prevention and Good Housekeeping for Municipal operations.................................................13
Site Visit Evaluation. Municipal Facility No.1.................... ................................. ....... ......... ...... ---- ....... 16
Site Visit Evaluation: MS4 Dutfdll No. 1.................... .............. ......... ......... ........... --..... ................. ........... 18
Appendix A' Supporting Documents
Appendix 8. Photograph log
DISCLAIMER
This audit consists of an evaluation of program compliance with the issued permit and implementation of
the approved Stormwater Management Plan. This audit report does not include a review of all program
components, and program deficiencies in addition to those noted may be present. The permittee is
required to assess program progress and permit compliance, and to implement the approved Stormwater
Management Plan in accordance with the issued permit.
NCS000564 Town of Wendell MS4 Audit 20220930 ii

Audit Details
Audit ID Number:
Audit Date(s):
NCS000564 Town of Wendell M54 Audit 20220$29
June 29, 2022
Minimum Control Measures Evaluated:
0 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
® MS4 Outfalls. Number visited: 1
❑ Construction Sites. Number visited: Choose an item.
❑ Post -Construction Stormwater Runoff Controls. Number visited: Choose an item.
❑ Other: Number visited: Choose an item.
❑ Other: Number visited: Choose an item.
Inspector(s) Conducting Audit
Name. Title
Oreanization
Thad Valentine
DEMLR — Land Quality Section
Lauren Garcia
DEMLR — Land Quality Section
Jeanette Powell
DEMLR — Stormwater Program
Audit Report Author:
Date:
Signature
Audit Report Author:
Date
Signature
NCS000564_Town of Wendell-20220930 Page 1 of 22

List of Supporting Documents
Item
Number
Document Title
When Provided
(Prior to/During/After)
1
Interim SWMP
Prior
2
GAP Analysis
After
3
Annual Report
Prior
4
Wake County Interlocal Agreement
Prior
5
CWEP Agreement
Prior
6
Illicit Discharge Detection and Elimination Program Plan
Prior
7
MS4 Operation and Maintenance Plan
Prior
NCS000564_Town of Wendell_20220930 Page 3 of 22

Program Implementation, Documentation & Assessment
I I.A.3
Keeping the
The permittee kept the Stormwater Plan up to date.
Yes
1
Stormwater Plan
Up to Date
The permittee notified DEMLR of any updates to the Stormwater Plan.
Yes
---
Comments (indicate the date of latest Stormwater Plan and describe the nature of any updates, if applicable).
The Interim SWMP was submitted to Jeanette Powell, Stormwater Program Coordinator, for review.
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.
No
---
Plan
The online materials included ordinances, or other regulatory mechanisms, or a list
identifying the ordinances, or other regulatory mechanisms, providing the legal
Yes
Online
authority necessary to implement and enforce the requirements of the permit.
Comments (Note what materials are available on line)
The SWMP has not been published online. There is an update to the website scheduled for 2023, and the SWMP will be published
during this time.
The Town's Unified Development Ordinance is available online. Chapter 6 covers stormwater.
II.A.3 & II.A.5
Stormwater Plan
Did DEMLR require a modification to the Stormwater Plan?
Yes
---
Modifications
If yes, did the permittee complete the modifications in accordance with the
Not
established deadline?
Applicable
-
Comments (Note date of DEMLR notification, modifications required, and date modifications were completed, as applicable)
Jeanette Powell, MS4 Program Coordinator, provided comments on the Interim SWMP. Updates to the SWMP are currently being
made. The deadline has not yes passed.
II.A.6 Sharing
Responsibility
Are any control measures implemented by an entity other than the permittee?
Yes
4,5
If yes, is there a written agreement in place?
Partial
4,5
Comments (List the specific control measures implemented by others that do not have adequate written agreements, if
applicable)
Wake County implements Sediment and Erosion Control for the Town. The Town partners with CWEP for implementation of Public
Involvement & Participation and Public Education & Outreach.
II.A.7
The permittee maintained written procedures for implementing the six minimum
Written
control measures.
Partial
4, 5, 6, 7
Procedures
Written procedures identified specific action steps, schedules, resources and
responsibilities for implementing the six minimum measures.
Partial
---
NCS000564_Town of Wendell 20220930 Page 5 of 22

Program Implementation, Documentation & Assessment
2. A description of the effectiveness of each program component.
Yes
3. Planned activities and changes for the next reporting period, for each
program component or activity.
Yes
4. Fiscal analysis.
Yes
Comments (Note dates that annual reports cover under current permit and generally describe report deficiencies, if any)
Annual Reports are submitted through RIMS.
Additional
Comments:
NCS000564_Town of Wendell_20220930 Page 7 of 22

Public Involvement and Participation
Additional
Comments:
NCS000564, Town of Wendell .20220930 Page 9 of 22

Illicit Discharge Detection and Elimination (IDDE)
II.D.2.e
The permittee maintained written procedures for conducting investigations of
Investigation
identified illicit discharges.
6
Procedures
Comments (Generally describe what procedures are documented)
Illicit Discharge Source Investigation is covered in Section 5 of the IDDE Program Plan.
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 dates) the illicit discharge was observed
Yes
6
2. The results of the investigation
Yes
6
3. Any follow-up of the investigation
Yes
6
4. The date the investigation was closed
Yes
6
Comments (Note whether a standard inspection form is utilized to capture consistent information and a tracking mechanism is
used)
The Town has not had any reported illicit discharges other than the pesticide spill in 2020. A log for IDDE Source Investigations is
included on page 19 of the IDDE Program Plan.
II.D.2.g Employee
The permittee implemented and documented a training program for appropriate
Training
municipal staff who, as part of their normal job responsibilities, may come into
No
---
contact with or otherwise observe an illicit discharge or illicit connection.
Comments (Generally describe the staff training program, including frequency and which staff are trained)
The training program is currently being developed.
II.D.2.h
The permittee informed public employees of hazards associated with illegal
Yes
Online
Public Education
discharges and improper disposal of waste.
The permittee informed businesses of hazards associated with illegal discharges and
improper disposal of waste.
No
---
The permittee informed the general public of hazards associated with illegal
Partial
Online
discharges and improper disposal of waste.
Comments (Note how each sector was informed, if applicable)
The public and public employees are informed through emails and information on the Town website and social media pages. The
Town should work on providing additional information to the general public through handouts and mailings.
NCS000564_Town of Wendell_20220930 Page 11 of 22

Pollution Prevention and Good Housekeeping for Municipal Operations
Staff Interviewed:
Joseph Collins, Town of Wendell
(Name, Title, Role)
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 No ---
stormwater runoff.
Comments (Note number of facilities, typical inventory data and any facilities that are not inventoried that should be)
An inventory is being developed.
II.6.2.b
The permittee maintained and implemented an O&M program for municipally
Operation and
owned and operated facilities with the potential for generating polluted
No
---
Maintenance (O&M)
stormwater runoff.
for Facilities
If yes, the O&M program specifies the frequency of inspections.
No
---
If yes, the O&M program specifies the frequency of routine maintenance
requirements.
No
---
If yes, the permittee evaluated the O&M program annually and updated it as
No
---
necessary.
Comments
The Town has an MS4 Operation and Maintenance Plan. Section 2 of this plan addresses Buildings and Facilities. However, this
document does not include an inventory of municipally owned and operated facilities with the potential for generating polluted
stormwater runoff. Currently, inspections of municipal facilities are not performed as a part of the MS4 O&M Program. General
maintenance best practices are included, but there is no frequency of maintenance. The Plan is not updated annually.
II.G.2.c
Spill Response
The permittee had written spill response procedures for municipal operations.
Partial
7
Procedures
Comments
Spill Response Cleanup Procedures are included in Appendix A of the M54 0&M Plan. Site specific spill procedures will need to be
available at Town -owned facilities.
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
Yes
---
corporate limits annually.
NCS000554_Town of Wendell_20220930 Page 13 of 22

Pollution Prevention and Good Housekeeping for Municipal Operations
Pesticide, Herbicide
The permittee ensured contractors are properly trained in pesticide, herbicide and
and Fertilizer
fertilizer application management.
Yes
---
Application
The permittee ensured all permits, certifications, and other measures for
Management
applicators are followed.
Yes
---
Comments
Town employees are trained to apply herbicides. Town employees do not handle pesticides.
Contractors who apply pesticides have a stipulation in their contract that their certifications must be kept up to date: "Section 3
Complete Work without Extra Cost Unless otherwise provided, the Contractor shall obtain and provide, without additional cost to
the Town, all labor material, equipment, transportation, facilities, services, permits, and license is necessary to perform the work."
The Town also keeps track of staff certifications to make sure they are kept current.
II.G.2.j
The permittee implemented an employee training program for employees involved
Staff Training
in implementing pollution prevention and good housekeeping practices.
No
7
Comments
There is not a specific written training. Staff follow best management practices listed in the MS4 O&M Plan (Best Practices for the
Use, Storage and Disposal of Potential Pollutants, Pesticide, Herbicide and Fertilizer Best Practices, Vehicle and Equipment
Maintenance Best Practices etc.).
II.G.2.k
described and implemented measures that prevent or minimize
Vehicle and
7heittee
ation of stormwater runoff from all areas used for vehicle and equipment
Yes
7
Equipment Cleaning
Comments
Vehicle Washing Procedures Best Practices are included on Section 3 of the MS4 O&M Plan. The Town conducts vehicle washing in
the WPW Maintenance Yard. There is no wash bay at this time. Vehicle washing runoff drains to a sediment collection pond and
flows over a grass swale before flowing offsite.
NCS000564_Town of Wendell_20220930 Page 15 of 22

Site Visit Evaluation: Municipal Facility No. 1
Facility Name:
Public Works Facility
Date and Time of Site Visit:
06/29/2022
Facility Address:
450 Lake Glad Road
Facility Type (Vehicle Maintenance, Landscaping, etc.):
Public Works and Vehicle Maintenance
Name of M54 inspector(s) evaluated:
Joseph Collins, Public Works Superintendent
Most Recent MS4 Inspection (List date and name of inspector):
N/A
Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name
Title
Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific?
An inspection schedule has not yet been developed for the Public Works Facility, so auditors walked the site with the Public Works
Superintendent and discussed the process fo{ future inspections. Regular MS4 inspections have not been conducted.
The facility does not have a SWPPP at this time.
What type of stormwater training do facility employees receive? How often?
They will receive Town training when the training is developed.
inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
NC State Training
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
Knowledgeable about what will need to be inspected and the programs that will need to be developed.
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Knowledgeable about what will need to be inspected and the programs that will need to be developed.
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form?
N/A
Does the MS4 inspector's process include taking photos?
N/A
Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)?
N/A
NCS000564_Town of Wendell_20220930 Page 17 of 22

Site Visit Evaluation: MS4 Outfall No. 1
Outfall ID Number:
Date and Time of Site Visit:
Outfall at Landing PI Dr and Jones Wood Court
06/29/2022
Outfall Location:
Outfall Description (Pipe Material/Diameter, Culvert, etc.):
Outfall at Landing PI Dr and Jones Wood Court
Culvert
Receiving Water.
Is Flow Present? If So, Describe (Color, Approximate Flow Rate,
Buffalo Creek
Sheen, Odor, Floatables/Debris, etc.):
No flow present
Most Recent Outfall Inspection/Screening (Date):
N/A
Days Since Last Rainfall:
Inches:
Unknown
Unknown
Name of MS4 Inspector(s) evaluated:
Joseph Collins, Public Works Superintendent
Observations
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
NC State Training
Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations?
Yes, about what will need to be inspected. Regula inspections are not performed at this time. Auditors looked at the outfall with the
Public Works Superintendent and discussed what inspections will look like in the future.
Inspection Procedures
Does the inspector's process include the use of a checklist or other standardized form?
N/A
Does the inspector's process include taking photos?
N/A
Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they?
N/A
NCS000564_Town of Wendell_20220930 Page 19 of 22

APPENDIX A: SUPPORTING DOCUMENTS
NC5000564Town of Wendell, 20220930 Page 21 of 22