NCS000249_NOC and Audit Report_20220930

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
BRIAN WRENN
Director
NORTH CAROLINA
Environmental Quality
September 30, 2021
CERTIFIED MAIL 7021 2720 0000 1254 6070
RETURN RECEIPT REQUESTED
City of Durham
Attn: Paul Wiebke, Assistant Director
101 City Hall Plaza
Durham, North Carolina 27701
Subject: NOTICE OF COMPLIANCE (NOC-2023-PC-0930)
City of Durham
NPDES MS4 Permit No. NCS000249
Durham County
Dear Mr. Wiebke:
On August 16n,, 2022 through August 18, 2022, staff from the North Carolina Department of Environmental
Quality (DEQ) conducted a compliance audit of subject National Pollutant Discharge Elimination System
(NPDES) Municipal Separate Storm Sewer System (MS4) Permit. The audit identified minor deficiencies with
the specific components of the MS4 permit that were reviewed, as provided in the attached DEQ MS4 Permit
Compliance Audit Report.
In accordance with Part VI of the permit and DEQ policy, a new 5-year MS4 permit will be issued in response
to the audit. As such, the permittee is required to complete the following actions:
(1) Respond in writing within thirty (30) calendar days from the date of receipt of this notice to
acknowledge these requirements and the intent to comply.
(2) Develop a Stormwater Management Plan (SWMP) which details specific actions, measurable goals,
and implementation timelines for the stormwater management program over the new 5-year
permit term. The SWMP must be documented utilizing the DEQ Phase 11 MS4 SWMP Template. The
permittee shall submit the SWMP to DEQ for review and comment within one hundred twenty (120)
calendar days from the date of receipt of this letter.
(3) Submit an NPDES MS4 permit application for whichever comes first:
a. At least one hundred eighty (180) days prior to permit expiration, or
It. Within thirty (30) days of receiving written DEQ concurrence that the submitted SWMP
documents a compliant stormwater management program and the MS4 should submit the
application including a signed Final Draft SWMP. A new 5-year NPDES MS4 permit will be
public noticed along with the Draft Final SWMP.
(4) Respond to comments on the Draft Final SWMP and submit a signed Final SWMP for DEQ approval
and final permit issuance. The final DEQ-approved SWMP shall become an enforceable component
D_E Q North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
Asheville Regional Office 1 2090 U.S. Highway 70 1 Swannanoa, North Carolina 28778
•� � «m=�u� o •�� �� 828.296,4500

of the NPDES MS4 permit and an Annual Self -Assessment Template that corresponds to the
approved SWMP will be provided.
Required documentation shall be submitted via e-mail to Isaiah. Reed (@ncdenr gov, or to:
DEQ-DEMLR Stormwater Program
Attn: Isaiah Reed
1612 Mail Service Center
Raleigh, NC 27699-1612
Thank you for your attention to this matter. Should you have any questions, please contact me at
Isaiah. ReedPncdenr. gov.
Sincerely
Isaiah Reed, PE, CPSWQ, MS4CECI
MS4 Program Coordinator
Enclosures: DEQ MS4 Permit Compliance Audit Report
CC:
Michelle.Woolfolk@dui,hamnc.gov
DEMLR Stormwater Program Supervisor
DEMLR NPDES MS4 Permit Laserfiche File
er oft
Q„ North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
ll���JJ{//t Asheville Regional Office 1 2090 U.S. Highway 70 1 Swannanoa, North Carolina 28778
u°na=.m of . wm:oul N.` 828.296.4500

MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM AUDIT REPORT
NPDES PERMIT NO. NCS000249
DURHAM, NORTH CAROLINA
101 City Hall Plaza
Durham, North Carolina 27701
Audit Documentation Request: April 5, 2022
Audit Date: August 16-18 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

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NCS000249 Durham MS4 Audit 20220930

TABLE OF CONTENTS
AuditDetails..................................................................................................................................................1
PermitteeInformation..................................................................................................................................2
List of Supporting Documents.......................................................................................................................3
Program Implementation, Documentation & Assessment...........................................................................4
Illicit Discharge Detection and Elimination (IDDE)........................................................................................5
Site Visit Evaluation: Municipal Facility No. 1...............................................................................................7
Site Visit Evaluation: Municipal Facility No. 2...............................................................................................9
Site Visit Evaluation: Municipal Facility No. 3.............................................................................................10
Site Visit Evaluation: MS4 Outfall No. 1......................................................................................................11
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 MS4 Audit 20220930 ii

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NCS000249 Durham MS4 Audit 20220930 Hi

Audit Details
Audit ID Number:
Audit Date(s):
NCS000249_Durham MS4 Audit_20220816
August 16, 17, and 18 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:
M Municipal Facilities. Number visited: 3
© 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
Organization
Isaiah Reed, Environmental Engineer
NCDEQ
Lauren Garcia, Environmental Specialist
NCDEQ
Thad Valentine, Environmental Specialist
NCDEQ
Audit Report Author:
Date:
Signature
NCS000249_Durham MS4 Audit_20220930 Page 1 of 11

Permittee Information
MS4 Permittee Name:
City of Durham
Permit Effective Date:
October 10, 2018
Permit Expiration Date:
October 9, 2022
Mailing Address: 101 City Hall Plaza. Durham, NC 27701
Date of Last MS4lnspection/Audit:
January 15, 2016
Co-permittee(s), if applicable: N/A
Permit Owner of Record: Paul Wiebke, Asst.
Director of Public Works
Primary M54 Representatives Participating in Audit
Name, Title
Organization
Day 1 (8/16/2022)
Michelle Woolfolk, Water Quality Manager
City of Durham
Ryan Eaves, Ste. Div. Mgr.
City of Durham
Laura Smith, Public Information and
Communications Analyst
City of Durham
Jim Azareto, IDDE Supervisor
City of Durham
John Loperfido, Asst. WQ Manager
City of Durham
Shea Balick, SWDR Manager
City of Durham
Paul Wiebke, Assistant Director
City of Durham
Day 2(8/17/2022)
Michelle Woolfolk, Water Quality Manager
City of Durham
Christine Cailleret, Env. Planning and
Compliance Coordinator
City of Durham
Blaine Lery, Env. Planning and Compliance
Coordinator
City of Durham
Jim Azarelo, IDDE Supervisor
City of Durham
John Loperfido, Asst. WQ Manager
City of Durham
NCS000249_Durham MS4 Audit_20220930 Page 2 of 11

List of Supporting Documents
Item
Number
Document Title
When Provided
(Prior to/During/After)
1
Stormwater Management Plan (January 2019)
Prior
2
SOPs Document
Prior
3
2021 Annual Report (Section A Docs)
Prior
4
Durham Stormwater Management and Pollution Control Ordinance
Prior
5
Training Documents (Section D Docs)
Prior
6
IDDE Investigations Enforcement Summary
Prior
7
IDDE Training Records (D7— IDDE Staff Training)
Prior
NCS000249_Durham MS4 Audit_20220930 Page 3 of 11

Program Implementation, Documentation & Assessment
Staff Interviewed:
Michelle Wolfolk, WQ Manager
(Name, Title, Role)
Jim Azareto, IDDE Supervisor
John Loperfido, Assistant WQ Manager
Permit Citation
Program Requirement
Status
supporting
Doc No.
II.A.1
The Permittee Maintained adequate legal mechanisms to implement all provisions of
Adequate Legal
the of the Stormwater Management Plan.
Yes
4
Mechanism
The permittee is current on payment of invoiced administering and compliance
monitoring fees (see Stormwater e-payments on DEMLR M54 web page).
Yes
BIMS
II.A.2 Stormwater
Plan
The permittee evaluated the performance and effectiveness of the program
Implementation
components at least annually.
Yes
3
and Evaluation
II.A.3
Keeping the
The permittee kept the Stormwater Plan up to date.
Yes
1
Stormwater Plan
Up to Date
See
The permittee notified DEMLR of any updates to the Stormwater Plan.
Yes
NCDEQ
LF
Did DEMLR require a modification to the Stormwater Plan?
No
II.A.4 Written
The permittee maintained written procedures for implementing the six minimum
Procedures
control measures.
Yes
2
Website reviewed during audit.
NCS000249_Durham MS4 Audit_20220930 Page 4 of 11

Illicit Discharge Detection and Elimination (IDDE)
Staff Interviewed:
Michelle Wolfolk, WQ Manager
(Name, Title,
Jim Azareto, IDDE Supervisor
Role)
John Loperfido, Assistant WQ Manager
Permit Citation
Program Requirement Status Supporting
Doc No.
II.D.2.a
Maintain
The permittee maintained appropriate legal Authorities. Yes q
appropriate legal
authorities
Ordinance has been used regularly. 82 NOVs and SS NOPs. 181 NORs. Fees are occasionally offset by receipts given which show
funds used to remediate the issues identified. NOV/NOR/NOP process outlined in the SOPS document.
Administration/Enforcement outlined in A-10 of the Ordinance. Section 7.4 (7-22) of the SWMP. Section 4 of the SOPS manual.
Written program for IDDE is in SOPS document section 4.
II.D.2.b
Software
Maintain a Storm
demonst
Sewer System
The permittee maintained a map system including major outfalls.
Yes
rated
Base Map of
during
Major MS4
the
Outfalls.
audit.
Mapping software examined and discussed during the audit.
II.D.2.c
Maintain written
The permittee maintained written procedures and SOPS for detecting and tracing
procedures and/or
Illicit discharges.
Yes
2
SOPS for IDDE.
II.D.2.c
The permittee maintained written procedures or SOPS for dry weather flow
Dry weather flow
Yes
2
inspections
inspections.
II.D.2.d
The permittee conducted IDDE training for appropriate municipal staff.
Yes
7
Employee Training
II.D.2.e
Website
Maintain a public
The permittee and publicized a reporting mechanism for the public to report illicit
examine
reporting
connections and discharges.
Yes
d during
mechanism
the
audit.
Publication and availability of reporting mechanisms were discussed during the audit.
II.D.2.f
Documentation
The permittee documented dates of investigations
Yes
6
The permittee documented enforcement actions
Yes
6
Tracking software and methods were discussed during the audit.
NCS000249_Durham MS4 Audit_20220930 Page 5 of 11

) Illicit Discharge Detection and Elimination (IDDE) )
Additional Recommendations:
Comments: It is recommended that a field report be developed for IDDE investigations.
It is recommended that the field report for dry weather flow includes a size/diameter/material section.
NCS000249_Durham MS4 Audit_20220930 Page 6 of 11

Site Visit Evaluation: Municipal Facility No. 1
Facility Name:
North Durham Water Reclamation Facility
Date and Time of Site Visit:
August 18, 2022
Facility Address:
1900 E Club Blvd.
Facility Type (Vehicle Maintenance, Landscaping, etc.):
WWTP
Name of MS4 inspector(s) evaluated:
James
Most Recent MS4 Inspection (Date and Entity):
October 24, 2018
Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name
Title
John Dodson
Operator
Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific?
Yes
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?
Annual Stormwater training.
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 M54 inspector's process include taking photos?
Yes
Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)?
Yes
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:
Stormwater contact with waste biosolids and resulting wastewater was discussed on site.
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 PM&GH practices relating to the NCG110000 requirements.
NCS000249_Durham M54 Audit_20220930 Page 7 of 11

Site Visit Evaluation: Municipal Facility No. 1
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
Not determined on site.
NCS000249_Durham MS4 Audit_20220930 Page 8 of 11

Site Visit Evaluation: Municipal Facility No. 2
Facility Name:
Fleet Maintenance Facility
Date and Time of Site Visit:
August 18, 2022
Facility Address:
1900 Camden Ave
Facility Type (Vehicle Maintenance, Landscaping, etc.):
Vehicle Maintenance
Name of MS4 inspector(s) evaluated:
Audrey Britton
Most Recent MS4 Inspection (List date and name of inspector):
February 7, 2019
Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name
Title
John Fergusson
Primary Contact
Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific?
Yes.
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?
Annual storm water training.
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)?
Yes
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:
No
Does the MS4 inspector's process include presenting the inspection findings to the facility contact?
Yes
Inspection Results
Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)?
No
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
N/A
NCS000249_Durham MS4 Audit_20220930 Page 9 of 11

Site Visit Evaluation: Municipal Facility No. 3
Facility Name:
City of Durham Public Works Operations Center
Date of Site Visit:
August 18, 2022
Facility Address:
1100 Martin Luther King Jr. Pkwy.
Facility Type (Vehicle Maintenance, Landscaping, etc.):
Public Works
Name of MS4 inspector(s) evaluated:
Jim Azareto
Most Recent MS4 Inspection (Date and Entity):
December 6, 2018
Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name
Title
Phillip Powell
Assistand Director of Operations
Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific?
Yes
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?
Annual5tormwater Training
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)?
Yes
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:
No
Does the MS4 inspector's process include presenting the inspection findings to the facility contact?
Yes
Inspection Results
Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)?
No
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
N/A
NCS000249_Durham MS4 Audit_20220930 Page 10 of 11

Site Visit Evaluation: MS4 Outfall No. 1
Outfall ID Number:
Date and Time of Site Visit:
46262
August 18, 2022 9:00 am
Outfall Location:
Outfall Description (Pipe Material/Diameter, Culvert, etc.):
300 Club Blvd.
Pipe (CMP)
Receiving Water:
Is Flow Present? If So, Describe (Color, Approximate Flow Rate,
Ellerbe Creek
Sheen, Odor, Floatables/Debris, etc.):
Submerged.
Most Recent Outfall Inspection/Screening (Date):
Not reviewed
Days Since Last Rainfall:
Inches:
Not reviewed
N/A
Name of MS4lnspector(s) evaluated:
Melissa Harrison, Environmental Planning and Compliance Specialist
Blaine Lary, Environmental Planning and Compliance Coordinator
Observations
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
Annual Stormwater Training.
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.
NCS000249_Durham M54 Audit_20220930 Page 11 of 11