NCS000245_Corrected NOC_20221010

ROY COOPER
Governor
ELIZABETH S. BISER
Secretory
BRIAN WRENN
Director
CERTIFIED MAIL 7022 0410 0002 1249 5391
RETURN RECEIPT REQUESTED
City of Raleigh
Attn: Stewart W. Miles
One Exchange Plaza
Raleigh, North Carolina 27601
NORTH CAROLINA
Environmental Quality
October 10, 2022
Subject: NOTICE OF COMPLIANCE (NOC-2023-PC-0930)
City of Raleigh
NPDES MS4 Permit No. NCS000245
Wake County
Dear Mr. Miles:
On August 231d, 2022 through August 25th, 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 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
b. 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
of the NPDES MS4 permit.
If
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
M1'OIiiH CA�OHNP
oeo•�=�� icmeuomenoiaaiM1 828.296.4500

Required documentation shall be submitted via e-mail to [e-mail] 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.Reed(@ncdenr.gov.
SincerLeed,
IsaiahPE, CPSWQ MS4C Cl
MS4 Program Coordinator
Enclosures: DEQ MS4 Permit Compliance Audit Report
CC:
Wayne Miles wayne milesCcdraleighnc.gov
DEMLR Stormwater Program Supervisor
DEMLR NPDES MS4 Permit Laserfiche File
oer 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
828.296.4500

MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM AUDIT REPORT
NPDES PERMIT NO. NCS000245
RALEIGH, NORTH CAROLINA
One Exchange Plaza
Raleigh, North Carolina 27601
Audit Date: August 23-25 2022
Report Date: September 30, 2022
North Carolina Department of Environmental Quality
Division of Energy, Mineral & Land Resources Stormwater Program
512 N. Salisbury Street, 9' floor
1612 Mail Service Center
Raleigh, NC 27699-1612

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NC5000245_Raleigh M54 Audit_20220930

TABLE OF CONTENTS
AuditDetails..................................................................................................................................................1
PermitteeInformation..................................................................................................................................2
Listof 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: Construction Stormwater Site No. 1.........................................................................10
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 Storm water
Management Plan in accordance with the issued permit.
NCS000245_Raleigh MS4 Audit_20220930 ii

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NCS000245_Raleigh MS4 Audit_20220930 iii

Audit Details
Audit ID Number:
Audit Date(s):
NC5000245_Raleigh MS4 Audit_20220930
August 23, 24, and 25, 2022
Minimum Control Measures Evaluated:
N Program Implementation, Documentation & Assessment
❑ Public Education & Outreach
❑ Public Involvement & Participation
N 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:
N Municipal Facilities. Number visited: 2
N 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
Audit Report Autho,/
Date:
Signature
NCS000245_Raleigh MS4 Audit_20220930 Page 1 of 11

Permittee Information
MS4 Permittee Name:
City of Raleigh
Permit Effective Date:
October 10, 2018
Permit Expiration Date:
October 9, 2023
Mailing Address:
One Exchange Plaza. Raleigh, North Carolina 27601
Date of Last MS4 Inspection/Audit:
January 15, 2016
Co-permittee(s), if applicable: N/A
Permit Owner of Record: Whit Wheeler
Primary MS4 Representatives Participating in Audit
Name, Title
Organization
Day 1 (8/23/2022)
Barbara Moranta, Engineering Supervisor
City of Raleigh
Heather Dutra, Water Quality Manager
City of Raleigh
Carmela Teichman, Water Quality Educator
City of Raleigh
Joyce Gaffney, Environmental Specialist
City of Raleigh
Stephen Jelteman, Engineer
City of Raleigh
Justin Harcum, Sr. Engineer
City of Raleigh
Mani Kumar, Stormwater Administrator
City of Raleigh
Scott Bryant, Stormwater Administrator
City of Raleigh
Ariel Bushel, Communications Analyst
City of Raleigh
Ben Brown, Stormwater Administrator
City of Raleigh
Lauren Witherspoon, Engineering
Supervisor
City of Raleigh
Matthew Hunt, Business Services Manager
City of Raleigh
Wayne Miles, Stormwater Program
Manager
City of Raleigh
Zachary Poole, Engineering Specialist
City of Raleigh
Day 2 (8/24/2022)
Heather Dutra, Water Quality Manager
City of Raleigh
Carmela Teichman, Water Quality Educator
City of Raleigh
Zachary Poole, Engineering Specialist
City of Raleigh
Stephen Jelteman, Engineer
City of Raleigh
Justin Harcum, Sr. Engineer
City of Raleigh
Brad Stuart, Engineer
City of Raleigh
Wayne Miles, Stormwater Program
Manager
City of Raleigh
NCS000245_Raleigh MS4 Audit_20220930 Page 2 of 11

List of Supporting Documents
Item
Number
Document Title
When Provided
(Prior to/During/After)
1
Raleigh MS4 SWMP
Prior
2
Stormwater Program Webpage
Prior
3
2021 Annual Report
Prior
4
Unified Development Ordinance
Prior
5
IDDE Ordinance
Prior
6
Training PPT
Prior
7
Industrial Facility Plan
Prior
8
Education, Outreach, and Public Involvement Plan
Prior
9
Illicit Discharge Detection and Elimination Plan
Prior
10
Pollution Prevention and Good Housekeeping Plan
Prior
11
WQ Assessment and Monitoring Plan
Prior
12
SCM Inspections Program Plan
Prior
NCS000245_Raleigh MS4 Audit_20220930 Page 3 of 11

Program Implementation, Documentation & Assessment
Staff Interviewed:
All in attendance Day 1
(Name, Title, Role)
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
q
Mechanism
The permittee is current on payment of invoiced administering and compliance
monitoring fees (see stormwater e-payments on DEMLR MS4 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.
1
Stormwater Plan
FYe
Up to Date
See
The permittee notified DEMLR of any updates to the Stormwater Plan.
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
7, B, 9,
Procedures
control measures.
Yes
10, 11,
12
Website reviewed during audit.
NCS000245_Raleigh MS4 Audit_20220930 Page 4 of 11

Illicit Discharge Detection and Elimination (IDDE)
Staff Interviewed:
All in attendance Day 2
(Name, Title,
Role)
Permit Citation
Program Requirement Stat supporting Doc
us No.
II.D.2.a
Maintain
The permittee maintained appropriate legal Authorities. Yes 4
appropriate legal
authorities
Ordinance lost used for enforcement in 2018.
144Investigations in 2022. (Ordinance section 13-5008)
II.D.2.b
Maintain a Storm
Software
Sewer System
The permittee maintained a map system including major outfalls.
Yes
demonstrate
Base Map of
d during the
Major MS4
audit.
Outfalls.
Mapping software reviewed 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
9
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
6
Employee Training
II.D.2.e
Website
Maintain a public
The permittee and publicized a reporting mechanism for the public to report illicit
examined
reporting
connections and discharges.
Yes
during the
mechanism
audit.
Methods of publications were examined during the audit.
II.D.2.f
Investigation
Documentation
tracking
The permittee documented dates of investigations
yes
software was
examined
during the
audit.
Documentati
The permittee documented enforcement actions
Yes
on examined
during the
audit.
Tracking software and methods were discussed during the audit.
NCS000245_Raleigh M54 Audit_20220930 Page 5 of 11

Illicit Discharge Detection and Elimination (IDDE)
Additional
Recommendations:
Comments:
It is recommended that an increased frequency of IDDE specific training be considered for appropriate IDDE
staff.
It is recommended that IDDE reporting data include open/closed dates specifically.
Documentation for several IDDE investigations were discussed during the audit.
NCS000245_Raleigh MS4 Audit_20220930 Page 6 of 11

Site Visit Evaluation: Municipal Facility No. 1
Facility Name:
Central Operations Facility
Date and Time of Site Visit:
August 25, 2022
Facility Address:
2550Operations Way
Raleigh 27604
Facility Type (Vehicle Maintenance, Landscaping, etc.):
Public Works
Name of MS4 inspector(s) evaluated:
Stephen Jeltema
Most Recent MS4 Inspection (Date and Entity):
Not Evaluated
Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name
Title
Victor Avila
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?
Stormwater 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)?
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)?
Modifications to PM&GH practices relating to the NCG080000 requirements.
Comments:
NCS000245_Raleigh MS4 Audit_20220930 Page 7 of 11

Site Visit Evaluation: Municipal Facility No. 1
During the site visit, secondary containment status of generators on site was discussed. As well as spill prevention measures in the
fueling areas.
NCS000245_Raleigh MS4 Audit_20220930 Page 8 of 11

Site Visit Evaluation: Municipal Facility No. 2
Facility Name:
Date and Time of site Visit:
Go Raleigh Operations facility
August 25, 2022
Facility Address:
Facility Type (Vehicle Maintenance, Landscaping, etc.):
4104 Poole Road
Vehicle Maintenance
Raleigh 27601
Name of MS4 inspector(s) evaluated:
Most Recent MS4 Inspection (List date and name of inspector):
Stephen leltema
No evaluated
Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name
Title
Benjamin Goldstein
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?
Stormwater 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)?
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
Comments:
SWPPP contents and monitoring documentation was discussed.
NCS000245_Raleigh MS4 Audit_20220930 Page 9 of 11

Site Visit Evaluation: Construction Site No. 1
Site/Project Name:
Date and Time of Site Visit:
Go Raleigh Parking
August 25, 2022
Site/Project Address:
Operator:
4104 Poole Road
Not evaluated
Raleigh 27601
Project Type (Commercial, Industrial, Residential, CIP, Roadway,
etc.):
NCG Permit ID Number:
Disturbed Acreage:
Not Evaluated
—4
Recent Enforcement Actions (Include Date):
None
Name of MS4 Inspector(s) evaluated:
Lauren Witherspoon
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
Does the site have approved erosion and sedimentation control plans onsite? Are they representative of current site conditions..
Yes
What type of stormwater training do site employees receive? How often?
Not evaluated
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
stormwater Training every 3 years.
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
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist?
Yes
Does the MS4 inspector's process include taking photos?
Yes
Does the MS4 inspector's process include reviewing approved plans (erosion and sedimentation control and/or SWPPP)?
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 violations? If so, explain:
No
Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing?
Not Evaluated
NCS000245_Raleigh MS4 Audit_20220930 Page 10 of 11

Site Visit Evaluation: Construction Site No. 1
Does the MS4 inspector's process include providing construction stormwater educational materials to the site contact?
Not evaluated
Compliance/Enforcement
What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in?
None
If compliance issues were identified, what timeline for correction/follow-up was provided?
N/A
NCS000245_Raleigh MS4 Audit_20220930 Page 11 of 11