NCS000247_(Signed) MS4 Audit Report_20230525

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May 25, 2023
CERTIFIED MAIL 7017 2680 0000 2237 5196
RETURN RECEIPT REQUESTED
Town of Cary
Attn: Sean R Stegall
PO Box 8005
316 North Academy Street
Cary, NC 27512
Subject: NOTICE OF COMPLIANCE (NOC-2023-PC-0418)
Town of Cary
NPDES MS4 Permit No. NCS000427
Wake County
Dear Mr. Stegall:
On April 18, 2023, 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
T. ere reviewed, as provided in
U.S. Postal Service
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c. Section H: Total Maximum Daily Loads.
North Carolina Department of CIi%ironmenf:rl Qualiry I Division of Energy.Nil neral and Land Resources
D E Ralcigh Regional orrice 1628 Mail Service Center,1:W0€iarreti D.ive Raleigh.North Caroliri::?7b09
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ROY COOPER
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DOUGLAS R.ANSCL -N'.: <' 4 r-ARU-",A
tofrr'int fli:• r;r Envfr-onmentat Quality
May 25, 2023
CERTIFIED MAIL 7017 2680 0000 2237 5146
RETURN RECEIPT REQUESTED
Town of Cary
Attn: Sean R Stegall
PO Box 8005
316 North Academy Street
Cary, NC 27512
Subject: NOTICE OF COMPLIANCE (NOC-2023-PC-0418)
Town of Cary
NPDES MS4 Permit No. NCS000427
Wake County
Dear Mr. Stegall:
On April 18, 2023, 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
Postal
ere reviewed, as provided in
CERTIFIED
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c. Section H: Total Maximum Daily Loads.
North Carolina Dep:rrt[r+ent of C[n'ironmental Quality ! Ditlsion nF Energy.FSinerat anCl Land IZesrurces
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DOUGLAS R.ANSEL No
Envlr-onmentalQuakly
May 25, 2023
CERTIFIED MAIL 7017 2680 0000 2237 5196
RETURN RECEIPT REQUESTED
Town of Cary
Attn: Sean R Stegall
PO Box 8005
316 North Academy Street
Cary, NC 27512
Subject: NOTICE OF COMPLIANCE (NOC-2023-PC-0418)
Town of Cary
NPDES MS4 Permit No. NCS000427
Wake County
Dear Mr. Stegall:
On April 18, 2023, 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) Self-evaluate the permit components that were not reviewed by DEQ for compliance and
submit the results within one hundred twenty (120) calendar days from the date of
receipt of this letter. The Part II of the MS4 Phase 1I Audit Template on the DEQ
stormwater web site can be used for this purpose. The specific sections that should be
self-audited include:
a. Part I1 Section B: Public Education and Outreach;
b. Section C, Public Involvement and Participation;
c. Section H: Total Maximum Daily Loads.
North Carolina Department of Environmental Quality I Division of E nergy,Mineral and Land Resources
Rale gh Regional Office 1628 Mail Service Center 13800 Barrett Drive I Raleigh,north Carolina 27604
919 191A200

(3) 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 II 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.
(4) 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.
(5) 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 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, 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 Thad
Valentine at [phone] or thad.valentine(�;ncdenr.gov or the MS4 Program Coordinator at
[e-mail].
Sincerely,
William H. Denton, IV, PE
Regional Engineer
DEMLR
Enclosures: DEQ MS4 Permit Compliance Audit Report
CC:
[e-mail]
DEMLR Stormwater Program Supervisor
[e-mail], DEMLR MS4 Program Coordinator
DEMLR NPDES MS4 Permit Laserfiche File

MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM AUDIT REPORT
NPDES PERMIT NO. NCS000427
Town of Cary, NORTH CAROLINA
316 N Academy Street
Audit Date: April 18, 2023
Report Date: May 24, 2023
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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NCS000427_Town of Cary MS4 Audit. 20230418 i

TABLE OF CONTENTS
AuditDetails..........................................................................................................................-..................... 1
PerrnMttee information........................................................................................................................----
2
list of Su pporti ng DoCurnents.................----..........--.......,..-..,........,,.......,.,............................................ 4
Program Implementation, Documentation&Assessment................... ..............-...................................... 5
Illicit Discharge Detection and Elimination (IDDE) ................................................................................------9
Construction Site Runoff Controls.......... ...... ...................................................... 3
Pollution Prevention and Good Housekeeping for Municipal Operations................................................. 17
Site Visit Evaluation; Municipal Facility 140. 1 .,,„.......................................................... ............—......---- 21
Site Visit Evaluation. M 4 Outfall No. 1 ..................... ...... .......................—................... 23
Site Visit Evaluation{ Construction Site No. 1............................................................................................. 25
Site Visit Evaluation; Post-Construction Stormwater Control Measure No- 1........................................... 27
AppP.ndix A, Supporting Documents
AppendixB. 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 Storm water
Management Plan in accordance with the issued permit.
NCS000427 Town of Cary MS4 Audit 20230418 ii

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NCS000427 Town of Cary MS4 Audit_20230418 �4t

Audit Details
Audit ID Number: Audit Date(s):
NCS000427_Cary MS4 Audit_20230418 04/18/2023
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
N Construction Site Runoff Controls-Delegated Sediment and Erosion Control Program
❑ Post-Construction Site Runoff Controls
N Pollution Prevention and Good Housekeeping for Municipal Operations
❑ Total Maximum Daily Loads(TMOLs)
Field Site Visits:
N Municipal Facilities. Number visited: 1
N MS4 Outfalls. Number visited: 1
N Construction Sites. Number visited: 1
❑ 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
Nam___e�Title Organization
Thad V nt DEQ-DEMLR Land Quality Section
Lau e a DEQ-DEMLR Land Quality Section
Audit Report Author: Date:
Signature —7kj
Audit Report Author: Date
Signature
NCS000427_Cary MS4 Audit_20230418 Page 1 of 30

Permittee Information
MS4 Permittee Name: Permit Effective Date: Permit Expiration Date:
Town of Cary 02/20/2017 02/19/2022
Date of Last MS4 Inspection/Audit:
Mailing Address: PO Box 8005,Cary, NC 27512 01/15/2026
Co-permittee(s),if applicable: N/A
Permit Owner of Record: Donald B Smith,WW CS Operator;Jamie Revels, Utilities Director
Primary MS4 Representatives Participating in Audit
Name,Title Organization
Tod Hoefler,Stormwater Specialist Town of Cary
Billy Lee,Stormwater Operating Manager Town of Cary
Marie Cefalo,Water Resources Outreach
Town of Cary
Supervisor
Richard Carter,Sr.Civil Designer Town of Cary
Jan Patterson,Senior Project Manager Town of Cary
Emily Cochran, Stormwater Program
Analyst Town of Cary
Eric Kulz, Environmental Specialist Town of Cary
Will Feely,Stormwater Field Services
Town of Cary
Technician
Mike Thompson,Stormwater Field Services
Town of Cary
Technician
Charles Brown,Stormwater Field Services
Town of Cary
Administrator
Michael Mazanek,Stormwater Project
Town of Cary
Manager
Lisa Booze, Stormwater Development and
Town of Cary
Floodplain Administrator
MS4 Receiving Waters
Waterbody Classification Impairments
Crabtree Creek C-NSW Fish Tissue Mercury
Walnut Creek C-NSW Fish Tissue Mercury
Swift Creek WS III Benthos (Nar, AL: FW)
Mtddle Creek C NSW Iron
Panther Creek WS IV Fish Tissue Mercury
NCS000427 Cary M54 Audit, 20230418 Page 2 of 30

White Oak Creek VOWS-IV Fish Tissue Mercury
NCS000427 Cary M54 Audit 20230418 Page 3 of 30

List of Supporting Documents
Item When Provided
Number Document Title (Prior to/During/After)
1 SWMP Before
2 Budget Summary Before
3 Org Chart Before
4 Town of Cary NPDES MS4 O&M Plan Before
5 CWEP Agreement Before
6 Cary IDDE Plan During
7 General Operating Guidelines for IDDE Weather Screening During
8 Pesticide Certifications During
9 PP&GH Training During
NCS000427 Cary MS4 Audit_20230418 Page 4 of 30

Program Implementation, Documentation &Assessment
Staff Interviewed: Tod Hoefler,Stormwater Specialist
(Name,Title,Role) Billy Lee,Stormwater Operating Manager
Marie Cefalo,Water Resources Outreach Supervisor
Richard Carter,Sr.Civil Designer
Jan Patterson,Senior Project Manager
Emily Cochran,Stormwater Program Analyst
Eric Kulz, Environmental Specialist
Will Feely,Stormwater Field Services Technician
Mike Thompson,Stormwater Field Services Technician
Charles Brown,Stormwater Field Services Administrator
Michael Mazanek,Stormwater Project Manager
Lisa Booze,Stormwater Development and Floodplain Administrator
Permit Citation Program Requirement Status Supporting
Doc No.
II.A.1 The permittee maintained adequate funding and staffing to implement and manage
Staffing and Ye, 1, 2
the provisions of the Stormwater Plan and meet all requirements of the permit.
Funding
The Stormwater Plan identifies a specific position(s)responsible for the overall
Y_ '
coordination,implementation,and revision to the Plan.
Responsibilities for all components of the Stormwater Plan are documented and
position(s)assignments provided. Y 1, 2,3
The permittee is current on payment of invoiced administering and compliance
Y. 84M5
monitoring fees(see stormwater e-payments on Df:MLR M54 web page).
Comments(Briefly describe funding mechanism,number of staff,etc.)
The Program is funded with the general fund.The Town funds the stormwater program from different revenue sources and has a 2
million operating budget,with a capital budget is 3.1 mil. Cary allocates about 2.9 million a year on stormwater. (Budget Summary
shown during audit). The Town maintains that the Program is adequately funded.
The provided SWMP identifies specific positions and responsibilities. Positions and responsibilities are also included in the Org Chart
and MS4 O&M Plan.
The Town has 12 employees dedicated to stormwater.
II.A.2 Stormwater The permittee evaluated the performance and effectiveness of the program
Plan Yes
components at least annually.
Implementation
and Evaluation If yes,the permittee used the results of the evaluation to modify the program
Yes
components as necessary to accomplish the intent of the Stormwater Program.
Did the permitted MS4 discharges cause or contribute to non-attainment of an
No -
applicable water quality standard?
If yes,did the permittee expand or better tailor its BMPs accordingly to address Not
the non-attainment? Applicable
NCS000427_Cary MS4 Audit_20230418 Page 5 of 30

Program Implementation, Documentation &Assessment
Comments
The Town performs a yearly evaluation of the Program. Updates are maintained in the Business Plan.The Business Plan is kept in
draft because it is always changing and is not a public document.
Informational flyers are mailed to repeat or specific groups of violators, in an effort to target and educate varying businesses with
the potential for polluted discharges.
The Town is currently transitioning into infield development since a large majority of residents are purchasing property, tearing
down houses,subdividing the old lot and building additional houses.The town is trying to gear the program to address this.The
Town updated the Program by adding inspectors and designating employees to different problems.The Town holds weekly
meetings on the biggest projects,good housekeeping work groups,CIP work groups,etc.The Town has made many ordinance
changes in the last few years.
II.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 2021 SWMP was provided prior to the audit.The SWMP is available in Laserfiche.The Town has not needed to notify the State
of any major changes.
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. Partial
Plan
The online materials included ordinances, or other regulatory mechanisms,or a list
identifying the ordinances,or other regulatory mechanisms, providing the legal Yes t :
authority necessary to implement and enforce the requirements of the permit.
Comments(Note what materials are available on line)
The SWMP is available in Laserfiche, but is not available on the Town website and is only available to citizens by requested.
Ordinances are available online and have recently been edited.
Legal authority—EC and IDDE in chapters 7 and 14.
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
Comments(Note date of DEMLR notification,modifications required,and date modifications were completed,as applicable)
DEMLR did not require any changes to the SWMP.
II.A.6 Sharing
Responsibility Are any control measures implemented by an entity other than the permittee? Partial
NCS000427 Cary MS4 Audit�20230418 Page 6 of 30

Program Implementation, Documentation &Assessment
77 tf yes, is there a written agreement in place? Not
Applicable
Comments(List the specific control measures implemented by others that do not have adequate written agreements,if
applicable)
The Town has a partnership with CWEP.
II.A.7 The permittee maintained written procedures for implementing the six minimum
Written control measures. Yes
Procedures
Written procedures identified specific action steps,schedules, resources and
Yes
responsibilities for implementing the six minimum measures.
Comments(List the specific minimum measures that do not have adequate written procedures,if applicable)
5OPs are maintained in the Town of Cary internal drive.The SOP for post-construction was viewed during the audit and included
details about all aspects of the program, including: transfer from construction to post construction,documentation, interaction
with other departments, paperwork, how-to's, inspection protocols,maintenance, links to templates,etc.
Ill.A The permittee maintained documentation of all program components including,but
Program not limited to, inspections, maintenance activities, educational programs, Yes
Documentation implementation of BMPs, enforcement actions etc., on file for a period of five years.
Comments(List the specific program components that do not have adequate documentation on file and why, if applicable)
Yes,viewed several examples during the audit.
1111.111 The permittee submitted annual reports to the Department within twelve months
Annual Report from the effective date of the permit(See Section 111.8.for the annual reporting Yes
Submittal period specific to this M54).
The permittee submitted subsequent annual reports every twelve months from the
Yes
scheduled date of the first annual report submittal.
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
Yes
of each major component of the Stormwater Plan for the past year and
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
Yes
the proposed changes and how these changes will impact the Stormwater
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 Yes
Plan.
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 Yes
Stormwater Plan.
S. An assessment of compliance with the permit, information on the
establishment of appropriate legal authorities,inspections,and enforcement Yes
actions.
NCS000427_Cary MS4 Audit 20230418 Page 7 of 30

Program Implementation, Documentation &Assessment
Comments(Note dates that annual reports cover under current permit and generally describe report deficiencies,if any)
The Town of Cary has submitted annual reports through RIMS
IV.B
Annual Reporting The Annual Reports document the following:
1. A summary of past year activities, including where applicable,specific
Yes
quantities achieved and summaries of enforcement actions.
2. A description of the effectiveness of each program component. Yes
3. Planned activities and changes for the next reporting period,for each
Yes
program component or activity.
4. Fiscal analysis. Yes
Comments(Note dates that annual reports cover under current permit and generally describe report deficiencies,if any)
The Town of Cary has submitted annual reports through RIMS.
Additional Documentation is thorough,well maintained, and current.
Comments: The SWMP should be available to the public on the town's website.
NCS000427 Cary MS4 Audit 20230418 Page 8 of 30

Illicit Discharge Detection and Elimination (IDDE)
Staff Interviewed: Tod Hoefler,Stormwater Specialist
(Name,Title, Billy Lee,Stormwater Operating Manager
Role) Marie Cefalo,Water Resources Outreach Supervisor
Richard Carter,Sr.Civil Designer
tan Patterson,Senior Project Manager
Emily Cochran,Stormwater Program Analyst
Eric Kulz,Environmental Specialist
Will Feely,Stormwater Field Services Technician
Mike Thompson,Stormwater Field Services Technician
Charles Brown,Stormwater Field Services Administrator
Michael Mazanek,Stormwater Project Manager
Lisa Booze,Stormwater Development and Floodplain Administrator
Permit Citation Program Requirement Status supporting
Doc No.
II.D.2.a
IDDE Program The permittee maintained a written IDDE Program. Yes 6
If yes,the written program includes provisions for program assessment and
Partial 6
evaluation and integrating program.
Comments(Note any deficiencies)
The IDDE Plan was provided prior to the audit.The Plan does not have specific provisions for evaluation, but there is a note that the
SOP will be updated as needed.
Public Works assists with IDDE identification and inspections for discharge.
The permittee maintained an IDDE ordinance or other regulatory mechanism(s)that Yes Online
II.D.2.b provides the legal authority to prohibit illicit connections and discharges to the MS4.
Legal Authorities If yes,the ordinance applies throughout the corporate limits of the permittee.
Yes Online
(Permit Part 1.0)
Comments
IDDE is included in Ch 14 of the TOC LDO.https://codelibrary.amlegal.corn/codes/cary/latest/overview
The ordinance applies throughout the corporate limits and ETJ. The Cary ETJ is smaller than city limits because of areas in counties.
Durham and Chatham local programs have jurisdiction in their counties.
II.D.2.c The permittee maintained a current map showing major outfalls* and receiving
Storm Sewer streams. Yes Online
System Map
Comments
TOC maintains several maps including a GIS Map and Stormwater Research Map.All major outfalls all mapped,and all outfall assets
can be viewed by clicking on the outfall.The map is very advanced.
*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>1 acres.
NCS000427_Cary MS4 Audit_20230418 Page 9 of 30

Illicit Discharge Detection and Elimination (IDDE)
iLD.2.d
Dry Weather Flow The permittee maintained a program for conducting dry weather flow field
5
observations in accordance with written procedures. Yes
Program
Comments(Generally summarize program,including frequency of observations and#or%of outfalls screened)
Dry weather screening is briefly mentioned in the IDDE SOP on page 2, but there is not a specific program. IDDE inspections are
performed regularly.Town maintains General Operating Guides for IDDE Dry Weather Screening. It has the actual procedures,
equipment,analysis of data,etc.
TOC maintains a Stormwater IDDE Map.Swrvey 123 is used for inspections.
II.D.2.e The permittee maintained written procedures for conducting investigations of
Investigation Yes Online
Procedures identified illicit discharges.
Comments(Generally describe what procedures are documented)
The IDDE SOP covers identifying illicit discharges,finding the source, and eliminating the illicit discharges and connections.The
Town maintains General Operating Guides for IDDE Dry Weather Screening,The Operating Guides includes the procedures,
equipment,analysis of data,etc.
IDDE incidents/investigations are recorded in a 311 Database at Carync.lightning.force.com.This database is not available to the
public.All IDDE information, inspections, addresses, phone numbers, is included in the database.
Citizen complaints come in through 311 and 311 generates a case. The case is then sent to the Stormwater section for inspection.
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
2. The results of the investigation Yes ---
3. Any follow-up of the investigation Yes ---
4. The date the investigation was closed Yes ---
Comments(Note whether a standard inspection form is utilized to capture consistent information and a tracking mechanism is
used)
An example of an IDDE investigation was shown during the audit.
It_D.2.A 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 Yes ---
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 IDDE Education/Training powerpoint was shown during the audit.
II.D.2.h The permittee informed public employees of hazards associated with illegal
Public Education discharges and improper disposal of waste. Yes •--
NCS000427_Cary MS4 Audit.20230418 Page 10 of 30

Illicit Discharge Detection and Elimination (IDDE)
The permittee informed businesses of hazards associated with illegal discharges and
Yes ---
improper disposal of waste.
The permittee informed the general public of hazards associated with illegal
Yes ---
discharges and improper disposal of waste.
Comments(Note how each sector was informed,if applicable)
The Town distributes IDDE Annual Mailers. The mailers rotate to different groups of residences, businesses, etc.The Town
distributes information at four different festivals as well. Utility users also get a monthly newsletter. Examples were shown during
the audit.
The Town of Cary website has newsletter examples on the Newsroom web page.
II.D.2.1 The permittee promoted, publicized, and facilitated a reporting mechanism for the
Public Reporting Yes
Mechanism public to report illicit discharges.
The permittee promoted, publicized, and facilitated a reporting mechanism for staff
Yes ---
to report illicit discharges.
The permittee established and implemented response procedures for citizen
Na ---
requests/reports.
Comments(Generally describe reporting mechanisms and how promoted/publicized/facilitated/established)
The public and Town employees can submit IDDE complaints in the 311 system and can save documents, pictures, voicemails,etc.
in the system.
TOC is required to contact the citizen within 24 hours during complaint responses.TOC should develop response procedures for
citizen complaints.
II.D.2.1 The permittee implemented a mechanism to track the issuance of notices of violation
Enforcement Yes 6,7
and enforcement actions administered by the permittee.
If yes, the mechanism includes the ability to identify chronic violators for
Yes ---
initiation of actions to reduce noncompliance.
Comments(Generally describe the established tracking mechanism, if applicable)
General operating guidelines for IDDE Dry Weather Screening.
Tracking Notices of Violation can be done through the 311 system by the case number.All notes and resolution details are listed in
the case.
Chronic violators can be tracked by name or address in the 311 system.All cases will be fisted.
NCS000427_Cary MS4 Audit_20230418 Page 11 of 30

Illicit Discharge Detection and Elimination (IDDE)
Additional
Comments:
NCS000427 Cary MS4 Audit_20230418 Page 12 of 30

Construction Site Runoff Controls
Staff Interviewed: Tod Hoefler,Stormwater Specialist
(Name,Title, Role) Billy Lee,Stormwater Operating Manager
Marie Cefalo,Water Resources Outreach Supervisor
Richard Carter,Sr.Civil Designer
)an Patterson,Senior Project Manager
Emily Cochran,Stormwater Program Analyst
Eric Kulz, Environmental Specialist
Will Feely,Stormwater Field Services Technician
Mike Thompson,Stormwater Field Services Technician
Charles Brown,Stormwater Field Services Administrator
Michael Mazanek,Stormwater Project Manager
Lisa Booze,Stormwater Development and Floodplain Administrator
Program Delegation Status:
® The permittee has a delegated Sediment and Erosion Control Program and implements the North Carolina
Sedimentation Pollution Control Act (SPCA)of 1973 components of this minimum measure(complete the permit
citation and SPCA citation sections).
❑ The permittee does not have a delegated Sediment and Erosion Control Program and relies on DEMLR to comply
with the North Carolina Sedimentation Pollution Control Act (SPCA) of 1973 components of this minimum measure
(complete only the permit citation section).
Permit Citation Program Requirement Status supporting
Doc No.
II.E.3 Construction
Site Runoff Controls The permittee provides and promotes a means for the public to notify the
(NPDES Permit No. appropriate authorities of observed erosion and sedimentation problems(e.g., Y
NCS000435] promoting the existence of the DEQ DEMLR"Stop Mud" hotline).
Comments(Describe how provided and promoted)
The publiE subm is complaints through the 311 System.
SPCA Citation Delegated Program Requirement Status supporting
Doc No.
113A-60 Local
The permittee has adopted an ordinance or other regulatory mechanism to enforce
erosion and yo, online
sedimentation the erosion and sedimentation control program.
control programs(a)
If yes,the ordinance meets or exceeds the minimum requirements of the
Y.
SPCA.
If yes, the ordinance applies throughout the corporate limits of the permittee.
Y
[Permit Port i.01
NCS000427_Cary MS4 Audit_20230418 Page 13 of 30

Construction Site Runoff Controls
Comments(Provide regulatory mechanism reference or Supporting Documentation number)
Chapter 11 of the TOC LDO addresses enforcement. https://codelibrary.amlegal.com/codes/cary/latest/overview
It applies throughout the corporate limits and ETJ.
§113A-60 Local
erosion and The permittee collects a fee paid by each person who submits an erosion and
Yes ---
sedimentation sedimentation control plan.
control programs(d)
Comments(indicate the fee amount,if applicable)
The TOC charges 500$per denuded acre for grading permits.There are no caps on fees and no separate review fee.There is a
$3500 overall fee to review a development plan.The development plan addresses more than sediment.After the third review,
additional fees are charged.
Applicants must have a development plan for an entire property. Permittees cannot just develop a road plan.
113A-60 Local Has any person initiated a land-disturbing activity(within the permittee's
erosion and jurisdiction)for which an erosion and sedimentation control plan is required in the Yes ---
sedimentation absence of an approved plan?
control programs(e) If yes,the permittee has notified the North Carolina Sedimentation Control
Yes ---
Commission of all such cases.
Has the permittee determined that a person engaged in a land-disturbing activity
Yrs
has failed to comply with an approved erosion and sedimentation control plan?
If yes, has the permittee referred any such matters to the North Carolina
Yes
Sedimentation Control Commission for inspection and enforcement?
Comments
Land disturbing activities have been initiated without an approved plan. Cary has areas in both the Neuse and Cape Fear River
basins.The State has jurisdiction in Neuse.The Town notifies Bill Denton, RRO Regional Engineer,when there is a NOV.
If applicants start development without paying the permit fees or without permits,the TOC doubles the fee during the permitting
process
The TOC does not review home plans for individual lots Lots are a part of the overall development plan.TOC does not allow mass
grading
§113A-61 Local The permittee reviews each erosion and sedimentation control plan submitted to
approval of erosion them and notifies the person submitting the plan that it has been approved, Yes
and sedimentation approved with modification, or disapproved within 30 days of receipt.
control plans The permittee only approves an erosion and sedimentation control plan upon
Yes
determining that it complies with all applicable State and local regulations.
The permittee has disapproved of an erosion and sedimentation control plan in
Y
order to protect riparian buffers along surface waters.
If yes,the permittee notified the Director of the Division of Energy, W
Mineral,and Land Resources within 10 days of the disapproval.
NCS000427_Cary MS4 Audit_20230418 Page 14 of 30

Construction Site Runoff Controls
Comments
The TOC does not approve plans that do not comply with State and Local regulations and adds an extra 50 ft to buffers in the Cape
Fear. Cary does not allow plating in the buffers for new development.
TOC LDO Ordinance requires that all developing plans show riparian buffers,wetlands, streams, etc. must provide 401/404 buffer
authorizations.TOC has delegated authority in the Cape Fear drainage area.
§_113A-61.i
Inspection of land- The certificate of approval of each erosion and sedimentation control plan
Yes --
disturbing activity; approved by the permittee includes a notice of the right to inspect.
notice of violation
(a) The permittee provides for inspection of land-disturbing activities to ensure
compliance with the SPCA and to determine whether the measures required in an Yes ---
erosion and sedimentation control plan are effective.
Comments
A grading permit was shown during the audit.The grading permit does include the right to inspect.The right to inspect is written
into the LOO. If there is an emergency such as an illicit discharge, Cary can get access to the site by contacting the police or by court
order.
§113A-61.1 When the permittee determines that a person engaged in land-disturbing activity
Inspection of land- has failed to comply with the SPCA,the Permittee immediately issues a notice of Yes
disturbing activity; violation upon that person.
notice of violation Each notice of violation issued by the permittee specifies the date by which the
(c) person must comply. Yes
Each notice of violation issued by the permittee informs the person of the actions
Yes
that need to be taken to comply.
Comments
An NOV example was shown during the audit.
113A-64 Penalties Does the permittee issue civil penalties as part of the erosion and sedimentation
Yes
program?
Comments(indicate when/why a civil penalty is issued,and the amount,if applicable)
Cary has not issued fines in the recent past.The Town issues a onetime$5,000 fine.
NCS000427_Cary MS4 Audit_20230418 Page 15 of 30

Construction Site Runoff Controls
Additional NPDES inspections should be performed and documented when inspecting all permitted construction sites.
Comments: When NPDES violations are identified, the contractor should be made aware of the deficiencies in the
inspection report. If after a reasonable amount of time,the deficiencies have not been corrected, the Town
can contact NCDEQ for assistance and the issuance of an NOV if necessary.
NCS000427_Cary MS4 Audit_20230418 Page 16 of 30

Pollution Prevention and Good Housekeeping for Municipal Operations
Staff Interviewed: Tod Hoefler,Stormwater Specialist
(Name,Title, Role) Billy Lee,Stormwater Operating Manager
Marie Cefalo,Water Resources Outreach Supervisor
Richard Carter,Sr.Civil Designer
Jan Patterson,Senior Project Manager
Emily Cochran,Stormwater Program Analyst
Eric Kulz,Environmental Specialist
Will Feely,Stormwater Field Services Technician
Mike Thompson,Stormwater Field Services Technician
Charles Brown,Stormwater Field Services Administrator
Michael Mazanek,Stormwater Project Manager
Lisa Booze,Stormwater Development and Floodplain Administrator
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 Yes ---
stormwater runoff.
Comments(Note number of facilities,typical inventory data and any facilities that are not inventoried that should be)
The Town maintains an inventory of facilities with the potential to generate polluted stormwater in an excel spreadsheet.All Town
properties that have structures on them are included in the spreadsheet.The facilities in BOLD are the ones that have the potential
to generate polluted stormwater. Each facility has its own,site specific, O&M plan.
The spreadsheet was shown during the audit.
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 Yes
Maintenance(O&M) stormwater runoff.
for Facilities
If yes, the O&M program specifies the frequency of inspections. Yes
If yes, the O&M program specifies the frequency of routine maintenance
Yes
requirements.
If yes, the permittee evaluated the O&M program annually and updated it as
Yes
necessary.
Comments
The Public Works O&M Plan was shown during the audit.The 0&M Plan included monthly inspection schedules. There is not a
specific maintenance schedule and maintenance is performed as needed.The facility has a fuel island, oil shed,salt storage, etc
II.G.2.c
Spill Response The permittee had written spill response procedures for municipal operations. Yes
Procedures
NCS000427_Cary MS4 Audit_20230418 Page 17 of 30

Pollution Prevention and Good Housekeeping for Municipal Operations
Comments
Spill response procedures were shown during the audit for the fleet maintenance building. Emergency contacts, cleanup
procedures, evaluations,small spills, med um and large spills specified were included.
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
Parking Lots corporate limits annually.
Maintenance If yes,the permittee evaluated the effectiveness of existing and new BMPs
Yes ---
based on cost and the estimated quantity of pollutants removed.
Comments
Public Works has a street sweeping program and leaf pickup. Street sweeping and leaf pickup is a contracted service, and the
streets are swept weekly with the remainder of the town being swept monthly.Waste is tracked by mileage and tonnage. During
the annual reporting period, the Town uses metrics to evaluate street sweeping effectiveness.The town uses the 311 system to
identifies problem areas and utilizing complaints for areas that need to be swept more often.
II.G.2.f The permittee maintained and implemented an O&M program for the stormwater
O&M for Catch
sewer system including catch basins and conveyance systems that it owns and Yes 4
Basins and
maintains.
Conveyance Systems
Comments(Briefly describe O&M program)
The Town maintains a NPDES M54 O&M Plan.
II.G.2.e The permittee maintained a current inventory of municipally-owned or operated
Structural structural stormwater controls installed for compliance with the permittee's post- Yes ---
Stormwater Controls construction ordinance.
Comments(Describe inventory information and number of controls in inventory)
The Town maintains a spreadsheet that includes all Town owned SCMs. There are 79 TOC SCMs, Dragon Fly Pond Works performs
monthly inspections and maintenance on each SCIVI. Inlets, riser structure, outlets,etc. are observed. Repair reports are submitted
if needed. SCMs are certified annually by an engineering firm.
NCS000427_Cary MS4 Audit-.20230418 Page 18 of 30

Pollution Prevention and Good Housekeeping for Municipal Operations
II.G.2.h The permittee maintained and implemented an 0&M program for municipally-
O&M for Structural owned or maintained structural stormwater controls installed for compliance with +
Stormwater Controls the permittee's post-construction ordinance. If yes,then:
The O&M program specified the frequency of inspections and routine
maintenance requirements.
The permittee documented inspections of all municipally-owned or maintained
Yes
structural stormwater controls.
The permittee inspected all municipally-owned or maintained structural
Yes
stormwater controls in accordance with the schedule developed by permittee.
The permittee maintained all municipally-owned or maintained structural
Yes
stormwater controls in accordance with the schedule developed by permittee.
The permittee documented maintenance of all municipally-owned or
w es
maintained structural stormwater controls.
Comments '
All SCMs have individual 0&M Plans. Dragon Fly Pond Works inspects SCMs once a month and provides maintenance services
following the inspection if needed.These services are followed with a detailed report.
II.G.2.1 The permittee ensured municipal employees are properly trained in pesticide,
Pesticide,Herbicide
herbicide and fertilizer application management.
and Fertilizer
Application The permittee ensured contractors are properly trained in pesticide, herbicide and
Yes --
Management fertilizer application management.
The permittee ensured all permits, certifications,and other measures for
Yes --
applicators are followed.
Comments
Contractor pesticide and herbicide certifications are kept up to date.
Town employees are certified for pesticides.
II.6.2.j The permittee implemented an employee training program for employees involved
Staff Training in implementing Yes 9
p g pollution prevention and good housekeeping practices.
Comments
Pollution Prevention and Good Housekeeping training was shown during the audit.
II.G.2.k 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 9
Equipment Cleaning cleaning.
NCS000427_Cary MS4 Audit_20230418 Page 19 of 30

Pollution Prevention and Good Housekeeping for Municipal Operations
Comments
Wash area maintenance is a part of the PP&GH training in powerpoint. It is also included in the facility O&M plan
Vehicle maintenance and washing O&M was shown during the audit.
Additional
Comments:
NCS000427_Cary MS4 Audit 20230418 Page 20 of 30

Site Visit Evaluation: Municipal Facility No. 1
Facility Name: Date and Time of Site Visit:
Vehicle Maintenance Facility 04/18/2023
Facility Address: Facility Type (Vehicle Maintenance,Landscaping,etc.):
400 lames Jackson Ave Fleet maintenance
Name of MS4 inspector(s)evaluated: Most Recent MS4 Inspection(List date and name of inspector):
Emily Cochran February 14, 2023
Eric Kulz
Name(s)and Title(s)of Facility Representative(s) Present During the Site Visit:
Name Title
Brandon Fleet Maintenance
Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP)or similar document?Is it facility-specific?
Yes, shown at audit and available at the facility.
What type of stormwater training do facility employees receive? How often?
Town trainings
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive?How often?
APWA training, NC State,Town training, IDDE training, etc.
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, but a more thorough inspection of all areas of the site should be done when performing this type of yearly inspection
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, as needed
Does the MS4 inspector's process include reviewing the facility's SWPPP(or similar document)?
Yes
NCS000427_Cary MS4 Audit_20230418 Page 21 of 30

Site Visit Evaluation: Municipal Facility No. 1
Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge?
v ;
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)?
N0
If compliance corrective actions were identified,what timeline for correction/follow-up was provided?
N/A
Notes/Comments/Recommendations
The O&M plan for this facility should include a site-specific inspection and maintenance plan. That plan would include inspections of
the vehicle wash area and fueling areas along with any other site-specific areas with the potential for polluted stormwater runoff
The no exposure permit is required to be updated at least annually, or when there is a change that would affect that designation
Failure to recertify every year is a violation of the no exposure agreement
NCS000427_Cary MS4 Audiit--20230418 rage 22 of 30

Site Visit Evaluation: MS4 Outfall No. 1
Outfall ID Number: Date and Time of Site Visit:
DR 764 15059 April 18,2023
Outfall Location: Outfall Description(Pipe Material/Diameter,Culvert,etc.):
Chapel Hill and Durham Rd 36"CMP(Diameter should be verified)
Receiving Water: Is Flow Present?If So,Describe(Color,Approximate Flow Rate,
Black Creek Sheen,Odor, Floatables/Debris,etc.):
Flow was present.
Most Recent Outfall Inspection/Screening(Date):
Unknown
Days Since last Rainfall: Inches:
4 Unknown
Name of MS4 Inspector(s)evaluated:
Charles Brown
Observations
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
APWA, NC State,Town 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
NCS000427—Cary MS4 Audit_20230418 Page 23 of 30

Site Visit Evaluation: MS4 Outfall No. 1
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?
N::A
Notes/Comments/Recommendations
Some litter was found and should be noted for further reference and possible cleanup.
NCS000427_.Cary MS4 Audit_20230418 Page 24 of 30

Site Visit Evaluation: Construction Site No. 1
Site/Project Name: Date and Time of Site Visit:
Bainbridge 04/18/2023
Site/Project Address: Operator: Unknown
Chapel Hill and NE Maynard Rd
Project Type(Commercial, Industrial,Residential,CIP, Roadway,
etc.): Residential
NCG Permit ID Number: Disturbed Acreage:
Unknown 15 acres
Recent Enforcement Actions(include Date):
Name of MS4 Inspector(s)evaluated:
Will Feely;Mike Thompson
Name(s)and Title(s)of Site Representative(s)Present During the Site Visit:
Name Title
N/A N/A
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?
Onsite training
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
APWA, NC State,Town training
Did the MS4 inspector appear knowledgeable about MS4 and NCGO10000 requirements for construction sites?
Yes
Did the MS4 inspector appear knowledgeable about erosion and sedimentation control/stormwater pollution prevention BMPs?
Yes
NCS000427_Cary MS4 Audit_20230418 Page 25 of 30

Site Visit Evaluation: Construction Site No. 1
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist?
Y�,5
Does the M54 inspector's process include taking photos?
Yes, as needed
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:
Nu
Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing?
Y1,%
Does the MS4 inspector's process include providing construction stormwater educational materials to the site contact?
Yes
Compliance/Enforcement
What,if any,enforcement actions(verbal warnings, NOV,etc.)did the inspection result in?
Site contractor have not been completing maintenance requirements and corrective actions listed in previous inspections.
If compliance issues were identified,what timeline for correction/follow-up was provided?
Determined by NOV
Notes/Comments/Recommendations
The inspector should recognize that althoug�i the town doesn't have the authority to enforce the NCG01 NPDES rules they can
comment on any defic:encies in their report and request that the requirements be followed.
NC5000427_Cary MS4 Audit 20230418 Page 26 of 30

Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1
Site Name: Date and Time of Site Visit:
Fleet Maintenance SCM 04/18/2023
Site Address: SCM Type:
Fleet Maintenance Facility Wet Pond
Most Recent M54 Inspection(include Date and Entity):
Unknown
Name of MS4 Inspector(s)evaluated: Most Recent MS4 Enforcement Activity(include Date):
Emily Cochran Unknown
Name(s)and Title(s)of Site Representatives)Present During the Site Visit:
Name Title
N/A N/A
Observations
Site Documentation
Does the site have an operation and maintenance plan?
Yes
Does the site have records of annual inspections?Are they performed by a qualified individual?
Yes
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive?How often?
NC State,APWA training
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,O&M
requirements,etc.)? Yf°;
inspection Procedures
Does the M54 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, as needed
Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections?
Yes
NCS000427 Cary MS4 Audit 20230418 Page 27 of 30

Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1
Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge?
Yarn
Did the MS4 inspector miss any obvious operation and maintenance deficiencies?If so,explain:
Yf 3
Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing?
YP,>
Compliance/Enforcement
What,if any, enforcement actions(verbal warnings, NOV,etc.)did the inspection result in?
N!A
If compliance issues were identified,what timeline for correction/follow-up was provided?
N/A
Notes/Comments/Recommendations
NCS000427_Cary MS4 Audit 20230419 Page 28 of 30

APPENDIX A: SUPPORTING DOCUMENTS
NCS000427 Cary MS4 Audit 20230418 Page 29 of 30

APPENDIX B: PHOTOGRAPH LOG
NCS000427 Cary MS4 Audit 20230418 Page 30 of 30