NCS000406_NOD and Audit Report_20230731

STAA
GOY COOPER C
Governor
ELIZABETH S.BISER
Secretary
DOUGLAS R.ANSEL NORTH CAROLINA
Interim Director Environmental Quality
July 31,2021
CERTIFIED MAIL 7022 2410 0003 1437 0446
RETURN RECEIPT REQUESTED
City of Wilmington
Attn: Tony Caudle, City Manager
102 N Third Street
Wilmington,North Carolina 28402
Subject: NOTICE OF DEFICIENCY(NOD-2023-PC-0212)
City of Wilmington
NPDES MS4 Permit No. NCS000406
New Hanover County
Dear Mr. Caudle:
On June 16,2023,staff from the North Carolina Department of Environmental Quality(DEQ)conducted a
compliance audit of the 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. This
report lists and describes the deficiencies with certain components of the MS4 permit,which constitutes a violation
of the Clean Water Act and is grounds for enforcement action.
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
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 and an Annual Self-Assessment Template that corresponds to the approved SWMP
will be provided.
North Carolina Department of Environmental Quality I Division of Energy,Mineral and Land Resources
512 North Salisbury Street 1 1612 Mail Service Center I Raleigh,North Carolina 27699-1612
rvarrm uaoiw
oro.,mm.m or m.maa,i� /`� 919.707.9200

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City of Wilmington
Notice of Deficiency
July 31,2023
Page 2 of 2
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
If the MS4 fails to meet the aforementioned requirements and/or submits a significantly noncompliant Draft SWMP,
DEQ may proceed with enforcement. As is stated in Part V, Section A.I(c)of the permit:
Under state law, a daily civil penalty ofnot more than twenty-five thousand dollars(525,000)per violation
may be assessed against any person who violates or fails to act in accordance with the terms, conditions,
or requirements of a permit[North Carolina General Statute 143-215.6A]. Please note that compliance
with the requirements of this NOD and/or issuance of civil or criminal penalties levied by DEQ does not
preclude the EPA from carrying out its own enforcement case against the permittee.
Thank you for your attention to this matter. Should you have any questions,please contact Isaiah Reed at(828)
296-4618 or isaiah.reedgdeg.nc.eov.
Sincerely /
Isaiah Reed, PE,CPSWQ, MS4CECI
MS4 Program Coordinator
North Carolina Department of Environmental Quality
Enclosures:
DEQ MS4 Program Audit Report(June 16,2023, City of Wilmington)
CC:
Jim Quinn, Stormwater Specialist iim.quinngwilmingtonnc.gov
Isaiah Reed, MS4 Program Coordinator Isaiah.reedP_deq.nc.eov
Dan Sams,Regional Engineer [e-mail]
DEMLR NPDES MS4 Permit Laserfiche File

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MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM AUDIT REPORT
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NPDES PERMIT NO. NCS000406
WILMINGTON, NORTH CAROLINA
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209 Coleman Drive
Audit Date: June 14, 2023
Report Date: July 31, 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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NC5000406_WilmingtonM54Audit_20230614 i

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TABLE OF CONTENTS
AuditDetails..................................................................................................................................................1
PermitteeInformation ..................................................................................................................................2
Listof Supporting Documents.......................................................................................................................4
Program Implementation, Documentation &Assessment...........................................................................5
Public Education and Outreach.....................................................................................................................8
Public Involvement and Participation...........................................................................................................9
Illicit Discharge Detection and Elimination (IDDE)......................................................................................10
Post-Construction Site Runoff Controls......................................................................................................12
Pollution Prevention and Good Housekeeping for Municipal Operations..................................................17
Site Visit Evaluation: Municipal Facility No. 1.............................................................................................19
Site Visit Evaluation: MS4 Outfall No. 1......................................................................................................20
Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1............................................21
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.
NCS000406_WilmingtonMS4Audit_20230614 ii

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NCS000406_WilmingtonMS4Audit_20230614 iii

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Audit Details
Audit ID Number: Audit Date(s):
NCS000406_wilmington MS4 Audit_20230614 June 14 and 15,2023
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Minimum Control Measures Evaluated:
® Program Implementation, Documentation&AssessmentI,
® Public Education&Outreach
® Public Involvement& Participation i
® 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
N MS4 Outfalls.Number visited: 1
❑ Construction Sites. Number visited:Choose an item.
® Post-Construction Stormwater Runoff Controls. Number visited: 1
❑ Other: . Number visited: Choose an item.
❑ Other: . Number visited:Choose an item.
Inspector(s) Conducting Audit
Name.Title Or¢anization
Isaiah Reed, MS4 Program Coordinator NCDEQ
Dan Sams, Regional Engineer NCDEQ
Christine Hall, Engineering Supervisor NCDEQ
Audit Report Author, Date
Signature 7/3//-2 ,,,2
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NCS000406_wilmington MS4 Audit_20230614 Page 1 of 21
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Permittee Information
M54 Permittee Name: Permit Effective Date: Permit Expiration Date:
City of Wilmington February 1,2018 January 31, 2023
Mailing Address: Date of Last M54 Inspection/Audit:
PO Box 1810.Wilmington, NC28402 9/15/2011
Co-permittee(s),if applicable:
None
Permit Owner of Record:
Anthony Caudle,City Manager
Primary MS4 Representatives Participating in Audit
Name,Title Organization
Jim Quinn,Stormwater Specialist City of Wilmington
Saskia Cohick,Stormwater GIS Manager City of Wilmington
Jennifer Butler,Stormwater Education
City of Wilmington
Program Manager
Anna Reh-Gingerich,Watershed
City of Wilmington
Coordinator
Fredrick Royal,Stormwater Services
City of Wilmington
Manager
Brian Rostholder, Compliance Specialist City of Wilmington
Dave Mayes, Public Services Director City of Wilmington
Aaron Beckner,Sr. Project Engineer City of Wilmington
Jay Carter, Field Ops City of Wilmington
Rob Gordon, Plan Review Engineer City of Wilmington
MS4 Receiving Waters
Waterbodv Classification Impairments
Smith Creek C;Sw None known
Burnt Mill Creek C;Sw None known
Greenfield Lake SC;Sw None known
Barnards Creek C;Sw None known
Motts Creek C;Sw None known
Howe Creek SA;ORW None known
Bradley Creek SC; HQW:# None known
Hewletts Creek SA; HQW None known
NCS000406_Wilmington M54 Audit_20230614 Page 2 of 21

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Whiskey Creek SA; HQW None known
Intercoastal Waterway SA;ORW None known
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Cape fear River Sc None known
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NCS000406_Wilmington MS4 Audit_20230614 Page 3 of 21

List of Supporting Documents
Item Document Title When Provided
Number (Prior to/During/After)
1 Annual Report Prior
2 Cape Fear River Watch/New Hanover County Agreements After
3 Written Programs After
4 Stormwater Watch Annual Report After
5 Cape Fear Report After
6 Creek Watchers Report After
7 Annual Summary for volunteer watershed reclamation Program. After
8 Public Comment form After
9 Map screenshot showing attributes of outfalls and infrastructure After
10 IDDE Ordinance After
11 Training Sign-in sheet After
12 Restaurant outreach brochure After
13 2018/2019 SCM Inspections list After
14 Deed with SCM restrictions After
15 Post-C Ordinance After
16 SCM Inventory After
17 SCM Plan approval letter After
18 Post C O&M Plan from submitted plans. After
19 Final Inspection CO approval document After
20 inventory of municipal facilities with potential to impact SW. After
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Program Implementation, Documentation &Assessment
Staff Interviewed: Jim Quinn,Stormwater Specialist
(Name,Title,Role) Fredrick Royal,Stormwater Manager
Permit Citation Program Requirement Status Supporting
Doc No.
II.A.1 The permittee maintained adequate funding and staffing to implement and manage
Staffing and the provisions of the Stormwater Plan and meet all requirements of the permit. Yes ---
Funding
The Stormwater Plan identifies a specific position(s)responsible for the overall Not
coordination, implementation,and revision to the Plan. Reviewed
Responsibilities for all components of the Stormwater Plan are documented and Not
position(s)assignments provided. Reviewed ---
The permittee is current on payment of invoiced administering and compliance Not
monitoring fees(see stormwater e-payments on DEMLR MS4 web page). Reviewed
SW Enterprise Utility based on impervious service/ERUs. No approved SWMP.
II.A.2 Stormwater The permittee evaluated the performance and effectiveness of the program
Plan components at least annually. Yes 1
Implementation
and Evaluation If yes,the permittee used the results of the evaluation to modify the program Not
components as necessary to accomplish the intent of the Stormwater Program. Reviewed
Did the permitted MS4 discharges cause or contribute to non-attainment of an yes 1
applicable water quality standard?
If yes,did the permittee expand or better tailor its BMPs accordingly to address Yes 1
the non-attainment?
Fecal Coliform has been identified as an issue for the MS4 discharges. Outreach has been directed to assess/address the issue.
II.A.3
Keeping the The permittee kept the Stormwater Plan up to date. No ---
Stormwater Plan
Up to Date
The permittee notified DEMLR of any updates to the Stormwater Plan. Not
Applicable
No approved SWMP.information provided after the audit shows prior NCDEQ guidance on SWMP approval.
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 Partial Website
authority necessary to implement and enforce the requirements of the permit.
Annual reports and Ordinances are available online.
Not
IDid DEMLR require a modification to the Stormwater Plan? I Applicable _ I
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Program Implementation, Documentation & Assessment
II.A.3&II.A.S If yes, did the permittee complete the modifications in accordance with the Not
Stormwater Plan Applicable ___
established deadline.?
Modifications
II.A.6 Sharing
Responsibility Are any control measures implemented by an entity other than the permittee? Yes 2 and 27
If yes, is there a written agreement in place? Yes 2 and 27
4-6 contracts with other entities to implement parts of the program.
II.A.7 The permittee maintained written procedures for implementing the six minimum
Written control measures. Partial 3
Procedures
Written procedures identified specific action steps,schedules, resources and
No ---
responsibilities for implementing the six minimum measures.
Plans for IDDE and Outreach/Education/Involvement.Review during audit indicate that the written programs are incomplete.
111A The permittee maintained documentation of all program components including, but
At least
Program not limited to, inspections,maintenance activities,educational programs, Yes
S years.
Documentation implementation of BMPs,enforcement actions etc.,on file for a period of five years.
Document retention is currently indefinite.
111.8 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 MS4).
The permittee submitted subsequent annual reports every twelve months from the Not
scheduled date of the first annual report submittal. Reviewed
The Annual Reports included appropriate information to accurately describe the progress,status,and results
of the permittee's Stormwater Plan,including, but not limited the following:
1. A detailed description of the status of implementation of the Stormwater Plan
as a whole.This will include information on development and implementation Not
of each major component of the Stormwater Plan for the past year and Reviewed
schedules and plans for the year following each report.
2. An adequate description and justification of any proposed changes to the
Stormwater Plan.This will include descriptions and supporting information for Not
the proposed changes and how these changes will impact the Stormwater Reviewed
Plan(results,effectiveness,implementation schedule,etc.).
3. Documentation of any necessary changes to programs or practices for
Not
assessment of management measures implemented through the Stormwater
Reviewed
Plan.
4. A summary of data accumulated as part of the Stormwater Plan throughout
Not
the year along with an assessment of what the data indicates in light of the
Reviewed
Stormwater Plan.
5. An assessment of compliance with the permit,information on the
establishment of appropriate legal authorities,inspections,and enforcement Not
Reviewed
actions.
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Program Implementation, Documentation & Assessment
IV.B
Annual Reporting The Annual Reports document the following:
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1. A summary of past year activities, including where applicable,specific Not
quantities achieved and summaries of enforcement actions. Reviewed
2. A description of the effectiveness of each program component. Not
Reviewed
3. Planned activities and changes for the next reporting period,for each Not
program component or activity. Reviewed
4. Fiscal analysis. Not
Reviewed
Comments:There is no approved SWMP.However,City of Wilmington staff have regarded the SWMP consistent with prior
guidance from DEQ staff.The distinctions and improvements to the way the SWMP is viewed were discussed,and future
processes will include all submittal and approval requirements outlined in the permit.
NC5000406_Wilmington MS4 Audit_20230614 Page 7 of 21

Public Education and Outreach
Staff Interviewed: Jim Quinn,Stormwater Specialist
(Name,Title,Role) Fredrick Royal,Stormwater Manager
Jennifer Butler,Stormwater Education Program Manager
Permit Citation Program Requirement Status supporting
Doc No.
II.B.2.a
The permittee defined goals and objectives of the Local Public Education and Yes 3
Goals and
Outreach Program based on community wide issues.
Objectives
Pet waste viewed as primary source.
II.B.2.b The permittee maintained a description of the target pollutants and/or stressors and
Yes 3
Target Pollutants likely sources.
Written program updated regularly.
II.B.2.c The permittee identified,assessed annually and updated the description of the target yes 3
Target Audiences audiences likely to have significant storm water impacts and why they were selected.
II.B.2.d Residential The permittee described issues,such as pollutants,the likely sources of those 4, 12 and
and Industrial/ pollutants,potential impacts,and the physical attributes of stormwater runoff in Yes
website.
Commercial Issues their education/outreach program.
II.B.2.e
Informational The permittee promoted and maintained an Internet web site designed to convey the yes Website
Web Site Program's message.
II.B.2.f The permittee distributed stormwater educational material to appropriate target
Public Education Yes 4
Materials groups.
II.B.2.z The permittee promoted and maintained a stormwater hotline/helpline for the 12
Hotline/Help Line Yes
purpose of public education and outreach. Website
II.B.2.h The permittee's outreach program, including those elements implemented locally or
Public Education through a cooperative agreement,included a combination of approaches designed to Yes 1
and Outreach reach the target audiences.
Program
For each media,event or activity, including Those elements implemented locally or
through a cooperative agreement the permittee estimated and recorded the extent Yes 1
of exposure.
Stormwater Watch, Brochure handed out at events, Website,81^grade program on website,Enviroscape program,K-9s for clean
water program.Booths at pet focused events.
NCS000406_Wilmington MS4 Audit_20230614 Page 8 of 21

Public Involvement and Participation
Staff Interviewed: Jim Quinn,Stormwater Specialist
(Name,Title,Role) Fredrick Royal,Stormwater Manager
Jennifer Butler,Stormwater Education Program Manager
Permit Citation Program Requirement Status supposing
Doc No.
II.C.2.a Volunteer
Community The permittee included and promoted volunteer opportunities designed to promote 1,5,and
Involvement ongoing citizen participation. Yes 6,7
Program
Door hangers and Storm-drain marking(Soil and Water).River Watch cleanups,10 cleanups annually. Creek Watchers. Volunteer
Watershed restoration program.Maintains map with data points jar outreach.
II.C.2.b
Mechanism for The permittee provided and promoted a mechanism for public involvement that
Yes $
Public provides for input on stormwater issues and the stormwater program.
Involvement
II.C2.c The permittee promoted and maintained a hotline/helpline for the purpose of public
Yes Website
Hotline/Help Line involvement and participation.
NC5000406_Wilmington MS4 Audit_20230614 Page 9 of 21

Illicit Discharge Detection and Elimination (IDDE)
Staff Interviewed: Brian Rostholder,Compliance Officer
(Name,Title, Jim Quinn,Stormwater Specialist
Role) Fredrick Royal,Stormwater Manager
Soskia Cohick,Stormwater GIS Manager
Permit Citation Program Requirement Status supposing
Doc No.
II.D.2.a
IDDE Program The permittee maintained a written IDDE Program. Yes 3
If yes,the written program includes provisions for program assessment and
Yes 3
evaluation and integrating program.
Wellington Avenue Investigation reviewed and analyzed.
The permittee maintained an IDDE ordinance or other regulatory mechanism(s)that Yes 10
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. Not
[Permit Part I.D] Reviewed
Enforcement documents reviewed.
II.D.2.t
The permittee maintained a current map showing major outfalls and receiving
Storm Sewer Yes 9
System Map streams.
Outfall map analyzed during audit.
II.D.2.d The permittee maintained a program for conducting dry weather flow field
Dry Weather Flow Yes 3
observations in accordance with written procedures.
Program
25%a year.lust includes the major outfalls. Tidal influence is a challenge for the permittee.
II.D.2.e
The permittee maintained written procedures for conducting investigations of yes 3
Procedures
Investigation
identified illicit discharges.
IDDE SOP and Written Program reviewed during audit.
II.D.2.f For each case of an illicit discharge or potential illicit discharge,the permittee documented and tracked the
Track and following:
Document
Investigations 1. The date(s)the illicit discharge was observed No ---
2. The results of the investigation No ---
3. Any follow-up of the investigation No ---
4. The date the investigation was closed No ---
A dedicated NOV IDDE tracking system which includes all required information shall be developed but is not currently available.
1 �
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Illicit Discharge Detection and Elimination (IDDE)
II.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 11
contact with or otherwise observe an illicit discharge or illicit connection.
Every two and a half years. On-boarding training.
II.D.2.h
The permittee informed public employees of hazards associated with illegal
Public Education Yes 11
discharges and improper disposal of waste.
The permittee informed businesses of hazards associated with illegal discharges and yes 12
improper disposal of waste.
The permittee informed the general public of hazards associated with illegal yes 12
discharges and improper disposal of waste.
Specific outreach to automotive and restaurants,etc.Mailed to restaurants.Restaurant poster which gets posted in employee
areas.
II.D.2.i The permittee promoted, publicized,and facilitated a reporting mechanism for the
Public Reporting Yes Website
Mechanism Public to report illicit discharges.
The permittee promoted, publicized,and facilitated a reporting mechanism for staff
Yes Website
to report illicit discharges.
The permittee established and implemented response procedures for citizen yes 3
requests/reports.
II.D.2A The permittee implemented a mechanism to track the issuance of notices of violation
Enforcement and enforcement actions administered by the permittee. No ---
If yes,the mechanism includes the ability to identify chronic violators for
No ---
initiation of actions to reduce noncompliance.
Tracking Mechanism which includes all required information has not been maintained.
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Post-Construction Site Runoff Controls
Staff Interviewed: Jim Quinn,Stormwater Specialist
(Name,Title, Role) Fredrick Royal,Stormwater Manager
Rob Gordon,Plan review Engineer
Jay Carter,Field Ops
Implementation(check all that apply):
® The permittee implements the components of this minimum measure.
❑ The permittee relies upon another entity to implement the components of this minimum measure: City of Wilmington
❑ The permittee implements the following deemed-compliant program(s),which meet NPDES MS4 post-construction
requirements for the areas where implemented and in compliance with the specific program requirements as provided in 15A
NCAC and noted below(Complete Session Law 2006-246 section below):
❑ Water Supply Watershed I(WS-1)—15A NCAC 26.0212
❑ Water Supply Watershed II(WS-11)—15A NCAC 2B.0214
❑ Water Supply Watershed III (WS-III)—15A NCAC 2B.0215
❑ Water Supply Watershed IV(WS-IV)—15A NCAC 26.0216
❑ Freshwater High Quality Waters(HOW)—15A NCAC 2H .1006
❑ Freshwater Outstanding Resource Waters(ORW)—15A NCAC 2H .1007
❑ Neuse River Basin Nutrient Sensitive(NSW) Management Strategy-15A NCAC 2B.0235
❑ Tar-Pamlico River Basin Nutrient Sensitive(NSW) Management Strategy-15A NCAC 213.0258
❑ Randleman Lake Water Supply Watershed Nutrient Management Strategy-15A NCAC 2B.0251
❑ Universal Stormwater Management Program—15A NCAC 2H .1020
Ordinance(s)(check all that apply):
The permittee utilizes the following ordinances and/or regulatory authority to fulfill post construction minimum measure program
requirements throughout the MS4 permitted area (check all that apply):
❑ DEQ model ordinance
* MS4 designed post-construction practices that meet or exceed 15A NCAC 02H .1000.
❑ DEQ approved comprehensive watershed plan
❑ DEQ approved ordinance for a deemed-compliant Program(see list above)
Instructions:
For MS4s not implementing a S.L. 2006-246 deemed-compliant program, complete only the Permit Citation section below.
For MS4s implementing a S.L.2006-246 deemed-compliant program, complete the Session Law 2006-246 section below. If the MS4
does not implement a deemed-compliant program throughout the entire MS4 permitted area, then complete the Permit Citation
section belowfor the permitted areas)not covered under the S.L.2006-246 deemed-compliant program.
Session Law 2006- program Requirement Status supporting
246 Doc No.
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Post-Construction Site Runoff Controls
Deemed-Compliant The permittee implements deemed-compliant Program requirements in !,
Not
Program(s) accordance with the applicable 15A NCAC rules. applicable
The permittee implements deemed-compliant Program requirements throughout
the entire MS4 area (If not, also complete the Permit Citation section below.) Not
Applicable
The permittee applies deemed-compliant Program requirements to all federal, j
state and local government projects within the permitted MS4 area who do not Not
Applicable
have their own NPDES stormwater permit.
The permittee included deemed-compliant Program reporting in their M54 Annual
Not
Reports.
Applicable
The permittee included deemed-compliant Program implementation in their
Not
Stormwater Management Plan. Applicable
Permit Citation Program Requirement Status supporting
Doc No.
II.F.2.a The permittee maintained an ordinance or other regulatory mechanism designed
Legal Authority to meet the objectives of the Post-Construction Site Runoff Controls Stormwater Yes 15
Management Program.
If yes,the ordinance applies throughout the corporate limits of the permittee
(Verify permit coverage area listed in Part I.D of permit and modify Yes 15
accordingly).
The permittee has the authority to review designs and proposals for new
development and redevelopment to determine whether adequate stormwater Yes 15
control measures will be installed, implemented,and maintained.
The permittee has the authority to request information such as stormwater plans,
inspection reports,monitoring results, and other information deemed necessary to
Yes 15
evaluate compliance with the Post-Construction Stormwater Management
Program.
The permittee has the authority to enter private property for the purpose of
inspecting at reasonable times any facilities,equipment, practices,or operations Yes 15
related to stormwater discharges.
Post Construction SW Ordinance was reviewed during the audit.
II.F.2.b
Stormwater Control The permittee utilizes strategies which include SCMs appropriate for the MS4. Yes 15
Measures(SCMs)
SCMs comply with 15A NCAC 02H .1000. Not
Reviewed
II.F.2.c The permittee conducted site plan reviews of all new development and
Plan Reviews redeveloped sites that disturb greater than or equal to one acre(including sites Yes 15
that disturb less than one acre that are part of a larger common plan of
development or sale).
State
If yes,the site plan reviews addressed how the project applicant meets the and City
performance standards. Yes Manuals
and
Specs
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Post-Construction Site Runoff Controls
If yes,the site plan reviews addressed how the project will ensure long-term yes 14
maintenance.
II.F.2.d The permittee maintained an inventory of projects with post-construction
Inventory of Projects structural stormwater control measures installed and implemented at new Yes 16
development and redeveloped sites.
The inventory included both public and private sector sites located within the
permittee's corporate limits that are covered by its post-construction ordinance Yes 16
requirements.
II.F2.e The permittee provided mechanisms such as recorded deed restrictions and
Deed Restrictions protective covenants that ensure development activities will maintain the project Yes 14
and Protective
consistent with approved plans.
Covenants
Deed restrictions.
II.F2.f The permittee implemented or required an operation and maintenance plan for
Mechanism to Yes 18
the long-term operation of the SCMs required by the program.
Require Long-term
Operation and The operation and maintenance plan required the owner of each SCM to perform
Maintenance No ---
and maintain a record of annual inspections of each SCM.
Annual inspection of permitted structural SCMs are required to be performed by a
No ---
qualified professional.
Inspection requirement not clearly laid out on the Ordinance or O&M Plan.Annual Inspection not requested from SCM Owners.
II.F.2.g The permittee conducted and documented inspections of each project site covered
Inspections of under performance standards, at least one time during the permit term (Verify this Yes 13
Structural is o permit condition in Part II.F.2.g of permit and modify accordingly).
Stormwater Control Before issuing a certificate of occupancy or temporary certificate of occupancy,the
Measures permittee conducted a post-construction inspection to verify that the permittee's
performance standards have been met or a bond is in place to guarantee Yes 19
completion(Verify this is a permit condition in Part II.F.2.g of permit and modify
accordingly.
The permittee developed and implemented a written inspection program for SCMs
installed pursuant to the post-construction program(Verify this is a permit No ---
condition in Part II.F.2.g of permit and modify accordingly.
The permittee documented and maintained records of inspections. Yes 13
The permittee documented and maintained records of enforcement actions. Partial --
Formal Inspection to issue CO.Inspect at certification,at renewal,at transfer.570 privately owned.No written program which
identifies inspection frequency.120 inspection done in the 21122 year.No SCM owners are currently sending in inspection
reports.
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Post-Construction Site Runoff Controls
II.F.2.h The permittee made available through paper or electronic means, ordinances,
Educational post-construction requirements,design standards checklists, and other materials
Materials and appropriate for developers. Yes Website
Training for Note:New materials may be developed by the permittee,or the permittee may use j
Developers materials adopted from other programs and adapted to the permittee's new
development and redevelopment program.
II.F.2.i Enforcement The permittee tracked the issuance of notices of violation and enforcement
--
actions. No
If yes,the tracking mechanism included the ability to identify chronic violators Not
for initiation of actions to reduce noncompliance. Applicable
II.F.3.b The permittee fully complies with post construction program requirements on its Not New Development own publicly funded construction projects. Reviewed ___
Municipally owned project plans not reviewed during the audit.
II.F3.c Does the MS4 have areas draining to Nutrient Sensitive Waters(NSW)pursuant to Not
Nutrient Sensitive 15A NCAC 02H .0150? Reviewed
Waters
If yes,does the permittee use SCMs that reduce nutrient loading in order to Not
meet local program requirements. Reviewed
If yes,does the permittee also still incorporate the stormwater controls Not
required for the project's density level. Reviewed
If yes,does the permittee also require documentation where it is not feasible to Not
use SCMs that reduce nutrient loading. Reviewed
II.F.3.d The permittee ensured that the design volumes of SCMs take into account the
Design Volume runoff at build out from all surfaces draining to the system. Yes ---
Where"streets'convey stormwater,the permittee designed SCMs to be sized to
treat and control stormwater runoff from all surfaces drainingto the SCM including
g Reviewed
streets,driveways,and other impervious surfaces.
Comments
NCS000406_Wilmington MS4 Audit_20230614 Page 15 of 21

Post-Construction Site Runoff Controls
Additional Interpretation of 15A NCAC 02H is inconsistent in comparison to Wilmington RO staff. Wilmington staff will
Comments: work with WiRO staff to better meet the expectations of the program and work on consistency.Discussions
included how pervious area is viewed in regard to permit application vs.exemption.
NCS000406_Wilmington MS4 Audit_20230614 Page 16 of 21

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Pollution Prevention and Good Housekeeping for Municipal Operations
Staff Interviewed: Jim Quinn,Stormwater Specialist
(Name,Title, Role) Fredrick Royal,Stormwater Manager j
Dave Mayes,Public Services DirectorI
Jay Carter,Field Ops.
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 20
stormwater runoff.
Inventory reviewed during inspection.
II.G.2.b The permittee maintained and implemented an 0&M program for municipally
Operation and owned and operated facilities with the potential for generating polluted Yes 21
Maintenance(O&M) stormwater runoff.
for Facilities
If yes,the O&M program specifies the frequency of inspections. Yes 21
If yes,the O&M program specifies the frequency of routine maintenance yes 21
requirements.
If yes,the permittee evaluated the C&M program annually and updated it as
Partial 21
necessary.
O&M Plan first created in 2020.
II.G.2.c
Spill Response The permittee had written spill response procedures for municipal operations. Yes 22
Procedures
Spill response SOP and SPCC.
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 No ---
Parking Lots corporate limits annually.
Maintenance If yes,the permittee evaluated the effectiveness of existing and new BMPs
No ---
based on cost and the estimated quantity of pollutants removed.
Evaluation of the effectiveness of the program is not documented.
II.G.2.e
O&M for Catch The permittee maintained and implemented an 0&M program for the stormwater
Basins and sewer system including catch basins and conveyance systems that it owns and Yes 21
maintains.
Conveyance Systems
II.G.2.f The permittee maintained a current inventory of municipally-owned or operated
Structural structural stormwater controls installed for compliance with the permittee's post- Yes 23
Stormwater Controls construction ordinance.
Inspections tracked through Munis.
NC5000406_Wilmington M54 Audit_20230614 Page 17 of 21

Pollution Prevention and Good Housekeeping for Municipal Operations
II.G.2.e The permittee maintained and implemented an O&M program for municipally-
O&M for Structural owned or maintained structural stormwater controls installed for compliance with Yes 24
Stormwater Controls the permittee's post-construction ordinance. If yes,then:
The O&M program specified the frequency of inspections and routine Yes 24
maintenance requirements.
The permittee documented inspections of all municipally-owned or maintained yes 13
structural stormwater controls.
The permittee inspected all municipally-owned or maintained structural Yes 13
stormwater controls in accordance with the schedule developed by permittee.
The permittee maintained all municipally-owned or maintained structural yes 13
stormwater controls in accordance with the schedule developed by permittee.
The permittee documented maintenance of all municipally-owned or
No ---
maintained structural stormwater controls.
Compare specificity between Public O&M Plan and privately owned O&M Plan.
II.G.2.h The permittee ensured municipal employees are properly trained in pesticide,
Pesticide,Herbicide Yes 25
herbicide and fertilizer application management.
and Fertilizer
Application The permittee ensured contractors are properly trained in pesticide, herbicide and Not
Management fertilizer application management. Applicable
The permittee ensured all permits,certifications, and other measures for Yes 25
applicators are followed.
Some application of herbicide.
II.G.2.i The permittee implemented an employee training program for employees involved
Staff Training Yes 26
in implementing pollution prevention and good housekeeping practices.
Jim Quinn trains public staff.
II.G.2.i 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 3
Equipment Cleaning cleaning.
Fleet Maintenance has an agreement with automated corwashes.
NCS000406_Wilmington MS4 Audit_20230614 Page 18 of 21

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Site Visit Evaluation: Municipal Facility No. 1
Facility Name: Date and Time of Site Visit: j
Stormwater operations Complex June 15,2023
Facility Address: Facility Type(Vehicle Maintenance,Landscaping,etc.): III
209 Coleman Drive Public Works
Name of MS4 inspector(s)evaluated: Most Recent MS4 Inspection(List date and name of inspector):
Jim Quinn,Stormwater Specialist Not reviewed
Name(s)and Title(s)of Facility Representative(s) Present During the Site Visit:
Name Title
Ed McGlofflin Operations Specialist
Rick Porter Facility Manager
John Fortune Fleet Maintenance Manager
Observations
Facility Documentation/Training If
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?
Bi-Annual SW Training.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive?How often?
No regular training documented.
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
Yes.
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Yes
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form?
Yes
Does the MS4 inspector's process include taking photos?
Yes
Does the MS4 inspector's process include reviewing the facility's SWPPP(or similar document)?
No
Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge?
Yes
Did the MS4 inspector miss any obvious areas of concern? If so, explain:
No
Does the MS4 inspector's process include presenting the inspection findings to the facility contact?
Yes
Inspection Results
Several issues were observed and discussed.Among them,were aging fuel storage tanks,secondary containment,and SWPPP
evaluations.The extent of investigation during inspections was also discussed at length.Corrections shall be made to inspection
practices moving forward. I
NCS000406_Wilmington MS4 Audit_20230614 Page 19 of 21

Site Visit Evaluation: MS4 Outfall No. 1
Outfall ID Number: Date of Site Visit:
26852 June 15,2023
Outfall Location: Outfall Description(Pipe Material/Diameter,Culvert,etc.):
Stadium Drive and Lake Shore Drive 36" RCP
Receiving Water: Is Flow Present?If So,Describe(Color,Approximate Flow Rate,
Greenfield Lake Sheen,Odor,Floatables/Debris,etc.):
Yes.Clear
Most Recent Outfall Inspection/Screening(Date):
Not Evaluated
Days Since Last Rainfall: Inches:
Not evaluated N/A
Name of MS4 Inspector(s)evaluated:
Jim Quinn,Stormwater Specialist
Observations
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
No regular training documented.
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?
No.
Does the inspector's process include taking photos?
Yes.
Did the M54 inspector miss any obvious potential illicit discharge indicators or maintenance issues?If so,what were they?
No.
Inspection Results
Did the outfall inspection result in any work orders or maintenance requests?If so,for what issue(s)?
No.
Will a follow-up outfall inspection be conducted?If so,for what reason?
Yes.Routine.
Notes/Comments/Recommendations
The reporting and documentation system were discussed as they are used to document dry-weather screening.It is
recommended that this process be modified to include an inspection report which gets filled out during each inspection.Any
evaluation of dry-weather screening should also include observation of the condition of the infrastructure.Phase I permit
requirements will also include a rating system to rate the health of the stream.
NCS000406_Wilmington MS4 Audit_20230614 Page 20 of 21

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i
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Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1
Site Name: Date of Site Visit: I
Carriage Hills June 14,2023
Site Address: SCM Type:
3740 Habberline Street Wet pond
Most Recent MS4 Inspection(Include Date and Entity):
Not evaluated
Name of MS4lnspector(s)evaluated: Most Recent MS4 Enforcement Activity(Include Date):
Lauris Belle,SCM Supervisor None
Name(s)and Title(s)of Site Representative(s) Present During the Site Visit:
Name Title
None
Observations
Site Documentation
Does the site have an operation and maintenance plan?
Yes.Not evaluated during the inspection.
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?
Bi-annual SW 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.)?
Yes.
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form?What format?
Yes.But not always filled out during the inspection.
Does the MS4 inspector's process include taking photos?
Occasionally.
Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections?
When needed.
Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge?
Yes.
Did the M54 inspector miss any obvious operation and maintenance deficiencies?If so,explain:
Possibly.Issues were observed at the emergency spillway which may not have been recognized in prior inspections.
Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing?
Yes.
Compliance/Enforcement
To be determined by municipal staff.
NC5000406_Wllmington MS4 Audit_20230614 Page 21 of 21