NCS000547_Audit Report_20210712

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NCS000547 Roxboro MS4 Audit 20210712

TABLE OF CONTENTS
AuditDetails .... --- ...... ...... ...... ---- .......... ....... -- ......... ......... — ... --, 1
PermitteeInformation......... ............... ..................... .................. ................................................................ 2
List of Supporting Documents ...... .... ............ ................................ 3
Program Implementation, 00Cumentation & Assessment..........................,......,.....,.............................-.. 4
Public Education and Outreach ................... ................................................. .................. -- .... ................ 8
Illicit Discharge Dctect ion and E firni naWn f I DOE) .............. .......... ............... ............ --.- ..................... 1
Pollution Prevention and Good Housekeeping for Municipal Operations........................... ...................... 14
Site Visit Evaluation. Municipal Facility No. I . ............... ...... - ..... — ............ ............ ............... -1111, ... 1117
Site Visit Evaluation. MS4 Outfall No. I ........... ...... ...... , - - - - —.1 - - I - r - - - I ...... ...... --- 19
Site Visit Evaluation., Post -Construction Stormwater Control Measure No. 1 ...... ....... - .................... 21
Appendix A: Supporting Documents
Appendix B: Photograph tog
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.
NCS000547-Roxboro MS4 Audit20210712 U

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NCS000S47 Roxboro MS4 Audit 20210712 iii

Audit Details
Audit ID Number:
Audit Date{sj:
NCS000547_Roxboro MS4 Audit_20210712
May 21, 2021
Minimum Control Measures Evaluated:
® Program Implementation, Documentation & Assessment
® Public Education & Outreach
❑ Public Involvement & Participation
® Illicit Discharge Detection & Elimination
❑ Construction Site Runoff Controls — No delegated Sediment and Erosion Control Program
❑ Construction Site Runoff Controls — Delegated Sediment and Erosion Control Program
❑ Post -Construction Site Runoff Controls
® Pollution Prevention and Good Housekeeping for Municipal Operations
❑ Total Maximum Daily Loads (TMDLs)
Field Site Visits:
® Municipal Facilities. Number visited: 1
® MS4 Outfalls. Number visited: 1
❑ Construction Sites. Number visited: Choose an item.
® Post -Construction Stormwater Runoff Controls. Number visited: 1
C] Other: Number visited: Choose an item.
❑ Other: Number visited: Choose an item.
Inspector(s) Conducting Audit
Name. Title
Organization
Thad Valentine
DEMLR Land Quality Section
Lauren Garcia
DEMLR Land Quality Section
Audit Report Author: � (�4
_ ! �'CE_ ��[ `�
Date -:/Signature 1AZI -oil
Audit Report Author:
Date
Signature
-7/
NCS000547—Roxboro MS4 Audit 20210712 Page 1 of 24

Permittee Information
MS4 Permittee Name: City of Roxboro
Permit Effective Date:
January 23, 2018
Permit Expiration Date:
January 31, 2023
Mailing Address: PO Box 128 Roxboro, NC 27573
Date of Last MS4 Inspection/Audit:
N/A
Co-permittee(s), if applicable: N/A
Permit Owner of Record: Thomas Warren Jr., Assistant City Manager
Primary MS4 Representatives Participating in Audit
Name, Title
Organization
Josh Johnson, Stormwater Engineer
City of Roxboro
Andy Oakley, Public Services Director
City of Roxboro
Phill Ross, Stormwater
Stormwater Program Coordinator, AWCK Inc.
MS4 Receiving Waters
Waterbody
Classification
Impairments
Marlow Creek
C
Benthos, Fish Tissue Mercury
Tanyard Branch
c:
Fish Tissue Mercury
Mitchel Creek
c:
Fish Tissue Mercury
Story's Creek
WS-II;HQW
Fish Tissue Mercury
North Flat River
WS III; NSW
Fish Tissue Mercury
NCS000547_Roxboro MS4 Audit_20210712
Page 2 of 24

List of Supporting Documents
Item
Number
Document Title
When Provided
(Prior to/During/After)
1
Stormwater Management Plan
Prior
2
Annual Report
Prior
3
Stormwater Ordinance
Prior
4
Stormwater Education Plan
After
5
CWEP Agreement
Prior
6
Falls Lake Program Narrative
Prior
7
Facilities O&M Plan
Prior
8
IDDE Program
Prior
9
Outfall Map
Prior
10
IDDE and PP&GH Training Powerpoint with Sign In
After
11
Spill Response SOP
After
12
SCM Maintenance Program
After
13
BMP Inventory
After
14
Pesticide Licenses
After
NCSOOOS47 Roxboro MS4 Audit 20210712
Page 3 of 24

Program Implementation, Documentation & Assessment
Staff Interviewed:
Josh Johnston, Stormwater Engineer
(Name, Title, Role)
Andy Oakley, Public Services Director
Phill Ross, Stormwater Program Coordinator
Permit Citation
Program Requirement
Status
Supporting
Doc No.
II.A.1
The permittee maintained adequate funding and staffing to implement and manage
Yes
1
Staffing and
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
coordination, implementation, and revision to the Plan.
Yes
1
Responsibilities for all components of the Stormwater Plan are documented and
position(s) assignments provided.
Yes
1
The permittee is current on payment of invoiced administering and compliance
Yes
BIMS
monitoring fees (see stormwater e-payments on DCMLR MS4 web page).
Comments (Briefly describe funding mechanism, number of staff, etc.)
Program started in 2012. The Program is funded by charging residential, commercial, and industrial sites a standard water meter
rate. The income generates enough extra funding that the city is able to fund extra projects, like repairing older storm sewer lines.
Street sweeping is also funded by these fees.
The fees are reviewed every five years to make sure the water meter rates are adequate for the City's needs.
Specific positions responsible for the overall coordination, implementation, and revision to the Plan is addressed on pages 9 and 12
of the Stormwater Plan. Responsibilities are included on page 12.
II.A.2 Stormwater
The permittee evaluated the performance and effectiveness of the program
Plan
components at least annually.
Yes
2
Implementation
and Evaluation
If yes, the permittee used the results of the evaluation to modify the program
Yes
2
components as necessary to accomplish the intent of the Stormwater Program.
Did the permitted MS4 discharges cause or contribute to non -attainment of an
applicable water quality standard?
No
---
If yes, did the permittee expand or better tailor its BMPs accordingly to address
Not
the non -attainment?
Applicable
Comments
The permittee submits a narrative format of the annual report. The annual report is prepared by the Stormwater Program
Coordinator with AWCK Inc.
NCS000547_Roxboro MS4 Audit_20210712 Page 4 of 24

Program Implementation, Documentation -& Assessment
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.
Not
Applicable
Comments (indicate the date of latest Stormwater Plan and describe the nature of any updates, if applicable).
The Stormwater Plan was last updated in 2019. No revisions have been necessary since 2019.
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
1
Plan
The online materials included ordinances, or other regulatory mechanisms, or a list
identifying the ordinances, or other regulatory mechanisms, providing the legal
Partial
3
authority necessary to implement and enforce the requirements of the permit.
Comments (!Vote what materials are available on line)
The annual report and Stormwater ordinance were available online. It was stated that the Stormwater Plan used to be available in
the same space, however a recent cyber-attack caused issues with the website and internal files, and it was believed the
Stormwater Plan never made it back online. Page 7 of the Ordinance addressed the City's authority.
The city should make the SWMP available online.
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 has not required any changes.
II.A.6 Sharing
Responsibility
Are any control measures implemented by an entity other than the permittee?
Yes
5
If yes, is there a written agreement in place?
Yes
5
Comments (List the specific control measures implemented by others that do not have adequate written agreements, if
applicable)
DEMLR is responsible for erosion control and construction stormwater in Roxboro. The city has an Agreement with the Clean Water
Education Partnership to assist with education and outreach.
II.A.7
The permittee maintained written procedures for implementing the six minimum
4, 5,
Written
control measures.
Yes
6,7,8, 12
Procedures
Written procedures identified specific action steps, schedules, resources and
responsibilities for implementing the six minimum measures.
Yes
---
Comments (list the specific minimum measures that do not have adequate written procedures, if applicable)
The Stormwater Education Plan, CWEP Agreement, Falls Lake Program !Narrative, IDDE Program, Facilities O&M Plan, and BMP
Operation and Maintenance Program were shown during the audit.
NCS000547_Roxboro MS4 Audit_20210712 Page 5 of 24

Program Implementation, Documentation & Assessment
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)
Covid affected the number of inspections the city was able to complete. An example of an IDDE inspection was shown during the
audit. All SCMs in the City of Roxboro are privately owned, but the city still performs inspections to make sure the SCMs are
maintained.
III.B
The permittee submitted annual reports to the Department within twelve months
Annual Report
from the effective date of the permit (See Section 111.6. for the annual reporting
Yes
2
Submittal
period specific to this M54).
The permittee submitted subsequent annual reports every twelve months from the
scheduled date of the first annual report submittal.
vt,
1
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
of each major component of the Stormwater Plan for the past year and
YPS
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
raw
the proposed changes and how these changes will impact the Stormwater
Applicable
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
Not
Applicable
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
2
Stormwater Plan.
5. An assessment of compliance with the permit, information on the
establishment of appropriate legal authorities, inspections, and enforcement
+
2
actions.
Comments (Note dates that annual reports cover undercurrent permit and generally describe report deficiencies, if any)
The permittee submits a narrative format of the annual report. The annual report is prepared by the Stormwater Program
Coordinator with AWCK Inc.
No changes have been made to the Plan.
IV.B
Annual Reporting
The Annual Reports document the following:
1. A summary of past year activities, including where applicable, specific
Y
2
quantities achieved and summaries of enforcement actions.
a'y
2. A description of the effectiveness of each program component.
2
NCS000547 Roxboro MS4 Audit 20210712
Page 6 of 24

Program Implementation, Documentation & Assessment
3. Planned activities and changes for the next reporting period, for each
program component or activity-
4. Fiscal analysis.
rs
Comments (Note dates that annual reports cover under current permit and generally describe report deficiencies, if any)
B,;..fc components are present in the narrative.
Additional
Comments:
NCS000547_Roxboro MS4 Audit_20210712
Page 7 of 24

Public Education and Outreach
Staff Interviewed:
Josh Johnston, Stormwater Engineer
(Name, Title, Role)
Andy Oakley, Public Services Director
Phill Ross, Stormwater Program Coordinator
Permit Citation
Program Requirement Status Supporting
Doc No.
11.6.2.a
The permittee defined goals and objectives of the Local Public Education and
Goals and
Yes
Outreach Program based on community wide issues.
Objectives
Comments (Generally describe process for establishing goals/objectives)
The city provided a City of Roxboro Stormwater Education Plan.
II.B.2.b
The permittee maintained a description of the target pollutants and/or stressors and
Target Pollutants
likely sources.
Yes
Comments (List target pollutants, note any that are missing or not appropriate)
Target pollutants are included in Part 7.1.3 of the SWMP. Target audiences are addressed in Part 7.1.2 of the Stormwater Plan. The
Clean Water Education Partnership targets residents and businesses like restaurants. Target sources include suspended solids,
floatable trash and debris are among the problem's sources.
The city should try to identify specific origins pollutant sources and include them in the SWMP.
II.B.2.c
The permittee identified, assessed annually and updated the description of the target
Target Audiences
audiences likely to have significant storm water impacts and why they were selected.
Yes
1
Comments (Describe any changes made, if applicable)
Addressed in Part 7.1.2 of the SWMP. The SWMP is updated regularly. The Clean Water Education Partnership addresses why the
target audiences were selected on their website: https:Hnc-cleanwater.com/stormwater-pollution/why-is-stormwater-a-problem/.
NCS000547_Roxboro M54 Audit_20210712 Page 8 of 24

Public Education and Outreach
II.B.2.d Residential
The permittee described issues, such as pollutants, the likely sources of those
and Industrial/
pollutants, potential impacts, and the physical attributes of stormwater runoff in
Yes
4,5
Commercial Issues
their education/outreach program.
Comments (Generally describe the residential/industrial/commercial issues addressed)
Addressed by the Clean Water Education Partnership and the City of Roxboro Education and Outreach Plan.
11.6.2.e
Informational
The permittee promoted and maintained an internet web site designed to convey the
Yes
Online
Web Site
program's message.
Comments (list web page address and general contents, or attach screen shot of landing page)
The City of Roxboro Stormwater Administration Webpage links directly to the Clean Water Education Partnership webpage:
https://www.cityofroxboro.com/government/pu blic-services/engineering-services/stormwater-ad ministration.
11.6.2.E
The permittee distributed stormwater educational material to appropriate target
Public Education
Yes
Online
Materials
groups.
Comments (List distributed materials and quantity, message, distribution mechanism, target audience for each if not included in
program documentation/annual reporting)
Clean Water Education Partnership provides printable materials to distribute to the public. The city distributes the brochures
available on the CWEP Printable Materials Webpage: https://nc-cleanwater.com/outreach/physical-resources/.
II.8.2.e
The permittee promoted and maintained a stormwater hotline/helpline for the
Hotline/Help Line
purpose of public education and outreach.
Yes
Online
Comments (Note hotline contact information and method(s) for advertising it)
The hotline is available on the Stormwater Administration Webpage https://www.cityofroxboro.com/government/public-
services/engineeri ng-services/stormwater- administration.
NCS000547_Roxboro MS4 Audit_20210712 Page 9 of 24

Public Education and Outreach
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
4,5
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
Partial
4,5
of exposure.
Comments (Generally describe approaches, extent of exposure. Note any cooperating entities, agreements and scope of services,
or reference comments in Section ll.A.6. above.)
The Clean Water Education Partnership handles many aspects of education and outreach. The city also developed a Stormwater
Education Plan as a supplement that addressed target audiences.
The BMP summery table could be expanded to better quantify the numbers associated with attendance for storrnwater activities.
Additional
Comments:
NCS000547 Roxboro MS4 Audit 20210712
Page 10 of 24

Illicit Discharge Detection and Elimination (IDDE)
Staff Interviewed:
Josh Johnston, Stormwater Engineer
(Name, Title,
Andy Oakley, Public Services Director
Role)
Phill Ross, Stormwater Program Coordinator
Permit Citation
Program Requirement Status Supporting
Doc No.
I I. D.2. a
IDDE Program
The permittee maintained a written IDDE Program. V., R
If yes, the written program includes provisions for program assessment and
evaluation and integrating program.
Comments (Note any deficiencies)
The written assessment and evaluation are included on Page 9 of the IDDE Program.
The permittee maintained an IDDE ordinance or other regulatory mechanism(s) that
II.D.2.b
provides the legal authority to prohibit illicit connections and discharges to the MS4.
Y+s
,
Legal Authorities
If yes, the ordinance applies throughout the corporate limits of the permittee.
[Permit Part 1.D]
Ycs
-
Comments
NC Jordan Watershed New Development Model Ordinance Section 7 (53-701). Jurisdiction is addressed under Section 53 105. 53
702 addresses authority and the right to inspect.
II.D.2.c
The permittee maintained a current map showing major outfalls* and receiving
Storm Sewer
Yes
9
System Map
streams.
Comments
The map includes all storm sewer piping. The map is interactive, and the outfall is identified by clicking on the piping. The receiving
waterbody and the outfall size are also provided.
*Nlojor 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 > 2 acres.
II.D.2.d
Dry Weather Flow
The permittee maintained a program for conducting dry weather flow field
Yes
S
observations in accordance with written procedures.
Program
Comments (Generally summarize program, including frequency of observations and N or % of outfalls screened)
Dry weather flow inspections are addressed on pages 4-7 of the IDDE Program. They are called "stream walks." The city may want
to rename the dry weather flow inspection program so it is clear this permit requirement has been met.
NCS000547_Roxboro MS4 Audit_20210712 Page 11 of 24

Illicit Discharge Detection and Elimination (IDDE)
II.D.2.e
The permittee maintained written procedures for conducting investigations of
Investigation
identified illicit discharges.
Yes
8
Procedures
Comments (Generally describe what procedures are documented)
Included on pages 4-5 of the IDDE Program.
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
Not
Investigations
1. The dates) the illicit discharge was observed
e
ApplicablNot
8
2. The results of the investigation
Applicable
8
3. Any follow-up of the investigation
Not
1
Applicable
$
4. The date the investigation was closed
Not
Applicable
8
Comments (Note whether a standard inspection form is utilized to capture consistent information and a tracking mechanism is
used)
It was stated the city is so small with so little industry that there are no illicit discharges. A spreadsheet to track illicit discharges
exists but has never needed to be used. The tracking system is addressed on Page 8 of the IDDE Program.
II.0.2.tt 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
10
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)
Annual training is handled by the consultant. The training consists of a combined power point that covers IDDE and PP&GH. All city
employees are given the training, including fire and EMS.
II.D.2.h
The permittee informed public employees of hazards associated with illegal
Yes
10
Public Education
discharges and improper disposal of waste.
The permittee informed businesses of hazards associated with illegal discharges and
5
improper disposal of waste.
Yes
The permittee informed the general public of hazards associated with illegal
Yes
5
discharges and improper disposal of waste.
Comments (Note how each sector was informed, if applicable)
Public employees receive the standard IDDE and PP&GH training. Businesses and the public are informed by the Clean Water
Education Partnership with printable materials.
NCS000547_Roxboro MS4 Audit_20210712 Page 12 of 24

Illicit Discharge Detection and Elimination (IDDE)
II.13.2.i
The permittee promoted, publicized, and facilitated a reporting mechanism for the
Public Reporting
public to report illicit discharges.
Yes
Online
Mechanism
The permittee promoted, publicized, and facilitated a reporting mechanism for staff
Online,
to report illicit discharges.
Yes
10
The permittee established and implemented response procedures for citizen
requests/reports.
Yes
$
Comments (Generally describe reporting mechanisms and how promoted/publicized/facilitated/established)
A hotline for complaints is available on the Stormwater Program Administration Webpage. Staff are informed of the hotline during
the IDDE and PP&GH training. Response procedures for citizen reports are addressed on Page 8 of the IDDE Program.
II.D.2.1
The permittee implemented a mechanism to track the issuance of notices of violation
Enforcement
and enforcement actions administered by the permittee.
Yes
2
If yes, the mechanism includes the ability to identify chronic violators for
initiation of actions to reduce noncompliance.
Yes
2
Comments (Generally describe the established tracking mechanism, if applicable)
A notice of violation has never bene issued by the city. A spreadsheet exists to track illicit discharges and chronic violators, but it has
never needed to be used. This is addressed on Page 8 of the annual report.
Additional
Comments.
NCS000547_Roxboro MS4 Audit_20210712 Page 13 of 24

Pollution Prevention and Good Housekeeping for Municipal Operations
Staff Interviewed:
Josh Johnston, Stormwater Engineer
(Name, Title, Role)
Andy Oakley, Public Services Director
Phill Ross, Stormwater Program Coordinator
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)
Provided on Page 2 of the facilities 0&M Plan
II.G.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
7
If yes, the O&M program specifies the frequency of routine maintenance
requirements.
No
---
If yes, the permittee evaluated the O&M program annually and updated it as
Yes
7
necessary.
Comments
The O&M Plan states facilities are inspected annually on Page 8 of the O&M Plan. The O&M Plan does not specifically include a
schedule for maintenance. Maintenance is performed as needed. The O&M Plan is updated as needed and is evaluated annually.
The city should include some site specific maintenance requirements and more specific best management practices are
recommended.
II.G.2.c
Spill Response
The permittee had written spill response procedures for municipal operations.
Yes
11
Procedures
Comments
Every city owned facility has spill response procedures posted onsite.
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
Not
Applicable
corporate limits annually.
NCSOOOS47_Roxboro MS4 Audit_20210712
Page 14 of 24

Pollution Prevention and Good Housekeeping for Municipal Operations
Parking Lots
If yes, the permittee evaluated the effectiveness of existing and new BMPs
Not
Maintenance
based on cost and the estimated quantity of pollutants removed.
Applicable
Comments
There are no City owned SCMs. The facility does perform street sweeping and trash removal. Leaf collection and street sweeoinp
debris are taken to licensed yard waste facilities where the tonnage is tracked. Addressed on Page II of the annual report.
II.13.2.1F
The permittee maintained and implemented an O&M program for the stormwater
O&M for Catch
Basins and
sewer system including catch basins and conveyance systems that it owns and
Partial
---
maintains.
Conveyance Systems
Comments (Briefly describe O&M program)
A dedicated O&M program for catch basins and the storm sewer systems was not available. Catch basin maintenance is not on a set
schedule but are performed as needed. Page 11 of the annual report includes a summary of catch basin maintenance. Culverts and
storm drains are cleaned by a jet truck or by hand as needed.
The city should develop a dedicated O&M Program for the stormwater sewer system.
II. G.2.¢
The permittee maintained a current inventory of municipally owned or operated
Structural
structural stormwater controls installed for compliance with the permittee's post-
gppi cable
12,13
Stormwater Controls
construction ordinance.
Comments (Describe inventory information and number of controls in inventory)
There are no city owned SCMs. However, the city maintains an inventory of private SCMs in Roxboro and has developed a BMP
Operation and Maintenance Program. The city holds privately owned SCMs to the standards outlined in the Program. The city also
performs inspections.
II.G.2.h
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
gppi �t
12
Stormwater Controls
the permittee's post -construction ordinance. If yes, then:
The O&M program specified the frequency of inspections and routine
Not
maintenance requirements.
applicable
12
The permittee documented inspections of all municipally -owned or maintained
Not
structural stormwater controls.
Applicable
12
The permittee inspected all municipally -owned or maintained structural
Not
stormwater controls in accordance with the schedule developed by permittee.
Applicable
12
The permittee maintained all municipally -owned or maintained structural
Not
Stormwater controls in accordance with the schedule developed by permittee.
Applicable
12
The permittee documented maintenance of all municipally -owned or
Not
maintained structural stormwater controls.
Applicable
12
Comments
There are no city owned SCMs. The city requires annual inspections to be submitted for privately owned SCMs. The City requires
standards for maintenance and requires and operation and maintenance agreement.
NCS000547—Roxboro MS4 Audit_20210712 Page 15 of 24

Pollution Prevention and Good Housekeeping for Municipal Operations
II.G.2.i
The permittee ensured municipal employees are properly trained in pesticide,
Pesticide, Herbicide
herbicide and fertilizer application management.
Yes
S"
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
applicators are followed.
Yes
1 :
Comments
The city offers pesticide certification as a pay incentive. There are no ontractors. All pesticides are handled by city employees.
Il.G.2.j
The permittee implemented an employee training program for employees involved
Staff Training
in implementing pollution prevention and good housekeeping practices.
Yes
Comments
Employees received the combined IDDE and PP&GH Trainino.
Ii.G.2.1k
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
7
Equipment Cleaning
cleaning.
Comments
There is a wash station located at the Public Service Facility. Wash water goes to the Sanitary Sewer. This is addressed on Page 5 of
the Facilities O&M Plan.
Additional
Comments:
NCS000547_Roxboro MS4 Audit 20210712
Page 16 of 24

Site Visit Evaluation: Municipal Facility No. 1
Facility Name:
Public Service Facility
Date and Time of Site Visit:
5/21/21
Facility Address:
779 Mountain Road
Facility Type (Vehicle Maintenance, Landscaping, etc.):
Public Service
Name of MS4 inspector(s) evaluated:
Phill Ross
Most Recent MS4 Inspection (List date and name of inspector):
5/11/2021
Names) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name
Title
Observations
Facility Documentation/TrainIng
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific?
City of Roxboro O&M Phan
What type of stormwater training do facility employees receive? How often?
PP&GH and IDDE city employee training. Provided annually.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
The inspector receives on the job training, NC State Training.
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
Yes
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Yes
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form?
Yes, a Public Facilities Stormwater Inspection Form
Does the M54 inspector's process include taking photos?
Yes, during inspections.
Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)?
City of Roxboro O&M Plan.
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Site Visit Evaluation: Municipal Facility No. 1
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:
Yes
Does the MS4 inspector's process include presenting the inspection findings to the facility contact?
Yes, if an issue is identified.
Inspection Results
Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)?
There were several spills, one larger than the others, identified throughout the facility. A pile of car batteries was stored outside.
not under cover. Some chemical containers were open or uncapped. Some empty containers were filled with water.
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
immediately. The large spill was being addressed during the site visit.
Notes/Comments/Recommendations
Recommend a site specific SWPPP or an NCG08 general Industrial Permit.
NC5000547__Roxboro MS4 Audit 20210712
Page 18 of 24

Site Visit Evaluation: MS4 Outfall No. 1
Outfall ID Number:
Date and Time of Site Visit:
Old Mill town Outfall
5/21/21
Outfall Location:
Outfall Description (Pipe Material/Diameter, Culvert, etc.):
Old Mill Town Neighborhood
S4" corrugated plastic
Intersection of Forest Street and Tanyard Branch.
Receiving Water:
Is Flow Present? If so, Describe (Color, Approximate Flow Rate,
Marlow Creek
Sheen, Odor, Floatables/Debris, etc.):
Trickle flow, no floatable or odor
Most Recent Outfall Inspection/Screening (Date):
S/11/2021
Days Since Last Rainfall:
Inches:
5/14/20?1
1/10inch
Name of MS4 Inspector(s) evaluated:
Observations
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
NC State SCM 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?
No, usually inspectors take a map of the outfall and take notes on the page.
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
NCS000547_Roxboro MS4 Audit_20210712 Page 19 of 24

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 issues)?
No, recently repaired
Will a follow-up outfall inspection be conducted? If so, for what reason?
No
Notes/Comments/Recommendations
NCS000547_Roxboro MS4 Audit 20210712
Page 20 of 24

Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1
Site Name: StrirAand Jones Memorial
Date and Time of Site Visit:
5/21/21
Site Address: Hwy 301 and Strickland Rd
SCM Type:
Dry detention pond
Most Recent MS4 Inspection (Include Date and Entity):
July 2019
Name of MS4 Inspector(s) evaluated:
SCMs are maintained privately, but private owners submit the
SCM 0&M Plans to the city for approval. Yearly inspection
reports are required by the city.
Most Recent MS4 Enforcement Activity (Include Date):
None
Name(s) and Title(s) of Site Representative(s) Present During the Site Visit:
Name
Title
Observations
Site Documentation
Does the site have an operation and maintenance plan?
Private owners create and maintain an SCM O&M Plan. The O&M Plan is required by the city.
Does the site have records of annual inspections? Are they performed by a qualified individual?
Yes, privately handled by the SCM owner.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
The contractors maintaining the SCMs are SCM certified. Inspectors also receive the NC State 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, 0&M
requirements, etc.)?
Yes
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form? What format?
Inspection report and SCM checklist
Does the MS4 inspector's process include taking photos?
Yes
NCS000547_Roxboro MS4 Audit_20210712 Page 21 of 24

Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1
Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections?
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 operation and maintenance deficiencies? If so, explain:
N❑
Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing?
If there are issues
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
NC5000547_Roxboro MS4 Audit. 20210712
Page 22 of 24

APPENDIX A: SUPPORTING DOCUMENTS
NCS000547_Roxboro MS4 Audit_20210712 Page 23 of 24

APPENDIX B: PHOTOGRAPH LOG
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