NCS000545_Audit Report_20220826

ROY COOPER
Governor
ELIZABETH S. BISER
i(N I N 7f l
BRIAN WRENN
Director
N+� vll
c.
Mtna�
NG R 1 H C ARC). I xJ s
Environmental Quality
August 19, 2022
CERTIFIED MAIL 7017 2680 0000 2237 0214
RETURN RECEIPT REQUESTED
City of Creedmoor
Attn: Robert Wheeler, Mayor
CIO Michael Frangos, Community Development Planner
PO Box 765
Creedmoor, NC 27522
Subject: NOTICE OF COMPLIANCE (NOC-2022-PC-0528)
City of Creedmoor
NPDES MS4 Permit No. NCS000545
Granville County
Dear Mr. Wheeler:
On May 28, 2022, staff from the North Carolina Department of Environmental Quality (DEQ) conducted
a compliance audit of subject National Pollutant Discharge Elimination System (NPDES) Municipal
Separate Storm Sewer System (MS4) Permit. The audit identified minor deficiencies with the specific
components of the MS4 permit that were reviewed, as provided in the attached DEQ MS4 Permit
Compliance Audit Report.
In accordance with Part VI of the permit and DEQ policy, a new 5-year MS4 permit will be issued in
response to the audit. As such, the permittee is required to complete the following actions:
(1) Respond in writing within thirty (30) calendar days from the date of receipt of this notice to
acknowledge these requirements and the intent to comply.
(2) 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 11 Audit Template on the DEQ stormwater web site can be used for
this purpose. The specific sections that should be self -audited include:
a. Section C, Public Involvement and Participation;
b. Section F: Post -Construction Site Runoff Controls;
c. Section H: Total Maximum Daily Loads.
(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.
D QNorth Carolina I)epartrtient of E;nvironn+cntal Qre.3lit) Div %lon of t.nergy M1Lneral and Land Resources
R;rlcilhRcyJiunal(J1tire Iln'�t341.ri1Service Center 3ftUOft.+rrrtit)rive Raleigh \ortlt(:,uolinal7r,{}q
i zu u�/

(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.Rced(6ncderH%gov, or to:
DEQ-DEMLR Stormwater Program
Attn: Isaiah Reed
1612 Mail Service Center
Raleigh, NC 27699-1612
Thank you for your attention to this matter. Should you have any questions, please contact Thad
Valentine at [phone] or thad.yalentineAncdenngov or the Interim MS4 Program Coordinator at
Isaiah, Reed ncdenr. gov.
Sincerely,
William H. Denton, IV, PE
Regional Engineer
DEMLR
Enclosures: DEQ MS4 Permit Compliance Audit Report
CC:
rwheeler c cit ofcreedmoor.or
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. NCS00054S
City of Creedmoor, NORTH CAROLINA
Po Box 765
Creedmoor, NC 27522
Audit Date: May 18, 2022
Report Date: August 15, 2022
North Carolina Department of Environmental Quality
Division of Energy, Mineral & Land Resources Stormwater Program
512 N. Salisbury Street, 9th floor
1612 Mail Service Center
Raleigh, NC 27699-1612

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NCS000545 Creedmoor MS4 Audit 20220815

TABLE OF CONTENTS
AuditDetails .................. ......................... ... ..... ..... .............................. . .. ............. -- .... ........., i
Permittee Information.. .. .. .. ................ ...-..............,.....,.................................. 2
Listof Supporting Documents.................................................................................... .......... ..... ......... 3
Program Implementation, Documentation & Assessment.......................................................................... 4
Pudic Participation and Involvement.........................................................-Error! Bookmark not de#lned.
Illicit Discharge Detection and Elimination (11)DE)................... ....... .................... ......................... .... .......10
Pollution Prevention and Good Housekeeping for Municipal Operations .. ...... ... ....... - .... ........ ........ ....... 14
Site Visit Evaluation: Municipal Facility Ada. 1... ....... -...... .......... .................................................. -........... 17
Site Visit Evaluation: M54 Outfall No. 1 ........ --- .............................. -- ............................. ..... .... _... 19
Site Visit Evaluation Post-Constrtuction Ste rmwater Control Mim sure No. 1........................................... 21
Appendix A. Supporting Documents
Appendix B: 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.
NCS000545 Creedmoor MS4 Audit 20220815 ii

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NCS000545 Creedmoor M54 Audit 20220815 IN

Audit Details
Audit ID Number:
Audit Dates):
NCS000545_Creedmoor MS4 Audit 20220815
May 28, 2022
Minimum Control Measures Evaluated:
® Program Implementation, Documentation & Assessment
® Public Education & Outreach
❑ Public Involvement & Participation
® Illicit Discharge Detection & Elimination
❑ Construction Site Runoff Controls - No delegated Sediment and Erosion Control Program
❑ Construction Site Runoff Controls - Delegated Sediment and Erosion Control Program
❑ Post Construction Site Runoff Controls
® Pollution Prevention and Good Housekeeping for Municipal Operations
❑ Total Maximum Daily Loads (TMDLs)
Field Site Visits:
® 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
❑ 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
Laurin Garcia
DEMLR - Land Quality Section
Audit Report Author:
Signature
Date:
Audit Report thor:
Date
Signature.
2 �Z
— j
NCS000545-Creedmoor MS4 Audit_20220815
Page 1 of 25

Permittee Information
MS4 Permittee Name:
City of Creedmoor
Permit Effective Date:
January 23, 2018
Permit Expiration Date:
January 31, 2023
Mailing Address: PO Box 765, Creedmoor, NC 27522
Date of Last MS4 Inspection/Audit:
February 11, 2015
Co-permittee(s), if applicable:
N/A
Permit Owner of Record:
Robert Wheeler, Mayor
Primary MS4 Representatives Participating in Audit
Name, Title
Organization
Michael Frangos, Asst. City Manager
City of Creedmoor
John Boyer, City Engineer
City of Creedmoor
Christina Conchilla, Consultant
Raftelis
Heidi Salminen, Planning Technician
City of Creedmoor
Gerald Smith, City Manager
City of Creedmoor
MS4 Receiving Waters
Waterbodv
Classification
Impairments
Holman Creek
WS-H;HQW,NSW,CA
Fish Tissue Mercury
Beaverdam Creek
WS-IV;NSW
Fish Tissue Mercury
Cedar Creek
WS-IV;NSW
Fish Tissue Mercury
Robertson Creek
WS IV;NSW
Fish Tissue Mercury
Ledge Creek
WS-IV;NSW
Fish Tissue Mercury
Whitaker Creek
WS IV;NSW
Fish Tissue Mercury
NCS000545_Creedmoor M54 Audit 20220815 Page 2 of 25

List of Supporting Documents
Item
Number
Document Title
When Provided
(Prior to/During/After)
1
SWMP
Prior
2
Organizational Chart
Prior
3
Job Description Example
Prior
4
Annual Report
Prior
5
CWEP Agreement
Prior
6
SCM Inspection Example
During
7
SCM O&M Agreement
During
8
Brochures
During
9
Outfall Map
Prior
10
IDDE iWorQ Screenshot
After
11
Training History Log
After
12
IDDE Quick Reference Field Guide
During
13
Public Works Facility SWPPP
During
14
Spill Response Procedures
During
15
Pesticide Certifications
After
16
Public Hearing Announcement
After
NCS000545_Creedmoor M54 Audit_20220815 Page 3 of 25

Program Implementation, Documentation & Assessment
Staff Interviewed:
Michael Frangos, Asst. City Manager
(Name, Title, Role)
John Boyer, City Engineer
Christina Conchilla, Consultant
Heidi Salminen, Planning Technician
Gerald Smith, City 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
coordination, implementation, and revision to the Plan.
Partial
1,2
Responsibilities for all components of the Stormwater Plan are documented and
position(s) assignments provided.
Yes
1, 2, 3
The permittee is current on payment of invoiced administering and compliance
monitoring fees (see stormwater e-payments on AEMLR MS4 web page).
Yes
Comments (Briefly describe funding mechanism, number of staff, etc.)
Program funding comes from an annual fee that property owners pay. Staff believe they are adequately funded.
The Stormwater Program has three dedicated positions.
Specific positions are identified in the SWMP. Each position has a detailed job description that I'sts specific responsibilities that was
provided prior to the audit.
Update specific positions regularly to show the current personnel for each position.
II.A.2 Stormwater
The permittee evaluated the performance and effectiveness of the program
Plan
components at least annually.
Yes
4
Implementation
and Evaluation
If yes, the permittee used the results of the evaluation to modify the program
components as necessary to accomplish the intent of the Stormwater Program.
Yes
4
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 effectiveness of the program is evaluated during the annual report submittal. Changes have been made to the program based
on the results of the annual report. For example, street sweeping was increased in the past year.
There is no industry in Creedmoor. The threat of an illicit discharge is low.
NCS000545_Creedmoor MS4 Audit_20220815 Page 4 of 25

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.
Yes
---
Comments (indicate the date of latest Stormwater Plan and describe the nature of any updates, if applicable).
The SWMP has been kept up to date. Creedmoor submitted the updated SWMP to Jeanette Powell, MS4 Program Coordinator, in
September 2021. The City of Creedmoor held a public meetirg while updating the SWMP.
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.
Yes
Online
Plan
The online materials included ordinances, or other regulatory mechanisms, or a list
identifying the ordinances, or other regulatory mechanisms, providing the legal
Yes
Online
authority necessary to implement and enforce the requirements of the permit.
Comments (Note what materials are available on line)
The Stormwater Plan is available under the "What You Can Do" tab on the City of Creedmoor webpage.
Article 19 of the Community Development Ordinance is available on the same website:
https://www.ci tyofcreed moo r.org/home/showpu bl isheddocu ment/6958/637605812440100000.
II.A.3 & II.A.5
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
5
If yes, is there a written agreement in place?
v-15
5
Comments (List the specific control measures implemented by others that do not have adequate written agreements, if
applicable)
The City of Creedmoor partners with CWEP to implement Public Education and Outreach. Creedmoor is also a part of the Upper
Neuse River Basin Association. DEMLR is responsible for sediment and erosion control.
II.A.7
The permittee maintained written procedures for implementing the six minimum
Written
control measures.
Yes
1
Procedures
Written procedures identified specific action steps, schedules, resources and
responsibilities for implementing the six minimum measures.
vE:s
1
NCS000545_Creedmoor MS4 Audit_20220815 Page 5 of 25

Program Implementation, Documentation & Assessment
Comments (List the specific minimum measures that do not have adequate written procedures, if applicable)
Written procedures are included in the SWMP.
Ill. A
The permittee maintained documentation of all program components including, but
Program
not limited to, inspections, maintenance activities, educational programs,
Yes
7
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)
SCM inspection examples were available during the audit, O&M Agreements were available. Documentation for complaints were
also viewed.
III;B
The permittee submitted annual reports to the Department within twelve months
Annual Report
from the effective date of the permit (See Section !ll.B. for the annual reporting
Yes
BIMS
Submittal
period specific to this MS4).
The permittee submitted subsequent annual reports every twelve months from the
scheduled date of the first annual report submittal.
Yes
RIMS
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
Yes
BIMS
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
the proposed changes and how these changes will impact the Stormwater
Yes
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
BIMS
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
BIMS
Stormwater Plan.
5. An assessment of compliance with the permit, information on the
establishment of appropriate legal authorities, inspections, and enforcement
Yes
BIMS
actions.
Comments (Note dates that annual reports cover under current permit and generally describe report deficiencies, if any)
The City of Creedmoor submits annual reports through BIMS.
IV.B
Annual Reporting
The Annual Reports document the following:
1. A summary of past year activities, including where applicable, specific
quantities achieved and summaries of enforcement actions.
Yes
BIMS
2. A description of the effectiveness of each program component.
Yes
BIMS
NCS000545_Creedmoor MS4 Audit_20220815 Page 6 of 25

Program Implementation, Documentation & Assessment
3. Planned activities and changes for the next reporting period, for each
Yes
BIMS
program component or activity.
4. Fiscal analysis.
Yes
BIMS
Comments (Note dates that annual reports cover under current permit and generally describe report deficiencies, if any)
The City of Creedmoor submits annual reports through BIMS.
Additional
Comments:
NCS000545 Creedmoor M54 Audit 20220815 Page 7 of 25

Public Involvement and Participation
Staff Interviewed:
Michael Frangos, Asst. City Manager
(Name, Title, Role)
John Boyer, City Engineer
Christina Conchilla, Consultant
Heidi Salminen, Planning Technician
Gerald Smith, City Manager
Permit Citation
Program Requirement Status Supporting
Doc No.
II.C.2.a Volunteer
Community
The permittee included and promoted volunteer opportunities designed to promote
Involvement
Yes 8
ongoing citizen participation.
Program
Comments (Generally describe process for establishing goals/objectives)
The City of Creedmoor holds Litter Sweep Events. The City posts on facebook to advertise events. Photos, brochures, and social
media posts were shown during the audit.
Falls Lake Academy has student requirements for volunteer opportunities. The City creates volunteer opportunities for the
students.
I I.C.2.b
Mechanism for
The permittee provided and promoted a mechanism for public involvement that
Online,
Public
provides for input on stormwater issues and the stormwater program.
Yes
16
Involvement
Comments (List target pollutants, note any that are missing or not appropriate)
The City maintains a complaint hotline: https://www.cityofcreedmoor.org/departments-and-services/community-
development/planning zoning/stormwater-program/obtaining-stormwater permits.
The City held a public hearing to solicit comments from the public when updat'ng the SWMP.
Many informational materials are available on the City stormwater Webpages. The City tracks how many people come to events.
CEWP does an annual report to show website traffic.
II.C.2.c
The permittee promoted and maintained a hotline/helpline for the purpose of public
Hotline/Help Line
involvement and participation.
y1,4
Online
Comments (Describe any changes made, if applicable)
The City maintains a complaint hotline: https://www.cityofcreedmoor.org/departments-and-services/community
development/planning-zoning/stormwater-program/obtaini nr-stormwater-permits.
NCS000545_Creedmoor MS4 Audit 20220815
Page 8 of 25

Public Involvement and Participation
Additional
Comments:
NCS000545_Creedmoor MS4 Audit_20220815
Page 9 of 25

Illicit Discharge Detection and Elimination (IDDE)
Staff Interviewed:
Michael Frangos, Asst. City Manager
(Name, Title,
John Boyer, City Engineer
Role)
Christina Conchilla, Consultant
Heidi Salminen, Planning Technician
Gerald Smith, City Manager
Permit Citation
Program Requirement Status Supporting
Doc No.
II.D.2.a
IDDE Program
The permittee maintained a written IDDE Program. Yes i
If yes, the written program includes provisions for program assessment and
Yes
evaluation and integrating program.
Comments (Note any deficiencies)
The written IDDE Program is included on pages 23 28 of the SWMP. Program Assessment for the IDDE Program is included on page
26, Section 6.3.6.
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.
Yes
Online
Legal Authorities
If yes, the ordinance applies throughout the corporate limits of the permittee.
[Permit Part 1.D)
Yes
Onlin
Comments
Illicit Discharges are addressed in Section 6 (19.15-3) of the Community Development Ordinance:
https://www. ci tyofcreedmoor.org/home/showpu blisheddocu ment/6958/637605812440100000.
Applicability of Jurisdiction is addressed in Section 1(19.5) of thr, Community Development Ordinance.
II.D.2.c
The permittee maintained a current map showing major outfalls* and receiving
Storm Sewer
Yes
9
System Map
streams.
Comments
The outfall map was provided prior to the audit. The City is aware of 21 major outfalls at this time. The map was completed in
January 2022.
*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 > 2 acres.
NCS000545 Creedmoor MS4 Audit 20220815
Page 10 of 25

Illicit Discharge Detection and Elimination (IDDE)
II.D.2.d
The permittee maintained a program for conducting dry weather flow field
Dry Weather Flow
observations in accordance with written procedures.
Partial
1
Program
Comments (Generally summarize program, including frequency of observations and # or % of outfalls screened)
A summary of dry weather flow field inspections are included in Section 6.3.3 of the SWMP. Public Works performs regular checks
of the outfalls. A dedicated Dry Weather Screening Inspection Form has not yet been developed. Outfalls associated with SCMs are
inspected when SCMs are inspected.
The City should develop more specific written procedures that cover conducting investigations of identified
discharges. It is recommended a dedicated form for outfall screening be developed.
II. D.2.e
The permittee maintained written procedures for conducting investigations of
Investigation
identified illicit discharges.
Partial
1
Procedures
Comments (Generally describe what procedures are documented)
A summary of how the city will continue to implement the IDDE Program is included in the SWMP.
The City should develop more specific written procedures for conducting investigations of illicit discharges.
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
Yes
10
2. The results of the investigation
Yes
10
3. Any follow-up of the investigation
Yes
10
4. The date the investigation was closed
Yes
10
Comments (Note whether a standard inspection form is utilized to capture consistent information and a tracking mechanism is
used)
IDDE Investigations are recorded in iWorQ. Each IDDE case shows the location, the date, and a summary that details the
investigation. It was suggested that a results column be added for clarity.
The City should include a results column in the tracking spread sheet that outlines how each illicit discharge incident
was resolved. It should include disposal details (who, when and how) where applicable).
II.D.2,e 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
1, 11
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)
A Training History Log was shown at the audit. Each employee gets regular stormwater training. IDDE employee training is also
summarized in the SWMP on page 26.
II.D.2.h
The permittee informed public employees of hazards associated with illegal
Public Education
discharges and improper disposal of waste.
Yes
$
NCS000545_Creedmoor MS4 Audit_20220815 Page 11 of 25

Illicit Discharge Detection and Elimination (IDDE)
The permittee informed businesses of hazards associated with illegal discharges and
improper disposal of waste.
Yes
$
The permittee informed the general public of hazards associated with illegal
discharges and improper disposal of waste.
Yes
$
Comments (Note how each sector was informed, if applicable)
Brochures are provided to employees and businesses. The City distributes information to the public at events and in the front lobby
of their office. There are educational posts on facebook. The City partners with CWEP. The City also distributes a quarterly
newsletter. An IDDE Quick Reference Field Guide is distributed to employees.
II.0.2A
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
to report illicit discharges.
Yes
12
The permittee established and implemented response procedures for citizen
requests/reports.
Partial
10
Comments (Generally describe reporting mechanisms and how promoted/publicized/facilitated/established)
A stormwater hotline is available on the City's webpage.
Staff report any illicit discharge complaints directly to Heidi Salminen, Planning Technician. All City staff are provided an IDDE Quick
Reference Field Guide that includes directions on how to respond and who to contact.
The SWMP states that the city has developed a tracker to track complaints and outcomes. Specific response procedures to citizen
complaints were not included. However, complaints and IDDE incidents are recorded in iWorQs and are addressed by staff.
It is recommended the city develop procedures for citizen requests/reports.
II.D.2.i
The permittee implemented a mechanism to track the issuance of notices of violation
Enforcement
and enforcement actions administered by the permittee.
Yes
10
If yes, the mechanism includes the ability to identify chronic violators for
Not
initiation of actions to reduce noncompliance.
Applicable
Comments (Generally describe the established tracking mechanism, if applicable)
IDDE incidents are recoded and tracked in iWorQs. Repeat violators could be identified by searching for the responsible party of the
discharge. The city has not yet had a repeat violator.
NC5000545_Creedmoor MS4 Audit_20220515
Page 12 of 25

Illicit Discharge Detection and Elimination (IDDE)
Additional
Comments:
NCS000545 Creedmoor MS4 Audit 20220815 Page 13 of 25

Pollution Prevention and Good Housekeeping for Municipal Operations
Staff Interviewed:
Michael Frangos, Asst. City Manager
(Name, Title, Role)
John Boyer, City Engineer
Christina Conchilla, Consultant
Heidi Salminen, Planning Technician
Gerald Smith, City Manager
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
13
stormwater runoff.
Comments (Note number of facilities, typical inventory data and any facilities that ore not inventoried that should be)
The city has one facility with the potential for generating polluted stormwater runoff, the Public Works Facility. Public Works
maintains a SWPPP for the facility. Vehicle washing is done at a third -party business. Vehicle maintenance is also done at a third -
party business.
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
13
Maintenance (O&M)
stormwater runoff.
for Facilities
If yes, the O&M program specifies the frequency of inspections.
Yes
13
If yes, the O&M program specifies the frequency of routine maintenance
requirements.
Yes
13
If yes, the permittee evaluated the O&M program annually and updated it as
necessary.
Yes
13
Comments
Public Works has been responsible for maintaining and implementing the SWPPP. inspections are done by public works staff
weekly. Maintenance is done as needed. The SWPPP is updated as necessary.
MS4 inspectors have not yet developed an inspection form for MS4 inspections.
I I.G.2.c
Spill Response
The permittee had written spill response procedures for municipal operations.
Yes
14
Procedures
Comments
The city has spill response procedures for the Public Works Facility.
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
---
corporate limits annually.
NCS000545_Creedmoor MS4 Audit_20220815 Page 14 of 25

Pollution Prevention and Good Housekeeping for Municipal Operations
Parking Lots
If yes, the permittee evaluated the effectiveness of existing and new I3MPs
Maintenance
based on cost and the estimated quantity of pollutants removed.
Yes
---
Comments
The City contracts with American Road Conservation to handle street sweeping. The trucks go to multiple contracts before heading
to the dump, so it is not possible to measure the tonnage of materials from just Creedmoor. The trucks only handle curb and gutter.
The city can only track by curb mile when evaluating the effectiveness of the BMPs.
The language in the Streep Sweeping Operations section of the SWMP (pg 38) does state the City will evaluate the effectiveness
based on both mileage and tonnage. This may need to be updated.
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
i
Basins and
maintains.
Conveyance Systems
Comments (Briefly describe O&M program)
Catch basins and stormwater sewer systems are addressed in Section 6.6.4 of the SWMP. They are cleaned manually with jet trucks
and repaired as needed. They have greatly improved the program through public education ny making the public aware of the
negative effects of yard waste in the storm system.
II.G.2.it
The permittee maintained a current inventory of municipally -owned or operated
Structural
structural stormwater controls installed for compliance with the permittee's post-
Yes
1,6,7
Stormwater Controls
construction ordinance.
Comments (Describe inventory information and number of controls in inventory)
The City only has one SCM that is municipally owned, located at the community center.
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
Yes
7
Stormwater Controls
the permittee's post -construction ordinance. If yes, then:
The O&M program specified the frequency of inspections and routine
maintenance requirements.
Yes
7
The permittee documented inspections of all municipally -owned or maintained
structural stormwater controls.
Yes
7
The permittee inspected all municipally -owned or maintained structural
stormwater controls in accordance with the schedule developed by permittee.
Yes
6,7
The permittee maintained all municipally -owned or maintained structural
stormwater controls in accordance with the schedule developed by permittee.
Yes
7
The permittee documented maintenance of all municipally -owned or
maintained structural stormwater controls.
Yes
7
Comments
The SWMP states the SCM is inspected several times per year and maintenanced on an as needed basis. The City indicated that the
SCM is inspected quarterly. The O&M Agreement and inspection reports are maintained in a binder for easy access. Inspection
reports were available in the binder. Maintenance occurs as needed. Public Works Department work orders were showed during
the audit.
NCS000545_Creedmoor MS4 Audit 20220815 Page 15 of 25

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
15
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
7,13
Comments
All pesticide and herbicide
applications are performed by Public Works employees. Pesticide licenses were provided following the
audit.
II.G.2.j
The permittee implemented an employee training program for employees involved
Staff Training
in implementing
p g pollution prevention and good housekeeping practices.
Yes
1, 11
Comments
Employee training for PP&GH is summarized on page 39 of the SWMP. A Training History Log was shown at 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
---
Equipment Cleaning
cleaning.
Comments
There is no wash bay at the Public Works facility. Vehicle washing is contracted with Auto Bright Self- Service facility. The City
maintains a monthly record of all washes.
Additional
Comments:
NCS000545_Creedmoor MS4 Audit_20220815 Page 16 of 25

Site Visit Evaluation: Municipal Facility No.1
Facility Name:
Date and Time of Site Visit:
Public Works Facility
05/18/2022
Facility Address:
Facility Type (Vehicle Maintenance, Landscaping, etc.):
404 Gray Street
Public Works and storage
Name of MS4 inspector(s) evaluated:
Most Recent MS4 Inspection (List date and name of inspector):
Steve Edwards, Public Works
Weekly
Heidi Salminen, Planning Technician
John Boyer, City Engineer
Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name
Title
Steve Edwards
Public Works
Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific?
Yes
What type of stormwater training do facility employees receive? How often?
Town training, pesticide license
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
NC State Training, APWA videos, on the job training
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
Yes, the facility was very clean. All chemicals stored properly
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Yes, the facility was very clean. All chemicals stored properly
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form?
No, done visually. A site specific inspection checklist should be developed
Does the MS4 inspector's process include taking photos?
As needed
Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)?
As needed
NCS000545_Creedmoor MS4 Audit_20220815 Page 17 of 25

Site Visit Evaluation: Municipal Facility No. 1
Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge?
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?
The facility contact conducted the inspection. An MS4 inspector will need to do an annual facility inspection and use an inspection
form for records.
Inspection Results
Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)?
No
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
N/A
Notes/Comments/Recommendation s
An M54 inspector will need to do an annual facility inspection and use an inspection form for records.
NCS000545—Creedmoor MS4 Audit_20220815
Page 18 of 25

Site Visit Evaluation: MS4 Outfall No. 1
Outfall ID Number:
Date and Time of Site Visit:
Community Center Outfall
5/18/2022
Outfall Location:
Outfall Description (Pipe Material/Diameter, Culvert, etc.):
NC 56/Whilton Ave
48" concrete
Receiving Water:
Is Flow Present? If So, Describe (Color, Approximate Flow Rate,
Whitaker Branch
Sheen, Odor, Floatables/Debris, etc.):
Outfall was flowing into a creek
Most Recent Outfall Inspection/Screening (Date):
Outfall inspections are not done on a schedule yet
Days Since Last Rainfall:
Inches:
7
0.2 Inch
Name of MS4 Inspector(s) evaluated:
Gerald Siebert, Code Enforcement
Observations
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
NC State, Town Training
Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations?
Yes, but focused on structural integrity. A Dry Weather Screening Inspection Form should be developed as the inspection program
is developed.
Inspection Procedures
Does the inspector's process include the use of a checklist or other standardized form?
Not currently
Does the inspector's process include taking photos?
As needed
Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they?
No
NCS000545_Creedmoor MS4 Audit_20220815 Page 19 of 25

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?
v!n
Notes/Comments/Recommendations
NCS000545_Creedmoor MS4 Audit_20220815 Page 20 of 25

Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1
Site Name:
Community Center SCM
Date and Time of Site Visit:
5/18/2022
Site Address:
108 E Wilton Ave
SCM Type:
Dry retention pond
Most Recent MS4 Inspection (Include Date and Entity):
5/1/2022
Name of MS4 Inspector(s) evaluated:
Gerald Siebert, Code Enforcement
Most Recent MS4 Enforcement Activity (Include Date):
N/A
Name(s) and Title(s) of Site Representative(s) Present During the Site Visit:
Name
Title
Gerald Siebert
Code Enforcement
Observations
Site Documentation
Does the site have an operation and maintenance plan?
Yps
Does the site have records of annual inspections? Are they performed by a qualified individual?
Yes, monthly
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
NC State Tr,iir ink
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?
Yes
Does the MS4 inspector's process include taking photos?
Yes
Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections?
As needed
NCS000545-Creedmoor MS4 Audit_20220815
Page 21 of 25

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?
Yes
Did the MS4 inspector miss any obvious operation and maintenance deficiencies? If so, explain:
No
Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing?
Yes, they are presented to Heide Salminen.
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?
The back slope of the SCM will be mowed
Notes/Comments/Recommendations
NCS000545_Creedmoor MS4 Audit_20220815 Page 22 of 25

NCS000545 Creedmoor MS4 Auditr20220815 Page 23 of 25

APPENDIX A: SUPPORTING DOCUMENTS
NCS000545 Creedmoor MS4 Audit_20220815 Page 24 of 25

APPENDIX B: PHOTOGRAPH LOG
NCS000545_Creedmoor MS4 Audit_20220815 Page 25 of 25