NCS000545_Self-Audit_20221118

DRAFT PHASE II MS4 AUDIT TEMPLATE
FOR PERMITS ISSUED PRIOR TO 2019
MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM AUDIT REPORT
NPDES PERMIT NO. NCS000545
Creedmoor, NORTH CAROLINA
211 North Main St., PO Box 765
Audit Date: 5/18/2022
Self -Audit Date: 11/18/2022
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

MS4 Permit Audit Report
Creedmoor, NC: NPDES Permit No. NCS000545
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Audit Date: Wed. May 18th, 2022

MS4 Permit Audit Report
Creedmoor, NC: NPDES Permit No. NCS000545
TABLE OF CONTENTS
AuditDetails.................................................................................................
Permittee Information..................................................................................
Supporting Documents.................................................................................
Program Implementation, Documentation & Assessment .............................
Public Education and Outreach.....................................................................
Public Involvement and Participation............................................................
Illicit Discharge Detection and Elimination (IDDE).........................................
Construction Site Runoff Controls.................................................................
Post -Construction Site Runoff Controls.........................................................
Pollution Prevention and Good Housekeeping for Municipal Operations ......
Total Maximum Daily Loads (TMDLs)............................................................
Site Visit Evaluation: Municipal Facility No. 1................................................
Site Visit Evaluation: Municipal Facility No. 2................................................
Site Visit Evaluation: MS4 Outfall No. 1.........................................................
Site Visit Evaluation: MS4 Outfall No. 2.........................................................
Site Visit Evaluation: Construction Site No. 1................................................
Site Visit Evaluation: Construction Site No. 2................................................
Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1.
Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 2.
Appendix A: Supporting Documents
Appendix B: Photograph Log
.1
.2
.3
,.4
,.8
11
13
16
19
25
28
30
32
34
36
38
40
42
44
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.
Audit Date: Wed. May 18t", 2022

MS4 Permit Audit Report
Creedmoor, NC: NPDES Permit No. NCS000545
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Audit Date: Wed. May 18th, 2022 iii

MS4 Permit Audit Report
Creedmoor, NC: NPDES Permit No. NCS000545
Audit Details
Audit ID Number:
Audit Date(s):
NCS000545 Creedmoor MS4 Audit 2022 Wed.
Minimum Control Measures Evaluated:
❑ Program Implementation, Documentation & Assessment
❑ Public Education & Outreach
❑X 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
❑X Post -Construction Site Runoff Controls
❑ Pollution Prevention and Good Housekeeping for Municipal Operations
❑X Total Maximum Daily Loads (TMDLs)
Field Site Visits:
❑ Municipal Facilities. Number visited: Choose an item.
❑ MS4Outfalls. Number visited: Choose an item.
❑ Construction Sites. Number visited: Choose an item.
❑ Post -Construction Stormwater Runoff Controls. Number visited: Choose an item.
❑ Other: Number visited: Choose an item.
❑ Other: Number visited: Choose an item.
Inspector(s) Conducting Audit
Name, Title
Organization
Michael Frangos, Assistant City Manager/ Community
City of Creedmoor
Development Director
John Boyer, P.E.
City of Creedmoor
Heidi Salminen, Planning Technician
City of Creedmoor
Gerard Seibert, Code Enforcement
City of Creedmoor
Audit Report Author:
Date:
Signature
Audit Report Author:
Date
Signature
Audit Date(s): Wed. May 18th, 2022 Page 1 of 47

MS4 Permit Audit Report
Creedmoor, NC: NPDES Permit No. NCS000545
Public Involvement and Participation
Staff Interviewed:
Michael Frangos- Assistant City Manager/ Community Development Director, John Boyer- City Engineer,
(Name, Title, Role)
Heidi Salminen- Planning Technician, Gerard Seibert- Code Enforcement
Permit Citation
Program Requirement Status SupportingDoc
No.
II.C.2.a Volunteer
Community
The permittee included and promoted volunteer opportunities designed to promote Yes Tab 9
Involvement
ongoing citizen participation.
Program
Comments (Note opportunities promoted and date(s) of volunteer events)
The City of Creedmoor offers its community members the opportunity to get out and help clean up Creedmoor during its yearly
Litter Sweep event. This event is generally held during the fall. This event also brings together multiple City departments that
help to keep the streams and ditches clear of litter and debris.
The City also promotes stormwater through social media and in -office brochures.
II.C.2.b
Mechanism for
The permittee provided and promoted a mechanism for public involvement that
Public
provides for input on stormwater issues and the stormwater program.
Yes
Tab 10
Involvement
Comments (Note mechanism(s) for input and how promoted)
The City offers citizens the opportunity to provide public comment during updates to the Creedmoor Development Ordinance,
which includes the City's stormwater ordinances.
• Watershed Protection Ordinance updated 2018, 2021, and 2022
• Soil Erosion and Sedimentation Control
• Flood Damage Prevention updated 2019 and 2021
Public comment on the Stormwater Management Plan (SWMP) update was held from March 1 to April 5, 2022. The City received
one comment. Additionally, during the development of the Creedmoor's City Plan 2040 two outreach events were held to
involve the public. We received multiple comments on stormwater in the City.
Audit Date(s): Wed. May 18th, 2022 Page 11 of 47

MS4 Permit Audit Report
Creedmoor, NC: NPDES Permit No. NCS000545
Public Involvement and Participation
II.C.2.c
The permittee promoted and maintained a hotline/helpline for the purpose of public
Tab 7 &
Hotline/Help Line
involvement and participation.
Yes
8
Comments (Note hotline contact information and how it is promoted)
On the City's website we promote the helpline/ hotline. If a citizen calls, emails, or visits the office to submit a concern or
complaint they are logged and a staff member follows up with that citizen.
The phone number and email to submit a SW concern/ complaint are also on posters around the office and on educational
material handed out at events.
Additional
While the City of Creedmoor does not host a Household Hazardous Waste disposal day the City promotes
Comments:
Granville Counties HHW disposal day by posting on the City's Facebook page.
Additionally, the City hosts a Drug Take Back Event and has a Medicine drop box in City Hall. (tab 9)
In 2017 Mr. Willis Herman, long-time Creedmoor resident, decided to take it upon himself to help beautify
the City by cleaning up litter around town. Mr. Herman was featured in the Spring 2017 edition of the
Creedmoor Happening and made a noticeable difference. (tab 9)
Audit Date(s): Wed. May 18t", 2022 Page 12 of 47

MS4 Permit Audit Report
Creedmoor, NC: NPDES Permit No. NCS000545
Post -Construction Site Runoff Controls
Staff Interviewed:
(Name, Title, Role)
Michael Frangos- Assistant City Manager/ Community Development Director, John Boyer- City Engineer,
Heidi Salminen- Planning Technician, Gerard Seibert- Code Enforcement
Audit Date(s): Wed. May 18t", 2022 Page 19 of 47

MS4 Permit Audit Report
Creedmoor, NC: NPDES Permit No. NCS000545
Post -Construction Site Runoff Controls
Implementation (check all that apply):
❑x The permittee implements the components of this minimum measure.
❑x The permittee relies upon another entity to implement the components of this minimum measure: Stimmel- for stormwater
review.
❑ 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 213.0212
❑X Water Supply Watershed II (WS-11) —15A NCAC 213.0214
❑ Water Supply Watershed III (WS-III) — 15A NCAC 213.0215
N Water Supply Watershed IV (WS-IV) — 15A NCAC 213.0216
© Freshwater High Quality Waters (HQW) —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 2B .0258
❑ Randleman Lake Water Supply Watershed Nutrient Management Strategy — 15A NCAC 213.0251
❑ 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.
❑X DEQ approved comprehensive watershed plan
❑X 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 below for the permitted area(s) not covered under the S.L. 2006-246 deemed -compliant program.
Session Law 2006- program Requirement Status Supporting
246 1 1
Doc No.
Audit Date(s): Wed. May 18th, 2022 Page 20 of 47

MS4 Permit Audit Report
Creedmoor, NC: NPDES Permit No. NCS000545
Post -Construction Site Runoff Controls
Deemed -Compliant
The permittee implements deemed -compliant Program requirements in
Appendi
Program(s)
accordance with the applicable 15A NCAC rules.
Yes
xH
The permittee implements deemed -compliant Program requirements throughout
Appendi
the entire MS4 area (If not, also complete the Permit Citation section below.)
Yes
xH
The permittee applies deemed -compliant Program requirements to all federal,
state and local government projects within the permitted MS4 area who do not
Yes
Appendi
have their own NPDES stormwater permit.
x H
The permittee included deemed -compliant Program reporting in their MS4 Annual
Appendi
Reports.
Yes
xH
The permittee included deemed -compliant Program implementation in their
Stormwater Management Plan.
Yes
SWMP
Comments
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
Appendi
Management Program.
xH
If yes, the ordinance applies throughout the corporate limits of the permittee
Veri
( fy permit coverage area listed in Part I.D of permit and modify
Yes
CDO-
accordingly).
Article 1
The permittee has the authority to review designs and proposals for new
development and redevelopment to determine whether adequate stormwater
Yes
Appendi
control measures will be installed, implemented, and maintained.
x H
The permittee has the authority to request information such as stormwater plans,
inspection reports, monitoring results, and other information deemed necessary to
Appendi
evaluate compliance with the Post -Construction Stormwater Management
Yes
x H
Program.
The permittee has the authority to enter private property for the purpose of
inspecting at reasonable times any facilities, equipment, practices, or operations
Not
Applicable
Appendi
x H
related to stormwater discharges. The city doesn't have big industry.
Comments (if the permittee relies upon another entity, specifically note the legal authority that allows that entity to implement
the program within the M54 area)
II.F.2.b
Appendi
Stormwater Control
The permittee utilizes strategies which include SCMs appropriate for the MS4.
Yes
x H, Tab
Measures (SCMs)
19
Appendi
SCMs comply with 15A NCAC 02H .1000.
Yes
x H, Tab
19
Audit Date(s): Wed. May 18th, 2022 Page 21 of 47

MS4 Permit Audit Report
Creedmoor, NC: NPDES Permit No. NCS000545
Post -Construction Site Runoff Controls
Comments
II.F.2.c
Tab 19,
Plan Reviews
The permittee conducted site plan reviews of all new development and
Tab 20,
redeveloped sites that disturb greater than or equal to one acre (including sites
Tab 21,
that disturb less than one acre that are part of a larger common plan of
Yes
Appendi
development or sale).
x
(article
20)
If yes, the site plan reviews addressed how the project applicant meets the
performance standards.
Yes
Tab 19
If yes, the site plan reviews addressed how the project will ensure long-term
O&M
Yes
Agreeme
maintenance.
nt
Comments
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
Tab 22
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
Tab 22
requirements.
Comments
II.F.2.e
The permittee provided mechanisms such as recorded deed restrictions and
Appendi
Deed Restrictions
protective covenants that ensure development activities will maintain the project
Yes
x H
and Protective
consistent with approved plans.
Covenants
Comments
II.F.2.f
The permittee implemented or required an operation and maintenance plan for
Appendi
Mechanism to
the long-term operation of the SCMs required by the program.
Yes
x H
Require Long-term
Operation and
The operation and maintenance plan required the owner of each SCM to perform
Appendi
Maintenance
and maintain a record of annual inspections of each SCM.
Yes
x H
Annual inspection of permitted structural SCMs are required to be performed by a
Appendi
qualified professional.
Yes
X H
Audit Date(s): Wed. May 18th, 2022 Page 22 of 47

MS4 Permit Audit Report
Creedmoor, NC: NPDES Permit No. NCS000545
Post -Construction Site Runoff Controls
Comments
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
Binder
Structural
is a 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
Binder
com pl etion (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
Partial
---
condition in Part II.F.2.g of permit and modify accordingly.
The permittee documented and maintained records of inspections.
Yes
Tab 12
The permittee documented and maintained records of enforcement actions.
Yes
Binder
Comments
The Code Enforcement officer inspects SCM's monthly. Each SCM has its own binder where paper copies are kept. A spreadsheet
tracking the inspection date and SCM condition is also kept on the office drive.
The Code Enforcement officer has a standard inspection form he uses during each inspection, but a written inspection program
could be put together.
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.
Tab 19,
Training for
Note: New materials may be developed by the permittee, or the permittee may use
Yes
Tab 7
Developers
materials adopted from other programs and adapted to the permittee's new
development and redevelopment program.
Comments (If the permittee has adopted materials from other programs, indicate here which materials they are using)
II.F.2.i Enforcement
The permittee tracked the issuance of notices of violation and enforcement
Yes
Tab 13
actions.
If yes, the tracking mechanism included the ability to identify chronic violators
yes
Tab 13
for initiation of actions to reduce noncompliance.
Comments
Audit Date(s): Wed. May 18th, 2022 Page 23 of 47

MS4 Permit Audit Report
Creedmoor, NC: NPDES Permit No. NCS000545
Post -Construction Site Runoff Controls
II.F.3.b
The permittee fully complies with post construction program requirements on its
New Development
own publicly funded construction projects.
Yes
Binder
Comments
II.F.3.c
Does the MS4 have areas draining to Nutrient Sensitive Waters (NSW) pursuant to
Nutrient Sensitive
15A NCAC 02H .0150?
Yes
Tab 18
Waters
If yes, does the permittee use SCMs that reduce nutrient loading in order to
meet local program requirements.
Yes
Tab 19
If yes, does the permittee also still incorporate the stormwater controls
required for the project's density level.
Yes
Tab 19
If yes, does the permittee also require documentation where it is not feasible to
use SCMs that reduce nutrient loading.
Yes
Tab 19
Comments (Provide reference for local requirements)
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
Tab 19
Where "streets" convey stormwater, the permittee designed SCMs to be sized to
treat and control stormwater runoff from all surfaces draining to the SCM including
Yes
---
streets, driveways, and other impervious surfaces.
Comments
Audit Date(s): Wed. May 18t", 2022 Page 24 of 47

MS4 Permit Audit Report
Creedmoor, NC: NPDES Permit No. NCS000545
Total Maximum Daily Loads (TMDLs)
Staff Interviewed:
(Name, Title, Role)
Program Status:
❑X The permittee is not subject to an approved TMDL (skip the rest of this section).
❑ The permittee is subject to an approved TMDL for: name of parameter(s) and date(s) approved
There ❑ is ❑ is not a Waste Load Allocation (WLA) in the approved TMDL (If there is a WLA, then complete items H.H.1-5
below. If there is not a WLA, skip to item H.H.6 below)
Permit Citation Program Requirement Status
Supporting
Doc No.
II.H.3 TMDLs Within 12 months of final TMDL approval, the permittee's annual reports included Choose
a description of existing programs, controls, partnerships, projects and strategies to
address impaired waters. an item.
Within 12 months of final TMDL approval, the permittee's annual reports provided Choose
a brief explanation as to how the programs, controls, partnerships, projects and
strategies address impaired waters. an item.
Comments
II.H.4 TMDLs
Within 24 months of final TMDL approval, the permittee's annual reports included
Choose
an assessment of whether additional structural and/or non-structural BMPs are
---
necessary to address impaired waters.
an item.
Within 24 months of final TMDL approval, the permittee's annual reports included
Choose
a brief explanation as to how the programs, controls, partnerships, projects and
---
strategies address impaired waters.
an item.
Comments
II.H.5 TMDLs
Within 36 months of final TMDL approval, the permittee's annual reports included
Choose
a description of activities expected to occur and when activities are expected to
---
an item.
occur.
Audit Date(s): Wed. May 18th, 2022 Page 28 of 47

MS4 Permit Audit Report
Creedmoor, NC: NPDES Permit No. NCS000545
Total Maximum Daily Loads (TMDLs)
Comments
II.H.6 TMDLs
If there is no Waste Load Allocation in the approved TMDL, the permittee
evaluated strategies and tailored and/or expanded BMPs within the scope of the
Choose
six minimum measures to enhance water quality recovery strategies in the
an item.
watershed(s) to which the TMDL applies.
The permittee described strategies and tailored and/or expanded BMPs in their
Choose
Stormwater Management Plan and annual reports
an item.
Comments
Audit Date(s): Wed. May 18th, 2022 Page 29 of 47