NCS000407_Audit Document and NOV Letter_20210604

DocuSign Envelope ID: D05BB852-F220-4CEF-9911-292ACC49FDF1
June 4, 2021
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
City of Mount Holly
Attention: Miles Braswell, City Manager, Owner
Post Office Box 406
Mount Holly, North Carolina 28120-0406
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
City of Mount Holly
Attention: Robert Whitt, Mayor, Co-owner
Post Office Box 406
Mount Holly, North Carolina 28120-0406
7017 2620 0000 6788 0462
7017 2620 0000 6788 0455
Subject: NOTICE OF VIOLATION (NOV-2021®PC-0303)
City of Mount Holly
NPDES MS4 Permit No. NCS000407
Gaston County
Dear Mr. Braswell and Mr. Whitt,
On May 24, 2021, 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 major
deficiencies with the specific components of the MS4 permit that were reviewed, as provided in
the attached DEQ MS4 Permit Compliance Audit Report. This report lists and describes the
serious deficiencies with certain components of the MS4 permit, which constitutes a violation of
the Clean Water Act and is grounds for enforcement action.
In accordance with Part VI of the permit and DEQ policy, a new 5-year MS4 permit will be
issued in response to the audit. To address the MS4 permit deficiencies, the City of Mount Holly
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) Adopt a Council Resolution within sixty (60) calendar days from the date of receipt of
this notice. The resolution must declare support for a compliant stormwater
North Carolina Department of Envirnomental Quafity I Division offnergy, Mnerai and Land Resources
Mooresville Regional office 1 610 Fast Center Avenue, Suite 3011 Mooresville North Carolina 26115
704.663,1699

DocuSign Envelope ID: D05BB852-F220-4CEF-9911-292ACC49FDF1
Notice of Violation
City of Mount Holly
June 4, 2021
Page 2 of 3
management program. A sample council resolution with the minimum requirements is
enclosed with this letter. An original signed document must be submitted to DEQ.
(3) Submit documentation for review and comment within one hundred twenty (120)
calendar days from the date of receipt of this letter:
a. The Illicit Discharge Detection and Elimination Program Plan, as required in Part
II, Section A.7. and Section D.2.a. of the current permit.
b. The MS4 Operation and Maintenance Program Plan, as required in Part II,
Section A.7. and Section G.21. of the current permit.
c. The Municipal SCM Operation and Maintenance Program Plan, as required in
Part II, Section A.7. and Section G.2.g. of the current permit.
d. Conduct a self -audit which includes, at a minimum, an evaluation of compliance
with the permit conditions found in Part Il Section E: Construction Site Runoff
Controls; Section F: Post -Construction Site Runoff Controls; Section H: Total
Maximum Daily Loads. The self -audit must be documented utilizing the
appropriate sections of the DEQ standard MS4 Permit Compliance Audit Report
Template.
Develop a Draft Stormwater Management Plan (SWMP) which details specific
actions, measurable goals, and implementation timelines to bring the stormwater
management program into compliance with NPDES MS4 requirements over the
new 5-year permit term. The SWMP must be documented utilizing the DEQ
Phase II MS4 SWMP Template. The SWMP must address all known compliance
deficiencies including, at a minimum, the items detailed in the DEQ MS4
Program Audit Report and the City of Mount Holly self -audit.
(4) Submit an NPDES MS4 permit application within thirty (30) days of receiving written
DEQ concurrence that the submitted Draft SWMP documents a compliant stormwater
management program. A new 5-year NPDES MS4 permit will be public noticed along
with the submitted SWMP.
(5)- Respond to public comments on the Draft SWMP and submit a Final SWMP for DEQ
approval and final permit issuance. The final DEQ-approved SWMP shall become an
enforceable component of the NPDES MS4 permit.
Required documentation shall be submitted via e-mail to jesse.mcdonnellnnedenngov, or to:
DEQ-DEMLR Stormwater Program
Attention: Jesse McDonnell
610 East Center Avenue
Mooresville, North Carolina 28115
^' North Carolina Department of Env€ronmwntal Quality I DlvisEon of orgy, Mineral and tand Aesources
Mooresville Regional Office 1 610 East Center Avenue, Suite 3011 Mooresville, North Carolina 2885
704.66316

DocuSign Envelope ID: D05BB852-F220-4CEF-9911-292ACC49FDF1
Notice of Violation
City of Mount Holly
June 4, 2021
Page 3 of 3
If the City of Mount Holly fails to meet the aforementioned requirements and/or submits a
significantly noncompliant Draft SWMP, DEQ may proceed with enforcement. As is stated in
Part V, Section A.1(c) of the permit:
Under state law, a daily civil penalty of not more than twenty-five thousand dollars
($25, 000) per violation may be assessed against any person who violates or fails to act in
accordance with the terms, conditions, or requirements of a permit [North Carolina
General Statute 143-215.6A]. Please note that compliance with the requirements of this
notice and/or issuance of civil or criminal penalties levied by DEQ does not preclude the
EPA from carrying out its own enforcement case against the permittee.
Thank you for your attention to this matter. Should you have any questions, please contact Jesse
McDonnell at [phone] or jesse.mcdonnell(a)ncdenr.jgov.
Sincerely,
DocuSigaaned by:
�W
d2CFABFC5B8C459...
Zahid S. Khan, CPM, CPESC, CPSWQ
Regional Engineer
Land Quality Section
Division of Energy, Mineral and Land Resources
Enclosures:
DEQ MS4 Permit Compliance Audit Report
Example Council Resolution
ec: Kimberly. [e-mail], City of Mount Holly Stormwater Coordinator
[e-mail], DEMLR Stormwater Program Supervisor
[e-mail], DEMLR MS4 Program Coordinator
DEMLR NPDES MS4 Permit Laserfiche File
North Carolina Department of Environmental Quality 1 itW[on of Enemy. Mineral and land Resources
Mooresville Regional Office 1 610 East tenter Avenue, Wite 3011 Mooresville.NortbCaroltna28115
704.663.1694

MUNICIPAL SEPARATE STORM SEWER SYSTEM 1
PROGRAM AUDIT REe •
Mount Holly, NORTH CAROLINA
400 East Central Avenue, Mount Holly, North Carolina 28120
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

(This page intentionally left blank)
NCS000407_Mount Holly MS4 Audit_20210524

AuditDetails..................................................................................................................................................1
PermitteeInformation..................................................................................................................................2
Listof Supporting Documents.......................................................................................................................3
Program Implementation, Documentation & Assessment...........................................................................4
PublicEducation and Outreach.....................................................................................................................7
Public Involvement and Participation...........................................................................................................8
Illicit Discharge Detection and Elimination (IDDE)........................................................................................9
Pollution Prevention and Good Housekeeping for Municipal Operations..................................................11
Site Visit Evaluation: Municipal Facility No. 1.............................................................................................13
Site Visit Evaluation: Municipal Facility No. 2.............................................................................................15
Site Visit Evaluation: Municipal Facility No. 3.............................................................................................17
Site Visit Evaluation: MS4 Outfall No. 1......................................................................................................19
Site Visit Evaluation: Post -Construction Stormwater Control Measure No.1............................................21
DISCLAIMER
This audit consists of an evaluation of program compliance with the issued permit and implementation of
the approved Stormwater Management Plan. This audit report does not include a review of all program
components, and program deficiencies in addition to those noted may be present. The permittee is
required to assess program progress and permit compliance, and to implement the approved Stormwater
Management Plan in accordance with the issued permit.
NCS000407_Mount Holly MS4 Audit_20210524 ii

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NCS000407_Mount Holly MS4 Audit_20210524

Audit ID Number: Audit Date(s):
NCS000407_Mount Holly MS4 Audit_20210524
May 24-25, 2021
Minimum Control Measures Evaluated:
N Program Implementation, Documentation & Assessment
N Public Education & Outreach-- - -
N Public Involvement & Participation
N 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
N Pollution Prevention and Good Housekeeping for Municipal Operations
❑ Total Maximum Daily Loads (TMDLs)
Field Site Visits:
N Municipal Facilities. Number visited: 3
N MS4 Outfalls. Number visited: 1
❑ Construction Sites. Number visited: Choose an item.
N Post -Construction Stormwater Runoff Controls. Number visited: 1
❑ Other: Number visited: Choose an item.
❑ Other: Number visited: Choose an item.
Jesse McDonnell, Environmental Specialist
North Carolina Department of Environmental Quality
Christopher Graybeal, Assistant Regional Engineer North Carolina Department of Environmental Quality
Audit Report Author: Jesse McDonnell Date:
1\ June 4, 2021
Signature
Audit Report -At or: Christopher raiybeal Date:
r , June 4, 2021
r
Signatur,_ ' < HIf
NCS000407-Mount Holly MS4 Audit_20210524 Page 1 of 22

ON ��Wl
MS4 Permittee Name: Permit Effective Date: Permit Expiration Date:
Town of Mount Holly February 2017 February 2022
Mailing Address:
Date of Last MS4 Inspection/Audit:
P.0 Box 406, Mount Holly, North Carolina 28120
June 5, 2012
Co-permittee(s), if applicable:
Permit Owner of Record:
Miles Braswell, City Manager; Robert Whitt, Mayor, Co -Owner; David Johnson, Utilities Director, Signature authority
David Johnson, Utilities Director
City of Mount Holly
Kimberly Sturgis, Stormwater Coordinator
City of Mount Holly
Derek Dixon, Site Inspector
City of Mount Holly
y .ram =�"�' �s rz"r -00
ON, gsg
Nil -WNW
Taylors Creek
WS-Iv
None Known
Fites Creek
WS-1v
None Known
Dutchman's Creek
WS-Iv
Turbidity
Stanley Creek
WS-Iv
None Known
South Stanley Creek
WS-Iv
None Known
NCS000407_Mount Holly MS4 Audit_20210524 Page 2 of 22

a 4�
1
Interlocal Agreement with Gaston County
Prior to
2
Mount Holly Website
Prior to
https://www.mtholly.us/
3
IDDE ordinance
After
4 `
Training Logs
Prior to
5
Map of Municipally Owned Facilities
After
6
Street Sweeper Hour Logs
After
7
IDDE Response and Inspection
After
8
Pesticide and Herbicide Applicator Licenses
After
NCS000407_Mount Holly MS4 Audit_20210524 Page 3 of 22

Kimberly Sturgis, Stormwater Coordinator
David Johnson, Utilities Director
Derek Dixon, Site inspector
The permittee maintained adequate funding and staffing to implement and manage
No
the provisions of the Stormwater Plan and meet all requirements of the permit.
x The Stormwater Plan identifies a specific position(s) responsible for the overall
coordination, implementation, and revision to the Plan.
;- Responsibilities for all components of the Stormwater Plan are documented and
position(s) assignments provided.
r"
a The permittee is current on payment of invoiced administering and compliance
Yes
BIMS
monitorin fees (see stormwater e- a ments on DEMLR MS4 web page).
Comments: The City currently has a small stormwater fee of $2.50/Residential Equivalent Unit (ERU)/month. Based on the audit,
funding is not sufficient for this program. The City does not have a current Stormwater Management Plan (SWMP). The City was
operating under the 2010-2015 SWMP. The stormwater fee is up to date with no balance due.
The permittee evaluated the performance and effectiveness of the program
components at least annually.
If es, the permittee used the results of the evaluation to modify the program
Y p fY p g
Not
components as necessary to accomplish the intent of the Stormwater Program.
applicable
---
Did the permitted MS4 discharges cause or contribute to non -attainment of an
No
---
_
applicable water quality standard?
..� If yes, did the permittee expand or better tailor its BMPs accordingly to address
Not
---
the non -attainment?
applicable
Comments: No documentation.
5
The permittee kept the Stormwater Plan up to date.
No
---
The permittee notified DEMLR of any updates to the Stormwater Plan.
No
---
Comments: The City did not maintain the SWMP. The most recent SWMP is from 2015. No SWMP was in effect during this permit
cycle.
NCS000407_Mount Holly MS4 Audit_20210524 Page 4 of 22

fv � «r
00
The permittee kept an up-to-date version of its Stormwater Plan available to the
No
Division and the. online.
public
' The online materials included ordinances, or other regulatory mechanisms, or a list
identifying the ordinances, or other regulatory mechanisms, providing the legal
Yes 2
authority necessary to implement and enforce the requirements of -the permit.
Comments: The City does not have the SWMP available on the webpage. The ordinances for legal authority are on the website.
Did DEMLR require a modification to the Stormwater Plan?
No
---
If yes, did the permittee complete the modifications in accordance with the
Not
established deadline?
Applicable
_
f
Comments: No modifications
were required by DEMLR.
Cs'porbt
Are any control measures implemented by an entity other than the permittee?
Yes
1
If yes, is there a written agreement in place?
Yes
1
Comments: Gaston County Natural Resources performs erosion control inspections for the county.
The permittee maintained written procedures for implementing the six minimum
control measures.
No
---
i�r�ac�diur�s
Written procedures identified specific action steps, schedules, resources and
No
---
responsibilities for implementing the six minimum measures.
Comments: No documentation.
ICE A`
The permittee maintained documentation of all program components including, but
�1P0 ti�tlt
not limited to, inspections, maintenance activities, educational programs,
No
---
lfifi1
implementation of BMPs, enforcement actions etc., on file for a period of five years.
Comments: No documentation.
11
The permittee submitted annual reports to the Department witlrtttu�t t?
1ttct8#t�pt
�e�f�l€f$t5ttttit (See Section 111.8. for the annual reporting
No
---
rrifi
period specific to this MS4).
The permittee submitted subsequent annual reports every twelve months from the
f
scheduled date of the first annual report submittal.
Yes
. Laserfiche
The Annual Reports included appropriate information to accurately describe the progress, status, and results
of the permittee's Stormwater Plan, including, but not limited the following:
1. A detailed description of the status of implementation of the Stormwater Plan
as a whole. This will include information on development and implementation
Not
of each major component of the Stormwater Plan for the past year and
Reviewed
-
schedules and plans for the year following each report.
NCS000407_Mount Holly MS4 Audit_20210524 Page 5 of 22

2. An adequate description and justification of any proposed changes to the
Stormwater Plan. This will include descriptions and supporting information for
Not
_
the proposed changes and how these changes will impact the Stormwater
Reviewed
Plan (results, effectiveness, implementation schedule, etc.).
_
3. Documentation of any necessary changes to programs or practices for
z
assessment of management measures implemented through the Stormwater
Not
-__
Plan.
Reviewed
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
Not
_--
Reviewed
Stormwater Plan.
5. An assessment of compliance with the permit, information on the
establishment of appropriate legal authorities, inspections, and enforcement
Not
---
Reviewed
Y
actions.
0 Annual reports are within Laserfiche.
The Annual Reports document the following:
1. A summary of past year activities, including where applicable, specific Not
quantities achieved and summaries of enforcement actions. Reviewed
2. A description of the effectiveness of each program component.
Not
---
Reviewed
3. Planned activities and changes for the next reporting period, for each
Not
program component or activity.
Reviewed
z
r �
�
Not
4. Fiscal analysis.
Reviewed
-
�r � r
Comments: Not Reviewed during this audit.
NCS000407_Mount Holly MS4 Audit_20210524 Page 6 of 22

s r
Kimberly Sturgis, Stormwater Coordinator
David Johnson, Utilities Director
r� Derek Dixon, Site inspector
The permittee defined goals and objectives of the Local Public Education and No
---
Outreach Program based on community wide issues.
Comments: No documentation.
- M The permittee maintained a description of the target pollutants and/or stressors and
wa
�Itsh likely sources.
No
Comments: The City did not maintain a description of target pollutants and/or stressors.
11
The permittee identified, assessed annually and updated the description of the target
%rgAdec
audiences likely to have significant storm water impacts and why they were selected.
No
---
r_
Comments: No documentation of annual assessment or updating.
I I�eidetra
The permittee described issues, such as pollutants, the likely sources of those
c�idEtSttlaf
pollutants, potential impacts, and the physical attributes of stormwater runoff in
No
---
[ier+Ltsus °
their education/outreach program.
Comments: No documentation.
The permittee promoted and maintained an internet web site designed to convey the
Yes
2
program's message.
Comments: The City maintained an internet website with public education and outreach materials. The website is published in all
stormwater educational documents.
j
#
The permittee distributed stormwater educational material to appropriate target
No
---
groups.
Comments: No documentation.
The permittee promoted and maintained a stormwater hotline/helpline for the
Yes
2
purpose of public education and outreach.
Comments: The City maintained a hotline on the website for the purpose of Public Education and Outreach.
i
The permittee's outreach program, including those elements implemented locally or
'�ik ldin
through a cooperative agreement, included a combination of approaches designed to
Partial
2
iutrttt
reach the target audiences.
`*� y
For each media, event or activity, including those elements implemented locally or
through a cooperative agreement the permittee estimated and recorded the extent
No
---
of exposure.
Comments: The City maintained the website and Facebook page. No documentation for extent of exposure.
NCS000407_Mount Holly MS4 Audit_20210524 Page 7 of 22

Kimberly Sturgis, Stormwater Coordinator
David Johnson, Utilities Director
Derek Dixon, Site inspector
The permittee included and promoted volunteer opportunities designed to promote
No --
ongoing citizen participation.
Comments: No documentation.
The permittee provided and promoted a mechanism for public involvement that
No ---
provides for input on stormwater issues and the stormwater program.
Comments: The City maintained a Stormwater Committee made of citizens. No documentation of frequency or topics of meetings. '-
II The permittee promoted and maintained a hotline/helpline forthe purpose of public yes 2
involvement and participation.
Comments: The City maintained a hotline on the website for the purpose of Public Involvement and Participation.
NCS000407_Mount Holly MS4 Audit_20210524 Page 8 of 22

Kimberly Sturgis, Stormwater Coordinator
David Johnson, Utilities Director
Derek Dixon, Site inspector
- now-- _ - - -
MORMIM EN 0�
ma
?lcl?rt The permittee maintained a written IDDE Program. No ---
If yes, the written program includes provisions for program assessment and Not
r
evaluation and integrating program. Applicable
Comments: No documentation.
The permittee maintained an IDDE ordinance or other regulatory mechanism(s) that
provides the legal authority to prohibit illicit connections and discharges to the MS4.
Yes
3
`
If yes, the ordinance applies throughout the corporate limits of the permittee.
Yes
3
(Permit Part I.D)
Comments: The City has maintained an IDDE Ordinance since 2006 within the City limits.
The permittee maintained a current map showing major outfalls and receiving
t6FiE1t
Yes
5
streams.
Comments: The City has maintained a map with all major outfalls.
#
The per maintained a program for conducting dry weather flow field
�a�IOUft
No
---
A_
observations in accordance with written procedures.
P�caghan� .
Comments: No documentation of dry weather flow program being maintained.
The permittee maintained written procedures for conducting investigations of
ll> din
Partial
7
s
identified illicit discharges.
Comments: The City has a list of procedures for conducting an IDDE investigation.
Et
For each case of an illicit discharge or potential illicit discharge, the permittee documented and tracked the
TCa�kllhd
following:
1. The date(s) the illicit discharge was observed
Yes
7
3
2. The results of the investigation
Yes
7
J l
3. Any follow-up of the investigation
Yes
7
4. The date the investigation was closed
Yes
7
Comments: The City has an IDDE response sheet that documents all aspects of the IDDE investigation.
NCS000407_Mount Holly MS4 Audit_20210524 Page 9 of 22

The permittee implemented and documented a training program for appropriate
municipal staff who, as art of their normal job responsibilities, may come into Partial 4
p p 1 p Y
contact with or otherwise observe an illicit discharge or illicit connection.
Comments: Only training
records are from 2019 and 2020.
The permittee informed public employees of hazards associated with illegal
discharges and improper disposal of waste.
Partial
4
The permittee informed businesses of hazards associated with illegal discharges and
improper disposal of waste.
No
---
The permittee informed the general public of hazards associated with illegal
discharges and improper disposal of waste.
No
---
Comments: annual training was conducted for employees, only two years have documented training. No documentation for
educational materials being delivered to businesses or the general public.
} `` x
The permittee promoted, publicized, and facilitated a reporting mechanism for the
Partial
2
public to report illicit discharges.
The permittee promoted, publicized, and facilitated a reporting mechanism for staff
r
to report illicit discharges.
partial
2
s f
The permittee established and implemented response procedures for citizen
No
---
requests/reports.
Comments: The City maintained a hotline for the public and staff to call to report an illicit discharge. No documentation of written
procedures when a report is received. _.
The permittee implemented a mechanism to track the issuance of notices of violation
Hilt �t)1��4
and enforcement actions administered by the permittee.
No
---
�
If yes, the mechanism includes the ability to identify chronic violators for
No
---
initiation of actions to reduce noncompliance.
Comments: The City tracked all IDDE reports/complaints within a spreadsheet.
NCS000407_Mount Holly MS4 Audit_20210524 Page 10 of 22

R .X` [yj "3 .'?.z f "�'G- -'''f` jy. „-=,cy�L -w` kr`# : S '3� T .✓,�-`
%��Jk�.a
Kimberly Sturgis, Stormwater Coordinator
David Johnson, Utilities Director
Y
Derek Dixon, Site inspector
1Ft3 `'
The permittee maintained a current inventory of facilities and operations owned
tip inrrrit ,�
and operated by the permittee with the potential for generating polluted Yes 5
stormwater runoff.
Comments: The City maintained a map of all municipally owned facilities. The facilities with potential to pollute need to be
identified on a separate list within the map.
t4x
The permittee maintained and implemented an O&M program for municipally
t)�irtC►rTtc
owned and operated facilities with the potential for generating polluted
No
---
iit�Ee{C?Scll}„
stormwater runoff.
fir FICilitis
If yes, the 0&M program specifies the frequency of inspections.
Not
-
Applicable
If yes, the C&M program specifies the frequency of routine maintenance.
Not
requirements.
Applicable
If yes, the permittee evaluated the 0&M program annually and updated it as
Not
necessary.
Applicable
_
Comments: No documentation.
IiI.G:2 C
Spit Fiepa�iss
The permittee had written spill response procedures for municipal operations.
No
---
Procectures
Comments: No documentation.
lF�,#f atCts�
The permittee evaluated existing and new BMPs that reduce polluted stormwater
llOfSr �i�fl #ublie 4 :
runoff from municipally -owned streets, roads, and public parking lots within its
Partial
6
Pt114 .
corporate limits annually.
Ma>3tence
If yes, the permittee evaluated the effectiveness of existing and new BMPs
Partial
6
based on cost and the estimated quantity of pollutants removed.
Comments: The City maintained a street sweeping schedule downtown and for problematic areas. The hours the sweeper was run
each week is recorded.
The permittee maintained and implemented an O&M program for the stormwater
sewer system including catch basins and conveyance systems that it owns and
No
---
maintains.
Conu�ys>sceSyst�nilr's
Comments: No documentation of written O&M program for conveyances.
(
The permittee maintained a current inventory of municipally -owned or operated
StixUctucat ,.=
structural stormwater controls installed for compliance with the permittee's post-
Yes
5
t4�lisvtr",ontlf►s-
construction ordinance.
NCS000407_Mount Holly MS4 Audit_20210524 Page 11 of 22

Comments: The City maintained a map of all municipally owned facilities. The facilities with potential to pollute need to be
identified on a separate list within the map.
The permittee maintained and implemented an O&M program for municipally -
owned or maintained structural stormwater controls installed for compliance with
No
---
the permittee s post-construction`brdinace. If yes, -then:
-
The O&M program specified the frequency of inspections and routine
Not
maintenance requirements.
Applicable
The permittee documented inspections of all municipally -owned or maintained
Not
structural stormwater controls.
Applicable
The permittee inspected all municipally -owned or maintained structural
developed by
Not
Applicable
stormwater controls in accordance with the schedule permittee.
-
The permittee maintained all municipally -owned or maintained structural
Not
---
stormwater controls in accordance with the schedule developed by permittee.
Applicable
The permittee documented maintenance of all municipally-owned'or
Not
maintained structural stormwater controls.
Applicable
Comments: No documentation of O&M program. Inspections have been conducted on a routine basis.
The permittee ensured municipal employees are properly trained in pesticide,
Yes
8
herbicide and fertilizer application management.
The permittee ensured contractors are properly trained in pesticide, herbicide and
Not
fertilizer application management.
Applicable
The ensured all certifications, and other measures for
permittee permits,
Yes
$
applicators are followed.
Comments: The City has three employees who are certified pesticide/herbicide applicators.
3
The permittee implemented an employee training program for employees involved
Partial
4
in implementing pollution prevention and good housekeeping practices.
Comments: The City has trainings for 2019 and 2020.
The permittee described and implemented measures that prevent or minimize
contamination of stormwater runoff from all areas used for vehicle and equipment
No
---
cleaning.
Comments: No Documentation.
NCS000407_Mount Holly MS4 Audit_20210524 Page 12 of 22

Facility Name: Date and Time of Site Visit:
City of Mount Holly Public Works May 25, 2021 at 9:00 am
Facility Address: Facility Type (Vehicle Maintenance, Landscaping, etc.):
218 Adrian St. Vehicle and equipment maintenance and storage
Mount Holly, NC 28120
Name of MS4 inspector(s) evaluated: Most Recent MS4 Inspection (List date and name of inspector):
Derek Dixon None
a dt(�{strf>:ailr #epesen;resent [rrir t xr ` F
yam..
Name Title
Facility Manager
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific?
No, the facility does not have a SWPPP.
What type of stormwater training do facility employees receive? How often?
Staff receive the illicit discharge and spill response training annually.
�t��Pec#+or'�ta�n�rigJKr�owl�dge _ `
What type of stormwater training does the MS4 inspector receive? How often?
The inspector has no MS4 specific training.
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
No, the facility has been operating without a State Stormwater Permit.
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Yes.
fl3e�#P#t1 poceduces
Does the MS4 inspector's process include the use of a checklist or other standardized form?
No.
Does the MS4 inspector's process include taking photos?
No.
Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)?
Not applicable.
NCS000407_Mount Holly MS4 Audit_20210524 Page 13 of 22

t.
Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge?
Yes.
Did the MS4 inspector miss any obvious areas of concern? If so, explain:
No.
Does the MS4 inspector's process include presenting the inspection findings to the facility contact?
Yes, the facility contact walked the site during the inspection.
Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)?
Yes, the facility will need to apply for a State Stormwater Permit. The general permit number will be NCGO80000 due to vehicle
maintenance.
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
The facility needs to apply for coverage under NCG080000 as soon as possible.
This facility inspection became a technical assistance inspection to educate the City about the proper procedures and processes
that should be used during an inspection. -
NCS000407_Mount Holly MS4 Audit_20210524 Page 14 of 22

Facility Name:
Date and Time of Site Visit:
City of Mount Holly Waste Water Treatment Plan (WWTP)
May 25, 2021 at 10:00 am
Facility Address:
Facility Type (Vehicle Maintenance, Landscaping, etc.):
201 Broome St.
Waste Water Treatment
Mount Holly, NC 28120
Name of MS4 inspector(s) evaluated:
Most Recent MS4 Inspection (Date and Entity):
Derek Dixson
None
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Name
Title
Doug Facility Supervisor
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?
The facility staff receive spill prevention and response and IDDE identification training annually.
Ins�ecltot` Tr�ln�ng/Knor�rledge
What type of stormwater training does the MS4 inspector receive? How often?
None.
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
No.
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Yes.
Does the MS4 inspector's process include the use of a checklist or other standardized form?
No.
Does the MS4 inspector's process include taking photos?
No.
Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)?
No.
NCS000407_Mount Holly MS4 Audit_20210524 Page 15 of 22

R2 M
Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge?
Yes.
Did the MS4 inspector miss any obvious areas of concern? If so, explain:
No.
Does the MS4 inspector's process include presenting the inspection findings to the facility contact?
Yes, the facility supervisor inspected the site along with the MS4 inspector.
X (� I S_l
Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)?
It is recommended to construct secondary containment around totes that are not inside or under cover.
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
No timeline was provided to have the repairs corrected.
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This facility inspection became a technical assistance inspection to educate the City about the proper procedures and processes
that should be used during an inspection.
NCS000407_Mount Holly MS4 Audit_20210524 Page 16 of 22

Facility Name: Date and Time of Site Visit:
City of Mount Holly Fire Department May 25, 2021 at 11:00 am
Facility Address:
Facility Type (Vehicle Maintenance, Landscaping, etc.):
433 Killian Ave
Fire Department
Mount Holly, NC 28120
Name of MS4 inspector(s) evaluated: Most Recent MS4 Inspection (List date and name of inspector):
Derek Dixson None
Name Title
_ y _
8t11{ i?#J#'ttC}rif�i[C1 s
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific?
No, the facility does not require a SWPPP.
What type of stormwater training do facility employees receive? How often?
The staff receive spill response training and IDDE training annually.
Inspect�rTt'atning/Itn�owledge - -
What type of stormwater training does the MS4 inspector receive? How often?
None.
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
Not applicable.
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Yes.
Ins �ct�orl i?�etedures x
Does the M54 inspector's process include the use of a checklist or other standardized form?
No.
Does the MS4 inspector's process include taking photos?
No.
Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)?
Not applicable.
NCS000407_Mount Holly MS4 Audit_20210524 Page 17 of 22

A
Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge?
Yes.
Did the MS4 inspector miss any obvious areas of concern? If so, explain:
No.
Does the MS4 inspector's process include presenting the inspection findings to the facility contact?
Yes.
Did the facility inspection result inanycorrective 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?
Not applicable.
NCS000407_Mount Holly MS4 Audit_20210524 Page 18 of 22

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Outfall ID Number:
Date and Time of Site Visit:
Woodland Avenue Outfall
May 25, 2021 at 11:30
Outfall Location:
Outfall Description (Pipe Material/Diameter, Culvert, etc.):
300 Woodland Avenue
36" RCP
Mount Holly, NC 28120
Receiving Water:
Is Flow Present? If So, Describe (Color, Approximate Flow Rate,
Dutchman's Creek
Sheen, Odor, Floatables/Debris, etc.):
No flow at the time of the inspection.
Most Recent Outfall Inspection/Screening (Date):
Unknown
Days Since Last Rainfall:
Inches:
13
0.25
Name of MS4 Inspector(s) evaluated:
Derek Dixson
r
tnspectc�r �raEnm�%'l�r�o��edg�„ _
What type of stormwater training does the M54 inspector receive? How often?
None.
Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations?
Yes.
Does the inspector's process include the use of a checklist or other standardized form?
Yes.
Does the inspector's process include taking photos?
Yes.
Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they?
No, this outfall recently had maintenance preformed.
NCS000407_Mount Holly MS4 Audit_20210524 Page 19 of 22

NCS000407_Mount Holly MS4 Audit_20210524 Page 20 of 22

Site Name: Date and Time of Site Visit:
Tuckaseege Park Wetland May 25, 2021 at 10:40 am
Site Address: SCM Type:
165 Broome St. Engineered Wetland
Mount Holly, NC 28120
Most Recent MS4 Inspection (Include Date and Entity):
None
Name of MS4 Inspector(s) evaluated: Most Recent MS4 Enforcement Activity (Include Date):
Derek Dixson None
Name Title
�ltE' �Q�Ul1�1111:at1�}tt '"
Does the site have an operation and maintenance plan?
Yes.
Does the site have records of annual inspections? Are they performed by a qualified individual?
Yes.
inse�tar'i�r�inr�gj��yv�ee
What type of stormwater training does the MS4 inspector receive? How often?
None.
Did the MS4 inspector appear knowledgeable about MS4 requirements for post -construction site runoff controls?
Yes.
Did the MS4 inspector appear knowledgeable about post -construction BMPs (general purpose/function, components, O&M
requirements, etc.)?
Yes.
tnpcf�i�n Prr3c�dures --
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?
No.
NCS000407_Mount Holly MS4 Audit_20210524 Page 21 of 22

Does the MS4 inspector's process include walking theentiresite 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?
No.
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What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in?
No actions.
If compliance issues were identified, what timeline for correction/follow-up was provided?
Not applicable.
NCS000407_Mount Holly MS4 Audit_20210524 Page 22 of 22