NCS000393_Dallas MS4 Audit Report_20201219

SEPARATEMUNICIPAL t
PROGRAM AUDIT REPO•
TOWN OF DALLAS, NORTH CAROLINA
210 North Holland Street
Dallas, North Carolina 28034
Audit Date: December 4, 2019
Report Date: December 19, 2019
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)
NCS000393 Dallas MS4 Audit 20191220

AuditDetails.....................................................................................................................
PermitteeInformation.....................................................................................................
List of Supporting Documents..........................................................................................
Program Implementation, Documentation & Assessment ..............................................
Public Education and Outreach........................................................................................
Public Involvement and Participation..............................................................................
Illicit Discharge Detection and Elimination (IDDE)...........................................................
Post -Construction Site Runoff Controls...........................................................................
Pollution Prevention and Good Housekeeping for Municipal Operations .......................
Site Visit Evaluation: Municipal Facility No. 1..................................................................
Site Visit Evaluation: MS4 Outfall No. 1...........................................................................
Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1.................
Appendix A: Supporting Documents
Appendix B: Photograph Log
............................1
............................ 2
............................3
............................4
............................7
............................ 8
............................9
..........................11
..........................15
.. ....................17
..........................19
..........................20
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.
NCS000393 Dallas MS4 Audit 20191220 ii

This page intentionally left blank
NCS000393 Dallas MS4 Audit 20191220

Audit Details
Audit ID Number: Audit Date(s):
NCS000393 Dalla MS4 Audit 20191205 1 December 4, 2019
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
N 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: 1
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.
r Inspector(s) Conducting Audit
- Name; 'title Organization
Isaiah Reed, Environmental Specialist NCDEQ
Lily Kay, Environmental Specialist NCDEQ
Audit Report Author- Date`:
Signature
Audit Report Author: Date
f U'
NCS000393 Dallas MS4 Audit 20191220 Page 1 of 21

�-�;� �_.� "' _�� ter_ -.ter;",. � ".% .- ,��'
- ..� -'
'S
film ow E7
1 Sign in Sheet
,-✓, �,.�'�` __
During
2
Interlocal agreement with Gaston County (Stormwater Ordinance)
Prior
3
Dallas annual report 2018-2019
Prior
4
Gaston County Stormwater Inspection Report
During
5
Bojangles Post -Construction SW Permit
During
6
SW BMP bi-annual inspection report (Dallas) (six separate reports)
During
7
NC Pesticide Applicator Cert card.
During
8
As built survey transmittal letter
During
9
Town of Dallas Stormwater Brochure and Newsletter
During
10
Regional Stormwater Partnership 2019 annual report
During
11
Gaston County Soil Erosion and Sedimentation Control Ordinance
Prior
12
Gaston County Stormwater Ordinance
Prior
13
Town of Dallas SCM Inventory
During
14
Interlocal Agreement with Gaston Co. ESC
Prior
15
Stormwater infrastructure Map
Prior
NCS000393 Dallas MS4 Audit 20191220 Page 3 of 21

-
-
t"
Joseph Alm, Stormwater Administrator
Johnny Denton, Town Engineer
Bill Trudnak, Public Works Director
The permittee maintained adequate funding and staffing to implement and manage
Yes
Y
the provisions of the Stormwater Plan and meet all requirements of the permit.
The Stormwater Plan identifies a specific position(s) responsible for the overall
No
coordination, implementation, and revision to the Plan.
t
Responsibilities for all components of the Stormwater Plan are documented and
position(s) assignments provided.
No
---
t
The permittee is current on payment of invoiced administering and compliance
r
monitoring fees (see Stormwater e-payments on DEMLR MS4 web page).
Yes
---
Town staff have not been operating under a Stormwater Management Plan.
t
The permittee evaluated the performance and effectiveness of the program
least
No
components at annually.
Ir�p�e>tn�ll��t�c�t�
If yes, the permittee used the results of the evaluation to modify the program
Not
components as necessary to accomplish the intent of the Stormwater Program.
Applicable
_
Did the permitted MS4 discharges cause or contribute to non -attainment of an
Not
applicable water quality standard?
Reviewed
-
If yes, did the permittee expand or better tailor its BMPs accordingly to address
Not
the non -attainment?
Applicable
--
No documented history of annual reports was made available at the time of the audit. One annual report for 2018119 was
available.
1 f
The permittee kept the Stormwater Plan up to date.
No
---
�di�rrf���r
The permittee notified DEMLR of any updates to the Stormwater Plan.
No
--
No Stormwater management plan has been implemented by the permittee.
The permittee kept an up-to-date version of its Stormwater Plan available to the
E?Il@ SIOlPSMdtll
No
--
Division and the public online.
#Et1t
The online materials included ordinances, or other regulatory mechanisms, or a list
identifying the ordinances, or other regulatory mechanisms, providing the legal
Partial
---
`
authority necessary to implement and enforce the requirements of the permit.
NCS000393 Dallas MS4 Audit 20191220 Page 4 of 21

01 ON ling
ROM
No Stormwater Management Plan had been maintained and implemented at the time of the audit. Links to Gaston County
ordinance and information were available on the Dallas website.
��
Did DEMLR require a modification to the Stormwater Plan?
q
Not
Applicable
---
r
If yes, did the permittee complete the modifications in accordance with the
Not
established deadline?
Applicable
Are any control measures implemented by an entity other than the permittee?
Yes
2 and 14
If yes, is there a written agreement in place?
Yes
2 and 14
Gaston County implements the Construction and Post -Construction requirements of the permit.
t `
The permittee maintained written procedures for implementing the six minimum
Nocontrol
measures.
t
Written procedures identified specific action steps, schedules, resources and
No
---
responsibilities for implementing the six minimum measures.
No written procedure was maintained by the permittee for the six minimum control measures.
[/
The permittee maintained documentation of all program components including, but
lPr€i t� f
not limited to, inspections, maintenance activities, educational programs,
Partial
Various
gntQtt
implementation of BMPs, enforcement actions etc., on file for a period of five years.
The permittee maintained documentation of many aspects of permit compliance, but many were lacking documentation and
implementation. See below for more information.
i [F
The permittee submitted annual reports to the Department within twelve months
l�iltp
from the effective date of the permit (See Section 111.B. for the annual reporting
No
---
period specific to this MS4).
The permittee submitted subsequent annual reports every twelve months from the
No
---
scheduled date of the first annual report submittal.
The Annual Reports included appropriate information to accurately describe the progress, status, and results
r 3
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
r
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
Applicable
_
schedules and plans for the year following each report.
NCS000393_Daltas IVIS4 Audit_20191220 Page 5 of 21

{
2. An adequate description and justification of any proposed changes to the
This include descriptions information for
Not
Stormwater Plan. will and supporting
the proposed changes and how these changes will impact the Stormwater
---
Applicable
r
}` Plan (results, effectiveness, implementation schedule, etc.).
3. Documentation of any necessary changes to programs or practices for
assessment of management measures implemented through the Stormwater
Not
--
Applicable
Plan.
4. A summary of data accumulated as part of the Stormwater Plan throughout
the year along with an assessment of what the data indicates in light of the
Not
--
Applicable
Stormwater Plan.
5. An assessment of compliance with the permit, information on the
establishment of appropriate legal authorities, inspections, and enforcement
Not
--
z
Applicable
actions.
Cdthtand htf,ry
fX
of submitted annual reports was not available at the time of the audit.
,
itirr>iaipdrting
U
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
Not
2. A description of the effectiveness of each program component.
-
Applicable
3. Planned activities and changes for the next reporting period, for each Not --
program component or activity. Applicable
Not
4. Fiscal analysis. --
Applicable
A documented history of submitted annual reports was not available at the time of the audit. The only annual report available
was the 2018-2019 annual report.
NCS000393 Dallas MS4 Audit 20191220 Page 6 of 21

��i�� Ed�atron and Qutreach
i rr rt+ av Johnny Denton, Town Engineer
Bill Trudnak, Public Works Director
Barry Webb, Project Coordinator
Zackery Foreman, WTP Superintendent
" Joseph Alm, Stormwater Administrator
# The permittee defined goals and objectives of the local Public Education and
'iflxit No ---
Outreach Program based on community wide issues.
C�bj�ct�ves
No SWMP has been maintained with defined goals.
11b
The permittee maintained a description of the target pollutants and/or stressors and
tt F'plluiaifs r"
likely sources.
No
---
No SWMP has been maintained with a description of Target Pollutants.
it B 2.
The permittee identified, assessed annually and updated the description of the target
TrgiiatAOdte��es =
audiences likely to have significant storm water impacts and why they were selected.
No
---
No SWMP has been maintained with a description of the target audience.
tldes�i3eCttiaj"
The permittee described issues, such as pollutants, the likely sources of those
�#t l,dt>3fir[1/
pollutants, potential impacts, and the physical attributes of stormwater runoff in
Yes
10
Corittercial"kstteS":
their education/outreach program.
Outreach efforts are covered in the Regional Stormwater Partnership's annual report.
The permittee promoted and maintained an internet web site designed to convey the
�t�lr1itit
Yes
program s message.
Weti Site
http://www.dallasnc.net/page/Storm_Water
The permittee distributed stormwater educational material to appropriate target
1kibG £tUC1tf?Ii
Partial
9
groups.
Education material was distributed in the form of brochures, inserts, newsletter and handouts.
tf.
The permittee promoted and maintained a stormwater hotline/helpline for the
#olin%H+Ip tin8 "";
purpose of public education and outreach.
Yes
---
http://www.dailasnc.net/pagelStorm_Water
The permittee's outreach program, including those elements implemented locally or
ic�bl�c duCEion
through a cooperative agreement, included a combination of approaches designed to
Not
---
WO
reach the target audiences.
Reviewed
Rragram
For each media, event or activity, including those elements implemented locally or
through a cooperative agreement the permittee estimated and recorded the extent
Partial
10
of exposure.
NCS000393_Dallas MS4 Audit_20191220 Page 7 of 21

NCS000393 Dallas MS4 Audit 20191220 Page 8 of 21

Johnny Denton, Town Engineer
Joseph Alm, Stormwater Administrator
The permittee maintained a written IDDE Program. I No I ---
If yes, the written program includes provisions for program assessment and Not
evaluation and integrating program. Applicable
The permittee has not maintained a written IDDE program.
t.
The permittee maintained an IDDE ordinance or other regulatory mechanism(s) that
No ---
�, provides the legal authority to prohibit illicit connections and discharges to the MS4.
7777d
If yes, the ordinance applies throughout the corporate limits of the permittee. Not
[Permit Part I.D] Applicable -
Adequate legal authority was not located in the Gaston County Ordinance, and the Town of Dallas' Ordinance was not available
at the time of the audit.
`
The permittee maintained a current map showing major outfalls and receiving
Storm Sewer
No
15
Sy�fi<e» �t(ap
streams.
No map has been maintained by the permittee, however a current map is being created.
'
The permittee maintained a program for conducting dry weather flow field
JLiry Wthe! Flow=
observations in accordance with written procedures.
No
---
Froglrarrt "
No dry weather flow field observations program has been maintained or implemented by the permittee.
The permittee maintained written procedures for conducting investigations of
Inuet��a#I4tt
identified illicit discharges.
No
---
Frocedaresv ,
No written procedure for illicit discharges has been maintained by the permittee.
i1 Af
For each case of an illicit discharge or potential illicit discharge, the permittee documented and tracked the
Track and
following:
Not
fnuesattoit5
1. The date(s) the illicit discharge was observed
A livable
Pp
2. The results of the investigation
Not
-
Applicable
3. Any follow-up of the investigation
Not
Applicable
Not
4. The date the investigation was closed
Applicable
No documented case was presented at the time of the audit.
NCS000393_Dallas MS4 Audit_20191220 Page 9 of 21

I~m�iltty�e
The permittee implemented and documented a training program for appropriate
Fr�ptng
municipal staff who, as part of their normal job responsibilities, may come into
Yes
u
contact with or otherwise observe an illicit discharge or illicit connection.
5 town personnel are CSI certified inspectors.
The permittee informed public employees of hazards associated with illegal
discharges and improper disposal of waste.
Yes
9
The permittee informed businesses of hazards associated with illegal discharges and
Yes
9
improper disposal of waste.
"
The permittee informed the general public of hazards associated with illegal
Yes
9
discharges and improper disposal of waste.
It
The permittee promoted, publicized, and facilitated a reporting mechanism for the
Pulblt 1f3#1F1 `
public to report illicit discharges.
Yes
---
N�ec�an�sm
The permittee promoted, publicized, and facilitated a reporting mechanism for staff
to report illicit discharges.
Yes
---
The permittee established and implemented response procedures for citizen
req uests/reports.
No
---
Complaint procedures follow once calls are received, but no written procedure is in ploce.
http://www.dallasnc.net/page/Storm_Water
The permittee implemented a mechanism to track the issuance of notices of violation
art#ir@itttll
No
---
and enforcement actions administered by the permittee.
If yes, the mechanism includes the ability to identify chronic violators for
Not
initiation of actions to reduce noncompliance.
Applicable
A documented history of NOVs was not available at the time of the audit.
NCS000393 Dallas MS4 Audit 20191220 Page 10 of 21

Joseph Alm, Stormwater Administrator
Johnny Denton, Town Engineer
Bill Trudnak, Public Works Director
Implementation (check all that apply):
❑ The permittee implements the components of this minimum measure.
® The permittee relies upon another entity to implement the components of this minimum measure: Gaston County
❑ 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
❑ Water Supply Watershed 11 (WS-11) —15A NCAC 28 .0214
❑ Water Supply Watershed III (WS-III) —15A NCAC 2B .0215
❑ 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 26 .0258
❑ Randleman Lake Water Supply Watershed Nutrient Management Strategy —15A NCAC 2B .0251
❑ Universal Stormwater Management Program —15A NCAC 2H .1020
Ordinance(s) (check all that apply):
The permittee utilizes the following ordinances and/or regulatory authority to fulfill post construction minimum measure program
requirements throughout the MS4 permitted area (check all that apply):
❑ DEQ model ordinance
® MS4 designed post -construction practices that meet or exceed 15A NCAC 02H .1000.
❑ DEQ approved comprehensive watershed plan
❑ DEQ approved ordinance for a deemed -compliant Program (see list above)
Instructions:
For MS4s not implementing a S.L. 2006-246 deemed -compliant program, complete only the Permit Citation section below.
For MS4s implementing a S.L. 2006-246 deemed -compliant program, complete the Session Law 2006-246 section below. If the MS4
does not implement a deemed -compliant program throughout the entire MS4 permitted area, then complete the Permit Citation
section below for the permitted area(s) not covered under the S.L. 2006-246 deemed -compliant program.
NCS000393—Dallas MS4 Audit_20191220 Page 11 of 21

Comments
The permittee implements deemed -compliant Program requirements in
Not
accordance with the applicable 15A NCAC rules. Reviewed -
The permittee implements deemed -compliant Program requirements throughout
Not
<< the entire MS4 area (If not, also complete the Permit Citation section below.) Reviewed
The permittee applies deemed -compliant Program requirements to all federal,
€€ state and local government projects within the permitted MS4 area who do not Not -
Reviewed
have their own NPDES stormwater permit.
The permittee included deemed -compliant Program reporting in their MS4 Annual
Reports.
The permittee included deemed -compliant Program implementation in their
Not
Stormwater Management Plan. Reviewed
The permittee maintained an ordinance or other regulatory mechanism designed
to meet the objectives of the Post -Construction Site Runoff Controls Stormwater Yes 12
Management Program.
If yes, the ordinance applies throughout the corporate limits of the permittee
(Verify permit coverage area listed in Part I.D of permit and modify Yes 12
accordingly).
The permittee has the authority to review designs and proposals for new
development and redevelopment to determine whether adequate stormwater Yes 12 and S
control measures will be installed, implemented, and maintained.
The permittee has the authority to request information such as stormwater plans,
inspection reports, monitoring results, and other information deemed necessary to
No ---
evaluate compliance with the Post -Construction Stormwater Management
Program.
- The permittee has the authority to enter private property for the purpose of
inspecting at reasonable times any facilities, equipment, practices, or operations No ---
related to stormwater discharges.
After review, is was found that the Gaston County SW Ordinance did not contain adequate legal authority to meet permit
The permittee utilizes strategies which include SCMs appropriate for the MS4.
SCMs comply with 15A NCAC 02H .1000.
Yes 8
Yes 12
NCS000393 Dallas MS4 Audit 20191220 Page 12 of 21

PfJSt•�:QC15��l�CtlCii`I Sl'�l' ���fl� CQit'�f"+�`##�S
i1.,2c
The permittee conducted site plan reviews of all new development and
'[�11ilttuus
redeveloped sites that disturb greater than or equal to one acre (including sites
Yes
5 and 13
that disturb less than one acre that are part of a larger common plan of
development or sale).
If yes, the site plan reviews addressed how the project applicant meets the
performance standards.
Yes
12
If yes, the site plan reviews addressed how the project will ensure long-term
Yes
12
maintenance.
F.F.
The permittee maintained an inventory of projects with post construction
InWi tftJO
structural stormwater control measures installed and implemented at new
Yes
13
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
13
requirements.
tieetl'Resfrictions ;.
The permittee provided mechanisms such as recorded deed restrictions and
No
protective covenants that ensure development activities will maintain the project
---
and protec�iv�
consistent with approved plans.
Caver�ants. ,
No documented mechanism was made available at the time of the audit.
The permittee implemented or required an operation and maintenance plan for
M@Ci8IilStTi;#O
the long-term operation of the SCMs required by the program.
Yes
12
Require Lang t�ri�
Clpertionaid
The operation and maintenance plan required the owner of each SCM to perform
Maiini#enance
and maintain a record of annual inspections of each SCM.
Yes
5
Annual inspection of permitted structural SCMs are required to be performed by a
qualified professional.
No
---
After review of the Gaston County Ordinance by Gaston County staff, all permit requirements were not located.
11
The permittee conducted and documented inspections of each project site covered
#nspection$Of
under performance standards, at least one time during the permit term (Verify this
Yes
4
5tru rat; , .
is o permit condition in Part II.F.2.g of permit and modify accordingly).
Storltturer G9ntttl
Before issuing a certificate of occupancy or temporary certificate of occupancy, the
permittee conducted apost-construction inspection to verify that the permittee's
performance standards have been met or a bond is in place to guarantee
Yes
8
completion(Verify this is a permit condition in Part II.F.2.g of permit and modify
accordingly.
The permittee developed and implemented a written inspection program for SCMs
installed pursuant to the post -construction program(Verify this is a permit
No
---
condition in Part II.F.2.g of permit and modify accordingly.
The permittee documented and maintained records of inspections.
Yes
4
The permittee documented and maintained records of enforcement actions.
Not
Applicable
No written procedure for the Post -Construction Site Runoff Controls has been maintained.
NCS000393_Dallas MS4 Audit_20191220 Page 13 of 21

fl.li " The permittee made available through paper or electronic means, ordinances,
dieaionl) post -construction requirements, design standards checklists, and other materials
I[atrlal� and appropriate for developers.
Partial
Traeirttg�r2Z Note: New materials maybe developed by the permittee, or the permittee may use
4Icipts materials adopted from other programs and adapted to the permittee's new
development and redevelopment program.
http://www.gastongov.com/government/departments/natural_resources/stormwater_control.php
None documented.
The permittee tracked the issuance of notices of violation and enforcement Not
actions. Applicable
If yes, the tracking mechanism included the ability to identify chronic violators Not
for initiation of actions to reduce noncompliance. Applicable
The permittee fully complies with post construction program requirements on its
Yes
own publicly funded construction projects.
Does the MS4 have areas draining to Nutrient Sensitive Waters (NSW) pursuant to Not
15A NCAC 02H .0150? Reviewed
If yes, does the permittee use SCMs that reduce nutrient loading in order to Not
meet local program requirements. Reviewed
If yes, does the permittee also still incorporate the stormwater controls Not
required for the project's density level. Reviewed
If yes, does the permittee also require documentation where it is not feasible to Not
use SCMs that reduce nutrient loading. Reviewed
The permittee ensured that the design volumes of SCMs take into account the
Yes
runoff at build out from all surfaces draining to the system.
Where "streets" convey stormwater, the permittee designed SCMs to be sized to
Not
treat and control stormwater runoff from all surfaces draining to the SCM including
Reviewed
streets, driveways, and other impervious surfaces.
5
NCS000393 Dallas MS4 Audit 20191220 Page 14 of 21

�. _ 1
}f +`
���ktp�llr.A�lQ 11
#'f�fPitR. T °RRI �
.� _ �:vc.�H" .. •vu.� ��r.� w, t e _ �,.' , r—. tT�.�, i.._.....�...._ ...rz.. .< '6.-. , ..._ �T 4 ,e _.-....� r...-..._...`Y.,--- _., _
l
Johnny Denton, Town Engineer
Bill Trudnak, Public Works Director
w�
�=
_� _
r The permittee maintained a current inventory of facilities and operations owned
1= 1btvC and operated by the permittee with the potential for generating polluted Partial 13
stormwater runoff.
List of SW ponds included some permittee facilities, but a list just for permittee facilities was not made available at the time of
the audit.
,� -
The permittee maintained and implemented an O&M program for municipally
�pealgrii
owned and operated facilities with the potential for generating polluted
No
---
[tt+Bt+{i1
stormwater runoff.
If yes, the 0&M program specifies the frequency of inspections.
Not
-
Applicable
If yes, the 0&M program specifies the frequency of routine maintenance
Not
requirements.
Applicable
--
-
If yes, the permittee evaluated the O&M program annually and updated it as
Not
necessary.
Applicable
The permittee did not maintain an O&M program for municipal facilities.
pt Re*Qn�
The permittee had written spill response procedures for municipal operations.
Partial
---
Pro��t(ures _v
#I Greet
The permittee evaluated existing and new BMPs that reduce polluted stormwater
FfQetl�ri# Pulii %'
runoff from municipally -owned streets, roads, and public parking lots within its
No
---
p�tkttig+�
corporate limits annually.
Mr�e�arrc€�
If yes, the permittee evaluated the effectiveness of existing and new BMPs
Not
based on cost and the estimated quantity of pollutants removed.
Applicable
---
The permittee did not evaluate and document any review of BMPs.
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.
CQn- yang Systems
The permittee did not maintain an O&M plan for the stormwater system.
The permittee maintained a current inventory of municipally -owned or operated
Strrai �;
structural stormwater controls installed for compliance with the permittee's post-
Yes
13
5torawter-`Gtsntrtiis:'
construction ordinance.
NCS000393_Dallas MS4 Audit_20191220 Page 15 of 21

PQ11t1�:rren��riQt�ui��ieirlii� �Iai�c>�p;I�lJIM
l
a
The permittee maintained and implemented an 0&M program for municipally-
ille�IrStrlsur owned or maintained structural stormwater controls installed for compliance with
No ---
Stomvilat�CC�tr1 the permittee's post -construction ordinance. If yes, then:
The 0&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
Not
stormwater controls in accordance with the schedule developed by permittee.
Applicable
--
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
--
''� ,'
The permittee ensured municipal employees are properly trained in pesticide,
PtG1deC+tE3t1E8
herbicide and fertilizer application management.
Yes
7
±dq� Ferfi�ltter
Itcattn
The permittee ensured contractors are properly trained in pesticide, herbicide and
Not
fertilizer application management.
Reviewed
--
The permittee ensured all permits, certifications, and other measures for
Not
applicators are followed.
Reviewed
--
The permittee implemented an employee training program for employees involved
C8t11i[>1
in implementing pollution prevention and good housekeeping practices.
No
---
11i 2i�
The permittee described and implemented measures that prevent or minimize
1/Fft1 aid
contamination of stormwater runoff from all areas used for vehicle and equipment
Yes
---
�qu>IpmentGlea�i�n `;
cleaning.
Vehicles are washed at local carwashes.
NCS000393 Dallas MS4 Audit 20191220 Page 16 of 21

Facility Name: Date and Time of Site Visit:
Public Works and WWTP December 4, 2019
Facility Address: Facility Type (Vehicle Maintenance, landscaping, etc.):
700 Ferguson Street
Dallas, North Carolina 28034 Public Works / WWTP
Name of MS4 inspector(s) evaluated: Most Recent MS4 Inspection (List date and name of inspector):
Bill Trudnak N/A
i�t�me{s� andl"�tie(s); ©f Facility �tep�`esenta>rive{s} Present.�ur)ng the Site;: Vise#
Name Title
Bill Trudnak Public Work Director
-"`_N�,- �-`�',rc'� `-' -3—a �s `� .-�-�4 -� '`�'`�n..?- - - - �' .,. �i',�, � �.7r•`�.. z' -� - _ �'" ,ems.=-� z
Ii����(�ty i7ocumerttatonj'fran�rig �. -, - {
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific?
No
What type of stormwater training do facility employees receive? How often?
None noted.
insp�ctnr Train►ngjKnowieeige : ;
What type of stormwater training does the MS4 inspector receive? How often?
CSI certification training and renewals.
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
titsprYctiart Procedur"es
No
NCS000393_Dallas MS4 Audit_20191220 Page 17 of 21

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
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
irfspectrvn Results '
Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)?
Yes. The facility must obtain coverage under an NPDES General Industrial Stormwater Permit. Housekeeping and possible offsite
waste issues were observed and discussed.
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
Not Reviewed.
NCS000393 Dallas MS4 Audit 20191220 Page 18 of 21

5�t� Veit E�r�luatiQ�n ��' C?r���
Outfall ID Number`. Date and Time of Site Visit:
None given. December 4, 2019
Outfall Location: Outfall Description (Pipe Material/Diameter, Culvert, etc.):
Corner of Maple and Gibbs Street Concrete headwall.
Receiving Water: Is Flow Present? If So, Describe (Color, Approximate Flow Rate,
Long Creek, Class C Sheen, Odor, Floatables/Debris, etc.):
Yes. Clear
Most Recent Outfall Inspection/Screening (Date):
None
Days Since Last Rainfall: Inches:
Not evaluated N/A
Name of MS4 Inspector(s) evaluated:
Bill Trudnak
Inspectgr 1 r n�ngf knai r[ei ge
What type of stormwater training does the MS4 inspector receive? How often?
CSI certification renewal.
Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations?
Yes
Inspection. Pirocedures
Does the inspector's process include the use of a checklist or other standardized form?
No
Does the inspector's process include taking photos?
No
Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they?
No
Irtspectian,Results
Did the outfall inspection result in any work orders or maintenance requests? If so, for what issue(s)?
No
Will a follow-up outfall inspection be conducted? If so, for what reason?
Yes. Routine.
NCS000393 Dallas MS4 Audit 20191220 Page 19 of 21

Site Name: Date and Time of Site Visit:
Bojangles December 4, 2019
Site Address: SCM Type:
1017 Dallas-Cherryville Hwy. Dry detention basin
Dallas, North Carolina 28034
Most Recent MS4 Inspection (Include Date and Entity):
None
Name of MS4 Inspector(s) evaluated: Most Recent MS4 Enforcement Activity (Include Date):
Joseph Alm None
�Uarne(sj and- T#t1e(s)' of S#te Representatives) Present Tour#ng the,ite Uit. " ,
Name Title
None
� I3oCi#rn+�t#tat#on
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
inspec#or 'fra#r#ir�gjK#to�irletige
What type of stormwater training does the MS4 inspector receive? How often?
None discussed.
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
inspect#on Procedures .,, __ '
Does the MS4 inspector's process include the use of a checklist or other standardized form? What format?
No
Does the MS4 inspector's process include taking photos?
No
NCS000393 Dallas MS4 Audit 20191220 Page 20 of 21

�rt'.'Cl��e#r,l�va��ra��c�r�� Pn�t„�"c�r�±hra�r�n�frrirtni€�r��['�►tt�r�l lt� n�;,.. v:
Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections?
Yes
Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge?
Yes
Did the MS4 inspector miss any obvious operation and maintenance deficiencies? If so, explain:
No
I��ies/ConentsjRecc�iendaiior�s
NCS000393_Dallas MS4 Audit_20191220 Page 21 of 21

Example Council Resolution of Commitment to Implement a Compliant NPDES MS4 Program
Resolution No
Date Adopted
RESOLUTION AFFIRMING THE COUNCIL'S SUPPORT
REGARDING IMPLEMENTATION OF A COMPLIANT NPDES MS4 STORMWATER PROGRAM
A RESOLUTION to develop and implement a compliant stormwater management program that meets
the requirements of the 004At National Pollutant Discharge Elimination System (NPDES) Municipal
Separate Storm Sewer System (MS4) Permit number NCS## to discharge stormwater, inclusive of the
required Stormwater Management Plan to be prepared by the 10*0 and approved by the North
Carolina Department of Environmental Quality.
WHEREAS, Section 402(p) of the federal Clean Water Act requires NPDES permits for stormwater
discharges from municipal separate storm sewer systems; and
WHEREAS, in North Carolina, NPDES Permits are issued by the North Carolina Department of
Environmental Quality; and
WHEREAS, the North Carolina Department of Environmental Quality issued the [1064N,, its fh tc
NPDES MS4 Permit for discharge of stormwater on DATE; and
WHEREAS, the N(4FA1V1'1= was issued Notice of Violation number NOV-####f ## on t)ATIj for
noncompliance with the issued NPDES MS4 Permit; and
WHEREAS, the [14NAtf acknowledges the specific Notice of Violation requirement to obtain anew
individual NPDES MS4 Permit; and
WHEREAS, the MS41tilAM, acknowledges the specific Notice of Violation requirement to conduct a self -
audit of permit compliance for the balance of permit requirements not specifically audited by the North
Carolina Department of Environmental Quality, and to develop a draft Stormwater Management Plan to
comply with Section 402(p)(3)(B)(iii) of the Clean Water Act, 40 CFR 122.34(b) and NPDES MS4 Permit
requirements, and to submit its draft Stormwater Management Plan to the North Carolina Department
of Environmental Quality no later than t�C}i S 1At NO i ato for review and approval; and
WHEREAS, the M~ acknowledges the specific Notice of Violation requirement to adopt a Council
Resolution to implement a compliant and enforceable stormwater management program as defined by
both the NPDES MS4 Permit number NCS## and the required new Stormwater Management Plan, and
said resolution is to be submitted to the North Carolina Department of Environmental Quality no later
than 6Q[yFrct`N4Utai; and
WHEREAS, the It41ATV1 acknowledges the requirement to provide adequate funding and staffing to
implement a Stormwater Management Program that complies with its NPDES MS4 Permit and approved
Stormwater Management Plan; and
WHEREAS, the AMacknowledges that North Carolina Department of Environmental Quality
enforcement action and penalties could result from non-compliance with the specific requirements in
Notice of Violation number NOV ### ##; and

Example Council Resolution of Commitment to Implement a Compliant NPDES MS4 Program
WHEREAS, the IVI O" acknowledges that any North Carolina Department of Environmental Quality
enforcement action and penalties may not prohibit the U.S. Environmental Protection Agency from
taking its own enforcement action for non-compliance with the issued NPDES MS4 Permit.
NOW, THEREFORE, BE IT RESOLVED that the Council of the (UIS4N_ * hereby affirms its support for
development and implementation of a compliant NPDES MS4 Stormwater Program.
NAME, Mayor
Stormwater Program Administrator
lAt�, Town Manager
NAW, Town Clerk
ADOPTED BY the City Council of thet#4NAtt, North Carolina the day of 2019 and
signed in authentication thereof the day of 2019.

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Town of Dallas
Attention: Rick Coleman, Mayor
210 North Holland Street
Dallas, North Carolina 28034
NORTH CAROLINA
Environmental Quality
January 10, 2020
70161370 0000 25919571
Subject: NOTICE OF VIOLATION (NOV-2019-PC-0778)
Town of Dallas
NPDES MS4 Permit No. NCS000393
Gaston County
Dear Mr. Coleman:
On December 4, 2019, staff from the North Carolina Department of Environmental Quality
(DEQ) conducted a compliance audit of the Town of Dallas National Pollutant Discharge
Elimination System (NPDES) Municipal Separate Storm Sewer System (MS4) Permit. For your
reference, a copy of the MS4 Program Audit Report issued by DEQ is enclosed with this notice.
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 Town of Dallas 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 management program.
A sample council resolution with the minimum requirements is enclosed with this letter. An
original signed document must be submitted to DEQ.
North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
®'EQI� Asheville Regional Office 1 2090 U.S. Highway 70 I Swannanoa, North Carolina 28778
�xrHcrwa�ru \ .:rr� ono � -

Notice of Violation
Town of Dallas
January 10, 2020
Page 2 of 3
(3) Submit documentation for review and comment within one hundred twenty (120) calendar days
from the date of receipt of this letter:
a. Conduct a self -audit which includes, at a minimum, an evaluation of compliance with the
permit conditions found in Section E: Construction Site Runoff Controls; Section F: Post -
Construction Site Runoff Controls. The self -audit must be documented utilizing the DEQ
standard MS4 Permit Compliance Audit Report Template.
b. Develop a Draft Stormwater Management Plan (S %W) 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 H 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 Town of
Dallas 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 Isaiah.reed a,ncdenr.gov, or to:
DEQ-DEMLR Stormwater Program
Attn: Isaiah Reed
2090 U.S. Highway 70
Swannanoa, North Carolina 28778
If the Town of Dallas 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
($23, 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 143-21 S. 6AJ. Please note that compliance with the requirements of this
NOD and/or issuance of civil or criminal penalties levied by DEQ does not preclude the
EPA from carrying out its own enforcement case against the permittee.

Notice of Violation
Town of Dallas
January 10, 2020
Page 3 of 3
Thank you for your attention to this matter. Should you have any questions, please contact
Isaiah Reed at [phone] or IsaiA.reed@,ncdenr.gov.
Sincerely,
Zahid Khan, CPM, CPESC, CPSWQ
Regional Engineer
Division of Energy, Mineral and Land Resources
Enclosures: DEQ MS4 Program Audit Report (December 4, 2019, Town of Dallas)
Copy of NPDES MS4 Permit No. NCS000393
Sample Council Resolution
cc: [e-mail]
Jeanette Powell, DEMLR MS4 Program Coordinator
Alaina Morman, DEMLR Stormwater Compliance & Enforcement
DEMLR NPDES MS4 Permit Laserfiche File

r�
0
3
u
}O
�Og
Blow
o
m six,