NCS000449_Cramerton NOV-2022-PC-0072_20220321

DocuSign Envelope ID: 14D93F7D-1210-4A10-9D28-659E54BAEBFE
ROY COOPER
Governor•
ELIZABETH S. BISER
Secreta?y
BRIAN WRENN
Director
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Town of Cramerton
Attention: David Pugh, Town Manager
155 North Main Street
Cramerton, North Carolina 28032
NORTH CAROL.INA.
Environmental Quality
March 16, 2022
7020 3160 0000 3277 1263
Subject: NOTICE OF VIOLATION (NOV-2022-PC-0072)
Town of Cramerton
NPDES MS4 Permit No. NCS000449
Gaston County
Dear Mr. Pugh:
On February 23, 2022, staff from the North Carolina Department of Environmental Quality (DEQ) conducted
a compliance audit of subject National Pollutant Discharge Elimination System (NPDES) Municipal Separate
Storm Sewer System (MS4) Permit. The audit identified 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. As such, the permittee is required to complete the following actions:
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.
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.
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.2.f. of the current permit.
North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
D.- E Mooresville Regional Office 1 610 East Center Avenue, Suite 3011 Mooresville, North Carolina 28115
704-663-1699

DocuSign Envelope ID: 14D93F7D-1210-4A10-9D28-659E54BAEBFE
Notice of Violation
Town of Cramerton
March 16, 2022
Page 2 of 3
c. The Municipal SCM Operation and Maintenance Program Plan, as required in Part II, Section A.7. and
Section G.21. of the current permit.
d. Self -evaluate the permit components that were not reviewed by DEQ for compliance and submit the
results within one hundred twenty (120) calendar days from the date of receipt of this letter. The Part II
of the MS4 Phase II Audit Template on the DEQ stormwater web site can be used for this purpose.
The specific sections that should be self -audited include:
Section E: Construction Site Runoff Controls;
ii. Section F: Post -Construction Site Runoff Controls;
iii. Section H: Total Maximum Daily Loads (TMDLs).
e. 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 self -audit.
4. Submit an NPDES MS4 permit application for whichever comes first:
a. At least one hundred eighty (180) days prior to permit expiration, or
b. Within thirty (30) days of receiving written DEQ concurrence that the submitted SWMP documents a
compliant stormwater management program and the MS4 should submit the application including a
signed Final Draft SWMP. A new 5-year NPDES MS4 permit will be public noticed along with the
Draft Final SWMP.
Respond to comments on the Draft Final SWMP and submit a signed Final SWMP for DEQ approval
and final permit issuance. The final DEQ-approved SWMP shall become an enforceable component of
the NPDES MS4 permit and an Annual Self -Assessment Template that corresponds to the approved
SWMP will be provided.
Required documentation shall be submitted via e-mail to Jeanette.Powell(rncderu.gov, or to:
DEQ-DEMLR Stormwater Program
Attn: Jeanette Powell
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
If the MS4 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

DocuSign Envelope ID: 14D93F7D-1210-4A10-9D28-659E54BAEBFE
Notice of Violation
Town of Cramerton
March 16, 2022
Page 3 of 3
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] [e-mail] or the MS4 Program Coordinator at
Jeanette. Powell( nedenr.gov.
Sincerely,
DocuSigned by:
42CFABFC588C459...
Zahid S. Khan, CPM, CPESC, CPSWQ
Regional Engineer
Land Quality Section
Department of Environmental Quality
Enclosures:
DEQ MS4 Permit Compliance Audit Report
Example Council Resolution
cc Josh Watkins, [e-mail]
DEMLR Stormwater Program Supervisor
[e-mail], DEMLR MS4 Program Coordinator
DEMLR NPDES MS4 Permit Laserfiche File

PROGRAM AUDIT
REPORT
Il���►'IJ�: ►��� � i 1 1 1��
Cramerton, NORTH CAROLINA
155 North Main St.
Cramerton, North Carolina
Audit Date: February 23, 2022
Report Date: March 16, 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

(This page intentionally left blank)
NCS000449 Town of Cramerton MS4 Audit 20220223 i

HU414UGOWGUMMI
AuditDetails..................................................................................................................................................1
PermitteeInformation..................................................................................................................................2
List of 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.............................................................................................14
Site Visit Evaluation: MS4 Outfall No. 1......................................................................................................15
Site Visit Evaluation: MS4 Outfall No. 2......................................................................................................16
AppendixA: Photograph Log.................................................................................................................................17
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 al/ 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.
NCS000449 Town of Cramerton MS4 Audit 20220223 ii

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NCS000449 Town of Cramerton MS4 Audit 20220223 iii

Audit ID Number: Audit Date(s):
NCS000449 Town of Cramerton MS4 Audit 20220223
February 23-24, 2022
Minimum Control Measures Evaluated:
® Program Implementation, Documentation & Assessment
® Public Education & Outreach
® Public Involvement & Participation
® Illicit Discharge Detection & Elimination
❑ Construction Site Runoff Controls — No delegated Sediment and Erosion Control Program
❑ Construction Site Runoff Controls — Delegated Sediment and Erosion Control Program
❑ Post -Construction Site Runoff Controls
® Pollution Prevention and Good Housekeeping for Municipal Operations
❑ Total Maximum Daily Loads (TMDLs)
Field Site Visits:
® Municipal Facilities. Number visited: 2
® MS4 Outfalls. Number visited: 2
❑ 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.
Jesse McDonnell, Environmental Specialist
North Carolina Department of Environmental Quality
Zahid S. Khan, Regional Engineer I North Carolina Department of Environmental Quality
Audit Report Author: Jesse McDonnell
Signature
Audit Report Author: Zahid Khan
Date:
Date
.-j_s I
NCS000449—Town of Cramerton MS4 Audit_20220223 Page 1 of 20

:-s
MS4 Permittee Name: Permit Effective Date: Permit Expiration Date:
Town of Cramerton February 20, 2017 February 19, 2022
Mailing Address: 155 North Main Street
Date of Last MS4 Inspection/Audit:
Cramerton, North Carolina 28032
June 5, 2012
Co-permittee(s), if applicable:
Not Applicable
Permit Owner of Record:
David Pugh, Town Manager
Josh Watkins, Public Works Director Town of Cramerton
1✓ _
Catawba River WS-V
None Known
NCS000449_Town of Cramerton MS4 Audit_20220223 Page 2 of 20

gem
MIN
1 Interlocal Agreement with Gaston County Erosion Control
Prior to
2
Gaston County Stormwater Ordinance
Prior to
3
Public Education and Outreach Data
After
4
Social Media Solicitation
After
5
Cramerton Stormwater Map
After
6
IDDE Report Form
After
7
Inventory of Owned Facilities
After
8
Drain Blocker Purchase
After
9
2018-2021 Annual Reports
After
10
Outfall Inspection from February 23, 2022
During
NCS000449_Town of Cramerton MS4 Audit_20220223 Page 3 of 20

r�'
IN - -:� MEOW,'�-
"� .�s`2= ., �r n .fie ` :_ ���. � b '•4.-.-�, x �-�a ,5�
Josh Watkins, Stormwater Coordinator
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.
The Stormwater Plan identifies a specific position(s) responsible for the overall
No
coordination, implementation, and revision to the Plan.
�# Responsibilities for all components of the Stormwater Plan are documented and
position(s) assignments provided.
NO
The permittee is current on payment of invoiced administering and compliance
monitoring fees (see stormwater e-payments on DEMLR MS4 web page).
Yes
RIMS
Comments: The permittee does have a stormwater fee and budget of approximately $200,000. However, there is only one staff
member with partial responsibility to MS4 program, and this staff member have lot of other job responsibilities to other programs.
The Permittee failed to maintain the Stormwater Management Plan (SWMP) including a list of any responsible persons and their
associated responsibilities.
The permittee evaluated the performance and effectiveness of the program
components at least annually.
If yes, the permittee used the results of the evaluation to modify the program
Not
Y
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
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.
The permittee kept the Stormwater Plan up to date.
No
---
The permittee notified DEMLR of any updates to the Stormwater Plan.
Not
f
Applicable
Comments: The permittee failed to maintain the SWMP. The current SWMP was created in 2010. No updates or changes
have been
made since the creation.
The permittee kept an up-to-date version of its Stormwater Plan available to the
No --
Division and the public online.
NCS000449_Town of Cramerton MS4 Audit_20220223 Page 4 of 20

20 ON
The online materials included ordinances, or other regulatory mechanisms, or a list
p�e�e identifying the ordinances, or other regulatory mechanisms, providing the legal No -
authority necessary to implement and enforce the requirements of the permit.
Comments: The SWMP or other associated documents are not available online.
UK Ail
Did DEMLR require a modification to the Stormwater Plan?
No
---
If yes, did the permittee complete the modifications in accordance with the
Not
3
established deadline?
Applicable
Comments: Not applicable.
�t
Are any control measures implemented by an entity other than the permittee?
Yes
1
t�
If yes, is there a written agreement in place?
Yes
1
Comments: The permittee has an interlocal agreement with Gaston County Natural Resource Department to conduct Erosion and
Sediment Control inspection along with Post -Construction Stormwater Control Measure (SCM) installation.
The permittee maintained written procedures for implementing the six minimum
_
�#
No
---
control measures.
Written procedures identified specific action steps, schedules, resources and
No
---
responsibilities for implementing the six minimum measures.
Comments No documentation of procedures being maintained.
t
The permittee maintained documentation of all program components including, but
not limited to, inspections, maintenance activities, educational programs,
Partial
1-10
�cc�meatc3
implementation of BMPs, enforcement actions etc., on file for a period of five years.
Comments: The permittee has maintained documentation for some areas of the permit but not all areas.
It
The permittee submitted annual reports to the Department within twelve months
1�lp
from the effective date of the permit (See Section III.B. for the annual reporting
Yes
9
tt}
period specific to this MS4).
The permittee submitted subsequent annual reports every twelve months from the
Yes
9
r
scheduled date of the first annual report submittal.
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
x v
of each major component of the Stormwater Plan for the past year and Reviewed
schedules and for the year following each report.
plans
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.).
NCS000449 Town of Cramerton MS4 Audit_20220223 Page 5 of 20

IMOMM ON
3. Documentation of any necessary changes to programs or practices for
assessment of management measures implemented through the Stormwater
Not
-
Reviewed
Plan.
4. A summary of data accumulated as part of the Stormwater Plan throughout
Not
the year along with an assessment of what the data indicates in light of the
Reviewed
Stormwater Plan.
5. An assessment of compliance with the permit, information on the
establishment of appropriate legal authorities, inspections, and enforcement
Not
actions.
Reviewed
..
nittee has submitted annual reports for years 2018-2021 via the BIMS portal.
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
INot
E program component or activity.
Reviewed
--
�
Not
z 4. Fiscal analysis.
Reviewed
-
Comments: Not reviewed.
NCS000449 Town of Cramerton MS4 Audit_20220223 Page 6 of 20

911,
((y(ynmm, mg gq, q gp gggggpp g ;-
.>r -
!� Josh Watkins, Stormwater Coordinator
defined
The permittee goals and objectives of the Local Public Education and
Outreach Program based issues. No ---
on community wide
Comments: No documentation of defined goals and objectives based on community wide issues.
r
The permittee maintained a description of the target pollutants and/or stressors and
� �fttt s
like) sources.
Y
No
---
Comments: No documentation of a target pollutant list being maintained.
�r
11
The permittee identified, assessed annually and updated the description of the target
agA�c�ien
audiences likely to have significant storm water impacts and why they were selected.
No
---
Comments: No documentation of annual assessment.
The permittee described issues, such as pollutants, the likely sources of those
nut
pollutants, potential impacts, and the physical attributes of stormwater runoff in
No
---
#��C['
their education/outreach program.
Comments: No documentation.
The permittee promoted and maintained an internet web site designed to convey the
No
---
program s message.
Comments: No documentation.
Pa1�Cat�
The permittee distributed stormwater educational material to appropriate target
Yes
3
groups.
Comments: The permittee has distributed and documented educational materials being distributed to multiple audience groups at
multiple events.
The permittee promoted and maintained a stormwater hotline/helpline for the
aiBi�i .n -
No
---
purpose of public education and outreach.
Comments The permittee does not maintain a hotline specific for public education and outreach.
The permittee's outreach program, including those elements implemented locally or
through a cooperative agreement, included a combination of approaches designed to
Yes
3,4
reach the target audiences.
For each media, event or activity, including those elements implemented locally or
through a cooperative agreement the permittee estimated and recorded the extent
Yes
3,4
of exposure.
Comments: The permittee distributed educational materials at different events in the town and via social media platforms. The
permittee also partners with Gaston County Natural Resource Department to conduct education events in schools within the Town.
NCS000449_Town of Cramerton MS4 Audit_20220223 Page 7 of 20

NCS000449 Town of Cramerton MS4 Audit_20220223 Page 8 of 20

¢Josh
Watkins, Stormwater Coordinator
Ott
The maintained a written IDDE Program. No ---
} permittee
If yes, the written program includes provisions for program assessment and Not
evaluation and integrating program. Applicable
Comments: The permittee has not maintained a written IDDE program.
ROM
The permittee maintained an IDDE ordinance or other regulatory mechanism(s) that
Yes
2
r
provides the legal authority to prohibit illicit connections and discharges to the MS4.
{
�T[
�
yes, the ordinance applies throughout the corporate limits of the permittee.
If
[Permit Part I.D]
yes
2
Comments: The permittee has adopted and follows the Gaston County Ordinance for IDDE.
F,
The permittee maintained a current map showing major outfalls and receiving
Yes
5
streams.
Comments: The permittee has a current map of stormwater outfalls, conveyance systems and receiving waters.
The permittee maintained a program for conducting dry weather flow field
Ec4111�
No
---
observations in accordance with written procedures.
Comments: The permittee does not have a written program for Dry Weather Flow. However, the permittee does conduct
inspections with a standardized inspection form.
The permittee maintained written procedures for conducting investigations of
►f$tttii
No
---
identified illicit discharges.
Comments: No documentation of written procedures to conduct IDDE investigation.
For each case of an illicit discharge or potential illicit discharge, the permittee documented and tracked the
following:
1. The date(s) the illicit discharge was observed
Yes
6
2. The results of the investigation
Yes
6
3. Any follow-up of the investigation
Yes
6
f
4. The date the investigation was closed
Yes
6
�c
Comments: The permittee does have an inspection and tracking sheet for IDDE investigations conducted.
NCS000449 Town of Cramerton MS4 Audit_20220223 Page 9 of 20

The permittee implemented and documented a training program for appropriate
municipal staff who, as part of their normal job responsibilities, may come into No ---
contact with or otherwise observe an illicit discharge or illicit connection.
Comments: The permittee does not have a training program in place at this time.
The permittee informed public employees of hazards associated with illegal
No
discharges and improper disposal of waste.
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: No documentation,
The permittee promoted, publicized, and facilitated a reporting mechanism for the
No
---
r
public to report illicit discharges.
The permittee promoted, publicized, and facilitated a reporting mechanism for staff
No
to report illicit discharges.
Xl-
The permittee established and implemented response procedures for citizen
requests/reports.
No
---
Comments: No documentation.
'
The permittee implemented a mechanism to track the issuance of notices of violation
Not
and enforcement actions administered by the permittee.
Applicable
X
If yes, the mechanism includes the ability to identify chronic violators for
Not
initiation of actions to reduce noncompliance.
Applicable
Comments: The permittee has not issued any NOV or enforcement actions at this time. The permittee does utilize a program called
iWorQ that can track and look up repeat enforcement actions.
NCS000449_Town of Cramerton MS4 Audit_20220223 Page 10 of 20

x
gut
Josh Watkins, Stormwater Coordinator
3
-.
-9
ME
The permittee maintained a current inventory of facilities and operations owned
aIlt��6rY and operated by the permittee with the potential for generating polluted Yes 7
stormwater runoff.
Comments: The permittee has maintained a list of all municipally owned and operated facilities.
The permittee maintained and implemented an O&M program for municipally
owned and operated facilities with the potential for generating polluted
No
---
v
stormwater runoff.
_Q�
Not
If yes, the O&M program specifies the frequency of inspections.
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
f
necessary.
Applicable
Comments: No documentation.
11
�(� =
The permittee had written spill response procedures for municipal operations.
No
--
QCttix��i���
Comments: No documentation.
iG2," des
The permittee evaluated existing and new BMPs that reduce polluted stormwater
}#ti1
runoff from municipally -owned streets, roads, and public parking lots within its
No
---
Rt[.t _
corporate limits annually.
tt>>
If yes, the permittee evaluated the effectiveness of existing and new BMPs
4
based on cost and the estimated quantity of pollutants removed.
No
---
Comments: No documentation or BMP inspections or annual assessment.
1t�
`The
permittee maintained and implemented an 0&M program for the stormwater
{�&f€tr aai
sewer system including catch basins and conveyance systems that it owns and
No
---
maintains.
Comments: No documentation of weekly inspections.
The maintained a current inventory of municipally -owned or operated
i
tui�t =
permittee
structural stormwater controls installed for compliance with the permittee's post-
Not
Scilrtvutrftr�1
construction ordinance.
Applicable
Comments: The permittee does not own any Stormwater Control Measures.
NCS000449 Town of Cramerton MS4 Audit_20220223 Page 11 of 20

lid
The permittee maintained and implemented an O&M program for municipally -"
3�t�CIC
owned or maintained structural stormwater controls installed for compliance with
Not
ftu€s�trQl
the permittee's post -construction ordinance. If yes, then:
Applicable
_
The 0&M program specified the frequency of inspections and routine
Not
maintenance requirements.
Applicable
PP
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
r
The permittee documented maintenance of all municipally -owned or
Not
maintained structural stormwater controls.
Applicable
Comments: The permittee has not maintained an O&M program because they do not own or maintain any SCMs.
The permittee ensured municipal employees are properly trained in pesticide,
Not
>;
herbicide and fertilizer application management.
Applicable
.
The permittee ensured contractors are properly trained in pesticide, herbicide and
fertilizer application management.
No
---
The permittee ensured all permits, certifications, and other measures for
No
---
applicators are followed.
Comments: The permittee does not apply pesticides, herbicides or fertilizers in house. Products are purchase by the permittee but
used by a third party. No documentation of contractor pesticide license.
The permittee implemented an employee training program for employees involved
J�itlil�tig,
in implementing pollution prevention and good housekeeping practices.
No
---
Comments: The permittee does not have a training program implemented at this time.
ILG.2k
The permittee described and implemented measures that prevent or minimize
t1i5
contamination of stormwater runoff from all areas used for vehicle and equipment
Yes
8
qupnt[eaning -
cleaning.
Comments: The only municipal operation that washes vehicles outside is the fire department. The fire department places a
temporary drain blocker on the storm drain and vacuums up all wash water after washing. All other municipally owned vehicles are
washed at a commercial site.
NCS000449_Town of Cramerton MS4 Audit_20220223 Page 12 of 20

Facility Name: Date and Time of Site Visit:
Public Works February 23, 2022, at 2:00pm
Facility Address: Facility Type (Vehicle Maintenance, Landscaping, etc.):
Eagle Road Public Works Facility
Cramerton, North Carolina
Name of MS4 inspector(s) evaluated: Most Recent MS4 Inspection (List date and name of inspector):
Josh Watkins
endt1e(s} Fc€)styteprsentativ�(srsettfiurrn the S€tl�s€tt
Name Title
Rodney Baker Public Works Director
"77-
Fac�ltjtcurhen#atonj€rain(rfg .. =..
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.
€nspetor Train€rigf know€ed,�e ..
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?
Yes.
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Yes.
€n�pett�ott Procedures
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)?
The facility does not have an SWPPP or similar document.
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.
7777,7
€nspect€on Results
Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)?
Yes, there is a tractor that is leaking hydraulic fluid. The leak needs to be stopped and the tractor put under cover until problem can
be resolved.
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
As soon as possible. Site contact said it will be resolved same day.
NCS000449_Town of Cramerton MS4 Audit_20220223 Page 13 of 20

Facility Name: Date and Time of Site Visit:
C. B. Huss Recreation Center February 23, 2022, at 2:35pm
Facility Address: Facility Type (Vehicle Maintenance, Landscaping, etc.):
8 Julian Street Park facility with chemical and landscape equipment storage.
Cramerton, North Carolina
Name of MS4 inspector(s) evaluated: Most Recent MS4 Inspection (Date and Entity):
Josh Watkins
t��me{s) aid Titie(s).of �aciiity iiepresen#atae{s) Present Durtng the Sy#� Visit,
Name Title
Eric Smallwood Parks and Recreation Director
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.
inspeciorTrantngjKn�wledge
What type of"stormwater training does the MS4inspectorreceive? How often?
None.
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
Yes.
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Yes.
-777777,
lnseectictr} Procetures ..'
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)?
The facility does not have a SWPPP or similar document.
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.
Irtseect�on Res�utts . ; ,'
Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)?
Yes, this facility is a pole barn with only three sides covered and a roof. There are oils and chemicals stored out from under cover or
near the open side of the building. A 5-gallon bucket and two 55-gallon drums with unknown contents were on site and uncovered.
The drums were empty and sealed.
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
NCS000449 Town of Cramerton MS4 Audit_20220223 Page 14 of 20

As soon as possible.
Outfall ID Number: Date and Time of Site Visit:
February 23, 2022, at 3:05pm
Outfall location: Outfall Description (Pipe Material/Diameter, Culvert, etc.):
North of Fire Department Kayak Launch 36" RCP
Receiving Water: Is Flow Present? If So, Describe (Color, Approximate Flow Rate,
South Fork of the Catawba River Sheen, Odor, Floatables/Debris, etc.):
Flow is present. This outfall discharges directly into the river. The
outfall is partially submerged in the river. About 1/3 full of
Most Recent Outfall Inspection/Screening (Date): sediment. No oils, sheens, odor or floatables were observed.
Days Since Last Rainfall: Inches:
One day 0.25"
Name of MS4 Inspector(s) evaluated:
Josh Watkins
Mm
Ins}�ectcl`r Tr�>n�ngjKnovirl+�dge.. : __ . _..,
What type of stormwater training does the MS4 inspector receive? How often?
None.
Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations?
Yes.
inspectfon Praeedures
Does the inspector's process include the use of a checklist or other standardized form?
Yes.
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.
Inspe%trc�n Rest�l�s ..
Did the outfall inspection result in any work orders or maintenance requests? If so, for what issue(s)?
Yes, the outfall pipe is about 1/3 full of sediment that needs to be removed.
Will a follow-up outfall inspection be conducted? If so, for what reason?
Yes, periodic re -inspection.
NCS000449 Town of Cramerton MS4 Audit_20220223 Page 15 of 20

Outfall ID Number: Date and Time of Site Visit:
Outfall Location: Outfall Description (Pipe Material/Diameter, Culvert, etc.):
South of the Fire Department Kayak Launch 24" RCP
Receiving Water: Is Flow Present? If So, Describe (Color, Approximate Flow Rate,
South Fork of the Catawba River Sheen, Odor, Floatables/Debris, etc.):
Yes, pipe is partially submerged in the river. No issues were
Most Recent Outfall Inspection/Screening (Date): observed.
Days Since Last Rainfall: Inches:
One day 0.25"
Name of MS4 Inspector(s):
Josh Watkins
Inspetr trart�ngJowledge
What type of stormwater training does the MS4 inspector receive? How often?
None.
Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations?
Yes.
lnspe�iloe� Pra�edue�s
Does the inspector's process include the use of a checklist or other standardized form? Obtain copy.
Yes.
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.
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, periodic reinspection.
NCS000449_Town of Cramerton MS4 Audit_20220223 Page 16 of 20

Photograph 1: Overview of Cramerton Public Works Facility.
Photograph 2: Additional overview of Cramerton Public Works Facility.
NCS000449_Town of Cramerton MS4 Audit_20220223 Page 17 of 20

Photograph 3: Tractor partially stored under cover with a hydraulic leak at public works.
Photograph 4: Inside the public works storage building.
NC5000449_Town of Cramerton MS4 Audit_20220223 Page 18 of 20

Photograph 5: Overview of parks and recreation storage pole barn.
NCS000449_Town of Cramerton MS4 Audit_20220223 Page 19 of 20

Photograph 7: Deicer in bags that are exposed to run off.
Photograph g: Miscellaneous buckets and oils undercover at parks and recreation storage
facility.
NCS000449_Town of Cramerton MS4 Audit_20220223 Page 20 of 20

Example Council Resolution of Commitment to Implement a Compliant NPDES MS4 Program
Resolution No.: _ .0
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: 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 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 I its
NPDES MS4 Permit for discharge of stormwater on [; and
WHEREAS, the was issued Notice of Violation number NOV _'' on for
noncompliance with the issued NPDES MS4 Permit; and
WHEREAS, the MOWN " acknowledges the specific Notice of Violation requirement to obtain a new
individual NPDES MS4 Permit; and
WHEREAS, the Mrs 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 for review and approval; and
WHEREAS, the 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 NCSAw 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 and
WHEREAS, the "01 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, they acknowledges 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 ,"-#,=�#1 ;and

Example Council Resolution of Commitment to Implement a Compliant NPDES MS4 Program
WHEREAS, the � 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 rz hereby affirms its support for
development and implementation of a compliant NPDES MS4 Stormwater Program.
Mayor
Stormwater Program Administrator
Town Manager
Town Clerk
ADOPTED BY the City Council of the = North Carolina the day of 2021 and
signed in authentication thereof the day of 2021.