NCS000429_NOV Letter_20220414

DocuSign Envelope ID: 7C58DF14-23EC-40A3-BFF8-A93CA3275A13
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
BRIAN WRENN
Director
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
NORTH CAROLINA
Env&vnrnentd Quality
April 14, 2022
City of Gastonia
Attention: Michael Peoples, City Manager
Post Office Box 1748
Gastonia, North Carolina 28053-1748
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7020 3160 0000 32771485
7020 3160 0000 32771478
City of Gastonia
Attention: Danon Lawson, Stormwater Administrator
1300 North Broad Street
Gastonia, North Carolina 28053
Subject: NOTICE OF VIOLATION (NOV-2022-PC-0166)
City of Gastonia
NPDES MS4 Permit No. NCS000429
Gaston County
Dear Sirs:
On March 29, 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:
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.
North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
Mooresville Regional Office 1 610 East Center Avenue, Suite 3011 Mooresville, North Carolina 28115
704-663-1699

DocuSign Envelope ID: 7C580F14-23EC-40A3-BFF8-A93CA3275A13
Notice of Violation
City of Gastonia
April 14, 2022
Page 2 of 3
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.
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.e. 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:
i. Section E: Construction Site Runoff Controls;
ii. Section F: Post -Construction Site Runoff Controls;
iii. Section H: Total Maximum Daily Loads.
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.
5. Respond to comments on the Draft Final SWMP and submit a signed Final SWMP for DEQ approval and final
permit issuance. The final DEQ-approved SWMP shall become an enforceable component of the NPDES MS4
permit and an Annual Self -Assessment Template that corresponds to the approved SWMP will be provided.
Required documentation shall be submitted via e-mail to [e-mail], or to:
DEQ-DEMLR Stormwater Program
Attn: Jeanette Powell
1612 Mail Service Center
Raleigh, NC 27699-1612

QocuSign Envelope ID: 7C58DF14-23EC-40A3-BFF8-A93CA3275A13
Notice of Violation
City of Gastonia
April 14, 2022
Page 3 of 3
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 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
[e-mail].
Sincerely,
ED�oc�uSigned�.,bfy':
5BSC459...
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
cc: Lawson, Danon [e-mail]
DEMLR Stormwater Program Supervisor
[e-mail], DEMLR MS4 Program Coordinator
DEMLR NPDES MS4 Permit Laserfiche File

G
MUNICIPAL SEPARATE STORM SEINER SYSTEM (MS4)
PROGRAM AUDIT REPORT
NPDES PERMIT NO. NCS000429
Gastonia, NORTH CAROLINA
1300 N. Broad Street
Audit Date: March 29, 2022
Report Date: April 14, 2022
North Carolina Department of Environmental Quality
Division of Energy, Mineral & Land Resources Stormwater Program
512 N. Salisbury Street, 9th floor
1612 Mail Service Center
Raleigh, NC 27699-1612
{

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NCS000429_Gastonia MS4 Audit 20220404

TABLE OF CONTENTS
AuditDetails..................................................................................................................................................1
PermitteeInformation..................................................................................................................................2
List of Supporting Documents.....................................................
Program Implementation, Documentation & Assessment...........................................................................4
Public Education 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: MS4 Outfall No. 1......................................................................................................16
Site Visit Evaluation: MS4 Outfall No. 2......................................................................................................17
AppendixA: Photograph Log................................................................................................................................18
DISCLAIMER
This audit consists of an evaluation of program compliance with the issued permit and implementation of
the approved Stormwater Management Plan. This audit report does not include a review of all program
components, and program deficiencies in addition to those noted may be present. The permittee is
required to assess program progress and permit compliance, and to implement the approved Storm water
Management Plan in accordance with the issued permit.
kS000429 Gastonia MS4 Audit 20220404

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NCS000429_Gastonia MS4 Audit 20220404 ii't

Audit ID Number: Audit Date(s):
NCS000429_Gastonia MS4 Audit_20220404 March 29-30, 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: Numbervisited: Choose an item.
❑ Other: . Number visited: Choose an �tem.
Inspector(s) ConcluctingAil-
Name, Title
Organization
Jesse McDonnell, Environmental Specialist NCDEQ
Zahid S. Khan, Regional Engineer
NCDEQ
Audit Report Author: Jesse McDonnell
Date:
Signature] : to
April 14, 2022
Audit Report Author: Zahid S. Khan
Date:
-f W`
Signature
April 14, 2022
NCS000429_Gastonia MS4 Audit_20220404 Page 1 of 24

MS4 Permittee Name:
City of Gastonia
Permit Effective Date: Permit Expiration Date:
February Z0, 2017 February 19, 2022
Mailing Address: P.O. Box 1748
Gastonia, North Carolina 28053-1748
Date of Last M54 I nspection/Audit:
June 5, 2012
Co-permittee(s), if applicable:
Permit Owner of Record:
Michael Peoples, City Manager
Name, Title
Organization
Da non Lawson, Stormwater Administrator
City of Gastonia
City of Gastonia
Robert Cloninger, Assistant Director of
Public Works
MS4 Receiving Waters
Anthony Creek
Class B
Impairments
None Known
Blackwood Creek
Class C
None Known
Catawba Creek
Class C
303(d)—Entire branch
Crowders Creek
Class C
303(d) — From SR1108 to NC321
Duharts Creek
Class WS-V
None Known
Kaglor Branch
Class C
None Known
Jule Allen Branch
Class C
None Known
Long Creek
Class C
303(d) — Entire Branch
Shoal Branch
Class C
None Known
NC5000429_Gastonia M54 Audit_20220404 Page 2 of 24

sf Supporting Documents
1 Municipal Stormwater Control Measure Operation and Maintenance Plan Prior to
2
2017-2018 Annual Report
Prior to
3
Stormwater Outfall Map
Prior to
4
City of Gastonia Stormwater Organization Chart/Hierarchy
Prior to
5
Interlocal Agreement with Gaston County for Post -Construction Stormwater
Prior to
6
Gastonia Stormwater Ordinance
Prior to
7
2020-2021 Annual Reports
During
8
Invoice for Mailers
During
9
Public Involvement Advertisements 1-4
During
10
City of Gastonia Website
h ttps: //www. c ityofg a st o n i a. c o m/government/departments/sto rm w at a r. htm I
Prior to
11
Structural Control Measure Map
During
12
Employee Training
During
13
Stormwater Commission Meeting Agendas,
After
14
HANSON Work Order Tracking
After
15
Example Stormwater Pollution Prevention Plan
After
W
NCS000429_Gastonia MS4 Audit_20220404 Page 3 of 24

htf _ Dannon Lawson, Stormwater Administrator
R Robert Cloninger, Assistant Director of Public Works
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
coordination, implementation, and revision to the Plan.
Partial
4
Responsibilities for all components of the Stormwater Plan are documented and
Yes
4
position(s) assignments provided.
TYes
BIMS
The permittee is current on payment of invoiced administering and compliance
monitoring fees (see stormwater e-payments on DEMLR MS4 web page).
Comments: The permittee does not have enough fulltime staff dedicated to the stormwater program to adequately maintain and
document all six minimum control measures. There are 2.5 staff dedicated to the stormwater program. On average, the program
has approximately a $600,000 annual budget obtained from the stormwater utility fee. The permittee has an organization chart,
but the Stormwater Management Plan (SWMP) has not been maintained over the duration of the permit.
t1 A.2 Stormwater
The permittee evaluated the performance and effectiveness of the program
Plan
components at least annually.
No
Implementation
d Evaluation
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
applicable water quality standard?
No
--
If yes, did the permittee expand or better tailor its BMPs accordingly to address
Not
the non -attainment?
Applicable
s'.c.
Comments: No documentation of an annual review of the stormwater program.
II.A.3 Aof
Keeping the -
The permittee kept the Stormwater Plan up to date.
No
---
Stormwater Plan
Lip to Date
The permittee notified DEMLR of any updates to the Stormwater Plan.
Not
Applicable
Comments: The permittee has a SWMP draft from August 2021. The SWMP has not been maintained perthe permit.
The permittee kept an up-to-date version of its Stormwater Plan available to the
Division and the public online.
—
No
NCS000429_Gastonia MS4Audit_20220404
Page 4 of 24

4 Availabll _ The online materials included ordinances, or other regulatory mechanisms, or a list
e Stormwater ' identifying the ordinances, or other regulatory mechanisms, providing the legal Yes 10
authority necessary to implement and enforce the requirements of the permit.
Comments. The permittee does not have the SWMP online. The City of Gastonia has the ordinance and educational materials
available on the stormwater program page.
II.A.3 & II.A.5
Stormwater Plan Did DEMLR require a modification to the Stormwater Plan? No ---
Modifications
If yes, did the permittee complete the modifications in accordance with the
Not
established deadline?
Applicable
—
Comments: No documentation of DEMLR requiring any changes to the SWMP.
6 Sharing
onsibili Are any control measures implemented by an entity other than the permittee?
Yes
5
If yes, is there a written agreement in place?
Yes
5
Comments: The permittee has an interlocal agreement with Gaston County Department of Natural Resources to conduct erosion
and sediment control inspection along with overseeing the installation of post -construction devises.
U The permittee maintained written procedures for implementing the six minimum
control measures.
No
--
Written procedures identified specific action steps, schedules, resources and
responsibilities for implementing the six minimum measures.
No
---
Comments: The permittee has not maintained written procedures or action steps forthe six minimum control measures (MCMs)
throughout the permit cycle. A draft SWMP was created in August 2021 that contains procedures and action steps for the MCMs.
The permittee maintained documentation of all program components including, but
not limited to, inspections, maintenance activities, educational programs,
No
—
implementation of BMPs, enforcement actions etc., on file fora period of five years.
Comments: The permittee does not have documentation of all MCMs over a period of 5 years.
The permittee submitted annual reports to the Department within twelve months
from the effective date of the permit (See Section M.B. for the annual reporting
Yes
2
period specific to this MS4).
The permittee submitted subsequent annual reports every twelve months from the
scheduled date of the first annual report submittal.
yes
7
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 forthe past year and
Reviewed
_
schedules and plans for the year following each report.
NCS000429_Gastonia M54 Audit_20220404 Page 5 of 24

grain Im_
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 orpractices 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
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
actions.
Comments: The permittee submitted annual reports within twelve months of the permit effective date and for all subsequent
years.
IV
nual Reporting kfi 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
4. Fiscal analysis.
Not
Reviewed
—
Comments: This section was not reviewed during this audit.
NCS000429_Gastonia MS4 Audit_20220404 Page 6 of 24

Public Education and 0utreac -
bStaff Interviewed: Dannon Lawson, Stormwater Administrator
PlalTie, Yitie,kta e�,r Robert Cloninger, Assistant Director of Public Works
t�erM �Ci4at[strb sof(nt Yd�gtif a `-.
il.6.2.a
The permittee defined goals and objectives of the Local Public Education and
Goals and No ---
Outreach Program based on community wide issues.
Objectives
Comments: The permittee has not maintained goals and objectives for public education and outreach. Goals have been defined in
the draft SWMP created in August 2021.
11.B.21
The permittee maintained a description of the target pollutants and/or stressors and
Target Pollutants
likely sources.
No
Comments: The permittee has not maintained a description of target pollutants or their likely sources. Target pollutants have been
defined within the draft SWMP created in August 2021.
II.B.2.c
The permittee identified, assessed annually and updated the description of the target
Target Audiences
audiences likely to have significant storm water impacts and why they were selected.
NO
---
Comments: No documentation of annual assessments of target audiences or their potential impact to stormwater.
h'2.d Residential
The permittee described issues, such as pollutants, the likely sources of those
and Industrial/
pollutants, potential impacts, and the physical attributes of stormwater runoff in
Yes
10
Commercial Issues
their education/outreach program.
Comments: The permittee has maintained educational materials/mailers on the website.
II.B.2.e
Informational
IWebInformational
The permittee promoted and maintained an internet web site designed to convey the
No
program's message.
--
Comments: The stormwater program website does not clearly convey the programs message or goals.
1l.6.2.f
Public Education
The permittee distributed stormwater educational material to a
p ppropriate target
yes
8
Materials
groups.
Comments: The permittee obtained and mailed flyers twice a year to all residents of the City of Gastonia.
11.E.2,g
The permittee promoted and maintained a stormwater hotline/helpline for the
Hotline/Help line
purpose of public education and outreach.
No
j Comments: The permittee has not maintained a specific hotline for Education and Outreach program.
II.B.2.h
The permittee's outreach program, including those elements implemented locally or
Public' Education
through a cooperative agreement, included a combination of approaches designed to
No
---
and Outreach
reach the target audiences.
Program
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 permittee partnered with Gaston County Department of Natural Resources and Carolina Regional Stormwater
Partnership to assist with the education of residents in Gastonia. However, there is no documentation of educational materials
publicized or extent of exposure for educational purposes.
NCS000429_Gastonia MS4 Audit_20220404 Page 7 of 24

f 1111@89ol4�k."6G�: urxfl s.zza�,. •5���,�a„"•t, •4 _c, z..
3
¢KA�,
Inteavie+esed: t Dannon Lawson, Stormwater Administrator
Robert Cloninger, Assistant Director of Public Works
i,MM
Community z The permittee included and promoted volunteer opportunities designed to promote Yes 9
Involvement ongoing citizen participation.
program
Comments: The permittee provided multiple stream clean ups for the public to partici pate. These advertisements were done on the
Facebook page of Keep Gastonia Beautiful, Inc.
[.2.b —
Mechanism for
The permittee provided and promoted a mechanism for public involvement that
Yes
13
I Public
provides for input on stormwater issues and the stormwater program.
Involvement
Comments: The permittee has a stormwater committee that meets every two months.These meetings are open to the public and
citizens are encouraged to participate.
rmittee promoted and maintained a hotline/helpline forthe purpose of public
No
MR[involvement
and participation.
Comments: The permittee has not maintained a specific hotline for Public Involvement and Participation.
NCS000429 GastoniaMS4Audit 20220404
Page 8 of 24

1 Illicit Disct���
1 Staff Interview ad: `
Cannon Lawson, Stormwater Administrator
(Name, Title,
Robert Cioninger, Assistant Director of Public Works
Role)
3
i Permit citation
pro am Reeliintreen'i� x
.°�iSattgS`„
IDDE Program -'
The permittee maintained a written IDDE Program.
No ---
If yes, the written program includes provisions for program assessment and
evaluation and integrating program.
No ---
Comments: The permittee has not maintained a written Illicit Discharge Detection and Elimination Program (IDDE).
The permittee maintained an IDDE ordinance or other regulatory mechanism(s) that
II.D.2.b
provides the legal authority to prohibit illicit connections and discharges to the MS4.
Yes
6
Legal Authorities
If yes, the ordinance applies throughout the corporate limits of the permittee.
(Permit PartLD]
Yes
6
Comments: The permittee has maintained an IDDE ordinance that applies throughout the entire corporate limits.
ILD.2.c
The permittee maintained a current map showing major outfalls and receiving
Storm Sewer
Yes
3
System Map
earns.
Comments: The Qermittee has maintained a current map of all major outfalls.
II.D.2.d
The permittee maintained a program for conducting dry weather flow field
Dry Weather Flow
observations in accordance with written procedures.
No
—
Program
Comments: The permittee has not maintained a dry weather flow program or staffing to conduct inspections.
ILD.2.e
The permittee maintained written procedures for conducting investigations of
Investigation
identified illicit discharges.
No
--
Procedures
Comments: The permittee has not maintained IDDE investigation procedures or staffing to conduct investigations.
II.D.2.f
For each case of an illicit discharge or potential illicit discharge,the permittee documented and tracked the
Track and
following:
Document
Investigations
1. The date(s) the illicit discharge was observed
Yes
14
2. The results of the investigation
Yes
14
3. Any follow-up of the investigation
Yes
14
4. The date the investigation was closed
yes
14
Comments: The permittee uses a work order program called HANSON to track potential IDDE. This program does address the items
listed above.
NCS000429_Gastonia MS4 Audit-20220404 Page 9 of 24

G §C a
i2. Employee"' The permittee implemented and documented a training program for appropriate
F municipal staff who, as part of their normal job responsibilities, may come into Yes 12
contact with or otherwise observe an illicit discharge or illicit connection.
Comments: The permittee conducts annual stormwater training for all municipal staff who may observe an illicit discharge while
completing their daily activities.
,r
The permittee informed public employees of hazards associated with illegal
Partial
12
Ph
PublisEducation'
ubldc
discharges and improper disposal of waste.
The permittee informed businesses of hazards associated with illegal discharges and
Partial
10
improper disposal of waste.
The permittee informed the general public of hazards associated with illegal
Yes
8
discharges and improper disposal of waste.
Comments:The permittee educated municipal staff on IDDE during their annual training; however, annual trainings were not
always specific to IDDE. The permittee provided general fliers to the public by mail and has information for businesses on the
website. There is no documentation of educational material being distributed specifically business.
The permittee promoted, publicized, and facilitated a reporting mechanism for the
Partial
10
he Reporting
public to report illicit discharges.
hanism
s
The permittee promoted, publicized, and facilitated a reporting mechanism for staff
to report illicit discharges.
No
---
The permittee established and implemented response procedures for citizen
No
--
equests/reports.
F
Comments: The permittee maintained a general stormwater number to direct all calls. There is no specific hotline or other
reporting mechanism for IDDE. Municipal staff know to upload all illicit discharge to HANSON to generate a work order and
investigation, this procedure is not documented. There are no written procedures for responding to citizen request.
The permittee implemented a mechanism to track the issuance of notices of violation
and enforcement actions administered by the permittee.
No
---
If yes, the mechanism includes the ability to identify chronic violators for
Not
initiation of actions to reduce noncompliance.
Applicable
Comments: The permittee does not have a mechanism to track NOVs or enforcement cases. All enforcement cases are turned over
to zoning or code enforcement. There is currently no enforcement mechanism specificto stormwater.
NCS000429_Gastonia MS4 Audit_20220404 Page 10 of 24

Staff IntervI411F.W9 Dannon Lawson, Stormwater Administrator
(Name, Title, Role) Robert Cloninger, Assistant Director of Public Works
Permit Citation
II.G.2.a The permittee maintained a current inventory of facilities and operations owned
Facility Inventory and operated by the permittee with the potential for generating polluted Yes 1
stormwater runoff.
Comments: The permittee has a map showing each municipally owned facility within the Municipal Stormwater Control Measure
Operation and Maintenance Plan. Aformal list should be created for ease of inspection.
II.G.2.b
The permittee maintained and implemented an O&M program for municipally
Operation and
owned and operated facilities with the potential for generating polluted
Yes
15
Maintenance (O&M)
stormwater runoff.
for Facilities
If yes, the O&M program specifies the frequency of inspections.
Yes
15
If yes, the O&M program specifies the frequency of routine maintenance
requirements.
Yes
15
If yes, the permittee evaluated the 0&M program annually and updated it as
necessary.
Yes
15
Comments: The permittee has an operation and maintenance plan (0&M) for municipally owned stormwater control measures
(SCM). Each facility has an O&M plan specific to that facility.
II.G.2.c
Spill Response
The permittee had written spill response procedures for municipal operations.
Yes
7
15
Procedures
Comments: I he permittee has written spill response procedures that are specific to each municipal facility.
II.G.2.d Streets,
The permittee evaluated existing and new BMPs that reduce polluted stormwater
Roads, and Public
runoff from municipally -owned streets, roads, and public parking lots within its
No
—
Parking Lots
corporate limits annually.
Maintenance
If yes, the permittee evaluated the effectiveness of existing and new BM Ps
based on cost and the estimated quantity of pollutants removed.
No
--
Comments: The permittee does operate two street sweepers daily. No documentation of amount of debris collected was provided.
II.G.2.f
O&M for Catch
The permittee maintained and implemented an O&M program for the stormwater
Basins and
sewer system including catch basins and conveyance systems that it owns and
No
—
GonvRyance Systems..
maintains.
Comments: No documentation of written maintenance for catch basins and conveyance systems. The permittee does implement an
'off right-of-way program' to assist the public with repairs to old, privately owned infrastructure.
II.G.2.d
The permittee maintained a current inventory of municipally -owned or operated
Structural
structural stormwater controls installed for compliance with the permittee's post-
ves
11
Stormwater Controls
construction ordinance.
Comments: The permittee has maintained a map of all SCMs owned and operated by the permittee along with all privately owned
SCMs.
NC5000429—Gastonia M54 Audit_20220404 Page 11 of 24

iti®n'Prevefi
2.e The permittee maintained and implemented an O&M program for municipally -
for Structural owned or maintained structural stormwater controls installed for compliance with Partial 1
jmwater Controls the permittee's post -construction ordinance. If yes, then:
The 0&M program specified the frequency of inspectionsand routine
Yes
1
maintenance requirements.
The permittee documented inspections of all municipally -owned or maintained
structural stormwater controls.
No
--
The permittee inspected all municipally -owned or maintained structural
stormwater controls in accordance with the schedule developed by permittee.
No
--
The permittee maintained all municipally -owned or maintained structural
stormwater controls in accordance with the schedule developed by permittee.
No
--
The permittee documented maintenance of all municipally -owned or
maintained structural stormwater controls.
No
—
Comments: i he permittee has an 0&M program that has not been fully implemented. The O&M program discusses inspection
frequency for all SCMs owned and operated by the permittee. There is no documentation of inspections or maintenance done.
I:G.2.f
The permittee ensured municipal employees are properly trained in pesticide,
Pesticide, Herbicide
herbicide and fertilizer application management.
No
---
and Fertilizer
Application
The permittee ensured contractors are properly trained in pesticide, herbicide and
Not
Management
fertilizer application management.
Applicable
The permittee ensured all permits, certifications, and other measures for
No
---
applicators are followed.
Comments: The permittee ensures all staff who apply pesticide, herbicide or fertilizer are property licensed and trained. The
permittee does not use outside contractors to apply pesticides, herbicides, or fertilizer. No documentation provided.
II.G:2.g
The permitte e implemented an employee training program for employees involved
Staff Training
in implementing pollution prevention and good housekeeping practices.
YesIT
Comments: The permittee conducts annual stormwater training for municipal staff.
aCG.2.h
The permittee described and implemented measures that prevent or minimize
khiclme and
contamination of stormwater runoff from all areas used for vehicle and equipment
No
uipent Cleaning
cleaning.
Comments: The permittee has a vehicle wash station. There is no written procedure to wash all equipment and vehicles in this
location.
NCS000429 Gastonia MS4 Audit 20220404 Page 12 of 24

Facility Name:
Date and Time of Site Visit:
City of Gastonia Garage
March 30, 2022, 10:00am
Facility Address:
Facility Type (Vehicle Maintenance, Landscaping, etc.):
800 North Broad St
Vehicle Maintenance
Gastonia, NC
Name of MS4 inspector(s) evaluated:
Most Recent MS4 Inspection (List date and name of inspector):
Danon Lawson
Name(s) and Title(s) of Facility Representative(s) Present During
the Site Visit:_
Name Title
Steve Huss Garage Supervisor
"= ..-::-. -:.,. ,.:�_.. -"`.--E7bseroations •
Facility Documentation/Training _
Does the facility have a Stormwater Pollution Prevention Plan (SW PPP) or similar document? Is it facility -specific?
Yes.
What type of stormwater training do facility employees receive? How often?
Employees receive Spill Prevention and Response training annually.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
The inspector is a certified SCM inspector certified and Sediment and Stormwater Inspector Certified.
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.
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form?
Yes.
Does the MS4 inspector's process include taking photos?
No pictures were taken at the time of this inspection.
Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)?
Yes. The facilities SWPPP was reviewed.
Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge?
No. The inspector did inspect all outfalls but did not walk the entire facility without prompting.
Did the M54 inspector miss any obvious areas of concern? If so, explain:
The inspector did not walk the entire facility without prompting.
Does the MS4 inspector's process include presenting the inspection findings to the facility contact?
Yes.
inspection Results
Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)?
Yes. The facility is not conducting analytical monitoring per the applicable Industrial Stormwater Permit.
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
The facility needs to begin analytical monitoring according to the Industrial Stormwater Permit during the next rain event.
NCS000429_Gastonia M54 Audit_20220404 Page 13 of 24

pal Facility No. A
The City of Gastonia refers to the area east of the parking lot as a detention basin. However, [his area does not have a riser or other
devise to retain or detain stormwater. This area has an open culvert allowing flows to directly discharge into the stream. This area
does not have the characteristics of a detention of retention BMP. The City of Gastonia noted that this area is on the schedule to
be broueht into current water quality standards.
NCS000429_Gastonia MS4 Audit_20220404 Page 14 of 24

Facility Name:
Date and Time of Site Visit:
Ferguson Park
March 30, 2022, 11:20am
Facility Address:
Facility Type (Vehicle Maintenance, Landscaping, etc.):
1401 Golf Course Drive
Landscaping
Gastonia, NC
Name of MS4 inspector(s) evaluated:
Most Recent MS4 Inspection (Date and Entity):
Danon Lawson
Name(s) and Titles) of Facility Representative(s) Present During
the site Visit:
Name
Title
=ansesvations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific?
Yes.
What type of stormwater training do facility employees receive? How often?
Employees receive Spill Prevention and Response training annually.
Inspector Training/Knowledge
- --- ---- _--- - — - -------.__.._-_--------
What type of stormwater training does the MS4 inspector receive? How often?
The inspector is a certified SCM inspector certified and Sediment and Stormwater Inspector Certified.
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.
Iespect-6n Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form?
Yes.
Does the MS4 inspector's process include taking photos?
No pictures were taken at the time of this inspection.
Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)?
Yes.
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.
Inspection Results
Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)?
Yes, there are two areas of erosion that need to be addressed along the fence line near Catawba Creek.
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
No specific timeline was provided. The erosion issues are not depositing offsite or into Catawba Creek.
NCS000429_Gastonia MS4 Audit_20220404 Page 15 of 24

Visit Evaluation: M54 Outfall N®,1
Outfall ID Number: Date and Time of Site Visit:
March 30, 2022, 1:37pm
or Location:
Outfall Description (Pipe Material/Diameter, Culvert, etc.):
Niblick Road and Union Road
36' RCP storm drain outfall
Receiving Water:
Is Flow Present? If So, Describe (Color, Approximate Flow Rate,
Catawba Creek
Sheen, Odor, Floatables/Debris, etc.):
No Flow was present at the time of this inspection.
Most Recent Outfall Inspection/Screening (Date):
Days Since Last Rainfall:
Inches:
Seven Days
0.38"
Name of M54 Inspector(s) evaluated:
Danon Lawson
ectorTraining/Knowledge _ a
What type of stormwater training does the MS4 inspector receive? How often?
The inspector is a certified SCM inspector certified and Sediment and Stormwater Inspector Certified.
Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations?
Yes.
Inspection Procedures
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 pictures were taken at the time of this inspection.
Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they?
No.
Inspection Results
Did the outfall inspection result in any work orders or maintenance requests? If so, for what issue(s)?
No.
Will a follow-up outfall inspection be conducted? If so, for what reason?
Yes, regular periodic inspections.
NCS000429_Gastonia MS4 Audit_20220404 Page 16 of 24

Outfall ID Number:
Date and Time of Site Visit:
March 30, 2022, 2:OOpm
Outfall Location:
Outfall Description (Pipe Material/Diameter, Culvert, etc.):
Fonda Drive and Freida Lane
Two 24" RCP adjacent 42" culvert
Receiving Water:
Is Flow Present? If So, Describe (Color, Approximate Flow Rate,
Anthony Creek
Sheen, Odor, Floatables/Debris, etc.):
Flow was present from the 42" culvert. This culvert passes water
under Fonda Drive along the drainage channel. No issues were
observed with the flow.
Most Recent Outfall Inspection/Screening (Date):
Days since Last Rainfall:
Inches:
Seven days
0.39"
Name of MS4lnspector(s):
Danon Lawson
What type of stormwater training does the MS4 inspector receive? How often?
The inspector is a certified SCM inspector certified and Sediment and Stormwater Inspector Certified.
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? Obtain copy.
Yes.
Does the inspector's process include taking photos?
No pictures were taken at the time of this inspection.
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.
NCS000429 Gastonia MS4 Audit 20220404 Page 17 of 24

APPENDIX A: Photograph Log
Photograph 1: Overview of City of Gastonia Garage.
NCS000429_Gastonia MS4 Audit_20220404 Page 18 of 24

Photograph 2: Additional overview of City of Gastonia Garage.
Photograph 3: View of fueling island with a spill at City of Gastonia Garage.
Photograph 4: View of bulk oil storage with a floor drain connected to sanitary sewer.
NCS000429_Gastonia MS4 Audit_20220404 Page 19 of 24

Photograph s: View of bulk hydraulic fluid storage without secondary containment.
Photograph 6: View of stormwater basin that does not detain stormwater flow at the City of
Gastonia Garage.
NCs000429_Gastonia M54 Audit_20220404 Page 20 of 24

Photograph 7: Overview of Ferguson Park.
Photograph 8: Additional overview of Ferguson Park with double walled fueling tanks.
NCS000429_Gastonia M54 Audit_20220404 Page 21 of 24

W:.
Photograph 9: Bulk pesticide and herbicide storage indoors, elevated, with drip containment.
Photograph 10: Lawnmower washing station at Ferguson Park with drain that discharges
directly to Catawba Creek.
NCS000429_Gastonia MS4 Audit_20220404 Page 22 of 24

Photograph 11: View of outfall from Ferguson Park baseball fields.
Photograph 12: View of Outfall at Fonda Dr with clear and clean discharge.
NCS000429_Gastonia MS4 Audit_20220404 Page 23 of 24