NCS000421_COMPLIANCE_20071123

STORMWATER DIVISION CODING SHEET
MS4 PERMITS
PERMIT NO.
DOC TYPE
❑FINAL PERMIT
❑ ANNUAL REPORT .
0��APPLICATION
�UC'OMPLIANCE
❑ OTHER
DOC DATE
❑ I.�-3
YYYYMMDD

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Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
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Colcen IL Sullins, Director
Division of Water Quality
November 23, 2007
Derrick Q. Boone
Stormwater Superintendent
City of High Point
211 South Hamilton Street
High Point, North Carolina 27161
Subject: NPDES Permit Number NCS000421
Compliance Evaluation
Dear Mr. Boone;
The North Carolina Department of Environment and Natural Resources (NCDENR), Division
of Water Quality (DWQ), conducted a Municipal Separate Storm Sewer System (MS4) Compliance
Evaluation of the City of High Point on October 23-24, 2007. The compliance evaluation is
conducted to evaluate the City's compliance with the requirements of Section 402(p) of the Clean
Water Act (CWA), 33 U.S.C. § 1342(p), the regulations promulgated there under at 40 Code of
Federal Regulations Part 122.26, and the North Carolina National Pollutant Discharge Elimination
System (NPDES) Permit No. NCS000421. The staff was very helpful during the compliance
evaluation and should be commended on the initiatives they've taken to managing stormwater under
the conditions of the City's permit.
'Phis document provides a summary of the compliance inspection. Results of the compliance
inspection have been divided into categories described below:
• Positive Findings. Findings that exceed expectations.
• Notice of Violation. A notice of violation is for any permit noncompliance that constitutes a
violation of the Clean Water Act and is grounds for enforcement action; for permit
termination, revocation and re -issuance, or modification; or denial of permit coverage upon
renewal application.
• Notice of non-compliance: A finding that could result in a Notice of Violation, a fine or
other enforcement action if corrective action is not taken.
• Deficiency. A deficiency is a finding that would not likely cause a Notice of Violation, a fine,
or other enforcement action. Discrepancies are normally a result of poor management
practices, failure to follow Standard Operating Procedures, and minor differences of
interpretation or administration oversights.
• Discrepancy. A discrepancy is an observation that would require additional information or
review to determine if the city was either in or not in compliance. Discrepancies are often
differences of interpretation or administrative oversights.
• Recommendations: Recommendations represent practices that should be considered to
improve the overall effectiveness of the program.
Wetlands and Stormwater Branch 1617 Mail Service Center Raleigh, NC 27699-1617
lntemet: h2o.enr.state.nc.us 512 N. Salisbury St. Raleigh, NC 27604
An Equal opportunity/Affirmative Action Employer — 50% Recycled110% Post Consumer Paper
Phone [phone]
FAX [phone]

Positive Findings
The City has done an effective job managing stormwater under the conditions of their permit.
All of the six minimum measures had innovative and effective measures that met or exceeded the
permit requirements including. citizen surveys, detailed maps for tracking illicit discharge detection
and elimination program, and a very effective construction and post construction program. The City
recently completed a survey of municipal operations and in the process of completing a
comprehensive evaluation of municipal operations. The City of High Point has also taken the
initiative to report all Spills and SSO's reaching storm drains or surface waters to the town's
stormwater section. The city has developed general stormwater educational material for schools and
homeowners and plans to identify and target businesses likely to have a significant stormwater
impact. The City has put together excellent Stormwater Pollution and Prevention Plan (SPPP) for the
HlTran Bus Service Center. Records of inspections, training and spill response were meticulously
maintained.
_Notice of Violation, Notice of Non -Compliance, and Deficiencies
During the compliance evaluation the compliance evaluation team did not observe any
findings that would result in a Notice of Violation, a Notice of non-compliance, or a Deficiency.
Discrepancies
The city's staff is currently evaluating the City's BMP manual to ensure the manual meets or
exceeds the 2007 State BMP manual. The evaluation will be completed by March 1, 2008, as
requested by the State.
A review of the watershed protection and Phase II elements of ordinance allows for 36% built
upon area (BUA) or 3 dwelling units (du) /acre without requiring stormwater controls. There was
only one development identified as taking advantage of the 36% (BUA) or 3 du/acre. It was within a
watershed that allows 36% BUA or 3 du/acre. There were no instances that development had
requested or been granted 36% BUA or 3 du/acre outside the watershed protection areas (i.e., within
the Phase II designated areas).
One of the objectives for public involvement and participation program is to provide
opportunities for the public, including major economic and ethnic groups, to participate in program
development and implementation. During the compliance evaluation it was not clear if the
Stormwater Services Division had effectively utilized citizen advisory committees for stormwater
related programs. Other than the citizens survey, efforts were directed at reacting to citizen's
complaints or concerns rather than actively soliciting public involvement and participation.
Recommendations
The City has put together excellent educational and training materials for construction site
operators. One of few opportunities the city has to review the training material is during the pre -
construction meeting. We recommend the city develop a standard agenda for pre -construction
meetings which in addition to a review of the plans, schedules, includes a discussion of procedures
for public input, sanctions to ensure compliance, requirements for construction site operators to
implement appropriate erosion and sediment control practices, procedures for site inspection and
enforcement of control measures, and requirements for construction site operators to control waste
such as discarded building materials, concrete truck washout, chemicals, litter, and sanitary waste at
the construction site that may cause adverse impacts to water quality.

As previously noted, the City has put together excellent Storinwater Pollution and Prevention
Plan (SPPP) for the HiTran Bus Service Center. We recommend the city include a record of topics
covered during the training, such as the one attached.
Should you have any questions related to this inspection please feel free to contact me at
919/733-5083, extension 545 or by e-mail at [e-mail].
Sincerely,
Mike Randall
Environmental Engineer
DWQ Stormwater Permitting Unit
cc: John Hennessy, DWQ Assistance and Compliance Oversight
Steve Tedder, DWQ Winston-Salem Regional Office Surface Water Protection Supervisor
Central.Files—_
S_tormwater_and General Permit Unif Filds

TRAINING PROGRAM OUTLINE
Annual training in storm water pollution prevention should be conducted for employees whose job
duties involve working with materials or equipment in storm water discharge areas. Training topics to
be addressed should include, at a minimum, good housekeeping, Spill prevention and response,
proper material handling and storage, and inspections. Training should address specific BMPs for
relevant drainage areas.
Good Housekeeping
C] Review basic cleanup procedures .
❑ Review proper disposal locations
❑ Remind staff of good housekeeping procedures
❑ Be sure employees know where routine cleanup equipment is located
❑ Review areas where outdoor storage of materials is and is not allowed
Spill. Prevention and Response
C] Identify potential spill areas and drainage routes
❑ Familiarize employees with past spill events - why they happened and the environmental
impact
❑ Review emergency contacts and telephone numbers
❑ Review the locations of spill cleanup equipment
❑ Provide incidental spill response training (or Emergency Response Training if applicable)
Materials Handling and Storage
❑ Identify potential pollutant sources (e.g., exposed materials)
❑ Be sure employees are aware of which materials are hazardous and where those materials
are stored
❑ Point out and explain container labels
❑ Tell employees to use the oldest materials first
❑ Explain recycling practices
❑ Demonstrate how valves are "tightly closed" and how drums should be sealed
Inspections
❑ Review inspection procedures
Brief description of training program materials (e.g., film, newsletter course)
A copy of this form must be placed in each attendee's personnel file upon completion of training.

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Qualily
October 15, 2007
Derrick Q. Boone
Stormwater Superintendent
City of High Point
211 South Hamilton Street
4igh Point, North Carolina 27161
Subject: NPDES Permit Number NCS000421
Compliance Evaluation
Dear Mr. Boone;
The North Carolina Department of Environment and Natural Resources (NCDENR),
Division of Water Quality (DWQ), will be conducting a Municipal Separate Storm Sewer System
(MS4) Compliance Evaluation of the City of High Point beginning October 23, 2007 with an in
brief at 9.00 AM and concluding with an out brief on October 24 at 3:00 PM.
The compliance evaluation is conducted to evaluate the City's compliance with the
requirements of Section 402(p) of the Clean Water Act (CWA), 33 U.S.C. § 1342(p), the
regulations promulgated there under at 40 Code of Federal Regulations Part 122.26, and the
North Carolina National Pollutant Discharge Elimination System (NPDES) Permit No.
NCS000421, effective July 1, 2005,
Pursuant to Part V, Section C, paragraph 4, of the permit the permittee shall allow the
Director, or an authorized representative, upon the presentation of credentials and other
documents as may be required by law, to;
(a) Enter upon the pennittee's premises where a regulated facility or activity is located or
conducted, or where records must be kept under the conditions of this permit;
(b) Have access to and copy, at reasonable times, any records of the pennittee that must
be kept under the conditions of this permit;
(c) Inspect at reasonable times any facilities, equipment (including monitoring and
control equipment), practices, or operations of the permittee regulated or required
under this permit; and
(d) Sample or monitor at reasonable times, for the purposes of assuring permit
compliance or as otherwise authorized by the Clean Water Act, any substances or
parameters at any location under the control of the permttee.
N r harolina
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North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet: www.ncwateMuality.or2 Location: 512 N. Salisbury St. Raleigh, NC 27604 Fax [phone]
An Equal OpporlunitylAfSrmative Action Employer — 5M. Recycled/10 k Post Consumer Paper

Attached is a compliance checklist that will be used during the evaluation. If you have any
questions concerning this compliance evaluation, please contact me at telephone number 919/733-5083
ext. 545 or by e-mail at [e-mail].
Sincerely,
Mike Randall
Environmental Engineer
DWQ Stormwater Pennitting Unit
cc: Shelton Sullivan, DWQ Assistance and Compliance Oversight
Steve Tedder, DWQ Winston-Salem Regional Office Surface Water Protection Supervisor
Central Files
Stormwater and General Permit Unit Files