NCS000444_Lowell MS4 AUDIT REPORT_20191030

MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM AUDIT REPORT
NPDES PERMIT NO. NCS000444
Lowell, NORTH CAROLINA
101 W. 1St Street
Audit Date: October 30, 2019
Report Date: January 6, 2020
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

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
(This page intentionally left blank)
Audit Date: October 30, 2019

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
TABLE OF CONTENTS
AuditDetails..................................................................................................................................................1
PermitteeInformation..................................................................................................................................2
SupportingDocuments..................................................................................................................................3
Program Implementation, Documentation & Assessment...........................................................................4
Public Education and Outreach.....................................................................................................................7
Public Involvement and Participation...........................................................................................................9
Illicit Discharge Detection and Elimination (IDDE)......................................................................................10
ConstructionSite Runoff Controls...............................................................................................................12
Post -Construction Site Runoff Controls......................................................................................................15
Pollution Prevention and Good Housekeeping for Municipal Operations..................................................19
Total Maximum Daily Loads(TMDLs).............................................................
Error! Bookmark not defined.
Site Visit Evaluation: Municipal Facility No. 1.............................................................................................21
Site Visit Evaluation: Municipal Facility No. 2................................................
Error! Bookmark not defined.
Site Visit Evaluation: MS4 Outfall No. 1......................................................................................................23
Site Visit Evaluation: MS4 Outfall No. 2......................................................................................................25
Site Visit Evaluation: Construction Site No. 1..............................................................................................27
Site Visit Evaluation: Construction Site No. 2..............................................................................................28
Site Visit Evaluation: Post -Construction Stormwater Control Measure No.
1............................................29
Site Visit Evaluation: Post -Construction Stormwater Control Measure No.
2............................................30
Appendix A: Supporting Documents
Appendix B: Photograph Log
DISCLAIMER
This audit consists of an evaluation of program compliance with the issued permit and implementation of
the approved Stormwater Management Plan. This audit report does not include a review of all program
components, and program deficiencies in addition to those noted may be present. The permittee is
required to assess program progress and permit compliance, and to implement the approved Stormwater
Management Plan in accordance with the issued permit.
Audit Date: October 30, 2019 ii

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
This page intentionally left blank
Audit Date: October 30, 2019 iii

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
Supporting Documents
Item
Plumber
Document Title
When Provided
(Prior to/During/After)
1
Stormwater Ordinance
Prior
2
Map of Phase II MS4 Outfalls
Prior
3
MoU SW Interlocal Agreement
Prior
4
Regional Stormwater Partnership FY 19 Yearly Report
During
5
Gaston County Department of Natural Resources Educator Yearly Report
During
6
Draft Stormwater Management Plan
During
7
Water Pollution Flyer
During
8
Leaf Collection Flyer
During
9
2 Gaston County Post Construction Stormwater Inspection Reports
During
10
2 Gaston County Construction Stormwater Inspection Reports
During
11
Storm Water Response Forms — IDDE tracking
During
12
Regional Stormwater Partnership Workshop Flyer
During
Audit Date(s): October 30, 2019 Page 3 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
Audit Details
Audit ID Number:
Audit Date(s):
NCS000444_Lowell MS4 Audit_20191030
October 30, 2019
Minimum Control Measures Evaluated:
© Program Implementation, Documentation & Assessment
© Public Education & Outreach
0 Public Involvement & Participation
❑X 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:
❑X Municipal Facilities. Number visited: 1
0 MS4 Outfalls. Number visited: 2
© Construction Sites. Number visited: 2
❑X Post -Construction Stormwater Runoff Controls. Number visited: 2
❑ Other: Number visited: Choose an item.
❑ Other: Number visited: Choose an item.
Inspector(s) Conducting Audit
Name, Title
Oreani gVgn
James Moore
NC DEQ
Lily Kay
NC DEQ
Audit Report Author:
Date:
Signature
Audit Repor Autho •
Date
Signature
L
im
Audit Date(s): October 30, 2019 Page 1 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
Perrnittee Information
MS4 Permittee Name: Town of Lowell
Permit Effective Date: Permit Expiration Date:
02/20/2017 02/19/2022
City, State, ZIP: Lowell, NC 28098
Date of Last M54 Inspection/Audit:
09/26/2014
Co-permittee(s), if applicable:
Permit Owner of Record: Kevin Krouse, City Manager
Primary MS4 Representatives Participating in Audit
Name, Title
Organization
Scott Attaway
Lowell , Development Services Administrator
John Boerger
Gaston County, Sediment Inspector
Jody Alm
Gaston County, Stormwater Administrator
Kevin Krouse
Lowell, City Manager
Thomas Shrewsberry
Lowell, Public Works Director
MS4 Receiving Waters
Waterbody
Classification
Impairments
South Fork Catawba River
N/A
Duharts Creek, UT
N/A
Audit Date(s): October 30, 2019 Page 2 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
Supporting Documents
Item When Provided
NumberDocument Title
0jart®jEurinf/ma:€3o
1 Stormwater Ordinance Prior
2
Map of Phase II MS4 Outfalls
Prior
3
MoU SW Interlocal Agreement
Prior
4
Regional Stormwater Partnership FY 19 Yearly Report
During
5
Gaston County Department of Natural Resources Educator Yearly Report
During
6
Draft Stormwater Management Plan
During
7
Water Pollution Flyer
During
8
Leaf Collection Flyer
During
9
2 Gaston County Post Construction Stormwater Inspection Reports
During
10
2 Gaston County Construction Stormwater Inspection Reports
During
11
Storm Water Response Forms — IDDE tracking
During
12
Regional Stormwater Partnership Workshop Flyer
During
Audit Date(s): October 30, 2019 Page 3 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
Program Implementation, Documentation & Assessment
Staff Interviewed:
Scott Attaway, Development Services Administrator — Office
(Name, Title, Role)
Thomas Shrewsberry, Public Works Director — Field
i�er°railrtaS:if�rt
I>rf}grf�rrj Requirement
S#atus
Supporting
Doe No.
II.A.3
The permittee maintained adequate funding and staffing to implement and manage
Staffing and
the provisions of the Stormwater Plan and meet all requirements of the permit.
Yes
---
Funding
The Stormwater Plan identifies a specific position(s) responsible for the overall
coordination, implementation, and revision to the Plan.
Yes
---
Responsibilities for all components of the Stormwater Plan are documented and
position(s) assignments provided.
Yes
---
The permittee is current on payment of invoiced administering and compliance
monitoring fees (see stormwater e-payments on DEMLR MS4 web page).
Yes
---
The Town pays for the
program through the general funds. The draft SWMP does identify the responsible parties for
implementing parts
of the plan. The Town does not have, nor has it been operating under, an approved Stormwater
Management Plan.
II.A.2 Stormwater
The permittee evaluated the performance and effectiveness of the program
Plan
components at least annually.
No
---
Implementation
and 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
The Town has not documented annual evaluations.
II.A.3
Keeping the
The permittee kept the Stormwater Plan up to date.
No
---
Stormwater Plan
Up to Date
I
The permittee notified DEMLR of any updates to the Stormwater Plan.
I
No
---
Comments (Indicate the date of latest Stormwater Plan and describe the nature of any updates, if applicable).
The Town does not have, nor has it been operating under, an approved Stormwater Management Plan.
Audit Date(s): October 30, 2019 Page 4 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
Program Implementation, Documentation & Assessment
II.A.4 Availability The permittee kept an up-to-date version of its Stormwater Plan available to the
of the Stormwater Division and the public online. No ---
Plan
The online materials included ordinances, or other regulatory mechanisms, or a list
identifying the ordinances, or other regulatory mechanisms, providing the legal
Yes
---
authority necessary to implement and enforce the requirements of the permit.
Comments (Note what materials are available on line)
https://www.lowellnc.com/222/Code-of-Ordinances The Town does not have, nor has it been operating under, an approved
Stormwater Management Plan.
Ii.A.3 & II.A.5
Stormwater Plan
Did DEMrequire a modification to the Stormwater Plan?
NotLR
Reviewed
Modifications
If yes, did the permittee complete the modifications in accordance with the
Not
established deadline?
Applicable
-
The Town does not have, nor has it been operating under, an approved Stormwater Management Plan.
II.A.6 Sharing
Responsibility
Are any control measures implemented by an entity other than the permittee?
Yes
3
If yes, is there a written agreement in place?
Yes
3
Gaston County and Regional Stormwater Partnership implement parts of the Public Education and Outreach minimum control
measure. Gaston County Natural Resources Department implements the Construction and Post Construction Stormwater
minimum control measures.
IL.A.7
The permittee maintained written procedures for implementing the six minimum
Written
control measures.
No
--
Procedures
Written procedures identified specific action steps, schedules, resources and
responsibilities for implementing the six minimum measures.
No
---
The Town has not maintained any written procedures.
111_A
The permittee maintained documentation of all program components including, but
Program
not limited to, inspections, maintenance activities, educational programs,
Partial
3
Documentation
implementation of BMPs, enforcement actions etc., on file for a period of five years.
Comments (List the specific program components that do not have adequate documentation on file and why, if applicable)
Public Education and Outreach - Gaston County Natural Resources Educator keeps a list of all the schools and how many children
she educated, and the Regional Stormwater Partnership publishes a yearly report. Construction Stormwater and Post
Construction Stormwater — Gaston County maintains all records of plan applications, reviews, approvals/disapprovals,
inspections and enforcement actions taken in a database. IDDE —The Town has not had any complaints to document and uses
work orders to document these instances for internally found issues. Public Involvement — No documentation was available, but
storm drain stickering events have taken place and the stickers were observed by NC DEQ staff in the field. Good Housekeeping
— No documentation has been maintained.
111.13
The permittee submitted annual reports to the Department within twelve months
Annual Report
from the effective date of the permit (See Section III.B. for the annual reporting
No
---
Submittal
period specific to this MS4).
Audit Date(s): October 30, 2019 Page 5 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
Program Implementation, Documentation & Assessment
The permittee submitted subsequent annual reports every twelve months from the
scheduled date of the first annual report submittal.
No
---
The Annual Reports included appropriate information to accurately describe the progress, status, and results
of the permittee's Stormwater Plan, including, but not limited the following:
1. A detailed description of the status of implementation of the Stormwater Plan
as a whole. This will include information on development and implementation
Not
of each major component of the Stormwater Plan for the past year and
Applicable
---
schedules and plans for the year following each report.
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
Applicable
-
Plan (results, effectiveness, implementation schedule, etc.).
3. Documentation of any necessary changes to programs or practices for
assessment of management measures implemented through the Stormwater
Not
Applicable
Plan.
4. A summary of data accumulated as part of the Stormwater Plan throughout
the year along with an assessment of what the data indicates in light of the
Not
Applicable
Stormwater Plan.
5. An assessment of compliance with the permit, information on the
establishment of appropriate legal authorities, inspections, and enforcement
Not
---
Applicable
actions.
Comments (Note dates that annual reports cover undercurrent permit and generally describe report deficiencies, if any)
The Permittee has not submitted any annual reports.
IV.B
Annual Reporting
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.
Applicable
---
2. A description of the effectiveness of each program component.
Not
---
Applicable
3. Planned activities and changes for the next reporting period, for each
Not
program component or activity.
Applicable
4. Fiscal analysis.
Not
Applicable
Comments (Note dates that annual reports cover under current permit and generally describe report deficiencies, if any)
Annual reports have not been submitted previously.
Audit Date(s): October 30, 2019 Page 6 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
Public Education and Outreach
Staff Interviewed:
Scott Attaway, Development Services Administrator — festival tents
(Name, Title, Role)
Regional Stormwater Partnership
Gaston county —Erin Hines, Natural Resources Educator
Permit Citation
Program Requi ement
Mattis
� support ng
r3or No.
11.6.2.a
Goals
The permittee defined goals and objectives of the Local Public Education and
and
Objectives
Outreach Program based on community wide issues.
Yes
4, 5, 6
The Town is targeting mechanics shops this year with mailer, training public works personnel — fire and police, contractor does
stormwater page and newsletter development, residential neighborhoods — no dumping stickers, new customer handout,
Freedom festival booth. The Regional Stormwater Partnership (RSP) and the Gaston County Natural Resources educator
supplied annual reports. The County reported how many children were educated in Lowell and the RSP reported advertising
goals and targeting efforts through media.
11.B.2.b
The permittee maintained a description of the target pollutants and/or stressors and
Target Pollutants
likely sources.
Partial
4,5
The Permittee has not maintained a description of target pollutants and/or stressors and likely sources.
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.
Partial
4,5
The Permittee's contractors have target audiences where the RSP targets audiences through media and Gaston County targets
the schools. The Town has distributed Water Pollution and Leaf Collection Fliers.
II.B.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
7,8
Commercial Issues
their education/outreach program.
The Permittee's contractors discuss pollutants, potential sources and impacts with school children. The Town has distributed
Water Pollution and Leaf Collection Fliers to businesses and residents.
11.6.2.e
Informational
The permittee promoted and maintained an internet web site designed to convey the
Partial
---
Web Site
program's message.
https://www.lowelima.gov/170/Stormwater
II.B.2.f
Public Education
The permittee distributed stormwater educational material to appropriate target
Yes
7,8
Materials
groups.
The Town has distributed Water Pollution and Leaf Collection Fliers to businesses and residents.
II.B.2.g
The permittee promoted and maintained a stormwater hotline/helpline for the
Hotline/Help Line
purpose of public education and outreach.
Yes
---
City Hall phone number, website
II.B.2.h
The permittee's outreach program, including those elements implemented locally or
through a cooperative agreement, included a combination of approaches designed to
Yes
---
reach the target audiences.
Audit Date(s): October 30, 2019 Page 7 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
Public Education and Outreach
Public Education
and Outreach For each media, event or activity, including those elements implemented locally or
Program through a cooperative agreement the permittee estimated and recorded the extent Yes 4,5
of exposure.
A cooperative agreement with Gaston County was available and gives them the authority over their construction and post
construction program elements and provides some education in the local schools. A contract with RSP has been established for
the public education and outreach program element.
Audit Date(s): October 30, 2019 Page 8 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
Public Involvement and Participation
Staff Interviewed:
Scott Attaway, Development Services Administrator
(Name, Title, Role)
Permit Citation
Program Requirement
Status Supporting
Doc No.
II.C.2.a Volunteer
Community
The permittee included and promoted volunteer opportunities designed to promote
Involvement
ongoing citizen participation.
No ---
Program
The Permittee has not included and promoted volunteer opportunities designed to promote citizen participation.
II.C.2.b
Mechanism for
The permittee provided and promoted a mechanism for public involvement that
Not
Public
provides for input on stormwater issues and the stormwater program.
Applicable
Involvement
II.C.2.c
The permittee promoted and maintained a hotline/helpline for the purpose of public
Hotline/Help Line
involvement and participation.
Yes
---
City Hall phone number, website
Audit Date(s): October 30, 2019 Page 9 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
Illicit Discharge Detection and Elimination (IDDE)
Staff Interviewed:
Thomas Shrewsberry, Public Works Director
(Name, Title,
Scott Attaway, Development Services Administrator
Role)
Permit Citition
Program Requirement
Status ng No.
F
II.D.2.a
IDDE Program
The permittee maintained a written IDDE Program.
Partial11
If yes, the written program includes provisions for program assessment and
evaluation and integrating program.
No ---
The Town investigates complaints and has a Storm Water Response form to fill out through the process. However, no illicit
discharges have been reported to the Town and an example was not available.
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
1
Legal Authorities
If yes, the ordinance applies throughout the corporate limits of the permittee.
[Permit Part I.D]
Yes
---
II.D.2.c
The permittee maintained a current map showing major outfalls* and receiving
Storm Sewer
No
---
System Map
strea ms.
Comments
A 2004-2005 map was developed by Gaston county which had pinned discharges, but the inventory is missing. Public works also
maintains books on 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
Public works investigates water leaks due to cost, but also looks for illicit discharges during dry weather. The Town employees
walk all ditches checking for leaks and testing for chlorine.
II.D.2.e
The permittee maintained written procedures for conducting investigations of
Investigation
identified illicit discharges.
No
---
Procedures
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 dates) the illicit discharge was observed
Yes
11
2. The results of the investigation
Yes
11
3. Any follow-up of the investigation
Yes
11
4. The date the investigation was closed
Yes
11
Audit Date(s): October 30, 2019 Page 10 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
Illicit Discharge Detection and Elimination (IDDE)
II.D.2.e Employee
Training
The permittee implemented and documented a training p p g program for appropriate
municipal staff who, as part of their normal job responsibilities, may come into
Yes
contact with or otherwise observe an illicit discharge or illicit connection.
An in-house training video from Partnership about illegal dumping and illicit discharges and discussion by already trained
employees.
II.D.2.h
The permittee informed public employees of hazards associated with illegal
Public Education
discharges and improper disposal of waste.
Yes
7
The permittee informed businesses of hazards associated with illegal discharges and
improper disposal of waste.
Yes
7
The permittee informed the general public of hazards associated with illegal
discharges and improper disposal of waste.
Yes
7
Some employees have been trained on pesticide application and a few have had stormwater pollution training.
II.D.2.i
The permittee promoted, publicized, and facilitated a reporting mechanism for the
Public Reporting
public to report illicit discharges.
Yes
---
Mechanism
The permittee promoted, publicized, and facilitated a reporting mechanism for staff
to report illicit discharges.
Yes
---
The permittee established and implemented response procedures for citizen
requests/reports.
Yes
---
Website
II- D.2.i
The permittee implemented a mechanism to track the issuance of notices of violation
Enforcement
and enforcement actions administered by the permittee.
Yes
---
If yes, the mechanism includes the ability to identify chronic violators for
initiation of actions to reduce noncompliance.
Yes
---
The Town uses a spreadsheet, monthly report, work orders, and the receptionist keeps a log on resident accounts.
Audit Date(s): October 30, 2019 Page 11 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
Construction Site Runoff Controls
Staff Interviewed:
Jody Alm, Gaston County Stormwater Administrator
(Name, Title, Role)
John Boerger, Gaston County, Sediment Inspector
Program Delegation Status:
❑X The permittee has a delegated Sediment and Erosion Control Program and implements the North Carolina
Sedimentation Pollution Control Act (SPCA) of 1973 components of this minimum measure (complete the permit
citation and SPCA citation sections).
❑ The permittee does not have a delegated Sediment and Erosion Control Program and relies on DEMLR to comply
with the North Carolina Sedimentation Pollution Control Act (SPCA) of 1973 components of this minimum measure
(complete only the permit citation section).
Permit Citation Program Requirement Status
Supporting'
Doc No.
II.E.3 Construction
Site Runoff Controls The permittee provides and promotes a means for the public to notify the
[NPDES Permit No. appropriate authorities of observed erosion and sedimentation problems (e.g., Yes
3
NCS000435] promoting the existence of the DEQ DEMLR "Stop Mud" hotline).
SPCA Citation
Delegated Program Requirement
Status
supporting
Doc No.
113A-60 Local
erosion and
The permittee has adopted an ordinance or other regulatory mechanism to enforce
Yes
1
sedimentation
the erosion and sedimentation control program.
control programs (a)
If yes, the ordinance meets or exceeds the minimum requirements of the
SPCA.
Yes
1
If yes, the ordinance applies throughout the corporate limits of the permittee.
[Permit Part I.D]
Yes
1
§ 113A-60 Local
erosion and
The permittee collects a fee paid by each person who submits an erosion and
sedimentation
sedimentation control plan.
Yes
1
control programs (d)
$300 non-refundable plan review processing fee for each acre of disturbed land or any part of an acre of disturbed land
(including off -site borrow and waste areas). No processing fee will be charged for a revised plan unless the revised plan contains
an increase in the number of acres to be disturbed.
Audit Date(s): October 30, 2019 Page 12 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
Construction Site Runoff Controls
113A-60 Local
Has any person initiated a land -disturbing activity (within the permittee's
erosion and
jurisdiction) for which an erosion and sedimentation control plan is required in the
No
---
sedimentation
absence of an approved plan?
control programs (e)
If yes, the permittee has notified the North Carolina Sedimentation Control
Not
Commission of all such cases.
Applicable
-
Has the permittee determined that a person engaged in a land -disturbing activity
has failed to comply with an approved erosion and sedimentation control plan?
No
-
If yes, has the permittee referred any such matters to the North Carolina
Not
Sedimentation Control Commission for inspection and enforcement?
Applicable
113A-61 Local
The permittee reviews each erosion and sedimentation control plan submitted to
approval of erosion
them and notifies the person submitting the plan that it has been approved,
Yes
3
and sedimentation
approved with modification, or disapproved within 30 days of receipt.
control plans
The permittee only approves an erosion and sedimentation control plan upon
determining that it complies with all applicable State and local regulations.
Yes
3
The permittee has disapproved of an erosion and sedimentation control plan in
order to protect riparian buffers along surface waters.
No
If yes, the permittee notified the Director of the Division of Energy,
Not
Mineral, and Land Resources within 10 days of the disapproval.
Applicable
---
§ 113A-61.1
Inspection of land-
The certificate of approval of each erosion and sedimentation control plan
disturbing activity;
approved by the permittee includes a notice of the right to inspect.
Yes
3
notice of violation
(a)
The permittee provides for inspection of land -disturbing activities to ensure
compliance with the SPCA and to determine whether the measures required in an
Yes
10
erosion and sedimentation control plan are effective.
§ 113A-61.1
When the permittee determines that a person engaged in land -disturbing activity
Inspection of land-
has failed to comply with the SPCA, the Permittee immediately issues a notice of
YeT
3
disturbing activity;
violation upon that person.
notice of violation
(c)
Each notice of violation issued by the permittee specifies the date by which the
person must comply.
Yes
3
Each notice of violation issued by the permittee informs the person of the actions
that need to be taken to comply.
Yes
3
Audit Date(s): October 30, 2019 Page 13 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
Construction Site Runoff Controls
113A-64 Penalties Does the permittee issue civil penalties as part of the erosion and sedimentation
Yes ---
program?
Audit Date(s): October 30, 2019 Page 14 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
Post -Construction Site Runoff Controls
Staff Interviewed: Jody Alm, Gaston County Stormwater Administrator
(Name, Title, Rote)
Implementation (check all that apply):
❑ The permittee implements the components of this minimum measure.
© The permittee relies upon another entity to implement the components of this minimum measure: Gaston County Department
of Natural Resources
❑ The permittee implements the following deemed -compliant program(s), which meet NPDES MS4 post -construction
requirements for the areas where implemented and in compliance with the specific program requirements as provided in 15A
NCAC and noted below (Complete Session Law 2006-246 section below):
❑ Water Supply Watershed I (WS-1) — 15A NCAC 2B .0212
❑ Water Supply Watershed II (WS-II) — 15A NCAC 213.0214
❑ Water Supply Watershed III (WS-III) — 15A NCAC 26 .0215
❑ Water Supply Watershed IV (WS-IV) —15A NCAC 2B .0216
❑ Freshwater High Quality Waters (HQW) —15A NCAC 2H .1006
❑ Freshwater Outstanding Resource Waters (ORW) — 15A NCAC 2H .1007
❑ Neuse River Basin Nutrient Sensitive (NSW) Management Strategy —15A NCAC 213 .0235
❑ Tar -Pamlico River Basin Nutrient Sensitive (NSW) Management Strategy — 15A NCAC 213 .0258
❑ Randleman Lake Water Supply Watershed Nutrient Management Strategy —15A NCAC 213 .0251
❑ Universal Stormwater Management Program —15A NCAC 2H .1020
Ordinance(s) (check all that apply):
The permittee utilizes the following ordinances and/or regulatory authority to fulfill post construction minimum measure program
requirements throughout the MS4 permitted area (check all that apply):
❑ DEQ model ordinance
❑ MS4 designed post -construction practices that meet or exceed 15A NCAC 02H .1000.
❑ DEQ approved comprehensive watershed plan
❑ DEQ approved ordinance for a deemed -compliant Program (see list above)
Inctriirflnnc-
For MS4s not implementing a S.L. 2006-246 deemed -compliant program, complete only the Permit Citation section below.
For MS4s implementing a S.L. 2006-246 deemed -compliant program, complete the Session Law 2006-246 section below. If the MS4
does not implement a deemed -compliant program throughout the entire MS4 permitted area, then complete the Permit Citation
section below for the permitted area(s) not covered under the S.L. 2006-246 deemed -compliant program.
Audit Date(s): October 30, 2019 Page 15 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
Post -Construction Site Runoff Controls
Deemed -Compliant
The permittee implements deemed -compliant Program requirements in
Program(s)
accordance with the applicable 15A NCAC rules.
Yes
3
The permittee implements deemed -compliant Program requirements throughout
the entire MS4 area (If not, also complete the Permit Citation section below.)
Yes
3
The permittee applies deemed -compliant Program requirements to all federal,
state and local government projects within the permitted MS4 area who do not
Not
have their own NPDES stormwater permit.
Applicable
The permittee included deemed -compliant Program reporting in their MS4 Annual
Reports.
The permittee included deemed -compliant Program implementation in their
Stormwater Management Plan.
No
---
Comments
Permit Citation
Program Requirement
II.F.2.a
The permittee maintained an ordinance or other regulatory mechanism designed
Legal Authority
to meet the objectives of the Post -Construction Site Runoff Controls Stormwater
Yes
1
Management Program.
If yes, the ordinance applies throughout the corporate limits of the permittee
(Verify permit coverage area listed in Part I.D of permit and modify
Yes
3
accordingly).
The permittee has the authority to review designs and proposals for new
development and redevelopment to determine whether adequate stormwater
Yes
3
control measures will be installed, implemented, and maintained.
The permittee has the authority to request information such as stormwater plans,
inspection reports, monitoring results, and other information deemed necessary to
evaluate compliance with the Post -Construction Stormwater Management
Yes
3
Program.
The permittee has the authority to enter private property for the purpose of
inspecting at reasonable times any facilities, equipment, practices, or operations
Yes
3
related to stormwater discharges.
The Permittee's local program with Gaston County maintains the post construction stormwater minimum control measure.
II.F.2.b
Stormwater Control
The permittee utilizes strategies which include SCMs appropriate for the MS4.
Yes
---
Measures (SCMs)
SCMs comply with 15A NCAC 02H .1000.
Yes
---
Audit Date(s): October 30, 2019 Page 16 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
Post -Construction Site Runoff Controls
II.F.2.c
The permittee conducted site plan reviews of all new development and
Plan Reviews
redeveloped sites that disturb greater than or equal to one acre (including sites
that disturb less than one acre that are part of a larger common plan of
Yes
3
development or sale).
If yes, the site plan reviews addressed how the project applicant meets the
performance standards.
Yes
3
If yes, the site plan reviews addressed how the project will ensure long-term
maintenance.
Yes
3
II.F.2.d
The permittee maintained an inventory of projects with post -construction
Inventory of Projects
structural stormwater control measures installed and implemented at new
Yes
2
development and redeveloped sites.
The inventory included both public and private sector sites located within the
permittee's corporate limits that are covered by its post -construction ordinance
Yes
2
requirements.
ILF.2.e
The permittee provided mechanisms such as recorded deed restrictions and
Deed Restrictions
and Protective
protective covenants that ensure development activities will maintain the project
Yes
3
consistent with approved plans.
Covenants
II.F.2.f
The permittee implemented or required an operation and maintenance plan for
Mechanism to
the long-term operation of the SCMs required by the program.
Yes
9
Require Long-term
Operation and
The operation and maintenance plan required the owner of each SCM to perform
Maintenance
and maintain a record of annual inspections of each SCM.
Yes
9
Annual inspection of permitted structural SCMs are required to be performed by a
qualified professional.
Yes
9
II.F.2.g
The permittee conducted and documented inspections of each project site covered
Inspections of
under performance standards, at least one time during the permit term (Verify this
Yes
9
Structural
is a permit condition in Part II.F.2.g of permit and modify accordingly).
Stormwater Control
Before issuing a certificate of occupancy or temporary certificate of occupancy, the
Measures
permittee conducted a post -construction inspection to verify that the permittee's
performance standards have been met or a bond is in place to guarantee
Yes
9
completion (Verify this is a permit condition in Part II.F.2.g of permit and modify
accordingly.
The permittee developed and implemented a written inspection program for SCMs
installed pursuant to the post -construction program(Verify this is a permit
Yes
9
condition in Part II.F.2.g of permit and modify accordingly.
The permittee documented and maintained records of inspections.
Yes
9
The permittee documented and maintained records of enforcement actions.
Yes
9
Audit Date(s): October 30, 2019 Page 17 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
Post -Construction Site Runoff Controls
11I.F.2.11h
The permittee made available through paper or electronic means, ordinances,
Educational
post -construction requirements, design standards checklists, and other materials
Materials and
appropriate for developers.
Training for
Note: New materials may be developed by the permittee, or the permittee may use
Partial
---
Developers
materials adopted from other programs and adapted to the permittee's new
development and redevelopment program.
Gaston County has all this information on their website and conducts an annual training for developers.
https://www.gastongov.com/government/departments/natural resources/stormwater control.php
II.F.2.11 Enforcement
The permittee tracked the issuance of notices of violation and enforcement
actions.
Yes
---
If yes, the tracking mechanism included the ability to identify chronic violators
for initiation of actions to reduce noncompliance.
Yes
---
Gaston County uses an in-house Database named Cesco.
II.F.3.b
The permittee fully complies with post construction program requirements on its
Not
New Development
own publicly funded construction projects.
Applicable
--
II.F.3.c
Does the MS4 have areas draining to Nutrient Sensitive Waters (NSW) pursuant to
Not
Nutrient Sensitive
15A NCAC 02H .0150?
Applicable
_
Waters
If yes, does the permittee use SCMs that reduce nutrient loading in order to
Not
meet local program requirements.
Applicable
---
If yes, does the permittee also still incorporate the stormwater controls
Not
required for the project's density level.
Applicable
---
If yes, does the permittee also require documentation where it is not feasible to
Not
use SCMs that reduce nutrient loading.
Applicable
Comments (Provide reference for local requirements)
II.F.3.d
The permittee ensured that the design volumes of SCMs take into account the
Design Volume
runoff at build out from all surfaces draining to the system.
Yes
---
Where "streets" convey stormwater, the permittee designed SCMs to be sized to
treat and control stormwater runoff from all surfaces draining to the SCM including
Yes
---
streets, driveways, and other impervious surfaces.
Comments
The design volumes are verified in the application review process.
Audit Date(s): October 30, 2019 Page 18 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
Pollution Prevention and Good Housekeeping fdt Municipal Operations
Staff Interviewed:
Thomas Shrewsberry, Public Works Director
(Name, Title, Rote)
Scott Attaway, Development Services Administrator
Permit CR atio6t
Program CI���yEaar �r�etat
II
E�tn��1s
r�����rE tiny,
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
partial
---
stormwater runoff.
The Permittee was able to verbally list all the municipal owned facilities.
II.G.2.b
The permittee maintained and implemented an 0&M program for municipally
Operation and
owned and operated facilities with the potential for generating polluted
No
---
Maintenance (O&M)
stormwater runoff.
for Facilities
If yes, the 0&M program specifies the frequency of inspections.
No
---
If yes, the 0&M program specifies the frequency of routine maintenance
No
---
requirements.
If yes, the permittee evaluated the 0&M program annually and updated it as
Not
necessary.
Applicable
Comments
The Town has BMPs and conducts employee training, has identified issues and eliminated or protected, keeps spill kits and spill
response station with oil dry, booms, spill containment area to stop flow, hazardous materials are kept in a cabinet, (2) 50-gallon
drums of oil and all hydraulic fluids kept on a containment pallet.
The Town's consultant does a yearly compliance inspection and training — Debbie Rogers, monthly staff safety meeting. Starting
internal inspections with a form and are going to conduct quarterly.
II.G.2.c
Spill Response
The permittee had written spill response procedures for municipal operations.
Partial
---
Procedures
No written spill response procedures were made available, but the Permittee designates containment areas and train employees
about the cleanup process.
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
Yes
---
Parking Lots
corporate limits annually.
Maintenance
If yes, the permittee evaluated the effectiveness of existing and new BMPs
based on cost and the estimated quantity of pollutants removed.
No
---
The Town has removed 500 cubic yard leaves and 570 cubic yards of brush, they walk creeks during the dry, conduct brush
collection weekly, collect bagged leaf and cleaning weekly, run the leaf vac Mon-Thurs from October until February and every
two weeks other than that.
ILG.2.f
The permittee maintained and implemented an O&M program for the stormwater
O&M for Catch
sewer system including catch basins and conveyance systems that it owns and
No
---
Basins and
Conveyance Systems
maintains.
The Town cleans storm drain catch basins before rain events and runs the leaf vac — curb and gutter in the dry monthly.
Audit Date(s): October 30, 2019 Page 19 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
Pollution Preventionjaga& Hojj&eping for Municipal Operations
II.G.2.e
The permittee maintained a current inventory of municipally -owned or operated
Structural
structural stormwater controls installed for compliance with the permittee's post-
Not
-
Stormwater Controls
construction ordinance.
Applicable
No new municipally owned or operated have been built recently.
II.G.2.h
The permittee maintained and implemented an O&M program for municipally -
O&M for Structural
owned or maintained structural stormwater controls installed for compliance with
Not
Stormwater Controls
the permittee's post -construction ordinance. If yes, then:
Applicable
The O&M program specified the frequency of inspections and routine
Not
maintenance requirements.
Applicable
The permittee documented inspections of all municipally -owned or maintained
Not
structural stormwater controls.
Applicable
-
The permittee inspected all municipally -owned or maintained structural
Not
stormwater controls in accordance with the schedule developed by permittee.
Applicable
_
The permittee maintained all municipally -owned or maintained structural
Not
stormwater controls in accordance with the schedule developed by permittee.
Applicable
-
The permittee documented maintenance of all municipally -owned or
Not I
maintained structural stormwater controls.
Applicable
---
II.G.2.i
The permittee ensured municipal employees are properly trained in pesticide,
Pesticide, Herbicide
herbicide and fertilizer application management.
Yes
---
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
applicators are followed.
Yes
---
II.G.2.j
The permittee implemented an employee training program for employees involved
Staff Training
in implementing
p g pollution prevention and good housekeeping practices.
No
---
II.G.2.k
The permittee described and implemented measures that prevent or minimize
Vehicle and
contamination of stormwater runoff from all areas used for vehicle and equipment
Yes
---
Equipment Cleaning
cleaning.
Vehicles are washed at the maintenance facility where the interior bay discharges to the sewer and large vehicles are washed at
the sewer plant.
Audit Date(s): October 30, 2019 Page 20 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
Site Visit Evaluation: Municipal Facility No. 1
Facility Name:
Public Works
Date and Time of Site Visit:
10/31/2019 2:00 pm
Facility Address:
109 Railroad Street. Lowell
Facility Type (Vehicle Maintenance, Landscaping, etc.):
Office, vehicle storage, vehicle maintenance
Name of MS4 inspector(s) evaluated:
James Moore and Lily Kay
Most Recent MS4 Inspection (List date and name of inspector):
N/A
Names) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name
Title
Thomas Shrewsberry
Public Works Director
---777777 Observations`
Facility Documentation/Training
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? Monthly safety meetings and training videos
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often? RSP
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? 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)? N/A
Audit Date(s): October 30, 2019 Page 21 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
Site Visit Evaluation: Municipal Facility No.1
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: outside metal storage and tractor leaks, but under cover
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)? No
If compliance corrective actions were identified, what timeline for correction/follow-up was provided? N/A
Audit Date(s): October 30, 2019 Page 22 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
Site Visit Evaluation: MS4 Outfall No.1
Outfall ID Number:
001
Date and Time of Site Visit:
10/30/2019
Outfall Location:
Catawba Run in River Falls subdivision.
Outfall Description (Pipe Material/Diameter, Culvert, etc.):
48" corrugated metal pipe
Receiving Water:
South Fork Catawba River
Is Flow Present? If So, Describe (Color, Approximate Flow Rate,
Sheen, Odor, Floatables/Debris, etc.):
Good flow approximately 20 gal/min, no sheen, floatables, debris,
or odor
Most Recent Outfall Inspection/Screening (Date):
Days Since Last Rainfall:
Raining at time of inspection
Inches:
Name of MS4 Inspector(s) evaluated: Thomas Shrewberry, Public Works Director
Observations
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often? Yes, Gaston County Annual Meeting
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? No
Does the inspector's process include taking photos? No
Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they? No
Audit Date(s): October 30, 2019 Page 23 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
Site Visit Evaluation: MS4 Outfall No.1
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, periodic inspection
Notes/Comments/Recommendations
Audit Date(s): October 30, 2019 Page 24 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
Site Visit Evaluation: MS4 Outfall No. 2
Outfall ID Number: Date and Time of Site Visit:
002
10/30/2019
Outfall Location: Outfall Description (Pipe Material/Diameter, Culvert, etc.):
Gist Street Lowell
(1) 36" concrete pipe, (1) 24" concrete pipe, and (1) 12"
corrugated plastic pipe
Receiving Water: Is Flow Present? If So, Describe (Color, Approximate Flow Rate,
South Fork Catawba River Sheen, Odor, Floatables/Debris, etc.):
Good flow approximately 50 gal/min, no sheen, floatables,
Most Recent Outfall Inspection/Screening (Date): debris, or odor. Good clarity
Days Since Last Rainfall:
Raining at the time of inspection
Name of MS4 Inspector(s):
Thomas Shrewsberry, Public Works Director
Inches:
f Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often? Yes, Gaston County Annual Meeting
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? Obtain copy. No
Does the inspector's process include taking photos? No
Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they? No
Audit Date(s): October 30, 2019 Page 25 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
Site Visit Evaluation: MS4 Outfall No. 2 1
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, periodic inspection
I Notes/Comments/Recommendations I
Audit Date(s): October 30, 2019 Page 26 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
Site Visit Evaluation: Construction Site No.1
Site/Project Name:
Hillbilly's BBQ
Date and Time of Site Visit:
10/30/2019 3:00 pm
Site/Project Address:
305 South Main Street Lowell
Operator: D and E Foods, Inc.
Project Type (Commercial, Industrial, Residential, CIP, Roadway,
etc.):
Commercial
NCG Permit ID Number:
NCG01
Disturbed Acreage:
2.0
Recent Enforcement Actions (Include Date): ,
None
Name of MS4 Inspector(s) evaluated:
John Boerger, Gaston County Sediment Inspector
Name(s) and Title(s) of Site Representative(s) Present During the
Site Visit:
Name
Title
None
Observations
Site Documentation/Training
Does the site have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it site -specific? Yes
Does the site have approved erosion and sedimentation control plans onsite? Are they representative of current site conditions?
Yes
What type of stormwater training do site employees receive? How often? RSP annual meeting.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often? NC State certification
Did the MS4 inspector appear knowledgeable about MS4 and NCGO10000 requirements for construction sites? Yes
Did the MS4 inspector appear knowledgeable about erosion and sedimentation control/stormwater pollution prevention BMPs?
Yes
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist? Yes
Does the MS4 inspector's process include taking photos? Yes
Does the MS4 inspector's process include reviewing approved plans (erosion and sedimentation control and/or SWPPP)? Yes
Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge? Yes
Did the MS4 inspector miss any obvious violations? If so, explain: No
Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing? Yes
Does the MS4 inspector's process include providing construction stormwater educational materials to the site contact? Yes, when
necessary.
Compliance/Enforcement
What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in? N/A
If compliance issues were identified, what timeline for correction/follow-up was provided? N/A
Audit Date(s): October 30, 2019 Page 27 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
Site Visit Evaluation: Construction Site No. 2
Site/Project Name:
River Falls Subdivision Phase II
Date and Time of Site Visit:
10/30/2019
Site/Project Address:
Off Main Street Lowell
Operator:
Dependable Development
Project Type (Commercial, Industrial, Residential, CIP, Roadway,
etc.):
Residential
NCG Permit ID Number:
NCG01
Disturbed Acreage:
15.3
Recent Enforcement Actions (Include Date):
NOV April, 2019 $2500
Name of MS4 Inspector(s) evaluated:
John Boerger, Gaston County Sediment Inspector
Name(s) and Title(s) of Site Representative(s) Present During the
Site Visit.
Name
Title
None
Observations
Site Documentation/Training
Does the site have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it site -specific? Yes
Does the site have approved erosion and sedimentation control plans onsite? Are they representative of current site conditions?
Yes.
What type of stormwater training do site employees receive? How often? Not determined.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often? RSP Annual meeting
Did the MS4 inspector appear knowledgeable about MS4 and NCGO10000 requirements for construction sites? Yes
Did the MS4 inspector appear knowledgeable about erosion and sedimentation control/stormwater pollution prevention BMPs?
Yes.
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist? Obtain copy. Yes
Does the MS4 inspector's process include taking photos? Yes, when needed
Does the MS4 inspector's process include reviewing approved plans (erosion and sedimentation control and/or SWPPP)? Yes
Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge? Yes
Did the MS4 inspector miss any obvious violations? If so, explain: No
Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing? Yes
Does the MS4 inspector's process include providing construction stormwater educational materials to the site contact? Yes, when
necessary.
Compliance/Enforcement
What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in? None
Audit Date(s): October 30, 2019 Page 28 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
Site Visit Evaluation: Post -Construction Stormwater Control Measure No.1
Site Name:
Eco Park
Date and Time of Site Visit:
10/30/2019
Site Address:
109 Kenworthy Avenue
SCM Type:
Sand filter
Most Recent MS4 Inspection (Include Date and Entity):
9/25/2019
Name of MS4 Inspector(s) evaluated:
Jody Alm, Gaston County Stormwater Administrator
Most Recent MS4 Enforcement Activity (Include Date):
N/A
Name(s) and Title(s) of Site Representative(s) Present During the
Site Visit:
Name
Title
N/A
Observations
Site Documentation
Does the site have an operation and maintenance plan? Yes
Does the site have records of annual inspections? Are they performed by a qualified individual? Yes
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often? RSP Annual
Did the MS4 inspector appear knowledgeable about MS4 requirements for post -construction site runoff controls? Yes
Did the MS4 inspector appear knowledgeable about post -construction BMPs (general purpose/function, components, 0&M
requirements, etc.)?
Yes
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form? What format? Yes
Does the MS4 inspector's process include taking photos? Yes
Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections?
Yes
Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge? Yes
Did the MS4 inspector miss any obvious operation and maintenance deficiencies? If so, explain: No
Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing? Yes
Compliance/Enforcement
What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in? None
If compliance issues were identified, what timeline for correction/follow-up was provided? N/A
Audit Date(s): October 30, 2019 Page 29 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 2
Site Name:
Enterprise Car Rental
Date and Time of Site Visit:
10/30/2019
Site Address:
4820 Wilkinson Boulevard
SCM Type:
Sand filter
Most Recent MS4 Inspection (Include Date and Entity):
10/1/2019
Name of MS4 Inspector(s) evaluated:
Jody Alm, Gaston County Stormwater Administrator
Most Recent M54 Enforcement Activity (Include Date):
None
Name(s) and Title(s) of Site Representative(s) Present During the
Site Visit:
Name
Title
None
Observations
Site Documentation
Does the site have an operation and maintenance plan? Yes
Does the site have records of annual inspections? Are they performed by a qualified individual? Yes
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often? RSP Annual
Did the MS4 inspector appear knowledgeable about MS4 requirements for post -construction site runoff controls? Yes
Did the MS4 inspector appear knowledgeable about post -construction BMPs (general purpose/function, components, O&M
requirements, etc.)? Yes
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form? What format? Yes
Does the MS4 inspector's process include taking photos? Yes
Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections?
Yes
Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge? Yes
Did the MS4 inspector miss any obvious operation and maintenance deficiencies? If so, explain: No
Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing? Yes
Compliance/Enforcement
What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in? None
If compliance issues were identified, what timeline for correction/follow-up was provided? N/A
Audit Date(s): October 30, 2019 Page 30 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
APPENDIX A: SUPPORTING DOCUMENTS
Audit Date(s): October 30, 2019 Page 31 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
APPENDIX B: PHOTOGRAPH LOG
Public Works facility
Spill containment point at the Public Works facility with sheen on the stormwater and booms installed
to mitigate the petroleum products. No spills were observed on the parking lot.
Audit Date(s): October 30, 2019 Page 32 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
Spill containment for liquids with a potential to travel outside.
Used motor oil stored elevated to detect leaks and stored in the back of the facility to minimize
any leak from getting outside.
Audit Date(s): October 30, 2019 Page 33 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
An overview of the facility.
The sand filter at Eco Park.
Audit Date(s): October 30, 2019 Page 34 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
The discharge from the Eco Park sand filter.
MS4 Outfall 001 at Gist Street.
Audit Date(s): October 30, 2019 Page 35 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
A close up view of the discharge from MS4 Outfall
An overview of the Enterprise Car Rental.
Audit Date(s): October 30, 2019 Page 36 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
A view of the sand filter at the Enterprise Car Rental.
A view of the discharge from the Enterprise Car Rental sand filter.
Audit Date(s): October 30, 2019 Page 37 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
A view of the Hillbilly's BBQ construction site.
The skimmer basin for the Hillbilly's BBQ construction site.
Audit Date(s): October 30, 2019 Page 38 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
Another view of the Hillbilly's BBQ construction site.
The rain gauge at Hillbilly's BBQ construction site.
Audit Date(s): October 30, 2019 Page 39 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
The concrete washout at Hillbilly's BBQ construction site.
A view of the MS4 outfall 002 with a "No Dumping" sticker.
Audit Date(s): October 30, 2019 Page 40 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
A view of the discharge from MS4 outfall 002.
A view of the South Fork Catawba River.
Audit Date(s): October 30, 2019 Page 41 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
The basin at River Falls subdivision.
River Falls subdivision
Audit Date(s): October 30, 2019 Page 42 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
A view of one inlet into the basin at River Falls subdivision.
The other inlet on the River Falls subdivision basin.
Audit Date(s): October 30, 2019 Page 43 of 44

MS4 Permit Audit Report
Lowell, NC: NPDES Permit No. NCS000444
A view of the discharge from the basin at the River Falls subdivision.
Audit Date(s): October 30, 2019 Page 44 of 44