NCS000449_Audit Report and Letter Received_20220330

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Complete items 1, 2, and 3.
Print your name and address on the reverse
so that we can return the card to you.
Attach this card to the back of the mailpiece,
or on the front if space permits.
❑ Agent
41 ❑ Addressee
C. Date of Delivery
Article Addressed to: I I D. Is delivery address different from item 1? ❑ Yes
If YES, enter delivery address below: ❑ No
Town of Cramerton
Attention: David Pugh, Town
155 North Main Street
Cramerton, North Carolina 28032
I
DLR ZK 03242022
3. Service Type
❑ Priority Mail Express®
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❑ Adult Signature
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❑ Adult Signature Restricted Delivery
❑ Registered Mail Restricted
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❑ Collect on Delivery Restricted Delivery
0 Signature ConfirmationTM
❑ Signature Confirmation
7 018 3090 0001 2322 6686 Restricted Delivery
Restricted Delivery
PS Form 3811, July 2015 PSN 7530-02-000-9053
Domestic Return Receipt

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gocuSign envelope ID: 756CC62C-5E1 D-47E7-A945-128FA451 F6DC
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
BRIAN WRENN
Director
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Town of Cramerton
Attention: David Pugh, Town Manager
155 North Main Street
Cramerton, North Carolina 28032
March 24, 2022
7018 3090 00012322 6686
Subject: NOTICE OF VIOLATION (NOV-2022-PC-0072)
Town of Cramerton
NPDES MS4 Permit No. NCS000449
Gaston County
Dear Mr. Pugh:
On February 23, 2022, staff from the North Carolina Department of Environmental Quality (DEQ) conducted
a compliance audit of subject National Pollutant Discharge Elimination System (NPDES) Municipal Separate
Storm Sewer System (MS4) Permit. The audit identified major deficiencies with the specific components of
the MS4 permit that were reviewed, as provided in the attached DEQ MS4 Permit Compliance Audit Report.
This report lists and describes the serious deficiencies with certain components of the MS4 permit, which
constitutes a violation of the Clean Water Act and is grounds for enforcement action.
In accordance with Part VI of the permit and DEQ policy, a new 5-year MS4 permit will be issued in response
to the audit. As such, the permittee is required to complete the following actions:
1. Respond in writing within thirty (30) calendar days from the date of receipt of this notice to
acknowledge these requirements and the intent to comply.
2. Adopt a Council Resolution within sixty (60) calendar days from the date of receipt of this notice. The
resolution must declare support for a compliant stormwater management program. A sample council
resolution with the minimum requirements is enclosed with this letter. An original signed document
must be submitted to DEQ.
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.
North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
Mooresville Regional Office 1610 East Center Avenue, Suite 301 :Mooresville, North -Carolina 28115
704-663.1699

DocuSign Envelope ID: 756CC62C-5E1D-47E7-A945-128FA451F6DC 1 4 0.,
Notice of Violation
Town of Cramerton
March 24, 2022
Page 2 of 3
c. The Municipal S CM Operation and Maintenance Program Plan, as required in Part II, Section A.7. and
Section G.21. of the current permit.
d. Self -evaluate the permit components that were not reviewed by DEQ for compliance and submit the
results within one hundred twenty (120) calendar days from the date of receipt of this letter. The Part II
of the MS4 Phase II Audit Template on the DEQ stormwater web site can be used for this purpose.
The specific sections that should be self -audited include:
i. Section E: Construction Site Runoff Controls;
I Section F: Post -Construction Site Runoff Controls;
iii. Section H: Total Maximum Daily Loads (TMDLs).
e. Develop a Draft Stormwater Management Plan (SWMP) which details specific actions, measurable
goals, and implementation timelines to bring the stormwater management program into compliance
with NPDES MS4 requirements over the new 5-year permit term. The SWMP must be documented
utilizing the DEQ Phase II MS4 SWMP Template. The SWW 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 Jeanette. Powell@udenngov, or to:
DEQ-DEMLR Stormwater Program
Attn: Jeanette Powell
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
If the MS4 fails to meet the aforementioned requirements and/or submits a significantly noncompliant Draft
SWMP, DEQ may proceed with enforcement. As is stated in Part V, Section A.1(c) of the permit:
Under state law, a daily civil penalty of not more than twenty-five thousand dollars ($25, 000) per violation
may be assessed against any person who violates or fails to act in accordance with the terms, conditions, or
requirements of a permit [North Carolina General Statute 143-215.6A]. Please note that compliance with the

pocuSign JEnvglope ID: 756CC62C-5E1 D-47E7 A945-128FA451 F6DC
Notice of Violation
Town of Cramerton
March 241 2022
Page 3 of 3
requirements of this notice and/or issuance of civil or criminal penalties levied by DEQ does not preclude the
EPA from carrying out its own enforcement case against the permittee.
Thank you for your attention to this matter. Should you have any questions, please contact Jesse McDonnell
at [phone] or [e-mail] or the MS4 Program Coordinator at
[e-mail].
Sincerely,
�EDO�CUSlgned�rb�y*
42CFABFC568C459...
Zahid S. Khan, CPM, CPESC, CPSWQ
Regional Engineer
Land Quality Section
Department of Environmental Quality
Enclosures:
DEQ MS4 Permit Compliance Audit Report
Example Council Resolution
cc Josh Watkins, [e-mail]
DEMLR Stormwater Program Supervisor
[e-mail], DEMLR MS4 Program Coordinator
DEMLR NPDES MS4 Permit Laserfiche File

MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM AUDIT REPORT
NPDES PERMIT NO. NCS000449
Cramerton, NORTH CAROLINA
155 North Main St.
Cramerton, North Carolina
Audit Date: February 2% 2022
Report Date: March 24, 2022
North Carolina Department of Environmental Quality
Division of Energy, Mineral & Land Resources Stormwater Program
512 N. Salisbury Street, 9th floor
1612 Mail Service Center
Raleigh, NC 27699-1612

(This page intentionally left blank)
NCS000449 Town of Cramerton MS4 Audit_20220223 ' i

TABLE OF CONTENTS
AuditDetails..................................................................................................................................................1
PermitteeInformation..................................................................................................................................2
Listof Supporting Documents.......................................................................................................................3
Program Implementation, Documentation & Assessment...........................................................................4
PublicEducation and Outreach.....................................................................................................................7
Public Involvement and Participation...........................................................................................................8
Illicit Discharge Detection and Elimination (IDDE)........................................................................................9
Pollution Prevention and Good Housekeeping for Municipal Operations..................................................11
Site Visit Evaluation: Municipal Facility No. 1.............................................................................................13
Site Visit Evaluation: Municipal Facility No. 2.............................................................................................14
Site Visit Evaluation: MS4 Outfall No. 1......................................................................................................15
Site Visit Evaluation: MS4 Outfail No. 2......................................................................................................16
Appendix'A: Photograph Log.................................................................................................................................17
DISCLAIMER
This audit consists of an evaluation of program compliance with the issued permit and implementation of
the approved Stormwater Management Plan. This audit report does not include a review of 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.
NCS000449_Town of Cramerton MS4 Audit_20220223 ii

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NCS000449 Town of Cramerton MS4 Audit 20220223 iii

Audit ID Number: Audit Date(s):
NCS000449—Town of Cramerton MS4 Audit_20220223 February 23-24, 2022
Minimum Control Measures Evaluated:
® Program Implementation, Documentation & Assessment
® Public Education & Outreach
® Public Involvement & Participation
® Illicit Discharge Detection & Elimination
❑ Construction Site Runoff Controls — No delegated Sediment and Erosion Control Program
❑ Construction Site Runoff Controls— Delegated Sediment and Erosion Control Program
❑ Post -Construction Site Runoff Controls
® Pollution Prevention and Good Housekeeping for Municipal Operations
❑ Total Maximum Daily Loads (TMDLs)
Field Site Visits:
9 Municipal Facilities. Number visited: 2
® MS4Outfalls. Number visited: 2
❑ Construction Sites. Number visited: Choose an item.
❑ Post -Construction Stormwater Runoff Controls. Number visited: Choose an tam.
❑ Other: Number visited:
Cl Other: Number visited:
Inspector(s) Conducting Audit
Name. Title
Organization
Jesse McDonnell, Environmental Specialist north Carolina Department of Environmental Quality
Zahid S. Khan, Regional Engineer
North Carolina Department of Environmental Quality
Audit Report Author: Jesse McDonnell
Date:
SignatureTT .���
Audit Report Author: Zahid Khan
Date
Signature S �L
'� 1 \2Z
NCS000449 Town of Cramerton MS4 Audit_20220223 Page 1 of 20

MS4 Permittee Name:
Town of Cramerton
Permit Effective Date: Permit Expiration Date:
February 20, 2017 February 19, 2022
Mailing Address:155 North Main Street Date of Last MS4 I nspection/Audit:
Cramerton, North Carolina 28032 June 5, 2012
Co-permittee(s), if applicable:
Permit Owner of Record:
Not Applicable
David Pugh, Town Manager
, Primary '
gating in Audit
Name, Title
Organization
Josh �Natkins, Public Works Director
Town of Cramerton
— —
MS4 Receiving Waters
Waterbodv
Classification
I Impairments
Catawba River
WS-V i None Known
NCS000449_Town of Cramerton MS4 Audit_20220223 Page 2 of 20

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

�� n .p
gra�fl 6¢�ap8�mentatio a, �ia.�1mend� tim w. Assessment
Intenvdewed ` Josh Watkins, Stormwater Coordinator
7
The permittee maintained adequate funding and staffing to implement and manage
No .he 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.
No
--
Responsibilities for all components of the Stormwater Plan are documented and
Dosition(s) assignments provided.
No
--
The permittee is current on payment of invoiced administering and compliance
Ty"
BIMS
monitoring fees (see stormwatere-payments on DEMLR MS4 web page).
Comments: The permittee does have a stormwater fee and budget of approximately $200,000. However, there is only one staff
member with partial responsibility to MS4 program, and this staff member have lot of other job responsibilities to other programs.
The Permittee failed to maintain the Stormwater Management Plan (SWMP) including a list of any responsible persons and their
associated responsibilities.
11.A.2 Stormwater
The permittee evaluated the performance and effectiveness of the program
Plan
components at least annually.
No
--
Implementation
" nd 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
Comments: No documentation.
II.A.3 -
eping the The permittee kept the Stormwater Plan up to date. No ---
rmwater Plan
Up to Date
The permittee notified DEMLR of any updates to the Stormwater Plan.
Not
Applicable
4,
Comments: The permittee failed to maintain the SWMP. The current SWMP was created in 2010. No updates or changes have been
made since the creation.
The permittee kept an up-to-date version of its Stormwater Plan available to the
Division and the public online.
No
NCS000449_Town of Cramerton MS4 Audit_20220223 Page 4 of 20

Program
II.A.4 Avallab The online materials included ordinances, or other regulatory mechanisms, or a list
of the Stormwater" identifying the ordinances, or other regulatory mechanisms, providing the legal No
Plan authority necessary to implement and enforce the requirements of the permit.
Comments: the SWMP or other associated documents are not available online.
II.A.3 & II.A.5
Stormwater Plan
Did DEMLR require a modification to the Stormwater Plan?
No
--
Mo lI ficet ns
„
If yes, did the permittee complete the modifications in accordance with the
Not
established deadline?
Applicable
—
Comments: Not applicable.
R.A.6 Sharing
Responsibility
Are any control measures implemented by an entity other than the permittee?
Yes
1
if yes, is there a written agreement in place?
Yes
1
Comments: The permittee has an interlocal agreement with Gaston County Natural Resource Department to conduct Erosion and
Sediment Control inspection along with Post -Construction Stormwater Control Measure (SCM) installation.
IIAJ
The permittee maintained written procedures for implementing the six minimum
Written
control measures.
No
--
Procedures
Nritten procedures identified specific action steps, schedules, resources and
responsibilities for implementing the six minimum measures.
No
--
Comments: No documentation of procedures being maintained.
III. A The permittee maintained documentation of all program components including, but
Program not limited to, inspections, maintenance activities, educational programs, Partial 1-10
Documentation implementation of BMPs, enforcement actions etc., on file for a period of five years.
Comments: The permittee has maintained documentation for some areas of the permit but not all areas.
IILB
The permittee submitted annual reports to the Departmenj within twelve months
Annual Report
frortrthe effective date of the permit (See Section III.B. for the annual reporting
Yes
9
Submittal
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
9
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
Reviewed
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
Reviewed
Plan (results, effectiveness, implementation schedule, etc.).
NCS000449—Town of Cramerton MS4 Audit_20220223 Page 5 of 20

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.
"mmants: The permittee has submitted annual reports for years 2018-2021 via the BIMS portal.
SB
Oaf R ortin ''
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.
I--
Reviewed
—
2. A description of the effectiveness of each program component.
Not
—
Reviewed
tt'
3. Planned activities and changes for the next reporting period, for each
Not
program component or activity.
Reviewed
_
4. Fiscal analysis.
Not
Reviewed
Comments: Not reviewed.
NCS000449_Town of Cramerton M54 Audit_20220223 Page 6 of 20

Public Education and Outmach
Staff Interviewed:
Josh Watkins, Stormwater Coordinator
(Name, Title, Role)
Permit i:rtation
Prcgraen Re ucrenrent Status
The permittee defined goals and objectives of the Local Public Education and
Goals and
No --
Outreach Program based on community wide issues.
Objectives
Comments: No documentation of defined goals and objectives based on communitywide issues.
II.B.2.b
permittee maintained a description of the target pollutants and/or stressors and
Target Pollutants
F1,kelysources.
Na
--
Comments: No documentation of a target pollutant list being maintained.
I1.8.2.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 assessment.
II.B.2.d Residential I
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
TN.
Commercial Issues
their education/outreach program.
Comments: No documentation.
ii.B.Ze
The permittee promoted and maintained an internet web site designed to convey the
Informational
program's message.
No
--
Web Site
Comments: No documentation.
11.6.2.E
The. permittee distributed stormwater educational material to appropriate target
Public Education
Yes
3
Materials
oroups.
Comments: The permittee has distributed and documented educational materials being distributed to multiple audience groups at
multiple events.
-1B'2'g
The permittee promoted and maintained a stormwater hotline/helpline forthe
Hotline/Help Line
purpose of public education and outreach.
No
Comments: The permittee does not maintain a hotline specific for public education and outreach.
1I.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
Yes
3,4
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
Yes
314
of exposure.
Comments: The permittee distributed educational materials at different events in the town and via social media platforms. The
permittee also partners with Gaston County Natural Resource Department to conduct education events in schools within the Town.
NCS000449_Town of Cramerton MS4 Audit_20220223 Page 7 of 20

NCS000449_Town of Cramerton MS4 Audit_20220223 Page 8 of 20

lfll�At E�Rsta�r
s
Josh Watkins, Stormwater Coordinator
IEnterviewed:
f (Name, Title,
f -Role)
mit Citation
P:
Q Requirement w
II.D.2.a
IDDE Program -
The permittee maintained a written IDDE Program. No ---
If yes, the written program includes provisions for program assessment and Not
evaluation and integrating program. Applicable
Comments: The oermittee has not maintained a written IDDE program.
he permittee maintained an IDDE ordinance or other regulatory mechanism(s) that
Yes
2
provides the legal authority to prohibit illicit connections and discharges to the I
II.D.2.b
Legal Authorities
If yes, the ordinance applies throughout the corporate limits of the permittee.
[Permit Part LD]
Yes
2
Comments: The permittee has adopted and follows the Gaston County Ordinance for IDDE.
II.D.2.c
`he permittee maintained a current map showing major outfalls and receiving
Yes
5
Storm Sewer
System Map
creams.
Comments: The permittee has a current map of stormwater outfalls, conveyance systems and receiving waters.
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 does not have a written program for Dry Weather Flow. However, the permittee does conduct
inspections with a standardized inspection form.
11.D.2.e -
maintained written procedures for conducting investigations ofInvestigation
TTclhepermittee
illicit discharges.
No
Procedurestified
Comments: No documentation of written procedures to conduct IDDE investigation.
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
6
2. The results of the investigation
Yes
6
3. Any follow-up of the investigation
Yes
6
4. The date the investigation was closed
Yes
6
Comments: The permittee does have an inspection and tracking sheet for IDDE investigations conducted.
NC5000449 Town of Cramerton M54 Audit_20220223 Page 9 of 20

c mscta
2. Emplayee; a:The permittee implemented and documented a training program for appropriate
municipal staff who, as part of their normal job responsibilities, may come into No —
contact with or otherwise observe an illicit discharge or illicit connection.
Comments: The permittee does not have a training program in place at this time.
The permittee informed public employees of hazards associated with illegal
bhc Education discharges and improper disposal of waste.
No
The permittee informed businesses of hazards associated with illegal discharges and
improper disposal of waste.
No
--
The permittee informed the general public of hazards associated with illegal
discharges and improper disposal of waste.
No
—
Comments: No cocumentation.
ILD.2.i
The permittee promoted, publicized, and facilitated a reporting mechanism for the
Public Reporting
Public to report illicit discharges.
No --
Mechanism
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
requests/repo rts.
No
--
Comments: No cocumentation.
1I.D.2
The permittee implemented a mechanism to track the issuance of notices of violation
Not
Enforcement
and enforcement actions administered by the permittee.
Applicable
___
If yes, the mechanism includes the ability to identify chronic violators for
Not
initiation of actions to reduce noncompliance.
Applicable
--
Comments: The permittee has not issued any NOV or enforcement actions at this time. The permittee does utilize a program called
iWorQ that can track and look up repeat enforcement actions.
NCS000449_Town of Cramerton MS4 Audit_20220223 Page 10 of 20

Pollution Prevention and Good Housekeeping for Municipal Operations
Staff Interviewed: �
Josh Watkins, Stormwater Coordinator
(Name, Title, Role) ..
y Gta.us s pp° tl"c
Permit atlaion
Program Regweement
w. N°-
u
ILG.G.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 7
stormwater runoff.
Comments: The permittee has maintained a list of all municipally owned and operated facilities.
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
No
---
Maintenance (O&M)
stormwater runoff.
for Facilities
Not
If yes, the 0&M program specifies the frequency of inspections.
Applicable
If yes, the 0&M program specifies the frequency of routine maintenance
Not
requirements.
Applicable
If yes, the permittee evaluated the 0&M program annually and updated it as
Not
necessary.
Applicable
Comments: No documentation.
Spill Response
The permittee had written spill response procedures for municipal operations.
No
---
Procedures
Comments: No documentation.
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
j corporate limits annually.
If yes, the permittee evaluated the effectiveness of existingand new BMPs
Maintenance
based on cost and the estimated quantity of pollutants removed.
No
--
Comments: No documentation or BMP inspections or annual assessment.
II.G.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
maintains.
Conveyance Systems
Comments: No documentation of weekly inspections.
II.G.2.e
The permittee maintained a current inventory of municipally -awned or operated
Structural
structural stormwater controls installed for compliance with the permittee's post-7Ac.bTle--
Stormwater Controls
construction ordinance.
Comments: The permittee does not own any Stormwater Control Measures.
NCS000449 Town of Cramerton M54 Audit_20220223 Page 11 of 20

ion PG@lietliioGl i�d G®od 6 ®NS np, fdt MEAnBCi[Ocii Operations
2.11 +vi The permittee maintained and implemented an O&M program for municipally-
for Structu ' owned or maintained structural stormwater controls installed for compliance with Not
Applicable
rmwater Controls the permittee's post -construction ordinance. If yes, then:
The 0&M program specified the frequency of inspections and routine
Not
maintenance requirements.
Applicable
The permittee documented inspections of all municipally -owned or maintained
Not
structural stormwater controls.
Applicable
The permittee inspected all municipally -owned or maintained structural
Not
stormwater controls in accordance with the schedule developed by permittee.
Applicable
The permittee maintained all municipally -owned or maintained structural
Not
stormwater controls in accordance with the schedule developed by permittee.
Applicable
_
1
The permittee documented maintenance of all municipally -owned or
Not
maintained structural stormwater controls.
Applicable
_
Comments: I he permittee has not maintained an O&M program because they do not own or maintain any SCMs.
II.G.2.i
The permittee ensured municipal employees are properly trained in pesticide,
Not
Pesticide, Herbicide
herbicide and fertilizer application management.
Applicable
and Fertilizer
Application
The permittee ensured contractors are properly trained in pesticide, herbicide and
Management
fertilizerapplication management.
No
---
The permittee ensured all permits, certifications, and other measures for
applicators are followed.
No
---
Comments: The permittee does not apply pesticides, herbicides or fertilizers in house. Products are purchase by the permittee but
used by a third party. No documentation of contractor pesticide license.
ILG.Z.j
The permittee implemented an employee training program for employees involved
Staff Training
in implementing Pollution prevention and good housekeeping Practices.
No
—
Comments the permittee does not have a training program implemented at this time.
:: ILG3.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
8
Equipment Cleaning
cleaning.
Comments: The only municipal operation that washes vehicles outside is the fire department. The fire department places a
temporary drain blocker on the storm drain and vacuums up all wash water after washing. All other municipally owned vehicles are
washed at a commercial site.
NCS000449_Town of Cramerton M54 Audit_20220223 Page 12 of 20

Facility Name:
Date and Time of Site Visit:
Public Works
February 23, 2022, at 2:00pm
Facility Address:
Facility Type (Vehicle Maintenance, Landscaping, etc.):
Eagle Road
Public Works Facility
Cramerton, North Carolina
Name of MS4 inspector(s) evaluated: Most Recent MS4 Inspection (List date and name of inspector):
Josh Watkins
Name(s) and Titles) of Facility Representatives) Present During the Site Visit:
Name Title
Rodney Baker Public Works Director
j 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?
None.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
None.
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
Yes.
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Yes.
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 inspectors process include reviewing the facility's SWPPP (or similar document)?
The facility does not have an SWPPP or similar document.
Does the MS4 inspectors process include walking the entire facility and inspectingall points of discharge?
Yes.
Did the MS4 inspector miss any obvious areas of concern? If so, explain:
No.
Does the MS4 inspector's process include presenting the inspection findings to the facility contact?
Yes, the facility contact walked the site during the inspection.
Inspection Results z
Did the facility inspection result in any corrective actions to be implemented? If so,forwhat issue(s)?
Yes, there is a tractor that is leaking hydraulic fluid. The leak needs to be stopped and the tractor put under cover until problem can
be resolved.
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
As soon as possible. Site contact said it will be resolved same day.
NCS000449_Town of Cramerton MS4 Audit_20220223 Page 13 of 20

Site Visit �FfB)lta$B®IS: 1J1�9�E[A�) � f;9W A' 2
Facility Name: Date and Time of Site Visit:
C. B. Huss Recreation Center February 23, 2022, at 2:35pm
Facility Address:
Facility Type (Vehicle Maintenance, Landscaping, etc.):
8 Julian Street
Park facility with chemical and landscape equipment storage.
Cramerton, North Carolina
Name of MS4 inspector(s) evaluated: Most Recent MS4 Inspection (Date and Entity):
Josh Watkins
Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name Title
Eric Smallwood Parks and Recreation Director
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?
None.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
None.
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
Yes.
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Yes.
Inspection Procedures
Does the M54 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 M54 inspector's process include reviewing the facility's SW PPP (or similar document)?
The facility does not have a SWPPP or similar document.
Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge?
Yes.
Did the MS4 inspector miss any obvious areas of concern? If so, explain:
No.
Does the MS4 inspector's process include presenting the inspection findings to the facility contact?
Yes, the facility contact walked the site during the inspection.
_Inspection Results ^`
Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)?
Yes, this facility is a pole barn with only three sides covered and a roof. There are oils and chemicals stored out from under cover or
near the open side of the building. A 5-gallon bucket and two 55-gallon drums with unknown contents were on site and uncovered.
The drums were empty and sealed.
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
NCS000449_Town of Cramerton MS4 Audit_20220223 Page 14 of 20

As soon as possible.
Outfall ID Number: Date and Time of Site Visit:
February 23, 2022, at 3:05pm
Outfall Location:
Outfall Description (Pipe Material/Diameter, Culvert, etc.):
North of Fire Department Kayak Launch
36" RCP
Receiving Water:
Is Flow Present? If So, Describe (Color, Approximate Flow Rate,
South Fork of the Catawba River
Sheen, Odor, Floatables/Debris, etc.):
Flow is present. This outfall discharges directly into the river. The
outfall is partially submerged in the river. About 1/3 full of
sediment. No oils, sheens, odor or floatables were observed.
Most Recent Outfall Inspection/Screening (Date):
Days Since Last Rainfall:
Inches:
One day
0.25"
Name of MS4 Inspector(s) evaluated:
Josh Watkins
asp or: n o
What type of stormwater training does the M54 inspector receive? How often?
None.
Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations?
Yes.
—
Inspection Procedures
Does the inspectors process include the use of a checklist or other standardized form?
Yes.
Does the inspector's process include taking photos?
No.
Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they?
No.
Inspection Results
Did the outfall inspection result in any work orders or maintenance requests? If so, for what issue(s)?
Yes, the outfall pipe is about 1/3 full of sediment that needs to be removed.
Will a follow-up outfall inspection be conducted? If so, for what reason?
Yes, periodic reinspection.
NCS000449 Town of Cramerton M54 Audit_20220223 Page 15 of 20

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

APPENDIX A: Photograph Log
Photograph 1: Overview of Cramerton Public Works Facility.
Photograph 2: Additional overview of Cramerton Public Works Facility.
NC5000449_Town of Cramerton MS4 Audit_20220223 Page 17 of 20

Photograph 3: Tractor partially stored under cover with a hydraulic leak at public works.
Photograph 4: Inside the public works storage building.
NCS000449_Town of Cramerton MS4 Audit_20220223 Page 18 of 20

Photograph 5: Overview of parks and recreation storage pole barn.
Photograph 6: 5-gallon bucket with unknown contents not under cover.
NC5000449_Town of Cramerton MS4 Audit_20220223 Page 19 of 20

Photograph 7: Deicer in bags that are exposed to run off.
Photograph 8: Miscellaneous buckets and oils undercover at parks and recreation storage
facility.
NCS000449_Town of Cramerton MS4 Audit_20220223 Page 20 of 20

Example Council Resolution of Commitment to Implement a Compliant NPDES MS4 Program
Resolution No.:;
Date Adopted:
RESOLUTION AFFIRMING THE�VA�COUNCIL'S SUPPORT
REGARDING IMPLEMENTATION OF A COMPLIANT NPDES MS4 STORMWATER PROGRAM
A RESOLUTION to develop and implement a compliant stormwater management program that meets
the requirements of the ® National Pollutant Discharge Elimination System (NPDES) Municipal
Separate Storm Sewer System (MS4) Permit number NCSM to discharge stormwater, inclusive of the
required Stormwater Management Plan to be prepared by the � and approved by the North
Carolina Department of Environmental Quality.
WHEREAS, Section 402(p) of the federal Clean Water Act requires NPDES permits for stormwater
discharges from municipal separate storm sewer systems; and
WHEREAS, in North Carolina, NPDES Permits are issued by the North Carolina Department of
Environmental Quality; and
WHEREAS, the North Carolina Department of Environmental Quality issued the NILNM its t�)'
NPDES M54 Permit for discharge of stormwater on = and
WHEREAS, the INAM was issued Notice of Violation number NOV on for
noncompliance with the issued NPDES MS4 Permit; and
WHEREAS, the NAkiid acknowledges the specific Notice of Violation requirement to obtain a new
individual NPDES MS4 Permit; and
WHEREAS, the ® acknowledges the specific Notice of Violation requirement to conduct a self -
audit of permit compliance for the balance of permit requirements not specifically audited by the North
Carolina Department of Environmental Quality, and to develop a draft Stormwater Management Plan to
comply with Section 402(p)(3)(B)(iii) of the Clean Water Act, 40 CFR 122.34(b) and NPDES MS4 Permit
requirements, and to submit its draft stormwater Management Plan to the North Carolina Department
of Environmental Quality no later than for review and approval; and
WHEREAS, the acknowledges the specific Notice of Violation requirement to adopt a Council
Resolution to implement a compliant and enforceable stormwater management program as defined by
both the NPDES MS4 Permit number NCSM and the required new stormwater Management Plan, and
said resolution is to be submitted to the North Carolina Department of Environmental Quality no later
thanT and
WHEREAS, the acknowledges the requirement to provide adequate funding and staffing to
implement a Stormwater Management Program that complies with its NPDES MS4 Permit and approved
Stormwater Management Plan; and
WHEREAS, the acknowledges that North Carolina Department of Environmental Quality
enforcement action and penalties could result from non-compliance with the specific requirements in
Notice of Violation number NOV ; and

Example Council Resolution of Commitment to Implement a Compliant NPDES MS4 Program
WHEREAS, the -acknowledges that any North Carolina Department of Environmental Quality
enforcement action and penalties may not prohibit the U.S. Environmental Protection Agency from
taking its own enforcement action for non-compliance with the issued NPDES MS4 Permit.
NOW, THEREFORE, BE IT RESOLVED that the Council of the _ hereby affirms its support for
development and implementation of a compliant NPDES MS4 Stormwater Program.
Mayor
Stormwater Program Administrator
Town Manager
-OwTown Clerk
ADOPTED BY the City Council of the � North Carolina the _ day of 2021 and
signed in authentication thereof the _ day of 2021.