WSCO_DAVE ProgramReviewAudit report signed_20230926

COMPLIANCE AUDIT/PROGRAM REVIEW REPORT
FOR
Davie County
WATER SUPPLY WATERSHED PROTECTION PROGRAM
ID NO. WSCO_DAVE
Mocksville, NORTH CAROLINA
298 East Depot Street
Mocksville, NC 27028
Audit Date: September 8, 2023
Report Date: September 26, 2023
North Carolina Department of Environmental Quality
Division of Energy, Mineral & Land Resources Stormwater Program
512 N. Salisbury Street, 6th floor
1612 Mail Service Center
Raleigh, NC 27699-1612

WSWP Program Audit Report
Davie County, NC: WSWP ID WSCO DAVE
TABLE OF CONTENTS
Audit/Program Review Details......................................................................................................................1
Local Government Information.....................................................................................................................2
SupportingDocuments..................................................................................................................................2
Program Implementation, Documentation &Assessment....................................................................... 3-5
Post-Construction Site Runoff Controls .................................................................................................... 6-9
SiteVisit Evaluation.....................................................................................................................................10
Audit Date: September 8, 2023 ii

WSWP Program Audit Report
Davie County, NC: WSWP ID WSCO DAVE
Audit/Program Review Details
ID Number: Date(s):
WSCO—DAVE-2023 September 8,2023
Minimum Control Measures Evaluated:
0 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
0 Post-Construction Site Runoff Controls
❑ Pollution Prevention and Good Housekeeping for Municipal Operations
❑Total Maximum Daily Loads (TMDLs)
Field Site Visits:
❑ Municipal Facilities. Number visited:Choose an it ern,
❑ MS4 Outfalls. Number visited:Choose ail item,
❑ Construction Sites. Number visited:Choose an it rn.
0 Post-Construction Stormwater Runoff Controls. Number visited:2
❑ Other: Number visited:Choose an itemn,
❑ Other: Number visited:Choose an item.
Inspector(s)Conducting Audit
Name.Title Organization
Paul Clark NCDEQ-DEMLR
Audit Report Author: Date:
Signature /2 9 c7� a0-Z3
Audit Report Author: Date:
Signature
Audit Report Author: Date
Signature
Audit Date(s): September 8, 2023 Page 1 of 10

WSWP Program Audit Report
Davie County, NC: WSWP ID WSCO DAVE
Local Government Information
Name: Davie County Program Effective Date: Recent Ordinance Date:
12/20/1993 6/18/2009
City,State,ZIP: Mocksville, NC 27028 Date of Last Audit: No record of previous audit
Administering program for other local government(s),if applicable:
Primary MS4 Representatives Participating in Audit
Name,Title Organization
Johnny Easter, Director Davie County-Planning and Development Services
Watersheds
Classification, Index
Waterbody Impairments
Supporting Documents
Item
Number
Davie County, NC Code of Ordinances-Title XV: Land Usage, Chapter 151:
1 Watershed Protection (6/18/2009) online
https://www.daviecountync.gov/DocumentCenter/View/128/watershed-
protection-PDF
Audit Date(s): September 8, 2023 Page 2 of 10

WSWP Program Audit Report
Davie County, NC: WSWP ID WSCO DAVE
Program Implementation, Documentation &''Assessment
Staff Johnny Easter, Planning and Development Services(P&DS) Director—started July 2022
Interviewed:
(Name,Title,
Role)
Topic Program Requirement Status Supportin
g Doc No.
Staffing and Local Government(LG) maintained adequate funding and staffing to implement
Yes
Funding and manage and meet all requirements of WSWP program.
LG has specific position(s) responsible for the overall coordination,
Yes
implementation, and revision of the program.
Responsibilities for all components of the WSWP program are documented and
No
position(s)assignments provided.
Comments
Davie County has the P&DS Director(Johnny Easter)and two planning/zoning staff. One position is currently vacant. The
three positions implement the water supply watershed protection program. These three positions have other responsibilities
as well. Davie County funds these three positions.
Job descriptions provide some information on responsibilities associated with implementing water supply watershed program,
huL DEQ recornrnends developing Borne Lype of SOP docurnenl. Lo beLLer identify and explain responslbllltles.
Program LG evaluated performance and effectiveness of program components at least
Implementation annually. No
and Evaluation If yes, LG used evaluation results to modify the program components as Not
necessary to accomplish the intent of the Stormwater Program. Applicable
Comments
Davie County stated that the DEQ program review on September 8t'served as program evaluation.
Keeping WSWP
Ordinance Up to LG kept the WSWP ordinance up to date. Yes
Date
LG notified DEMLR of any updates to the WSWP Ordinance. Not
Applicable
Comments
Davie County, NC Code of Ordinances-Title XV: Land Usage, Chapter 151: Watershed Protection(6/18/2009)
https://www.daviecou ntync.gov/Docu mentCenter/View/128/watershed-protection-P D F
WSWP Ordinance LG kept an up-to-date version of its WSWP Ordinance available to Division and
Availability public online. Yes
Online materials included ordinances, or other regulatory mechanisms, or a list
identifying ordinances, or other regulatory mechanisms, providing the legal Yes
authority necessary to implement and enforce the requirements of the program.
Ordinance online: https://www.daviecountync.gov/DocumentCenter/View/128/watershed-protection-PDF
The watershed protection,zoning, and overlay district sections all reference each other
Survey and
Uploads Did LG complete survey? Yes ---
Audit Date(s): September 8, 2023 Page 3 of 10

WSWP Program Audit Report
Davie County, NC: WSWP ID WSCO DAVE
Program Implementation, Documentation &Assessment
Did LG upload ordinance and/or watershed map(s)? No me.v
Completed survey during program review and plans to upload the ordinance and map.
Sharing
Responsibility Is program partially or fully implemented by an entity other than the permittee? No ---
If yes, is there a written agreement in place? Not
Applicable
Comments
Davie County does planning for Mocksville and Bermuda Run in addition to the Davie County. Davie County will send copies
of the agreements it has with these two municipalities.
Written
Procedures LG maintained written procedures(i.e.,SOPs)for implementing WSWP program. No
Written procedures identified specific action steps,schedules, resources and
No
responsibilities for implementing WSWP program.
Comments
Job descriptions provide some information on responsibilities associated with implementing water supply watershed
program, but DEQ recommends developing some type of SOP document to better identify and explain responsibilities.
Program LG maintained documentation of all program components including, but not
Documentation limited to, inspections, maintenance activities, educational programs, Partial
implementation of BMPs, enforcement actions etc.,on file for period of five years.
Comments(List the specific program components that do not have adequate documentation on file and why,if applicable)
Davie County does not offer the high density option and directs more dense development to municipalities. This eliminates
the need for storm water control measure inspections and other related activities. Davie County shared some documentation
during the program review, but could improve in this area.
Audit Date(s): September 8, 2023 Page 4 of 10

WSWP Program Audit Report
Davie County, NC: WSWP ID WSCO DAVE
Program Implementation, Documentation & Assessment
Comments
Davie County-application submittal/review process:
Before application received by Planning and Development Services(P&DS), County Health Department or private licensed soil
scientist signs off on project confirming that it meets density requirements. County also confirms that site has adequate well
or is connected to public drinking water supply and has adequate septic or is connected to wastewater collection system.
P&DS receives application. Smaller projects do not require Technical Review Committee (TRC)meeting. For larger projects,
TRC(includes Fire Marshall, NCDOT, DEQ,school board rep, public utilities,telephone company)conducts more thorough
reviews and provides input to P&DS. P&DS ensures proposed project follows applicable ordinances. For example, confirm
that it is zoned correctly,and that lot sizes,setbacks, and other items are correct. PD&S sends comments from all TRC
members to developer to address. Developer works with all TRC members separately to ensure all the components are met.
After all reviews are complete and requirements are addressed in plans, P&DS signs off on plat(for large projects)or issues
zoning permits for smaller projects(i.e., individual lots). Davie County issues zoning permits for all projects independent of
requirements that are met. Davie County does not issue separate watershed permits for those projects located in water
supply watershed protection watersheds. After project is complete, P&DS visits site to ensure requirements are met.
Of the portion of county that is outside municipalities, 98 percent is zoned residential and has one lot/acre requirement.
Thus,the majority of proposed projects will meet water supply watershed protection requirements by meeting general zoning
requirements. County requirements direct denser development into the municipalities.
Davie County does planning for Bermuda Run and Mocksville. Mocksville projects are reviewed by a procedure similar to
Davie County. In Bermuda Run,all developments require TRC review/input.
Follow-up Items:
1. Davie County will revise ordinance to eliminate 10/70 option and add density averaging requirement.
2. Davie County will send MOAs between Davie County and Bermuda Run and Mocksville.
3. There is a portion of Davie County that is required to meet NPDES MS4 Phase II post construction stormwater
requirements because it falls within a Municipal Sphere of Influence or an Urbanizing Area. NCDEQ sent Davie
County information on these requirements.
Audit Date(s): September 8, 2023 Page 5 of 10

WSWP Program Audit Report
Davie County, NC: WSWP ID WSCO DAVE
Post-Construction Site Runoff Controls
Staff Interviewed: Johnny Easter, Planning and Development Services Director
(Name,Title,Role)
Implementation(check all that apply):
❑X The permittee implements the components of this minimum measure.
❑ The permittee relies upon another entity to implement the components of this minimum measure: name of entity
❑ 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 213.0212
❑ Water Supply Watershed II (WS-II)—15A NCAC 213.0214
0 Water Supply Watershed III (WS-III)—15A NCAC 26.0215
© Water Supply Watershed IV(WS-IV)—15A NCAC 213.0216
❑ 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 2B.0235
❑ Tar-Pamlico River Basin Nutrient Sensitive(NSW) Management Strategy—15A NCAC 2B.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 program requirements
(check all that apply):
❑x 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)
Topic' Program Requirement Status Supporting
Doc No.
Legal Authority LG maintained an ordinance or other regulatory mechanism designed to meet
objectives of Water Supply Watershed Protection Program. Yes
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
accordingly).
LG has authority to review designs and proposals for new development and
redevelopment to determine whether adequate stormwater control measures will Not
Applicable
be installed, implemented, and maintained.
Audit Date(s): September 8, 2023 Page 6 of 10

WSWP Program Audit Report
Davie County, NC: WSWP ID WSCO DAVE
Post-Construction Site Runoff Controls
LG has authority to request information such as stormwater plans, inspection
reports, monitoring results, and other information deemed necessary to evaluate Not
Applicable
compliance with the Post-Construction Stormwater Management Program.
LG has authority to enter private property for the purpose of inspecting at
reasonable times any facilities,equipment, practices,or operations related to Yes
stormwater discharges.
Comments
Ordinance online: https://www.daviecountync.gov/DocumentCenter/View/128/watershed-protection-PDF.
Zoning Ordinance involved with Building inspection—issuing Certificate of Occupancy(CO) after final inspection. Davie County
does not offer the high density option,so several items in the post construction section of the program review/audit report are not
applicable.
Stormwater Control
The ermittee utilizes strategies which include SCMs. Not
Measures(SCMs) P g Applicable
SCMs comply with 15A NCAC 02H .1000. Not
Applicable
Plan Reviews LG conducted site plan reviews of all new development and redeveloped sites that Not
disturb greater than or equal to one acre(WS IV watersheds) Applicable
If yes,site plan reviews addressed how project applicant meets performance Not
standards. Applicable
If yes,site plan reviews addressed how project will ensure long-term Not
maintenance. Applicable
Inventory of Projects LG maintained an inventory of projects with post-construction structural
stormwater control measures installed and implemented at new development and Not
Applicable
redeveloped sites.
Inventory included both public and private sector sites located within LG's Not
corporate limits that are covered by its post-construction ordinance requirements. Applicable
Deed Restrictions LG provided mechanisms such as recorded deed restrictions and protective
and Protective covenants that ensure development activities will maintain the project consistent Not
Covenants Applicable
with approved plans.
Comments
Davie county plans to add Density Averaging to the ordinance and this will include deed restrictions, etc.
Mechanism to LG implemented or required an operation and maintenance plan for the long-term Not
Require Long-term operation of SCMs required by program. Applicable
Operation and
Maintenance The operation and maintenance plan required LG or owner(or contractor)of each Not
SCM to perform and maintain a record of annual inspections of each SCM. Applicable
Annual inspection of permitted structural SCMs are required to be performed by a Not
qualified professional. Applicable
Audit Date(s): September 8, 2023 Page 7 of 10

WSWP Program Audit Report
Davie County, NC: WSWP ID WSCO DAVE
Post-Construction Site Runoff Controls
Inspections of LG conducted and documented inspections of each project site covered under Not
Structural performance standards,at least once each five years. Applicable
Stormwater Control`
Measures Before issuing a certificate of occupancy or temporary certificate of occupancy, LG (a)
conducted post-construction inspection to verify that the permittee's performance Yes
standards have been met or a bond is in place to guarantee completion.
LG developed and implemented a written inspection program for SCMs installed Not
pursuant to the post-construction program. Applicable
LG documented and maintained records of inspections. Not
Applicable
LG documented and maintained records of enforcement actions. Not
Applicable
Comments
(a) CO issued after inspection that confirms building inspection,etc. requirements have been met.
Educational
Materials and LG made available through paper or electronic means,ordinances, post-
Training for construction requirements, design standards checklists,and other materials No
Developers appropriate for developers.
Enforcement
LG tracked issuance of notices of violation and enforcement actions. No
If yes,the tracking mechanism included the ability to identify chronic violators Not
for initiation of actions to reduce noncompliance. Applicable
Comments
All developments are below the density requirements,so they all meet density requirements.
Audit Date(s): September 8, 2023 Page 8 of 10

WSWP Program Audit Report
Davie County, NC: WSWP ID WSCO DAVE
Post-Construction Site Runoff Controls
New Development LG complies with post construction program requirements on its own publicly
Yes ---
funded construction projects.
Nutrient Sensitive Does the LG have areas draining to Nutrient Sensitive Waters(NSW) pursuant to
Waters 15A NCAC 02H .0150? No
If yes, does LG use SCMs that reduce nutrient loading in order to meet local Not
program requirements. Applicable F-m
If yes, does LG also still incorporate the stormwater controls required for the Not
project's density level. Applicable
If yes, does LG also require documentation where it is not feasible to use SCMs Not
that reduce nutrient loading. Applicable _wm
Comments
Davie County drains to High Rock Lake, may be future Nutrient Sensitive Water(NSW)with Nutrient Management Strategy(NMS).
These deemed-compliant items pertain to local governments implementing MS4 programs. By implementing the water supply
watershed protection program,the local government can satisfy certain NPDES MS4 post construction stormwater requirements.
This does not apply to Davie Cuurily, but a pur Lion of Davie Cuunly uulside of Berrnuda Run and outside the water supply
watershed protection boundary falls within NPDES Phase II MS4 MSI or UA. There are some notes on this subject at the end of the
Program Implementation, Documentation,and Assessment section of this program review/audit report.
Design Volume LG ensured that the design volumes of SCMs take into account the runoff at build Not
out from all surfaces draining to the system. Applicable
Where"streets"convey stormwater,the local government designed SCMs to be
sized to treat and control stormwater runoff from all surfaces draining to the SCM Not
Applicable
including streets,driveways,and other impervious surfaces.
Audit Date(s): September 8, 2023 Page 9 of 10

WSWP Program Audit Report
Davie County, NC: WSWP ID WSCO DAVE
Site Visits Evaluation
Site Name: Date and Time of Site Visit:
1. Hidelberg, September 8, 2023
2. Sheffield Acres SD(TRC review)
Site Address: SCM Type:
1. Old Dutch Road
2. Molly Road
Most Recent Inspection(Include Date and Entity):
Name of Inspector(s)evaluated: Most Recent Enforcement Activity(Include Date):
Name(s)and Title(s)of Site Representative(s) Present During the Site Visit:
Name Title
Paul Clark Water Supply Watershed Protection Coordinator
Observations
Notes/Comments/Recommendations
Davie County does not implement the high density option as part of the water supply watershed program. Site visits confirmed
that low density requirements were met.
Audit Date(s): September 8, 2023 Page 10 of 10