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NCS000488_Valdese 2018 MS4 AUDIT REPORT_20181003
ROY COOPER NORTH CAROLINA Governor Environmental Quality MICHAEL S. REGAN Secretary WILLIAM E. (TOBY) VINSON, JR. interim Director November 27, 2018 CERTIFIED MAIL: 7016 1370 0001 6571 6320 RETURN RECEIPT REQUESTED Town of Valdese Town of Valdese Attention: John F. Black Jr., Mayor Attention: Greg Padgett, Water Resources Post Office Box 339 Director Valdese, North Carolina 28690 Post Office Box 339 Valdese, North Carolina 28690 Town of Valdese Attention: Seth Eckard, Town Manager Post Office Box 339 Valdese, North Carolina 28690 Subject: Municipal Separate Stormwater Sewer System Audit Report MS4 Permit: NCS000488 Burke County, North Carolina Dear Mr. Eckard, Mr. Black, and Mr. Padgett: Enclosed, please find a copy of the Compliance Evaluation Inspection Report for the subject municipality's MS4 audit conducted on October 3, 2018. The enclosed report will contain a summary of the items discussed during the audit. You will receive a separate report addressing timelines for the corrective actions, as well as any specific action required by the department to address any areas to be improved. Should you have any questions concerning this report, please do not hesitate to contact me at (828) 296-4500 or by email at Isaiah.reed@ncdenr.gov. Sincere Isaiah Reed, C SCI, MS4CEC Environmental Specialist Land Quality Section Enclosure: Inspection Report EC: Jeanette Powell, Engineer Jeanette.powell@ncdenr.gov rvomrvcaaourva North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources Asheville Regional Office 12090 U.S. Highway 70 1 Swannanoa, North Carolina 28778 828.296.4500 NORr Ch�:OIJN D z� oepa=W of Envimnmenlal quality Town of Valdese MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) PROGRAM AUDIT REPORT Valdese, NORTH CAROLINA 102 Massel Avenue Valdese, North Carolina 28690 Report Date: November 27, 2018 Audit Date: October 3, 2018 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 U.S. Environmental Protection Agency, Region IV Sam Nunn Atlanta Federal Center 61 Forsyth Street SW Atlanta, GA 30303-8963 MS4 Inspection Report Town of Valdese NCS000488 (This page intentionally left blank) Inspection Date: October 3, 2018 MS4 Inspection Report Town of Valdese NCS000488 TABLE OF CONTENTS InspectionDetails..........................................................................................................................................1 PermitteeInformation..................................................................................................................................2 MS4Receiving Waters...................................................................................................................................2 Listof Documents Collected..........................................................................................................................3 Program Implementation, Documentation, & Assessment..........................................................................4 Public Education and Outreach.....................................................................................................................9 Public Involvement and Participation.........................................................................................................11 Illicit Discharge Detection and Elimination(IDDE)......................................................................................12 Erosion and Sedimentation Control Program Delegation Status................................................................16 Post -Construction Site Runoff Controls Program Implementation Status..................................................17 perm ittee.....................................................................................................................................................17 entity...........................................................................................................................................................17 If implemented by another entity, indicate which entity: Click here to enter text...................................17 Post -Construction Site Runoff Controls......................................................................................................17 Pollution Prevention and Good Housekeeping for Municipal Operations..................................................22 Total Maximum Daily Loads (TMDLs) Applicability Status..........................................................................26 Site Visit Evaluation: Municipal Facility No. 1.............................................................................................26 Site Visit Evaluation: MS4 Outfall No. 1......................................................................................................28 Site Visit Evaluation: MS4 Outfall No. 2......................................................................................................29 Additional Notes............................................................................................. Error! Bookmark not defined. Appendix A: Document Log This inspection consists of an evaluation of program compliance with the issued permit and implementation of the approved Stormwater Management Plan. This inspection report does not include a review of all program components. 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. Inspection Date: October 3, 2018 ii MS4 Inspection Report Town of Valdese NCS000488 This page intentionally left blank Inspection Date: October 3, 2018 iii MS4Inspection Report Town of Valdese NCS000488 Inspection Details Inspection ID Number: Inspection Date(s): October 3, 2018 Minimum Control Measures Evaluated: ®Program Implementation ®Public Education & Outreach ®Public Involvement and Participation ®Illicit Discharge Detection & Elimination ❑Construction Site Runoff Controls N Post -Construction Site Runoff Controls ®Pollution Prevention and Good Housekeeping for Municipal Operations NTotal Maximum Daily Loads (TMDLs) Field Site Visits: NMunicipal Facility(ies). Number visited: 1 N MS4 Outfall(s). Number visited: 2 ❑Construction Site(s). Number visited:0 ❑ Post -Construction Stormwater Runoff Controls. Number visited: 0 N Other: Outfall that permitee was unable to locate during previous inspection. Number visited: 1 N Other: Location of sinkhole associated with a piped stream . Number visited: 1 Inspector(s) Conducting Inspection Name, Title Organization Isaiah Reed, Environmental Specialist NCDEQ Inspection Report Author: Date: Signature Inspection Report Author: Date Signature Inspection Date: October 3, 2018 Page 1 of 31 MS4lnspection Report Town of Valdese NCS000488 Permittee Information MS4 Permittee Name: Town of Valdese NPDES Permit Number: NCS000488 City, State, ZIP: Valdese, North Carolina 28690 Date of Last MS4lnspection/Audit: None Co-permittee(s), if applicable: N/A Primary MS4 Representatives Participating in Inspection Name Title Role Email Joe McNeely Stormwater Technician (Valdese) jmcneely@valdesenc.gov Greg Padgett Water Resources Director (Valdese) gpadgett@valdesenc.gov Benjie Thomas Consultant (West Consultants bthomas@west-consultants.com MS4 Receiving Waters Waterbody Impairments Catawba River 11-(37) WS-IV, B;CA None Hoyle Creek 11-45-(2) WS-IV ;CA None McGalliard Creek 11-44-(3) WS-IV ;CA None Dye Branch 11-44-(2) WS-IV None Inspection Date: October 3, 2018 Page 2 of 31 MS4Inspection Report Town of Valdese NCS000488 List of Documents Collected Number Document Title Provided Prior to/During/After Inspection: 1 Attendance Sheet During 2 2017 SWMP Annual Report During 3 Valdese SWMP from September, 2013 Prior to 4 IDDE Records Prior to 5 Stormwater Ordinance Prior to 6 Stormwater Handouts During 7 Employee Training Prior to 8 Spill Response Prior to 9 Western Piedmont Council of Governments Info Prior to Inspection Date: October 3, 2018 Page 3 of 31 MS4Inspection Report Town of Valdese NCS000488 Program Implementation, Documentation, & Assessment Permit Citation Program Requirement Status Supporting'. Doc No. II.A.1 The permittee maintained adequate funding and staffing to implement and manage the Yes 3 Staffing and provisions of the Stormwater Plan and meet all requirements of the permit. Funding The Stormwater Plan identifies a specific position(s) responsible for the overall Yes 3 coordination, implementation, and revision to the Plan. Responsibilities for all components of the Stormwater Plan are documented and Yes 3 position(s) assignments provided. Yes (Billing [Thermittee is current on payment of invoiced administering and compliance section ring fees. in BIMS) Comments During the discussion of this section, Mr. McNeely explained that he will be likely retiring in February. Mr. Padgett then explained that they have been in discussions with the City of Morganton for meeting future permit requirements. II.A.Z The permittee evaluated the performance and effectiveness of the program No T7 Stormwater components at least annually. Plan Implementation P If yes, the permittee used the results of the evaluation to modify the program Not Applicabl and Evaluation components as necessary to accomplish the intent of the Stormwater Program. e Did the permitted MS4 discharges cause or contribute to non -attainment of an Not Reviewe applicable water quality standards? d Not If yes, did the permittee expand or better tailor its BMPs accordingly? Applicabl e Comments The SWMP has not been reviewed and updated annually. II.A.3 No 3 [Thermittee kept the Stormwater Plan up to date. Inspection Date: October 3, 2018 Page 4 of 31 MS4Inspection Report Town of Valdese NCS000488 Program Implementation, Documentation, & Assessment Permit Citation Program Requirement Status So cortiNong Keeping the Not Stormwater The permittee notified DEMLR of any updates to the Stormwater Plan. Applicabl Plan Up to Date e The SWMP has not been modified since its conception in 2013. II.A.4 The permittee kept an up-to-date version of its Stormwater Plan available to the No Availability of Division and the public online. the Stormwater Plan The online materials included ordinances, or other regulatory mechanisms, or a list No identifying the ordinances, or other regulatory mechanisms, providing the legal authority necessary to implement and enforce the requirements of the permit. A plan was available at the time of the inspection, but not easily available on line. While the permitee does have a stormwater page on their website, it does not have any stormwater ordinances available on that page. II.A.S Not Stormwater Did DEMLR require a modification to the stormwater Plan? Applicabl Plan e Modifications f yes, did the permittee complete the modifications in accordance with the Not Reviewe established deadline? d Comments During the discussion; updating and revising of the SWMP was discussed and Mr. Padgett has said that these updates will take place soon. II.A.6 Sharing Yes Responsibility Are any control measures implemented by an entity other than the permittee? No If yes, is there a written agreement in place? Inspection Date: October 3, 2018 Page 5 of 31 MS4Inspection Report Town of Valdese NCS000488 Program Implementation, Documentation, & Assessment .Permit Citation Program Requirement Status SD sorting Comments Western Piedmont Council of Governments provides public education and outreach for the town at least annually. II.A.7 The permittee maintained written procedures for implementing the six minimum Yes 3 Written control measures. Procedures Written procedures identified specific action steps, schedules, resources and Yes 3 responsibilities for implementing the six minimum measures. Comments The permittee has written procedures for all minimum control measures except construction site storm water which is handled by the North Carolina Department of Environmental Quality. III_A The permittee maintained documentation of all program components including, but not No Program limited to, inspections, maintenance activities, educational programs, implementation Documentation of BMPs, enforcement actions etc., on file for a period of five years. Comments All program components have not been met. See list of documents collected. III_B The permittee submitted annual reports to the Department within twelve months from Yes Annuai Report the effective date of the permit. Submittal The permittee submitted subsequent annual reports every twelve months from the Yes scheduled date of the first submittal. The Annual Reports included appropriate information to accurately describe the progress, status, and results of the permittee's Stormwater Plan, including, but not limited to the following: 1. A detailed description of the status of implementation of the Stormwater Plan Yes as a whole. This includes information on development and implementation of each major component of the Stormwater Plan for the past year and schedules and plans for the year following each report. Inspection Date: October 3, 2018 Page 6 of 31 MS4Inspection Report Town of Valdese NCS000488 Program Implementation, Documentation, & Assessment Permit Citation Program Requirement Status supporting Ooc No. 2. An adequate description and justification of any proposed changes to the Not Stormwater Plan. This includes descriptions and supporting information for the Applicabl proposed changes and how these changes will impact the Stormwater Plan e (results, effectiveness, implementation schedule, etc.). 3. Documentation of any necessary changes to programs or practices for Not assessment of management measures is implemented through the Stormwater Applicabl Plan. e 4. A summary of data accumulated as part of the Stormwater Plan throughout the Yes 4 year was provided along with an assessment of what the data indicated. 5. An assessment of compliance with the permit, information on the establishment Yes 3 and 5 of appropriate legal authorities, inspections, and enforcement actions. 6. A summary of past year activities, including where applicable, specific quantities Yes 4 achieved and summaries of enforcement actions. (Part IV, B. 1) No 7. A description of the effectiveness of each program component. (Part IV, B. 1) 8. Planned activities and changes for the next reporting period, for each program No component or activity. (Part IV, B. 1) No 9. Fiscal analysis. (Part IV, B. 1) Comments Answers based on documentation sent to the inspector, and made available on site. These components shall be reflected in the new SWMP and associated documentation. Inspection Date: October 3, 2018 Page 7 of 31 MS4Inspection Report Town of Valdese NCS000488 Program Implementation, Documentation, & Assessment Permit Citation Program Requirement 7 status supporting Doc No. Staff Joe McNeely was primarily the staff member implementing the permit requirements and conducting Interviewed: inspections. Mr. McNeely is the Town of Valdese's Stormwater Technician. (Name/Title/ Role) Additional Comments: Inspection Date: October 3, 2018 Page 8 of 31 MS4Inspection Report Town of Valdese NCS000488 Public Education and Outreach Permit Citation Program Requirement Status supporting Doc No. II.B.2.a The permittee defined goals and objectives of the Local Public Education and Outreach yes 3 Goals and Program based on community wide issues. Objectives Comments In addition to the Western Piedmont Council Governments outreach and the occasional mailed information sent out to all "water bill" addresses, the permitee also sets up a table to hand out information about stormwater and potential pollutants at an annual festival (Waldensian Festival) that takes place in the town of Valdese. II.B.2.b The permittee maintained a description of the target pollutants and/or stressors and Partial 3 Target likely sources. Pollutants Comments Information on pollutant sources included a list of municipal site which the permittee deemed a possible pollutant source, and summaries of IDDE inspections in the hand written reports. Lacked a list of community concerns and a focus on outreach to those pollutants of concern. II.B.2.c The permittee identified, assessed annually and updated the description of the target No Target audiences likely to have significant storm water impacts and why they were selected. Audiences Comments Inspection Date: October 3, 2018 Page 9 of 31 MS4Inspection Report Town of Valdese NCS000488 Public Education and Outreach Permit Citation Program Requirement Status supporting g G Doc No. 11.B.2.d Yes 6 Residential and The permittee described issues, such as pollutants, the likely sources of those pollutants, Industrial/ potential impacts, and the physical attributes of stormwater runoff, in their Commercial education/outreach program. Issues Comments In addition to the Western Piedmont Council Governments outreach and the occasional mailed information sent out to all "water bill" addresses, the permittee also sets up a table to hand out information about stormwater at an annual festival that takes place in the town of Valdese. II.B.2.e The permittee promoted and maintained an internet web site designed to convey the Yes Informational program's message. Web Site Comments https://www.townofvaidese.com/utilities/storm-water/ 11.B.2.f Yes 6 Public The permittee distributed stormwater educational material to appropriate target groups. Education Materials Comments In addition to the Western Piedmont Council Governments outreach and the occasional mailed information sent out to all "water bill" addresses, the permitee also sets up a table to hand out information about stormwater at an annual festival that takes place in the town of Valdese. I I.B.2.¢ The permittee promoted and maintained a stormwater hotline/helpline for the purpose Yes Hotline/Help of public education and outreach. Line Comments A hotline is available on the website. "To report a violation, call Joe McNeely at (828) 879-2131." https://www.townofvaldese.com/utilities/storm-water/ Inspection Date: October 3, 2018 Page 10 of 31 MS4Inspection Report Town of Valdese NC5000488 Public Education and Outreach Permit Citation Program Requirement - Status supporting Doc No. 11.6.2.1h The permittee's outreach program, including those elements implemented locally or yes 9 Public through a cooperative agreement, included a combination of approaches designed to Education and reach the target audiences. Outreach Program For each media, event or activity, including those elements implemented locally or No through a cooperative agreement, the permittee estimated and recorded the extent of exposure. Comments The majority of the public education is performed by WPCOG. No "extent of exposure" was documented. WPCOG should be supplying that. Staff Joe Mcneely, Stormwater Technician (Inspections and public outreach) Interviewed: Greg Padgett, Water Resources Director (Name/Title/ Role) Public Involvement and Participation Permit Citation Program Requirement Status supposing Doc No. II.C.2.a No Volunteer The permittee included and promoted volunteer opportunities designed to promote Community ongoing citizen participation. Involvement Program Comments The lack of public involvement was discussed at length. Mr. Padgett will be implementing a plan moving forward to address this issue. Future public involvement shall be documented thoroughly. Inspection Date: October 3, 2018 Page 11 of 31 M54Inspection Report Town of Valdese NCS000488 Public Involvement and Participation Permit Citation Program Requirement Status supporting Doc No. II.C.2.b No Mechanism for The permittee provided and promoted a mechanism for public involvement that Public provides for input on stormwater issues and the stormwater program. Involvement Comments II.C.2.c The permittee promoted and maintained ahotline/helpline for the purpose of public Yes Hotline/Help involvement and participation. Line Comments https://www.townofvaidese.com/utilities/storm-water/ Staff Joe Mcneely, Stormwater Technician (Inspections and public outreach) Interviewed: Greg Padgett, Water Resources Director (Name/Title/ Role) I Illicit Discharge Detection and Elimination (IDDE) I I Permit Citation I Program Requirement. I Status I._^ .� �,.".I II.D.2.a IDDE Program The permittee maintained a written IDDE Program. Yes 13 Inspection Date: October 3, 2018 Page 12 of 31 MS4 Inspection Report Town of Valdese NCS000488 Illicit Discharge Detection and Elimination (IDDE) Permit Citation Program Requirement Status supporting. q Doc No. If yes, the written program includes provisions for program assessment and Yes 3 evaluation and integrating program. Comments Inspection reports from responses to citizen complaints were made available prior to the inspection, and a sequence was given in the SWMP concerning how to evaluate those complaints. The permittee maintained an IDDE ordinance or other regulatory mechanism(s) that Yes 5 II.D.2.b provides the legal authority to prohibit illicit connections and discharges to the MS4. Legal Yes 5 Authorities If yes, the ordinance applies throughout the corporate limits of the permittee. ]Permit Part I.D] Comments The ordinance was evaluated and discussed. Modifications to that ordinance are possible in the future to allow for more substantial inspections by the Town of Valdese inspectors. II.D.2.c Yes Storm Sewer The permittee maintained a current map showing major outfalls and receiving streams. System Map Comments This map was presented at the time of the inspection. It is available to town staff only and includes all stormwater infrastructure (including coordinates and size of utilities) and outfalls that fall within the MS4 community. The permittee maintained a program for conducting dry weather flow field observations No Dry Weather in accordance with written procedures. Flow Program Comments After discussion, Mr. Padgett shall implement dry weather inspections moving forward. This may include soliciting additional help from the City of Morganton. Inspection Date: October 3, 2018 Page 13 of 31 MS4Inspection Report Town of Valdese NCS000488 Illicit Discharge Detection and Elimination (IDDE) Supporting, Permit Citation. Program Requirement Status Doc No. II.D.2.e Yes 3 The permittee maintained written procedures for conducting investigations of identified Investigation illicit discharges. Procedures Comments Inspection reports from responses to citizen complaints was made available prior to the inspection, and a sequence was given in the SWMP concerning how to evaluate those complaints. (See II.D.2.a) II.D.2.f For each case of an illicit discharge or potential illicit discharge, the permittee Yes 4 Track and documented and tracked the following: Document Yes 4 Investigations 1. The date(s) the illicit discharge was observed Yes 4 2. The results of the investigation Yes 4 3. Any follow-up of the investigation No 4. The date the investigation was closed Comments The IDDE inspections were conducted and summarized in hand written reports. There is currently not an open/close mechanism concerning these complaints. II.D.2.e The permittee implemented and documented a training program for appropriate Yes 7 Employee municipal staff who, as part of their normal job responsibilities, may come into contact Training with or otherwise observe an illicit discharge or illicit connection. Comments Employee training documents were provided, including training for Mr. McNeely as recant as March 24, 2018. II.D.2.h The permittee informed public employees of hazards associated with illegal discharges No Public and improper disposal of waste. Education The permittee informed businesses of hazards associated with illegal discharges and No improper disposal of waste. Inspection Date: October 3, 2018 Page 14 of 31 MS4Inspection Report Town of Valdese NCS000488 Illicit Discharge Detection and Elimination (IDDE) Permit Citation Program Requirement Status SDocoNong The permittee informed the general public of hazards associated with illegal discharges Yes 6 and improper disposal of waste. Comments While general public outreach was informative, business and public employee outreach has not been conducted. II.D.2.1 The permittee promoted, publicized, and facilitated a reporting mechanism for the Yes Website Public public to report illicit discharges. Reporting Mechanism The permittee promoted, publicized, and facilitated a reporting mechanism for staff to Yes report illicit discharges. Yes 4 The permittee established and implemented citizen request response procedures. Comments IDDE inspection reports were made available to demonstrate how citizen complaints are responded to. Town staff is made aware of who to contact by other town staff and supervisors. II.D.2.i The permittee implemented a mechanism to track the issuance of notices of violation No Enforcement and enforcement actions administered by the permittee. If yes, the mechanism includes the ability to identify chronic violators for initiation of Not Applicabl actions to reduce noncompliance. e Comments The permittee has not issued any NOV's under the current permit term. Inspection Date: October 3, 2018 Page 15 of 31 MS4 Inspection Report Town of Valdese NCS000488 Illicit Discharge Detection and Elimination (IDDE) Permit Citation Program Requirement g Status supporting Doc No. Staff Joe Mcneely, Stormwater Technician (Inspections and public outreach) Interviewed: Greg Padgett, Water Resources Director (Name/Title/ Role) Additional Comments: Erosion and Sedimentation Control Program Delegation Status ❑ The permittee has a delegated erosion and sedimentation control program. If so, indicate when the program was delegated: Click here to enter text. ® The permittee does not have a delegated erosion and sedimentation control program. Note: the requirements in this section are cited from the North Carolina Sedimentation Pollution Control Act (SPCA) of 1973. Inspection Date: October 3, 2018 Page 16 of 31 MS4Inspection Report Town of Valdese NCS000488 Post -Construction Site Runoff Controls Program Implementation Status M The Post -Construction Site Runoff Controls program requirements are implemented bythe permittee ❑ The Post -Construction Site Runoff Controls program requirements are implemented by another entity If implemented by another entity, indicate which entity: Click here to enter text. Post -Construction Site Runoff Controls Permit Citation Program Requirement g q Status t supporting .Doc No. II.F.2.a The permittee maintained an ordinance or other regulatory mechanism designed to Yes Legal Authority meet the objectives of the Post -Construction Site Runoff Controls Stormwater 5 Management Program. If yes, the ordinance applies throughout the corporate limits of the permittee. Yes ]Permit Part I.D] The permittee has the authority to review designs and proposals for new development Yes 5 and redevelopment to determine whether adequate stormwater control measures will be installed, implemented, and maintained. The permittee has the authority to request information such as stormwater plans, Yes 5 inspection reports, monitoring results, and other information deemed necessary to evaluate compliance with the Post -Construction Stormwater Management Program. The permittee has the authority to enter private property for the purpose of inspecting Yes 5 at reasonable times any facilities, equipment, practices, or operations related to stormwater discharges. Comments Due to the lack of recent construction in the Town of Valdese, Mr. Padgett explained that, they have no Post -construction stormwater BMPs that he is aware of. I I.F.2.b The permittee had implemented strategies which include Stormwater Control Measures Not Reviewe Strategies (SCMs) appropriate for the MS4. d Not The permittee has complied with 15 NCAC 025 .1000 Reviewe d Comments II.F.2.c The permittee conducted site plan reviews of all new development and redeveloped Not Plan Reviews sites that disturb greater than or equal to one acre (including sites that disturb less than Reviewe one acre that are part of a larger common plan of development or sale). d Inspection Date: October 3, 2018 Page 17 of 31 MS4Inspection Report Town of Valdese NCS000488 Post -Construction Site Runoff Controls Permit Citation Program Requirement Status 'supporting Doc No. Not If yes, the site plan reviews addressed how the project applicant meets the Reviewe performance standards. d Not If yes, the site plan reviews addressed how the project will ensure long-term Reviewe maintenance. d Comments II.F.2.d The permittee maintained an inventory of projects with post -construction structural Not Inventory of stormwater control measures installed and implemented at new development and Reviewe Projects redeveloped sites. d The inventory included both public and private sector sites located within the Not permittee's corporate limits that are covered by its post -construction ordinance Reviewe requirements. d Comments II.F.2.e Yes 3 Deed The permittee provided mechanisms such as recorded deed restrictions and protective Restrictions covenants that ensure development activities will maintain the project consistent with and Protective approved plans. Covenants Comments II.F_2.f The permittee implemented or required an operation and maintenance plan for the Not Mechanism to long-term operation of the SCMs required by the program. Reviewe Require Long- d term The operation and maintenance plan required the owner of each SCM to perform and Not Operation and Reviewe maintain a record of annual inspections of each SCM. d Maintenance Inspection Date: October 3, 2018 Page 18 of 31 MS4Inspection Report Town of Valdese NCS000488 Post -Construction Site Runoff Controls Permit Citation Program Requirement Status Supporting Doc No. ' Annual inspection of permitted structural SCMs are required to be performed by a Not Reviewe qualified professional. d Comments II.F.2.s The permittee conducted and documented inspections of each project site covered Not Reviewe Inspections under performance standards, at least one time during the permit term. d Before issuing a certificate of occupancy or temporary certificate of occupancy, the Not permittee conducted a post -construction inspection to verify that the permittee's Reviewe performance standards have been met or a bond is in place to guarantee completion. d Not The permittee documented and maintained records of inspection findings. Reviewe d Not The permittee documented and maintained records of enforcement actions. Reviewe d Comments II.F.2.h The permittee made available through paper or electronic means, ordinances, post- Yes 5 Educational construction requirements, design standards checklists, and other materials appropriate Materials and for developers. Training for Note: New materials may be developed by the permittee, or the permittee may use Developers materials adapted from other programs and adapted to the permittee's new development and redevelopment program. Comments (if the permittee has adopted materials from other programs, indicate here which materials they are using) Inspection Date: October 3, 2018 Page 19 of 31 MS4Inspection Report Town of Valdese NCS000488 Post -Construction Site Runoff Controls Permit Citation Program Requirement Status supporting DocNo: II.F.2.i Not Enforcement The permittee tracked the issuance of notices of violation and enforcement actions. Applicabl e If yes, the tracking mechanism included the ability to identify chronic violators for Not gpplicabl initiation of actions to reduce noncompliance. e Comments II.F.3.d Pursuant to 15A NCAC 02H .0150, for areas draining to Nutrient Sensitive Waters, the Not Nutrient permittee used SCMs that reduce nutrient loading in order to meet local program Applicabl Sensitive requirements e Waters If yes, the permittee also still incorporated the stormwater controls required for the Not Applicabl project's density level. e Documentation shall be provided where it is not feasible to use stormwater control Not measures (SCMs) that reduce nutrient loading. In areas where the Department has Applicabl approved a Nutrient Sensitive Water Urban Stormwater Management Program, the e provisions of that program fulfill the nutrient loading reduction requirement. Comments II.F.3.e The permittee designed SCMs such that the design volume of SCMs take into account the Not Design Volume runoff at build out from all surfaces draining to the system. Reviewe d Where "streets" convey stormwater, the permittee designed SCMs to be sized to treat Not and control stormwater runoff from all surfaces draining to the SCM including streets, Reviewe driveways, and other impervious surfaces. d Comments The Town of Valdese relies on DEMUR design standards for SCMs. Inspection Date: October 3, 2018 Page 20 of 31 M54Inspection Report Town of Valdese NCS000488 Post -Construction Site Runoff Controls Permit Citation Program Requirement Status supporting Doc No: Staff Joe Mcneely, Stormwater Technician (Inspections and public outreach) Interviewed: Greg Padgett, Water Resources Director (Name/Title/ Role) Additional Comments: Inspection Date: October 3, 2018 Page 21 of 31 MS4Inspection Report Town of Valdese NCS000488 Pollution Prevention and Good Housekeeping for Municipal Operations Permit Citation Program Requirement Status supporting `Dot No. II.G.2.a Yes 3 The permittee maintained a current inventory of facilities and operations owned and Facility operated by the permittee with the potential for generating polluted stormwater runoff. Inventory Comments A list was presented in the SWMP on page 27. This list includes "Stormwater Pollution Potential'. II.G.2.b The permittee maintained and implemented an O&M program for municipally owned No Operation and and operated facilities with the potential for generating polluted stormwater runoff. Maintenance (O&M) for Choose Facilities If yes, the 0&M program specifies the frequency of inspections. an item. If yes, the 0&M program specifies the frequency of routine maintenance Choose requirements. an item. If yes, the permittee evaluated the O&M program annually and updated it as Choose necessary. an item. Comments An O&M program is in the SWMP , but that facilities do not currently get inspected. II.G.2.c Yes 8 Spill Response The permittee had written spill response procedures for municipal operations. Procedures Comments A spill procedure document was made available prior to the inspection. II.G.2.d Partial Streets, Roads, The permittee evaluated, based on cost and the estimated quantity of pollutants and Public removed, existing and new BMPs annually that reduce polluted stormwater runoff from Parking Lots municipally -owned streets, roads, and public parking lots within its corporate limits. Maintenance Inspection Date: October 3, 2018 Page 22 of 31 MS4Inspection Report Town of Valdese NCS000488 Pollution Prevention and Good Housekeeping for Municipal Operations .Permit Citation Program Requirement - Status supporting Doc No... Comments A verbal estimation was made of the quantity of material removed. No Documentation was available at the time of the inspection. II.G.2.e Yes 4 O&M for Catch The permittee maintained and implemented an 0&M program for the stormwater sewer Basins and system including catch basins and conveyance systems that it owns and maintains. Conveyance Systems Comments The storm drains are cleaned out periodically, through the use of a "vac -truck". Also, all inlets were inspected in 2010 and evaluated for condition. However, major improvements to these systems were not recorded and staff being interviewed were unable to recollect any such improvements taking place. II.G.2.f The permittee maintained a current inventory of municipally -owned or operated Not Structural structural stormwater controls installed for compliance with the permittee's post- Applicabl Stormwater construction ordinance. e Controls Comments Mr. Padgett and Mr. McNeely explained that, due to the lack of construction, there are no existing Structural BMPs. Inspection Date: October 3, 2018 Page 23 of 31 MS4 Inspection Report Town of Valdese NCS000488 Pollution Prevention and Good Housekeeping for Municipal Operations Permit Citation Program Requirement.. Status supporting `Doc No. II.G.2.g The permittee maintained and implemented an 0&M program for municipally -owned or Not O&M for maintained structural stormwater controls installed for compliance with the permittee's Applicabl Structural post -construction ordinance. e Stormwater The O&M program specified the frequency of inspections and routine maintenance Yes 3 Controls requirements. The permittee documented inspections of all municipally -owned or maintained Not Applicabl structural stormwater controls. e The permittee inspected all municipally -owned or maintained structural stormwater No controls in accordance with the schedule developed by permittee. The permittee documented maintenance of all municipally -owned or maintained Not Applicabl structural stormwater controls. e The permittee maintained all municipally -owned or maintained structural stormwater Not Applicabl controls in accordance with the schedule developed b p y permittee. e Comments Inspections conducted in recent years concerning Stormwater have been responsive in nature. II.G.2.h Yes Pesticide, The permittee ensured municipal employees are properly trained. Herbicide and Fertilizer Not Application The permittee ensured contractors are properly trained. Reviewe Management d The permittee ensured all permits, certifications, and other measures for applicators are Yes followed. Comments During the discussion, Mr. Padgett and Mr. McNeely explained that only approved personnel with the town are allowed to apply herbicide, and that they use a contracted exterminator for pesticides. Inspection Date: October 3, 2018 Page 24 of 31 MS4Inspection Report Town of Valdese NCS000488 Pollution Prevention and Good Housekeeping for Municipal Operations Permit Citation program Requirement Status SupportingDoc No. ; II.G.2.1 The permittee implemented an employee training program for employees involved in No Staff Training implementing pollution prevention and good housekeeping practices. Comments No documentation was provided to confirm that any staff other than Mr. McNeely were being trained. II.G.2.i Not Vehicle The permittee described and implemented measures that prevent or minimize RReviewe contamination of stormwater runoff from all areas used for vehicle and equipment Equipment pment cleaning. Cleaning Comments Staff Joe Mcneely, Stormwater Technician (Inspections and public outreach) Interviewed: Greg Padgett, Water Resources Director (Name/Title/ Role) Additional Comments: Inspection Date: October 3, 2018 Page 25 of 31 MS4 Inspection Report Town of Valdese NC5000488 Total Maximum Daily Loads (TMDLs) Applicability Status ❑ The permittee is subject to an approved TMDL for Click here to enter text. © The permittee is NOT subject to an approved TMDL Site Visit Evaluation: Municipal Facility No. 1 Facility Name: Valdese Public Works Date and Time of Site Visit: October 3, 2018 Facility Address: 100 Whisnant St SE Facility Type (Vehicle Maintenance, Landscaping, etc.): Vehicle Maintenance Name of MS4 inspector(s): Joe McNeely Most Recent MS4 Inspection (Date and Entity): 2010 Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit: Name Title Joe McNeely Stormwater Technician Greg Padgett Utilities Manager Observations Facility Documentation/Training Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific? Yes, there is a SWPPP on site as required by the Industrial SW Permit. What type of stormwater training do facility employees receive? How often? None discussed during the inspection. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Various Stormwater training documentation. Most recent being March, 2018. Training is typically received at least annually. Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? Moderately. Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping? Yes. Inspection Date: October 3, 2018 Page 26 of 31 MS4 Inspection Report Town of Valdese NCS000488 Site Visit Evaluation: Municipal Facility No. 1 Inspection Procedures Does the MS4 inspector's process include the use of a checklist or other standardized form? Obtain copy. No. No form has been used due to the lack of regular inspections at the facility. 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)? No 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: SWPPP for the facility was not evaluated. Does the MS4 inspector's process include presenting the inspection findings to the facility contact? Yes Inspection Results Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)? Yes. Severe erosion was observed at an outfall from the facility. Due to the location of two outfalls at the facility, they will need to be cleaned out and have brush removed to allow for proper inspection. If compliance corrective actions were identified, what timeline for correction/follow-up was provided? None at the time of inspection. The inspector will be following up on the issues observed. Notes/Comments/Recommendations During Mr. McNeely's inspection, several items were noted and discussed, but Mr. McNeely and Mr. Padgett were still unaware of what authority the MS4 operator has to ensure that the items will be corrected. Inspection Date: October 3, 2018 Page 27 of 31 MS4 Inspection Report Town of Valdese NCS000488 Site Visit Evaluation: MS4 Outfall No. 1 Outfall ID Number: Date and Time of Site Visit: None October 3, 2018 Outfall Location: Outfall Description (Pipe Material/Diameter, Culvert, etc.): Fraley Road railroad crossing 36" CMP discharging -20 feet from a tributary of Dye Branch. Receiving Water: Is Flow Present? If so, Describe (Color, Approximate Flow Rate, Tributary of Dye Branch Sheen, Odor, Floatables/Debris, etc.): No flow present. Most Recent Outfall Inspection/Screening (Date): 2010 Days Since Last Rainfall: Inches: Unknown Name of MS4lnspector(s): Joe McNeely Observations Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Various Stormwater training documents were provided. Most recent being March, 2018 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 Inspection Date: October 3, 2018 Page 28 of 31 MS4 Inspection Report Town of Valdese NCS000488 Site Visit Evaluation: MS4 Outfall No. 1 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)? Due to severe erosion, the outfall will need to be maintained. Will a follow-up outfall inspection be conducted? If so, for what reason? Mr. Padgett indicated that, before they can proceed further with repairs, they will need to contact the railroad staff and gain permission. Notes/Comments/Recommendations Severe erosion was observed, but due to the outfall's proximity to the railroad, Mr. Padgett and Mr. McNeely were unsure whose responsibility it was to fix the outfall. Both have been made aware that the outfall must be maintained and to contact the railroad for further action. Site Visit Evaluation: MS4 Outfall No. 2 Outfall ID Number: Date and Time of Site Visit: None October 3, 2018 Outfall Location: Outfall Description (Pipe Material/Diameter, Culvert, etc.): Martinat Drive. Concrete pipe coming from a nearby drop -inlet. Inspection Date: October 3, 2018 Page 29 of 31 MS4 Inspection Report Town of Valdese NCS000488 Site Visit Evaluation: MS4 Outfall No. 2 Receiving Water: Is Flow Present? If So, Describe (Color, Approximate Flow Rate, Unnamed Tributary to Hoyle Creek Sheen, Odor, Floatables/Debris, etc.): None Observed Most Recent Outfall Inspection/Screening (Date): 2010 Days Since Last Rainfall: Inches: Unknown Name of MS4lnspector(s): Joe McNeely Observations Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Various stormwater training documents were provided. Most recent being March, 2018 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 Inspection Results Did the outfall inspection result in any work orders or maintenance requests? If so, for what issue(s)? The inspector will be notifying the appropriate staff that the area around the outfall needs to be maintained. Will a follow-up outfall inspection be conducted? If so, for what reason? Yes. An inspection will be conducted in the winter to confirm that the outfall is visible and not in need of repair. Notes/Comments/Recommendations Inspection Date: October 3, 2018 Page 30 of 31 MS4 Inspection Report Town of Valdese NCS000488 Site Visit Evaluation: MS4 Outfall No. 2 This outfall was chosen because it was on a list of outfalls that the MS4 inspector was unable to locate in 2010. Due to the density of vegetation, and possible burying of the outfall, it has still not been located. The MS4 inspector will be returning to this outfall in the winter to confirm its condition. If the outfall cannot be located, a thorough inspection of the upstream and downstream areas should performed to evaluate any potential issues. Inspection Date: October 3, 2018 Page 31 of 31