NCS000488_Valdese Self Audit_20190930

MS4 Permit Audit Report
Town of Valdese, NC: NPDES Permit No. NCS000488
DRAFT PHASE II MS4 AUDIT TEMPLATE
FOR PERMITS ISSUED PRIOR TO 2019
MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM AUDIT REPORT
NPDES PERMIT NO. NCS000474
Town of Valdese, NORTH CAROLINA
102 Massel Avenue
Valdese, NC 28690
Audit Date: 10.3.2018
Report Date: 9.27.2019
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
Audit Date: 9.27.19

MS4 Permit Audit Report
Town of Valdese, NC: NPDES Permit No. NCS000488
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Audit Date: 9.27.19

MS4 Permit Audit Report
Town of Valdese, NC: NPDES Permit No. NC5000488
TABLE OF CONTENTS
AuditDetails..................................................................................................................................................1
PermitteeInformation..................................................................................................................................2
SupportingDocuments, . q , . 6 6 6 6 P d I I d 1 4 1 1 4 1 1 1 1 4 1 1 . . . . . . 6 6 . . W 6 6 . a I d I I d 6 1 4 1 d 1 4 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 P I 1 1 4 1 1 1 1 1 1 1 1 1 1 1 P * 6 & 6 0 6 & 6 4 3
Program Implementation, Documentation & Assessment..........................................................................64
PublicEducation and Outreach, . I 1 1 4 1 4 1 4 1 1 1 1 1 1 1 1 1 1 1 . I & 6 1 6 1 d I I d 1 4 1 4 1 d I I I P , , P . . . . . . . W P 0 N 4 N 4 P 4 4 P I P 4 . . . . . . 6......................7
Public Involvement and Participation.........................................................................................................10
Illicit Discharge Detection and Elimination(IDDE)......................................................................................12
Construction Site Runoff Controls. . I . 1 6 1 * 1 6 6 1 d I I d 1 4 1 1 1 1 1 4 1 1 1 d 6 1 d 6 1 4 1 4 1 4 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 . I . 6 . d 6 t 6 1 1 d I I I P 4 N P 0 4 P P W a '15
Post -Construction Site Runoff Controls......................................................................................................18
Pollution Prevention and Good Housekeeping for Municipal Operations.,.. ... 4,4 ............... P .... 6,6 ... d ....... 4 ..... 23
DISCLAIMER
This audit consists of an evaluation of program compliance with the issued permit and implementation of
the approved Stormwater Management Plan. This audit report does not include a review of all program
components, and program deficiencies in addition to those noted may be present. The permittee is
required to assess program progress and permit compliance, and to implement the approved Stormwater
Management Plan in accordance with the issued permit.
Audit Date: 9.27.19 iii

MS4 Permit Audit Report
Town of Valdese, NC: NPDES Permit No, NCS000488
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Audit Date: 9.27.19 iv

MS4 Permit Audit Report
Town of Valdese, NC: NPDES Permit No, NCS000488
Audit Details
Audit ID Number:
Audit Date(s):
NCS000488 Town of Valdese MS4 Audit 20190909
09.27.2019
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:
❑ Municipal Facilities. Number visited: Choose an item.
❑ MS4Outfalls. Number visited: Choose an item.
❑ Construction Sites. Number visited: Choose an item.
❑ Post -Construction Stormwater Runoff Controls. Number visited: Choose an item.
❑ Other: . Number visited: Choose an item.
❑ Other: . Number visited: Choose an item.
Inspector(s) Conducting Audit
Name. Title
Organization
Alison Adams, Director of Community and Regional Planning
Western Piedmont Council of Government
Greg Padgett, Town Water Resource Director
Town of Valdese
Jack Cline, Stormwater Administrator
Western Piedmont Council of Government
Audit Report uthor:
Date: 09.27.2019
Signat 4a_wn�
Audit Report A thor:
Date
Signature I
/42 C
Audit Report Author:d
Date
Signature 964fzAt
712-F 1'
Audit Date(s): 09,27.2019 Page 1 of 25

MS4 Permit Audit Report
Town of Valdese, NC: NPDES Permit No, NC5000488
Permittee Information
M54 Permittee Name:
Town of Valdese
Permit Effective Date:
02.20.2017
Permit Expiration Date:
02,19.2022
City, State, ZIP:
Valdese, NC 28690
Date of Last MS4 Inspection/Audit:
10.012018
Co-permittee(s), if applicable:
N/A
Permit Owner of Record: Town of Valdese
Primary MS4 Representatives Participating in Audit
Name, Title
Organization
Greg Padgett, Town Water Resource
Director
Town of Valdese
MS4 Receiving Waters
Waterbody
Classification
Impairments
Catawba River 11-(37)
WS-IV, B; CA
Hoyle Creek 11-45 (2)
WS-IV; CA
McGalliard Creek 11-44- (3)
WS-IV; CA
Fish Community (NAR, AL, FW)
Dye Branch 11-44- (2)
WS-IV
Audit Date(s): 09.27.2019 Page 2 of 25

MS4 Permit Audit Report
Town of Valdese, NC: NPDES Permit No, NCS000488
Supporting Documents I
Audit Date(s): 09.27.2019 Page 3 of 25

M54 Permit Audit Report
Town of Valdese, NC: NPDES Permit No, NCS000488
Program Implementation, Documentation & Assessment
Staff Interviewed:
Greg Padgett,
(Name, Title, Role)
Town of Valdese Water Resource Director
Permit Citation
Program Requirement
Status
supporting
Doc No.
II.AA
The permittee maintained adequate funding and staffing to implement and manage
Not
Staffing and
the provisions of the Stormwater Plan and meet all requirements of the permit.
Applicable
___
Funding
The Stormwater Plan identifies a specific position(s) responsible for the overall
Not
coordination, implementation, and revision to the Plan.
Applicable
Responsibilities for all components of the Stormwater Plan are documented and
Not
position(s) assignments provided.
Applicable
The permittee is current on payment of invoiced administering and compliance
Not
monitoring fees (see stormwater e-payments on DEMLR MS4 web page).
Applicable
Comments (Briefly describe funding mechanism, number of staff, etc.)
All items in this section were reviewed during the Annual DEQ Audit. It was mentioned that the Town of Valdese has been in
discussion with the City of Morganton; however since then Valdese has contracted with the COG for all Stormwater services.
II.A.2 Stormwater
The permittee evaluated the performance and effectiveness of the program
Not
Plan
components at least annually.
Applicable
Implementation
and Evaluation
If yes, the permittee used the results of the evaluation to modify the program
Not
components as necessary to accomplish the intent of the Stormwater Program.
Applicable
Did the permitted MS4 discharges cause or contribute to non -attainment of an
applicable water quality standard?
No
---
If yes, did the permittee expand or better tailor its BMPs accordingly to address
Not
the non -attainment?
Applicable
Comments
The only impaired water body in the Town limits is McGalliard creek for fish community issues, for which actions are being taken by
the town to repair the issue caused through a 319 grant and limiting further turbidity issues. All other items above were addressed
during the DEQ Annual audit or were not applicable.
Audit Date(s): 09.27.2019 Page 4 of 25

MS4 Permit Audit Report
Town of Valdese, NC: NPDES Permit No, NC5000488
Program Implementation, Documentation & Assessment
II.A.3
Keeping the
The permittee kept the Stormwater Plan up to date.
Not
Applicable
Stormwater Plan
Up to Date
The permittee notified DEMLR of any updates to the Stormwater Plan.
Not
Applicable
All other items above were addressed during the DIED, Annual audit or were not applicable.
II.A.4 Availability
The permittee Kept an up-to-date version of its Stormwater Plan available to the
of the Stormwater
Division and the public online.
Yes
---
Plan
The online materials included ordinances, or other regulatory mechanisms, or a list
identifying the ordinances, or other regulatory mechanisms, providing the legal
Yes
authority necessary to implement and enforce the requirements of the permit.
All items above were addressed during the DEQAnnual audit; however since the audit the Town of Valdese has placed the
stormwater ordinance in a more accessible location on the Town's utility website— the SWMP will also be uploaded to this location
once it is accepted and adopted.
II.A.S Stormwater
Plan Modifications
Did DEMLR require a modification to the Stormwater Plan?
q
Not
Applicable
If yes, did the permittee complete the modifications in accordance with the
established deadline?
Yes
---
In the audit, "no" was applied to the requirement to modify the stormwater plan; however the Town is in the process of updating
the Stormwater Management Plan, per the DEQ's request to become compliant. The Town of Valdese will be turning in the revised
SWMP to the state within the said time frame per the NOV letter.
![A& Sharing
Responsibility
Are an control measures implemented b an entity other than the permittee?
Y P Y Y P
Not
___
Applicable
If yes, is there a written agreement in place?
Not
Applicable
All items above were addressed during the DEQ Annual audit; however since the audit the Town of Valdese has approved a contract
with the WPCOG for stormwater management.
II.A3
The permittee maintained written procedures for implementing the six minimum
Not
Written
control measures.
Applicable
Procedures
Written procedures identified specific action steps, schedules, resources and
Not
responsibilities for implementing the six minimum measures.
Applicable
All other items above were addressed during the DEQ Annual audit or were not applicable.
Audit Date(s): 09.27.2019 Page 5 of 25

MS4 Permit Audit Report
Town of Valdese, NC: NPDES Permit No, NC5000498
Program Implementation, Documentation & Assessment
IIIA
The permittee maintained documentation of all program components including, but
Program
not limited to, Inspections, maintenance activities, educational programs,
Not
Applicable
Documentation
implementation of BMPs, enforcement actions etc., on file for a period of five years.
All other items above were addressed during the DEQ Annual audit or were not applicable.
111,13
The permittee submitted annual reports to the Department within twelve months
Annual Report
from the effective date of the permit (See Section 111.8. for the annual reporting
Not
Applicable
Submittal
period specific to this MS4).
The permittee submitted subsequent annual reports every twelve months from the
Not
scheduled date of the first annual report submittal.
Applicable
The Annual Reports included appropriate information to accurately describe the progress, status, and results
of the permittee's Stormwater Plan, Including, but not limited the following:
1. A detailed description of the status of implementation of the Stormwater Plan
as a whole. This will include information on development and implementation
Not
of each major component of the Stormwater Plan for the past year and
Applicable
schedules and plans for the year following each report.
2. An adequate description and justification of any proposed changes to the
Stormwater Plan. This will include descriptions and supporting information for
Not
the proposed changes and how these changes will impact the Stormwater
Applicable
Plan (results, effectiveness, Implementation schedule, etc.).
3. Documentation of any necessary changes to programs or practices for
assessment of management measures implemented through the Stormwater
Not
Applicable
Plan.
4. A summary of data accumulated as part of the Stormwater Plan throughout
the year along with an assessment of what the data indicates in light of the
Not
Applicable
Stormwater Plan.
5. An assessment of compliance with the permit, information on the
establishment of appropriate legal authorities, inspections, and enforcement
Not
Applicable
actions.
6. A summary of past year activities, including where applicable, specific
Not
quantities achieved and summaries of enforcement actions.
Applicable
7. A description of the effectiveness of each program component.
Not
Applicable
8. Planned activities and changes for the next reporting period, for each
Not
program component or activity.
Applicable
9. Fiscal analysis.
Not
Applicable
All other items above were addressed during the DEQ Annual audit or were not applicable.
Audit Date(s): 09.27.2019 Page 6 of 25

MS4 Permit Audit Report
Town of Valdese, NC: NPDES Permit No, NCS000488
Program Implementation, Documentation & Assessment
Public Education and Outreach
Staff Interviewed:
Greg Padgett,
(Name, Title, Role)
Town Water Resource Director
Permit Citation
Program Requirement
Status supporting
Doc No.
II.B.2.a
The permittee defined goals and objectives of the Local Public Education and
Not
Goals and
Outreach Program based on community wide issues.
Applicable
Objectives
All other items above
were addressed during the DEQAnnual audit or were not applicable.
II*B.20b
The permittee maintained a description of the target pollutants and/or stressors and
Not
Target Pollutants
likely sources.
Applicable
All other items above
were addressed during the DEQ Annual audit or were not applicable.
II.B.2.c
The permittee identified, assessed annually and updated the description of the target
Not
Target Audiences
audiences likely to have significant storm water impacts and why they were selected.
Applicable
_
All other items above
were addressed during the DEQ Annual audit or were not applicable.
Audit Date(s): 09.27.2019 Page 7 of 25

MS4 Permit Audit Report
Town of Valdese, NC: NPDES Permit No, NCS000488
Program Implementation, Documentation & Assessment
II.B.2.d Residential
The permittee described issues, such as pollutants, the likely sources of those
and Industrial/
pollutants, potential impacts, and the physical attributes of stormwater runoff in
Not
Applicable
Commercial Issues
their education/outreach program.
All other items above were addressed during the DEQ Annual audit or were not applicable.
II.B.2.e
The permittee promoted and maintained an internet web site designed to convey the
Not
Informational
program's message.
Applicable
Web Site
All other items above were addressed during the DEQ Annual audit or were not applicable.
II.B.2.f
The permittee distributed stormwater educational material to appropriate target
Educationpp
7NOtPublic
Materials
groups.
All other items above were addressed during the DEQ Annual audit or were not applicable.
II.B.2.z
The permittee promoted and maintained a stormwater hotline/helplineforthe
Not
Hotline/Help Line
purpose of public education and outreach.
Applicable
All other items above were addressed during the DEQ Annual audit or were not applicable.
tl.B.2.h
The permittee's outreach program, including those elements implemented locally or
through a cooperative agreement, included a combination of approaches designed to
Not
Applicable
reach the target audiences.
Audit Date(s): 09.27.2019 Page 8 of 25

MS4 Permit Audit Report
Town of Valdese, NC: NPDES Permit No. NCS000488
Program Implementation, Documentation & Assessment
Public Education
and Outreach For each media, event or activity, including those elements implemented locally or
Program through a cooperative agreement the permittee estimated and recorded the extent Partial
of exposure.
Post DEQ audit WPCOG has provided a report
of public outreach
and
education to the
Town of Valdese. The COG
is moving from
a regional tactic to a site specific approach. In
this approach the
COG
will be recording
the extent of exposure.
II.B.2.h was previously reviewed during the DEQ audit.
Additional
Comments:
Audit Date(s): 09.27.2019 Page 9 of 25

MS4 Permit Audit Report
Town of Valdese, NC: NPDES Permit No. NCS000488
Public Involvement and Participation
Staff Interviewed:
Greg Padgett,
(Name, Title, Role)
Town Water Resource Director
Permit Citation
Program Requirement
Status supporting
Doc No.
II.C.2.a Volunteer
Community
The permittee included and promoted volunteer opportunities designed to promote
Involvement
ongoing citizen participation.
Yes ---
Program
Post DEQ audit the Town of Valdese is now documenting cleanups by volunteer groups. Trash/stream cleanup has occurred since
the audit with the aid
of Friends of the Valdese
On Saturday, April 6 -12
volunteers collected 12 bags of trash and 3 tires out of the cove and along the shore
line (24 hours total).
Nothing done to roads.
II.C.2.b
Mechanism for
The permittee provided and promoted a mechanism for public involvement that
Not
Public
provides for input on stormwater issues and the stormwater program.
Applicable
Involvement
All other items above
were addressed during the DEQ Annual audit or were not applicable.
II.C.2.c
The permittee promoted and maintained a hotline/helpline for the purpose of public
Not
Hotline/Help Line
involvement and participation.
Applicable
All other items above
were addressed during the DEQ Annual audit or were not applicable.
Audit Date(s): 09.27.2019 Page 10 of 25

MS4 Permit Audit Report
Town of Valdese, NC: NPDES Permit No. NCS000488
and Participation
Additional
Comments:
Audit Date(s): 09.27.2019 Page 11 of 25

MS4 Permit Audit Report
Town of Valdese, NC: NPDES Permit No, NCS000488
Illicit Discharge
Detection and Elimination (IDDE)
Staff Interviewed:
Greg Padgett,
(Name, Title,
Role)
Town Water Resource Director
Permit Citation
Program Requirement
Status supporting
Doc No.
II.D.2.a
IDDE Program
The permittee maintained a written IDDE Program,
Not
Applicable
If yes, the written program includes provisions for program assessment and
Not
evaluation and integrating program.
Applicable
All other items above
were addressed during the DEQ Annual audit or were not applicable.
The permittee maintained an IDDE ordinance or other regulatory mechanism(s) that
Not
provides the legal authority to prohibit illicit connections and discharges to the MS4.
Applicable
II.D.2.b
Legal Authorities
If yes, the ordinance applies throughout the corporate limits of the permittee.
Not
[Permit Part I.D]
Applicable
All other items above
were addressed during the DEQ Annual audit or were not applicable.
II.D.2.c
The permittee maintained a current map showing major outfalls* and receiving
Not
Storm Sewer
streams.
Applicable
pv
___
System Map
Comments
All other items above
were addressed during the DEQAnnual audit or were not applicable.
I I.D.2A
The permittee maintained a program for conducting dry weather flow field
Choose
Dry Weather Flow
observations in accordance with written procedures.
an item.
Program
As mentioned in the DEQ audit no dry weather flow inspections were completed; however now that the Town
of Valdese is
contracted with WPCOG dry weather monitoring will occur during the winter months.
Audit Date(s): 09.27.2019 Page 12 of 25

MS4 Permit Audit Report
Town of Valdese, NO NPDES Permit No. NCS000488
Illicit Discharge Detection and Elimination (IDDE)
II.D.2.e
The permittee maintained written procedures for conducting investigations of
Not
Investigation
identified illicit discharges.
Applicable
Procedures
_
All other items above were addressed during the DEQ Annual audit or were not applicable.
II.D.2.f
For each case of an illicit discharge or potential illicit discharge, the permittee documented and tracked the
Track and
following:
Document
Investigations
1. The dates the illicit discharge was observed
()
Not
Applicable
_
2. The results of the investigation
Not
Applicable
3. Any follow-up of the investigation
Not
Applicable
4. The date the investigation was closed
Not
Applicable
All other items above were addressed during the DEQ Annual audit or were not applicable.
II.D..,g Employee
The permittee implemented and documented a training program for appropriate
Training
municipal staff who, as part of their normal job responsibilities, may come into
Not
---
Applicable
contact with or otherwise observe an illicit discharge or illicit connection.
All other items above were addressed during the DEQ Annual audit or were not applicable.
II.D.2.h
The permittee informed public employees of hazards associated with illegal
Not
Public Education
discharges and improper disposal of waste.
Applicable
---
The permittee informed businesses of hazards associated with illegal discharges and
Not
improper disposal of waste.
Applicable
The permittee informed the general public of hazards associated with illegal
Not
discharges and improper disposal of waste.
Applicable
All other items above were addressed during the DEQ Annual audit or were not applicable.
Audit Date(s): 09.27.2019 Page 13 of 25

MS4 Permit Audit Report
Town of Valdese, NO NPDES Permit No. NCS000488
Illicit Discharge Detection and Elimination (IDDE)
II.D.2.i
The permittee promoted, publicized, and facilitated a reporting mechanism for the
Not
Public Reporting
public to report illicit discharges.
Applicable
___
Mechanism
The permittee promoted, publicized, and facilitated a reporting mechanism for staff
Not
to report illicit discharges.
Applicable
The permittee established and implemented response procedures for citizen
Not
requests/reports.
Applicable
All other items above were addressed during the DEQ Annual audit or were not applicable.
II.D.2.1
The permittee implemented a mechanism to track the issuance of notices of violation
Enforcement
and enforcement actions administered by the permittee.
Yes
If yes, the mechanism includes the ability to identify chronic violators for
initiation of actions to reduce noncompliance.
Yes
---
As mentioned in the DEQ audit, no NOVs were issued; however the Town of Valdese has now contracted with WPCOG for a
proactive approach to monitor illicit discharges. WPCOG will be using a GIS online application to track violations and the process
associated to obtain compliance.
Audit Date(s): 09.27.2019 Page 14 of 25

MS4 Permit Audit Report
Town of Valdese, NC: NPDES Permit No. NCS000488
Construction Site Runoff Controls
Staff Interviewed:
Greg Padgett,
(Name, Title, Role)
Town Water Resource Director
Program Delegation Status:
❑ The permittee has a delegated Sediment and Erosion Control Program and implements the North Carolina
Sedimentation Pollution Control Act (SPCA) of 1973 components of this minimum measure (complete the permit
citation and SPCA citation sections).
© The permittee does not have a delegated Sediment and Erosion Control Program and relies on DEMLR to comply
with the North Carolina Sedimentation Pollution Control Act (SPCA) of 1973 components of this minimum measure
(complete only the permit citation section).
Permit Citation Program Requirement Status supporting
Doc No.
ILE.3 Construction
Site Runoff Controls The permittee provides and promotes a means for the public to notify the
appropriate authorities of observed erosion and sedimentation problems e. Not
(NPDES Permit No.it p ( g" Applicable
NCS000435] promoting the existence of the DEQ DEMLR "Stop Mud" hotline).
The state manages sediment and erosion control for the town —this does not apply.
SPCA Citation
Delegated Program Requirement
Status
supporting
Doc No.
113A-60 Local
The permittee has adopted an ordinance or other regulatory mechanism to enforce
Not
erosion and
the erosion and sedimentation control program.
Applicable
---
sedimentation
control programs (a)
If yes, the ordinance meets or exceeds the minimum requirements of the
Not
SPCA.
Applicable
_
If yes, the ordinance applies throughout the corporate limits of the permittee.
Not
[Permit Part I.D]
Applicable
The state manages sediment and erosion control for the town —this does not apply.
§ 113A-60 Local
erosion and
The permittee collects a fee paid by each person who submits an erosion and
Not
sedimentation
sedimentation control plan.
Applicable
control programs (d)
Audit Date(s): 09.27.2019 Page 15 of 25

MS4 Permit Audit Report
Town of Valdese. NC: NPDES Permit No. NCS000488
Construction Site Runoff Controls
The state manages sediment and erosion control for the town — this does not apply.
11§ 3A-60 Local
Has any person initiated a land -disturbing activity (within the permittee's
erosion and
jurisdiction) for which an erosion and sedimentation control plan is required in the
Not
Applicable
sedimentation
absence of an approved plan?
control programs (e)
If yes, the permittee has notified the North Carolina Sedimentation Control
Not
Commission of all such cases.
Applicable
Has the permittee determined that a person engaged in a land -disturbing activity
Not
has failed to comply with an approved erosion and sedimentation control plan?
Applicable
If yes, has the permittee referred any such matters to the North Carolina
Not
Sedimentation Control Commission for inspection and enforcement?
Applicable
The state manages sediment and erosion control for the town — this does not apply.
11§ 3A-61 Local
The permittee reviews each erosion and sedimentation control plan submitted to
approval of erosion
them and notifies the person submitting the plan that it has been approved,
Not
Applicable
and sedimentation
approved with modification, or disapproved within 30 days of receipt.
control plans
The permittee only approves an erosion and sedimentation control plan upon
Not
determining that it complies with all applicable State and local regulations.
Applicable
The permittee has disapproved of an erosion and sedimentation control plan in
Not
order to protect riparian buffers along surface waters.
Applicable
If yes, the permittee notified the Director of the Division of Energy,
Not
Mineral, and Land Resources within 10 days of the disapproval.
Applicable
The state manages sediment and erosion control for the town —this does not apply.
§ 113A-61.1
Inspection of land-
The certificate of approval of each erosion and sedimentation control plan
Not
disturbing activity;
approved by the permittee includes a notice of the right to inspect.
Applicable
notice of violation
(a)
The permittee provides for inspection of land -disturbing activities to ensure
compliance with the SPCA and to determine whether the measures required in an
Not
Applicable
erosion and sedimentation control plan are effective.
The state manages sediment and erosion control for the town —this does not apply.
Audit Date(s): 09.27.2019 Page 16 of 25

MS4 Permit Audit Report
Town of Valdese, NC: NPDES Permit No. NCS000488
Construction Site Runoff Controls
§ 113A-61.1
When the permittee determines that a person engaged in land -disturbing activity
Inspection of land-
has failed to comply with the SPCA, the Permittee immediately issues a notice of
Not
Applicable
disturbing activity;
violation upon that person.
notice of violation
Each notice of violation issued by the permittee specifies the date by which the
Not
(c)
person must comply.
Applicable
Each notice of violation issued by the permittee informs the person of the actions
Not
that need to be taken to comply.
Applicable
The state manages sediment and erosion control for the town — this does not apply.
11§ 3A-64 Penalties
Does the permittee issue civil penalties as part of the erosion and sedimentation
Not
program?
Applicable
The state manages sediment and erosion control for the town — this does not apply.
Audit Date(s): 09.27.2019 Page 17 of 25

MS4 Permit Audit Report
Town of Valdese, NC: NPDES Permit No, NCS000488
Post -Construction Site Runoff Controls
Staff Interviewed: Greg Padgett,
(Name, Title, Role)
Town Water Resource Director
Implementation (check all that apply):
❑ The permittee implements the components of this minimum measure.
❑ The permittee relies upon another entity to implement the components of this minimum measure:
N 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-I) — 15A NCAC 2B .0212
❑ Water Supply Watershed ll(WS-II)-15ANCAC 2B.0214
❑ Water Supply Watershed III (WS-III) —15A NCAC 2B .0215
N Water Supply Watershed IV (WS-IV) —15A NCAC 2B .0216
❑ Freshwater High Quality Waters (HOW) —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 2B .0251
❑ Universal Stormwater Management Program —15A NCAC 2H .1020
Ordinance(s) (check all that apply):
The permittee utilizes the following ordinances and/or regulatory authority to fulfill post construction minimum measure program
requirements throughout the MS4 permitted area (check all that apply):
N DEQ model ordinance
❑ MS4 designed post -construction practices that meet or exceed 15A NCAC 02H .1000.
❑ DEQ approved comprehensive watershed plan
N DEQ approved ordinance for a deemed -compliant Program (see list above)
Instructions:
For MS4s not implementing a S.L. 2006-246 deemed -compliant program, complete only the Permit Citation section below.
For MS4s implementing a S.L. 2006-246 deemed -compliant program, complete the Session Law 2006-246 section below. If the MS4
does not implement a deemed -compliant program throughout the entire MS4 permitted area, then complete the Permit Citation
section below for the permitted area(s) not covered under the S.L. 2006-246 deemed -compliant program.
Session Law 2006- program Requirement Status supporting
246 Doc No.
Audit Date(s): 09.27.2019 Page 18 of 25

MS4 Permit Audit Report
Town of Valdese, NC: NPDES Permit No. NC5000488
Post -Construction Site Runoff Controls
Deemed -Compliant
The permittee implements deemed -compliant Program requirements in
Program(s)
accordance with the applicable 15A NCAC rules.
Yes
---
The permittee implements deemed -compliant Program requirements throughout
the entire MS4 area (If not also complete the Permit Citation section below.)
Yes
---
The permittee applies deemed -compliant Program requirements to all federal,
state and local government projects within the permitted MS4 area who do not
Yes
---
have their own NPDES stormwater permit.
The permittee included deemed -compliant Program reporting in their MS4 Annual
Reports,
Yes
The permittee included deemed -compliant Program implementation in their
Stormwater Management Plan.
Yes
---
The Town either has previously used compliant components or is now planning to apply them.
Permit Citation
Program Requirement
Status
supporting
Doc No.
II.F.2.a
The permittee maintained an ordinance or other regulatory mechanism designed
Legal Authority
to meet the objectives of the Post -Construction Site Runoff Controls Stormwater
Not
Applicable
Management Program.
If yes, the ordinance applies throughout the corporate limits of the permittee
(Verify permit coverage area listed in Part LD of permit and modify
Not
Applicable
accordingly).
The permittee has the authority to review designs and proposals for new
development and redevelopment to determine whether adequate stormwater
Not
Applicable
control measures will be installed, implemented, and maintained.
The permittee has the authority to request information such as stormwater plans,
inspection reports, monitoring results, and other information deemed necessary to
Not
evaluate compliance with the Post -Construction Stormwater Management
Applicable
Program.
The permittee has the authority to enter private property for the purpose of
inspecting at reasonable times any facilities, equipment, practices, or operations
Not
Applicable
related to stormwater discharges.
All other items above were addressed during the DEQ Annual audit or were not applicable.
II.F.2.b
Stormwater Control
The permittee utilizes strategies which include SCMs appropriate for the MS4.
Not
---
Applicable
Measures (SCMs)
SCMs comply with 15A. NCAC 02H .1000.
Not
.
Applicable
Audit Date(s):09.27.2019 Page 19 of 25

MS4 Permit Audit Report
Town of Valdese, NC: NPDES Permit No. NCS000488
Post -Construction Site Runoff Controls
Comments
The Town currently does not have any SCMs, but the components are in place in case they are needed.
ILF.2.c
The permittee conducted site plan reviews of all new development and
Plan Reviews
redeveloped sites that disturb greater than or equal to one acre (including sites
Not
that disturb less than one acre that are part of a larger common plan of
Applicable
development or sale).
If yes, the site plan reviews addressed how the project applicant meets the
Not
performance standards.
Applicable
If yes, the site plan reviews addressed how the project will ensure long-term
Not
maintenance.
Applicable
---
Comments
There has been little to no development in the Town of Valdese that would trigger Phase II application. The appropriate measures
are in place to ensure long term maintenance such as bonds, recorded easements, and if the Town does have a private SCM
installed implementation of an 0 & M would be needed.
ILF.2.d
The permittee maintained an inventory of projects with post -construction
Inventory of Projects
structural stormwater control measures installed and implemented at new
Not
Applicable
development and redeveloped sites.
The inventory included both public and private sector sites located within the
permittee's corporate limits that are covered by its post -construction ordinance
Not
Applicable
requirements.
Comments
No structures, so nothing to report. If structures existed, or as they are developed in the future, then a list will be maintained.
ILF.2.e
The permittee provided mechanisms such as recorded deed restrictions and
Deed Restrictions
Not
protective covenants that ensure development activities will maintain the project
---
and Protective
Applicable
consistent with approved plans.
Covenants
Comments
This item above was addressed during the DEQ Annual audit
ILF.2.f
The permittee implemented or required an operation and maintenance plan for
Mechanism to
the long-term operation of the SCMs required by the program.
No
---
Require Long-term
Operation and
The operation and maintenance plan required the owner of each SCM to perform
Maintenance
and maintain a record of annual inspections of each SCM.
No
---
Annual inspection of permitted structural SCMs are required to be performed by a
Not
qualified professional.
Applicable
Comments
0&M Plan was not previously in place; however it will be developed for facilities that require one.
Audit Date(s): 09.27.2019 Page 20 of 25

MS4 Permit Audit Report
Town of Valdese, NC: NPDES Permit No. NC5000488
Post -Construction Site Runoff Controls
II.F.2.g
The permittee conducted and documented inspections of each project site covered
Inspections of
under performance standards, at least one time during the permit term (Verify this
Not
Applicable
Structural
is a permit condition in Part II.F.2.g of permit and modify accordingly).
Stormwater Control
Before issuing a certificate of occupancy or temporary certificate of occupancy, the
Measures
permittee conducted a post -construction inspection to verify that the permittee's
performance standards have been met or a bond Is in place to guarantee
Not
Applicable
completion(Verify this is a permit condition in Part II.F.2.g of permit and modify
accordingly.
The permittee developed and implemented a written Inspection program for SCMs
installed pursuant to the post -construction program (Verify this is a permit
Not
Applicable
condition in Part II.F.2.g of permit and modify accordingly.
The permittee documented and maintained records of inspections.
Not
---
Applicable
The permittee documented and maintained records of enforcement actions.
Not
Applicable
Due to there being no SCMs inspections have not occurred. There was previously an inspection program in place; however it will be
brought up to current state standard.
II.F.2.h
The permittee made available through paper or electronic means, ordinances,
Educational
post -construction requirements, design standards checklists, and other materials
Materials and
appropriate for developers.
Not
Training for
Note: New materials maybe developed by the permittee, or the permittee may use
Applicable
Developers
materials adopted from other programs and adapted to the permittee's new
development and redevelopment program.
This items above was addressed during the DEQ Annual audit
II.F.Z.i Enforcement
The permittee tracked the issuance of notices of violation and enforcement
Not
actions.
Applicable
---
If yes, the tracking mechanism included the ability to identify chronic violators
Not
for initiation of actions to reduce noncompliance.
Applicable
This items above was addressed during the DEQAnnual audit
II.F.3.b
The permittee fully complies with post construction program requirements on its
Not
New Development
own publicly funded construction projects.
Applicable
To date there have been no publicly funded projects. Should a new project be developed from public funds, the systems to'comply
with post construction requirements will be in place.
Audit Date(s): 09.27.2019 Page 21 of 25

MS4 Permit Audit Report
Town of Valdese, NC: NPDES Permit No, NCS000488
Post"Construction Site Runoff Controls
II.F3.c
Does the MS4 have areas drainingto Nutrient Sensitive Waters NSW
(NSW) pursuant to
Nutrient Sensitive
15A NCAC 02H .0150?
No
Waters
If yes, does the permittee use SCMIs that reduce nutrient loading in order to
Not
meet local program requirements.
Applicable
---
If yes, does the permittee also still incorporate the stormwater controls
Not
required for the project's density level.
Applicable
If yes, does the permittee also require documentation where It is not feasible to
Not
use SCMs that reduce nutrient loading.
Applicable
This items above was addressed during the DEQ Annual audit, however, it is not applicable to the Town of Valdese as they do not
have any NSW to make this a required program component.
II.F.3.d
The permittee ensured that the design volumes of SCMs take into account the
Not
Design Volume
runoff at build out from all surfaces draining to the system.
Applicable
Where "streets" convey stormwater, the permittee designed SCMs to be sized to
treat and control stormwater runoff from all surfaces draining to the SCM including
Not
Applicable
streets, driveways, and other impervious surfaces.
Comments
This items above was addressed during the DEQ Annual audit, "The Town of Valdese relies on DEMLR design standards for SCMs."
Audit Date(s): 09.27:2019 Page 22 of 25

M54 Permit Audit Report
Town of Valdese, NC: NPDES Permit No, NCS000488
Pollution Prevention and Good Housekeeping for Municipal Operations
Staff Interviewed:
Greg Padgett,
(Name, Title, Role)
Town Water Resource Director
Permit Citation
Program Requirement
Status supporting
Doc No.
II.G.2.a
The permittee maintained a current inventory of facilities and operations owned
Facility Inventory
and operated by the permittee with the potential for generating polluted
Not
Applicable I
stormwater runoff.
Comments (Note number of facilities, typical inventory data and anyfacilities that are not inventoried that
should be)
All other items above
were addressed during the DEQ Annual audit or were not applicable.
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
p p g g polluted
Not
ApplicableMaintenance
(O&M)
stormwater runoff.
for Facilities
If yes, the 0&M program specifies the frequency of inspections.
Not
Applicable
If yes, the O&M program specifies the frequency of routine maintenance
Not
requirements.
Applicable
If yes, the permittee evaluated the O&M program annually and updated it as
Not
necessary.
Applicable
---
Comments
All other items above
were addressed during the DEQ Annual audit or were not applicable.
II.G.2.c
Spill Response
The permittee had written spill response procedures for municipal operations.
Not
Applicable
Procedures
Comments
All other items above
were addressed during the DEQ Annual audit or were not applicable.
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
Partial
corporate limits annually.
Audit Date(s): 09.27.2019 Page 23 of 25

M54 Permit Audit Report
Town of Valdese, NC: NPDES Permit No, NC5000488
Pollution Prevention and Good Housekeeping for Municipal Operations
Parking Lots
If yes, the permittee evaluated the effectiveness of existing and new BMPs
Not
Maintenance
based on cost and the estimated quantity of pollutants removed.
Applicable
.__
Comments
All other items above were addressed during the DEQ Annual audit or were not applicable. Since the DEQ audit the Town of Valdese
has now began documenting the quantity of the material removed.
March 2019, Friends of the Valdese Rec cleaned Lovelady and Meytre Streets. 30 Bags of trash, 16 people, 40 hours - roadside
cleanup
II.G.2.f
O&M for Catch
The permittee maintained and implemented an 0&M program for the stormwater
Basins and
sewer system including catch basins and conveyance systems that it owns and
Not
Applicable
maintains.
Conveyance Systems
Comments (Briefly describe O&M program)
All other items above were addressed during the DEQAnnual audit or were not applicable.
II.G.2.e
The permittee maintained a current inventory of municipally -owned or operated
Structural
structural stormwater controls installed for compliance with the permittee's post-
Not
Stormwater Controls
construction ordinance.
Applicable
Comments (Describe inventory information and number of controls in inventory)
All other items above were addressed during the DEQ Annual audit or were not applicable.
II.G.2.h
The permittee maintained and implemented an C&M program for municipally -
O&M for Structural
owned or maintained structural stormwater controls installed for compliance with
Not
Stormwater Controls
the permittee's post -construction ordinance. If yes, then:
Applicable
The 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 -awned or maintained structural
Not
stormwater controls in accordance with the schedule developed by permittee.
Applicable
The permittee documented maintenance of all municipally -owned or
Not
maintained structural stormwater controls.
Applicable
---
Comments
All other items above were addressed during the DEQ Annual audit or were not applicable.
Audit Date(s): 09.27.2019 Page 24 of 25

MS4 Permit Audit Report
Town of Valdese, NC: NPDES Permit No, NCS000488
Pollution Prevention and Good Housekeeping for Municipal Operations
Pesticide,
Pesticide, Herbicide
The permittee ensured municipal employees are ro properly trained in pesticide,
P PP P y P
Not
and Fertilizer
herbicide and fertilizer application management.
Applicable
Application
The permittee ensured contractors are properly trained in pesticide, herbicide and
Management
fertilizer application management.
Partial
The permittee ensured all permits, certifications, and other measures for
Not
applicators are followed.
Applicable
---
Comments
The Town hired certified contractors, but did not keep a record of the contractor's certifications on file. All other items above were
addressed during the DEQ Annual audit or were not applicable.
II.G.2.j
Staff Training
The ermittee implemented an employee trainin
P Pg program for employees Involved
n implementing pollution prevention and good housekeeping
P g p' g practices.
Partial
Comments
During the audit this measurement was not reviewed. Training is being done in each department by department head. The
stormwater technician was not involved with doing any training of staff. Documentation was not included with the stormwater
plan. Once the revisions to the stormwater management plan are accepted by DEQ and the new plan is adopted by the town, staff
will be required to attend training. A log of when, who, and the subject matter will be recorded.
11.G.2.k
The permittee described and implemented measures that prevent or minimize
Vehicle and
contamination of stormwater runoff from all areas used for vehicle and equipment
Yes
---
Equipment Cleaning
cleaning.
Comments
Municipal vehicles are maintained at the public works facility at 100 Whisnant Street. Vehicles are washed and serviced indoors. A
few pieces of equipment are maintained at wastewater plant. There is a dedicated area for this, drains into the sanitary wastewater
treatment system.
,vuart uate(s): 09.27.2019 Page 25 of 25