HomeMy WebLinkAboutPackets - Stormwater Utillity Commission (199)
AGENDA
STORMWATER UTILITY COMMISSION
REGULAR SESSION
JANUARY 16, 2025
HOPI CONFERENCE ROOM
11000 N. LA CAÑADA DRIVE
REGULAR SESSION AT OR AFTER 4:00 PM
CALL TO ORDER
ROLL CALL
CALL TO AUDIENCE - at this time, any member of the public is allowed to address the Commission on any
issue not listed on today’s agenda. Pursuant to the Arizona open meeting law, individual Commission
members may ask Town staff to review the matter, ask that the matter be placed on a future agenda, or
respond to criticism made by speakers. However, the Commission may not discuss or take legal action on
matters raised during "Call to Audience." In order to speak during "Call to Audience", please specify what
you wish to discuss when completing the blue speaker card.
COUNCIL LIAISON COMMENTS (INFORMATIONAL ONLY)
DIRECTORS REPORT (INFORMATIONAL ONLY)
REGULAR SESSION AGENDA
1.REVIEW AND APPROVAL OF THE NOVEMBER 21, 2024 MEETING MINUTES
2.NOMINATION AND ELECTION OF STORMWATER UTILITY COMMISSION CHAIR EFFECTIVE
JANUARY 17, 2025
3.NOMINATION AND ELECTION OF STORMWATER UTILITY COMMISSION VICE CHAIR EFFECTIVE
JANUARY 17, 2025
4.DISCUSSION REGARDING THE STORMWATER UTILITY COMMISSION REGULAR SESSION
MEETING SCHEDULE FOR CALENDAR YEAR 2025
5.DISCUSSION OF MEETINGS AND EVENTS
6.DISCUSSION OF 2024/2025 TOWN OF ORO VALLEY MS4 COMPLIANCE SCHEDULE,
SECOND QUARTER REPORT
7.DISCUSSION OF RESULTS OF NOVEMBER 14, 2024 TOWN OF ORO VALLEY MS4 AUDIT BY ADEQ
ADJOURNMENT
POSTED: 1/13/25 at 5:00 PM by dt
POSTED: 1/13/25 at 5:00 PM by dt
When possible, a packet of agenda materials as listed above is available for public inspection at least 24 hours prior
to the Commission meeting in the Town Clerk's Office between the hours of 8:00 a.m. – 5:00 p.m.
The Town of Oro Valley complies with the Americans with Disabilities Act (ADA). If any person with a disability needs
any type of accommodation, please notify the Town Clerk’s Office at least five days prior to the Commission meeting
at 229-4700.
INSTRUCTIONS TO SPEAKERS
Members of the public have the right to speak during any posted public hearing. However, those items not
listed as a public hearing are for consideration and action by the Commission during the course of their
business meeting. Members of the public may be allowed to speak on these topics at the discretion of the
Chair.
If you wish to address the Commission on any item(s) on this agenda, please complete a blue speaker card located
on the Agenda table at the back of the room and give it to the Recording Secretary. Please indicate on the
speaker card which item number and topic you wish to speak on, or if you wish to speak during “Call to
Audience,” please specify what you wish to discuss when completing the blue speaker card.
Please step forward to the podium when the Chair announces the item(s) on the agenda which you are interested in
addressing.
1. For the record, please state your name and whether or not you are a Town resident.
2. Speak only on the issue currently being discussed by the Commission. Please organize your speech, you will only
be allowed to address the Commission once regarding the topic being discussed.
3. Please limit your comments to 3 minutes.
4. During “Call to Audience”, you may address the Commission on any issue you wish.
5. Any member of the public speaking must speak in a courteous and respectful manner to those present.
Thank you for your cooperation.
“Notice of Possible Quorum of the Oro Valley Town Council, Boards, Commissions and Committees: In accordance
with Chapter 3, Title 38, Arizona Revised Statutes and Section 2-4-4 of the Oro Valley Town Code, a majority of the
Town Council, Board of Adjustment, Historic Preservation Commission, Parks and Recreation Advisory Board,
Stormwater Utility Commission, and Water Utility Commission may attend the above referenced meeting as a
member of the audience only.”
Stormwater Utility Commission 1.
Meeting Date:01/16/2025
Requested by: Dennis Roberts, Public Works Submitted By:Yarina Hynd, Public Works
SUBJECT:
REVIEW AND APPROVAL OF THE NOVEMBER 21, 2024 MEETING MINUTES
RECOMMENDATION:
Staff recommends approval.
EXECUTIVE SUMMARY:
N/A
BACKGROUND OR DETAILED INFORMATION:
N/A
FISCAL IMPACT:
N/A
SUGGESTED MOTION:
I MOVE to approve (approve with changes), the November 21, 2024 meeting minutes.
Attachments
11-21-24 Draft Minutes
D R A F T
MINUTES
STORMWATER UTILITY COMMISSION
REGULAR SESSION
NOVEMBER 21, 2024
HOPI CONFERENCE ROOM
11000 N. LA CAÑADA DRIVE
REGULAR SESSION AT OR AFTER 4:00 PM
CALL TO ORDER
Chair Crocker called the meeting to order at 4:00 P.M.
ROLL CALL
Present: Richard Hawkinson, Commissioner
Rob Schlicher, Commissioner
Richard Crocker, Chair
Absent: Gary Mattson, Vice Chair
Staff Present:Aimee Ramsey, Deputy Director Public Works
Dennis Roberts, Interim Stormwater Division Manager
Attendees: Joyce Jones-Ivey, Town Council Liaison
Vice Chair Mattson arrived at 4:01
CALL TO AUDIENCE
There were no speaker requests at this time.
COUNCIL LIAISON COMMENTS (INFORMATIONAL ONLY)
Councilmember Joyce Jones-Ivey sat in for Councilmember Dr. Harry Greene for this meeting.
Councilmember Jones-Ivey comments:
When she was first on Town Council, she was the liaison for the Stormwater Utility Commission (SWUC)
and wanted to say thank you to and remind the Commission that the Stormwater Utility (SWU) and the
SWUC are unsung heroes for all we do to contribute to the infrastructure of the Town
Explore OV app
Oro Valley Holiday Festival of the Arts on Dec 7
Project Graduation to help students have a safe graduation
Town Council's vote to approve the zoning code amendment to require a Conditional Use Permit for
vehicle storage facilities
DIRECTORS REPORT (INFORMATIONAL ONLY)
11/21/24 Minutes, Stormwater Utility Commission Regular Session 1
DIRECTORS REPORT (INFORMATIONAL ONLY)
Aimee Ramsey Deputy Director Public Works commented on the following:
Thank You to Councilmember Jones-Ivey for stepping in for Councilmember Greene who was unable to
attend today's meeting
Introduction of Dennis Roberts as the Interim Stormwater Utility Division Manager
Cancellation of December 19 2025 Stormwater Utility Meeting
At the January 16 2025 meeting Ms. Ramsey will have a presentation for the Commission on the Notice of
Intent for the Rate Review for F/Y 2025/26
REGULAR SESSION AGENDA
1.REVIEW AND APPROVAL OF THE SEPTEMBER 19, 2024 MEETING MINUTES
Motion by Commissioner Richard Hawkinson, seconded by Vice Chair Gary Mattson to approve the
September 19, 2024 regular session minutes as written.
Vote: 4 - 0 Carried
2.DISCUSSION OF MEETINGS AND EVENTS
Mr. Roberts discussed recent meetings and events.
3.RECOGNITION OF OUTGOING STORMWATER UTILITY COMMISSIONER GARY MATTSON
Mr. Roberts gave a thank you and farewell to Vice Chair Mattson for his four years of service to the
Stormwater Utility Commission.
Vice Chair Mattson commented that the SWU staff is the most efficient effective staff he has ever
encountered over 45 years of working with small towns. The SWU staff is always concerned about
bringing efficient, effective delivery of services to this Town.
Chair Crocker commented that since he has been on the Commission the last three years, he has
appreciated Vice Chair Mattson's financial experience and comments on how we try to set rates and
financial things looking into the future. Chair Crocker also commented on how he echoes Vice Chair
Mattson's comments about the SWU staff, and that he has been amazed at how far forward-looking the
Stormwater Utility Department is.
4.DISCUSSION OF 2024/2025 TOWN OF ORO VALLEY MS4 COMPLIANCE SCHEDULE FIRST
QUARTER REPORT
Mr. Roberts reported on the Towns 2024/2025 MS4 Compliance Schedule, Quarter 1, July–September
2024 time period. The summary table shows that the SWU is up to date and has met their quarterly
goals.
Ms. Ramsey commented that the items presented on this schedule that the SWU brings before the
Commission quarterly, are rolled up into our Annual Report at the end of the year. We are right on track
with this schedule.
5.DISCUSSION OF NOVEMBER 14, 2024 TOWN OF ORO VALLEY MS4 AUDIT BY ADEQ
Mr. Roberts reported that on October 16, 2024 the Town of Oro Valley (the Town) was informed that
11/21/24 Minutes, Stormwater Utility Commission Regular Session 2
Mr. Roberts reported that on October 16, 2024 the Town of Oro Valley (the Town) was informed that
the Town was going to be audited by the Arizona Department of Environmental Quality (ADEQ) on
November 14, 2024.
The field observations encompassed visits to four locations within the Town. The audit included an
examination of records and on-site observations. The ADEQ intended to visit one active construction
site, one completed construction site, a municipal site, and one of the Town's MS4 outfall locations. Mr.
Roberts reported that the audit went extremely well. The findings will be reported at the January 16,
2025 SWUC meeting.
6.DISCUSSION AND POSSIBLE ACTION REGARDING THE ANNUAL STORMWATER UTILITY RATE
ANALYSIS RECOMMENDATION TO MAYOR AND COUNCIL FOR FISCAL YEAR 2025/26
Ms. Ramsey stated that the SWUC has gone through numerous presentations and spreadsheets over
the past year. If the SWUC moves to approve the rate increase at this meeting, the next steps to be
taken are referenced in the attached document Timeframe for SWU Rate Adjustment.
Stormwater Utility will have a meeting with Councilmembers and Town Manager Jeff Wilkins to get
approval to go to Council. At the January SWUC meeting, the same presentation that will be brought to
the Town Council will be brought before the SWUC for feedback. The authorization to advertise for
Notice of Intent to Adjust the SWU Rate will be on the Town Council March 2025 Agenda.
Vice Chair Mattson commented that since he became a member of the SWUC 4 years ago, many
financial discussions have taken place over a long period of time.
Motion by Vice Chair Gary Mattson, seconded by Commissioner Richard Hawkinson to approve a
recommendation to the Mayor and Council to support a Stormwater Utility base rate increase of $2.00 per
month per Equivalent Residential Unit.
Vote: 4 - 0 Carried
ADJOURNMENT
Motion by Commissioner Rob Schlicher, seconded by Vice Chair Gary Mattson to adjourn the meeting.
Vote: 4 - 0 Carried
Chair Crocker adjourned the meeting at 4:33 P.M.
I hereby certify that the foregoing minutes are a true and correct copy of the minutes of the regular session of the
Town of Oro Valley Stormwater Utility Commission of Oro Valley, Arizona held on the 21st day of November 2024.
I further certify that the meeting was duly called and held and that a quorum was present.
___________________________
Yarina Hynd
Senior Office Specialist
11/21/24 Minutes, Stormwater Utility Commission Regular Session 3
Stormwater Utility Commission 2.
Meeting Date:01/16/2025
Requested by: Dennis Roberts, Public Works Submitted By:Yarina Hynd, Public Works
SUBJECT:
NOMINATION AND ELECTION OF STORMWATER UTILITY COMMISSION CHAIR EFFECTIVE JANUARY 17,
2025
RECOMMENDATION:
N/A
EXECUTIVE SUMMARY:
Section 3-6-4 of the Oro Valley Town Code states, "The board shall elect its own officers annually...".
BACKGROUND OR DETAILED INFORMATION:
Chair Crocker will open and close nominations. All Commissioners are eligible for consideration.
FISCAL IMPACT:
N/A
SUGGESTED MOTION:
I MOVE to elect ________________ as Stormwater Utility Commission Chair.
Stormwater Utility Commission 3.
Meeting Date:01/16/2025
Requested by: Dennis Roberts, Public Works Submitted By:Yarina Hynd, Public Works
SUBJECT:
NOMINATION AND ELECTION OF STORMWATER UTILITY COMMISSION VICE CHAIR EFFECTIVE JANUARY
17, 2025
RECOMMENDATION:
N/A
EXECUTIVE SUMMARY:
Section 3-6-4 of the Oro Valley Town Code states, "The board shall elect its own officers annually...".
BACKGROUND OR DETAILED INFORMATION:
Chair Crocker will open and close nominations. All Commissioners are eligible for consideration.
FISCAL IMPACT:
N/A
SUGGESTED MOTION:
I MOVE to elect ________________ as Stormwater Utility Commission Vice Chair.
Stormwater Utility Commission 4.
Meeting Date:01/16/2025
Requested by: Dennis Roberts, Public Works Submitted By:Yarina Hynd, Public Works
SUBJECT:
DISCUSSION REGARDING THE STORMWATER UTILITY COMMISSION REGULAR SESSION MEETING
SCHEDULE FOR CALENDAR YEAR 2025
RECOMMENDATION:
This report is for informational purposes only. No action is required to be taken.
EXECUTIVE SUMMARY:
The Town of Oro Valley Stormwater Utility Commission holds their Regular Session Meetings on the 3rd Thursday
of the month at 4:00 p.m. The attached document lists the anticipated meeting dates for regular meetings of the
Stormwater Utility Commission for 2025.
BACKGROUND OR DETAILED INFORMATION:
Town Code Section 15-24-6 establishes a Town of Oro Valley Stormwater Utility Commission comprised of five (5)
Oro Valley residents, and the Mayor and Council shall appoint the members. Commissioners serve two-year terms,
with possible reappointment for a second term.
Regular Session Meetings are scheduled on the 3rd Thursday of the month at 4:00 p.m.
Topics discussed during Regular Session Meetings are mostly informational related to ongoing SW projects and
administrative reports. One exception to this is the requirement in Town Code 15-24-13 Section H that the
Stormwater Utility Commission (SWUC) annually review the Stormwater Utility revenue requirements and
recommend to the Town Council rate adjustments as necessary.
FISCAL IMPACT:
N/A
SUGGESTED MOTION:
This report is informational only.
Attachments
2025 SWUC Meeting Schedule
ORO VALLEY STORMWATER UTILITY COMMISSION
REGULAR MEETING SCHEDULE
2025
SWUC MEETING DATES (3RD THURSDAY at 4:00pm)
January 16, 2025
February 20, 2025
March 20, 2025
April 17, 2025
May 15, 2025
June 19, 2025
July 17, 2025
August 21, 2025
September 18, 2025
October 16, 2025
November 20, 2025
December 18, 2025 (typically a canceled meeting to coincide with Town Council Holiday Schedule)
Stormwater Utility Commission 5.
Meeting Date:01/16/2025
Requested by: Dennis Roberts, Public Works Submitted By:Dennis Roberts, Public Works
SUBJECT:
DISCUSSION OF MEETINGS AND EVENTS
RECOMMENDATION:
N/A
EXECUTIVE SUMMARY:
The following is a list of immediate past, and future, stormwater meetings and events.
November 21, 2024 - Oro Valley Stormwater Utility Commission Meeting
December 17, 2024 - Oro Valley Stormwater Utility Commission Meeting (CANCELED)
January 15, 2025 - Pima County Regional Flood Control Advisory Committee Meeting
January 16, 2025 - Oro Valley Stormwater Utility Commission Meeting
BACKGROUND OR DETAILED INFORMATION:
For informational purposes only.
FISCAL IMPACT:
N/A
SUGGESTED MOTION:
N/A
Stormwater Utility Commission 6.
Meeting Date:01/16/2025
Requested by: Dennis Roberts, Public Works Submitted By:Scott Bennett, Public Works
SUBJECT:
DISCUSSION OF 2024/2025 TOWN OF ORO VALLEY MS4 COMPLIANCE SCHEDULE, SECOND
QUARTER REPORT
RECOMMENDATION:
This report is for informational purposes only.
EXECUTIVE SUMMARY:
The Town of Oro Valley's Stormwater Management Program and Annual Report to ADEQ outline the Minimum
Control Measures (MCMs) implemented to manage and control the quality of stormwater runoff from the MS4. Each
MCM has assigned implementation dates and frequencies, measurable goals, and designated departments
responsible for them. This memorandum serves as a report regarding the Town’s Stormwater Management
Program for the second quarter of the Annual Reporting Period for 2024-2025, covering the dates from October 1st
to December 31st. This document has been created to update stakeholders on the status of project implementation,
detailing completed tasks that are either (A) ongoing or continuous, or (B) scheduled to be performed at least once
each year. Enclosed with this Memorandum is a summary table that details each of the six (6) required MCMs along
with their corresponding subset of Best Management Practices (BMPs). This summary table indicates that the
Stormwater Utility is current and has successfully achieved this quarter’s objectives for the ongoing and continuous
implementation of BMPs.
BACKGROUND OR DETAILED INFORMATION:
The Town oversees stormwater quality following the guidelines set by the Arizona Pollutant Discharge Elimination
System (AZPDES) Permit AZG2021-002, which permits the discharge of stormwater from the municipal separate
storm sewer system (MS4) into receiving waters, including Waters of the United States (WOTUS). The MS4
typically includes roads, storm drains, and infrastructure that directs runoff into drainage systems or temporary
stream channels. The Town has implemented a Stormwater Management Program (SWMP) that outlines the
control measures employed to manage the quality of discharges from the MS4. The following are the Best
Management Practices (BMPs):
MCM-1. Public Education and Outreach
MCM-2. Public Participation and Involvement
MCM-3. Illicit Discharge Detection and Elimination
MCM-4. Construction Site Runoff Control
MCM-5. Post-Construction Runoff Control
MCM-6. Pollution Prevention/Good Housekeeping for Municipal Operations
The Town’s Stormwater Management Program outlines the practices employed to ensure compliance with Part 6.4
of the AZPDES Permit concerning Minimum Control Measures. It includes detailed implementation dates and
frequencies, measurable goals, and the departments responsible for these actions. Our team monitors these
thirty-three (33) specific responsibilities and has created the attached summary table that outlines project
implementation regarding completed tasks that are either (A) ongoing or continuous, or (B) to be performed at least
once each year. The attached summary Table indicates that the Stormwater Utility is completely current and has
successfully achieved this quarter’s objectives for the ongoing and continuous implementation of BMPs. The
successfully achieved this quarter’s objectives for the ongoing and continuous implementation of BMPs. The
upcoming update is set to be prepared and distributed following the conclusion of the 3rd quarter on March 31st,
2025.
FISCAL IMPACT:
N/A
SUGGESTED MOTION:
N/A
Attachments
MS4-Quarter-2-Compliance-Schedule
2024/2025 Town of Oro Valley MS4 Compliance Schedule
July - Sept Oct - Dec Jan - Mar Apr - June
MCM-1 Public Education and Outreach
BMP 1.1 Create and update informational brochures (A)x x
BMP 1.2 Distribution of informational brochures to the general public (A)x x
BMP 1.3 Distribution of brochures to businesses that potentially affect stormwater quality (B)
BMP 1.4 Stormwater content in the Oro Valley Vista Newsletter (B)x
BMP 1.5 Outreach events at Town of Oro Valley schools (B)
BMP 1.6 Display of outreach materials on Town owned Sun Shuttle buses. (A)x x
BMP 1.7 Stormwater content on the Town of Oro Valley website (A)x x
BMP 1.8 Effective response to public inquiries (A)x x
MCM-2 Public Participation and Involvement
BMP 2.1 Public participation through the Stormwater Utility Commission (SWUC) (A)x x
BMP 2.2 Public involvement through notification of monthly SWUC meetings (A)x x
BMP 2.3 Public interaction with SWU Staff (A)x x
BMP 2.4 Solicitation of public comments regarding key components of utility operations (A)x x
BMP 2.5 Encouragement of public participation via volunteer groups sponsored by the TOV (A)x x
BMP 3.1 Implementation of an IDDE program (A)x x
BMP 3.2 Identification and Mapping of the MS4 (A)x x
BMP 3.3 Identification and mapping of the Town's Municipal Outfall Inventory (A)x x
BMP 3.4 Annual Municipal Employee Illicit Discharge Training Program (B)
BMP 3.5 Training of Town volunteers (A)x x
BMP 3.6 Written IDDE Procedures (A)x x
BMP 4.1 Comprehensive pre-construction site plan review (A)x x
BMP 4.2 Erosion and sediment control for capital improvement projects (A)x x
BMP 4.3 Establishment and review of Town ordinances regarding disposal of hazardous construction site
waste, sediment control, and erosion control (A)x x
BMP 4.4 Documentation of procedures (A)x x
BMP 4.5 Personnel Qualifications and Education of Private Contractors/Developers (A)x x
BMP 4.6 Establish Procedures for Receipt and Consideration of Constituent Submittals (A)x x
BMP 5.1 Creation, review and enforcement of post-construction stormwater pollution prevention
regulatory mechanisms and standard operating procedures (A)x x
BMP 5.2 Comprehensive GIS Inventory of Active and Finished Construction Projects (A)x x
BMP 5.3 Implement Standard Operating Procedure on Post-Construction Inspections (A)x x
BMP 5.4 Site Plan Reviews (A)x x
BMP 6.1 Inspection of Town of Oro Valley Municipal Operations, Storage, and Maintenance Facilities (A)x x
BMP 6.2 Street Sweeping (A)x x
BMP 6.3 Implementation of SPCC and Operation and Maintenance Plans for Town Maintenance
Facilities (A)x x
BMP 6.4 Municipal Employee Training Program (B)
BMP 6.5 Town of Oro Valley Municipal Vehicle and Heavy Equipment Washing Procedures (A)x x
BMP 6.6 Town of Oro Valley Fleet Maintenance Schedule (A)x x
BMP 6.7 Facility Safety Data Sheet Inventory (A)x x
(A) Ongoing and Continuous
(B) Done Only Once Per Fiscal Year
x means task completed during indicated quarter
S. Bennett 12/20/2024
Quarter
MCM-5 Post-Construction Runoff Control
MCM-6 Pollution Prevention and Good Housekeeping for Municipal Operations
MCM-4 Construction Site Stormwater Run-Off Control
MCM-3 Illicit Discharge Detection and Elimination
Stormwater Utility Commission 7.
Meeting Date:01/16/2025
Requested by: Dennis Roberts, Public Works Submitted By:Scott Bennett, Public Works
SUBJECT:
DISCUSSION OF RESULTS OF NOVEMBER 14, 2024 TOWN OF ORO VALLEY MS4 AUDIT BY ADEQ
RECOMMENDATION:
N/A
EXECUTIVE SUMMARY:
SMALL MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) AUDIT
On November 14, 2024, the Arizona Department of Environmental Quality (ADEQ) carried out a routine compliance
audit of the Town’s MS4 Program, in accordance with the Arizona Pollutant Discharge Elimination System
(AZPDES) General Permit for Stormwater Discharges from Small (Phase II) Municipal Separate Sewer Systems
(MS4s) to Protected Surface Waters. The audit sought to assess the Town's implementation of its stormwater
management program and pinpoint any potential issues.
The MS4 audit included on-site visits and a thorough examination of the stormwater management program
implemented by the MS4 owner/operator. This encompassed an evaluation of the legal authority, procedures,
implementation of those procedures, and sufficient resources, where relevant, for the six Minimum Control
Measures of the MS4 program:
Public Education and Engagement1.
Engagement of the Public2.
Illicit Discharge Detection and Elimination3.
Oversight of Construction Site Runoff4.
Post-Construction Site Runoff Management5.
Effective Management in Municipal Operations6.
The compliance audit identified minor deficiencies which were addressed during the exit debrief on the day of the
audit. The observations and deficiencies were primarily associated with:
Enforcement Response Plan for the Town’s Illicit Discharge Detection and Elimination System1.
Suggestions for the Annual Training on Illicit Discharge Detection and Elimination, and Good Housekeeping2.
Small modifications to the processes at the municipal facility (680 W. Calle Concordia)3.
Guidelines for procedures during SWPPP inspections4.
All comments are presently being addressed, and results will be submitted to ADEQ.
BACKGROUND OR DETAILED INFORMATION:
On October 16, 2024, the Arizona Department of Environmental Quality (ADEQ) informed the Stormwater Utility of
a scheduled 5-year audit of the Town's MS4 Program on November 14, 2024. The MS4 program is a federal
requirement established under the Clean Water Act (33 U.S.C. 1251 et seq.), the National Pollutant Discharge
Elimination System Regulations (40 CFR Part 122), and Arizona state regulations governing stormwater discharge
(ARS Title 49, Chapter 2, Article 3.1).
The most recent audit conducted for the Town of Oro Valley occurred in 2019. The MS4 selection cycle of ADEQ
occurs every five years. The state of Arizona has 54 MS4s. More than ten audits are performed annually.
One week before the audit, at 10:30 AM on Thursday, November 7, 2024. ADEQ conducted a conference call to
review the audit report requirements, seek documentation, and finalize logistics.
The audit included an examination of records and on-site observations. The ADEQ solicited the subsequent
documentation:
Stormwater Management Plan (SWMP)1.
Enforcement Response Plan (ERP)2.
A written Illicit Discharge Detection & Elimination (IDDE) program 3.
Storm Sewer System Map4.
Inventory of active construction sites5.
Inventory of municipal facilities6.
Organizational chart with departments and key personnel positions7.
Documented visual monitoring 8.
Construction site inspection reports9.
Annual training records10.
The field observations encompassed visits to four locations within the Town of Oro Valley. They intended to visit one
active construction site, one completed construction site, a municipal site, and one of the Town's MS4 outfall
locations.
The active construction site inspection was conducted in real-time under the supervision of ADEQ auditors. The
remaining three locations are fully developed. The locations are La Posada as the active construction site, the
Saguaro Viejos East Subdivision as the completed site, the Town of Oro Valley Public Works Operations Facility at
680 W Calle Concordia, and the MS4 outfall situated near the Water Utility Site next to N Pusch View Lane.
ADEQ supplied the Stormwater Utility Staff with an Audit Report template, a Notice of Inspection Rights, and an
AZPDES Universal Inspection Report template to facilitate our preparation.
Reference the attachment for details.
FISCAL IMPACT:
N/A
SUGGESTED MOTION:
N/A
Attachments
MS4 Audit Report
SURFACE WATER PROTECTION (SWP) - INSPECTION REPORT
Revised February 2022 LTF: 91833 Page 1
Facility Name (PLACE): Oro Valley MS4
Facility Type: Municipal Separate Storm Sewer System (MS4)
Permit Number (LTF): 91833
Alternative Permit ID: AZSM 91833
County: Pima
Inspection ID: 456065
Type of Inspection: AZPDES Stormwater MS4 Audit
☒ Compliance Inspection (☒ Checked if Announced) ☐ Complaint Inspection - Complaint ID: ☐ Follow-Up Inspection:
Physical Location: 11000 N La Canada Dr.
City, State, Zip: Oro Valley, AZ 85737
Mailing Address: 11000 N La Canada Dr.
City, State, Zip: Oro Valley, AZ 85737
Lead Inspector (Author): Steven Saeed
Inspector Email: saeed.steven@azdeq.gov
Inspector Phone: (520) 419-7322
Additional Inspectors: Bronson Patten
Permittee (CUSTOMER): Town of Oro Valley Stormwater Utility
Address: 11000 N La Canada Dr., Oro Valley, AZ 85737
Phone: 520-229-4850
Email: pw@orovalleyaz.gov
Inspection Date: 11/14/2024
Weather: Sunny
Start Time: 8:00 AM
End Time: 5:00 PM
Results of Inspection: ☐ No alleged deficiencies were noted during the course of the inspection. No ADEQ action will result from this inspection. ☐ Alleged deficiencies were noted during the course of the inspection and all deficiencies were corrected by the close of business on the final
day of inspection. No ADEQ action will result from this inspection.
☒ Alleged deficiencies were noted during the course of the inspection. Additional correspondence regarding this inspection may be
forthcoming.
If applicable, ADEQ documents its initial determination that the alleged deficiencies are:
☐ Committed intentionally.
☐ Not correctable within a reasonable period of time as determined by the agency.
☐ Evidence of a pattern of noncompliance as demonstrated by alleged deficiencies previously identified in an inspection report or other
written notice at the same premises.
☐ A significant risk to any person, the public health, safety or welfare or the environment.
Inspection Report Delivery Method: email from ADEQ office
Inspection Report Issued Date: 12/20/2024 Facility Initials: ADEQ Initials:
Attachment(s):
Notice of Inspection Rights
Small Business Bill of Rights
Program Checklist(s)
Photograph Log
Exit Debriefing
Attendee Name Title (include license#) Company/Agency Opening Inspection Debrief
Steven Saeed Surface Water Inspector
& Case Manager ADEQ ☒ ☒ ☒
Bronson Patten Surface Water Inspector
& Case Manager ADEQ ☒ ☒ ☒
Dennis Roberts, P.E., CFM Senior Stormwater
Engineer Town of Oro Valley ☒ ☒ ☒
Scott Bennett, M.S. Stormwater Utility GIS
Analyst Town of Oro Valley ☒ ☒ ☒
Jane Hutchins Construction Inspector Town of Oro Valley ☒ ☒ ☒
Aimee Ramsey Deputy Director – Public
Works Town of Oro Valley ☒ ☐ ☒
Introduction
12/20/2024
SWP INSPECTION REPORT
Revised February 2022 LTF: 91833 Page 2
Observations
Permit Related Documents Reviewed Before/During Inspection
☒ AZPDES Permit ☐ Fact Sheet ☐ Operator Certs
☒ SWPPP/SWMP ☐ Previous ADEQ Inspection Reports ☒ Sampling Records
☒ Training Records ☒ Visual Inspections ☐ Other:
Field Observations
The order of field locations visited was the following:
1. Outfall
a. MO-5 in the SWMP
b. 32.396778, -110.965439
2. Municipal Facility
a. Oro Valley Street Maintenance
b. 680 W Calle Concordia, Oro Valley, AZ 85704
3. Active Construction Site
a. La Posada at Pusch Ridge (AZCN96637)
This audit was a routine compliance audit for the Arizona Pollutant Discharge Elimination System (AZPDES) General Permit for Stormwater
Discharges from Small (Phase II) Municipal Separate Sewer Systems (MS4s) to Protected Surface Waters. This audit was conducted on Thursday,
November 14, 2024. The audit was conducted physically on-site. ADEQ sent copies of the Notice of Inspection Rights (NOIR), the AZPDES
Universal Inspection Report template, and the Small MS4 Audit Report template to John Spiker on October 16, 2024. On October 21, 2024,
Aimee Ramsey, Oro Valley Public Works Deputy Director, responded to the email providing notification that she was in receipt of the audit
notification and documents sent. Ms. Aimee Ramsey also provided notification that Mr. John Spiker was no longer employed with the Town of
Oro Valley.
On November 7, 2024, ADEQ and the Town of Oro Valley had a virtual Logistics Call to discuss the scope and expectations of the MS4 audit, and
finalize logistics for the day of the audit. On November 8, 2024, ADEQ sent a copy of the tentative audit agenda to the Town of Oro Valley.
The audit consists of two portions: field observations and documentation review. For the field observations, we visited four locations: two (2)
municipal facilities and two (2) outfall(s)/screening point(s). The documentation review consists of examining records relevant to all applicable
Minimum Control Measures (MCMs).
On the day of the audit, Bronson Patten, Surface Water Inspector & Case Manager, and I (hereinafter the “Inspection Team”) met Dennis
Roberts, P.E., CFM, Scott Bennett, M.S., and Jane Hutchins (hereinafter the “onsite representatives”) at 11000 N La Canada Dr. Building D, Oro
Valley, 85737, around 8:00 AM. Aimee Ramsey attended the opening conference and documentation review virtually, and attended a portion of
the closing conference in-person.
Facility/Site Description/Treatment Process?
The Town of Oro Valley owns and operates a Phase II MS4.The Town of Oro Valley is located in northeastern Pima County, approximately three
miles north of the City of Tucson. The Town covers an area of 36 square miles and is located between the Santa Catalina and Tortolita
mountains. According to the United States Census Bureau, as of 2023 the estimated population for the Town of Oro Valley was 48,311.
The Town of Oro Valley stormwater infrastructure includes 203 miles of roads, 1099 constructed channels, 593 culverts (pipe and box), 1113
storm drain pipes, 1923 catch basin inlets, 232 stormwater detention basins, and 175 first-flush filtration devices.
The MS4 does not discharge to an impaired or not-attaining water, nor an Outstanding Arizona Water (OAW). The receiving waters for the Town
of Oro Valley MS4 are Big Wash (WBID AZ15050301-018) and Canada Del Oro Wash (WBID AZ15050301-016).
Opening Conference
I first introduced myself to the onsite representatives. I then read the NOIR and received a signature on the NOIR from Mr. Dennis Roberts. After
receiving a signature on the NOIR, we started reviewing relevant compliance documentation. After completing the review of relevant
compliance documentation, we moved on to field observations.
Closing Conference
After concluding the field observations, we held the audit closing conference. I gave the onsite representatives my evaluation of what was
reviewed and observed. I received a signature on the Field Exit Debrief Form from Mr. Dennis Roberts. Some deficiencies were noted during the
course of the audit.
SWP INSPECTION REPORT
Revised February 2022 LTF: 91833 Page 3
b. 32.408, -110.9602
4. Post -Construction Stormwater BMP #1
a. Retention Basin
b. Saguaros Viejos East
c. 11274 N Gemini Dr., Oro Valley, AZ 85742
5. Post -Construction Stormwater BMP #2
a. Gabion wall
b. 32.409564, -111.008522
See Program Checklist (Phase II Municipal Separate Storm Sewer System (MS4) Audit Report) for observations.
After the field observations, we reconvened at to hold the closing conference.
Comments and Potential Deficiencies (Areas of Concern)
The ERP, did not include the following factors in prioritizing escalated enforcement:
1. Severity of non-compliance;
2. Repeated non-compliance;
3. Proximity to a receiving water or storm sewer system; and,
4. Other appropriate factors.
Annual Report posted
- The annual reports are required to be posted no later than 30-days of the due date of the annual report.
- The due date for the 2023-24 Annual Report was September 30, 2024.
- The deadline to post the 2023-24 annual report on the Town’s website was October 30, 2024. I did not observe the 2023-24 Annual
Report posted on the Town’s website at the time of the audit.
Annual Training (IDDE & Good Housekeeping)
- Training should be provided at least annually to all employees involved with stormwater:
o “provide annual training to employees involved in the IDDE program (e.g., street workers, inspectors, solid waste personnel,
etc.). The training shall include the IDDE program components and how to recognize illicit discharges”.
o “Develop and implement an annual employee training program to incorporate pollution prevention and good housekeeping
techniques into everyday operations and maintenance activities”.
Municipal Facility (Oro Valley Street Maintenance):
- Black material observed on the ground. According to the onsite representatives, the material was “asphalt tailings”.
- Two barrels and two totes containing a white material were observed open, on the ground, exposed to stormwater.
- One barrel observed cut in half with water and a rust colored material inside.
- Black stains observed outside of the secondary containment for the used oil storage
- Dumpster leaking
- Recommend acquiring containment BMPs (e.g. oil booms)
Construction Site (La Posada at Pusch Ridge):
- Good housekeeping
- Sediment observed on asphalt
- Recommend Town of Oro Valley construction inspectors walk the entire site during inspections, specifically the perimeter and any
outfalls.
SWP INSPECTION REPORT
Revised February 2022 LTF: 91833 Page 4
Site Map – Document Areas Visited/Not Visited (draw on aerial imagery added prior to inspection)
Outfall:
MO-5
Municipal Facility:
Oro Valley Street
Maintenance
SWP INSPECTION REPORT
Revised February 2022 LTF: 91833 Page 5
Construction Site:
La Posada at Pusch Ridge
(AZCN96637)
Post-Construction
Stormwater BMP #1:
Saguaros Viejos East
Retention Basin
SWP INSPECTION REPORT
Revised February 2022 LTF: 91833 Page 6
Post-Construction
Stormwater BMP #2:
Canada Ridge Gabion Wall
Rev. 3/22/21
-ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY
NOTICE OF INSPECTION RIGHTS
FACILITY INFORMATION ADEQ INFORMATION
Facility Name (Customer): Town of Oro Valley MS4 Date/Time of Inspection: 11/14/2024 8:00 AM
Facility Location (Place): 11000 N La Canada Dr, Oro Valley, 85737 County: Pima
Inspector: Steven Saeed
Mailing Address: 11000 N La Canada Dr, Oro Valley, 85737 Telephone: (520) 419-7322
Accompanied by: Bronson Patten
Responsible Party: Town of Oro Valley
On-Site Representative: Dennis Roberts, P.E., CFM ADEQ Follow-up Contact: Leigh Padgitt
Telephone: (520) 229-4818
Title: Senior Stormwater Engineer Title: Manager
E-mail: droberts@orovalleyaz.gov Telephone: (602) 291-2710
The ADEQ representative(s) identified above were present at the above address on the above listed date and time. Upon entry to the
premises, the ADEQ representative(s) met with me, presented photo identification indicating that they are ADEQ employees and
explained:
☒ That the purpose of the inspection is to determine:
☒ Compliance with Title 49 of the Arizona Revised Statutes, Title 18 of the Arizona Administrative Code* and/or:
Arizona Revised Statutes: Title 49 , Chapter 2 , Article 3.1 .
Arizona Administrative Code: Title 18 , Chapter 11 , Article 1 and 4 .
Permit/Agreement Number: AZG2021-002.
☐ Qualification for a license issued pursuant to:
Arizona Revised Statutes: Title 49 , Chapter 2 , Article 9 .
Arizona Administrative Code: Title 18 , Chapter 5 , Article 1 .
☒ That this inspection is conducted pursuant to the authority granted in Arizona Revised Statutes § 49-104(B)(8) and/or:
Arizona Revised Statutes: § 41-1009, 49-203(B)(1).
Arizona Administrative Code: ____________________________________.
Permit/Agreement Number: _____________________________________.
☒ That the state shall not be barred by the statutes of limitations of actions, according to A.R.S. § 12-510, except as provided
in A.R.S. § 12 -529 concerning certain claims based on navigability of watercourses. According to 28 U.S.C. § 2462, the
U.S. government must commence an action within 5 years after the date the claim first accrued.
☒ The applicability of the Small Business Bill of Rights pursuant to Arizona Revised Statutes § 41 -1001(21).
☒ That the fee for this inspection is: $0 .
*The Arizona Revised Statutes (A.R.S.) can be found on the internet: www.azleg.state.az.us/ArizonaRevisedStatutes.asp while the
Arizona Administrative Code (A.A.C.) can be found at www.azsosaz.gov/public_services/Table_of_Contents.htm.
While I have the right to refuse to sign this form, the ADEQ representatives may still proceed with the inspection.
☒ I have read this notice and discussed any questions or concerns with the ADEQ representatives and I have received the Small
Business Bill of Rights.
_____________________________________________________________________________ ___________
Signature of Regulated Person or Authorized On -Site Representative Date
☐ The regulated person or authorized on-site representative refused to sign.
_____________________________________________________________________________ ___________
Name of Regulated Person or Authorized On -Site Representative Title
☐ The regulated person or authorized on-site representative was not present at the facility.
_____________________________________________________________________________ ___________
Signature of ADEQ Representative Date
Rev. 3/22/21
INSPECTION RIGHTS
☒ I understand that I can accompany the ADEQ representative(s) on the premises, except during confidential interviews.
☒ I understand that I have right, on request, to:
Copies of any original documents taken during the inspection, and that ADEQ will provide copies of those
documents at ADEQ’s expense;
A split of any samples taken during the inspection, if the split of the samples would not prohibit an analysis
from being conducted or render an analysis inconclusive;
Copies of any analysis performed on samples taken during the inspection and that ADEQ would provide
copies of this analysis at ADEQ’s expense;
Copies of any documents to be relied on to determine compliance with licensure or regulatory requirements if
the agency is otherwise permitted by law to do so.
☒ I also understand that:
Each person who is interviewed by an ADEQ inspector during the inspection must be informed that:
(1) participation in an interview is voluntary, unless legally compelled to participate;
(2) they have the right to have an attorney or other experts in their field present during the interview to
represent or advise the regulated person;
(3) the ADEQ inspector may not take any adverse action or treat less favorably or draw any inference as a
result of the regulated person’s decision to be represented by an attorney or advised by any other experts
in their field;
(4) statements made by the person may be included in the inspection report; and
(5) they have the right to 24 hours to review and revise any written witness statements drafted by the ADEQ
inspector on which the ADEQ inspector requests that person’s signature.
If the information and documents provided to the ADEQ inspector become a public record, trade secrets and
proprietary and confidential information may be redacted, unless the information and documents are not
confidential pursuant to statute.
Each person interviewed during the inspection must be informed that statements made by the person may be
included in the inspection report;
Each person whose conversation is recorded during the inspection must be informed that the conversation is
being tape recorded;
If an administrative order is issued or a permit decision is made based on the results of the inspection, I have
the right to appeal that administrative order or permit decision. I understand that my administrative hearing
rights are set forth in Arizona Revised Statutes § 41-1092 et seq. and my rights relating to an appeal of a final
agency decision are found in Arizona Revised Statutes § 12-901 et seq;
If I have any questions or concerns about this inspection, I may contact the person listed as the ADEQ Follow-
up Contact on the front of this form; ADEQ’s Ombudsman at (602) 771-4322 (toll free inside Arizona at
(800) 234-5677, extension 7714322); or the Arizona Ombudsman-Citizens’ Aid office at (602) 277-7292 (toll
free at (800) 872-2879);
If I have any questions concerning my rights to appeal an administrative order or permit decision, I may
con tact ADEQ’s Administrative Counsel Edwin Slade at (602) 771-2242 (toll free inside Arizona at (800)
234-5677, extension 7712242).
Rev. 3/22/21
Arizona Revised Statutes: Small Business Bill of Rights
41-1001.01. Regulatory bill of rights; small businesses
A. To ensure fair and open regulation by state agencies, a person:
1. Is eligible for reimbursement of fees and other expenses if the person prevails by
adjudication on the merits against an agency in a court proceeding regarding an
agency decision as provided in section 12-348.
2. Is eligible for reimbursement of the person's costs and fees if the person prevails
against any agency in an administrative hearing as provided in section 41-1007.
3. Is entitled to have an agency not charge the person a fee unless the fee for the
specific activity is expressly authorized as provided in section 41-1008.
4. Is entitled to receive the information and notice regarding inspections and audits
prescribed in section 41-1009.
5. May review the full text or summary of all rulemaking activity, the summary of
substantive policy statements and the full text of executive orders in the register as
provided in article 2 of this chapter.
6. May participate in the rulemaking process as provided in articles 3, 4, 4.1 and 5 of
this chapter, including:
(a) Providing written comments or testimony on proposed rules to an agency as
provided in section 41-1023 and having the agency adequately address those
comments as provided in section 41-1052, subsection D, including comments or
testimony concerning the information contained in the economic, small business
and consumer impact statement.
(b) Filing an early review petition with the governor's regulatory review council as
provided in article 5 of this chapter.
(c) Providing written comments or testimony on rules to the governor's regulatory
review council during the mandatory sixty-day comment period as provided in
article 5 of this chapter.
7. Is entitled to have an agency not base a licensing decision in whole or in part on
licensing conditions or requirements that are not specifically authorized by statute,
rule or state tribal gaming compact as provided in section 41-1030, subsection B.
8. Is entitled to have an agency not make a rule under a specific grant of rulemaking
authority that exceeds the subject matter areas listed in the specific statute or not
make a rule under a general grant of rulemaking authority to supplement a more
specific grant of rulemaking authority as provided in section 41-1030, subsection C.
9. May allege that an existing agency practice or substantive policy statement
constitutes a rule and have that agency practice or substantive policy statement
declared void because the practice or substantive policy statement constitutes a rule
as provided in section 41-1033.
10. May file a complaint with the administrative rules oversight committee concerning:
(a) A rule's, practice's or substantive policy statement's lack of conformity with
statute or legislative intent as provided in section 41-1047.
(b) An existing statute, rule, practice alleged to constitute a rule or substantive
policy statement that is alleged to be duplicative or onerous as provided in
section 41-1048.
11. May have the person's administrative hearing on contested cases and appealable
agency actions heard by an independent administrative law judge as provided in
articles 6 and 10 of this chapter.
12. May have administrative hearings governed by uniform administrative appeal
procedures as provided in articles 6 and 10 of this chapter and may appeal a final
Rev. 3/22/21
administrative decision by filing a notice of appeal pursuant to title 12, chapter 7,
article 6.
13. May have an agency approve or deny the person's license application within a
predetermined period of time as provided in article 7.1 of this chapter.
14. Is entitled to receive written notice from an agency on denial of a license
application:
(a) That justifies the denial with references to the statutes or rules on which the
denial is based as provided in section 41-1076.
(b) That explains the applicant's right to appeal the denial as provided in section
41-1076.
15. Is entitled to receive information regarding the license application process before or
at the time the person obtains an application for a license as provided in sections
41-1001.02 and 41-1079.
16. May receive public notice and participate in the adoption or amendment of
agreements to delegate agency functions, powers or duties to political subdivisions
as provided in section 41-1026.01 and article 8 of this chapter.
17. May inspect all rules and substantive policy statements of an agency, including a
directory of documents, in the office of the agency director as provided in section
41-1091.
18. May file a complaint with the office of the ombudsman-citizens aide to investigate
administrative acts of agencies as provided in chapter 8, article 5 of this title.
19. Unless specifically authorized by statute, may expect state agencies to avoid
duplication of other laws that do not enhance regulatory clarity and to avoid dual
permitting to the extent practicable as prescribed in section 41-1002.
20. May have the person's administrative hearing on contested cases pursuant to title
23, chapter 2 or 4 heard by an independent administrative law judge as prescribed
by title 23, chapter 2 or 4.
B. The enumeration of the rights listed in subsection A of this section does not grant any
additional rights that are not prescribed in the sections referenced in subsection A of
this section.
C. Each state agency that conducts audits, inspections or other regulatory enforcement
actions pursuant to section 41-1009 shall create and clearly post on the agency's
website a small business bill of rights. The agency shall create the small business bill of
rights by selecting the applicable rights prescribed in this section and section 41-1009
and any other agency-specific statutes and rules. At the request of an authorized on-
site representative of the regulated small business, the agency shall provide a written
document of the small business bill of rights. In addition to the r ights listed in this
section and section 41-1009, the agency notice of the small business bill of rights shall
include the process by which a small business may file a complaint with the agency
employees who are designated to assist members of the public or regulated community
pursuant to section 41-1006. The notice must provide the contact information of the
agency's designated employees. The agency notice must also state that if the regulated
person has already made a reasonable effort with the agency to resolve the problem
and still has not been successful, the regulated person may contact the office of
ombudsman-citizens aide.
Phase II Municipal Separate Storm Sewer System (MS4)
Audit Report
Revised August 2024 XXXXX Page 1
MS4 Name: Town of Oro Valley MS4 Permit #: AZM 91833 Inspection ID: 456065
Protected Surface Water(s) receiving discharges: Big Wash (WBID AZ15050301-018); Canada Del Oro Wash (WBID AZ15050301-016)
Impaired or OAW: n/a
General Permit Requirements
Citation Permit Requirement C: Compliant
NC: Noncompliant
N/A: Not Applicable
3.2.8 Up-to-date organizational chart with departments and key personnel positions ☒ C ☐ NC ☐ N/A
The Town of Oro Valley maintains an up-to-date organizational chart. The organizational chart was observed
during the audit,
3.3 Enforcement Response Plan (ERP) has been developed. ☐ C ☒ NC ☐ N/A
The Town of Oro Valley Enforcement Response Plan (ERP) was observed at the time of the audit.
The ERP, did not include the following factors in prioritizing escalated enforcement:
1. Severity of non-compliance;
2. Repeated non-compliance;
3. Proximity to a receiving water or storm sewer system; and,
4. Other appropriate factors
4.0 – 4.1 A Stormwater Management Program (SWMP) that meets the terms and
conditions of the Permit (See Table 1 below). ☒ C ☐ NC ☐ N/A
The SWMP was reviewed. See Table 1 below.
4.2 A copy of the most up-to-date SWMP has been made available to the public
during normal business hours and posted on the permittee’s website. ☒ C ☐ NC ☐ N/A
Revised August 2024 LTF: 91833 Page 2
A copy of the most up-to-date SWMP is available on the permittee’s website
(https://www.orovalleyaz.gov/Government/Departments/Public-Works/Stormwater-Management).
8.1 The permittee has performed annual program evaluations. ☒ C ☐ NC ☐ N/A
8.3 Annual Reports were complete and submitted on or before the due date each
year of Permit coverage. ☒ C ☐ NC ☐ N/A
The Annual Report for Reporting Year 2023-24 was submitted to ADEQ on September 24, 2024, before the
due date of September 30, 2024.
Table 1: Contents of the Stormwater Management Program [4.1 (1-10)] C: Compliant
NC: Noncompliant
N/A: Not Applicable
(1) Listing of all protected surface waters, their classification under the applicable state surface water quality
standards (SWQS), any impairment(s) and associated pollutant(s) of concern, applicable TMDLs and WLAs, and
number of outfalls from the MS4 that discharge to each waterbody. ☒ C ☐ NC ☐ N/A
(2) Process and schedule for creating and maintaining an up-to-date map that includes, at a minimum, the storm
sewer system, outfalls, and protected surface waters.
☒ C ☐ NC ☐ N/A
(3) Illustrate any areas that are not subject to the MS4 and identify why there is no discharge within the MS4
boundaries.
☒ C ☐ NC ☐ N/A
(4) Listing of all known, ongoing discharges that cause or contribute to the exceedance of an applicable surface
water quality standard. ☐ C ☐ NC ☒ N/A
(5) Description of practices to achieve compliance with the permit; include personnel, position or department,
and BMPs. ☒ C ☐ NC ☐ N/A
(6) Description of practices to achieve compliance with applicable TMDLs or waste load allocation, including
measurable goal(s) for each BMP and corresponding milestones and timeframes. ☐ C ☐ NC ☒ N/A
(7) Analytical monitoring program for impaired or not-attaining waters, and for Outstanding Arizona Waters to
ensure compliance with permit limitations, wasteload allocation(s), and SWQS. ☐ C ☐ NC ☒ N/A
(8) Sampling and Analysis Plan (SAP) that includes the following minimum components: sample collection,
equipment and containers, decontamination, calibration procedures, sample frequency (based on illicit
discharge characteristics), document site conditions, field notes, sample preservation, tracking (chain-of-
custody), and handling.
☒ C ☐ NC ☐ N/A
Revised August 2024 LTF: 91833 Page 3
(9) Protocol for annual program evaluation (Part 8.1)
☒ C ☐ NC ☐ N/A
(10) Identification of personnel (department, position, etc.) responsible for program implementation. ☒ C ☐ NC ☐ N/A
Revised August 2024 LTF: 91833 Page 4
MCM 6.1: Public Education and Outreach
Citation Permit Requirement C: Compliant
NC: Noncompliant
N/A: Not Applicable
6.1 The permittee has identified and implemented an educational program that
focuses on the impacts of stormwater discharges to and from the MS4. ☒ C ☐ NC ☐ N/A
6.1.1 The permittee has provided public education/outreach to at least one (1) target
group, and focus its efforts on conveying relevant messages using one (1) or
more appropriate topics during each year of the permit term.
☒ C ☐ NC ☐ N/A
The Town of Oro Valley has provided education/outreach to more than one target group, including schools,
homeowners, and vehicle owners.
The topics included proper disposal of hazardous waste, draining swimming pools, automotive care,
stormwater runoff issues and residential stormwater management practices, illicit discharges, and proper
disposal of oil.
During Reporting Year 2023-24, the Town of Oro Valley mailed a brochure on water quality to all residents
within the Town of Oro Valley. This mail insert included information on pool and spa discharge, the Town's
MS4 program, and illicit discharge reporting. These brochures were mailed by Town of Oro Valley to the
21,000 water utility customers in April 2024.
Public Education and Outreach brochures can be found on the Town’s website:
https://www.orovalleyaz.gov/Government/Departments/Public-Works/Stormwater-Management.
The Town of Oro Valley host booths at different events in the community throughout the reporting years:
- Oro Valley “State of the Town (10/24/2023 & 10/31/2024)
o The town hosts a booth at this event every year
o Hosted at the El Conquistador Resort
o Sponsored by the Town of Oro Valley and local businesses
o 226 people impressions at the Oro Valley state of the town 10/31/2024
- Pima Association of Governments (PAG) presentation on Stormwater Asset Management (11/28/2023)
- Wilson K-8 STEAM Fair (01/23/2024)
o Targeting 7th and 8th graders
- Celebrate Oro Valley (04/13/2024)
Revised August 2024 LTF: 91833 Page 5
- Pima County Senior Resource Fair (04/20/2024
Based on input from the last ADEQ MS4 audit, the Town has been using a clicker to count the number of
people that come by their booths at different events.
6.1.2 The permittee has provided business sector education/outreach to at least one
(1) target group and focus its efforts on conveying relevant messages using one
(1) or more appropriate topic(s) during each year of the permit term.
☒ C ☐ NC ☐ N/A
2022-23: HOAs
2023-24: Waste Management
- Waste Management; Republic Services; Waste Connections of Arizona; Titan Trash Removal
- Some other smaller waste management companies (construction; roll off; etc.)
2024-25: Landscapers
From the 2023-24 Annual Report:
“For Reporting Year 2023-24, the Town of Oro Valley received more reports from the public regarding paint
and other substances leaking from garbage trucks than in previous years. As such, the Town targeted waste
management/disposal companies for reporting year 2023/2024. The message delivered through
development of a new brochure was: the importance of reducing pollution through proper disposal of
hazardous materials that are not meant to be placed inside a curbside pickup container. The Town of Oro
Valley requested that each company serving the Town, reach out to their customer base and remind them of
what can and cannot be placed within the curbside trash bins.”
6.1.3 The program shall focus on messages for specific audiences as well as show
progress toward the defined educational goals of the program. The permittee
has identified methods that it will use to evaluate the effectiveness of the
educational messages and the overall education program.
☒ C ☐ NC ☐ N/A
The Town of Oro Valley’s evaluation surrounding effectiveness of the educational messages involves the
amount of complaints they’re receiving. Based on the lack of complaints with waste management, the Town
suspects the business sector outreach has been effective.
6.1.4 The permittee has modified any ineffective messages or distribution techniques
on an annual basis. ☒ C ☐ NC ☐ N/A
The Town Identified an ineffective distribution technique: setting the booth in the wrong location at events
(specifically events at parks). The Town had set up their booth at the corner of the park and everybody was in
the park.
An ineffective distribution technique: bike bells. The Town attempted to hand-out bike bells as a swag item at
events. According to the onsite representatives, not many people wanted the bike bells.
Revised August 2024 LTF: 91833 Page 6
MCM 6.2: Public Involvement and Participation
Citation Permit Requirement C: Compliant
NC: Noncompliant
N/A: Not Applicable
6.2 The permittee has provided opportunities to engage the public to participate in
the review and implementation of the permittee’s SWMP. ☒ C ☐ NC ☐ N/A
6.2.1 All public involvement activities comply with state and local public notice
requirements. The SWMP and all annual reports are available to the public. ☐ C ☒ NC ☐ N/A
I observed the SWMP and 2022-23 Annual Report on the Town’s website.
The annual reports are required to be posted no later than 30-days of the due date of the annual report. The
due date for the 2023-24 Annual Report was September 30, 2024. The deadline to post the 2023-24 annual
report on the Town’s website was October 30, 2024. I did not observe the 2023-24 Annual Report posted on
the Town’s website at the time of the audit.
6.2.2 The permittee has annually provided the public an opportunity to participate in
the review, revisions, updates, and implementation of the SWMP. ☒ C ☐ NC ☐ N/A
Stormwater Utility commission: 5-member commission, created as a result for public participation. The
commission meets monthly. Meetings are open to the public; the public can join in-person or virtually. The
commission gets the opportunity to provide comments on the annual report every year. The commission gets
the opportunity to review updates to the SWMP. The commission also receives a quarterly status update
from the Town.
6.2.3 The permittee shall create opportunities for citizens to participate in the
implementation of stormwater controls ☒ C ☐ NC ☐ N/A
Mayor’s roadway cleanup of Tangerine Rd (9/9/2023).
Adopt a road program.
6.2.4
The permittee has provided and publicized a reporting system to facilitate and
track public reporting of spills, discharges and/or dumping to the MS4 on a
continuous basis
☒ C ☐ NC ☐ N/A
Revised August 2024 LTF: 91833 Page 7
The Town of Oro Valley has a “report a spill” tab on their website. The public can report spills, discharges,
and/or dumping online, by phone, or by email. The report gets sent to every member of Public Works. The
complaint triggers the inspector to evaluate.
6.2.5 The permittee has documented the details of the public involvement and
participation program in the SWMP. ☒ C ☐ NC ☐ N/A
Town of Oro Valley Stormwater Management Program, Section II Stormwater Control Measures.
Revised August 2024 LTF: 91833 Page 8
MCM 6.3: Illicit Discharge Detection and Elimination (IDDE) Program
Citation Permit Requirement C: Compliant
NC: Noncompliant
N/A: Not Applicable
6.3
The permittee has identified, developed, implemented and enforced a
program to detect and eliminate illicit discharges into the MS4. The IDDE
program has been recorded in a written document.
☒ C ☐ NC ☐ N/A
6.3.1 A prepared and maintained up-to-date storm sewer map of the MS4. ☒ C ☐ NC ☐ N/A
I observed a GIS map with assets in Cartegraph.
I observed a map in ArcGIS which contained roads with drainage systems, municipal streets, catch basins,
channels, and storm drains, as well as the location of all outfalls and protected surface waters.
6.3.2(a) Appropriate enforcement procedures have been implemented to prohibit non-
stormwater discharges into the MS4. ☒ C ☐ NC ☐ N/A
6.3.2(b)
The written IDDE program includes a reference or citation of the authority
(ordinance or other regulatory mechanism) the permittee will use to
implement all aspects of the IDDE program.
☒ C ☐ NC ☐ N/A
Authority for this program is the “Storm Water Quality Management and Discharge Control Ordinance”
described in Town Code Chapter 15-24.
6.3.3
A written statement that clearly identifies responsibilities with regard to
eliminating illicit discharges. The statement identifies the lead municipal agency
or department responsible for implementing the IDDE Program as well as any
other agencies or departments that may have responsibilities for aspects of the
program.
☒ C ☐ NC ☐ N/A
The Town of Oro Valley Stormwater Utility Staff.
Revised August 2024 LTF: 91833 Page 9
6.3.5 Illicit discharges to the MS4 are eliminated, when discovered. ☐ C ☐ NC ☒ N/A
No illicit discharges have been identified.
6.3.7(a)
Written procedures for conducting visual monitoring (both dry and wet
weather) of outfalls from the MS4 have been developed, implemented, and
maintained. ☒ C ☐ NC ☐ N/A
Written procedures for conducting visual monitoring of outfalls from the MS4 were observed during the
audit.
6.3.7(b) The permittee has visually monitored at least 20% of all outfalls during each
year of the permit term. ☒ C ☐ NC ☐ N/A
The Town has identified 5 major outfalls close in proximity to dense commercial and residential land use. The
Town visually monitors all 5 outfalls each fiscal year. I observed copies of completed visual monitoring during
the audit.
6.3.7(c) The permittee has established a follow-up screening schedule for identified or
suspected illicit discharges to ensure they do not recur. ☒ C ☐ NC ☐ N/A
The follow-up monitoring shall be continued on an as needed basis until the discharge has been eliminated.
Revised August 2024 LTF: 91833 Page 10
6.3.9 The permittee has provided annual training to employees involved in the IDDE
program. ☐ C ☒ NC ☐ N/A
Selected staff are trained as Certified Stormwater Inspectors by the National Stormwater Center or equivalent
(currently have 13). The Town of Oro Valley annually trains every Operations and Maintenance employee.
I observed an employee sign-in sheet from June 3, 2022.
According to the onsite representatives, the most recent training occurred on June 26, 2024. However, this
training only included Parks & Recreation employees and did not include all employees involved in the IDDE
program (e.g., street workers, inspectors, solid waste personnel, etc.). I did not observe an employee sign-in
sheet for this training at the time of the audit.
6.3.10 A program has been implemented to identify facilities and activities that
discharge to the MS4 without an AZPDES/NPDES permit. ☒ C ☐ NC ☐ N/A
The Town identifies construction activity non-filers through the permitting process.
Revised August 2024 LTF: 91833 Page 11
MCM 6.4: Construction Activity Stormwater Runoff Control
Citation Permit Requirement C: Compliant
NC: Noncompliant
N/A: Not Applicable
6.4 A Construction Activity Stormwater Runoff Control program has been
developed, implemented, maintained, and enforced. ☒ C ☐ NC ☐ N/A
6.4.2(a) An ordinance or other regulatory mechanism that requires the use of erosion
and sediment control practices has been adopted and implemented. ☒ C ☐ NC ☐ N/A
The “Storm Water Quality Management and Discharge Control Ordinance” described in Town Code Chapter
15-24.
6.4.2 (b)
An inventory of all construction activities that disturb or will disturb one (1) or
more acres within the permitted area, including those that are less than one (1)
acre but are part of a larger common plan of development or sale if the larger
common plan will ultimately disturb greater than one (1) acre.
☒ C ☐ NC ☐ N/A
I observed an inventory of construction activities. The construction sites are mapped on Cartegraph. In total,
at the time of the audit there were 12 active construction sites within the MS4.
6.4.2(c) Written procedures for site plan review have been developed and
implemented. ☒ C ☐ NC ☐ N/A
Written procedures for site plan review were observed during the audit.
6.4.2(d)-(e) Written procedures for site inspections and enforcement of sediment and
erosion control measures have been developed. ☒ C ☐ NC ☐ N/A
Written procedures for site inspections were observed during the audit.
Revised August 2024 LTF: 91833 Page 12
6.4.2(f)
Written procedures for site inspections have been implemented in accordance
with the frequency specified in the permit. At least 80% of scheduled
inspections conducted annually.
☒ C ☐ NC ☐ N/A
The Town of Oro Valley inspects every construction site twice per month.
6.4.2(g)
Based on construction activity inspection findings, the permittee shall take all
necessary follow-up actions (i.e., re-inspection, enforcement) to ensure
compliance in accordance with the permittee’s enforcement response plan.
☒ C ☐ NC ☐ N/A
The first step of the Town’s ERP is to issue a verbal or written warning. The Town has never escalated an issue
to a Notice of Violation based on construction activity inspection findings. An example of a written warning
was observed during the audit. The Town representatives mentioned they have observed repeated
noncompliance at the La Posada construction site.
6.4.2(h) Requirements for construction site operators to implement sediment and
erosion control BMPs appropriate for the conditions at the construction site. ☒ C ☐ NC ☐ N/A
6.4.2(i)
Requirements for construction site operators to control wastes, including but
not limited to: discarded building materials, paints, fertilizers, concrete
washout, chemicals, litter, equipment leaks, and sanitary wastes. ☒ C ☐ NC ☐ N/A
6.4.3
Staff who conduct activities related to implementing the construction
stormwater program have the knowledge, skills, and abilities to proficiently
carryout their assigned duties.
☒ C ☐ NC ☐ N/A
Revised August 2024 LTF: 91833 Page 13
Selected staff are trained as Certified Stormwater Inspectors by the National Stormwater Center or equivalent
(currently have 13).
6.4.4
A program to provide education to construction activity operators on erosion
and sediment control BMP requirements has been developed and
implemented. ☒ C ☐ NC ☐ N/A
The Town of Oro Valley holds pre-construction meetings with every active construction site. At these
meetings, the Town provides the operators with information about erosion and sediment control BMP
requirements, as well as good housekeeping requirements.
Revised August 2024 LTF: 91833 Page 14
MCM 6.5: Post-Construction Stormwater Management in New &
Redevelopment
Citation Permit Requirement C: Compliant
NC: Noncompliant
N/A: Not Applicable
6.5
A program has been developed, implemented, and enforced to address post-
construction stormwater runoff from new development and redevelopment
projects that disturb one (1) or more acres of land (or less than one (1) acre if
part of a common plan of development) that discharge into the permittee’s
MS4.
☒ C ☐ NC ☐ N/A
6.5.2
The new development/redevelopment program shall include an ordinance or
regulatory mechanism to address runoff from new development and
redevelopment projects.
☒ C ☐ NC ☐ N/A
The “Storm Water Quality Management and Discharge Control Ordinance” described in Town Code Chapter
15-24.
6.5.3 The permittee designed, implemented, and maintained a site plan review
process to evaluate and approve post-construction stormwater controls. ☒ C ☐ NC ☐ N/A
Written procedures for site plan review were observed during the audit.
6.5.4
The permittee implemented and maintained an inventory system of all post-
construction structural stormwater control measures installed and
implemented at new development and redeveloped sites, including both public
and private sector sites located within the permit area that discharge into the
MS4. The inventory must be searchable by property location (either on paper
or electronic) or other relevant criteria.
☒ C ☐ NC ☐ N/A
Revised August 2024 LTF: 91833 Page 15
6.5.5
The permittee established processes, procedures, and other such provisions
necessary to ensure the long-term operation and maintenance of post-
construction stormwater BMPs.
☒ C ☐ NC ☐ N/A
The Town of Oro Valley conducts inspections of post-construction BMPs. The Town inspects 20% of all post-
construction BMPs every fiscal year, inspecting all post-construction BMPs within 5 years.
Revised August 2024 LTF: 91833 Page 16
MCM 6.6: Pollution Prevention and Good Housekeeping for Municipal
Operations
Citation Permit Requirement C: Compliant
NC: Noncompliant
N/A: Not Applicable
6.6
An operations and maintenance program has been developed, implemented,
and maintained with the ultimate goal of preventing or reducing pollutant
runoff from municipal facilities and activities.
☒ C ☐ NC ☐ N/A
6.6.2(a) An inventory of all municipally-owned and operated facilities that discharge has
been developed. ☒ C ☐ NC ☐ N/A
An inventory of all municipally-owned and operated facilities that discharge was observed during the audit.
6.6.2(b) Municipal facilities have been prioritized based on pollutant discharge risk. ☒ C ☐ NC ☐ N/A
The inventory of all municipally-owned and operated facilities that discharge included a prioritization based
on pollutant discharge risk.
6.6.2(c)-(d) Inspection schedule for municipal facilities has been developed based on
priority, implemented, and updated as appropriate. ☒ C ☐ NC ☐ N/A
Based on the prioritization, an inspection schedule is also included in the inventory of all municipally-owned
and operated facilities that discharge.
6.6.2(e) Stormwater controls have been developed, implemented, and maintained at
municipally-owned or operated facilities. ☒ C ☐ NC ☐ N/A
Revised August 2024 LTF: 91833 Page 17
6.6.2(f)
An annual employee training program to incorporate pollution prevention and
good housekeeping techniques into everyday operations and maintenance
activities has been developed and implemented.
☐ C ☒ NC ☐ N/A
I observed an employee sign-in sheet from June 3, 2022.
According to the onsite representatives, the most recent training occurred on June 26, 2024. However, this
training only included Parks & Recreation employees and I did not observe an employee sign-in sheet for this
training at the time of the audit.
6.6.2(g)
Maintenance activities, schedules, and long-term inspection procedures for
structural and non-structural stormwater controls to reduce floatables, trash,
and other pollutants discharged from the MS4 have been developed.
☐ C ☒ NC ☐ N/A
Municipal Facility (Oro Valley Street Maintenance):
- Black material observed on the ground
- Two barrels and two tubs containing a white material were observed open, on the ground, exposed to
stormwater
- One barrel observed cut in half with a rust colored material inside
- Black stains observed outside of the secondary containment for the used oil storage
- Dumpster leaking
- Recommend acquiring containment BMPs (e.g. oil booms)
Revised August 2024 LTF: 91833 Page 18
7.0: Analytical Monitoring
Citation Permit Requirement C: Compliant
NC: Noncompliant
N/A: Not Applicable
7.0 Analytical monitoring is being conducted in accordance to approved test
methods. ☐ C ☐ NC ☒ N/A
7.1.2
Permittee has identified outfall locations in the SWMP that discharge to
impaired waters, not-attaining waters, OAWs, and any additional monitoring
required by ADEQ.
☐ C ☐ NC ☒ N/A
7.2.1 Stormwater discharges have been sampled for stormwater characterization. ☒ C ☐ NC ☐ N/A
Stormwater characterization was observed during the audit.
7.2.6 All parameters listed in Appendix B are monitored. ☒ C ☐ NC ☐ N/A
7.3 A written Sampling and Analysis Plan (SAP) has been developed and includes
all of the minimum required contents. ☒ C ☐ NC ☐ N/A
A written SAP was observed during the audit.
7.6 Discharge Monitoring Reports (DMRs) are submitted as required. ☐ C ☐ NC ☒ N/A
Revised August 2024 LTF: 91833 Page 19
Outfall / Screening Point
Name: MO-5 Type: Residential/Commercial
Most Recent MS4 Inspection: Protected Surface Water:
Canada del Oro
Observations:
This outfall discharges to an unnamed ephemeral stream (Reach Code 15050301000954). The discharge
flows into this stream, and then flows approximately a quarter-mile northwest into the Canada del Oro
wash. I did not observe any discharge at the time of the field observations. I did not observe an overgrowth
of vegetation, trash and debris, or structural maintenance needs on the Oro Valley owned infrastructure.
Municipal Facility
Name: Oro Valley Street Maintenance Type: Maintenance
Most Recent MS4 Inspection: MS4 Outfall:
Observations:
The perimeter of the facility is a cement block wall. I observed weep holes in the perimeter wall, specifically
in the southwest corner (Photo No. 3) and along the northern perimeter (Photo No. 6). I observed
equipment storage in the southwest corner (Photo No. 2) and along the northern perimeter (Photo No. 5). I
observed an equipment and vehicle washing area onsite (Photo No. 4).
I observed a black material observed on the ground (Photo No. 7). According to onsite representatives, the
material was “asphalt tailings”.
In the northern area of the facility, I observed two open barrels and two open totes all containing an
unknown white material (Photo Nos. 8-10).
In the northeast corner of the facility, I observed a barrel cut in half, exposed to stormwater. I observed
water and a rust colored material within each half-barrel (Photo Nos. 11-12).
Along the eastern perimeter, I observed the used oil storage (Photo Nos. 13-16). Used oil is stored under
cover, within curbing. Black stains on the concrete were observed. I observed the used battery storage
(Photo No. 17). The used battery storage had the lid on at the time of the field observations.
I observed the fuel island (Photo Nos. 18). I observed the above ground storage tank containing unleaded
gasoline (Photo No. 19). I observed an available spill kit (Photo No. 20) and available absorbent (Photo No.
21) at the fuel island.
I observed a leak in the back of a dumpster located onsite (Photo No. 22).
Revised August 2024 LTF: 91833 Page 20
Construction Site
Name: La Posada at Pusch Ridge Type: Commercial
Acres: 21.5
CGP Authorization No.:
AZCN96637
Most Recent MS4 Inspection:
MS4 Outfall:
Observations:
I observed a stormwater drain onsite with fabric filter was installed (Photo No. 23). I observed a rip-rap
lined stormwater conveyance channel (Photo No. 24). I observed tracking of sediment observed on asphalt
on the northern portion of the construction site (Photo No. 25). I observed a roll-off dumpster; filled with
trash (Photo No. 26). I observed a designated area for concrete washout (Photo No. 27).
Post-Construction Stormwater BMP #1
Name: Saguaros Viejos East
Type: Retention Basin
Most Recent MS4 Inspection: MS4 Outfall:
Observations:
I did not observe any discharge at the time of the field observations. I did not observe an overgrowth of
vegetation, trash and debris, or structural maintenance needs on the Oro Valley owned infrastructure.
Revised August 2024 LTF: 91833 Page 21
Post-Construction Stormwater BMP #2
Name: Canada Ridge
Type: Gabion Wall
Most Recent MS4 Inspection: MS4 Outfall:
Observations:
I did not observe any discharge at the time of the field observations. I did not observe an overgrowth of
vegetation, trash and debris, or structural maintenance needs on the Oro Valley owned infrastructure.
Stormwater Field Inspection Photograph Log
Revised March 2022 Page 1
Facility Name (PLACE): Town of Oro Valley MS4 Inspectors: Steven Saeed &
Bronson Patten Weather: Sunny
Permit Authorization No.: AZSM 91833 Inspection No.: 456065 Inspection Date: 14-Nov-24
Photo No.
1.
Direction Photo Taken:
West
Photo Description:
Outfall MO-5
This outfall discharges to an unnamed
ephemeral stream seen in the picture
(Reach Code 15050301000954). The
discharge flows into this stream, and then
flows approximately a quarter-mile
northwest into the Canada del Oro wash.
Photo No.
2.
Direction Photo Taken:
Southeast
Photo Description:
Municipal Facility (Oro Valley Street
Maintenance)
Equipment storage observed in the
southwest corner of the facility.
Stormwater Field Inspection Photograph Log
Revised March 2022 Page 2
Photo No.
3.
Direction Photo Taken:
n/a
Photo Description:
Municipal Facility (Oro Valley Street
Maintenance)
Weep hole observed in the wall in the
southwest corner of the facility.
Photo No.
4.
Direction Photo Taken:
South
Photo Description:
Municipal Facility (Oro Valley Street
Maintenance)
Equipment and vehicle washing area.
Stormwater Field Inspection Photograph Log
Revised March 2022 Page 3
Photo No.
5.
Direction Photo Taken:
East
Photo Description:
Municipal Facility (Oro Valley Street
Maintenance)
Equipment storage along the northern
perimeter.
Photo No.
6.
Direction Photo Taken:
West
Photo Description:
Municipal Facility (Oro Valley Street
Maintenance)
Weep holes observed in the wall along the
northern perimeter.
Stormwater Field Inspection Photograph Log
Revised March 2022 Page 4
Photo No.
7.
Direction Photo Taken:
n/a
Photo Description:
Municipal Facility (Oro Valley Street
Maintenance)
A black material observed on the ground.
According to onsite representatives, the
material was “asphalt tailings”.
Photo No.
8.
Direction Photo Taken:
West
Photo Description:
Municipal Facility (Oro Valley Street
Maintenance)
Two open totes, both containing an
unknown white material.
Stormwater Field Inspection Photograph Log
Revised March 2022 Page 5
Photo No.
9.
Direction Photo Taken:
North
Photo Description:
Municipal Facility (Oro Valley Street
Maintenance)
Two open barrels and two open totes, all
containing an unknown white material.
Photo No.
10.
Direction Photo Taken:
n/a
Photo Description:
Municipal Facility (Oro Valley Street
Maintenance)
An open barrel containing an unknown
white material.
Stormwater Field Inspection Photograph Log
Revised March 2022 Page 6
Photo No.
11.
Direction Photo Taken:
n/a
Photo Description:
Municipal Facility (Oro Valley Street
Maintenance)
A barrel cut in half, exposed to
stormwater. I observed water and a rust
colored material in each half.
Photo No.
12.
Direction Photo Taken:
n/a
Photo Description:
Municipal Facility (Oro Valley Street
Maintenance)
A barrel cut in half, exposed to
stormwater. I observed water and a rust
colored material in each half.
Stormwater Field Inspection Photograph Log
Revised March 2022 Page 7
Photo No.
13.
Direction Photo Taken:
East
Photo Description:
Municipal Facility (Oro Valley Street
Maintenance)
Used oil storage. Used oil is stored within
curbing. Black stains on the concrete were
observed.
Photo No.
14.
Direction Photo Taken:
Northwest
Photo Description:
Municipal Facility (Oro Valley Street
Maintenance)
Used oil storage. Used oil is stored within
curbing. Black stains on the concrete were
observed.
Stormwater Field Inspection Photograph Log
Revised March 2022 Page 8
Photo No.
15.
Direction Photo Taken:
Northeast
Photo Description:
Municipal Facility (Oro Valley Street
Maintenance)
Used oil storage. Used oil is stored within
curbing. Black stains on the concrete were
observed.
Photo No.
16.
Direction Photo Taken:
East
Photo Description:
Municipal Facility (Oro Valley Street
Maintenance)
Used oil storage. Used oil is stored within
curbing. Black stains on the concrete were
observed.
Stormwater Field Inspection Photograph Log
Revised March 2022 Page 9
Photo No.
17.
Direction Photo Taken:
n/a
Photo Description:
Municipal Facility (Oro Valley Street
Maintenance)
Used battery storage; lid was on at the
time of the audit.
Photo No.
18.
Direction Photo Taken:
Northeast
Photo Description:
Municipal Facility (Oro Valley Street
Maintenance)
General overview of the fuel island. Some
overhead cover provided.
Stormwater Field Inspection Photograph Log
Revised March 2022 Page 10
Photo No.
19.
Direction Photo Taken:
Southeast
Photo Description:
Municipal Facility (Oro Valley Street
Maintenance)
Above ground storage tank filled with
unleaded gasoline.
Photo No.
20.
Direction Photo Taken:
n/a
Photo Description:
Municipal Facility (Oro Valley Street
Maintenance)
Spill kit available onsite at the fuel island.
Stormwater Field Inspection Photograph Log
Revised March 2022 Page 11
Photo No.
21.
Direction Photo Taken:
n/a
Photo Description:
Municipal Facility (Oro Valley Street
Maintenance)
Absorbent material available onsite for
spills.
Photo No.
22.
Direction Photo Taken:
n/a
Photo Description:
Municipal Facility (Oro Valley Street
Maintenance)
Leak observed on the backside of an
onsite dumpster.
Stormwater Field Inspection Photograph Log
Revised March 2022 Page 12
Photo No.
23.
Direction Photo Taken:
n/a
Photo Description:
Construction Site (La Posada at Pusch
Ridge)
Stormwater drain onsite. Fabric filter was
installed.
Photo No.
24.
Direction Photo Taken:
North
Photo Description:
Construction Site (La Posada at Pusch
Ridge)
Rip-rap lined stormwater conveyance
channel.
Stormwater Field Inspection Photograph Log
Revised March 2022 Page 13
Photo No.
25.
Direction Photo Taken:
South
Photo Description:
Construction Site (La Posada at Pusch
Ridge)
Tracking of sediment observed on asphalt
on the northern portion of the
construction site.
Photo No.
26.
Direction Photo Taken:
Northwest
Photo Description:
Construction Site (La Posada at Pusch
Ridge)
Roll-off dumpster; filled with trash.
Stormwater Field Inspection Photograph Log
Revised March 2022 Page 14
Photo No.
27.
Direction Photo Taken:
Northwest
Photo Description:
Construction Site (La Posada at Pusch
Ridge)
Designated area for concrete washout.
Photo No.
28.
Direction Photo Taken:
South
Photo Description:
Post-Construction Stormwater BMP #1
(Saguaros Viejos East Retention Basin)
Culvert discharging flow from the
neighborhood into the retention basin.
Stormwater Field Inspection Photograph Log
Revised March 2022 Page 15
Photo No.
29.
Direction Photo Taken:
East
Photo Description:
Post-Construction Stormwater BMP #2
(Canada Ridge Gabion Wall)
ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY
FIELD INSPECTION EXIT DEBRIEFING
Site Name/ID No(s): Town of Oro Valley MS4 Inspection Date:11/14/2024
Location: Oro Valley, AZ Environmental Program(s): AZPDES Stormwater
You have just received an inspection conducted to evaluate compliance with the Arizona Revised Statutes,
Title 49; the Arizona Administrative Code; and applicable permits/licenses. The following is intended to summarize potential
deficiencies noted during the inspection, items you should consider for follow up action, or additional information requested by the
inspector that is necessary to make a compliance determination. Be advised that additional reports and correspondence may be
forthcoming from ADEQ. Any omissions in this exit debriefing shall not be construed as a determination of compliance with
applicable laws and rules.
The ERP, did not include the following factors in prioritizing escalated enforcement:
1. Severity of non-compliance;
2. Repeated non-compliance;
3. Proximity to a receiving water or storm sewer system; and
4. Other appropriate factors
Annual Training (IDDE & Good Housekeeping)
- Training should be provided at least annually to all employees involved with stormwater:
o “provide annual training to employees involved in the IDDE program (e.g., street workers, inspectors, solid waste
personnel, etc.). The training shall include the IDDE program components and how to recognize illicit discharges”
o “Develop and implement an annual employee training program to incorporate pollution prevention and good
housekeeping techniques into everyday operations and maintenance activities”
Municipal Facility (“680”):
- Black material observed on the ground
- Two barrels and two tubs containing a white material were observed open, on the ground, exposed to stormwater
- One barrel observed cut in half with a rust colored material inside
- Black stains observed outside of the secondary containment for the used oil storage
- Dumpster leaking
- Recommend acquiring containment BMPs (e.g. oil booms)
Construction Site:
- Good housekeeping
- Sediment observed on asphalt
- Recommend walking the entire site during inspections
Additional areas of concern can be found on the back of this form
Please submit requested documentation by: ASAP.
Facility Representative Inspector
Name: Dennis Roberts, P.E., CFM Steven Saeed, CPMSM
Signature:
Please submit your response to your inspector’s attention at the Arizona Department of Environmental Quality, 1110 West
Washington Street, Phoenix, Arizona 85007.