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HomeMy WebLinkAboutWSCO_FORS_WSWP Audit Report Signed_20210728COMPLIANCE AUDIT REPORT FOR FORSYTH WINSTON SALEM WATER SUPPLY WATERSHED PROTECTION PROGRAM ID NO. WSCO_FORS Winston Salem, NORTH CAROLINA PO Box 2511 100 East First Street, Suite 328 Winston-Salem, NC 27101 Audit Date: April 27, 2021 Report Date: July 28, 2021 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 WSWP Program Audit Report Winston Salem, NC: WSWP ID WSCO_FORS TABLE OF CONTENTS AuditDetails........................................................................................................................ PermitteeInformation........................................................................................................ SupportingDocuments........................................................................................................ Program Implementation, Documentation & Assessment ................................................. Post -Construction Site Runoff Controls.............................................................................. Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1.................... Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 2.................... 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 Storm water Management Plan in accordance with the issued permit. Audit Date: April 27, 2021 ii WSWP Program Audit Report Winston Salem, NC: WSWP ID WSCO-FORS Audit Details Audit ID Number: Audit Date(s): WSCO-FORS-20210427 20210427 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: moose an itern. ❑ MS4 Outfalls. Number visited: ❑ Construction Sites. Number visited: ::... ® Post -Construction Stormwater Runoff Controls. Number visited: 2 ❑ Other: Number visited: 7' ose '"tt ❑ Other: Number visited: C ) :;se an �. . Inspector(s) Conducting Audit Name, Title Organization Paul Clark NCDEQ-DEMLR I -- Audit Report Author: Date: Signature��i _ Audit Report Author: Date Signature Audit Date(s): April 27, 2021 Page 1 of 15 WSWP Program Audit Report Winston Salem, NC: WSWP ID WSCO FORS Local Government Information Name: Forsyth —Winston Salem Permit Effective Date: Permit Expiration Date: City, State, ZIP: 100 East First Street, Suite 328 Winston-Salem, NC 27101 Date of Last Inspection/Audit: Co-permittee(s), if applicable: Permit Owner of Record: Primary MS4 Representatives Participating in Audit Name, Title Or-Ranization Matthew Osborne Erosion Control, Floodplain Management, and WSWP programs Stormwater Manager Andy Allen Keith Huff Field Operations Director — stormwater, roads Watersheds Waterbodv Classification Impairments Audit Date(s): April 27, 2021 Page 2 of 15 WSWP Program Audit Report Winston Salem, NC: WSWP ID WSCO_FORS Supporting Documents Item Number Document Title When Provided (prior to/During/After) 1 Winston Salem Forsyth Unified Development Ordinance — 8.3, 8.4, https://www.cityofws.org/DocumentCenter/View/4687/Winston-Salem-and- Forsyth-County-U n ified-Development-Ordinances-PDF online 2 Walkertown WSWP ordinance - Chapter C— Article III —Salem Lake Watershed Protection, Article IV — Watershed Protection https://library.municode.com/nc/walkertown/codes/unified_development—ordi nance?nodeld=CHCENOR ARTIIIWAPR 20210416 Salem Lake SCM Master List online 3 After 4 20210511 COWS SCM Ponds 20210verview Map After 5 20210511 Variance Requirements Agreement EC and Planning Staff After 6 Appendix A Org Chart DONE After 7 20200312 Org Chart After 8 FY 2021-2021 Workplan MOsborne After 9 20180222 Walkertown Watershed Protection Ordinance Gravel BUA Update After 10 20151103 Walkertown Attorney Existing BUA Clarification After 11 20210511 WSWP Forsyth WS Audit Followup WS Version FINAL 202104 Forsyth WS Gap Analysis After 12 During Program Implementation, Documentation & Assessment Staff Interviewed: Matthew Osborne, Andy Allen, Keith Huff (Name, Title, Role) Permit Citation Program Requirement Status Supporting Doc No. II.A.1 LG maintained adequate funding and staffing to implement and manage and meet all requirements of WSWP program. Yes 6,7,8 Audit Date(s): April 27, 2021 Page 3 of 15 WSWP Program Audit Report Winston Salem, NC: WSWP ID WSCO FORS Program Implementation, Documentation & Assessment Staffing and LG has specific position(s) responsible for the overall coordination, implementation, Funding and revision of the program . Yes 6,7,8 Responsibilities for all components of the WSWP program are documented and position(s) assignments provided. Yes 6,7,8 LG is current on payment of invoiced administering and compliance monitoring fees Not _ (see stormwater e-payments on DEMLR MS4 web page). Applicable Comments (Briefly describe funding mechanism, number of staff, etc.) Positions are budgeted as reoccurring. Web site includes organization chart with all positions and their responsibilities (see HR Section 1184). Please see supporting document nos. 6, 7, and 8. II.A.2 Progam LG evaluated the performance and effectiveness of the program components at least Implementation annually. Yes 12 and Evaluation If yes, the permittee used the results of the evaluation to modify the program components as necessary to accomplish the intent of the Stormwater Program. Yes 12 Comments Gap analysis (supporting document no. 12) evaluates and reviews programmatic functions. It may involve communication with other programs to learn/share information. Gap analyses done on as needed basis. 11.A.3 Keeping WSWP The permittee kept the WSWP ordinance up to date. Yes 1,2 Ordinance Up to Date The permittee notified DEMLR of any updates to the WSWP Ordinance. Yes 1,2 Comments (indicate the date of latest Stormwater Plan and describe the nature of any updates, if applicable). Forsyth-WS UDO-Chapter C — Articles III and IV, Walkertown UDO Article III. Ordinances revised to incorporate legislative and other changes as needed II.A.4 WSWP LG kept an up-to-date version of its WSWP Ordinance available to the Division and Ordinance the public online. Yes 1,2 Availability The online materials included ordinances, or other regulatory mechanisms, or a list identifying the ordinances, or other regulatory mechanisms, providing the legal Yes 1,2 authority necessary to implement and enforce the requirements of the program. Comments (Note what materials are available online) Ordinances contain majority of information necessary to implement program. Walkertown attorney letter has some additional guidance on existing development. II.A.3 & Il.A.5 Stormwater Plan Did DEMLR require a modification to the Ordinance? No Modifications If yes, did the permittee complete the modifications in accordance with the Not established deadline? Applicable Audit Date(s): April 27, 2021 Page 4 of 15 WSWP Program Audit Report Winston Salem, NC: WSWP ID WSCO_FORS Program Implementation, Documentation & Assessment Comments (Note date of DEMLR notification, modifications required, and date modifications were completed, as applicable) IL.A.6 Sharing Responsibility Are any control measures implemented by an entity other than the permittee? No If yes, is there a written agreement in place? Not - Applicable Comments (List the specific control measures implemented by others that do not have adequate written agreements, if applicable) 11.A.7 Written LG maintained written procedures for implementing Control measures. No --- Procedures Written procedures identified specific action steps, schedules, resources and No --- responsibilities for implementing WSWP program. Comments (List the specific minimum measures that do not have adequate written procedures, if applicable) Forsyth WS does not have written, formalized SOPs to memorialize programmatic flow process functions. Staff has been trained on the job from incumbent staff member regarding the administration of WSWP ordinance. III. A The permittee maintained documentation of all program components including, but Program not limited to, inspections, maintenance activities, educational programs, Yes ,p 1112 Documentation implementation of BMPs enforcement actions etc., on file for a period of five years. Comments (List the specific program components that do not have adequate documentation on file and why, if applicable) See comments at end of Program Implementation, Documentation, and Assessment section. Audit Date(s): April 27, 2021 Page 5 of 15 WSWP Program Audit Report Winston Salem, NC: WSWP ID WSCO—FORS Program Implementation, Documentation & Assessment Comments (Note dates that annual reports cover under current permit and generally describe report deficiencies, if any) - Forsyth WS implements WSWP program in Winston Salem, Walkertown, and Forsyth County (except those municipalities that administer program themselves). - Salem Lake offers low and high density, density averaging, and 5/70. Other watersheds offer low density and 5/70 - Pre 2008, post -construction projects that required Stormwater Control Measures (SCMs) are maintained in one geodatabase layer. This layer includes Salem Lake SCMs - Post 2008, post construction projects that require SCMs are maintained in comprehensive spreadsheet. Salem Lake SCMs are included in comprehensive spreadsheet. This spreadsheet includes permit number, address, type and number of SCMs on site, and as builts. Some of this information such as permit number is pulled into inspection plus spreadsheet (described below). - Projects with SCMs (high density) are reviewed by Joe Fogarty. - Inspection reports and pictures, issued violations and enforcement actions are in excel spreadsheet/yearly master file that catalogs all SCM information. This spreadsheet/yearly master file runs with geodatabase, so staff can compare annual progression of compliance and SCM condition. - All WSWP permits (including those in Salem Lake) that do NOT require Stormwater Control Measures (SCMs) are mapped in another geodatabase layer. These projects are currently reviewed by M. Osborne. - Permit system has flagging mechanism to show if proposed project is in WSWP area. If proposed project is not compliant, applicant must submit request to city of county zoning board of adjustments. - Regular applications are handled by WSWP program, but variance application requests must go to either Forsyth Board or Adjustments or Winston Salem Board or Adjustments. - ForsythWS improved variance submittal requirements, so that specific amount of increased BUA is now included - 5/70 tracking - entire project tract acreage is subtracted from total as opposed to just the BUA area portion of project - Erosion control staff field verify that developments are built according to requirements - There have been no WSWP — BUA or vegetated exceedances - WSWP exceedances would use E&SC NOV notice as a template, could also be similar to floodplain - Density averaging/paired parcel - metes and bounds description, recorded deed and conservation easement are recorded as part of DA/PP process - After NOV issued, entity has 10 days to respond and 90 days to correct deficiency - 2008 program improvements: - All post construction permits entered in geodatabase spreadsheet - WSWP permit holders must submit annual inspection report by qualified professional, earlier ForsythWS responsible - Forsyth WS has investigated the possibility of pulling information from different databases (such as that from SCM review spreadsheet, inspection plus spreadsheet) into one large database, but it is too expensive at this time. Audit Date(s): April 27, 2021 Page 6 of 15 WSWP Program Audit Report Winston Salem, NC: WSWP ID WSCO_FORS I Post -Construction Site Runoff Controls I Staff Interviewed: (Name, Title, Role) Matthew Osborne, Andy Allen, Keith Huff 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: name of entity ❑ The permittee implements the following deemed -compliant program(s), which meet NPDES MS4 post -construction requirements for the areas where implemented and in compliance with the specific program requirements as provided in 15A NCAC and noted below (Complete Session Law 2006-246 section below): ❑ Water Supply Watershed I (WS-1) —15A NCAC 26 .0212 ❑ Water Supply Watershed II (WS-II) —15A NCAC 213.0214 ® Water Supply Watershed III (WS-III) —15A NCAC 213.0215 ® Water Supply Watershed IV (WS-IV) —15A NCAC 213.0216 ❑ Freshwater High Quality Waters (HQW) —15A NCAC 2H .1006 ❑ Freshwater Outstanding Resource Waters (ORW) —15A NCAC 2H .1007 ❑ Neuse River Basin Nutrient Sensitive (NSW) Management Strategy —15A NCAC 26 .0235 ❑ Tar -Pamlico River Basin Nutrient Sensitive (NSW) Management Strategy —15A NCAC 213.0258 ❑ Randleman Lake Water Supply Watershed Nutrient Management Strategy —15A NCAC 213.0251 ❑ Universal Stormwater Management Program —15A NCAC 2H .1020 Ordinance(s) (check all that apply): The permittee utilizes the following ordinances and/or regulatory authority to fulfill post construction minimum measure program requirements throughout the MS4 permitted area (check all that apply): ❑ DEQ model ordinance ❑ MS4 designed post -construction practices that meet or exceed 15A NCAC 02H .1000. ❑ DEQ approved comprehensive watershed plan ® DEQ approved ordinance for a deemed -compliant Program (see list above) Instructinns- 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. Audit Date(s): April 27, 2021 Page 7 of 15 WSWP Program Audit Report Winston Salem, NC: WSWP ID WSCO_FORS Post -Construction Site Runoff Controls Session Law 2006- Program Requirement Status Supporting 246 Doc No. Deemed -Compliant The permittee implements deemed -compliant Program requirements in Program(s) accordance with the applicable 15A NCAC rules. Not Applicable The permittee implements deemed -compliant Program requirements throughout the entire MS4 area (If not, also complete the Permit Citation section below.) Not Applicable The permittee applies deemed -compliant Program requirements to all federal, state and local government projects within the permitted MS4 area who do not Not Applicable have their own NPDES stormwater permit. The permittee included deemed -compliant Program reporting in their MS4 Annual Reports. The permittee included deemed -compliant Program implementation in their Stormwater Management Plan. Not Applicable Comments 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 Yes 1,2 Management Program. If yes, the ordinance applies throughout the corporate limits of the permittee (Verify permit coverage area listed in Part I.D of permit and modify Yes 1,2 accordingly). The permittee has the authority to review designs and proposals for new development and redevelopment to determine whether adequate stormwater Yes 1,2 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 yes 1,2 evaluate compliance with the Post -Construction Stormwater Management Program. The permittee has the authority to enter private property for the purpose of inspecting at reasonable times any facilities, equipment, practices, or operations Yes 1,2 related to stormwater discharges. Comments (if the permittee relies upon another entity, specifically note the legal authority that allows that entity to implement the program within the MS4 area) I I. F.2. b Stormwater Control The permittee utilizes strategies which include SCMs appropriate for the MS4. Yes 1,2,3,4 Measures (SCMs) SCMs comply with 15A NCAC 02H .1000. Yes 1,2,3,4 Audit Date(s): April 27, 2021 Page 8of15 WSWP Program Audit Report Winston Salem, NC: WSWP ID WSCO_FORS Post -Construction Site Runoff Controls Comments II.F.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 that disturb less than one acre that are part of a larger common plan of Yes 3,4,11 development or sale). If yes, the site plan reviews addressed how the project applicant meets the performance standards. Yes 3,4,11 If yes, the site plan reviews addressed how the project will ensure long-term maintenance. Yes 3,4,11 Comments II.F.2.d The permittee maintained an inventory of projects with post -construction Inventory of Projects structural stormwater control measures installed and implemented at new Yes 3,4,11 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 Yes 3,4,11 requirements. Comments 1LF.2.e The permittee provided mechanisms such as recorded deed restrictions and Deed Restrictions protective covenants that ensure development activities will maintain the project Yes 1,2 and Protective consistent with approved plans. Covenants Comments Il.F.21 The permittee implemented or required an operation and maintenance plan for 1,2 Mechanism to the long-term operation of the SCMs required by the program. Yes Require Long-term 1,2 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. Yes Annual inspection of permitted structural SCMs are required to be performed by a 1,2 qualified professional. Yes Comments Audit Date(s): April 27, 2021 Page 9 of 15 WSWP Program Audit Report Winston Salem, NC: WSWP ID WSCO FORS Post -Construction Site Runoff Controls II.F.2.e 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 Yes 3,4,11 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 3,4,11 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 Yes 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 3,4,11 installed pursuant to the post -construction program(Verify this is a permit Yes condition in Part II.F.2.g of permit and modify accordingly. 3,4,11 The permittee documented and maintained records of inspections. Yes 3,4,11 The permittee documented and maintained records of enforcement actions. Yes Comments 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. Training for Note: New materials may be developed by the permittee, or the permittee may use Yes 1,2 Developers materials adopted from other programs and adapted to the permittee's new development and redevelopment program. Comments (if the permittee has adopted materials from other programs, indicate here which materials they are using) II.F.2.i Enforcement The permittee tracked the issuance of notices of violation and enforcement actions. Yes 3,4,11 If yes, the tracking mechanism included the ability to identify chronic violators for initiation of actions to reduce noncompliance. Yes 3,4,11 Comments II.F.3.b The permittee fully complies with post construction program requirements on its New Development own publicly funded construction projects. Yes 3,4,11 Comments Audit Date(s): April 27, 2021 Page 10 of 15 WSWP Program Audit Report Winston Salem, NC: WSWP ID WSCO_FORS Post -Construction Site Runoff Controls II.F.3.c Does the local government have areas draining to Nutrient Sensitive Waters (NSW) Nutrient Sensitive pursuant to 15A NCAC 02H .0150? No Waters If yes, does the permittee use SCMs that reduce nutrient loading in order to Choose meet local program requirements. an item, If yes, does the permittee also still incorporate the stormwater controls Ci �= required for the project's density level. an item, If yes, does the permittee also require documentation where it is not feasible to Choose use SCMs that reduce nutrient loading. an item Comments (Provide reference for local requirements) II.F.3..d The permittee ensured that the design volumes of SCMs take into account the 3,4,11 Design Volume runoff at build out from all surfaces draining to the system. Yes Where "streets" convey stormwater, the permittee designed SCMs to be sized to 3,4,11 treat and control stormwater runoff from all surfaces draining to the SCM including Yes streets, driveways, and other impervious surfaces. Comments Audit Date(s): April 27, 2021 Page 11 of 15 WSWP Program Audit Report Winston Salem, NC: WSWP ID WSCO FORS Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1 Site Name: Dollar General Date and Time of Site Visit: 4/27/2021 Site Address: SCM Type: Above ground sand filter 3103 Kernersville Road, Winston-Salem, NC 27107 Most Recent Inspection (Include Date and Entity): Most Recent Enforcement Activity (Include Date): Site Visit: Name of Inspector(s) evaluated: Name(s) and Title(s) of Site Representative(s) Present During the Name Title Matthew Osborne Erosion Control, Floodplain Management, and WSWP programs Andy Allen Stormwater Manager Paul Clark Environmental Program Consultant Observations Site Documentation Does the site have an operation and maintenance plan? Yes. Joe (Forsyth WS) uses Operation and Maintenance plan (and inspection forms) available on NCDEQ-DEMLR — Stormwater website. After the Permittee and Permittee's engineer completes the 0&M agreement. It is then reviewed/approved by Keith Huff (Forsyth WS Field Operations Director) and Forsyth WS attorney. After all parties approve O&M agreement, it is recorded with Forsyth County Register of Deeds. Does the site have records of annual inspections? Yes, they are maintained in inspections plus database, Are they performed by a qualified individual? Yes Inspector Training/Knowledge What type of stormwater training does the inspector receive? How often? Pre-2008 inspections were done by city, post 2008 done by Permittee. Forsyth WS inspectors must take NCSU O&M SW training. People taking this training need to be recertified every three years. New inspectors shadow experienced inspectors. After first year, new inspectors are sent with notebooks and they contact experienced inspectors as needed. Experienced inspectors go to field to assist newer inspectors as needed. Other training includes webinars and APWA. Non -Forsyth WS inspectors must either be certified professional engineers, land surveyors, or have taken all required training. Did the inspector appear knowledgeable about requirements for post -construction site runoff controls? Yes Audit Date(s): April 27, 2021 Page 12 of 15 WSWP Program Audit Report Winston Salem, NC: WSWP ID WSCO_FORS Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1 Did the inspector appear knowledgeable about post -construction BMPs (general purpose/function, components, O&M requirements, etc.)? Yes Inspection Procedures Does the inspector's process include the use of a checklist or other standardized form? What format? Yes. Forsyth WS uses forms available by NCDEQ. Forsyth WS approves use of other forms. Does the inspector's process include taking photos? Yes. Photos taken of all SCMs as well as the site perimeter. This documentation better enables compliance tracking. Ensuring that needed maintenance, repair, etc. occur. Does the inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections? Forsyth WS ensures Permittee and its engineers are meeting requirements. If not deficiencies noted and then followup occurs to ensure requirements are met. Does the inspector's process include walking the entire site and inspecting all points of discharge? Yes. Did the inspector miss any obvious operation and maintenance deficiencies? If so, explain: No Does the inspector's process include presenting the inspection findings to the site contact in writing? Forsyth WS ensures Permittee and its engineers are meeting requirements. If not deficiencies noted and then followup occurs to ensure requirements are met. Compliance/Enforcement What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in? NA. Yet NOVs and followup are tracked in the inspection plus spreadsheet. If compliance issues were identified, what timeline for correction/follow-up was provided? NA Yet NOVs and followup are tracked in the inspection plus spreadsheet. Notes/Comments/Recommendations Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 2 Site Name: Stewart Road Date and Time of Site Visit: 4/27/2021 Audit Date(s): April 27, 2021 Page 13 of 15 WSWP Program Audit Report Winston Salem, NC: WSWP ID WSCO_FORS Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 2 Site Address: SCM Type: 212 Steward Road Winston-Salem, NC 27107 Most Recent MS4 Inspection (Include Date and Entity): Name of MS4 Inspector(s) evaluated: Most Recent MS4 Enforcement Activity (Include Date): Name(s) and Title(s) of Site Representative(s) Present During the Site Visit: Name Title Matthew Osborne Erosion Control, Floodplain Management, and WSWP programs Andy Allen Stormwater Manager Paul Clark Environmental Program Consultant Observations Site Documentation Does the site have an operation and maintenance plan? Does the site have records of annual inspections? Are they performed by a qualified individual? Inspector Training/Knowledge What type of stormwater training does the inspector receive? How often? Did the inspector appear knowledgeable about requirements for post -construction site runoff controls? Did the inspector appear knowledgeable about post -construction BMPs (general purpose/function, components, 0&M requirements, etc.)? Inspection Procedures Does the inspector's process include the use of a checklist or other standardized form? What format? Does the inspector's process include taking photos? Does the inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections? Audit Date(s): April 27, 2021 Page 14 of 15 WSWP Program Audit Report Winston Salem, NC: WSWP ID WSCO_FORS Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 2 Does the inspector's process include walking the entire site and inspecting all points of discharge? Did the inspector miss any obvious operation and maintenance deficiencies? If so, explain: Does the inspector's process include presenting the inspection findings to the site contact in writing? Compliance/Enforcement What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in? If compliance issues were identified, what timeline for correction/follow-up was provided? Notes/Comments/Recommendations This site does not have engineered stormwater control measure(s). It is a low density residential development and the back portions of the single family lots are open and vegetated with grass cover. Audit Date(s): April 27, 2021 Page 15 of 15