HomeMy WebLinkAboutNCS000430_Audit Report_20220624MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM AUDIT REPORT
NPDES PERMIT NO. NCS000430
MONTREAT, NORTH CAROLINA
1200 Montreat Rd.
Montreat, North Carolina 28757
Audit Date: June 23, 2022
Report Date: June 24, 2022
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
(This page intentionally left blank)
NC5000430 Montreat MS4 Audit 20220623
TABLE OF CONTENTS
AuditDetails..................................................................................................................................................1
PermitteeInformation..................................................................................................................................2
List of Supporting Documents.......................................................................................................................3
Program Implementation, Documentation & Assessment...........................................................................4
Public Education and Outreach.....................................................................................................................7
Public Involvement and Participation...........................................................................................................8
Illicit Discharge Detection and Elimination(IDDE)........................................................................................9
Pollution Prevention and Good Housekeeping for Municipal Operations.................................................11
Site Visit Evaluation: Municipal Facility No. 1.............................................................................................13
Site Visit Evaluation: MS4 Outfall No. 1......................................................................................................14
Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1............................................15
DISCLAIMER
This audit consists of an evaluation of program compliance with the issued permit and implementation of
the approved Stormwater Management Plan. This audit report does not include a review of all program
components, and program deficiencies in addition to those noted may be present. The permittee is
required to assess program progress and permit compliance, and to implement the approved Stormwater
Management Plan in accordance with the issued permit.
NCS000430 MontreatMS4Audit 20220623 ii
This page intentionally left blank
NC5000430 Montreat M54 Audit 20220623 Hi
Audit Details
Audit ID Number:
Audit Date(s):
NCS000430_Montreat MS4 Audit_20220623
June 23, 2022
Minimum Control Measures Evaluated:
N Program Implementation, Documentation & Assessment
N Public Education & Outreach
N Public Involvement & Participation
N 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
N Pollution Prevention and Good Housekeeping for Municipal Operations
❑ Total Maximum Daily Loads (TMDLs)
Field Site Visits:
N Municipal Facilities. Number visited: 1
N MS4 Outfalls. Number visited: 1
❑ Construction Sites. Number visited: Choose an item.
N Post -Construction Stormwater Runoff Controls. Number visited: 1
❑ Other: Number visited: Choose an item.
❑ Other: Number visited: Choose an item.
Inspector(s) Conducting Audit
Name. Title
Organization
Isaiah Reed, Environmental Engineer
NCDEQ
James Rogers, Environmental Specialist
'
NCDEQ
Audit Report Auth %
Date:
Signature
� /
Audit Report Author:
Date:
Signature
NCS000430_Montreat MS4 Audit_20220623 Page 1 of 16
Permittee Information
MS4 Permittee Name:
Town of Montreat
Permit Effective Date:
2/20/2017
Permit Expiration Date:
2/19/2022
Mailing Address:
96 Rainbow Ter. Montreat, North Carolina 28757
Date of Last MS4 Inspection/Audit:
2/28/2014
Co-permittee(s), if applicable:
Permit Owner of Record:
Timothy R. Helms, Mayor
Primary MS4 Representatives Participating in Audit
Name, Title
Organization
Mary Roderick, Regional Planner
Land of Sky (COG)
Daniel Wiggs, Maintenance Tech
Town of Montreat
Ben Blackburn, Town Administrator
Town of Montreat
Barry Creasman, Public Works Director
Town of Montreat
MS4 Receiving Waters
Waterbody
Classification
Impairments
Flat Creek
C
Piney Branch
C;HQW
Kitchen Branch
C
Little Piney Branch
C
Puncheon Branch
C
NCS000430_Montreat MS4 Audit_20220623 Page 2 of 16
List of Supporting Documents
Item
Number
Document Title
When Provided
(Prior to/During/After)
1
Water Quality Assessment
Prior
2
Land of Sky Contract
During
3
2016SWMP
Prior
4
Land of Sky Powerpoint
During
5
General Ordinance
Prior
6
SCM Inventory
During
7
Training certificates
During
NCS000430_Montreat MS4 Audit_20220623 Page 3 of 16
Program Implementation, Documentation & Assessment
Staff Interviewed:
Mary Roderick, Regional Planner
(Name, Title, Role)
Daniel Wiggs, Maintenance Tech
Ben Blackburn, Town Administrator
Barry Creasman, Public Works Director
Permit Citation
Program Requirement
Status
supporting
Doc No.
II.A.1
The permittee maintained adequate funding and staffing to implement and manage
Staffing and
the provisions of the Stormwater Plan and meet all requirements of the permit.
No
Funding
The Stormwater Plan identifies a specific position(s) responsible for the overall
coordination, implementation, and revision to the Plan.
No
3
Responsibilities for all components of the Stormwater Plan are documented and
position(s) assignments provided.
No
3
The permittee is current on payment of invoiced administering and compliance
monitoring fees (see stormwater e-payments on DEMCR M54 web page).
No
2016 SWMP has not been maintained.
II.A.2 Stormwater
The permittee evaluated the performance and effectiveness of the program
Plan
components at least annually.
No
---
Implementation
and Evaluation
If yes, the permittee used the results of the evaluation to modify the program
Not
components as necessary to accomplish the intent of the Stormwater Program.
Applicable
Did the permitted MS4 discharges cause or contribute to non -attainment of an
applicable water quality standard?
No
1
If yes, did the permittee expand or better tailor its BMPs accordingly to address
Not
the non -attainment?
Applicable
.--
Water quality assessment done in 2020. No annual evaluation has been documented.
II.A.3
Keeping the
The permittee kept the Stormwater Plan up to date.
No
---
Stormwater Plan
Up to Date
The permittee notified DEMLR of any updates to the Stormwater Plan,
Not
Applicable
The SWMP has not been maintained.
II.A.4 Availability
The permittee kept an up-to-date version of its Stormwater Plan available to the
of the Stormwater
Division and the public online.
No
---
Plan
The online materials included ordinances, or other regulatory mechanisms, or a list
identifying the ordinances, or other regulatory mechanisms, providing the legal
Partial
Website
authority necessary to implement and enforce the requirements of the permit.
Townofmontreat.org
NCS000430_Montreat MS4 Audit_20220623 Page 4 of 16
Program Implementation, Documentation & Assessment
II.A.3 & II.A.S
Stormwater Plan
Did DEMLR require a modification to the Stormwater Plan?
Not
Applicable
Modifications
If yes, did the permittee complete the modifications in accordance with the
Not
established deadline?
Applicable
II.A& Sharing
Responsibility
Are any control measures implemented by an entity other than the permittee?
Yes
2
If yes, is there a written agreement in place?
No
---
Land of Sky has implemented an amount of Public Education/Outreach and Public Involvement/Participation. However, no
agreement has been made.
II.A.7
The permittee maintained written procedures for implementing the six minimum
Written
control measures.
No
---
Procedures
Written procedures identified specific action steps, schedules, resources and
responsibilities for implementing the six minimum measures.
No
Permittee did not maintain a written program for all MCMs.
Ill A
The permittee maintained documentation of all program components including, but
Program
not limited to, inspections, maintenance activities, educational programs,
Yes
---
Documentation
implementation of BMPs, enforcement actions etc., on file for a period of five years.
1113
The permittee submitted annual reports to the Department within twelve months
Annual Report
from the effective date of the permit (See Section III.B. for the annual reporting
Yes
alms
Submittal
period specific to this MS4).
The permittee submitted subsequent annual reports every twelve months from the
scheduled date of the first annual report submittal.
Yes
BIMS
The Annual Reports included appropriate information to accurately describe the progress, status, and results
of the permittee's Stormwater Plan, including, but not limited the following:
1. A detailed description of the status of implementation of the Stormwater Plan
as a whole. This will include information on development and implementation
Not
of each major component of the Stormwater Plan for the past year and
Reviewed
"""
schedules and plans for the year following each report.
2. An adequate description and justification of any proposed changes to the
Stormwater Plan. This will include descriptions and supporting information for
Not
the proposed changes and how these changes will impact the Stormwater
Reviewed
Plan (results, effectiveness, implementation schedule, etc.).
3. Documentation of any necessary changes to programs or practices for
assessment of management measures implemented through the Stormwater
Not
Plan.
Reviewed
4. A summary of data accumulated as part of the Stormwater Plan throughout
the year along with an assessment of what the data indicates in light of the
Not
---
Stormwater Plan.
Reviewed
NCS000430_Montreat MS4 Audit_20220623 Page 5 of 16
Program Implementation, Documentation & Assessment
5. An assessment of compliance with the permit, information on the
establishment of appropriate legal authorities, inspections, and enforcement
Not
Reviewed
actions.
IV.8
Annual Reporting
The Annual Reports document the following:
1. A summary of past year activities, including where applicable, specific
Not
quantities achieved and summaries of enforcement actions.
Reviewed
2. A description of the effectiveness of each program component.
Not
Reviewed
3. Planned activities and changes for the next reporting period, for each
Not
program component or activity.
Reviewed
4. Fiscal analysis.
Not
Reviewed
NC5000430_Montreat M54 Audit_20220623 Page 6 of 16
Public Education and Outreach
Staff Interviewed:
Mary Roderick, Regional Planner
(Name, Title, Role)
Daniel Wiggs, Maintenance Tech
Ben Blackburn, Town Administrator
Barry Creasman, Public Works Director
Permit Citation
Program Requirement Status Supporting
Doc No.
11.6.2.a
The permittee defined goals and objectives of the Local Public Education and
Goals and
No 3
Outreach Program based on community wide issues.
Objectives
Goals not specifically
identified in SWMP.
11.8.2.b
The permittee maintained a description of the target pollutants and/or stressors and
Target Pollutants
likely sources.
Partial
3
The SWMP contains some language concerning target pollutants.
II.B.2.c
The permittee identified, assessed annually and updated the description of the target
Target Audiences
audiences likely to have significant storm water impacts and why they were selected.
No
11.B.2.d Residential
The permittee described issues, such as pollutants, the likely sources of those
and Industrial/
pollutants, potential impacts, and the physical attributes of stormwater runoff in
No
---
Commercial Issues
their education/outreach program.
II.8.2.e
The permittee promoted and maintained an internet web site designed to convey the
Informational
program's message.
No
---
Web Site
No link on the Towns page to link to Landofsky.
II.B.2.f
Public Education
The permittee distributed stormwater educational material to appropriate target
Materials
groups.
No
---
No material distributed.
II.B.2.¢
The permittee promoted and maintained a stormwater hotline/helpline for the
Hotline/Help Line
purpose of public education and outreach.
No
II.B.2.h
The permittee's outreach program, including those elements implemented locally or
Public Education
through a cooperative agreement, included a combination of approaches designed to
No
---
and Outreach
reach the target audiences.
Program
For each media, event or activity, including those elements implemented locally or
through a cooperative agreement the permittee estimated and recorded the extent
No
---
of exposure.
Activity was documented with Land of Sky. However, an agreement is not In place for Land of Sky to implement the
requirements of this MCM.
NCS000430_Montreat MS4 Audit_20220623 Page 7 of 16
Public Involvement and Participation
Staff Interviewed:
Mary Roderick, Regional Planner
(Name, Title, Role)
Daniel Wiggs, Maintenance Tech
Ben Blackburn, Town Administrator
Barry Creasman, Public Works Director
Permit Citation
Program Requirement Status supporting
Doc No.
II.C.2.a Volunteer
Community
The permittee included and promoted volunteer opportunities designed to promote
Involvement
NO
ongoing citizen participation.
Program
Activity was documented with Land of Sky. However, an agreement is not in place for Land of Sky to implement the
requirements of this MCM.
II.C.2.b
Mechanism for
The permittee provided and promoted a mechanism for public involvement that
Public
provides for input on stormwater issues and the stormwater program.
No
Involvement
II.C2.c
The permittee promoted and maintained a hotline/helpline for the purpose of public
Hotline/Help Line
involvement and participation.
ves
Website
Townofmontreat.or7
NCS000430_Montreat MS4 Audit_20220623 Page 8 of 16
Illicit Discharge Detection and Elimination (IDDE)
Staff Interviewed:
Mary Roderick, Regional Planner
(Name, Title,
Daniel Wiggs, Maintenance Tech
Role)
Ben Blackburn, Town Administrator
Barry Creasman, Public Works Director
Permit Citation
Program Requirement Status supporting
Doc No.
II.D.2.a
IDDE Program
The permittee maintained a written IDDE Program. No ---
If yes, the written program includes provisions for program assessment and Not
evaluation and integrating program. Applicable
No written IDDE program
has been maintained.
The permittee maintained an IDDE ordinance or other regulatory mechanism(s) that
II.D.2.b
provides the legal authority to prohibit illicit connections and discharges to the MS4.
Partial
S
Legal Authorities
If yes, the ordinance applies throughout the corporate limits of the permittee.
[Permit Part I.D]
Yes
---
Penalty section of IDDE ordinance is not clear.
II.D.2.c
The permittee maintained a current map showing major outfalls* and receiving
MS4
Storm Sewer
Yes
Field
System Map
streams.
Map app
Drainage areas not considered in creation of the map.
II.D.2.d
The permittee maintained a program for conducting dry weather flow field
Dry Weather Flow
observations in accordance with written procedures.
No
---
Program
A dry weather flow field inspections program is in the process of being created.
II.D.2.e
The permittee maintained written procedures for conducting investigations of
Investigation
identified illicit discharges.
No
---
Procedures
No written program has been maintained.
II.D.2.f
For each case of an illicit discharge or potential illicit discharge, the permittee documented and tracked the
Track and
following:
Document
Investigations
1. The date(s) the illicit discharge was observed
Not
Applicable
2. The results of the investigation
Not
Applicable
3. Any follow-up of the investigation
Not
Applicable
4. The date the investigation was closed
Not
Applicable
No IDDE events recorded.
NCS000430_Montreat MS4 Audit_20220623 Page 9 of 16
Illicit Discharge Detection and Elimination (IDDE)
II.D.2.e Employee
The permittee implemented and documented a training p p g program for appropriate
Training
municipal staff who, as part of their normal job responsibilities, may come into
No
---
contact with or otherwise observe an illicit discharge or illicit connection.
No Training program implemented.
II.D.2.h
The permittee informed public employees of hazards associated with illegal
Public Education
discharges and improper disposal of waste.
No
The permittee informed businesses of hazards associated with illegal discharges and
improper disposal of waste.
No
The permittee informed the general public of hazards associated with illegal
discharges and improper disposal of waste.
No
---
The permittee promoted, publicized, and facilitated a reporting mechanism for the
Public Reporting
public to report illicit discharges.
Yes
Website
Mechanism
The permittee promoted, publicized, and facilitated a reporting mechanism for staff
to report illicit discharges.
Yes
Software
The permittee established and implemented response procedures for citizen
requests/reports.
No
---
The permittee implemented a mechanism to track the issuance of notices of violation
Enforcement
and enforcement actions administered by the permittee.
No
If yes, the mechanism includes the ability to identify chronic violators for
Not
initiation of actions to reduce noncompliance.
Applicable
---
No notices of violation have been issued. No tracking mechanism has been Implemented.
NCS000430_Montreat MS4 Audit_20220623 Page 10 of 16
Pollution Prevention and Good Housekeeping for Municipal Operations
Staff Interviewed:
Mary Roderick, Regional Planner
(Name, Title, Role)
Daniel Wiggs, Maintenance Tech
Ben Blackburn, Town Administrator
Barry Creasman, Public Works Director
Permit Citation
Program Requirement
Status
Supporting
Doc No.
II.G.2.a
The permittee maintained a current inventory of facilities and operations owned
Facility Inventory
and operated by the permittee with the potential for generating polluted
No
---
stormwater runoff.
II.G.2.b
The permittee maintained and implemented an 0&M program for municipally
Operation and
owned and operated facilities with the potential for generating polluted
No
---
Maintenance (O&M)
stormwater runoff.
for Facilities
If yes, the O&M program specifies the frequency of inspections.
Not
Applicable
If yes, the 0&M program specifies the frequency of routine maintenance
Not
requirements.
Applicable
---
If yes, the permittee evaluated the O&M program annually and updated it as
Not
necessary.
Applicable
---
No 0&M plan has been created and maintained.
II.G.2.c
Spill Response
The permittee had written spill response procedures for municipal operations.
No
---
Procedures
No Spill response plan has been developed and maintained.
II.G.2.d Streets,
The permittee evaluated existing and new BMPs that reduce polluted stormwater
Roads, and Public
runoff from municipally -owned streets, roads, and public parking lots within its
No
---
Parking Lots
corporate limits annually.
Maintenance
If yes, the permittee evaluated the effectiveness of existing and new BMPs
Not
based on cost and the estimated quantity of pollutants removed.
Applicable
No annual evaluation has been documented.
II.G.2.f
O&M for Catch
The permittee maintained and implemented an 0&M program for the stormwater
Basins and
sewer system including catch basins and conveyance systems that it owns and
No
---
Conveyance Systems
maintains.
No operation and maintenance plan has been developed and maintained.
II.G.2.d
The permittee maintained a current inventory of municipally -owned or operated
Structural
structural stormwater controls installed for compliance with the permittee's post-
yes
6
Stormwater Controls
construction ordinance.
Inventory maintained and provided.
NC5000430_Montreat M54 Audit_20220623 Page 11 of 16
Pollution Prevention and Good Housekeeping for Municipal Operations
II.G.2.e
The permittee maintained and implemented an O&M program for municipally -
O&M for Structural
owned or maintained structural stormwater controls installed for compliance with
No
---
Stormwater Controls
the permittee's post -construction ordinance. If yes, then:
The C&M program specified the frequency of inspections and routine
Not
maintenance requirements.
Applicable
---
The permittee documented inspections of all municipally -owned or maintained
Not
structural stormwater controls.
Applicable
---
The permittee inspected all municipally -owned or maintained structural
Not
stormwater controls in accordance with the schedule developed by permittee.
Applicable
The permittee maintained all municipally -owned or maintained structural
Not
stormwater controls in accordance with the schedule developed by permittee.
Applicable
The permittee documented maintenance of all municipally -owned or
Not
maintained structural stormwater controls.
Applicable
---
No operation and maintenance plan has been developed and maintained.
II.G.2.f
The permittee ensured municipal employees are properly trained in pesticide,
Not
Pesticide, Herbicide
herbicide and fertilizer application management.
Applicable
and Fertilizer
Application
The permittee ensured contractors are properly trained in pesticide, herbicide and
Not
Management
fertilizer application management.
Applicable
The permittee ensured all permits, certifications, and other measures for
Not
applicators are followed.
Applicable
No Pesticides, Herbicides, or fertilizers are utilized by the permittee.
II.G.2.g
The ermittee implemented an employee trainin
p pg program for employees involved
Staff Training
in implementing pollution prevention and good housekeeping practices.
No
---
No training program has been developed and implemented.
II.G.2.h
The permittee described and implemented measures that prevent or minimize
Vehicle and
contamination of stormwater runoff from all areas used for vehicle and equipment
Yes
Equipment Cleaning
cleaning.
Town vehicles are washed in Black Mountain.
NCS000430_Montreat MS4 Audit_20220623 Page 12 of 16
Site Visit Evaluation: Municipal Facility No. 1
Facility Name:
Public Works Facility
Date and Time of Site Visit:
6/23/2022 3:00 pm
Facility Address:
Rainbow Terrace
Facility Type (Vehicle Maintenance, Landscaping, etc.):
Public works, landscaping
Name of MS4 inspector(s) evaluated:
Barry Creasman, Public Works Director
Most Recent MS4 Inspection (List date and name of inspector):
None
Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name
Title
Daniel Wiggs
Maintenance Tech II
Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific?
No SWPPP or other stormwater document for the facility has been developed.
What type of stormwater training do facility employees receive? How often?
None.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
Applicable staff have become certified inspectors. Continued certification requires continuing ed hours.
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
Yes.
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Yes.
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form?
No.
Does the MS4 inspector's process include taking photos?
No.
Does the MS4 Inspector's process include reviewing the facility's SWPPP (or similar document)?
No.
Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge?
Yes.
Did the MS4 inspector miss any obvious areas of concern? If so, explain:
No.
Does the MS4 inspector's process include presenting the inspection findings to the facility contact?
N/A
Inspection Results
Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)?
No.
NCS000430_Montreat MS4 Audit_20220623 Page 13 of 16
Site Visit Evaluation: MS4 Outfall No. 1
Outfall ID Number:
Date and Time of Site Visit:
None given.
June 23, 2022 3:30 pm
Outfall Location:
Outfall Description (Pipe Material/Diameter, Culvert, etc.):
Kentucky Road
36" galvanized metal
Receiving Water:
Is Flow Present? If So, Describe (Color, Approximate Flow Rate,
Flat Creek
Sheen, Odor, Floatables/Debris, etc.):
None
Most Recent Outfall Inspection/Screening (Date):
None
Days Since Last Rainfall:
Inches:
Not reviewed
N/A
Name of MS4 Inspector(s) evaluated:
Barry Creaasman
Observations
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
Applicable staff have become certified inspectors. Continued certification requires continuing ed hours.
Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations?
Yes.
Inspection Procedures
Does the inspector's process include the use of a checklist or other standardized form?
No.
Does the inspector's process include taking photos?
No.
Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they?
No.
Inspection Results
Did the outfall inspection result in any work orders or maintenance requests? If so, for what issue(s)?
No.
Will a follow-up outfall inspection be conducted? If so, for what reason?
Yes. Routine.
Notes/Comments/Recommendations
NCS000430_Montreat MS4 Audit_20220623 Page 14 of 16
Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1
Site Name:
Bio-cell at Town Hall
Date and Time of Site Visit:
6/24/2022
Site Address:
Rainbow Terrace
SCM Type:
Bio-Cell
Most Recent MS4 Inspection (Include Date and Entity):
None
Name of MS4 Inspector(s) evaluated:
Barry Creasman
Most Recent MS4 Enforcement Activity (Include Date):
None
Name(s) and Title(s) of Site Representative(s) Present During the Site Visit:
Name
Title
Barry Creasman
Public Works Director
Daniel Wiggs
Maintenance Tech If
Observations
Site Documentation
Does the site have an operation and maintenance plan?
No.
Does the site have records of annual inspections? Are they performed by a qualified individual?
Not reviewed.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
Applicable staff have become certified inspectors. Continued certification requires continuing ed hours.
Did the MS4 inspector appear knowledgeable about M54 requirements for post -construction site runoff controls?
No.
Did the MS4 inspector appear knowledgeable about post -construction BMPs (general purpose/function, components, 0&M
requirements, etc.)?
Yes.
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form? What format?
No.
Does the MS4 inspector's process include taking photos?
Not reviewed
Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections?
Not reviewed at time of inspection.
Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge?
Yes
Did the MS4 inspector miss any obvious operation and maintenance deficiencies? If so, explain:
No.
Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing?
Yes.
Compliance/Enforcement
What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in?
Modifications to the permittee's documentation process will be made.
NCS000430_Montreat MS4 Audit_20220623 Page 15 of 16
Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1
If compliance issues were identified, what timeline for correction/follow-up was provided?
Not evaluated.
NCS000430_Montreat MS4 Audit_20220623 Page 16 of 16