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HomeMy WebLinkAboutNCS000540_Self Audit_20220831MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) PROGRAM AUDIT REPORT NPDES PERMIT NO. NCS000540 MOORESVILLE, NORTH CAROLINA P.O. Box 878 Mooresville, NC 228115 Audit Date: August 10, 2022 Report Date: August 16, 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 REGFIVE AUG 12022 LAND QUALITY SECTION ASHFVBIF MS4 Permit Audit Report Mooresville, NC: NPDES Permit No. NCS000540 (This page intentionally left blank) Audit Date: August 10, 2022 MS4 Permit Audit Report Mooresville, NC: NPDES Permit No. NCS000540 Construction Site Runoff Controls ........................ Post -Construction Site Runoff Controls ............... Total Maximum Daily Loads (TMDLs)................... Appendix A: Supporting Documents Appendix B: Photograph Log 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. LAND QUALITY SECTI01' ASHFIIIU. F Audit Date: August 10, 2022 MS4 Permit Audit Report Mooresville, NC: NPDES Permit No. NCS000540 This page intentionally left blank Audit Date: August 10, 2022 iii MS4 Permit Audit Report Mooresville, NC: NPDES Permit No. NCSOOOS40 Audit Details Audit ID Number: Audit Date(s): NC5000540_Mooresville MS4 Audit_20220810 August 10, 2022 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 M Post -Construction Site Runoff Controls ❑ Pollution Prevention and Good Housekeeping for Municipal Operations ® Total Maximum Daily Loads (TMDLs) Field Site Visits: ❑ Municipal Facilities. Number visited: Choose an item. ❑ MS4 Outfalls. Number visited: Choose an item. ❑ Construction Sites. Number visited: Choose an item. ❑ Post -Construction Stormwater Runoff Controls. Number visited: Choose an item. ❑ Other: Number visited: Choose an item. ❑ Other: Number visited: Choose an item. Inspector(s) Conducting Audit Name, Title Organization Marissa Meltzer, Stormwater Program Specialist Town of Mooresville Nick Lynch, Stormwater Maintenance Supervisor Town of Mooresville Audit Report Author: Marissa Meltzer, Stormwater Program Date: Specialist i B / a N Signature _A Audit Report Author: Date Signature LAND Q aHLF\in.SF-C71OV Audit Date(s): August 10, 2022 Page 1 of 14 MS4 Permit Audit Report Mooresville, NC: NPDES Permit No. NCS000540 Permittee Information MS4 Permittee Name: Town of Mooresville Permit Effective Date: November 2011 Permit Expiration Date: August 2021 City, State, ZIP: P.O. Box 878 Mooresville, NC 28115 Date of Last MS4 Inspection/Audit: June 8, 2022 Co-permittee(s), if applicable: Permit Owner of Record: Randall Hemann, Town Manager Primary MS4 Representatives Participating in Audit Name, Title Organization Marissa Meltzer, Stormwater Program Specialist Town of Mooresville Nick Lynch, Stormwater Maintenance Supervisor Town of Mooresville MS4 Receiving Waters Waterbodv Classification Impairments Byers Creek WS-IV, CA None Known Davidson Creek WS-IV, CA None Known McCrary Creek WS-IV, B; CA None Known Reeds Creek WS-IV, B; CA None Known Work Creek WS-IV, B; CA None Known Back Creek WS-II, HQW None Known Dye Creek C None Known Rocky River C Benthos Poor South Fork Withrow Creek C None Known West Branch Rocky River C None Known Audit Date(s): August 10, 2022 Page 2 of 14 MS4 Permit Audit Report Mooresville, NC: NPDES Permit No. NCS000540 Supporting Documents Item Number Document Title When Provided (Prior to/During/After) I Interlocal Agreement Between Town of Mooresville & Iredell County Prior To (during DEQ Audit) 2 Town of Mooresville Unified Development Ordinance During 3 Post Construction and Illicit Discharge and Connection Ordinance During 4 Town of Mooresville Land Development Standards During 5 Town of Mooresville Administrative Manual During 6 Sketch Plan Checklist, Concept Plan Checklist, Site Plan Checklist During 7 Private SCM Inventory During 8 Town SCM Inventory & Inspection Log Prior To (during DEQ Audit) 9 SCM Inspection Processes Sheet During 10 Enforcement Spreadsheet During RECEIVE P LAND QUALITY 5ECTIO HEUII.( P Audit Date(s): August 10, 2022 Page 3 of 14 MS4 Permit Audit Report Mooresville, NC: NPDES Permit No. NC5000540 Construction Site Runoff Controls Staff Interviewed: Marissa Meltzer, Stormwater Program Specialist (Name, Title, Role) Nick Lynch, Stormwater Maintenance Supervisor Program Delegation Status: ❑ The permittee has a delegated Sediment and Erosion Control Program and implements the North Carolina Sedimentation Pollution Control Act (SPCA) of 1973 components of this minimum measure (complete the permit citation and SPCA citation sections). N The permittee does not have a delegated Sediment and Erosion Control Program and relies on DEMLR to comply with the North Carolina Sedimentation Pollution Control Act (SPCA) of 1973 components of this minimum measure (complete only the permit citation section). Permit Citation Program Requirement Status supporting Doc No. II.E.3 Construction Site Runoff Controls The permittee provides and promotes a means for the public to notify the ]NPDES Permit No. appropriate authorities of observed erosion and sedimentation problems (e.g., Yes 1 NCS000435] promoting the existence of the DEQ DEMLR "Stop Mud" hotline). Comments (Describe how provided and promoted) The Town of Mooresville does not have a delegated Sediment and Erosion Control Program. The Town relies on DEMLR to comply with the North Carolina Sedimentation Pollution Control Act (SPCA) of 1973. An interlocal agreement has been in place with Iredell County since 2009 to conduct erosion and sediment control inspections within the limits of the Town of Mooresville. The Town of Mooresville website advertises the Stop Mud hotline and contact information for Iredell County Erosion Control. Town staff frequently receives call about construction site runoff and will investigate accordingly to determine if the concern can be pursued as an illicit discharge. Resident complaints are logged as service requests and are passed on to Iredell County for their investigation and enforcement. SPCA Citation Delegated Program Requirement Status supporting Doc No. 113A-60 Local The permittee has adopted an ordinance or other regulatory mechanism to enforce Not erosion and the erosion and sedimentation control program. Applicable sedimentation control programs (a) If yes, the ordinance meets or exceeds the minimum requirements of the Not SPCA. Applicable If yes, the ordinance applies throughout the corporate limits of the permittee. Not [Permit Part I.D] Applicable Comments (Provide regulatory mechanism reference or Supporting Documentation number) Audit Date(s): August 10, 2022 Page 4 of 14 MS4 Permit Audit Report Mooresville, NC: NPDES Permit No. NCS000540 Construction Site Runoff Controls § 113A-60 Local erosion and The permittee collects a fee paid by each person who submits an erosion and Not sedimentation sedimentation control plan. Applicable control programs (d) Comments (indicate the fee amount, If applicable) 113A-60 Local Has any person initiated a land -disturbing activity (within the permittee's erosion and jurisdiction) for which an erosion and sedimentation control plan is required in the Not sedimentation absence of an approved plan? Applicable control programs (e) If yes, the permittee has notified the North Carolina Sedimentation Control Not Commission of all such cases. Applicable Has the permittee determined that a person engaged in a land -disturbing activity Not has failed to comply with an approved erosion and sedimentation control plan? Applicable If yes, has the permittee referred any such matters to the North Carolina Not Sedimentation Control Commission for inspection and enforcement? Applicable Comments 113A-61 Local The permittee reviews each erosion and sedimentation control plan submitted to approval of erosion them and notifies the person submitting the plan that it has been approved, Not Applicable and sedimentation approved with modification, or disapproved within 30 days of receipt. control plans The permittee only approves an erosion and sedimentation control plan upon Not determining that it complies with all applicable State and local regulations. Applicable The permittee has disapproved of an erosion and sedimentation control plan in Not order to protect riparian buffers along surface waters. Applicable If yes, the permittee notified the Director of the Division of Energy, Not Mineral, and Land Resources within 10 days of the disapproval. Applicable Comments Audit Date(s): August 10, 2022 Page 5 of 14 MS4 Permit Audit Report Mooresville, NC: NPDES Permit No. NCS000540 Construction Site Runoff Controls § 113A-61.1 Inspection of land- The certificate of approval of each erosion and sedimentation control plan Not disturbing activity; approved by the permittee includes a notice of the right to inspect. Applicable notice of violation (a) The permittee provides for inspection of land -disturbing activities to ensure compliance with the SPCA and to determine whether the measures required in an Not Applicable erosion and sedimentation control plan are effective. Comments § 113A-61.1 When the permittee determines that a person engaged in land -disturbing activity Inspection of land- has failed to comply with the SPCA, the Permittee immediately issues a notice of Not Applicable disturbing activity; violation upon that person. notice of violation Each notice of violation issued by the permittee specifies the date by which the Not (c) person must comply. Applicable --- Each notice of violation issued by the permittee informs the person of the actions Not that need to be taken to comply. Applicable Comments 113A-64 Penalties Does the permittee issue civil penalties as part of the erosion and sedimentation Not program? Applicable Comments (indicate when/why a civil penalty is issued, and the amount, if applicable) Audit Date(s): August 10, 2022 Page 6 of 14 MS4 Permit Audit Report Mooresville, NC: NPDES Permit No. NCS000540 Post -Construction Site Runoff Controls Staff Interviewed: (Name, Title, Role) Marissa Meltzer, Stormwater Program Specialist Nick Lynch, Stormwater Maintenance Supervisor LAND Q SHLF�IIISF�TI01 Audit Date(s): August 10, 2022 Page 7 of 14 MS4 Permit Audit Report Mooresville, INC: NPDES Permit No. NCS000540 Post -Construction Site Runoff Controls 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 2B .0212 ® Water Supply Watershed II (WS-II) —15A NCAC 2B .0214 ❑ Water Supply Watershed III (WS-III) —15A NCAC 213.0215 ® Water Supply Watershed IV (WS-IV) — 15A NCAC 2B.0216 ❑ Freshwater High Quality Waters (HOW) —15A NCAC 2H .1006 ❑ Freshwater Outstanding Resource Waters (ORW) —15A NCAC 2H .1007 ❑ Neuse River Basin Nutrient Sensitive (NSW) Management Strategy —15A NCAC 213 .0235 ❑ Tar -Pamlico River Basin Nutrient Sensitive (NSW) Management Strategy —15A NCAC 2B .0258 ❑ Randleman Lake Water Supply Watershed Nutrient Management Strategy-15A NCAC 2B .0251 ❑ Universal Stormwater Management Program — 15A NCAC 2H .1020 Ordinance(s) (check all that apply): The permittee utilizes the following ordinances and/or regulatory authority to fulfill post construction minimum measure program requirements throughout the MS4 permitted area (check all that apply): ® 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) Instructions: For MS4s not implementing a S.L. 2006-246 deemed -compliant program, complete only the Permit Citation section below. For MS4s implementing a S.L. 2006-246 deemed -compliant program, complete the Session Law 2006-246 section below. if the MS4 does not implement a deemed -compliant program throughout the entire M54 permitted area, then complete the Permit Citation section below for the permitted orea(s) not covered under the S.L. 1006-246 deemed -compliant program. Session Law 2006- program Requirement Status Supporting 246 Doc No. Audit Date(s): August 10, 2022 Page 8 of 14 MS4 Permit Audit Report Mooresville, NC: NPDES Permit No. NCS000540 Post -Construction Site Runoff Controls Deemed -Compliant The permittee implements deemed -compliant Program requirements in Program(s) accordance with the applicable i5A NCAC rules. Yes 2 The permittee implements deemed -compliant Program requirements throughout the entire MS4 area (If not, also complete the Permit Citation section below.) Yes 2 The permittee applies deemed -compliant Program requirements to all federal, state and local government projects within the permitted M54 area who do not Not have their own NPDES stormwater permit. Applicable The permittee included deemed -compliant Program reporting in their MS4 Annual Reports. Not Applicable The permittee included deemed -compliant Program implementation in their stormwater Management Plan. Not Applicable Comments Deemed -Compliant Programs (Water Supply Watersheds WS-II & WS-IV) are enforced through the Town of Mooresville Unified Development Ordinance. The Water Supply Watershed program was audited by NCDEQ in April 2022 with no required changes to this implementation. *Remaining points are not applicable as current permit does not require annual reporting for deemed -compliant programs or SWMP implementation. 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 3 Management Program. If yes, the ordinance applies throughout the corporate limits of the permittee (Verify permit coverage area listed in Part LD of permit and modify Yes 3 accordingly). The permittee has the authority to review designs and proposals for new development and redevelopment to determine whether adequate stormwater Yes 3 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 evaluate compliance with the Post -Construction stormwater Management Yes 3 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 3 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) *For corporate limit question: Sec 25-5(d) of Ordinance: "The provisions of this chapter shall apply within the areas designated on the Town of Mooresville Annexation Map, as amended" The permittee utilizes strategies which include SCMs appropriate for W619194. Yes 4 Audit Date(s): August 10, 2022 011ALI(YSF- T'O' 4SHFVI 4Page 9 of 14 MS4 Permit Audit Report Mooresville, NC: NPDES Permit No. NCS000540 Post -Construction Site Runoff Controls Stormwater Control Measures (SCMs) SCMs comply with 15A NCAC 02H .1000. Yes 4 Comments The Town's Land Development Standards require SCMs to be designed and constructed in compliance with the latest version of NCDENR Stormwater Design Manual. As indicated by NCDEQ website, the Stormwater design Manual is compatible with the Minimum Design Criteria that are codified in the stormwater rules. 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 Yes 4, 5, 6 that disturb less than one acre that are part of a larger common plan of development or sale). If yes, the site plan reviews addressed how the project applicant meets the Yes 4, 5, 6 performance standards. If yes, the site plan reviews addressed how the project will ensure long-term Yes 4, 5, 6 maintenance. Comments The Town utilizes Plan Review Checklists and enforces CO/Plat requirements. SCM's require as built certification by PE, final inspection, and an operation and maintenance agreement to be in place prior to CO. 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 7 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 8 requirements. Comments Inventory of projects with post -construction SCM's is kept on the Stormwater OneDrive. SCM's are also mapped by parcel on ArcGIS Online. Town maintained post- construction SCM's are kept in a separate database and are also mapped on ArcGIS Online. II.F.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 3 and Protective consistent with approved plans. Covenants Comments Sec 25-24(a) of Post Construction Ordinance "Deed recordation and indications on plat. The applicable operations and maintenance agreement, conservation easement, or dedication and acceptance into public maintenance (whichever is applicable) pertaining to every structural BMP shall be referenced on the final plat and shall be recorded with the county register of deeds upon final plat approval. If no subdivision plat is recorded for the site, then the operations and maintenance agreement, conservation easement, or dedication and acceptance into public maintenance, whichever is applicable shall be recorded with the county register of deeds so as to appear in the chain of title of all subsequent purchasers under generally accepted searching principles." II.F.2.f The permittee implemented or required an operation and maintenance plan for the long-term operation of the SCMs required by the program. Yes 3 Audit Date(s): August 10, 2022 Page 10 of 14 MS4 Permit Audit Report Mooresville, NC: NPDES Permit No. NCS000540 Post -Construction Site Runoff Controls Mechanism to The operation and maintenance plan required the owner of each SCM to perform Require Long-term and maintain a record of annual inspections of each SCM. Yes 3 Operation and Maintenance Annual inspection of permitted structural SCMs are required to be performed by a qualified professional. Yes 3 Comments See Sec. 25-19 and 25-20 of Post Construction Ordinance. 0&M agreements are required for all structural SCM's and are binding on all subsequent landowners. 0&M outlines maintenance requirements and inspection frequency. Annual inspections are required for all SCM's and are due to the Stormwater Program Specialist by March 31" of each calendar year. Inspection must be completed by a qualified professional (engineer, surveyor, landscape architect or an individual with SCM Inspection and Maintenance Certification from NC State. II.F.2.¢ The permittee conducted and documented inspections of each project site covered Inspections of under performance standards, at least one time during the permit term (Verify this Not Structural is o permit condition in Part II.F.2.g of permit and modify accordingly). Applicable Stormwater Control Before issuing a certificate of occupancy or temporary certificate of occupancy, the Measures permittee conducted a post -construction inspection to verify that the permittee's performance standards have been met or a bond Is in place to guarantee Not Applicable completion (Verify this is a permit condition in Part II.17.2.9 of permit and modify accordingly. The permittee developed and Implemented a written inspection program for SCMs installed pursuant to the post -construction program(Verify this is a permit Partial 9 condition in Part II.F.2.g of permit and modify accordingly. The permittee documented and maintained records of inspections. Yes 7 The permittee documented and maintained records of enforcement actions. Yes 10 Comments Written Process and Requirements for Annual Inspections has been effective since 2018. All annual inspections are logged in an Excel database. Enforcement actions are also logged in the Excel Database to track NOV's and repeat offenses. 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 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) Post Construction Ordinance, Land Development Standards, Land Development Process, Checklists, O&M Agreements, Inspection Forms and Stormwater Facility Maintenance Guide on Town Website.a LAND QUAUI sECTV' ASI�Ftt'I I''�' Audit Date(s): August 10, 2022 Page 11 of 14 MS4 Permit Audit Report Mooresville, NC: NPDES Permit No. NCS000540 Post -Construction Site Runoff Controls II.F_2.i Enforcement The permittee tracked the issuance of notices of violation and enforcement Yes 10 actions. If yes, the tracking mechanism included the ability to identify chronic violators for initiation of actions to reduce noncompliance. Yes 10 Comments Violations and enforcement actions are logged in an excel database on the Stormwater OneDrive II.F3.b 7Theppeurmittee fully complies with post construction program requirements on itsNew Yes 8 Developmentcly funded construction projects. Comments Town projects are held to the same requirements as private development. There is an inventory of Town maintained SCMs that were installed for compliance with Post -Construction requirements. SCM's are inspected on the schedules recommended by the Stormwater Design Manual. As-builts, past inspection logs and maintenance records are saved II.F3.c Does the MS4 have areas draining to Nutrient Sensitive Waters (NSW) pursuant to Nutrient Sensitive 15A NCAC 02H .0150? No --- Waters If yes, does the permittee use SCMs that reduce nutrient loading in order to Not meet local program requirements. Applicable If yes, does the permittee also still incorporate the stormwater controls Not required for the project's density level. Applicable If yes, does the permittee also require documentation where it is not feasible to Not use SCMs that reduce nutrient loading. Applicable Comments (Provide reference for local requirements) The Town of Mooresville does not have any areas draining to Nutrient Sensitive Waters. II.F3.d The permittee ensured that the design volumes of SCMs take into account the Design Volume runoff at build out from all surfaces draining to the system. Yes 4 Where "streets" convey stormwater, the permittee designed SCMs to be sized to treat and control stormwater runoff from all surfaces draining to the SCM including Yes 4 streets, driveways, and other impervious surfaces. Comments The Town ensures design volumes of SCMs take into account the runoff at build out from all surfaces draining to the system and ensures all streets. Driveways and other impervious surfaces are considered in the design size. See Land Development Standards. Audit Date(s): August 10, 2022 Page 12 of 14 MS4 Permit Audit Report Mooresville, NC: NPDES Permit No. NCS000540 Total Maximum Daily Loads (TMDLs) Staff Interviewed: Marissa Meltzer, Stormwater Program Specialist (Name, Title, Role) Program Status: ❑ The permittee is not subject to an approved TMDL (skip the rest of this section). ® The permittee is subject to an approved TMDL for: Rocky River (13-17) is subject to a TMDL for fecal coliform was approved in September 2002. There ❑ is ® is not a Waste Load Allocation (WLA) in the approved TMDL (If there is o WLA, then complete items II.H.1-5 below. If there is not a WLA, skip to item II.14.6 below) Permit Citation Program Requirement Status supJNo. Do II.H.3 TMDLs Within 12 months of final TMDL approval, the permittee's annual reports included a description of existing programs, controls, partnerships, projects and strategies to Not Applicable address impaired waters. Within 12 months of final TMDL approval, the permittee's annual reports provided a brief explanation as to how the programs, controls, partnerships, projects and Not Applicable strategies address impaired waters. Comments ILH.4 TMDLs Within 24 months of final TMDL approval, the permittee's annual reports included an assessment of whether additional structural and/or non-structural BMPs are Not necessary to address impaired waters. Applicable Within 24 months of final TMDL approval, the permittee's annual reports included a brief explanation as to how the programs, controls, partnerships, projects and Not strategies address impaired waters. Applicable Comments" I_ANl7 QUALM `l Sh! ,Tldt AfiII(�i,ll II.H.5 TMDLs Within 36 months of final TMDL approval, the permittee's annual reports included a description of activities expected to occur and when activities are expected to Not Applicable occur. Audit Date(s): August 10, 2022 Page 13 of 14 MS4 Permit Audit Report Mooresville, NC: NPDES Permit No. NCS000540 Total Maximum Daily Loads (TMDLs) Comments II.11.6 TMDLs If there is no Waste Load Allocation in the approved TMDL, the permittee evaluated strategies and tailored and/or expanded BMPs within the scope of the six minimum measures to enhance water quality recovery strategies in the Yes --- watershed(s) to which the TMDL applies. The permittee described strategies and tailored and/or expanded BMPS in their Partial --- Stormwater Management Plan and annual reports Comments The Town of Mooresville takes measures to address the TMDL for fecal coliform in Rocky River. The Rocky River Wastewater Treatment operates under a NCGI10000 permit and has an updated Stormwater Pollution Prevention Plan for the facility. The SWPPP outlines the layout of the facility, outfall monitoring information and the best management practices used to limit exposure. Pet waste was added to the list of Target Pollutants in hopes to mitigate Fecal Coliform in Rocky River and educational materials are to be distributed to appropriate audiences. Audit Date(s): August 10, 2022 Page 14 of 14