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HomeMy WebLinkAboutNCS000430_Self-Audit_20221101DRAFT PHASE II MS4 AUDIT TEMPLATE FOR PERMITS ISSUED PRIOR TO 2019 Edit yellow highlighted items to be specific to the MS4 being audited. MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) PROGRAM AUDIT REPORT NPDES PERMIT NO. NCS000430 Montreat, NORTH CAROLINA PO Box 426 Montreat, NC 28757 Audit Date: 10/21/2022 Report Date: 10/25/2022 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 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 (This page intentionally left blank) Audit Date: XXX MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 TABLE OF CONTENTS AuditDetails..................................................................................................................................................1 PermitteeInformation..................................................................................................................................2 SupportingDocuments.................................................................................................................................3 Program Implementation, Documentation & Assessment...........................................................................4 Public Education and Outreach.....................................................................................................................8 Public Involvement and Participation.........................................................................................................11 Illicit Discharge Detection and Elimination(IDDE)......................................................................................13 Construction Site Runoff Controls..............................................................................................................16 Post -Construction Site Runoff Controls......................................................................................................19 Pollution Prevention and Good Housekeeping for Municipal Operations.................................................25 Total Maximum Daily Loads (TMDLs).........................................................................................................28 Site Visit Evaluation: Municipal Facility No. 1.............................................................................................30 Site Visit Evaluation: Municipal Facility No. 2.............................................................................................32 Site Visit Evaluation: MS4 Outfall No. 1......................................................................................................34 Site Visit Evaluation: MS4 Outfall No. 2......................................................................................................36 Site Visit Evaluation: Construction Site No. 1.............................................................................................38 Site Visit Evaluation: Construction Site No. 2.............................................................................................40 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1............................................42 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 2............................................44 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. Audit Date: XXX ii MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 This page intentionally left blank Audit Date: XXX MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Audit Details Audit ID Number: Audit Date(s): NCS000430_Montreat MS4 Audit_20221021 10/21/2022 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 ❑X Post -Construction Site Runoff Controls ❑ Pollution Prevention and Good Housekeeping for Municipal Operations ❑X 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 Oreanization N/A Self Audit Audit Report Author: Date: A'7 10/21/2022 Signature Audit Report Author: Date Signature Audit Date(s): 10/21/2022 Page 1 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Permittee Information MS4 Permittee Name: Permit Effective Date: Permit Expiration Date: Date of Last MS4 Inspection/Audit: City, State, ZIP: Co-permittee(s), if applicable: Permit Owner of Record: Primary MS4 Representatives Participating in Audit Name, Title Organization MS4 Receiving Waters Waterbody Classification Impairments Audit Date(s): 10/21/2022 Page 2 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Supporting Documents Item When Provided Number Document Title (Prior to/During/After) Audit Date(s): 10/21/2022 Page 3 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Program Implementation, Documentation & Assessment Staff Interviewed: (Name, Title, Role) Permit Citation Program Requirement Status Supporting Doc No. II.A.1 The permittee maintained adequate funding and staffing to implement and manage Choose Staffing and the provisions of the Stormwater Plan and meet all requirements of the permit. an item. Funding The Stormwater Plan identifies a specific position(s) responsible for the overall Choose coordination, implementation, and revision to the Plan. an item. Responsibilities for all components of the Stormwater Plan are documented and Choose position(s) assignments provided. an item. The permittee is current on payment of invoiced administering and compliance Choose monitoring fees (see stormwater e-payments on DEMLR M54 web page). an item. Comments (Briefly describe funding mechanism, number of staff, etc.) II.A.2 Stormwater The permittee evaluated the performance and effectiveness of the program Choose Plan components at least annually. an item. Implementation and Evaluation If yes, the permittee used the results of the evaluation to modify the program Choose components as necessary to accomplish the intent of the Stormwater Program. an item. Did the permitted MS4 discharges cause or contribute to non -attainment of an Choose applicable water quality standard? an item. If yes, did the permittee expand or better tailor its BMPs accordingly to address Choose the non -attainment? an item. Comments Audit Date(s): 10/21/2022 Page 4 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Program Implementation, Documentation & Assessment I I.A.3 Choose Keeping the The permittee kept the Stormwater Plan up to date. --- Stormwater Plan an item. Up to Date Choose The permittee notified DEMLR of any updates to the Stormwater Plan. --- an item. Comments (Indicate the date of latest Stormwater Plan and describe the nature of any updates, if applicable). II.A.4 Availability The permittee kept an up-to-date version of its Stormwater Plan available to the Choose of the Stormwater Division and the public online. an item. Plan The online materials included ordinances, or other regulatory mechanisms, or a list Choose identifying the ordinances, or other regulatory mechanisms, providing the legal --- authority necessary to implement and enforce the requirements of the permit. an item. Comments (Note what materials are available on line) II.A.3 & II.A.5 Choose Stormwater Plan Did DEMLR require a modification to the Stormwater Plan? --- an item. Modifications If yes, did the permittee complete the modifications in accordance with the Choose established deadline? an item. Comments (Note date of DEMLR notification, modifications required, and date modifications were completed, as applicable) II.A.6 Sharing Choose Responsibility Are any control measures implemented by an entity other than the permittee? --- an item. Choose If yes, is there a written agreement in place? --- an item. Comments (List the specific control measures implemented by others that do not have adequate written agreements, if applicable) II.A.7 The permittee maintained written procedures for implementing the six minimum Choose Written control measures. an item. Procedures Written procedures identified specific action steps, schedules, resources and Choose responsibilities for implementing the six minimum measures. an item. Comments (List the specific minimum measures that do not have adequate written procedures, if applicable) Audit Date(s): 10/21/2022 Page 5 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Program Implementation, Documentation & Assessment III. A The permittee maintained documentation of all program components including, but Choose Program g not limited to, inspections, maintenance activities, educational programs, Documentation implementation of BMPs, enforcement actions etc., on file for a period of five years. an item. Comments (List the specific program components that do not have adequate documentation on file and why, if applicable) 111.13 The permittee submitted annual reports to the Department within twelve months Choose Annual Report from the effective date of the permit (See Section III.B. for the annual reporting --- Submittal period specific to this MS4). an item. The permittee submitted subsequent annual reports every twelve months from the Choose scheduled date of the first annual report submittal. an item. 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 Choose of each major component of the Stormwater Plan for the past year and an item. 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 Choose the proposed changes and how these changes will impact the Stormwater an item. Plan (results, effectiveness, implementation schedule, etc.). 3. Documentation of any necessary changes to programs or practices for Choose assessment of management measures implemented through the Stormwater Plan. an item. 4. A summary of data accumulated as part of the Stormwater Plan throughout Choose the year along with an assessment of what the data indicates in light of the --- Stormwater Plan. an item. 5. An assessment of compliance with the permit, information on the Choose establishment of appropriate legal authorities, inspections, and enforcement actions. an item. Comments (Note dates that annual reports cover under current permit and generally describe report deficiencies, if any) IV.B Annual Reporting The Annual Reports document the following: 1. A summary of past year activities, including where applicable, specific Choose quantities achieved and summaries of enforcement actions. an item. Choose 2. A description of the effectiveness of each program component. --- an item. 3. Planned activities and changes for the next reporting period, for each Choose program component or activity. an item. Audit Date(s): 10/21/2022 Page 6 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Program Implementation, Documentation & Assessment Choose 4. Fiscal analysis. an item Comments (Note dates that annual reports cover under current permit and generally describe report deficiencies, if any) Audit Date(s): 10/21/2022 Page 7 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Public Education and Outreach Staff Interviewed: (Name, Title, Role) Permit Citation Program Requirement Status Supporting Doc No. II.B.2.a The permittee defined goals and objectives of the Local Public Education and Choose Goals and Outreach Program based on community wide issues. an item. Objectives Comments (Generally describe process for establishing goals/objectives) II.B.2.b The permittee maintained a description of the target pollutants and/or stressors and Choose Target Pollutants likely sources. an item. Comments (List target pollutants, note any that are missing or not appropriate) II.B.2.c The permittee identified, assessed annually and updated the description of the target Choose Target Audiences audiences likely to have significant storm water impacts and why they were selected. an item. Comments (Describe any changes made, if applicable) Audit Date(s): 10/21/2022 Page 8 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Public Education and Outreach II.B.2.d Residential The permittee described issues, such as pollutants, the likely sources of those Choose and Industrial/ pollutants, potential impacts, and the physical attributes of stormwater runoff in Commercial Issues their education/outreach program. an item. Comments (Generally describe the residential/industrial/commercial issues addressed) II.B.2.e The permittee promoted and maintained an internet web site designed to convey the Choose Informational --- program's message. an item. Web Site Comments (list web page address and general contents, or attach screen shot of landing page) II.B.2.f The permittee distributed stormwater educational material to appropriate target Choose Public Education Materials groups. an item. Comments (List distributed materials and quantity, message, distribution mechanism, target audience for each if not included in program documentation/annual reporting) II.B.2.e The permittee promoted and maintained a stormwater hotline/helpline for the Choose Hotline/Help Line purpose of public education and outreach. an item. Comments (Note hotline contact information and method(s) for advertising it) II.B.2.h The permittee's outreach program, including those elements implemented locally or Choose through a cooperative agreement, included a combination of approaches designed to reach the target audiences. an item. Audit Date(s): 10/21/2022 Page 9 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Public Education and Outreach Public Education and Outreach For each media, event or activity, including those elements implemented locally or Choose Program through a cooperative agreement the permittee estimated and recorded the extent of exposure. an item. Comments (Generally describe approaches, extent of exposure. Note any cooperating entities, agreements and scope of services, or reference comments in Section II.A.6. above.) Additional Comments: Audit Date(s): 10/21/2022 Page 10 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Public Involvement and Participation Staff Interviewed: (Name, Title, Role) Permit Citation Program Requirement Status supporting Doc No. II.C.2.a Volunteer Community The permittee included and promoted volunteer opportunities designed to promote Choose Involvement ongoing citizen participation. an item. Program Comments (Note opportunities promoted and date(s) of volunteer events) II.C.2.b Mechanism for The permittee provided and promoted a mechanism for public involvement that Choose Public provides for input on stormwater issues and the stormwater program. an item. Involvement Comments (Note mechanism(s) for input and how promoted) II.C.2.c The permittee promoted and maintained a hotline/helpline for the purpose of public Choose Hotline/Help Line involvement and participation. an item. Comments (Note hotline contact information and how it is promoted) Audit Date(s): 10/21/2022 Page 11 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Public Involvement and Participation Additional Comments: Audit Date(s): 10/21/2022 Page 12 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Illicit Discharge Detection and Elimination (IDDE) Staff Interviewed: (Name, Title, Role) Permit Citation Program Requirement Status Supporting Doc No. II.D.2.a Choose IDDE Program The permittee maintained a written IDDE Program. an item. If yes, the written program includes provisions for program assessment and Choose evaluation and integrating program. an item. Comments (Note any deficiencies) The permittee maintained an IDDE ordinance or other regulatory mechanism(s) that Choose II.D.2.b provides the legal authority to prohibit illicit connections and discharges to the MS4. an item. Legal Authorities If yes, the ordinance applies throughout the corporate limits of the permittee. Choose [Permit Part I.D] an item. Comments II.D.2.c The permittee maintained a current map showing major outfalls and receiving Choose Storm Sewer --- streams. an item. System Map Comments *Major outfalls are discharges from > 36" diameter pipes or drainage areas of > 50 acres. In areas zoned for industrial activity, major outfalls are > 12" or drainage area > 2 acres. II.D.2.d The permittee maintained a program for conducting dry weather flow field Choose Dry Weather Flow --- observations in accordance with written procedures. an item. Program Comments (Generally summarize program, including frequency of observations and # or % of outfalls screened) Audit Date(s): 10/21/2022 Page 13 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Illicit Discharge Detection and Elimination (IDDE) II.D.2.e The permittee maintained written procedures for conducting investigations of Investigation identified illicit discharges. Procedures Comments (Generally describe what procedures are documented) 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 Choose Investigations 1. The dateg (s)the illicit discharge was observed an item. --- Choose 2. The results of the investigation --- an item. Choose 3. Any follow-up of the investigation --- an item. Choose 4. The date the investigation was closed an item. Comments (Note whether a standard inspection form is utilized to capture consistent information and a tracking mechanism is used) II.D.2.e Employee The permittee implemented and documented a training program for appropriate Choose Training municipal staff who, as part of their normal job responsibilities, may come into --- contact with or otherwise observe an illicit discharge or illicit connection. an item. Comments (Generally describe the staff training program, including frequency and which staff are trained) II.D.2.h The permittee informed public employees of hazards associated with illegal Choose Public Education discharges and improper disposal of waste. an item. The permittee informed businesses of hazards associated with illegal discharges and Choose improper disposal of waste. an item. The permittee informed the general public of hazards associated with illegal Choose discharges and improper disposal of waste. an item. Comments (Note how each sector was informed, if applicable) Audit Date(s): 10/21/2022 Page 14 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Illicit Discharge Detection and Elimination (IDDE) II.D.2.i The permittee promoted, publicized, and facilitated a reporting mechanism for the Choose Public Reporting public to report illicit discharges. an item. Mechanism The permittee promoted, publicized, and facilitated a reporting mechanism for staff Choose to report illicit discharges. an item. The permittee established and implemented response procedures for citizen Choose requests/reports. an item. Comments (Generally describe reporting mechanisms and how promoted/publicized/facilitated/established) II.D.2.i The permittee implemented a mechanism to track the issuance of notices of violation Choose Enforcement and enforcement actions administered by the permittee. an item. If yes, the mechanism includes the ability to identify chronic violators for Choose initiation of actions to reduce noncompliance. an item. Comments (Generally describe the established tracking mechanism, if applicable) Audit Date(s): 10/21/2022 Page 15 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Construction Site Runoff Controls Staff Interviewed: (Name, Title, Role) Program Delegation Status: ❑ The permittee has a delegated Sediment and Erosion Control Program and implements the North Carolina Sedimentation Pollution Control Act (SPCA) of 1973 components of this minimum measure (complete the permit citation and SPCA citation sections). ❑ The permittee does not have a delegated Sediment and Erosion Control Program and relies on DEMLR to comply with the North Carolina Sedimentation Pollution Control Act (SPCA) of 1973 components of this minimum measure (complete only the permit citation section). Permit Citation Program Requirement Status Supporting Doc No. II.E.3 Construction Site Runoff Controls The permittee provides and promotes a means for the public to notify the Choose (NPDES Permit No. appropriate authorities of observed erosion and sedimentation problems (e.g., --- NCS000435J promoting the existence of the DEQ DEMLR "Stop Mud" hotline). an item. Comments (Describe how provided and promoted) SPCA Citation Delegated Program Requirement Status Supporting Doc No. 113A-60 Local The permittee has adopted an ordinance or other regulatory mechanism to enforce Choose erosion and sedimentation the erosion and sedimentation control program. an item. control programs (a) If yes, the ordinance meets or exceeds the minimum requirements of the Choose SPCA. an item. If yes, the ordinance applies throughout the corporate limits of the permittee. Choose [Permit Part I.D] an item. Comments (Provide regulatory mechanism reference or Supporting Documentation number) § 113A-60 Local erosion and The permittee collects a fee paid by each person who submits an erosion and Choose sedimentation sedimentation control plan. an item. control programs (d) Audit Date(s): 10/21/2022 Page 16 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Construction Site Runoff Controls Comments (indicate the fee amount, if applicable) § 113A-60 Local Has any person initiated a land -disturbing activity (within the permittee's Choose erosion and jurisdiction) for which an erosion and sedimentation control plan is required in the --- sedimentation absence of an approved plan? an item. control programs (e) If yes, the permittee has notified the North Carolina Sedimentation Control Choose Commission of all such cases. an item. Has the permittee determined that a person engaged in a land -disturbing activity Choose has failed to comply with an approved erosion and sedimentation control plan? an item. If yes, has the permittee referred any such matters to the North Carolina Choose Sedimentation Control Commission for inspection and enforcement? an item. Comments § 113A-61 Local The permittee reviews each erosion and sedimentation control plan submitted to Choose approval of erosion them and notifies the person submitting the plan that it has been approved, --- and sedimentation approved with modification, or disapproved within 30 days of receipt. an item. control plans The permittee only approves an erosion and sedimentation control plan upon Choose determining that it complies with all applicable State and local regulations. an item. The permittee has disapproved of an erosion and sedimentation control plan in Choose order to protect riparian buffers along surface waters. an item. If yes, the permittee notified the Director of the Division of Energy, Choose Mineral, and Land Resources within 10 days of the disapproval. an item. Comments § 113A-61.1 Inspection of land- The certificate of approval of each erosion and sedimentation control plan Choose disturbing activity; approved by the permittee includes a notice of the right to inspect. an item. notice of violation (a) The permittee provides for inspection of land -disturbing activities to ensure Choose compliance with the SPCA and to determine whether the measures required in an --- erosion and sedimentation control plan are effective. an item. Comments Audit Date(s): 10/21/2022 Page 17 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Construction Site Runoff Controls § 113A-61.1 When the permittee determines that a person engaged in land -disturbing activity Choose Inspection of land- has failed to comply with the SPCA, the Permittee immediately issues a notice of --- disturbing activity; violation upon that person. an item. notice of violation Each notice of violation issued by the permittee specifies the date by which the Choose (c) person must comply. an item. Each notice of violation issued by the permittee informs the person of the actions Choose that need to be taken to comply. an item. Comments § 113A-64 Penalties Does the permittee issue civil penalties as part of the erosion and sedimentation Choose program? an item. Comments (indicate when/why a civil penalty is issued, and the amount, if applicable) Audit Date(s): 10/21/2022 Page 18 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 I Post -Construction Site Runoff Controls I Staff Interviewed: I Mary Roderick, Regional Planner LOSRC, Stormwater Program Support (Name, Title, Role) Audit Date(s): 10/21/2022 Page 19 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Post -Construction Site Runoff Controls Implementation (check all that apply): ❑X 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 ❑X 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-11) — 15A NCAC 213.0214 ❑ Water Supply Watershed III (WS-III) —15A NCAC 213.0215 ❑ Water Supply Watershed IV (WS-IV) —15A NCAC 213.0216 ❑X Freshwater High Quality Waters (HOW) —15A NCAC 2H .1006 ❑ Freshwater Outstanding Resource Waters (ORW) —15A NCAC 2H .1007 ❑ Neuse River Basin Nutrient Sensitive (NSW) Management Strategy-15A NCAC 2B .0235 ❑ Tar -Pamlico River Basin Nutrient Sensitive (NSW) Management Strategy —15A NCAC 2B .0258 ❑ Randleman Lake Water Supply Watershed Nutrient Management Strategy — 15A NCAC 2B .0251 ❑X 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 ❑X 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 MS4 permitted area, then complete the Permit Citation section below for the permitted area(s) not covered under the S.L. 2006-246 deemed -compliant program. Session Law 2006- supporting 246 Program Requirement Status Doc No. Audit Date(s): 10/21/2022 Page 20 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Post -Construction Site Runoff Controls Deemed -Compliant The permittee implements deemed -compliant Program requirements in Program(s) accordance with the applicable 15A NCAC rules. Yes --- The permittee implements deemed -compliant Program requirements throughout the entire MS4 area (If not also complete the Permit Citation section below.) Yes --- The permittee applies deemed -compliant Program requirements to all federal, state and local government projects within the permitted MS4 area who do not Yes --- have their own NPDES stormwater permit. The permittee included deemed -compliant Program reporting in their MS4 Annual Reports. Yes The permittee included deemed -compliant Program implementation in their Stormwater Management Plan. Yes --- 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 --- Management Program. If yes, the ordinance applies throughout the corporate limits of the permittee. Yes The permittee has the authority to review designs and proposals for new development and redevelopment to determine whether adequate stormwater Yes --- 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 --- 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 --- 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) II.F.2.b Stormwater Control The permittee utilizes strategies which include SCMs appropriate for the MS4. Yes --- Measures (SCMs) SCMs comply with 15A NCAC 02H .1000. Yes --- Audit Date(s): 10/21/2022 Page 21 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 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 --- development or sale). If yes, the site plan reviews addressed how the project applicant meets the performance standards. Yes --- If yes, the site plan reviews addressed how the project will ensure long-term maintenance. Yes --- Comments On sites over an acre, the town also consults the Buncombe County Stormwater Administrator for review. Sites over 10,OOOsf require plans to be certified by a qualified registered NC professional. An O&M plan must be submitted before a CO is issued and is recorded on the deed. 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 --- 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 --- requirements. Comments 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 --- and Protective consistent with approved plans. Covenants Comments II.F.2.f The permittee implemented or required an operation and maintenance plan for Mechanism to the long-term operation of the SCMs required by the program. Yes --- Require Long-term Operation and The operation and maintenance plan required the owner of each SCM to perform Maintenance and maintain a record of annual inspections of each SCM. Yes -- Annual inspection of permitted structural SCMs are required to be performed by a qualified professional. Yes --- Comments Audit Date(s): 10/21/2022 Page 22 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Post -Construction Site Runoff Controls II.F.2.g The permittee required and documented inspections of each project site covered Inspections of under performance standards, at least one time during the permit term. Yes -- Structural 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 Yes --- completion. The permittee developed and implemented a written inspection program for SCMs installed pursuant to the post -construction program. Yes --- The permittee documented and maintained records of inspections. Yes --- Choose an item. 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 --- 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 Choose _ an item. Choose an item. Comments II.F.3.b The permittee fully complies with post construction program requirements on its New Development own publicly funded construction projects. Yes -- Comments Audit Date(s): 10/21/2022 Page 23 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Post -Construction Site Runoff Controls II.F.3.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 Choose meet local program requirements. an item. If yes, does the permittee also still incorporate the stormwater controls Choose 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 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 treat and control stormwater runoff from all surfaces draining to the SCM including Yes -- streets, driveways, and other impervious surfaces. Comments Audit Date(s): 10/21/2022 Page 24 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Pollution Prevention and Good Housekeeping for Municipal Operations Staff Interviewed: (Name, Title, Role) Permit Citation Program Requirement Status Supporting Doc No. II.G.2.a The permittee maintained a current inventory of facilities and operations owned Choose Facility Inventory and operated by the permittee with the potential for generating polluted stormwater runoff. an item. Comments (Note number of facilities, typical inventory data and any facilities that are not inventoried that should be) II.G.2.b The permittee maintained and implemented an O&M program for municipally Choose Operation and owned and operated facilities with the potential for generating polluted --- Maintenance (O&M) stormwater runoff. an item. for Facilities Choose If yes, the O&M program specifies the frequency of inspections. an item. If yes, the O&M program specifies the frequency of routine maintenance Choose requirements. an item. If yes, the permittee evaluated the O&M program annually and updated it as Choose necessary. an item. Comments II.G.2.c Choose Spill Response The permittee had written spill response procedures for municipal operations. --- an item. Procedures Comments II.G.2.d Streets, The permittee evaluated existing and new BMPs that reduce polluted stormwater Choose Roads, and Public runoff from municipally -owned streets, roads, and public parking lots within its --- an item. corporate limits annually. Audit Date(s): 10/21/2022 Page 25 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Pollution Prevention and Good Housekeeping for Municipal Operations Parking Lots If yes, the permittee evaluated the effectiveness of existing and new BMPs —noose Maintenance --- based on cost and the estimated quantity of pollutants removed. an item. Comments II.G.2.f O&M for Catch The permittee maintained and implemented an O&M program for the stormwater Choose sewer system including catch basins and conveyance systems that it owns and - Basins and an item. Conveyance Systems maintains. Comments (Briefly describe O&M program) II.G.2.e The permittee maintained a current inventory of municipally -owned or operated Choose Structural structural stormwater controls installed for compliance with the permittee's post- --- an item. Stormwater Controls construction ordinance. Comments (Describe inventory information and number of controls in inventory) II.G.2.h The permittee maintained and implemented an 0&M program for municipally- Choose O&M for Structural owned or maintained structural stormwater controls installed for compliance with --- Stormwater Controls the permittee's post -construction ordinance. If yes, then: an item. The 0&M program specified the frequency of inspections and routine Choose maintenance requirements. an item. The permittee documented inspections of all municipally -owned or maintained Choose structural stormwater controls. an item. The permittee inspected all municipally -owned or maintained structural Choose stormwater controls in accordance with the schedule developed by permittee. an item. The permittee maintained all municipally -owned or maintained structural Choose stormwater controls in accordance with the schedule developed by permittee. an item. The permittee documented maintenance of all municipally -owned or Choose maintained structural stormwater controls. an item. Comments II.G.2.i The permittee ensured municipal employees are properly trained in pesticide, Choose herbicide and fertilizer application management. an item. Audit Date(s): 10/21/2022 Page 26 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Pollution Prevention and Good Housekeeping for Municipal Operations Pesticide, Herbicide The permittee ensured contractors are properly trained in pesticide, herbicide and Choose and Fertilizer fertilizer application management. an item. Application Management The permittee ensured all permits, certifications, and other measures for Choose applicators are followed. an item. Comments II.G.2.j The permittee implemented an employee training program for employees involved Choose Staff Training in implementing pollution prevention and good housekeeping practices. an item. Comments II.G.2.k The permittee described and implemented measures that prevent or minimize Choose Vehicle and contamination of stormwater runoff from all areas used for vehicle and equipment Equipment Cleaning cleaning. an item. Comments Audit Date(s): 10/21/2022 Page 27 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Total Maximum Daily Loads (TMDLs) Staff Interviewed: Mary Roderick, Regional Planner LOSRC, Stormwater Program Support (Name, Title, Role) Program Status: ❑X The permittee is not subject to an approved TMDL (skip the rest of this section). ❑ The permittee is subject to an approved TMDL for: name of parameter(s) and date(s) approved There ❑ is ❑ is not a Waste Load Allocation (WLA) in the approved TMDL (If there is a WLA, then complete items H.H.1-5 below. If there is not a WLA, skip to item H.H.6 below) Permit Citation Program Requirement Status Supporting Doc No. II.H.3 TMDLs Within 12 months of final TMDL approval, the permittee's annual reports included Choose a description of existing programs, controls, partnerships, projects and strategies to an item. address impaired waters. Within 12 months of final TMDL approval, the permittee's annual reports provided Choose a brief explanation as to how the programs, controls, partnerships, projects and - an item. strategies address impaired waters. Comments II.H.4 TMDLs Within 24 months of final TMDL approval, the permittee's annual reports included Choose an assessment of whether additional structural and/or non-structural BMPs are - necessary to address impaired waters. an item. Within 24 months of final TMDL approval, the permittee's annual reports included Choose a brief explanation as to how the programs, controls, partnerships, projects and strategies address impaired waters. an item. Comments II.H.S TMDLs Within 36 months of final TMDL approval, the permittee's annual reports included Choose a description of activities expected to occur and when activities are expected to --- an item. occur. Audit Date(s): 10/21/2022 Page 28 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Total Maximum Daily Loads (TMDLs) Comments II.H.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 Choose six minimum measures to enhance water quality recovery strategies in the an item. watershed(s) to which the TMDL applies. The permittee described strategies and tailored and/or expanded BMPs in their Choose Stormwater Management Plan and annual reports an item. Comments Audit Date(s): 10/21/2022 Page 29 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Site Visit Evaluation: Municipal Facility No. 1 Facility Name: Date and Time of Site Visit: Facility Address: Facility Type (Vehicle Maintenance, Landscaping, etc.): Name of MS4 inspector(s) evaluated: Most Recent MS4 Inspection (List date and name of inspector): Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit: Name Title Observations Facility Documentation/Training Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific? What type of stormwater training do facility employees receive? How often? Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping? Inspection Procedures Does the MS4 inspector's process include the use of a checklist or other standardized form? Does the MS4 inspector's process include taking photos? Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)? Audit Date(s): 10/21/2022 Page 30 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Site Visit Evaluation: Municipal Facility No. 1 Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge? Did the MS4 inspector miss any obvious areas of concern? If so, explain: Does the MS4 inspector's process include presenting the inspection findings to the facility contact? Inspection Results Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)? If compliance corrective actions were identified, what timeline for correction/follow-up was provided? Notes/Comments/Recommendations Audit Date(s): 10/21/2022 Page 31 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Site Visit Evaluation: Municipal Facility No. 2 Facility Name: Date and Time of Site Visit: Facility Address: Facility Type (Vehicle Maintenance, Landscaping, etc.): Name of MS4 inspector(s) evaluated: Most Recent MS4 Inspection (Date and Entity): Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit: Name Title Observations Facility Documentation/Training Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific? What type of stormwater training do facility employees receive? How often? Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping? Inspection Procedures Does the MS4 inspector's process include the use of a checklist or other standardized form? Does the MS4 inspector's process include taking photos? Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)? Audit Date(s): 10/21/2022 Page 32 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Site Visit Evaluation: Municipal Facility No. 2 Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge? Did the MS4 inspector miss any obvious areas of concern? If so, explain: Does the MS4 inspector's process include presenting the inspection findings to the facility contact? Inspection Results Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)? If compliance corrective actions were identified, what timeline for correction/follow-up was provided? Notes/Comments/Recommendations Audit Date(s): 10/21/2022 Page 33 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Site Visit Evaluation: MS4 Outfall No. 1 Outfall ID Number: Date and Time of Site Visit: Outfall Location: Outfall Description (Pipe Material/Diameter, Culvert, etc.): Receiving Water: Is Flow Present? If So, Describe (Color, Approximate Flow Rate, Sheen, Odor, Floatables/Debris, etc.): Most Recent Outfall Inspection/Screening (Date): Days Since Last Rainfall: Inches: Name of MS4 Inspector(s) evaluated: Observations Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations? Inspection Procedures Does the inspector's process include the use of a checklist or other standardized form? Does the inspector's process include taking photos? Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they? Audit Date(s): 10/21/2022 Page 34 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 I Site Visit Evaluation: MS4 Outfall No. 1 1 Inspection Results Did the outfall inspection result in any work orders or maintenance requests? If so, for what issue(s)? Will a follow-up outfall inspection be conducted? If so, for what reason? I Notes/Comments/Recommendations I Audit Date(s): 10/21/2022 Page 35 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Site Visit Evaluation: MS4 Outfall No. 2 Outfall ID Number: Date and Time of Site Visit: Outfall Location: Outfall Description (Pipe Material/Diameter, Culvert, etc.): Receiving Water: Is Flow Present? If So, Describe (Color, Approximate Flow Rate, Sheen, Odor, Floatables/Debris, etc.): Most Recent Outfall Inspection/Screening (Date): Days Since Last Rainfall: Inches: Name of MS4 Inspector(s): Observations Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations? Inspection Procedures Does the inspector's process include the use of a checklist or other standardized form? Obtain copy. Does the inspector's process include taking photos? Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they? Audit Date(s): 10/21/2022 Page 36 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 I Site Visit Evaluation: MS4 Outfall No. 2 1 Inspection Results Did the outfall inspection result in any work orders or maintenance requests? If so, for what issue(s)? Will a follow-up outfall inspection be conducted? If so, for what reason? Notes/Comments/Recommendations Audit Date(s): 10/21/2022 Page 37 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Site Visit Evaluation: Construction Site No. 1 Site/Project Name: Date and Time of Site Visit: Site/Project Address: Operator: Project Type (Commercial, Industrial, Residential, CIP, Roadway, etc.): NCG Permit ID Number: Disturbed Acreage: Recent Enforcement Actions (Include Date): Name of MS4 Inspector(s) evaluated: Name(s) and Title(s) of Site Representative(s) Present During the Site Visit: Name Title Observations Site Documentation/Training Does the site have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it site -specific? Does the site have approved erosion and sedimentation control plans onsite? Are they representative of current site conditions? What type of stormwater training do site employees receive? How often? Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Did the MS4 inspector appear knowledgeable about MS4 and NCG010000 requirements for construction sites? Did the MS4 inspector appear knowledgeable about erosion and sedimentation control/stormwater pollution prevention BMPs? Audit Date(s): 10/21/2022 Page 38 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Site Visit Evaluation: Construction Site No. 1 Inspection Procedures Does the MS4 inspector's process include the use of a checklist? Does the MS4 inspector's process include taking photos? Does the MS4 inspector's process include reviewing approved plans (erosion and sedimentation control and/or SWPPP)? Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge? Did the MS4 inspector miss any obvious violations? If so, explain: Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing? Does the MS4 inspector's process include providing construction stormwater educational materials to the site contact? 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 Audit Date(s): 10/21/2022 Page 39 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Site Visit Evaluation: Construction Site No. 2 Site/Project Name: Date and Time of Site Visit: Site/Project Address: Operator: Project Type (Commercial, Industrial, Residential, CIP, Roadway, etc.): NCG Permit ID Number: Disturbed Acreage: Recent Enforcement Actions (Include Date): Name of MS4 Inspector(s) evaluated: Name(s) and Title(s) of Site Representative(s) Present During the Site Visit: Name Title Observations Site Documentation/Training Does the site have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it site -specific? Does the site have approved erosion and sedimentation control plans onsite? Are they representative of current site conditions? What type of stormwater training do site employees receive? How often? Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Did the MS4 inspector appear knowledgeable about MS4 and NCGO10000 requirements for construction sites? Did the MS4 inspector appear knowledgeable about erosion and sedimentation control/stormwater pollution prevention BMPs? Audit Date(s): 10/21/2022 Page 40 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Site Visit Evaluation: Construction Site No. 2 Inspection Procedures Does the MS4 inspector's process include the use of a checklist? Obtain copy. Does the MS4 inspector's process include taking photos? Does the MS4 inspector's process include reviewing approved plans (erosion and sedimentation control and/or SWPPP)? Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge? Did the MS4 inspector miss any obvious violations? If so, explain: Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing? Does the MS4 inspector's process include providing construction stormwater educational materials to the site contact? 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 Audit Date(s): 10/21/2022 Page 41 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1 Site Name: Date and Time of Site Visit: Site Address: SCM Type: 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 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 MS4 inspector receive? How often? Did the MS4 inspector appear knowledgeable about MS4 requirements for post -construction site runoff controls? Did the MS4 inspector appear knowledgeable about post -construction BMPs (general purpose/function, components, 0&M requirements, etc.)? Inspection Procedures Does the MS4 inspector's process include the use of a checklist or other standardized form? What format? Does the MS4 inspector's process include taking photos? Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections? Audit Date(s): 10/21/2022 Page 42 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1 Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge? Did the MS4 inspector miss any obvious operation and maintenance deficiencies? If so, explain: Does the MS4 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? I Notes/Comments/Recommendations I Audit Date(s): 10/21/2022 Page 43 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 2 Site Name: Date and Time of Site Visit: Site Address: SCM Type: 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 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 MS4 inspector receive? How often? Did the MS4 inspector appear knowledgeable about MS4 requirements for post -construction site runoff controls? Did the MS4 inspector appear knowledgeable about post -construction BMPs (general purpose/function, components, 0&M requirements, etc.)? Inspection Procedures Does the MS4 inspector's process include the use of a checklist or other standardized form? What format? Does the MS4 inspector's process include taking photos? Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections? Audit Date(s): 10/21/2022 Page 44 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 2 Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge? Did the MS4 inspector miss any obvious operation and maintenance deficiencies? If so, explain: Does the MS4 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? I Notes/Comments/Recommendations I Audit Date(s): 10/21/2022 Page 45 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 APPENDIX A: SUPPORTING DOCUMENTS Audit Date(s): 10/21/2022 Page 46 of 47 MS4 Permit Audit Report Montreat, NC: NPDES Permit No. NCS000430 APPENDIX B: PHOTOGRAPH LOG Audit Date(s): 10/21/2022 Page 47 of 47