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HomeMy WebLinkAboutNCS000424_FLETCHER MS4 AUDIT REPORT_20200720MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) PROGRAM AUDIT REPORT NPDES PERMIT NO. NCS000424 Town of Fletcher, NORTH CAROLINA 300 Old Cane Creek Road Audit Date: July 16, 2020 Report Date: July 17, 2020 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) NCS000424 Fletcher MS4 Audit 20200116 TABLE OF CONTENTS AuditDetails..................................................................................................................................................1 PermitteeInformation..................................................................................................................................2 List of Supporting Documents.......................................................................................................................3 Program Implementation, Documentation & Assessment...........................................................................4 PublicEducation and Outreach.....................................................................................................................7 Public Involvement and Participation...........................................................................................................8 Illicit Discharge Detection and Elimination (IDDE)........................................................................................9 Pollution Prevention and Good Housekeeping for Municipal Operations..................................................11 Total Maximum Daily Loads(TMDLs)..........................................................................................................13 Site Visit Evaluation: Municipal Facility No. 1.............................................................................................14 Site Visit Evaluation: MS4 Outfall No. 1......................................................................................................16 Site Visit Evaluation: MS4 Outfall No. 2......................................................................................................17 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1............................................18 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. NCS000424 Fletcher MS4 Audit 20200716 II This page intentionally left blank NCS000424 Fletcher MS4 Audit 2020071b Audit Details Audit ID Number: Audit Date(s): NCS000424_Town of Fletcher MS4 Audit_20200716 July 16, 2020 Minimum Control Measures Evaluated: ® Program Implementation, Documentation & Assessment ® Public Education & Outreach M Public Involvement & Participation X Illicit Discharge Detection & Elimination ❑ Construction Site Runoff Controls— No delegated Sediment and Erosion Control Program ❑ Construction Site Runoff Controls — Delegated Sediment and Erosion Control Program ❑ Post -Construction Site Runoff Controls © Pollution Prevention and Good Housekeeping for Municipal Operations © Total Maximum Daily Loads (TMDLs) Field Site Visits: 0 Municipal Facilities. Number visited: 1 © MS4 Outfalls. Number visited: 2 ❑ Construction Sites. Number visited: Choose an item. 0 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 Specialist NCDEQ Audit Report Author- Date: Signature _� 7Z'7/ 7 Audit Report Author: Date Signature NCS000424_Town of Fletcher M54 Audit_20200716 Page 1 of 19 Permittee Information M54 Permittee Name: Town of Fletcher Permit Effective Date: February 20, 2017 Permit Expiration Date: February 19, 2020 Mailing Address: 300 Old Cane Creek Road Date of Last MS4 Inspection/Audit: 02/27/2014 Co-permittee(s), if applicable: Permit Owner of Record: William B. Moore, Mayor Primary MS4 Representatives Participating in Audit Name, Title organization Christine Brown, Engineering Technician McGill Natalie J. Berry, Project Engineer Henderson County Eric Rufa, Planning Director Town of Fletcher Jabbo Pressley, Public Works Director Town of Fletcher MS4 Receiving Waters Waterbody Classification Impairments Cane Creek C Fish Tissue Mercury (Nar, FC, NC), Benthos (Nar, AL, FW) Pinner Creek C;Tr Hoopers Crek C;Tr Kimsey Creek C Higgins Creek C Frady Lake C NCS000424_Town of Fletcher MS4 Audit_20200716 Page 2 of 19 List of Supporting Documents Item Number Document TitEe When Provided (Prior to/During/After) 1 SWMPA During 2 Agreement with Henderson County Prior to 3 Pesticide certification During 4 Staff training sign in sheet. During 5 Fletcher, NC Land Development Code Prior to NCS000424_Town of Fletcher MS4 Audit_20200716 Page 3 of 19 Program Implementation, Documentation & Assessment Staff Interviewed: Eric Rufa, Planning Director (Name, Title, Role) Christine Brown, Engineering Technician Natalie J. Berry, Project Engineer Permit Citation Program Requirement Status supporting Doc No. il.A.l 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 --- Responsibilities for all components of the Stormwater Plan are documented and position(s) assignments provided. No --- The permittee is current on payment of invoiced administering and compliance monitoring fees (see stormwater e-payments on DEMLR MS4 web page). Yes --- No Stormwater Management Plan has been maintained or implemented. II.A.2 Stormwater The permittee evaluated the performance and effectiveness of the program Plan components at least annually. Yes 1 Implementation and Evaluation If yes, the permittee used the results of the evaluation to modify the program components as necessary to accomplish the intent of the Stormwater Program. No --- Did the permitted MS4 discharges cause or contribute to non -attainment of an applicable water quality standard? No --- If yes, did the permittee expand or better tailor its BM Ps accordingly to address the non -attainment? No --- SWMPA has been submitted regularly, but no documented modifications to the SWMP. ILA-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. No --- A SWMP has not been maintained and implemented. 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 See identifying the ordinances, or other regulatory mechanisms, providing the legal Partial commen authority necessary to implement and enforce the requirements of the permit. is Ordinances and regulatory documents available at: Hendersoncountync.gov/waterresources/page/storm water-phase-ii-local-program Fletchernc.org NCS000424_Town of Fletcher M54 Audit_20200716 Page 4 of 19 Program Implementation, Documentation & Assessment II.A.3 & II.A.S Not Stormwater Plan require a modification to the Stormwater Plan? Did D>=MLR re q Applicable __ - Modifications If yes, did the permittee complete the modifications in accordance with the Not established deadline? Applicable _ No SWMP has been submitted or implemented. II.A.6 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? Partial 2 An agreement is in place with Henderson County but it does not reference the MCM or permit number specifically. 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 --- No written procedures have been maintained by the permittee. III. A The permittee maintained documentation of all program components including, but Program not limited to, inspections, maintenance activities, educational programs, No --- Documentation implementation of BMPs, enforcement actions etc., on file for a period of five years. The permittee has not maintained documentation of all program components. 111.13 The permittee submitted annual reports to the Department within twelve months Annual Report from the effective date of the permit (See Section 11l.B. for the annual reporting Yes 1 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 1 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 Reviewed Plan. 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 Reviewed Stormwater Plan. NCS000424_Town of Fletcher MS4 Audit_20200716 Page 5 of 19 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. SWMPA submitted annually. IV.B 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 SWMPA submitted annually. NC5000424_Town of Fletcher M54 Audit_20200716 Page 6 of 19 Public Education and Outreach Staff Interviewed: Eric Rufa, Planning Director (Name, Title, Role) Christine Brown, Engineering Technician Natalie J. Berry, Project Engineer Permit Citation Program Requirement Status Supporting Doc No. I I. B.2. a The permittee defined goals and objectives of the Local Public Education and Goals and Outreach Program based on community wide issues. No --- Objectives II.B.2.b The permittee maintained a description of the target pollutants and/or stressors and Target Pollutants likely sources. No --- 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 --- II.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. 11.B.2.e The permittee promoted and maintained an internet web site designed to convey the informational program's message. No --- Web Site II.B.2.f The permittee distributed stormwater educational material to appropriate target Public Education No --- Materials groups. II.B.2.g 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. The permittee has not maintained a Public education and outreach program. NCS000424_Town of Fletcher MS4 Audit_20200716 Page 7 of 19 Public Involvement and Participation Staff Interviewed: Eric Rufa, Planning Director (Name, Title, Role) Christine Brown, Engineering Technician Natalie Berry, Project Engineer Permit Citation Program Requirement Status Supporting Doc No. II.C.2.a Volunteer Community The permittee included and promoted volunteer opportunities designed to promote No Involvement ongoing citizen participation. Program The permittee does not promote volunteer opportunities to promote ongoing citizen participation. 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.C.2.c The permittee promoted and maintained a hotline/helpline for the purpose of public Hotline/Help Line involvement and participation. Na --- NCS000424_Town of Fletcher MS4 Audit_20200716 Page 8 of 19 Illicit Discharge Detection and Elimination (IDDE) Staff Interviewed: Eric Rufa, Planning Director (Name, Title, Christine Brown, Engineering Technician Role) labbo Pressley, Public Works Director Permit Citation Program Requirement Status SupportingDoc No. I I. 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.Z.b provides the legal authority to prohibit illicit connections and discharges to the M54. Yes 5 Legal Authorities If yes, the ordinance applies throughout the corporate limits of the permittee. [Permit Part I.D] Yes 5 Il.o.z.c The permittee maintained a current map showing major outfalls* and receiving Storm Sewer No --- System Map strea ms. A current map has not been maintained by the permittee. A map from 2007 is available. 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 No dry weather flow field observation program has been written or implemented. II.D.2.e The permittee maintained written procedures for conducting investigations of Investigation identified illicit discharges. No --- Procedures No written procedure has been maintained for IDDE. 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 No --- 2. The results of the investigation No --- 3. Any follow-up of the investigation No --- 4. The date the investigation was closed No --- No tracking mechanism has been implemented for IDDE. II.D.2.g Employee The permittee implemented and documented a training 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 specific IDDE training in implemented regularly by the permittee. NCS000424_Town of Fletcher MS4 Audit_20200716 Page 9 of 19 Illicit Discharge Detection and Elimination (IDDE) 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. Na --- The permittee informed the general public of hazards associated with illegal discharges and improper disposal of waste. Na --- II.d.2.i The permittee promoted, and facilitated a reporting mechanism for the See 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. No --- The permittee established and implemented response procedures for citizen requests/reports. Partial --- Responses to citizen requests documented in correspondence. II.D.2.1 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 NOV tracking mechanism has been maintained and implemented. NCS000424_Town of Fletcher MS4Audit_20200716 Page 10 of 19 Pollution Prevention and Good Housekeeping for Municipal Operations Staff Interviewed: Eric Rufa, Planning Director (Name, Title, Role) Christine Brown, Engineering Technician Jabbo Pressley, Public Works Director Permit Citation Program Requirement Status Supporting Doc No. II.6.2.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. There has no inventory maintained of municipal facilities. 11.6.2.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 0&M program specifies the frequency of inspections. No --- If yes, the O&M program specifies the frequency of routine maintenance No --- requirements. If yes, the permittee evaluated the O&M program annually and updated it as Na --- necessary. No O&M Program has been maintained for municipal facilities. II.G.2.c Spill Response The permittee had written spill response procedures for municipal operations. No - Procedures The permittee has recently created a spill response and reporting plan to be implemented moving forward. 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 The permittee maintained and implemented an O&M program for the stormwater O&M for Catch sewer system including catch basins and conveyance systems that it owns and No --- Basins and maintains. Conveyance Systems No O&M plan has been maintained for the stormwater system. Il.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- No --- Stormwater Controls construction ordinance. An inventory of municipally owned SCMs. NCS000424 Town of Fletcher MS4 Audit 20200716 Page 11 of 19 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 O&M program specified the frequency of inspections and routine maintenance requirements. No --- The permittee documented inspections of all municipally -owned or maintained structural stormwater controls. No --- The permittee inspected all municipally -owned or maintained structural stormwater controls in accordance with the schedule developed by permittee. No --- The permittee maintained all municipally -owned or maintained structural stormwater controls in accordance with the schedule developed by permittee. No --- The permittee documented maintenance of all municipally -owned or maintained structural stormwater controls. Na --- No written program has been maintained far municipally owned Structureal Control Measures. II.G.2.f The permittee ensured municipal employees are properly trained in pesticide, Pesticide, herbicide herbicide and fertilizer application management. Yes 3 and Fertilizer Application The permittee ensured contractors are properly trained in pesticide, herbicide and Management fertilizer application management. No ___ The permittee ensured all permits, certifications, and other measures for Not applicators are followed. Applicable Permittee has Pesticide certifications for Public Works Director. II.G.2.g The permittee implemented an employee training program for employees involved Staff Training in implementing pollution prevention and good housekeeping practices. Yes 4 Staff training last implemented March 9, 2020. 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 No --- Equipment Cleaning cleaning. No documentation available for implemented measures. NCS000424_Town of Fletcher M54Audit_20200716 Page 12 of 19 Total Maximum Daily Loads (TMDLs) Staff Interviewed: Eric Rufa, Planning Director (Name, Title, Role) Christine Brown, Engineering Technician Natalie Berry, Project Engineer 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: Fish Tissue Mercury (Nar, FC, NC) 2008, Benthos (Nar, AL, FW) 2008. 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.N.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 a description of existing programs, controls, partnerships, projects and strategies to No 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 No --- strategies address impaired waters. Town staff did not address any of the impairments of Cane Creek, II.H.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 No --- necessary to address impaired waters. 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 No --- strategies address impaired waters. No TMDL considerations have been included in the annual reports. 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 No --- occur. No TMDL considerations have been included in the annual reports. 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 six minimum measures to enhance water quality recovery strategies in the No --- watershed(s) to which the TMDL applies. The permittee described strategies and tailored and/or expanded BMPs in their Stormwater Management Plan and annual reports No --- No TMDL considerations have been included in the annual reports. NCS000424_Town of Fletcher MS4 Audit_20200716 Page 13 of 19 Site Visit Evaluation: Municipal Facility No. 1 Facility Name: Public Works Facility Date and Time of Site Visit: July 16, 2020. 2:00pm Facility Address: 25 Howard Gap Road Name of MS4 inspector(s) evaluated: Eric Rufa Facility Type (Vehicle Maintenance, Landscaping, etc.): Vehicle Maintenance Most Recent MS4 Inspection (List date and name of inspector): N/A Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit: Name Title Public Works Director Jabbo Pressley Observations Facility Documentation/Training Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific? No 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? Stormwater DVD. Periodically. No set schedule. Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? No 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? No Did the MS4 inspector miss any obvious areas of concern? If so, explain: No NCS000424_Town of Fletcher MS4 Audit_20200716 Page 14 of 19 Site Visit Evaluation: Municipal Facility No, 1 Does the MS4 inspector's process include presenting the inspection findings to the facility contact? No Inspection Results Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)? Yes. The valve for the secondary containment was not maintained in an off position. If compliance corrective actions were identified, what timeline for correction/follow-up was provided? Corrected during inspection. Notes/Comments/Recommendations The permittee had not designated any specific staff for the facility inspections. NCS000424_Town of Fletcher MS4 Audit_20200715 Page 15 of 19 Site Visit Evaluation: MS4 Outfall No. 1 Outfall ID Number: Date and Time of Site Visit: None 7/16/2020 3:00 p m Outfall Location: Outfall Description (Pipe Material/Diameter, Culvert, etc.): 85 Howard Gap Road -18 inch plastic pipe. Receiving Water: Is Flow Present? If So, Describe (Color, Approximate Flow Rate, Cane Creek Sheen, Odor, Floatables/Debris, etc.): No flow present. Most Recent Outfall Inspection/Screening (Date): None Days Since Last Rainfall: Inches: N/E Name of MS4 Inspector(s) evaluated: Eric Rufa Observations Inspector Training/Knowledge What type of stormwater training does the M54 inspector receive? How often? stormwater DVD. 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 NCS000424_Town of Fletcher MS4 AuditW20200716 Page 16 of 19 Site Visit Evaluation: MS4 Outfall No. 2 Outfall ID Number: Date and Time of Site Visit: None 7/16/2020 3:30pm Outfall Location: outfall Description (Pipe Material/Diameter, Culvert, etc.): 404 Glennsprings Drive Undetermined Receiving Water: Is Flow Present? If So, Describe (Color, Approximate Flow Rate, Unnamed tributary of Cane Creek Sheen, Odor, Floatables/Debris, etc.): No flow observed. Most Recent Outfall Inspection/Screening (Date): None Days Since Last Rainfall: Inches: N/E Name of MS4 Inspector's): Eric Rufa Observations Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Stormwater DVD. No regular schedule. 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? Obtain copy. 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)? Yes. Maintenance, repair, and cleaning at the outfall location was discussed during the audit. Will a follow-up outfall inspection be conducted? If so, for what reason? Yes. Part of the outfall monitoring for permit requirements. NCS000424_Town of Fletcher M54 Audit_20200716 Page 17 of 19 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1 Site Name: Date and Time of Site Visit: Town Hall dry detention pond 7/16/2020 Site Address: SCM Type: 300 Old Cane Creek Road Dry Detention Pond Most Recent MS4 Inspection (Include Date and Entity): None Name of M54 Inspector(s) evaluated: Most Recent M54 Enforcement Activity (Include Date): Eric Rufa None Name(s) and Title(s) of Site Representative(s) Present During the Site Visit: Name Title Planning Director Eric Rufa 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? No Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Stormwater DVD. No set schedule. Did the MS4 inspector appear knowledgeable about MS4 requirements for post -construction site runoff controls? No Did the M54 inspector appear knowledgeable about post -construction BMPs (general purpose/function, components, O&M requirements, etc.)? No Inspection Procedures Does the M54 inspector's process include the use of a checklist or other standardized form? What format? No Does the MS4 inspectors process include taking photos? No Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections? No Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge? No Did the MS4 inspector miss any obvious operation and maintenance deficiencies? If so, explain: No NCS000424_Town of Fletcher MS4 Audit_20200716 Page 18 of 19 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1 Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing? No Compliance/Enforcement What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in? None If compliance issues were identified, what timeline for correction/follow-up was provided? Not determined. NCS000424 Town of Fletcher MS4 Audit .20200716 Page 19 of 19