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HomeMy WebLinkAboutNCS000417_RANLO MS4 AUDIT REPORT_20200810MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) PROGRAM AUDIT REPORT Town of Ranlo, NORTH CAROLINA 1624 Spencer Mountain Road Gastonia, North Carolina 28054 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) NCS000417 Ranlo MS4 Audit 20200804 AuditDetails..................................................................................................................................................I PermitteeInformation..................................................................................................................................2 Listof 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 Site Visit Evaluation: Municipal Facility No. 1.............................................................................................13 Site Visit Evaluation: Municipal Facility No. 2.............................................................................................14 Site Visit Evaluation: MS4 Outfall No. 1......................................................................................................15 Site Visit Evaluation: Post -Construction Stormwater Control Measure No.1............................................16 AppendixA: Photos.................................................................................................................................................17 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. NCS000417 Ranlo MS4 Audit 20200804 ii This page intentionally left blank NCS000417 Ranlo MS4 Audit 20200804 Audit ID Number: Audit Date(s): NCSO00417_Ranio MS4 Audit_20200804 August 4, 2020 Minimum Control Measures Evaluated: ® Program Implementation, Documentation & Assessment ® Public Education & Outreach • Public Involvement & Participation • Illicit Discharge Detection & Elimination ❑ Construction Site Runoff Controls — No delegated Sediment and Erosion Control Program ❑ Construction Site Runoff Controls — Delegated Sediment and Erosion Control Program' ❑ Post -Construction Site Runoff Controls i• Pollution Prevention and Good Housekeeping for Municipal Operations ❑ Total Maximum Daily Loads (TMDLs) Field Site Visits: ® Municipal Facilities. Number visited: 2 M MS4 Outfalls. Number visited: 1 ❑ Construction Sites. Number visited: Choose an item. * Post -Construction Stormwater Runoff Controls. Number visited: 1 ❑ Other: Number visited: Choose an item. ❑ Other: Number visited: Choose an itern. Inspector(s) Conducting Audit Name.; Title Or�arrization Isaiah Reed, Environmental Specialist NCDEQ Lily Kay, Environmental Specialist NCDEQ Audit Report Author: Date: Signature Audit Report Author: Date Signature l [ ;2 o .03 - NCS000417_Ranlo MS4 Audit_20200804 Page 1 of 19 Permittee Information MS4 Permittee Name: Permit Effective Date: Permit Expiration Date: Town of Ranlo 2/20/2017 2/19/2022 Mailing Address: 1624 Spencer Mountain Road Date of Last MS4 Inspection/Audit: None Co-permittee(s), if applicable: None Permit Owner of Record: Charles L. Graham Primary MS4 Representatives Participating in Audit Name, Title Organization Joseph Alm, Stormwater Administrator Gaston County Natural Resources Jon Boerger, Natural Resources Conservationist Gaston County Natural Resources Johnny Denton, Consulting Engineer Diamond Engineering Jason Green, Public Works Director Town of Ranlo Jonathan Blanton, Town Manager Town of Ranlo Corey Correll, Parks and Rec Director Town of Ranlo NIS4 Receiving Waters Waterbodv Classification Impairments Burton Branch C None known of Housers Branch C None known of Long Creek C None known of Tributary of Housers Branch C None known of NCS000417_Ranlo MS4 Audit_20200804 Page 2 of 19 List of Supporting Documents Item Document Title When Provided Number (Prior to/During/After) 1 Interlocal Agreement with Gaston County During 2 2019 Annual Report Prior to 3 Outreach Flyer During 4 Regional Stormwater Partnership Information During 5 Outfalls Map During NCS000417_Ranlo MS4 Audit_20200804 Page 3 of 19 ' •gram Implementation,Documentation Staff Interviewed: Jonathan Blanton, Town Manager (Name, Title, Role) Joseph Alm, Stormwater Administrator Johnny Denton, Consulting Engineer Jon Boerger, Natural Resources Conservationist Jason Green, Public Works Director Permit Citation Program Requirement Status supporting Doc No. ILA.1 The permittee maintained adequate funding and staffing to implement and manage Staffing and the provisions of the Stormwater Plan and meet all requirements of the permit. No --- Funding The Stormwater Plan identifies a specific position(s) responsible for the overall coordination, implementation, and revision to the Plan. No --- Responsibilities for all components of the Stormwater Plan are documented and positionassignments 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 submitted or created. II.A.2 Stormwater The permittee evaluated the performance and effectiveness of the program Plan components at least annually. No --- Implementation and Evaluation If yes, the permittee used the results of the evaluation to modify the program Not components as necessary to accomplish the intent of the Stormwater Program. Applicable --- Did the permitted MS4 discharges cause or contribute to non -attainment of an Not applicable water quality standard? Reviewed -- If yes, did the permittee expand or better tailor its BMPs accordingly to address Not the non -attainment? Applicable -"- No impacts to water quality standards are known. II.A.3 Keeping the The permittee kept the Stormwater Plan up to date. No __- Stormwater Plan Up to Date The permittee notified DEMLR of any updates to the Stormwater Plan. No --- No Stormwater Management Plan has been maintained or created. II.A.4 Availability The permittee kept an up-to-date version of its Stormwater Plan available to the of the Stormwater Division and the public online. No --- Plan The online materials included ordinances, or other regulatory mechanisms, or a list identifying the ordinances, or other regulatory mechanisms, providing the legal No --- authority necessary to implement and enforce the requirements of the permit. Online materials do not include all information required by the permit. NCS000417_Ranlo MS4 Audit_20200804 Page 4 of 19 Program Implementation, Documentation & Assessment mwater Plan Did DEMLR require a modification to the Stormwater Plan? 7 Not -- r11.A.3&lI.A.5 ifications Applicable If yes, did the permittee complete the modifications in accordance with the _ Not established deadline? Applicable -" No SWMP has been submitted. II.A.6 Sharing Responsibility Are any control measures implemented by an entity other than the permittee? Yes 1 If yes, is there a written agreement in place? Yes 1 Gaston County is contracted to implement Post Construction and Construction Stormwater. The permittee maintained written procedures for implementing the six minimum Written 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. 111_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. Program Components have not been documented. III_B The permittee submitted annual reports to the Department within twelve months Annual Report from the effective date of the permit (See Section III.B. for the annual reporting No --- 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. Partial 2 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 of each major component of the Stormwater Plan for the past year and No --- 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 the proposed changes and how these changes will impact the Stormwater Na --- 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 No --- 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 Partial 2 Stormwater Plan. NCS000417_Ranlo MS4 Audit_20200804 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 No actions. 2019 Annual report includes some information but does not meet permit requirements. IV.B` Annual Reporting The Annual Reports document the following: 1. A summary of past year activities, including where applicable, specific No quantities achieved and summaries of enforcement actions. ""- :::]: 2. A description of the effectiveness of each program component. No --- 3. Planned activities and changes for the next reporting period, for each program component or activity. No 4. Fiscal analysis. Partial 2 2019 Annual Report includes some information but does not meet permit requirements. NCS000417_Ranlo MS4 Audit_20200804 Page 6 of 19 Public• and Outreach Staff Interviewed: Jonathan Blanton, Town Manager (Name, Title, Role) Joseph Alm, Stormwater Administrator Johnny Denton, Consulting Engineer Jon Boerger, Natural Resources Conservationist Jason Green, Public Work Director Permit Citation Program Requirement Status Supporting Doc No. II.B.2.a Goals and The permittee defined goals and objectives of the Local Public Education and Objectives Outreach Program based on community wide issues. No --" No defined goals for Outreach prior to audit. II.B.2.b The permittee maintained a description of the target pollutants and/or stressors and Target Pollutants likely sources. No --- No Outreach program has been maintained. 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 ___ No description of target audiences has been maintained. II.8.2.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. No description has been maintained. II.B.2.e Informational The permittee promoted and maintained an internet web site designed to convey the Web Site program's message. Partial Webs Townofranlo.org i1.B.2.f Public Education The permittee distributed stormwater educational material to appropriate target Materials groups. Partial 3 A brochure was sent out in 2019. II.B.2.>; The permittee promoted and maintained a stormwater hotline/helpline for the Hotline/Help Line purpose of public education and outreach. No No Hotline has been maintained for Public Education and Outreach. 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 Outreach efforts are limited to 2019 and includes a utility bill insert. NCS000417_Ranlo MS4 Audit_20200804 Page 7 of 19 Public Involvement and Participation Staff Interviewed: Jonathan Blanton, Town Manager (Name, Title, Role) ` Joseph Alm, Stormwater Administrator Johnny Denton, Consulting Engineer Jon Boerger, Natural Resources Conservationist Jason Green, Public Work Director Permit Citation Program Requirement Status supporting Doc No. II.C.2a Volunteer Community The permittee included and promoted volunteer opportunities designed to promote Involvement No --- ongoing citizen participation. Program II.C.2b 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. No --- No Public Involvement program has been maintained or implemented. NCS000417_Ranlo MS4 Audit_20200804 Page 8 of 19 Illicit Discharge Detection and Elimination (IDDE) Staff Interviewed: Jonathan Blanton, Town Manager (Name, Title, Joseph Alm, Stormwater Administrator Role) Johnny Denton, Consulting Engineer Jon Boerger, Natural Resources Conservationist Jason Green, Public Work Director Permit Citation Program Requirement Status Supporting Doc No. II.D.2.a IDDE Program The permittee maintained a written IDDE Program. No --- If yes, the written program includes provisions for program assessment and Not evaluation and integrating program. Applicable --- No Written IDDE Program has been maintained. The permittee maintained an IDDE ordinance or other regulatory mechanism(s) that II.D.2.b provides the legal authority to prohibit illicit connections and discharges to the M54. No --- Legal Authorities If yes, the ordinance applies throughout the corporate limits of the permittee. Not [Permit Part I.D] Applicable No Stormwater Ordinance has been adopted and implemented. II.D.2.c Storm Sewer The permittee maintained a current map showing major outfalls and receiving System Map streams. No --- A map is present but has not been updated and does not include all information required by the permit. II.D.2.d Dry Weather Flow The permittee maintained a program for conducting dry weather flow field Program observations in accordance with written procedures. No No Dry weather flow field observation program has been documented. II.D.2.e Investigation The permittee maintained written procedures for conducting investigations of Procedures identified illicit discharges. No --- No written program 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 Not --- Applicable 2. The results of the investigation Not --- Applicable 3. Any follow-up of the investigation Not Applicable --- 4. The date the investigation was closed Not --- Applicable No Illicit discharge reports documented. NCS000417_Ranlo MS4 Audit_20200804 Page 9 of 19 Illicit Discharge Detection and Elimination (IDDE) Employee TrainiThe permittee implemented and documented a training program for appropriate Training ng 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. The permittee has not provided training for municipal staff on IDDE. II.D2.h The permittee informed public employees of hazards associated with illegal Public Education discharges and improper disposal of waste. No --- The permittee informed businesses of hazards associated with illegal discharges and improper disposal of waste. No The permittee informed the general public of hazards associated with illegal discharges and improper disposal of waste. Partial 3 II.D.2.1 The permittee promoted, publicized, and facilitated a reporting mechanism for the Public Reporting public to report illicit discharges. No --- 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. No --- No written procedure for reporting IDDE has been maintained. II.Q.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 initiation of actions to reduce noncompliance. No --- No tracking mechanism has been created for issuances of NOVs. NCS000417_Ranlo MS4 Audit_20200804 Page 10 of 19 Pollution Prevention and Good Housekeeping for Municipal Operations Staff Interviewed: Jonathan Blanton, Town Manager (Name, Title, Role) Joseph Alm, Stormwater Administrator Johnny Denton, Consulting Engineer Jon Boerger, Natural Resources Conservationist Jason Green, Public Work Director Permit Citation Program Requirement Status supporting Doc No. II.G.2.a The permittee maintained a current inventory of facilities and operations owned Facility Inventory and operated by the permittee with the potential for generating polluted No - stormwater runoff. A current inventory has not been maintained. II.G.2.b The permittee maintained and implemented an O&M program for municipally Operation and owned and operated facilities with the potential for generating polluted No --- Maintenance (O&M) stormwater runoff. for Facilities If yes, the O&M program specifies the frequency of inspections. Not --- Applicable If yes, the O&M program specifies the frequency of routine maintenance Not requirements. Applicable If yes, the permittee evaluated the O&M program annually and updated it as Not necessary. Applicable --- No written O&M Plan has been created and documented. II.G.2.c Spill Response The permittee had written spill response procedures for municipal operations. No --- Procedures No Written Spill response procedures have been maintained. II.G.2.d Streets, The permittee evaluated existing and new BMPs that reduce polluted stormwater Roads, and Public runoff from municipally -owned streets, roads, and public parking lots within its No --- Parking Lots corporate limits annually. Maintenance If yes, the permittee evaluated the effectiveness of existing and new BMPs Not based on cost and the estimated quantity of pollutants removed. Applicable No annual evaluation has been documented. II.G.2.f O&M for Catch The permittee maintained and implemented an O&M program for the stormwater Basins and sewer system including catch basins and conveyance systems that it owns and No --- Conveyance Systems maintains. No O&M plan is available at the time of the inspection. II.G.2.e The permittee maintained a current inventory of municipally -owned or operated Structural structural stormwater controls installed for compliance with the permittee's post- Partial 5 Stormwater Controls construction ordinance. The town does not own any Structural Control Measures. NCS000417_Ranlo MS4 Audit_20200804 Page 11 of 19 Pollution Prevention and Good Housekeeping for Municipal Operations II.G.2.h 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 Not maintenance requirements. Applicable -�- The permittee documented inspections of all municipally -owned or maintained Not structural stormwater controls. Applicable-- The permittee inspected all municipally -owned or maintained structural Not stormwater controls in accordance with the schedule developed by permittee. Applicable The permittee maintained all municipally -owned or maintained structural Not stormwater controls in accordance with the schedule developed by permittee. Applicable --- The permittee documented maintenance of all municipally -owned or Not maintained structural stormwater controls. Applicable NoO&M Plan has been maintained for Municipally owned SCMs. . II.G.2.1 Pesticide, Herbicide The permittee ensured municipal employees are properly trained in pesticide, and Fertilizer herbicide and fertilizer application management. No 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 applicators are followed. No No training provided for pesticide and herbicide application. II.G.2.1 Staff Training The permittee implemented an employee trainin p pg program for employees involved in implementing pollution prevention and good housekeeping practices. No No training has been regularly implemented. Il.G.2.k 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 written plan including measures utilized to reduce or prevent SW. NCS000417_Ranlo MS4 Audit_20200804 Page 12 of 19 Site Visit Evaluation: Municipal Facility No. 1 Facility Name: Date and Time of Site Visit: Public Works August 4, 2020 Facility Address: Facility Type (Vehicle Maintenance, Landscaping, etc.): 120 Duff Street Public Works Name of MS4 inspector(s) evaluated: Most Recent MS4 Inspection (List date and name of inspector): Jason Green None Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit: Name Title Jason Green Public Works Director. 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? None 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 M54 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 Does the MS4 inspector's process include presenting the inspection findings to the facility contact? Yes Inspection Results Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)? No If compliance corrective actions were identified, what timeline for correction/follow-up was provided? N/A Notes/Comments/Recommendations NCS000417_Ranlo MS4 Audit_20200804 Page 13 of 19 Site Visit Evaluation: Municipal Facility No. 2 Facility Name: Date and Time of Site Visit: Composting Location August 4, 2020 Facility Address: Facility Type (Vehicle Maintenance, Landscaping, etc.): Duff Street Composting and staging yard Name of MS4 inspector(s) evaluated: Most Recent MS4 Inspection (Date and Entity): Jason Green None Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit: Name Title Jason Green Public Works Director 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? None 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: Yes. The storage of appliances and other material represented a possible source of polluted stormwater runoff. Does the MS4 inspector's process include presenting the inspection findings to the facility contact? Yes Inspection Results Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)? Yes. Relocation or covering of appliance dumpster. If compliance corrective actions were identified, what timeline for correction/follow-up was provided? Not specified. NCS000417_Ranlo MS4 Audit_20200804 Page 14 of 19 Site Visit Evaluation: MS4 Outfall No. 1 Outfall ID Number: Date and Time of Site Visit: None given August 4, 2020 Outfall Location: Outfall Description (Pipe Material/Diameter, Culvert, etc.): Joselynn Drive Concrete Receiving Water: Is Flow Present? If So, Describe (Color, Approximate Flow Rate, Housers Branch Sheen, Odor, Floatables/Debris, etc.): None Most Recent Outfall Inspection/Screening (Date): None Days Since Last Rainfall: Inches: Not evaluated N/A Name of MS4 Inspector(s) evaluated: Jason Green, Public Works Director Observations Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? None 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)? Yes. Removal of Silt fence. Will a follow-up outfall inspection be conducted? If so, for what reason? Yes. Routine. NCS000417_Ranlo MS4 Audit_20200804 Page 15 of 19 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1 Site Name: Date and Time of Site Visit: H&H Sand Filter August 4, 2020 Site Address: SCM Type: Boulder Court Sand Filter Most Recent MS4 Inspection (Include Date and Entity): July 30, 2020 Gaston County Name of MS4 Inspector(s) evaluated: Most Recent MS4 Enforcement Activity (Include Date): Joseph Alm, Stormwater Administrator Name(s) and Title(s) of Site Representative(s) Present During the Site Visit: Name Title None Observations Site Documentation Does the site have an operation and maintenance plan? Not Reviewed. Does the site have records of annual inspections? Are they performed by a qualified individual? Yes Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? Not Reviewed Did the MS4 inspector appear knowledgeable about MS4 requirements for post -construction site runoff controls? Yes Did the MS4 inspector appear knowledgeable about post -construction BMPs (general purpose/function, components, O&M requirements, etc.)? Yes Inspection Procedures Does the MS4 inspector's process include the use of a checklist or other standardized form? What format? Yes. Inspection form. Not filled out during Audit, but documented. Does the MS4 inspector's 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? Yes Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge? Yes Did the MS4 inspector miss any obvious operation and maintenance deficiencies? if so, explain: No Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing? Yes Compliance/Enforcement What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in? None If compliance issues were identified, what timeline for correction/follow-up was provided? N/A NCS000417_Ranlo MS4 Audit_20200804 Page 16 of 19 APPENDIX A: Photos Dumpster located at Composting facility. NCS000417_Ranlo MS4 Audit_20200804 Page 17 of 19 Storage of garbage trucks at composting facility. NCS000417_Ranlo MS4 Audit_20200804 Page 18 of 19 Storage of materials at composting facility. NCS000417_Ranlo MS4 Audit_20200804 Page 19 of 19