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Home My WebLink AboutNCS000290_DOD Camp Lejeune MS4 Audit Report_20201014 MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) NPDES PERMIT NO. NCS000290 UNITED STATES MARINE CORPS CAMP LEJEUNE & MARINE CORPS AIR STATION NEW RIVER (MCBCL) ONSLOW COUNTY Audit Date: SEPTEMBER 24 – 25, 2020 Report Date: October 14, 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 NCS000290_DOD Camp Lejeune MS4 Audit Report_20201014 i (This page intentionally left blank) NCS000290_DOD Camp Lejeune MS4 Audit Report_20201014 ii TABLE OF CONTENTS Audit Details .................................................................................................................................................. 1 Permittee Information .................................................................................................................................. 2 List of Supporting Documents ....................................................................................................................... 4 Program Implementation, Documentation & Assessment ........................................................................... 6 Illicit Discharge Detection and Elimination (IDDE) ...................................................................................... 10 Post-Construction Site Runoff Controls - USMP ......................................................................................... 13 Pollution Prevention and Good Housekeeping for Municipal Operations ................................................. 15 Oil Water Separators (OWS) ....................................................................................................................... 18 Industrial Activities ..................................................................................................................................... 19 Site Visit Evaluation: Facility No. 1 .............................................................................................................. 21 Site Visit Evaluation: Facility No. 2 .............................................................................................................. 23 Site Visit Evaluation: MS4 Outfall No. 1 ...................................................................................................... 25 Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1 ............................................ 27 Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 2 ............................................ 29 Appendix A: Supporting Documents (See Laserfiche Portal for Supporting Documents) 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. NCS000290_DOD Camp Lejeune MS4 Audit Report_20201014 iii This page intentionally left blank. NCS000290_DOD Camp Lejeune MS4 Audit Report_20201014 Page 1 of 31 Audit Details Audit ID Number: NCS000290_Camp Lejeune MS4 Audit_20200924 Audit Date(s): September 24 – 25, 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 ☒ Oil Water Separators ☒ Post-Construction Site Runoff Controls ☒ Pollution Prevention and Good Housekeeping for Municipal Operations ☒ Oil Water Separators ☒ Industrial Activities ☒ Monitoring Requirements ☐ Impaired Waters & Total Maximum Daily Loads (TMDLs) Field Site Visits: ☒ Municipal Facilities. Number visited: 2 ☒ MS4 Outfalls. Number visited: 1 ☐ Construction Sites. Number visited: Choose an item. ☒ Post-Construction Stormwater Runoff Controls. Number visited: 2 ☐ Other: ________________________________. Number visited: Choose an item. ☐ Other: ________________________________. Number visited: Choose an item. Inspector(s) Conducting Audit Name, Title Organization Jeanette Powell, MS4 Program Coordinator DEQ-DEMLR Connor Musial, WIRO DEQ-DEMLR Natalie Norberg, RRO DEQ-DEMLR Audit Report Author: Jeanette Powell, MS4 Program Coordinator Signature Date: 10/14/2020 NCS000290_DOD Camp Lejeune MS4 Audit Report_20201014 Page 2 of 31 Permittee Information MS4 Permittee Name: Camp Lejeune Permit Effective Date: April 1, 2016 Permit Expiration Date: March 31, 2021 Mailing Address: Director, EMD 12 Post Lane Camp Lejeune, NC 28547 Date of Last MS4 Inspection/Audit: March 4, 2015 Co-permittee(s), if applicable: N/A Permit Owner of Record: Robert A. Lowder, EMD Director Primary MS4 Representatives Participating in Audit Name, Title Organization Capt. Christopher Swift, Deputy Director MCB Camp Lejeune EMD Ken Humes, Jr., Head Environmental Compliance Branch, MCB Camp Lejeune Michael Taylor, Head Environmental Assessment Section, MCB Camp Lejeune Talia Prendergast, PW Civil Engineer Public Works Division , MCB Camp Lejeune Matthew Horne, PW Civil Engineer Public Works Division , MCB Camp Lejeune Elsa Boujie, Environmental Specialist EMD, MCB Camp Lejeune MS4 Receiving Waters: White Oak River Basin Waterbody Classification Impairments Bear Creek SB, NSW Beaverdam Creek SB, NSW Brinson Creek SC, NSW Cogdels Creek SC, NSW Courthouse Bay SA Edwards Creek SC, NSW Farnell Bay SC, NSW NCS000290_DOD Camp Lejeune MS4 Audit Report_20201014 Page 3 of 31 French’s Creek SC, NSW Mott Creek C, NSW Morgan Bay SC, NSW New River SC, HQW, NSW, SA Northeast Creek SC, HQW, NSW Scales Creek SC, HQW, NSW Southwest Creek C, NSW Stick Creek SC, HQW, NSW Stones Creek SA Strawhorn Creek SC, NSW Wallace Creek SB, NSW Wilson Bay SC, HQW, NSW NCS000290_DOD Camp Lejeune MS4 Audit Report_20201014 Page 4 of 31 List of Supporting Documents Item Number Document Title When Provided (Prior to/During/After) 1 Stormwater Management Plan, March 2003 (128 pages) Prior 2 Stormwater Pollution Prevention Plan, March 2013 (567 pages) Prior 3 Stormwater Outfall Monitoring Plan - Part I, June 2013 (175 pages) Prior 4 Stormwater Outfall Monitoring Plan - Part II, June 2013 (175 pages) Prior 5 2017, 2018, 2019 and 2020 Annual Reports Prior 6 2016 Final MS4 Permit Prior 7 Oil Pollution Abatement Facility Inventory During 8 Best Management Practice (BMP) Inspection Form During 9 Visual Observation Point (VOP) Inspection Form During 10 List of Base Orders & Air Station Orders After 11 Approved Monitoring Plan (May 5, 2013) Prior 12 DEQ Monitoring Plan Approval Letter (May 20, 2013) Prior 13 NCDEQ Invoice Payment Status Prior 14 CTEP – Conservation Training & Education Portal Demonstrated On-Site 15 MAXIMO – Online Work Order Management System Demonstrated On-Site 16 Enforcement Access Database Demonstrated On-Site 17 Environmental Management System Portal Demonstrated On-Site 18 Spill Reporting System Demonstrated On-Site 19 e-SWPPP System Demonstrated On-Site 20 MS4 GIS Mapping Demonstrated On-Site NCS000290_DOD Camp Lejeune MS4 Audit Report_20201014 Page 5 of 31 21 Desktop Turnover Binder Demonstrated On-Site 22 ODI – Official Document Inventory Demonstrated On-Site 23 SSO Form Demonstrated On-Site 24 ECE -Environmental Compliance Evaluation System Demonstrated On-Site 25 Audit Photo Log NCS000290_DOD Camp Lejeune MS4 Audit Report_20201014 Page 6 of 31 Program Implementation, Documentation & Assessment Staff Interviewed: (Name, Title, Role) Ken Humes, Jr., Head, Environmental Compliance Branch, MCB Camp Lejeune Michael Taylor, Head, Environmental Assessment Section, MCB Camp Lejeune Talia Prendergast, PW Civil Engineer, Public Works Division, MCB Camp Lejeune Matthew Horne, PW Civil Engineer, Public Works Division, MCB Camp Lejeune Permit Citation Program Requirement Status Supporting Doc No. II.A.1 Program Implementation The permittee developed and maintained a Stormwater Plan. Yes 1 The permittee developed and maintained the authority to implement all provisions of the Stormwater Plan. Yes 10 The permittee notified the Division of proposed major modifications to the Stormwater Plan and provided the reasons and justifications for those changes. Yes 11 The permittee maintained adequate funding and staffing to implement and manage the provisions of the Stormwater Plan. Yes --- The permittee is current on payment of invoiced administering and compliance monitoring fees (see stormwater e-payments on DEMLR MS4 web page). Yes 13 Comments: The permittee maintains a detailed Stormwater Management Plan. Authority to implement the plan is provided through Base Orders, which are available online and serve a similar function to municipal ordinances. The permittee submitted a program major modification to the Division on May 5, 2013 and received approval to implement the proposed Monitoring Plan on May 20, 2013. No other major modifications have been made. The program is well run and provides adequate funding for staffing and program administration. As of September 29, 2020, all payments are current for invoiced administering and compliance monitoring fees. III.1 Program Assessment Documentation The permittee maintains documentation of all program components that are being undertaken to implement the Stormwater Plan including, but not limited to, inspections, maintenance activities, educational programs, implementation of BMPs, enforcement actions, and other stormwater activities. Yes --- The permittee maintains documentation of all monitoring and sampling being performed for a period of three years. Yes --- Comments The permittee maintains all required documentation for a minimum of three years. See details in specific sections of this audit report. III.2 The permittee kept the Stormwater Plan up to date. Yes --- NCS000290_DOD Camp Lejeune MS4 Audit Report_20201014 Page 7 of 31 Program Implementation, Documentation & Assessment Keeping the Stormwater Plan Up to Date The permittee submitted comprehensive annual reports Yes 5 The permittee notified DEMLR of any updates to the Stormwater Plan. Not Applicable --- Comments The permittee reviews the stormwater plan and program during the annual reporting process. Comprehensive annual reports are submitted in a timely manner. Minor changes are incorporated, as necessary. Any major revisions would be submitted to the Division. There were no major updates to the Stormwater Plan during the current permit term. II.A.4 Availability of the Stormwater Plan The permittee kept an up-to-date version of its Stormwater Plan available to the Division and the public online. Partial --- The online materials included ordinances, or other regulatory mechanisms, or a list identifying the ordinances, or other regulatory mechanisms, providing the legal authority necessary to implement and enforce the requirements of the permit. Yes 10 Comments The Stormwater Plan is not currently available online, but the web page is currently being reconstructed to comply with DOD standards and numerous links are non-functional at this time. Base Orders that provide the legal authority to implement the program are available online. III.3 Stormwater Plan Modifications Did DEMLR require a modification to the Stormwater Plan? No --- If yes, did the permittee complete the modifications in accordance with the established deadline? Not Applicable --- Comments II.A.6 Sharing Responsibility Are any control measures implemented by an entity other than the permittee? Yes --- If yes, is there a written agreement in place? Yes --- Comments The Division implements construction site control program and post-construction control program components for the permittee in accordance with 15A NCAC 02H .1017 and Part II, and Sections E.1 and F.2 of the permit. DEMLR issues Erosion and Sediment Control (E&SC) permits as well as State Stormwater permits for individual projects. There are currently 48 E&SC permits and 473 active State Stormwater permits. III.2 Annual Program Assessment The permittee evaluated the performance and effectiveness of the program components at least annually. Yes 5 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. Yes 5 NCS000290_DOD Camp Lejeune MS4 Audit Report_20201014 Page 8 of 31 Program Implementation, Documentation & Assessment The permittee submitted a report of this evaluation to the Division on an annual basis. Yes 5 If yes, reporting included appropriate information to accurately describe the progress, status, and results of the Stormwater Plan Yes 5 Comments The permittee submitted timely annual reports as required, which included narrative reports for 2017 and 2018, and BIMS SWPMA reports for 2019 and 2020. III.3 Stormwater Plan Modifications Did DEMLR require a modification to the Stormwater Plan? No --- If yes, did the permittee complete the modifications in accordance with the established deadline? Not Applicable --- Comments: DEMLR did not request any modifications to the Stormwater Plan. III.4 Additional Information Did DEMLR request additional reporting information to assess the progress and results of the Stormwater Plan? No --- If yes, did the permittee provide the information in accordance with the established deadline? Not Applicable --- Comments: DEMLR did not request any additional reporting information to assess the progress and results of the Stormwater Plan. IV.1 Records Retention The permittee documented and maintained visual monitoring records at the facility. Yes 11, 19 The permittee documented and maintained analytical monitoring records at the facility. Yes 11, 19 The permittee documented and maintained the Stormwater Pollution Prevention Plan at the facility. Yes 19 The permittee retained records of all monitoring information, including all calibration and maintenance records and all original strip chart recordings for continuous monitoring instrumentation, and copies of all reports required by this Permit for a period of at least 3 years from the date of the sample, measurement, report or application. Yes 19 Comments: The permittee has a state certified lab which maintains all required documentation. The e-SWPPP system was demonstrated during the audit, which includes documentation of visual observation point inspections and qualitative analytical monitoring for grab sampling as provided in the approved Monitoring Plan. NCS000290_DOD Camp Lejeune MS4 Audit Report_20201014 Page 9 of 31 Program Implementation, Documentation & Assessment IV.4 Twenty-four Hour Reporting The permittee reported to DEMLR any noncompliance that may constitute an imminent threat to health or the environment. Yes 17 If yes, did the permittee provide the information orally within 24 hours? Yes 17 If yes, did the Director waive the written report when the oral report was received within 24 hours? Not Applicable --- Did the permittee provide a written report within 5 days? Yes 17 If yes, did the written report contain a description of the noncompliance, and its causes; the period of noncompliance, including exact dates and times, and if the noncompliance has not been corrected, the anticipated time compliance is expected to continue; and steps taken or planned to reduce, eliminate, and prevent reoccurrence of the noncompliance? Yes 17 Comments: The Environmental Management System Portal was demonstrated during the audit and includes documentation of appropriate notifications to the DEQ Wilmington Regional Office. Additional Comments: The program staff are very knowledgeable about the program, water quality issues, and the administrative tools used to implement, document and track program implementation. The program management protocols are standardized, well understood and efficient. In addition, staff maintain Desktop Turnover Notebooks that incorporate standard procedures and information for succession employees. NCS000290_DOD Camp Lejeune MS4 Audit Report_20201014 Page 10 of 31 Illicit Discharge Detection and Elimination (IDDE) Staff Interviewed: (Name, Title, Role) Ken Humes, Jr., Head, Environmental Compliance Branch, MCB Camp Lejeune Michael Taylor, Head, Environmental Assessment Section, MCB Camp Lejeune Talia Prendergast, PW Civil Engineer, Public Works Division, MCB Camp Lejeune Matthew Horne, PW Civil Engineer, Public Works Division, MCB Camp Lejeune Permit Citation Program Requirement Status Supporting Doc No. II.D.2.a Storm Sewer System Map The permittee maintained, assessed, and updated as necessary a map identifying major outfalls. Yes 20 The map components include major outfalls and receiving streams, and type of conveyance system (i.e., either closed pipe or open drainage). Yes 20 For closed pipe systems, the map identifies the pipe material, shape, and size. Yes 20 Comments The permittee maintains a GIS-based MS4 map that includes an asset inventory, major outfalls, drainage areas, receiving streams, flow direction, monitoring sites and buildings/facilities with hazardous materials. The MS4 mapping is updated as new assets are constructed and swales and open drainage are being incorporated. The GIS tool interfaces with the e-SWPPP to provide inspection data. *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.b Dry Weather Screening The permittee maintains a written field screening procedure for detecting and tracing the sources of illicit discharges and for removing the sources or reporting the sources to the State to be properly permitted. Partial 3,4,21 The permittee implemented a program for conducting regular dry weather flow field observations for outfalls associated with industrial activities. Yes 21 If yes, the permittee implemented the program in accordance with the written field screening procedure. Yes 21 Comments: The permittee utilizes a standard form, a standard process and maintains procedures in the Desktop Turnover Binder and approved Outfall Monitoring Plan. The procedures are adequate for experienced staff but could incorporate more detail. The permittee does not maintain a single comprehensive written field screening procedure document, which could be beneficial to the program and should incorporate common terminology from the permit. II.D.2.c Written Illicit Discharge Procedures The permittee maintained written procedures for conducting investigations into the source of all identified illicit discharges, including approaches to requiring such discharges to be eliminated. Yes 21 If yes, the written procedures were assessed annually and updated as necessary. Yes 21 NCS000290_DOD Camp Lejeune MS4 Audit Report_20201014 Page 11 of 31 Illicit Discharge Detection and Elimination (IDDE) Comments: The permittee maintains and updates the Desktop Turnover Binder annually. II.D.2.d Illicit Discharge Investigations The permittee tracked and documented all illicit discharge investigations. Yes 22 If yes, the date(s) the illicit discharge was observed; the results of the investigation; any follow-up of the investigation; and the date the investigation was closed were documented. Yes 22 Comments: The permittee tracks, documents and maintains documentation of all illicit discharge, spills, and release investigations. All investigations are tracked and documented through closure and are maintained in the Official Document Inventory (ODI). II.D.2.e Employee Training The permittee implemented a training program for appropriate personnel, who, as part of their normal job responsibilities, may come into contact with or otherwise observe an illicit discharge or illicit connection to the storm sewer system. Yes 14 If yes, the permittee documented the training program including identified appropriate personnel, the schedule for conducting the training and the proper procedures for reporting and responding to an illicit discharge or connection. Yes 14 The permittee provided follow-up training as needed to address changes in personnel, procedures, or techniques. Yes 14 Comments: Staff receive comprehensive 2-day EM101 training as part of the base-wide basic training. Training is tracked in the CTEP portal. II.D.2.f Public Education The permittee informed public employees of hazards associated with illegal discharges and improper disposal of waste. Yes --- The permittee informed businesses of hazards associated with illegal discharges and improper disposal of waste. Yes --- The permittee informed the general public of hazards associated with illegal discharges and improper disposal of waste. Yes --- Comments: Base-wide basic EM101 training includes hazards associated with illegal discharges and improper disposal of waste. Housing also provides a welcome package which includes written information. Each Unit has an assigned environmental compliance officer (ECO) who is certified annually. NCS000290_DOD Camp Lejeune MS4 Audit Report_20201014 Page 12 of 31 Illicit Discharge Detection and Elimination (IDDE) II.D.2.g Reporting Mechanism The permittee promoted, publicized, and facilitated a reporting mechanism for the public to report illicit discharges. Yes --- The permittee promoted, publicized, and facilitated a reporting mechanism for staff to report illicit discharges. Yes --- The permittee established and implemented response procedures for citizen requests/reports. Yes --- The permittee conducted reactive inspections in response to complaints. Yes --- The permittee conducted follow-up inspections as needed to ensure that corrective measures have been implemented by the responsible party to achieve and maintain compliance. Yes --- Comments: The permittee maintains a hotline, which is publicized online and in training. The Stormwater Program Administrator and 911 maintain 24/7 service for urgent issues. A standardized response tree and process is in place. II.D.2.h Sanitary Sewer Overflows The permittee implemented written procedures to identify and report sanitary sewer overflows and sewer leaks to the system operator. Yes 23 If yes, the permittee assessed annually, and updated as necessary the written procedures to identify and report sanitary sewer overflows and sewer leaks to the system operator. Yes 23 Comments: The permittee maintains a hotline, which is publicized online and in training. The Stormwater Program Administrator and 911 maintain 24/7 service for urgent issues. The permittee maintains a standard spill decision tree, process and utilizes the standard DEQ reporting form, which includes incident numbers and photographs. Additional Comments: The permittee maintains excellent inter-division knowledge, awareness, and communication in support of the IDDE program. Hotspots are proactively identified; temporary repairs are initiated in a timely manner and long-term remedies are designed and constructed as needed. NCS000290_DOD Camp Lejeune MS4 Audit Report_20201014 Page 13 of 31 Post-Construction Site Runoff Controls - USMP Staff Interviewed: (Name, Title, Role) Ken Humes, Jr., Head, Environmental Compliance Branch, MCB Camp Lejeune Michael Taylor, Head, Environmental Assessment Section, MCB Camp Lejeune Talia Prendergast, PW Civil Engineer, Public Works Division, MCB Camp Lejeune Matthew Horne, PW Civil Engineer, Public Works Division, MCB Camp Lejeune Implementation (check all that apply): ☒ The permittee implements some components of this minimum measure. ☒ The permittee relies upon another entity to implement some components of this minimum measure: NCDEQ ☒ 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-I) – 15A NCAC 2B .0212 ☐ Water Supply Watershed II (WS-II) – 15A NCAC 2B .0214 ☐ Water Supply Watershed III (WS-III) – 15A NCAC 2B .0215 ☐ Water Supply Watershed IV (WS-IV) – 15A NCAC 2B .0216 ☐ Freshwater High Quality Waters (HQW) – 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 ☒ Universal Stormwater Management Program – 15A NCAC 2H .1020 02H .1020(q) Program Requirement Status Supporting Doc No. USMP for Federal Facilities and DOD Installations The permittee implements deemed-compliant Program requirements in accordance with the applicable 15A NCAC rules [Ref. 15A NCAC 02H .1020 Universal Stormwater Management Program]. Yes - The permittee incorporated specific restrictions and conditions into base master plans or other appropriate instruments. If yes: Yes 10 The plan/instruments ensure that development activities will be maintained consistent with (NCDEQ) approved plans. Yes 10, 22 Comments: In accordance with 15A NCAC 02H .1017 and Part II, Section F.2 of the MS4 permit, the permittee relies on the Division’s Wilmington Regional Office for implementation of post-construction control program plan review and permitting. The permittee implements standardized stormwater requirements through Base and Air Station Orders. The RFP process incorporates post construction project specifications in the UFC. The permittee maintains a master plan for development through 2040. The permittee maintains operation and maintenance documents and permits in the ODI. NCS000290_DOD Camp Lejeune MS4 Audit Report_20201014 Page 14 of 31 Post-Construction Site Runoff Controls - USMP II.f.2.c. 15A NCAC 02B .0104(f) (f) Discharge from groundwater remediation projects addressing water quality problems shall be allowed if an engineering alternatives analysis submitted for approval in accordance with 15A NCAC 02H .0105(c) demonstrates that no practicable alternative exists to such a discharge. Not Applicable --- Comments There are no surface water discharge points for groundwater remediation. All CERCLA sites are air quality permitted. Additional Comments: The permittee performs and maintains inspections of permitted Stormwater Control Measures. Maintenance is managed through MAXIMO (Doc. No. 15) if noted deficiencies cannot be immediately remedied by staff. The permittee utilizes a standard inspection process and form (Doc. No. 8). Staff are well trained, knowledgeable, and aware of the water quality impacts that SCMs can have. NCS000290_DOD Camp Lejeune MS4 Audit Report_20201014 Page 15 of 31 Pollution Prevention and Good Housekeeping for Municipal Operations Staff Interviewed: (Name, Title, Role) Ken Humes, Jr., Head, Environmental Compliance Branch, MCB Camp Lejeune Michael Taylor, Head, Environmental Assessment Section, MCB Camp Lejeune Talia Prendergast, PW Civil Engineer, Public Works Division, MCB Camp Lejeune Matthew Horne, PW Civil Engineer, Public Works Division, MCB Camp Lejeune Permit Citation Program Requirement Status Supporting Doc No. II.G.2.a & b Facility Inventory The permittee developed an inventory of facilities and operations with the potential for generating polluted stormwater runoff. Yes 20 The permittee identified the stormwater outfalls corresponding to each of the facilities. Yes 20 The permittee identified the receiving waters to which each facility discharges. Yes 20 The permittee maintained and updated the inventory annually. Yes 20 Comments: The permittee maintains an inventory of high priority sites in the GIS system, which provides overlay capability with the MS4 mapping. New development is added upon acceptance. Triennial flyover-based updates are also incorporated. II.G.2.c Operation and Maintenance (O&M) for Facilities The permittee maintained and implemented an O&M program for facilities and operations with the potential for generating polluted stormwater runoff. Yes 10, 19, 22, 24 If yes, the O&M program specifies the frequency of inspections. Yes - If yes, the O&M program specifies the frequency of routine maintenance requirements. Yes - Comments: The permittee assigns each Unit a certified Environmental Compliance Officer who is the responsible party for routine inspections. The Environmental Compliance Evaluation system automatically escalates notifications for incomplete tasks. Site visits are required for follow up confirmation of findings. The permittee inspects high priority sites monthly, ASTs weekly and OWS daily. Inspections are maintained in the ODI. II.G.2.d Spill Response Procedures The permittee has written spill response procedures for facilities and operations with the potential for generating polluted stormwater runoff. Yes 10, 22 Comments: The permittee implements unit level contingency plans with standard documentation. NCS000290_DOD Camp Lejeune MS4 Audit Report_20201014 Page 16 of 31 Pollution Prevention and Good Housekeeping for Municipal Operations II.G.2.e Streets, Roads, and Public Parking Lot Maintenance The permittee implements BMPs selected to reduce polluted stormwater runoff from municipally owned streets, roads, and parking lots. Yes --- Comments: The permittee implements a comprehensive pavement management program which includes parking lot inspections, vehicle towing, on-call response for clean-up, and routine roadway and street sweeping utilizing vacuum sweepers. II.G.2.f O&M for Catch Basins and Conveyance Systems The permittee developed an O&M program for the stormwater sewer system. If yes, then: Yes 15 The O&M Program includes catch basins and conveyance systems. Yes --- The O&M Program includes route maps. Yes --- The O&M Program specifies the frequency of inspections. Yes --- The O&M Program specifies the routine maintenance requirements. Yes --- Comments: The permittee inspects 5% of the system annually. Maintenance is performed as needed by roads and grounds crews. Remedies for specific issues are enacted by Operations staff or referred to Design Branch staff. II.G.2.g Structural Stormwater Controls The permittee developed an inventory of structural stormwater control measures. If yes, then: Yes 20 The inventory identifies the stormwater outfalls corresponding to each structural stormwater control measure. Yes --- The inventory identifies the receiving waters to which each structural stormwater control measure discharges. Yes --- The inventory of structural stormwater control measures is maintained and updated regularly. Yes --- Comments: The permittee maintains a GIS-based inventory of SCMs which is linked to the approved/permitted plans and the As-built drawings. The GIS-based system allows for overlay of the MS4 mapping layer to identify drainage area, receiving stream, outfall, etc. The inventory is updated as SCMs are accepted. NCS000290_DOD Camp Lejeune MS4 Audit Report_20201014 Page 17 of 31 Pollution Prevention and Good Housekeeping for Municipal Operations II.G.2.h O&M for Structural Stormwater Controls The permittee maintained and implemented an O&M program for structural stormwater controls. Yes 8, 19, 20 The O&M program specified the frequency of inspections. Yes --- The O&M program specified the routine maintenance requirements. Yes --- The permittee inspected all structural stormwater controls in accordance with the schedule developed by permittee. Yes --- The permittee maintained all structural stormwater controls in accordance with the schedule developed by permittee. Yes --- The permittee documented inspections of all structural stormwater controls. Yes --- The permittee documented maintenance of all structural stormwater controls. Yes --- Comments: The permittee maintains a GIS-based inventory of permitted SCMs. Each device has a standard state O&M plan associated with it, which includes inspection frequency and routine maintenance requirements. The permittee utilizes a standard inspection form and long-term document management system. Minor repairs/maintenance are enacted immediately and documented as part of the inspection. Work orders are submitted for larger maintenance and repair tasks. II.G.2.i Staff Training The permittee implemented an employee training program for personnel involved in implementing pollution prevention and good housekeeping practices. Yes 14 Comments: The permittee implements base wide EM101 and EM102 training. Environmental Management Division staff also receive additional documented training. II.G.2.j Vehicle and Equipment Cleaning The permittee described and implemented measures that prevent or minimize contamination of stormwater runoff from all areas used for vehicle and equipment cleaning. Yes 14, 24 Comments: The permittee implements base wide EM101 and EM102 training. The permittee assigns each Unit a certified Environmental Compliance Officer who is the responsible party for routine inspections. The Environmental Compliance Evaluation system automatically escalates notifications for incomplete tasks. Site visits are required for follow up confirmation of findings. Additional Comments: The permittee implements a comprehensive and proactive pollution prevention program, which is evident by conditions on base. It is recommended that the permittee incorporate inspector signature into any paper inspection documents. The current federal standard is a “wet” original signature. NCS000290_DOD Camp Lejeune MS4 Audit Report_20201014 Page 18 of 31 Oil Water Separators (OWS) Staff Interviewed: (Name, Title, Role) Ken Humes, Jr., Head, Environmental Compliance Branch, MCB Camp Lejeune Michael Taylor, Head, Environmental Assessment Section, MCB Camp Lejeune Talia Prendergast, PW Civil Engineer, Public Works Division, MCB Camp Lejeune Matthew Horne, PW Civil Engineer, Public Works Division, MCB Camp Lejeune Permit Citation Program Requirement Status Supporting Doc No. II.I OWS Inventory The permittee developed an inventory of oil water separators that discharge to either the stormwater system, directly into the waters of the state, or have engineered diversionary catchment basins. If yes, the inventory includes: Yes 7, 20 The location of the oil water separator Yes --- The activities that occur in the oil water separator’s drainage area Yes --- The materials that are handled in the drainage area Yes --- The name of the water body to which it drains Yes --- The number of the outfall that the oil water separator discharges into Yes --- The drainage area draining into the oil water separator Yes --- The oil water separator’s design capacity Yes --- Comments: The permittee maintains a GIS-based inventory of 769 oil water separators including location, capacity, and efficiency. The OWS layer can be overlayed on the MS4 map and other GIS layers to provide activities, materials, drainage area, outfall, and other relevant information. Additional Comments: The permittee performs an inventory study every ten years to evaluate condition and efficiency of each OWS. Interim updates are performed to add new OWS. NCS000290_DOD Camp Lejeune MS4 Audit Report_20201014 Page 19 of 31 Industrial Activities Staff Interviewed: (Name, Title, Role) Ken Humes, Jr., Head, Environmental Compliance Branch, MCB Camp Lejeune Michael Taylor, Head, Environmental Assessment Section, MCB Camp Lejeune Talia Prendergast, PW Civil Engineer, Public Works Division, MCB Camp Lejeune Matthew Horne, PW Civil Engineer, Public Works Division, MCB Camp Lejeune Permit Citation Program Requirement Status Supporting Doc No. II.H.3 Base Wide SPPP In lieu of complying with the requirements of paragraph 2 of this section, the permittee proposed and submitted to the Division for approval a base wide Stormwater Pollution Prevention Plan (Plan) that effectively meets the requirements to develop, maintain and implement a Stormwater Pollution Prevention Plan (Plan) for each facility and/or area with an industrial activity covered by this permit Yes 2, 15, 16, 17, 18, 19, 20, 22, 23, 24 Comments: The permittee implements an approved Base Wide Stormwater Pollution Prevention Plan in lieu of complying with Part II, Section H.2 of the permit. The program is supported by an e-SWPPP, Environmental Management System portal and enforcement database, online work order management system, Environmental Compliance Evaluation System, GIS mapping and a spill reporting system and standardized documentation including an official document inventory, and SSO form. II.H.4 Base Wide Monitoring Plan In lieu of complying with the requirements of paragraph 2 of this section [II.H.2] , the permittee proposed and submitted to the Division for their approval a base wide Monitoring Plan that effectively meets the requirements to develop, maintain and implement a Monitoring Plan for each facility and/or area with an industrial activity covered by this permit. If yes: Yes 11, 12 The permittee used the monitoring results to modify the program components as necessary to accomplish the intent of the Stormwater Program. Yes --- The Base Wide Monitoring Plan includes a description of the location of each sample point, the activities which they drain, and the water bodies to which they drain. Yes 20 The permittee submitted results of the monitoring program to the Division according to the provisions of Part IV of this permit. Part IV includes: Yes --- Visual monitoring is documented, and records are maintained at the facility along with the Stormwater Pollution Prevention Plan. Yes 9, 20, 22 Copies of analytical monitoring results are maintained on-site. Yes 22 NCS000290_DOD Camp Lejeune MS4 Audit Report_20201014 Page 20 of 31 Industrial Activities Records of all monitoring information, including all calibration and maintenance records and all original strip chart recordings for continuous monitoring instrumentation, and copies of all reports required by this Permit are retained for a period of at least 3 years from the date of the sample, measurement, report or application. Yes --- Comments: The permittee implements an approved Base Wide Monitoring Plan in lieu of complying with Part II, Section H.2 of the permit. The monitoring plan is documented in the April 18, 2013 Technical Memorandum / 2013 Stormwater Outfall Monitoring Plan (SWOMP) Update and was approved by DEQ on May 20, 2013. Analytical monitoring is performed in accordance with the approved plan and included benchmarks. The permittee maintains an inventory of all monitoring locations and utilizes the information to incorporate appropriate changes to the plan. Additional Comments: The permittee maintains a vigorous visual monitoring program which is supported by analytical monitoring as warranted. The permittee also maintains a state certified lab, which includes appropriate documentation and analytical monitoring analyses to maintain certification. NCS000290_DOD Camp Lejeune MS4 Audit Report_20201014 Page 21 of 31 Site Visit Evaluation: Facility No. 1 Facility Name: Auto Hobby Shop Date and Time of Site Visit: 09/25/2020 at 10:30 AM Facility Address: Birch St. Building 1250, Camp Lejeune, NC Facility Type (Vehicle Maintenance, Landscaping, etc.): Vehicle Maintenance Name of MS4 inspector(s) evaluated: Elsa Boujie, Environmental Specialist, EMD Most Recent MS4 Inspection (List date and name of inspector): 03/11/2020 Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit: Name and Title Capt. Christopher Swift, Deputy Director, MCB Camp Lejeune EMD Michael Taylor, Head, Environmental Assessment Section, MCB Camp Lejeune Talia Prendergast, PW Civil Engineer, Public Works Division, MCB Camp Lejeune Matthew Horne, PW Civil Engineer, Public Works Division, MCB Camp Lejeune Observations Facility Documentation/Training Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility-specific? The facility operates under the base-wide e-SWPPP. Implementation of pollution prevention and good housekeeping measures was evident. What type of stormwater training do facility employees receive? How often? Facility staff receive the mandatory EM101 basic training in stormwater pollution prevention and awareness. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? The inspector receives mandatory EM101 basic training in stormwater pollution prevention and awareness and on the job training from their supervisor. Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? The inspector was very knowledgeable about the permit requirements, facility, performing inspections, and appropriate pollution prevention and good housekeeping measures. Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping? The inspector was very 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? The standard protocol includes use of a standard inspection form and database for tracking inspections. NCS000290_DOD Camp Lejeune MS4 Audit Report_20201014 Page 22 of 31 Site Visit Evaluation: Facility No. 1 Does the MS4 inspector’s process include taking photos? The inspector utilizes photographs when specific deficiencies are found. Does the MS4 inspector’s process include reviewing the facility’s SWPPP (or similar document)? The inspector reviewed the on-site binders and was familiar with the location of documentation and the general facility layout. Does the MS4 inspector’s process include walking the entire facility and inspecting all points of discharge? The inspector performed a comprehensive inspection that included the inside and outside of the facility. Did the MS4 inspector miss any obvious areas of concern? If so, explain: The inspector did not note the lack of drip pans for some vehicles stored outdoors. 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)? The facility was in good condition. It was recommended that drip pans be utilized for vehicles stored outdoors. If compliance corrective actions were identified, what timeline for correction/follow-up was provided? N/A Notes/Comments/Recommendations The inspector was very knowledgeable and performed a comprehensive, multi-media inspection of the facility. NCS000290_DOD Camp Lejeune MS4 Audit Report_20201014 Page 23 of 31 Site Visit Evaluation: Facility No. 2 Facility Name: MCAS Air Station GSE Production Control Date and Time of Site Visit: 9:15 AM on 09/25/2020 Facility Address: AS4146 White St. MCAS Camp Geiger Facility Type (Vehicle Maintenance, Landscaping, etc.): Vehicle maintenance/ storage for aircraft tugs (previously fuel testing) Name of MS4 inspector(s) evaluated: Elsa Boujie, Environmental Specialist, EMD Most Recent MS4 Inspection (Date and Entity): AST Inspection 6/19/2020 Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit: Name and Title Capt. Christopher Swift, Deputy Director, MCB Camp Lejeune EMD Michael Taylor, Head, Environmental Assessment Section, MCB Camp Lejeune Talia Prendergast, PW Civil Engineer, Public Works Division, MCB Camp Lejeune Matthew Horne, PW Civil Engineer, Public Works Division, MCB Camp Lejeune Observations Facility Documentation/Training Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility-specific? The facility operates under the base-wide e-SWPPP. Implementation of pollution prevention and good housekeeping measures was evident. What type of stormwater training do facility employees receive? How often? Facility staff receive the mandatory EM101 basic training in stormwater pollution prevention and awareness. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? The inspector receives mandatory EM101 basic training in stormwater pollution prevention and awareness and on the job training from their supervisor. Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? The inspector was very knowledgeable about the permit requirements, facility, performing inspections, and appropriate pollution prevention and good housekeeping measures. Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping? The inspector was very 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? The standard protocol includes use of a standard inspection form and database for tracking inspections. NCS000290_DOD Camp Lejeune MS4 Audit Report_20201014 Page 24 of 31 Site Visit Evaluation: Facility No. 2 Does the MS4 inspector’s process include taking photos? The inspector utilizes photographs when specific deficiencies are found. Does the MS4 inspector’s process include reviewing the facility’s SWPPP (or similar document)? The inspector reviewed the on-site binders and was familiar with the location of documentation and the general facility layout. Does the MS4 inspector’s process include walking the entire facility and inspecting all points of discharge? The inspector performed a comprehensive inspection that included the stormwater collection system and exposed activities. Did the MS4 inspector miss any obvious areas of concern? If so, explain: The inspector did not note a trickle of non-stormwater flow in the collection system and evidence of sedimentation and vegetation growth in drop inlets. 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 corrective actions were issued upon completion of the inspection. Collection system maintenance should be noted. If compliance corrective actions were identified, what timeline for correction/follow-up was provided? N/A Notes/Comments/Recommendations The inspector performed a comprehensive evaluation of the facility. It is recommended that non-stormwater flows be identified and readily noted to prevent being overlooked where an issue may be present. Where vegetation is established within drop inlets, the system should be maintained to provide free flowing collection and conveyance of stormwater during an event. See Photo P9250007. NCS000290_DOD Camp Lejeune MS4 Audit Report_20201014 Page 25 of 31 Site Visit Evaluation: MS4 Outfall No. 1 Outfall ID Number: OAS 005 Date and Time of Site Visit: 09/25/2020 at 9:42 AM Outfall Location: Old Air Station (OAS) Demarco St. near the Ammo Depot Outfall Description (Pipe Material/Diameter, Culvert, etc.): Grass Lined Swale Receiving Water: Southwest Creek Is Flow Present? If So, Describe (Color, Approximate Flow Rate, Sheen, Odor, Floatables/Debris, etc.): No dry weather flow was evident Most Recent Outfall Inspection/Screening (Date): 06/01/2020 Days Since Last Rainfall: Inches: Name of MS4 Inspector(s) evaluated: Michael Taylor, Head, Environmental Assessment Section Observations Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? The inspector receives the mandatory EM101 basic training in stormwater pollution prevention and awareness and is trained in stormwater control measure inspection and maintenance. Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations? The inspector had an excellent knowledge of illicit discharge indicators and investigations. Inspection Procedures Does the inspector’s process include the use of a checklist or other standardized form? Yes, a standard VOP form is utilized. Does the inspector’s process include taking photos? Photos are utilized where specific issues are identified. Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they? The inspector did not miss any obvious indicators or maintenance issues. NCS000290_DOD Camp Lejeune MS4 Audit Report_20201014 Page 26 of 31 Site Visit Evaluation: MS4 Outfall No. 1 Inspection Results Did the outfall inspection result in any work orders or maintenance requests? If so, for what issue(s)? N/A Will a follow-up outfall inspection be conducted? If so, for what reason? N/A Notes/Comments/Recommendations Inspectors are well trained and very knowledgeable about the collection system, outfall and monitoring locations. Standard protocols are efficient and effective, and documentation is standardized as well. NCS000290_DOD Camp Lejeune MS4 Audit Report_20201014 Page 27 of 31 Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1 Site Name: SWP-007 Date and Time of Site Visit: 09/24/2020 at 3:00 PM Site Address: G Street & Julian Smith Road SCM Type: Wet Detention Facility Most Recent MS4 Inspection (Include Date and Entity): 05/06/2020 Name of MS4 Inspector(s) evaluated: Michael Taylor, Head, Environmental Assessment Section Most Recent MS4 Enforcement Activity (Include Date): Active Work Order for repair of erosion and vegetation removal Name(s) and Title(s) of Site Representative(s) Present During the Site Visit: Name and Title Capt. Christopher Swift, Deputy Director, MCB Camp Lejeune EMD Michael Taylor, Head, Environmental Assessment Section, MCB Camp Lejeune Talia Prendergast, PW Civil Engineer, Public Works Division, MCB Camp Lejeune Matthew Horne, PW Civil Engineer, Public Works Division, MCB Camp Lejeune Observations Site Documentation Does the site have an operation and maintenance plan? Yes. The SCM is subject to the standard state O&M plan for a wet detention basin. Does the site have records of annual inspections? Are they performed by a qualified individual? Yes. Inspection documents are maintained in a standardized records retention system and inspections are performed by qualified individuals. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? The inspector receives the mandatory EM101 basic training in stormwater pollution prevention and awareness and is trained in stormwater control measure inspection and maintenance annually. Did the MS4 inspector appear knowledgeable about MS4 requirements for post-construction site runoff controls? Yes. The inspector as knowledgeable about the purpose, design and function of the SCM. NCS000290_DOD Camp Lejeune MS4 Audit Report_20201014 Page 28 of 31 Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1 Did the MS4 inspector appear knowledgeable about post-construction BMPs (general purpose/function, components, O&M requirements, etc.)? Yes. The inspector was knowledgeable about SCMs, their purpose, function, design, and O&M requirements. Inspection Procedures Does the MS4 inspector’s process include the use of a checklist or other standardized form? What format? Yes. The inspector utilizes a standard inspection form and database. Does the MS4 inspector’s process include taking photos? Photos are utilized where specific issues are identified. Does the MS4 inspector’s process include reviewing the site’s operation and maintenance plan and records of annual inspections? Yes. The inspector was familiar with the location and content of the previous inspections and the O&M Plan. Does the MS4 inspector’s process include walking the entire site and inspecting all points of discharge? Yes. The inspector walked the site, reviewed the entire device and inspected all points of discharge. Did the MS4 inspector miss any obvious operation and maintenance deficiencies? If so, explain: The inspector noted damage to SWP007 inlet headwall where erosion had lifted the liner on a previous inspection and a project work order had already filed for repairs. Does the MS4 inspector’s process include presenting the inspection findings to the site contact in writing? Yes. The inspector utilizes a standardized system to document and report findings. Compliance/Enforcement What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in? The site is currently under Work Order for remedies of previously identified issues. If compliance issues were identified, what timeline for correction/follow-up was provided? Minor remedies are implemented immediately. Design remedies typically take 6 months to design. Notes/Comments/Recommendations The inspector performs a comprehensive and thorough evaluation of the system with a focus on water quality and device performance. NCS000290_DOD Camp Lejeune MS4 Audit Report_20201014 Page 29 of 31 Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 2 Site Name: SWP-210 Date and Time of Site Visit: 09/25/2020 at 8:10 AM Site Address: Cross Street Barracks HP 117 SCM Type: Wet Detention SCM Most Recent MS4 Inspection (Include Date and Entity): 06/29/2020 Name of MS4 Inspector(s) evaluated: Elsa Boujie, Environmental Specialist, EMD Most Recent MS4 Enforcement Activity (Include Date): N/A Name(s) and Title(s) of Site Representative(s) Present During the Site Visit: Name and Title Capt. Christopher Swift, Deputy Director, MCB Camp Lejeune EMD Michael Taylor, Head, Environmental Assessment Section, MCB Camp Lejeune Talia Prendergast, PW Civil Engineer, Public Works Division, MCB Camp Lejeune Matthew Horne, PW Civil Engineer, Public Works Division, MCB Camp Lejeune Observations Site Documentation Does the site have an operation and maintenance plan? Yes. The SCM is subject to the standard state O&M plan for a wet detention basin. Does the site have records of annual inspections? Are they performed by a qualified individual? Yes. Inspection documents are maintained in a standardized records retention system and inspections are performed by qualified individuals. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? The inspector receives the mandatory EM101 basic training in stormwater pollution prevention and awareness and is trained in stormwater control measure inspection and maintenance annually. Did the MS4 inspector appear knowledgeable about MS4 requirements for post-construction site runoff controls? Yes. The inspector as knowledgeable about the purpose, design and function of the SCM. NCS000290_DOD Camp Lejeune MS4 Audit Report_20201014 Page 30 of 31 Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 2 Did the MS4 inspector appear knowledgeable about post-construction BMPs (general purpose/function, components, O&M requirements, etc.)? Yes. The inspector was knowledgeable about SCMs, their purpose, function, design, and O&M requirements. Inspection Procedures Does the MS4 inspector’s process include the use of a checklist or other standardized form? What format? Yes. The inspector utilizes a standard inspection form and database. Does the MS4 inspector’s process include taking photos? Photos are utilized where specific issues are identified. Does the MS4 inspector’s process include reviewing the site’s operation and maintenance plan and records of annual inspections? Yes. The inspector was familiar with the location and content of the previous inspections and the O&M Plan. Does the MS4 inspector’s process include walking the entire site and inspecting all points of discharge? Yes. The inspector walked the site, reviewed the entire device and inspected all points of discharge. Did the MS4 inspector miss any obvious operation and maintenance deficiencies? If so, explain: The inspector did not miss any obvious operation and maintenance deficiencies, but should have noted the submerged smoker stand debris in the forebay and that noted erosion could possibly indicate a pipe failure in progress. Does the MS4 inspector’s process include presenting the inspection findings to the site contact in writing? Yes. The inspector utilizes a standardized system to document and report findings. Compliance/Enforcement What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in? N/A If compliance issues were identified, what timeline for correction/follow-up was provided? N/A Notes/Comments/Recommendations The inspector performs a comprehensive and thorough evaluation of the system with a focus on water quality and device performance. See Photos P9250001 – P9250006 NCS000290_DOD Camp Lejeune MS4 Audit Report_20201014 Page 31 of 31 APPENDIX A: SUPPORTING DOCUMENTS SUPPORTING DOCUMENTATION IS ON FILE IN THE NCDEQ PUBLIC LASERFICHE PORTAL