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HomeMy WebLinkAboutNCS000422_Black Mountain MS4 AUDIT REPORT_20200228ROY COOPER Covemor MICHAEL S. REGAN Secretary BRIAN WRENN Acting Director NORTH CAROLINA Environmental Quality February 28, 2020 CERTIFIED MAIL: 7019 0700 0000 8867 7286 RETURN RECEIPT REQUESTED Town of Black Mountain Attention: Don Collins, Mayor 160 Midland Avenue Black Mountain, North Carolina 28711 Subject: Municipal Separate Stormwater Sewer System Audit Report MS4 Permit: NCS000422 Buncombe County, North Carolina Dear Mr. Collins: Enclosed, please find a signed copy of the Audit Report for the subject municipality's MS4 audit conducted on February 12, 2020. The enclosed report will contain a summary of the items discussed during the audit. Should you have any questions concerning this report, please do not hesitate to contact me at (828) 296-4500 or by email at Isaiah.reed@ncdenr.gov. Sinc r Isaiah Ree , C Q, CEPSCI, MS4CECI Environmental Specialist Land Quality Section Enclosure: Audit Report (Town of Black Mountain) EC: Jeanette Powell, MS4 Program Coordinator Alaina Morman, Environmental Specialist Jessica Trotman, Planning Director D_EQ� North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources - Asheville Regional Office 1 2090 U.S. Highway 70 1 Swannanoa, North Carolina 28778 ",. a °'A�m.n+w+m� /'� 828,296.4500 MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) PROGRAM AUDIT REPORT NPDES PERMIT NO. NCS000422 Black Mountain, NORTH CAROLINA 160 Midland Avenue Black Mountain, North Carolina 28711 Audit Date: February 12, 2020 Report Date: February 26, 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) NCS000422 Black Mountain MS4 Audit 20200226 TABLE OF CONTENTS AuditDetails..................................................................................................................................................1 PermitteeInformation..................................................................................................................................2 Listof Supporting Documents.......................................................................................................................3 Program Implementation, Documentation & Assessment...........................................................................4 Public Education 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 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. NCS000422 Black Mountain MS4 Audit 20200226 ii This page intentionally left blank NCS000422 Black Mountain MS4 Audit 20200226 iii Audit Details Audit ID Number: Audit Date(s): NCS000422_Black Mountain MS4 Audit_20200226 February 12, 2020 Minimum Control Measures Evaluated: N Program Implementation, Documentation & Assessment N Public Education & Outreach N Public Involvement & Participation N 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 N Pollution Prevention and Good Housekeeping for Municipal Operations ❑ Total Maximum Daily Loads (TMDLs) Field Site Visits: N Municipal Facilities. Number visited: 2 N MS4Outfalls. Number visited: I ❑ Construction Sites. Number visited: Choose an item. ❑ Post -Construction Stormwater Runoff Controls. Number visited: Choose an item. ❑ Other: Number visited: Choose an item. ❑ Other: Number visited: Choose an item. Inspector(s) Conducting Audit Name. Title Organization Isaiah Reed, Environmental Specialist NCDEQ Audit Report Author: Date: Signatur 2 Audit Report Author: Date Signature NCS000422 Black Mountain MS4 Audit 20200212 Page 1 of 15 Permittee Information MS4 Permittee Name: Black Mountain Permit Effective Date: February 20, 2017 Permit Expiration Date: February 19, 2022 Mailing Address: 160 Midland Avenue. Black Mountain, NC 28711 Date of Last MS4 Inspection/Audit: N/A Co-permittee(s), if applicable: Permit Owner of Record: Albert Richardson Primary M54 Representatives Participating in Audit Name, Title Organization Jessica Trotman, Planning Director Town of Black Mountain MS4 Receiving Waters Waterbody Classification Impairments Swannanoa River (and UTs) C Tomohawk Branch (and UTs) B Briar Branch B Wolfpit Branch B Laurel Branch B;Tr Camp Branch (and UTs) C Lynch Creek C Britton Creek C Flat Creek (and UTs) C McCoy Cove Unable to locate data NCS000422 Black Mountain MS4 Audit 20200212 Page 2 of 15 List of Supporting Documents Item Number Document Title When Provided (Prior to/During/After) 1 Draft 0&M for municipal facilities Prior 2 Draft Stormwater Ordinance Prior 3 DraftSWMP Prior 4 Dry Weather Detection Program Prior 5 Hotline information Prior 6 IDDE Training information Prior 7 Inventory of Municipal Facilities Prior 8 Pesticide License Prior 9 Post -Construction SW Notification Prior 10 Report a Polluter and ESC insert. Prior 11 SCM Inspections Prior 12 SCM Map Prior 13 SOP for Building and Ground Maintenance Prior 14 SOP for Parking Lot Maintenance Prior 15 SOP for Salt Application Prior 16 SOP for Swimming Pool Prior 17 Spill Response Training Prior 18 Water Distribution Details and Standards Manual Prior 19 MCM Statements (TMDL, IDDE, PP&GH, PE&O, PCSRC and PI&P) Prior 20 Stormwater Ordinance After NCS000422_Black Mountain MS4 Audit_20200212 Page 3 of 15 Program Implementation, Documentation & Assessment Staff Interviewed: Jessica Trotman, Planning Director (Name, Title, Role) Permit Citation Program Requirement Status supporting Doc No. II.A.1 The permittee maintained adequate funding and staffing to implement and manage 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 --- The Toan of Black Mountain has recently created a Draft SWMP but has not been maintaining or operating under an approved SWMP. II.A.2 Stormwater The permittee evaluated the performance and effectiveness of the program See Plan Yes NCDECt Implementation components at least annually. Files 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 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 The permittee is not aware of any non -attainment of an applicable water quality standard. The permittee has submitted annual reports through the public BIMS portal. 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 --- The permittee has not maintained or operated under an approved SWMP. 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 Partial --- authority necessary to implement and enforce the requirements of the permit. The permittee has not maintained or operated under an approved SWMP. The permittee has maintained a website with stormwater information available. https://www.townofblackmountain.orgl2434/Stormwater-Management NCS000422_Black Mountain MS4 Audit_20200212 Page 4 of 15 Program Implementation, Documentation & Assessment II.A.3 & II.A.5 Stormwater Plan Did DEMLR require a modification to the Stormwater Plan? Not Applicable Modifications If yes, did the permittee complete the modifications in accordance with the Not established deadline? Applicable 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? No --- Buncombe County implements the Erosion and Sediment Control program through an approved local program. 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 --- The permittee has not maintained written procedures for the six minimum control measures. Written procedures have recently been created. Ill 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. All program components have not been fully documented by the permittee. 111.13 The permittee submitted annual reports to the Department within twelve months Annual Report from the effective date of the permit (See Section HLB. for the annual reporting Yes See DEQ Files Submittal period specific to this MS4). The permittee submitted subsequent annual reports every twelve months from the See DEQ scheduled date of the first annual report submittal. Yes Files 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. NCS000422_Black Mountain MS4 Audit_20200212 Page 5 of 15 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. Annual Reports submitted through the Public BIMS Portal. 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 Annual reports submitted through the Public Bims Portal. NC5000422 Black Mountain M54 Audit 20200212 Page 6 of 15 Public Education and Outreach Staff Interviewed: Jessica Trotman, Planning Director (Name, Title, Role) Permit Citation Program Requirement Status supporting Doc No. II.B.2.a The permittee defined goals and objectives of the Local Public Education and Goals and No --- Outreach Program based on community wide issues. Objectives No written Public Education and Outreach Program has been maintained. II.B.2.b The permittee maintained a description of the target pollutants and/or stressors and No --- Target Pollutants likely sources. No written Public Education and 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 --- Annual assessments have not been documented by the permittee. 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 inTani, al 10 Commercial Issues their education/outreach program. Erosion and Sediment Control issues were addressed in utility bill insert. 11.B.2.e The permittee promoted and maintained an internet web site designed to convey the Informational program's message. ves --- Web Site https://www. townofblackmountain.org/2434/Stormwater-Management II.B.2.f The permittee distributed stormwater educational material to appropriate target Public Education Partial 10 Materials groups. Outreach and educational material was distributed as utility bill inserts. II.B.2.z The permittee promoted and maintained a stormwater hotline/helpline for the Hotline/Help Line purpose of public education and outreach. Yes 5 I I.B.2.h Presenta Public Education The permittee's outreach program, including those elements implemented locally or tion and Outreach through a cooperative agreement, included a combination of approaches designed to Yes during Program reach the target audiences. the Audit. 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. Nc5000422 Black Mountain M54 Audit 20200212 Page 7 of 15 Public Involvement and Participation Staff Interviewed: Jessica Trotman, Planning Director (Name, Title, Role) Permit Citation Program Requirement Status Supporting Doc No.. Presents II.C.2.a Volunteer lion Community The permittee included and promoted volunteer opportunities designed to promote Yes During Involvement ongoing citizen participation. the Program Audit II.C.2.b Mechanism for The permittee provided and promoted a mechanism for public involvement that Yes --- Public provides for input on stormwater issues and the stormwater program. Involvement https://www.townofbiackmountain.orgl2434IStormwater-Management II.C.2.c The permittee promoted and maintained a hotline/helpline for the purpose of public Yes $ Hotline/Help Line involvement and participation. NCS000422_Black Mountain MS4 Audit_20200212 Page 8 of 15 Illicit Discharge Detection and Elimination (IDDE) Staff Interviewed: Jessica Trotman, Planning Director (Name, Title, Role) Permit Citation Program Requirement Status supporting Dot 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 No --- evaluation and integrating program. While a written IDDE program has now been created, a written program has not been maintained throughout the permit cycle. The permittee maintained an IDDE ordinance or other regulatory mechanism(s) that Yes 20 provides the legal authority to prohibit illicit connections and discharges to the MS4. II.D.2.b Legal Authorities If yes, the ordinance applies throughout the corporate limits of the permittee. [Permit Port I.D] Yes --- II.D.2.c The permittee maintained a current map showing major outfalls* and receiving Storm Sewer No --- System Map streams. The permittee has not maintained a current map of major outfalls. 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 A written program has recently been created. However, a written program has not been maintained or implemented throughout the life of the permit. II.D.2.e The permittee maintained written procedures for conducting investigations of Investigation identified illicit discharges. No --- Procedures While a written program has recently been written, a program has not been maintained and implemented throughout the permit term. 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 Not Investigations 1. The date(s) the illicit discharge was observed 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 IDDE cases were documented by the Permittee. NCS000422_Black Mountain MS4 Audit_20200212 Page 9 of 15 Illicit Discharge Detection and Elimination (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 Yes 6 contact with or otherwise observe an illicit discharge or illicit connection. II.D.2.h The permittee informed public employees of hazards associated with illegal Public Education discharges and improper disposal of waste. Partial The permittee informed businesses of hazards associated with illegal discharges and Partial --- improper disposal of waste. The permittee informed the general public of hazards associated with illegal Partial --- discharges and improper disposal of waste. These requirements were partially addressed at a community workshop, outlined in a presentation given during the audit. II.D.2.i The permittee promoted, publicized, and facilitated a reporting mechanism for the 10 Public Reporting public to report illicit discharges. Partial 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 No ... reciuests/reports. Contact hotline info was given out in utility bill inserts. II.D.2.i 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 NOVs were documented to track. However, a specific tracking system had not been created at the time of the audit. NCS000422 Black Mountain MS4 Audit 20200212 Page 10 of 15 Pollution Prevention and Good Housekeeping for Municipal Operations Staff Interviewed: Jessica Trotman, Planning Director (Name, Title, Role) Permit Citation Program Requirement Status Supporting Doc No. II.G.2.a The permittee maintained a current inventory of facilities and operations owned Facility Inventory and operated by the permittee with the potential for generating polluted Yes 7 stormwater runoff. II.G.2.b The permittee maintained and implemented an C&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 0&M program specifies the frequency of routine maintenance No --- requirements. If yes, the permittee evaluated the 0&M program annually and updated it as No --- necessary. While O&M Programs have recently been written for publicly owned facilities, an O&M program has not been maintained throughout the permit cycle. II.G.2.c Spill Response The permittee had written spill response procedures for municipal operations. No --- Procedures A maintained written Spill Response Plan was not made available at the time of the audit. 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 0&M program for the stormwater 0&M for Catch sewer system including catch basins and conveyance systems that it owns and No --- Basins and Conveyance Systems maintains. II.G.2.h The permittee maintained a current inventory of municipally -owned or operated Structural structural stormwater controls installed for compliance with the permittee's post- Not Applicable Stormwater Controls construction ordinance. NCS000422_Black Mountain MS4 Audit_20200212 Page 11 of 15 Pollution Prevention and Good Housekeeping for Municipal Operations II.G.2.1 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 Not Applicable Stormwater Controls the permittee's post -construction ordinance. If yes, then: The 0&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 II.G.2.1 The permittee ensured municipal employees are properly trained in pesticide, Pesticide, Herbicide herbicide and fertilizer application management. Yes 8 and Fertilizer Application The permittee ensured contractors are properly trained in pesticide, herbicide and Management fertilizer application management. Yes --- The permittee ensured all permits, certifications, and other measures for applicators are followed. Yes --- II.G.2.k The permittee implemented an employee training program for employees involved Staff Training in implementing pollution prevention and good housekeeping practices. ves 6 II.G.2.1 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. See comments in site visits for more information. NCS000422_Black Mountain MS4 Audit_20200212 Page 12 of 15 Site Visit Evaluation: Municipal Facility No. 1 Facility Name: Date and Time of Site Visit: Public Works February 12, 2020 1:30 pm Facility Address: Facility Type (Vehicle Maintenance, Landscaping, etc.): 304 Black Mountain Avenue Various Name of MS4 inspector(s) evaluated: Most Recent MS4 Inspection (List date and name of inspector): Jessica Trotman, Planning Director None 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? One training event documented. Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? Partially. Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping? Partially. 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 M54 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: Secondary Containment issues were observed during the inspection and discussed on site. 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. Secondary Containment was not provided for liquid materials. If compliance corrective actions were identified, what timeline for correction/follow-up was provided? Not determined. NCS000422 Black Mountain MS4 Audit 20200212 Page 13 of 15 Site Visit Evaluation: Municipal Facility No. 1 Site Visit Evaluation: Municipal Facility No. 2 Facility Name: Date and Time of Site Visit: Public Safety February 12, 2:30pm Facility Address: Facility Type (Vehicle Maintenance, Landscaping, etc.): 106 Montreat Road Vehicle Maintenance. Law enforcement. Fire Department Name of MS4 inspector(s) evaluated: Most Recent MS4 Inspection (Date and Entity): Jessica Trotman None 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? One training event documented. Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? Partially Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping? Partially 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? Yes Did the MS4 inspector miss any obvious areas of concern? If so, explain: The nature and construction of shop drain and the location of vehicle washing activity was a point of confusion. 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. The vehicle washing activities for police cars will be relocated. If compliance corrective actions were identified, what timeline for correction/follow-up was provided? Not determined. NCS000422_Black Mountain MS4 Audit_20200212 Page 14 of 15 Site Visit Evaluation: MS4 Outfall No. 1 Outfall ID Number: Date and Time of Site Visit: Not numbered February 12, 2020. 3pm Outfall Location: Outfall Description (Pipe Material/Diameter, Culvert, etc.): Corner of Sutton and Richardson Pipe. `28" diameter Receiving Water: Is Flow Present? If So, Describe (Color, Approximate Flow Rate, Swannanoa River Sheen, Odor, Floatables/Debris, etc.): Yes, Clear Most Recent Outfall Inspection/Screening (Date): None Days Since Last Rainfall: Inches: Raining during audit. Name of MS4 Inspector(s) evaluated: Jessica Trotman Observations Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? One training event documented. Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations? Partially. 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 Will a follow-up outfall inspection be conducted? If so, for what reason? No NCS000422_Black Mountain MS4 Audit_20200212 Page 15 of 15