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Federal Facilities and an MS4 Audit. Thea Lomax Presenter EPA, Region 6 Storm Water Enforcement. Overview. Federal Facilities (Definition, types) MS4s (Definition, examples) MS4 SWMP Requirements (Specific for federal facilities)

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Federal Facilities and an MS4 Audit

Thea Lomax

Presenter

EPA, Region 6

Storm Water Enforcement


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Overview

  • Federal Facilities (Definition, types)

  • MS4s (Definition, examples)

  • MS4 SWMP Requirements (Specific for federal facilities)

  • MS4 Audit (Definition, Goals, Benefits, Preparation, Process)

  • Resources & Tools

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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What is a Federal Facility?

  • A federal facility is any building, installation, land, etc., owned or leased by the federal government.

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Types of Federal Facilities

  • Federal facilities can include universities, prisons, hospitals, roads (i.e., departments of transportation), military bases (e.g., State Army National Guard barracks), parks and office buildings/complexes.

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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What is an MS4?

  • The term “MS4” is commonly used to describe both:

    • The infrastructure used to convey stormwater runoff

    • The owner/operator of the infrastructure that is permitted to discharge this runoff

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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What is an MS4?

According to 40 CFR 122.26(b)(8), municipal separate storm sewer system means a “conveyance or system of conveyances (including roads with drainage systems, municipal streets, catch basins, curbs, gutters, ditches, man-made channels, or storm drains):

(i) Owned or operated by a State, city, town, borough, county, parish, district, association, or other public body (created by or pursuant to State law)...including special districts under State law such as a sewer district, flood control district or drainage district, or similar entity, or an Indian tribe or an authorized Indian tribal organization, or a designated and approved management agency under section 208 of the Clean Water Act that discharges into waters of the United States.

(ii) Designed or used for collecting or conveying storm water;

(iii) Which is not a combined sewer; and

(iv) Which is not part of a Publicly Owned Treatment Works (POTW) as defined at 40 CFR 122.2.”

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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What is a sMS4?

  • According to 40 CFR 122.26(b)(16), small MS4s are similar to large and medium except they may be owned or operated bythe United States and includes systems similar to separate storm sewer systems in municipalities such as systems at military bases, large hospital or prison complexes, and highways and other thoroughfares but does not include sewers in very discrete areas, such as individual buildings.

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit



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Examples of MS4s

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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MS4 SWMP Requirementsfor Federal Facilities

■ Apply/obtain an NPDES permit

■ Develop and implement six minimum control measures of the permit:

1. Public Education and Outreach

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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MS4 SWMP Requirementsfor Federal Facilities

■ Apply/obtain an NPDES permit

■ Develop and implement six minimum control measures of the permit:

1. Public Education and Outreach

2. Public Participation/Involvement

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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MS4 SWMP Requirementsfor Federal Facilities

■ Apply/obtain an NPDES permit

■ Develop and implement six minimum control measures of the permit:

1. Public Education and Outreach

2. Public Participation/Involvement

3. Illicit Discharge Detection and Elimination

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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MS4 SWMP Requirementsfor Federal Facilities

■ Apply/obtain an NPDES permit

■ Develop and implement six minimum control measures of the permit:

1. Public Education and Outreach

2. Public Participation/Involvement

3. Illicit Discharge Detection and Elimination

4. Construction Site Runoff

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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MS4 SWMP Requirementsfor Federal Facilities

■ Apply/obtain an NPDES permit

■ Develop and implement six minimum control measures of the permit:

1. Public Education and Outreach

2. Public Participation/Involvement

3. Illicit Discharge Detection and Elimination

4. Construction Site Runoff

5. Post-Construction Runoff

Federal Facilities and an MS4 Audit


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MS4 SWMP Requirementsfor Federal Facilities

■ Apply/obtain an NPDES permit

■ Develop and implement six minimum control measures of the permit:

1. Public Education and Outreach

2. Public Participation/Involvement

3. Illicit Discharge Detection and Elimination

4. Construction Site Runoff

5. Post-Construction Runoff

6. Good Housekeeping/Pollution Prevention

for Municipal Operations

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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MS4 SWMP Requirementsfor Federal Facilities

■ Some Implementation Concerns

1. Unique characteristics

2. Lack of Legal Authority

3. Multiple Regulated Entities

■ Establish cooperative agreements with cities and counties in implementing the storm water management program

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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What is an MS4 Audit?

  • “Comprehensive evaluation of all components of an MS4 program to assess compliance with the NPDES permit and development and implementation of the storm water management programs.

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Goals of an MS4 Audit

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Goals of the MS4 Audit

  • Determine permittee’s compliance with their MS4 permit

  • Determine whether the MS4 is meeting the Maximum Extent Practicable (MEP) in reducing pollutants in storm water discharges

  • Provide compliance assistance in Storm Water Management Plan (SWMP) development and implementation

    • Assist in MS4 program development

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Benefits of an MS4 Audit

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Benefits of an MS4 Audit

  • Stronger coordination and working relationship between the permitting authority (and/or EPA) and the permittee

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Benefits of an MS4 Audit

  • Stronger coordination and working relationship between the permitting authority (and/or EPA) and the permittee

  • Better understanding by the permittee of the expectations and permit requirements

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Benefits of an MS4 Audit

  • Stronger coordination and working relationship between the permitting authority (and/or EPA) and the permittee

  • Better understanding by the permittee of the expectations and permit requirements

  • Clarity of MS4 permit requirements or SWMP plans

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Benefits of an MS4 Audit

  • Stronger coordination and working relationship between the permitting authority (and/or EPA) and the permittee

  • Better understanding by the permittee of the expectations and permit requirements

  • Clarity of MS4 permit requirements or SWMP plans

  • SWMP strengths and areas for improvement identified

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Benefits of an MS4 Audit

  • Stronger coordination and working relationship between the permitting authority (and/or EPA) and the permittee

  • Better understanding by the permittee of the expectations and permit requirements

  • Clarity of MS4 permit requirements or SWMP plans

  • SWMP strengths and areas for improvement identified

  • Improved permitting authority’s knowledge of the permittee’s operations, priorities, constraints and challenges

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Benefits of an MS4 Audit

  • Stronger coordination and working relationship between the permitting authority (and/or EPA) and the permittee

  • Better understanding by the permittee of the expectations and permit requirements

  • Clarity of MS4 permit requirements or SWMP plans

  • SWMP strengths and areas for improvement identified

  • Improved permitting authority’s knowledge of the permittee’s operations, priorities, constraints and challenges

  • More effective SWMPs that result in better water quality and reduced pollutants in storm water discharges to the MS4

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Preparation to be audited

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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What should I ask myself first?

  • Where is my Storm Water Management Plan?

  • Where is my legal authority for storm water activities (ordinances/agreements)?

  • Do I know what is in the SWMP?

  • Do I have copies of all my annual reports?

  • Have I allowed myself plenty of time to do this audit?

  • Do I have copies of everything we say we sent to the PA (EPA or State)?

  • Where is that checklist EPA gave me?

  • Do I have everything I need in one place or do I know where it is?

  • Have I contacted and scheduled all needed persons to participate in the audit?

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Municipal Separate Storm Sewer System (MS4)AuditPrepared byEPA Region 6Water Enforcement BranchMunicipal/Industrial Section (6EN-WM)Revised March 2009 from the November 2006 Checklist

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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ANNUAL REPORTS

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Purpose of Annual Reports

To report the progress of activities implemented to accomplish the goals of the SWMP.

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Annual Reports

■ Include a status on:

1. Compliance with SWMP schedules

2. Public Education/Outreach

3. Public Participation/Involvement

4. Illicit Discharge Detection and Elimination

5. Construction Site Runoff

6. Post-Construction Site Runoff

7. Good Housekeeping/Pollution Prevention for Municipal

Operations

8. Proposed changes to the SWMP in the coming reporting year

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Annual Reports

■ Include a status on:

9. Revisions, if necessary, to the assessment of controls land the fiscal

analysis reported in the permit application or the most recent annual

report10. Summary of monitoring data accumulated throughout the reporting

year

11. Summary of the number of the NPDES NOIs received for each

general permit

12. Number of site notices received from small construction site operators

seeking coverage for storm water discharges

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Annual Reports

■ Include a status on:

13. Number of inspections conducted for industrial facilities

14. Number of inspections conducted for construction sites

15. Annual expenditures for the reporting period, with a breakdown

for the major elements of the SWMP, and the budget for the

year (reporting year) following each annual report

16. Summary describing the number of enforcement actions

17. Summary describing the nature of enforcement actions

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Annual Reports

■ Include a status on:

18. Summary describing the number of inspections

19. Summary describing the nature of inspections

20. Summary describing the number of education programs

21. Identification of any water quality improvements

22. Identification of any water quality degradations

23. Identification of any progress towards measurable goals

24. Identification of any progress toward measured reductions in pollutants

25. Discharge Monitoring Reports for the reporting period

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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STORM WATER MANAGEMENT PLAN

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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SWMP

■ Comprehensive document that includes the

implementation process for each required

NPDES six minimum control measures

■ Updated

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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PUBLIC EDUATION/OUTREACH

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Public Education/Outreach

  • Measurable Goals

  • Ordinances, agreements

  • Management, organizational structure, responsibilities

  • Meeting schedules

  • Contracted services

  • Training

  • Records

  • Handouts

  • Evaluation Tool

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Public Education/OutreachPesticides, Herbicides, Fertilizers

  • Proper use

  • Disposal

  • Storage

  • Handouts developed / meetings held

  • Promotion/Publicized/Facilitated

  • Mechanisms to measure effectiveness of program

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Public Education/OutreachPublic Reporting of Illicit Discharges

  • Departments responsible

  • Promote, publicize, facilitate reporting of illicit discharges or WQ impacts associated with discharges

  • Programs developed to allow public participation in reporting illicit discharges

  • Speaking engagements / event participation

  • Tracking number of illicit discharges reported by public

  • Educational material developed (including disposal of grass clippings, leaf litter, animal wastes)

  • Mechanisms to measure results of public participation/education

  • Measures to reach multi-ethnic / minority communities

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Public Education/OutreachDisposal of Used Oil/Household Hazardous Waste

  • Departments responsible

  • Programs to educate about disposal of used oil and household hazardous waste materials

  • Speaking engagements / event participation

  • Promote, publicize, facilitate program

  • Training materials developed

  • Responses to program (how many gallons of household hazardous waste or used oil collected)

  • Measures to reach children, physically challenged, non-English speaking/reading

  • Mechanisms to measure effectiveness of program

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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PUBLIC PARTICIPATION/INVOLVMENT

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Public Participation/Involvement

  • Measurable Goals

  • Ordinances, agreements

  • Management, organizational structure, responsibilities

  • Meeting schedules

  • Contracted services

  • Training

  • Records

  • Handouts

  • Evaluation Tool

Federal Facilities and an MS4 Audit


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Public Participation/Involvement

  • Public involvement on management practices, control techniques and systems, design and engineering methods, etc.

  • Programs implemented to provide adequate public education and ample opportunities for public participation in development/implementation of SWMP

  • Measures to encourage public participation

  • Public meetings held annually? Attendees? Publicity? Topics covered?

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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ILLICIT DISCHARGE DETECTION and ELIMINATION

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Illicit Discharge Detection and Elimination

  • Measurable Goals

  • Ordinances, agreements

  • Management, organizational structure, responsibilities

  • Meeting schedules

  • Contracted services

  • Training

  • Records

  • Evaluation Tool

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Illicit discharge detection/elimination: Planning and Evaluation

  • Inspections

  • Investigations

  • Records management

  • Field screening

  • Follow-ups

  • Enforcement

  • Citizen complaints (reporting and resolution)

  • Identification of industrial dischargers and their pollutants

  • Identification of measurable goals

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Illicit discharge detection/elimination:Sanitary Sewers

  • Reliable tracking system

  • Controls to limit infiltration of seepage from sanitary sewers

  • Owners of leaking privately owned sewer lines

  • Procedures to eliminate reoccurrence of seepage into MS4

  • Documentation (what type information; i.e., location, cause, resolution, etc.)

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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CONSTRUCTION SITE RUNOFF

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Construction Site Runoff

  • Measurable Goals

  • Ordinances, agreements

  • Management, organizational structure, responsibilities

  • Meeting schedules

  • Contracted services

  • Training

  • Records

  • Evaluation Tool

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Construction Site RunoffPlanning and Evaluation

  • Inspection program (both public and MS4 owned sites) – scheduling, prioritization, follow-ups, enforcement, citizen complaints

  • Targeted areas

  • Identification of MS4 specific controls

  • Mechanism to measure BMP effectiveness

  • Databases for tracking

  • Identification of POCs

  • Citizen complaints

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Construction Site RunoffTraining

  • MS4 Inspector training

  • Adequate number of dedicated inspectors

  • Compliance Assistance/training for site operators (seminars, meetings, roundtables, etc.)

  • Training materials developed by MS4

  • Specific outreach for small businesses and minority businesses

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Construction Site RunoffInventory

  • Identification of universe (including sites disturbing less than 1 acre) and schedule for updating

  • Mechanism for tracking projects – Number and status, NOI, inspections/results/follow-up, enforcement actions), citizen complaints

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Construction Site RunoffControl requirements and BMPs

  • Technical guidance used as standards for design/selection of nonstructural and structural BMPs

  • Requirements for following tech guidance

  • Minimum operation and maintenance requirements

  • Installation and maintenance requirements

  • MS4-preferred BMPs to be used

  • Different BMPs for different seasons

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Construction Site RunoffPlan review

  • Building permit requirements (i.e., NOI, SWP3, etc.)

  • MS4 notification of responsibilities under storm water permitting program

  • Requirement to submit SWP3 with project plans

  • SWP3 review

  • Mechanism for changes to SWP3

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Construction Site RunoffInspections

  • Criteria for prioritizing inspections

  • Pre-construction meetings with inspectors and contractors

  • Inspections of all phases (i.e., clearing/grubbing/site prep, mass grading/public infrastructure/utility, building construction/final grading

  • Departments in charge of erosion and sediment control inspections

  • Records management (checklists, inspection form, electronic database)

  • Designated inspectors and qualifications

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Construction Site RunoffEnforcement/Referrals

  • Addressing non-compliance

  • Escalating enforcement

  • Follow-up inspections

  • Tracking for inspections, enforcement actions, follow-ups, repeat violators

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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POST-CONSTRUCTION RUNOFF

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Post-ConstructionPlanning and Evaluation

  • Commercial and residential areas

  • Departments responsible for implementation

  • Inspection criteria

  • Enforcement criteria

  • Mechanism to determine effectiveness

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Post-Construction ControlsMaintenance of Structural Controls

  • Identification of POCs

  • Specific areas targeted for pollutant reduction and application of specific BMPs

  • Maintenance scheduling for structural controls (including floatables)

  • Procedures to develop, implement and enforce controls from new development and significant re-development after construction

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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GOOD HOUSEKEEPING/POLLUTION PREVENTION for MUNICIPAL OPERATIONS

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Poor Housekeeping vs. Good Housekeeping OPERATIONS

Implement catch basin cleaning

Polluted catch basin

Lack of maintenance yard management

Maintain maintenance yard

Federal Facilities and an MS4 Audit


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Poor Housekeeping vs. Good Housekeeping OPERATIONS

Paints left exposed to storm water

Batteries and drums left exposed to storm water

Federal Facilities and an MS4 Audit


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Poor Housekeeping vs. Good Housekeeping OPERATIONS

Maintenance yard well managed. Drums

Stored underneath a shed and placed on

platforms

Trash container exposed to storm water, not

covered with a lid.

Federal Facilities and an MS4 Audit


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Poor Housekeeping vs. Good Housekeeping OPERATIONS

Sloppy road paint storage

Storm drain inlet not cleaned

Federal Facilities and an MS4 Audit


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Poor Housekeeping vs. Good Housekeeping OPERATIONS

Stock piles covered

Federal Facilities and an MS4 Audit


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Good Housekeeping/Pollution Prevention for Municipal Operations

  • Measurable Goals

  • Ordinances, agreements

  • Management, organizational structure, responsibilities

  • Meeting schedules

  • Contracted services

  • Training

  • Inventory

  • Records

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Good Housekeeping/Pollution Prevention for Municipal Operations

  • Mapping

  • Operations and Maintenance Procedures

  • Operations and Maintenance Activities

  • Non-Structural and Structural Pollution Control Devices

  • BMPs

  • Inspections

  • PHFs

  • Evaluation Tool

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Audit Process Operations

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Audit Process OperationsPre-Audit1. Schedule date/time/location for the audit2. Arrange specific times to meet with the SWMP Representative 3. Prepare a 10 minute overview of each program4. Compile SWMP records, information, plans for review5. Prepare and provide to the auditor a list of facilities for inspection observation and other requested informationAudit1. Start on time2. Introduction3. Presentation4. Interview5. Inspection observations6. File reviews7. Closing conference

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Audit Process OperationsPost-Audit1. Technical staff review of findings and information collected 2. Report completed3. If violations, Copy of Report and Administrative Order issued4. If no violation, Copy of Report and letter of compliance issued.

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Resources & Tools Operations

www.epa.gov/region6/sw

www.epa.gov (search for MS4)

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit


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Resources & Tools Operations

■ EPA’s Regulated Small MS4s website

http://cfpub.epa.gov/npdes/stormwater/phase2.cfm

■ Measurable Goals Guidance

http://cfpub.epa.gov/npdes/stormwater/measurablegoals/index.cfm

■ Stormwater Phase II Compliance Assistance Guide

http://www.epa.gov/npdes/pubs/comguide.pdf

Federal Facilities and an MS4 Audit


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Resources & Tools Operations

■ Training

http://cfpub.epa.gov/npdes/outreach.cfm?program_id=0&otype=1

Federal Facilities and an MS4 Audit


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Resources & Tools Operations

Final EPA MS4 Program Evaluation Guidance

http://www.epa.gov/npdes/pubs/ms4guide_withappendixa.pdf

http://www.epa.gov/npdes/pubs/ms4guide_appendicesb-d.pdf

http://www.epa.gov/npdes/pubs/ms4guide_withappendixa.doc

http://www.epa.gov/npdes/pubs/ms4guide_appendicesb-d.doc

Federal Facilities and an MS4 Audit


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Resources & Tools Operations

■ EPA’s Menu of Best Management Practices (BMPs)

http://cfpub.epa.gov/npdes/stormwater/menuofbmps/index.cfm

■ Illicit Discharge Detection and Elimination Manual

http://cfpub2.epa.gov/npdes/docs.cfm?program_id=6&view=allprog&sort=name#iddemanual

or it can be downloaded from the Center for Watershed Protection website at

http://www.cwp.org/idde_verify.htm

■ EPA Stormwater Month Outreach Materials and Reference Documents

http://cfpub.epa.gov/npdes/stormwatermonth.cfm

Federal Facilities and an MS4 Audit


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???? Operations

Federal Facilities and an MS4 Audit


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Contacts Operations

EPA Thea Lomax 214-665-8098

Diana McDonald 214-665-7495

Everett Spencer 214-665-8060

Linda Smith 214-665-6641

Federal Facilities and an MS4 Audit

Federal Facilities and an MS4 Audit