MS4 Audits II Audits.pdf · 2011-12-14 · MS4 Compliance Assistance Compliance Assistance Documents were developed to assist permittees covered by the 2008 MS4 general permits. The

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Municipal Separate Storm Sewer Municipal Separate Storm Sewer System PermittingSystem Permitting

(MS4)(MS4)

By Keith NobleBy Keith Noble

Water Resources Division Water Resources Division

Department of Environmental Quality Department of Environmental Quality

MS4 AuditsMS4 Audits

Storm Water Management Plan (SWMP)Storm Water Management Plan (SWMP)--Developed under the Developed under the

Jurisdictional General PermitJurisdictional General Permit

Storm Water Pollution Prevention Initiative Storm Water Pollution Prevention Initiative (SWPPI) Developed under the (SWPPI) Developed under the

Watershed General PermitWatershed General Permit

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Audit is based on the 2003 General Permits Audit is based on the 2003 General Permits and the approved plan (SWMP or SWPPI).and the approved plan (SWMP or SWPPI).

Audit

SWPPI Approved Under Withdrawn 2008 Watershed General Permit MIG619000

SWPPI Approved Under2003 Watershed

General Permit MIG610000

SWMP Approved Under Withdrawn 2008 Jurisdictional

General PermitMIS049000

SWMP Approved Under 2003 Jurisdictional

General PermitMIS040000

Phase I Communities

PrearrangedPrearranged•• DEQ staff will contact the permittee to set DEQ staff will contact the permittee to set up the auditup the audit

–– Find a date that is mutually agreeableFind a date that is mutually agreeable

–– Allows the permittee to:Allows the permittee to:

•• Gather the appropriate staff or consultantsGather the appropriate staff or consultants

•• Compile appropriate documentsCompile appropriate documents

–– Ordinances Ordinances

–– ProceduresProcedures

–– Record keeping Record keeping

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Confirmation letter will be sentConfirmation letter will be sent

Included will be an:Included will be an:

Audit Preparation ChecklistAudit Preparation Checklist

Tentative schedule Tentative schedule

Content of the AuditContent of the Auditstated in the confirmation letterstated in the confirmation letter

Could be based on one part of the programCould be based on one part of the program

OrOr

The whole program The whole program

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What you should have availableWhat you should have availableat the Auditat the Audit(Audit Preparation Checklist)(Audit Preparation Checklist)

Copies of Copies of PlansPlansWatershed Management Plans (WMP)Watershed Management Plans (WMP)

Public Participation Plan (PPP) Public Participation Plan (PPP)

Storm Water Pollution Prevention Initiative (SWPPI)Storm Water Pollution Prevention Initiative (SWPPI)

Storm Water Management Plan (SWMP)Storm Water Management Plan (SWMP)

Public Education Plan (PEP)Public Education Plan (PEP)

Illicit Discharge Elimination Plan (IDEP)Illicit Discharge Elimination Plan (IDEP)

What you should have availableWhat you should have availableat the Auditat the Audit

Ordinances or Regulatory MechanismsOrdinances or Regulatory Mechanisms

Checklists/worksheets used by the permitteeChecklists/worksheets used by the permittee

Standard Operating Standard Operating ProceduresProcedures

Documentation of efforts for each programDocumentation of efforts for each program

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Personnel responsible for overseeing and/or Personnel responsible for overseeing and/or implementing the:implementing the:

PEP programPEP program

IDEP programIDEP program

Post construction programPost construction program

Pollution Prevention/Good Housekeeping Pollution Prevention/Good Housekeeping program program

Who should be at the audit

Content of the auditContent of the audit

Overview of the:Overview of the:

WMP (updated or revised?)WMP (updated or revised?)

Public Involvement (PPP or PIP)Public Involvement (PPP or PIP)

SWPPI or SWMPSWPPI or SWMP

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Public Education Public Education

PEPPEP

Activities implementedActivities implemented

Documentation of ActivitiesDocumentation of Activities

Timelines for ImplementationTimelines for Implementation

Public EducationPublic Education

Methods for determining effectiveness of Methods for determining effectiveness of educational activitieseducational activities

MeasureableMeasureable

Show improvement or increased understandingShow improvement or increased understanding

Number of itemsNumber of items

distributed often failsdistributed often fails

to measure to measure

the effectivenessthe effectiveness

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Compliance Assistance DocumentsCompliance Assistance Documents

www.michigan.gov/deqstormwaterwww.michigan.gov/deqstormwater

Click on Municipal Program/Click on Municipal Program/

MS4 Compliance AssistanceMS4 Compliance Assistance

Compliance Assistance Documents were developed Compliance Assistance Documents were developed to assist permittees covered by the 2008 MS4 to assist permittees covered by the 2008 MS4 general permits.general permits.

The 2008 MS4 general permits were withdrawn.The 2008 MS4 general permits were withdrawn. As As such, the Compliance Assistance Documents may such, the Compliance Assistance Documents may not meet all the requirements of the 2003 MS4 not meet all the requirements of the 2003 MS4 general permits.general permits.

The documents are intended for guidance only.The documents are intended for guidance only. If If you have questions about these documents and you have questions about these documents and how they relate to compliance with an MS4 how they relate to compliance with an MS4 permit, please contact DEQ district staff.permit, please contact DEQ district staff.

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Illicit Discharge Elimination Plan Illicit Discharge Elimination Plan (IDEP) Implementation(IDEP) Implementation

TrainingTraining

CoordinationCoordination

Regulatory MechanismRegulatory Mechanism

Mapping of Point SourcesMapping of Point Sources

Illicit Discharge Elimination Plan Illicit Discharge Elimination Plan (IDEP) Implementation(IDEP) Implementation

Sanitary Infiltration into MS4Sanitary Infiltration into MS4

Dry Weather ScreeningDry Weather Screening

Elimination of Illicit DischargesElimination of Illicit Discharges

Documentation Documentation

ActionsActions

Evaluation of EffectivenessEvaluation of Effectiveness

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Post ConstructionPost Construction

Legal AuthorityLegal AuthorityOrdinanceOrdinance

Regulatory MechanismRegulatory Mechanism

Requirements and BMPsRequirements and BMPs

Site Plan Review Procedures and ExamplesSite Plan Review Procedures and Examples

Maintenance?Maintenance?

Post ConstructionPost Construction

BMP InventoryBMP Inventory

BMP Inspection and MaintenanceBMP Inspection and Maintenance

EnforcementEnforcement

Municipal owned projectsMunicipal owned projects

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Construction Storm Water ControlsConstruction Storm Water Controls

NotificationsNotifications

Preliminary PlansPreliminary Plans

Receiving ComplaintsReceiving Complaints

Note: 2003 watershed permit does not have this as a Note: 2003 watershed permit does not have this as a separate section of the permitseparate section of the permit

Pollution Prevention and Good Pollution Prevention and Good Housekeeping (P2GH)Housekeeping (P2GH)

TrainingTraining

EmployeesEmployees

ContractorsContractors

DocumentationDocumentation

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Pollution Prevention and Good Pollution Prevention and Good HousekeepingHousekeeping

Storm Water Structural ControlsStorm Water Structural Controls

Maintenance activitiesMaintenance activities

Disposal of O& M WastesDisposal of O& M Wastes

Maintenance SchedulesMaintenance Schedules

Inspection ProceduresInspection Procedures

Mapped?Mapped?

Google earth functionGoogle earth function


Controls for Reducing or Eliminating Controls for Reducing or Eliminating Discharge of Pollutants FromDischarge of Pollutants From

Streets, Roads, HighwaysStreets, Roads, Highways

Parking LotsParking Lots

BMPsBMPs

SweepingSweeping

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Catch basin cleanoutCatch basin cleanout

DeicingDeicing

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Ditch CleaningDitch Cleaning

Pavement Repair

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Snow StorageSnow Storage

Unpaved areasUnpaved areas

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“Plan for the proper disposal of Operations and Maintenance Wastes”


Controls for Reducing or Eliminating Discharge Controls for Reducing or Eliminating Discharge of Pollutants Fromof Pollutants From

Areas with exposure of materials to storm waterAreas with exposure of materials to storm water

such as maintenance and storage areassuch as maintenance and storage areas

Review of SWPPPReview of SWPPP

(If SWPPI developed under withdrawn 2008 permits)(If SWPPI developed under withdrawn 2008 permits)

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Controls for Reducing or Eliminating Controls for Reducing or Eliminating Discharge of Pollutants Related to the Discharge of Pollutants Related to the Application of:Application of:

PesticidesPesticides

HerbicidesHerbicides

Fertilizers Fertilizers

ConsiderConsider

TrainingTraining

StorageStorage

AlternativesAlternatives

Pollution Prevention and Good Pollution Prevention and Good HousekeepingHousekeeping•• Inspection of Inspection of

Municipal PropertiesMunicipal Properties

–– GaragesGarages

–– Storage YardsStorage Yards

–– DPWsDPWs

–– Compost FacilitiesCompost Facilities

–– Animal controlAnimal control

–– Mosquito ControlMosquito Control

–– Bus GaragesBus Garages

–– ParksParks

–– OthersOthers

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Post Audit ConferencePost Audit Conference

DiscussDiscuss

PositivesPositives

Letter to be sent Letter to be sent

Concerns and violationsConcerns and violations

Compliance with storm water permit Compliance with storm water permit

Other water quality regulationsOther water quality regulations

Part 5 Rules (Polluting Materials)Part 5 Rules (Polluting Materials)

Part 4 Rules (Water Quality)Part 4 Rules (Water Quality)

Industrial Storm water regulated facilitiesIndustrial Storm water regulated facilities

Mosquito Control (Additives)Mosquito Control (Additives)

Follow up ReportFollow up Report

Letter will be sent with a reportLetter will be sent with a report

Usually within 60 daysUsually within 60 days

Corrective actionsCorrective actions

ResponseResponse

DatesDates

RecommendationsRecommendations

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Stakeholder Group MeetingsStakeholder Group Meetings

•• Statewide representationStatewide representation

•• Met monthly April through OctoberMet monthly April through October

•• All aspects of the MS4 general permits All aspects of the MS4 general permits were discussedwere discussed

•• Permittees communicated what worked Permittees communicated what worked and what didn’tand what didn’t

Next StepsNext Steps

•• DEQ reviewing information from the stakeholder DEQ reviewing information from the stakeholder meetingsmeetings

•• Moving away from general permits Moving away from general permits

•• Moving towards reviewing current and proposed Moving towards reviewing current and proposed actions in the application processactions in the application process

•• Not discouraging watershed processNot discouraging watershed process

•• Stakeholder group will reconvene when new Stakeholder group will reconvene when new information is availableinformation is available

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MS4 Court CaseMS4 Court Case

The circuit court action continues to be in The circuit court action continues to be in abeyance pending the Court of Appeals abeyance pending the Court of Appeals decision on the State’s appeal. The Court decision on the State’s appeal. The Court of Appeals has not made a decision on the of Appeals has not made a decision on the appeal at this time.appeal at this time.

www.michigan.gov/deqstormwaterwww.michigan.gov/deqstormwater