Self-audit guidance for Phase II MS4s

Introduction

MPCA and local MS4 staff during an MPCA audit

The Minnesota Pollution Control Agency (MPCA) staff conduct audits of Stormwater Pollution Prevention Programs (SWPPPs) to determine compliance with the MS4 General Permit and to provide technical assistance to staff in regulated Municipal Separate Storm Sewer Systems (MS4s). The MPCA’s intent is to audit all SWPPPs for MS4s regulated under the MS4 General Permit every seven years. Between MPCA audits, it is recommended to conduct a self-audit to check your progress with meeting permit requirements.

Conduct a self-audit using the Phase II MS4 Audit Report Form. The Audit Report Form is the same form MPCA staff use to determine the compliance status of each requirement after an audit is conducted. During the self-audit, you should review each permit requirement and note whether or not the activity is complete.

During the self-audit, review your SWPPP document that was submitted to the MPCA upon application for permit coverage. The SWPPP document has, for each MCM, your MS4-specific measureable goals, established best management practices (BMPs), timeframes for new BMP implementation, and the name or position title of staff responsible for BMP implementation. The BMPs, measurable goals, and timeframes indicated in the SWPPP document may be changed if you feel your SWPPP would benefit from being updated after your self-audit or annual program evaluation.

Before conducting your self-audit, gather all files, documents, and materials related to your SWPPP, including annual reports, SWPPP document, public notices, maps, written procedures, enforcement action documentation, regulatory mechanism(s), etc. Documentation of the activity should be easily accessible and available for review.

Please note that completing a self-audit, regardless of the results, does not preclude the MPCA from taking enforcement after an MPCA lead audit related to any of the activities required by the MS4 General Permit. If you have any questions relating to your SWPPP, please contact your MPCA MS4 staff.

We have included tips on enhancing your SWPPP for each MCM. These are not direct permit requirements, but methods MPCA staff have observed during audits that make local stormwater programs more effective. We have also included general questions MPCA staff could ask during an audit. These questions are to prompt thought about your SWPPP in areas MPCA staff may focus during the audit. MPCA staff will ask general questions during the audit, but also questions specific to your SWPPP and stormwater activities. The questions noted are not a final and complete list of questions that can or will be asked during an MPCA audit. In addition, please refer to the Self-audit webinar for additional information.

Overall program management

Tips for overall program management

• Develop a process and key contacts for coordinating SWPPP activities across departments.
• Remember to perform an annual evaluation of your SWPPP and SWPPP document.
• Perform an annual evaluation of all written procedures to ensure they reflect current processes and staff.

Questions and concepts to consider

• Which staff are involved in the implementation of your SWPPP and how are activities coordinated across departments?
• If outside groups are involved in your SWPPP, what are their roles or authorities, and how do you coordinate with them?
• How is your stormwater program funded and what aspects of the SWPPP does the funding cover?

MCM 1 - Public Education and Outreach

Tips for a successful public education and outreach program

• Partner with organizations that specialize in public education and outreach, like Soil and Water Conservations Districts or non-profits.
• Partner with neighboring communities to standardize the messaging related to your community’s waterbodies.
• Develop culturally appropriate materials in languages applicable to the demographics of your community.
• Conduct baseline screenings (e.g. through surveys) to evaluate the impact of your public education program and extent to which your program is changing behaviors.
• Use a database or spreadsheet to track the number of outreach materials distributed and the date(s) of distribution.

Questions and concepts to consider

• How were target audiences and high priority topics chosen?
• How do you evaluate the effectiveness of your public education and outreach program?
• Have you established behavior change goals and, if so, what have you done to cause behavior changes within your audiences?
• What methods are you using to reach your target audiences and how do you know if you are successful?
• Are you reevaluating your target audiences periodically?

MCM 2 - Public Involvement

Tips for a successful public involvement program

• Use existing municipal events, like Public Works Open Houses, fairs, or household hazardous waste collection days to solicit input on your SWPPP. If using an existing, on-going event as your public opportunity for the public to provide input, be sure to follow your local public notice requirements.
• Provide access to the SWPPP in various forms to meet the needs of all residents (i.e. hardcopies in municipal facilities and electronically).

Questions and concepts to consider

• How are you getting annual input on the SWPPP from the public?
• What is your process for receiving, considering, and responding to public input on the SWPPP?
• How are you involving all groups (e.g. residents, businesses, public officials) in your SWPPP?
• Are you, or have you considered, storm drain stenciling events to involve the public and raise awareness of stormwater impacts?
• What volunteer activities does your community sponsor or partner to host?
• What are your community’s public notice requirements?

MCM 3 - Illicit Discharge Recognition and Reporting

Tips for a successful illicit discharge detection & elimination program

• Maintain a database or spreadsheet to collect all required information for illicit discharge discoveries and complaints.
• Coordinate with other municipal operations (fire, police, etc.) to create the procedures for investigating, locating, and eliminating the source of illicit discharges and spill responses to ensure the procedure includes all relevant staff and tools that can be used in various situations (e.g. booms, spill response kits).
• Train all staff on the MS4 General Permit requirements for illicit discharges, including police officers, fire fighters, and building officials.

Questions and concepts to consider

• How are illicit discharge inspections prioritized and tracked?
• How do you know when to pursue and elevate enforcement actions related to observed illicit discharges?
• How do you use the storm sewer map when you receive a complaint regarding or discover an illicit discharge?
• What tools are available for staff to use while preventing or minimizing impacts of illicit discharges?
• Which staff respond to illicit discharge complaints and how do they evaluate the situation?
• Are the storm sewer or sanitary sewer systems evaluated to determine illicit or cross connections?

MCM 4 - Construction Stormwater Runoff Control

Tips for a successful construction stormwater program

• Fill out a standard checklist during all construction site inspections.
• Ensure your regulatory mechanism requires all erosion, sediment, and waste controls as described in the Construction Stormwater General Permit.
• Fill out a standard checklist during all site plan reviews.
• Document all enforcement actions, including verbal warnings.
• Use a database or spreadsheet to track all required information related to enforcement actions.

Questions and concepts to consider

• What are the difference between inspecting a private and publically owned/operated construction site?
• What is the process for conducting a construction site inspection and what does the inspector look for onsite?
• What is the process, from application to approval, for a proposed construction project?
• What is the site review process – who is involved, what is evaluated, and how are findings communicated with the applicant?
• How does the construction site inspector know when to pursue and elevate enforcement actions?

MCM 5 - Post-construction Stormwater Management

Tips for a successful post-construction stormwater program

• Fill out a standard checklist during all site plan reviews to ensure the reviewer is evaluating for appropriate post-construction water quality and design standards.
• Explicitly state the post-construction water quality and volume standards (e.g. retain a one inch of runoff for all new impervious for new development; net reduction for redevelopment).
• Adopt Minimal Impact Design Standards (MIDS) for new and redevelopment post-construction water quality and volume standards.
• Track all privately owned structural stormwater BMPs that have or will need a maintenance agreement.

Questions and concepts to consider

• Is there an overall comprehensive plan that guides new and re-development standards and other stormwater management strategies?
• What does the site plan reviewer look for when reviewing projects for post-construction stormwater management?
• What is your tool to ensure long-term maintenance of private permanent stormwater BMPs?
• Do you provide technical assistance or guidance on, or require specific, post-constructions structural stormwater BMPs?
• Does your private structural stormwater BMP long-term maintenance tool require the owner/operator to report to you at an established frequency, such as annually, regarding the condition of the BMP?

MCM 6 - Pollution Prevention/Good Housekeeping for Municipal Operations

Tips for a successful pollution prevention program

• Use a standard checklist to document all outfall, pond, and structural stormwater BMP inspections.
• If using a standard checklist for inspections and include a section dedicated to illicit discharge assessment.
• Include new and seasonal staff training with other required staff training events.
• Develop a stormwater runoff control plan for facilities on the facility inventory and assign a key contact for each facility.

Questions and concepts to consider

• What BMPs are in place at each facility in the Facility Inventory?
• Do you subcontract any maintenance activities (e.g. lawn mowing, fertilizer application, snow plowing, etc.) and, if so, are the contractors aware and appropriately trained to protect water quality?
• What are your procedures for inspecting ponds, outfalls, and structural stormwater BMPs?
• What are your procedures for street sweeping and deicing application?