Self-audit guidance for Phase II MS4s

Introduction

The purpose of this document is to provide municipal separate storm sewer system (MS4) staff guidance on how to conduct a self-audit of a stormwater pollution prevention program (SWPPP).

The Minnesota Pollution Control Agency (MPCA) staff conduct audits of SWPPPs to determine compliance with the MS4 General Permit and to provide technical assistance to staff in regulated MS4s. The MPCA’s intent is to audit all SWPPPs for MS4s regulated under the MS4 General Permit every seven years. Between MPCA audits, you may want to conduct a self-audit to check your progress with meeting permit requirements.

This document details each of the six Minimum Control Measures (MCMs) described in the MS4 General Permit and the activities required to be implemented and/or documented under each MCM. During the self-audit, you should review each permit requirement and note whether or not the activity is complete. In addition, documentation of the activity should be easily accessible and available for review. If specific documentation is required, it is noted with the activity’s description. Also review the MPCA’s guidance on the documentation required to be retained under the MS4 General Permit.

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. Once all documents are gathered, use the tables below to guide the self-audit of your program. To mark an activity complete, you must have all supporting documentation and the activity must meet all of the requirements.

In this guidance 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 in this document are not a final and complete list of questions that can or will be asked during an MPCA audit.

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 the appropriate MPCA staff, listed on the MS4 Permittee Staff Assignments webpage in the Minnesota Stormwater Manual.

In addition, please refer to the Self-audit webinar for additional information.

Overall program management

Activity description	Activity complete and available?
Staff and their stormwater responsibilities documented for those who implement components of the SWPPP.	Yes or No
A map of the MS4 system with the following: all pipes 12 inches or more in diameter including their flow direction and an ID number, all outfalls including their ID number and geographic coordinates, all structural stormwater BMPs that are part of the MS4, and all receiving waters.	Yes or No
Partnerships established to implement the SWPPP or aspects of the SWPPP, including any formal agreements.	Yes or No
Enforcement actions conducted are documented, including verbal warnings, with the following information: name of the party in noncompliance; date, location, and description of the violation, including reference to relevant Regulatory Mechanism; corrective actions required & completion schedule; date and type of enforcement used; referrals to other regulatory organizations (if any); and date violation resolved.	Yes or No
A Pond, Wetland, and Lake Inventory complete and submitted to the MPCA.	Yes or No
For MS4s that discharge to waters with a total maximum daily load (TMDL) that was approved by USEPA before the issuance of the MS4 General Permit. For each TMDL, documentation of the following: TDML project name, numeric waste load allocation (WLA) type (i.e. categorical or individual) and units, pollutant of concern, applicable flow data, interim milestones (BMPs) and dates for implementation to make progress toward meeting the WLAs, strategies for continued BMP implementation beyond the term of the MS4 General Permit, and and target dates the applicable WLA will be achieved.	Yes or No
For MS4s with an Alum or Ferric Chloride Phosphorus Treatment System. Documentation of the following: geographic coordinates of the system, the name or position titles of those responsible for the operation of the system, and annual reporting information.	Yes or No

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

Activity description	Activity complete and available?
The SWPPP document describing BMPs to educate the public on the impact stormwater discharges have on water bodies and actions citizens, businesses, and other local organizations can take to reduce the discharge of pollutants to stormwater.	Yes or No
The SWPPP document with measurable goals for each BMP (e.g. number of materials distributed, number of website hits, or number/percentage of behaviors changed) and timeframes and staff responsible for implementation.	Yes or No
Partnerships established to implement the SWPPP or aspects of the SWPPP, including any formal agreements.	Yes or No
High priority stormwater-related issue(s) are identified (e.g., specific TMDL reduction targets; responsible management of pet waste, household chemicals, yard waste, or deicing materials).	Yes or No
Outreach and educational materials related to stormwater-related high priority issues are distributed and documented.	Yes or No
Outreach and educational materials related to illicit discharge recognition and reporting are documented.	Yes or No
Implementation plan developed that consists of the following: target audience and measurable goals; staff responsible for implementation; specific activities and schedules to meet measurable goals; description of coordination with education partners, if applicable; and an annual evaluation of measurable goals.	Yes or No
An annual evaluation of the effectiveness of the implementation plan has been completed.	Yes or No
Modifications made to the program as a result of the annual evaluation are documented.	Yes or No
Public education activities held are documented, including dates of the activities.	Yes or No
Educational materials have been distributed and documented with quantities, descriptions, and dates.	Yes or No

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

Activity description	Activity complete and available?
The SWPPP document identifies public involvement BMPs to solicit public input on the SWPPP.	Yes or No
The SWPPP document identifies measurable goals for each BMP (e.g. numbers of public meetings held or number participants involved in specific activities), associated timeframes, and staff responsible for implementation.	Yes or No
Annual public opportunity for the public to provide input on the SWPPP is held and documented with dates and locations of events and notices to the public.	Yes or No
Access provided to the following: SWPPP document, annual reports, and other documentation that supports the SWPPP.	Yes or No
Events and notices to the public of events scheduled are documented with dates and locations.	Yes or No
Outreach and educational materials related to illicit discharge recognition and reporting are documented.	Yes or No
Public input regarding the SWPPP is considered and documented with MS4 staff responses and subsequent modifications to the SWPPP.	Yes or No

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

Activity description	Activity complete and available?
The SWPPP document identifies BMPs to detect and eliminate illicit discharges into the small MS4.	Yes or No
The SWPPP document identifies measurable goals for each BMP (e.g. number of staff trained, amount of pipe to be televised, or number of dry weather inspections completed) and timeframes and staff responsible for implementation.	Yes or No
Regulatory mechanism adopted to prohibit illicit discharges into your MS4.	Yes or No
Enforcement Response Procedures (ERPs) developed to compel compliance with the regulatory mechanism that prohibits illicit discharges into the MS4.	Yes or No
Illicit discharge detection is incorporated into all inspection and maintenance activities, including during dry weather.	Yes or No
Visual inspections are used to detect and track the source of illicit discharges.	Yes or No
Field staff are trained in illicit discharge recognition.	Yes or No
Priority areas likely to have illicit discharges and more frequent illicit discharge inspections are identified and the dates and locations of inspections documented.	Yes or No
Procedures for investigating, locating, and eliminating the source of illicit discharges has been developed and followed.	Yes or No
Procedures for responding to spills has been developed and followed.	Yes or No
Reports of alleged illicit discharges received are documented with dates of the reports and any follow-up actions taken.	Yes or No
Dates of discovery of all illicit discharges are documented with the following: location and the responsible party of illicit discharges, if known; and actions taken including dates to address discovered illicit discharges.	Yes or No

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

Activity description	Activity complete and available?
The SWPPP document identifies BMPs to develop and support the program that reduces pollutants in stormwater runoff to the small MS4 from construction activity.	Yes or No
The SWPPP document identifies measurable goals for each BMP (e.g. number of trained inspectors) and timeframes and staff responsible for implementation.	Yes or No
Regulatory mechanism has been adopted to address construction site stormwater runoff control.	Yes or No
Site plan review procedures have been developed and followed to ensure compliance with the construction site stormwater runoff control regulatory mechanism.	Yes or No
Site plan review procedures notify applicants of need to get coverage under the MPCA’s Construction Stormwater General Permit (Permit number MN R100001).	Yes or No
Written procedures have been developed for consideration of reports submitted by the public related to noncompliance or other stormwater related information at construction sites.	Yes or No
Construction Site Inspection procedures have been developed and followed. Procedures must include the following: prioritization criteria for sites to be inspected, a frequency for construction site inspections, and name/title of those conducting site inspections.	Yes or No
Construction site inspections are documented by checklists or other written means.	Yes or No
ERPs to compel compliance with the construction site stormwater runoff control regulatory mechanism has been developed.	Yes or No
Procedures for responding to spills has been developed and followed.	Yes or No
Site plan reviews of construction site stormwater runoff control are documented with stormwater related comments and supporting information.	Yes or No
Site plan reviewers and construction site inspectors are trained and the training is documented.	Yes or No

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

Activity description	Activity complete and available?
The SWPPP document identifies BMPs to develop and support the program that prevents or reduces water pollution after construction activity is completed.	Yes or No
The SWPPP document identifies measurable goals for each BMP (e.g. number of trained site plan reviewers) and timeframes and staff responsible for implementation.	Yes or No
Regulatory mechanism has been adopted to address post-construction storm water management.	Yes or No
Mitigation provisions have been developed for situations where total suspended solids (TSS) or total phosphorus (TP) standards for post-construction stormwater management cannot be met on site & documentation associated with mitigation projects is retained.	Yes or No
Legal mechanism for long-term operation and maintenance of structural stormwater BMPs has been developed.	Yes or No
Site plan review procedures to ensure compliance with the post-construction stormwater management regulatory mechanism have been developed and are followed.	Yes or No
Site plan reviews to determine compliance with the post-construction stormwater management regulatory mechanism are documented with the project name, location, owner and operator, and any checklists and calculations used to determine compliance.	Yes or No
ERP to compel compliance with the post-construction stormwater management regulatory mechanism has been developed.	Yes or No

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

Activity description	Activity complete and available?
The SWPPP document identifies BMPs to develop and support the program that prevents or reduces the discharge of pollutants from permittee owned/operated facilities and operations to the small MS4.	Yes or No
The SWPPP document identifies measurable goals for each BMP (e.g. train all staff annually or inspect 20% of outfalls per year) and timeframes and staff responsible for implementation.	Yes or No
Facilities inventory of municipally owned/operated facilities that contribute pollutants to stormwater has been created.	Yes or No
BMPs to prevent or reduce pollutants in stormwater discharges for facilities in the Facilities Inventory have been implemented.	Yes or No
BMPs for MS4 discharges that may affect Source Water Protection Areas have been implemented.	Yes or No
Procedures and schedule for determining TSS and TP treatment effectiveness of stormwater ponds has been developed.	Yes or No
Structural stormwater BMPs are inspected (including illicit discharge screening) annually and inspections are documented.	Yes or No
Stormwater ponds are inspected (including illicit discharge screening) at least once per term of the MS4 General Permit and inspections are documented.	Yes or No
Outfalls are inspected (including illicit discharge screening) at least one per term of the MS4 General Permit and inspections are documented.	Yes or No
Stockpiles and storage and material handling areas are inspected (including illicit discharge screening) quarterly and inspections are documented.	Yes or No
Maintenance is conducted and documented based on outfall, pond, structural stormwater BMP, stockpile, or storage and handling facility inspection findings.	Yes or No
Training program has been developed to train staff commensurate with their job duties. The training program must address the following: importance of protecting water quality, permit requirements relevant to job duties, and a schedule to train new and seasonal employees.	Yes or No
Pond sediment excavation and removal activities documented with the following: unique ID number of each stormwater pond, the volume of sediment removed, results from any testing of sediment from each removal activity, and location(s) of final disposal of excavated sediment.	Yes or No
Employee training is documented with a list of topics covered, names of employees in attendance, and the date of each event.	Yes or No

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?