Assessing total suspended sediment and total phosphorus removal efficiency of permittee owned/operated constructed stormwater ponds Revision as of 21:46, 16 November 2020 by Mtrojan (talk | contribs) (→Limitation of MPCA Stormwater Pond Design Criteria Methodology)
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This page provides guidance related to assessing the total suspended sediment (TSS) and total phosphorus (TP) removal efficiency of permittee owned/operated ponds constructed and used for the collection and treatment of stormwater. Four (4) evaluation strategies are discussed.
- Evaluation of Minnesota Pollution Control Agency (MPCA) stormwater pond design criteria
- Stormwater pond inspection/assessment
- Stormwater pond pollutant removal modeling
- Stormwater pond water quality monitoring
The TSS and TP removal efficiency of constructed stormwater ponds degrades over time due to the loss of storage volume to sedimentation and/or sediment phosphorus release. For this reason, it is critical that stormwater ponds be sized correctly for their contributing drainage area and that pond inspection and assessments be performed routinely to monitor sedimentation and identify potential maintenance needs. In addition to evaluating pollutant removal efficiency through comparison to design standards and evaluation of sedimentation, the water quality performance of stormwater ponds can be evaluated using various water quality modeling programs or measured directly through water quality monitoring.
Guidance presented will assist MS4s (Municipal Separate Storm Sewer System) evaluate the TSS and TP treatment effectiveness of ponds post-construction and over their design life. The adjacent table provides a summary of the four (4) TSS and TP removal efficiency evaluation strategies discussed within this memorandum.
TSS and TP Removal Efficiency Evaluation Strategies
Link to this table
| Pollutant Removal Assessment Strategy | Description | Relative effort | Relative accuracy |
|---|---|---|---|
| Evaluation of MPCA stormwater pond design criteria | Evaluation of pond sizing criteria against MPCA stormwater pond design standards to produce a relative evaluation of pond performance | Low | Low |
| Stormwater pond inspection/assessment | Guidance related to scheduling and performing routing visual inspections and less-frequent assessments of pond sedimentation depth | Medium/high | NA1 |
| Stormwater pond pollutant removal modeling | Evaluation of the pollutant reduction achieved by stormwater ponds through the use of empirically-based or physically-based water quality models | Low/medium | Medium |
| Stormwater pond water quality monitoring | Evaluation of the pollutant reduction achieved by stormwater ponds through direct monitoring of pollutant concentrations into and leaving the pond | High | High |
1Stormwater pond inspection/assessment does not inherently provide an estimate of TSS/TP removal. However, inspection/assessment efforts are critical to ensuring a stormwater pond is performing as originally designed.
Contents
Evaluation of MPCA Stormwater Pond Design Criteria
The MPCA Minnesota Stormwater Manual contains detailed design criteria for many water quality best management practices (BMPs), including constructed stormwater ponds. In addition to outlining construction stormwater pond requirements stipulated by the MPCA Construction General Permit (CGP), the Minnesota Stormwater Manual’s Design Criteria for Stormwater Ponds contains guidance and recommendations related to many aspects of stormwater pond design and construction, from grading and site layout, to overflow spillway design and development of a landscaping plan. Although guidance within the Design Criteria for Stormwater Ponds is primarily focused on requirements related to construction of design of stormwater ponds for new development, elements within the guidance related to sizing of the pond permanent pool volume and live storage water quality volume can be used to evaluate (a) the impact of sedimentation over time and (b) the impact of development and changing land use over time on the water quality performance of existing stormwater ponds. The following subsections outline how design criteria can be used to evaluate the water quality treatment efficiency of existing stormwater ponds and how design criteria can be used to estimate pollutant load reduction.
Estimating Water Quality Performance of Existing Stormwater Ponds
As discussed in Section 2.0, the Minnesota Stormwater Manual’s Design Criteria for Stormwater Ponds contains guidance and requirements related to the sizing of pond permanent pool volume (Vpp) and live storage water quality volume (Vwq). As defined by the Minnesota Stormwater Manual, the permanent pool (aka, “dead storage”) is the volume of water below the pond outlet, and the water quality volume (aka, “live storage”) is the storage volume between the pond outlet and the pond overflow elevation as shown in Figure 1.
The Minnesota Stormwater Manual’s Design Criteria for Stormwater Ponds outlines minimum requirements for permanent pool volume (Vpp) and water quality volume (Vwq) as outlined by the CGP. Narrative descriptions and resulting equations used to evaluate minimum volume required are outlined below.
The Required minimum permanent pool volume, or dead storage (Vpp), below the outlet elevation), is 1800 cubic feet of storage below the outlet pipe for each acre that drains to the pond
\(V_{pp} = 1800A\)
where
- A = the drainage area of the stormwater pond (acres)
or
\(V_{pp} = 0.0417 A \)
where
- A = the drainage area of the stormwater pond (square feet)
The equations and definitions, above, were created for designing and constructing a stormwater pond to treat runoff from new development. Existing stormwater ponds may have larger Vpp than the minimum required by the CGP, or may have larger or smaller Vwq than required. To estimate the water quality performance of existing stormwater ponds, methodology outlined in the Minnesota Stormwater Manual’s MIDS Calculator documentation for stormwater ponds requires the user to evaluate the tributary area to the pond and volume dimension of the pond to determine the “design level” (e.g., Design Level 2) of the pond, and recommends assumed pollutant removal efficiency values based on the design level (e.g., 84% TSS removal for Design Level 2). Criteria for each MIDS stormwater pond design level are summarized in Table 2.
MIDS Calculator stormwater pond design level criteria related to pond volume
Link to this table
| MIDS Stormwater Pond Design Level1 | Permanent Pool Volume (Vpp), ft3 | Water Quality Volume (Vwq), ft3 | Pollutant reduction (%)2 | |||
|---|---|---|---|---|---|---|
| TSS | TP | PP | DP | |||
| Design Level 1 | ≥ 1,800 ft3 per acre of tributary area | <= 1 inch from impervious area | 60 | 34 | 62 | 0 |
| Design Level 2 | <= 1 inch from impervious area | 84 | 50 | 84 | 8 | |
| Design Level 3 | <= 1.5 inch from impervious area | 90 | 60 | 90 | 23 | |
1From MIDS Calculator documentation for stormwater ponds. Note: the table summarizes design-level criteria related to permanent pool volume and water quality volume. The complete list of criteria for each design level is summarized on the MIDS calculator
website linked above.
2 TSS = total suspended solids; TP = total phosphorus; PP = particulate phosphorus; and DP = dissolved phosphorus. Pollutant
reduction values cited assume no upstream treatment within tributary area to pond (i.e., untreated urban runoff).
Steps for summarizing the estimating water quality performance of existing stormwater ponds using methodology outlined in the Minnesota Stormwater Manual’s Design Criteria for Stormwater Ponds and MIDS Calculator documentation for stormwater ponds are outlined, below.
1) Determine the permanent pool volume (Vpp) of the pond – the VPP can be determined through a number of sources, including record drawings, as-builts, and bathymetric survey. Note: before using record drawing or as-built data, a pond assessment (Section 3.0) should be conducted to determine the extent to which sedimentation has reduced the Vpp. If estimating volume from bathymetric contour data, the following equation can be used to calculate volume between any two bathymetric contours. The total bathymetric volume can then be calculated by summing the volume between all available bathymetric contours
\( 𝑽_{𝟏−𝟐} = (𝑨_𝟏 + 𝑨_𝟐)/2 × (𝑬_𝟐 − 𝑬_𝟏) \)
Where,
- V1-2 = the volume between contours 1 and 2;
- A1 and A2 = the area of contours 1 and 2, respectively; and
- E1 and E2 = the elevation of contours 1 and 2, respectively
After calculating the volume between each bathymetric contour, the total bathymetric volume can be calculated by summing the volume calculated between each set of contours
\( ∑ 𝑽_𝒊 = (𝑨_{𝒏+𝟏} + 𝑨_n)/𝟐 × (𝑬_{𝒏+𝟏} − 𝑬_𝒏) \)
If only the area at the bottom of the pond (App) and the area at the permanent pool of the pond (Abot) is known, the bathymetric volume can be calculated using the simplified equation
\( ∑ 𝑽_{bathymetric} = (𝑨_{pp} + 𝑨_{bot})/𝟐 × (𝑬_{pp} − 𝑬_{bot}) \)
Where
- Vbathymetric = bathymetric volume;
- App = area at the permanent pool of the pond;
- Abot = area at the bottom of the pond;
- Epp = elevation at the bottom of the pond; and
- Ebot = elevation of the bottom of the pond.
2) Determine the water quality volume (Vwq) of the pond – as shown in Figure 1, the Vwq is the volume between the ponds permanent pool and the natural or designed overflow elevation. The Vwq can be determined through a number of sources, including record drawings, as-builts, survey data, and surface LiDAR data. A rough estimate of Vwq can be calculated by determining the permanent pool area and the area at the natural or designed overflow elevations. Equation 3, above, can then be used using these two elevations and areas.
3) Evaluate the Vpp of the pond – determine the CGP required Vpp based on the total drainage area to the stormwater pond using Equation 1, above (i.e., 1,800 ft3 per acre of drainage area). If the Vpp is greater than 1,800 ft3, proceed to step 4. If the Vpp of the pond is less than 1,800 ft3 per acre of drainage area, guidance within the Minnesota Stormwater Manual suggests that the pond should not be included in site pollutant removal calculations, as the pond is unlikely to provide adequate treatment. To estimate the water quality performance of a stormwater pond not meeting minimum Vpp requirements, calculations in the following steps can proceed by using only the area for which the Vpp is sized to adequately treat (i.e., Vpp ÷ 1,800 ft3 /acre = treated area (acres)). The remaining portion of the total drainage area to the pond would then be assumed to bypass (i.e., 0% treatment). Alternatively, water quality performance of undersized stormwater ponds can be evaluated through modeling (Section 4.0) or monitoring (Section 5.0).
4) Evaluate the tributary impervious area to the pond – for small sites (e.g., developments less than two acres, etc.), impervious area can be determined through manual evaluation of site impervious cover from record drawings or site plans. For larger drainage stormwater ponds with larger drainage areas (e.g. regional stormwater ponds with drainage areas greater than five acres), land use datasets can be used to estimate total impervious area within the ponds drainage area. The Minnesota Geospatial Information Office (MnGeo) maintains a database of current and historic land use which can be used to evaluate land use and estimate impervious area. Additionally, the University of Minnesota (UMN) provides land cover and impervious data at varying resolution statewide and for specific regions throughout Minnesota (e.g. Twin Cities Metro, Duluth, Rochester, etc.).
5) Determine the impervious area treatment depth in the pond Vwq – using the pond Vwq (Step 2) tributary impervious area (step 4), calculate the impervious area treatment depth using Equation 4, below. Note: Equation 4 is the same as Equation 2 but rearranged to calculate the impervious area treatment depth provided by the pond Vwq.
\( 𝑫_𝒊 = 𝑽_𝒘 𝑨_𝒊 × 𝟏_{𝒊𝒇} \)
Where
- Dimp = impervious area treatment depth (inch);
- Vwq = water quality volume in cubic feet (ft3); and
- Aimp = tributary impervious area (ft2).
6) Determine the MIDS pond design level and corresponding pollutant reduction (%) – after confirming the Vpp is greater than 1,800 ft3 per tributary acre (Step 3) and determining the impervious area treatment depth in the Vwq (Step 5), reference Table 2 to determine the MIDS pond design level (e.g., Design Level 2) and corresponding pollutant reduction (e.g. 84% TSS reduction). Note: pollutant reduction values (%) included in Table 2 assume no upstream water quality BMPs in the tributary area to the stormwater pond (i.e., untreated stormwater runoff). If BMPs within the watershed to the stormwater pond provide significant treatment (e.g., 50% of the tributary area passes through a large infiltration basin before discharging to the stormwater pond), water quality performance should instead be evaluated through modeling (Section 4.0) or monitoring (Section 5.0).
7) Determine influent pollutant loading and pollutant load reduction (lbs) – after determining the pond level design pollutant removal efficiency (%) from Table 2, annual pollutant mass removal (e.g., pounds to TSS removal per year) can be determined by applying the pollutant removal efficiency (%) to the annual influent pollutant mass load. Methodology for determining the annual influent pollutant mass load to the stormwater pond and calculating the pollutant mass removal within the stormwater pond is discussed in Section 2.2.
Estimating Annual Pollutant Load Reduction Existing Stormwater Ponds
To estimate the pollutant mass reduction (e.g., pounds of TSS removal per year) in an existing stormwater pond, it is first critical to determine the annual pollutant mass load from the tributary watershed to the stormwater pond. One method of estimating annual pollutant export associated with runoff from a watershed is the Simple Method (Schueler, 1987; CWP & CSN, 2008). The Simple Method is utilized by many annualized water quality models (e.g., the MPCA Simple Estimator spreadsheet model, see Section 4.0) and is a recommended method for calculating credits for stormwater ponds in the Minnesota Stormwater Manual. The Simple Method equation is shown below (Equation 5), followed by steps for determining Simple Method parameter inputs, calculating annual pollutant loading, and calculating annual pollutant reduction
\( 𝑳_{annual} = 𝟎.𝟐 × 𝑨 × 𝑷 × 𝑷_𝒋 × 𝑹_𝒗 × 𝑬MC_{𝒑ollutant} \)
Where
- Lannual = annual pollutant load to the stormwater pond (e.g., pounds of TSS per year, lbs TSS/yr);
- A = drainage area to stormwater pond (acres);
- P = annual precipitation depth (in);
Pj = fraction of rainfall events that produce runoff (default value of 0.9);
- Rv = runoff coefficient (see discussion in Step 1, below);
- EMCpollutant = the flow-weighted event mean concentration (EMC) of pollutant in runoff (mg/L, see discussion in Step 1, below); and
- 0.227 = unit conversion factor.
1) Determine Simple Method input parameters – the following defines each Simple Method input parameter and provides a summary of how to determine or estimate each parameter:
- Drainage Area (A) – the total drainage area to the pond (acres).
- Annual Precipitation (P) – annual average precipitation depth (inches). Can be determined from local long-term rainfall records (e.g., 10-year average precipitation from local airport).
Note: average annual precipitation depth within the state of Minnesota by zip code can be determined using the MIDS Calculator.
- Rainfall Fraction (Pj) – fraction of rainfall events which produce runoff (unitless). This Simple Method assumes some fraction of annual rainfall is delivered in small, low-intensity rainfall events that do not produce runoff. Typically, a PJ value of 0.9 is assumed.
- Runoff Coefficient (Rv) – the runoff coefficient is the fraction of annual rainfall that is converted into runoff. Runoff coefficient can be calculated as a function of site impervious area using the equation, below. Note: a description of how to determine site impervious area
and impervious fraction is provided in Section 2.1, Step 4. Alternatively, the area-weighted watershed Rv value can be calculated using the land use-based Rv values from the MPCA Simple Estimator shown in Table 3.
\( 𝑹_𝒗 = 𝟎.𝟎5 + 𝟎𝟎9 × 𝑰 \)
Where,
- I = impervious area percentage (i.e., if 75% impervious, I = 75).
- Pollutant Concentration (EMCpollutant) – the flow-weighted average pollutant EMC (mg/L). Because localized monitoring of runoff pollutant EMCs is typically not available, standard literature values for pollutant EMC can be used to estimate pollutant loading. The MIDS Calculator suggests typical urban runoff EMC values of 54.5 mg/L and 0.3 mg /L for TSS and TP, respectively. Land used based EMC values from the MPCA Simple Estimator can be used to calculate a land use-based area weighted TSS and TP EMC based on land use within the drainage area to the stormwater pond. These values are based on an extensive literature review.
MPCA Simple Estimator: Rv, TSS EMC, and TP EMC Values for Land Use Types
Link to this table
| Land use | Runoff coefficient (Rv)1 | Event mean concentration (EMC)(mg/L) | |
|---|---|---|---|
| Total phosphorus (TP) | Total suspended solids (TSS) | ||
| Commercial | 0.8 | 0.200 | 75 |
| Industrial | 0.8 | 0.235 | 93 |
| Institutional | 0.75 | 0.25 | 80 |
| Mixed use | 0.5 | 0.290 | 76 |
| Open space | 0.2 | 0.190 | 21 |
| Residential | 0.4 | 0.325 | 73 |
| Transportation | 0.8 | 0.280 | 87 |
1Runoff coefficients vary with soil and slope. Link here
2) Calculate annual pollutant load reduction – after calculating the annual pollutant loading to the stormwater pond (Step 1), the stormwater pond annual pollutant mass load reduction (e.g., pounds of TSS removed per year) can be calculated using the equation, below
\( 𝑹_{annual} = 𝑳_{annual} × 𝑷R_{pollutant} \)
Where, Rannual = annual pollutant load reduction (e.g. pounds of TSS removed per year, lbs TSS/yr); Lannual = annual pollutant load to the stormwater pond (e.g., pounds of TSS per year, lbs TSS/yr); and PRpollutant = pollutant reduction efficiency of the stormwater pond (%). Note: determination of pollutant reduction efficiency is discussed in Section 2.1.
Limitation of MPCA Stormwater Pond Design Criteria Methodology
The MPCA stormwater pond design criteria described in Section 2.0 is a simplified methodology used to provide an estimate of stormwater pond water quality performance when other, more accurate methods (see methods listed in Table 1) are not feasible. The following list summarizes limitations of the MPCA stormwater pond design criteria methodology:
- Input sensitivity: because the methodology produces an annualized estimate of pollutant reduction, input assumptions can have a significant impact on pollutant reduction calculations. For example, assumed TSS pollutant event mean concentrations from Table 3 could impact TSS influent loading by ± 100%. For this reason, input parameters should be carefully evaluated based on site-specific and best-available information. The methodology is especially sensitive to the following parameters:
- Directly connected imperious fraction (Section 2.1);
- Pollutant event mean concentration (Section 2.2); and
- Water quality and permanent pool volume of the pond (Section 2.1).
- Upstream treatment: this methodology assumes no water quality treatment in the tributary area to the stormwater pond. Because upstream, tributary BMPs have the potential to impact the pollutant loading and pollutant particle scale distribution, this methodology should not be used for stormwater ponds with significant upstream water quality treatment.
- In-pond dynamics: this methodology does not account for in-pond dynamics such as:
- Internal phosphorus loading (i.e., the release of bound phosphorus from pond sediment);
- Sediment resuspension (i.e., scour of previously-settled sediment during large inflow events);
- Inlet/outlet short-circuiting (i.e., inlet flow moving directly to outlet, limiting the flow detention time);
- Macrophyte growth (i.e., the growth and life cycle of aquatic plants and algae).
Stormwater Pond Inspection and Assessment
As discussed in Section 1.0, the pollutant removal efficiency of constructed stormwater ponds degrades over time due to the loss of storage volume to sedimentation. Additionally, routine maintenance issues (e.g., pond outlet trash rack clogged with debris after storm; sand bar formation at inlet(s); etc.) can significantly reduce the hydraulic and water quality performance of stormwater ponds. For this reason, the municipal separate storm sewer system (MS4) General Permit requires permittees to: a) Perform routine visual inspection of structural BMPs (i.e., inspection), and b) Develop procedures and a schedule to determining the total suspended solids (TSS) and total phosphorus (TP) treatment effectiveness of all municipally owned/operated stormwater ponds (i.e., assessment) (MS4 General Permit Part III.D.6.), including evaluation of sedimentation.
For the purposes of evaluating the pollutant removal efficiency of stormwater ponds, “inspection” is defined as all components of routine visual inspection (Section 3.1). This typically involves walking the pond perimeter, inspecting outlets, and looking for signs of sedimentation and potential maintenance needs (e.g., clogged outlet).
A stormwater pond “assessment” encompasses all activities related to determining the total suspended solids (TSS) and total phosphorus (TP) treatment effectiveness of permittee owned and operated stormwater ponds (Section 3.2). As outlined by the MS4 General Permit, this involves developing procedures to evaluate TSS and TP treatment effectiveness, including development of a schedule for completing assessments of all municipal owned and operated stormwater ponds. Because the pollutant removal efficiency of a stormwater pond can be reduced as permanent pool volume is lost to sedimentation, a pond assessment should include an evaluation of sediment accumulation within the pond. Guidance in Sections 2.0, 4.0, and 5.0 provides methods for estimating, modeling, and directly monitoring the TSS and TP removal efficiency of ponds, respectively, but do not provide guidance on evaluating the permanent pool volume lost to sedimentation. For this reason, the assessment subsection (Section 3.2) provides guidance on how to estimate and directly measure sedimentation volume.
The following subsections provide guidance and recommendations related to the development of inspection and assessment procedures for stormwater ponds.
Inspection
Although the MS4 General Permit requires annual inspection of structural BMPs (Part III.D.E), the permit makes special exception for stormwater ponds, requiring only one (1) inspection of all ponds and outfalls prior to the expiration date of the permit. Due to critical hydraulic, water quality, and flood protection functions of stormwater ponds, it is recommended that inspection plans be developed to ensure that that:
1) Visual inspection of all municipal stormwater ponds and associated inlets and outlets occurs at least once per year; and that 2) Additional visual inspections are performed as needed in response to large storms (e.g., a rainfall event greater than 2 inches).
Visual Inspection SOP and Checklist
Developing a visual inspection standard operating procedure (SOP) for stormwater ponds is critical for ensuring that visual inspections are carried out in a standardized and repeatable fashion. Standardization allows results of inspections from different ponds to be compared to assess relative priority of inspection and maintenance needs, and repeatability allows results of inspections of the same pond to be tracked year to year to evaluate how condition of the stormwater pond has changed. In addition to allowing for evaluation of inspection prioritization (discussed further in Section 3.1.2), an inspection SOP checklist also increases the efficiency and effectiveness of inspectors / municipal operators while performing routing visual inspections.
Although there are many examples for visual inspection SOP checklists which can be used as templates for designing a stormwater pond inspection SOP (see example in Appendix A), it is recommended that an individual use these documents as templates and revise as needed based on conditions within the MS4 (e.g., number of stormwater ponds managed, staff availability and skills, etc.). The following list outlines specific recommendations that should be included or considered in the development of a visual inspection SOP for stormwater ponds:
- Electronic documentation: tracking inspection electronically, rather than relying on paper files, allows for more efficient analysis / tracking of pond inspections. If tracked with paper files in field, include instructions to scan and enter notes electronically within one (1) day of completing inspection. If possible, consider tracking inspection notes electronically in field using a laptop or tablet.
- Quantitative metrics: whenever possible, include quantitative (i.e., numerical) metrics, as being quantitative allows for tracking of maintenance needs over time and relative comparison of maintenance needs between ponds. For example, if including a checklist item for outlet clogging consider using a numerical scale (e.g., “Is the outlet clogged? Rate 1-5, where 1 indicates 0% clogged, and 5 indicates ≥ 90% clogged).
- Photo documentation: include photos of site in visual inspection protocol. As needed, be instructive regarding photos (e.g., “include photograph of inlet #1, inlet #2, pond outlet structure, and emergency overflow berm”). Photos can be useful in tracking evolving conditions over time (e.g. formation of sand bar near pond inlet).
- Immediate action protocols: include protocols / instructions for addressing maintenance needs requiring immediate action (e.g., blocked/obstructed inlet, pipe failure, etc.).
- Infrastructure inventory: include record drawing (e.g., as-built, aerial imagery with locations circled, sketch, etc.) for each pond indicating where critical infrastructure is located (e.g., inlets, outlets).
- Field staking / marking / GPS coordinates: include instructions related to field marking e.g., place stake with orange ribbon to indicate inlet, orange spray paint to indicate structure damage such as joint operation, etc.) and/or recording the GPS coordinates of critical structures. This can greatly increase efficiency of maintenance and future site inspections.
- Visual inspection of sedimentation: include instructions to evaluate visual signs of sedimentation (e.g., formation of sand bars in pond, bank and channel erosion, bank failure, outlet silted in / buried, etc.). Direct assessment / measurement of pond sedimentation is
typically not conducted during routine visual assessment, but signs of sedimentation/changes in sedimentation observed during visual inspection can indicate need to perform an assessment of pond sedimentation (Section 3.2).
- Visual inspection for short-circuiting: include instructions to evaluate proximity of inlets to outlets. If inlets are located near to outlets, flow into the pond can “short-circuit” directly to the outlet, allowing for little residence time and sedimentation of influent particles, greatly reducing pollutant removal efficiency from the affected inlet(s). If short-circuiting is occurring, inlets may be realigned or baffles may be installed to prevent bypass of pollutants.
An example of a stormwater pond visual inspection SOP checklist from the EPA’s Stormwater Wet Pond and Wetland Management Guidebook (USEPA, 2019) is included in Appendix A. In addition to providing a detailed inspection checklist, the guidebook outlines detailed recommendations related to recommended frequency of pond inspection and maintenance. Adapted from the guidebook (USEPA, 2019), Table 5 and Table 6 outline the inspection operator skill level required and recommended frequency for various inspection tasks. Note: some inspection tasks outlined in Table 6 are in excess of the once annual visual inspection recommendation outlined in this memorandum, and are included to provide context and frequency recommendations for a wide range of inspection actions which should be considered based on factors unique to the MS4 (e.g., number of ponds managed, staff availability and qualifications, etc.) when developing a stormwater pond inspection SOP.