Sewerage & Water Board of New Orleans

Transcription

1 Sewerage & Water Board of New Orleans What happens when EPA comes to town

2 Goals of Today Say what! We are being Audited by EPA No?fied two weeks in advance Where can I hide????? Records request It a big deal Meet with Co- permijees (we are happy now) Meet with EPA and all Co- permitees Audit and site inspec?on Exit interview Thank God that is over

3 Meeting with Co-Permittees to map out how we could get away (leave town)

4 Meeting with EPA and all of the Co-Permittees

5 EPA and the City of New Orleans

6 Records Requested: MS4 PROGRAM COMPLIANCE AUDIT RECORDS REQUEST FOR NEW ORLEANS SEWERAGE AND WATER BOARD MAY 6 & 9, 2013 Program Management 1. Stormwater Management Plan if available. 2. Program organizational chart and/or a description of the departments involved in the implementation of your MS4 program and their responsibilities. 3. Basic MS4 program financial/budget information, including stormwater fees & revenue (available during the audit). 4. Stormwater components of any city plans or ordinances, building permits, etc.

7 Industrial, Commercial and Municipal Operated Facilities 1. Current inventory of Type I and Type II industrial/commercial facilities discharging/ contributing pollutant loadings to the MS4, including facilities with LPDES individual or general stormwater permits. 2. Inventory of facilities with no exposure certification and date of last inspection at each facility. 3. Prioritization procedures for selecting Type I and Type II industrial and commercial facilities for inspection. 4. Tracking system for inspections of Type I and Type II industrial and commercial facilities. (An example page or screen shot can be provided during the audit).

8 1. Industrial/commercial facility stormwater inspection reports (May 2011 to present). 2. Industrial stormwater inspector training materials, standard operating procedures (SOPs) and/or checklists used in the field by the MS4 (available during the audit). 3. Any stormwater monitoring records for Type I and Type II industrial and commercial high-risk facilities including sampling locations, sampling dates, and analytical data. 4. Enforcement letters issued to Type I and Type II industrial/commercial facilities (May 2011 to present). 5. List of all municipal operated facilities (e.g., maintenance garages, landfills, wastewater treatment plants, school bus garages, etc.). 6. Stormwater inspection records for all municipal operated facilities to document pollution prevention/good housekeeping (May 2011 to present) (available during the audit)

9 1. Employee training programs and employee training records for municipal owned and operated facilities (available during the audit). 2. Controls implemented by the MS4 to reduce the discharge of pollutants from fertilizers, herbicides and pesticide storage and application on municipal owned properties (available during the audit). 3. Controls implemented by the MS4 to reduce the discharge of pollutants from roadways (available during the audit).

10 Construction 1. Local ordinance(s) for soil erosion and sediment control and other construction stormwater-related pollutant control. 2. Site plan and Best Management Practice (BMP) plan review checklists, guidelines, and/or SOPs (available during the audit). 3. Construction BMP Field Manual (available during the audit). 4. Inventory of active construction sites (public and private with location). 5. Date of last inspection for each active construction site. 6. Tracking system used for construction inspections (An example page or screen shot can be provided during the audit) 7. Construction site stormwater inspection records (May 2011 to current).

11 1. Enforcement letters/documentation sent to construction contractors or site operators (May 2011 to present) 2. Construction stormwater inspector training materials, SOPs and/or checklists used in the field (available during the audit). 3. All construction site files for one public construction project and one private construction project including all site plan review documentation, BMP plan review documentation, construction inspections, and follow up action documentation including enforcement actions if necessary (available during the audit). 4. Educational materials, LPDES construction permitting program responsibilities, and training given to construction site operators/contractors or building permit applicants (available during the audit).

12 New Development/Redevelopment Stormwater Management 1. Master plan for reducing stormwater pollutants following new development or redevelopment. 2. New development/redevelopment stormwater manual and design standards (available during the audit). 3. Inventory of new development/redevelopment structural controls and best management practices (BMPs) (public and private with location). 4. Tracking system used to manage inspection and maintenance of the structural controls and BMPs (An example page or screen shot can be provided during the audit). 5. New development/redevelopment structural stormwater controls and BMP inspection records (May 2011 to current). 6. Maintenance records for public owned stormwater structural controls and BMPs (available during the audit). 7. New development/redevelopment structural control systems and BMP inspector training guidelines, SOPs, and/or checklists (available during the audit).

13 Storm Drain System Mapping (available during the audit) 1. Storm drain system mapping tools, focusing on layers/mapping that informs the MS4 program activities (e.g., storm drain system, structural controls, outfalls, receiving waters, etc.). 2. Plan and schedule for mapping entire system (if not already complete).

14 Illicit Discharge Detection and Elimination 1. Ordinance/regulatory mechanism prohibiting non-stormwater discharges to the MS4. 2. Records of all dry weather field screening inspections (May 2011 to present). 3. Complete dry weather screening files for any outfalls, manholes, or inlets where water was found flowing from May 2011 to present, including sampling results and follow up action through resolution (available during the inspection). 4. Tracking system used to document dry-weather screening locations and to select future screening locations (An example page or screen shot can be provided during the inspection) 5. Inventory of potential or confirmed illicit discharges or incidents reported by citizens, city MS4 staff, and other city staff (i.e., Fire Department) and resolution (May 2011 to present).

15 1. Enforcement letters or documentation sent to individuals/facilities responsible for illicit discharges. 2. Dry weather screening training, guidelines, SOPs and/or checklists (available during the audit). 3. List of spills other than sanitary sewer overflows (SSOs) that entered the storm sewer system and associated emergency response (May 2011 to present). 4. List of SSO (May 2011 to present). 5. Procedures or SOPs for cleanup of SSO that reach the storm drains (available during the audit).

16 Public Education 1. Outreach materials to facilitate reporting of illicit discharges and improper disposal, including floatables into the storm sewer system (examples can be provided the audit). 2. Outreach materials to promote the proper use, application, and disposal of pesticides, and the proper management and disposal of automotive fluids (examples can be provided during the audit). 3. List of public events or other mechanisms where outreach materials were provided (May 2011 to present). * Note: In addition to the items requested, also provide any other documents or tools that you believe demonstrate program procedures, policies, strategies, development and/or effectiveness.

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