Phase II MS4 Evaluations: Requirements and Results

Transcription

1 Phase II MS4 Evaluations: Requirements and Results Presenters: Wayne T. Craney, P.E., ODEQ Carrie Evenson, Ph.D., ODEQ

2 Outline Background Information and Permitting in Oklahoma Minimum Control Measures MS4 Program Evaluations Things to Consider Recommendations Questions and Discussion

3 Background Information Delegation of NPDES Programs to ODEQ November 19, 1996 Permitting and enforcement of municipal and industrial wastewater September 9, 1997 Stormwater discharges associated with construction and industrial sites Industrial pretreatment

4 Oklahoma s MS4 Permits Phase I (2 permittees) Individual permits City of Oklahoma City City of Tulsa Phase II (43 permittees) General permit 34 Cities 5 Counties 4 Non-Traditional Entities

5 Oklahoma s Phase I MS4 Permits Individual Permits Oklahoma City first issued September 1, 1995 Tulsa first issued April 1, 1997 Both are co-permittees with ODOT and OTA Pollution Prevention Approach Stormwater Management Program (SWMP) Developed by MS4 Spells out how MS4 will address/manage stormwater discharges

6 Oklahoma s Phase II MS4 Permits General Permit, OKR04 Effective February 8, 2005 Pollution prevention approach Uses SWMP Must address six minimum control measures Select BMPs Identify Measurable Goals Evaluate effectiveness Update SWMP

7 Minimum Control Measures MCM #1: Public Education and Outreach Distribution of information and educational materials or performance of equivalent outreach Audience: Community served by MS4 Common mechanisms: brochures, utility bill inserts, websites, school presentations or activities Other mechanisms: videos or other information on cable access channels, community events, newspaper ads, training events, creek signage

8 Minimum Control Measures MCM #2: Public Involvement/Participation Inclusion of the public in stormwater-related activities and development of SWMP Audience: Community served by MS4 Common mechanisms: website, Mayor/City Action Line, open public meetings Other mechanisms: Citizen representation on city taskforces or panels, volunteer activities

9 Minimum Control Measures MCM #3: Illicit Discharge Detection and Elimination Identification and elimination of unapproved non-stormwater discharges to the MS4 Includes a dry weather field screening component and storm sewer map Identification of outfalls Must educate the public on hazards of illicit discharges Audience: Community served by MS4

10 Minimum Control Measures MCM #4: Construction Site Stormwater Runoff Control Development and implementation of a program to reduce pollution from construction sites Includes plan review, inspection, and enforcement programs Audience: Construction site operators Optional MCM 7: Municipal construction projects covered by MS4 general permit

11 Minimum Control Measures MCM #5: Post-Construction Stormwater Management in New Development and Redevelopment Development and implementation of a program to address stormwater runoff from new and redevelopment projects Audience: Community served by MS4 Common mechanisms: structural and nonstructural BMPs (i.e. rain gardens and barrels, preserving open space, etc)

12 Minimum Control Measures MCM #6: Pollution Prevention/Good Housekeeping for Municipal Operations Development of an MS4-wide operation, maintenance and training program for MS4 personnel Audience: MS4 personnel Common mechanisms: Employee training using MCM #1 materials, on-the-job training, and seminars; municipal facility inspections; street sweeping; catch basin cleaning; pet waste stations in parks and common areas

13 MS4 Program Evaluations Goals Develop productive, cooperative working relationship with stormwater managers/city officials Determine status of program development and implementation Evaluate staff s knowledge of and vision for the future of the MS4 program Provide technical assistance Use available staff and resources wisely

14 MS4 Program Evaluations 2006 First Phase I MS4 audited by ODEQ 2007 EPA MS4 Evaluation Guide released First Phase II MS4 audit conducted by ODEQ Second Phase I MS4 audit conducted by ODEQ 2008 Phase II MS4 Screening Evaluation procedures developed and used by ODEQ in 2 municipalities No site visits or inspections

15 MS4 Program Evaluations 2009 Screening evaluations used for all remaining Phase II MS4s Field visits included to allow ODEQ inspectors to evaluate MS4 personnel 2010 and 2011 Screening evaluations continued 2012 Screening evaluations completed

16 MS4 Program Evaluations Phase II Screening Evaluations Process: Three-person evaluation team Team leader is alternated No back-to-back assignments Allows team leader to complete report before beginning next evaluation Direct interview and records review with stormwater manager/staff/city officials

17 Pre-Evaluation Preparation MS4 Stormwater Manager Contacted Time and location arranged Copy of checklist provided Checklist can be modified to fit special conditions/requirements Information Requested SWMP Annual report List of municipal, industrial, and construction SW sites with previous enforcement history

18 Pre-Evaluation Preparation Documents Reviewed Divide and conquer approach Notes taken Supplemental questions prepared Agenda Prepared Combined field work and document review Appropriate MCM reviewed prior to conducting field work

19 During Evaluation Have necessary documents and forms available Document log kept as evaluation proceeds Preprinted document labels used to keep things organized Name of MS4: Permit No.: _OKR04 Relevant MCM: Document No.: Evaluation Date:

20 During Evaluation Interview with Stormwater Manager and Appropriate MS4 Staff Opening meetings conducted each morning to direct day s activities MS4 staff should be directly responsible for permit requirement or briefed by responsible party Phone availability is helpful

21 Field Activities Evaluation worksheets used Interaction between MS4 staff, other City departments, and regulated community observed Multiple inspection teams used if more than one MS4 inspector is available Sites selected in each inspector s area

22 Exit Interview Have Mayor, Public Works Director, and/or other responsible official present, if possible Arranged ahead of time to ensure availability Time to review notes and prepare findings included in evaluation agenda The Goal = No Surprises!!

23 Things to Consider: MCMs #1 & 2: Tracking and documentation Implementation of other strategies beyond brochures Utilization of MS4 websites Citizen comments/complaints system Evaluation of BMP effectiveness

24 Things to Consider: MCM #3: Tracking and documentation Ordinances Determine existence and strength of requirements Definition and identification of outfalls Dry weather field screening Identification of the source of illicit discharges Visual or analytical methods

25 Things to Consider: MCM #4: Tracking and documentation Inspections Who conducts them? How well have they been trained in stormwater issues? Checklists and forms Have they been developed? Are they being used? Where are they being kept/stored/filed? Aids in consistency for plan review and site inspections

26 Things to Consider : MCM #5: Least developed MCM Often limited to flood control measures Ordinances Determine existence and strength of requirements Changing status quo is often difficult What resources are available locally? Are there examples in private developments or other MS4s?

27 Things to Consider : MCM #6: Municipal facilities can be a problem area Some have excelled; most need work Permit coverage at WWTPs Operation and maintenance plans Inspections Spoils disposal from street sweeping and catch basin cleaning Availability of spill kits

28 Things to Consider: Optional MCM #7 If elected, it must be executed MS4 becomes control authority Is the MS4 able to enforce requirements on MS4- owned projects? Tracking and documentation SWP3s Inspections BMP installation

29 Things to Consider: Annual Reports Executive summary Does it highlight MS4 s achievements? Most only address the basic BMPs Many could use more information on related activities beyond the BMPs Numbers are helpful Inspections conducted, enforcement actions taken, permits issued, brochures distributed, municipal construction projects underway

30 Recommendations Procedural Highly labor intensive Requires extreme attention to detail and organization Programmatic MS4s often not reporting all activities conducted limited to permit requirements Methods to document pollutant removal/pollution reduction amounts need to be developed

31 Recommendations Review SWMP and Annual Report prior to evaluation Is MS4 meeting BMP schedule in SWMP and reporting accomplishments in AR? Have key personnel available in person or by phone Find out where program documentation is kept and who tracks it Have that person available during the evaluation process

32 Recommendations Recognize that program may involve more than a BMP list Take credit for all stormwater-related activities conducted by the MS4 Be prepared to make lots of copies We Remember: documentation! Preparation + Opportunity = Success

33 Wayne s Words of Wisdom MS4s have unique personalities, like individuals. Are all different Have shared responsibilities, especially for enforcement We encourage MS4s to meet goals We encourage MS4s to improve/innovate If needed, use Trust but Verify approach

34 Questions, Comments, Discussion