EPA MS4 AUDIT Minnesota Experience

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EPA MS4 AUDITMinnesota Experience

• Frank Pafko
• Director, Office of Environmental Stewardship
• MN Department of Transportation

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• MINNESOTA

• One General MS4 Permit applies to entire state
• MnDOT SWPPPs Greater MN and Metro District
• Metro MS4 was audited 1st DOT in EPA Region V
• Urbanized portions of 8 Counties
• Population of 2 Million
• 40,000 acres of R/W
• 3950 lane miles of state trunk highway
• 1200 bridges

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EPA Audit of Metros MS4 Program

• Three Fun Filled Days

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• 90-Day Notice of Audit

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• Questions that EPA Will Ask

• What are you doing?
• What guidelines, policy training do you follow?
• How do you plan/ prepare for what you do?
• How do you track what you do?

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Audit Itself

• 3 from EPA, 4 MPCA and 2 EPA consultants.
• Spent ½ day going over material in office, ½ day
  in field for 3 days. Lots of extra time after
  they left pulling more materials and prep for
  next day.
• 2 teams for field review one focused on
  construction the other on maintenance.
• Full access to our facilities, projects and
  people.

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• AUDIT FINDINGS Potential Violations

1. Outreach strategy lacked specific targets goals
2. Illicit Discharge procedures incomplete
3. Storm sewer mapping incomplete
4. No written procedures site inspection/enforcement
   
5. Structural control inspections less than 20 /
   year
6. Facility Storm Water Plans not up-to-date
7. Training needed for maintenance personnel

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• 1. The Metro district did not include specific
  target audiences and goals as part of its written
  outreach strategy

• Disagreed with the finding
• Target audiences, goals outreach strategies
  clearly listed in MS4 SWPPP
• Pointed out errors in report

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• 2. Metro Districts procedures for observing
  outfalls to screen for improper discharges do not
  include a method to rule out suspect flows

• Disagreed with the finding
• Developed procedures to fit the needs of the
  permittee, rather than prescriptive, one size
  fits all approach.
• Pointed out errors in report

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• 3. Storm Sewer Mapping Incomplete

• Disagreed with finding
• Permit does not define the map, only the data
  points that must be represented
• Five datasets contain more than required info
• Moving to comprehensive GIS map (GeoCortex)
• Pointed out errors in report
• Ditches flow direction
• Ultimate receiving water

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• 4. Metro District had not developed written
  procedures for site inspection and enforcement of
  control measures

• Formalized our procedures for construction
  erosion control oversight inspections
• Pilot project started in August 2011, using
  incentives rather than just penalties
• Focused training use of withholdings
• Pointed out errors in report

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• 5.Metro District needs to ensure that 20 of all
  structural controls are inspected each year

• Disagreed with finding
• Inspection season April November
• 3 months remain to inspect 87 ponds
• Added truck station ponds to inventory
• Tree and brush removal around ponds
• EPA wanted all removed
• Undertook selective removal

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• 6. Metro District Facility Storm Water Plans
  (FSWP) are not reflective of current site
  conditions and have not been fully implemented

• Created Metro Maintenance Stormwater Committee
• Revised FSWPs
• Established main contact for each facility
• Water Resource Engineering involvement in all
  facility upgrades

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• 7. Need for training on pollution prevention and
  FSWP Plans for truck station and fleet
  maintenance staff

• Corrected deficiency
• 526 maintenance personnel trained
• Completed by February 9, 2011

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• EPA Acknowledged Positive Attributes

• MS4 SWPPP covers entire Metro District
• Dedicated MS4 Metro Construction Engineer
• Monetary penalty for unresponsive contractors
• Minnesota Snow Ice Control Field handbook for
  Snow Plow Operators
• Research into treatment capabilities

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Conclusions

• DOCUMENTATION, DOCUMENTATION, DOCUMENTATION
• How to get people on board?
• Build relationships.
• Never enough resources.

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