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EPA MS4 AUDIT Minnesota Experience

EPA MS4 AUDIT Minnesota Experience. Frank Pafko Director, Office of Environmental Stewardship MN Department of Transportation. MINNESOTA. One General MS4 Permit: applies to entire state MnDOT SWPPPs: Greater MN and Metro District Metro MS4 was audited – 1 st DOT in EPA Region V

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EPA MS4 AUDIT Minnesota Experience

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  1. EPA MS4 AUDITMinnesota Experience Frank Pafko Director, Office of Environmental Stewardship MN Department of Transportation

  2. 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

  3. EPA Audit of Metro’s MS4 Program Three Fun Filled Days

  4. 90-Day Notice of Audit

  5. 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?

  6. 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.

  7. AUDIT FINDINGS – Potential Violations Outreach strategy lacked specific targets & goals Illicit Discharge procedures incomplete Storm sewer mapping incomplete No written procedures: site inspection/enforcement Structural control inspections: less than 20% / year Facility Storm Water Plans not up-to-date Training needed for maintenance personnel

  8. 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

  9. 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

  10. 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

  11. 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

  12. 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

  13. 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

  14. 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

  15. 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

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

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