EPA MS4 AUDITMinnesota Experience

Frank PafkoDirector, Office of Environmental

StewardshipMN Department of Transportation

• 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

MINNESOTA

EPA Audit of Metro’s MS4 Program

Three Fun Filled Days

90-Day Notice of Audit

• 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?

Questions that EPA Will Ask

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.

1. Outreach strategy lacked specific targets & goals2. Illicit Discharge procedures incomplete3. Storm sewer mapping incomplete4. No written procedures: site inspection/enforcement5. Structural control inspections: less than 20% / year6. Facility Storm Water Plans not up-to-date7. Training needed for maintenance personnel

AUDIT FINDINGS – Potential Violations

• Disagreed with the finding• Target audiences, goals & outreach strategies

clearly listed in MS4 SWPPP• Pointed out errors in report

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

• 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

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

• 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

3. Storm Sewer Mapping Incomplete …

• 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

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

• 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

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

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

facility upgrades

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

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

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

• 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

EPA Acknowledged Positive Attributes

Conclusions

DOCUMENTATION, DOCUMENTATION, DOCUMENTATION

How to get people on board?

Build relationships.

Never enough resources.