1. PH - (405) 702-8100 Fax - (405) 702-8101 Municipal Separate Storm Sewer System (MS4) Audits: The Oklahoma Experience Carrie Evenson, Ph.D., P.E. Oklahoma DEQ

2. PH - (405) 702-8100 Fax - (405) 702-8101 Outline Background Information Activities in Oklahoma Phase I Audits Phase II Audits Phase II Screening Evaluations Things to Consider Lessons Learned

3. PH - (405) 702-8100 Fax - (405) 702-8101 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. PH - (405) 702-8100 Fax - (405) 702-8101 Oklahoma’s MS4 Permits Phase I MS4s Individual Permits Oklahoma City first issued September 1, 1995 Tulsa first issued April 1, 1997 Both are co-permittees with ODOT and OTA Phase II MS4s 51 cities, counties, & non-traditional entities General Permit, OKR04 First issued in February 2005 6 Minimum Control Measures

5. PH - (405) 702-8100 Fax - (405) 702-8101 MS4 Program Evaluations 2004 Guidelines and procedures developed by EPA 2005 First Phase I MS4s audited by EPA 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

6. PH - (405) 702-8100 Fax - (405) 702-8101 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

7. PH - (405) 702-8100 Fax - (405) 702-8101 MS4 Program Evaluations EPA’s MS4 Evaluation Guide http://www.epa.gov/npdes/pubs/ms4guide_withapp endixa.pdf http://www.epa.gov/npdes/pubs/ms4guide_withapp endixa.pdf Very large document Program evaluation worksheets = 83 pages Describes a range of evaluations From inspections to audits Covers Phase I and Phase II MS4s Can be modified to fit needs of State

8. PH - (405) 702-8100 Fax - (405) 702-8101 Activities in Oklahoma Phase I Audits First audit conducted in November 2006 Audit team included Permitting and Enforcement personnel Used EPA checklist Version prior to release of MS4 Evaluation Guide Modified to fit permit requirements

9. PH - (405) 702-8100 Fax - (405) 702-8101 Activities in Oklahoma Pre-Audit Preparation Contact City Stormwater Manager Arrange location and time Written request for information SWMP Annual Report List of Municipal, Industrial, and Construction SW sites with previous enforcement Document review Divide and conquer approach Prepare agenda

10. PH - (405) 702-8100 Fax - (405) 702-8101

11. Activities in Oklahoma City of Tulsa November 14 th – 17 th, 2006 Consisted of document review, personnel interviews, and field inspections Included inspection of co-permittee facilities Required availability of numerous City of Tulsa personnel

12. PH - (405) 702-8100 Fax - (405) 702-8101 City of Tulsa MS4 Audit Document Review and Personnel Interviews Opening meetings each morning Small group interviews for each section of checklist Consisted of 1-2 ODEQ staff and appropriate City of Tulsa personnel MS4 staff should be directly responsible for permit requirement or briefed by responsible party Phone availability is helpful

13. PH - (405) 702-8100 Fax - (405) 702-8101 City of Tulsa MS4 Audit Field Activities Inspections of municipal maintenance yards, ODOT and OTA facilities, construction sites, and industrial facilities Teams of 1-3 ODEQ personnel and appropriate City personnel Used inspection forms and technical assistance reports to document findings

14. PH - (405) 702-8100 Fax - (405) 702-8101 Activities in Oklahoma City of Oklahoma City November 5 th – 9 th, 2007 Similar schedule to City of Tulsa Additional 0.5 day to view City’s Household Hazardous Waste Control Facility, Central Maintenance Yard, and stormwater controls to capture floatables

15. PH - (405) 702-8100 Fax - (405) 702-8101 Document Review Similar process as with City of Tulsa One-on-one interviews with Stormwater Quality’s Unit Supervisors Stormwater Quality Manager able to move between interview groups Other City personnel brought in as necessary City of Oklahoma City MS4 Audit

16. PH - (405) 702-8100 Fax - (405) 702-8101 Field Activities Municipal maintenance yards, ODOT and OTA facilities Used evaluation worksheets from EPA MS4 Evaluation Guide Inspection of facility Observation of interaction between SW staff and other City departments

17. PH - (405) 702-8100 Fax - (405) 702-8101 Construction and Industrial Site Evaluations Sites selected had previous enforcement actions taken by City Observation and evaluation of City inspectors Select sites in each inspector’s area Field Activities

18. PH - (405) 702-8100 Fax - (405) 702-8101 Phase II MS4 Evaluations Evolved over time Considered/attempted to date: Mini audit Similar to Phase I audit Document review and field visits Screening criteria Limited document review Focus on a particular MCM No field inspections Screening evaluations Current procedure All MCMs evaluated Includes field inspections

19. PH - (405) 702-8100 Fax - (405) 702-8101 Activities in Oklahoma Phase II Mini-Audits Modified MS4 Evaluation Guide to fit permit requirements Reduced from 83 to 14 pages Checklist format Similar to Phase I audits Shorter duration Included document review and site visits Audit team included permitting and enforcement staff

20. PH - (405) 702-8100 Fax - (405) 702-8101 City of Midwest City Mini-Audit June 12 th – 14 th, 2007 Visited municipal facilities, structural controls, and construction sites Document review covered all MCMs Stormwater manager was primary source of information

21. PH - (405) 702-8100 Fax - (405) 702-8101 City of Midwest City Mini-Audit Outcomes City of Midwest City Comprehensive program that adequately meets MCMs and exceeds several of them Used as resource by city departments and organizations as well as neighboring Phase II MS4 programs Procedural Audit team too large for smaller MS4s Process resource- and labor-intensive Not flexible enough for small MS4s in first years of program development

22. PH - (405) 702-8100 Fax - (405) 702-8101 Activities in Oklahoma Phase II Screening Evaluations Goals: Develop productive, cooperative working relationship with Stormwater Managers Determine status of program development and implementation Provide technical assistance Use available staff and resources wisely

23. PH - (405) 702-8100 Fax - (405) 702-8101 Activities in Oklahoma Phase II Screening Evaluations Process: Small evaluation team  Wisest use of limited staff and resources  Industrial Wastewater inspectors involved as duties allow  Team leader is alternated  No back-to-back assignments  Allows team leader to complete report before beginning next evaluation

24. PH - (405) 702-8100 Fax - (405) 702-8101 Activities in Oklahoma Phase II Screening Evaluations Process: Direct interview with MS4 staff Questionnaire/checklist used  Covers all aspects of program  Review SWMP and most recent annual report Site visits or inspections  Added to give more detailed information on program

25. PH - (405) 702-8100 Fax - (405) 702-8101 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

26. PH - (405) 702-8100 Fax - (405) 702-8101 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

27. PH - (405) 702-8100 Fax - (405) 702-8101 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: _______________

28. PH - (405) 702-8100 Fax - (405) 702-8101 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

29. PH - (405) 702-8100 Fax - (405) 702-8101 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

30. PH - (405) 702-8100 Fax - (405) 702-8101 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!!

31. PH - (405) 702-8100 Fax - (405) 702-8101 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

32. PH - (405) 702-8100 Fax - (405) 702-8101 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

33. PH - (405) 702-8100 Fax - (405) 702-8101 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

34. PH - (405) 702-8100 Fax - (405) 702-8101 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?

35. PH - (405) 702-8100 Fax - (405) 702-8101 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

36. PH - (405) 702-8100 Fax - (405) 702-8101 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

37. PH - (405) 702-8100 Fax - (405) 702-8101 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

38. PH - (405) 702-8100 Fax - (405) 702-8101 Lessons Learned Procedural Preparation + Opportunity = Success 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

39. PH - (405) 702-8100 Fax - (405) 702-8101 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

40. PH - (405) 702-8100 Fax - (405) 702-8101 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 documentation!

41. PH - (405) 702-8100 Fax - (405) 702-8101 Questions, Comments, Suggestions