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Federal Facilities and an MS4 Audit Thea Lomax Presenter

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Title: Federal Facilities and an MS4 Audit Thea Lomax Presenter


1
Federal Facilities and an MS4 Audit
  • Thea Lomax
  • Presenter
  • EPA, Region 6
  • Storm Water Enforcement

2
Overview
  • Federal Facilities (Definition, types)
  • MS4s (Definition, examples)
  • MS4 SWMP Requirements (Specific for federal
    facilities)
  • MS4 Audit (Definition, Goals, Benefits,
    Preparation, Process)
  • Resources Tools

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
3
What is a Federal Facility?
  • A federal facility is any building, installation,
    land, etc., owned or leased by the federal
    government.

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
4
Types of Federal Facilities
  • Federal facilities can include universities,
    prisons, hospitals, roads (i.e., departments of
    transportation), military bases (e.g., State Army
    National Guard barracks), parks and office
    buildings/complexes.

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
5
What is an MS4?
  • The term MS4 is commonly used to describe both
  • The infrastructure used to convey stormwater
    runoff
  • The owner/operator of the infrastructure that is
    permitted to discharge this runoff

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
6
What is an MS4?
  • According to 40 CFR 122.26(b)(8), municipal
    separate storm sewer system means a conveyance
    or system of conveyances (including roads with
    drainage systems, municipal streets, catch
    basins, curbs, gutters, ditches, man-made
    channels, or storm drains)
  • (i) Owned or operated by a State, city, town,
    borough, county, parish, district, association,
    or other public body (created by or pursuant to
    State law)...including special districts under
    State law such as a sewer district, flood control
    district or drainage district, or similar entity,
    or an Indian tribe or an authorized Indian tribal
    organization, or a designated and approved
    management agency under section 208 of the Clean
    Water Act that discharges into waters of the
    United States.
  • (ii) Designed or used for collecting or conveying
    storm water
  • (iii) Which is not a combined sewer and
  • (iv) Which is not part of a Publicly Owned
    Treatment Works (POTW) as defined at 40 CFR
    122.2.

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
7
What is a sMS4?
  • According to 40 CFR 122.26(b)(16), small MS4s are
    similar to large and medium except they may be
    owned or operated by the United States and
    includes systems similar to separate storm sewer
    systems in municipalities such as systems at
    military bases, large hospital or prison
    complexes, and highways and other thoroughfares
    but does not include sewers in very discrete
    areas, such as individual buildings.

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
8
Federal Facilities and an MS4 Audit
9
Examples of MS4s
Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
10
MS4 SWMP Requirements for Federal Facilities
  • Apply/obtain an NPDES permit
  • Develop and implement six minimum control
    measures of the permit
  • 1. Public Education and Outreach

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
11
MS4 SWMP Requirements for Federal Facilities
  • Apply/obtain an NPDES permit
  • Develop and implement six minimum control
    measures of the permit
  • 1. Public Education and Outreach
  • 2. Public Participation/Involvement

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
12
MS4 SWMP Requirements for Federal Facilities
  • Apply/obtain an NPDES permit
  • Develop and implement six minimum control
    measures of the permit
  • 1. Public Education and Outreach
  • 2. Public Participation/Involvement
  • 3. Illicit Discharge Detection and Elimination

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
13
MS4 SWMP Requirements for Federal Facilities
  • Apply/obtain an NPDES permit
  • Develop and implement six minimum control
    measures of the permit
  • 1. Public Education and Outreach
  • 2. Public Participation/Involvement
  • 3. Illicit Discharge Detection and Elimination
  • 4. Construction Site Runoff

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
14
MS4 SWMP Requirements for Federal Facilities
  • Apply/obtain an NPDES permit
  • Develop and implement six minimum control
    measures of the permit
  • 1. Public Education and Outreach
  • 2. Public Participation/Involvement
  • 3. Illicit Discharge Detection and Elimination
  • 4. Construction Site Runoff
  • 5. Post-Construction Runoff

Federal Facilities and an MS4 Audit
15
MS4 SWMP Requirements for Federal Facilities
  • Apply/obtain an NPDES permit
  • Develop and implement six minimum control
    measures of the permit
  • 1. Public Education and Outreach
  • 2. Public Participation/Involvement
  • 3. Illicit Discharge Detection and Elimination
  • 4. Construction Site Runoff
  • 5. Post-Construction Runoff
  • 6. Good Housekeeping/Pollution Prevention
  • for Municipal Operations

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
16
MS4 SWMP Requirements for Federal Facilities
  • Some Implementation Concerns
  • 1. Unique characteristics
  • 2. Lack of Legal Authority
  • 3. Multiple Regulated Entities
  • Establish cooperative agreements with cities
    and counties in implementing the storm water
    management program

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
17
What is an MS4 Audit?
  • Comprehensive evaluation of all components of an
    MS4 program to assess compliance with the NPDES
    permit and development and implementation of the
    storm water management programs.

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
18
Goals of an MS4 Audit
Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
19
Goals of the MS4 Audit
  • Determine permittees compliance with their MS4
    permit
  • Determine whether the MS4 is meeting the Maximum
    Extent Practicable (MEP) in reducing pollutants
    in storm water discharges
  • Provide compliance assistance in Storm Water
    Management Plan (SWMP) development and
    implementation
  • Assist in MS4 program development

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
20
Benefits of an MS4 Audit
Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
21
Benefits of an MS4 Audit
  • Stronger coordination and working relationship
    between the permitting authority (and/or EPA) and
    the permittee

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
22
Benefits of an MS4 Audit
  • Stronger coordination and working relationship
    between the permitting authority (and/or EPA) and
    the permittee
  • Better understanding by the permittee of the
    expectations and permit requirements

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
23
Benefits of an MS4 Audit
  • Stronger coordination and working relationship
    between the permitting authority (and/or EPA) and
    the permittee
  • Better understanding by the permittee of the
    expectations and permit requirements
  • Clarity of MS4 permit requirements or SWMP plans

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
24
Benefits of an MS4 Audit
  • Stronger coordination and working relationship
    between the permitting authority (and/or EPA) and
    the permittee
  • Better understanding by the permittee of the
    expectations and permit requirements
  • Clarity of MS4 permit requirements or SWMP plans
  • SWMP strengths and areas for improvement
    identified

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
25
Benefits of an MS4 Audit
  • Stronger coordination and working relationship
    between the permitting authority (and/or EPA) and
    the permittee
  • Better understanding by the permittee of the
    expectations and permit requirements
  • Clarity of MS4 permit requirements or SWMP plans
  • SWMP strengths and areas for improvement
    identified
  • Improved permitting authoritys knowledge of the
    permittees operations, priorities, constraints
    and challenges

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
26
Benefits of an MS4 Audit
  • Stronger coordination and working relationship
    between the permitting authority (and/or EPA) and
    the permittee
  • Better understanding by the permittee of the
    expectations and permit requirements
  • Clarity of MS4 permit requirements or SWMP plans
  • SWMP strengths and areas for improvement
    identified
  • Improved permitting authoritys knowledge of the
    permittees operations, priorities, constraints
    and challenges
  • More effective SWMPs that result in better water
    quality and reduced pollutants in storm water
    discharges to the MS4

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
27
Preparation to be audited
Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
28
What should I ask myself first?
  • Where is my Storm Water Management Plan?
  • Where is my legal authority for storm water
    activities (ordinances/agreements)?
  • Do I know what is in the SWMP?
  • Do I have copies of all my annual reports?
  • Have I allowed myself plenty of time to do this
    audit?
  • Do I have copies of everything we say we sent to
    the PA (EPA or State)?
  • Where is that checklist EPA gave me?
  • Do I have everything I need in one place or do I
    know where it is?
  • Have I contacted and scheduled all needed persons
    to participate in the audit?

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
29
Municipal Separate Storm Sewer System
(MS4) Audit Prepared by EPA Region 6 Water
Enforcement Branch Municipal/Industrial Section
(6EN-WM) Revised March 2009 from the November
2006 Checklist
Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
30
ANNUAL REPORTS
Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
31
Purpose of Annual Reports
  • To report the progress of activities implemented
    to accomplish the goals of the SWMP.

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
32
Annual Reports
  • Include a status on
  • 1. Compliance with SWMP schedules
  • 2. Public Education/Outreach
  • 3. Public Participation/Involvement
  • 4. Illicit Discharge Detection and Elimination
  • 5. Construction Site Runoff
  • 6. Post-Construction Site Runoff
  • 7. Good Housekeeping/Pollution Prevention for
    Municipal
  • Operations
  • 8. Proposed changes to the SWMP in the coming
    reporting year

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
33
Annual Reports
  • Include a status on
  • 9. Revisions, if necessary, to the assessment of
    controls land the fiscal
  • analysis reported in the permit
    application or the most recent annual
  • report 10. Summary of
    monitoring data accumulated throughout the
    reporting
  • year
  • 11. Summary of the number of the NPDES NOIs
    received for each
  • general permit
  • 12. Number of site notices received from small
    construction site operators
  • seeking coverage for storm water
    discharges

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
34
Annual Reports
  • Include a status on
  • 13. Number of inspections conducted for
    industrial facilities
  • 14. Number of inspections conducted for
    construction sites
  • 15. Annual expenditures for the reporting
    period, with a breakdown
  • for the major elements of the SWMP,
    and the budget for the
  • year (reporting year) following each
    annual report
  • 16. Summary describing the number of enforcement
    actions
  • 17. Summary describing the nature of enforcement
    actions

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
35
Annual Reports
  • Include a status on
  • 18. Summary describing the number of inspections
  • 19. Summary describing the nature of inspections
  • 20. Summary describing the number of education
    programs
  • 21. Identification of any water quality
    improvements
  • 22. Identification of any water quality
    degradations
  • 23. Identification of any progress towards
    measurable goals
  • 24. Identification of any progress toward
    measured reductions in pollutants
  • 25. Discharge Monitoring Reports for the
    reporting period

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
36
STORM WATER MANAGEMENT PLAN
Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
37
SWMP
  • Comprehensive document that includes the
  • implementation process for each required
  • NPDES six minimum control measures
  • Updated

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
38
PUBLIC EDUATION/OUTREACH
Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
39
Public Education/Outreach
  • Measurable Goals
  • Ordinances, agreements
  • Management, organizational structure,
    responsibilities
  • Meeting schedules
  • Contracted services
  • Training
  • Records
  • Handouts
  • Evaluation Tool

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
40
Public Education/Outreach Pesticides, Herbicides,
Fertilizers
  • Proper use
  • Disposal
  • Storage
  • Handouts developed / meetings held
  • Promotion/Publicized/Facilitated
  • Mechanisms to measure effectiveness of program

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
41
Public Education/Outreach Public Reporting of
Illicit Discharges
  • Departments responsible
  • Promote, publicize, facilitate reporting of
    illicit discharges or WQ impacts associated with
    discharges
  • Programs developed to allow public participation
    in reporting illicit discharges
  • Speaking engagements / event participation
  • Tracking number of illicit discharges reported by
    public
  • Educational material developed (including
    disposal of grass clippings, leaf litter, animal
    wastes)
  • Mechanisms to measure results of public
    participation/education
  • Measures to reach multi-ethnic / minority
    communities

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
42
Public Education/Outreach Disposal of Used
Oil/Household Hazardous Waste
  • Departments responsible
  • Programs to educate about disposal of used oil
    and household hazardous waste materials
  • Speaking engagements / event participation
  • Promote, publicize, facilitate program
  • Training materials developed
  • Responses to program (how many gallons of
    household hazardous waste or used oil collected)
  • Measures to reach children, physically
    challenged, non-English speaking/reading
  • Mechanisms to measure effectiveness of program

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
43
PUBLIC PARTICIPATION/INVOLVMENT
Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
44
Public Participation/Involvement
  • Measurable Goals
  • Ordinances, agreements
  • Management, organizational structure,
    responsibilities
  • Meeting schedules
  • Contracted services
  • Training
  • Records
  • Handouts
  • Evaluation Tool

Federal Facilities and an MS4 Audit
45
Public Participation/Involvement
  • Public involvement on management practices,
    control techniques and systems, design and
    engineering methods, etc.
  • Programs implemented to provide adequate public
    education and ample opportunities for public
    participation in development/implementation of
    SWMP
  • Measures to encourage public participation
  • Public meetings held annually? Attendees?
    Publicity? Topics covered?

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
46
ILLICIT DISCHARGE DETECTION and ELIMINATION
Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
47
Illicit Discharge Detection and Elimination
  • Measurable Goals
  • Ordinances, agreements
  • Management, organizational structure,
    responsibilities
  • Meeting schedules
  • Contracted services
  • Training
  • Records
  • Evaluation Tool

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
48
Illicit discharge detection/elimination
Planning and Evaluation
  • Inspections
  • Investigations
  • Records management
  • Field screening
  • Follow-ups
  • Enforcement
  • Citizen complaints (reporting and resolution)
  • Identification of industrial dischargers and
    their pollutants
  • Identification of measurable goals

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
49
Illicit discharge detection/elimination Sanitary
Sewers
  • Reliable tracking system
  • Controls to limit infiltration of seepage from
    sanitary sewers
  • Owners of leaking privately owned sewer lines
  • Procedures to eliminate reoccurrence of seepage
    into MS4
  • Documentation (what type information i.e.,
    location, cause, resolution, etc.)

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
50
CONSTRUCTION SITE RUNOFF
Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
51
Construction Site Runoff
  • Measurable Goals
  • Ordinances, agreements
  • Management, organizational structure,
    responsibilities
  • Meeting schedules
  • Contracted services
  • Training
  • Records
  • Evaluation Tool

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
52
Construction Site Runoff Planning and Evaluation
  • Inspection program (both public and MS4 owned
    sites) scheduling, prioritization, follow-ups,
    enforcement, citizen complaints
  • Targeted areas
  • Identification of MS4 specific controls
  • Mechanism to measure BMP effectiveness
  • Databases for tracking
  • Identification of POCs
  • Citizen complaints

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
53
Construction Site Runoff Training
  • MS4 Inspector training
  • Adequate number of dedicated inspectors
  • Compliance Assistance/training for site operators
    (seminars, meetings, roundtables, etc.)
  • Training materials developed by MS4
  • Specific outreach for small businesses and
    minority businesses

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
54
Construction Site Runoff Inventory
  • Identification of universe (including sites
    disturbing less than 1 acre) and schedule for
    updating
  • Mechanism for tracking projects Number and
    status, NOI, inspections/results/follow-up,
    enforcement actions), citizen complaints

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
55
Construction Site Runoff Control requirements and
BMPs
  • Technical guidance used as standards for
    design/selection of nonstructural and structural
    BMPs
  • Requirements for following tech guidance
  • Minimum operation and maintenance requirements
  • Installation and maintenance requirements
  • MS4-preferred BMPs to be used
  • Different BMPs for different seasons

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
56
Construction Site Runoff Plan review
  • Building permit requirements (i.e., NOI, SWP3,
    etc.)
  • MS4 notification of responsibilities under storm
    water permitting program
  • Requirement to submit SWP3 with project plans
  • SWP3 review
  • Mechanism for changes to SWP3

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
57
Construction Site Runoff Inspections
  • Criteria for prioritizing inspections
  • Pre-construction meetings with inspectors and
    contractors
  • Inspections of all phases (i.e.,
    clearing/grubbing/site prep, mass grading/public
    infrastructure/utility, building
    construction/final grading
  • Departments in charge of erosion and sediment
    control inspections
  • Records management (checklists, inspection form,
    electronic database)
  • Designated inspectors and qualifications

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
58
Construction Site Runoff Enforcement/Referrals
  • Addressing non-compliance
  • Escalating enforcement
  • Follow-up inspections
  • Tracking for inspections, enforcement actions,
    follow-ups, repeat violators

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
59
POST-CONSTRUCTION RUNOFF
Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
60
Post-Construction Planning and Evaluation
  • Commercial and residential areas
  • Departments responsible for implementation
  • Inspection criteria
  • Enforcement criteria
  • Mechanism to determine effectiveness

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
61
Post-Construction Controls Maintenance of
Structural Controls
  • Identification of POCs
  • Specific areas targeted for pollutant reduction
    and application of specific BMPs
  • Maintenance scheduling for structural controls
    (including floatables)
  • Procedures to develop, implement and enforce
    controls from new development and significant
    re-development after construction

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
62
GOOD HOUSEKEEPING/POLLUTION PREVENTION for
MUNICIPAL OPERATIONS
Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
63
Poor Housekeeping vs. Good Housekeeping
Implement catch basin cleaning
Polluted catch basin
Lack of maintenance yard management
Maintain maintenance yard
Federal Facilities and an MS4 Audit
64
Poor Housekeeping vs. Good Housekeeping
Paints left exposed to storm water
Batteries and drums left exposed to storm water
Federal Facilities and an MS4 Audit
65
Poor Housekeeping vs. Good Housekeeping
Maintenance yard well managed. Drums Stored
underneath a shed and placed on platforms
Trash container exposed to storm water,
not covered with a lid.
Federal Facilities and an MS4 Audit
66
Poor Housekeeping vs. Good Housekeeping
Sloppy road paint storage
Storm drain inlet not cleaned
Federal Facilities and an MS4 Audit
67
Poor Housekeeping vs. Good Housekeeping
Stock piles covered
Federal Facilities and an MS4 Audit
68
Good Housekeeping/Pollution Prevention for
Municipal Operations
  • Measurable Goals
  • Ordinances, agreements
  • Management, organizational structure,
    responsibilities
  • Meeting schedules
  • Contracted services
  • Training
  • Inventory
  • Records

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
69
Good Housekeeping/Pollution Prevention for
Municipal Operations
  • Mapping
  • Operations and Maintenance Procedures
  • Operations and Maintenance Activities
  • Non-Structural and Structural Pollution Control
    Devices
  • BMPs
  • Inspections
  • PHFs
  • Evaluation Tool

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
70
Audit Process
Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
71
Audit Process Pre-Audit 1. Sch
edule date/time/location for the audit 2. Arrange
specific times to meet with the SWMP
Representative 3. Prepare a 10 minute overview of
each program 4. Compile SWMP records,
information, plans for review 5. Prepare and
provide to the auditor a list of facilities for
inspection observation and other requested
information Audit 1. Start on time 2. Introductio
n 3. Presentation 4. Interview 5. Inspection
observations 6. File reviews 7. Closing
conference
Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
72
Audit Process Post-Audit 1. Te
chnical staff review of findings and information
collected 2. Report completed 3. If violations,
Copy of Report and Administrative Order
issued 4. If no violation, Copy of Report and
letter of compliance issued.
Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
73
Resources Tools
  • www.epa.gov/region6/sw
  • www.epa.gov (search for MS4)

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
74
Resources Tools
  • EPAs Regulated Small MS4s website
  • http//cfpub.epa.gov/npdes/stormwater/phase2.cfm
  • Measurable Goals Guidance
  • http//cfpub.epa.gov/npdes/stormwater/measurableg
    oals/index.cfm
  • Stormwater Phase II Compliance Assistance Guide
  • http//www.epa.gov/npdes/pubs/comguide.pdf

Federal Facilities and an MS4 Audit
75
Resources Tools
  • Training
  • http//cfpub.epa.gov/npdes/outreach.cfm?program_i
    d0otype1

Federal Facilities and an MS4 Audit
76
Resources Tools
  • Final EPA MS4 Program Evaluation Guidance
  • http//www.epa.gov/npdes/pubs/ms4guide_withappend
    ixa.pdf
  • http//www.epa.gov/npdes/pubs/ms4guide_appendices
    b-d.pdf
  • http//www.epa.gov/npdes/pubs/ms4guide_withappend
    ixa.doc
  • http//www.epa.gov/npdes/pubs/ms4guide_appendices
    b-d.doc

Federal Facilities and an MS4 Audit
77
Resources Tools
  • EPAs Menu of Best Management Practices (BMPs)
  • http//cfpub.epa.gov/npdes/stormwater/menuofbmps/
    index.cfm
  • Illicit Discharge Detection and Elimination
    Manual
  • http//cfpub2.epa.gov/npdes/docs.cfm?program_id6
    viewallprogsortnameiddemanual
  • or it can be downloaded from the Center for
    Watershed Protection website at
  • http//www.cwp.org/idde_verify.htm
  • EPA Stormwater Month Outreach Materials and
    Reference Documents
  • http//cfpub.epa.gov/npdes/stormwatermonth.cfm

Federal Facilities and an MS4 Audit
78
  • ????

Federal Facilities and an MS4 Audit
79
Contacts
  • EPA Thea Lomax 214-665-8098
  • Diana McDonald 214-665-7495
  • Everett Spencer 214-665-8060
  • Linda Smith 214-665-6641

Federal Facilities and an MS4 Audit
Federal Facilities and an MS4 Audit
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