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1、MS4 Program Evaluation Guidance U S Environmental Protection Agency Office of Wastewater Management Comments on this guide should be directed to Jenny Molloy U S EPA Water Permits Division 202 564 1939 Molloy Jennifer epa gov January 2007 Field test version EPA 833 R 07 003 CONTENTS January 2007i EP
2、A 833 R 07 003 1 Introduction and Background 2 1 1Overview 2 1 2Regulatory Overview 5 1 3Types of Permittees 7 2 Pre Evaluation Preparation 9 2 1Evaluation Goals and Benefits 9 2 2Advance Preparation 10 2 3Materials to Review Before the Evaluation 13 2 4Annual Report Reviews 15 3 Conducting a Screen
3、ing Level Evaluation 19 3 1Screening level procedures 19 3 2Common screening level questions 19 3 3Screening level evaluation follow up 22 4 Conducting a Detailed On Site Evaluation 23 4 1Program Management 25 4 2Public Education and Participation 37 4 3MS4 Maintenance Activities 43 4 4Construction
4、Activities 55 4 5Post Construction Controls 66 4 6Industrial Commercial Facilities 76 4 7Illicit Discharge Detection and Elimination 85 5 Post Evaluation Activities 92 5 1Preparing the Written Report 92 5 2Follow Up Activities 97 Appendix A Glossary Develop Phase II MS4 stormwater management program
5、s SWMPs Assess pollutants of concern Provide technical assistance Unlike NPDES industrial wastewater permits which typically contain specific end of pipe effluent limits based on water quality standards or available treatment technology MS4 permits usually include programmatic requirements involving
6、 the implementation of best management practices BMPs in order to reduce pollutants discharged to the maximum extent practicable MEP In addition the permittees often are allowed flexibility in the types of BMPs and activities implemented to meet permit requirements This flexibility as well as the mu
7、ltifaceted nature of the requirements makes it difficult to evaluate the effectiveness of MS4 stormwater programs The purpose of this Guidance is to provide NPDES permitting authority staff the information and questions necessary to conduct a comprehensive MS4 program evaluation and determine if the
8、 permittee is implementing the program in order to reduce pollutants discharged to the MEP This Guidance is not intended to be used as a checklist rather as a reference to prepare for and conduct an MS4 evaluation The evaluator must ultimately rely on personal experience and best professional judgme
9、nt BPJ to conduct a comprehensive MS4 program evaluation An MS4 program evaluation is ultimately based on the requirements in the MS4 permit and commitments made in the stormwater management program SWMP These should serve as the primary references for a specific MS4 program evaluation with this Gui
10、dance used as a tool to help assess compliance with the SWMP Plan and the permit The evaluator may also recommend additional activities that should be conducted by the permittee to improve the SWMP The term evaluation can refer to an audit inspection or screening process depending on the level of de
11、tail utilized These terms are defined under Common Terms below It is important to keep in mind that this Guidance is not an enforcement how to document but can be used to assist in the enforcement process by describing a process for consistently and accurately assessing and documenting the complianc
12、e status of permittees based on permit or SWMP requirements Notes checklists and reports developed as a result of an evaluation will be helpful when justifying and generating enforcement actions Intended Audience This Guidance is written for State and EPA staff responsible for NPDES MS4 permit issua
13、nce compliance and inspections TIP The questions and issues addressed in this MS4 Evaluation Guidance are intended to be used as a reference during an MS4 program evaluation not as a script or checklist during the review Each evaluation should be customized to the issues and requirements specific to
14、 that MS4 TIP Permittees may find this Guidance useful in conducting a self audit to identify and proactively address issues CHAPTER 1 INTRODUCTION AND BACKGROUND January 20073 EPA 833 R 07 003 Permittees may also find the information in this Guidance useful in conducting a self audit to improve the
15、 effectiveness of their SWMP Objective Evaluation This Guidance is intended to provide information to evaluators to help them objectively evaluate if the permittee is implementing the SWMP to the MEP This is going to vary from state to state and by permittee For example some states have requirements
16、 that go beyond the federal regulations or have state programs or policies that affect the way in which certain requirements are articulated in a permit In addition individual NPDES MS4 permits may provide some details on the type of program elements the permittee must implement but not describe in detail all activities necessary to implement each element Typically these permits require that the permittee s SMWP Plan include this detail however and be submitted for approval Or permits may specif
