8 Responsibilities of Phase II MS4s on Construction Sites
- Managing and Tracking Active NOI CGP Permits
MS4s have the responsibility to track new NOIs as they are filed and ensure the appropriate projects have NOIs. They are also responsible for confirming Notices of Termination as well as assisting the permittee in closing out permits on completed construction projects.
- Onsite Start-up Pre-construction Meetings
MS4s should hold pre-construction meetings with the owners and/or operators of a new project. They should document communications with the owners and operators on stormwater regulations. These meetings should include, an on-site review of the SWPPP plans and evaluation of the Best Management Practices, as well as a discussion on the construction schedule, the operator inspection requirements, and any other issues as needed.
- Monthly Inspections on Permitted Construction Projects
The MS4 should perform monthly inspections on all Construction General Permit (CGP) and Common Plan of Development (CPoD) Permit sites. Also, any non-incorporated stormwater activity, or permits not falling under the NPDES permit program NOI.
- Bi-weekly Inspections for High Priority CGP and CPoD Permit Sites
MS4s are required to conduct more frequent, bi-weekly inspections on projects designed as High Priority. This requirement includes tracking and following up on rain events for these sites.
- Final Inspections Approving a Notice of Termination (NOT)
During the NOT inspection, the MS4 should follow a checklist to be sure that all items are finished prior to confirming the termination. There should be at least one final onsite inspection, or more if needed to ensure all items are completed. Once all items are completed, they need to communicate with their State Departments of Environmental Quality about the NOT.
- Permit Enforcement
MS4s are required to implement a method of escalating enforcement. This can include Verbal Warnings, Written Warnings, Stop Work Orders, and other methods. They should coordinate with Code Enforcement for the issuance of potential citations as well as their State’s Department of Environmental Quality regarding any penalties or violations of the stormwater rules.
- Annual Reporting
Each year, the MS4 needs to submit numbers and other key indicators showing the level of compliance in their municipality.
- Document and Communication Retention
All documents need to be stored during the project and after its completion for a specific time frame, often up to five years.