Monday, February 28, 2011

Recent EPA Inspection of the Columbia MS4

EPA Environmental Services staff was in Columbia from February 14 to February 18 inspecting the MS4 (Municipal Separate Storm Sewer System) which includes the City of Columbia, Boone County and the University of Missouri.

The EPA was evaluating our policies, procedures and documentation of how the Columbia MS4 implements the minimum control measures (MCMs) that result in a significant reduction of pollutants into our receiving streams.  Each of the three co-permittees:  City, County and MU, had their turn to show their documentation and give on-site tours.  Overall, the EPA inspectors were impressed with how well our entities work together with regard to stormwater.

EPA Inspectors were investigating how our MS4 is implementing the Minimum Control Measures (MCM) found in the NPDES Permit for Phase II communities.  The MCMs that they focused on were Illicit Discharge Detection and Elimination, Construction Site Runoff Controls, Post-Construction Storm Water Management and Pollution Prevention/ Good Housekeeping.  For each of these categories, EPA reviewed our ordinances, records, policies, procedures, and training.  Where applicable, they interviewed appropriate staff and conducted site visits.

EPA Inspectors toured two private City developments:  the recently completed Landmark Hospital and The Grove and two City projects:
Scott Boulevard
and the addition to the City’s Wastewater Treatment Plant.  Each construction site is required to have a Storm Water Pollution Prevention Plan (SWPPP).  At each site, the EPA reviewed the SWPPP and inspection logs.  Each construction site is required to inspect the constructed erosion and sediment control practices on a regular basis and document inspections and any corrective actions to the erosion and sediment control plan.  EPA conducted a thorough review of inspection reports at each site. 

EPA Inspectors also visited the City Salt Storage Facility and the Grissum Building, which houses City of Columbia Public Works Operations.  Both of these tours highlighted the stormwater pollution prevention measures that are currently in place or planned for those two facilities.  Operations Staff provided EPA with information about our extensive reporting of sanitary sewer overflows (SSOs) and the programs that are in place to address them.  Staff also provided an overview of other City programs, such as Household Hazardous Waste and downtown street sweeping, which keep pollutants out of our waterways. 

This inspection is an opportunity for the City to evaluate our strengths and weaknesses concerning our stormwater program.   We are planning comprehensive training for all staff to address some of our weaknesses in Good Housekeeping and Pollution Prevention.  The EPA Inspectors were impressed with signs on storm drains and parking garages in downtown areas to prevent dumping.  They also mentioned they would be sending other communities in the region to Columbia as an example of how to implement certain activities.

We will not know the outcome of the investigation for another 60 days, but look forward to the opportunity to improve the City’s stormwater program.  The bottom line for any EPA investigation is DOCUMENTATION.   The stormwater utility has been working to implement many of the necessary ordinances, policies and procedures to protect our waterways and improve stormwater quality.