1. MS4 On-site evaluations & common findings
Presented by: Jack Higginbotham
TCEQ

2. Illicit Discharge Detection and Elimination Program (IDDE) MCM II
On-site EVALUATIONS by TCEQ Investigator:
Inspections of permittee owned facilities (e.g., material storage yards; fleet storage and maintenance; recycling facilities, composting facilities etc.);
Inspections/screening of inlets/outfalls (MS4 Ph. II Levels 1-3)
Evaluation of a dry weather screening field observation by MS4 Operator (MS4 Ph. II Level 4);
COMMON FINDINGS:
1) Failure to document inspections OR Failure to adequately conduct inspections;
2) Failure to develop an adequate outfall map;
3) Failure to retain documentation from employee training;
4) Failure to create/develop adequate ordinances;
5) Failure to conduct dry weather screening (MS4 Ph. II Level 4);
6) Failure to identify priority areas (MS4 Ph. II Level 4);

3. Construction Site Stormwater Runoff MCM III
On-site EVALUATIONS by TCEQ Investigator:
Evaluation of MS4 Operator inspections of multiple sites within the MS4;
Evaluation will focus on comprehensively addressing stormwater pollution prevention plan (SWP3) records, whether installed best management practices (BMPs) on-site are adequate and overall maintenance needs of adequate BMPs.
COMMON FINDINGS:
1) Failure to document inspections OR Failure to adequately conduct inspections;
2) Failure to create/retain comprehensive list of active construction sites (MS4 Ph. II Levels 3-4);
3) Failure to retain documentation from employee training;
4) Failure to create/develop adequate ordinances;

4. Post-Construction Stormwater Management… MCM IV
On-site EVALUATIONS by TCEQ Investigator:
Evaluation of MS4 Operator Inspections of water quality basins, retention/detention ponds within the MS4;
Evaluation will focus on identifying BMP maintenance needs and overall adequacy of the BMP;
Recently "stabilized" sites within the MS4 that are submitting Notice of Terminations (NOTs);
Problem areas/ongoing complaints regarding post-structural controls;
COMMON FINDINGS:
1) Failure to document inspections OR Failure to adequately conduct inspections;
2) Failure to retain documentation from employee training;
3) Failure to create/develop adequate ordinances;

5. Pollution Prevention and Good Housekeeping Measures MCM V
On-site EVALUATIONS by TCEQ Investigator:
Inspections of high-priority facilities (MS4 Ph. II Levels 3-4);
BMP effectiveness evaluations at high-priority facilities and municipal operations and maintenance (O&M) (MS4 II Levels (3-4);
Evaluation of contractor/MS4 Operator oversight of municipal O&M
COMMON FINDINGS:
1) Failure to document inspections/proof of oversight for contracted out projects;
2) Failure to implement BMPs during MS4 O&M;
3) Failure to document inspections of high-priority facilities *(Phase II Level requirement);
&…

6. Pollution Prevention and Good Housekeeping Measures MCM V
COMMON FINDINGS (continued):
Failure to implement adequate spill response measures at high-priority facilities:
e.g., if high–priority facility is close to a water body the RE needs spill kits on- site that include booms. Furthermore, documentation must be provided to investigator that prove employees have been trained on boom deployment. *(MS4 Ph. II Level 3-4 requirement)

7. Industrial Stormwater Sources MCM VI
On-site EVALUATIONS by TCEQ Investigator: (MCM VI applicable to phase II Level 4 MS4s and Phase I MS4s)
Evaluation of MS4 Operator Inspections of MSGP facilities within the MS4:
Evaluation will focus on comprehensively addressing SWP3 records, whether installed BMPs on-site are adequate and overall maintenance needs of adequate BMPs.
COMMON FINDINGS:
1) Failure to document inspections OR Failure to adequately conduct inspections;
2) Failure to retain documentation from employee training;
3) Failure to create/develop adequate ordinances;

8. Authorization for Construction Activities where the MS4 is the Site Operator MCM VII
*MCM is optional and provides an alternative to the MS4 operator seeking coverage under Texas Pollutant Discharge Elimination System (TPDES) Construction General Permit (CGP) TXR150000;
MS4 Operator still must maintain a SWP3 and implement appropriate control measures;
*MCM is only available for projects where the MS4 is a construction site operator or owner, and the MCM does not provide any authorization for other construction site operators at a municipal project;
Does not qualify contractors of the MS4 Operator that are disturbing 1 to over 5 acres; separate authorization must be obtained under the CGP;

9. TCEQ Region 13 – San Antonio Office
14250 Judson Road San Antonio, Texas 78233
Office: