The EPA has provided notice to the NCDEMLR that the communities of Asheville and Lenoir will be audited in the next 30 days, and that they also intend to audit four to six more North Carolina MS4 Phase II communities within the next few months. Additionally, NCDEMLR plans to audit 20% of permittees per year. Currently there are 122 MS4 entities covered by 109 NPDES MS4 individuals permits in North Carolina. What this means to you is that, if you’re a MS4 Phase II community, your chances of being audited is just a matter of time. Are you ready? Here are the top five things you need to know.
1. Whatever is in your stormwater management plan is an enforceable part of your permit.
If you’re not doing it and don’t plan to do it, consider removing it from your plan or modifying the language so that it is an option or a goal rather than something you will be required to do.
2. If you don’t have a documentation of it, it didn’t happen.
Auditors want to see a paper or preferably an electronic trail documenting your actions. Keep good records readily available and organized so you can demonstrate that you’re doing those things required by your permit.
3. Your stormwater program manager is held responsible for all the municipality’s/county’s operations.
EPA auditors look at a city or county as a whole. They are not interested in what department a program falls in. If it’s part of the MS4 permit, the stormwater manager will be held accountable so make sure other departments and facilities stay in compliance.
4. When you sit down at the table to review your program, take the offensive and be proactive - don’t wait for them to ask about your program.
Pre-audit your program and be ready to demonstrate that you’re managing a well-run and compliant program.
5. Regularly communicate with other departments and facilities.
Complying with stormwater requirements is rarely high on other’s radar screens. In order to ensure that staff is doing the things they are supposed to (inspections, training, record keeping), you need to send regular reminders and follow up with inspections to make sure others within your program are doing what they must to stay in compliance.
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