MS4 MS4 Opening MeetingOpening Meeting

20072007

Palm Beach County MS4Palm Beach County MS4

Year 4 AuditYear 4 Audit

DEP & SAIC Points of Contact DEP & SAIC Points of Contact SAIC MS4 Inspector:SAIC MS4 Inspector:

Robert van den AkkerRobert van den Akker

SAICSAIC

12901 Science Drive12901 Science Drive

Orlando, FL 32826Orlando, FL 32826

Ph: (407) 243-3978Ph: (407) 243-3978

Fax: (703) 243-3353Fax: (703) 243-3353

Email: vandenakkerr@saic.comEmail: vandenakkerr@saic.com

DEP Contact:DEP Contact:Sarah JozwiakSarah Jozwiak

Ph: (850) 245-7523 Ph: (850) 245-7523

Email: sara.jozwiak@dep.state.fl.usEmail: sara.jozwiak@dep.state.fl.us

OverviewOverview Audit ScheduleAudit Schedule Annual Permit Assessment ProcessAnnual Permit Assessment Process Audit Audit

Opening MeetingOpening Meeting Records ReviewRecords Review Special notesSpecial notes

Annual Report Annual Report Section VII, Columns C – FSection VII, Columns C – F Attachments Attachments Signatory RequirementSignatory Requirement

Permit ReapplicationPermit Reapplication

Year 4 Audit ScheduleYear 4 Audit ScheduleDate Time Activity Permittee Location

July 16thMON.

1:00 – 5:00Records Review/ Site

VisitsCity of West Palm

BeachCity of West Palm Beach Offices

July 17thTUE.

8:00 – 12:00Records Review/ Site

VisitsVillage of Wellington Village of Wellington Offices

1:00 – 5:00Records Review/ Site

VisitsVillage of Royal Palm

BeachVillage of Royal Palm Beach

Offices

July 18thWED.

9:00 – 11:30 Joint Meeting All Permittees

Northern Palm Beach County Improvement District

Offices357 Hiatt Drive

Palm Beach Gardens

1:00 – 3:00Records Review/ Site

VisitsCity of Greenacres City of Greenacres Offices

3:00 – 5:00Records Review/ Site

VisitsCity of Lake Worth City of Lake Worth Offices

July 19thTHURS.

8:00 – 12:00Records Review/ Site

VisitsCity of Boynton Beach City of Boynton Beach Offices

1:00 – 3:00Records Review/ Site

VisitsCity of Riviera Beach City of Riviera Beach Offices

3:00 – 5:00Records Review/ Site

VisitsVillage of North Palm

BeachVillage of North Palm Beach

Offices

*Reserve date*

July 20thFRI.

8:00 – 10:00Possible Records

Review/Site VisitsCity of Lake Worth City of Lake Worth Offices

10:30 – 12:30Possible Records

Review/Site VisitsVillage of North Palm

BeachVillage of North Palm Beach

Offices

Annual Permit Assessment ProcessAnnual Permit Assessment Process

Submit:Submit: Annual Report Annual Report

Receive:Receive: Audit Notification Audit Notification **and AR Commentsand AR Comments** Letter Letter

**Possibly Submit:**Possibly Submit: AR Comment Response AR Comment Response

**Possibly Provide for Review:**Possibly Provide for Review: Audit Materials (records & Audit Materials (records & ordinances)ordinances)

**Possibly Receive:**Possibly Receive: Audit RAI Letter Audit RAI Letter

**Possibly Submit:**Possibly Submit: Audit RAI Response Audit RAI Response

Receive:Receive: Year 3 Permit Assessment Letter Year 3 Permit Assessment Letter

**Possibly Submit:**Possibly Submit: Permit Assessment Response Permit Assessment Response

**Possibly Receive:**Possibly Receive: Addendum to Permit Assessment Letter Addendum to Permit Assessment Letter

Audit: Opening MeetingAudit: Opening Meeting

AR CommentsAR Comments Inspector’s AR comments...some in addition to Inspector’s AR comments...some in addition to

DEP’s DEP’s Any questions on DEP’s AR CommentsAny questions on DEP’s AR Comments Submittal of responseSubmittal of response

Permit reapplication to be submitted with Year Permit reapplication to be submitted with Year 4 AR4 AR

General questions?General questions?

Audit: Records ReviewsAudit: Records Reviews

The records reviews focus on The records reviews focus on correlating the datacorrelating the data reported in the AR in Column C reported in the AR in Column C with the with the permittee’s documentation/recordspermittee’s documentation/records reported in reported in Column D for each reporting item.Column D for each reporting item.

When a large number is reported, need to see at When a large number is reported, need to see at least a sample of the record reported. least a sample of the record reported.

Provide records from the reporting year only.Provide records from the reporting year only.

The implementation of any non-reportable The implementation of any non-reportable requirements, such as legal authority, policies, requirements, such as legal authority, policies, procedures, will also be reviewed.procedures, will also be reviewed.

Site visits will be conducted as time allows.Site visits will be conducted as time allows.

Audit: Satisfactory RecordsAudit: Satisfactory Records Must have a record/documentation for every value Must have a record/documentation for every value

reported in Column C.reported in Column C. Just like taxes...you need receipts for those deductions!Just like taxes...you need receipts for those deductions!

Can estimate values for certain reporting items but still Can estimate values for certain reporting items but still need to document how the estimate was arrived at.need to document how the estimate was arrived at.

The record The record must be an actual record documenting the must be an actual record documenting the value reportedvalue reported..

A copy of the Construction Activities brochure does not A copy of the Construction Activities brochure does not document that 75 of them were distributed.document that 75 of them were distributed.

The record The record must clearly reflect the reporting item was must clearly reflect the reporting item was accomplishedaccomplished..

A list of construction projects does not demonstrate that pre-A list of construction projects does not demonstrate that pre-construction reviews for E&S controls were performed for them.construction reviews for E&S controls were performed for them.

Audit: Special Notes Audit: Special Notes

Inspectors may change from year to yearInspectors may change from year to year

The program is evolving – it is not staticThe program is evolving – it is not static

Purpose of the annual report review and audit is Purpose of the annual report review and audit is for DEP to get an in-depth view of how well the for DEP to get an in-depth view of how well the permit requirements are being implementedpermit requirements are being implemented

The annual report is also for:The annual report is also for: Your benefit for next year’s reportYour benefit for next year’s report Analysis of yearly MS4 activitiesAnalysis of yearly MS4 activities

EPA and DEPEPA and DEP

AR: Most Common Reporting ErrorsAR: Most Common Reporting Errors

Not explaining why reporting “0” activities in Not explaining why reporting “0” activities in Column C for:Column C for: Pro-active illicit discharge inspectionsPro-active illicit discharge inspections Training (illicits, spills, construction)Training (illicits, spills, construction) Inspections (MS4, muni. facilities, constr. sites)Inspections (MS4, muni. facilities, constr. sites) Pesticide/herbicide certifications (if report “0” for both Pesticide/herbicide certifications (if report “0” for both

personnel & contractors)personnel & contractors)

Leaving gaps in Column D or Column E when Leaving gaps in Column D or Column E when reported a value in Column Creported a value in Column C

Not reporting an actual document name, or the Not reporting an actual document name, or the correct document name, in Column Dcorrect document name, in Column D

AR: Section VII, Column CAR: Section VII, Column C

Only numbers or a frequency (if specified in the Only numbers or a frequency (if specified in the reporting item) are to be inserted here. reporting item) are to be inserted here.

Do not leave Column C blank or insert “N/A” if Do not leave Column C blank or insert “N/A” if no activities, no activities, rather insert a “0” and explain why rather insert a “0” and explain why the lack of datathe lack of data..

Only report a value in Column C if have a record Only report a value in Column C if have a record to support it. to support it. If no record, need to report “0.”If no record, need to report “0.”

Place any notes/comments regarding the Place any notes/comments regarding the reported values in Column F.reported values in Column F.

AR: Section VII, Column DAR: Section VII, Column D Be as specific as possible about the Be as specific as possible about the actual actual

title title of the record/document. of the record/document.

Avoid generic termsAvoid generic terms such as: such as: Log, spreadsheet, folder, file, checklist, report, Log, spreadsheet, folder, file, checklist, report,

emailemail Paper records, electronic file, Excel, databasePaper records, electronic file, Excel, database Public Works filesPublic Works files

Avoid the name of an entityAvoid the name of an entity such as: such as: Streets Dept.Streets Dept. Bob GreenBob Green VolunteersVolunteers

AR: Section VII, Column D (cont.)AR: Section VII, Column D (cont.)

Indicate the full title and type of the record from Indicate the full title and type of the record from which the values in Column C were obtained:which the values in Column C were obtained: Commercial/Residential Construction Site Inspection Commercial/Residential Construction Site Inspection

ChecklistsChecklists Green Turf Monthly Invoices Green Turf Monthly Invoices JMC Services, Inc. Invoices (2/3/06, 6/10/06)JMC Services, Inc. Invoices (2/3/06, 6/10/06) Email to Bob Green, Public Works Director, from Jane Email to Bob Green, Public Works Director, from Jane

Smith, WAVE, on 8/6/06Smith, WAVE, on 8/6/06 Streets Division Monthly Summary Reports – Streets Division Monthly Summary Reports –

Activities #60 and #61 (or name the line items)Activities #60 and #61 (or name the line items) Smirnoff Database – Search Code 112Smirnoff Database – Search Code 112 Daily Work Orders – SW Codes 4, 5, and 9Daily Work Orders – SW Codes 4, 5, and 9 Illicit Discharge Training Sign-in Sheet (6/12/06)Illicit Discharge Training Sign-in Sheet (6/12/06) DEP Qualified Stormwater Management Inspector DEP Qualified Stormwater Management Inspector

Certifications Certifications

AR: AR: Section VII, Column ESection VII, Column E

Be as specific as possibleBe as specific as possible. . Include the department name as well as the Include the department name as well as the

particular division, and even the responsible particular division, and even the responsible person’s position title.person’s position title.

If more than one entity conducts the activities If more than one entity conducts the activities under a single permit requirement, such as under a single permit requirement, such as the municipality and the county, list both with the municipality and the county, list both with detail – do not simply state “Palm Beach detail – do not simply state “Palm Beach County” as the other entity. Also, include the County” as the other entity. Also, include the POC for that entity.POC for that entity.

Be sure to include the Be sure to include the name of any name of any contractorscontractors hired to perform an activity. hired to perform an activity.

AR: AR: Section VII, Column FSection VII, Column F Reasons for permit requirements not completedReasons for permit requirements not completed

Reasons for variances from normal activitiesReasons for variances from normal activities

Notes/comments regarding the entities performing Notes/comments regarding the entities performing the activities the activities

Listing of names of certified/trained staff (if short list)Listing of names of certified/trained staff (if short list)

Indicate if number in Column C is an estimate and Indicate if number in Column C is an estimate and how it was arrived athow it was arrived at

Provide information on any additional activities not Provide information on any additional activities not recorded (so can’t be reported in Column C)recorded (so can’t be reported in Column C)

Permit Reapplication: Permit Reapplication: Comments Requested by DEP Comments Requested by DEP

Part II of the permitPart II of the permit Particularly Table II.A.1.a...need to include all Particularly Table II.A.1.a...need to include all

components of your MS4 and inspection and components of your MS4 and inspection and maintenance frequenciesmaintenance frequencies

Part III of the permitPart III of the permit

Tailored MS4 AR FormTailored MS4 AR Form Column B reporting items ONLY (all other parts Column B reporting items ONLY (all other parts

of the form are per Rule 62-624.600(2), F.A.C.)of the form are per Rule 62-624.600(2), F.A.C.)

Permit Reapplication: Permit Changes All provisions will likely be applicable to all permittees but All provisions will likely be applicable to all permittees but

need to be implemented only as applicable.need to be implemented only as applicable. For example, Part III.A.5 now only applicable to County will likely For example, Part III.A.5 now only applicable to County will likely

be expanded to all munis.be expanded to all munis.

For the purpose of For the purpose of greater claritygreater clarity::

Additional requirement details, either pulled directly from Additional requirement details, either pulled directly from Part II or new language.Part II or new language.

Additional annual reporting detail, but not the full list of Additional annual reporting detail, but not the full list of items in tailored forms. Trying to sync the permit more items in tailored forms. Trying to sync the permit more with the annual report form.with the annual report form.

Moving around/splitting/combiningMoving around/splitting/combining of some provisions.

Permit Reapplication: Next Steps Permit Reapplication: Next Steps

Permit will not be reissued by expiration date Permit will not be reissued by expiration date Current permit Current permit will automatically be administratively will automatically be administratively

continuedcontinued until it is reissued until it is reissued Have no set schedule for when permit will be reissuedHave no set schedule for when permit will be reissued

Use flow chart as guidance for permittee Use flow chart as guidance for permittee responsibilities and timing of stepsresponsibilities and timing of steps

3 official versions: 3 official versions: DraftDraft →→ Intent to IssueIntent to Issue →→ FinalFinal

Public noticePublic notice required of: required of: DraftDraft & & Intent to IssueIntent to Issue

Facility Decision Schedule will be the first item Facility Decision Schedule will be the first item you receiveyou receive

SAMPLE FACILITY DECISION SCHEDULE

Process ElementsProjected Date of Completion

Permit Application received (is complete) 1/1/07

Effective Date of Permit Application (date of Decision Schedule Letter) 1/7/07

Draft Permit/Fact Sheet to Applicant and EPA 1/14/07 (A)

Applicant to Publish Public Notice of Draft Permit (no later than) 2/14/07 (B)

Applicant to Provide Proof of Publication of Draft Permit Notice (no later than) 3/1/07 (C)

Public Comment Period Ends (no later than) 3/16/07 (D)

Intent to Issue (ITI) Permit/Fact Sheet to Applicant and EPA 4/15/07 (E)

Applicant to Publish Public Notice of ITI Permit (no later than) 5/15/07 (F)

Applicant to Provide Proof of Publication of ITI Permit Notice (no later than) 5/23/07 (G)

Public Petition Period Ends (no later than) 5/30/07 (H)

Final Permit to Applicant and EPA 6/30/07 (I)

USE THE FOLLOWING GUIDANCE TO FILL IN THE SCHEDULE:A. Draft Permit/ Fact Sheet to Applicant and EPA (Date 0)*B. Applicant to Publish Public Notice of Draft Permit (A + 30 days)C. Applicant to Provide Proof of Publication of Draft Permit Notice (B + 14 days)D. Public Comment Period Ends (B + 30 days)E. Intent to Issue (ITI) Permit/Fact Sheet to Applicant and EPA (D + 30 days) *F. Applicant to Publish Public Notice of ITI Permit (E + 30 days)G. Applicant to Provide Proof of Publication of ITI Permit Notice (F + 7 days)H. Public Petition Period Ends (F + 14 days)I. Issue Final Permit (F + 30 days)** These are estimated dates that are not based on the administrative timelines for permitting.

Future ReportingFuture Reporting

Year 5:Year 5: 10/01/06-09/30/07, due 03/30/08 10/01/06-09/30/07, due 03/30/08

Year 1:Year 1: 10/01/07- 1yr. from re-issuance 10/01/07- 1yr. from re-issuance date, due 6 months laterdate, due 6 months later Will be longer than 12 monthsWill be longer than 12 months

ExampleExample

If the permit is reissued on 12/10/07:If the permit is reissued on 12/10/07:

Year 1:Year 1: 10/01/07-12/09/08, due 06/09/09 10/01/07-12/09/08, due 06/09/09

Year 2:Year 2: 12/10/08-12/09/09, due 06/09/10 12/10/08-12/09/09, due 06/09/10

Permit Template ReviewPermit Template Review

DEP developed a permit “template” to try DEP developed a permit “template” to try to achieve more consistency…your permit to achieve more consistency…your permit will likely look very much like the templatewill likely look very much like the template

DEP is striving for more consistency in the DEP is striving for more consistency in the permits:permits: With DEP rules & policyWith DEP rules & policy With Federal rules & policyWith Federal rules & policy Between permitsBetween permits Among like permittees (e.g., FDOTs)Among like permittees (e.g., FDOTs)

DEP & SAIC Points of ContactDEP & SAIC Points of ContactSAIC MS4 Inspector:SAIC MS4 Inspector:

Robert van den AkkerRobert van den AkkerSAICSAIC

12901 Science Drive12901 Science DriveOrlando, FL 32826Orlando, FL 32826Ph: (407) 243-3978Ph: (407) 243-3978Fax: (703) 243-3353Fax: (703) 243-3353

Email: vandenakkerr@saic.comEmail: vandenakkerr@saic.com

DEP Contact:DEP Contact:Sarah JozwiakSarah Jozwiak

Ph: (850) 245-7523 Ph: (850) 245-7523 Email: sara.jozwiak@dep.state.fl.usEmail: sara.jozwiak@dep.state.fl.us