PROJECT

MS4 Compliance Support & Stormwater Analysis

Our team assisted with and coordinated municipal separate storm sewer system (MS4) compliance for the City of Grandview, Missouri, including continued updates of the city’s stormwater management program plan with practical and feasible best management practices (BMPs).

We have continued to support the city in documenting MS4 compliance activities through 2024, including preparations for and response to a recent audit completed by the Missouri Department of Natural Resources (MDNR).

MS4 Compliance Support                                                               

The city’s stormwater management program was first inspected by MDNR in 2017. The agency identified violations on two minimum control measures: illicit discharge detection and elimination, and pollution prevention and good housekeeping.

We evaluated existing BMPs for each minimum control measure (MCM) and determined the feasibility of implementation. We also examined the activities and practices the city was already doing in support of its MS4 goals. Based on this comparison, we updated the city’s plan for its stormwater management program with practical BMPs.

This update involved a facilitated meeting with city departments to educate staff, identify BMPs already in place, and identify feasible tasks and metrics to measure progress over a five-year implementation period. For compliance with the pollution prevention and good housekeeping minimum control measure, a detailed stormwater inspection and analysis of the city’s Public Works Maintenance Facility was completed. Our team developed a facility stormwater runoff management plan specific to the site and established training for the facility’s staff related to storage of equipment and materials to protect area streams.

Client

City of Grandview

Location

Grandview, Missouri

Region

Midwest

Services

Environmental

Stormwater Management

Industries

Water

Environmental

The city was issued an updated MS4 permit in 2022. Our ongoing support for compliance documentation through 2023 included an update of the stormwater management program and plan, outfall reconnaissance inventory, post-construction BMP inspections, and compilation of the annual report required by the MS4 permit.

We updated the Facility Stormwater Plan for the Public Works Department to the newly titled Municipal Facilities Stormwater Operations & Maintenance Manual. This effort included collaboration between Public Works and Parks & Recreation to plan for documentation and completion of required, routine stormwater inspections at 22 municipal facilities. Maps were developed specific to stormwater impact at each facility, with best practices identified as related to stormwater. Inspection forms were developed specific to each facility, for use by staff. Our team trained city staff in the use of this manual through a meeting and collaborative inspections.

On notification in late 2023 of a pending audit scheduled for January 2024, we worked closely with the city to define a preparation approach that accounted for holiday schedules and a physical move of city staff, which was already scheduled within the same timeframe. The Board of Aldermen were notified and educated of the typical audit process and the city’s MS4 program status. Intentional preparations anticipating MDNR’s visit included:

• Review of the city’s construction site runoff program. We identified inspector training and associated checklists to meet the MS4 permit requirements. Inspections of active sites were completed, with inspection results compiled in the checklist report. Processes were documented for plan review and construction tracking of active sites. Our team assisted in identifying recommended updates to the effective ordinance that reflect city procedures and current MS4 permit requirements.

• Inspections and preparations at city facilities. We completed inspections at all 22 municipal facilities per the Municipal Facilities Stormwater Operations & Maintenance Manual. This effort included additional training of city staff in the inspection requirements and documentation as outlined in the manual, as well as continued follow-up with city staff on completion of tasks in preparation for the audit. We utilized a drone to assist in completing and documenting inspections of the larger facilities, in particular larger footprint parks. Our team actively discussed results of inspections with city staff and helped prepare them for potential questions from MDNR. A result of this process was an update to city procedures at their facilities that not only benefits stormwater but also improves the efficiencies of the staff and city resources.

• Review of Stormwater Management Program & Plan. Our team initiated the typical annual reporting documentation and update process with city staff in preparation for the audit, while also anticipating the February deadline for compilation of documentation associated with 2023. We facilitated meetings with city staff to review the program and plan document for each minimum control measure, redlined needed updates based on this discussion, and then reviewed the measurable goals and associated documentation. We also discussed potential questions that MDNR may ask.

Our team assisted the city in responding to MDNR’s requests before the scheduled audit. This support included compiling documentation for MDNR by a defined deadline, identifying staff who needed to participate in the audit, developing an agenda for the two-day audit, and proactively communicating with MDNR to suggest alternative approaches to requested field inspections based on active weather conditions. We attended the audit meetings with city staff, assisting in facilitation, providing documentation and discussing the expectations of the MDNR audit team.

As a result of this effort, we identified the benefits of the audit preparation process in evaluating the current compliance status. This has evolved to: implementing a “mock audit” process to prepare, evaluate and educate those involved with MS4 compliance for a community; to continuing to build depth in understanding these requirements; and integrating the resulting processes and documentation into everyday activities.