HomeMy WebLinkAbout05-13-21 Correspondence - DEQ Stormwater Audit •
D E AdERN h Q- -N
Montana Department
of Environmental Quality
May 11, 2021
The Honorable Cyndy Andrus
City of Bozeman
PO Box 1230
Bozeman, MT 59771
RE:Small Municipal Separate Storm Sewer System (MS4) Inspection:City of Bozeman and Montana State
University, Montana Pollutant Discharge Elimination System (MPDES) Permit Authorization MTR040002:
City of Bozeman Small MS4
Dear Mayor Cyndy Andrus:
The Department of Environmental Quality (DEQ) is providing notification for a planned inspection of the
City of Bozeman and Montana State University MS4 Programs. Montana DEQ is scheduling the inspection
for June 15-18, 2021. The inspection will be completed with representatives of Montana DEQ and
members of the Storm Water Management Team for the City of Bozeman and Montana State University.
Information to be reviewed during the inspection will include the following sections of the General Permit
for Storm Water Discharges Associated with Small Municipal Storm Sewer Systems (General Permit):
• Part ILA—Storm Water Management Program
• Part II.A.1—Public Education and Outreach
• Part II.A.2—Public Involvement and Participation
• Part II.A.3—Illicit Discharge Detection and Elimination
• Part II.A.4—Construction Site Storm Water Management
• Part II.A.5—Post Construction Storm Water Management in New and Redevelopment
• Part II.A.6—Pollution Prevention/Good Housekeeping for Permittee Operations
• Part 11.6—Training
• Part II.C—Sharing Responsibility
• Part III—Special Conditions
o Parts A and B
• Part IV—Monitoring, Recording, and Reporting Requirements
o Parts A and B
Information Requested
To facilitate the inspection, Montana DEQ is requesting the following information be submitted from each
respective party by June 4,2021:
• Part ILA—Storm Water Management Program
o Formalized Mechanisms of Communication—Meeting Agendas, Notes and/or Summaries,
for all meetings completed with the Storm Water Management Team for 2020
■ City of Bozeman and Montana State University
o Current Organizational Chart for Montana State University or how they fit into Bozeman's
Organizational Chart (Part 1.5 of the SWMP—Section 1.0 Page 10)
Greg Gianforte,Governor I Chris Dorrington, Director I P.O. Box 200901 1 Helena,MT 59620-0901 1(406)444-2544 1 www.deq.mt.gov
City of Bozeman-City of Bozeman Small MS4 Page 2 of 4
MTR040002
May 11,2021
• Part II.A.3—Illicit Discharge Detection and Elimination (IDDE)
o Part II.A.3.d.ii—Adopt Ordinance or Other Regulatory Mechanism to Prohibit Illicit
Discharges
■ Montana State University—provide a copy of regulatory mechanism to prohibit
illicit discharges and summary of legal authority.
o Part II.A.3.d.iii—Provide a copy of formalized cooperative agreements between City of
Bozeman and Montana State University to implement the IDDE program.
■ City of Bozeman and Montana State University
O Part II.A.3.d.iv—IDDE enforcement response plan (ERP) through ordinance, formal policies,
or memoranda of understanding with neighboring MS4
■ Montana State University
o Part iI.A.3.e.i and e.iii—Copies of all dry weather screening field sheets and/or reports
completed of outfalls for 2020 including high priority outfalls screened in 2020.
■ City of Bozeman and Montana State University
O Part II.A.3.f.iii and f.iv—Documentation of All Investigations Conducted and Corrective
Actions Completed for 2020
■ City of Bozeman and Montana State University
• Part II.A.4—Construction Site Storm Water Management
o Part II.A.4.a.ii—Formal Policies or Other Mechanisms to Require Construction Storm Water
Controls
■ Montana State University—provide a copy of the authority summary,written policy,
and written procedures.
o Part II.A.4.a.iii—Formal ERP to ensure compliance with the construction storm water
management regulatory mechanisms on regulated projects including private property.
■ Montana State University
o Part II.A.4.b.ii and b.iii—Copies of Completed Storm Water Management Plan Review
Checklists
■ City of Bozeman
• Provide copies for 10 projects completed in 2020.
• Requested copies are limited to review completed on projects equal to or
over one acre of disturbance.
■ Montana State University
• Provide copies for all reviews completed in 2020 (3)
o Part II.A.4.c.iii—Copies of Completed Construction Site Storm Water Management
Inspection Checklists
■ City of Bozeman
• Provide copies of 10 projects for 2020.
• Requested copies are limited to inspections completed on projects equal to
or over one acre of disturbance.
■ Montana State University
• Provide copies of completed inspections in 2020 (5)
O Part II.A.4.c.iv—Copy of up-to-date "Regulated Project Inventory" containing all permits and
approvals received or applied for from State or Federal regulatory agencies.
■ City of Bozeman—provide regulatory project inventory for projects equal to or over
one acre of disturbance for 2020.
Greg Gianforte,Governor I Chris Dorrington, Director I P.O.Box 200901 1 Helena,MT 59620-0901 1(406)444-2544 1 www.deq.mt.gov
City of Bozeman -City of Bozeman Small MS4 Page 3 of 4
MTR040002
May 11, 2021
■ Montana State University—provide regulatory project inventory for all projects for
2020.
• Part II.A.5—Post Construction Site Storm Water Management in New and Redevelopment
o Part II.A.5.b.i and b.ii—Copy of Plan Review Checklist and copies of all completed Plan
Review Checklists
■ City of Bozeman—copies for projects reviewed in 2020.
■ Montana State University—copies for projects reviewed in 2020.
o Part II.A.5.b.iii—Formal ERP Documentation supporting the implementation of requirements
that all regulated projects comply with the run-off reduction requirement.
■ City of Bozeman and Montana State University
o Part II.A.5.c.i and c.ii—Copy of Inspection Form or Checklist and copies of all completed Post
Construction Storm Water Management Control Inspection Forms
■ City of Bozeman—copies for all inspections completed in 2020.
■ Montana State University—copies for all inspections completed in 2020.
o Part II.A.5.c.viii—Copies of all inspections completed of permittee-owned high priority post-
construction storm water management controls, findings, and resulting compliance actions.
■ City of Bozeman and Montana State University
o Part II.A.5.c.ix—Copies of all inspections completed of all high priority privately-owned post
construction storm water management controls.
■ City of Bozeman—copies of all inspections completed in 2020.
• Part II.A.6—Pollution Prevention/Good Housekeeping for Permittee Operations
o Part II.A.6.a.i—Copy of Inventory of Permittee Owned/Operated Facilities and Activities
■ City of Bozeman and Montana State University
o Part II.A.6.a.ii—Updated Map Identifying Locations of All Facilities and Activities
■ City of Bozeman and Montana State University
o Part II.A.6.a.iii—Copies of Inspections and Communications Completed in conjunction with
the development of Standard Operating Procedures(SOPS)
■ City of Bozeman and Montana State University
o Part II.A.6.a.iv—Copies of training curriculum and sign in sheets completed in conjunction
with the development of each SOP.
■ City of Bozeman and Montana State University
o Part II.A.6.a.v—Copies of records for trainings completed in 2019 and 2020.
■ City of Bozeman and Montana State University
• Part II.B—Training:
o Copy of the curriculum and/or information covered during all trainings conducted in permit
year 2017.
■ City of Bozeman and Montana State University
o Copy of the curriculum and/or information covered during all trainings conducted in permit
year 2020.
■ City of Bozeman and Montana State University
o Sign in sheets for all personnel that attended trainings, including new hires between January
1, 2017,to present date.
■ City of Bozeman and Montana State University
• Part II.0—Sharing Responsibility
o Copy of Written Agreements between the City of Bozeman and Montana State University
for implementation of any Minimum Control Measure (MCM)
Greg Gianforte,Governor I Chris Dorrington, Director I P.O. Box 200901 1 Helena,MT 59620-0901 1(406)444-2544 1 www.deq.mt.gov
City of Bozeman-City of Bozeman Small MS4 Page 4 of 4
MTR040002
May 11, 2021
• Part III—Special Conditions and Part IV—Monitoring, Recording,and Reporting Requirements
o Copies of Bench Sheets, Chain of Custody Forms, and Laboratory Analytical Reports for all
monitoring completed in 2020.
■ City of Bozeman
Documentation outlined in the section titled Information Requested can be mailed to: Montana
Department of Environmental Quality, Water Protection Bureau, 220 West Lamme,Suite 1B, Bozeman,
MT 59715, Attn: Christopher Romankiewicz.Alternatively, the documentation can be submitted
electronically through the City of Bozeman's FACTS account. If you have questions regarding your FACTS
account, please contact Gina Self with the MPDES Data Management Team at (406)444-5388 or
Gself@mt.gov. If the requested information is not available, please provide a written explanation
detailing why the information is not available by June 4, 2021.
Montana DEQ will confirm the inspection date, provide an inspection schedule, and identify appropriate
staff one week before the date of the scheduled inspection. Notification will be provided by email.
Montana DEQ looks forward to meeting with your staff and discussing the efforts of the City of Bozeman
Small MS4 to protect water quality through the MS4 Program. If you have any questions, please
feel free to contact me at the information listed below.
I appreciate you and your staff's time and consideration.
Sincerely,
C
Christopher Romankiewicz
Lead Compliance Inspector
Compliance,Training, and Technical Assistance
Water Quality Division
Montana Department of Environmental Quality
cromankiewicz@mt.gov
cc:Kayla Mehrens,Storm Water Program Coordinator,City of Bozeman,via email:kmehrens@bozeman.net
EJ Hook,Director,Facilities Services,Montana State University,via email:edward.hookl@montana.edu
FACTS
Greg Gianforte,Governor I Chris Dorrington, Director I P.O.Box 200901 1 Helena,MT 59620-0901 1(406)444-2544 1 www.deq.mt.gov