• BMP #5: Ensure that controls are installed that shall prevent or minimize water quality impacts. The permittee shall inspect all qualifying development or redevelopment projects during the construction phase to ensure proper installation of the approved structural PCSM BMPs. A tracking system (e.g., database, spreadsheet, or written list) shall be implemented to track the inspections conducted and to track the results of the inspections (e.g., BMPs were, or were not, installed properly).
• During the reporting period have you inspected all qualifying development and redevelopment projects during the construction phase to ensure proper installation of approved structural BMPs?
• ☐ Yes ☒ No ☐ Not Applicable (no qualifying projects during reporting period)
• Has a tracking system been established and maintained to record results of inspections?

☐ Yes ☑ No

BMP #6: Develop a written procedure that describes how the permittee shall address all required components of this MCM.

Have you developed a written plan that addresses: 1) minimum requirements for use of structural and/or non-structural BMPs in plans for development and redevelopment; 2) criteria for selecting and standards for sizing stormwater BMPs; and 3) implementation of an inspection program to ensure that BMPs are properly installed? □ Yes ☒ No

MCM #5 Comments:

All SWM for development projects that are great than 5,000 SF or new impervious area are reviewed and inspected by the Township's consultant, GPI. The developer/owner is required to sign an O&M agreement. We are working on compiling the list of all existing PCSM BMPs and developing an ongoing inspection program for these facilities.

MCM #6 – POLLUTION PREVENTION / GOOD HOUSEKEEPING

• BMP #1: Identify and document all operations that are owned or operated by the permittee and have the potential for generating pollution in stormwater runoff to the MS4. This includes activities conducted by contractors for the permittee.
• Have you identified all facilities and activities owned and operated by the permittee that have the potential to generate stormwater runoff into the MS4? ☒ Yes ☐ No
• When was the inventory last reviewed? August 16, 2019
• When was it last updated? A list of all Township owned property has been generated. The impact of these properties on SWM has not been identified. The Millcreek Township Streets Department is responsible for the maintenance of sixteen flood detention facilities located throughout the Township. The streets dept also maintains the storm sewer system. Frequently clogged channels, pipe inlets, and other troublesome conveyance facilities are listed and checked after each significant rainfall or snow melt. The Township conitinously works on designing and constructing new conveyance and regional detention facilities while resolving drainage complaints, maintaining existing facilities and obtaining easements to clean existing open channels throughout the Township.
• BMP #2: Develop, implement and maintain a written O&M program for all operations that could contribute to the discharge of pollutants from the MS4, as identified under BMP #1. This program shall address stormwater collection or conveyance systems within the regulated MS4.
• Have you developed a written O&M program for the operations identified in BMP #1? ☐ Yes ☒ No
• Date of last review or update to written O&M program: A written O&M plan for the Township has not been developed yet, but we have identified it as a goal for this permit cycle. We are exploring the option to implement a stormwater fee and would like to design the stormwater program to address all aspects of the MS4 permit requirements.