Las Vegas Valley Municipal Separate Storm Sewer System

2014 Audit Report

Executive Summary

The Nevada Division of Environmental Protection (NDEP) conducted an audit of the Las Vegas
Valley Municipal Separate Storm Sewer System (MS4). The purpose of the audit was to assess
the Las Vegas Valley agencies for compliance with the Las Vegas Valley MS4 National Pollution
Discharge Elimination System (NPDES) permit, and the Las Vegas Valley Storm Water Quality
Management Plan (SWMP). The audit involved the following co-permittees: City of Las Vegas,
City of Henderson, City of North Las Vegas, Clark County Regional Flood Control District, and
Clark County.

According to the audit, NDEP found compliance issues that must be addressed by all five (5) co-
permittees to both establish and maintain a MS4 program that is compliant with the NPDES
permit and SWMP. The audit report lists non-compliance in two (2) categories:
1) MS4 Program Management Structure, and
2) Potential Permit Violations/Areas Needing Improvement.

1. MS4 Program Management Structure:

Clear evidence that elected Board Members and City/County Managers are aware of and
committed to the program.
A named organization and leader that is empowered and accountable to oversee compliance
with the NPDES permit and SWMP.
A named leader within each co-permittees organization that is empowered and accountable
to execute the entire program.
A commitment to ensure that the budgets of all co-permittees include allocations for
staffing, equipment and materials.

2. Potential Permit Violations/Areas Needing Improvement:

Legal Authority Training
Mapping of Major Outfalls in the MS4. Public Outreach and Education.
MS4 Maintenance Activities. Construction and Industrial Site Inspections
Illicit Discharge Detection and Elimination. Industrial Facility Monitoring and Control
Post-Construction Program for New Development and Significant Redevelopment.
Stormwater Budgets.

The audit requires a single unified response from all co-permittees by December 4, 2015. The
response must include a plan and schedule to address MS4 Program Management Structure,
and include a plan and schedule to ensure full compliance with the NPDES permit and SWMP.
The response must also include a plan and schedule to address areas needing improvement.