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MS4 introduction

Spanish Fork 9-3-2013

Ryan Taylor

on 3 September 2013

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Transcript of MS4 introduction

Separate Storm Sewer System Phase II Basics

Public Education
What is the
MS4 program
Evolution of Storm Water Regulations
Illicit Discharge
Construction Runoff
Post Construction
Good House
Audit & Documentation Requirements
MS4 Program
Phase II MS4 Requirements

Public Education/Outreach
Public Participation/Involvement
Illicit Discharge Detection/Elimination
Pollution Prevention/Good Housekeeping
Construction Site Runoff Control
Post Construction Runoff Control

BMP's must be measurable and show improvements in water quality
The next step in EPA’s effort to preserve, protect and improve the nation’s water resources from polluted storm water runoff:

Expanding Phase I program requiring additional operators of small MS4’s in urbanized areas to implement a program featuring 6 minimum functional areas to control polluted storm water runoff.

Owner-Operator- > 1 acre - Obligated to comply regardless of location
Municipalities - Obligated to comply within certain population densities, must submit annual MS4 report and regulate construction sites

NPDES permits regulate the discharges from:
Wastewater treatment facilities
Industrial facilities
Concentrated animal feeding operations
Wet weather flows, such as:
Storm water discharges from industrial activities
Construction activities
Municipal storm water discharges

National Pollutant Discharge Elimination System (NPDES)— Section 402

Urban Areas are efficiently drained by storm water drainage systems
Urban Construction
History of Regulation

Phase I Rules 5 acres construction sites and municipalities > 100,000 population density
1/3 of U.S. waters polluted
Phase II Rules > 1 acre construction sites and municipalities > 10,000 population density
Local jurisdiction can regulate smaller sites
Major push on Enforcement

History of Regulation

2/3’s of U.S. waters are polluted
Clean Water Act restructured to regulate “point source” discharges through NPDES permitting
National Resource Defense Council (NRDC) files lawsuit challenging USEPA’s exemption of storm water discharges
Clean Water Act revised to mandate regulation of storm water … Non Point Source Pollution
National Urban Runoff Program Study- NURP

History of Regulation

1950’s - The Cayahoga River
Phase I

Storm Water Phase I & II
USA-Environmental Protection Agency

Air Toxics
Concentrated Animal Feeding Operations
Combined Sewer Overflows and Sanitary Sewer Overflows
New Source Review
Petroleum Refining
Clean Water Act: Wet Weather

Ensuring compliance with Clean Water Act requirements by addressing environmental challenges that are exacerbated by wet weather. Storm water runoff from urban areas can include a variety of pollutants, such as sediment, bacteria, organic nutrients, hydrocarbons, metals, oil and grease.

EPA’s National Priorities 2008-2010

Drafting/Revising Portions of the SWMP
Public Education & Public Involvement Ideas
System Mapping
Draft Ordinance Preparation
IDDE Inspections
Construction Inspections
Documentation Programs
Storm Water Pollutants
Road salts
Increased streamflow
Volume & Velocity

What is an MS4?
(Municipal Separate Storm Sewer System)

The MS4 program is:
Primarily focused on storm water QUALITY
Addresses non-point source pollution in cities
Is a discharge permit
Similar in some ways to a discharge permit for waste water, or industrial activities
Cost Money

(1) Residents, (2) businesses, institutions, and commercial facilities, (3) developers and contractors, and (4) MS4 industrial facilities

Outreach & educational efforts should include a multimedia approach

Provide and document info. given to the public about the MS4’s prohibitions against illicit discharges and improper disposal of waste.

Septic system maintenance, lawn care, benefits of on-site infiltration of storm water, effects of auto work, car washing on WQ, proper disposal of pool water, pet waste
Public Education and Outreach
Construction: developers, contractors, engineers, development review staff, land use planners

Provide and document any information and training
Low Impact Development (LID) practices
Specific requirements for long-term storm water management (post-construction)

Public Education and Outreach
Water Fairs
TV & radio advertizing
Contractor trainings (RSI classes)
School programs

Public Education and Outreach
Public Education and Outreach
Businesses and Institutions/MS4-owned/operated Facilities:

Proper lawn maintenance
Benefits of on-site infiltration
Building & equipment maintenance
Salt/deicing materials
Proper storage of materials (pollution prevention)
Proper mgmt. of waste materials & dumpsters
Proper mgmt. of parking lot surfaces (sweeping)

Public Education and Outreach
Public Participation/Involvement

Advisory panels
Public hearings
Watershed committees
Stewardship programs
Volunteer opportunities

A discharge to an MS4 that is not composed entirely of storm water except those listed in permit.
Illicit Discharge Detection and Elimination (IDDE)
Program Components:
Storm Sewer System Mapping
Routine Dry Weather Screening of outfalls
Inspection Form,
Qualified Inspectors
Ordinance or other Regulatory Mechanism
Investigation of Suspected Illicit Discharges and/or Improper Disposal
SOPs, inspection report
Escalating Enforcement Procedures
Illicit Discharge Detection and Elimination (IDDE)
Program Components:
Field assessment activities to verify outfall locations, detect illicit discharges, including dry weather screening of outfalls/facilities serving priority areas:
20 percent of priority areas by August 1, 2011
Additional 20 percent of priority areas each year thereafter
Illicit Discharge Detection and Elimination (IDDE) (cont.)
Program Components:
Inform public of hazards associated with illegal discharges and improper disposal of waste
Publicly list and publicize a hotline/other local telephone number for reporting
Written spill/illegal dumping response procedure, including contract staff and other responsible entities
Municipal Staff Education and Training

Illicit Discharge Detection and Elimination (IDDE) (cont.)
Poorly maintained BMPs can result in significant quantities of sediment being discharged to storm drains
Construction Site Storm Water Runoff Control
Pre-construction SWPPP Review Procedures and Checklist
Construction Site SWPPPs and BMPs
Ordinance/Other regulatory mechanism that requires BMP / BEP practices at construction sites
Concrete washout, off-site tracking, chemicals, litter, sanitary waste

Construction Site Storm Water Runoff Control
Construction Site Inspections using State Inspection Form (Checklist),
By a Qualified Inspector
Identify Priority Construction Sites
Monthly Inspections
Biweekly Inspections (Priority Sites)
Proximity to waterbody
Soil erosion potential
Site slope
Project size
Sensitivity to receiving water
Past record of non-compliance by operators
Escalating Enforcement Procedures
Training and Education
Construction Site Storm Water Runoff Control
Prior to Land Disturbance: to ensure all BMP’s are in place.

During Active Construction

Following Active Construction: to ensure final stabilization; all temporary BMP’s removed.

Construction Site Storm Water
Runoff Control

Every active construction site inspected once per month
High priority sites every two weeks
Inspections by a qualified inspector (RSI)
Inspections completed on state forms
Construction Site Inspections

Mimic pre-development hydrology of the previously undeveloped site; or
Improve the hydrology of a redeveloped site and reduce the discharge of storm water
Private and public development
Evaluate and encourage a LID approach where practicable
Infiltrate, evapotranspire or harvest and use storm water

Long-Term Storm Water Management

Ordinance or other regulatory mechanism that requires long-term post-construction storm water controls
Require BMP selection, design, installation, O & M necessary to protect water quality and reduce discharge of pollutants to MS4
Both construction-phase and post-construction phase access to
(O & M)
Escalating enforcement procedures
Bill or recoup costs from property owners

Long-Term Storm Water Management
Site plan reviews that incorporate consideration of WQ impacts
Pre-construction SWPPP review to ensure they include long-term storm water management measures
Permanent structural BMPs inspected at least once during installation
Inspections and any necessary maintenance conducted annually (either by Permittee/agreement)
Permittee inspects at least once every 5 years; document with inspection report
Long-Term Storm Water Management
Include provisions to allow permittees to inspect BMPs on private property or require private property owners to provide annual certification by a qualified third party that adequate maintenance has been performed
Long-Term Storm Water Management
Structural BMPs: storm water retention, grassed or vegetative swales, stream buffers, vegetative filter strips, infiltration basins, energy dissipaters, constructed wetlands, sand filters, etc.
Green infrastructure practices: rainwater harvesting, rain gardens, permeable pavement, and vegetative swales

Long-Term Storm Water Management
Infiltration islands in parking lots can help reduce storm water runoff.

Long-Term Storm Water Management

Minimizing development in areas susceptible to erosion and sediment loss
Minimize disturbance of native soils and vegetation
Limiting growth to identified areas
Minimizing imperviousness
Maintaining open space,
Protecting sensitive areas; wetlands and stream buffers
Preserving natural drainage patterns
Education for developers and the public about project designs that minimize water quality impacts
Long-Term Storm Water Management
Develop a plan to retrofit existing developed sites that are adversely impacting WQ.

Emphasis on controls that infiltrate, evapotranspire, and harvest/use storm water

Rank control measures to determine those best suited for retrofitting as well as those that could later be considered.
Long-Term Storm Water Management
Inventory of potential retrofit locations should consider locations that:
Contribute POCs to impaired waterbody
Contribute to receiving waters that are significantly eroded
Tributary to a sensitive or protected area
Tributary to areas prone to flooding
Long-Term Storm Water Management
Prioritize retrofit locations:
Cost effectiveness
Pollutant removal effectiveness
Amount of impervious area potentially treated
Maintenance requirements
Aesthetic qualities

Long-Term Storm Water Management
Inventory of all structural storm water control measures (both private and public)
Maintenance requirements
Inspection information
Long-Term Storm Water Management
O & M Programs
Facilities Inventory
Employee Training
Pollution Prevention and Good Housekeeping for Municipal Operations
O & M Program for Municipal Operations/Facilities/Controls
Storm water collection and conveyance systems
Roads, highways, and parking lots
Vehicle fleets
Municipal buildings
Parks and Open Space
Vehicle and equipment maintenance shops

Pollution Prevention and Good Housekeeping for Municipal Operations
Facility, Operations, Storm Water Controls Inventory
High-priority facilities: those having a high potential to generate storm water pollutants
Sediment, nutrients, hydrocarbons, pesticides, chlorine, trash, bacteria
Material/heavy equipment storage areas
Maintenance areas
Pollution Prevention and Good Housekeeping for Municipal Operations
SOPs should include BMPs that, when applied to the municipal operation, facility or storm water control will protect water quality and reduce the discharge of pollutants to the MS4.

Pollution Prevention and Good Housekeeping for Municipal Operations
Inspections (high-priority)

Weekly visual inspections (refer to SOPs) tracked in a log
Identify deficiencies and corrective actions
Quarterly comprehensive inspections
Document using an inspection reports noting deficiencies and corrective actions
Quarterly visual
Any observed problems (e.g., color, foam, sheen, turbidity) associated with pollutant sources or controls
Inspection report
Pollution Prevention and Good Housekeeping for Municipal Operations
What type of training do field staff (e.g., storm sewer maintenance crews, street sweepers) receive on spill response and IDDE?
In-house training

Are staff generally educated about what illicit discharges are and how to report them?
Municipal Staff Education and Training

Clear, written plan,
Measurable goals
Detailed standard operating procedures
Detailed BMP's used in the city
Updated frequently (annually)
Reflects actual city procedures


Written procedures

Inspection Documents

Plan review, checklists

Municipal SOPs and Maintenance Schedules
Records Review
Construction Site Inspections
Municipal Facilities Inspections
IDDE / Dry Weather Inspections
Post-Construction Inspections
Complaint Response
Lack of basic permit knowledge
Lack of SWMP review and modification
Common Issues
Track and Document everything!!
Training / Education
Who, how many, what, copy of presentation etc.
Public involvement
Who, how many, what, when, pictures, etc.
Inspections, pictures, complaints, etc.
Enforcement actions

Proper Documentation
Legally enforceable
Allows for inspection
Escalating Enforcement

Phase II
Can Help
An MS4 is NOT...
A storm water master plan
A hydraulic model of the system
A storm water design manual
A flood control program
A zoning restriction program
Where To Start
1) Draft Storm water management plan for your city
2) Fill out the Notice of Intent Form (NOI) and submit
3) Implement the storm water management plan
4) Measure & evaluate performance of SWMP BMP's
5) Submit annual report on SWMP implementation and performance
6) Revise SWMP document
7) Improve and Repeat
Public Participation/Involvement
Storm drain stenciling
Community clean-ups
Citizen watch groups,
“Adopt a Storm Drain”
Public Participation/Involvement
Current SWMP online for public review (required)
Complaint hotline / Web site
Free disposal day

Improper waste and waste water disposal
Failure to conduct necessary inspections
Common Issues
Lack of documentation i.e., written procedures, checklists, inspection forms, rationale statement
Common Issues
Improper waste and waste water disposal

House Keeping
Disposal records
Daily logs

Post Construction
O&M records
Inspections, precipitation records, copies of SWPPP's
SWPPP reviews
Check lists
Precon meeting notes
Annual Reports
Brief document
highlight results of program
measurements of BMP's
Document successes
Document area's for improvement
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