MS4 & Construction Storm Water Permits Todd A. Bennett Environmental Protection Engineer Illinois EPA – Peoria Regional Office

What is the MS4 Program? Municipal Separate Storm Sewer Systems Addresses discharge of polluted, untreated storm water from urbanized areas Phase I (1990) Individual NPDES permits 750 large/medium cities and highly populated counties Phase II (1999) General NPDES permits 6,700 smaller urbanized areas USEPA Region 5 Program Emphasis

Rock Island & Henry Counties Based on US Census data Davenport, Iowa-Illinois Urbanized Area Original list of potential permits 24 in Rock Island County 7 in Henry County Waiver/Permit Process 10 permits in Rock Island County 1 permit in Henry County

Current MS4 Permits Village of Carbon Cliff Village of Coal Valley City of East Moline Village of Hampton Village of Milan City of Moline Village of Rapids City Rock Island County City of Rock Island City of Silvis City of Colona

Permit for MS4s Permit No. ILR40 Requires Notice of Intent (NOI) Effective March 1, 2016 Expires February 28, 2021 Requires Notice of Intent (NOI) Allows for shared responsibilities and partnering Automatic coverage by ILR10 after NOI

Special Conditions Discharges not causing or contributing to water quality standard violations (35 IAC 302) Total Maximum Daily Load (TMDL) considerations Deicing activities control measures (watershed group participation)

Storm Water Management Program “The permittee must develop, implement, and enforce a storm water management program designed to reduce the discharge of pollutants from their MS4, to the maximum extent practicable, to protect water quality...” Six minimum control measures... Best Management Practices (BMPs) Annual evaluations

1. Public Education/Outreach Education materials or outreach activities Private property pollution prevention Green infrastructure strategies Benefits/costs

2. Public Involvement/Participation Comply with State/local public notice requirements Minimum of one MS4 public meeting annually Identify and involve environmental justice (EJ) areas

3. Illicit Discharges Storm sewer system map Ordinance addressing illicit discharges to MS4 Enforcement program Periodic outfall dry-weather inspections

4. Construction Runoff Control Ordinance requiring erosion and sediment control Control non-storm water discharges (e.g. concrete washout) Require Storm Water Pollution Prevention Plans (SWPPPs) per ILR10 Site plan review procedures

Permit for Construction Activities Permit No. ILR10 Effective August 1, 2013 Modified April 30, 2014 Expires July 31, 2018 Disturbance of one or more acres total land area or less if part of larger development Requires NOI

Special Conditions Control non-storm water discharges TMDL considerations Discharges not causing or contributing to water quality standard violations (35 IAC 302)

Contents of the SWPPP Site Description Nature of work Sequence of activities Area estimation Site map Receiving water(s)

Contents of the SWPPP Controls Illinois Urban Manual www.aiswcd.org/IUM “... must be designed, installed, and maintained.”

Contents of the SWPPP Erosion and Sediment Controls Control storm water volume and velocity Minimize erosion at outlets and channel/streambank Minimize soil exposure Minimize disturbance of steep slopes Minimize sediment discharge Use natural buffers, vegetated areas, infiltration Minimize soil compaction Preserve topsoil

Contents of the SWPPP Stabilization Practices Interim (temporary) and permanent practices Site-specific scheduling Preserve existing vegetation to the extent possible Record of key dates major grading construction cessation (temporary or permanent) initiation of stabilization activity

Contents of the SWPPP “... Stabilization of disturbed areas must be initiated within 1 working day of permanent or temporary cessation of earth disturbing activities and shall be completed as soon as possible but not later than 14 days from the initiation of stabilization work in the area.”

Contents of the SWPPP Structural Practices Treatment Chemical Use Divert flows Store flows Limit runoff Sediment basins Outlets that draw from the surface Stabilize inlet and outlet Facilitate maintenance as necessary Treatment Chemical Use Identification Dosages and MSDS Storage and protection Proper usage Staff training

Contents of the SWPPP BMPs for 303(d) listed waters Pollution prevention practices (wash waters, wastes, leaks, and spills) Solid waste collection Compliance with applicable State and local regulations (waste disposal, sanitary sewers, septic systems, etc.) BMPs for post-construction storm water management

Contents of the SWPPP Inspections At least every 7 days Within 24 hours of precipitation of 0.5 inches or more Monthly if construction ceased due to frozen conditions Reports of each inspection maintained onsite

Contents of the SWPPP Records Kept at least 3 years beyond termination (or expiration) of the permit Maintain copies of SWPPP and inspection reports onsite Public posting of NOI and copy of ILR10 in a prominent place

Permit Termination After final stabilization is complete After elimination of construction storm water discharges Submit Notice of Termination by mail or electronically to the Permit Section

5. New and Redevelopment Post-Construction Runoff Volume and Pollutant Load Minimization Implementation of structural and/or non-structural BMP strategies (see order of preference in permit) Long-term operation and maintenance plans Public surfaces runoff minimization (e.g. green infrastructure) Private property runoff minimization program Ordinance and regulatory mechanisms Long-term maintenance and operation of BMPs

6. Municipal Housekeeping Annual training of municipal staff and contractors Pollution prevention program Equipment and vehicle wash waters Minimization of waste exposure Spill and leak prevention and procedures Regular inspection and maintenance of municipal BMPs Deicing material storage (structure required)

Monitoring Monitoring and Assessment Program Developed and implemented within 180 days of permit For smaller MS4s (population less than 25,000)... May just conduct visual inspections for offensive conditions For larger MS4s... Combination of various monitoring strategies Dependent on the characteristics of your MS4 Any analyses of discharges should at least include TSS, Total N, Total P, fecal coliform, chlorides, and oil & grease

Recordkeeping Records retained until 5 years after expiration of permit NOI SWMP Plan Annual reports Monitoring data Maintained onsite or locally available for inspection Website posting Annual reports (5 years)

Reporting Annual Reports Due by June 1 of each year Cover period of March to March Assessments BMPs Compliance Summary of monitoring results Summary of upcoming plans Responsibility sharing changes TMDL changes

Resources and Guidance USEPA MS4 Website https://www.epa.gov/npdes/stormwater-discharges-municipal-sources Overview of MS4 requirements Guidance for developing MS4 program Resources for 6 Minimum Control Measures of SWMP Resources Long-Term Storm Water Planning Fees and funding Training and webcasts

Questions Contact information: Todd A. Bennett todd.bennett@illinois.gov (309) 671-3028 Cathy Demeroukas cathy.demeroukas@illinois.gov (217) 785-3954