Introduction to Compliance Assistance Documents Part I

Compliance Assistance Documents  Morning Overview: Discharge Point Location Discharge Point Location SWPPI/SWMP – Standard Requirements SWPPI/SWMP – Standard Requirements Alternatives Alternatives Scope of the SWPPI/SWMP Scope of the SWPPI/SWMP Public Education Program Public Education Program Pollution Prevention/Good Housekeeping Pollution Prevention/Good Housekeeping

MS4 Website  Electronic copy of the MS4 Permits  Compliance Assistance Documents  Links to other storm water resources

What is a MS4? What is a MS4?  Municipal Separate Storm Sewer System All separate storm sewers owned/operated by a municipality or public entity that discharge to surface waters of the state All separate storm sewers owned/operated by a municipality or public entity that discharge to surface waters of the state A separate storm sewer system is a system of drainage, including, but not limited to, roads, catch basins, curbs, gutters, parking lots, ditches, conduits, pumping devices, or man- made channels. A separate storm sewer system is a system of drainage, including, but not limited to, roads, catch basins, curbs, gutters, parking lots, ditches, conduits, pumping devices, or man- made channels.

What is a discharge point? “Any location on the MS4 owned or operated by the permittee that discharges directly to a surface water of the state, or any location on the MS4 owned or operated by the permittee that discharges to any other separate storm sewer system before discharging to a surface water of the state.”

Mapping of Discharge Points For points identified, constructed, or installed after application: Provide an updated map Location Unique identifier Receiving surface waters Latitude/Longitude

Mapping of Discharge Points  Labeling of Discharge Point: Required under Jurisdictional Permit Required under Jurisdictional Permit Recommended for Watershed Permittees Recommended for Watershed Permittees

Questions?

Program Plans  Storm Water Pollution Prevention Initiative (SWPPI) Watershed Permit Watershed Permit Requirements listed on pages 8-20 Requirements listed on pages 8-20 Permittee specific Permittee specific Typically submitted 1 year after issuance of COC Typically submitted 1 year after issuance of COC  Storm Water Management Program (SWMP) Jurisdictional Permit Requirements listed on pages 5-18 Permittee specific Typically submitted 6 months after issuance of COC.

SWPPI Development  Flexibility  Complete and approved upon submittal  Implementation begins upon submittal  Department may request modification at any time  PEP/IDEP submitted as part of SWPPI  Example summary table for SWPPI included in assistance document

SWMP Development  Complete and approved upon submittal  Implementation begins upon submittal  Department may request modification at any time  Six minimum measures  Best Management Practices  Measurable Goals  Timeframes  Example table for SWMP development is included in assistance document

Compliance Evaluations  To begin this permit cycle  Compliance determined based on actions listed in the SWPPI/SWMP File Reviews File Reviews Staff Interviews Staff Interviews Field Visits Field Visits

Questions?

Alternative Approaches  Allowed for in both permits  Submitted for review and approval with SWPPI or SWMP  At least as effective as the standard permit requirement

Alternative Approaches  Key points to include: Detailed description of the approach Detailed description of the approach Participating permittees Participating permittees Part(s) of permit the alterative fulfills Part(s) of permit the alterative fulfills Implementation schedule Implementation schedule Benefits and drawbacks Benefits and drawbacks Evaluation of effectiveness Evaluation of effectiveness

SWPPI Alternative Approaches  Allowed for any standard requirement  Example: IDEP or Post-construction Alternative Approaches

SWMP Alternative Approach  Allowed for E. Coli and Phosphorus TMDLs  IDEP dry weather screening  Post-construction storm water control requirements

Alternative Approval Process  Submit to the Department for review  Implementation Team review and comment  Department Approval/Modification/Denial  Implemented upon approval

 Modifications may be requested  Modifications must be completed within six months of SWPPI/SWMP submittal, or other date set by the Department If your approach is denied because it needs modification…

If your approach is denied…  If modifications are not completed, or if the approach is denied SWPPI/SWMP must be revised to meet applicable standard permit requirement within 90 days of notification from the Department SWPPI/SWMP must be revised to meet applicable standard permit requirement within 90 days of notification from the Department

Questions?

Scope of SWPPI - Regulated Area  Regulated area = Area under a watershed management planning process (watershed not deferred) and the urbanized area.  Post-construction and PEP are implemented throughout the regulated area.  All other requirements are implemented only where the permittee owns and operates a MS4 in the regulated area

Example 1 – Watershed Permittee MS4 A MS4 B MS4 D MS4 C Deferred Watershed Watershed Not Deferred Urbanized Area

Scope of SWMP – Regulated Area  Regulated area = the urbanized area  All permit requirements are implemented for MS4s within the urbanized area

Example 2 – Jurisdictional Permittee MS4 A MS4 C Urbanized Area MS4 B Non-Urbanized Area MS4 D MS4 E

Questions?

Public Education Plan/Program  Submitted as part of the SWPPI or SWMP  PEP requirements vary slightly between SWPPI and SWMP

Public Education Plan  Methods for determining the overall effectiveness shall be included in the plan  Example methods: Individually or cumulatively assess actions/delivery mechanisms Individually or cumulatively assess actions/delivery mechanisms Survey Survey May include working collaboratively to assess watershed-wide May include working collaboratively to assess watershed-wide Some combination of the above Some combination of the above

Questions?

Pollution Prevention and Good Housekeeping Activities for Municipal Operations  Will address these topics in the SWPPI/SWMP: Employee/Contractor Training Employee/Contractor Training Structural Storm Water Control Effectiveness Structural Storm Water Control Effectiveness Roadways, Parking Lots and Bridges Roadways, Parking Lots and Bridges Fleet Maintenance and Storages Yards; and Fleet Maintenance and Storages Yards; and Managing Vegetated Properties Managing Vegetated Properties  Activities may involve many facets of your everyday municipal operations

P2/GH Employee/Contractor Training  Relevant municipal operations that effect water quality  Example topics: Landscaping practices Landscaping practices Fleet maintenance and operations Fleet maintenance and operations Proper disposal of waste & wastewaters Proper disposal of waste & wastewaters Storm sewer maintenance Storm sewer maintenance

P2/GH Employee/Contractor Training  Existing employees – one training session prior to expiration of this permit  New employees – one training session during first year of employment  Contractors – trained before they begin contract work (providing training materials is adequate)

P2/GH Structural Storm Water Control  Type and Number of Structural Controls owned/operated

P2/GH Structural Storm Water Control  List of Municipal Properties Parks, cemeteries, public works yards, etc Parks, cemeteries, public works yards, etc

P2/GH Structural Storm Water Control  Schedules for Inspection and Maintenance  Inspections should be documented and retained

P2/GH Disposal of Operation and Maintenance Waste  Procedures to dispose of O & M wastes in accordance with: Part 111 (hazardous waste) Part 111 (hazardous waste) Part 115 (solid waste) Part 115 (solid waste) Part 121 (liquid industrial waste) Part 121 (liquid industrial waste)  “Guidance for Catch Basin Cleaning Activities”

P2/GH - Adding Facilities or Structural Controls  Design and install based on: Treatment Volume Standard Treatment Volume Standard Channel Protection Criteria Channel Protection Criteria Requirements for O & M Requirements for O & M  Upgrading and rehabilitation of existing facilities or structural controls, based on the criteria listed above

 Permittees should consider the impacts of snow removal practices. The following may reduce the discharge of pollutants into the MS4:  Store on grassed areas  Don’t plow into surface waters  Prevent piling near storm drains P2/GH – Snow Removal Practices

P2/GH – Salt & Sand  Salt and sand applied to improve traction shall be prevented from entering MS4s and receiving streams to MEP  Storage of salt and sand must be managed properly

 Control dust and suspended solids in runoff from unpaved roads and parking lots Diversions Diversions Dust control products Dust control products Minimizing Disturbance Minimizing Disturbance Stabilization Stabilization Good gravel Good gravel Removal of snow plow ridges Removal of snow plow ridges P2/GH – Unpaved Roads

 Minimize the discharge of pollutants related to the management of vegetation on land the permittee owns or operates  Training of Employees and Contractors  Phosphorus-free fertilizers P2/GH – Managing Vegetated Properties

 Program to minimize impacts Implement and maintain riparian zones Native landscaping Integrated Pest Management Prevent leaves & grass from entering storm drains & surface waters Composting Aerate compacted soil P2/GH – Managing Vegetated Properties

Questions?