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

2. 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

3. 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

5. 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

6. 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

7. 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)

8. 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

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

10. 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

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

12. 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

13. 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

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

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

16. Contents of the SWPPP
Controls
Illinois Urban Manual
“... must be designed, installed, and maintained.”

17. 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

18. 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

19. 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.”

20. 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

21. 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

22. 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

23. 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

24. 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

25. 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

26. 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)

27. 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

28. 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)

29. 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

30. Resources and Guidance
USEPA MS4 Website
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

31. Questions
Contact information:
Todd A. Bennett
(309)
Cathy Demeroukas
(217)