Introduction to Compliance Introduction to Compliance Assistance DocumentsAssistance Documents

Part IPart I

Compliance Assistance DocumentsCompliance Assistance Documents

Morning Overview:Morning Overview: Discharge Point LocationDischarge Point Location SWPPI/SWMP – Standard RequirementsSWPPI/SWMP – Standard Requirements AlternativesAlternatives Scope of the SWPPI/SWMPScope of the SWPPI/SWMP Public Education ProgramPublic Education Program Pollution Prevention/Good HousekeepingPollution Prevention/Good Housekeeping

MS4 WebsiteMS4 Website

www.michigan.gov/deqstormwaterwww.michigan.gov/deqstormwater

Electronic copy of the MS4 PermitsElectronic copy of the MS4 Permits Compliance Assistance DocumentsCompliance Assistance Documents Links to other storm water resourcesLinks to other storm water resources

What is a MS4?What is a MS4? Municipal Separate Storm Municipal Separate Storm

Sewer SystemSewer System

All separate storm sewers All separate storm sewers owned/operated by a municipality owned/operated by a municipality or public entity that discharge to or public entity that discharge to surface waters of the statesurface waters of the state

A separate storm sewer system is A separate storm sewer system is a system of drainage, including, but a system of drainage, including, but not limited to, roads, catch basins, not limited to, roads, catch basins, curbs, gutters, parking lots, ditches, curbs, gutters, parking lots, ditches, conduits, pumping devices, or man-conduits, pumping devices, or man-made channels.made channels.

What is a discharge point?What is a discharge point?

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

Mapping of Discharge PointsMapping of Discharge Points

For points identified, For points identified, constructed, or installed constructed, or installed after application:after application:

Provide an updated mapProvide an updated map• LocationLocation• Unique identifierUnique identifier• Receiving surface watersReceiving surface waters• Latitude/LongitudeLatitude/Longitude

Mapping of Mapping of Discharge PointsDischarge Points

Labeling of Discharge Point:Labeling of Discharge Point: Required under Jurisdictional PermitRequired under Jurisdictional Permit Recommended for Watershed PermitteesRecommended for Watershed Permittees

Questions?Questions?

Program PlansProgram Plans

Storm Water Storm Water Pollution Prevention Pollution Prevention Initiative (SWPPI)Initiative (SWPPI) Watershed PermitWatershed Permit Requirements listed Requirements listed

on pages 8-20on pages 8-20 Permittee specificPermittee specific Typically submitted 1 Typically submitted 1

year after issuance of year after issuance of COCCOC

Storm Water Storm Water Management Management Program (SWMP)Program (SWMP) Jurisdictional PermitJurisdictional Permit Requirements listed on Requirements listed on

pages 5-18pages 5-18 Permittee specificPermittee specific Typically submitted 6 Typically submitted 6

months after issuance months after issuance of COC.of COC.

SWPPI DevelopmentSWPPI Development FlexibilityFlexibility Complete and approved upon submittalComplete and approved upon submittal Implementation begins upon submittalImplementation begins upon submittal Department may request modification at Department may request modification at

any timeany time PEP/IDEP submitted as part of SWPPIPEP/IDEP submitted as part of SWPPI Example summary table for SWPPI Example summary table for SWPPI

included in assistance documentincluded in assistance document

SWMP DevelopmentSWMP Development Complete and approved upon submittalComplete and approved upon submittal Implementation begins upon submittalImplementation begins upon submittal Department may request modification at any Department may request modification at any

time time Six minimum measuresSix minimum measures Best Management PracticesBest Management Practices Measurable GoalsMeasurable Goals TimeframesTimeframes Example table for SWMP development is Example table for SWMP development is

included in assistance documentincluded in assistance document

Compliance EvaluationsCompliance Evaluations

To begin this permit cycleTo begin this permit cycle

Compliance determined based on actions Compliance determined based on actions listed in the SWPPI/SWMPlisted in the SWPPI/SWMP File ReviewsFile Reviews Staff InterviewsStaff Interviews Field VisitsField Visits

Questions?Questions?

Alternative ApproachesAlternative Approaches

Allowed for in both permitsAllowed for in both permits

Submitted for review and approval with Submitted for review and approval with SWPPI or SWMPSWPPI or SWMP

At least as effective as the standard permit At least as effective as the standard permit requirementrequirement

Alternative ApproachesAlternative Approaches

Key points to include:Key points to include: Detailed description of the approachDetailed description of the approach Participating permitteesParticipating permittees Part(s) of permit the alterative fulfillsPart(s) of permit the alterative fulfills Implementation scheduleImplementation schedule Benefits and drawbacks Benefits and drawbacks Evaluation of effectivenessEvaluation of effectiveness

SWPPI Alternative ApproachesSWPPI Alternative Approaches

Allowed for any Allowed for any standard requirementstandard requirement

Example: IDEP or Example: IDEP or Post-construction Post-construction Alternative Alternative ApproachesApproaches

SWMP Alternative ApproachSWMP Alternative Approach

Allowed for E. Coli Allowed for E. Coli and Phosphorus and Phosphorus TMDLsTMDLs

IDEP dry weather IDEP dry weather screening screening

Post-construction Post-construction storm water control storm water control requirementsrequirements

Alternative Approval ProcessAlternative Approval Process

Submit to the Department for Submit to the Department for reviewreview

Implementation Team review Implementation Team review and commentand comment

Department Department Approval/Modification/DenialApproval/Modification/Denial

Implemented upon approvalImplemented upon approval

Modifications may be requested Modifications may be requested

Modifications must be completed within Modifications must be completed within six months of SWPPI/SWMP submittal, or six months of SWPPI/SWMP submittal, or other date set by the Departmentother date set by the Department

If your approach is denied because If your approach is denied because it needs modification…it needs modification…

If your approach is denied…If your approach is denied…

If modifications are not completed, or if the If modifications are not completed, or if the approach is deniedapproach is denied SWPPI/SWMP must be revised to meet SWPPI/SWMP must be revised to meet

applicable standard permit requirement within applicable standard permit requirement within 90 days of notification from the Department90 days of notification from the Department

Questions?Questions?

Scope of SWPPI - Regulated AreaScope of SWPPI - Regulated Area

Regulated area = Area under a watershed Regulated area = Area under a watershed management planning process (watershed not management planning process (watershed not deferred) and the urbanized area.deferred) and the urbanized area.

Post-construction and PEP are implemented Post-construction and PEP are implemented throughout the regulated area. throughout the regulated area.

All other requirements are implemented only All other requirements are implemented only where the permittee owns and operates a MS4 where the permittee owns and operates a MS4 in the regulated areain the regulated area

Example 1 – Watershed PermitteeExample 1 – Watershed Permittee

MS4 A

MS4 B

MS4 D

MS4 C

Deferred Watershed

Watershed Not Deferred

Urbanized Area

Scope of SWMP – Regulated AreaScope of SWMP – Regulated Area

Regulated area = the urbanized area Regulated area = the urbanized area

All permit requirements are implemented All permit requirements are implemented for MS4s within the urbanized areafor MS4s within the urbanized area

Example 2 – Jurisdictional PermitteeExample 2 – Jurisdictional Permittee

MS4 A MS4 CUrbanized Area

MS4 B

Non-Urbanized Area

MS4 D MS4 E

Questions?Questions?

Public Education Plan/ProgramPublic Education Plan/Program

Submitted as part of Submitted as part of the SWPPI or the SWPPI or SWMP SWMP

PEP requirements PEP requirements vary slightly vary slightly between SWPPI between SWPPI and SWMPand SWMP

Public Education PlanPublic Education Plan

Methods for determining the overall Methods for determining the overall effectiveness shall be included in the planeffectiveness shall be included in the plan

Example methods:Example methods: Individually or cumulatively assess actions/delivery Individually or cumulatively assess actions/delivery

mechanismsmechanisms SurveySurvey May include working collaboratively to assess May include working collaboratively to assess

watershed-widewatershed-wide Some combination of the aboveSome combination of the above

Questions?Questions?

Pollution Prevention and Good Pollution Prevention and Good Housekeeping Activities for Municipal Housekeeping Activities for Municipal

OperationsOperations

Will address these topics in the SWPPI/SWMP:Will address these topics in the SWPPI/SWMP: Employee/Contractor TrainingEmployee/Contractor Training• Structural Storm Water Control EffectivenessStructural Storm Water Control Effectiveness• Roadways, Parking Lots and BridgesRoadways, Parking Lots and Bridges• Fleet Maintenance and Storages Yards; andFleet Maintenance and Storages Yards; and• Managing Vegetated PropertiesManaging Vegetated Properties

Activities may involve many facets of your Activities may involve many facets of your everyday municipal operationseveryday municipal operations

P2/GH Employee/Contractor TrainingP2/GH Employee/Contractor Training

Relevant municipal Relevant municipal operations that effect operations that effect water qualitywater quality

Example topics: Example topics: Landscaping practicesLandscaping practices Fleet maintenance and Fleet maintenance and

operationsoperations Proper disposal of waste & Proper disposal of waste &

wastewaterswastewaters Storm sewer maintenanceStorm sewer maintenance

P2/GH Employee/Contractor TrainingP2/GH Employee/Contractor Training

Existing employees – one training session Existing employees – one training session prior to expiration of this permitprior to expiration of this permit

New employees – one training session New employees – one training session during first year of employment during first year of employment

Contractors – trained before they begin Contractors – trained before they begin contract work (providing training materials contract work (providing training materials is adequate) is adequate)

P2/GH Structural Storm Water ControlP2/GH Structural Storm Water Control

Type and Number of Structural Controls Type and Number of Structural Controls owned/operatedowned/operated

P2/GH Structural Storm Water ControlP2/GH Structural Storm Water Control

List of Municipal PropertiesList of Municipal Properties Parks, cemeteries, public works yards, etcParks, cemeteries, public works yards, etc

P2/GH Structural Storm Water ControlP2/GH Structural Storm Water Control

Schedules for Inspection and MaintenanceSchedules for Inspection and Maintenance Inspections should be documented and Inspections should be documented and

retainedretained

P2/GH Disposal of Operation and P2/GH Disposal of Operation and Maintenance WasteMaintenance Waste

Procedures to dispose of Procedures to dispose of O & M wastes in O & M wastes in accordance with:accordance with:

Part 111 (hazardous Part 111 (hazardous waste)waste)

Part 115 (solid waste)Part 115 (solid waste) Part 121 (liquid industrial Part 121 (liquid industrial

waste)waste)

““Guidance for Catch Guidance for Catch Basin Cleaning Activities”Basin Cleaning Activities”

P2/GH - Adding Facilities or P2/GH - Adding Facilities or Structural ControlsStructural Controls

Design and install based on:Design and install based on: Treatment Volume StandardTreatment Volume Standard Channel Protection CriteriaChannel Protection Criteria Requirements for O & MRequirements for O & M

Upgrading and rehabilitation of existing Upgrading and rehabilitation of existing facilities or structural controls, based on facilities or structural controls, based on the criteria listed abovethe criteria listed above

Permittees should Permittees should consider the impacts of consider the impacts of snow removal practices. snow removal practices. The following may The following may reduce the discharge of reduce the discharge of pollutants into the MS4: pollutants into the MS4:

Store on grassed areasStore on grassed areas Don’t plow into surface Don’t plow into surface

waterswaters Prevent piling near storm Prevent piling near storm

drainsdrains

P2/GH – Snow Removal PracticesP2/GH – Snow Removal Practices

P2/GH – Salt & SandP2/GH – Salt & Sand

Salt and sand applied Salt and sand applied to improve traction to improve traction shall be prevented shall be prevented from entering MS4s from entering MS4s and receiving streams and receiving streams to MEPto MEP

Storage of salt and Storage of salt and sand must be sand must be managed properlymanaged properly

Control dust and Control dust and suspended solids in suspended solids in runoff from unpaved runoff from unpaved roads and parking lotsroads and parking lots

DiversionsDiversions Dust control productsDust control products Minimizing DisturbanceMinimizing Disturbance StabilizationStabilization Good gravelGood gravel Removal of snow plow Removal of snow plow

ridgesridges

P2/GH – Unpaved RoadsP2/GH – Unpaved Roads

Minimize the discharge of Minimize the discharge of pollutants related to the pollutants related to the management of management of vegetation on land the vegetation on land the permittee owns or permittee owns or operatesoperates

Training of Employees Training of Employees and Contractorsand Contractors

Phosphorus-free Phosphorus-free fertilizersfertilizers

P2/GH – Managing Vegetated P2/GH – Managing Vegetated PropertiesProperties

Program to Program to minimize impactsminimize impacts Implement and Implement and

maintain riparian maintain riparian zoneszones

Native landscapingNative landscaping Integrated Pest Integrated Pest

ManagementManagement Prevent leaves & Prevent leaves &

grass from entering grass from entering storm drains & storm drains & surface waterssurface waters

CompostingComposting Aerate compacted Aerate compacted

soilsoil

P2/GH – Managing P2/GH – Managing Vegetated Vegetated PropertiesProperties

Questions?Questions?