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San Diego County Office of Education. Small MS4/Municipal Storm Water Workshop October 17, 2005. Welcome!. Introductions Housekeeping Initial Comments. Why Are We Here?. Review Small MS4 General Permit Requirements

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San Diego County Office of Education

Small MS4/Municipal

Storm Water Workshop

October 17, 2005


Welcome l.jpg
Welcome!

  • Introductions

  • Housekeeping

  • Initial Comments


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Why Are We Here?

  • Review Small MS4 General Permit Requirements

  • Review the Draft Storm Water Management Plan (SWMP) prepared for your District

  • Review the timeline for future activities


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Background

  • In 1999, the U.S. EPA Federal promulgated the Phase I storm water regulations for large MS4s, and for industrial and construction activities.

  • An MS4 is a Municipal Separate Storm Sewer System (i.e. a storm water conveyance system or system of conveyances, including roads, curbs, gutters, catch basins, channels and storm drains).

  • Within California, the federal storm water regulations are being implemented through MS4 permits adopted by the State Water Resources Control Board (SWRCB) and the local Regional Water Quality Control Board (RWQCB)


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Why are Small MS4s Being Regulated?

  • Urban runoff has been identified as a major source of surface water pollution in the United States

  • Urban runoff can contain sediment, nutrients, pathogens, petroleum hydrocarbons, heavy metals, herbicides, and other pollutants

  • Urban runoff from new development can impact natural vegetation, increase runoff volumes and velocities, and result in greater pollutant loads in surface waters


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So…What is this Small MS4 General Permit About?

  • The large MS4s owned and operated by the County of San Diego and each existing city therein are already permitted.

  • The SWRCB adopted a General Permit for Small MS4s on April 30, 2003. School districts and community colleges are considered “non-traditional” Small MS4s.

  • The General Permit requires that school districts and community colleges apply to be permitted within 180 days after being designated by the RWQCB.


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What Must Schools Districts Do To Be Permitted?

  • Submit a Notice of Intent (NOI)

  • Prepare and submit a Storm Water Management Plan (SWMP)

    • Describe Best Management Practices (BMPs) to address Six Minimum Control Measures and reduce pollutant discharges to Maximum Extent Practicable (MEP) *

    • Establish Measurable Goals

    • Identify Responsible Individuals

  • Payment of an annual permit fee is not required at this time

    * More stringent requirements apply in “high growth” areas (>25% increase in 10 years)


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Draft SWMP

Sections:

  • 1. Executive Summary

  • 2. Introduction

  • 3. Public Education and Outreach

  • 4. Public Involvement/Participation

  • 5. Illicit Discharge Detection and Elimination

  • 6. Construction Site Storm Water Runoff Control

  • 7. Post-Construction Storm Water Management in New

    Development and Redevelopment

  • 8. Pollution Prevention/ Good Housekeeping

  • 9. Monitoring and Reporting

  • 10. Supplemental Requirements

  • 11. Certification

  • Appendices


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Section 1Executive Summary

  • Introduction

  • General Permit Summary

  • BMP Summary

  • BMPs Applicable to Specific Departments or Activities (in appendices)


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Section 2Introduction

  • Background

    • List of District Sites

    • Description of Affected Watersheds

    • District Growth (>25% of 10 years?)

  • Small MS4 Permit Requirements

  • Program Benefits


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Section 2High Growth Districts

Districts with >25% increase in students and staff over 10 years (based primarily on DataQuest records):

  • Carlsbad Unified

  • Del Mar Union

  • Grossmont Union High

  • Grossmont-Cuyamaca Community College

  • Rancho Santa Fe

  • San Dieguito Union High

  • San Pasqual Union

  • San Ysidro

  • Sweetwater Union

  • Valley Center - Pauma Unified

  • Vallecitos


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Section 3Public Education and Outreach

  • Requirements

  • Control Measure Description

  • BMPs:

    • Develop Education Program

    • Educate Students

    • Train Employees and Facility Users

    • Inform Consultants and Contractors

  • Measurable goals and responsibleindividual(s) for each BMP


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Measurable Goals

  • The dates in the SWMP must be achievable

  • The District will have to report progress toward meeting each measurable goal in its annual reports

  • The RWQCB expects the Districts to proceed towards SWMP implementation (and not delay completion of all tasks for 5 years)


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Responsible Individuals

  • Potential persons responsible to implement BMPs:

    • Superintendent

    • Director of Maintenance, Operations and Transportation

    • Facility Planner

    • Principals and Teachers


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Section 4Public Involvement/Participation

  • Requirements

  • Control Measure Description

  • BMPs:

    • Public Notice

    • Storm Drain Marking Program

    • Local Watershed Input

    • Community Activity

  • Measurable goals and responsibleindividual(s) for each BMP


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Section 5Illicit Discharge Detection and Elimination

  • Requirements

  • Control Measure Description

  • BMPs:

    • Establish Legal Authority (amend District Policy if needed)

    • Map Preparation

    • Illicit Discharge Elimination

  • Measurable goals and responsibleindividual(s) for each BMP


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Section 6Construction Site Storm Water Runoff Control

  • Requirements

  • Control Measure Description

  • BMPs:

    • Establish Legal Authority (amend District Policy if needed)

    • Construction Plan Review

    • Construction Site Inspection

    • Construction Site - PublicInquiries/Complaints

  • Measurable goals and responsibleindividual(s) for each BMP


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Section 7Post-Construction Storm Water Management in New Development and Redevelopment

  • Requirements

  • Control Measure Description

  • BMPs:

    • Establish Legal Authority (amend District Policy if needed)

    • Develop Design Standards

    • BMP Inspection

  • Measurable goals and responsibleindividual(s) for each BMP


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Section 8Pollution Prevention/Good Housekeeping

  • Requirements

  • Control Measure Description

  • BMPs:

    • Pollution Prevention/ Good Housekeeping

    • Spill Prevention/Response

    • Environmentally Preferable Products

    • Bus Maintenance Facility

  • Measurable goals and responsibleindividual(s) for each BMP


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Section 9Monitoring and Reporting

  • Monitoring:

    • Construction Site Inspections

    • Surveillance for Non-Storm Water Discharges

    • Structural or Treatment Control BMP Inspections

  • Reporting:

    • Annual Reports (due September 15 of each year after the district is permitted)

    • Noncompliance Reports (if unable to certify compliance with SWMP or other General Permit requirements)

  • Records:

    • Retention (at least 5 years)

    • Submittal to RWQCB Upon Request

    • Availabile to public


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Section 10Supplemental Requirements(High Growth Districts Only)

The District must:

  • Comply with additional Receiving Water Limitations (if it is determined that facility runoff is causing or contributing to exceedence of water quality standards

    • Submit a report describing existing BMPs and the additional BMPs that will be implemented.

    • Revise SWMP and implement additional BMPs

  • Adopt and implement Mandatory Design Standards:

    • General Standards (e.g. peak post-development runoff, outdoor material and trash storage standards)

    • Category-Specific Standards (e.g. restaurant wash area, automotive repair shop, and parking lot standards)


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Section 11Certification

  • Certification that SWMP is accurate and complete.

  • Must be signed by a principal executive officer, ranking elected official or authorized representative (e.g. Superintendent)


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Appendices(BMPs Applicable to Specific Departments or Activities)

  • Appendix A: Facility Planning BMPS

  • Appendix B: Maintenance and Operations BMPs

  • Appendix C: Grounds Maintenance BMPs

  • Appendix D: Teacher/Administration BMPs

  • Appendix E: Special Event BMPs

  • Appendix F: Agricultural/ Confined Animal BMPs (some districts)

  • Appendix G: Autoshop BMPs (some districts)

  • Appendix H: General Small MS4 Permit


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When Must Schools Comply?

  • Submit NOI and SWMP within 180 days after being designated by the RWQCB.

  • Implement SWMP over 5 years (showing continued progress).

  • After being permitted, submit Annual Reports by September 15 of each year.


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Annual Reports

  • Summarize results for each reporting period (July 1 through June 30)

    • Status of compliance with General Permit conditions

    • Assessment of BMP effectiveness

    • Status of progress towards meeting measurable goals

    • Monitoring results (if any)

    • Activities planned for next year

    • Proposed revisions to SWMP (with justification)


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Next Steps…

  • Provide comments on the draft SWMP back to SDCOE by January 16, 2006

  • Follow-up District Visits (Spring/Summer 2006) to clarify remaining questions and determine what you are already doing

  • Once the SWMP is finalized, adopt Resolution directing Superintendentto implement and enforce the SWMP

  • District Designation by Regional Water Board for MS4 Compliance: Date Still Uncertain


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Next Steps Continued…

  • Submit final Storm Water Management Plan and NOI within 180 days after being designated by the RWQCB

  • Receive RWQCB approval and Permit coverage

  • After being permitted, begin submitting annual reports by September 15 of each year


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Legal Authority Issues

  • Peggy Strand, Best, Best & Krieger


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Thank You for Attending!

Additional questions? Contact:

  • Joanne Branch at SDCOE (858) 292-3833 [email protected]

  • Steve Herrera at OEMC (530) 677-5286 [email protected]


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