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Introduction to Compliance Assistance Documents

Introduction to Compliance Assistance Documents. Part I. Compliance Assistance Documents. Morning Overview: Discharge Point Location SWPPI/SWMP – Standard Requirements Alternatives Scope of the SWPPI/SWMP Public Education Program Pollution Prevention/Good Housekeeping. MS4 Website.

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Introduction to Compliance Assistance Documents

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  1. Introduction to Compliance Assistance Documents Part I

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

  3. MS4 Website www.michigan.gov/deqstormwater • Electronic copy of the MS4 Permits • Compliance Assistance Documents • Links to other storm water resources

  4. 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 • 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.

  5. 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.”

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

  7. Mapping of Discharge Points • Labeling of Discharge Point: • Required under Jurisdictional Permit • Recommended for Watershed Permittees

  8. Questions?

  9. Storm Water Pollution Prevention Initiative (SWPPI) Watershed Permit Requirements listed on pages 8-20 Permittee specific 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. Program Plans

  10. 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 Watershed Permit

  11. 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 Jurisdictional Permit

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

  13. Questions?

  14. 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

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

  16. SWPPI Alternative Approaches • Allowed for any standard requirement • Example: IDEP or Post-construction Alternative Approaches Watershed Permit

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

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

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

  20. 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

  21. Questions?

  22. 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 Watershed Permit

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

  24. Scope of SWMP – Regulated Area • Regulated area = the urbanized area • All permit requirements are implemented for MS4s within the urbanized area Jurisdictional Permit

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

  26. Questions?

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

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

  29. Questions?

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

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

  32. 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)

  33. P2/GH Structural Storm Water Control • Type and Number of Structural Controls owned/operated

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

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

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

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

  38. P2/GH – Snow Removal Practices • 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

  39. 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

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

  41. P2/GH – Managing Vegetated Properties • 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

  42. 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

  43. Questions?

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