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MS4 Permit Updates. May 9, 2014. Jay Hoskins, P.E. Metropolitan St. Louis Sewer District. MS4 Permit Updates. MS4 Permit Renewal 3 rd Term Permit Stormwater Management Plan Highlights Federal Rulemaking Show-Me Rain Gardens Website. MS4 Permit Renewal.

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ms4 permit updates

MS4 Permit Updates

May 9, 2014

Jay Hoskins, P.E.

Metropolitan St. Louis Sewer District

ms4 permit updates1
MS4 Permit Updates

MS4 Permit Renewal

3rd Term Permit Stormwater Management Plan Highlights

Federal Rulemaking

Show-Me Rain Gardens Website

ms4 permit renewal
MS4 Permit Renewal
  • 2nd Term Permit expired June 12, 2013
  • MDNR has proposed, but not issued, a 3rd term MS4 general permit
    • 2nd term permit is administratively continued
  • Key issues in proposed permit
    • Water quality standards in MS4 permits
    • TMDL implementation
    • Affordability
water quality standards
Water Quality Standards (???)

CWA: Permits for discharges from municipal storm sewers…shall require controls to reduce the discharge of pollutants to the maximum extent practicable, including management practices, control techniques and system, design and engineering methods, and such other provisions as the Administrator or the State determines appropriate for the control of such pollutants.

tmdl implementation
TMDL Implementation
  • No MSD streams have EPA approved TMDLs, at present
  • Proposed permit requires
    • The permittee develop a TMDL Plan within 30 months following EPA approval of a TMDL
    • “Plan to address TMDL assumptions, requirements, WLAs, and LAs”
    • “Permittee must implement the plan”
  • MO statutes require MDNR perform a Finding of Affordability for new permit requirements
  • MDNR’s finding only addressed TMDL plan development—not implementation
    • “TMDL implementation responsibilities are not new requirements.”
    • Recently, MDNR managers agreed to revise this position and perform the affordability determination for plan implementation, in the future
ongoing ms4 permit activities
Ongoing MS4 Permit Activities
  • Continue to implement 6 MCMs…
    • Public Education & Outreach
    • Public Involvement & Participation
    • Illicit Discharge Detection & Elimination
    • Construction Site SW Control
    • Post-Construction SW Mgt in Development
    • P2/Good Housekeeping for Muni Ops
  • Submit 2013-14 annual report by July 28
  • Co-permittee group tabling most 3rd term SWMP activities until permit is renewed
3 rd term permit planning process
3rd Term Permit Planning Process
  • 7 planning committee


  • 3 public stakeholder group


  • 3 newsletter publications
  • New goal development
    • Researched new BMPs
    • MDNR audit


  • Draft SWMP public Notice

in October 2012

  • Final SWMP mailed to MDNR in December 2012
  • Available on MSD website
3 rd term permit plan new goals
3rd Term Permit Plan: New Goals
  • Develop standardized checklists and reporting procedures for post-BMPs
    • DONE—see BMP toolkit
  • Redevelopment Roadway Workgroup
    • Begun—not finished
  • Workgroup on incentives & awards for participating in NPS reduction programs
    • Begun—not finished
  • Ask cities to review, update parking ordinances (as needed)
    • Legal Impediment WG Recommendation
3 rd term permit plan new goals1
3rd Term Permit Plan: New Goals
  • Workgroup on improving NPS education in schools
  • Develop and distribute brochures on individual sewage disposal systems
  • Develop and conduct “staged” construction BMP inspection training
  • Updating municipal O&M model template, ask cities to update plans
  • Review BMP performance for bacteria, chloride
federal stormwater rulemaking
Federal Stormwater Rulemaking
  • EPA Finalized “Construction and Development Effluent Guidelines and Standards”
    • Effluent limits reflecting best practicable technology currently available:
      • “Control stormwater discharges, including both peak flowrates and total stormwater volume”
      • “Provide and maintain natural buffers around waters of the United States, direct stormwater to vegetated areas and maximize stormwater infiltration to reduce pollutant discharges, unless infeasible”
    • Withdrew numeric turbidity standard
  • EPA has deferred development of national post-construction BMP performance standard
show me rain gardens turn your yard into a superhero
Show-Me Rain Gardens(Turn your Yard Into a Superhero)
  • Education
  • Tips & tools
  • Picture gallery
  • Rain garden registration
Jay Hoskins

(314) 436-8757