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Understanding MS4 and SWPPI Requirements for Effective Stormwater Management

This document provides an overview of compliance assistance for Municipal Separate Storm Sewer Systems (MS4) and Storm Water Pollution Prevention Initiatives (SWPPI). It covers essential aspects such as discharge point locations, mapping requirements, permit submissions, and alternative approaches to compliance. Key features include the scope of SWPPI, public education programs, and best management practices. Understanding these components is crucial for municipalities to effectively manage stormwater and comply with Michigan's regulations.

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Understanding MS4 and SWPPI Requirements for Effective Stormwater Management

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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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