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Introduction to Compliance Assistance Documents

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... suspended solids in runoff from unpaved roads and parking lots Diversions Dust control products Minimizing Disturbance Stabilization ... and modification ... – PowerPoint PPT presentation

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Title: Introduction to Compliance Assistance Documents


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.

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8
Mapping of Discharge Points
  • For points identified, constructed, or installed
    after application
  • Provide an updated map
  • Location
  • Unique identifier
  • Receiving surface waters
  • Latitude/Longitude

9
Mapping of Discharge Points
  • Labeling of Discharge Point
  • Required under Jurisdictional Permit
  • Recommended for Watershed Permittees

10
Questions?
11
Program Plans
  • 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.

12
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
13
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
14
Compliance Evaluations
  • To begin this permit cycle
  • Compliance determined based on actions listed in
    the SWPPI/SWMP
  • File Reviews
  • Staff Interviews
  • Field Visits

15
Questions?
16
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

17
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

18
SWPPI Alternative Approaches
  • Allowed for any standard requirement
  • Example IDEP or Post-construction Alternative
    Approaches

Watershed Permit
19
SWMP Alternative Approach
  • Allowed for E. Coli and Phosphorus TMDLs
  • IDEP dry weather screening
  • Post-construction storm water control requirements

Jurisdictional Permit
20
Alternative Approval Process
  • Submit to the Department for review
  • Implementation Team review and comment
  • Department Approval/Modification/Denial
  • Implemented upon approval

21
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

22
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

23
Questions?
24
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
25
Example 1 Watershed Permittee
Deferred Watershed
MS4 D
MS4 B
Watershed Not Deferred
MS4 C
MS4 A
Urbanized Area
Watershed Permit
26
Scope of SWMP Regulated Area
  • Regulated area the urbanized area
  • All permit requirements are implemented for MS4s
    within the urbanized area

Jurisdictional Permit
27
Example 2 Jurisdictional Permittee
MS4 E
MS4 D
Non-Urbanized Area
Urbanized Area
MS4 C
MS4 A
MS4 B
Jurisdictional Permit
28
Questions?
29
Public Education Plan/Program
  • Submitted as part of the SWPPI or SWMP
  • PEP requirements vary slightly between SWPPI and
    SWMP

30
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

31
Questions?
32
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

33
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

34
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)

35
P2/GH Structural Storm Water Control
  • Type and Number of Structural Controls
    owned/operated

36
P2/GH Structural Storm Water Control
  • List of Municipal Properties
  • Parks, cemeteries, public works yards, etc

37
P2/GH Structural Storm Water Control
  • Schedules for Inspection and Maintenance
  • Inspections should be documented and retained

38
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

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40
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

41
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
  • Dont plow into surface waters
  • Prevent piling near storm drains

42
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

43
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

44
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

45
  • 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

P2/GH Managing Vegetated Properties
46
Questions?
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