Introduction to Compliance Assistance Documents

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Introduction to Compliance Assistance Documents

• Part I

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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

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MS4 Website

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

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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.

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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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Mapping of Discharge Points

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

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Mapping of Discharge Points

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

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Questions?
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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.

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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
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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
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Compliance Evaluations

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

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Questions?
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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

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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

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SWPPI Alternative Approaches

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

Watershed Permit
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SWMP Alternative Approach

• Allowed for E. Coli and Phosphorus TMDLs
• IDEP dry weather screening
• Post-construction storm water control requirements

Jurisdictional Permit
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Alternative Approval Process

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

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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

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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

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Questions?
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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
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Example 1 Watershed Permittee
Deferred Watershed
MS4 D
MS4 B
Watershed Not Deferred
MS4 C
MS4 A
Urbanized Area
Watershed Permit
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Scope of SWMP Regulated Area

• Regulated area the urbanized area
• All permit requirements are implemented for MS4s
  within the urbanized area

Jurisdictional Permit
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Example 2 Jurisdictional Permittee
MS4 E
MS4 D
Non-Urbanized Area
Urbanized Area
MS4 C
MS4 A
MS4 B
Jurisdictional Permit
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Questions?
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Public Education Plan/Program

• Submitted as part of the SWPPI or SWMP
• PEP requirements vary slightly between SWPPI and
  SWMP

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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

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Questions?
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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

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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

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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)

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P2/GH Structural Storm Water Control

• Type and Number of Structural Controls
  owned/operated

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P2/GH Structural Storm Water Control

• List of Municipal Properties
• Parks, cemeteries, public works yards, etc

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P2/GH Structural Storm Water Control

• Schedules for Inspection and Maintenance
• Inspections should be documented and retained

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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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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

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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

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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

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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

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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

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• 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
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Questions?