hal zweng field services environmental engineer february 2015
TRANSCRIPT
Municipal Separate Storm Sewer System (MS4)
• Part of the National Pollutant Discharge Elimination System (NPDES)
• Required of any urban public agency that discharges to the waters of the state
• DEQ administers and enforces on behalf of the EPA
MDOT MS4 Permit
• Issued in 2005• Expired in 2009 but administratively
extended due to regulatory issues• New permit expected to be issued
September 2015• Five Year contract for Engineering
Assistance should be advertised soon
• Public Participation Program• Public Education Program• Illicit Discharge Elimination Program• Construction Storm water Runoff Control Program• Post-Construction Storm water Runoff Control Program• Pollution Prevention / Good Housekeeping
Storm Water Management Plan:Six Minimum Measures
Post Construction Storm water Management Plan
• Permanent, engineered and constructed measures
• May be incorporated into current design elements or be separate additional elements
• Best Management Practices (PC-BMPs)• Not the same as Soil Erosion and
Sedimentation Control
Water quality Standard:Treat the first inch of runoff from the entire site
OrTreat the runoff from 90% of all
runoff producing stormsAnd
BMPs must be designed to reduce suspendedsolids by 80% or to a concentration
of less than 80 mg/l
Post-Construction runoff rate and volume must not exceed pre-development rate and volume up to the two-year, 24-hour storm
Channel Protection Standard:
• May be met by site-specific measures, or alternatively by off-site mitigation within the watershed, or by payment-in-lieu.
• Compliance with 2018 construction.
Both Standards:
• Consider these requirements during scoping and allow for these features in budget.
• Look for areas that may be suitable for volume BMPs (interchanges, excess Right of Way, etc.).
• Consider ways to use existing features to improve water quality (vegetated ditches, side slopes, bio swales, rain gardens).
What can be done?
• Almost all BMPs require maintenance.
• Engage maintenance staff during scoping to discuss BMP selection.
• Environmental section will be working with central maintenance to develop BMP selection guidance.
Other things to consider:
• EPA and PG Environmental staff conducted inspection of MDOT program April 28 – May 2, 2014
• Focused on two of the six minimum measures
• Included field and documentation reviews, although emphasis was on field
• MDEQ and MDOT staff accompanied the inspectors
EPA Audit of MDOT MS4 ProgramApril – May, 2014
• Construction Site Storm Water Runoff Control
• Pollution Prevention / Good Housekeeping for MDOT operations
• Visited seven construction sites and 13 operational facilities
• 19 Potential non-compliance / Program Deficiency Findings
• 70 Observations
EPA Audit of MDOT MS4 ProgramApril – May, 2014
• Soil Erosion and Sedimentation Control, and much more
• Disposal of waste materials
• Storage of construction materials
• Housekeeping of equipment storage and maintenance areas
• Documentation
• Training
Construction Site Storm Water Runoff Control
• SESC Controls must be installed and maintained according to plans, or as documented
• Inspections must be timely and documented
• Inspections must continue until final stabilization
• Inspections must document follow up actions
Construction Site Storm Water Runoff Control
• Waste material onsite must be contained and disposed of
• Containers must be covered and sealed
• Concrete wash out areas must be protected from storm water inlets
• Materials such as reinforcing steel and guardrail must be covered
Construction Site Storm Water Runoff Control
• Fuels and lubricants stored onsite must have secondary containment
• Leaks and drips must be contained and / or cleanup up immediately
• Spill kits must be available onsite
Construction Site Storm Water Runoff Control
• Training is being evaluated and updated
• Industry outreach is being developed
• Working with MDEQ to augment the Part 91 training that is currently offered
Construction Site Storm Water Runoff Control
• One of the six minimum measures
• Dry weather screening to check for possible contaminated runoff
• Follow up on reports of illicit connections
• Construction and maintenance screening
Illicit Discharge Elimination Program
Municipal Separate Storm Sewer System (MS4)
Not a water of the state Regulated by the National Pollutant
Discharge Elimination System (NPDES) Permit requires that we have an Illicit
Discharge Elimination Plan (IDEP)
Any discharge to a storm sewer system that is not composed entirely of stormwater or uncontaminated groundwater.
Illict Dischage
A physical connection to the storm sewer that primarily conveys non-stormwater discharges; or a physical connection not authorized or permitted by the local authority.
Illict Connection
Construction Project Screening:What to look for:
• Floatables (oil sheen, sewage, trash)• Dry weather flow• Odor• Foam• Others (color, turbidity, stains or
deposits, excessive vegetation at outlet point)
What then?
Contact:Region Resource Analyst
Storm Water Program ManagerMDEQ PEAS Hotline
www.michigan.gov/stormwatermgt
• Outlet pipes in roadside ditches
• Sometimes sump pump outlets, these are allowed
• Sometimes septic tank outlets, not allowed
Construction Screening:What to look for
• Oil or other substances in catch basin sumps
• Solids (other than leaves, grass, or roadside debris)
• Odors
• Sheen
• Foam
Construction Screening:What to look for
• Contact Project Manager
• Contact Region Resource Specialist
• Document location and attempt to determine extent of contamination
• Maintain the connection as best as possible
Construction Screening:What to do
• Do not let contamination run into the ground
• Do not bulkhead an outlet
Construction Screening:What NOT to do