Dean Tuomari Wayne County Department of Public Services Water Quality Management Division , dtuomari@waynecounty.com 734-326-4483 Michigan Water Environment Association Annual Industrial Pretreatment Program Seminar September 26, 2013
Introduction Review Elements of the Municipal Separated Storm Sewer System(MS4) Permit Application http://www.michigan.gov/documents/deq/wrd-stormwater- MS4-Application_402860_7.pdf Permit Application Elements Storm Water Management Program the eight elements Eighty plus procedures required Illicit Discharge Elimination Program Case Histories How IPP staff can be the eyes and ears Accomplishmnets
Permit Application Elements Define the regulated urbanized areas as defined by the 2000 Census
Permit Application Elements Identify discharges to waters of the State Identify discharge points Identify the point where your system discharges to another jurisdiction Agreements between jurisdictions on follow up is allowable Note- open county drains are considered Waters of the State
Permit Application Elements List nested jurisdictions in the application E.g. school districts Community/ies under a county permit Provide name and general description of nested jurisdictions
Permit Element Stormwater Management Program Eight Elements - The main objectives of the permit Enforcement Response Procedure 1. Public Participation Program 2. Public Education Program 3. Construction Stormwater Runoff Program 4. Post Construction Stormwater Runoff Program 5. Pollution Prevention and Good Housekeeping 6. Program Total Maximum Daily Load (TMDL) Implementation 7. Program Illicit Discharge Elimination Program 8.
Stormwater Management Program Enforcement Response Procedure 1. Response to violation of permitees ordinances • Contain the ordinance/s • Method for tracking non-compliance • Date/location • Nature of the violation • Enforcement response used • Schedule for compliance • Date violation was resolved •
Stormwater Management Program Public Participation Plan 2. If it a collaborative effort with watershed or regional • partners identify, the collaborative activities Procedures on how the public participates in the • development of the Stormwater Management Plan How is the Plan made available for public review/comment? • How the public is invited to participate in implementation • and review?
Stormwater Management Program Public Education Program (PEP) 3. Provide procedure to assess high priority community issues and target the issues to reduce pollutants in stormwater Identify /prioritize PEP topics based on assessment of community high priority issues. Eleven PEP topics in the permit application For each topic provide Target audience Key message Delivery mechanism and frequency
Stormwater Management Program Public Education Program (PEP) 3. Topics include: • Promote public stewardship of watersheds • Educate the public on illicit discharges • Education on importance of green infrastructure • Education on the proper maintenance of septic systems • Promote methods for proper riparian lands to protect water • quality Identify /educate commercial, industrial, institutional • entities that may contribute pollutants to stormwater Provide a procedure for evaluating effectiveness of the PEP • Assess changes in public awareness •
Stormwater Management Program 4. Construction Stormwater Runoff Program Is the permittee a Part 91 agency (Soil Erosion)? • If not list the agency it relies on for Part 91 agency • Procedure for notifying the Part 91 agency when pollutant from a • construction site enters MS4. Procedure to notify MDEQ when pollutant from a construction • site enters MS4. Procedure to notify Part 91 agency of construction activity • greater than one acre.
Stormwater Management Program 5. Post Construction Stormwater Runoff Program Ordinance for post construction runoff • Water quality performance standard • Treat first inch of runoff from entire site • Treat runoff from 90% of all runoff producing storms • Source of rainfall data • Channel Protection Performance Standard • Site runoff does not exceed pre development rate and • volume up to 2 year 24 hour storm
Stormwater Management Program 5. Post Construction Stormwater Runoff Program Site specific requirements (new and redevelopment) • Infiltration BMP should not exaberate current groundwater • contamination issues. Do BMPs consider potential pollutants from “hotspots” • (E.g. gas stations, auto recyclers, scrap yards, etc) • Off-Site Mitigation/Payment in Lieu Programs • Is off-site mitigation allowed for redevelopment? • Does ordinance allow Payment in Lieu? • Fee paid to permitee for stormwater management project • Same jurisdiction, watershed, sewershed •
Stormwater Management Program 6. Pollution Prevention and Good Housekeeping Municipal Facility and Structural Stormwater Control Inventory Updated inventory of municipal facilities and stormwater structures Municipal facilities Police/Fire stations, vehicle yards, public parking lots, animal control building Structural storm water controls e.g. rain gardens, catch basins, constructed wetlands, pump stations Up-to-date maps with locations for items above Procedure for updating the inventory
Stormwater Management Program 6. Pollution Prevention and Good Housekeeping Maintenance Activities for Structural Stormwater Controls Procedure for prioritizing routine inspection, maintenance and cleaning of catch basins Revision procedure for updating priority areas.
Stormwater Management Program 6. Pollution Prevention and Good Housekeeping Location of impervious surfaces E.g. streets, parking lots Identify street sweeping methods Seasonal issues e.g. leaf pickup Describe dewatering and disposal of waste material Management of vegetated properties Certified pest control applicator Employee training Employee training program for staff that perform pollution prevention and good house keeping
Stormwater Management Program 6. Pollution Prevention and Good Housekeeping Contractor requirements Comply with pollution prevention and good housekeeping practices 7. Total Maximum Daily Load (TMDL) Implementation Plan A TMDL Implementation Plan will have a waste load allocation to the municipality Describe current/future Best Management Practices (BMP)that make progress towards meeting waste load allocation in TMDL plan Monitoring plan to assess effectiveness of BMP to reach load reduction requirement in the TMDL plan.
Stormwater Management Program 8. Illicit Discharge Elimination Program (IDEP) Definitions • Illicit Connection- physical connection • to a MS4 that convey non-stormwater discharge or not authorized by local authority Illicit Discharge-any discharge or seep • that is not stormwater or uncontaminated ground water
Stormwater Management Program 8. Illicit Discharge Elimination Program (IDEP) Examples of Illicit Discharges • Grey Water Discharge
Stormwater Management Program 8. Illicit Discharge Elimination Program (IDEP) Up-to date storm sewer system map Identify location of outfalls Identify points of discharge Identify water of the State that receive the discharge Indicate where the maps can be found
Stormwater Management Program 8. Illicit Discharge Elimination Program (IDEP) Procedure for prioritize areas with potential of illicit • discharges E.g. Areas with: • History of illicit discharge • Onsite Sewage Disposal Systems • Older infrastructure • Poor dry weather water quality • Provide geographical location of priority areas •
Stormwater Management Program 8. Illicit Discharge Elimination Program (IDEP) Procedure for prioritizing areas with potential for • illicit discharges
Stormwater Management Program 8. Illicit Discharge Elimination Program (IDEP) Procedure for field observations of outfalls • Water color, clarity, floatables, odor • Structural condition, staining, deposits • Bacterial sheens, algae, slimes, • Field screening procedures • pH • Ammonia • Fluoride • Detergents •
Stormwater Management Program 8. Illicit Discharge Elimination Program (IDEP) Procedure for source investigation • How will the source be determined? • Procedures for responding to spills • Procedure for reporting of polluting material to waters • of the state from storm system Polluting material defined by Part 5 rules. • Response to illicit discharge • Corrective action • Compliance schedule •
Stormwater Management Program 8. Illicit Discharge Elimination Program (IDEP) IDEP Training of staff • Once during permit cycle • New staff within the first year of hire • Evaluation • How is effectiveness of IDEP program evaluated? • Wayne County does pollutant load reduction calculations • Illicit discharge ordinance •
Dye Testing Dropping the dye Liquid Packets Alternate colors Green Fluorescent red Rule 97 file notice of intent
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