C LICK TO EDIT M ASTER TITLE STYLE MS4 Inspections Is your Municipality ready? ● Click to edit Master text styles o Second level ● Third level Presented by: o Fourth level Kevin A. Brett, P.E. Lennon, Smith, Souleret Engineering Inc. February 25, 2016 Est. 1985 Lennon, Smith, Souleret Engineering, Inc. Civil Engineers and Surveyors
M UNICIPAL S EPARATE S TORM S EWER S YSTEM (MS4) C LICK TO EDIT M ASTER TITLE STYLE ● Click to edit Master text styles ● What is a MS4? o Second level o Municipal Separate Storm Sewer System ● Third level o Any conveyance that is: o Fourth level ● Used for collecting and/or conveying stormwater ● Owned by a municipality or any other public body ● Not used as a combined sewer ● Not part of Publically Owned Treatment Works o Current Permit is 5-Year Permit o Goal for DEP: To inspect each MS4 within the 5-Year Permit term o DEP – Southwest began inspections in 2015 and will complete by 2017
DEP I NSPECTIONS C LICK TO EDIT M ASTER TITLE STYLE ● Click to edit Master text styles ● Plan for full day with DEP Inspector o Second level o First half of the day spent in the office reviewing the ● Third level documentation related to each MCM o Fourth level o Second half of day in the field inspecting public works facilities, BMPs, outfalls, etc. ● The appropriate staff are available o Key personnel such as: ● Manager ● MS4 Coordinator/Administrative Staff responsible for documentation ● Code Enforcement Official ● Public works Director/Supervisor ● Municipal Engineer
I NSPECTIONS BY DEP C LICK TO EDIT M ASTER TITLE STYLE ● Click to edit Master text styles ● To ensure that all the required inspection goals are o Second level met DEP requests that the following materials are to ● Third level be pulled from the municipal files, separated, and o Fourth level placed on a table prior to the DEP Inspector’s arrival ● It is recommended each MCM be placed in its own binder for a more organized review ● DEP will review the municipality's written plan and use the following checklist:
C LICK TO EDIT M ASTER TITLE STYLE ● Click to edit Master text styles o Second level ● Third level o Fourth level
T HE MCM' S W HICH W ILL BE R EVIEWED ARE : C LICK TO EDIT M ASTER TITLE STYLE ● Click to edit Master text styles o MCM #1 - Public Education and Outreach on o Second level Stormwater Impacts ● Third level o MCM #2 - Public Involvement/Participation o Fourth level o MCM #3 - Illicit Discharge Detection and Elimination o MCM #4 - Construction Site Stormwater Runoff Control o MCM #5 - Post-Construction Stormwater Management (PCSM) in New and Re-Development Activities o MCM #6 - Pollution Prevention/Good Housekeeping
MCM N O . 1 C LICK TO EDIT M ASTER TITLE STYLE ● Click to edit Master text styles ● Public Education and Outreach on Stormwater o Second level Impacts ● Third level o BMP No. 1: Develop, Implement and Maintain a o Fourth level Written Public Education and Outreach Program o BMP No. 2: List of Target Audiences – Need to be specific o BMP No. 3 and 4: Distribute Stormwater Educational Materials A Minimum of Three Different Ways o Need a flow diagram on what staff is responsible for each element of the Plan
MCM N O . 2 C LICK TO EDIT M ASTER TITLE STYLE ● Click to edit Master text styles ● Public Involvement/Participation o Second level o BMP No. 1: Develop and Implement ● Third level Public Involvement Participation Program o Fourth level ● Who, What, When and Where! o BMP No. 2: Provide Public Notice for Public Review, Input, and Feedback ● Who, What, When and Where! o BMP No. 3: Regularly Solicit Public Involvement from Target Audience Groups (MCM No. 1) ● How! And Who will do it!
MCM N O . 3 C LICK TO EDIT M ASTER TITLE STYLE ● Click to edit Master text styles Typical Question asked: o Second level ● What is an Outfall? ● Third level o “The Point Where a MS4 Discharges o Fourth level Stormwater to Other Surface Water of this Commonwealth” o BMP No. 4: Conduct Outfall Screening o Outfall Types ● Pipe Outfall ● Catch Basin ● Curb and Gutter ● Roadside Ditch ● Swale ● Where do we test?
MCM N O . 3 C LICK TO EDIT M ASTER TITLE STYLE ● Click to edit Master text styles ● Outfall Testing o Second level o 20% of outfalls shall be tested ● Third level each year of the five (5) year o Fourth level permit cycle o Outfalls are visually inspected 48 hours after a precipitation event o If dry weather flow is evident, two grab samples must be taken
MCM N O . 3 C LICK TO EDIT M ASTER TITLE STYLE ● Click to edit Master text styles • Illicit Discharge Detection o Second level and Elimination ● Third level – BMP No. 1: Develop o Fourth level Written Program – BMP No. 2: Develop and Maintain a Map of Regulated Small MS4 Outfalls – BMP No. 3: Map of Storm Sewer Collection and Conveyance Systems – Follow Up – Documentation
MCM N O . 3 C LICK TO EDIT M ASTER TITLE STYLE ● Click to edit Master text styles ● Follow up - Illicit Discharges o Second level o Identify the source of the illicit discharge ● Third level ● Pollutant source can be determined based on the pollutants found o Fourth level during grab sample analysis o Use storm sewer maps to pinpoint source by inspecting storm sewer structures o Smoke and dye testing can also be implemented o Televise sewer system to detect sanitary cross connections or other prohibited discharge connections o Documentation – If it is not documented it did not happen
MCM N O . 3 C LICK TO EDIT M ASTER TITLE STYLE ● Click to edit Master text styles ● Once Identified Illicit Discharge Correction - o Second level o Determine if flow is from illegal dumping or improper connections ● Third level o Take appropriate action to correct discharge o Fourth level ● If a violation is found, notify the property owner and set a timeframe for correction of violation. o Document all measures taken to correct illicit discharge o Notification of Entity responsible and follow up on if its been done o Board may need to create policy for how to handle non- compliant entities, i.e. Homeowners Associations, residents, etc. Staff will need direction on path to take. ● Notice of Violation ● Take to Magistrate ● Complete work and lien property
MCM N O . 3 C LICK TO EDIT M ASTER TITLE STYLE ● Click to edit Master text styles ● Ordinances – Has yours been updated? o Second level o BMP No. 5: Need to Enact a Stormwater Management ● Third level Ordinances o Fourth level ● Stormwater Management Ordinance ● Prohibited Discharge Ordinance ● Small Project Application o BMP No. 6: Need to Provide Educational Material to Target Audiences
MCM N O . 4 C LICK TO EDIT M ASTER TITLE STYLE ● Click to edit Master text styles ● Documentation of Compliance with Construction Site o Second level Stormwater Runoff Control ● Third level o BMP No. 1: Develop a Program Containing All Procedures o Fourth level Necessary to Comply o BMP No. 2: Erosion and Sediment Control BMPs o BMP No. 3: Construction Site Operators to Control Site Waste o BMP No. 4: Record Tracking System
MCM N O . 4 C LICK TO EDIT M ASTER TITLE STYLE ● Click to edit Master text styles ● Reliance on Pennsylvania's Program o Second level o Most municipalities should have a Memorandum of Understanding ● Third level with their County Conservation District that outlines the services o Fourth level that the Conservation District provides to the municipality o Typically this includes review and approval of Erosion and Sedimentation Control Plans and issuance of NPDES Permits o Reliance on the Conservation District does not alleviate the Municipality from compliance with the requirements of MCM No. 4
MCM N O . 4 C LICK TO EDIT M ASTER TITLE STYLE ● Click to edit Master text styles ● Municipal Responsibilities o Second level o Keep a copy of your Memorandum of Understanding with your ● Third level MS4 documentation o Fourth level o Develop and implement a system for routine inspection of erosion and sedimentation controls at all active construction sites ● May be completed along with current inspections, i.e. footer inspections, framing inspection ● Procedures for issuance of notices of violation and enforcement must developed o Develop and implement a system for tracking and resolving complaints associated with construction site runoff
MCM N O . 5 C LICK TO EDIT M ASTER TITLE STYLE ● Click to edit Master text styles ● Post-Construction Stormwater Management (PCSM) o Second level in New and Re-Development Activities ● Third level o BMP No. 1: Written Program o Fourth level o BMP No. 2: Tracking System to Record Qualifying Projects o BMP No. 3: Controls to Ensure Minimal Water Quality Impacts o BMP No. 4: Enforce an Ordinance to Address PCSM BMPs o BMP No. 5: Encourage Low Impact Development (LID) o BMP No. 6: Ensure Operation and Maintenance of All PCSM BMPs Installed After March 2003
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