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MS4 Permitting Process

MS4 Permitting Process. William Creal Water Bureau Permits Section Chief. MS4 Permitting Process. Two permit options Process to date Process forward Implementation committee. Summary of Requirements of the New Permits. Watershed Permit

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MS4 Permitting Process

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  1. MS4 Permitting Process William Creal Water Bureau Permits Section Chief

  2. MS4 Permitting Process • Two permit options • Process to date • Process forward • Implementation committee

  3. Summary of Requirements of the New Permits

  4. Watershed Permit Public education and Post construction = watershed boundary Remaining requirements = MS4 owned/operated within watershed Coverage Area

  5. Jurisdictional Permit MS4 owned/operated within urbanized area Coverage Area

  6. Discharge point information on application Discharge point = discharges to surface waters of state and to other MS4s Categorical coverage Authorized Discharges

  7. Discharges after application, but not categorical coverage Less than 1,500 this permit cycle More than 1,500 next permit cycle Discharge Point Location

  8. Constructed/installed after submittal JP = lat/long also for discharges after application and labeling for new constructed/installed Discharge Point Location

  9. WP = submit revised plan JP = public notice, citizen advisory committee, watershed organizations Public Participation

  10. Update needed unless demonstrate Evaluating effectiveness Triggers for revision Watershed Management Plan

  11. SWPPI regulatory document Approved upon submittal if it meets GP requirements MDEQ reopener if SWPPI is deficient Revise SWPPI within 90 days unless negotiate timeline OR COC Modification Implement upon submittal Approval/Reopener

  12. Allowed for many SWPPI requirements Needs MDEQ approval Innovative watershed alternatives are encouraged Work with WB staff prior to SWPPI submittal Alternative Approaches

  13. Watershed or regional PEP (WP only) Watershed effectiveness (WP only) Topics similar to last permit added septic system, native landscaping JP = Additional topics P-free fertilizer & restaurant education Public Education

  14. Stormwater related, approved TMDLs Actions to make progress in meeting water quality standards Total Maximum Daily Loads (TMDL)

  15. E.Coli/Total Phosphorus monitoring: Outfall monitoring at 50% major discharge points Elective monitoring option (WP only) Total Maximum Daily Loads (TMDL)

  16. Regulatory mechanism prohibiting illicit discharges to MS4 Staff training Illicit Discharge Elimination

  17. Program to eliminate discharges: Storm sewer map Illicit Discharge Elimination • Dry weather screening at discharge point • OR collaborative approach at waters of the state (WP only)

  18. Regulatory mechanism New development and redevelopment >1 acre. Requirements include: Water quality criteria, channel protection criteria, O & M, enforcement mechanisms. Post Construction Runoff Control

  19. Standards met by: Incorporate standards given in permit Grandfather existing mechanism includes WQ & channel criteria Procedures in place Submit an alternative approach or outcome based approach Standards slightly different between permits Post Construction Runoff Control

  20. Part 91 and Permit by Rule Procedures to: Notify agencies of sediment & other wastes Ensure for erosion controls in preliminary site plans Receipt and considerations of complaints Construction Stormwater Runoff Control

  21. Employee / contractor training Structural stormwater control effectiveness Roads, parking lots & bridges Fleet maintenance & storage yards Managing vegetated property Pollution Prevention/ Good Housekeeping

  22. Existing employees: 1 session permit cycle New employees: 1 session first year of employment Contractors: trained before work performed/can include in bid specifications Employee/Contractor Training

  23. Inspect structural controls owned/operated Swales, infiltration, detention basins, catch basins Structural Stormwater Control Effectiveness

  24. Structural Stormwater Control Effectiveness • Inspect structural controls owned/operated • Swales, infiltration, detention basins, catch basins • Summary list of municipal properties and structural controls • Location information by first progress report • Information retained by permittee

  25. O & M waste disposed of according to state law New controls meet post construction standards Structural Stormwater Control Effectiveness

  26. Reduce TSS to MEP First p-report current control level & estimate load reduction Second p-report evaluate effectiveness & identify methods to improve JP has a 25% reduction goal. Progress report develop methods to attain 25% reduction goal Roadways, Parking Lots and Bridges

  27. Good housekeeping practices salt and sand storage; gravel parking lots/roads Bans use of coal tar emulsions to seal asphalt (Austin, TX 2006) Roadways, Parking Lots and Bridges

  28. Stormwater Pollution Prevention Plan (SWPPP) at each facility. Certified stormwater operator Or integrate into SWPPI and overseen by stormwater program manager (WP only) Fleet Maintenance/Storage Yards

  29. Elements include: site map, list of significant materials, schedules, description of good housekeeping practices, etc. Fleet Maintenance/ Storage Yards

  30. Process to train employees/contractors P-free fertilizer Program to minimize stormwater impacts from managed vegetated properties Managing Vegetated Property

  31. Coverage Area WP = watershed area JP = MS4 area Discharge Location JP = labeling, lat/long of existing Public Participation WP = update plan JP = participate on citizen groups Watershed Plan WP = may need updating JP = goals/objectives, stresses, wq status Jurisdictional vs. Watershed

  32. More flexibility WP = alternative approaches allowed JP = no flexibility TMDL WP = Elective option for E.Coli/TP TMDL JP = Requires outfall monitoring PEP WP = watershed/regional PEPs and evaluation Jurisdictional vs. Watershed

  33. IDEP WP = dry weather screening option at outfalls to waters of the state JP = dry weather screening at all discharge points Roadways JP = 25% reduction goal and progress reporting Fleet maintenance WP = Incorporate into SWPPI; stormwater manager JP = SWPPP and certified stormwater operator Jurisdictional vs. Watershed

  34. What’s the relative emphasis on outcome: water quality vs. institutional simplicity? Are you a township, city, school, county? Do you have an approved TMDL? Do you have a number of maintenance/ storage yards? Jurisdictional vs. Watershed Food for Thought

  35. What is your current permit? Do you have numerous discharge points vs. outfalls to the waters of the state? Are you interested in an alternative approach? Working collaborative on public education? Jurisdictional vs. Watershed Food for Thought

  36. Submit an alternative approach on any of the items One PEP Watershed evaluation Elective monitoring option for TMDL Elective IDEP option Municipal education topics Post construction runoff control Watershed Group Decisions

  37. Questions • Contact Mark Fife at 517-241-8993 or fifem@michigan.gov for permit or application questions. • Contact the appropriate district staff for program implementation/compliance questions. • For additional information go to http://www.michigan.gov/deq and click on water, then surface water, then storm water, then Municipal Program/ MS4 Permit Guidance

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