MS-4 (Municipal Separate Storm Sewer System)
-What is MS-4? Municipal Separate Storm Sewer Systems
-Owned by state, city, town, village or public entity that discharges to waters of the US
-Designed or used to collect or convey storm water (including, storm drains, pipes & ditches)
-Not a combined sewer
-Not part of a publicly owned treatment works (Sewage treatment plants)
Some key words and acronyms:
-MS4 - Municipal Separate Storm Sewer System
-MCM - Minimum Control Measure
-BMP - Best Management Practice
-Outfall - a point source as defined by 40 CFR 122.2 at the point where a municipal separate storm sewer discharges to waters of the United States and does not include open conveyances connecting two municipal separate storm sewers, or pipes, tunnels or other conveyances which connect segments of the same stream r other waters of the United States and are used to convey waters of the United States.
-Illicit Discharge - An illicit discharge is defined as any discharge to the municipal separate storm sewer system that is not composed entirely of storm water, except for discharges allowed under a NPDES permit or waters used for firefighting operations.
-Township involvement: Our ultimate goal as a township is to reduce Nitrogen, Phosphorus, & Sediment by 60%. Ways we can meet this goal is through our Chesapeake Bay Pollution Reduction Plan and the 6 MCM’s listed below.
-If you see someone dumping in a storm water inlet please contact Paul Rodrigo, 717-901-5298 or email email@example.com
or call the Township at 717-901-5261
The information below is a detailed summary of the requirements of Fairview Township's MS-4 Permit Requirements
6 MCM’s (Minimum Control Measures)
MCM #1 – PUBLIC EDUCATION AND OUTREACH ON STORM WATER IMPACTS
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9/28/2015 MS-4 Meeting Presentation
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BMP #1: Develop, implement and maintain a written Public Education and Outreach Program
Measurable Goal: For renewal permittees, the existing PEOP shall be reviewed and revised as necessary. The permittee’s PEOP shall be designed to achieve measurable improvements in the target audience’s understanding of the causes and impacts of stormwater pollution and the steps they can take to prevent it.
BMP #2: Develop and maintain lists of target audience groups present within the areas served by your MS4
Measurable Goal: For renewal permittees, the lists shall continue to be reviewed and updated annually.
BMP #3: Annually publish at least one educational item on your Stormwater Management Program
Measurable Goal: In subsequent years (and for renewal permittees), the list of items published and the content in these items shall be reviewed, updated, and maintained annually. Your publications shall contain stormwater educational information that addresses one or more of the 6 MCMs.
BMP #4: Distribute stormwater educational materials to the target audiences
Measurable Goal: All permittees shall select and utilize at least two distribution methods in each permit year. These are in addition to the newsletter and website provisions of BMP #3.
Develop and implement a written program
MCM #2 – PUBLIC INVOLVEMENT/PARTICIPATION
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BMP #1: Develop, implement and maintain a written Public Involvement and Participation Program (PIPP)
Measurable Goal: All permittees shall re-evaluate the PIPP each permit year and revise as needed.
BMP #2: Prior to adoption of any ordinance (municipal permittees) or SOP (non-municipal permittees) required by the permit, provide adequate public notice and opportunities for public review, input, and feedback.
Measurable Goal: Advertise any proposed MS4 Stormwater Management Ordinance or SOP, provide opportunities for public comment, evaluate any public input and feedback, and document the comments received and the municipality’s response.
BMP #3: Regularly solicit public involvement and participation from the target audience groups. This should include an effort to solicit public reporting of suspected illicit discharges. Assist the public in their efforts to help implement your SWMP. Conduct public meetings to discuss the on-going implementation of your SWMP.
Measurable Goals: Conduct at least one public meeting per year to solicit public involvement and participation from target audience groups. The public should be given reasonable notice through the usual outlets a reasonable period in advance of each meeting. During the meetings, you should present a summary of your progress, activities, and accomplishments with implementation of your SWMP, and you should provide opportunities for the public to provide feedback and input. Your presentation can be made at specific MS4 meetings or during any other public meeting. Under this MCM, you should document and report instances of cooperation and participation in your activities; presentations you made to local watershed organizations and conservation organizations; and similar instances of participation or coordination with organizations in your community. You also should document and report activities in which members of the public assisted or participated in your meetings and in the implementation of your SWMP, including education activities or organized implementation efforts such as cleanups, monitoring, storm drain stenciling, or others.
c.) Develop and implement a written program
MCM #3 – ILLICIT DISCHARGE DETECTION AND ELIMINATION (IDD&E)
BMP #1: You shall develop and implement a written program for the detection, elimination, and prevention of illicit discharges into your regulated MS4s. Your program shall include dry weather field screening of outfalls for nonstormwater flows, and sampling of dry weather discharges for selected chemical and biological parameters. Test results shall be used as indicators of possible discharge sources.
Measurable Goal: For renewal permittees, the existing IDD&E program shall continue to be implemented and evaluated annually. Records shall be kept of all outfall inspections, flows observed, results of field screening and testing, and other follow-up investigation and corrective action work performed under this program.
BMP #2: Develop and maintain a map of your regulated small MS4. The map must also show the location of all outfalls and the locations and names of all surface waters of the Commonwealth (e.g., creek, stream, pond, lake, basin, swale, channel) that receive discharges from those outfalls.
Measurable Goals: For renewal permittees, the existing map(s) of your regulated small MS4 shall be updated and maintained as necessary during each year of coverage under the permit.
BMP #3: In conjunction with the map(s) created under BMP #2 (either on the same map or on a different map), new permittees shall show, and renewal permittees shall update, the entire storm sewer collection system, including roads, inlets, piping, swales, catch basins, channels, basins, and any other features of the permittee’s storm sewer system including municipal boundaries and/or watershed boundaries.
Measurable Goals: For renewal permittees, update and maintain the map(s) as necessary during each year of permit coverage.
BMP #4: Following the IDD&E program created pursuant to BMP #1, the permittee shall conduct outfall field screening, identify the source of any illicit discharges, and remove or correct any illicit discharges using procedures developed under BMP #1.
For all permittees, outfall inspections need to be prioritized according to the perceived chance of illicit discharges within the outfall’s contributing drainage area. Observations of each outfall shall be recorded each time an outfall is screened, regardless of the presence of dry weather flow. Proper quality assurance and quality control procedures shall be followed when collecting, transporting or analyzing water samples. All outfall inspection information shall be recorded on the Outfall Reconnaissance Inventory/Sample Collection field sheet excerpted from the Illicit Discharge Detection and Elimination: A Guidance Manual for Program Development and Technical Assessments (CWP, October 2004). Adequate written documentation shall be maintained to justify a determination that an outfall flow is not illicit. If an outfall flow is illicit, the actions taken to identify and eliminate the illicit flow also shall be documented.
BMP #5: Enact a stormwater management ordinance (municipal entities) or develop an SOP (non-municipal entities) to implement and enforce a stormwater management program that includes prohibition of non-stormwater discharges to the regulated small MS4.
Measurable Goal: Renewal permittees must continue to maintain, update, implement, and enforce a Stormwater Management Ordinance that satisfies all applicable requirements. (For non-municipal permittees, the SOP satisfies this requirement. If no existing SOP exists, it should be developed during the first year of coverage).
Measurable Goal: Renewal permittees shall update their existing ordinance, if necessary, and submit documentation of completion to the Department. (For non-municipal permittees, submit the SOP to the first report).
BMP #6: Provide educational outreach to public employees, business owners and employees, property owners, the general public and elected officials (i.e., target audiences) about the program to detect and eliminate illicit discharges.
Measurable Goals: During each year of permit coverage, appropriate educational information concerning illicit discharges shall be distributed to the target audiences using methods outlined under MCM #1. If not already established, set up and promote a stormwater pollution reporting mechanism (e.g., a complaint line with message recording) by the end of the first year of permit coverage for the public to use to notify you of illicit discharges, illegal dumping or outfall pollution. Respond to all complaints in a timely and appropriate manner. Document all responses, include the action taken, the time required to take the action, whether the complaint was resolved successfullye
g.) Develop and implement a written program
MCM #4 – CONSTRUCTION SITE STORM WATER RUNOFF CONTROL
BMP #1: Develop your program consisting of all procedures necessary to comply with the requirements of this MCM. Your program shall provide for construction stormwater permitting, construction inspection, and enforcement of installation and maintenance of the necessary E&S control measures. Your program shall describe clearly how your program will be coordinated with DEP’s NPDES Construction Stormwater Permitting program.
Measurable Goals: For all permittees, your program shall be reviewed and updated during each year of permit coverage. The purpose of the written program is to establish clear roles and responsibilities for the implementation of the MCM #4 requirements. An agreement between the permittee, the CCD, and any other resources to be used by the permittee that clearly defines roles for each entity is recommended. If an agreement is made, you shall place and keep a written copy in your file, consistent with the Retention of Records requirements in this Permit. Please note that in accordance with Section A.2.h in Part A of the Authorization to Discharge, as the permittee you are responsible to ensure that implementation of all requirements under this Permit are fulfilled.
BMP #2: The permittee shall enact, implement, and enforce an ordinance to require the implementation of erosion and sediment control BMPs, as well as sanctions to ensure compliance.
Measurable Goal: Permittees shall submit a letter signed by a municipal official, municipal engineer or the municipal solicitor as an attachment to their first periodic report certifying the enactment and implementation of a stormwater management ordinance that meets all requirements of this permit.
BMP #3: Develop and implement requirements for construction site operators to control waste at the construction site that may cause adverse impacts to water quality. While sediment is the most common pollutant of concern for MCM #4, there are other types of pollutants that also can be a concern and the intent of this BMP is to address these other types of pollutants, such as, but not limited to, discarded building materials, washout from concrete trucks, chemicals, litter, and sanitary waste.
Measurable Goal: New permittees shall establish requirements to address this BMP by the end of the first year of permit coverage. Renewal permittees shall continue to implement existing requirements and update as necessary. This could be implemented by written municipal ordinance/code provisions, by standard notes on the site plans, by any other written format that accomplishes the objectives of this BMP, or by any combination of these measures. The goal of this BMP shall be communicated to construction site operators during pre-construction meetings. This BMP shall be implemented during each year of the MS4 permit. Permittees must prepare and maintain records of site inspections, including dates and results and you must maintain these records in accordance with the Retention of Records requirements in this Permit.
BMP #4: Develop and implement procedures for the receipt and consideration of public inquiries, concerns, and information submitted by the public (to the permittee) regarding local construction activities. The permittee shall demonstrate acknowledgement and consideration of the information submitted, whether submitted verbally or in writing.
Measurable Goal: Permittees shall establish and implement a tracking system to keep a record of any submitted public information as well as your response, actions, and results. This BMP shall be implemented during each year of coverage under this General Permit and information should be submitted with the each periodic report
MCM #5 – POST-CONSTRUCTION STORM WATER MANAGEMENT IN NEW DEVELOPMENT AND REDEVELOPMENT
BMP #1: Develop a written procedure that describes how the permittee shall address all required components of this MCM. Guidance can be found in the Pennsylvania Stormwater Best Management Practices Manual.
Measurable Goal: The written procedure shall be developed by the end of the first year of permit coverage and be reviewed and updated every permit year thereafter, as needed. The intent of BMP #1 is for the permittee to describe how the listed tasks will be accomplished.
BMP #2: Require the implementation of a combination of structural and/or non-structural BMPs that are appropriate to the local community, that minimize water quality impacts, and that are designed to maintain pre-development runoff conditions. This requirement can be met by ensuring that the selected BMPs comply with the municipal Stormwater Management Ordinance that meets the requirements of the permit.
Measurable Goal: All qualifying development or redevelopment projects shall be reviewed to ensure that their postconstruction stormwater management plans and selected BMPs conform to the applicable requirements. A tracking system (e.g., database, spreadsheet, or written list) shall be maintained to record qualifying projects and their associated BMPs. In your records, you shall note if there are no qualifying projects in a calendar year.
BMP #3: Ensure that controls are installed that shall prevent or minimize water quality impacts.
Measurable Goal: All qualifying development or redevelopment projects shall be inspected during the construction phase to ensure proper installation of the approved structural PCSM BMPs. A tracking system (e.g., database, spreadsheet, or written list) shall be implemented to track the inspections conducted and to track the results of the inspections (e.g., BMPs were, or were not, installed properly). Permittees not relying on DEP’s statewide QLP to satisfy requirements under this BMP shall summarize construction inspections and results in periodic reports. See BMP #6 for requirements related to post-construction inspection and tracking of PCSM BMPs to ensure that the operation and maintenance plan is being implemented.
BMP #4: The permittee shall enact, implement, and enforce an ordinance (municipal) or SOP or other regulatory mechanism (non-municipal) to address post-construction stormwater runoff from new development and redevelopment projects, as well as sanctions and penalties associated with non-compliance, to the extent allowable under State or local law.
Measurable Goal: All permittees shall submit a letter signed by a municipal official, municipal engineer or the municipal solicitor as an attachment to their first periodic report certifying the enactment of a stormwater management ordinance that meets the requirements of this General Permit.
BMP #5: Develop and implement measures to encourage and expand the use of Low Impact Development (LID) in new and redevelopment. Measures also should be included to encourage retrofitting LID into existing development. DEP’s Pennsylvania Stormwater Best Management Practices Manual provides guidance on implementing LID practices.
Measurable Goal: In your inventory of development and redevelopment projects authorized for construction since March 10, 2003, that discharge stormwater to your regulated MS4s, indicate which projects incorporated LID practices and for each project list and track the BMPs that were used.
Measurable Goal: Enact ordinances consistent with LID practices and repeal sections of ordinances that conflict with LID practices. Progress with enacting and updating your ordinances to enable the use of LID practices shall be summarized in the periodic reports.
BMP 6: Ensure adequate operation and maintenance of all post-construction stormwater management BMPs installed at all qualifying development or redevelopment projects (including those owned or operated by the permittee).
Measurable Goal: Within the first year of coverage under this permit, new permittees shall develop and implement a written inspection program to ensure that stormwater BMPs are properly operated and maintained. The program shall include sanctions and penalties for non-compliance. All permittees shall review and update the inspection program annually and shall continue to implement this BMP.
Measurable Goal: An inventory of PCSM BMPs shall be developed by permittees and shall be continually updated during the term of coverage under the permit as development projects are reviewed, approved, and constructed. This inventory shall include all PCSM BMPs installed since March 10, 2003 that discharge directly or indirectly to your regulated small MS4s. The inventory also should include PCSM BMPs discharging to the regulated small MS4 system that may cause or contribute to violation of water quality standard. The inventory shall include:
- all PCSM BMPs that were installed to meet requirements in NPDES Permits for Stormwater Discharges Associated with Construction Activities approved since March 10, 2003;
- the exact location of the PCSM BMP (e.g., street address);
- information (e.g., name, address, phone number(s)) for BMP owner and entity responsible for BMP Operation and Maintenance (O&M), if different from BMP owner;
- the type of BMP and the year it was installed;
- maintenance required for the BMP type according to the Pennsylvania Stormwater BMP Manual or other manuals and resources;
- the actual inspection/maintenance activities for each BMP;
- an assessment by the permittee if proper operation and maintenance occurred during the year and if not, what actions the permittee has taken, or shall take, to address compliance with O&M requirements.
c.) Develop and implement a written program
MCM #6 – POLLUTION PREVENTION / GOOD HOUSEKEEPING
BMP #1: Identify and document all facilities and activities that are owned or operated by the permittee and have the potential for generating stormwater runoff to the regulated small MS4. This includes activities conducted by contractors for the permittee. Activities may include the following: street sweeping; snow removal/deicing; inlet/outfall cleaning; lawn/grounds care; general storm sewer system inspections and maintenance/repairs; park and open space maintenance; municipal building maintenance; new construction and land disturbances; right-of-way maintenance; vehicle operation, fueling, washing and maintenance; and material transfer operations, including leaf/yard debris pickup and disposal procedures. Facilities can include streets; roads; highways; parking lots and other large paved surfaces; maintenance and storage yards; waste transfer stations; parks; fleet or maintenance shops; wastewater treatment plants; stormwater conveyances (open and closed pipe); riparian buffers; and stormwater storage or treatment units (e.g., basins, infiltration/filtering structures, constructed wetlands, etc.).
Measurable Goal: By the end of the first year of permit coverage, new permittees shall identify and document all types of municipal operations, facilities and activities and land uses that may contribute to stormwater runoff within areas of municipal operations that discharge to the regulated small MS4. Renewal permittees should have completed this list during the previous permit term. For all permittees, this information shall be reviewed and updated each year of permit coverage, as needed. Part of this effort shall include maintaining a basic inventory of various municipal operations and facilities.
BMP #2: Develop, implement and maintain a written operation and maintenance (O&M) program for all municipal operations and facilities that couldcontribute to the discharge of pollutants from the regulated small MS4s, as identified under BMP #1. This program (or programs) shall address municipally owned stormwater collection or conveyance systems, but could include other areas (as identified under BMP #1). The O&M program(s) should stress pollution prevention and good housekeeping measures, contain site-specific information, and address the following areas:
- Management practices, policies, and procedures shall be developed and implemented to reduce or prevent the discharge of pollutants to the regulated small MS4s. The permittee shall consider eliminating maintenance area discharges from floor drains and other drains if they have the potential to discharge to storm sewers.
- Maintenance activities, maintenance schedules, and inspection procedures to reduce the potential for pollutants to reach the regulated small MS4s.
- Controls for reducing or eliminating the discharge of pollutants from streets, roads, highways, municipal parking lots, maintenance and storage yards, waste transfer stations, fleet or maintenance shops with outdoor storage areas, salt / sand (anti-skid) storage locations and snow disposal areas. Controls for solid chemical products stored and utilized for the principal purpose of deicing roadways for public safety must be consistent with the BMPs for existing salt storage and distribution sites contained in the PAG-03 NPDES General Permit for Stormwater Discharges Associated with Industrial Activity.
- Procedures for the proper disposal of waste, including dredge spoil, accumulated sediments, trash, household hazardous waste, used motor oil, street sweepings, and other debris.
Measurable Goal: During the first year of permit coverage, new permittees shall develop and implement a written O&M program that complies with BMPs #1 and #2. Renewal permittees shall continue to implement their existing program. All permittees shall review the O&M program annually, edit as necessary, and continue to implement during every year of permit coverage.
BMP #3: Develop and implement an employee training program that addresses appropriate topics to further the goal of preventing or reducing the discharge of pollutants from municipal operations to your regulated small MS4s. The program may be developed and implemented using guidance and training materials that are available from federal, state or local agencies, or other organizations. Any municipal employee or contractor shall receive training. This could include public works staff, building / zoning / code enforcement staff, engineering staff (on-site and contracted), administrative staff, elected officials, police and fire responders, volunteers, and contracted personnel. Training topics should include operation, inspection, maintenance and repair activities associated with any of the municipal operations / facilities identified under BMP #1. Training should cover all relevant parts of the permittee’s overall stormwater management program that could affect municipal operations, such as illicit discharge detection and elimination, construction sites, and ordinance requirements.
Measurable Goal: During the first year of permit coverage, new permittees shall develop and implement a training program that identifies the training topics that will be covered, and what training methods and materials will be used. Renewal permittees shall continue to operate under their existing program. All permittees shall review the training program annually, edit it as necessary, and continue to implement it during every year of permit coverage.
Measurable Goal: Your employee training shall occur at least annually (i.e., during each permit coverage year) and shall be fully documented in writing and reported in your periodic reports. Documentation shall include the date(s) of the training, the names of attendees, the topics covered, and the training presenter(s).
Chesapeake Bay - Before Tropical Storm Lee
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