MS4 Permit Compliance in a Multiple Department Organization

AZ Water Association Robert Hollander, P.E.

Stormwater Quality Workshop Environmental Resources Manager

November 7, 2017 City of Peoria Public Works - Utilities

Agenda

• Why this presentation?

• The Municipal Separate Storm Sewer System

(MS4) Permit

• Challenge to MS4 Permittees

• Addressing the challenge

• Examples and Open Forum

Why this presentation?

• New Permit

• Recent audits/inspections

• New identified MS4 entities

The Small Municipal Separate Storm Sewer System (MS4) Permit

• New General Permit for

Stormwater Discharges from

Small Municipal Separate Storm

Sewer Systems

• Effective September 30, 2016

• Expires midnight September 29,

2021

• Last Permit issued December 19,

2002

Introduction to The Small Municipal Separate Storm Sewer System (MS4) Permit

• Purpose• Prevent/minimize pollutants getting into storm water

• Help meet the “Fishable/Swimmable” goals of the

Clean Water Act

Introduction to The Municipal Separate Storm Sewer System (MS4) Permit

• Permit Elements (Minimum Control Measures)

• Public Education and Outreach

• Public Participation and Involvement

• Illicit Discharge Detection and Elimination

• Construction Activity Stormwater Runoff Control

• Post-Construction Stormwater Management in New Development

and Redevelopment

• Pollution Prevention and Good Housekeeping for Municipal

Operations

Introduction to the Small MS4 Permit

• Notice of Intent (NOI)

• Use to seek coverage under Permit

• Stormwater Management Program/Plan (SWMP)

• Outlines Best Management Practices (BMPs) to meet MCMs

The Challenge to MS4 Permittees

• Requires implementation of elements over multiple

departments and divisions (decentralized programs)

• Other departments have different priorities

• Unequal appreciation for or understanding of water quality

regulatory requirements

• Workforce issues (e.g. retirements)

The Challenge to MS4 Permittees (cont.)

• Goal: Present approach to comply with MS4 Permit

where stormwater related activities are carried out

by multiple departments (i.e. decentralized)

Creating A Common Sense of Purpose

• Get on the same page

• Educate/Inform other

departments/divisions

• Stormwater quality high priority to

EPA/Primacy agencies (i.e. States, Tribes)

• Management support

• Understanding of importance

• Adequate organizational positioning

• Evaluate organizational efficiencies

• Funding

• Evaluate need

• Need to incorporate into budget cycles

Building a Team

• Train staff on BMPs

• Fact Sheets - EPA

• Guidance documents – EPA,

utilities, associations

• Training videos/materials –

Websites, vendors, utilities

Building a Team (continued)

• Avoid this

• Assign responsibility

• Staff familiar with facilities

and operations

• Hold accountable (e.g.

consider including as

performance goal in

evaluations)

Coordination and Measurement

• Execution

• Assign responsible departments/divisions

• Establish goals

• Establish measurable targets

• Identify target audiences

• Collect data

• Evaluate results

Coordination and Measurement (continued)

• Set up coordination meetings with responsible staff

• Communicate goals, targets, and measurement methods

• Use visual presentations (e.g. spreadsheets, Gannt Charts)

• Establish internal reporting deadlines

• Each function provides status at meeting goals

Coordination and Measurement (continued)

• Set up coordination meetings with responsible staff (cont.)

• Establish regular schedule

• Monthly or Quarterly

• Prepare agendas

• Introductions

• Progress at meeting goals and targets

• Challenges faced

• Problem solving

Coordination and Measurement (continued)

• Identify and Empower Coordinator(s)• Within departments/divisions/functions

• Overall program coordinator

Coordination and Measurement (continued)

• Identify and Empower Program

Coordinator (cont.)

• Identify responsibilities

• Conducts Annual Program Assessment

• Inspections of municipally-owned facilities

• Dry weather monitoring

• Wet weather stormwater discharge monitoring

• Collects data and prepares Annual Report

• Internal Quality Assurance/Quality Control (not

stepping on toes, but…)

• Audits of other departments/divisions/functions

Coordination and Measurement (continued)

• Automate data collection and reporting

• To meet documentation requirements

• Readily available information

• Simplify reporting

• Eliminate/minimize errors

Coordination and Measurement (continued)

• Automation Tools

• Spreadsheets

• Electronic databases

Coordination and Measurement (continued)

• Spreadsheets

• Developed from Stormwater Management Program or

Plan (SWMP)

• Example:

• Columns

• Minimum Control Measures

• BMPs

• Target measures

• Responsible position

• Metrics/Values

Coordination and Measurement (continued)

Coordination and Measurement (continued)

• Electronic databases

• Different departments may use different databases for business

activities

• In Peoria

• Accela – Construction inspections

• Hansen – Work order system (Stormwater system inspections and maintenance)

• Linko – Compliance inspections (e.g. Pretreatment Program)

• Dedicated compliance databases

• Can databases communicate with each other (i.e. export/import data)?

Examples

• Public Education and

Outreach

• Individual MS4s

• Printed information (e.g.

brochures)

• Website

• SWAG

Examples

• Partnerships (Stormwater Outreach for Regional

Municipalities – STORM)

• Leverage funding and resources

• Reach larger regional audience (e.g. website, bulletin boards, movie

theater public service announcements)

Examples

• Public Involvement and

Participation

• Environmental clean-up events

• Festivals (e.g. PlanetPalooza –

Earth Day)

• Household Hazardous Waste

Events

Examples

• Illicit Discharge Detection and Elimination

• Permittees must have written program

• Identification is everyone’s responsibility

• Train all utility field personnel

• Assistance from public (e.g. utility website)

• Peoria Reporter app

• Training videos and brochures

Examples

Peoria Reporter app Issue Type Take Photos

Examples

Hotlines

Examples

• Investigation

• GIS

• Boots on the

ground

Examples

• Construction Activity Stormwater Runoff Control

• Development/Engineering Departments

• Site development

• Building construction

• Inspections staff must be adequately trained

• Review Stormwater Pollution Prevention Plans (SWPPPs)

• Are stormwater controls installed, maintained, and operating

properly?

Examples

• Post-Construction Stormwater Management in New

Development and Redevelopment

• After all construction activity complete and site(s) are stabilized

• Retention basins, outfalls, scuppers

Examples

• Pollution Prevention and Good Housekeeping for

Municipal Operations

• Most challenging: involves multiple departments and

facilities

• Service yards with multiple tenants

• All tenant functions must be responsible for own activities

• Coordination critical

Examples

• Follow Up

• Enforcement

• Administrative

• Code Compliance

Conclusions

• Municipalities must comply with their MS4 Permits

• Decentralized nature of functions creates challenges

• MS4s must create common sense of purpose

• Inform/train management and staff

• Establish organizational structure

• Empower coordinator and assign responsibility

• Coordinate, communicate and measure effectiveness

Information

• Fact Sheets and Guidance Documents:

https://www.epa.gov/npdes/national-menu-best-

management-practices-bmps-stormwater

• Stormwater Training

• https://www.mapistry.com/learning-center/mapistry-

guide-on-how-to-make-stormwater-training-

fun?utm_campaign=Training&utm_content=624365

69&utm_medium=social&utm_source=linkedin

Questions and Open Forum

“Statements of fact and opinion expressed are those of

the author(s) / presenter(s).

AZ Water, AZAWWA, and AZWEA assume no

responsibility for the content, nor do they represent

official policy of the Association.”