ms4 permit updates may 9, 2014 jay hoskins, p.e. metropolitan st. louis sewer district
TRANSCRIPT
MS4 Permit Updates
May 9, 2014
Jay Hoskins, P.E.
Metropolitan St. Louis Sewer District
MS4 Permit Updates
1. MS4 Permit Renewal 2. 3rd Term Permit Stormwater
Management Plan Highlights3. Federal Rulemaking4. Show-Me Rain Gardens Website
MS4 Permit Renewal 2nd Term Permit expired June 12, 2013 MDNR has proposed, but not issued, a
3rd term MS4 general permit 2nd term permit is administratively
continued Key issues in proposed permit
Water quality standards in MS4 permits TMDL implementation Affordability
Water Quality Standards (???)CWA: Permits for discharges from municipal storm sewers…shall require controls to reduce the discharge of pollutants to the maximum extent practicable, including management practices, control techniques and system, design and engineering methods, and such other provisions as the Administrator or the State determines appropriate for the control of such pollutants.
TMDL Implementation No MSD streams have EPA approved
TMDLs, at present Proposed permit requires
The permittee develop a TMDL Plan within 30 months following EPA approval of a TMDL
“Plan to address TMDL assumptions, requirements, WLAs, and LAs”
“Permittee must implement the plan”
Affordability MO statutes require MDNR perform a
Finding of Affordability for new permit requirements
MDNR’s finding only addressed TMDL plan development—not implementation “TMDL implementation responsibilities
are not new requirements.” Recently, MDNR managers agreed to
revise this position and perform the affordability determination for plan implementation, in the future
Ongoing MS4 Permit Activities
Continue to implement 6 MCMs… Public Education & Outreach Public Involvement & Participation Illicit Discharge Detection & Elimination Construction Site SW Control Post-Construction SW Mgt in Development P2/Good Housekeeping for Muni Ops
Submit 2013-14 annual report by July 28 Co-permittee group tabling most 3rd term
SWMP activities until permit is renewed
3rd Term Permit Planning Process
7 planning committee meetings 3 public stakeholder group meetings 3 newsletter publications New goal development
Researched new BMPs MDNR audit recommendations
Draft SWMP public Notice in October 2012 Final SWMP mailed to MDNR
in December 2012 Available on MSD website
3rd Term Permit Plan: New Goals Develop standardized checklists and
reporting procedures for post-BMPs DONE—see BMP toolkit
Redevelopment Roadway Workgroup Begun—not finished
Workgroup on incentives & awards for participating in NPS reduction programs Begun—not finished
Ask cities to review, update parking ordinances (as needed) Legal Impediment WG Recommendation
3rd Term Permit Plan: New Goals Workgroup on improving NPS
education in schools Develop and distribute brochures on
individual sewage disposal systems Develop and conduct “staged”
construction BMP inspection training Updating municipal O&M model
template, ask cities to update plans Review BMP performance for
bacteria, chloride
Federal Stormwater Rulemaking EPA Finalized “Construction and Development
Effluent Guidelines and Standards” Effluent limits reflecting best practicable
technology currently available: “Control stormwater discharges, including both peak
flowrates and total stormwater volume” “Provide and maintain natural buffers around waters of
the United States, direct stormwater to vegetated areas and maximize stormwater infiltration to reduce pollutant discharges, unless infeasible”
Withdrew numeric turbidity standard EPA has deferred development of national
post-construction BMP performance standard
Show-Me Rain Gardens(Turn your Yard Into a Superhero)
Education Tips & tools Picture
gallery Rain garden
registration
