Illinois EPA MS4/ILR10 permit overview & changes

Transcription

1 Illinois EPA MS4/ILR10 permit overview & changes Stasi Brown, CPESC Resource Analyst Kane-DuPage Soil & Water Conservation District

2 Questions We Hope To Answer: Requirements of an MS4 & ILR10 permits how does the ILR10 General Construction permit relate to the MS4 permit? What are for the new or amended requirements for the MS4 and General Construction permit?

3 NPDES Overview Phased approach for stormwater was required by the 1987 CWA Amendments Phase I: Stormwater Application and Implementation Rules (1990) Addressed major sources of runoff Phase II: Construction t ti Sites > 5 acres (1995) Construction Sites > 1 acre and Small MS4 s (1999) We are still in Phase II new permit changes

4 NDPES permit descriptions: National Pollutant Discharge Elimination System An MS4 or NPDES permit No. ILR40 covers discharges for Municipal Separate Storm Sewer Systems VS. A General e Construction o permit or NPDES permit No. ILR10 covers individual construction projects (within or outside a MS4) over 1 acre.

5 MS4 Basics Municipal Separate Storm Sewer System Storm sewer systems may include: Ditches and Detention Ponds Curbs/gutters Storm sewer pipes Phase II MS4s are any small MS4s that are: located in a urbanized area as defined by the Bureau of Census designated by the Illinois EPA

6 MS4 Permit Requirements Create/Implement/Evaluate a Stormwater Management Plan (SWMP) Reduce discharge of pollutants to the maximum extent practicable (MEP) Protect Water Quality Implement Best Management Practices (BMPs) to satisfy each of the six minimum control measures

7 Six Minimum Control Measures Public Education and Outreach* Public Participation and Involvement Illicit Discharge Detection and Elimination Construction Site Runoff Control* Post-Construction t ti Runoff Control Pollution Prevention/Good Housekeeping

8 Stormwater Management Plan Identify local concerns and characteristics Show what your community will contribute t for funding and staffing the program. List activities to address each of the 6 measures Schedule for implementation Measurable Goals - Establish a Baseline what issues will you target? Milestones or targets by which to measure how the activity is progressing Date of Completion - Measurable Goal/BMP Tracking Guidance Way to monitor/report progress audit Info on permit, measurable goals and audit found at: us/water/permits/storm-water/ms4.html

9 MS4 Permit Requirements Submitted the Stormwater Management Plan with NOI (this is different than a ILR10 NOI) Implemented by March 2008 current permit We are still in Phase II for this permit. Phase III will bring additional changes that have not yet been defined. Must evaluate program and submit reports: Annual reports by June 1 Keep relevant records for at least 3 years Make available to an inspector and the public

10 MS4 permit text Minimal control measures 4 & 5 reference ILR10 permit Applicable construction sites within MS4 boundaries must follow NPDES permit No. ILR10 BMP s must be at least as restrictive as the most updated Illinois Urban Manual.

11 ILR10 permit referred within the MS4 permit Municipalities need to be very familiar with the requirements of the NPDES ILR10 permit

12 Required Paperwork for ILR10 permitted sites: Notice of Intent (NOI) different than the MS4 NOI form SWPPP Storm Water Pollution Prevention Plan Made available to Sub-Contractors All required sections are present (see ILR10 permit part IV or Contractor Certification Statement is signed The NOI & SWPPP must be completed and onsite BEFORE start of construction.

13 Permit Change - Filing your Notice of Intent t (NOI) To receive authorization under this general permit, a discharger must submit a completed Notice of Intent (NOI) in accordance with Part VI.G (Signatory Requirements) and the requirements of this Part in sufficient time to allow a 30 day review period after the receipt of the NOI by the Agency and the start t of construction. ti The completed NOI may be submitted electronically to the following address: Discharges that were previously covered by a valid General NPDES Discharges that were previously covered by a valid General NPDES Permit for Storm Water Discharges from Construction Site Activities are automatically covered by this permit.

14 Permit Change - NOI submittal period Part II.A.1 - has been revised to clarify the need to submit the NOI in sufficient time to allow a 30 day period after receipt of the NOI and the start of construction

15 Stormwater Pollution Prevent Plan - 1. Text SWPPP contains: - Taken from ILR10 2. Site Plan - Keep Updated

16 SWPPP Text Site Specific Information is Needed All required sections must be present: Site Description, Controls, Stabilization Practices, Construction ti Practices, Storm Water Management, Other Controls Local requirements are met Maintenance, Inspections, Non-Stormwater Discharges (see ILR10 permit part IV or Contractor Certification Statement is present and signed

17 Permit Change - Electronic submission of SWPPP Part t II.C.7 - has been revised to include electronic submission of the Storm Water Pollution Prevention Plan to the Agency at the following address: epa.constilr10swppp@illinois.gov

18 Pre-Construction Checklist ILR10 Paperwork Designated SESC inspector/contact NOI and copy of ILR10 permit ONSITE SWPPP ONSITE Inspection log ONSITE Site Inspections - weekly and after.5 rains These requirements are the same for an MS4 permitted construction site.

19 Self Inspection Logs Should Include: Date of the Inspection Initials of onsite inspector Dates of Major Grading Activities Status of SESC practices Dates of installation Dates of maintenance Outlets and stormwater exit points Evidence of Sediment leaving the site? Inspections must occur every week or after Inspections must occur every week or after every ½ rainstorm event (or equivalent snow fall)

20 Permit Change - Inspector qualifications Part IV.D.4 - has been revised to include the qualifications of qualified personnel, such as a Professional Engineer (P.E.) E)a Certified Professional in Erosion and Sediment Control (CPESC), a Certified Erosion Sediment and Storm Water Inspector (CESSWI) or other knowledgeable person.

21 What should be inspected? - All Erosion and Sediment Control measures shown on the plans - Entry points to stormwater facilities V S

22 What should be inspected? - Any areas where impacts can be observed to receiving waters

23 What should be inspected? ongoing management issues - Visible erosion or accumulated sediments and potential problem areas

24 Permit Change stabilization requirements Originally disturbed areas had to be stabilized according to the 14/21 day rule. This has now changed to: Where the initiation of stabilization measures by the 7th day after construction activity temporarily or permanently ceases on a portion of the site is precluded by snow cover, stabilization measures shall be initiated as soon as practicable. Wh t ti ti it ill ti f th it Where construction activity will resume on a portion of the site within 14 days from when activities ceased, (e.g. the total time period that construction activity is temporarily ceased is less than 14 days) then stabilization measures do not have to be initiated on that portion of site by the 7th day after construction activity temporarily ceased.

25 Incidence of Non-Compliance Sites should report MAJOR noncompliance issues which have occurred onsite. IEPA does not usually use IONs to initiate iti t enforcement actions

26 Permit Change - Electronic submittal of ION s Part IV.D.4.d - has been revised to allow telephone, fax, and notification of incidences of non-compliance compliance. However, at the present time the Agency requires original signatures on the ION forms sent to the Agency following the submission.

27 Importance of upholding permit requirements The most common non-point source pollutants in Illinois are nutrients and sediment. Loss of sediment into local streams and rivers can cause: Sediment carries other harmful pollutants like heavy metals and toxins Loss of recreational use Harm fish, plants and animals that t rely on local l bodies of water Nutrient loading and depleted Oxygen levels

28 All forms are available on the website Notice of Intent (NOI) Notice of Termination (NOT) Incidence of Noncompliance (ION) General Storm Water Permit water/index.html

29 Stasi McCrory, CPESC Resource Analyst 2315 Dean Street, Suite 100 St. Charles, Illinois (630) ext. 3