Reign Consulting Presents
COVERED TOPICS 1. Introduction and Legal 2. Small MS4 Permit 3. Risk 4. Discharges 5. What to expect 6. How to prepare 7. Conclusion
INTRODUCTION AND LEGAL
INTRODUCTION GOAL = Eliminate pollutants discharged from the MS4. AUTHORITY = MS4 authorized to regulate Industry and Construction operators with potential to discharge.
LEGAL Established pursuant to the Clean Water Act (CWA) 402(p)(1-2) and (3)(iii), section 208 of the CWA, 64 FR 68722, to ensure that: Pollutant discharges are reduced to the maximum extent practicable (MEP), Protect water quality, Satisfy the appropriate water quality requirements of the CWA.
2016 SMALL MS4 PERMIT
SMALL MS4 PERMIT
SMALL MS4 PERMIT
MUNICIPALITIES
SMALL MS4 COUNTIES
OTHER SMALL MS4S
NEW 2016 SMALL MS4S
POTENTIAL SMALL MS4S
RISK
RISK MATRIX 1.Proximity to receiving waters 2.Type of receiving water impaired, outstanding water, non-attaining, tributary 3.Site size 4.Type of pollutants on site 5.Site pollution discharge record previous violations 6.Complaints
RISK MATRIX Previous Violations Proximity to impaired or unique waters Proximity to surface waters < One Acre Increased Site Area Increased Pollutants Previous Complaints
DISCHARGES
DISCHARGES Storm Water Run-off from all exposed areas of site. Non Storm Water Allowed in the Multi Sector General Permit (MSGP) and the Construction General Permit (CGP).
DISCHARGES Non-Stormwater Discharges may be disallowed if there is a potential to contain pollutants. (Part 1.3)
DISCHARGES Potential for causing erosion, sedimentation, and turbidity if the velocity is not reduced
DISCHARGES
DISCHARGES
DISCHARGES
WHAT TO EXPECT
WHAT TO EXPECT MS4 Notice of Intent to be posted on the ADEQ website for public comment. Opportunity for industries and individuals to add comments. http://azdeq.gov/notices Key words: MS4
WHAT TO EXPECT Comment Period Date: Feb.13 COMMENT PERIOD BEGINS Proposed AZPDES MS4 General Permit Coverage to Maricopa County COMMENT PERIOD ENDS Proposed AZPDES MS4 General Permit Coverage to Maricopa County On March 15, 2017, the public comment period will end for the proposed issuance of Arizona Pollutant Discharge Elimination System (AZPDES) Municipal Storm Sewer Systems (MS4) General Permit coverage to Maricopa County. The public comment period began Feb. 13, 2017.
WHAT TO EXPECT Potential dischargers to be inventoried. Enforcement procedures. Enforcement Response Plan (ERP). Dischargers may be required to registered. Accountability. Compliance and enforcement standards.
WHAT TO EXPECT Storm sewer mapping to isolate illicit discharges. Illicit discharge tracking holding offenders accountable.
WHAT TO EXPECT Develop, implement, and enforce SWMP Describe practices to achieve compliance Abide by state and MS4 ordinances. SWMP as public record Guidance for maintaining compliance.
WHAT TO EXPECT Enforcement Response Plan (ERP) to be developed and enforceable by November 1, 2018. ERP Plan to include: Escalated enforcement, Severity of non-compliance, Repeated non-compliance, Proximity to receiving water or storm sewer system
RISK MATRIX Previous Violations Proximity to impaired or unique waters Proximity to surface waters < One Acre Increased Site Area Increased Pollutants Previous Complaints
HOW TO PREPARE
HOW TO PREPARE Establish a point of contact with the MS4 Sign up for news letters or updates Participate in public comment sessions Offer alternative options or timelines when negotiating permit details
HOW TO PREPARE Perform an analytical site evaluation Apply for State Permit coverage - General, Individual, No exposure Site specific Storm Water plan Install control measures to prevent pollutants from leaving site or reduce exposure to storm water Complete scheduled and rain event inspections Complete and submit reports
MULTI SECTOR GENERAL PERMIT (MSGP) Site specific Storm Water Management Plan (SWMP) or Storm Water Pollution Prevention Plan (SWPPP) Required inspections Discharge sampling and reporting Subject to regulatory inspections Annual permit renewal fee
CONSTRUCTION GENERAL PERMIT (CGP) Site specific Storm Water Pollution Prevention Plan (SWPPP) Required inspections Discharge sampling and reporting Subject to regulatory inspections Annual permit renewal fee
No water discharges from site. All materials, processes, and storage is contained inside or under cover of structures. Property is lower than surrounding properties. 5 year coverage NO EXPOSURE
HOW TO PREPARE Planning and Budgeting Technological planning Cost of doing business Preventative, structural, and administrative control measures Voluntary efforts Compliance violations
QUESTIONS?
IN CONCLUSION Everyone doing their part keeps the community a clean place to live and work. Prevention is less expensive than clean-up Storm drains do not lead to treatment plant, they flow directly to the closest MS4, surface water, or wash.
Thank you Deborah Schadewald-Kohler Principle Solutions Consultant Reign Consulting 602-989-1162 ReignTrooper@gmail.com REIGN CONSULTING TM SOLUTIONS FOR ARIZONA STORM WATER 2017 REIGN CONSULTING TM & CATCH THE WIND, LLC
Deborah Schadewald-Kohler Principal Solutions Consultant Reign Consulting - Solutions for Arizona Storm Water 602-989-1162 Reigntrooper@gmail.com Deborah Schadewald-Kohler has been working in regulatory water quality with the Salt River Maricopa-Pima Indian Community and the Arizona Department of Environmental Quality and as a compliance inspector in the private sector for over 12 years. Her regulatory experience includes Municipal Separate Storm Sewer Systems (Phase 1 and 2), construction, industrial, and mining stormwater compliance, large and small drinking water system sanitary surveys, waste water treatment compliance, and pre-treatment compliance. Deborah is also well versed in the prevention planning, water system planning review, monitoring, and the reporting necessary in Arizona. Ms. Schadewald-Kohler holds a Masters degree in Environmental Science with emphasis on Green Infrastructure and Low Impact Redevelopment from Prescott College.