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SW101
Municipal Separate Storm
Sewer Systems (MS4s)
What is an MS4?
A municipal separate storm sewer system (MS4) is:
A conveyance or system of conveyances... owned by a
State, city, town, federal agency*, or other public entity
that discharges to waters of the U.S. and is:
– designed or used for collecting or conveying storm
water
– not a combined sewer
– not part of a Publicly Owned Treatment Works
(POTW)
*only Phase II Small MS4s
Types of MS4s
• Phase I: based population within city or
unincorporated part of county
– Large MS4 250,000 or greater pop.
– Medium MS4 100,000 – 250,000 pop.
– Designated
• Phase II: based primarily on Census Bureau
Urbanized Areas and not political boundary
– Regulated Small MS4 in UA
– Designated outside UA
– Unregulated
Small MS4 Coverage
Urbanized Area Definition
A central place (or places) and the adjacent
densely settled surrounding territory that together
have a minimum residential population of 50,000
people and a minimum average density of 1,000
people/square mile.
Small MS4 Coverage
Determining Location in a UA
• Appendix 6 to the preamble
• Link on Region 6 MS4 Web page via
www.epa.gov/region6/sws
• State Data Centers
Small MS4 Coverage
Designation by the PA
• The PA must develop and apply
designation criteria to small MS4s, located
outside of a UA, serving a jurisdiction with
>10,000 population and >1,000/sq. mile
population density
Designation by the PA
Designation Criteria
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Discharge to sensitive waters
High growth or growth potential
High population density
Contiguity to an urbanized area
Significant contributor of pollutants to
waters of the U.S.
• Ineffective protection of water quality
by other programs
Designation by the PA
• The PA must also designate any small
MS4 that is substantially contributing
pollutants to a physically
interconnected regulated MS4
• Anyone may petition PA to designate
any MS4
Regulated Small MS4 Waivers
Waiver Option 1
Available where…
– The regulated small MS4 serves a population of less
than 1,000 within the UA
– The regulated small MS4 is not contributing to the
pollutant loadings of a physically interconnected
regulated MS4
– If the regulated small MS4 is discharging to an
impaired water body, storm water controls are not
needed based on a TMDL that addresses the pollutants
of concern
Regulated Small MS4 Waivers
Waiver Option 2
Available where…
– The regulated small MS4 serves a population of
less than 10,000
– The PA has evaluated all waters that receive a
discharge from the regulated small MS4
– The PA has determined that storm water controls
are not needed based on a TMDL or equivalent
analysis that addresses the pollutants of concern
– The PA has determined that future discharges will
not impact water quality.
Regulated MS4
Permit Requirements
• Required to develop, implement and enforce a
program to reduce the discharge of pollutants
to the Maximum Extent Practicable (MEP) and
effectively prohibit discharge of non-storm
water into MS4
• Program must include:
– Comprehensive program (Large MS4s)
– Six minimum control measures (Small MS4s)
– Evaluation/assessment efforts & recordkeeping
Six Minimum Control
Measures
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Public Education and Outreach
Public Involvement/Participation
Illicit Discharge Detection and Elimination
Construction Site Runoff Control
Post-Construction Storm Water
Management in New and Redevelopment
• Pollution Prevention/Good Housekeeping
for Municipal Operations
Regulated Small MS4
Permit Requirements
• Must submit an NOI or individual permit
application and identify the following elements
for each minimum control measure:
–
–
–
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Best management practices
Measurable goals
Timing and frequency of the actions
Responsible persons
WHEN YOUR CAR'S LEAKING OIL ON
THE STREET, REMEMBER IT'S NOT JUST
LEAKING OIL ON THE STREET.
WHEN YOU'RE WASHING YOUR CAR IN THE
DRIVEWAY, REMEMBER YOU'RE NOT JUST
WASHING YOUR CAR IN THE DRIVEWAY.
WHEN YOUR PET GOES ON THE LAWN,
REMEMBER IT DOESN'T JUST GO ON THE LAWN.
WHEN YOU'RE FERTILIZING THE LAWN,
REMEMBER YOU'RE NOT JUST FERTILIZING
THE LAWN.
The Interaction of Federal
and Municipal Construction
Programs
• NPDES Storm Water Construction Program
– Administered by the NPDES PA
– Requires the construction operator to obtain an NPDES storm
water permit
– Nationwide coverage
– Qualifying Local Programs (QLPs) can be referenced in permit
• NPDES-regulated MS4 Construction Programs
– Administered by the MS4 operator
– Requirements vary between MS4s
Deadlines for Small MS4
Compliance
• “Automatically” designated small MS4s:
– Permit coverage by March 10, 2003
– If PA has approved schedule for phasing coverage
for MS4s <10,000 - coverage by March 8, 2007
• Full implementation of MS4’s program:
– Within 5 years of permit issuance
SW101
Examples of Municipal
BMPs and Measurable
Goals
Public Education and Outreach
What Are Some BMPs for Implementing
This Measure?
• Develop and distribute brochures or fact sheets
for general public and specific audiences
• Develop and distribute recreational guides to
educate groups such as golfers, hikers,
paddlers, climbers, fishermen, and campers
• Develop alternative information sources, such
as web sites, bumper stickers, refrigerator
magnets, posters for bus and subway stops, and
restaurant placemats
Public Education and Outreach
What Are Some BMPs for Implementing
This Measure?
• Establish a library of educational materials for
community and school groups
• Encourage volunteer citizen educators to staff a
public education task force
• Participate with educational displays at home
shows and community festivals
• Develop educational programs for school-age
children
Public Education and Outreach
What Are Some BMPs for Implementing
This Measure?
• Develop program for storm drain stenciling of
storm drains with messages such as “Do Not
Dump - Drains Directly to Lake”
• Set up storm water hotlines for information and
for citizen reporting of polluters
• Provide economic incentives to citizens and
businesses (e.g., rebates to homeowners
purchasing mulching lawnmowers or
biodegradable lawn products)
Public Education and Outreach
What Are Appropriate Measurable
Goals?
Target
1 year
2 years
3 years
4 years
Activity
Brochures developed and distributed in water
utility bills; a storm water hotline in place;
volunteer educators trained.
A web site created; school curricula developed;
storm drains stenciled.
A certain percentage of restaurants no longer
dumping grease and other pollutants down storm
sewer drains.
A certain percentage reduction in litter or animal
waste detected in discharges.
Public Participation
What Are Some BMPs for Implementing
This Measure?
• Set up public meetings/citizen panels to allow
citizens to discuss various viewpoints and
provide input concerning appropriate storm
water management policies and BMPs
• Establish volunteer water quality monitoring
program to give citizens first-hand knowledge
of the quality of local water bodies and provide
a cost-effective means of collecting water
quality data
Public Participation
What Are Some BMPs for Implementing
This Measure?
• Develop group of volunteer educators/speakers
who can conduct workshops, encourage public
participation, and staff special events
• Encourage storm drain stenciling by concerned
citizens and students
• Encourage community clean-ups along local
waterways, beaches, and around storm drains
Public Participation
What Are Some BMPs for Implementing
This Measure?
• Support citizen watch groups to aid local
enforcement authorities in the identification of
polluters
• Develop “Adopt A Storm Drain” programs to
encourage individuals or groups to keep storm
drains free of debris and to monitor what is
entering local waterways through storm drains
Public Participation
What Are Appropriate Measurable
Goals?
Target
1 year
2 years
3 years
4 years
Activity
Notice of a public meeting in different print
media and bilingual flyers; citizen panel
established; volunteers organized to locate
outfalls/illicit discharges and stencil drains.
Final recommendations of citizen panel; radio
spots promoting program and participation.
A certain percentage of the community
participating in community clean-ups.
Citizen watch groups established in a certain
percentage of neighborhoods; outreach to all
population sectors completed.
Illicit Discharge Detection & Elimination
What Are Some BMPs for Implementing This
Measure?
• Collect all existing information on outfall locations
(e.g., city records, drainage maps, storm drain maps),
and then conduct field surveys to verify locations;
• Develop storm water ordinance to prohibit illicit
discharges;
• Locate problem areas for detailed screening using
methods such as public complaints; visual screening;
water sampling from manholes and outfalls during dry
weather; and infrared and thermal photography.
• Coordinate volunteers for locating outfalls or
stenciling storm drains.
Illicit Discharge Detection & Elimination
What Are Some BMPs for Implementing This
Measure?
• Determine the source of the problems using methods
such as: dye-testing buildings in problem areas; dyeor smoke-testing buildings at the time of sale; tracing
the discharge upstream in the storm sewer; employing
a certification program that shows that buildings have
been checked for illicit connections; implementing an
inspection program of existing septic systems; and
using video to inspect the storm sewers.
• Educate and work with dischargers found to be
sources of illicit connections.
Illicit Discharge Detection & Elimination
What Are Some BMPs for Implementing This
Measure?
• Document the number of outfalls screened; any
complaints received and corrected; the number of
discharges and quantities of flow eliminated; and the
number of dye or smoke tests conducted.
• Develop informative brochures, and guidances for
specific audiences and school curricula.
• Design a program to publicize and facilitate public
reporting of illicit discharges.
• Initiate recycling programs for commonly dumped
wastes, such as motor oil, antifreeze, and pesticides.
Illicit Discharge Detection & Elimination
What Are Appropriate Measurable Goals?
Target
1 year
2 years
3 years
4 years
Activity
Sewer system map completed; recycling program
for household hazardous waste in place.
Ordinance in place; training for public employees
completed; a certain percentage of sources of
illicit discharges determined.
A certain percentage of: illicit discharges
detected; illicit discharges eliminated; and
households participating in quarterly household
hazardous waste special collection days.
Most illicit discharge sources detected and
eliminated.
Construction Site Runoff Control
What Are Some BMPs for Implementing
This Measure?
• Develop an ordinance that requires controls for
polluted runoff from construction sites that
disturb more than one acre;
• Develop procedures for site plan reviews and
inspections;
• Develop procedures for the receipt and
consideration of public inquiries, concerns, and
information submitted regarding local
construction activities.
Construction Site Runoff Control
What Are Appropriate Measurable Goals?
Target
1 year
2 years
3 years
4 years
Activity
Ordinance or other regulatory mechanism in
place; procedures for information submitted by
the public in place.
Procedures for site inspections implemented; a
certain percentage rate of compliance achieved by
construction operators.
Maximum compliance with ordinance; improved
clarity and reduced sedimentation of local
waterbodies.
Increased numbers of sensitive aquatic organisms
in local waterbodies.
Post-Construction/ New Development/
Redevelopment
What Are Some Non-Structural BMPs for
Implementing This Measure?
• Develop master plans, comprehensive plans, or
zoning ordinances to guide the growth of your
community away from sensitive areas and restrict
certain types of growth to areas that can support it
without compromising water quality.
• Establish site-based local controls such as buffer strip
and riparian zone preservation, minimization of
disturbance and imperviousness, and maximization of
open space.
Post-Construction/ New Development/
Redevelopment
What Are Some Structural BMPs for
Implementing This Measure?
• Incorporate storm water storage into your system by
gathering runoff in wet ponds, dry basins, or
multichamber catch basins and slowly releasing it to
receiving waters or drainage systems.
• Build infiltration systems such as infiltration
basins/trenches, dry wells, and porous pavement, to
facilitate the percolation of runoff through the soil to
ground water, and, thereby reduce storm water
quantity and mobilization of pollutants.
Post-Construction/ New Development/
Redevelopment
What Are Some Structural BMPs for
Implementing This Measure?
• Incorporate vegetative practices such as grassy
swales, filter strips, artificial wetlands, and rain
gardens to enhance pollutant removal,
maintain/improve natural site hydrology,
promote healthier habitats, and increase
aesthetic appeal.
Post-Construction/ New Development/
Redevelopment
What Are Appropriate Measurable Goals?
Target
1 year
2 years
3 years
4 years
Activity
Strategies developed that include structural and/or
non-structural BMPs.
Strategies codified by use of ordinance or other
regulatory mechanism.
Reduced percent of new impervious surfaces
associated with new development projects.
Improved clarity and reduced sedimentation of
local waterbodies.
Pollution Prevention/ Good Housekeeping
for Municipal Operations
What Are Some BMPs for Implementing This
Measure?
• Establish maintenance activities, maintenance
schedules, and long-term inspection procedures for
structural and non-structural controls to reduce
floatables and other pollutants discharged from the
separate storm sewers.
• Establish procedures for the proper disposal of waste
removed from the separate storm sewer systems,
including dredge spoil, accumulated sediments,
floatables, and other debris.
Pollution Prevention/ Good Housekeeping
for Municipal Operations
What Are Some BMPs for Implementing This
Measure?
• Develop programs that promote recycling, minimize
pesticide use, and ensure the proper disposal of animal
waste to reduce or eliminate the discharge of
pollutants from areas such as roads and parking lots,
maintenance and storage yards, and waste transfer
stations;
• Coordinate with flood control managers to ensure that
new flood management projects assess the impacts on
water quality and examine existing projects for
incorporation of additional water quality protection
devices or practices.
Pollution Prevention/ Good Housekeeping
for Municipal Operations
What Are Appropriate Measurable Goals?
Target
1 year
2 years
3 years
4 years
Activity
Pollution prevention plan completed; employee
training materials developed; procedures in place
for catch basin cleaning and street sweeping.
Training for appropriate employees completed;
recycling program fully implemented.
Some pollution prevention BMPs incorporated
into master plan; a certain percentage reduction in
pesticide and sand/salt use; maintenance schedule
for BMPs established.
A certain percentage reduction in floatables
discharged; a certain compliance rate with
maintenance schedules for BMPs; controls in
place for all areas of concern.