What Are the Phase II Small MS4 Program Requirements?
Operators of regulated small MS4s are required to design their programs to: Reduce the discharge of pollutants to the “maximum extent practicable” (MEP);_ Protect water quality; and_Satisfy the appropriate water quality requirements of the Clean Water Act.Implementation of the MEP standard will typically require the development and implementation of BMPs (Best Management Practice) and the achievement of measurable goals to satisfy each of the six minimum control measures.
The Phase II Rule defines a small MS4 storm water management program as a program comprising six elements that, when implemented in concert, are expected to result in significant reductions of pollutants discharged into receiving waterbodies.
Stormwater pollution from point sources and nonpoint sources is a challenging water quality problem. Unlike pollution from industry or sewage treatment facilities, which is caused by a discrete number of sources, stormwater pollution is caused by the daily activities of people everywhere. Rainwater and snowmelt run off streets, lawns, farms, and construction and industrial sites and pick up fertilizers, dirt, pesticides, oil and grease, and many other pollutants on the way to our rivers, lakes, and coastal waters. Stormwater runoff is our most common cause of water pollution.
Education and outreach are key components to any
successful stormwater program.
The six MS4 program elements, termed “minimum control measures,” are outlined below:
1. Public Education and Outreach
Distributing educational materials and performing outreach to inform citizens about the impacts polluted storm water runoff discharges can have on water quality.
2. Public Participation/Involvement
Providing opportunities for citizens to participate in program development and implementation, including effectively publicizing public hearings and/or encouraging citizen representatives on a storm water management panel.
3. Illicit Discharge Detection and Elimination
Developing and implementing a plan to detect and eliminate illicit discharges to the storm sewer system (includes developing a system map and informing the community about hazards associated with illegal discharges and improper disposal of waste).
4. Construction Site Runoff Control
Developing, implementing, and enforcing an erosion and sediment control program for construction activities that disturb 1 or more acres of land (controls could include silt fences and temporary storm water detention ponds).
5. Post-Construction Runoff Control
Developing, implementing, and enforcing a program to address discharges of post-construction storm water runoff from new development and redevelopment areas. Applicable controls could include preventative actions such as protecting sensitive areas (e.g., wetlands) or the use of structural BMPs such as grassed swales or porous pavement.
6. Pollution Prevention/Good Housekeeping
Developing and implementing a program with the goal of preventing or reducing pollutant runoff from municipal operations. The program must include municipal staff training on pollution prevention measures and techniques (e.g., regular street sweeping, reduction in the use of pesticides or street salt, or frequent catch-basin cleaning). or its chosen BMPs and measurable goals for each minimum control measure. To help permittees identify themost appropriate BMPs for their programs, EPA will issue a“menu,” of BMPs to serve as guidance. NPDES permitting authorities can modify the EPA menu or develop their own list.