Stormwater Management Program Updates
SWMP Updates – SWIM CoalitionJune 8, 2017
Agenda
2
1. Introductions
2. Legal Authority: Local Law & Rules
3. Stormwater Management Program (SWMP) Development
a. SWMP Plan Deliverable Timeline
b. Pollution Prevention/Good Housekeeping (PPGH) for Municipal Operations and Facilities
i. Municipal Facilities and Operations Inventory
ii. Municipal self-assessment procedures and initial assessments (started 03/17)
iii. Employee Training Program
iv. Runoff Reduction/GI Feasibility for Upgrades
c. Industrial and Commercial Stormwater Sources
i. Facility Inventory
ii. Legal Authority
iii. Unpermitted Facility Inspection
iv. MSGP Facility Inspection
v. MSGP Facility Prioritization
4. Questions
Legal Authority: Local Law & Rules
New York City MS4 Legislation
Intro 1346-2016 introduced by City Council on November 16, 2016
Public hearing held by Environmental Protection Committee on December
13, 2016
Intro 1346-2016, Version A approved by Environmental Protection
Committee on May 8, 2017
Intro 1346-2016, Version A passed by City Council on May 10, 2017
Local law signed by the Mayor on May 30, 2017
3
Legal Authority: Local Law & Rules
New York City MS4 Legislation
The version passed by the City Council and signed by the Mayor includes
several revisions from the original bill:
o New provision requiring consideration of the feasibility of green
infrastructure for certain capital projects Citywide
o Language clarifying that stop work orders apply to the work being done
in violation of applicable requirements
o Correction of a drafting error identified at the December 2016 hearing,
to clarify who is qualified to inspect post-construction stormwater
controls
o Changes to the effective date provisions to specify the range in which
DEP is allowed to set the effective dates for each program by rule
o A number of non-substantive technical edits and clarifications
4
Legal Authority: Local Law & Rules
Rulemaking: The local law authorizes agencies to make rules immediately
Illicit Discharge Detection & Elimination
The City is working on revisions to its existing IDDE rules to implement
provisions in the local law relating to illicit discharges to the MS4
The City expects to publish those draft revisions for public comment in
summer 2017, and to proceed with the CAPA process
The rulemaking will proceed concurrently with SWMP development;
program implementation not contingent on SWMP approval
Construction/Post-Construction and Commercial/Industrial Programs
Rules for these programs will reflect program elements currently being
developed for the SWMP
The City expects to propose draft rules in spring 2018, when these
programs will be more fully developed
The rules will be finalized in order to allow implementation of these
programs after the SWMP is approved
5
6
SWMP Plan Deliverable Timeline
Task Duration Start Finish
Public Review 2 months April 2 June 1
DEP coordinates final edits 2 months June 1 July 31
Submit to DEC - August 1, 2018
Topics Stakeholder Date
Draft Work Plan to
determine Floatables
loading rate
SAG Sept 2017
TBD SAG Nov/Dec 2017
Public Comments on
SWMP DraftSAG
Spring/Summer
2018
Public Meetings Tentatively Scheduled
Stormwater Management Program (SWMP)
1. Introduction
2. Program Overview
3. Public Education and Outreach
4. Public Involvement /
Participation
5. Mapping
6. Illicit Discharge Detection and
Elimination (IDDE)
7. Construction Site Stormwater
Run-off Control
8. Post-Construction Stormwater
Management
9. Pollution Prevention / Good
Housekeeping for Municipal
Operations and Facilities
10. Industrial and Commercial
Stormwater Sources
11. Control of Floatable and
Settable Trash and Debris
12. Monitoring and Assessment of
Controls
13. Reliance on Third Parties
14. Recordkeeping
15. Annual Reporting and
Certification
SWMP Chapters
10
Pollution Prevention/Good Housekeeping Program Status
Elements covered under Pollution Prevention/Good Housekeeping (PPGH) for
Municipal Operations and Facilities:
Elements completed to date:
Municipal Facilities and Operations Inventory
Municipal Facility Prioritization Protocol and Preliminary Prioritization
Stormwater Control Measures for PPGH
Elements in working progress:
Municipal self-assessment procedures and initial assessments (started 03/17)
Employee Training Program
Third-Party Contracted Services Requirements
Runoff Reduction/GI Feasibility for Upgrades
PPGH Measurable Goals
8
PP/GH Key Elements
9
MS4 SPDES Permit
Compliance for PP/GH
Inventory/ Prioritize
Facilities & Operations
Third Party Notifications
Pre-Assessment
Activities
GI Evaluation
Assessment ProceduresMSGP
Coverage
Post-Assessment
Action Planning
Annual Reporting
Requirements
Train, Implement, and Report Progress
PP/GH Facilities/Onsite Operations
10PP/GH Program Requirements
Vehicle/Equipment Operations Vehicle/Equipment Maintenance and Repair
Vehicle/Equipment Cleaning
Vehicle/Equipment Fueling
Truck Bed Management
Vehicle/Equipment Storage
Other Types of Facilities Golf Courses
Animal Recreational Facilities/Stables
Swimming Pools
Marine Operations
Material Storage Facilities General Outdoor Storage
Above-Ground Storage Tanks
Underground Storage Tanks
Drum Storage and Management
Material Stockpiles
Waste Management Facilities Waste Transfer Stations
Landfills
Shooting Ranges
Drum Storage & Management
Salt Storage & Management
PP/GH Off-site Operations
11PP/GH Program Requirements
Stormwater Collection System Maintenance
Catch basin/inlet cleaning and Repair
Storm sewer/underground facility cleaning
and repair
Ditch/open channel cleaning and repair
Green infrastructure/open facility
maintenance
Hydrologic habitat maintenance
Paved Surface Maintenance
Pavement Cleaning
Winter Pavement maintenance
Pavement/Sidewalk resurfacing and repair
Spill prevention and response
Bridge/elevated structure maintenance
Landscaping and Open Space Maintenance
Herbicide/pesticide/fertilizer application
Landscape/ground care
Turf management
Building Maintenance and Repair
Building Repair and Remodeling
Painting
Solid Waste Collection
Pavement/Sidewalk Resurfacing and Repair
Catch Basin/Inlet Cleaning and Repair
NYC MS4 Municipal Facilities
12
PP/GH Site Prioritization Preliminary Results
13
Agency Number of Sites
Low
Priority
Medium
Priority
High
Priority
DCAS 5 2 3 0
DEP 131 16 115 0
DOC 2 0 0 2
DOE 175 18 157 0
DOT 78 55 21 2
DPR 269 177 92 0
DSNY 100 47 49 4
FDNY 77 36 40 1
NYPD 68 22 44 2
Grand Total 905 373 521 11
Overview of PP/GH Self-Assessment Steps
14
Key Participants in PP/GH Program
15
Key Participants
Prepare for
Assessments
Perform
Assessment
Participate in
Assessment
Perform
SCMs Report Progress
NYCDEP Liaison P Initial
Agency PP/GH
LiaisonP P
PP/GH Contractor P Initial
Agency Assessor(s) P Subsequent Initial P
Facility Managers P P P
Operation Supervisors P P P
Staff P
PP/GH Program Requirements
PP/GH Assessments Schedule
High-priority and Pilot site assessments through summer 2017
Potential modifications to the assessment process completed by fall 2017
Remaining site assessments late 2017 through 2021, with multiple teams
operating in parallel
Date: 3/1
3
3/2
0
3/2
7
4/3
4/1
0
4/1
7
4/2
4
5/1
5/8
5/1
5
5/2
2
5/2
9
6/5
6/1
2
6/1
9
6/2
6
7/3
7/1
0
7/1
7
7/2
4
7/3
1
8/7
8/1
4
8/2
1
8/2
8
9/4
9/1
1
9/1
8
9/2
5
10
/1
11
/1
12
/1
2018 2019 2020 2021High and Pilot Site AssessmentsDOC DSNY DOTFDNYNYPDDPRDOEDCASDEP
Modification of Process for AssessmentsLow and Med Priority Sites - Assessments DSNYDOTDPRDOEFDNYDCASDEPNYPD
Agency Kick-Off Meeting for High and Pilot SitesHigh Priority Site Assessments
Pilot Site AssessmentsLow and Medium Prority Site Assessments
20
Proposed Future PP/GH Assessments Frequencies
Initial Assessments, supported by PPGH Contractor
o High-priority facilities: By August 1, 2018
o Low-and Medium-priority facilities: By August 1, 2021 (Proposed)
Follow-up Assessments, by Agency assessors (Proposed)
o High-priority facilities: every 2 years
o Medium-priority facilities: every 5 years
o Low-priority facilities: every 7 years
o Note: effective SCMs may lower priority / assessment frequency
Progress reporting: Annually
17PP/GH Program Requirements
PP/GH Training Program
Training program is a specific requirement of the MS4 Permit.
Objective: To ensure consistent implementation & tracking of PPGH permit
requirements.
Program options include:
Classroom training of site assessors regarding their role and responsibilities
o Agencies need to identify individuals responsible for site assessments
On-line training of municipal staff responsible for the proper implementation and
tracking of SCMs in municipal operations.
Optional “Train the Trainer” classroom training for facility managers or
operational supervisors of high-priority facilities. Trainers to provide on-going
messaging to their staff to ensure SCM implementation and tracking.
Program success will be measured by actual use and tracking (through
self-assessments) of the SCMs by employees in day to day operations.
22
Third-Party Certification and PP/GH Applicability Matrix
Part IV.G.1.h of the Permit requires any third-party entities performing
municipal operations as contracted services to meet permit requirements as
they apply to the activity performed
Part IV.K of the Permit requires the City to ensure, through signed
certification statement, contract or agreement, that third parties performing
any activities to develop or implement the SWMP will comply with permit
requirements applicable to the work performed by the third party
DEP and the Law Department have provided model certification statements
and other guidance to the interagency group to assist in compliance with
these provisions
19
Runoff Reduction/GI Feasibility for Upgrades
20
Runoff Reduction and Green Infrastructure Evaluation During Planned Municipal Upgrades-Simple version provided below.
Project Funding
Environmental Analysis
Hydrogeological Analysis
Expense
Does Post-Construction Generate Runoff and POCs?
PerformFeasibility Analysis
No
STOP - No
Evaluation Warranted
STOP – No Evaluation Warranted
Yes
Physical Site Conditions
If technical feasibility analysis presents no constraints
Yes Implement G.I.
No
Is implementation of G.I. Cost-Effective?
STOP (Project Not Feasible)
Capital>2MM
Public Buildings
Right of Way
This process will inform the following annual reporting items:1. Number of projects evaluated for
G.I and runoff reduction.2. Number of G.I. runoff reduction
projects completed.
Because each
project may
be different as
to which step
is more or
less labor
intensive,
agencies can
have the
flexibility to
implement
these steps in
the order they
feel is more
convenient.
MSGP Programs for Municipal Operations & Facilities
s
21
Part IV.G.1.i.
Agencies must choose the type of coverage:
o NYSDEC - MSGP
o NYCDEP - MS4
Current inventory includes 4 MSGP sites:
o 3 DOT
o 1 DSNY
o Assessments may identify additional sites subject to MSGP
If NYSDEC - MSGP: Continue reporting as done currently – no other
requirements
If NYCDEP - MS4: Also subject to PPGH reporting requirements
Agencies need to decide by August 1st, 2018 the type of coverage:
Refer to handout titled, MSGP or MS4 Permit Coverage Election
Pollution Prevention and Good Housekeeping
22
Next Steps:
Continue assessments of high priority and pilot sites
Revise protocols based on assessment findings
Continue developing training program. Will circulate training plan among sub-
team for review and comment
Industrial/Commercial
Industrial/Commercial
Stormwater Sources
23
2015* 2016 2017 2018 2019 2020
Aug 1, 2015
MS4 Permit
Effective Date
SWMP Plan Development
August 1, 2018
Submit SWMP plan to DECSection IV.H requires City to
develop inspection programs for
unpermitted and MSGP sites
Aug 1, 2020
MS4 Permit
Renewal
Legal Authority
Established
* - Calendar years
Interim Reports Due
August 1, 2016 and 2017
SWMP Implementation
Industrial/Commercial Timeline
Unpermitted industrial and commercial sites inspection program
plan due August 1, 2018
MSGP inspection program plan
due August 1, 2018
Facility inspections expected to
begin 45 days after SWMP approval
DEC
APPROVAL
6
Rulemaking
Expected procurement for third-party contractor
to implement inspection program
Inventory of Industrial/Commercial Facilities
25
MS4 Permit – Part H.1.a.ii
• DEP must prepare and maintain an inventory of all industrial and commercial
sites/sources within its jurisdiction (regardless of ownership), within three years of
2015, that could discharge POCs in stormwater to the MS4
Industrial Commercial Inventory:
• Industrial Sites/Sources
o 40 CFR § 122.26(b)(14)(i-ix and xi)
o Facilities subject to Section 313 of Title III of the Superfund Amendments and
Reauthorization Act (SARA)
o Hazardous waste treatment, disposal, storage and recovery facilities
o NYCDEP Industrial Pretreatment Program (IPP)
• Other industrial or commercial sites/sources tributary to an impaired water that
generates significant amount of POCs for which the water body is impaired
• Other industrial or commercial sites/sources that DEP determines may contribute a
significant pollutant load to the MS4
Unpermitted I/C Facility Inspection Screening
34
Schedule inspections based on findings of desktop/web-based evaluations performed by DEP to prepare inventory:
Locate site with DoITT Land Use database:
• Drains to MS4
• Land use category
Review aerial/street view images of site:
• Presence/significance of an “industrial activity”
• Evidence of “stormwater exposure”
ID businesses with incorrect SIC Codes/classifications
Schedule per “likelihood” of MSGP applicability
Incorporate work efficiency into schedule (proximity, travel time, seasonal, etc.)
27
Examples of No Further Analysis
27
Stained glass imaging company lists SIC code under Sector E (e.g., glass, clay, cement,
concrete, and gypsum products), though there is no potential for business to impact stormwater.
28
Example of Further Analysis
28
Facility which also has SIC code listed under Sector E with high potential
to impact stormwater.
29
Industrial Commercial Map
29
Facility Inventory
30
Staten Island Industrial Commercial Map
30
SWMP Plan Objectives for Industrial/Commercial Businesses
Control stormwater pollution from industrial and commercial businesses
potentially engaged in “industrial activities,” as defined under EPA and DEC
regulations.
For each candidate business:
o Identify and inventory
o Inspect and assess
o Refer findings to DEC
27
BMP BMP Description
Schedule (Yrs.)Responsible
Position1 2 3 4 510.1 Provide an industrial
and commercial pollution control program
Inventory and assess businesses conducting “industrial activities” and/or determined to be significant sources of stormwater pollution.
X X X X X
10.2 Provide for staff training
Train staff/third-parties responsible for assessing inventoried businesses.
X
Educate and Train
Next Steps
The SWMP will be submitted on August 1, 2018 to
NYSDEC
Once the SWMP is approved, inspections will begin
immediately
32
SPDES Industrial Stormwater Facility Inspection Program
33
Initial inventory: Business categories
subject to industrial stormwater
permitting
Web-based inventory screening
o Potentially Drains to MS4
o Current permitting status
Type of inspection
o None (Individual permit/NOT)
o Complaint-based
o Unpermitted facility
o MSGP permit
No Further
Action
Required by
DEP
Prioritize for
MSGP
Inspections
No
Individual Permit or
NOT Yes
Approved
NOI for MSGP
No
Yes
Schedule for
Unpermitted I/C
Inspections
A B
Determine DEC
SPDES Permit
Status
No Exposure
Certification
No
Yes
Inventory
Businesses
with MSGP SIC
Codes
Wrong SIC/
not draining to MS4Definitive
Potential
Complaint
Based
Inspections
Per Criteria in 40 CFR Part 122.26(b)(14)(i) through (ix) and (xi), using commercially-available databases
Industrial/Commercial Stormwater Sources
34
DEP anticipates a large number of facilities
that will need to be assessed for SPDES
DEP needs to determine how many
facilities will be part of the regular
inspection cycle, and commensurate
staffing needs
DEP has drafted an RFP to inspect
permitted and unpermitted facilities
(Anticipate advertisement June 2017)
Contractor will conduct analysis for staffing
needs once inspection program has been
fully implemented
Contractor will develop and implement
training program for DEP staff
Contractor will perform a study to
determine if any other sectors not currently
covered under MSGP need to be permitted
for next permit cycle
Initial facility inspections
by third-party contractor
35
NYSDEC MSGP Sectors
36
Example NYSDEC MSGP SIC Codes
Unpermitted I/C Facility Inspection Program
37
Notify business – one time only
Assemble background
On-site inspections
o Characterize SPDES applicability
o Characterize exposure
Post-inspection reporting
o Notify business of findings
o Notify DEC of findings
o Revise inventory
Pre-Inspection Activities• Notify business of inspection• Review available data about business• Assemble inspection equipment,
information
Quarterly Pre-Planning• Maintain I/C inventory and priorities• Quarterly identification of businesses
to inspect per priorities
On-Site Inspection Procedures• Introductions• Facility walkthrough• Wrap-up Meeting to review findings
Post-Inspection Activities• Complete inspection report • Notify facility of findings• Log findings in database• Update inventory, prioritization• Refer findings to DEC for SPDES
coverage determination
What is a SWPPP?
Stormwater Pollution Prevention Plan (SWPPP)
A site specific document which identifies potential sources of stormwater
pollution and control measures to eliminate impacts to stormwater runoff.
Elements of a SWPPP:
General site description, facility information
Site map, including outfalls, drainage areas, and direction of stormwater
flow
Potential sources of pollution
History of spills and releases
Best management practices to control impacts to runoff (structural & non-
structural)
Permit-Required Controls (inspection procedures, spill response plans, etc.)
Monitoring and Sampling Data
38
39
Example SWPPP Table of Contents
Examples of Potential MSGP Facilities
40
Primary Industrial Activity: Water Transportation
Potential sector this facility might be subject to: Sector Q: Water Transportation
Typical parameters that require monitoring under this sector: TSS, COD, Oil & Grease, Aluminum, Cadmium, Copper, Chromium, Iron, Lead, Zinc
Site Specific SWPPP should identify locations where the following activities or sources may be exposed to precipitation/surface runoff:
• Fueling
• Engine maintenance/repair
• Vessel maintenance/repair, pressure washing
• Painting/Sanding/Blasting
• Welding, Metal fabrication
• Loading/unloading areas
• Locations used for the treatment, storage or disposal of wastes
• Liquid storage tanks/areas (e.g., paint, solvents, resins)
• Material storage areas (e.g., blasting media, aluminum, steel, scrap iron)
Examples of Potential MSGP Facilities
41
Primary Industrial Activity: Storage and Recycling
Potential sector this facility might be subject to: Sector N: Scrap Recycling
Typical parameters that require monitoring under this sector: TSS, COD, Oil & Grease, Aluminum, Cadmium, Copper, Chromium, Iron, Lead, Zinc
Site Specific SWPPP should identify locations where the following activities or sources may be exposed to precipitation/surface runoff:
• Locations of haul and access roads
• Scrap and waste material storage areas
• Outdoor scrap and waste processing equipment
• Areas where materials are sorted, transferred, stockpiled
• Containment areas
Examples of Potential MSGP Facilities
42
Primary Industrial Activity: Timber
Potential sector this facility might be subject to: Sector A: Timber Products
Typical parameters that require monitoring under this sector: TSS, COD, Zinc, TN, Phosphorous, Arsenic, Chromium, Copper
Site Specific SWPPP should identify locations where the following activities or sources may be exposed to precipitation/surface runoff:
• Processing areas
• Treatment chemical storage areas
• Treated wood and residue storage areas
• Wet decking areas
• Dry decking areas
• Untreated wood and residue storage areas
• Treatment equipment storage areas
Examples of Potential MSGP Facilities
43
Primary Industrial Activity: Land Transportation
Potential sector this facility might be subject to: Sector P: Land Transportation and/or Warehousing
Typical parameters that require monitoring under this sector: Oil and Grease, COD, BTEX
Site Specific SWPPP should identify locations where the following activities or sources may be exposed to precipitation/surface runoff:
• Fueling stations
• Vehicle/equipment maintenance or cleaning areas
• Storage areas for vehicle/equipment with actual or potential fluid leaks
• Loading/unloading areas
• Areas where treatment, storage or disposal of wastes occur; liquid storage tanks
• Processing areas, storage areas, and all monitoring areas
Examples of Potential MSGP Facilities
44
Primary Industrial Activity: Waste Recycling
Potential sector this facility might be subject to: Sector N: Scrap Recycling
Typical parameters that require monitoring under this sector: TSS, COD, Oil & Grease, Aluminum, Cadmium, Copper, Chromium, Iron, Lead, Zinc
Site Specific SWPPP should identify locations where the following activities or sources may be exposed to precipitation/surface runoff:
• Locations of haul and access roads
• Scrap and waste material storage areas
• Outdoor scrap and waste processing equipment
• Areas where materials are sorted, transferred, stockpiled
• Containment areas
Examples of Potential MSGP Facilities
45
Primary Industrial Activity: Glass, Clay, Cement
Potential sector this facility might be subject to: Sector E: Glass, Clay, Cement, Concrete, and Gypsum Products
Typical parameters that require monitoring under this sector: Aluminum, TSS, pH, Iron
Site Specific SWPPP should identify locations where the following activities or sources may be exposed to precipitation/surface runoff:
• Bag house or other dust control device
• Recycle/sedimentation pond, clarifier or other device used for the treatment of process wastewater and the areas that drain to the treatment device
Examples of Potential MSGP Facilities
46
Primary Industrial Activity: Auto Salvage Yard
Potential sector this facility might be subject to: Sector M: Auto Salvage Yard
Typical parameters that require monitoring under this sector: TSS, Oil & Grease, Iron, Aluminum, Lead, BTEX
Site Specific SWPPP should identify locations where the following activities or sources may be exposed to precipitation/surface runoff:
• Vehicle storage areas
• Dismantling areas
• Parts storage areas (e.g., engine blocks, tires, hub caps, batteries, hoods, mufflers)
• Liquid storage lands and drums for fuel and other fluids
• Location of each discharge and monitoring point
Examples of Potential MSGP Facilities
47
Primary Industrial Activity: Scrap and Waste Materials
Potential sector this facility might be subject to: Sector N: Scrap Recycling
Typical parameters that require monitoring under this sector: TSS, COD, Oil & Grease, Aluminum, Cadmium, Copper, Chromium, Iron, Lead, Zinc
Site Specific SWPPP should identify locations where the following activities or sources may be exposed to precipitation/surface runoff:
• Locations of haul and access roads
• Scrap and waste material storage areas
• Outdoor scrap and waste processing equipment
• Areas where materials are sorted, transferred, stockpiled
• Containment areas
Examples of Industrial Activities and Potential Risk
48
Higher Risk for Stormwater Impact: Open Vehicle Storage (Outside with Fluids Not Drained) Lower Risk for Stormwater Impact: Covered Vehicle Storage
Vehicle/Equipment Storage
Examples of Industrial Activities and Potential Risk
49
Proper StorageHigher Risk for Stormwater Impact: Drums stored without spill containment
Louisville Metropolitan Sewer District
Lower Risk for Stormwater Impact: Drums stored indoors on spill pallets
Drum Storage/Management
Examples of Industrial Activities and Potential Risk
50
Temporary Covered StorageHamilton County Public Health Department: Higher Risk for Stormwater Impact: Uncovered
salt pileLower Risk for Stormwater Impact: Covered salt pile
Material Stockpiles
Example: Salt Pile
Improper vs. Proper Spill Response
51
Higher Risk for Stormwater Impact: Unattended spill
Lower Risk for Stormwater Impact: Quick spill
response
Spill Response
Examples of Industrial Activities and Potential Risk
52
Waste Liquid Disposal Restrictions
Hamilton County Public Health
DepartmentHigher Risk for Stormwater Impact: Leaking dumpster Lower Risk for Stormwater Impact: Well-managed dumpster
52
Waste Management and Disposal
SPDES Industrial Stormwater MSGP Facility Inspection SOP
(currently 21 MSGP sites)
53
Pre-inspection activities
o Maintain inventory/priorities/inspection schedule
o Assemble/assess background information
On-site inspection procedures
o Records review
o Walk-through inspection
o Characterize permit compliance
Post-inspection reporting
o Use DEC/BWT inspection criteria
o Notify business of findings
o Notify DEC of findings
o Revise inventory/priorities
Pre-Inspection Activities
• Review available data about business• Prioritization findings
• Latest facility MSGP data from DEC• 5-year violation record
• Assemble inspection equipment
Quarterly Pre-Planning
• Maintain I/C inventory, priorities
• Quarterly identification of businesses to inspect per priorities
• Request facility MSGP data from DEC
On-Site Inspection Procedures
• Introductions• On-Site Records Review
• SWPPP• Self-Inspection/Monitoring Reports
• Facility Walkthrough
• Confirm Facility Drainage to MS4• Wrap-up meeting to review findings
Post-Inspection Activities
• Complete Inspection Report• Notify facility of findings
• Log Inspection findings in database• Update I/C inventory, prioritization
• Notify DEC (as necessary)
MSGP Facility Inspection Program
Prioritize Facilities per Potential Water
Quality Impact
A
Potential WQ
Impact?
High/ Very High
Medium
Obtain MSGP Data from DEC
Low/ Very LowHigh Priority
for InspectionLow Priority
for Inspection
Medium Priority for Inspection
Obtain MSGP data from DEC
Prioritize per potential WQ Impacts:
o Use DEC and BWT criteria
• SWPPP adequacy
• POC type/quantity/exposure
• Observed housekeeping
• Proximity to impaired water
• Violation history
Revise priority for next scheduled inspection based on inspection findings.
54
Prioritize MSGP Facilities/Sites for Inspection
MSGP Facility Inspection Program
Initial Prioritization of MSGP Sites
NYSDEC provided prioritization for 18 MSGP sites within MS4
MSGP Inspection Frequency
Once a site receives a permit, it will be ranked and inspected at the following
frequency:
55
Initial DEC’s Prioritization Rating *Number of MSGP Sites
High 2
Medium 12
Low 4
Facility/Activity Priority Inspection Frequency
High Annual
Medium 3 Years
Low 5 Years
I/C Draft Facility-Specific Information Database Framework
56
57
I/C Draft Facility-Specific Information Database Framework
Industrial/Commercial Inspection Staff Training
Syllabus
o MSGP applicability requirements:
• SIC Codes / SARA Title III/HazMat Facilities
• Industrial activities defined
• No Exposure Certification Criteria
o Development/Maintenance/Prioritization of City I/C Inventory
o MSGP Compliance Requirements:
• Notice of Intent/Modification/Termination
• SWPPPs (e.g., site map, BMPs, SCMs, O&M)
• Self-monitoring (e.g., annual inspections, quarterly visual monitoring, annual dry weather monitoring, impaired waterbody monitoring)
• Monitoring reports
Training Protocol:
o Staff/contractors to train
o Training methods/materials
o Training frequency
58
Industrial Commercial Stormwater Sources
59
Next Steps:
Continue refining inventory of industrial/commercial facilities
Complete procedures for the inspection of permitted and unpermitted
MSGP sites
Third-party contractor procurement
o Anticipated Advertising Summer 2017
o Anticipated Contract Registration Summer/Fall 2018
For more information, visit our website: nyc.gov/dep/ms4
If you have questions or feedback, please contact the MS4 Team at: