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ILLICIT
AND ELIMNATION
ST. LOUIS COUNTY
PHASE II
STORMWATER
MANAGEMENT PLAN
Fall 2017
THIRD
TERM
PERMIT
2017-2021
PUBLIC EDUCATION
PUBLIC INVOLVEMENT
ILLICIT DISCHARGE
DETECTION
CONSTRUCTION SITE
CONTROLS
POST-CONSTRUCTION
MANAGEMENT
MUNICIPAL POLLUTION
PREVENTION
Contents
Stormwater Management Plan Development ....................................................................................... 1
Stormwater Management Plan Coordination ........................................................................................ 2
Applicability .......................................................................................................................... 2 A.
Permitting Strategy .............................................................................................................. 2 B.
Plan Area Watersheds ......................................................................................................... 4 C.
Responsibility ....................................................................................................................... 5 D.
SWMP Responsibility........................................................................................................... 5 E.
Watershed Water Quality ...................................................................................................................... 6
Minimum Control Measure Number 1, Public Education and Outreach of Stormwater Impacts
(MCM1).................................................................................................................................................. 8
Permit Requirements ........................................................................................................... 8 A.
Pollutant Sources ................................................................................................................. 8 B.
Minimum Control Measure Number 2, Public Involvement and Participation (MCM2) ....................... 15
Permit Requirements ......................................................................................................... 15 A.
BMP Development ............................................................................................................. 15 B.
Minimum Control Measure Number 3, Illicit Discharge Detection and Elimination (MCM3) ............... 18
Permit Requirements ......................................................................................................... 18 A.
Applicability ........................................................................................................................ 19 B.
Stormwater System ........................................................................................................... 20 C.
Enforcement ...................................................................................................................... 20 D.
BMP Development ............................................................................................................. 20 E.
Minimum Control Measure Number 4, Construction Site Stormwater Runoff Control (MCM4) .......... 23
Permit Requirements ......................................................................................................... 23 A.
Applicability ........................................................................................................................ 24 B.
Municipality Implementation Options ................................................................................. 24 C.
BMP Development ............................................................................................................. 25 D.
Minimum Control Measure Number 5, Post-Construction Stormwater Management in New
Development and Redevelopment (MCM5) ........................................................................................ 28
Permit Requirements ......................................................................................................... 28 A.
BMP Development ............................................................................................................. 29 B.
Minimum Control Measure Number 6, Pollution Prevention Good Housekeeping for Municipal
Operations (MCM6) ............................................................................................................................. 34
Permit Requirements ......................................................................................................... 34 A.
BMP Development ............................................................................................................. 35 B.
Appendix A, St. Louis County SWMP Co-permittees ......................................................................... 40
Appendix B, St. Louis County SWMP Co-permittees Contact Information ......................................... 41
Appendix C, MCM4 Co-permittee Ordinance and Regulatory Mechanism ........................................ 43
1
Stormwater Management Plan Development
On December 14, 2016, the Metropolitan St. Louis Sewer, St. Louis County, and 59
St. Louis County Municipalities were issued a General State Operating Permit MO-
R040005 for the MSD Municipal Separate Storm Sewer Syste m. This permit is
required by the Federal Clean Water Pollution Control Act and was issued by the
Missouri Department of Natural Resources (MDNR). The permit’s facility name is
“MSD Small MS4 Co-Permit.”
This permit requires municipal separate storm sewer systems (MS4s) to implement
best management practices (BMPs) via an iterative process to reduce the discharge
of pollutants into MS4 to the maximum extent practicable (MEP) for the goal of
attainment with Missouri’s Water Quality Standards. To meet this requirement,
MS4s must develop a stormwater management plan (SWMP) that implements the
permit’s requirements for the following six minimum control measures:
1. Public Education and Outreach
2. Public Participation and Involvement
3. Illicit Discharge and Elimination
4. Construction Site Runoff Control
5. Post-Construction Runoff Control
6. Pollution Prevention and Good Housekeeping
The 2016 Permit allows permittees one year of the effective date to revise their
SWMP. To comply with the revised permit conditions, MSD and its co-permittees
are submitting this SWMP to the MDNR. The 2012 St. Louis County SWMP that
MSD submitted with its permit application is superseded by this document.
2
Stormwater Management Plan Coordination
Applicability A.
The 1999 Phase II Stormwater Regulations were promulgated to provide
appropriate stormwater management for political subdivisions in urbanized areas
which were exempted under the 1990 (Phase I) regulations. Appendix 6,
Governmental Entities Located Fully or Partially W ithin an Urbanized Area, of the
preamble to the USEPA’s December 8, 1999 rule listed most of the political
subdivisions in St. Louis County as entities requiring a Phase II NPDES Permit.
University City was added additionally as a co -permittee, based on the population
served by separate storm sewers and other relevant factors.
Permitting Strategy B.
Missouri’s Phase II Stormwater Regulations for small MS4s are contained in 10
CSR 20-6.200. The statute allows regulated Small MS4s to seek coverage under a
general permit or under a site-specific permit. MSD and the other regulated political
subdivisions in St. Louis County have received the general permit. While MSD and
each political subdivision that is regulated by the Phase II regulations and located
within MSD’s boundaries has received its own operating permit, all have agreed to
coordinate permit compliance activities as co-permittees. The co-permittee strategy
encourages cooperation among municipal governments, a watershed approach to
reducing pollution, and the sharing of legal, financial, and administrative
responsibilities.
Figure 2 on page 3 shows the St. Louis County municipalities and MSD’s
boundaries. MSD’s boundaries cover approximately 525 square miles, and will
henceforth be referred to as the “Plan Area.” Although there are ninety
municipalities located within MSD’s county service area, only fifty-nine and the St.
Louis County received the MS4 permit. Two municipalities in St. Louis County,
Pacific and Eureka, are located outside of MSD’s service area and are not part of
the co-permittee group. Appendix A lists the 61 permitted entities in the group.
Figure 1, Co-permittees Defined
Co-permittee How Many
Municipalities 59
St. Louis County 1
MSD 1
Total 61
3
Figure 2, Incorporated Places in St. Louis County
4
Plan Area Watersheds C.
St. Louis County stormwater drains into three major watersheds: the Mississippi
River, the Meramec River, and the Missouri River. All stormwater runoff from the
County ultimately enters the Mississippi River. The Mississippi River forms the
eastern boundary of the southernmost and northernmost portions of the Plan Area
with the remainder entering the western boundary of the City of St. Louis and its
combined sewer system. The Meramec River generally forms the southern
boundary of the Plan Area except for a portion in the west of the County where the
border includes land south of the Meramec River that is drained by its tributaries.
The Missouri River forms the northern boundary of the Plan Area. Many small
tributaries feed into each of these three major rivers. Figure 3 shows the location of
stream tributaries within the major watersheds of the Plan Area.
Figure 3, St. Louis County Watersheds
5
Responsibility D.
MSD is recognized as the coordinating authority of the SWMP under the St. Louis
Metropolitan Small MS4 Stormwater Permit, MO-R040005. Each co-permittee has
been assigned responsibility for specific BMPs to comply with the six MCMs related
to their governmental purpose. For example,
Public Education and Outreach (MCM 1) on stormwater impacts and Public
Involvement and Participation (MCM 2) can best be coordinated by the MSD,
with specific tasks performed with municipal support.
Since MSD already has responsibility to operate and maintain the separate
storm sewer systems in the county, it carries the bulk of the responsibility to
comply with the requirements of MCM 3, Illicit Discharge Detection and
Elimination.
St. Louis County and municipalities, who operate land disturbance programs,
are largely responsible for implementing BMPs to control pollution from land
disturbance activities and compliance with MCM 4 requirements.
For MCM 5, because MSD is the recognized continuing authority for public
sewer extensions within its jurisdictional boundaries and has overall plan
review responsibilities for stormwater management, it is responsible for post-
construction structural BMPs. St. Louis County and municipalities, who
maintain land use and zoning authority, are responsible for implementing
post-construction nonstructural BMPs that need to be implemented in
conjunction with MSD’s efforts.
All co-permittees are responsible for ensuring their own municipal operations
comply with requirements under MCM 6, Pollution Prevention/Good
Housekeeping for Municipal Operations.
SWMP Responsibility E.
The person primarily responsible for the SWMP is the MSD Program Manager for
Environmental Compliance Programs. Contact information is as follows.
Metropolitan St. Louis Sewer MSD
Engineering Department – Environmental Compliance
Program Manager of Environmental Compliance Programs
c/o Jay Hoskins, P.E.
10 E. Grand Ave.
St. Louis, MO 63147
Phone: 314-436-8757
jshosk@stlmsd.com
6
Each municipality and St. Louis County also has a person primarily responsible for
the SWMP. That contact information is provided in Appendix B.
Watershed Water Quality
Section 303(d) of the Federal Clean Water Act requires states to identify water
bodies that do not meet water quality standards (impaired waters) after applying the
existing regulations. Table 1 shows Plan Area water bodies with segments on the
2016 303(d) listing.
Table 1: 2016 303(d) listing
Waterbody Bacteria
(E Coli) Chloride Other
Antire Creek X pH
Bee Tree Lake Mercury
Black Creek X X
Bonhomme Creek X pH
Coldwater Creek X X
Creve Coeur Creek X X Dissolved Oxygen
Deer Creek X X
Fee Fee Creek X X
Fenton Creek X X
Fishpot Creek X X
Grand Glaize Creek X X Mercury
Gravois Creek X X
Gravois Creek X X
Keifer Creek X X
Maline Creek X X
Mattese Creek X X
Meramec River X Lead
Mississippi River X
River des Peres X X Dissolved Oxygen
Spring Branch X
Two mile Creek X
Watkins Creek X X
Wildhorse Creek X
Williams Creek X
7
MDNR has developed and EPA has approved Total Maximum Daily Loads (TMDLs)
to address bacteria (E.Coli) in four watersheds (Table 2). At the time this SWMP
was written, MDNR has drafted and put on public notice three additional TMDLs
(which have not been approved by EPA).
Table 2: Bacteria (E.Coli) Total Maximum Daily Loads
Water Body EPA Approval
Date
Public Notice
Date
Coldwater Creek 7/13/2016
Creve Coeur Creek 7/13/2016
Deer & Black Creek 3/17/2017
Fishpot Creek 7/13/2016
Grand Glaize Creek 3/17/2017
Mailne Creek 3/17/2017
Watkins Creek 7/13/2016
8
Minimum Control Measure Number 1, Public Education
and Outreach of Stormwater Impacts (MCM1)
Permit Requirements A.
Section 4.2.1.1 of the 2016 Permit requires the permittee to implement a public
education program to distribute educational material to the community or conduct
equivalent outreach activities about the impact of stormwater discharges on
waterbodies and steps the public can take to reduce pollutants in stormwater runoff.
As part of the SWMP, the Public Education and Outreach Program shall include the
following information at a minimum:
4.2.1.1.1 A plan on how target audiences are identified for the public
education program who are likely to have significant stormwater
impacts (including commercial and industrial entities):
4.2.1.1.2 A plan to inform individuals and households about steps they
can take to reduce stormwater pollution;
4.2.1.1.3 A plan to inform individuals and groups on how to become
involved in the SWMP (with activities such as local stream and
lake restoration activities);
4.2.1.1.4 The outreach strategy, including the mechanisms (e.g., printed
brochures, newspapers, media, workshops, etc...) to reach
target audiences; and
4.2.1.1.5 The pollutant(s) sources that the permittee’s education program
is designed to address.
Table 3 provides the specific BMPs that will be used to comply with 4.2.1.1.1 -
4.2.1.1.4. Pollutant sources (4.2.1.1.5) are addressed below.
Pollutant Sources B.
1. Pet Waste
Pet waste left on the ground pollutes stormwater when it rains or snows. Pollutants
associated with pet waste include bacteria, ammonia, oxygen demand, and
nutrients (nitrogen).
2. Yard Management
Yard waste such as leaves, grass clippings, weeds, brush, and small twigs that are
disposed of along a creek or in a storm drain can impact water quality.
9
Yard waste decaying in creeks decomposes and creates low dissolved oxygen,
releases nutrients (nitrogen and phosphorus), and elevated suspended solids.
Stormwater containing fertilizers and pesticides from incorrect application and/or
improper storage can also cause environmental problems (e.g., toxicity to aquatic
life). Good management of fertilizers application is consistent with the goals of
Missouri’s Nutrient Reduction Strategy.
3. Individual Sewage Disposal Systems
Commonly known as septic systems, these systems are designed to hold, treat, and
dispose of household wastewater. Systems that are not properly installed and
regularly serviced allow bacteria, viruses, nutrients, and ammonia to enter
groundwater and streams.
4. Winter Deicing and Storage Activities
Significant levels of salt (e.g., sodium chloride and calcium chloride) in waters can
occur when salt is applied on roads, parking lots and driveways during deicing
activities. Chloride is highly soluble and very mobile in water. High levels of chloride
are toxic to aquatic life.
5. Household Hazardous Waste
Many products around the home are hazardous because they contain chemicals
that are toxic, corrosive, flammable, or reactive. Though usually safe if used
according to the directions, when these products are no longer usable or wanted,
they become household hazardous waste. If dumped onto the ground or poured
into the storm sewer, household hazardous waste can contaminate groundwater
and streams.
6. Land Disturbance
Land disturbance is dredging, clearing, grading, excavating, transporting or filling
from construction activities including but not limited to subdivisions, shopping
centers, and road projects. Sediment is the primary pollutant from land disturbance
activities.
7. Fats, Oils, and Grease
Fats, oil, and grease (FOG) are found in common foods and food ingredients such
as meat, fish, butter, cooking oil, gravy, sauces, mayonnaise, and food scraps.
There are also “hidden oils,” such as salad dressing, syrup, batter and cheese.
10
When FOG is poured down the drain, it can form blockages that restrict wastewater
flow, eventually causing a blockage. Blockages can cause sewer overflows that
pollute streams.
8. Swimming Pools
Discharges (drains, overflows, and filter backwash water) of chlorinated pool water
and saltwater to a storm sewer or stream contain pollutants such as elevated
suspended solids, chlorides, and abnormal pH. These pollutants impact many
species of aquatic life.
9. Industrial Activities
Stormwater runoff from industrial facilities can easily become polluted by metals,
chemicals, sediment, fertilizers, and trash. When exposed to the atmosphere, many
industrial activities contribute to stormwater pollution (such as metal grinding and
polishing, vehicle/equipment maintenance, improper disposal of hazardous was te,
and more). Wastes, residues, and byproducts from these activities can enter storm
drains and streams harming aquatic life and impacting water quality.
Table 3
11
Permit Year 1, 2017 Permit Year 2, 2018 Permit Year 3, 2019 Permit Year 4, 2020 Permit Year 5, 2021
1
Query MSD Environmental
Compliance Pretreatment
Information Management System
for active industrial entities.
Maintain list of active
industrial entities who
could have a significant
stormwater impact.
MSD
Provide co-permittees
with a list of industrial
stormwater sources.
Update list and distribute
to co-permittees by end of
plan year.
Update list and distribute
to co-permittees by end of
plan year.
Update list and distribute
to co-permittees by end of
plan year.
Update list and distribute
to co-permittees by end of
plan year.
Update list and distribute
to co-permittees by end of
plan year.
List updated, distributed,
and filed.
2
Query MSD Environmental
Compliance Pretreatment
Information Management System
for approved commercial haul-
waste vendors.
Maintain list of active
commercial individual
waste haulers who could
have a significant
stormwater impact.
MSD
Provide co-permittees
with a list of waste
haulers.
Update list and distribute
to co-permittees by end of
plan year.
Update list and distribute
to co-permittees by end of
plan year.
Update list and distribute
to co-permittees by end of
plan year.
Update list and distribute
to co-permittees by end of
plan year.
Update list and distribute
to co-permittees by end of
plan year.
List updated, distributed,
and filed.
3
Query MSD Asset Management
System for list of active food
service and restaurant
establishment facilities.
Maintain list of active food
service and restaurant
establishments who could
have a significant
stormwater impact.
MSD
Provide co-permittees
with a list of food service
and restaurant
establishments.
Update list and distribute
to co-permittees by end of
plan year.
Update list and distribute
to co-permittees by end of
plan year.
Update list and distribute
to co-permittees by end of
plan year.
Update list and distribute
to co-permittees by end of
plan year.
Update list and distribute
to co-permittees by end of
plan year.
List updated, distributed,
and filed.
4
Survey trade associations (such as
Home Builders Association,
Associated General Contractors,
American Society of Civil
Engineers, and Property Managers)
involved with land disturbance,
land development, and property
management activities.
Maintain list of trade
associations with members
that could have a
significant stormwater
impact.
MSD
Provide co-permittees
with list of trade
associations.
Develop list and
distribute to co-
permittees by end of plan
year.
Update list and distribute
to co-permittees by end of
plan year.
Update list and distribute
to co-permittees by end of
plan year.
Update list and distribute
to co-permittees by end of
plan year.
Update list and distribute
to co-permittees by end of
plan year.
List updated, distributed,
and filed.
5
Query municipal building permit
databases for active major land
disturbance contractors.
Maintain list of contractors
that could have a
significant stormwater
impact.
All
Provide co-permittees
with a list of contractors
who are currently
engaged in major land
disturbance activities.
Update list and distribute
to co-permittees by end of
plan year.
Update list and distribute
to co-permittees by end of
plan year.
Update list and distribute
to co-permittees by end of
plan year.
Update list and distribute
to co-permittees by end of
plan year.
Update list and distribute
to co-permittees by end of
plan year.
List updated, distributed,
and filed.
6 Collect stormwater education
survey.
Develop a baseline of
water quality and nonpoint
source pollution awareness
and behaviors, and identify
target audiences for future
SWMP revisions.
MSD
Develop a baseline of
public water quality
awareness in service area.
Develop survey questions,
complete third party
survey, record and analyze
findings.
None None None
Complete third party
survey, record and analyze
findings.
Awareness baseline
developed.
7
Develop database of all K-12 public
and private school districts in plan
area.
Foster nonpoint source
pollution and water quality
awareness in community.
MSD
Maintain a
comprehensive database
of schools and contacts,
which could be
information outlets.
Develop database of
schools and contacts by
end of plan year
Maintain database of
schools and designated
contacts.
Maintain database of
schools and designated
contacts.
Maintain database of
schools and designated
contacts.
Maintain database of
schools and designated
contacts.
Database developed.
Track schools providing
stormwater education.
4.2.1.1.2 8
Develop and distribute stormwater
messages for MSD bills and
websites. Topics would include
littering, pet waste, yard
management (including nutrient
application), individual sewage
disposal systems, winter deicing,
swimming pools, and household
hazardous waste.
Reach plan area customers
with concise messages on
MSD bills and websites.
MSD
Greater awareness of best
practices to protect water
quality.
None Develop message library
by end of the plan year.
Distribute messages on
MSD bills and websites.
Record number of MSD
bills mailed and website
pages views/hits.
Distribute messages on
MSD bills and websites.
Record number of MSD
bills mailed and website
pages views/hits.
Distribute messages on
MSD bills and websites.
Record number of MSD
bills mailed and website
pages views/hits.
Message library
developed and
representative copies of
bills filed. Track number
of bills sent with
messages. Track number
of website page hits and
views.
Measurable Goals, Milestones, and Dates BMP Evaluation
Process/Criteria
4.2.1.1.1
Permit
Requirement BMP Description BMP Purpose Responsible
Person
Expected Result of
BMP
Table 3
12
Permit Year 1, 2017 Permit Year 2, 2018 Permit Year 3, 2019 Permit Year 4, 2020 Permit Year 5, 2021
9 Maintain and provide library of
stormwater education materials.
Provide brochures, flyers,
and other media that can
be used at public events
and upon request.
MSD Provide education to
various audiences.
Maintain adequate
supply of existing
educational materials that
address general
awareness and pollutant
sources in the SWMP for
target audiences,
individuals, and
households.
Maintain adequate
supply of existing
educational materials that
address general
awareness and pollutant
sources in the SWMP for
target audiences,
individuals, and
households.
Maintain adequate
supply of existing
educational materials that
address general
awareness and pollutant
sources in the SWMP for
target audiences,
individuals, and
households.
Maintain adequate
supply of existing
educational materials that
address general
awareness and pollutant
sources in the SWMP for
target audiences,
individuals, and
households.
Maintain adequate
supply of existing
educational materials that
address general
awareness and pollutant
sources in the SWMP for
target audiences,
individuals, and
households.
Materials developed and
available for distribution.
Increase awareness and
positive behavior change.
Provide pet waste
brochures to St. Louis
County Animal Control
quarterly, starting 2017
fourth calendar quarter.
St. Louis Animal Control
distributes pet waste
brochures during
adoptions.
Provide pet waste
brochures to St. Louis
County Animal Control
quarterly. St. Louis Animal
Control distributes pet
waste brochures during
adoptions.
Provide pet waste
brochures to St. Louis
County Animal Control
quarterly. St. Louis Animal
Control distributes pet
waste brochures during
adoptions.
Provide pet waste
brochures to St. Louis
County Animal Control
quarterly. St. Louis Animal
Control distributes pet
waste brochures during
adoptions.
Provide pet waste
brochures to St. Louis
County Animal Control
quarterly. St. Louis Animal
Control distributes pet
waste brochures during
adoptions.
Track number of
brochures provided to St.
Louis County Animal
Control.
Increase awareness and
positive behavior change.
Provide pet waste
brochures to St. Louis
humane society quarterly.
Humane Society
distributes pet waste
brochures during
adoptions.
Provide pet waste
brochures to St. Louis
humane society quarterly.
Humane Society
distributes pet waste
brochures during
adoptions.
Provide pet waste
brochures to St. Louis
humane society quarterly.
Humane Society
distributes pet waste
brochures during
adoptions.
Provide pet waste
brochures to St. Louis
humane society quarterly.
Humane Society
distributes pet waste
brochures during
adoptions.
Providepet waste
brochures to St. Louis
humane society quarterly.
Humane Society
distributes pet waste
brochures during
adoptions.
Track number of
brochures provided to St.
Louis Humane Society.
Increase awareness and
positive behavior change.
Partner with
environmental
organization (such as the
Missouri Botanical Garden
Earthways Center) to offer
one education event on
stormwater management.
Record class attendance.
Partner with
environmental
organization (such as the
Missouri Botanical Garden
Earthways Center) to offer
at least two education
events on stormwater
management. Record
class attendance.
Partner with
environmental
organization (such as the
Missouri Botanical Garden
Earthways Center) to offer
at least two education
events on stormwater
management. Record
class attendance.
Partner with
environmental
organization (such as the
Missouri Botanical Garden
Earthways Center) to offer
at least two education
events on stormwater
management. Record
class attendance.
Partner with
environmental
organization (such as the
Missouri Botanical Garden
Earthways Center) to offer
at least two education
events on stormwater
management. Record
class attendance.
Classes completed and
attendance tracked.
MSD Increase awareness and
positive behavior change.
Partner with
environmental
organization (such as St.
Louis Audubon Society
Bring Conservation Home)
to: 1) support distribution
of education material and
2) provide stormwater
management education to
landowners. Record
education material
distributed.
Partner with
environmental
organization (such as St.
Louis Audubon Society
Bring Conservation Home)
to: 1) support distribution
of education material and
2) provide stormwater
management education to
landowners. Record
education material
distributed.
Partner with
environmental
organization (such as St.
Louis Audubon Society
Bring Conservation Home)
to: 1) support distribution
of education material and
2) provide stormwater
management education to
landowners. Record
education material
distributed.
Partner with
environmental
organization (such as St.
Louis Audubon Society
Bring Conservation Home)
to: 1) support distribution
of education material and
2) provide stormwater
management education to
landowners. Record
education material
distributed.
Partner with
environmental
organization (such as St.
Louis Audubon Society
Bring Conservation Home)
to: 1) support distribution
of education material and
2) provide stormwater
management education to
landowners. Record
education material
distributed.
Education completed.
Track type and number
of material distributed.
Measurable Goals, Milestones, and Dates BMP Evaluation
Process/Criteria
4.2.1.1.2
10
Provide presentations and
educational materials to families
and homeowners.
Foster nonpoint source
pollution and water quality
awareness in community.
MSD
Permit
Requirement BMP Description BMP Purpose Responsible
Person
Expected Result of
BMP
Table 3
13
Permit Year 1, 2017 Permit Year 2, 2018 Permit Year 3, 2019 Permit Year 4, 2020 Permit Year 5, 2021
4.2.1.1.2 11 Post pet waste signs in parks.
Foster nonpoint source
pollution and water quality
awareness in community.
St. Louis County
and
Municipalities
Increase awareness and
positive behavior change.
Post pet waste signs in
each city and St. Louis
County owned park.
Record and report on
number of pet waste signs
posted.
Post pet waste signs in
each city and St. Louis
County owned park.
Record and report on
number of pet waste signs
posted.
Post pet waste signs in
each city and St. Louis
County owned park.
Record and report on
number of pet waste signs
posted.
Post pet waste signs in
each city and St. Louis
County owned park.
Record and report on
number of pet waste signs
posted.
Post pet waste signs in
each city and St. Louis
County owned park.
Record and report on
number of pet waste signs
posted.
Track number of parks
and posted pet waste
signs.
4.2.1.1.3 12
Maintain database of community
partners with water pollution
education interests.
Know partners that can
work with MSD to Foster
nonpoint source pollution
and water quality
awareness in community.
See MCM 2 for utilization.
MSD
Provide participation
opportunities, in MCM2,
to individuals and groups.
Develop database of
individuals, partners, and
activities. Distribute
activities list to individuals
and groups.
Update database of
individuals, partners, and
activities. Distribute
activities list to individuals
and groups.
Update database of
individuals, partners, and
activities. Distribute
activities list to individuals
and groups.
Update database of
individuals, partners, and
activities. Distribute
activities list to individuals
and groups.
Update database of
individuals, partners, and
activities. Distribute
activities list to individuals
and groups.
List updated, distributed,
and filed. See also
material distribution,
presentation, and MCM2
BMPs.
13
Provide educational materials to
industrial entities, waste haulers,
and food service and restaurant
establishments.
Foster nonpoint source
pollution and water
quality awareness in
community
MSD Increase awareness and
positive behavior change.
Provide educational
materials to industrial
entities and waste
haulers. Distribute fats,
oils, and grease brochure
at MSD food service and
restaurant establishment
inspections. Distribute IDD
brochure at MSD,
pretreatment inspections.
Record number of
material distributed.
Provide educational
materials to industrial
entities and waste
haulers. Distribute fats,
oils, and grease brochure
at MSD food service and
restaurant establishment
inspections. Distribute IDD
brochure at MSD,
pretreatment inspections.
Record number of
material distributed.
Provide educational
materials to industrial
entities and waste
haulers. Distribute fats,
oils, and grease brochure
at MSD food service and
restaurant establishment
inspections. Distribute IDD
brochure at MSD,
pretreatment inspections.
Record number of
material distributed.
Provide educational
materials to industrial
entities and waste
haulers. Distribute fats,
oils, and grease brochure
at MSD food service and
restaurant establishment
inspections. Distribute IDD
brochure at MSD,
pretreatment inspections.
Record number of
material distributed.
Provide educational
materials to industrial
entities and waste
haulers. Distribute fats,
oils, and grease brochure
at MSD food service and
restaurant establishment
inspections. Distribute IDD
brochure at MSD,
pretreatment inspections.
Record number of
material distributed.
Material distribution
completed. Track
number of material
distributed.
MSD
Increase awareness and
positive behavior change
within trade associations
that is topical to their
industry.
Permittee group will offer
one meeting with trade
associations. Record
materials distributed
Permittee group will offer
one meeting with trade
associations. Record
materials distributed
Permittee group will offer
one meeting with trade
associations. Record
materials distributed
Permittee group will offer
one meeting with trade
associations. Record
materials distributed
Permittee group will offer
one meeting with trade
associations. Record
materials distributed
Meetings completed.
Track number of
meetings and material
distributed. Records
saved in MSD files.
Co-permittees Increase awareness and
positive behavior change
MSD will distribute
education material at a
minimum of 6 requested
presentations or
information booths.
Record event material
distributed and
attendance.
MSD will distribute
education material at a
minimum 6 requested
presentations or
information booths.
Record event material
distributed and
attendance. All
permittees that distribute
material at events will
report material
distributed and estimated
attendance.
MSD will distribute
education material at a
minimum 6 requested
presentations or
information booths.
Record event material
distributed and
attendance. All
permittees that distribute
material at events will
report material
distributed and estimated
attendance.
MSD will distribute
education material at a
minimum 6 requested
presentations or
information booths.
Record event material
distributed and
attendance. All
permittees that distribute
material at events will
report material
distributed and estimated
attendance.
MSD will distribute
education material at a
minimum 6 requested
presentations or
information booths.
Record event material
distributed and
attendance. All
permittees that distribute
material at events will
report material
distributed and estimated
attendance.
Events completed. Track
number of events and
material distributed.
Records saved in
copermittees files.
14
Provide presentations and
educational materials to trade
associations, schools, and
watershed groups
Foster nonpoint source
pollution and water
quality awareness in
community
Measurable Goals, Milestones, and Dates BMP Evaluation
Process/Criteria
4.2.1.1.4
Permit
Requirement BMP Description BMP Purpose Responsible
Person
Expected Result of
BMP
Table 3
14
Permit Year 1, 2017 Permit Year 2, 2018 Permit Year 3, 2019 Permit Year 4, 2020 Permit Year 5, 2021
Increase awareness and
positive behavior change.
Develop and distribute
stormwater information at
a St. Louis area sports
venue.
Develop and distribute
stormwater information at
a St. Louis area sports
venue.
Develop and distribute
stormwater information at
a St. Louis area sports
venue.
Develop and distribute
stormwater information at
a St. Louis area sports
venue.
Develop and distribute
stormwater information at
a St. Louis area sports
venue.
Track type and number
of material distributed.
Increase awareness and
positive behavior change.
Host Information booth
and record what and how
many material distributed
at St. Louis Earth Day in
Forest Park.
Host Information booth
and record what and how
many material distributed
at St. Louis Earth Day in
Forest Park.
Host Information booth
and record what and how
many material distributed
at St. Louis Earth Day in
Forest Park.
Host Information booth
and record what and how
many material distributed
at St. Louis Earth Day in
Forest Park.
Host Information booth
and record what and how
many material distributed
at St. Louis Earth Day in
Forest Park.
Track type and number
of material distributed.
Increase awareness and
positive behavior change. None
Host Information booth
and record what and how
many material distributed
at St. Louis Home and
Garden Show.
Host Information booth
and record what and how
many material distributed
at St. Louis Home and
Garden Show.
Host Information booth
and record what and how
many material distributed
at St. Louis Home and
Garden Show.
Host Information booth
and record what and how
many material distributed
at St. Louis Home and
Garden Show.
Track type and number
of material distributed.
Increase awareness and
positive behavior change.
Develop and distribute
stormwater information at
a St. Louis area
amusement or recreation
venue.
Develop and distribute
stormwater information at
a St. Louis area
amusement or recreation
venue.
Develop and distribute
stormwater information at
a St. Louis area
amusement or recreation
venue.
Develop and distribute
stormwater information at
a St. Louis area
amusement or recreation
venue.
Develop and distribute
stormwater information at
a St. Louis area
amusement or recreation
venue.
Track type and number
of material distributed.
16 Develop and advertise videos to be
utilized in social media platforms.
Develop concise messages
that can be used on MSD
and partner social media
platforms.
MSD Provide education to
broad audiences
Develop two videos that
can be utilized in the
desired format
Provide or purchase
minimum 10,000 spots per
year. Record number of
plays.
Provide or purchase
minimum 10,000 spots per
year. Record number of
plays.
Provide or purchase
minimum 10,000 spots per
year. Record number of
plays.
Provide or purchase
minimum 10,000 spots per
year. Record number of
plays.
Videos developed and
track number of online
plays.
MSD
4.2.1.1.4
15
Partner with community
organizations to provide
stormwater information to a broad
audience.
Foster nonpoint source
pollution and water quality
awareness in community.
Measurable Goals, Milestones, and Dates BMP Evaluation
Process/Criteria
Permit
Requirement BMP Description BMP Purpose Responsible
Person
Expected Result of
BMP
15
Minimum Control Measure Number 2, Public Involvement
and Participation (MCM2)
Permit Requirements A.
Section 4.2.2.1 of the 2016 Permit requires the permittee to implement a public
involvement/participation program that provides opportunities for public involvement
in the development and oversight of the permittee’s SWMP, and provides
opportunities for public involvement of the permittee’s renewal application. The
public involvement/participation program shall, at a minimum, include the following:
4.2.2.1.1 A public notice period to allow the public to review the SWMP
and renewal application prior to the submission of the SWMP
and renewal application to the Department. It is recommended
that the public review period is at least 10 (ten) business days;
4.2.2.1.2 A notice of public meeting, if needed, regarding the SWMP and
renewal application. It is recommended that the notice should
be at least 72 hours prior to the meeting;
4.2.2.1.3 A plan to target all potentially affected stakeholder groups,
including but not limited to, commercial and industrial
businesses, trade associations, environmental groups,
homeowner associations and educational organizations;
4.2.2.1.4 If the permittee utilizes a stormwater management
panel/committee, then the permittee shall provide opportunities
for citizen representatives on the panel/committee;
4.2.2.1.5 If appropriate, volunteer monitoring or stream/lake clean-up
activities; and
4.2.2.1.6 Provide opportunities and work with citizen volunteers willing to
educate others about the permittee’s SWMP.
BMP Development B.
Specific implementation of the public involvement and participation best
management practices are presented in Table 4.
Table 4
16
Permit Year 1, 2017 Permit Year 2, 2018 Permit Year 3, 2019 Permit Year 4, 2020 Permit Year 5, 2021
4.2.2.1.1 17
Post SWMP on MSD's website for
30 days. Announce the SWMP is
available to review, using e-mail
and social media.
Provide opportunity for
input on the SWMP.MSD
Comply with permit
requirement for public
notice.
Revised SWMP posted on
MSD stormwater section
and social media
platforms for 30 days.
Revised SWMP e-mailed
to stakeholders
None None None
4th term SWMP posted
on MSD stormwater
section and social media
platforms for at least 10
days. Revised SWMP e-
mailed to stakeholders
SWMP e-mailed and
posted on MSD
website/social media
platforms. Record all
comments to the SWMP.
4.2.2.1.2 18
Hold a meeting at MSD's office.
Provide advance notice on MSD's
website and by e-mail.
Provide opportunity for
input on the SWMP.MSD
Comply with permit
requirement for public
meeting.
Revised SWMP public
meeting notice posted on
MSD stormwater section
at least 72 hours before
meeting.
None None None
4th term SWMP public
meeting notice posted on
MSD stormwater section
at least 72 hours before
meeting.
SWMP meeting
announcement posted
on MSD website. File
meeting minutes.
4.2.2.1.3 19
Maintain a list of outlets to
provide information. Send letter or
e-mail inviting comment in
advance of finalizing SWMP.
Maintain contact with
stakeholder organizations
and their leadership.
MSD
Provide education and
participation
opportunities to target
audiences.
Send a letter or e-mail to
contacts on list, offering
opportunity to comment
on the revised SWMP.
Review and update list
annually.
Review and update list
annually.
Review and update list
annually.
Send a letter or e-mail to
contacts on list, offering
opportunity to comment
on the 4th term SWMP.
List developed and
communication sent.
4.2.2.1.4 20
Invite citizens to provide
representation on the steering
committee, with goal of including
2 citizens on steering committee
Provide opportunity for
input on the SWMP MSD
Provide participation
opportunities to
interested citizens
Send a letter or e-mail
invitation to at least 10
citizen contacts. Based on
interest, select 2 parties to
participate on the
committee.
None None
Send a letter or e-mail
invitation to at least 10
citizen contacts. Based on
interest, select 2 parties to
participate on the
committee.
None SWMP notification
opportunities developed.
4.2.2.1.5 21 Participate in at least one cleanup
event annually.
Foster nonpoint source
pollution and water quality
awareness in community.
All
Prevent disposal of wastes
in waterways. Increase
awareness and positive
behavior change.
MSD will organize with
partner organizations one
or more annual stream or
neighborhood clean-up
events to cover the Plan
Area. Each co-permittee
will participate with a
planned event, or
participate in their own
stream or neighborhood
clean-up activity in the
community. Record
participation activity.
Co-permittee group will
provide equipment, in-
kind sponsorship, staff
support, and/or financial
sponsorship, for
Confluence Trash Bash,
River des Peres Trash
Bash, and Operation Clean
Stream. Record
participation activity.
Co-permittee group will
provide equipment, in-
kind sponsorship, staff
support, and/or financial
sponsorship, for
Confluence Trash Bash,
River des Peres Trash
Bash, and Operation Clean
Stream. Record
participation activity.
Co-permittee group will
provide equipment, in-
kind sponsorship, staff
support, and/or financial
sponsorship, for
Confluence Trash Bash,
River des Peres Trash
Bash, and Operation Clean
Stream. Record
participation activity.
Co-permittee group will
provide equipment, in-
kind sponsorship, staff
support, and/or financial
sponsorship, for
Confluence Trash Bash,
River des Peres Trash
Bash, and Operation Clean
Stream. Record
participation activity.
Clean-ups completed.
Track number of
participants and waste
amounts collected.
Measurable Goals, Milestones, and Dates BMP Evaluation
Process/Criteria
Permit
Requirement BMP Description BMP Purpose Responsible
Person
Expected Result of
BMP
Table 4
17
Permit Year 1, 2017 Permit Year 2, 2018 Permit Year 3, 2019 Permit Year 4, 2020 Permit Year 5, 2021
4.2.2.1.5 22
Continue to operate two
household hazardous waste drop-
off facilities.
Provide safe and
economical outlet for
household hazardous
waste disposal
St. Louis County
Prevent disposal of wastes
in waterways. Increase
awareness and positive
behavior change.
Operate the two
household hazardous
waste drop-off facilities
and record participation
and the amount of
household hazardous
waste collected.
Operate the two
household hazardous
waste drop-off facilities
and record participation
and the amount of
household hazardous
waste collected.
Operate the two
household hazardous
waste drop-off facilities
and record participation
and the amount of
household hazardous
waste collected.
Operate the two
household hazardous
waste drop-off facilities
and record participation
and the amount of
household hazardous
waste collected.
Operate the two
household hazardous
waste drop-off facilities
and record participation
and the amount of
household hazardous
waste collected.
Two locations remain
open. Track number of
participants and waste
amounts collected.
23
Provide training to educators,
watershed group members, and
others on how to use the
Enviroscape® watershed models.
Engage citizen volunteers
on how to educate
students on sources of
pollution and best
practices, providing
additional resources.
MSD
Provide additional
resources/labor who can
help with education on
sources of stormwater
pollution and best
practices
Provide or partner with
environmental
organization to provide an
annual workshop on how
to use the model.
Provide or partner with
environmental
organization to provide an
annual workshop on how
to use the model.
Provide or partner with
environmental
organization to provide an
annual workshop on how
to use the model.
Provide or partner with
environmental
organization to provide an
annual workshop on how
to use the model.
Provide or partner with
environmental
organization to provide an
annual workshop on how
to use the model.
Classes completed and
track attendance.
24 Provide Enviroscape ® watershed
models for community use.
Foster nonpoint source
pollution and water quality
awareness in community.
MSD
Provide opportunity to
increase awareness and
positive behavior change.
Target 50 presentations,
maintain reservation
tracking database, and
record presentations.
Target 50 presentations,
maintain reservation
tracking database, and
record presentations.
Target 50 presentations,
maintain reservation
tracking database, and
record presentations.
Target 50 presentations,
maintain reservation
tracking database, and
record presentations.
Target 50 presentations,
maintain reservation
tracking database, and
record presentations.
Track number of
presentations
completed.
25
Provide storm drain marker
instructions and equipment to
citizen volunteers.
Foster nonpoint source
pollution and water quality
awareness in community.
MSD
Provide opportunity to
increase awareness and
positive behavior change.
Target 500 markers
applied and record how
many projects completed
(markers and door
hangers).
Target 500 markers
applied and record how
many projects completed
(markers and door
hangers).
Target 500 markers
applied and record how
many projects completed
(markers and door
hangers).
Target 500 markers
applied and record how
many projects completed
(markers and door
hangers).
Target 500 markers
applied and record how
many projects completed
(markers and door
hangers).
Track number of markers
and door hangers placed.
26 Develop storm drain marking GIS
map.
Maintain map of marked
inlets.MSD
Provide tool to facilitate
participation
opportunities.
Develop GIS map layer,
develop mapping
procedures, record
labeled inlets (new and
from available past
records).
Maintain GIS map layer
and record labeled inlets.
Maintain GIS map layer
and record labeled inlets.
Maintain GIS map layer
and record labeled inlets.
Maintain GIS map layer
and record labeled inlets.
GIS map layer completed
for use to direct public
where they can label
inlets.
27
Provide resources, as available, to
citizen volunteer organizations
that promote green infrastructure
and other healthy water
programming.
Foster nonpoint source
pollution and water quality
awareness in community.
MSD
Provide tools to facilitate
education, increase
awareness, and positive
behavior change.
Develop resource library
of existing material (i.e.,
BMP O&M series
brochures, websites).
Distribute education
material upon request via
presentations/information
booths and mailings.
Record what, when, and
who material distributed
to.
Update resource library of
existing material (i.e., BMP
O&M series brochures,
websites). Distribute
education material upon
request via
presentations/information
booths and mailings.
Record what, when, and
who material distributed
to.
Update resource library of
existing material (i.e., BMP
O&M series brochures,
websites). Distribute
education material upon
request via
presentations/information
booths and mailings.
Record what, when, and
who material distributed
to.
Update resource library of
existing material (i.e., BMP
O&M series brochures,
websites). Distribute
education material upon
request via
presentations/information
booths and mailings.
Record what, when, and
who material distributed
to.
Update resource library of
existing material (i.e., BMP
O&M series brochures,
websites). Distribute
education material upon
request via
presentations/information
booths and mailings.
Record what, when, and
who material distributed
to.
Resource library
completed and track
number of material
distributed.
4.2.2.1.6
Measurable Goals, Milestones, and Dates BMP Evaluation
Process/Criteria
Permit
Requirement BMP Description BMP Purpose Responsible
Person
Expected Result of
BMP
18
Minimum Control Measure Number 3, Illicit Discharge
Detection and Elimination (MCM3)
Permit Requirements A.
Section 4.2.3.1 of the 2016 Permit requires the permittee to develop, implement,
and enforce a program to detect and eliminate illicit discharges, as defined in 10
CSR 20-6.200 and 40 CFR 122.34(b)(3), into the permittee’s regulated Small MS4.
As part of the SWMP document, the permittee’s illicit discharge detection and
elimination program shall include the development and implementation of, at a
minimum:
4.2.3.1.1 A storm sewer map showing the location of all constructed
outfalls and the names and locations of all receiving waters of
the state that receive discharges from those outfalls. The
permittee shall describe the sources of information used for the
map(s), and how the permittee plans to verify the outfall
locations with field surveys. If already completed, the permittee
shall describe how the map was developed and how the map
will be regularly updated. The permittee shall make the map
information available to the Department upon request;
4.2.3.1.2 To the extent allowable under state or local law an effective
prohibition, through ordinance or other regulatory mechanism,
of non-stormwater discharges into the permittee’s storm sewer
system and implementation of appropriate enforcement
procedures and actions. The permittee shall identify the
mechanism (ordinance or other regulatory mechanism) the
permittee will use to effectively prohibit illicit discharges into the
Small MS4. If the permittee needs to develop this mechanism,
describe the permittee’s plan and implementation schedule. If
the permittee’s ordinance or regulatory mechanism is already
developed, include a copy of the relevant sections with the
permittee’s SWMP;
4.2.3.1.3 A plan and implementation schedule to detect and address
non-stormwater discharges, including discharges from illegal
dumping and spills, to the permittee’s system;
4.2.3.1.4 A dry weather field screening plan for non-stormwater flows
and field tests of selected chemical parameters as indicators of
discharge sources.
19
The plan shall also address on-site sewage disposal systems
that flow into the permittee’s storm drainage system;
4.2.3.1.5 Procedures for locating priority areas which include areas with
higher likelihood of illicit connections (e.g., areas with older
sanitary sewer lines) or ambient sampling to locate impacted
reaches;
4.2.3.1.6 Procedures for tracing the source of an illicit discharge,
including the specific techniques the permittee will use to detect
the location of the source;
4.2.3.1.7 Procedure for eliminating the illicit discharge;
4.2.3.1.8 A plan to ensure through appropriate enforcement procedures,
including fines, and actions that the permittee’s illicit discharge
ordinance (or other regulatory mechanism) is implemented;
4.2.3.1.9 A plan to inform public employees, businesses and the general
public of hazards associated with illegal discharges and
improper disposal of waste. The permittee shall describe how
this plan will coordinate with all other minimum control
measures, monitoring, and TMDL implementation (if
applicable);
4.2.3.1.10 A plan to address non-stormwater discharges or flows (i.e.,
illicit discharges) the permittee identifies as significant
contributors of pollutants to the regulated Small MS4 including
authorized non-stormwater discharges contained in Section
1.2.2.2 of the permit.1
Applicability B.
An illicit discharge is any discharge to the stormwater system that is not composed
entirely of stormwater, except for discharges pursuant to a state operating permit,
1 The permittee is authorized to discharge the non-stormwater sources provided the permitting
authority has not determined these sources to be substantial contributors of pollutants to the
permittee’s MS4 that required a separate permit. These include landscape irrigation and lawn
watering; rising groundwater; uncontaminated groundwater infiltration (infiltration is defined as water
other than wastewater that enters a sewer system, including sewer service connections and
foundation drains, from the ground through such means as defective pipes, pipe joints, connection s,
or manholes. Infiltration does not include, and is distinguished from, inflow); uncontaminated
pumped groundwater; discharges from potable water sources; foundation or footing drains; air
conditioning condensate; springs; uncontaminated water from crawl space pumps; flows from
riparian habitat and wetlands; street wash water; discharges or flows from emergency fire -fighting
activities; individual residential car washing; and dechlorinated residential swimming pool discharges.
20
other than stormwater discharge permits and discharges from firefighting activities.
An illicit discharge or connection may result from:
Illegal dumping practice (i.e., improper disposal of waste).
A direct connection from the sanitary sewer to the storm sewer.
Indirect connection from improper surface discharges to the storm sewer
(i.e., hosing down outdoor areas on a parking lot or other impervious
surface.
Stormwater System C.
The stormwater system within the MSD service area consists of man-made
facilities, structures, and natural watercourses used for collecting and conducting
stormwater to, through and from drainage areas to the points of final outlet
including, but not limited to, any and all of the following: sewers, pipes, inlets,
conduits and appurtenant features, canals, creeks, channels, catch basins, ditches,
streams, rivers, gulches, gullies, flumes, culverts, siphons, retention or detention
basins, dams, floodwalls, levees, and pumping stations.2 MSD maps the entire
stormwater system using a geographic information system (GIS).
Enforcement D.
MSD utilizes provisions in its sewer use ordinances to prohibit illicit discharges into
the stormwater system. MSD Ordinance No. 12559 adopted December 13, 2007,
is used as the legal enforcement tool to control such discharges.
BMP Development E.
Specific illicit discharge detection and elimination best management practices are
presented in Table 5.
2 As defined by MSD Ordinance 14393.
Table 5
21
Permit Year 1, 2017 Permit Year 2, 2018 Permit Year 3, 2019 Permit Year 4, 2020 Permit Year 5, 2021
28
Maintain GIS system showing
constructed MS4 outfalls and
receiving streams.
View outfalls in plan area
watersheds.MSD Permit compliance.
Maintain map of
constructed outfalls on
GIS.
Maintain map of
constructed outfalls on
GIS.
Maintain map of
constructed outfalls on
GIS.
Maintain map of
constructed outfalls on
GIS.
Maintain map of
constructed outfalls on
GIS.
Constructed outfalls
mapped.
29
Use map update work orders to
track any modifications to the
sewer map.
Keep current information
on storm sewer system in
plan area watersheds
MSD Permit compliance.Maintain work order
records of map updates.
Maintain work order
records of map updates.
Maintain work order
records of map updates.
Maintain work order
records of map updates.
Maintain work order
records of map updates.
Maps updates completed
through work orders.
4.2.3.1.2 30 Enforce MSD ordinance 12559, and
other ordinances as required.
Provides MSD legal
authority to address illicit
discharges.
MSD Permit compliance.
Enforce MSD Ordinance.
Record enforcement
actions.
Enforce MSD Ordinance.
Record enforcement
actions.
Enforce MSD Ordinance.
Record enforcement
actions.
Enforce MSD Ordinance.
Record enforcement
actions.
Enforce MSD Ordinance.
Record enforcement
actions.
Ordinance developed
and enforced. Track
number of enforcement
actions.
31
Survey all natural channels
identified on stormwater GIS map
once per 5 years.
Detect and eliminate illicit
discharges.MSD
Identify illicit discharges
and take enforcement
action as necessary.
Survey 280 miles of storm
channels for illicit
discharges. Record
mileage, findings, and
resolutions.
Survey 280 miles of storm
channels for illicit
discharges. Record
mileage, findings, and
resolutions.
Survey 280 miles of storm
channels for illicit
discharges. Record
mileage, findings, and
resolutions.
Survey 280 miles of storm
channels for illicit
discharges. Record
mileage, findings, and
resolutions.
Survey 280 miles of storm
channels for illicit
discharges. Record
mileage, findings, and
resolutions.
Track mileage, findings
from surveys, and
resolutions.
32 Respond to reports of illegal
dumping.
Detect and eliminate illicit
discharges .MSD
Identify illicit discharges
and take enforcement
action as necessary.
Respond to customer
complaints in accordance
with the effective version
of MSD's SOP for Customer
Sewer Maintenance
Requests.
Respond to customer
complaints in accordance
with the effective version
of MSD's SOP for Customer
Sewer Maintenance
Requests.
Respond to customer
complaints in accordance
with the effective version
of MSD's SOP for Customer
Sewer Maintenance
Requests.
Respond to customer
complaints in accordance
with the effective version
of MSD's SOP for Customer
Sewer Maintenance
Requests.
Respond to customer
complaints in accordance
with the effective version
of MSD's SOP for Customer
Sewer Maintenance
Requests.
Track service requests,
work orders, and
resolutions. Initial
response times comply
with policy at least 90%
of the occurrences.
4.2.3.1.4 33
Maintain operating procedures for
field testing and surveying to help
identify chemicals indicative of
illicit discharge.
Field screening provides for
timely and efficient illicit
source identification and
elimination.
MSD
Provide tools to identify
illicit discharges and take
enforcement action as
necessary.
Maintain field screening
plan.
Maintain field screening
plan.
Maintain field screening
plan.
Maintain field screening
plan.
Maintain field screening
plan. Review and revise
plan as needed.
Standard operating
procedures completed
and update as needed.
34
Maintain and annually review
findings from channel surveys.
Previous findings inspected.
Identify priority areas for
potential monitoring and
followup.
MSD Ensures there is followup
on potential sources.
Review findings and
inspect each as necessary
to ensure 1-in-5 year
frequency is achieved.
Review findings and
inspect each as necessary
to ensure 1-in-5 year
frequency is achieved.
Review findings and
inspect each as necessary
to ensure 1-in-5 year
frequency is achieved.
Review findings and
inspect each as necessary
to ensure 1-in-5 year
frequency is achieved.
Review findings and
inspect each as necessary
to ensure 1-in-5 year
frequency is achieved.
Annual review of all
findings. All finding areas
inspected 1-in-5 years,
minimum.
35
Review representative water
quality data collected by MSD to
prioritize investigation areas.
Use the water quality data
that MSD collects to
identify sources.
MSD
Identify reaches that are
affected by sources.
Allows development of a
plan for sources.
None
Review water quality data
and provide summary
report comparing data to
channel inspection
findings, for 2017 WQ
data.
Review water quality data
and provide summary
report comparing data to
channel inspection
findings, for 2018 WQ
data.
Review water quality data
and provide summary
report comparing data to
channel inspection
findings, for 2019 WQ
data.
Review water quality data
and provide summary
report comparing data to
channel inspection
findings, for 2020 WQ
data.
Report submitted and
filed.
36
Develop a tabular database and
GIS layer of areas that may utilize
individual sewage disposal systems
(i.e., septic tanks).
Have a database of areas
with individual sewage
disposal systems that could
be used to assist illicit
discharge investigations
All Efficiently complete illicit
discharge investigations None
Identify possible files,
databases, or other
information that could
contain such information.
Using GIS, identify
possible areas for
investigation.
Using GIS, identify
possible areas for
investigation.
None Database developed.
4.2.3.1.1
4.2.3.1.3
4.2.3.1.5
Measurable Goals, Milestones, and Dates BMP Evaluation
Process/Criteria
Permit
Requirement BMP Description BMP Purpose Responsible
Person
Expected Result of
BMP
Table 5
22
Permit Year 1, 2017 Permit Year 2, 2018 Permit Year 3, 2019 Permit Year 4, 2020 Permit Year 5, 2021
4.2.3.1.5 37
Develop a tabular database and
GIS layer of properties that have
participated in the sewer lateral
repair program.
Have a database of
properties that have
participated in the sewer
lateral repair program that
could be used to assist
illicit discharge
investigations
All Efficiently complete illicit
discharge investigations None None None
Using GIS, review and
survey existing plan area
data sources.
Using GIS, review and
survey existing plan area
data sources.
Database developed.
4.2.3.1.6 38
Maintain operating procedures for
tracing illicit discharges from
public sewer system.
Timely detect and
eliminate illicit discharges
within entire plan area
MSD
Have tools to identify
illicit discharges and take
enforcement action as
necessary.
Maintain and implement
standard operating
procedures.
Maintain and implement
standard operating
procedures.
Maintain and implement
standard operating
procedures.
Maintain and implement
standard operating
procedures.
Maintain and implement
standard operating
procedures.
Standard operating
procedures completed
and updated as needed.
4.2.3.1.7 39 Maintain operating procedures for
eliminating illicit discharges
Timely elimination of illicit
discharges MSD
Identify illicit discharges
and take enforcement
action as necessary.
Maintain and implement
standard operating
procedures. Report
number of illicit
discharges, resolved and
outstanding.
Maintain and implement
standard operating
procedures. Report
number of illicit
discharges, resolved and
outstanding.
Maintain and implement
standard operating
procedures. Report
number of illicit
discharges, resolved and
outstanding.
Maintain and implement
standard operating
procedures. Report
number of illicit
discharges, resolved and
outstanding.
Maintain and implement
standard operating
procedures. Report
number of illicit
discharges, resolved and
outstanding. Revise
procedures as needed.
Track number of illicit
discharges, resolved and
outstanding. Standard
operating procedures
completed and updated
as needed.
4.2.3.1.8 40 Maintain enforcement plan for
addressing illicit discharges.
Timely elimination of illicit
discharges.MSD
Identify illicit discharges
and take enforcement
action as necessary.
Maintain and implement
ordinance.
Maintain and implement
ordinance.
Maintain and implement
ordinance.
Maintain and implement
ordinance.
Maintain and implement
ordinance.
SOP completed and
updated as needed.
Record location and
number of brochures and
door hangers provided as
part of illicit discharge
investigations.
Record location and
number of brochures and
door hangers provided as
part of illicit discharge
investigations.
Record location and
number of brochures and
door hangers provided as
part of illicit discharge
investigations.
Record location and
number of brochures and
door hangers provided as
part of illicit discharge
investigations.
Record location and
number of brochures and
door hangers provided as
part of illicit discharge
investigations.
Number of educational
material tracked.
Analyze MCM1
education survey.
None
Review "location and
numbers" to determine if
modifications to MCM 1
activities is needed.
None None
Review "where and
numbers" to determine if
modification to MCM 1
activities is needed.
Number of educational
material tracked.
Analyze MCM1
education survey.
4.2.3.1.10 42
Provide public outreach
communications tools (brochures,
etc.) to sources of non-stormwater
discharge that could be substantial
contributors of pollutants into the
MS4, such as street cleaning,
residential car washing, and
residential swimming pools
Foster stormwater NPS
pollution awareness and
behavior change in
community
MSD
Provide education and
increase awareness and
positive behavior change
Record location and
number of brochures and
door hangers provided as
part of IDD investigations.
Record location and
number of brochures and
door hangers provided as
part of IDD investigations.
Record location and
number of brochures and
door hangers provided as
part of IDD investigations.
Record location and
number of brochures and
door hangers provided as
part of IDD investigations.
Record location and
number of brochures and
door hangers provided as
part of IDD investigations.
Number of educational
material tracked.
Analyze MCM1
education survey.
Foster stormwater
nonpoint source pollution
awareness and behavior
change in community.
MSD
Provide education and
increase awareness and
positive behavior change.
4.2.3.1.9 41
Maintain and distribute brochures,
door hangers, and other
communication tools that inform
about hazards associated with
illegal discharges and
improper disposal of waste.
Measurable Goals, Milestones, and Dates BMP Evaluation
Process/Criteria
Permit
Requirement BMP Description BMP Purpose Responsible
Person
Expected Result of
BMP
23
Minimum Control Measure Number 4, Construction Site
Stormwater Runoff Control (MCM4)
Permit Requirements A.
Section 4.2.4.1 of the 2016 Permit requires the permittee to develop, implement and
enforce a program to reduce pollutants in any stormwater runoff to their regulated
Small MS4 from construction activities that result in land disturbance of greater than
or equal to one acre. Reduction of stormwater discharges from construction activity
disturbing less than one acre shall be included in the program if that construction
activity is part of a larger common plan of development or sale that would disturb
one acre or more. As part of the SWMP, the permittee’s construction site
stormwater runoff control program shall include the development and
implementation of, at a minimum:
4.2.4.1.1 An ordinance or other regulatory mechanism to require
operators to implement erosion and sediment control BMPs at
construction sites; to include sanctions designed to ensure
compliance, to the extent allowable under state or local law;
and
4.2.4.1.1.1 If the permittee needs to develop this mechanism, the
permittee shall describe the plan and scheduled
implementation. If the permittee’s ordinance or regulatory
mechanism is already developed, the permittee shall include a
copy of the relevant sections with the permittee’s SWMP.
4.2.4.1.2 Requirements for construction site operators to control
construction-site waste that may cause adverse impacts to
water quality, such as discarded building materials, concrete
truck washout, chemicals, litter and sanitary waste;
4.2.4.1.3 Procedures for the permittee to consider and review all pre-
construction site plans for potential water quality impacts;
4.2.4.1.4 Procedures for the permittee receive and consider information
submitted by the public, including coordination with the
permittee’s public education and involvement programs;
4.2.4.1.5 Procedures for the permittee to inspect sites and enforce
control measures, including prioritization of site inspection; and
24
4.2.4.1.5.1 The permittee shall inspect (or require inspection of) any
structure that functions to prevent pollution of stormwater or to
remove pollutants from stormwater and ensure that all BMPs
are implemented and effective; and a monitoring plan with
implementation schedules shall be referenced in the SWMP
document.
4.2.4.1.6 A plan designed to ensure compliance with the permittee’s
erosion and sediment control regulatory mechanism, including
the sanctions and enforcement mechanisms the permittee will
use to ensure compliance and procedures for when certain
sanctions will be used. Possible sanctions include non-
monetary penalties (such as stop work orders), fines, bonding
requirements, and/or permit denials for non-compliance.
Applicability B.
Within the Plan Area, construction and land disturbance activities are performed by
private entities, as well as by MSD, St. Louis County, and many of the municipal co -
permittees. Land disturbance activities conducted by the co-permittees are handled
in-house or with the use of a contractor.
As a result of the first Phase II permit, each Plan Area co -permittee has amended
its existing construction and land disturbance program or developed a new program
(Appendix C), which includes adoption of appropriate Phase II compliant policies,
procedures, and ordinances to reduce pollutants from construction activities that
result in a land disturbance of equal to or greater than 1 acre in size. Activities
conducted by private entities are subject to the land disturbance permitting
requirements of the co-permittee, depending upon the governmental jurisdiction
within which the site is located. In addition to any local approvals, every
construction site operator must also obtain a separate MDNR permit for any land
disturbance activities affecting an area of one acre or more. Regardless of the
status of local approvals, land disturbance activities on such sites may not
commence prior to the issuance of a state land disturbance permit.
Municipality Implementation Options C.
Each incorporated municipality has the authority and responsibility to perform
construction permitting and inspection services as a basic element of the police
powers afforded municipal governments in Missouri. Each has implemented a
Phase II compliance land disturbance program to regulate construction within their
jurisdiction.
25
Some municipalities provide full permitting and inspection services with their own
resources. These municipalities have implemented the p roject reviews, permitting,
inspection, complaint response, and other activities needed to implement the
permit’s land disturbance program.
A second option many municipalities have taken is to adopt St. Louis County’s
ordinance and contract with St. Louis County for Code Enforcement. The County
contracts for permitting (including plan review and construction authorization
documents) and code enforcement, including periodic and critical event inspections.
The County contract requires the construction site operator to gain zoning approval
from the municipality for a project before a county permit is issued. In addition, the
municipality issues its final occupancy permits only after the Department of Public
Works has completed all construction inspections. In all cases the ordinance
authority and any penalties for non-compliance are the responsibility and authority
of the individual municipal governments.
BMP Development D.
Specific construction site stormwater runoff control best management practices are
presented in Table 6.
Table 6
26
Permit Year 1, 2017 Permit Year 2, 2018 Permit Year 3, 2019 Permit Year 4, 2020 Permit Year 5, 2021
4.2.4.1.1 43
Maintain list of regulatory
mechanisms and active land
disturbance programs.
Ensure co-permittee land
disturbance programs are
implemented.
MSD Permit compliance.
Record each copermittees
ordinance or other
regulatory mechanism.
Record each copermittees
ordinance or other
regulatory mechanism.
Record each copermittees
ordinance or other
regulatory mechanism.
Record each copermittees
ordinance or other
regulatory mechanism.
Record each copermittees
ordinance or other
regulatory mechanism.
Track number of
copermittees programs.
4.2.4.1.1.1 44 Verify regulatory authority.
Ensure existing co-
permittee land disturbance
programs have authority.
MSD Permit compliance
Record each copermittees
ordinance or other
regulatory mechanism in
the SWMP.
Record each copermittees
ordinance or other
regulatory mechanism in
the SWMP.
Record each copermittees
ordinance or other
regulatory mechanism in
the SWMP.
Record each copermittees
ordinance or other
regulatory mechanism in
the SWMP.
Record each copermittees
ordinance or other
regulatory mechanism in
the SWMP.
Track copermittees
programs information.
See Appendix C
4.2.4.1.2 45
Maintain written procedures and
guidance materials for operators
to follow.
Prevent land disturbance
related waste from leaving
the land disturbance area.
St. Louis County
and
Municipalities
Waste sources contained
by BMPs
Record each copermittees
written procedure
Record each copermittees
written procedure
Record each copermittees
written procedure
Record each copermittees
written procedure
Record each copermittees
written procedure
Track procedures
completed.
4.2.4.1.3 46
Maintain written procedures and
guidance materials for permittees
to follow.
Require development pre-
construction planning See
also MCM5.
St. Louis County
and
Municipalities
Appropriate sediment and
erosion BMPs installed
Record each copermittees
written procedure
Record each copermittees
written procedure
Record each copermittees
written procedure
Record each copermittees
written procedure
Record each copermittees
written procedure
Track procedures
completed.
Permittees will follow
procedures to ensure
timely and appropriate
responses.
Notification to start
recording each
copermittees
complaints/follow-up
written procedure name
in year 2
Record each copermittees
complaints/follow-up
written procedure name
Record each copermittees
complaints/follow-up
written procedure name
Record each copermittees
complaints/follow-up
written procedure name
Record each copermittees
complaints/follow-up
written procedure name
Track procedures
completed.
Reduce pollution leaving
site by demonstrating
timely response occurred.
Notification to start
recording each
copermittees number of
complaints and follow-up
actions in year 2
Record each copermittees
number of complaints and
follow-up actions
Record each copermittees
number of complaints and
follow-up actions
Record each copermittees
number of complaints and
follow-up actions
Record each copermittees
number of complaints and
follow-up actions
Track number of
copermittees complaint
investigations (formal
and informal).
Maintain written procedures to
receive (i.e., public complaint
hotline) respond to, and track
public inquiries and complaints.
Provide timely customer
response to complaints
from land disturbance
related waste leaving the
land disturbance area.
MSD
Reduce pollution leaving
site by demonstrating
timely response occurred.
Record number of
findings, complaints, and
response actions
Record number of
findings, complaints, and
response actions
Record number of
findings, complaints, and
response actions
Record number of
findings, complaints, and
response actions
Record number of
findings, complaints, and
response actions
Track number of MSD
MCM3 land disturbance
findings. See also MCM3
St. Louis County
and
Municipalities
Measurable Goals, Milestones, and Dates BMP Evaluation
Process/Criteria
Permit
Requirement BMP Description BMP Purpose Responsible
Person
Expected Result of
BMP
4.2.4.1.4 47
Maintain written procedures to
receive (i.e., public complaint
hotline) respond to, and track
public inquiries and complaints.
Provide timely customer
response to complaints
from land disturbance
related waste leaving the
land disturbance area.
Table 6
27
Permit Year 1, 2017 Permit Year 2, 2018 Permit Year 3, 2019 Permit Year 4, 2020 Permit Year 5, 2021
4.2.4.1.5 48
Maintain written procedures and
checklists for permittees to follow
during SWPPP inspections.
To ensure BMPs properly
installed and maintained.
St. Louis County
and
Municipalities
St. Louis County and
municipailities will
inspect that appropriate
sediment and erosion
BMPs are installed.
Record each copermittees
written procedure and
checklist.
Record each copermittees
written procedure and
checklist.
Record each copermittees
written procedure and
checklist.
Record each copermittees
written procedure and
checklist.
Record each copermittees
written procedure and
checklist.
Track procedures
completed.
4.2.4.1.5.1 49
Inspect land disturbance sites and
as specified in land disturbance
program ordinance.
To ensure BMPs properly
installed and maintained.
St. Louis County
and
Municipalities
St. Louis County and
municipailities will
inspect that appropriate
sediment and erosion
BMPs are installed.
Notification to start
recording each
copermittees number of
inspections at each active
land disturbance site in
year 2.
Record each copermittees
number of inspections at
each active land
disturbance site.
Record each copermittees
number of inspections at
each active land
disturbance site.
Record each copermittees
number of inspections at
each active land
disturbance site.
Record each copermittees
number of inspections at
each active land
disturbance site.
Inspection records
support program
compliance.
4.2.4.1.6 50 Maintain written procedures for
enforcement actions.
Provide authority to
implement program.
St. Louis County
and
Municipalities
St. Louis County and
municipailities will follow
enforcement procedures
when needed.
Record each copermittees
number of formal
enforcements.
Notification to include
informal actions in year 2.
Record each copermittees
number of informal and
formal enforcements.
Record each copermittees
number of informal and
formal enforcements.
Record each copermittees
number of informal and
formal enforcements.
Record each copermittees
number of informal and
formal enforcements.
Track number of informal
and formal enforcements
Measurable Goals, Milestones, and Dates BMP Evaluation
Process/Criteria
Permit
Requirement BMP Description BMP Purpose Responsible
Person
Expected Result of
BMP
28
Minimum Control Measure Number 5, Post-Construction
Stormwater Management in New Development and
Redevelopment (MCM5)
Permit Requirements A.
Section 4.2.5.1 of the 2016 Permit requires the permittee to develop, implement and
enforce a program to address the quality of long-term stormwater runoff from new
development and redevelopment projects that disturb equal to and greater than one
acre, including projects less than one acre that are part of a larger common plan of
development or sale, that discharge into the permittee’s regulated Small MS4. The
permittee’s program shall ensure that controls are in place that have been designed
and implemented to prevent or minimize water quality impacts. As part of the
SWMP document, the post-construction runoff control program shall include the
following information, at a minimum:
4.2.5.1.1 An ordinance or other regulatory mechanism to address post -
construction runoff from new development and redevelopment
projects to the extent allowable under state or local law. If the
permittee needs to develop a mechanism, the permittee shall
describe the plan and a schedule for implementation. If the
permittee’s ordinance or regulatory mechanism is already
developed, the permittee shall include a copy of the relevant
sections with the SWMP document;
4.2.5.1.2 A plan to ensure adequate long-term operation and
maintenance of selected BMPs, including, as appropriate, types
of agreements between the permittee and other parties such as
post-development landowners or regional authorities;
4.2.5.1.3 Strategies to minimize water quality impacts, which include a
combination of structural and/or non-structural BMPs
appropriate for the permittee’s community, including but not
limited to the assessment of site characteristics at the
beginning of the construction site design phase to ensure
adequate planning for stormwater program compliance. The
goal of this approach is to arrive at designs that protect
sensitive areas, minimize the creation of stormwater pollution,
and utilize BMPs that effectively remove stormwater pollution.
29
This can be achieved by reasonably mimicking pre-
construction runoff conditions on all affected new development
projects, or the permittee may achieve this goal through a
method more appropriate for its community;
4.2.5.1.4 An inspection plan with implementation schedules for post-
construction BMPs;
4.2.5.1.5 The permittee shall inspect or require the inspection of post-
construction stormwater BMPs to ensure that all BMPs are
implemented and effective.
BMP Development B.
Both structural and non-structural BMPs have a role in effectively addressing
stream impairment and water quality. A milestone activity of the SWMP will be to
continue implementing Plan Area wide requirements for stormwater facilities on
development projects over 1 acre. MSD requires all stormwater facilities to be
provided and designed in accordance with provisions contained in the “Rules and
Regulations and Engineering Design Requirements for Sanitary Sewer and
Stormwater Drainage Facilities,” as amended. These Rules and Regulations
include requirements for BMPs for stormwater control and watershed protection to
be incorporated into the project design. These rules and regulations are
implemented under the authority of MSD Ordinance 9030, and the Rules and
Regulations implementing the Phase II BMPs were adopted by the MSD Board of
Trustees in Resolution 2630. The Rules and Regulations include stormwater design
criteria for:
Water quality treatment of the project disturbed area, or equivalent, using the
90th percentile daily rainfall depth or continuous simulation modeling
indicating 90% of all annual rainfall is treated by the BMP.
Reducing runoff volume to pre-construction levels on new development sites.
New development sites include those with less than 20% impervious area
and/or where prior land use activities have not impaired the site and
utilization of natural processes like infiltration are still possible. A BMP’s
ability to adequately reduce runoff is assessed based on average annual
rainfall or continuous simulation modeling over a typical year. Runoff is
defined as water discharged to the MS4 by overflow (bypass) and/or by
underdrain piping (e.g., treated water that does not infiltrate).
Extended detention storage and release of the 1 -year 24-hour storm to
reduce channel erosion, as appropriate for the site.
30
MSD applies these water quality design criteria on projects within the Plan Area that
discharge to waters of the state or drainage areas tributary to a stormwater outlet.
MSD applies the water quality design criteria on projects within the flood control
levee MSDs. Projects located within flood control levee MSDs may utilize regional
water quality plans approved by MSD. These regional plans may adopt a modified
3-pronged approach: at the source, in master channels, and in flood storage basin
structures, as reviewed and responded to by MDNR in a letter dated May 10, 2011.
To be considered an effective BMP for stand-alone treatment of the water quality
volume, the BMP shall demonstrate a minimum removal efficiency of 80% total
suspend solids and have an acceptable longevity rate in the field (i.e., be
maintainable). MSD maintains an online BMP Toolbox on its website for developers
and engineers who submit post-construction BMP plans to MSD and co-permittees.
The Toolbox helps navigate a user through the technica l and procedural paths to
post-construction stormwater BMPs design, installation and maintenance.
MSD, St. Louis County, and the Plan Area municipalities will continue to approve
development plans only after ensuring the development meets all applicable
requirements. St. Louis County and municipalities enforce ordinances related to
land use BMPs in their planning and zoning function. St. Louis County and each
municipality has implemented procedures to ensure that all applicable private and
public development projects involving stormwater management are reviewed and
approved by MSD. MSD enforces sewer and drainage design requirements
mandating structural and non-structural post-construction BMPs. MSD will continue
to issue permits for and inspect the construction of all structural BMPs.
An executed maintenance agreement is required with all projects where BMPs are
required to comply with the permit, and where MSD is not performing BMP
maintenance. All structural BMPs located on private property (i.e., all parcels that
are assigned a locator identification number by the St. Louis County assessor’s
office) will be maintained by the property owner(s), and MSD will enforce the
maintenance through a Maintenance Agreement that is recorded with the property
deed. MSD will also require a maintenance agreement be executed for BMPs
located within right-of-way and for which MSD is not performing routine
maintenance, although these agreements cannot be recorded with the right -of-way
property.
31
MSD maintains responsibility under the Plan to ensure BMPs are maintained and
MSD will continue to inspect BMPs to ensure adequate operation. MSD has
enforcement authority to ensure owners maintain their post construction BMPs in
MSD Ordinance 12559, Article IV, Part C. MSD BMP inspections will be conducted
at a minimum of once every three years for each BMP, or an alternate frequency
deemed appropriate for the BMP type, and MSD will continue enforcement
compliance using MSD Ordinance 12559.
Specific best management practices for post-construction stormwater management
in new development and redevelopment are presented Table 7.
Table 7
32
Permit Year 1, 2017 Permit Year 2, 2018 Permit Year 3, 2019 Permit Year 4, 2020 Permit Year 5, 2021
MSD
New and redevelopment
projects that disturb
greater than or equal to
one acre will implement
BMPs.
Implement Ordinance and
Design Rules.
Implement Ordinance and
Design Rules.
Implement Ordinance and
Design Rules.
Implement Ordinance and
Design Rules.
Implement Ordinance and
Design Rules.
Ordinance and Design
Rules completed and
implemented.
St. Louis County
and
Municipalities
New and redevelopment
projects that disturb
greater than or equal to
one acre will implement
BMPs.
Implement ordinance to
regulate and enforce post-
construction strategies.
Implement ordinance to
regulate and enforce post-
construction strategies.
Implement ordinance to
regulate and enforce post-
construction strategies.
Implement ordinance to
regulate and enforce post-
construction strategies.
Implement ordinance to
regulate and enforce post-
construction strategies.
Ordinance completed
and implemented.
Develop and Implement
maintenance agreement
for each project, unless
BMP maintained by MSD.
Develop and Implement
maintenance agreement
for each project, unless
BMP maintained by MSD.
Develop and Implement
maintenance agreement
for each project, unless
BMP maintained by MSD.
Develop and Implement
maintenance agreement
for each project, unless
BMP maintained by MSD.
Develop and Implement
maintenance agreement
for each project, unless
BMP maintained by MSD.
All MSD approved
projects, with BMPs that
are not maintained by
MSD, have maintenance
agreement. Annual
internal review of 5
projects.
Implement MSD BMP
Enforcement and
Response Plan.
Update & implement MSD
BMP Enforcement and
Response Plan.
Implement MSD BMP
Enforcement and
Response Plan.
Implement MSD BMP
Enforcement and
Response Plan.
Implement MSD BMP
Enforcement and
Response Plan.
Plan updated. See below
for description of metrics
used.
53
Utilize matrix of BMPs on BMP
toolbox. Maintain existing
strategies
Requires developments to
implement appropriate
strategies and controls to
address post-construction
run-off.
MSD Implement BMPs to MEP.
Developments will utilize
BMPs and design
requirements as listed on
the BMP toolbox. List
water quality (WQ) and
channel protection (CPv)
requirements.
Update BMP toolkit, as
needed. Developments
will utilize BMPs and
design requirements as
listed on the BMP toolbox.
List WQ and CPv
requirements.
Developments will utilize
BMPs and design
requirements as listed on
the BMP toolbox. List WQ
and CPv requirements.
Developments will utilize
BMPs and design
requirements as listed on
the BMP toolbox. List WQ
and CPv requirements.
Developments will utilize
BMPs and design
requirements as listed on
the BMP toolbox. List WQ
and CPv requirements.
Development projects
follow rules. Toolbox is
complete and updated as
needed. Annual internal
review of 5 projects.
54
Copermittees will review and
update parking ordinances and/or
polices, as needed
Reduce impervious parking
areas and reduce barriers
to incorporating green
infrastructure into parking
areas.
Ballwin,
Bellefontaine
Neighbors, Black
Jack, Bridgeton,
Chesterfield,
Creve Coeur, Des
Peres, Ellisville,
Fenton,
Frontenac,
Kirkwood, Ladue,
Manchester,
Maryland Heights,
Olivette,
Overland, Sunset
Hills, St. Louis
County, Town and
Country,
Wildwood
Optimize use of
impervious areas in
parking
None None None
Copermittees reviews
completed. Track
copermittees actions to
either change on not
change their policy as a
result of their reviews.
MSD BMPs will function
correctly.
4.2.5.1.3
Review the model parking ordinance presented in the
Stormwater Best Management Practices Post-
Construction Recommendations – Addressing Legal
Impediments and Mandated Impervious Areas, February
2011 report, compare this model to current ordinance(s),
and revise current ordinance and/or policies, as
appropriate.
4.2.5.1.1 51
Follow MSD ordinances 9030 and
12559, MSD Rules and Regulations,
and County and Municipal
Ordinances.
Requires developers and
plan reviewers to
implement appropriate
strategies and controls to
address post-construction
run-off.
4.2.5.1.2 52
Follow plan review process for
executing maintenance
agreements environmental
compliance inspection process for
long term maintenance.
To ensure long-term
operation of BMPs.
Measurable Goals, Milestones, and Dates BMP Evaluation
Process/Criteria
Permit
Requirement BMP Description BMP Purpose Responsible
Person
Expected Result of
BMP
Table 7
33
Permit Year 1, 2017 Permit Year 2, 2018 Permit Year 3, 2019 Permit Year 4, 2020 Permit Year 5, 2021
55 Maintain optional conceptual
review process.
Provides developers with
plan review assessment of
appropriate strategies and
controls to address post-
construction run-off.
MSD
Identify opportunities for
water quality protection
early in the development
project planning phase.
Record number of
developments that are
charged for utilizing the
conceptual review service.
Record number of
developments that are
charged for utilizing the
conceptual review service.
Record number of
developments that are
charged for utilizing the
conceptual review service.
Record number of
developments that are
charged for utilizing the
conceptual review service.
Record number of
developments that are
charged for utilizing the
conceptual review service.
Number of conceptual
reviews.
56 Site Design Guide Available
Provide developers and
plan reviewers a way to
implement BMP
MSD
Protect sensitive areas,
minimize stormwater
pollution, and utilize
effective BMPs.
Site Design Guidance
document available.
Site Design Guidance
document available.
Site Design Guidance
document available.
Site Design Guidance
document available.
Site Design Guidance
document available.
Site Design Guidance
available for public use.
57 Use pre-condition assessment with
early stage project planning.
Requires developers and
permittees to assess
conditions early.
All
Protect sensitive areas,
minimize stormwater
pollution, and utilize
effective BMPs.
Have process requiring pre-
construction planning by
MSD Site Design Guidance
or equivalent procedure.
Have process requiring pre-
construction planning by
MSD Site Design Guidance
or equivalent procedure.
Have process requiring pre-
construction planning by
MSD Site Design Guidance
or equivalent procedure.
Have process requiring pre-
construction planning by
MSD Site Design Guidance
or equivalent procedure.
Have process requiring pre-
construction planning by
MSD Site Design Guidance
or equivalent procedure.
Process available,
process used. Annual
(starting in year 2) review
audit of up to 5 projects.
Implement construction
inspection requirements,
as defined in rules and
regulations.
Implement construction
inspection requirements,
as defined in rules and
regulations.
Implement construction
inspection requirements,
as defined in rules and
regulations.
Implement construction
inspection requirements,
as defined in rules and
regulations.
Implement construction
inspection requirements,
as defined in rules and
regulations.
Annual internal review of
4 projects.
Schedule and track BMP
three year inspections.
Schedule and track BMP
three year inspections.
Schedule and track BMP
three year inspections.
Schedule and track BMP
three year inspections.
Schedule and track BMP
three year inspections.
All BMPs are inspected
once per 3 years,
minimum.
Implement Enforcement
Response Plan and track
number of BMP
enforcement actions
Implement Enforcement
Response Plan and track
number of BMP
enforcement actions
Implement Enforcement
Response Plan and track
number of BMP
enforcement actions
Implement Enforcement
Response Plan and track
number of BMP
enforcement actions
Implement Enforcement
Response Plan and track
number of BMP
enforcement actions
Report number of
enforcement actions
taken. Enforcement
action taken within 45
days of notice of
problem, 90% of the
time.
Require and track BMP
owner annual reports
Require and track BMP
owner annual reports
Require and track BMP
owner annual reports
Require and track BMP
owner annual reports
Require and track BMP
owner annual reports
Report number of annual
reports received and
outstanding.
BMPs constructed and
maintained to function
properly.
4.2.5.1.3
4.2.5.1.4 &
4.2.5.1.5 58
Inspect all water quality BMPs and
use key performance indicators to
demonstrate compliance.
To ensure long-term
operation of BMPs.MSD
Measurable Goals, Milestones, and Dates BMP Evaluation
Process/Criteria
Permit
Requirement BMP Description BMP Purpose Responsible
Person
Expected Result of
BMP
34
Minimum Control Measure Number 6, Pollution Prevention
Good Housekeeping for Municipal Operations (MCM6)
Permit Requirements A.
Section 4.2.6.1 of the small MS4 general permit requires the permittee to develop
and implement an operation and maintenance program that includes a training
component and has the ultimate goal of preventing or reducing pollutant runoff from
municipal operations. As part of the SWMP, the pollution prevention/good
housekeeping program shall include the following information, at a minimum:
4.2.6.1.1 A government employee training program to prevent and
reduce stormwater pollution from activities such as park and
open space maintenance, fleet and building maintenance, new
construction and land disturbances, and stormwater system
maintenance. The permittee shall describe any existing,
available material the permittee plans to use such as those
available from EPA, the state, or other organizations. The
permittee shall describe how this plan will coordinate with all
other minimum control measures, monitoring and TMDL
implementations where applicable;
4.2.6.1.2 A list of all municipal operations that are impacted by this
operation and maintenance program. The permittee shall also
include a list of industrial facilities that the permittee owns or
operates that are subject to NDPES permits for discharges of
stormwater associated with industrial activity that ultimately
discharge to the permittee’s MS4. The permittee shall include
the permit number or a copy of the No Exposure Exemption
Certification (if applicable) for each facility. NPDES permitted
facilities not owned or operated by the permittee are not
required to be part of the list;
4.2.6.1.3 Maintenance BMPs, maintenance schedules, and long-term
inspection procedures for controls to reduce floatable and other
pollutants to the permittee’s regulated Small MS4;
4.2.6.1.4 Controls for reducing or eliminating the discharge of pollutants
from street, roads, highways, municipal parking lots,
maintenance and storage yards, waste transfer station, fleet or
maintenance shops with outdoor storage areas, and salt/sand
35
storage locations and snow disposal areas the permittee
operates;
Procedures for the proper disposal of waste removed from the
permittee’s Small MS4 and areas of jurisdiction, including
dredged material, accumulated sediments, floatables and other
debris;
4.2.6.1.5 Procedures to assess impacts of water quality for new flood
management projects, if applicable. Flood management
projects are those projects developed or designed to reduce
flooding.
4.2.6.2 All paints, solvents, petroleum products and petroleum waste
products (except fuels) under the control of the permittee shall
be stored so that these materials are not exposed to
stormwater. Sufficient practices of spill prevention, control,
and/or management shall be provided to prevent any spill of
these pollutants from entering waters of the state. Any
containment system used to implement this requirement shall
be constructed of materials compatible with the substances
contained and shall also prevent the contamination of
groundwater.
BMP Development B.
The scope of municipal operations varies widely among the 60 entities involved in
this SWMP. Municipal operations range from very small municipalities, having no
municipal facilities other than a few blocks of local streets, to the county
government, having responsibility for regional highways, parks, high rise municipal
buildings, major construction activities, fleet maintenance operations, airport and all
the other various operations of a major county government. Because of this broad
variation in activities, selection of appropriate BMPs to satisfy the permit
requirements will vary considerably among the co-permittees. Training programs
will be similarly varied. Each co-permittee identified and listed their operations that
are impacted by the MS4 permit requirements referenced in Section A a bove and
have supplied the required information as part of their MS4 permit application.
Implementation of an Operation and Maintenance Program using a program model
is required by each co-permittee. The program model is based on the following
common municipal operations:
36
General Housekeeping and Operation and Maintenance
Vehicle/Equipment Repair and Maintenance Operations
Vehicle/Equipment Washing
Facility Repair, Remodeling and Construction
Cleaning and Maintenance of Roadways, Highways, Bridges, and Parking
Facilities
Maintenance of Parks, Green Spaces, Trails, and Landscaping
Cleaning and Maintenance of Drainage Channels, Storm Sewers, and Inlet
Structures.
Operation and Maintenance of Recycling Facilities
Water Quality Impact Assessment of Flood Management Projects
Specific BMPs for pollution prevention/good housekeeping for municipal operations
best management practices are presented in Table 8.
Table 8
37
Permit Year 1, 2017 Permit Year 2, 2018 Permit Year 3, 2019 Permit Year 4, 2020 Permit Year 5, 2021
All
Training program exists,
and updated to
coordinate.
Maintain training
program.
Maintain training
program.
Maintain training
program.
Maintain training
program.
Review training program
and update as needed.
Track number of training
programs completed and
implemented. Year 5
review documented.
MSD
Co-permittee employees
will be offered MSD
annual training
opportunities.
Hold 4 training events and
record attendance.
Hold 4 training events and
record attendance.
Hold 4 training events and
record attendance.
Hold 4 training events and
record attendance.
Hold 4 training events and
record attendance.
Track training events
completed and
attendance.
Facilities listed in written
operation and
maintenance program.
Notification to complete
list in operation and
maintenance program
plan in year 2.
Maintain current list in
operation and
maintenance program
plan.
Maintain current list in
operation and
maintenance program
plan.
Maintain current list in
operation and
maintenance program
plan.
Maintain current list in
operation and
maintenance program
plan.
List completed
Maintain No Exposure
certification status, as
applicable.
Notification to review
certification status of each
facility and renew as
necessary by end of year
2.
Review certification status
of each facility, renew as
necessary, and record
application/expiration
dates.
Review certification status
of each facility, renew as
necessary, and record
application/expiration
dates.
Review certification status
of each facility, renew as
necessary, and record
application/expiration
dates.
Review certification status
of each facility, renew as
necessary, and record
application/expiration
dates.
No Exposure Exemption
Certification applications
completed before
expiration dates.
Confirm appropriate
BMPs implemented and
functioning correctly
Record inspection dates
and locations.
Record inspection dates
and locations.
Record inspection dates
and locations.
Record inspection dates
and locations.
Record inspection dates
and locations.
Inspection completed
and track number of
inspections.
Written operation and
maintenance program in
place. Program reflects
practice.
Implement Operation and
Maintenance program.
Implement Operation and
Maintenance program.
MSD will take the lead to
update the February 2005
dated Operation and
Maintenance Program
model template for co-
permittees.
Implement Operation and
Maintenance program.
MSD will distribute the
revised Operation and
Maintenance Program
model template and ask
co-permittees to review
and consider the need to
update their operation
and maintenance
programs.
Implement Operation and
Maintenance program.
Implement Operation and
Maintenance program.
Model Operation and
Maintenance Program
template complete and
track number of co-
permittee programs
implemented.
62
Maintain written inspection
checklist template for performing
inspections .
To ensure BMPs properly
installed and maintained.MSD
Confirm appropriate
BMPs implemented and
functioning correctly .
Checklist available for
copermittees. Provide
checklist at MSD annual
training events.
Checklist available for
copermittees. Provide
checklist at MSD annual
training events.
Checklist available for
copermittees. Provide
checklist at MSD annual
training events.
Checklist available for
copermittees. Provide
checklist at MSD annual
training events.
Checklist available for
copermittees. Provide
checklist at MSD annual
training events.
Inspection checklist
template completed and
distributed at annual
MSD training.
All
4.2.6.1.3
61 Maintain written Operation and
Maintenance Program.
To ensure BMPs properly
installed and maintained.All
4.2.6.1.1 59
Provide annual training to all MSD,
municipal, and St. Louis County
employees who work in municipal
operations impacted by
stormwater.
To prevent and reduce
stormwater pollution from
municipal operations.
4.2.6.1.2 60
List all operational facilities that
are subject to MCM 6. List all
operational facilities that are
subject to No Exposure
certification.
Identify copermittees
industrial discharges not
covered under a separate
NPDES operating permit
Measurable Goals, Milestones, and Dates BMP Evaluation
Process/Criteria
Permit
Requirement BMP Description BMP Purpose Responsible
Person
Expected Result of
BMP
Table 8
38
Permit Year 1, 2017 Permit Year 2, 2018 Permit Year 3, 2019 Permit Year 4, 2020 Permit Year 5, 2021
63
Install BMPs (e.g., rain gardens and
permeable pavement) with
construction of municipal facilities
and roadways, where feasible.
Provide pollutant controls
with projects.All
Reduce discharge of
pollutants from project
areas.
Project plans include
BMPs. Permittees build
BMPs. Permittees
maintain and report on
BMP condition.
Project plans include
BMPs. Permittees build
BMPs. Permittees
maintain and report on
BMP condition.
Project plans include
BMPs. Permittees build
BMPs. Permittees
maintain and report on
BMP condition.
Project plans include
BMPs. Permittees build
BMPs. Permittees
maintain and report on
BMP condition.
Project plans include
BMPs. Permittees build
BMPs. Permittees
maintain and report on
BMP condition.
Permittees build BMPs
with projects, where
feasible. Permittees
report on BMP status in
annual report, starting in
year 2.
Salt application rates
documented
Record BMPs and
application rates.
Record BMPs and
application rates.
Record BMPs and
application rates.
Record BMPs and
application rates.
Record BMPs and
application rates.
Analyze salt application
rate data annually for
application trends.
Consider also stream
water quality data.
Use alternative deicing
approaches to reduce
chloride load, where
feasible.
Track copermittees use of
alternative deicing
approaches.
Track copermittees use of
alternative deicing
approaches.
Track copermittees use of
alternative deicing
approaches.
Track copermittees use of
alternative deicing
approaches.
Track copermittees use of
alternative deicing
approaches.
Report annually on the
number of permittees
utilizing alternative
deicing approaches.
4.2.6.1.5 65 Maintain written Operation and
Maintenance Program.
To prevent and reduce
stormwater pollution from
municipal operations.
All
Written operation and
maintenance program in
place. Program reflects
practice.
Implement Operation and
Maintenance program.
Implement Operation and
Maintenance program.
MSD will take the lead to
update the February 2005
dated Operation and
Maintenance Program
model template for co-
permittees.
Implement Operation and
Maintenance program.
MSD will distribute the
revised Operation and
Maintenance Program
model template and ask
co-permittees to review
and consider the need to
update their operation
and maintenance
programs.
Implement Operation and
Maintenance program.
Implement Operation and
Maintenance program.
Model Operation and
Maintenance Program
template complete and
track number of co-
permittee programs
implemented.
4.2.6.1.6 66
Maintain written guidelines for
MSD to follow when preparing
preliminary engineering project
studies.
To assess water quality
impacts for new flood
management projects.
MSD Written guidelines in
place.
Implement guidelines for
preparing preliminary
engineering project
studies.
Implement guidelines for
preparing preliminary
engineering project
studies.
Implement guidelines for
preparing preliminary
engineering project
studies.
Implement guidelines for
preparing preliminary
engineering project
studies.
Implement guidelines for
preparing preliminary
engineering project
studies.
Guidelines for preparing
preliminary engineering
project studies complete
and implemented.
4.2.6.1.4
64
Track salt application rates. Set
baseline key performance
indicator of salt application rates.
To prevent and reduce
stormwater pollution from
deicing operations.
St. Louis County
and
Municipalities
Measurable Goals, Milestones, and Dates BMP Evaluation
Process/Criteria
Permit
Requirement BMP Description BMP Purpose Responsible
Person
Expected Result of
BMP
Table 8
39
Permit Year 1, 2017 Permit Year 2, 2018 Permit Year 3, 2019 Permit Year 4, 2020 Permit Year 5, 2021
4.2.6.1.6 67 Maintain written Operation and
Maintenance Program.
To assess and mitigate
water quality impacts for
new flood management
projects.
All
Written operation and
maintenance program in
place. Program reflects
practice.
Implement Operation and
Maintenance program.
Implement Operation and
Maintenance program.
MSD will take the lead to
update the February 2005
dated Operation and
Maintenance Program
model template for co-
permittees.
Implement Operation and
Maintenance program.
MSD will distribute the
revised Operation and
Maintenance Program
model template and ask
co-permittees to review
and consider the need to
update their operation
and maintenance
programs.
Implement Operation and
Maintenance program.
Implement Operation and
Maintenance program.
Model Operation and
Maintenance Program
template complete and
track number of co-
permittee programs
implemented.
4.2.6.2 68 Maintain written Operation and
Maintenance Program.
To prevent and reduce
stormwater pollution from
municipal operations.
All
Written operation and
maintenance program in
place. Program reflects
practice.
Implement Operation and
Maintenance program.
Implement Operation and
Maintenance program.
MSD will take the lead to
update the February 2005
dated Operation and
Maintenance Program
model template for co-
permittees.
Implement Operation and
Maintenance program.
MSD will distribute the
revised Operation and
Maintenance Program
model template and ask
co-permittees to review
and consider the need to
update their operation
and maintenance
programs.
Implement Operation and
Maintenance program.
Implement Operation and
Maintenance program.
Model Operation and
Maintenance Program
template complete and
track number of co-
permittee programs
implemented.
Measurable Goals, Milestones, and Dates BMP Evaluation
Process/Criteria
Permit
Requirement BMP Description BMP Purpose Responsible
Person
Expected Result of
BMP
40
Appendix A
St. Louis County SWMP Co-permittees
1. City of Ballwin 32. City of Maryland Heights
2. City of Bellefontaine 33. City of Moline Acres
3. City of Bel-Ridge 34. City of Normandy
4. City of Berkeley 35. City of Northwoods
5. City of Black Jack 36. City of Oakland
6. City of Breckenridge Hills 37. City of Olivette
7. City of Brentwood 38. City of Overland
8. City of Bridgeton 39. City of Pagedale
9. City of Calverton Park 40. City of Richmond Heights
10. City of Charlack 41. City of Rock Hill
11. City of Chesterfield 42. City of Shrewsbury
12. City of Clarkson Valley 43. City of St. Ann
13. City of Clayton 44. City of St. John
14. City of Cool Valley 45. City of Sunset Hills
15. City of Crestwood 46. City of Town & Country
16. City of Creve Coeur 47. City of University City
17. City of Dellwood 48. City of Valley Park
18. City of Des Peres 49. City of Vinita Park
19. City of Ellisville 50. City of Warson Woods
20. City of Fenton 51. City of Webster Groves
21. City of Ferguson 52. City of Wildwood
22. City of Florissant 53. City of Winchester
23. City of Frontenac 54. City of Woodson Terrace
24. City of Glendale 55. St. Louis County
25. City of Green Park 56. Town of Norwood Court
26. City of Hazelwood 57. Village of Bel-Nor
27. City of Jennings 58. Village of Hanley Hills
28. City of Kirkwood 59. Village of Marlborough
29. City of Ladue 60. Village of Riverview
30. City of Lakeshire 61. Metropolitan St. Louis Sewer
District (coordinating authority for
implementation of SWMP) 31. City of Manchester
41
Appendix B
St. Louis County SWMP Co-permittees Contact Information
Co-permittee First Name Last Name Title Phone
City of Ballwin Gary Kramer Director of Public Works (636) 227-2185
City of Bellefontaine Neighbors Deni Donovan City Clerk (314) 867-0076
City of Bel-Ridge Cary Herndon Public Works Supervisor (314) 267-6846
City of Berkeley Debra Irvin Municipal Services Manager (314) 400-3705
City of Black Jack Vijay Bhasin Director of Public Works (314) 355-0400
City of Breckenridge Hills George Mudd Building Inspector (314) 427-6868
City of Brentwood Dan Gummersheimer Building Official (314) 963-8643
City of Bridgeton Robert Gunn Director of Public Works (314) 739-7665
City of Calverton Park James Paunovich Chairman, Board of Trustees (314) 524-1212
City of Charlack Peter Daub Director of Public Works (314) 427-4715
City of Chesterfield James Eckrich PW Director/City Engineer (636) 537-4764
City of Clarkson Valley Michele McMahon City Clerk (636) 227-8607
City of Clayton Spencer Litteken Civil Engineer (314) 290-8575
City of Cool Valley Deborah Jones City Clerk (314) 521-3500
City of Crestwood James Gillam Director of Public Works (314) 729-4722
City of Creve Coeur Matt Wohlberg City Engineer (314) 442-2084
City of Dellwood Marvin Crumer Public Services Director (314) 869-8686
City of Des Peres Stephen Meyer Director of Public Works (314) 835-6130
City of Ellisville John Collins City Engineer (636) 227-9660
City of Fenton Dan Howard Project/Code Enforcement Mgr (636) 349-8155
City of Ferguson Matthew Unrein Director of Public Works (314) 524-4721
City of Florissant Tom Goldkamp Civil Engineer (314) 839-7643
City of Frontenac Jeff Wappelhorst Building Commissioner (314) 994-0646
City of Glendale Jaysen Christensen City Administrator (314) 965-3600
City of Green Park James Mello City Administrator (314) 894-7336
City of Hazelwood Nikki Miller Project Manager (314)513-5031
City of Jennings William Kaeshamer Director of Public Works (314) 381-7184
City of Kirkwood Chris Pflasterer Assistant Public Works Director (314) 822-5819
City of Ladue Anne Lamitola Director of Public Works (314) 993-5665
City of Lakeshire Tony Seher Mayor, City of Lakeshire (314) 605-3578
City of Manchester Bob Ruck Director of Public Works (636) 227-1385
City of Maryland Heights Cliff Baber Construction Manager (314) 738-2258
City of Moline Acres Dennis DeShay Public Works Director (314) 868-2433
City of Normandy Rodney Jarrett Director of Public Works (314) 267-3695
City of Northwoods Lillian Eunice City Administrator (314) 385-8000
42
Co-permittee First Name Last Name Title Phone
City of Oakland Deborah LeMoine City Administrator (314) 416-0026
City of Olivette Bruce McGregor Director of Public Works (314) 993-0252
City of Overland Jason McConachie City Administrator (314) 952-1952
City of Pagedale Craig Lovings Public Works Director (314) 803-9204
City of Richmond Heights Chris Boyd Director of Public Works (314) 655-3670
City of Rock Hill Al Hayden Director of Parks & Recreation (314) 561-4304
City of Shrewsbury Tony Wagner Public Works Superintendent (314) 645-7441
City of St. Ann Shawn Seymour Director of Public Services (314) 447-1650
City of St. John James Phillips Director of Public Works (314) 427-8700
City of Sunset Hills Bryson Baker Director of Public Works (314) 849-3400
City of Town & Country Craig Wilde Director of Public Works (314) 587-2824
City of University City Jennifer Wendt Project Manager (314) 505-8562
City of Valley Park Gerald Martin Director of Public Works (636) 225-8930
City of Vinita Park Gerald French Public Works Director (314) 428-7373
City of Warson Woods Michael Dell'Orco Acting City Engineer (314) 965-3100
City of Webster Groves Michael Harney Building Commissioner (314) 963-5317
City of Wildwood Rick Brown Director of Public Works (636) 405-2024
City of Winchester Barbara Beckett City Administrator (636) 391-0600
City of Woodson Terrace Doug Zaiz Director of Public Works (314) 427-2600
St. Louis County Ray Gawlik Storm Water Manager (314) 615-8157
Town of Norwood Court Dennis Callahan Town Clerk & Attorney (314) 764-4500
Village of Bel-Nor Christina Buchek Mayor (314) 973-8866
Village of Hanley Hills Dorothy Matthews Administrative Assistant (314) 725-0909
Village of Marlborough Joy Drennan Village Administrator (314) 962-5055
Village of Riverview Phil Crimi Street Department Supervisor (314) 868-0700
43
Appendix C
MCM4 Co-permittee Ordinance and Regulatory M echanism
Co-Permittee Name Reported Phase II Land Disturbance Program St. Louis County Code
Enforcement Agreement
City of Ballwin Ord. 04-07 No
City of Bellefontaine Ordinance #2079 No
City of Bel-Ridge Ord. 2006-4 Ord. 415.010 No
City of Berkeley Ord. 3809 No
City of Black Jack Ord 971 Yes
City of Breckenridge Hills Ord 1100 No
City of Brentwood Ordinance 4010 No
City of Bridgeton Storm Water Management Program (Ordinance #05-43)No
City of Calverton Park Ordinance 662 Yes
City of Charlack Ord. 08-611 Yes
City of Chesterfield Ord. No. 2801; Chap 31 of Municipal Code No
City of Clarkson Valley Ord 08-003 No
City of Clayton Ord. 5965 Chapter 430 No
City of Cool Valley Ordinance 1128 Yes
City of Crestwood Ordinance 3889, Grading and excavating ordinance.No
City of Creve Coeur Ordinance 5043 No
City of Dellwood Ordinance 1170 Yes
City of Des Peres Ord. 2260, enacted 11-10-2003 No
City of Ellisville Ordinance 2769 No
City of Fenton Ord 3389 Yes
City of Ferguson Ord # 7-225 No
City of Florissant Ord 7358 No
City of Frontenac Ordinance 2010-1621 No
City of Glendale Ord 09-10 Yes
City of Green Park Ord 445-Land Disturbance Code Yes
City of Hazelwood Ord 3910-07 No
City of Jennings Ord. 2149 No
City of Kirkwood Ordinance 9174 No
City of Ladue Ordinance 1950 No
City of Lakeshire Ordinance 862 No
City of Manchester Ordinance 09-1967 Yes
City of Maryland Heights Ordinance 2008-3037 No
City of Moline Acres Ord 993 Yes
City of Normandy Ordinance 594 No
City of Northwoods 07-02 Art. D No
44
Co-Permittee Name Reported Phase II Land Disturbance Program St. Louis County Code
Enforcement Agreement
City of Oakland Ordinance 735 Yes
City of Olivette Ord 2277, Ord 2370, Ord 2395, Ord 2426, Ord 2470 No
City of Overland 2008-29 No
City of Pagedale Ordinance 1321 Yes
City of Richmond Heights Ord. 4965 No
City of Rock Hill Ord 535 Yes
City of Shrewsbury Ord 2444 No
City of St. Ann Ord. 2533 No
City of St. John Ordinance No. 907 No
City of Sunset Hills Ordinance 1613 No
City of University City Ordinance # 7060 Yes
City of Town & Country Ord 4034 No
City of Valley Park Ord 1473 No
City of Vinita Park Ord 21578 No
City of Warson Woods Ordinance 1305 No
City of Webster Groves Ord 8591 No
City of Wildwood Ord 1488 No
City of Winchester City Ordinance 961 No
City of Woodson Terrace Ord 1692 Yes
St. Louis County Ordinance # 25,494 No
Town of Norwood Court Ord 314 Yes
Village of Bel-Nor Ord 859 Yes
Village of Hanley Hills Ordinance 948 Yes
Village of Marlborough Ordinance 05-422 Yes
Village of Riverview Ord 07-18 No
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