HomeMy Public PortalAboutMSDMS4 MCM6 OPERATION
AND MAINTENANCE
PROGRAM FOR
ST4RMWATER POLLUTION
PREVENTION
RICHARD L. UNVERFERTH, MSD DIRECTOR OF ENGINEERING
SIGNATURE[ DATE: 3J2S JZ(
JASON T. PETEREIN, MSD DEC PROGRAM MANAGER
SIGNATURE: �' DATE: -0-
TABLE OF CONTENTS
Chapter 1 - Program Administration .............................................................................................2
Chapter 2 - General Housekeeping, Operation and Maintenance................................................4
Chapter 3 - Vehicle/Equipment Repair and Maintenance Operations.........................................10
Chapter 4 - Vehicle/Equipment Washing....................................................................................14
Chapter 5 - Facility Repair, Remodeling and Construction.........................................................16
Chapter 6 - Cleaning and Maintenance of Driveways and Parking Facilities..............................19
Chapter 7 - Maintenance of Green Space and Landscaping......................................................21
Chapter 8 - Cleaning and Maintenance of Drainage Channels, Storm Sewers and Inlet
Structures...................................................................................................................................24
Chapter 9 - Water Quality Impact Assessment of Flood Management Projects.........................28
APPENDICES ............................................................................................................................30
Appendix 1- Corps of Engineers Regional General Permit (RGP-44).........................................31
Glossary: Definitions of Terms Used In This Document .............................................................34
For More Information…...............................................................................................................38
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Chapter 1 - Program Administration
A. Introduction:
The Missouri Department of Natural Resources (MDNR) issues the Phase II Storm Water
Permit to MSD and 59 other co-permittees in St. Louis County. The area served by the 60 co-
permittees is collectively known as the St. Louis Metropolitan Small Municipal Separate Storm
Sewer System (MS4). One of the minimum control measures in the permit that must be
addressed by the co-permittees includes pollution prevention and good housekeeping for
municipal operations. Specifically, MCM 6 section of the permit requires each co-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.”
A Stormwater Management Plan (SWMP) for the St. Louis Metropolitan Small MS4
Stormwater is implemented under the Phase II permit. As a co-permittee under the state
permit, MSD is bound by the commitments contained in the Plan. The SWMP requires a
model operation and maintenance program template and that each co-permittee implement a
written operation and maintenance program.
This document represents MSD’s adoption of the model program as applicable and tailored to
address MSD’s operation and maintenance of the separate storm sewer system. Where the
operations described in this manual are contracted, rather than performed by MSD
employees, the best management practices (BMPs) will be imposed to the maximum extent
practicable on the contractor through purchasing or contract mechanisms by including BMPs
in the scope of work or job/service specifications. Contractors will be required to obtain all
applicable local/state/federal environmental permits.
B. Policies:
MSD has developed an Environmental Management System (EMS) that outlines a systematic
process that guides MSD’s activities to ensure implementation of environmental requirements
and to encourage the achievement of continuous improvement of environmental compliance.
The environmental policy adopted by MSD is as follows:
MSD is committed to wastewater collection and treatment, biosolids management, and
stormwater management in an environmentally responsible manner by using the 3C’s
listed below. MSD will:
x Comply with all environmental regulations, laws, and standards applicable to
our processes and produced wastes to the best of our capabilities,
x Continually improve MSD’s environmental performance by implementing an
environmental management system through which objectives and targets are
set and reviewed to reduce environmental impacts.
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x Communicate this policy and our environmental performance to MSD
employees, the general public, regulatory agencies, and other MSD
stakeholders.
C. Organization of Manual:
The SWMP prepared for St. Louis County by the Planning Committee contains a detailed
listing of BMP elements that were to be considered when developing a model operation and
maintenance program for the 60 co-permittees. The Planning Committee placed these
elements into nine major categories of municipal operations/activities. All categories, except
recycling facility operations, were included in this program as applicable to MSD operations.
D. Administration:
The individual responsible for administration of the operation and maintenance (O&M)
program is the Assistant Director of Engineering’s Division of Environmental Compliance
(DEC). The Regulatory Affairs section is responsible for ensuring the program is kept up to
date and for ensuring employees are trained on the procedures implementing the program.
Individual departments affected by the sections in this O&M manual are responsible for
implementation in their area of responsibility.
MSD will train all staff associated with activities that can impact pollution in storm water runoff.
Each chapter will identify employees who should be subject to training on that particular
chapter. Employees will receive general storm water pollution prevention training and Best
Management Practices (BMPs) overview. Upon implementation of specific procedures,
management will review the new procedures that incorporate storm water BMPs, proper
waste management and applicable NPDES permit requirements with all employees affected.
New employees will be trained on applicable procedures within the first year of employment.
To maintain proficiency, a schedule of periodic retraining at safety meetings will be
implemented, or provisions made for an employee awareness campaign to ensure employees
remain aware of the BMPs and proper waste management. Records documenting the training
of employees will be maintained by the HR department. Contractors working for MSD and
implementing BMPs for their work, as described in Section A., will be required in the
specification to train their employees on the BMPs and other applicable conditions of the
specification.
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Chapter 2 - General Housekeeping, Operation and Maintenance
A. Description of Activities:
MSD operations include a variety of activities conducted to maintain MSD owned property and
facilities. This chapter will apply to all locations and covers basic housekeeping best
management practices (BMPs) and those that are not specifically covered in the other
chapters of this document. This chapter covers custodial and building maintenance activities,
materials management and storage, safe material substitutions, spill plans, establishment of
general O&M procedures, scheduling, record keeping and housekeeping practices in general.
Subsequent chapters of this document cover BMPs specifically related to the chapter’s topic.
B. Locations:
The following locations are MCM6 applicable reporting centers for MSD employees who
operate and maintain hundreds of pump stations and thousands of miles of sewer.
x Grand Glaize Maintenance Yard, 1033 Grand Glaize Pkwy., Valley Park MO 63088
x Mintert Maintenance Yard, 7500 Mintert Industrial Dr., St. Louis MO 63135
x Sulphur Maintenance Yard, 1900 Sulphur Ave., St. Louis MO 63110
x Lemay Pump Station, 8520 Virginia Ave., St. Louis MO 63111
C. Materials/Supplies acquisition, storage and usage:
For all MSD facility locations covered by this plan, material/supply needs are administered by
Supervisors and planner/schedulers. Equipment and inventory maintained at MSD facilities is
tracked in a managed maintenance system, Maximo. Inventory items and equipment subject
to regulatory programs are identified and tracked in the District’s environmental management
system, EMS.
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D. Waste generation, storage, disposal, recycling:
Standard office waste is generated, along with waste from custodial operations at MSD
locations. Wastes from building and office maintenance activities are disposed in covered
dumpsters located at each location. The dumpsters are currently removed under contract. A
list of these waste collection locations are in the table below.
Trash Containers, Quantities, and Frequency of Pick-up
Location Capacity Quantity Frequency
per Week
Max Weight
per Container
Grand Glaize Maintenance Yard
4 cu. yd.
open top
20 cu. yd.
open top
20 cu. yd.
open top
6 cu. yd.
6 cu. yd.
2
2
2
1
1
As needed
As needed
1
2
4
0.80 ton
0.60 ton
0.60 ton
1.2 ton
1.2 ton
Mintert Maintenance Yard 6 cu. yd. 1 2 1.2 ton
Sulphur Maintenance Yard
8 cu. yd.
6 cu. yd.
4 cu. yd.
2 cu. yd.
1
1
1
1
2
2
2
2
1.6 ton
1.2 ton
0.8 ton
0.4 ton
A list of typical regulated wastes and guidance for the disposal of common wastes are
provided in the Training – Waste Management document and the SOP – MSD Waste
Evaluation document found at
http://insidemsd/engineering/environmentalcompliance/Pages/ComplianceChecklists.as
px.
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E. Best Management Practices (BMP):
FACILITIES:
x Ensure grease traps and oil/water separators in garage and maintenance areas are
maintained. Avoid sanitary sewer grease-blockages or oil releases to sanitary
sewers by regularly pumping out traps and separators.
x Maintain site plumbing plans showing sanitary and storm sewer connections.
Ensure wastewater is discharged only to the sanitary sewer, and storm water to the
storm sewer. Label storm drain inlets to ensure they are used only for storm water
drainage.
x Reduce the risk of West Nile Virus at MSD facilities by reducing stagnant water
(mosquito breeding grounds) caused by cans, containers, tires and debris. MSD
performs routine cleaning of trapped, combined storm sewer inlets as part of regular
sewer maintenance. Refer to MU Extension IPM Guides at:
http://ipm.missouri.edu/pubs/
(See Chapter 7 for additional BMPs.)
x In plant operation, reduce standing water, such as in out-of-service basins, tanks,
containment, etc. Before draining accumulated water in containment areas, inspect
water for contamination prior to discharging to surface water. If contaminated,
contact DEC to evaluate disposal.
x Inspect for pests prior to application of any pesticides or herbicides. Apply as a
point of use application whenever possible. Broadcast applications are used only
when needed. Use nonchemical pest control practices, such as mechanical and
biological controls, when possible, or less toxic products when needed. Purchase
chemicals according to MSD’s environmental procurement procedure. Contractors
utilized for these services must comply with these BMP’s.
x Minimize the use of herbicides for weed control. With turf grass, prevention of weed
infestation begins with practices to promote healthy grass through proper planting,
watering, fertilizing, mowing, aerification, and thatch control. Contractors utilized for
these services must comply with these BMP’s. Refer to MU Extension Publication
IPM1009: https://extension2.missouri.edu/mx399
(See Chapter 7 for additional BMPs.)
x
MATERIAL MANAGEMENT:
x MSD has developed a procedure to encourage the purchase environmentally
friendly products and services. This procedure is included in the Appendix to this
program.
x Reduce waste with source reduction, preventing the generation of waste, and reuse
products when practical.
x Evaluate waste disposal by
considering recycling or energy
recovery options. Collect and
recycle the following wastes
generated from operations: electronic devices (CRT monitors plus PCs, printers,
circuit boards), lead-acid batteries, nickel-cadmium and other recyclable batteries,
d i (CRT it l PC i t
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light bulbs, mercury switches, off-spec fuel, organic solvent, scrap metal, tires, and
used oil.
x Provide for the proper disposal of all wastes generated or collected in the course of
operations, in accordance with all applicable local, state and federal laws.
x Inspect facilities for litter on a regular basis, and clean up as needed.
x Keep trash container lids closed to keep rain out. Do not dispose of liquid waste in
any trash container.
x Ensure that the collection frequency of trash containers is appropriate to avoid
overflows from the containers.
x Outdoor material stockpiles at both permanent locations and at job sites should be
covered to protect from rainfall and prevent contamination of storm water runoff.
x Material stockpiles which cannot feasibly be covered should be surrounded by a
berm or otherwise contained so that storm water runoff can be captured.
x Petroleum products, fuels, chemicals, hazardous and toxic materials, and all wastes
should be labeled, stored and handled with appropriate safeguards. These
safeguards are to prevent contamination of storm water from drips and spillage from
the transfer of materials (for example, cover storage containers, use collection trays
for drips, maintain spill kits and floor drain plugs to contain spills, etc.). Liquid
containers should be stored under roof; or if outdoors, containers should be kept
clean and sealed water-tight.
x Prevent spills of hazardous materials by selecting storage areas that avoid traffic to
minimize accidental contact, and select areas that are away from storm drain inlets
and streams to minimize the impact of a leak or spill. Storage areas should be kept
clean and organized.
x Contain and clean up all spills immediately.
Ensure employees are familiar with spill
response procedures and the location of spill
kits to enable them to stop the spills at the
source and contain the spilled material. With
training on hazards listed on a material safety
data sheet (MSDS), minor spills can be
addressed by employees, however, significant
spills will require evacuation and contacting
emergency responders.
x Keep MSDS for chemicals onsite for
information on reportable spill quantities, proper handling, and health and safety
issues. MSDS’s for products used by MSD are available on the intranet at:
http://insidemsd/
x Maintain and post a list of emergency contact numbers for spill reporting and spill
clean-up contractor response. Employees will call the MSD Dispatcher, who will
notify:
-Operations Management
-Risk Management
-DEC, who will obtain a spill contractor and notify appropriate agencies:
Missouri Department of Natural Resources (MDNR) – 573-634-2436,
National Response Center – 800-424-8802,
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x Reportable quantities (RQ) for chemicals are listed on the MSDS, and petroleum
RQs include: any amount released to a storm sewer or waterway causing a sheen,
25 gallons from an underground tank, and 50 gallons from all other sources. RQs
for other common MSD chemicals and wastes can be found in the Training –
Chemical Response, Training – Stormwater BMPs & Good Housekeeping and
Training – Spill Prevention, Control & Countermeasure (SPCC) documents:
http://insidemsd/engineering/environmentalcompliance/Pages/ComplianceChecklist
s.aspx
x Prepare for appropriately handling the clean-up of the spilled material and disposal
of waste. Do not hose down spills to the storm sewer system. Clean up spills with
dry methods, using absorbent to pick up fluids.
x Spill Prevention Control and Countermeasure (SPCC) plans are required to meet
regulatory criteria in 40 CFR 112 for sites with a storage capacity of more than
1,320 U.S. gallons in total of all aboveground containers (only counting containers
with 55 gallons or greater storage capacity) or more than 42,000 U.S. gallons in
completely buried containers and could reasonably be expected to discharge oil to
navigable waters of the U.S. or adjoining shorelines such as lakes, rivers, or
streams.
x Establish at all MSD facilities, materials management and inventory controls to
include the proper identification of hazardous and non-hazardous substances, and
proper labeling of all containers. Specific regulated wastes are identified in MSD’s
EMS intranet site and at
http://insidemsd/engineering/environmentalcompliance/Pages/ComplianceChecklist
s.aspx.
COMMUNITY:
x DEC’s Phase II program educates
citizens on trash, pet waste and other
nonpoint source pollution issues to
promote compliance with MSD and
municipal ordinances using available
methods such as brochures, internet
sites, social media, classroom
presentations, public event participation,
educational workshops, etc.
x DEC’s Phase II program participates with
the general public, schools, watershed
groups, stream teams and others by promoting and assisting in neighborhood and
stream clean-up activities (addressing trash and invasive species), and storm drain
marking projects.
x DEC inspects open channels and takes appropriate action to enforce MSD
Ordinance 15048 or refers to appropriate health departments to enforce against
illegal discharges to storm water from sources such as septic tanks discharging to
storm water, and other illegal discharges to stormwater.
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O&M PROGRAM:
x Departments and facilities should incorporate the BMPs in this program manual into
applicable standard operation and maintenance procedures, such as maintaining
equipment and vehicle preventative maintenance schedules in Maximo.
x Annual facility inspections will be assigned and tracked in the EMS to ensure
compliance with the general housekeeping BMPs in this manual. More frequent
inspection schedules will be established if warranted by findings in the annual
inspection. Facility management should be aware of general housekeeping issues
and correct problems as they arise.
x DEC and applicable Departments must maintain records that effectively track
implementation of this program and that provide the information necessary to meet
the documentation and reporting requirements of the MS4 permit.
F. NPDES Permit status:
Applicable MDNR general storm water permits must be obtained if MSD engages in the
following activities described by the following categories:
Equipment/Vehicle Washing (G75, See also Chapter 4) - Car wash wastewater
treatment systems for design flows of 50,000 gallons per day or less. This includes no-
discharge land application systems. Provides for 500 gallons per day de minimus
exemption under certain conditions.
Vehicle Maintenance (R80C, See also Chapter 3) - Motor freight transportation and
warehousing.
Permitting was addressed by DEC when the Phase II stormwater permit was received
in 2003. No general permits were required and vehicle maintenance was identified with
no exposure to stormwater. However, any changes in operations must be reevaluated
for applicable permits and reporting.
G. Training:
All MSD employees involved in maintenance operations, construction, facility or site
design, and building/warehouse management will be trained on the BMPs in this
chapter.
In addition to training on the housekeeping BMPs and proper waste management, MSD
employees will be provided general awareness of NPDES discharge requirements.
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Chapter 3 - Vehicle/Equipment Repair and Maintenance Operations
A. Description of Activities:
Fleet maintenance facilities at MSD are responsible for the maintenance and repair of
equipment and vehicles ranging from chain saws and light vehicles to loaders and tandem
dump trucks. Preventative maintenance or PM’s include oil and filter changes, tune ups and
tire rotations. Repairs include engine and transmission replacement; brake, suspension or
axle repair; and welding work. There are fueling sites at many of MSD’s facilities. Outside
contractors perform services such as glass repair or replacement and all bodywork.
B. Locations:
MSD has fleet vehicle maintenance facilities located at:
x 1025 Grand Glaize Parkway
x 900 Sulphur Avenue
x 7500 Mintert Industrial Drive
The above locations perform vehicle and equipment maintenance for the operations
department. The fleet maintenance facilities are currently responsible for 507 assets. 486 of
those assets are managed by MSD shops, and the other 21 assets are outsourced for
maintenance. The main garage at Sulphur has six (6) working bays, and both the Grand
Glaize and Mintert garage have two (2) bays. The majority of repair and maintenance work is
done inside; however, due to the difficulty in moving certain pieces of equipment, some work
is done outside or at the job site. The materials/supplies used at this facility are all stored
inside, except for several small above ground storage tanks which are stored under cover and
in secondary containment. Equipment maintenance by MSD employees occurs at all
wastewater treatment plant and pump station maintenance locations. Petroleum and oil
storage locations are identified below, and will be tracked in the EMS.
Fueling facilities from underground storage tanks (UST) are located at the following MCM6
applicable facilities:
x 1033 Grand Glaize Parkway
x 7500 Mintert Industrial Drive
x 1900 Sulphur Avenue
Additionally, petroleum and oil above ground storage tanks (AST) are located at the following
facilities:
x 2156 Creve Coeur Mill Road
x 1033 Grand Glaize Parkway
x 1900 Sulphur Avenue
x 1100 South Wharf Street
x 200 Thatcher Avenue
x 8520 Virginia Avenue
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C. Responsible Parties:
The Fleet Operations Supervisor oversees all aspects of fleet and facilities administration and
some of the day-to-day operations with the rest being administered by our two (2) Fleet Team
Leaders. Sulphur Garage has one (1) Fleet Team Leader, four (4) Fleet mechanic Sr., and
one (1) Fleet mechanic helper II. Grand Glaize Garage has one (1) Fleet Team Leader and
four (4) Fleet mechanic Sr. Mintert Garage, administered by Sulphur Garage Fleet Team
Leader, has two (2) Fleet mechanic Sr.
D. Materials/Supplies acquisition, storage and usage:
Materials /supplies for all locations are ordered through the main garage and delivered directly
to each location. The quantity of materials in stock are maintained in MSD’s inventory control
system known as Maximo.
The underground fuel tanks meet all 1998 UST standards and are insured by the Missouri
Petroleum Storage Tank Insurance Fund (PSTIF).
E. Waste generation, storage, disposal, recycling:
Waste generated by operations at all locations including treatment plants and garages are
included in waste evaluation guidance documents located at
http://insidemsd/engineering/environmentalcompliance/Pages/ComplianceChecklists.aspx.
Regulated waste streams are tracked in the EMS and guidance for the disposal of common
waste is located at
http://insidemsd/engineering/environmentalcompliance/Pages/ComplianceChecklists.aspx.
F. Best Management Practices (BMP):
OPERATIONS:
x A preventive maintenance program to minimize fluid leaks and equipment failures has
been established and is tracked using the Maximo system. Operators and mechanics
should be conscientious of leaking oil and other fluids by inspecting vehicles and
equipment frequently for leaks, collecting leaks with pans or absorbent and repairing
leaks.
x Most routine vehicle maintenance and repairs at MSD facilities are performed indoors.
On occasion and when necessary, outside maintenance work will be performed in a
paved area with provisions made to contain and clean up all drips and spills.
x MSD will use non-hazardous, environmentally safe products when possible. MSD will
avoid the use of chlorinated organic solvents.
x All supply material and waste containers are marked clearly and properly to identify the
contents.
x Material safety data sheets (MSDS) for chemicals with information on reportable spill
quantities, proper handling and health and safety are found at http://insidemsd/.
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x All supply material and waste containers are stored under cover to prevent contact with
rainfall; or when uncovered, containers are clean and sealed.
x Tops of containers have absorbent mats, as
needed, and are free of standing liquid, and
stored containers are kept closed.
x Waste oils, filters, antifreeze, and other wastes
are collected in designated, labeled containers
and managed according to the Material
Management section in Chapter 2.
x Records of waste pick-ups are logged and
maintained in file.
x Drain pans are labeled for specific types of
fluid. Use pans under vehicles and equipment
with fluid leaks. Always use drip pans when
making and breaking connections.
x Used oil filters should be gravity drained for 24 hrs with the anti-drain back valve or
filter dome punctured to facilitate the draining process. Crushing the oil filter and
recycling is preferred.
x Batteries, waste oil, etc. having spill/leak potential are stored indoors or in designated
tanks, and are in secondary containment, when possible.
x Neutralizer and absorbent are kept near both new and used batteries.
x All floors are clean of oil and grease.
x Immediately clean up all spills of chemicals or vehicle fluids using dry methods
(absorbents), minimizing the use of water whenever possible.
x Vehicle operators should remain with the vehicle during fueling, and not to top-off the
fuel tank to avoid overflows and spills.
x For painting or sanding activities outdoors, use a tarp enclosure to contain and capture
material. Collect and dispose of paint chips and sand blast waste in the trash for
non-lead based paint, or evaluate potential lead-based paint for hazardous waste
disposal.
x Keep the facility and surrounding area clear of litter.
SPILL PREVENTION:
x Spill control plans should be in place with procedures for proper spill response to
minimize environmental impacts. SPCC plans must meet regulatory criteria in 40 CFR
112 for sites with an aggregate aboveground storage capacity exceeding 1,320 gallons
(excluding those tanks and oil-filled equipment below 55 gallons in capacity) or if the
aggregate underground storage capacity of the facility exceeds 42,000 gallons
(excluding those that are currently subject to all the technical requirements of 40 CFR
Part 280 or all of the technical requirements of state programs approved under 40 CFR
Part 281) and if, due to its location, the facility could reasonably be expected to
discharge oil into or upon the navigable waters or adjoining shorelines of the United
States.
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x In areas where spills could occur, such as fueling and loading areas, keep spill kits with
absorbent materials nearby and display signage indicating the location of those spill
kits. Storm drain plugs or covers can be used to prevent the flow of spilled material
from entering the storm drain.
x For fueling areas, post signs that state “Do not leave vehicle unattended” and “No
topping off”.
x Maintain equipment to ensure the physical integrity of tanks and containers, proper
operation of automatic shutoff devices on pumps, and overfill protection and spill
buckets on tanks.
x Emergency phone numbers are clearly posted at phones near material storage areas
and fueling areas.
FACILITY:
x In new construction, all floors in work areas will be sloped to floor drains that are
connected to an MSD approved sediment /oil trap prior to discharge into the sanitary
sewer system. New and existing traps will be pumped out as needed.
x A site-plumbing schematic showing all drains, traps, and shut offs for utilities should be
maintained in the shop. Employees should be made aware of sanitary and storm
sewers to ensure all wastewater is discharged to the sanitary sewer.
x Storm drains/inlets can be labeled to help protect from improper usage.
x In future improvements, fueling areas are recommended to be designed with a roof to
prevent contact with storm water. The area should be graded and sloped to direct
storm water runoff away from the site and to prevent runoff from flowing over the
fueling area.
G. NPDES (National Pollutant Discharge Elimination System) Permit status:
Vehicle maintenance facilities of this type are considered “municipal / industrial” facilities
under the Missouri Storm Water Regulations and are subject to separate NPDES storm water
(Phase I) permitting requirements under MDNR general permit R80C. As stated above, all of
MSD vehicle repairs and maintenance are preformed indoors or are otherwise done without
exposure to storm water. Therefore, a NPDES Storm Water permit is not required and the
MS4 application indicated that these operations were not exposed to stormwater.
H. Training:
Training on storm water BMPs will be provided to mechanics, storekeepers, material handlers,
laborers, equipment operators, and management staff working at facilities identified in Section
B. All employees will be provided safety training in monthly safety meetings to periodically
include required environmental training and HAZMAT training.
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Chapter 4 - Vehicle/Equipment Washing
A. Description of Activities:
MSD will wash vehicles and equipment at designated wash bay facilities designed according
to this chapter. At MSD facilities where no wash bay exists, all vehicles and equipment will be
taken to commercial facilities when washing is required.
B. Locations:
The MSD wash bay facilities are located at the following locations:
Grand Glaize Yard - 1033 Grand Glaize Parkway
North Yard - 7500 Mintert Industrial Drive
Sulphur Yard - 1900 Sulphur Avenue
General Grant’s Car Wash – 8344 Watson Rd is the designated commercial
car wash for pool cars
C. Responsible Parties:
The Operations Division Manager responsible for a facility is responsible for ensuring that
vehicles are taken off-site to approved commercial facilities for washing, or that washing on
MSD property is done in the locations specified in Section B.
D. Materials/Supplies acquisition, storage and usage:
The specification for wash soap to be used should include non-phosphate, biodegradable
detergent.
E. Wash bay design and waste disposal:
Wash water from vehicle and equipment washing must be disposed in the MSD sanitary
sewer, with pretreatment using a sediment/oil trap. The accumulated solids in the
sediment/oil trap must be pumped out and properly disposed of, such as at a wastewater
treatment plant by an MSD approved waste hauler. If floating oils and grease accumulate in
the sediment/oil trap, the contents must be disposed by a permitted waste hauler at a
commercial facility able to handle oily waste.
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F. Best Management Practices (BMPs):
(FOR OFF-SITE WASHING)
x All vehicles are taken to designated commercial facilities when washing is needed.
(FOR MSD WASHING)
x Wash bay facilities are designed to collect wash water, pretreat with a sediment/oil trap
(interceptor), and discharge to the sanitary sewer system. The trap must be pumped as
needed.
x Wash bays should be curbed or otherwise sloped to prevent storm water runoff from
flowing onto the wash pad and discharging to the sanitary system.
x Mobile wash services must collect wash water for recycling or proper disposal into a
sanitary sewer.
x Job-site mud removal is performed without detergent in a contained, permeable (gravel)
area with wash water infiltrating into soil or gravel.
G. NPDES Permit status:
N/A. MSD does not hold a General Permit G75 for vehicle or equipment wash wastewater.
H. Training:
MSD employees responsible for operating and maintaining fleet vehicles and equipment will
be made aware of BMPs regarding washing, and the proper, designated locations for
washing.
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Chapter 5 - Facility Repair, Remodeling and Construction
A. Description of Activities:
On an as-needed basis, MSD personnel perform minor renovations/repairs and small capital
improvements on facilities, such as erecting or removing partitions, replacing a door or
window, painting, etc. Major projects are typically contracted out to commercial firms
specializing in the type of work required. This chapter would also apply to sewer related
construction.
B. Locations:
MSD Sulphur Yard contains a shop and material storage areas for facility repair, remodeling
and construction; and MSD employees are involved in these activities. Repair, remodeling,
construction and capital improvements are periodically performed on all types of MSD facilities
by MSD employees from treatment plants and the collection system yards. Outside
contractors are typically used for larger projects.
C. Responsible Parties:
The Operations Division Managers are the responsible parties that will ensure all repairs,
remodeling and construction will be performed without subjecting the stormwater system to
any new contaminant streams. Engineering Program Management is responsible for the
construction practices of the contractors that work on MSD facilities.
D. Materials/Supplies acquisition, storage and usage:
Varies with nature of job. Materials are purchased on an as-needed basis and in quantities
expected to be completely consumed in the process of completing the project. The majority of
materials are purchased on a project basis and are consumed during that project. Materials
that can pollute stormwater should be stored indoors or under cover so they are protected
from rainfall and runoff. All unused portions of materials should be properly secured to
prevent loss, such as bagged cement. The yards store sand and gravel for sewer
construction and repair.
E. Waste generation, storage, disposal, recycling:
Waste generation varies with the nature of the job. Typically, wastes consist of small amounts
of lumber cut-offs, wallboard scraps, empty paint cans, etc. Order and mix only the amount of
materials necessary for the work to be completed. Dispose of all waste properly, and recycle
whenever possible. Never bury waste material or leave material in the street, gutter, or near a
creek or streambed that would allow the material to enter the storm water system. Such
materials are disposed in the MSD maintenance dumpster for pick-up by the contracted waste
hauler. Clean up of equipment is to be performed in designated areas. Never clean up
concrete mixers and equipment or paint brushes where the washout enters the street, storm
drains, drainage ditches, or streams.
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Leaks, drips, or spills should be cleaned up immediately. Clean up using “dry” methods,
absorbent materials or rags, or remove the contaminated soil or material.
F. Best Management Practices (BMP):
FACILITY DESIGN:
x Consider designing facilities for “Low Impact Development” to reduce the volume and rate
of storm water runoff from impervious areas to improve water quality. Refer to information
on Low Impact Development from EPA’s web site at: https://www.epa.gov/nps/urban-
runoff-low-impact-development for more information about Low Impact Development
methods.
x In designing storm water drainage facilities, use the following BMPs, in accordance with
MSD’s storm water drainage facility design regulations, to improve the water quality of site
drainage: wet detention ponds, wetlands, structural filter systems, open channel grass
swales, vegetative filter strips, and riparian buffers along streams. MSD’s design
regulations are contained in the “Rules and Regulations and Engineering Design
Requirements for Sanitary Sewage and Stormwater Drainage Facilities”.
x Carefully design and install plumbing and storm water systems to code, eliminating cross-
connections between sanitary and storm drain systems that are discovered.
x Design material storage and handling areas to avoid rain and storm water runoff contacting
stored material.
x Consider landscaping designs that use native vegetation to reduce the need for irrigation,
fertilizer and pesticide.
LAND DISTURBANCE:
x Comply with MSD’s Land Disturbance Permit MO-R100010. For projects less than the
land disturbance permit thresholds, minimize water quality impacts by complying with
relevant Standard Construction Specifications: keep work sites and haul routes clean from
debris, excavated material shall not obstruct gutters or stormwater drainage, and excess
material shall not be deposited in a stream. Restore site and working areas to their
original conditions as soon as possible. Protect stream banks that are to remain
undisturbed, restoring damaged areas to original condition.
x All construction or maintenance activities that excavate in or discharge any dredge or fill
material into a “water of the United States” requires a Corps of Engineers 404 permit and a
MDNR 401 water quality certification. Waters of the United States include ditches, creeks,
rivers, lakes, ponds and wetlands. See Appendix 3 for a summary of permit requirements.
CONSTRUCTION/REMODELING:
x In accordance with MSD purchasing procedures as stated in Chapter 2, every effort is
made to purchase materials that are manufactured with recycled materials.
x Properly store materials as far away from storm inlets and streams as practical, and cover
stored materials to avoid storm water impacts.
x Small quantities of inert demolition wastes and construction scraps are disposed in MSD
dumpsters. If larger quantities are generated, arrangements are made with a MSD
contracted hauler for a special pick-up.
x Keep work sites clean, pickup trash that can be wind blown daily.
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x Utilize certified asbestos inspectors to inspect floor tile, ceiling tile, fire-proof barriers and
doors, roofing material and insulating materials for asbestos content prior to demolition.
Manage material using certified asbestos personnel.
x Utilize certified inspectors to inspect for lead based paint on structures older than 1978.
Use only state certified removal contractors for lead based paint abatement.
x When scraping or washing to remove non-lead based paint, collect paint chips in a tarp for
proper disposal. Use water-based paint instead of oil-based paint whenever possible.
x Ensure that facility plumbing connects all sanitary wastewater discharges to the sanitary
sewer, and that storm water is sent to the storm sewer system.
G. NPDES Permit status:
Land disturbance projects over 1 acre require a Land Disturbance Permit MO-R100 from the
MDNR. Stormwater operating permits will not apply unless process or wastewater will be
discharged to storm water and not to the sanitary sewers.
H. Training:
All MSD employees involved in facility construction, facility repair and remodeling activities will
be trained on the BMPs presented in this chapter. Personnel should be trained in the items
noted below:
General housekeeping
Material storage, cleanup, and disposal
Material reuse and recycling
Equipment cleanup
Land disturbance erosion control
Reduction of material for disposal through storage, reuse, or recycling can greatly reduce
material and disposal costs, long term liability, preserve environmental quality, and provide a
positive public image.
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Chapter 6 - Cleaning and Maintenance of Driveways and Parking Facilities
A. Description of Activities:
MSD is responsible for the cleaning and maintenance of driveways and parking facilities at its
facilities. MSD has a limited amount of activity in this area, but activities may include street
sweeping, flushing, applying surface seals, patching, and snow removal. Patching operations
involve the preparation of potholes and the fill of either hot mix or cold patching material, or
pouring concrete.
B. Locations:
All driveways and parking lots at MSD facilities.
C. Responsible Parties:
The Operations Division Managers are responsible for their facilities.
D. Materials/Supplies Acquisition, Storage and Usage:
Materials are purchased as needed for repairs. Salt is purchased for deicing in winter. MSD
and MSD hired contractors will store and handle materials on MSD property in a manner to
reduce their impact to storm water contamination.
E. Waste Generation, Storage, Disposal, Recycling:
No large volume, routine waste streams are generated. A list of typical regulated wastes and
guidance for the disposal of common wastes are provided in the Training – Waste
Management document and the SOP – MSD Waste Evaluation document found at
http://insidemsd/engineering/environmentalcompliance/Pages/ComplianceChecklists.aspx
F. Best Management Practices (BMP):
MAINTENANCE:
x If certain road maintenance activities are prone to produce pollutants that can be
carried off with storm water runoff, schedule these maintenance activities during times
of dry weather if possible.
x On asphalt overlays, ensure storm water drainage capacity of curbs and inlets is
maintained by milling down into the street at the curb, or using open graded thin
bonded overlay.
DE-ICING:
x Minimize the use of salt without compromising safety. Plow snow before applying salt.
x Apply product evenly and do not exceed the application rate indicated in the
instructions.
x Check parking lots for excessive application.
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x Store salt on an impervious surface and cover.
x As available, use road weather information such as weather forecasts and
meteorological data to maximize the efficiency and effectiveness of resources.
CLEANING:
x Remove as much mud, grit, salt and debris as possible using dry methods (by
scraping, brooming, etc.) prior to roadway flushing.
x Evaluate the need for street sweeping to remove grit and trash at facility parking lots
and driveways.
x Do not hose down parking lots in a manner that discharges wash water to the storm
drain untreated.
G. NPDES Permit status:
Not Applicable
H. Training:
MSD employees and contractors involved in driveway maintenance and repair will be trained
on the BMPs in this chapter.
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Chapter 7 - Maintenance of Green Space and Landscaping
A. Description of Activities:
MSD owns 159 parcels of property in St. Louis County and 220 parcels of property in St. Louis
City. MSD has responsibility for the development and maintenance of green space in
conjunction with the operations of treatment plants and lift stations. The parcels of property
owned by MSD comprises of 1,215 acres In St. Louis County and 641 acres in St. Louis City .
The green spaces include trees and facility landscaping.
The creation and design of green space can assist in management of storm water by
providing green infrastructure and a means of absorbing rainwater, slowing its release into
streams, storing, filtering and slowing storm water runoff down and thus preventing or
reducing flash flooding downstream. MSD has an opportunity to use their green space to
benefit the environment and to demonstrate best practices for storm water management.
Maintenance activities include mowing of grassy areas, pruning trees, removing fallen limbs,
mulching, emptying trash receptacles, and parking lot maintenance.
B. Locations:
Green spaces are interlaced throughout the District and are maintained by MSD staff as
necessary.
C. Responsible Parties:
The Director of Operations has authority over District green spaces. MSD maintains many
contracts for lawn care services.
D. Materials/Supplies acquisition, storage and usage:
Only small quantities of materials are maintained for landscaping and green space
maintenance operations.
E. Waste generation, storage, disposal, recycling:
Wastes generated by landscaping maintenance operations are included in waste evaluation
guidance documents at
http://insidemsd/engineering/environmentalcompliance/Pages/ComplianceChecklists.aspx.
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F. Best Management Practices (BMP):
GREENSPACE DESIGN AND SITING:
x Creating undeveloped, natural open space and preserving established trees and other
natural vegetation, particularly around natural drainage areas, such as creeks, is
recommended. Tree buffers and tall grass filters around streams improve water quality,
slow runoff and prevent erosion. A minimum buffer width of 50 feet is recommended.
x When practical, avoid site development and placing facilities in the flood plain.
x Design sites to preserve natural resources such as wetlands and existing natural draining
areas, minimizing their loss and maintaining existing trees and a riparian corridor next to
creeks to the degree possible. Minimize creek crossings, and place them only after
consideration of the stream features to enable natural flow.
x Design landscaping that uses native vegetation to reduce the need for irrigation, fertilizer
or pesticides. Select plants appropriate for site conditions for sun, moisture, and soil type.
x Utilize low impact development to minimize impervious surfaces, See Chapter 5.
x In designing storm water drainage facilities, use the following BMPs, in accordance with
MSD’s storm water drainage facility design regulations, to improve the water quality of site
drainage and slow the release of water to streams: wet detention ponds, wetlands,
structural filter systems, vegetative filter strips and riparian buffers along streams, pervious
pavement or green (vegetated) roofs. The use of open channel swales instead of curbs
along roads and parking lots is beneficial to filter pollutants and reduce the volume and
rate of storm water flow. MSD’s design regulations are contained in the “Rules and
Regulations and Engineering Design Requirements for Sanitary Sewage and Stormwater
Drainage Facilities”.
LANDSCAPE MAINTENANCE:
x Remove litter and debris regularly.
x Mow grass higher and leave grass clippings on the lawn to retain moisture and nutrients.
x Properly dispose of yard waste, for example, by composting. Do not dump yard waste into
creeks.
x Minimize mowing of open space sites, depending on site objectives.
x Remove exotic invasive vegetation and replace with native plantings as resources are
available.
x Determine and use the optimum fertilizer application rate.
x Apply fertilizer only in cool weather, preferably fall. Avoid application before a rain, and do
not apply fertilizer at rates higher than indicated in on label instructions. Apply slow
release fertilizers such as methylene urea, IDBU or resin coated fertilizer.
PESTICIDE/HERBICIDE USE:
x When pesticide or herbicide use is required, select pesticides carefully, avoiding highly
water soluble and very environmentally stable products to minimize potential for leaching
from soils into waterways. Environmentally friendly products readily degrade in the
environment and/or bind to soil particles. Contractors utilized for these services must be
appropriately licensed/certified and comply with these BMP’s.
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x Minimize the use of herbicides for weed control. This includes practices that keep plants
healthy, such as selecting disease and pest resistant varieties and maintaining good
growing conditions. For turf grass, prevention of weed infestation begins with practices to
promote healthy grass through proper planting, watering, fertilizing, mowing, aerification,
and thatch control. Refer to MU Extension Publication IPM1009:
https://extension2.missouri.edu/mx399
x Pesticide application should be timed carefully and combined with other pest management
practices. Pests and their development stage should be identified accurately and pesticide
applications made only when necessary, using the least amount needed and the least
toxic product for adequate pest control.
x Read pesticide labels carefully for information and restrictions about the rate, timing, and
placement of the pesticide in that container. Calibrate equipment to apply at the proper
rate. Apply when the threat of rain is low to avoid wasting material and washing pesticide
into waterways. Carefully calculate how much pesticide concentrate is needed to treat the
specific site with the equipment being used, to eliminate disposal of excess spray mix.
x Store pesticides in their original containers in a cool, well-ventilated building with a
concrete floor. Handle pesticides carefully to avoid spills.
x Dispose of pesticide waste properly, following label instructions.
x Use mechanical controls to keep pests in check, such as species specific, pheromone
based traps. Eliminate conditions favorable to pests and place barriers to control pests
and weeds.
x Use natural, biological controls, when practical, including natural enemies of pests, such
as: predators, parasites, pathogens, pheromones, and juvenile hormones.
G. NPDES Permit status:
Not applicable
H. Training:
All employees directly involved in the design, construction and maintenance of landscaping,
and green spaces will be trained on the BMPs in this chapter. Affected employees will likely
be: facility engineers, equipment operators, gardeners, laborers, and contract operations
providing these services.
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Chapter 8 - Cleaning and Maintenance of Drainage Channels, Storm
Sewers and Inlet Structures
A. Description of Activities:
The storm drainage system functions to collect and convey surface runoff to receiving waters
during storms in order to prevent flooding. The system consists of improved and unimproved
drainage channels, culverts, bridges, trench drains, gutters, ditches, swales, storm sewers
and storm inlet structures. Maintenance of the system is necessary to ensure it functions
hydraulically as intended. MSD has the major responsibility for the cleaning and maintenance
of improved channels and storm sewers in the Plan Area. Maintenance responsibilities are
defined in MSD’s “Statement of Policy for Maintenance of Stormwater Sewer Systems and
Facilities”. Many of the co-permittees are responsible for maintaining the storm sewer
systems on their property and on systems not dedicated to the MSD system. In addition,
municipalities are responsible for maintaining bridges, storm culverts, ditches and gutters
along the streets in their city. MSD does maintain road inlets and culverts on systems
dedicated to MSD. MSD does not maintain detention and retention basins or yard swales.
Maintenance of basins and yard swales is the responsibility of property owners, as addressed
in MSD’s “Rules and Regulations and Engineering Design Requirements for Sanitary Sewage
and Stormwater Drainage Facilities”.
B. Locations:
The MSD separate storm system includes approximately 3,000 miles of storm sewers and
1,390 miles of open natural drainage ditches and channels. All structures are identified on
facility base maps. The number of catch basins on the separate storm system is
approximately 48,000. Generally, the inlets on the storm system are not constructed with
traps to capture oil, grease or debris.
C. Responsible Parties:
Position Employee Telephone
Director of Operations Bret Berthold (314) 768-6356
Grand Glaize Yard, Division Manager Edward Laux (636) 861-6759
Mintert Yard, Division Manager John Welch (314) 646-2040
Sulphur Yard, Division Manager Debra Aylsworth (636) 861-6758
Director of Engineering Rich Unverferth (314) 768-6204
D. Equipment/Materials/Supplies acquisition, storage and usage:
MSD has numerous Vactors for cleaning inlets and hydroflush units for cleaning storm
sewers. Hoist trucks and front end loaders for maintenance in channels. Contractors are
used for clearing brush blockages.
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E. Waste generation, storage, disposal, recycling:
Wastes generated from maintenance of the storm drainage system must be disposed of
properly. All waste being disposed of in a landfill must not contain free liquid. Water draining
from waste destined for a sanitary landfill is considered wastewater and must be disposed of
in a sanitary sewer system. A list of typical regulated wastes and guidance for the disposal of
common wastes are provided in the Training – Waste Management document and the SOP –
MSD Waste Evaluation document found at
http://insidemsd/engineering/environmentalcompliance/Pages/ComplianceChecklists.aspx.
The following MSD locations are used for the disposal of grit generated from the collection
system:
Sanitary & Combined Sewer Grit – Bissell WWTP only
Storm Sewer Grit – Sulphur Maintenance Yard, Grand Glaize Maintenance
Yard or Bissell WWTP
F. Best Management Practices (BMP):
GENERAL:
x Within budgetary constraints and responsibilities, perform preventative maintenance of
the storm drainage system to remove flow obstructions to reduce flooding and erosion
problems and improve water quality.
x Utilize care in cleaning catch basins, storm sewers and drainage channels, to properly
collect and dispose of waste as indicated in Section E to minimize contaminants
discharged into storm water. When possible, focus cleaning efforts before rainy
seasons and in consideration of major public events.
x If storm inlets/catch basins, storm sewers and drainage channels are impacted by
non-storm water discharges or illegal dumping of waste, contact DEC at 314-436-8710
for investigation and enforcement.
x Identify failing detention or retention basins and report them to MSD Customer Service
at 314-768-6260.
x Comply with the MSD Projects Land Disturbance Storm Water Permit MOR100010 for
all projects disturbing over 1 acre, requiring a storm water pollution prevention plan,
erosion and sediment control, and periodic inspections. For projects less than the land
disturbance program thresholds, minimize water quality impacts by complying with
relevant Standard Construction Specifications: keep work sites and haul routes clean
from debris, excavated material shall not obstruct gutters or stormwater drainage, and
excess material shall not be deposited in a stream. Restore site and working areas to
their original conditions as soon as possible. Protect stream banks that are to remain
undisturbed, restoring damaged areas to original condition.
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DRAINAGE CHANNELS:
x All construction or maintenance activities that excavate in or discharge any dredge or
fill material into a “water of the United States”, which includes ditches, creeks, rivers,
lakes, ponds, and wetlands, requires a Corps of Engineers 404 permit and a MDNR
401 water quality certification. Examples of construction or repair activities requiring a
permit include: sewer creek crossings, outfall structures, stream bank stabilization, and
all channel modifications. See Appendix 3 for a summary of permit requirements.
x Consider downstream conditions prior to spot channel stabilization efforts to avoid
simply moving problems downstream. Revegetate stabilized areas that were not
previously lawn areas with native plants whenever possible, and as soon as possible.
x DEC will inspect all open drainage channels under its Illicit Discharge Detection
Program, and will notify MSD’s Operations Department, St. Louis County, the
municipality or MoDOT, as applicable, regarding maintenance needs concerning
damaged structures or blockages requiring removal.
CATCH BASINS:
x As enabled by funding, move from a reactive
maintenance program for catch basins, to a
scheduled, routine maintenance program, and finally,
begin to prioritize planned maintenance activities
through a process of analyzing data collected.
Identify areas for additional maintenance to coincide
with litter from major public events, and based on
work orders generated by customer complaints
and/or flooding. Increase or reduce maintenance of
inlets based on the quantity of trash or debris identified during previous maintenance.
STORM SEWERS:
x As enabled by funding, move from a reactive maintenance program for storm sewers,
to a scheduled, routine maintenance program, and finally, begin to prioritize storm
sewer maintenance on a specified frequency based on analyzing data collected, such
as, flat grades, low flow, review of work orders, and/or review of customer complaints.
x Utilize care in cleaning storm sewers by flushing, to properly collect waste using
debris/sediment traps.
x Seal/repair joints in structures to prevent root intrusion and soil wash-out.
x Minimize or avoid the use of chemical root/vegetation killers, and use the least toxic
alternatives when necessary.
DETENTION BASINS:
x Existing control structures undergoing renovation are modified to the maximum extent
practicable to meet new construction criteria in MSD’s “Rules and Regulations and
Engineering Design Requirements for Sanitary Sewage and Stormwater Drainage
Facilities”.
x As required by the SWMP MCM5, inspect facilities to insure proper operation and
maintenance, and enforce requirements as needed, inspecting for: trash and debris
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removal, vegetation control, vector control, structural and erosion repair, and sediment
removal to restore capacity.
G. NPDES Permit status:
MSD has obtained an MS4 Permit, MO-R040005.
H. Training:
MSD collection system operators and contractors involved in maintenance of drainage
systems will be trained on the BMPs in this chapter.
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Chapter 9 - Water Quality Impact Assessment of Flood Management
Projects
A. Description of Activities:
New flood management projects located within the District must be assessed for impacts on
water quality. Existing projects must be assessed for incorporation of additional water quality
protection devices or practices, where feasible. Flood management projects in the Plan Area
can include: regional storm water control (retention basins, detention basins); flood control
levees and associated pump stations; storm water drainage conveyance capacity
improvements; projects involving land buyouts; and designated uses of flood plain land.
Storm water management projects in both development and re-development will be assessed
for water quality impact, according to MSD’s “Rules and Regulations and Engineering Design
Requirements for Stormwater Drainage Facilities”, which address the Storm Water
Management Plan water quality requirements under MCM 5. Storm water management
projects within designated levee districts, such as Monarch-Chesterfield, Earth City and
Riverport will be based on the Storm Water Master Plan for these districts. All flood
management projects involving channel modification will also be assessed for aquatic and
water quality impacts through the Corps of Engineers 404 permit and MDNR 401 water quality
certification process.
B. Locations:
MSD does not maintain any existing regional stormwater detention or retention basins. The
Stormwater System Master Improvement Plan, as updated, identifies and evaluates all
potential stormwater improvements to address issues, such as flooding, erosion and water
quality. A list of stormwater projects implemented under the Capital Improvement and
Replacement Program are maintained in the District’s Oracle Enterprise Business System.
C. Responsible Parties:
This chapter mainly applies to the Engineering Department through the planning, design and
installation of flood management projects. MSD has general responsibility for storm water
drainage facilities in the Plan Area. St. Louis County, municipalities, and property owners
have responsibility for the drainage facilities not dedicated to, and maintained by MSD. St.
Louis County and municipalities maintain control over planning and zoning, land use
regulations, and flood plain management through ordinances.
D. Materials/Supplies acquisition, storage and usage:
Not applicable. For construction phase of work, land disturbance requirements will apply.
See Chapter 2 and 8 for construction and maintenance.
29
E. Waste generation, storage, disposal, recycling:
Not applicable. See Chapter 2, 5 and 8 for maintenance.
F. Best Management Practices (BMP):
x Implement and enforce procedures requiring that water quality factors be incorporated
into the design and operation of storm water/flood control structures.
x Existing control structures undergoing renovation are modified to the maximum extent
practicable to meet new construction criteria in MSD’s “Rules and Regulations and
Engineering Design Requirements for Sanitary Sewage and Stormwater Drainage
Facilities”.
x Design new flood management projects to prevent or minimize adverse water quality
impacts, exploring alternative programs utilizing non-structural flood damage reduction
and stream bank stabilization measures to the maximum extent practicable, such as
flood proofing houses, and buy outs.
x Use models based on fully developed conditions, and adopt a free board above base
flood elevation for development, when specified in municipal floodplain ordinances.
x Survey watersheds downstream from proposed projects to determine potential water
quality impacts. Design proposed projects to minimize downstream impact.
x Work closely with local governments, environmental organizations and others to
develop multi-use open space corridors along streams which will allow for overbank
floodplain storage. Floodplains are preserved to the maximum extent practicable.
x Use non-structural flood management practices to the maximum extent practicable,
utilizing acquisition of flood-prone property where possible.
x Open storm water conveyance systems are used to the maximum extent practicable to
preserve natural conditions and habitat.
x Channel improvement projects are to use natural approaches rather than concrete,
riprap or other “hard” techniques to the maximum extent practicable.
x Inlets and outlets from closed portions of conveyance systems are designed to
minimize scour and erosion.
x Employ natural solutions and use controls that preserve the hydrology of a site as a
first line of flood control to the maximum extent practicable.
G. NPDES Permit status:
Not applicable
H. Training:
Employees and contractors responsible for the planning and design of the flood management
projects identified in Section A will be trained on the BMPs in this chapter. In addition,
employees performing this work will be familiar with MSD’s rules and regulations and
engineering design requirements for storm water drainage facilities.
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APPENDICES
31
Appendix 1- Corps of Engineers Regional General Permit (RGP-44)
On March 16, 2018 the U.S. Army Corps of Engineers (USACE) issued Permit Number MVS-
RGP-44 to the Metropolitan St. Louis Sewer District (MSD) pursuant with Section 404 of the
Clean Water Act. The permit authorizes excavation or discharge of fill material into waters of
the U.S. in order to perform work associated with the maintenance, repair, or inspection of
public stormwater, sanitary, or combined sewer systems. This general permit does not
authorize new infrastructure built in natural streams or wetland areas.
The Missouri Department of Natural Resources’ (MDNR) Water Protection Program approved
the USACE request for Clean Water Act Section 401 Water Quality Certification (WQC) to
accompany the MVS-RGP-44 permit on March 1, 2018. The WQC authorizes the discharge of
fill materials into existing, engineered stormwater channels or basins previously constructed in
or considered waters of the United States in Jefferson, St. Charles, and St. Louis Counties,
including the city of St. Louis.
Under this general permit, only incidental discharge of materials related to maintenance or
improvement activities is permitted. Debris or sediment removed to restore conveyance
capacity or vegetation removed to conduct maintenance related activities shall not be returned
directly to the water way. Additionally, excess materials from any maintenance activities shall
not be sidecast into any jurisdictional waters. Such materials shall be removed from the site
and placed beyond the high bank on a non-wetland site.
This general permit eliminates the need for individual permit review and allows certain
activities to proceed with no delay, provided that the general or specific conditions for the
general permit are met. Prior to issuance of this general permit, individual permits were
required for all activities regulated under Section 404 of the Clean Water Act.
The types of activities authorized by this general permit are:
1. Sediment and Debris Removal: This permit authorizes the removal of accumulated
sediment, log jams, and collected debris; including during periods of active discharge within
the stormwater system; to restore the conveyance capacity of the system and reduce the
potential for flooding.
2. Maintaining Existing Stormwater Conveyances or Basins in Waters of the U.S.:
Maintaining existing stormwater conveyance structures including the removal and
replacement of damaged sections of culverts, pipes, and transfer tubes; removal and
replacement of inlet and outlet structures, weirs, flumes, trash racks, riprap, grade stabilizers,
pumps, valves, and channels lined with concrete, riprap, stone, block, gabion baskets, and
other like materials. This also includes maintenance and clean out of existing culverts, weep
holes, and outfall structures. This permit does not authorize the replacement of entire
stormwater or sanitary systems.
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3. Improvements to Existing Stormwater Management Facilities: Improvements or
maintenance to existing stormwater management features to improve water quality or add bio-
retention, setbacks, rain gardens, natural re-vegetation. This activity does not include stream
channelization, impoundments, or piping.
4. Maintenance or Repair of Existing Stormwater, Sanitary or Combined Sewer Systems
in Waters of the U.S., including separation of systems. Maintenance and clean out of existing
culverts, weep holes, and outfall structures associated with improved stormwater channels.
Also includes placement of material, including riprap, at outfalls and along the channel banks
for the purpose of protecting the sewer system and excavation needed to access, maintain, or
repair sewer infrastructure.
5. Maintenance and Repair of Existing Access Roads and Ramps, including re-grading;
as necessary to perform items 1-4 above. The maintenance and repair activities shall result in
only the minimum waterbody impacts necessary to return the access roads or structures to
their asbuild condition. The general permit also authorizes minor modifications to repair
access roads and ramps, provided that the modifications do not increase their footprint within
waters of the U.S. The general permit does not authorize the construction of new permanent
access roads, ramps, or other access structures in waters of the U.S.; or conversion of stream
channels to temporary roadway; or operation of equipment within the stream channels as de
facto roadways; with the exception of temporary perpendicular crossings.
6. Vegetation Removal necessary to perform items 1-5 above. Vegetation removal would
occur through native and non-native vegetation removal within and along the banks of existing
recharge basin facilities, and within and around existing water conveyance structures.
Vegetation removal shall be the minimum necessary. Permittee may use a combination of
mechanical vegetation cutters, hand tools, and heavy equipment to remove vegetation. This
activity also includes debris removal to reduce flooding and protect integrity of system.
This permit requires MSD to submit a spreadsheet or annual report describing projects
utilizing this General Permit. MSD has decided to submit these reports on a quarterly basis to
provide the USACE with a more frequent project update.
If the planned construction or maintenance activity involves the excavation or discharge of any
dredge or fill material into a “water of the United States” while performing an activity not
covered under Permit Number MVS-RGP-44, then a Corps of Engineers 404 permit and a
MDNR 401 water quality certification is required. The permitting and certification process is
shared between the Corps and the MDNR. The Corps has the sole authority to determine
whether the activity is regulated; whether a site specific, individual 404 permit is required, or
whether a Nationwide Permit (NWP) applies for projects with minor impacts.
The MDNR requires any project that needs a 404 Permit from the Corps (individual or NWP)
to also obtain a 401 Water Quality Certification (401 Certification) from MDNR. The 401
Certification is verification by the state that the project will not violate water quality standards.
After you contact the Corps about your project and, if applicable, submit an application, they
will send you a letter authorizing your project under a particular permit. If the Corp's letter to
you indicates that you must obtain an individual 401 certification, you must send an
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application to MDNR. If they state that MDNR has ‘conditionally certified’ your activity, and
have enclosed certification conditions, then nothing further is needed.
Questions about permit applicability and procedures for obtaining individual permits can be
found on the following web pages: http://www.mvs.usace.army.mil/Missions/Regulatory.aspx
http://dnr.mo.gov/env/wpp/401/index.html
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Glossary: Definitions of Terms Used In This Document
The following definitions are specific to the St. Louis Metropolitan Small MS4 and to MSD.
Best Management Practice (BMP)means: Schedules of activities, prohibitions of practices,
maintenance procedures and other management practices to prevent or reduce the pollution
of streams within St. Louis County from urban runoff. BMPs also include treatment
requirements, operating procedures and practices to control site runoff, spillage or leaks,
sludge or waste disposal or drainage from raw material storage. BMPs may be structural or
non-structural.
Coordinating Authority means: The municipal entity, which is one of the co-permittees to a
state issued Phase II storm water permit that is recognized by the Missouri Department of
Natural Resources (MDNR) as the party which will coordinate the activities of all of the co-
permittees in meeting the requirements of the permit. For the St. Louis County Plan Area, the
Metropolitan St. Louis Sewer District (MSD) has been identified in the permit as the
coordinating authority for the 60 co-permittees. One of the coordinating authority’s
responsibilities is to prepare and submit an annual report to the MDNR on the status of
compliance of all 60 co-permittees with the permit and approved SWMP.
Co-permittee means: An individual permittee named in a Phase II permit that is issued to
multiple entities within a single urbanized area such as St. Louis County. Within the St. Louis
County Plan Area, each of the 60 co-permittees is responsible only for the permit conditions
relating to the discharges for which it is the owner or operator and for carrying out the
responsibilities for which it has been designated within the SWMP. The co-permittees share
in the financial and administrative responsibilities under the permit and cooperate with each
other and with the coordinating authority in complying with the terms of the permit and with
meeting the commitments in the SWMP.
x Making efficient use of resources - a product that uses energy, fuel or water more
efficiently or that uses less paper, ink or other resources.
x Being durable or having a long economically useful life and/or can be economically
repaired or upgraded.
Green Infrastructure means: An adaptable term used to describe an array of products,
technologies, and practices that use natural systems – or engineered systems that mimic
natural processes – to enhance overall environmental quality and provide utility services.
Green Space means: A planned and preserved open land; an interconnected system of open
land, determined to have cultural, ecological, developmental, agricultural, and/or recreational
value.
Maximum Extent Practicable (MEP)means: The technology-based discharge standard for
Municipal Separate Storm Sewer Systems to reduce pollutants in storm water discharges that
was established by CWA §402 (p). A discussion of MEP as it applies to regulated small MS4s
is found at 40 CFR 122.34.
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MCMs means: Minimum Control Measures. The six MCMs are: Public education and
outreach; Public participation/involvement; Illicit discharge, detection and elimination;
Construction site runoff control; Post-construction site runoff control; and Pollution
prevention/good housekeeping.
Municipal Industrial Facility means: An industrial facility, as defined in the federal and state
storm water regulations, which is owned or operated by a municipality. The regulations define
covered industrial facilities by their Standard Industrial Classification (SIC) codes as published
by the U.S. Office of Management and Budget. From this extensive list of covered SIC codes,
the following operations have been identified as those most likely to be owned or operated by
a municipality: Landfills, Hazardous Waste Treatment/Storage/Disposal facilities,
Transportation Operations, Vehicle Maintenance or Fueling facilities, Vehicle Washing
facilities, Solid Waste Transfer facilities, Wastewater Treatment facilities, Recycling facilities,
Yard Waste/Composting facilities and certain types of Warehousing & Storage facilities.
Municipal Separate Storm Sewer System (MS4)means: A conveyance or system of
conveyances including roads and highways with drainage systems, municipal streets, catch
basins, curbs, gutters, ditches, paved or unpaved channels or storm drains designated and
utilized for routing of storm water which is contained within the municipal corporate limits or is
owned and operated by the state, city, town, village, county, district, association or other
public body created by or pursuant to the laws of Missouri having jurisdiction over disposal of
sewage, industrial waste, storm water or other liquid wastes and is not a part or portion of a
combined sewer system. (This definition adapted from Section (1) (C) 16 of Missouri Storm
Water Regulation 10 CSR 20-6.200).Each of the 60 co-permittees operates its own MS4. In
addition, the term is used to refer to the entire St. Louis County Plan Area which is identified in
the Phase II permit as the St. Louis Metropolitan Small MS4.
Municipal Work Group means: A group of municipal representatives organized under the
provisions of Chapter 14 of the St. Louis County SWMP to develop a model Operation and
Maintenance Program and a Training Program for the 60 co-permittees in order to comply
with the provisions of Section 4.2.6.1 of the Plan Area Phase II storm water permit.
Municipality means: Any public entity as described in the definition of Municipal Separate
Storm Sewer System. St. Louis County and the Metropolitan St. Louis Sewer District (MSD)
are considered “municipalities” for the purposes of the Phase II storm water permit along with
the 59 cities, towns and villages that are co-permittees. The Missouri Department of
Transportation (MoDOT) is also a “municipality” and operates an MS4 within the Plan Area.
However, MoDOT is covered by a separate state permit and is not a co-permittee under the
St. Louis Metropolitan Small MS4 permit.
Nonpoint Source Pollution means: Pollution resulting from land runoff, precipitation,
atmospheric deposition, drainage, seepage or hydrologic modification or any source of water
pollution that does not meet the legal definition of “point source” in section 502(14) of the
Clean Water Act.
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NPDES means: National Pollutant Discharge Elimination System. This term was introduced
in Section 402 of the federal Water Pollution Control Act of 1972 (last amended in 1987 and
now known as the Clean Water Act). Section 402 provides for the issuance of NPDES
permits for the discharge of pollutants to waters of the United States and specifies the
conditions under which permits may be issued. The 1987 amendments established the
phased permitting requirements for municipal storm water discharges. In Missouri, the
Missouri Department of Natural Resources has been delegated the authority to issue NPDES
permits.
Phase I means: The first phase of the federal storm water regulations. These took effect
December 17, 1990. Phase I regulations provide for storm water permitting for industrial
facilities, for land disturbance sites 5 acres or greater in size and for MS4s having populations
greater than 100,000 (medium and large MS4s). Industrial facilities operated by
municipalities, regardless of size, are included under Phase I. See definition of “Municipal
Industrial Facility.”
Phase II means: The second phase of the federal storm water regulations. These took effect
February 7, 2000. Phase II regulations provide for storm water permitting for MS4s, in
urbanized areas as defined by the Bureau of the Census, with populations below 100,000
(Small MS4s) and for land disturbance sites between 1 acre and 5 acres in size. Each of the
individual municipal entities within the St. Louis County Plan Area has a population below
100,000 and is, therefore, a Small MS4 subject to Phase II requirements.
Phase II Permit means: Storm water permit # MO-R040005 with an original effective date of
March 10, 2003, issued by the Missouri Department of Natural Resources to the 61 St. Louis
County co-permittees. The second term permit went into effect on June 13, 2008. This permit
was issued pursuant to the provisions of Missouri Storm Water Regulation 10 CSR 20-6.200.
Plan Area means: The portion of St. Louis County served by separate storm sewers and
within the corporate boundaries of the Metropolitan St. Louis Sewer District. The Plan Area
includes the 58 cities, towns and villages who are co-permittees as well as unincorporated St.
Louis County. While there are a total of 88 municipalities in the Plan Area, 18 have
populations of less than 1000 and are therefore, exempt from the Phase II permitting
requirements, per Section (1)(C)24 of Missouri storm water regulation 10 CSR 20-6.200. The
City of St. Louis and twelve county municipalities adjoining the City of St. Louis are served by
combined sewers and are not part of the Plan Area. The Plan Area is identified in the Phase
II permit as the St. Louis Metropolitan Small MS4.
Plan Area Training Committee means: The Municipal Work Group defined above.
Recycling Facility means: any co-permittee-owned or operated facility which collects, for
recycling, common household recyclables such as paper, plastic, glass, cardboard, etc. or
which collects and processes yard wastes for use as mulch or compost.
St. Louis Municipalities Phase II Storm Water Planning Committee means: A group of
representatives from municipal governments, St. Louis County, MSD and various state and
regional agencies which developed the Storm Water Management Plan for St. Louis County.
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Separate Storm Sewer means: A pipe, conduit, conveyance or system of conveyances
(including roads with drainage systems, municipal streets, catch basins, curbs, gutters,
ditches, manmade channels or storm drains) designed and intended to receive and convey
storm water and which discharges to waters of the state and which is not part of a combined
sewer system.
Storm Water means: Rainfall runoff, snow melt runoff and surface runoff and drainage.
Storm Water Management Plan (SWMP) or Plan means: The Plan developed for the
St. Louis County Plan Area by the St. Louis Municipalities Phase II Storm Water Planning
Committee and approved by the Missouri Department of Natural Resources through the
issuance of NPDES permit MO-R040005.
Sustainable (green) Service means: A service acquired from a supplier who has a green
operational policy and whose internal practices promote sustainability.
Urban Runoff means: Storm water and other runoff from streets, parking lots, rooftops,
residential, commercial and industrial areas and any areas that have been rendered
impervious through development activities. Such runoff becomes contaminated with
fertilizers, pesticides, vehicle drippings and emissions, animal wastes, street litter, yard
wastes, silt, chemical spills and other urban wastes. These contaminants are carried through
the separate storm sewers and discharged into area streams where they degrade the water
quality, harm aquatic life and other wildlife, reduce aesthetic and recreational values and
make the waters unsafe for human use.
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For More Information…
x MDNR Stormwater Information Clearinghouse
https://dnr.mo.gov/env/wpp/stormwater/
x Spill Response and Reporting – For EPA contacts and reporting instructions:
https://readycontainment.com/technical-library/epa-emergency-spill-response/
MDNR contact and reporting instructions: https://dnr.mo.gov/env/esp/esp-eer.htm
x EPA -Stormwater BMPs
https://www.epa.gov/npdes/national-menu-best-management-practices-bmps-
stormwater#poll
x Stormwater Waste Management Guidance – Pollution Prevention Guidance
publications:
https://www.epa.gov/p2