MS4 General Permit Compliance

What was the Challenge?

In 2017, the City of Derby received a Request for Information from the EPA regarding their registration for the DEEP’s General Permit for the Discharge of Stormwater from Small Municipal Separate Storm Sewer Systems (“MS4 General Permit”).  The request from the EPA was sent to the city for their non-compliance with the MS4 General Permit.  Prior to 2017, there were many changes to the leadership in the city and, unfortunately, the City’s compliance with the MS4 General Permit fell by the wayside.

This project held many challenging goals, among them: bringing the City back into compliance with their MS4 General Permit; working with a revolving staff at the City; gathering available data from the City; working with inaccurate mapping for an aging storm sewer system; conducting fieldwork without a full complement of information; working within a limited available budget for a municipal entity; and meeting the accelerated compliance schedule established in the EPA’s request.

How did Barton & Loguidice provide a solution?

Anchor Engineering met with the Mayor and Public Works Director to review the available data that the city had on their storm sewer system and established goals in meeting the requirements of the Request for Information from the EPA and the DEEP’s MS4 General Permit to the maximum extent practicable.  A stormwater management plan, stormwater discharge ordinance, and Illicit Discharge Detection and Elimination (IDDE) program were completed specific to the city, meeting the requirements of the EPA and the DEEP.  Using the information provided by the city and information gathered while conducting field inspections throughout the city, a GIS database of the City’s storm sewer system was started from scratch, which now includes over 130 outfalls, several thousand catch basins and stormwater structures, and approximately 3 miles of storm piping.

Dry weather and wet weather screening and sampling were conducted at every outfall in the city in compliance with the requirements of the EPA and the DEEP.  A list has now been generated of each outfall that may be associated with a potential illicit discharge and efforts are now being conducted with the city to eliminate the sources of these illicit discharges.

Why was the project a success?

Based on the level of efforts conducted, the City was able to fulfill the majority of the requirements established in the EPA’s Request for Information and they are now able to focus on continuing to remain in compliance with the DEEP’s MS4 General Permit.

Mapping efforts continue throughout the city to build a complete storm sewer system that can be a valuable tool to the city for years to come.

Constant communication was conducted between the City, the EPA and the DEEP to ensure that the needs of all parties involved were met.  Efforts will continue in the years ahead to assist the city in maintaining compliance with MS4 General Permit to the maximum extent practicable given the available resources from the city for an unfunded mandate.