Structural Controls and Stormwater Collection System Operation is the first permit program. The intent of this requirement is for the Permittee to operate and maintain its MS4 in a manner that reduces the discharge of pollutants. The permit requires an inventory of all structural controls owned/maintained by the Permittee. The permit also specifies a schedule for the inspection and maintenance of specific types of MS4 components. The permit requires a written procedure for the inspection and maintenance activity. To assist the Permittee, templates of written procedures have been developed and are available to download. Click on the structural control listed below to download a template of a written procedure for that item. Guidelines for the use of the templates are also available here.
These SOP templates are made available for use by the individual permittees in complying with the MS4 NPDES permit requirement for the development and implementation of "...written Standard Operating Procedures to conduct inspections and maintenance of the structural controls and roadway stormwater collection systems operated by the permittee in accordance with Table II.A.1.a of the permit…”
These templates can be used as is, with minor customization pertaining to your specific system. They can be altered significantly to fit your own inspection and maintenance procedures. They can be disregarded all-together and your own inspection and maintenance procedures may be documented. It is recommended that you refer to Table II.A.1.a. of the permit when developing your own SOPs; it’s very likely that FDEP and/or its consultants will use that table as a guide when they audit SOP documentation in the future.
Please note, if you contract out for your inspection/maintenance activities, you are required to have a copy of the contract that specifies the “schedule and frequency of the inspection and maintenance activities to be conducted.”
Recommendations for using the templates:
- There are spaces for filling in the number of each structural control within your MS4, as well as a cue to include a map that shows their location.
- Work with field staff that will actually do the inspections/maintenance to identify if these procedures work for your MS4.
- You may need to do some research to identify specific information about specific controls (e.g. expected performance in a swale or detention area). If this type of information is unavailable, the person in charge of stormwater for your jurisdiction could make a decision on an acceptable level of performance, and that can be used as your guide.
- Pump stations typically have O&M manuals already developed. If used, these should be cited or incorporated by reference in your SOP for stormwater pumps stations. If they are not used (or don’t exist), a more detailed SOP for each unique pump station should be developed.
- A geographic information system (GIS) is typically considered to be an electronic map & database (using software such as ArcMap, or AutoCad), but a hardcopy map with a legend or associated database of information is essentially a GIS as well. Either will prove useful as a way of inventorying, tracking scheduled and completed inspections, and identifying where maintenance is needed.
- The use of inspection forms/checklists is not required. However, you may find them to be an easy way of tracking/documenting completed inspection activities. You might also use work orders, maps, etc. for the required documentation.
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For those interested, SAIC compiled a description of stormwater structural controls. Click here to download a PDF copy of the file (5 pages).
