MS4

MS4 Project Managers, Your Nightmare is Over

Four Steps to Better SWPPPs, SOPs, and Staff Training

Everyone has office horror stories. You know those moments of chaos and confusion that derail the simplest projects. Those missteps that make you want to bury your head in your chest and pretend no one can see you.

Everyone has these terrors. MS4 managers are no exception. An MS4 manager assists with permits and regulations for municipal separate storm sewer systems (MS4s).

If you’re an MS4 manager, we feel your pain. We know what it’s like when EPA and DEQ inspections go wrong. We know how it feels when a field staff member dumps extra herbicide mix into wash water with live vegetation. When someone washes equipment over a storm drain. When someone places a full bucket of oily waste behind the maintenance building.

Why do these horrible ‘gotcha’ moments happen repeatedly? How can we prevent them in the future? At GKY, our planners can help answer these tough questions. We want to save you from any more MS4 horror stories with these four steps.

1. Start with Strong SOPs

The first step in preventing problems is having the right plans in place. Of course, that’s easier said than done. Old habits die hard. Stormwater is not a day-to-day priority for most organizations. Regulators know what to look for, and they can easily catch you off guard.

Still, with the right procedures in place, anything is possible. You need to develop pollution prevention standard operating procedures (SOPs), stormwater pollution prevention plans (SWPPPs), and employee training programs. Many MS4 operators have already taken these important steps.

For effective MS4 programs, you need to focus on long-term goals rather than short-term projects. To achieve your long-term goals, MS4 programs need to be consistent, built from the ground up, unambiguous, fully integrated into daily activities, and positively reinforced.

2. Mind Your Messaging

All elements of your program should be consistent. You want to make sure everything works together seamlessly. You also want to reinforce consistent messages about everything you do.

Consistency among your SOPs, SWPPPs, and training programs is key. For example, procedures for vehicle fueling should be identical whether in a SOP or a SWPPP. Training should reinforce those same messages.

MS4 managers also need to rethink the way these messages and procedures are developed. In the past, SOPs and SWPPPs were developed first, and training materials were developed second to reflect the language in those documents.

Perhaps it is time to reverse this direction. What are the behaviors and actions that we want staff to employ? How can we work these into SOPs and then by default into SWPPPs?

You should focus on staff behavior first and procedures second. That way, the SOPs and SWPPPs will be more likely to support an effective MS4 program. The key to success is the human element, not what is written on paper.

With this in mind, directions also have to be unambiguous. For instance, it’s not enough to write that materials will be “disposed of in accordance with local state and federal requirements.” You should write step-by-step how to responsibly and legally dispose of the materials. Messages and procedures should be clear, simple and understandable. Clear messaging means less room for human error and fewer horror stories in your future.

3. Have the Right Tools

Now that you have your plans and your messages in place, it’s time to act. You should make sure the SOPs are fully integrated into daily activities.

To make this possible, you need to have the right tools. Even the best SOP will fail if you don’t have the materials you need to get the job done. Say the SOP requires you to clean up spilled fuel cans, sweep up the mess and dispose of it in the dumpster. If you don’t have spill-dri, you can’t clean up the spill. If you don’t have a broom, you can’t sweep up the spill-dri.

Without the right tools, there’s no way to follow the SOP. If the proper materials are provided and staff are encouraged to follow SOPs during daily activities, these procedures will become commonplace.

4. Repeat, Reinforce, Repeat again

Last but not least, SOPs need to be reinforced. You can’t walk on a construction site without seeing a “Danger: Hard Hats Required in this Area” sign. Behaviors and actions taught as part of staff training and incorporated into SOPs and SWPPPs must be reinforced.

If possible, you should post these reminders around the job site. Signs such as “Clean up Spills” should be posted near the spill-dri containers.

Positive reinforcement, that conveys expectations rather than prohibitions will also make your methods more effective. “Dump no waste, drains to river” is a catchy message that certainly gets the point across. But that does not help the employee who still has to empty the mop bucket of dirty, sudsy water.

If mop water has to be emptied into the sewer, that is what your sign should say. You should reinforce behaviors and actions with clear, descriptive statements. Tell employees what they should do, rather than what they should not do.

Now what?

These steps should help you reach your MS4 program goals. Effective programs focus on solid plans, positive behaviors, clear messages, integrated procedures and daily reinforcement. With all of this in place, your projects will be smooth, and your stories will be happy, instead of horrifying.


Contact Us!
Need help with your MS4 program? GKY’s team of experienced planners can help. Give us a call, and we can make sure your program has the SOPs, SWPPPs and staff training it needs to succeed. Get in touch with GKY experts today!


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TMDLs – Load Allocations through Resource Misallocations

We live in an incredibly complex and dynamic time for managing our water resources.  Our urban areas are hit with ever-more onerous stormwater permit (MS4) conditions, and the MS4 nexus with pollutant loading restrictions imposed by Total Maximum Daily Loads (TMDLs) will further ratchet up the burden (and resulting cost of compliance).  Several issues highlight red flags with the current program:

  • The water quality monitoring upon which a finding of impairment is based – and, thus, the need for a TMDL is established – is oftentimes severely limited.  I’ve seen a case in which single monthly grab samples over a year was used to determine a pathogen impairment.  Water quality is complex and dynamic, and concentrations can vary by orders of magnitude over the course of hours.  A number of independent, non-anthropogenic (non-human) variables can change a sample’s results radically, such as drought, unusually wet conditions, or wildlife or managed herd waste deposition.  Heck, a cow defecating in a stream near a monitoring site can raise pathogen levels by three orders of magnitude for a period of minutes.
  • Water quality modeling is performed to develop a TMDL.  These models require calibration to take generalized equations and apply them to site-specific conditions through the adjustment of calibration parameters.  Monitoring data is critical to the calibration process.  In many instances, TMDLs are based on very complex models (such as EPA’s BASINS) which are calibrated with severely limited monitoring data.  This is like solving one equation with several unknowns – you can certainly find a solution, but there is no way of knowing if it is the RIGHT solution.
  • The pollutant loading allocations established in a TMDL can impose millions of dollars of infrastructure investment by these urban areas. As an example, we work with a small MS4 with a population of approximately 25,000 which has a wasteload allocation established under a TMDL.  The implementation plan for the TMDL estimates a cost to the community of $20 million!

So, we have limited monitoring data establishing the need for water quality protection.  This limited data is used to calibrate oftentimes very complex models that establish pollutant loading allocations.  The allocations can impose millions of dollars of infrastructure investment.  Under the current system, we skimp on monitoring and modeling – the two activities that form the scientific foundation for management – and use potentially compromised science to establish prohibitively expensive requirements.  This is akin to trying to swat a fly with your eyes shut.  To hit the fly, you need to aim with your eyes open.  The key to a successful TMDL is proper targeting – quantifying how existing pollutant sources must be reduced to meet water quality standards.  Without appropriate investment in monitoring and modeling, proper targeting is more a matter of luck than sound science.

Thank you,

Stuart Stein

President, GKY