Minimum Control Measures

Public Education and Outreach - The purpose of the Public Education and Outreach Minimum Control Measure is to inform residents, visitors, public service employees, commercial and industrial facility operators, and construction site personnel that are located or operate within the MS4 area about the impacts storm water runoff can have on water quality and ways they can minimize their impact on storm water quality.

A community that is informed and knowledgeable is critical to the success of the local storm water program. An understanding of storm water issues will help gain public support for the program. Other benefits include, but are not limited to greater compliance with the program and support for local funding initiatives

Public Participation and Involvement - Provisions should be developed and utilized that allow opportunities for constituents within the MS4 area to participate and provide input in the development and implementation of the storm water management program. A community that is active and involved will be critical to the success of the program. Citizens and business leaders that participate are more than likely to take an active role in program implementation, provide local broad base expertise, and serve as a conduit to local programs, citizen groups, etc.

Illicit Discharge Detection and Elimination - An MS4 operator is required to develop and implement a strategy to detect and eliminate illicit discharges into the MS4 conveyance system.

Illicit discharge is defined as any discharge to an MS4 conveyance that is not composed entirely of storm water, except naturally occurring floatables, such as leaves or tree limbs. Sources of illicit discharges include sanitary wastewater, septic tank effluent, car wash wastewater, oil disposal, radiator flushing disposal, laundry wastewater, roadway accident spillage, and household hazardous wastes.

Illicit discharges can significantly contribute to high pollutant loadings into MS4 conveyances systems. These discharges include heavy metals, toxics, oil and grease, solvents, nutrients, and bacteria.

Use this online form to report a suspected illicit discharge.

Construction Site Storm Water Runoff Control - An MS4 operator is required to develop, implement, manage, and enforce an erosion and sediment control minimum control measure for construction activities. The program and ordinance must at a minimum meet the requirements of 327 IAC 15-5, Rule 5 (scroll to page 10). 327 IAC 15-5 is the State of Indiana construction/land disturbance regulation. The primary purpose of Rule 5 is to reduce pollutants, principally sediment that is associated with construction activities. Rule 5 requires all sites where land disturbance is one (1) or more obtain a general permit from the state.

The program developed by the MS4 must include procedures for construction plan review, site inspection, and, when necessary, enforcement. An MS4 entity must create or revise a policy, ordinance, or other regulatory mechanism to provide the necessary legal authorities to control, and, when necessary, penalize the source of noncompliance to the MS4 entity specifications created for construction runoff. MS4 entities that do not have the ability to create or enforce ordinances will need to either create an enforceable policy document, or enter into a legal agreement with another entity to implement this control measure.

The program must include requirements for the use of erosion and sediment control measures, as well as measures to properly manage and control other pollutants that may be associated with construction activities. The Indiana Storm Water Quality Manual provides principles of managing a construction site and standards and specifications on various storm water quality measures

Post-Construction Storm Water Runoff Control - An MS4 operator is required to develop, implement, manage, and enforce a program to address discharges of post-construction storm water runoff from new development and redevelopment areas. The program should be focused on areas that disturb one (1) or more acres of land.

Planning for post-construction measure should be included with the development of the construction plan for the project. Planning these measures prior to land disturbance is essential to accommodate them into the overall development plan. During construction, some of the post-construction measures may also be utilized as sediment trapping devices. Once the construction activity is complete, the post-construction measures specified by the MS4 entity can become operational to ensure adequate storm water quality is maintained from the developed site. The Indiana Storm Water Quality Manual provides planning principles for layout and design of a project site and standards and specifications on various storm water quality measures that target pollutants associated with post-construction runoff.

An MS4 entity must create, or revise, a policy, ordinance, or other regulatory mechanism to provide the necessary legal authorities to control, and, when necessary, penalize the source of noncompliance to the MS4 entity specifications created for post-construction runoff. MS4 entities that do not have the ability to create or enforce ordinances will need to either create an enforceable policy document, or enter into a legal agreement with another entity to implement this control measure.

Municipal Operations Pollution Prevention and Good Housekeeping - The final minimum control measure addresses the storm water discharges that are associated with operations internal to the MS4. This measure requires the MS4 to evaluate and alter operations internally to ensure a reduction in the pollutants that are generated from municipal operations.

Below are several items that are required to be addressed for this minimum control measure:

• Maintenance of the MS4 conveyances is essential to reducing the potential for pollutants and are addressed through periodic litter pick up, cleaning and maintenance of storm water systems, pavement sweeping, roadside shoulder and conveyance system maintenance, and remediation measures for scoured outfalls.
• Reduce or eliminate the discharge of pollutants from roads, parking lots, maintenance and storage yards, and waste transfer stations.
• Develop procedures for the proper disposal of materials removed from storm sewer systems, conveyances channels, and operational areas.
• Consider modification of flood management projects to address storm water quality in addition to quantity. This approach may also be suitable by retrofitting existing flood management structures.
• MS4 area personnel that are involved in the internal operational activities must receive relevant storm water training. This training can be conducted "in-house" by MS4 entity staff or some other trainer and must occur, at a minimum, annually.