Introduction
This document has been prepared in direct connection with a 2023 National Pollutant Discharge Elimination System (NPDES) Permit Application for Discharge of Stormwater to Surface Waters of the State from a Municipal Separate Storm Sewer System (MS4) prepared by Kieser & Associates, LLC (K&A) on behalf of Western Michigan University (WMU).
The NPDES Program protects the surface waters of the state by assuring that discharges of wastewater comply with state and federal regulations. Anyone discharging or proposing to discharge wastewater to the surface waters of the state are required to make application for and obtain a valid NPDES permit prior to wastewater discharge.
NPDES permits are required under Section 402 of the Federal Clean Water Act (the “Federal Act”), as amended (33 U.S.C. 1251 et seq., P.L. 92-500, 95-217), and under Part 31, Water Resources Protection, of Michigan’s “Natural Resources and Environmental Protection Act”, 1994 PA 451, as amended (NREPA). Part 31 of the NREPA also provides authority for the State to issue NPDES permits. The Michigan Department of Environmental, Great Lakes, and Energy (EGLE) administers the NPDES permit program for the State of Michigan.
Regulated Area
A map identifying the urbanized area associated with the WMU jurisdictional boundary (as defined by the 2010 Census) is provided as Figure 1. The WMU MS4 system is located within the Kalamazoo urbanized area and discharges stormwater into surface waters of the state via stormwater outfalls to Arcadia Creek and/or points of discharge to the adjoining City of Kalamazoo MS4 drainage network.
Outfalls and Points of Discharge
The surface water of the state that receives stormwater discharge from the WMU MS4 footprint is Arcadia Creek. All WMU stormwater outfalls and points of discharge are summarized in Table 1. Attachment G, "BMP Maintenance plan," contains Table 1 and Figures. WMU Facilities Management maintains this map, and a web-based GIS system. There are a total of 10 stormwater outfalls that discharge to Arcadia Creek. Additionally, there are 24 stormwater points of discharge where the WMU storm sewer system enters an adjoining MS4 drainage network owned by the City of Kalamazoo. These City outfalls also discharge to Arcadia Creek.
Enforcement Response Procedure
The WMU campus is regulated as an MS4 under the NPDES Permit program. Unlike other municipalities, the University has total control over the storm sewer system within the campus footprint. More specifically, there are no opportunities or mechanisms to allow other entities to connect to the WMU MS4 infrastructure within the campus footprint. As a result, the University is solely responsible for its own MS4 permit compliance. As summarized within this SWMP, WMU has taken and will continue a proactive approach to stormwater management and implementation of stormwater control measures (or best management practices), and serves as a model for others within the Kalamazoo River Watershed to follow.
Tracking Non-Compliance
WMU will utilize a spreadsheet to track instances of non-compliance. The following information will be documented:
• Description of violation
• Location of violation
• Date violation occurred
• Name of responsible person/department
• Enforcement action taken by WMU
• Date compliance was reestablished
• Action(s) taken to reduce, eliminate and prevent recurrence of the non-compliant discharge
Detailed information and copies of correspondence for each violation will be maintained in a separate file.
Stormwater Management Program
The WMU Stormwater Management Program (SWMP) is comprised of six major elements. These six major elements include the minimum measures required by the U.S. EPA, EGLE, and are listed as follows:
1. Public Participation/Involvement Program (PPP) - to promote, publicize, and facilitate education for the purpose of encouraging the public to reduce the discharge of pollutants to stormwater to the maximum extent practicable
2. Public Education Program (PEP) - to share components of the SWMP and encourage participation in its review and implementation
3. Illicit Discharge Elimination Program (IDEP) - to detect and eliminate illicit connections and discharges to the MS4
4. Construction Stormwater Runoff Control Program - to augment Part 91 rules dealing with soil erosion, offsite sedimentation and other construction-related wastes
5. Post-Construction Runoff Control Program - (for new development and redevelopment projects) to address post-construction stormwater runoff from projects that disturb one acre or more, including projects less than one acre that are part of a larger common plan of development that would disturb one acre or more
6. Pollution Prevention and Good Housekeeping Program - to minimize pollutant runoff to the maximum extent practicable from municipal operations that discharge stormwater to the surface waters of the state
The following chapters of this text are intended to demonstrate compliance with these six minimum control measures and applicable water quality requirements as part of the NPDES Permit Application and SWMP.
References
Boyer, K. B., and Kieser, M.S. (2012) Urban Stormwater Management—An MS4 Success Story for Western Michigan University. Journal of Green Building (7):1, pp. 28–39.
Kieser & Associates, LLC (K&A). 2011. Western Michigan University TMDL Compliance Planning Project. Prepared for Western Michigan University (Project Code: 8635-0006).
Kieser & Associates, LLC (K&A). 2014. Western Michigan University Arcadia Creek Water Quality Monitoring Project. Prepared for Western Michigan University (Project Code: 2-12-0502).
Attachments
Published: 3/25/2024