LOOKING UNDER THE RUG: DEVELOPING AND IMPLEMENTING STORMWATER POLLUTION PREVENTION PLANS TO SATISFY GOOD HOUSEKEEPING/POLLUTION PREVENTION REQUIREMENTS

The Louisville and Jefferson County Metropolitan Sewer District (MSD) is responsible for managing stormwater and sewer service in Louisville Metro and is tasked with achieving safe, clean waterways for the community. In 2011 Louisville MSD, permitted as a Phase I Municipal Separate Storm Sewer System (MS4), received its current MS4 permit. The permit expanded upon previous permit requirements, including a requirement to have site-specific Stormwater Pollution Prevention Plans (SWPPPs) for all major facilities. At the time the permit was issued, MSD did not have site-specific SWPPPs for its seven major facilities, dedicated inspection personnel, an inspection and enforcement protocol, or training developed for operations staff at major facilities. The primary goal of this project was to satisfy MSD’s expanded MS4 permit requirements and to address feedback from the EPA Enforcement Division’s 2012 MS4 audit regarding Good Housekeeping/Pollution Prevention (GH/P2).