June 1, 2001 Public Workshop Orange County MS4 Permit, Urban Storm Water Runoff Management Program Order No. 01-20 (NPDES No. CAS 618030). Mark Smythe Chief, Coastal Storm Water Unit. Purpose of this Workshop. Give a short history on the municipal permit for Orange County
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Chief, Coastal Storm Water Unit
Permittees are required to develop and implement programs and policies necessary, to control the discharge of pollutants in urban runoff to the Maximum Extent Practicable (MEP)
While the term SUSMP originated in Region 4’s 1996 MS4 permit for Los Angeles County, the 1993 Orange County DAMP, Appendix G, Water Quality Management Plan (WQMP), presented a list of structural and non-structural BMPs for new development within Orange County.
June 15, 2001 Staff will incorporate comments received as of 6/1/01 and release a 2nd draft permit
July 6, 2001 Deadline for written comments on the 2nd draft permit prior to the 7/20/01 workshop
July 20, 2001 2nd workshop at regular Board Meeting
July 31, 2001 Release of final draft for 45-day review
August 21, 2001 Deadline for written comments on final draft permit prior to Public Hearing
September 14, 2001 Public Hearing on proposed permit
Some municipalities do not have control over sanitary sewers. The requirement for identifying and correcting problems with the sanitary sewer systems should be directed at the local sanitation districts. ( Lake Forest, Tustin, Westminster, Yorba Linda)
Regional Board staff will work with the sanitation districts to develop and implement a comprehensive plan to address this problem. A number of permittees own/operate sewage collection systems. These permittees will be required to participate in this process.
The requirements for new development within 303(d) listed watersheds is contradictory to the TMDL watershed approach; erroneously compares post-development runoff with pre-development runoff instead of with Basin Plan water quality objectives; is inequitable in that current dischargers are free to continue their loadings until the TMDL is implemented; and, ‘no new loading’ will result in the unnecessary expenditures of large sums of money (Lake Forest, Tustin, Westminster, Yorba Linda).
The TMDL requirements included in Section XIV of the draft order are consistent with the implementation plans developed in cooperation with all the stakeholders. For discharges to 303(d) listed waterbodies, all dischargers, existing as well as new, are required to implement appropriate BMPs. The permit does not allow existing dischargers to continue their loadings until TMDL implementation. All dischargers must implement appropriate control measures to insure that their discharges do not cause or contribute to any further violations of water quality objectives.
The requirement that municipalities control discharges “into” the MS4 expands on Clean Water Act requirements that municipalities control discharges “from” their MS4. (Lake Forest, Tustin, Westminster, Yorba Linda)
In Orange County and other parts of the State, some of the natural streambeds have been modified to convey storm water flows. These conveyance systems are both an MS4 and a receiving water. Beneficial uses of these waterbodies must be protected. In certain cases, these conveyance systems may be used for conveying storm water to a regional treatment facility. In such cases, the permittees must ensure that the dischargers implement appropriate BMPs on flows that enter “into” the MS4.
The permit’s requirement that infiltration BMPs would protect groundwater quality requires information not available to the permittees. This research should be conducted by the State or EPA. ( Lake Forest, Tustin, Westminster, Yorba Linda)
Infiltration BMPs should not become a conduit for transferring pollutants in storm water to groundwater. If appropriate BMPs are implemented, infiltration systems should not be a threat to groundwater.
The requirement that municipalities monitor, inspect and enforce construction and industrial sites already under the statewide General Permits is transferring the Regional Board’s responsibilities to the municipalities. (Tustin, Westminster)
The municipalities are not required to enforce the State’s General Permits. However, the municipalities are required to ensure that all construction sites and industrial facilities are in compliance with local laws and regulations. By co-ordinating these efforts with Regional Board Staff, duplicative and overlapping regulatory oversight can be avoided.