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Stormwater: MS4 Stormwater permitting requirements for small municipal separate storm sewer systems 2014 Environmental Trade Fair. Polly Porter . Compliance Assistance Specialist . Waco – Region 9 . 254 -761-303 9 . polly.porter@tceq.texas.gov. Technical Assistance.
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Stormwater: MS4 Stormwater permitting requirements for small municipal separate storm sewer systems 2014 Environmental Trade Fair.
Polly Porter. Compliance Assistance Specialist. Waco – Region 9. 254-761-3039. polly.porter@tceq.texas.gov .
Technical Assistance. • Free and Confidential. • Multi-media. • Compliance Hotline. • One-on-one help from regional staff. • Special programs (if eligible). • EnviroMentor (EM). • Site Visit / Compliance Commitment (C2).
Who does SBLGA help? • Marinas. . • Metal Finishers/Fabricators. • PST Facilities (fuel) . • Print Shops. • Manufacturing Facilities. • Reinforced Plastics. • Surface Coaters. • Trade Associations. • Transportation/Distribution. • Wastewater Plants. • Wood Products. • Airports. • Auto Body / Repair. • Building Contractors. • Car Washes. • Compost Operations. • Concrete Batch Plants. • Drinking Water Plants. • Dry Cleaners. • Foundries. • Local Governments.
Compliance resources can be searched by industry, issue or special topics. TexasEnviroHelp.org
Customer Satisfaction Survey. Submit comments about your experience. Be specific when possible.
What is stormwater?What is a discharge? Stormwater is rainfall. Run-off carries potential pollutants as a discharge.
Rule References. Federal. • Clean Water Act. • 40 Code of Federal Regulations. • Chapter 122.26. State. • Texas Water Code. • Chapter 26.121. • 30 Texas Administrative Code. • Chapters 281, 305, 308.
EPA National Pollutant Discharge Elimination System TCEQ Texas Pollutant Discharge Elimination System Phase I and II MS4s (Municipalities, et al) MSGP (Industrial) CGP (Construction)
What is a permit? • Effluent limitations and requirements for 5 years. • Authorizes discharges from specific activities and certain non-stormwater discharges.
TPDES. • Multi-Sector General Permit (MSGP). • TXR050000 (August 14, 2011-2016). • Construction General Permit (CGP). • TXR150000 (March 5, 2013-2018). • Municipal Separate Storm Sewer Systems (MS4s). • Phase I – large and medium cities. • Individual / customized. • Phase II – small cities. • General Permit TXR040000(Dec. 13, 2013-2018).
What is an MS4? • Publicly owned or operated drainage system designed to convey stormwater. • Not a wastewater collection or sewer. • May include non-traditional entities such as military bases, transportation systems, hospitals, universities, correctional facilities and a variety of districts.
Regulated Districts. Jurisdiction of the TCEQ: GCD Groundwater Conservation District. ID Irrigation District MMDMunicipal Management District. MUDMunicipal Utility District Regional District. RD Regional District. SCDStormwater Control District. SUDSpecial Utility District. WCID Water Control & Improvement District. WIDWater Improvement District.
Urbanized Area. • High density of residential population identified by 2000 and 2010 U.S. Census: • 1,000 to 50,000 people per square mile. • 500 people/square mile at boundaries. • Conveyance located fully or partially within UA. • Must regulate only that portion within UA. • “Once in, always in.”
2000 CensusWilliamson County MS4s must regulate only the portion inside the UA not covered by another entity’s permit/SWMP.
2010 Census Williamson County MS4s must regulate only the portion inside the UA not covered by another entity’s permit/SWMP.
Waiver Option. Waiver 1: • Serve population less than 1,000 within a UA. • No significant contribution to: • pollutant loadings of and interconnected MS4. • pollutants identified as a cause of impairment to receiving water body. Waiver 2: • Data and labor intensive. • More costly than permit.
Applications. • DeadlineJune 11, 2014. • Full permit coverage: • Notice of Intent - form 20368. • $100 application fee. • Stormwater Management Program (SWMP). • Waiver 1 Option – form 20369. • Anticipated: • 750 - NOI for full permit coverage. • 115 - Waiver 1.
Authorization Process. • Submit NOI & SWMP or Waiver application. • Administrative review by the TCEQ. • Additional information from applicant. • Technical Review of SWMP. • Additional information from applicant. • Public Notice published in newspaper. • Public Meeting. • Approved by the TCEQ.
Impaired Water Body. • Impaired = EPA approved303(d) list. • Identify pollutant of concern. • Determine if MS4 contributing POC. • SWMP must include: • Focused BMPs for reducing POC. • Measurable goals for each BMP. • Bacteria - identify and focus on sources. • Assess progress. • Include in Annual Report.
Water Body with TMDL. • Total Maximum Daily Load established. • Identify cause of impairment. • Determine if MS4 contributing POC. • SWMP must include: • Targeted controls for reducing POC. • Measurable goals for each control. • Create benchmarks. • Bacteria - identify and focus on sources; refer to watershed’s Implementation Plan. • Assess progress – collect or use other’s data. • Include in Annual Report.
Tiered Approach. Permit requirements are based on UA population: • Level 1: < 10,000 population. • Level 2: 10,000 – 40,000 & non-traditional. • Level 3: 40,000 – 100,000. • Level 4: > 100,000.
Administrative Requirements. • Application for permit coverage • Storm Water Mgmt. Program approved by TCEQ. • Establish measurable goals to MEP. • Maintain records evaluating efforts • Implement SWMP by end of permit term • Annual Report • Submit within 90 days of end of each permit year
Technical Requirements. Develop and implement comprehensive SWMP to: • Reduce pollution to maximum extent practicable. • Meet water quality requirements of CWA and TWC. • Required only inside of UA boundaries. • BMPs, ordinances, and other mechanisms. • Include six minimum control measures.
Signatory Authority. NOI, NOC, SWMP, Annual Report - 30 TAC 305.44. • Corporation. • responsible corporate officer. • Government entities. • principle executive officer. • Ranking elected official. • Mayor.
Delegation of Authority. Authorized person may delegate - 30 TAC 305.128. • Authority assigned for other responsibilities. • May specify individual OR position having. responsibility for the facility, department, project, activity or environmental matters. • Must be in writing – TCEQ form 20403.
SWMP Includes a map and six Minimum Control Measures: • Public Education, Outreach and Involvement • Illicit Discharge Detection and Elimination • Construction Site Runoff Control • Post-Construction Mgmt. in New & Redevelopment • Pollution Prevention and Good Housekeeping for Municipal Operations. • Industrial SW Sources • Optional – Construction by MS4.
For each MCM. • Establish measurable goals. • Evaluate / assess efforts to meet goals. • Meet MEP standard for each goal. • Maintain records evaluating efforts. • Report progress annually. • Full implementation by end of permit term.
Implementation Options. • Share program elements w/others: • Phase I or II existing programs. • Phase II developing programs. • Each MS4 responsible for: • Applying for permit coverage. • Compliance with SWMP.
Assessment. • Monitor WQ to assess pollutant reductions. • Evaluate social indicators / behavior change. • Document progress toward goals. • Provide feedback to program management. • Ensure efficient use of resources. • Meet regulatory requirements.
Monitor Water Quality. • Most direct approach. • Verifiable results. • May focus on: • Biological – E. coli, fish, algae. • Physical – flow, turbidity, erosion. • Chemical – levels of phosphorus and other nutrients, metal content.
Social Indicators. • Gauge public education efforts: • Use surveys or questionnaires. • Take attendance at events or meetings. • Behavior changes: • Observation. • Participation. • Increase or decrease in complaints.
Annual Report. • Status of compliance with permit conditions. • Progress towards reducing pollutants. • Summary of information and monitoring data. • Evaluation of the BMPs. • Assessment of efforts toward goals. • Statement of activities planned.
Due Dates. • Within 90 days from end of permit year. • Depends on 12 month period selected: • Permit. • Calendar. • Fiscal. • ExistingMS4’s 1st report must include all months since end of last reporting period. • NewMS4’s 1st report must include all months since permit effective date.
TCEQ Investigations. • Basic review becomes more comprehensive. • Recordkeeping and Reporting. • NOI/SWMP. • Annual Reports. • Supporting data. • Noncompliance Notification – 30 TAC 305.125(9). • Submitted timely. • Signatory requirements met. • Included required elements. • SWMP used as reference.
How to be in compliance… • Know the applicable sections of the permit. • Communicate throughout organization. • Use available resources and partners. • Implement and maintain appropriate controls. • Request to change SWMP when necessary. • Contact the TCEQ for guidance if needed.
Resources. • TCEQ: • Assistance Tools for Stormwater Permitting. • 319 Nonpoint Source Grant. • EPA: • Smart Growth Achievement Funding. • Environmental Workforce Development and Job Training Grant. • Other MS4s. • Councils of Government. • Texas Municipal League. • Texas Association of Counties.
Stormwater Permitting Program. Agency Contact Info. (technical questions). • 512-239-4671. • swgp@tceq.texas.gov. • Stormwater Permitting, MC-148. Texas Commission on Environmental Quality. P. O. Box 13087. Austin TX 78711-3087.
Stormwater Processing Center. Contractor Contact Info. (forms questions). • 512-239-3700. • swpermit@tceq.texas.gov. • Stormwater Processing Center, MC-228. Texas Commission on Environmental Quality. P. O. Box 13087. Austin TX 78711-3087.