Transcript SCOE-SCOD, Noble, TX, Stormwater Compliance

TxDOT Strategies for
Phase II MS4 Stormwater
Compliance
Dianna Noble, P. E.
Environmental Affairs Division
Texas Department of Transportation
SCOE/SCOD Meeting
June 2004
In Strategy the longest way round is often the shortest way there…
B.H. Liddell Hart
Texas Pollutant Discharge Elimination
System (TPDES)
 1987 amendments to the Clean Water Act required EPA to
permit storm water discharges.
 Phase I, finalized in 1990 required NPDES storm water permits
for industrial activities and large cities.
 EPA approved the TPDES Program in September, 1998.
 Phase II became final in December, 1999. All MS4’s within
urbanized areas with populations less than 100,000 must
obtain a TPDES MS4 permit.
 TPDES Phase II MS4 rules apply to 233 Texas small towns and
rural areas, and state highway system roads within urbanized
areas.
Texas Urbanized
Areas requiring a
Phase II MS4 permit
Proposed Texas Commission on
Environmental Quality (TCEQ) Phase II TPDES
MS4 General Permit
TCEQ published a draft Phase II MS4 General Permit in
September, 2002 to permit storm water discharges from
small MS4’s.
Permit Requirements
 Small MS4s must implement a Storm Water Management
Program (SWMP) to reduce discharge of pollutants to the
maximum extent practicable.
 SWMP must include Six Minimum Control Measures, Best
Management Practices and Measurable Goals.
 MS4 operator must submit an NOI and SWMP, or individual
permit application.
 Permit Coverage is for 5 years.
Proposed TCEQ Phase II TPDES
MS4 General Permit – Court Case
 The permit has not been finalized. The March 10, 2003
permit deadline was delayed by a Federal Appeals Court
case.
 The Court said EPA must amend the general permitting
option for Phase II MS4s to comply with the Clean Water
Act regarding
Review of NOIs by TCEQ
 Opportunity for public hearing on NOIs
 Public availability of NOIs

TxDOT MS4 Phase II SWMPs

EPA and TCEQ recommend that MS4s
which will require Phase II permits
develop SWMPs now – do not wait for the
General Permit.

TxDOT is developing and will implement a
Phase II SWMP.
Proposed Texas Phase II MS4
General Permit SWMP will require
implementation over 5 years; includes
Six Minimum Control Measures (MCMs)
1.
2.
3.
4.
5.
6.
7.
Public Education & Outreach
Public Involvement and Participation
Illicit Discharge Detection and Elimination
Pollution Prevention & Good Housekeeping
Construction Site Runoff Control
Post-Construction Storm Water Management
Authorization for Municipal Construction
Activities (Optional Measure)
TxDOT Phase II MS4 Implementation
 TCEQ requires SWMP to be implemented
over 5 years
 TxDOT Districts may incorporate current
Phase I SWMP provisions into Phase II
SWMP
TxDOT Strategies
Stormwater Runoff Control and Water Quality
Research Projects
Support TxDOT Districts with Engineering
Consultant Services Contracts for Phase II
implementation
Build on TxDOT Storm Water Programs
Strategies - continued
Worked with stakeholder groups and TCEQ to
influence TCEQ’s original General Permit.
Will work with stakeholders and TCEQ again to
implement Court directed requirements.
Will work with TCEQ to develop statewide
transportation Phase II MS4 General Permit
TxDOT MS4 Work Group will continue to develop
guidance for six required Phase II MS4 Minimum
Control Measures for TxDOT Districts.
Research
Texas Transportation Institute, Texas A & M University,
Texas Department of Transportation
Design Methods, Selection, and CostEffectiveness of Stormwater Quality Structures
(Project Number 0-1837)
 Cost comparison index to identify the most cost effective stormwater
BMP options for meeting stormwater quality requirements.
 Lifecycle cost in relation to efficiency in removing TSS, the primary
index pollutant in storm water
 Design methods for estimating pollutant loads and sizing selected
structures.
Cost per pound of TSS removed from
Infiltration Basins
Cost per Pound in Dollars
3.50
3.00
Concrete
2.50
Partial
Concrete
2.00
1.50
1.00
0.50
Earthen
0.00
0
10
20
30
40
Watershed in Acres
50
60
% Percent Pollutant Removal of
Stormwater BMPs
TSS
Total
Total
Lead Zinc
PhosNitrogen
phorous
Oil &
Grease
Detention Ponds
(48 hr. detention)
90
50
50
50
90
70
Wet Ponds
80
51
33
45
66
n/a
Infiltration Ponds
90
70
50
55
90
75
Water Quality
Swales
80
35
75
75
75
65
Stormwater
Wetlands
75
50
30
50
60
n/a
Research
Center for Transportation Research, The University of
Texas at Austin, Texas Department of Transportation
Process Framework for Identifying and Prioritizing
Water Quality Improvement for Meeting TMDLs in Texas
(Project Number 0-4252)
 To anticipate the requirements of the TMDL process and have data at
hand to respond if TxDOT is identified as contributing to the impairment.
 Identified major causes of impairment of water bodies in Texas as bacteria
and low dissolved oxygen concentrations.
 Interactive GIS map of the impaired streams was created in ArcGIS to aid
TxDOT in identifying where the impaired segments are in relation to major
highways and roads.
Impaired Stream
Segments in Texas
shown in Red
Effectiveness of BMPs in Removing Constituents
TSS
TKN
Nitrate
Austin Sand
Filters
High
Med
Low
Med
Med
Med
Extended
Detention
Basin
Med
Low
Low
Med
High
Low
Wet Basin
High
Low
Med
Low
High
High
Infiltration
Basin
High
High
High
High
High
High
Vegetated
Swales
Low
Med
Low
Low
High
Low
Buffer Strips
Med
Low
Low
Low
High
Varied
TP
Total
Zinc
Fecal
Colif.
Effectiveness of BMPs in Removing
Constituents in Highway Runoff
Percent
Removal
150
100
TSS
TZ
50
TP
% Removal TSS
% Removal Total Zinc
0
Unlined
Extended
Detention
Basin
-50
-100
-150
TN
Austin
Sand
Filter
% Removal Nitrate
Wet
Basin
Vegetated
Buffer
Strip
% Removal Total Phosphate
Swale
Storm Water Contracts
 5 Contracts awarded for environmental engineering consultant
services.
 Total award amount $2,500,000
 Assist TxDOT Districts with MS4 and Construction Storm Water
Permit requirements.
 Train TxDOT Districts’ staff on TPDES CGP and MS4 storm water
permits.
 Perform various statewide Phase I and Phase II MS4 program
components.
 Perform MS4 compliance tracking.
Storm Water Contracts
(continued)
 Field inspections of TxDOT construction sites to
determine compliance with TPDES Construction
General permit requirements.
 Train TxDOT Districts’ staff on selection, design,
installation and maintenance of temporary and
permanent erosion and sediment control measures
and other BMPs.
Use of Storm Water Contracts

TxDOT Dallas District


TxDOT Ft. Worth District


$480,000 for total Phase II Program
$100,000 for Phase II Outfall Mapping and
Screening
Environmental Affairs Division

Stormwater Field Inspector’s Guide
Summary
TxDOT Strategies for Phase II
MS4 Stormwater Compliance
 Continue dialog with TCEQ
 TxDOT MS4 Work Group to continue
developing guidance for TxDOT Districts
 Use Environmental Engineering Consultants
contracts
Questions?