TxDOT Strategies for Phase II MS4 Stormwater Compliance Dianna Noble, P. E. Environmental Affairs...
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Transcript of TxDOT Strategies for Phase II MS4 Stormwater Compliance Dianna Noble, P. E. Environmental Affairs...
TxDOT Strategies for TxDOT Strategies for Phase II MS4 Stormwater Phase II MS4 Stormwater
ComplianceCompliance
Dianna Noble, P. E.Dianna Noble, P. E.
Environmental Affairs DivisionEnvironmental Affairs Division
Texas Department of TransportationTexas 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 Texas Pollutant Discharge Elimination System (TPDES)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 Texas Urbanized Areas requiring a Areas requiring a
Phase II MS4 permitPhase II MS4 permit
ProposedProposed Texas Commission on Texas Commission on Environmental Quality (TCEQ) Phase II TPDES Environmental Quality (TCEQ) Phase II TPDES
MS4 General PermitMS4 General PermitTCEQ 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.
ProposedProposed TCEQ Phase II TPDES TCEQ Phase II TPDES MS4 General Permit – Court CaseMS4 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 SWMPsTxDOT MS4 Phase II SWMPs
EPA and TCEQ recommend that MS4s EPA and TCEQ recommend that MS4s which will require Phase II permits which will require Phase II permits develop SWMPs now – do not wait for the develop SWMPs now – do not wait for the General Permit.General Permit.
TxDOT is developing and will implement a TxDOT is developing and will implement a Phase II SWMP. Phase II SWMP.
Proposed Texas Phase II MS4 Proposed Texas Phase II MS4 General PermitGeneral Permit SWMP will require SWMP will require
implementation over 5 years; includesimplementation over 5 years; includes
1. Public Education & Outreach 2. Public Involvement and Participation3. Illicit Discharge Detection and Elimination4. Pollution Prevention & Good Housekeeping 5. Construction Site Runoff Control6. Post-Construction Storm Water Management7. Authorization for Municipal Construction
Activities (Optional Measure)
Six Minimum Control Measures (MCMs)Six Minimum Control Measures (MCMs)
TCEQ requires SWMP to be implemented TCEQ requires SWMP to be implemented over 5 yearsover 5 years
TxDOT Districts may incorporate current TxDOT Districts may incorporate current Phase I SWMP provisions into Phase II Phase I SWMP provisions into Phase II SWMPSWMP
TxDOT Phase II MS4 ImplementationTxDOT Phase II MS4 Implementation
TxDOT StrategiesTxDOT Strategies
Stormwater Runoff Control and Water Quality Stormwater Runoff Control and Water Quality Research ProjectsResearch Projects
Support TxDOT Districts with Engineering Support TxDOT Districts with Engineering Consultant Services Contracts for Phase II Consultant Services Contracts for Phase II implementationimplementation
Build on TxDOT Storm Water ProgramsBuild on TxDOT Storm Water Programs
Strategies - Strategies - continuedcontinued Worked with stakeholder groups and TCEQ to Worked with stakeholder groups and TCEQ to
influence TCEQ’s original General Permit.influence TCEQ’s original General Permit.
Will work with stakeholders and TCEQ again to Will work with stakeholders and TCEQ again to implement Court directed requirements.implement Court directed requirements.
Will work with TCEQ to develop statewide Will work with TCEQ to develop statewide transportation Phase II MS4 General Permittransportation Phase II MS4 General Permit
TxDOT MS4 Work Group will continue to develop TxDOT MS4 Work Group will continue to develop guidance for six required Phase II MS4 Minimum guidance for six required Phase II MS4 Minimum Control Measures for TxDOT Districts.Control Measures for TxDOT Districts.
ResearchResearchTexas Transportation Institute, Texas A & M University,
Texas Department of Transportation
Design Methods, Selection, and Cost-Effectiveness 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 Cost per pound of TSS removed from Infiltration BasinsInfiltration Basins
0.00
0.50
1.00
1.50
2.00
2.50
3.00
3.50
0 10 20 30 40 50 60
Watershed in Acres
Co
st p
er P
ou
nd
in D
olla
rs
Concrete
Partial Concrete
Earthen
% Percent Pollutant Removal of Stormwater BMPs
TSS Total Phos-phorous
Total Nitrogen
Lead Zinc 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
ResearchResearchCenter for Transportation Research, The University of Texas Center for Transportation Research, The University of Texas
at Austin, Texas Department of Transportationat 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
TSSTSS TKNTKN NitrateNitrate TPTP Total Total ZincZinc
Fecal Fecal Colif.Colif.
Austin Sand Austin Sand FiltersFilters
HighHigh MedMed LowLow MedMed MedMed MedMed
Extended Extended Detention Detention BasinBasin
MedMed LowLow LowLow MedMed HighHigh LowLow
Wet BasinWet Basin HighHigh LowLow MedMed LowLow HighHigh HighHigh
Infiltration Infiltration BasinBasin
HighHigh HighHigh HighHigh HighHigh HighHigh HighHigh
Vegetated Vegetated SwalesSwales
LowLow MedMed LowLow LowLow HighHigh LowLow
Buffer StripsBuffer Strips MedMed LowLow LowLow LowLow HighHigh VariedVaried
Effectiveness of BMPs in Removing ConstituentsEffectiveness of BMPs in Removing Constituents
Effectiveness of BMPs in Removing Effectiveness of BMPs in Removing Constituents in Highway RunoffConstituents in Highway Runoff
-150
-100
-50
0
50
100
150
% Removal TSS
% Removal Total Zinc
% Removal Nitrate
% Removal Total Phosphate
TSS
TZ
TP
TNAustin Sand Filter
Unlined Extended Detention Basin
Wet Basin
Vegetated Buffer Strip
Swale
Percent Removal
Storm Water ContractsStorm Water Contracts 5 Contracts awarded for environmental engineering consultant 5 Contracts awarded for environmental engineering consultant
services. services.
Total award amount $2,500,000Total award amount $2,500,000
Assist TxDOT Districts with MS4 and Construction Storm Water Assist TxDOT Districts with MS4 and Construction Storm Water Permit requirements.Permit requirements.
Train TxDOT Districts’ staff on TPDES CGP and MS4 storm water Train TxDOT Districts’ staff on TPDES CGP and MS4 storm water permits.permits.
Perform various statewide Phase I and Phase II MS4 program Perform various statewide Phase I and Phase II MS4 program components.components.
Perform MS4 compliance tracking.Perform MS4 compliance tracking.
Storm Water ContractsStorm Water Contracts(continued)(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 ContractsUse of Storm Water Contracts TxDOT Dallas DistrictTxDOT Dallas District
$480,000 for total Phase II Program$480,000 for total Phase II Program
TxDOT Ft. Worth DistrictTxDOT Ft. Worth District $100,000 for Phase II Outfall Mapping and $100,000 for Phase II Outfall Mapping and
ScreeningScreening
Environmental Affairs DivisionEnvironmental Affairs Division Stormwater Field Inspector’s GuideStormwater Field Inspector’s Guide
SummarySummary
Continue dialog with TCEQContinue dialog with TCEQ
TxDOT MS4 Work Group to continue TxDOT MS4 Work Group to continue developing guidance for TxDOT Districtsdeveloping guidance for TxDOT Districts
Use Environmental Engineering Consultants Use Environmental Engineering Consultants contractscontracts
TxDOT Strategies for Phase II MS4 Stormwater Compliance
Questions?