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Texas Pollutant Discharge Elimination System (TPDES) Permitting Municipal Separate Storm Sewer Systems (MS4s) Water Quality Seminar October 13, 2016 Rebecca L. Villalba Elizabeth Dickinson Texas Commission on Environmental Quality Stormwater & Pretreatment Team Water Quality Division (512) 239 4671 Municipal Separate Storm Sewer Systems (MS4)
A MS4 is a publicly owned or operated stormwater drainage system designed to collect or convey stormwater NPDES Electronic Reporting Rule Final rule was effective on December 21, 2015 40 CFR Part 127 Waiver option from electronic reporting is available
Religious beliefs No internet access Others Final rule available at EPA website: http://www2.epa.gov/compliance/proposednpdes-electronic-reporting-rule NPDES Electronic Reporting Rule Requirements Phase I effective December 21, 2016 Discharge Monitoring Reports (DMRs) must be
submitted electronically TCEQ is moving to EPAs NetDMR system Phase II effective Dec. 21, 2020 States submit implementation plan for meeting Phase II requirements to EPA by Dec. 21, 2016 General permit applications must be submitted electronically MS4 annual reports must be submitted electronically National Pollutant Discharge Elimination System (NPDES) Phase II MS4 Remand Rule 40 CFR 122.33 and 122.34
Proposed rule published in Fed. Reg. Jan. 6, 2016 Proposal includes three options for states to administer their Phase II MS4 programs Option 1: Traditional general permit approach Option 2: Procedural approach Option 3: State choice approach EPA states rule would not establish new requirements on MS4s TCEQ supports Option 3 National Pollutant Discharge Elimination System (NPDES) Phase II MS4 Remand Rule
40 CFR 122.33 and 122.34 EPA is working on finalizing the language EPA held two focused conference calls with states to ask questions On June 22, 2016, six states, including Texas attended the EPA closed face-to-face meeting in Washington DC to discuss the final draft. EPA showed the draft final rule to the states in attendance States discussed concerns with the language
Language for the final rule expected to be complete by November 2016 Which MS4s are Regulated? Medium and Large MS4s (Phase I) Individual TPDES Permits Small MS4s in urbanized areas (Phase II) TCEQ General Permit Phase I MS4s Medium and Large MS4s
Municipal population 100,000+ (1990 Census) Includes public entities in the urbanized area (UA) TxDOT, universities, MUDs, etc. Universe: 26 individual TPDES permits Includes 50 permittees due to coalitions *No new permits issued Requirements of Phase I MS4s Develop a Stormwater Management Program (SWMP) to address Minimum Control Measures (MCMs)
Public Education and Outreach/Public Involvement and Participation Pollution Prevention/Good Housekeeping for Municipal Operations MS4 Maintenance Activities Illicit Discharge Detection and Elimination Construction Site Runoff Post-Construction Control Measures Industrial & High Risk Runoff Requirements of Phase I MS4s Perform Monitoring - three options 1. Representative Storm Events, 2. Representative Rapid Bioassessment, or 3. Watershed Monitoring - Regional Wet Weather Characterization Program
(Dallas-Fort Worth area) Coordinated by North Central Texas Council of Governments Eight members Program reviewed and approved by TCEQ Requirements of Phase I MS4s Monitoring of Floatables Often required in 2 locations at a frequency 2 times per year Report collected amount Submit Annual Reports TCEQ reviews and provides feedback
Phase I MS4s Permit Renewals EPA Review on Renewals from 2011 Requested similar requirements as Phase II MS4 General Permit Priority areas MS4 maps Impaired waterbodies Requesting to see inspection or audit reports completed by TCEQ Phase I MS4 Permit Renewals Renewals - 2016 All permits will be revised to address comments made by EPA on previous MS4 permits Measurable goals are required for MCMs Provision from existing permits are continued
E-Reporting Rule provisions for DMRs and annual reports No other major changes are expected Use application form TCEQ-20214 no changes Attachment 4 will be requested by permit writer Senate Bill 709 New notice requirement TxDOT MS4 Statewide Individual Permit WQ0005011000 Application received March 18, 2013 Coverage will replace 15 Phase I individual permits 19 Phase II authorizations under the Phase II GP
Coverage will include 22 new Phase II MS4 areas Image of TxDOT home page TxDOT MS4 Statewide Individual Permit WQ0005011000 Transition Period Previous Phase I MS4 co-permittees reapply without TxDOT All requirements in Phase I and Phase II MS4 permits need to be met TxDOT Phase I responsibilities will be carried over to the statewide individual
permit TxDOT MS4 Statewide Individual Permit WQ0005011000 Permit Timeline February 2016 - EPA approval of permit April 8 to May 16 2016 - Public notice and comment period 10 entities submitted comments in 6 letters 4 entities requested a public hearing
Response to Comments completed Aug. 15, 2016 Phase II MS4 Program Small MS4s in urbanized areas (UAs) Population based on the 2000 and 2010 Censuses Regulated via a general permit Waiver option Individual TPDES permit is an option
Compliance History rating Other considerations *Image courtesy of the City of Round Rock Phase II MS4 General Permit TXR040000 Renewed December 13, 2013 Expires December 13 2018 Tiered Permitting Approach - based on population served by the MS4 Level 1 less than 10,000
Level 2 - at least 10,000 to less than 40,000 includes non-traditional MS4s Level 3 - at least 40,000 to less than 100,000 Level 4 - 100,000 or more *Based on the 2000 and 2010 Censuses Waiver Option from Permitting Requirements Option 1 Serves a population less than 1,000 and Discharge not contributing substantially to interconnected regulated MS4 No TMDL or WLA for an impaired water body that requires the MS4 to have additional controls Option 2
Serves a population under 10,000 and Receiving water has been evaluated No TMDL or WLA for an impaired water body that requires the MS4 to have additional controls Future discharge will not impair water body Phase II MS4s Active Authorizations There are 515 NOIs and 77 Waivers 21 percent are level 1 52 percent are level 2 9 percent are level 3 2 percent are level 4 16 percent are waivers 515 NOIs
77 Waivers Phase II MS4 SWMP Minimum Control Measures (MCMs) 1. 2. 3. 4. Public Education, Outreach, and Involvement Illicit Discharge Detection and Elimination Construction Site Stormwater Runoff Control Post-Construction Stormwater Management in New Development and Redevelopment 5. Pollution Prevention and Good Housekeeping for Municipal Operations
6. Industrial Stormwater Sources (Level 4 only) 7. Optional MCM for Construction done by the Permittee (MS4) Select measurable goals frequency, month and year Stormwater Management Program Implementation of SWMP Develop a schedule Implemented over the 5 year permit term Must be fully implemented at the end of the 5 year permit term Coalitions Develop, implement, and share same SWMP
Each MS4 is responsible for own compliance Enter into agreements with clear delineation of responsibilities Phase II MS4 General Permit Applying for Coverage Submit: Notice of Intent (NOI), Form TCEQ 20368 SWMP Fee TCEQ performs technical review of SWMP MS4 publishes public notice in newspaper Opportunity for the public to view and/or submit comments on the NOI and SWMP 30-Day comment period
NOI Technical Review Common Issues No response to emails MCM 1a and 1b are separate MCM 3 and 4 cannot be combined Month/Year/Frequency is missing Measurable goals are not clear How to resolve issues
Get help from the TCEQ Speak with your permit coordinator Contact Small Business and Local Government assistance (SBLGA) Communicate with neighboring MS4s Phase II MS4 Notice of Change Notice of change (NOC)
Changes to SWMP Form Number TCEQ 20392 Submit separately from the Annual Report NOC is needed for Replace an infeasible BMP with an alternative BMP All other changes specified in permit NOC is not needed for Adding BMPs or replacing a BMP with a similar BMP Non-substantive changes De-annexing land Impaired Water Bodies Additional Permit Requirements
Category 5 - CWA 303(d) for stream segment, no TMDL Category 4 - Not on CWA 303(d), with watershed TMDL 2014 Texas Integrated Report Index of Water Quality Impairments Image of page from texas integrated report Phase II MS4 Annual Report
Annual Due 90 days after last day of the selected reporting year Flexibility selecting reporting year Report Fiscal year, calendar year, or permit year Reporting year can not change during the
permit term Phase II Annual Reports Submit the original report to the TCEQ Stormwater & Pretreatment Team (MC 148) Submit a copy of the report to the appropriate TCEQ regional office Specify in the report cover letter that the TCEQ Regional Office has been sent a copy of the report
Retain a copy of the report on site Always use the most recent template Annual Report template (Form 20561) available: http://www.tceq.texas.gov/assistance/water/sw-ms4.html Annual Reports Helpful Hints Report enough detail to be useful for MS4 and TCEQ
Include a cover letter on letterhead with essential information e.g., date, the TCEQ Region the MS4 is located in, MS4 name and permit authorization number, and any other MS4s names and numbers if in a coalition Coalition reports should include associated entity with certification signature Annual Reports Helpful Hints Always send certifications with original, wet ink signatures, not scanned or copied Always indicate which reporting year option you have chosen with exact dates of the period Please respond to e-mails requesting information
in a timely manner This is the time to report your accomplishments and show your progress! Phase II Annual Reports Issues identified during reviews
Not including annual reporting option: Calendar, Permit, Fiscal Year Cover letter missing or lacking information Not specifying last day of fiscal year Not quantifying activities conducted Not responding to requests for information Revised Annual Report template released based on lessons learned Remember to use the SWMP and Permit as a reference! Phase II Annual Reports
Common Reasons for receiving a request for information Signature is a scan, photocopy or e-signature MS4 did not use the current template Impaired waters information left blank Number of construction sites missing Not all BMPs are included Reporting dates are missing
Improvement Annual reports need to show improvement Each year the MS4 needs to work a little harder, make a little more progress Dont be satisfied with doing ok, aim to be great! If you have the resources to go further, do it! Remember, each permit renewal will have more requirements, prepare now! Dont be afraid to think outside the box! Tried and True BMPs Stormwater Hotlines Public education classes, posters, and websites Inlet markers
Staff training SWP3 review Pet waste stations Fat, oil, and grease education Unique BMPs Here are some fun and unique BMPs Texas MS4s have implemented Christmas tree pick up Geocaching course with stormwater information Environmental topic art contest Annual Environmental Compliance Achievement Award Custom grates and manhole covers Public transportation stormwater
announcements TPDES Stormwater Program Contacts Water Quality Division Stormwater & Pretreatment Team Rebecca L. Villalba, Team Leader Hanne Lehman Nielsen Dan Siebeneicher Lindsay Garza Gordon Cooper Kent Trede Elizabeth Dickinson Austin Office: (512) 239-4671 Contact Information Small Business and Local Government Assistance
(SBLGA) (800) 447-2827 [email protected] http://www.tceq.texas.gov/assistance Permitting Information (Technical) (512) 239-4671 [email protected] https://www.tceq.texas.gov/permitting/stormwater Questions? Picture of five hands holding a water circle
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