NPDES Permit - PennDOT ECMS Frameset

NPDES Permit - PennDOT ECMS Frameset

Meeting Maintenances Requirements of Operating PennDOTs Municipal Separate Storm Sewer System NPDES NPDES Permit Permit -- PA PA I-1215-00-05-0002 I-1215-00-05-0002 Pennsylvania Department of Transportation Webinar Presented by: 12/11/2012; Slide 1 Rocksroy C. Bailey Apex Companies, LLC

www.dot.state.pa.us Learning Objectives Familiarity with Municipal Separate Storm Sewer System (MS4) and NPDES Permit Expectations of EPA and PADEP How this affects design, construction and maintenance personnel Reporting and deliverables 2/10/2012; Slide 2 www.dot.state.pa.us What is an MS4?

A conveyance or system of conveyances that is: Owned by state, city, town or public entity that discharges to waters Designated or used to collect or convey stormwater Not a combined sewer Not part of a publicly owned treatment works 2/10/2012; Slide 3 www.dot.state.pa.us Example Conveyance Includes roads with drainage systems,

municipal streets, catch basins, curbs, gutters, ditches, man-made channels, or stormwater drains that discharge untreated stormwater into the waters of the Commonwealth 2/10/2012; Slide 4 www.dot.state.pa.us Example Conveyance Two types of BMPs operated within

PennDOTs MS4s 2/10/2012; Slide 5 www.dot.state.pa.us Facility Related MS4 Examples of sheet flow towards a small retention basin 2/10/2012; Slide 6 www.dot.state.pa.us PennDOTs MS4 Transportation authorities are responsible for maintaining stormwater systems

Challenges Roads can convey polluted runoff Linear systems cross multiple watersheds and jurisdictions Stormwater systems convey pollutants sourced outside the ROW Solution NPDES Permit Management of their stormwater systems Develop/Implement comprehensive stormwater program 2/10/2012; Slide 7 www.dot.state.pa.us What is the NPDES MS4 Permit?

National Pollution Discharge Elimination System EPA, under Clean Water Act, seeks to eliminate water pollution by regulating point source discharges Point sources are discrete conveyances Pipes or man-made ditches 2/10/2012; Slide 8

www.dot.state.pa.us Who Must Have an NPDES Permit? Clean Water Act requires anyone discharging pollutants from one source into water: Municipal wastewater systems Industries and commercial facilities Concentrated animal feeding operations Municipal and industrial stormwater systems

2/10/2012; Slide 9 www.dot.state.pa.us Municipal Separate Storm Sewer Systems (MS4s) Operators of MS4s within designated urbanized areas must obtain NPDES Permit Also non-urbanized areas designated by permitting authority NPDES Phase I I -Designated Municipal MS4 Areas 4/ 18/ 2005 ERI E WARRE N

SUSQUEHANNA B RADFORD MCKE AN TI OGA POTT E R CRAWFORD WAYNE WYOMI NG FOREST

LACKAWANNA SULL I VAN CAME RON E LK VENANGO PI KE L YCOM I NG ME RCER

CLI NT ON CL ARI ON L UZE RNE JE FFERSON MONROE COL UMB I A MONTOUR L AWRE NCE CL E ARFI E LD CE NT RE UNI ON CARBON

B UTL ER NORTHUMBE RL AND ARMSTRONG NORTHAMPT ON SNYDER SCHUYL KI L L B EAVER I NDI ANA L EHI GH

MI FFL I N JUNI AT A CAMBRI A ALL E GHENY B L AI R PERRY B ERKS DAUPHI N LE B ANON HUNT I NGDON

BUCKS WEST MORE LAND MONT GOME RY WASHI NGT ON CUMBE RLAND L ANCAST E R BE DFORD GRE E NE 2/10/2012; Slide 10

PHI LADE L PHI A CHE ST ER SOM ERSET FAYE TT E FUL T ON FRANKL I N YORK DE L AWARE ADAMS

www.dot.state.pa.us Pennsylvania Urbanized Area Map Reference: http://cfpub.epa.gov/npdes/stormwater/urbanmapr esult.cfm?state=PA 2/10/2012; Slide 11 www.dot.state.pa.us Urbanized Area Map Details http://www.portal.state.pa.us/portal/server.pt/community/stormwater_m anagement/10628/urbanized_area_numbers/669155

1/18/2012; Slide 12 www.dot.state.pa.us Application to PennDOT MS4 Operational Permit No. PA 1-1315-00-50002 Five-year period beginning July 15, 2011 Effects: 2/10/2012; Slide 13

Maintenance, Design, Construction, Counties, Municipal Services, and Facilities Management www.dot.state.pa.us Permit Language Approval to discharge in accordance with the terms and conditions herein .. No condition or this permit shall release PENNDOT from any responsibility or requirement under Pennsylvania or Federal

environmental statutes and regulations. 2/10/2012; Slide 14 www.dot.state.pa.us Four Parts of the Permit Part Part Part Part

2/10/2012; Slide 15 A - Permit Elements B - General Conditions C Other Conditions D Special Conditions www.dot.state.pa.us Part A Effluent Limitations and Other Requirements Minimum Control Measures (MCMs) Reporting

2/10/2012; Slide 16 www.dot.state.pa.us Effluent Limitations PennDOT must: Implement Stormwater Management Program described in Permit Design to reduce discharge of pollutants Make level of effort maximum extent practicable So, what are you doing? 2/10/2012; Slide 17

www.dot.state.pa.us Six Established Minimum Control Measures 1. Public education and outreach on stormwater impacts 2. Pubic participation and involvement 3. Illicit discharge detection and elimination 4. Construction site runoff control 5. Post-construction stormwater management 6. Pollution prevention and good housekeeping 2/10/2012; Slide 18 www.dot.state.pa.us

Part B Permit Renewal Requirements Management Requirements Renewal, termination, revocation, amendment, etc Reporting Non-compliance, testing, record retention Responsibilities Duty to comply, penalties, etc. Definitions 2/10/2012; Slide 19

www.dot.state.pa.us Definitions Best Management Practices Activities, controls, planning or procedures to minimize accelerated erosion and sedimentation and manage stormwater to protect, maintain, reclaim and restore quality of surface waters and .before, during and after earth disturbance activities. 2/10/2012; Slide 20 www.dot.state.pa.us

Definitions Earth disturbance activity Construction or other human activity which disturbs surface of land, including land clearing, grubbing, grading, excavations. 2/10/2012; Slide 21 www.dot.state.pa.us Definitions Outfall

Point Source is point where MS4 discharges to surface waters of Commonwealth: this does not include open conveyances connecting two MS4s or pipes, tunnels or other conveyances which connect segments of same stream or other surface waters and are used to convey surface waters. 2/10/2012; Slide 22 www.dot.state.pa.us

Definitions Point Source Discernible, confined and discrete conveyance including, but not limited to, any pipe, ditch, channel, tunnel, conduit, well, discrete fissure, container, rolling stock CAAP, CAFO, landfill leachate collection system or vessel or floating craft from which pollutants are or may be discharged. 2/10/2012; Slide 23 www.dot.state.pa.us Definition

Illicit Discharge Any discharge (or seepage) to MS4 not composed entirely of stormwater. Examples include dumping of motor vehicle fluids, household hazardous waste, grass clipping, leaf litter, animal wastes, or unauthorized discharge of sewage, industrial waste, restaurant wastes. Illicit discharges can be accidental or intentional 2/10/2012; Slide 24 www.dot.state.pa.us Part C Other Conditions Discharges must be entirely

stormwater 14 exceptions including pools, springs, sumps, etc. Reporting Implementation of Minimum Control Measures (MCMs) Permit compliance Corrective actions 2/10/2012; Slide 25 www.dot.state.pa.us Part C Other Conditions Post Construction BMP Plan Review

Longer Term O&M of PC BMPs Certification 2/10/2012; Slide 26 www.dot.state.pa.us Part D - Special Conditions MCM 1 Public Outreach MCM 2 - Public Participation and Involvement MCM 3 - Illicit Discharge Detection/ Elimination MCM 4 - Construction Site Runoff Control MCM 5 - Post-Construction SW Mgmt in New Development and Redevelopment

MCM 6 Pollution Prevention and Good Housekeeping for Municipal Operations and Maintenance 2/10/2012; Slide 27 www.dot.state.pa.us Part D TMDL Plan Agree to develop TMDL Plan that addresses pollutant loading in: A. New discharges in urbanized areas B. Existing discharges in urbanized areas C. Reduction of TMDL system-wide Banking/credits for improvements outside urbanized areas Reduction in fertilizer and mowing cycles

2/10/2012; Slide 28 www.dot.state.pa.us Questions 2/10/2012; Slide 29 www.dot.state.pa.us MCM 3 Illicit Discharge Detection & Elimination IDD&E control measures: Develop maps of MS4 that identify outfalls, receiving streams, and EPA or DEP urbanized

areas Update procedures to detect illicit discharges in Publication 23 - Maintenance Manual Use STAMPP personnel to inspect 25% of roadway systems annually Train STAMPP and maintenance field personnel to detect observable discharges 2/10/2012; Slide 30 www.dot.state.pa.us MCM 3 Illicit Discharge Detection/ Elimination Publication 23, Chapter 8 Drainage and Drainage Systems

Drainage systems should operate as designed to convey stormwater away from road 8.4 Unlawful for any person to discharge sewage or drainage, except surface drainage, within legal limits of ROW Publication 73 Drainage Condition Survey Field Manual Identify and rate MS4 system 2/10/2012; Slide 31 www.dot.state.pa.us Illicit Discharge Examples 2/10/2012; Slide 32

www.dot.state.pa.us Illicit Discharge Examples 2/10/2012; Slide 33 www.dot.state.pa.us MCM 3-Illicit Discharge Detection Responses Observe and record characteristics Color, odor, sheen, flow, garbage/sewage, surrounding vegetation

condition Make reasonable efforts to trace discharge to source Document steps taken to identify and remove 2/10/2012; Slide 34 www.dot.state.pa.us MCM 3 - Illicit Connection An illegally connected pipe or any other improper connection that conveys illicit discharges to storm drain system or waterways.

Note Pipes Running to open waterway 2/10/2012; Slide 35 www.dot.state.pa.us MCM 3-Illicit Discharge Documentation Expected that records of field investigations include:

Date and exact place of observation(s) Name of individual making observation Description of observation Results of any screening or analytical testing performed 2/10/2012; Slide 36 www.dot.state.pa.us MCM 3-Illicit Discharge Documentation PennDOTs Illicit Discharge Reporting Form 2/10/2012; Slide 37 www.dot.state.pa.us

MCM3-Illicit Discharge Reporting Documentation sent to SEMP Section SEMP Section contacts and forwards information/records reported to PADEP 2/10/2012; Slide 38 www.dot.state.pa.us MCM3-Illicit Discharge Reporting Illicit discharge reporting from public Perform a site view Document conditions and screening as above Forward as above

2/10/2012; Slide 39 www.dot.state.pa.us MCM 3 Illicit Discharge Mitigation Appropriate steps to mitigate Document steps taken Contact PADEP if outside of PennDOTs control 2/10/2012; Slide 40 www.dot.state.pa.us MCM 3-Illicit Discharge Reporting

2/10/2012; Slide 41 http://www.depweb.state.pa.us/portal/server.pt/com munity/dep_home/5968 www.dot.state.pa.us MCM 3-Illicit Discharge Reporting Call appropriate PADEP region: >5 gallons hazardous material >5 gallons petroleum Incidents of illegal/ improper disposal

2/10/2012; Slide 42 www.dot.state.pa.us MCM 3 Program Goals Mapping of MS4 System High risk areas prioritized IDD&E Program developed Training Maintenance personnel trained Inspection 25% of MS4 system inspected and screened for illicit discharges

2/10/2012; Slide 43 www.dot.state.pa.us Questions 2/10/2012; Slide 44 www.dot.state.pa.us MCM 5 Post-Construction Stormwater Management Requires PennDOT to: Coordinate PCSM plans with County Conservation Districts and PADEP

Implement/update Anti-degradation and Post Construction Stormwater Management Policy Update/revise E&S, BMPs and stormwater control policies or guidance as operational observations dictate Seek partnerships for construction mitigation projects Provide training on erosion, sediment and stormwater control policy materials/guidance documents 2/10/2012; Slide 45 www.dot.state.pa.us MCM 5 Post-Construction Stormwater Management

Ensure NPDES PCSM BMPs operated and maintained 2/10/2012; Slide 46 www.dot.state.pa.us MCM 5 Post-Construction Stormwater Management What are inspection requirements? Use maintenance inspection and STAMPP Report and correct operational issues Use existing inspection forms 2/10/2012; Slide 47

www.dot.state.pa.us MCM 5 Post-Construction Stormwater Management Questions on MCM 5 2/10/2012; Slide 48 www.dot.state.pa.us MCM 6 Pollution Prevention and Good Housekeeping Targeted objectives PennDOT facilities: Winter services

Stockpiles and garage management Road maintenance activities Welcome Centers and Safety Rest Areas Employee training 2/10/2012; Slide 49 www.dot.state.pa.us MCM 6 Pollution Prevention and Good Housekeeping

Publication 23, Chapter Chapter Chapter Chapter 8 Drainage and Drainage Systems 12 Buildings and Grounds 20 Waste Management 21 Storage Tank Management

Publication 611 Combined Facility Response Plan SEM Program 2/10/2012; Slide 50 www.dot.state.pa.us MCM 6 Pollution Prevention and Good Housekeeping Chapter 8 Drainage & Drainage Systems Routine inspections to: Confirm satisfactory conditions Evaluate conditions for cleanup and repair 2/10/2012; Slide 51

www.dot.state.pa.us MCM 6 Pollution Prevention and Good Housekeeping Chapter 12 Buildings and Grounds Purpose to, ..maintain these facilities in a neat and tidy manner Includes: Maintenance of stormwater BMPs Proper materials storage 2/10/2012; Slide 52 www.dot.state.pa.us

MCM 6 Pollution Prevention and Good Housekeeping Chapters 20 and 21, Pub 611 and CFRP Reduce or eliminate waste Comply with regulations Appropriately plan and respond to spills/leaks 2/10/2012; Slide 53 www.dot.state.pa.us MCM 6 Pollution Prevention and Good Housekeeping Coordinated with local municipal MS4 Must define responsibility and maintenance

of any BMP in writing 2/10/2012; Slide 54 www.dot.state.pa.us MCM 6 - Program Goals Year 1: Information gathering Facilities stormwater inspection/condition Vehicle operations procedures and PP efforts Training (none at this time) Years 2-5: Review data and implement BMP maintenance program revise as necessary

Develop/implement/update facility pollution prevention plans Train employees on maintenance, PP and related 2/10/2012; Slide 55 www.dot.state.pa.us Questions Copyright 2011 by the Commonwealth of Pennsylvania. All rights reserved. No part of this publication may be reproduced, stored in a retrieval system, or transmitted in any form or by any means electronic, mechanical, photocopying, recording or otherwise without prior written permission by PennDOT. This training course was developed in partnership with the Pennsylvania Department of Transportations Business Leadership and Administrative Services Office and the Business Leadership and Administrative Services Office and the Bureau of Project Delivery and Apex Companies, LLC. It is offered as part of the Pennsylvania Department of

Transportations Highway Administration Comprehensive Training Plan exclusively through the Technical Training and 2/10/2012; Slide 56 Development Section. . www.dot.state.pa.us

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