Storm Water Management Plan Guidance

OVERVIEW

The TPDES MS4 Storm Water general permit requires that a Storm Water Management Program (SWMP) be developed and implemented. The program must address each of the following Six Minimum Control Measures:

A 7th optional control measure may be developed to allow for construction activities where the MS4 is the operator.

As the MS4 operator, you have the flexibility to determine which Best Management Practices (BMPs) are suitable and practicable for your municipality to efficiently address storm water management and fulfill the requirements of the general permit. Each BMP must include Measurable Goals and a schedule of implementation which is over the course of five (5) years. The chosen BMPs and measurable goals submitted in the application become your municipality’s requirements of the Phase II General Permit. What you submit to the TCEQ is what you are required to accomplish over the permitting cycle.

The General Permit allows for small MS4s that are physically interconnected, located in the same urbanized area, or are located in the same watershed to combine or share efforts in meeting the SWMP requirements. Each permittee is entirely responsible for meeting the SWMP within the boundaries of their MS4. Even though efforts may be shared or combined, each MS4 is required to submit their own SWMP to the TCEQ.

Any storm water management activities initiated up to three years prior to permit issues may be included in the SWMP under the appropriate headings. Small MS4s are encouraged to evaluate current programs and/or activities and identify gaps and opportunities to expand or improve.

Prior to submitting your Notice of Intent (NOI) and SWMP to the TCEQ, please review the requirements of the final permit once it is issued. This guidance is based upon the requirements stated in the draft permit that was released in the Texas Register on September 27, 2002. The proposed draft permit for Phase II MS4s can be found at the TCEQ website http://www.tnrcc.state.tx.us/permitting/waterperm/wwperm/tpdestorm.html.

<Back to Top

PUBLIC EDUCATION AND OUTREACH

The outreach must inform the public about the impacts polluted storm water run-off can have on water quality, hazards associated with illegal discharges and improper disposal of waste, and ways they can minimize their impact on storm water quality.

An informed and knowledgeable community is crucial to the success of a storm water management program. The program will gain support as the community becomes informed as to how their actions can affect storm water quality. When communities become aware of their surroundings, they gain a sense of responsibility for those actions.

A reasonable attempt should be made by the MS4 operator to distribute educational materials or conduct outreach activities regarding the impacts of storm water discharges on Galveston Bay and local waterbodies and the steps that can be taken to reduce or prevent storm water pollution.

The outreach should be targeted to the following constituents:

Outreach examples for individuals and homeowners are:

You may use storm water educational materials provided by TCEQ, EPA, public-interest groups, Texas Cooperative Extension or any other MS4. You are encouraged to tailor your program to address the needs and viewpoints of all communities which include children, minority and disadvantaged communities, and the business community. The permit allows separate MS4s to work jointly on community projects.

Your outreach program could include, but certainly are not limited to:

<Back to Top

PUBLIC INVOLVEMENT/PARTICIPATION

Your public involvement and participation program must include provisions to allow opportunities for all constituents. You must comply with State and local public notice requirements when implementing this program.

Public participation establishes ownership of a community by those who live and work in them. Community participants offer a broad range of expertise and are a valuable and free resource. Community-wide programs can establish connections between local government and environmental and public interest groups. As people become involved and take part in the development and implementation of the program, they take on a sense of responsibility. With this support, people may be less likely to challenge the MS4’s program which could lead to delays and hinder the program’s success.

Examples of public involvement activities are:

Activities/Public Participation

Involvement/Public Opinion

<Back to Top

ILLICIT DISCHARGE DETECTION AND ELIMINATION

You must develop, implement and enforce a program to detect and eliminate illicit discharges into your small MS4. And a section within the SWMP must be developed to establish a program to detect and address non-storm water discharges and illegal dumping.

The State defines an illicit discharge as “…any discharge to a municipal separate sewer system that is not entirely composed of storm water…” with some exceptions such as firefighting activities. These discharges are considered illicit because the MS4s are not designed to accept, process, or discharge non-storm water wastes. Also known as dry weather flows, illicit discharges originate from a number of sources beginning with mistaken or deliberate wastewater connections to the MS4. Dry weather flows could also originate from an illicit connection such as infiltration into the MS4 or spills flowing into storm drains. People pouring used oil or paint into storm drains is also considered illicit discharges. Through various EPA studies, illicit discharges have shown to contain high levels of pollutants including heavy metals, toxics, oil and grease, solvents, nutrients, viruses, and bacteria. These levels were found to be high enough to significantly impact the water quality of the receiving waters which is a threat to the aquatic, wildlife, and human health.

The SWMP must include or address the following:

For complete and detailed requirements, please refer to the draft permit available at http://www.tceq.state.tx.us.

Storm Sewer Map

A map of the storm sewer system must be developed and must include the following:

The SWMP must include the source of information used to develop the storm water map, including how the outfalls were verified and how the map with be regularly updated.

The map is not submitted with the NOI and SWMP to the TCEQ. Actions to develop the map must be initiated when the permit has been issued. The permit does not require the map to be intensely complicated, just thorough.

<Back to Top

POLLUTION PREVENTION/GOOD HOUSEKEEPING FOR MUNICIPAL OPERATIONS

You must develop and implement an operation and maintenance program that includes a training component and has the ultimate goal of preventing or reducing pollutant runoff from municipal operations.

Municipal Operations

This measure is a key element of the small MS4 storm water management program. The MS4 operator must examine their current operations and maintenance program and ultimately alter their actions to help reduce pollution when performing municipal activities and from municipal owned areas.

The SWMP must include a list of all:

Examples of municipal operations and municipally owned areas include, but are not limited to:

Properly developed and implemented operation and maintenance programs reduce the risk of water quality problems as a result of improperly managed municipal activities. Examples of municipal activities that may be considered are but not limited to:

Disposal

Procedures for appropriate disposal of pollutants must be developed to include procedures for the proper disposal of waste including:

Training Program

The training program must be developed for all employees responsible for municipal operations subject to the pollution /prevention/good housekeeping program.The training program must include training materials directed at preventing and reducing storm water pollution from municipal operations. Examples must be included in the SWMP.

Examples of employee training:

Structural Control Maintenance

If best management practices include structural controls, maintenance of the controls must be performed at a frequency determined by the MS4 and consistent with maintaining the effectiveness of the BMP. The SWMP must list all of the following:

The SWMP must include an individual permit number, general permit authorization number, or a copy of a signed NOI or NEC for each industrial activity conducted by the MS4 and subject to TPDES storm water regulations.

<Back to Top

CONSTRUCTION SITE STORM WATER RUNOFF CONTROL

You must develop, implement, and enforce a program to reduce pollutants from construction activities that result in a land disturbance of greater than or equal to one acre.

Activities associated with development and construction usually involves disturbing a large amount of land leaving the site void of vegetation and implements and materials exposed to the elements. Large amounts of waste are also generated at a construction site. Run-off from construction sites have been found to contain high levels of sediment, construction chemicals and debris, phosphorous and nitrogen from fertilizers, pesticides and petroleum derivatives. The siltation and the contribution of other pollutants due to construction site run- off can cause physical, chemical, and biological harm to our wetlands, bayous, and bay.

The program must include the development and implementation of, at a minimum, an ordinance or other regulatory mechanism to require erosion and sediment controls, as well as sanctions to ensure compliance.

Because there may be limitations on regulatory legal authority, the small MS4 operator is required to satisfy this minimum control measure only to the maximum extent practicable and allowable under State, Tribal, or local law.

Requirements for construction site contractors to:

The MS4 operator must develop procedures for:

<Back to Top

POST-CONSTRUCTION STORM WATER MANAGEMENT IN NEW DEVELOPMENT AND REDEVELOPMENT

The MS4 operator must develop, implement, and enforce a program to address storm water runoff from new development and redevelopment projects that disturb greater than or equal to one acre.

Post-construction run-off controls are necessary to maintain good water quality conditions after an area has be developed. The increased impervious surface area creates more run-off to waterbodies during storm events. Also, as water flows over an area that has been transformed by development, it picks up harmful sediment and chemicals which become suspended in the run-off and are discharged into our local bayous and ultimately Galveston Bay. Your storm water management program must ensure that controls are in place to prevent or minimize water quality impacts and try to maintain pre-development runoff conditions.

Water quality impacts and run-off issues can be addressed efficiently with sound planning procedures. Minimization of impervious surfaces, wetland protection, and vegetated drainage ways are some of the control that may be considered for use during the design phase of the project. You may also consider agreements or ordinances which place the responsibility of structural controls on the property owner. Examples of other cities’ ordinances can be found at http://www.epa.gov/owow/nps/ordinance/storm water.htm.

Authorization for Municipal Construction Activities

The development of Minimum Control Measures (MCM) for municipal construction activities is an optional measure and is an alternative to the MS4 seeking coverage under TPDES general permit TXR150000.

GENERAL REQUIREMENTS

Permittees must provide documentation of the development, implementation, and evaluation of the SWMP. The documentation must be included in the SWMP and may be required to be submitted in the annual report.

At a minimum, the documentation must include:

These items are required elements stated in the draft permit to be part of the SWMP that supports the General Permit Application to the TCEQ.

<Back to Top