minimum requirements for construction site compliance
TRANSCRIPT
MS4 Requirements for Construction Site Storm Water
Runoff Control
Craig T. Maske, P.E., CFM
DODSON | A WALTER P MOORE COMPANY
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Presentation Topics
• Definitions
• MS4 and Construction Site Operator Requirements
• Tools for Reviewers/Inspectors
• Questions
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Definitions
• Municipal Separate Storm Sewer System
• Regulated Construction Site
– Small
– Large
• Storm Water Pollution Prevention Plan (SWP3)
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Pre-Construction Requirements
• Construction Site Operator
– Prepare Storm Water Pollution Prevention Plan (SWP3)
– Notify TCEQ of intent to discharge
– Notify MS4 operator
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Pre-Construction Requirements
• Large and Small Construction Sites
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Prepare SWP3 X X
Submit NOI to TCEQ X ---
Submit NOI to MS4 Operator X (7 Days) X (2 Days)
Post Site Notice at Entrance X X
Post NOI at Entrance X ---
Large Sites
(>=5 Ac)
Small Sites
(>1 Ac < 5 Ac)Task Notes
Fee $225/$325 (efile/paper)
(Small Sites Submit Site Notice)
Obtaining CGP Coverage
Pre-Construction Requirements
• MS4 Operator
– Review Site Plans/SWP3
– Receive and File NOI/Site Notice
– Issue Local Permits
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Pre-Construction Requirements
• Storm Water Pollution Prevention Plan Review
– SWP3 must contain all elements noted in Part III, Section F of TCEQ permit
– Many of these elements are not prepared until after permitting
– Additional elements added by Construction Site Operator prior to construction
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SWP3 Versus SWP3
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Construction Requirements
• BMPs must be planned and implemented
– Sediment and erosion controls
– Waste controls
– Other controls
• Inspections, maintenance and recordkeeping
– Construction Site Operator (regular)
– MS4 Operator (periodic)
• And assess penalties as necessary
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Inspections
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Photo Courtesy of Jon Jones, P.E., Wright Water Engineers, Inc.
Post-Construction Requirements Construction Site Operator
• Prepare and submit notice of termination (NOT) to TCEQ
• Large operators submit copy to MS4 operator
• Remove site notice and fill out bottom corner • Small operators submit copy of completed SN to MS4
• Keep copies of all paperwork for your records • At least 3 years from date of NOT
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Post-Construction Requirements MS4 Operator
• Receive NOT/completed Site Notice
• Ensure project meets termination requirements
• Ensure post-construction controls are in place
– Established vegetation, detention, etc.
– Depending on ordinance
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Tools for MS4s
• Storm Water Ordinance
– Requirements for construction operators
– Citations and fines for violations
• TCEQ Small Business/Local Government Assistance Program
– www.TexasEnviroHelp.org
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Final Thoughts…
• MS4 operators get to act as the first line of plan review and enforcement for TCEQ
• More construction site runoff requirements coming soon…
• More MS4 permit requirements coming soon…
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