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?