MS4 PROGRAM UPDATES September 14, 2016 ENV Conference September 14, 2016
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1 MS4 PROGRAM UPDATES September 14, 2016
2 Table of Contents 1 MS4 Program Update Statewide Permit Update Interim Activities Other Program Activities
3 Current Permits and Program Currently implementing 34 permits (Phase I and Phase II): Phase I permits Expired Unexpired Phase II permits Expired New Phase II areas (new urbanized areas, 2010 census) San Marcos Urbanized areas increased in size All expired permits administratively continued until statewide permit issued Annual reports continue Wet weather monitoring continues All on-going programs continue 3
4 Unexpired Phase I Permits District Co-Permittee Expiration Date Amarillo Amarillo April 28, 2019 Arlington City of Arlington, UT Arlington April 26, 2017 Laredo City of Laredo, Laredo Community College November 21,
5 Purpose of Statewide Permit Streamline 34 permits into 1 statewide permit Simplify reporting Standardized statewide SWMP specific to TxDOT operations Develop fiscally responsible program Focus on areas in which TxDOT has authority and influence 5
6 Status of Statewide Permit WQ TCEQ received public comment TCEQ published Final Decision Letter and Response to Comments (RTC) One change to permit based on comments (clarification) RTC allows request for contested case hearing through Sept 14 6
7 Public Notice of Draft Permit Public comment ended May 16, 2016 Notices published statewide per district in the newspaper of greatest circulation 4 sets of public comments received 2 written (<1 pg) 1 letter (2 pgs) 1 letter with data (346 pgs ) Hearing request 7
8 Steps Remaining to Receive Permit TCEQ reviews request for reconsideration/contested case hearing TCEQ grants or denies hearing request If granted: TCEQ begins legal proceedings with requestor If denied: TCEQ issues permit 8
9 How is Statewide Permit different? Modeled after Phase II Permit Includes previous requirements from Phase I permits Anti-backsliding Includes regulated area from previous permits plus new Phase II areas from 2010 census Focus on programmatic enhancements for IDDE Facility inspections Mapping permanent controls Enhanced TMDL requirements Enhanced training requirements 9
10 Statewide Permit Implementation Focus on IDDE Stormwater pollutants often originate outside ROW No enforcement authority to implement ordinances, assess fines IDDE in lieu of Wet Weather Monitoring Collect water quality samples from IDDEs 10
11 When Statewide Permit is Issued Statewide Permit Training IDDE Facility inspections Annual report template Etc. Outfall Mapping TMDL Support Annual Reporting Mapping Permanent Controls 11
12 What do I do until the Statewide Permit? Complete Annual Reports Phase II permit reports due November 10, 2016 (within 90 days of the end of the permit year) Reporting period = August 13, 2015 August 12, 2016 Continue implementation of your permit 12
13 What do I do until the Statewide Permit? Do not renew as co-permittee No NCTCOG participation Review your permit for action completed by co-permittees Activities need to continue See Interim BMPs spreadsheet Implement in new 2010 Census Urbanized Areas 13
14 Map Viewer 9a124f1c ce78d427f Search arcgis.com for TxDOT MS4 areas Provides 2000 and 2010 Census Areas Displays outfalls 14
15 Map Viewer 15
16 Map Viewer 16
17 Other Program Activities EPA Self Review Observations Document Updates Tools Development 17
18 Recent EPA Self Review EPA conducted audit of MS4 permit in several districts Included Construction General Permit compliance Audit findings: Form 2118 priority applied differently by each inspector Inspectors not inspecting BMPs to TxDOT spec Contractors not installing to spec SWPPP site map and inspection forms incomplete 18
19 EPA Self Review Observations Focusing on Enforcement MS4 must enforce throughout entire MS4 area Both TxDOT and non-txdot projects Must follow through with construction inspections and escalate as needed Record-keeping Must keep records 3 years after permit termination Update SWPPPs, document follow-up with inspections Must follow our own procedures That is our enforcement of the MS4 program We function on EPA s behalf 19
20 Operations Compliance Branch Adrienne Boer, CFM, CPESC, PMP Amy Foster, CPESC Layde Philips, PMP David Nuckels 20
21 Operations Compliance Branch What we have done this year: Facility Surveys Environmental compliance support Guidance/Training NOV support What we can help with: CGP, MS4 questions Maintenance facility compliance EMS support WAs for stormwater, SPCC, facility compliance 21
22 Statewide Permit Tools Development Annual Report Template One statewide report for statewide permit Completed at district level for district s activities.xls spreadsheet format Training protocol for Statewide permit IDDE training Facility Inspections Annual Report 22
23 Update to ENV 300 and 301 Updating for on-line, computer-based training Currently developing recommendations report with consultant Expect update to training early 2017 Would like feedback & involvement from Construction & Design Division 23
24 Stormwater Hub ENV/stormwater/hub/SitePages/Home.aspx Search stormwater from Sharepoint 24
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26 Stormwater Hub! ENV/stormwater/hub/SitePages/Home.aspx Insert screen captures 26
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34 Stormwater Contract Service Experience Mapping/Tracking Monitoring & Compliance Reports & Analysis Mapping and tracking systems GIS services IDDE inspections, follow-up, and complaints SWPPPs CGP field oversight CCTV Inspections Remote sensing Wet weather monitoring/ Representative monitoring Floatables debris monitoring Training programs TMDLs and I-Plans Compliance auditing Facility inspection BMP inspection Permit negotiations Public education/outreach Annual report, District-specific report Good housekeeping Implementation Plan Development Event Mean Concentration (EMC) analysis TMDL studies, I-Plans Retention/detention pond retrofit studies BMP effectiveness analysis Scientific Services Contract Full service stormwater capabilities to ensure compliance Exceptional services to provide analysis, planning, and support 34
35 Questions? Adrienne Boer (512)
TXDOT MS4 PROGRAM. Adrienne Boer, CFM, CPESC, PMP Program Manager Operations Compliance TxDOT Environmental Affairs
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