TxDOT Strategies for Phase II MS4 Stormwater Compliance Dianna Noble, P. E. Environmental Affairs Division Texas Department of Transportation SCOE/SCOD Meeting June 2004

In Strategy the longest way round is often the shortest way there…. B In Strategy the longest way round is often the shortest way there… B.H. Liddell Hart

Texas Pollutant Discharge Elimination 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 Areas requiring a Phase II MS4 permit

Proposed Texas Commission on Environmental Quality (TCEQ) Phase II TPDES MS4 General Permit TCEQ 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.

Proposed TCEQ Phase II TPDES MS4 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 SWMPs EPA and TCEQ recommend that MS4s which will require Phase II permits develop SWMPs now – do not wait for the General Permit. TxDOT is developing and will implement a Phase II SWMP.

Proposed Texas Phase II MS4 General Permit SWMP will require implementation over 5 years; includes Six Minimum Control Measures (MCMs) Public Education & Outreach Public Involvement and Participation Illicit Discharge Detection and Elimination Pollution Prevention & Good Housekeeping Construction Site Runoff Control Post-Construction Storm Water Management Authorization for Municipal Construction Activities (Optional Measure)

TxDOT Phase II MS4 Implementation TCEQ requires SWMP to be implemented over 5 years TxDOT Districts may incorporate current Phase I SWMP provisions into Phase II SWMP

TxDOT Strategies Stormwater Runoff Control and Water Quality Research Projects Support TxDOT Districts with Engineering Consultant Services Contracts for Phase II implementation Build on TxDOT Storm Water Programs

Strategies - continued Worked with stakeholder groups and TCEQ to influence TCEQ’s original General Permit. Will work with stakeholders and TCEQ again to implement Court directed requirements. Will work with TCEQ to develop statewide transportation Phase II MS4 General Permit TxDOT MS4 Work Group will continue to develop guidance for six required Phase II MS4 Minimum Control Measures for TxDOT Districts.

Research Texas 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 Infiltration Basins 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 70 Wet Ponds 80 51 33 45 66 n/a Infiltration Ponds 55 75 Water Quality Swales 35 65 Stormwater Wetlands 30 60

Research Center for Transportation Research, The University of Texas at 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

Effectiveness of BMPs in Removing Constituents TSS TKN Nitrate TP Total Zinc Fecal Colif. Austin Sand Filters High Med Low Extended Detention Basin Wet Basin Infiltration Basin Vegetated Swales Buffer Strips Varied

Effectiveness of BMPs in Removing Constituents in Highway Runoff Percent Removal TSS TZ TP Unlined Extended Detention Basin Wet Basin Vegetated Buffer Strip TN Austin Sand Filter Swale

Storm Water Contracts 5 Contracts awarded for environmental engineering consultant services. Total award amount $2,500,000 Assist TxDOT Districts with MS4 and Construction Storm Water Permit requirements. Train TxDOT Districts’ staff on TPDES CGP and MS4 storm water permits. Perform various statewide Phase I and Phase II MS4 program components. Perform MS4 compliance tracking.

Storm Water Contracts (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 Contracts TxDOT Dallas District $480,000 for total Phase II Program TxDOT Ft. Worth District $100,000 for Phase II Outfall Mapping and Screening Environmental Affairs Division Stormwater Field Inspector’s Guide

TxDOT Strategies for Phase II MS4 Stormwater Compliance Summary TxDOT Strategies for Phase II MS4 Stormwater Compliance Continue dialog with TCEQ TxDOT MS4 Work Group to continue developing guidance for TxDOT Districts Use Environmental Engineering Consultants contracts

Questions?