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Texas Pollutant Discharge Elimination System
Small Municipal Separate Storm Sewer System (MS4)
Storm Water Management Program
Texas Department of Transportation
Environmental Affairs Division
March 2006
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Texas Department of Transportation
Small Municipal Separate Storm Sewer System
Storm Water Management Program
Contents
I.
Introduction
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II. Minimum Control Measures (MCMs)
1.
Public Education and Outreach on Storm Water Impacts MCM
1.A. Permit Requirements
1.B. Current Program
1.C. Best Management Practices and Measurable Goals
1.D. Implementation Schedule for MCM
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2.
Public Involvement and Participation MCM
2.A. Permit Requirements
2.B. Current Program
2.C. Best Management Practices and Measurable Goals
2.D. Implementation Schedule for MCM
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3.
Illicit Discharge Detection and Elimination MCM
3.A. Permit Requirements
3.B. Current Program
3.C. Best Management Practices and Measurable Goals
3.D. Implementation Schedule for MCM
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4.
Pollution Prevention and Good Housekeeping for Operations MCM
4.A. Permit Requirements
4.B. Current Program
4.C. Best Management Practices and Measurable Goals
4.D. Implementation Schedule for MCM
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5.
Construction Site Storm Water Runoff Control MCM
5.A. Permit Requirements
5.B. Current Program
5.C. Best Management Practices and Measurable Goals
5.D. Implementation Schedule for MCM
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6.
Post Construction Storm Water Management in New Development and
Redevelopment MCM
6.A. Permit Requirements
6.B. Current Program
6.C. Best Management Practices and Measurable Goals
6.D. Implementation Schedule for MCM
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Texas Department of Transportation
Small Municipal Separate Storm Sewer System
Storm Water Management Program
I. Introduction
This document contains the Storm Water Management Program (SWMP) of the Texas
Department of Transportation _________ District to comply with Texas Pollutant Discharge
Elimination System (TPDES) General Permit No. TXR 040000 requirements.
When the SWMP is accepted by Texas Commission on Environmental Quality (TCEQ) it will
reflect final permit conditions under the TPDES General Permit for stormwater discharge from
small MS4s.
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II. Minimum Control Measures (MCMs)
1. Public Education and Outreach on Storm Water Impacts MCM
1.A. Permit Requirements
(a). A public education program to distribute educational materials to the community or conduct
equivalent outreach activities that will be used to inform the following groups within the MS4 area:
(1) residents;
(2) visitors;
(3) public service employees;
(4) businesses;
(5) commercial and industrial facilities; and
(6) construction site personnel.
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.
(b). The MS4 operator must document that a reasonable attempt was made to reach all constituents within
the MS4 area to meet this measure.
1.B. Current Program
TxDOT’s Environmental Affairs Division distributes educational materials to the community at
educational fairs and expositions, including “Tex and Dot Water Quality activity books, and
“Wildflowers: A Natural Water Filter.”
A poster, Basic Principles or Erosion and Sediment Control and Other Source Controls, was
designed for roadway construction contractors and inspectors to educate them on protecting
soils from erosive forces and on-site capture of eroded soils and sediments. To accompany the
posters, rain gauges are distributed to contractors to remind them when to check storm water
control devices.
Since 1995 TxDOT’s Environmental Affairs Division has published a quarterly newsletter titled
“ENVision”, which focuses specifically on environmental issues. ENVision is circulated
internally and to outside agencies. Although a wide range of environmental topics are
presented, issues which pertain to stormwater quality are also addressed.
TxDOT’s employee newspaper titled “Transportation News”, now in its 25th volume and a
circulation over 17,000, has featured various articles concerning environmental awareness.
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Information about NPDES/TPDES requirements, stormwater management and stormwater
BMPs are incorporated into in-house environmental training classes such as TxDOT EPD Water
Resources (ENV 118) and Texas Transportation Institute (TTI) Erosion and Sediment Control
(ENV 102).
TxDOT has ongoing programs on water quality impacts such as the Don’t Mess with Texas litter
prevention campaign, Partners Program, Report a Litterer, and “Messin with Texas” video which
was sent to all Texas high schools.
Don't Mess with Texas
Don't Mess with Texas (DMT) is the tough-talking litter prevention media campaign sponsored
by the Texas Department of Transportation (TxDOT). The campaign reminds Texans to keep
their trash in the car and off our roads. TxDOT’s main web page has an environmental section
with information on environmental resources and a link to the DMT web page,
The Don't Mess with Texas "Excuses" campaign debuted on radio and television statewide April
5, 2005. Following the results of newly released 2004 research, the campaign continues to
target Texas' worst litterers: 16 to 24-year-olds. The radio spots appeal to today's generation of
litterers by featuring a series of young people giving half-baked excuses for their littering
behavior. At the end an announcer comes in with a new campaign tagline, "Hey, you dropped
something."
Don’t Mess with Texas outdoor adverting campaign, features 3-D billboards with oversized fast
food items. The oversized ads are aimed at reducing fast-food litter, which accounts for 20
percent of all roadside litter. They can be seen in Austin, Dallas, El Paso, Houston, the Rio
Grande Valley and San Antonio. Traditional flat billboards that complement the larger-than-life
message featured on the 3-D boards were placed in 10 other Texas towns.
Campus Cleanup
The Campus Cleanup was started in 2004 to encourage college students to get involved in
litter-prevention activities on their campuses and in their communities so they see the how litter
harms their personal environments. This event is just one more way Don’t Mess with Texas is
targeting the state’s worst litterers – Texans 16 to 24 years of age.
The Don't Mess with Texas Road Tour traveled more than 10,000 miles to 25 towns in Texas
between April and August 2004 to spread the message about litter prevention. It reached more
than 315,000 Texans and collected 6,232 pledges to not litter during its tour. In return for their
participation and gained knowledge of litter-prevention, visitors were rewarded for participating
with T-shirts, temporary tattoos, bumper stickers, and litterbags.
http://www.dontmesswithtexas.org
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Partners Program
TxDOT established the Partners Program to enlist the aid of Texas businesses, schools, civic
and environmental groups and government agencies to address the most common types of litter
and find new ways to prevent Texans from trashing roadsides. Partner organizations sign an
annual agreement stating that their organization will participate in the program and encourage
all employees or members to participate in Don't Mess with Texas events and promotions.
Organizations that join the Don't Mess with Texas Partner program receive DMT products,
shopping bags, and other publicity materials from TxDOT, and listing on
www.dontmesswithtexas.org.
Report a Litterer Program
TxDOT’s Report a Litterer program allows Texans to turn in any people they observe tossing
things out of their vehicle or accidentally littering from an uncovered load. The information can
be submitted to TxDOT through the DMT web page,
http://www.dontmesswithtexas.org/report_a_litterer.php by noting the license plate number,
make of the vehicle, time of day, location, date, and the item littered. Submitted information is
compared to our vehicle registration database and when an exact match is located a letter is
mailed to the litterer along with a Don't Mess with Texas litterbag.!
Adopt-a-Highway Program
The Adopt-a-Highway program gives groups the opportunity to help their communities by
collecting litter and beautifying roadsides. Groups adopt a two-mile stretch of highway for a
minimum of two years and agree to clean it four times or more per year. TxDOT features the
groups’ name on an Adopt-a-Highway sign marking the adopted section and provides safety
vests, litterbags, and safety training. The program has more than 4,000 groups statewide.
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1.C. Best Management Practices and Measurable Goals for
Public Education and Outreach on Storm Water Impacts MCM
Each TxDOT District should modify the following optional BMPs and optional Measurable
Goals to reflect the District’s activities. When the SWMP is accepted by TCEQ it will
become part of the general permit. TCEQ compliance inspections will focus on whether the
MS4 operator is implementing the programs described in their SWMP.
1.C.1. Distribute educational materials and information
TxDOT _________ District will distribute educational materials to the community or conduct
equivalent outreach activities about the impacts of storm water discharges on local water
bodies.
TxDOT _________ District will distribute educational stormwater brochures and other materials
to the community at public forums such as fairs and expositions.
Distribute storm drain discs, fish-shaped informational door hangers and “Wildflowers: A Natural
Water Filter” brochures to the general public at public forums such as fairs and expositions.
Distribute copies of “Messin’ with Texas”, a 15 minute original comedy video that takes the litter
prevention message directly to Texas teens, to each secondary school within the TxDOT
District. Contact: Txdot Travel Division.
Optional Measurable Goals
1. Distribute _ (# of) _ storm drain discs.
2. Distribute _ (# of) __ door hangers.
3. Distribute _ (# of) __ “Wildflowers: A Natural Water Filter” brochures and wildflower
seed packets.
4. Distribute _ (# of) __ “Wetbook,” activity books to school children.
5. Distribute _ (# of) __ “Tex and Dot Water Quality” activity books to school children.
6. Distribute _ (# of) __ “Only Rain Down the Drain” temporary tattoos to school children.
7. Distribute _ (# of)__ copies of “Messin’ with Texas.”
8. Bilingual and single language stormwater brochures are developed, distributed, or available
at District and Area Offices.
9. Articles may be prepared for publications.
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1.C.2. An outreach program on water quality impacts from MS4 discharges.
TxDOT will promote, publicize, and facilitate public education on water quality impacts
associated with discharges from municipal separate storm sewer systems.
Optional Measurable Goals
1. Distribute storm water fact sheets and guides to educate the public.
2. Distribute fact sheets on disposal of oil, antifreeze and toxic materials. For example TCEQ’s
“Useful Recycling in Texas, Don’t be Crude, Put Oil in Its Place”.
1.C.3. Educational and training guidelines for TxDOT employees.
Develop and distribute educational and training guidelines about storm water pollution and
watershed protection issues for TxDOT planners, highway designers, construction site
personnel, maintenance personnel, and contractors.
Optional Measurable Goals
1. Guidelines for TxDOT planners, highway designers are developed.
2. Guidelines for TxDOT construction and maintenance personnel are developed.
3. Educational and training guidelines for TxDOT contractors are developed.
4. Guidelines are distributed.
1.C.4. Educational and training measures for TxDOT personnel
Use existing training, such as ENV 120-Erosion and Sedimentation Control, TxDOT Annual
Short Course, TxDOT design training program, and contracted training to educate employees
on storm water pollution and watershed protection issues.
Optional Measurable Goals
1. Training of TxDOT design and planning personnel about the impacts polluted storm water
runoff can have on water quality are incorporated into existing training programs.
2. Training of TxDOT vehicle drivers and operators of heavy equipment on the importance of
proper vehicle maintenance are incorporated into existing training programs.
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1.C.5. Educational and training measures for contractors
Distribute educational materials to contractors.
Increase training opportunities for contractors regarding storm water issues.
Expand existing training programs to include contractors, concerning storm water pollution,
recycling of waste oil, batteries and tires; and proper disposal of construction wastes and
hazardous materials.
Optional Measurable Goals
1. Pre-construction meetings will include a presentation of Storm Water Pollution Prevention
(SW3P) plans and TCEQ 401-BMP requirements.
2. Distribute “Basic Principles of Erosion and Sediment Control” posters and rain gauges at
pre-construction meetings.
3. Contractors for sweeping, mowing, landscaping and litter control programs will be provided
information regarding identification and reporting of storm water issues in their work areas.
1.C.6. Public Education and Outreach
Identify and use existing programs to augment public information efforts.
Present demonstration projects which illustrate the impacts of storm water discharges on local
water bodies.
Show and distribute video “Messin' with Texas" which is a 15-minute original comedy video that
takes the litter prevention message directly to Texas teens.
(http://www.dontmesswithtexas.org/education.php).
Optional Measurable Goals
1. Distribute watershed protection literature to students.
2. Storm water demonstration project is presented in various venues.
2.
“Messin' with Texas" is shown to __ # of__ Texas Teens.
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1.C.7. Event participation
Participate in trade shows, fairs, and festivals such as the Texas Parks and Wildlife Exposition
and other events such as the Keep Texas Beautiful Lake and River Clean up Program clean
ups.
Optional Measurable Goal
Distribute fact sheets on storm water impacts at trade shows, fairs and clean up events.
1.C.8. Stencils and Signs
Aquifer Recharge/Contributing Zone signs are placed in appropriate areas.
Distribute storm drain stencils with “Do Not Dump - Drains Directly to Lake” or similar warning.
(See TCEQ’s Storm Drain Stenciling: A Manual for Communities, GI-212.)
Optional Measurable Goals
1. __# of ___ Aquifer Recharge/Contributing Zone signs are placed.
2. __# of __ storm drain stencils are distributed.
1.C.9. Outreach and education for minority citizens on storm water impacts
Conduct outreach activities to inform and educate minority citizens on storm water impacts.
Optional Measurable Goals
1.
2.
3.
4.
Conduct multi-language outreach outreach at public events.
Write articles and notices for ethnic newspapers.
Multi-language signs are placed at storm water inlets.
Multi-language posters and brochures regarding storm water impacts are distributed.
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1. D. Implementation Schedule - Public Education and Outreach MCM
The implementation schedule must reflect the best management practices and activities to be
implemented by the TxDOT District for their Storm Water Management Program; the
implementation schedule will become part of the District’s MS4 Phase II general permit
requirements.
Program
Public Education
& Outreach
Activity (BMP) – Edit as necessary
Distribute Storm Drain Discs
Distribute Activity Books
Distribute temporary tattoos
Distribute “Messin with Texas”
Distribute literature to students
Outreach Program
Distribute facts sheets
Distribute storm drain stencils
Conduct outreach for minority citizens
Education & Training
Guidelines
Develop guidelines for TxDOT planners & designers
Develop guidelines for construction personnel
Develop guidelines for maintenance personnel
Develop guidelines for TxDOT contractors
Guidelines are distributed
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II.2. Public Involvement and Participation MCM
2.A. Permit Requirements
a). Identify and implement a public involvement and participation program. This must include
provisions to allow opportunities for all constituents within the MS4 area to participate in the storm water
management program development and implementation.
(b). The MS4 operator must, at a minimum, comply with State and local public notice requirements when
implementing a public involvement/participation program.
(c)The MS4 operator must, via documented efforts, ensure that sufficient opportunities were allotted to
involve all constituents interested in participating in the program process to meet this measure.
2.B. Current Program
Public involvement is an ongoing aspect of TxDOT’s planning process that encourages and
solicits public input and provides the opportunity for the public to become fully informed and
participate.
TxDOT will comply with state and local public notice requirements when implementing its MS4
public involvement and participation program and will document that sufficient opportunities are
allotted to involve all interested constituents.
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2.C.
Best Management Practices and Measurable Goals for
Public Involvement and Participation MCM
Each TxDOT District should modify the following optional (BMPs) and Measurable Goals
to reflect the District’s activities. When the SWMP is accepted by TCEQ it will become part
of the general permit. TCEQ compliance inspections will focus on whether the MS4 operator is
implementing the programs described in their SWMP.
2.C.1. Public Involvement and Participation
TxDOT will provide for open forums for the public to discuss various viewpoints and provide
comments on appropriate storm water management policies and BMPs at existing public
meetings.
Optional Measurable Goals for Public Involvement and Participation
1. Identify employee task group to develop guidelines for the open forums.
2. Open forums on storm water management at existing public meetings begin.
2.C.2. Forming Partnerships
TxDOT will identify existing programs or develop new ones which involve cooperation and
partnership with other agencies.
Optional Measurable Goals for Forming Partnerships
1. Participate with Keep Texas Beautiful (ktb.org) in the Don’t Mess With Texas Trash-Off.
2. Participate in local cleanup programs such as Keep Texas Beautiful lake and river cleanup
programs.
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2.C.3. Community Clean-up Program
TxDOT will provide opportunities for citizens to participate in the TxDOT Adopt a Highway
Program.
Optional Measurable Goals for Community Clean-up Program
1. Opportunities are provided for citizens to participate in the Adopt a Highway Program.
2. Adopt-a-Highway volunteers are identified or trained to serve as citizen monitors for water
quality and highway runoff on their adopted stretches of highway.
2.C.4. Storm Drain Stencil Program
TxDOT will purchase or create storm drain stencils and provide volunteers an opportunity to
participate in marking the storm drains and inlets. (See TCEQ’s Storm Drain Stenciling: A
Manual for Communities, GI-212.)
Optional Measurable Goals for Storm Drain Stencil Program
1. Gather a volunteer employees to develop a storm drain stencil program.
2. The volunteers develops a storm drain stencil program.
3. The Storm Drain Stencil volunteers will stencil ___% of the MS4 outfalls.
4. The Storm Drain Stencil volunteers will stencil the remaining MS4 outfalls.
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2.D. Implementation Schedule - Public Involvement/Participation MCM
The implementation schedule must reflect the best management practices and activities to be
implemented by the TxDOT District for their Storm Water Management Program; the
implementation schedule will become part of the District’s MS4 Phase II general permit
requirements.
Program
Activity (BMP)- Edit as necessary
Public Involvement
& Participation Program
Identify employees for task group
Date Due
Task group develops Public Involvement
Program
Community Clean-up
Program
Adopt-a-highway volunteers are trained
Storm Drain Stencil
Program
Gather volunteers
Volunteers develop program
___% of outfalls are stenciled
Remaining outfalls are stenciled
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II.3. Illicit Discharge Detection and Elimination MCM
3.A. Permit Requirements
(a) Illicit Discharges
A section within the SWMP must be developed to establish a program to detect and eliminate illicit
discharges to the MS4. The SWMP must include the manner, ordinance or other regulatory mechanism,
used to effectively prohibit illicit discharges.
(1) Detection - the SWMP must list the techniques used for detecting illicit discharges.
(2) Elimination - the SWMP must include appropriate enforcement procedures and actions for
removing the source of an illicit discharge.
(b) Non-Storm Water Discharges
A section within the SWMP must be developed to establish a program to detect and address non-storm
water discharges and illegal dumping to the MS4.
All non-storm water flows must be considered by the permittee to determine if they are a significant
contributor of pollutants to the MS4.
All non-storm water discharges that significantly contribute pollutants to the MS4 must be effectively
prohibited.
(c) Incidental Non-Storm Water Discharges
A list of occasional incidental non-storm water discharges that will not be addressed as illicit discharges
may also be developed. Any local controls or conditions placed on these discharges must be documented
in the SWMP.
The SWMP must also include a provision prohibiting any individual non-storm water discharge that is
determined to be contributing significant amounts of pollutants to the MS4.
(d) Storm Sewer Map
(1) A map of the storm sewer system must be developed and must include:
(i) the location of storm sewer pipes, ditches, and other conveyances owned by the permittee, or
at a minimum, the drainage area for each outfall;
(ii) the location of all major outfalls; and
(iii) the names and locations of all waters of the U.S. that receive discharges from the outfalls.
(2) The SWMP must include the source of information used to develop the storm sewer map,
including how the outfalls were verified and how the map will be regularly updated.
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3.B. Current Program
Statewide Illicit Discharge Detection & Elimination (IDDE) Program and Outfall Tracking System
(OTS) is currently being developed.
IDDE Program
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Audit existing resources and programs
Establish responsibility and authority
Establish tracking of discharges and responses
Desktop assessment of illicit discharge potential
Field mapping
Field inspections of outfalls during dry weather
Wet weather screening as necessary
Follow-up investigations
Third party notification or TxDOT mitigation
Annual reporting
Outfall Tracking System
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
Streamline annual reporting obligations
Provide greater access to information
Field survey and inspection work
Facilitate distribution and delegation of permit compliance duties
Create a framework for future compliance tracking and automation functions.
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3.C. Best Management Practices and Measurable Goals for
Illicit Discharge Detection and Elimination Program
3.C.1 Program to detect and eliminate illicit discharges to TxDOT’s MS4
Required: A program to detect and eliminate illicit discharges to the MS4, including an ordinance or
mechanism to effectively prohibit illicit discharges.
TxDOT will rely on local city or county governments to satisfy the requirements of this section
including:

A program to detect and eliminate illicit discharges to TxDOT’s MS4, including an
ordinance or other regulatory mechanism to effectively prohibit illicit discharges.

Enforcement procedures and actions for removing the sources of illicit discharges.

A program to detect and address non-storm water discharges and illegal dumping to
TxDOT’s MS4.
TxDOT __________ District will develop an agreement with the local city or county government
regarding this requirement. The agreement will list the conditions under which the local
government will extend their illicit discharge program into TxDOT’s ROW. City ordinances and
enforcement would apply to all illicit discharges into TxDOT storm sewer systems.
In the event that the local government does not have a program or does not agree to implement
their illicit discharge program within TxDOT’s ROW, then TxDOT Environmental Affairs Division
will develop an agreement with TCEQ regarding the requirements of this section.
3.C. 2. Non-storm water discharges and illegal dumping detection program
Required: A program to detect and address non-storm water discharges and illegal dumping to the MS4.
TxDOT will rely on local city or county governments and TCEQ to address non-storm water
discharges, including illegal dumping into its MS4.
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3.C.3. Storm Sewer System Map
Required: A map of the storm sewer system which includes the location of conveyances, location of all
major outfalls and the names and locations of all waters of the U.S. that receive discharges from the
outfalls.
TxDOT Environmental Affairs Division has developed the Storm Water Management System
(SWMS) which includes storm sewer mapping and a statewide management system for storm
water permit compliance purposes. The SWMS include maps of locations of all major outfalls
and the names and location of all waters of the United States, which receive discharges from
the outfalls.
Optional Measurable Goals for Storm Sewer System Map
1. Storm sewer maps are created.
2. The maps are available and updated as necessary.
3.C.4. Outfall Tracking System
TxDOT ENV has developed and will implement a statewide outfall tracking system.
Optional Measurable Goals for Outfall Tracking System
1. Outfall tracking system is developed.
2. Outfall inventory and field mapping is accomplished.
3. Tracking of discharges and responses is established.
4. Field inspection of __ % of outfalls during dry weather is accomplished.
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3.C.5. Outfall Screening
Using either TxDOT personnel, hired contractors, or through other third-party arrangements, the
regulated portion of the MS4 will be inspected for dry weather discharges. Wet weather
screening will be used as necessary to monitor outfalls in areas of high rainfall.
Each outfall screening report will include the following:
1.
2.
3.
4.
5.
Location (using GPS receiver)
Dimensions
Presence of silt, soil or trash in and around outfall
Presence of dry weather flow through outfall
Preliminary assessment of dry weather flow, i.e. odors, color, sheen, etc.
Optional Measurable Goals for Outfall Screening BMP
1. Guidelines for dry weather screening are prepared.
2. Dry weather screening activities begin and ___ % of the MS4 in the permit area is screened.
3. Wet weather screening will begin is as necessary to monitor outfalls in areas of high rainfall.
3.C.6. Illicit Discharge Documentation
A record will be made of each possible illicit discharge in which follow-up actions were required.
The record will consist of a geographical point of reference, date, description of flow, and
summary of follow up actions.
The District will develop detailed records of negative findings of dry weather inspections.
Optional Measurable Goals for illicit discharge documentation
A uniform documentation and reporting form is developed to meet the requirement for a concise
annual report for the MS4 general permit.
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3.C.7. Reporting
In the event that a possible illicit discharge is identified, TxDOT will trace the flow upstream to
the extent of state property. TxDOT will report flows originating off of state ROW to the
appropriate city, county, or other entity with jurisdiction for further action. In the event the flow
appears to create a hazard or contain toxic or noxious substances, TxDOT will report the flow to
the TCEQ.
Optional Measurable Goals for Reporting
1. Employees are trained on the Outfall Tracking System .
2. Employees are trained to report all possible illicit and non-storm water discharges.
3.C.8. Floatables Monitoring Program
TxDOT will develop a floatables monitoring program, which will include bi-annual monitoring of
two representative locations for floatable materials. Floatables include paper, plastic and
styrofoam cups, bottles, cans, and bags.
Optional Measurable Goals for Floatables Monitoring Program
1. Two representative locations are selected for bi-annual monitoring.
2. Bi-annual monitoring of two representative locations begins.
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3.C.9. Training
TxDOT personnel implementing the outfall screening or floatable monitoring program will
receive appropriate training to perform their job effectively.
TxDOT personnel will be trained to inspect the areas where on-system ditches drain into natural
creeks or into city/county storm sewer.
TxDOT will prepare a guidance manual for use by TxDOT employees, contractors and other
third parties that may perform inspections on behalf of TxDOT.
TxDOT construction inspectors will be cross-trained to recognize non-storm water discharges
and report them.
Optional Measurable Goals for Training
1. Training of TxDOT personnel who will implement this program begins.
2. Guidance manual is prepared.
3. Construction inspectors are cross-trained.
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3.D. Implementation Schedule Illicit Discharge Detection and Elimination MCM
The implementation schedule must reflect the best management practices and activities to be
implemented by the TxDOT District for their Storm Water Management Program; the
implementation schedule will become part of the District’s MS4 Phase II general permit
requirements.
Program
Activity (BMP)- Edit as necessary
IDDE Program
Develop agreement with local government
or TCEQ
Storm Sewer Map
Storm Water Management System is developed
Maps are compiled
Outfall tracking system
Outfall Tracking System is created
Outfall inventory and field mapping accomplished
Tracking of discharges is established
Field inspection of __ % of outfalls during dry weather
Floatables Monitoring
Program
Monitoring locations are selected
Bi-annual monitoring begins
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II.4. Pollution Prevention/Good Housekeeping MCM
4.A. Permit Requirements
A section within the SWMP must be developed to establish an operation and maintenance program. The
operation and maintenance program must have the ultimate goal of identifying methods and practices for
conducting municipal operations in a manner to prevent or reduce pollution in storm water runoff.
(a) Good Housekeeping and Best Management Practices
Controls must be used to reduce or eliminate the discharge of pollutants when runoff from municipal
operations is determined to be a significant contributor of pollution to the MS4.
(b) Training
A training program must be developed for all employees responsible for municipal operations. The
training program must include training materials directed at preventing and reducing storm water
pollution from municipal operations. Examples or descriptions of training materials being used must be
included in the SWMP.
(c) Structural Control Maintenance
If best management practices include structural controls, maintenance of the controls must be performed
at a frequency determined by the MS4 operator and consistent with maintaining the effectiveness of the
BMP. The SWMP must list all of the following:
(1) maintenance activities
(2) maintenance schedules
(3) long-term inspection procedures for controls used to reduce floatables and other pollutants.
(d)
Disposal of Waste
Waste removed from the MS4, from structural controls, or collected as a result of municipal operations
and maintenance activities must be properly disposed. A section within the SWMP must be developed to
include procedures for the proper disposal of waste, including:
(1) dredge spoil
(2) accumulated sediments
(3) floatables
(e) Municipal Operations and Industrial Activities. The SWMP must include a list of all:
(1) municipal operations that are subject to the operation, maintenance, or training program
developed under the conditions of this section; and
(2) municipally owned or operated industrial activities that are subject to TPDES storm water
regulations.
The SWMP must include an individual permit number, general permit authorization number, or a copy of
a signed NOI or NEC (no exposure certification form for TPDES General Permit TXR050000) for each
industrial activity conducted by the MS4 and subject to TPDES storm water regulations. If an NOI or
NEC has been submitted, but an acknowledgment has not yet been received from the TCEQ, a copy of the
submitted NOI or NEC Form may be made readily available.
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4.B. Current Program
Employee Training
TXDOT incorporates pollution prevention as related to TxDOT facilities in the following classes:
1.
2.
3.
4.
5.
Revegetation
Erosion and Sediment Control
Hazardous Materials training
Training for equipment drivers/operators on proper vehicle maintenance and operation
Employee training on pollution prevention at monthly supervisor meetings and at
monthly safety meetings
6. Annual In-house CEU training in pollution prevention, herbicide application, hazardous
Materials.
Vegetation Management
TxDOT utilizes an Integrated Vegetation Management Program incorporating mechanical,
chemical, cultural and biological methods for management of the right of way. TxDOT operates
this program under the guidance of the Department’s Environmental Impact Statement on the
pest management programs
Wildflower Program
The Wildflower Program is part of a comprehensive vegetation management program. It
encourages the growth of native species that require less mowing and care. Wildflowers help to
conserve water, control erosion and provide a habitat for wildlife. Mowing is delayed until
wildflowers have set mature seeds, assuring the preservation and propagation of wildflower
species. Detailed information on the wildflower program is located in the Roadside Vegetation
Management Manual
Spill Response
TxDOT has a cooperative spill response plan with TCEQ, the District counties, local fire
departments, DPS, and other local entities.
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4.C.
Best Management Practices and Measurable Goals for
Pollution Prevention / Good Housekeeping
Each TxDOT District should modify the following optional BMPs and Measurable Goals
to reflect the District’s activities. When the SWMP is accepted by TCEQ it will become part
of the general permit. TCEQ compliance inspections will focus on whether the MS4 operator is
implementing the programs described in their SWMP.
Requirement: Operation and maintenance program which identifies methods for conducting
maintenance operations in ways that prevent and reduce pollution in storm water runoff.
4.C.1. Reduce pollution of storm water from maintenance operations
TxDOT will use the following methods which reduce pollution from operations:
Document preventative maintenance procedures performed on TxDOT vehicles.
Identify potential hazardous materials used in operations.
Assign staff to monitor operations for storm water pollution.
Assign staff to identify pollution prevention and reduction methods for operations.
Optional Measurable Goals
1. Identify Maintenance staff responsible for tasks.
2. Staff identifies existing and new methods for preventing or reducing pollution of storm water
runoff from maintenance operations.
3. New methods are implemented.
4.C. 2 Controls to reduce or eliminate discharge of pollutants from operations
Requirement: Controls must be used to reduce or eliminate the discharge of pollutants from operations.
Evaluate existing controls and where possible introduce new ones, including:




Berms to contain accidental discharge of hazardous materials.
Cleaning of storm drain inlets.
Street sweeping and litter programs
Vacuum equipped street cleaning equipment
Optional Measurable Goals
1. Existing controls are evaluated
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2. Contract routine maintenance for cleaning of storm drain inlets.
3. Review and possibly revise street sweeping and litter program schedules.
4. Newly purchased street cleaners are vacuum equipped.
4.C.3. Training of Maintenance employees
Requirement: Training for all employees responsible for operations.
TxDOT will develop a program or document existing program for maintenance staff which
includes training materials directed at preventing and reducing storm water pollution.
The training program could include:

Training on the impacts of storm water pollution.

An education program for maintenance personnel which teaches Integrated Pest
Management and decision making processes.
Optional Measurable Goals
1. A training program is developed or identified by TxDOT staff or contractors.
2. Training of staff begins.
Required: Examples or descriptions of training materials must be included in the SWMP.
Training Classes
ENV 100 Environmental Pursuit
ENV 101 Environment in Project Development
ENV 102 Stormwater Erosion & Control
ENV 111 Revegetation Training
ENV 118 EPD Water Resources
ENV 500 Herbicide Certification Training
ENV 501 Herbicide Equipment Training
CON 105 Intro to Cst/Mnt Inspection
MNT 125 Maint Contract Inspectors Course
Training Materials: Manuals
Maintenance Management Manual
Maintenance Operations Manual
Roadside Vegetation Management Manual
A Guide to Roadside Vegetation Establishment
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4.C.4. Structural Control Maintenance
Required: List of maintenance activities for structural controls
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
Required: List of maintenance schedules for structural controls
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
Required: List of long-term inspection procedures for structural controls to reduce floatables
and other pollutants
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
4.C.5. Disposal of waste
Required: Waste removed from the MS4, from structural controls, or collected as a result of operations
and maintenance activities must be properly disposed.
TxDOT policies for handling and disposal of wastes removed from storm sewers is outlined in a
memo to TxDOT District Maintenance Directors which contains guidance on the discharge of
storm water from vactor trucks, disposition of vactor truck solids, and discharge of high pressure
wash water from cleaning of TxDOT storm sewer pipes. (Memo from Dianna Noble, P.E. and
Zane Webb, P.E. to Maintenance Directors, February 24, 2005)
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Required: Procedures for disposal of wastes:
(1) dredge spoil
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
(2) accumulated sediments
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
(3) floatables
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
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4.C.6. Operations subject to this section.
Required: List all operations subject to this section.
for example:
Material storage at maintenance facilities
Wash wastes from vehicles
Stockpiled materials
Sanding and de-icing activities
Roadside Mowing, debris/litter removal
Street sweeping
Picnic and rest area maintenance
Seeding, sodding, hydro mulching, blanketing
Pesticide and fertilizer application
Unpaved road maintenance
Microsurfacing
Adding or widening pavement
Parking area maintenance
Landscaping
Tree/brush control (pruning/disposal)
SW3P (maintenance, install)
Ditch maintenance (remove and haul silt, fill eroded areas)
Reshape ditches
Slope repair, stabilization
Culvert and storm drain maintenance (silt, debris removal, inlet and storm drain cleaning)
Stormwater pump station maintenance (meters, pumps, generators, wet/dry wells, debris
screening baskets, sediment buildup)
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
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4.D. Implementation Schedule Pollution Prevention / Good Housekeeping
The implementation schedule must reflect the best management practices and activities to be
implemented by the TxDOT District for their Storm Water Management Program; the
implementation schedule will become part of the District’s MS4 Phase II general permit
requirements.
Program
Activity (BMP) – edit as necessary
Operation and Maintenance
Storm Water Program
Identify staff responsible for program
Date Due
Identify potential hazardous materials
Identify existing and new methods to
reduce storm water pollution
New methods are implemented
Evaluate existing pollution controls
Introduce new ones.
Training
Storm water training is integrated into
existing training classes.
Integrated pest management pesticide
application training begins.
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II. 5. Construction Site Storm Water Runoff Control MCM
5.A. Permit Requirements
The MS4 operator must develop, implement, and enforce a program to reduce pollutants in any storm
water runoff to the MS4 from construction activities that result in a land disturbance of greater than or
equal to one acre or if that construction activity is part of a larger common plan of development or sale
that would disturb one acre or more.
(a). 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, to the extent allowable under State and local law.
(b). Requirements for construction site contractors to, at a minimum:
(1). implement appropriate erosion and sediment control best management practices; and
(2). control waste such as discarded building materials, concrete truck washout water, chemicals,
litter, and sanitary waste at the construction site that may cause adverse impacts to water quality;
(c). The MS4 operator must develop procedures for:
(1) site plan review which incorporate consideration of potential water quality impacts;
(2) receipt and consideration of information submitted by the public; and
(3) site inspection and enforcement of control measures.
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5.B. Current Program
Storm Water Pollution Prevention Plan
TxDOT complies with the TCEQ TPDES General Permit for Construction Activity. The TPDES
permit program controls water pollution from construction activities by requiring a SW3P at all
construction sites which disturb one acre or more of soil.
TxDOT further requires a SW3P for all construction sites which will disturb any amount of soil.
TxDOT implements the following construction contractor oversight activities
Require TPDES authorization to be obtained by the construction operator prior to
commencement of construction activities.
Require a SW3P implemented according to the provisions of the TPDES CGP.
Require a signed copy of the construction site notice posted at the construction site.
Erosion and Sedimentation Control
Temporary and permanent BMPs designed to reduce and control erosion and sedimentation
and minimize impacts created by storm water runoff are used during construction.
Erosion control at TxDOT construction sites is accomplished by:
1. Design steps to minimize bare soil exposure.
2. Stabilize the soil with vegetation or other materials to hold it in place.
3. Minimize the erosive velocities of storm water runoff.
Sediment control is generally accomplished with BMPs such as silt fences and rock filter dams
placed to capture moving sediments.
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Standard Specifications: TxDOT Standard Specifications for Construction and
Maintenance of Highways, Streets, and Bridges, June 1, 2004
Item 7.19.
Preservation of Cultural and Natural Resources and the Environment. If
the Contractor initiates changes to the Contract and the Department approves
the changes, the Contractor is responsible for obtaining clearances and
coordinating with the appropriate regulatory agencies.
Item 7.19.B.
TPDES and SW3P. The Department will file the Notice of Intent (NOI) and the
Notice of Termination (NOT) for work shown on the plans in the right of way.
Adhere to all requirements of the SWP3.
Item 7.19.C.
Work in Waters of the United States. For work in the right of way, the Department
will obtain any required Section 404 permits from the U.S. Army Corps of
Engineers before work begins. Adhere to all agreements, mitigation plans, and
standard best management practices required by the permit. When Contractorinitiated changes in the construction method changes the impacts to waters of
the U.S., obtain new or revised Section 404 permits.
Item 7.19.D.
Work in Navigable Waters of the United States. For work in the right of way, the
Department will obtain any required Section 9 permits from the U.S. Coast Guard
before work begins. Adhere to the stipulations of the permits and associated best
management practices.
Item 7.19.E.
Work over the Recharge or Contributing zone of Protected Aquifers. Make every
reasonable effort to minimize the degradation of water quality resulting from
impacts relating to work over the recharge or contributing zones of protected
aquifers, as defined and delineated by the TCEQ.
Item 7.19.F.
For all project-specific locations (PSLs) on or off the right of way (material
sources, waste sites, parking areas, storage areas, field offices, staging areas,
haul roads, etc.), signing the Contract certifies compliance with all applicable
laws, rules, and regulations pertaining to the preservation of cultural resources,
natural resources, and the environment as issued by other agencies.
All subcontractors must also comply with applicable environmental laws, rules,
regulations, and requirements in the Contract. Obtain written approval from the
Engineer for all PSLs in the right of way not specifically addressed in the plans.
Prepare an SWP3 for all Contractor facilities, such as asphalt or concrete plants
located within TxDOT right of way. Comply with all TCEQ permit requirements for
portable facilities, such as concrete batch plants, rock crushers, asphalt
plants, etc. Address all environmental issues, such as Section 404 permits,
wetland delineation, endangered species consultation requirements, or
archeological and historic site impacts. Obtain all permits and clearances in
advance.
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Specifications for Erosion and Sedimentation Control (June 1, 2004)
Through its environmental specifications TxDOT requires its contractors to implement erosion
and sediment control best management practices and to control construction site wastes. The
specifications require stabilization of disturbed areas, maintenance and inspection of control
measures. TXDOT requires these measures to be installed and maintained throughout the
construction contract.
Item 506
Temporary Erosion, Sedimentation and Environmental Controls. Install, maintain,
and remove erosion, sedimentation, and environmental control devises. Remove
accumulated sediment and debris.
Item 506.2
Materials
506.2.A.
506.2.B.
506.2.C.
506.2.D.
506.2.E.
506.2.F.
506.2.G.
506.2.F.
506.2.I.
506.2.J.
Rock Filter Dams
Temp Pipe Slope Drains
Baled Hay
Temporary Paved Flumes
Construction Exits (rock, timber, foundation course)
Embankment for Erosion Control
Pipe Outlet
Construction Perimeter Fence
Sandbags
Temporary Sediment Control Fence
Item 506.4.A. Contractor Responsibilities
Implement SW3P in accordance with the storm water permit requirements.
Develop and implement an SW3P for project-specific material supply plants
within and outside of the Department’s right of way. Prevent water pollution
from storm water associated with construction activity from entering any
surface water or private property on or adjacent to the project site.
Specifications for Earth Work and Landscape (June 1, 2004)
Item 158
Item 160
Item 161
Item 162
Item 164
Item 168
Item 169
Item 170
Item 180
Item 192
Item 459
Specialized Excavation for erosion control or other specialized needs
Topsoil
Erosion Control Compost, Compost Manufactured Topsoil
Sodding for Erosion Control
Temporary or Permanent Seeding for Erosion Control
Vegetative Watering
Soil Retention Blankets. (Approved Product List at
www.dot.state.tx.us/mnt/erosion/contents/htm
Irrigation System
Wildflower Seeding
Landscape Planting
Gabions and Gabion Mattresses
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Project Development and Environmental Review Process
Environmental concerns regarding a project are identified early in project development. To
identify environmental concerns the District Environmental Coordinator conducts an
environmental document research of federal, state, and local agency databases, on-the-ground
surveys, and site visits to identify and assess environmental constraints.
Preliminary structure and hydraulic studies are conducted to evaluate environmental impacts of
highway encroachments on waterways and floodplains. Changes in water surface elevation,
construction in channels, bridge construction methods, etc. commonly impact environmental
resources. A Corps of Engineers Section 404 permit may be required for wetland area
disturbance, work in channels, channel/stream modifications, and dewatering/construction
methods.
Waterways are reviewed in the field and input is provided to the drainage engineer regarding
environmental aspects of the project. Previously conducted hydraulic studies, FEMA maps,
local flood control policies, and Corps of Engineers requirements for specific floodplains are
reviewed.
After preparing a roadway drainage design, stream crossing, culvert and storm drain hydraulics,
a storm water pollution prevention plan is designed. Designing erosion control devices includes
determining the type and size of facilities for minimizing erosion and siltation during and after
project construction. Storm Water Pollution Prevention Plans (SW3P) are prepared to detail the
construction of devices that minimize erosion and sedimentation during construction.
Environmental Documentation and Clearance
A natural resources study is conducted by the TxDOT District to determine potential impacts to
water quality, wetland, floodplains, and navigable waterways. All potential impacts are
documented and an environmental document is prepared in order to obtain environmental
clearance.
Obtaining environmental clearance involves preparing an environmental document that
incorporates the comments received on the draft environmental document from the public and
regulatory/resource agencies during the public availability and review period, and responses to
those comments. Intergovernmental cooperation and coordination to obtain water quality
concerns regarding the project initiated at the beginning of project development continues
throughout the process.
Utility Accommodation rules
TxDOT’s Utility Accommodation rules require vegetation and site clean up when utility
installation is complete. The utility must return the right of way to a condition equal to its original
condition, including reseeding or resodding to prevent erosion. After the area is brought to
grade, the entire disturbed area must be covered in accordance with the department's Standard
Specifications for Construction and Maintenance of Highways Streets & Bridges. Subchapter C,
Section 21.38 (b).
If settlement or erosion occurs due to the actions of the utility, the utility must, at its expense,
reshape, reseed, or resod the area as directed by the department. Subchapter C, Section 21.38
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(b)(3).
Highways adjacent to utility construction sites must be kept free from debris, construction
material, and mud. At the end of every construction day, construction equipment and materials
must be removed from the horizontal clearance, placed as far from the pavement edge as
possible, and properly protected. Subchapter C, Section 21.38 (b)(5).
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5.C. Best Management Practices and Measurable Goals for
Construction Site Storm Water Runoff Control MCM
Each TxDOT District should modify the following optional Measurable Goals for each
BMP to reflect the District’s activities. When the SWMP is accepted by TCEQ it will become
part of the general permit. TCEQ compliance inspections will focus on whether the MS4
operator is implementing the programs described in their SWMP.
5.C.1. Construction Storm Water Program BMPs
Required: A program to reduce pollutants in storm water runoff to the MS4 from construction activities
and sanctions to ensure compliance to the extent allowable under State and local law.
The MS4 operator must develop and implement a program to reduce pollutants in any storm water runoff
to the MS4 from construction activities that result in a land disturbance of greater than or equal to one
acre.
a. TxDOT construction (in ROW)
TxDOT requires that all its construction projects meet TCEQ TPDES Construction General
Permit requirements and further requires that all projects with any amount of soil disturbance
implement a storm water pollution prevention plan.
Required: Construction site contractors must implement appropriate erosion and sediment control BMPS
and control wastes.
This requirement is met. TxDOT currently has requirements for contractors (See Specifications
for Erosion and Sediment Control in Section 5.B. of this SWMP.)
b.
Non-TxDOT construction in ROW
TxDOT requires compliance with all environmental regulations including the TPDES
Construction General Permit on all construction projects within its right-of-way, including
the following:






TxDOT Toll Roads
Private toll roads
County toll roads
Regional toll roads
Regional Mobility Authorities
Utilities – TxDOT’s Utility Accommodation Rules Require that connecting utilities
conform to state and federal environmental regulations, including storm water
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pollution prevention, endangered species, and wetlands. TxDOT Administrative
Rules, Subchapter C, Section 21.37 (a)(9).
c. Non-TxDOT Construction Off Right-of-Way
For discharges generated from construction projects off-TxDOT right-of-way which
discharge into TxDOT’s MS4, TxDOT _________ District will use existing agreement with
city or develop an agreement with the local city or county government to implement their
local program to reduce pollutants in storm water runoff to the MS4 from non-TxDOT
construction activities. In the event that local governments do not agree to implement a
program TxDOT Environmental Affairs Division will develop an agreement with TCEQ
regarding the requirements of this section.
5.C.2. Site Plan Review BMP
Required: Develop procedures for site plan review which incorporates consideration of potential water
quality impacts.
TxDOT will perform site plan review of its construction projects only. Pre-construction site plan
reviews are conducted on all TxDOT projects. See Current Programs, Project Development
and Environmental Review Process (Section 5B)
Optional Measurable Goals
This activity is accomplished.
5.C.3. Consideration of Public Input BMP
Required: Develop procedures for receipt and consideration of information submitted by the public.
Current procedures will be evaluated and new procedures developed if necessary.
Optional Measurable Goal
Citizen concerns are documented and records are maintained.
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5.C.4. Site Inspection BMP
Required: Develop procedures for site inspection and enforcement of control measures.
TxDOT requires that all construction projects meet TCEQ TPDES Construction General Permit
requirements including site inspection requirements.
Optional Measurable Goal
Current site inspection procedures are reviewed, documented and revised if necessary.
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5.D. Implementation Schedule Construction Site Storm Water Runoff Control MCM
The implementation schedule must reflect the best management practices and activities to
be implemented by the TxDOT District for their Storm Water Management Program; the
implementation schedule will become part of the District’s MS4 Phase II general permit
requirements.
Program
Activity (BMP)- edit as necessary
Construction Site Runoff Control
Requirements for contractors are
reviewed and re-written if necessary
Date Due
Requirements for contractors are
discussed at pre-construction meetings
Program for non-TxDOT construction
Develop agreement with local government
or TCEQ to implement their program for
discharges to TxDOT’s MS4 from
construction adjacent to TxDOT’s ROW.
Develop policies and requirements for
discharges on TxDOT ROW from construction
by others.
Procedures for receipt of information
by the public
Review and document current procedures.
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II.6. Post Construction Storm Water Management in New Development
and Redevelopment MCM
6.A. Permit Requirements
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, including
projects less than one acre that are part of a larger common plan of development or sale that will result in
disturbance of one or more acres, that discharge into the small MS4. The program must ensure that
controls are in place that would prevent or minimize water quality impacts;
(a) Develop and implement strategies which include a combination of structural and/or nonstructural BMPs appropriate for your community;
(b) Use an ordinance or other regulatory mechanism to address post-construction runoff from new
development and redevelopment projects to the extent allowable under State and local law; and
(c) Ensure adequate long-term operation and maintenance of BMPs.
6.B. Current Programs
Permanent storm water BMPs can reduce the peak runoff by decreasing the volume released
over time and velocity of storm discharge. When these BMPs are applied to a project site, the
impacts of the construction activity that can result in an increase in storm water runoff are
minimized. Infiltration and vegetative BMPs remove pollutants by allowing the settling of
particulate matter, filtration, and biological uptake of nutrients and pollutants. The selection of
the proper BMP for a project is dependent on characteristics of the specific project site. Some
project sites may require a combination of BMPs.
TxDOT uses various permanent BMPs to minimize stormwater quantities. These include:







Irrigation
Extended detention (wet/dry) basins
Vegetative filter strips
Constructed wetlands
Wet basins
Sedimentation ponds
Filtration ponds
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Re-vegetation Program
The Maintenance Division’s re-vegetation program requires maintenance personnel to
periodically inspect and maintain vegetative BMPs.
Wildflower Program
The wildflower program is part of a comprehensive vegetation management program. It
encourages the growth of native species that requires less mowing and care. The native
grasses and wildflowers help to conserve water, control erosion and provide a habitat for
wildlife. Mowing is delayed until wildflowers have set mature seeds, thus assuring the
preservation and propagation of wildflower species. Detailed information on the wildflower
program is located in the printed Roadside Vegetation Management Manual and at
http://crossroads/org/mnt/VM/Millenium3/index.htm.
BMP Maintenance
TxDOT’s Maintenance Division periodically inspects and repairs roadside BMPs to ensure
adequate long-term operation and maintenance of BMPs.
Manuals
TxDOT uses the following manuals as guidance and procedures for the design, construction,
and maintenance of stormwater controls for development and redevelopment projects.

Evaluation and Management of Highway Runoff Water Quality, FHWA, 1996

The Highway Design Division Operations and Procedures Manual Part II-B, TxDOT

The Hydraulic Manual, TxDOT Bridge Division.

A Practical Guide to the Establishment of Vegetative Cover on Highway Rights-of-Way

Vegetation Management Section, Maintenance Division, TxDOT

Storm Water Management Guidelines for Construction Activities, TxDOT, 2002
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6.C. Best Management Practices and Measurable Goals for Post
Construction Storm Water Management in New Development and
Redevelopment MCM
Each TxDOT District should modify the Measurable Goals for the following BMPs to
reflect the District’s activities. When the SWMP is accepted by TCEQ it will become part of
the general permit. TCEQ compliance inspections will focus on whether the MS4 operator is
implementing the programs described in their SWMP.
6.C.1. Program to address storm water runoff from new development and
redevelopment projects which discharge to TxDOT’s MS4.
Required: A program to address storm water runoff to the MS4 from new development and
redevelopment projects that disturb greater than or equal to one acre.
TxDOT’s program will minimize water quality impacts and attempt to maintain pre-development
runoff conditions. Primary water quality impacts are those related to changes in storm water
runoff quantity as impervious cover increases and potential water quality impacts due to
constituent loadings associated with highway facilities.
TxDOT will begin an evaluation of its design guidelines and procedures, evaluating flow and
pollution load reductions consistent with safety and site-specific design considerations, including
local topography. Modifications would be recommended following the evaluation and be
incorporated into the TxDOT Design Manual.
a. In Right-of-Way
1. TxDOT Projects
1. Evaluate current structural and non-structural BMPs.
2. Evaluate current program for inspecting structural erosion and sediment control BMPs.
3. Develop program or document existing program which ensures installation and
maintenance of controls that prevent or minimize ongoing water quality impacts.
2. Non-TxDOT Projects
TxDOT will work with utilities, regional mobility authorities and other entities that may disturb
soil in TxDOT’s right-of-way to address post-construction runoff into its MS4.
BMPs that TxDOT may require in its ROW include the following:

Permanent post-construction stormwater BMPs which reduce type and quantity of
pollution in stormwater runoff
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
Permanent post-construction stormwater BMPs which reduce quantity of water
delivered to water bodies during storms

Documentation of BMP inspection program
b. Off Right-of-Way
For discharges into TxDOT’s MS4 that are generated from off-TxDOT ROW, as
possible, TxDOT will work with property owners adjacent to its ROW to address postconstruction runoff.
TxDOT __________ District will develop an agreement with the local city or county
government to implement their post-construction program for discharges into TxDOT’s
MS4 generated from off-TxDOT ROW. In the event that the local government does not
agree to implement their program, TxDOT Environmental Affairs Division will develop an
agreement with TCEQ regarding the requirements of this section.
Optional Measurable Goals
Identify adjacent property owners discharging into TxDOT’s MS4 and any water quality controls
they may have.
Develop water quality requirements for discharges from adjacent properties.
Develop agreement with local city or county government or TCEQ.
6.C.2. Strategies which include a combination or structural and non-structural
BMPs
Required: Develop and implement strategies which include structural and non-structural BMPs.
Structural BMPs:
TxDOT’s current program includes structural and non-structural BMPs. Permanent post
construction stormwater BMPs available to TxDOT include the following:
Vegetated swales – TxDOT will continue to use grass swales where possible in medians and
drainage ditches.
Vegetative filter strips - TxDOT will continue to use vegetative filter strips on roadway shoulders
for overland storm water flow where possible.
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Establishing and maintaining vegetation – TxDOT will continue its program of establishing and
maintaining vegetation at the completion of construction activities.
Permanent stabilization applied to unpaved areas (sodding, seeding, mulching with seed) TxDOT will continue its program of establishing permanent stabilization at the completion of
construction activities.
Energy dissipaters – TxDOT will continue to use energy dissipaters where open drainage
systems exist and positive roadway drainage can be maintained.
Reduction of runoff velocity - where possible TxDOT will use erosion control structures to
control erosive velocities in unlined channels such as pipe slope drains and paved flumes.
Curb elimination – TxDOT will implement where possible.
Non-structural BMPs:
Litter control - TxDOT will continue its aggressive litter control programs.
Reduction of direct discharges
Inlet stenciling
Optional Measurable Goals:
Review design guidelines for permanent post construction BMPs and modify if applicable to
improve flow rate and pollution load reductions.
Incorporate design modifications into Design Manual.
6.C.3. Mechanism to address post-construction runoff
Required: Ordinance or other regulatory mechanism to address post-construction runoff to the extent
allowable under State and local law.
TxDOT has limited regulatory authority to address post-construction runoff by other entities;
therefore, TxDOT________District will develop an agreement with the local city or county
government to implement this requirement in TxDOT’s right-of-way and outside and adjacent to
TxDOT’s right-of-way discharging into TxDOT’s MS4. In the event that the local government
does not agree to implement their program, TxDOT Environmental Affairs Division will develop
an agreement with TCEQ regarding the requirements of this section.
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a. Post Construction Runoff - In TxDOT’s Right-of-Way
1. TxDOT Toll Roads
Evaluate current structural and non-structural post construction BMPs.
Evaluate current program for inspecting post construction structural BMPs.
Develop program or document existing program which ensures post
construction controls that prevent or minimize water quality impacts.
2. Non-TxDOT Toll Roads
TxDOT will work with entities such as Regional Mobility Authorities, utiliites, private
toll roads, county and regional toll authorities that may disturb soil in TxDOT’s rightof-way to address post-construction runoff into its MS4.
b. Post Construction Runoff - Off TxDOT’s Right-of-Way
In the event that the local government does not agree to address post-construction runoff
generated from off TxDOT ROW and discharging into TxDOT’s MS4, then TxDOT
Environmental Affairs Division will develop an agreement with TCEQ regarding the
requirements of this section.
6.C.4.
Long-term operation and maintenance of BMPs
Required: Ensure adequate long-term operation and maintenance of BMPs.
TxDOT’s Maintenance Division inspects and maintains structural BMPs. TxDOT will evaluate
its current operation and maintenance procedures and upgrade them if necessary.
Optional Measurable Goals

Current operation and maintenance procedures are evaluated.

Operation and maintenance procedures are upgraded as necessary.
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6.D. Implementation Schedule - Post Construction Storm Water
Management in New Development and Redevelopment MCM
The implementation schedule must reflect the best management practices and activities to be
implemented by the TxDOT District for their Storm Water Management Program; the
implementation schedule will become part of the District’s MS4 Phase II General Permit
requirements.
Program
Activity (BMP)- edit as necessary
Date Due
New Development and ReDevelopment Storm Water Program
Evaluate current non-structural BMPs
Evaluate current BMP inspection
program
Non-TxDOT facilities in ROW
Evaluate current TxDOT requirements
Evaluate current post-construction BMPs
in use by non-TxDOT facilities in ROW
Develop program or requirements for
non-TxDOT facilities
Implement program or requirements
T:\NRM\WRM\MS4\ Working SWMP 03 14 06.doc
D:\ Working SWMP 03 14 06.doc
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