Construction Site Stormwater Runoff Review Texas Pollutant Discharge Elimination System (TPDES) General Permit TXR150000 This presentation is intended to aid in achieving compliance and should not be interpreted as a comprehensive compliance source. What are we trying to prevent. Stormwater History – Abilene September 11, 1998 – EPA issues first MS4 permit to the City of Abilene. August 23, 2003 - Stormwater Utility Division created following the July 2002 flood and EPA/TCEQ requirements. April 17, 2006 – TCEQ issues permit to the City of Abilene. EPA permit no longer active. What are the City’s requirements under the MS4 permit? Monitor the use and maintenance of appropriate structural and non-structural control measures. Inspect Construction sites and conduct enforcement of control measures. Provide appropriate education and training. Notify building permit applicants of their potential responsibilities under the TPDES permit. Who is responsible for permit compliance? Anyone with day-to-day operational control of activities at a construction site. The person or persons that have operational control over construction plans and specifications. Developers Builders Designers Contractors Sub-contractors When is a construction site permit required? Large Construction Activity (Submit NOI) Land disturbance of greater than 5 acres; or less than 5 acres but part of a larger plan of development. – Sub-divisions – Strip malls Small Construction Activity (Submit CSN) Land disturbance of greater than 1 acre and less than 5 acres; or less than 1 acre but part of a larger plan of development. What are my requirements if I am subject to the stormwater permit? Develop a Stormwater Pollution Prevention Plan (SWP3) according to the provisions of the General Permit (TXR150000). Submit a Notice of Intent (NOI) to the City and TCEQ or Small Construction Site Notice (CSN) to the City. Post copy of NOI and Large CSN or Small CSN at site visible to the public. Implement SWP3 prior to beginning of construction activities. Notice of Change (NOC) Notice of Termination (NOT) – Site stabilization (70%) Stormwater Pollution Prevention Plan (SWP3) Completed prior to obtaining NOI/CSN. Implemented prior to construction activities. Updated/maintained as necessary (living document). Must provide compliance with terms and conditions of the general permit. Must be made available to inspectors. SWP3 (cont’d) SWP3 must contain at a minimum: Nature of construction activity and potential pollutant sources. Intended schedule of major activities of soil disturbance. Total number of acres of the entire property and disturbed area. Name of receiving water bodies that will receive discharges. Copy of the TPDES general permit TXR150000. SWP3 Site Map Site map should illustrate the erosion/sediment controls; A map showing general location of site (city or county map); Drainage patterns and approximate slopes after major grading; Areas where soil disturbance will occur; Location of all major structural controls; Locations of off-site materials, waste, equipment storage areas; Surface waters, adjacent or in close proximity; and Locations where stormwater will discharge from the site to a surface water body. Notice of Intent (NOI) or Construction Site Notice (CSN) The NOI is to be submitted to the MS4 operator and TCEQ after development of the SWP3. The NOI has a $225 electronic/ $325 standard mail fee to the TCEQ while the CSN is no charge. The CSN is to be submitted to the City of Abilene Stormwater Utility Division only. Both are to be posted on-site. Implementation of SWP3 The SWP3 should be implemented prior to any land disturbance. Erosion and Sediment controls in place. Changes can and should be made to the SWP3 at this time if implementation is modified from original plans. Sediment Controls vs. Erosion Controls. Silt Fence Silt fence is a good option for sediment control but offers no stabilization for erosion control. Must be installed correctly and maintained! Good Silt Fence Installations Bad Silt Fence Installations Bad Silt Fence Placement Good Silt Fence Placement Mulch Socks Mulch sock is a good option for sediment control but offers no stabilization for erosion control. Also, must be installed correctly and maintained! Mulch Sock Installations Rip Rap Entrance Rip Rap or other entrance control measures are required to keep dirt and other construction debris from entering the road, MS4, and waters of the U.S. Should be marked on the Site Map and maintained. Concrete/Paint Washout Pit If disposal of concrete residual is to be discarded on-site, a concrete washout area should be designated and maintained. Should be marked on the Site Map in the SWP3. Erosion Control Mats Erosion control mats are an efficient erosion control and stabilization measure. Must be maintained! Storm Drain Inlet Protection Protection of a storm drain inlet is imperative since these lead straight to creeks. Many different methods for protection of storm drains. Storm Drain Inlet Protection Sediment and Erosion Control Best Management Practices Be Innovative If it doesn’t work, fix it. Use common sense for each site. Keep dirt and construction debris out of the street, water conveyances, and waters of the U.S. Site Stabilization Part of Post-Construction permit requirements 70% stabilization Must inform new responsible party of stabilization requirements. Aesthetics! Inspections Site is open to inspections from the City, TCEQ, and/or the EPA. City Ordinance will be used by inspectors for enforcement purposes. Inspections by the City Inspections will be conducted by: NOI/CSN submittal Drive by visual recognition Complaints After significant rain events. Inspections will be conducted under the TCEQ General Permit regulations. Inspections by the City Inspectors will be looking for: NOI/CSN posting Site conditions as established by the SWP3. SWP3 Erosion and Sediment control implementation and maintenance and whether they are effective. – City will have the authority to request modifications or changes in BMP’s if not effective. Inspection Enforcement The City will use the following schedule while conducting inspections: Voluntary compliance Stop Work orders Monetary fines 5 Deadly Sins from the EPA Dirt in the street Blowing trash Concrete/paint washout Leaks & Spills Poorly maintained BMP’s Questions, comments, ideas?