2014 Draft MA MS4 Permit

Transcription

1 2014 Draft MA MS4 Permit 495 / METROWEST Partnership Presented by Bill Arcieri, VHB March 26, 2015

2 Basic Components of the MS4 General Permit Notice of Intent (NOI) (90 days) Stormwater Management Plan (1 year) Six Minimum Measures (MEP) Public Education and Outreach Public Involvement and Participation Illicit Discharge Detection and Elimination (IDDE) Site Construction Runoff Control Post-Construction Runoff Control Good Housekeeping Water Quality Effluent Based Limits Annual Reports Source: EPA Web Site

3 First Year Reporting / Plan Prep Requirements 1. NOI Submittal 2. SWMP Preparation 3. Inventory and O&M Plans for municipal-owned parks, buildings, facilities and equipment, 4. Inventory Sanitary Sewer Overflow (SSO) 5. Inventory of MS4 infrastructure requiring rehab and/or repair, 6. Priority Ranking of Catchments to Initiate Catchment Investigations 7. Phosphorus Control Plan (PCP) or other Pollutant Source Control Plan, 8. Update/ Prepare Written IDDE Plan, 9. Prepare SWPPP(s) for relevant municipal facilities, 10. Update written protocols for erosion control inspections and infrastructure maintenance.

4 Notice of Intent Form 90 Days from Effective Permit Date Basic Storm Sewer information Endangered Species Historic Properties Basic BMP Descriptions Certification and Signature Provides Authorization to Discharge What s New New Electronic Form Detailed Listing of BMPs & Outfalls by Water bodies (Impaired) Impaired Submittal of Existing System Mapping Posted for 30-day Public Notice / Review

5 Stormwater Management Plan What s Included: Detailed BMP Description for each Six Min Meas. & Impaired Waters Responsibility and timeline IDDE Protocols Mapping Annual Evaluation and Reporting What s New: Source Control Plans for outfalls draining to Impaired Waters Meet TMDL Requirements, e.g., Charles River, Assabet River, Cape Cod Nitrogen Add l IDDE & Mapping Requirements Written O&M Plan for Municipal Activities SWPPP for Municipal Vehicle Maintenance Facilities

6 Public Education and Outreach What s New Targeted Messages to Four Different Audiences; Residents Businesses & Commercial Contractors/Developers Industrial Facilities Need to Deliver Two Messages over Permit Term

7 Public Involvement and Participation What s New: Public Input in Developing SWMP Provide Residents an Opportunity to Review and Recommend Changes to SWMP on Annual Basis Citizen Advisory Comm., Dedicated Web Site, Annual Workshop

8 Illicit Discharge Detection & Elimination (IDDE) SSO Inventory (120 days) Outfall & Interconnection Inventory (1 yr) Expanded System Mapping (2 years) Written IDDE Plan (1 year) Legal Authority Ordinance IDDE Program Responsibilities Priority Ranking of Catchments Catchment Investigation Protocols

9 Catchment Investigation Procedures Catchment Priority Ranking Problem Catchments (no dry weather sampling) High Priority Low Priority Excluded Catchment Investigation Procedures Dry & Wet Weather Outfall & Interconnection Screening / Sampling Manhole Inspection / Mapping Removal / Confirmatory Sampling if Elevated Levels

10 IDDE/Catchment Investigation Completion Timeline 3 years 5 years 10 years Dry Weather Screening/Sampling 100 % of Problem Catchments 100% of all other MS4 Catchments 80 % of Problem Catchments 40 % all other MS4 Catchments -- Initiate Catchment Investigation Procedures no later than 15 months of Effective Date of permit

11 Construction Site Runoff Control Not Much New Ordinance/ Site Plan Regs Written Plan for Site Inspections and Reporting Enforce Spill & Waste Control Refueling Areas Concrete Wash-out Asphalt waste

12 Post-Construction Stormwater Management In 2 yrs, modify regs to require capture/treat 1 of runoff from all IC Areas for new & redevelopment disturbing > 1 acre Provide pollutant removal =/> to that provided by biofiltration BMP sized for 1 runoff (EPA BMP Performance Charts) Require as-built submittals O&M plans for all BMPs

13 Post-Construction Stormwater Management (cont.) By 2 nd Annual Report, track DCIA & DIA added or reduced in each sub-basin In 3 yrs, report on current street design & parking lot guidelines to minimize IC area In 4 yrs, develop a report assessing how current regs encourage LID & water reuse Year 4, Inventory and priority ranking of municipal-owned property and IC area By 6 th year, implement demonstration project Source: VHB Project Plans

14 Good Housekeeping Measures W/in 1 year, inventory all municipally owned parks, buildings, facilities, etc. Develop written O&M Plan for all facilities, parks and paved surfaces Inspection and cleaning details for all CB s and BMPs (CB s when > 50% full) Street sweeping (1 or 2 /yr) SWPPPs for municipal facilities

15 Water Quality Requirements

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17 Charles River Phosphorus TMDL Phase 1 of Plan (end of 5 yrs) Conduct legal analysis Funding source assessment ID BMPs to achieve 25% of target reduction Phase 2 (end of 15 yrs) Implement BMPs to achieve 50 % of target reduction Phase 3 (20 yrs) 100 % of the target reduction

18 Phosphorus Control Plan (PCP) Timeline 1-5 years 5-10 years years years Create Phase 1 Plan Implement Phase 1 Plan Create Phase 2 Plan Implement Phase 2 Plan Create Phase 3 Plan Implement Phase 3 Plan

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20 Nitrogen Source Identification Report Develop Plan by Year 4 Identify & Quantify Potential N Sources Identify Potential Retrofits & Non-Structural Measures Implement 1 Demonstration Project by Year 6 Develop Tracking System to Document Add l Sources or Reductions through BMPs on Annual Basis (e.g. septic systems, IC area, land conversions, etc.) New projects are required to demonstrate no net increase in N load

21 Discharges to Chloride Impaired Waters Six Streams Listed as Chloride Impaired (Andover, Tewksbury, Millbury, Uxbridge) Requirements Include: Development of a Salt Reduction Plan Tracking of Salt Use Employee training Equipment Upgrades Equipment Calibration and Application Guidelines

22 What s Next? Public comment period ended February 27, 2015 EPA to review public comments Issue Final Permit (Possibly Dec. 2015) Permit will become effective 6 months after issuance date (June 2016)

23 22 offices throughout the east coast Caroline Hampton