Austin Peay State University

Stormwater ProgramKristen Spicer, Ph.D.

Regulatory Oversight

• Environmental Protection Agency (EPA) – Clean Water Act 1972• Tennessee Department of Environment

and Conservation (TDEC) – NPDES Permits for Small Municipal Separate Storm Sewer Systems (MS4)

Phase II MS4

• What is an MS4?• A conveyance or system of

conveyances• Owned by a city, town, or other

public entity (university) that discharges to water of the U.S.

• Designed to collect or convey stormwater (including drains, pipes, ditches, etc.)

• NOT a combined sewer• NOT part of a POTW (sewage

treatment plant)

• Who is covered by Phase II?• Operators of small MS4s in

“urbanized areas” as delineated by the Census Bureau. Essentially, any MS4 not already covered by Phase I.

• How did APSU end up on this list?• In TN, TDEC decided that

education institutions that housed students would be considered a small MS4, essentially a small city within a city.

What does this mean for APSU?

Stormwater Management

• Submit Notice of Intent• Receive Notice of Coverage• Stormwater Management Plan (SWMP)

Six Minimum Control Measures

• Public Education and Outreach• Public Participation and Involvement• Illicit Discharge Detection and Elimination• Construction Site Runoff Control• Post-Construction Runoff Control• Pollution Prevention / Good Housekeeping

Timeline for Implementation

• NOC- July 2012 • PIE Plan – 12 months – July 2013• Illicit Discharge Policy - 18 months – Jan 2014• Enforcement and Response Plan – 18 months – Jan 2014• Stormwater Management Plan (SWMP) – 12 months – July

2013• Inventory of BMPs – 12 months – July 2013• 5-year Permit Cycle – BMPs for each year

YEAR ONE – Public Education and Outreach

AthleticsGrounds / MaintenanceHousingCoursesProject WETWebsitePIE

YEAR ONE – Public Participation and Involvement• Public Meetings *• Citizen Involvement• Hands-On Events• Method for Public Reporting / Complaints / Questions

YEAR ONE – Illicit Discharge Detection and Elimination

• Administrative Policy prohibiting non-stormwater discharges - DRAFT• Develop and maintain a storm/sewer

system map of campus• Complaint Reporting Mechanism

(Work Order Line or Online)• Sanitary wastewater (sewage overflows)• Car wash, laundry, or industrial wash

water• Concrete truck washout – construction• Improper disposal of automotive fluids• Mop water dumping in storm drain

Construction Site Runoff Control

• Maintain an inventory of all projects disturbing 1 acre or more*• Modify contract language requiring

SWPPPs• Develop a review process for SWPPPs• Develop an audit program with an

audit checklist• Staff performing inspections attend

TDEC’s Level 1 training

Permanent Stormwater Management

• Develop an inventory and tracking system for permanent stormwater treatment BMPs• Review existing design

standards for impediments to implementing green infrastructure

Pollution Prevention / Good Housekeeping YEAR ONE• Review existing service

contracts and modify as necessary• Provide General training to

Physical Plant staff• Develop pollution

prevention policies, as applicable

• Storage of sand, gravel, salt, etc.• Sweeping of parking lots• What to do with those

unknown chemicals• Reasonable application of

fertilizers and pesticides

TMDLs and 303d Listed Streams

• Total Maximum Daily Load (TMDL) for e-coli – Red River• 303d listed streams – State

listed priority impaired streams – Red River

SWMP Oversight and Reporting

• Develop and maintain the written Stormwater Management Plan• Committee – Krissy Spicer, Tom Hutchins, Lindsay Jackson,

Mark Davidson, Director of Facilities, Projects and Planning• Annual Report to TDEC