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.
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
Athletics
Grounds / Maintenan
ce
HousingCourses
Project WET
Website
PIE
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