Note for CE 491 with Professor Batson at UA
Note for CE 491 with Professor Batson at UA
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Date Created: 02/06/15
CE 491 002 Storm Water Management Robert Pitt PhD PE Various State Storm Water Pollution Prevention Plans SWPPP California Michigan amp South Dakota Aaron A Quick October 13 2005 TABLE g CONTENTS II III IV VI Introduction to Storm Water Pollution Prevention Plans SWPPP and the National Pollutant Discharge Elimination System NPDES California Michigan South Dakota Summary and Conclusions Works Cited Quick 2 I INTRODUCTION TO STORM WATER POLLUTION PREVENTION PLANS SWPPP AND THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM NPDE S The motivation behind storm water pollution prevention has become prevalent in the last several years Scientists and engineers alike realize that nonpoint source runoff contains a multitude of pollutants This runoff often untreated before making its way into community lakes streams and rivers has caused growing concern about the ultimate cleanliness of our waterways and water sources Since the 1987 amendments to the Clean Water Act CWA the United States Environmental Protection Agency USEPA has been mobilized to design and implement measures to curb and eventually eliminate these pollutants Various point sources have been identified and targeted for reductions in runoff pollutant concentrations including 0 Municipal Separate Sewer Systems 0 Construction Sites 0 Industrial Activities In 1990 further regulation stated that under USEPA guidelines municipal and industrial storm water discharges must comply with National Pollutant Discharge Elimination System NPDES standards In some cases the authority to grant NPDES permits has been delegated to state agencies specifically in California the State Water Resources Control Board and nine Regional Water Quality Control Boards are responsible for these permits Compliance with these regulations often resides solely with the developing entity andor the construction contractor associated with said developments Best management practices BMP shall be utilized in order to maintain compliance as needed Projects not covering more than one acre of land are not included under the current NPDES program Therefore these projects do not require coverage under the NPDES permit or a SWPPP plan to be developed However in extenuating circumstances where a possible threat to water quality exists a SWPPP plan may be required for implementation This paper seeks to identify and explain several differing approaches to implementing storm water prevention measures and the parameters that serve as a guide to meet these standards Of the fifty states in the nations California Michigan and South Dakota will be examined for the following 0 Ordinance Coverage 7 Who must apply for and follow these regulations 0 Numeric Discharge Limits 7 Concentration restrictions Load limitations Required levels of control 0 Volumetric Discharge Limitations 7 Matching predevelopment levels Percentage of these levels Required Runoff Treatments 7 Is the first half inch of rain to be treated per storm Storm Water Control Requirements 7 Detention pond volumes Required Best Management Practices BMPs Storm Water Control Vendor Requirements 7 Proof of application functionality Storm Water Modeling Specifications 7 Are analytical procedures provided Quick 3 11 CALIFORNIA STORM WATER POLLUTION PREVENTION PLANS California requires storm water pollution prevention plans for three various types of discharges including municipal wastewater industrial and construction site runoffs It must be noted that if any of these projects or areas encompass more than one of the nine Regional Water Quality Control Boards jurisdiction separate plans Notice of Intent N01 and Termination packages must be submitted to each presiding branch of the agency Municipal wastewater permitting for discharges developed through a twostage phasing process and applied to municipal separate storm sewer systems MS4s Begun in 1990 Phase One consists of medium and large municipalities being required to establish implement and maintain a storm water pollution prevention plan in accordance with NPDES regulations Medium municipalities are considered to serve 100000 to 250000 constituents whereas large municipalities serve over a quarter of a million people Due to large numbers and sometimes overlapping water treatment facilities many permits are held jointly to encompass an entire metropolitan area Phase Two consists of coverage through a general permit for storm water discharge from small MS4s and applied to nontraditional discharges These nontraditional sources included military bases hospital complexes prisons public campuses and other governmental installations Though speci c numerical goals are not explicit in the guidelines for SWPPPs set forth by the California Water Board they are expected to comply with Section 402p of the Federal Clean Water Act This mandates that they must consist of controls that reduce or eliminate pollutants to the maximum extent practicable MEP Control measures are also discussed within the various management programs and establish the best management practices BMP for addressing certain situations Areas include education and outreach illicit discharge detection and elimination construction and postconstruction controls and good housekeeping for municipal operations Generally speaking medium to large municipality facilities are also required to conduct chemical monitoring while small facilities require no testing Industrial facility storm water pollution regulations are covered in a broad sweeping general permit and coverage extends over ten categories of industrial activity Requirements associated with the General Industry Permit include implementing measures that achieve results with the best available technology BAT that is economically possible along with the best conventional pollutant control technology BCT available Industrial sites are also bound to develop and employ storm water pollution prevention plans according to governing regulations Monitoring plans must be included to these plans as well Under the SWPPP sources of pollutants are to be identified and the means to manage the sources in order to reduce storm water pollution are explained Additionally the General Industrial Permit requires that an annual report be submitted each July 1 to the state ensuring compliance with these regulations Quick 4 Construction site storm water prevention plans are required when one or more acres of land are disturbed or when speci c projects are within a larger development of one or more acres Coverage is maintained under the General Permit for Discharges of Storm Water Associated with Construction Activity Activities subject to this permit include clearing grading and ground disturbances such as stockpiling or excavation Other activities not included are regular maintenance activities performed to restore the original line grade or capacity of the facility Storm water pollution prevention plans are also required with construction activities Site speci c features of this plan include site drawings with proposed construction perimeters of project area external discharge points and watershed areas to one quarter of a mile outside the project edges topology geographic features that may affect drainage patterns across the site impervious percentages across the site including roadways rooftops sidewalks empty lots etcetera and storm water collection and discharge points Best management practices are also established for construction sites and must be listed The BMPs utilized to reduce andor eliminate storm water pollutants must be noted on the site map as well In addition to the BMPs monitoring by both visual and chemical methods for various pollutants must be established performed and documented If discharges into an impaired waterway due to sedimentation occur an additional sedimentation plan must be drawn up and maintained as well Though traditional schools of thought would typically indicate that numeric discharges limits would be included in documentation associated with the California Storm Water Pollution Prevention Plans no reliable and blanketing information was available Given the subjective nature of various sites where storm water runolT can be monitored each site maintains unique features that may or may not fall under criteria for another site elsewhere in the state The most sweeping of statements found consisted of relying on the federally mandated standards of waterways in accordance with the Clean Water Act Further though some data was found regarding establishing runoff and runon coefficients from Caltrans California Department of Transportation no set limits or parameters are set Runon discharges can utilize the Rational Method for determining external drainages that may cross the project site but application is limited to areas less than 13 kmz Rainfall intensity standards are not specified either which seems rather counterintuitive However there are guides for plotting intermediate return periods and determining rainfall depths in order to calculate these intensities in millimeters per hour Additionally though there are no specifications on BMPs there are listings for minimum requirements to be considered These practices cover soil stabilization sediment controls wind erosion tracking controls nonstorm water management and waste management and materials pollution controls Obviously given the fact that no officially prescribed BMPs are mandated no information can be provided about specific vendor policies andor the required sizing of various controls ie detention ponds Quick 5 III MICHIGAN STORM WATER POLLUTION PREVENTION PLANS Michigan information regarding Storm Water Pollution Prevention Plans is extremely thorough In addition to reliance on the NPDES standards from the Federal government the Department of Environment and Natural Resources provides a wealth of information regarding required levels and tolerances of various pollutants A brief history of storm water practices is also included and brie y reviewed here Michigan has broken up the conventional thought patterns associated with storm water pollution and ooding into various paradigms This stems back to the unsightly open ditches of sewage and stagnant waters in the 19111 century to the current thoughts of creating sustainable and environmentally friendly areas through structural and institutional practices Many of the current ordinances associated with Michigan s storm waters focused first on ood detention where ooding occurred often from ice jams or snow melt in addition to large storm events This thought pattern has progressed and now considers pollution controls and water quality concerns Based on modeling and research pollutants tend to decrease concentration over time with larger storm events Through the widely accepted practice of treating the first half of an inch of rainfall many of the pollutants are contained Michigan scientists however feel this First Flush criterion only applies to single site scenarios A better treatment process in their minds is to create a ninety percent 90 treatment capability for multiple sites or for a watershed basin By capturing and treating 90 of the storm water runoff they presume that due to the varying time of runoff to reach the treatment point that much more of the pollutants are removed In addition to the 90 Rule Michigan has taken a more holistic approach to storm water treatment By examining channelforming ow features associated with bankfull conditions which occur every one or two years Michigan approaches control of these ows as a remedy to water quality and facilitate stream stabilization These control measures help reduce scour at the upstream end of the reach and downstream sedimentation issues In addition to controlling peak ows the durations are also addressed as bankfull conditions often weaken stream banks compounding erosion and stability problems Continued efforts regarding storm water runoff research modeling treatment and maintenance reside in the state legislature Through govemmentally imposed laws and regulations local watershed entities can organize and prepare specific plans to aid in the integration coordination and implementation of these initiatives Once these plans have been devised sitespecific best management practices BMP can be installed Some of these as listed by the Michigan Department of Environmental Quality include rain gardens green roofs grass swales and in ltration basins These control measures help to maintain ecological stability in an environmentally friendly and consistent manner Quick 6 Michigan storm water listings also include acceptable limits for various pollutants including bacteria fecal coliform and E coli phosphorous total suspended solids biochemical oxygen demands dissolved oxygen and temperature and pH concerns Table HA below lists these pollutants along with the associated limiting discharge amounts from storm water runoff These ef uent limits are dictated by the Michigan Water Quality Standards passed down within state Act 451 POLL U TAN T ACCEPTABLE LIMITS POSSIBLE SOURCES 200 bacteria100 mL water monthly average Point Source Pollution Fecal Coliform 400 bacteria100 mL water 7day average 130 bacteria100 mL water Municipal treatment plant bypassover ow discharges Illicit Connections W astewater owing into storm sewer systems NonPoint Source Pollution Agricultural runoff animal waste septic seepage Point Source Pollution Sewage treatment plants primarily from toothpaste detergents pharmaceuticals and foodtreating compounds NonPoint Source Pollution Lake sediment during turnover phosphate deposits andor rocks from weathering erosion and leaching urban runoff agricultural areas mining operations E Coli 30day average Waters classified as full body contact 300 bacteria100 mL water Anytime EColi Waters classified as partial body 1000 momma100 mL water Anytrme contact 1 mgL Typical 7 DEQ can impose stricter limits where Phosphorous assrmrlatrve capacrtres must not be exceeded 30 mgL 30day average 1 Total Suspended Solids 45 mgL 7day average 1 Any solids that will not pass through a filter 7 typically there are only narrative limits dealing with turbidity and color oil films floating solids foam settling solids suspended solids and deposits Biochemical Oxygen Demands Nitrogenous Oxygen Dem and 2 Carbonaceous Oxygen Demand 2 Point Source Pollution W astewater treatment facilities pulp and paper mills and meat and food processing plants NonPoint Source Pollution Agricultural and urban runoff and livestock operations Quick 7 7 L c 01 dW at 6an ish er 1 e S 3 Diurnal plant processes Seasonal waterbody turnover Water owsstagnations Microbes versus organic matter present Dissolved Oxygen DO 5 mgL Warmwater Fisheries 3 Heat loading limitations 9 Cooling waters Urban runoff Temperature 2 F 7 Coldwater Fisheries Soil erosion cloudy waters affect sunlightwarmth absorption 5 F 7 Warmwater Fisheries 6395 7 Dally mmlmum Acid rain Industrial facilities pH Wastewater treatment plants 90 7 Daily maximum DTotal Suspended Solids limits are given as narrative guidelines No speci c limitations are imposed but rather determined on a speci c basis as required Biochemical oxygen demands are determined in conjunction with dissolved oxygen DO limits These limits are based on several factors including organic material present ammonia and nitrogen levels Again these limits are simply narrative guidelines 3 Dissolved oxygen DO levels are given as minimum guidelines based on USEPA requirements for cold and warm water sheries in order to support Waterbome Wildlife These limits are established in concordance with biochemical oxygen demands as noted above TABLE II A Summarizing the Michigan approach to storm water runoff control and treatment can be reduced to three rather simpli ed ideologies listed below While following these seemingly simple steps governmental in uence and scienti c methods can be applied to aid in their execution This ultimately aids in the repair restoration remediation or achievement of desired results Manage runoff from large storms to limit ooding Treat the First Flush of storm water runoff often the initial half inch and 3 Controlling the channelforming ows and volumes to protect channels from excessive scour and sedimentation 1 Again though Michigan discusses many of the state water quality limitations regarding ef uent levels there are no speci c BMPs that are required by state regulations Obviously no vendor or sizing requirements associated with implementation of these practices are stipulated as long as they are conducive to limiting storm water runoff to the limits stated above Additionally according to Michigan s interpretation of the NPDES requirements permits are required of anyone discharging or proposing to discharge waste or wastewater into the surface waters of the State and is intended to control direct discharge into the surface waters of the State by imposing ef uent limits and other conditions necessary to meet State and federal requirements Michigan DEQ 2002 Quick 8 IV SOUTH DAKOTA STORM WATER POLLUTION PREVENTION PLANS South Dakota storm water pollution prevention plan guidelines seemed extremely vague and rather repetitive While requiring permitting to be secured for construction sites industrial facilities and municipal wastewater treatment plants as mandated in federal regulatory ordinances the application process almost replicates itself for each coverage area Construction site permitting is both covered under the General Permit for Storm Water Discharges The minimum requirements for preparing a storm water pollution prevention plan include A description of the project The total area that will be disturbed A description of how you will control runoff and reduce pollutants both during and after construction A site map showing the direction of any drainage the slopes after grading and the location of any storm water controls such as hay bales sedimentation fences settling ponds etc The name of any bodies of water near the site and An inspection and maintenance schedule for storm water controls at the site Enforcement and monitoring of the SWPPP in South Dakota is marginal as a copy of the plan is not required for submittal to the Department of Environmental Services office but rather simply kept onsite unless specifically requested N01 to discharge is required for submittal no less than fteen 15 days before commencement of projects and updates are to be kept onsite in the SWPPP Industrial permitting coverage is also provided under a General Permit for Storm Water Discharges Minimum plan requirements are very similar to the construction site discharge requirements listed above with little variation The pollution prevention plan must include A description of the project A description of how you will control runoff and reduce pollutants A site map showing the direction of any drainage and the location of any storm water controls The name of any bodies of water near the site and An inspection and maintenance schedule for storm water controls at the site Also similar to construction project guidelines the N01 is required fteen days 15 in advance though provisions are listed for projects already underway In addition those projects within city limits may have additional requirements and must be met accordingly those these are municipally instituted and not listed on the statewide plan guidelines Waivers for industrial facilities may also be filed if the pollutant prone materials do not Quick 9 come in contact with precipitation or runoff waters Proper forms are provided for requesting these exemptions and must be led with the proper state agency Municipal wastewater treatment plants also require permitting under the federal statutes Municipal separate storm sewer systems MS4s serving all localities are required to provide veri cation of discharge limiting treatment procedures Similar to the federal program mandates South Dakota requirements pull directly from the USEPA guidelines for storm water management and list the following six control measures to be implemented Public education and outreach Public participationinvolvement Illicit discharge detection and elimination Construction site storm water runoff control Postconstruction storm water management and Pollution prevention good housekeeping for municipal operations Unlike the construction site or industrial pollution prevention plans municipal treatment plans are required to be submitted to the state environmental agency Based on state legislative Act 745401 basic water quality standards were established for ef uent limitations and runoff concentrations These parameters are listed in Table IIIA below POLLUTANTCONDITION EFFLUENTLIMITATIONS Suspended Solids 1 10 mgL 24hour composited sampling Biochemical Oxygen Demand 1 10 mgL 5day sample Coldwater Fisheries 40 maximum Temperature Loading Warmwater Fisheries 50 maximum Incremental Hourly Gains 3 maximum High Quality Fishery Waters Not to exceed design flow of the minimum 7day average low flow that can be expected to occur once in every 25 years Flow Rates Low Quahty Flshery Waters Not to exceed design flow of the minimum 7day average low flow that can be expected to occur once in every five years 7Q5 or 10 cubic foot per second whichever is greater Limits for suspended solids andbiochemical oxygen demand are not to exceed 175 mgL in any single grab sampling at anytime TABLE III A Quick 10 South Dakota storm water prevention plan design and implementation as stated in state online references seems vague at best Given the perceived nature of possible funding andor manpower limitations for the state these programs may be difficult to implement 7 much less enforce This is evident in the construction site and industrial facility permitting in particular due to the self regulating nature of the requirements Additionally there are no provisions or discussions related to BMPs or control measure implementation vendors or proof of adequacy in regard to functionality or size of these devices Continuing in the vague nature of the South Dakota Department of Environmental Services there is also no discussion of discharge volume or ow rate limitations or treatment of a certain amount of runoff Quick 11 V SUMMARY AND CONCLUSIONS In reviewing the approach of three different states in different parts of the country several conclusions can be drawn related to not only the various states interpretations of the federally mandated regulations associated with Storm Water Pollution Prevention Plans but also their implementation procedures Surprisingly given the referenced materials Michigan seemed to have the most comprehensive and readily available information dealing with a majority of the topics dealt with in the scope of this project Many similarities pervaded each of the state approaches obviously a result of the USEPA guidelines for SWPPP development implementation and maintenance The various permits required included construction activities industrial facilities and municipal wastewater treatment plants in all states Approaches at that point differed greatly based on each state s legislative guidance policies for water quality standards Depending on the appropriate measures from a topdown perspective Clean Water Act regulatory guidelines being the most preemptive specific state guidelines referred to those or in some cases were a little more stringent due to onsite conditions andor extenuating circumstances in sitespecific situations Again Michigan seemed to lead the way in the most comprehensive and holistic approach to storm water pollution prevention and remedy plans Through not only water quality concerns but also channelforming ows and stability issues along with ood control their approach dealt with underlying factors of contribution to pollution discharges and not only with the storm waters themselves Further it was noted that in all cases very little specification was provided regarding the institution of best management processes BMP While implicitly provided for in the water quality guidelines none of the three states covered delineated specific control measures Instead narrative and suggestive measures were incorporated for a wide array of solutions to be considered on a casebycase basis Additionally no explicit discharge limitations for flow rates or volumes were imposed other than those established through legislative water quality standards acts Though Michigan addressed various control methods that could be implemented sizing andor functionality guarantees from vendors were never mentioned across the board Based on the results of these examinations along with the relatively wide spread knowledge of funding and manpower concerns the storm water pollution prevention plans can be widely considered as self regulating procedural issues Though routine inspections may be performed by the appropriate state agencies given the sheer magnitude of ongoing construction projects industrial facility waste production and municipal treatment plants it may be nearly impossible to ensure that water quality standards are not violated in each and every case It must also be noted that sitespecific implementation provides for an enormous gray area where BMP may need constant attention and remediation before appropriate discharge levels are attained to meet water quality standards Quick 12 VI WORKS CITED California Environmental Protection Agency Construction Storm Water Program 05 July 2005 10 September 2005 lthttpwwwwaterboardscagovstormwtrconstructionhtmlgt California Environmental Protection Agency Industrial Storm Water Program 05 July 2005 10 September 2005 lthttp www waterboards ca govstormwtrindustrialhtmlgt California Environmental Protection Agency Municipal Program 05 July 2005 10 September 2005 lthttpwwwwaterboardscagovstormwtrmunicipalhtmlgt Michigan Department of Environmental Quality Bacteria 09 June 2003 15 September 2005 lthttpwwwdeqstatemiusdocumentsdeqswqnpdesBacteriapdfgt Michigan Department of Environmental Quality Biological Oxygen Demand 09 June 2003 15 September 2005 lthttpwwwdeqstatemiusdocumentsdeqswq npdesBiochemicalOXygenDemandpdfgt Michigan Department of Environmental Quality Dissolved Oxygen 09 June 2003 15 September 2005 lthttpwwwdeqstatemiusdocumentsdeqswqnpdes DissolvedOXygenpdfgt Michigan Department of Environmental Quality pH 09 June 2003 15 September 2005 lthttpwwwdeqstatemiusdocumentsdeqswqnpdespHpdfgt Michigan Department of Environmental Quality Phosphorous 09 June 2003 15 September 2005 lthttpwwwdeqstatemiusdocumentsdeqswqnpdes Phosphoruspdfgt Quick 13 Michigan Department of Environmental Quality Storm Water Management Ordinances 09 June 2003 15 September 2005 lthttpwwwmichigangovprinterFriendlyO1687713533137368273716119804 00htmlgt Michigan Department of Environmental Quality Temperature 09 June 2003 15 September 2005 lthttpwwwdeqstatemiusdocumentsdeqswqnpdes Temperaturepdfgt Michigan Department of Environmental Quality Total Suspended Solids 09 June 2003 15 September 2005 lthttpwwwdeqstatemiusdocumentsdeqswqnpdes TotalSuspendedSolidspdfgt Michigan Department of Environmental Quality Who Needs an NPDES Permit 28 January 2002 15 September 2005 lthttpwwwmichigangovprinterFriendlyO 16877 13 53313736827371310200quot 00htmlgt South Dakota Department of Environment and Natural Resources Storm Water Permit for Construction Activities 10 September 2005 lthttpwwwstatesdusdenrDESSurfacewaterstormconhtmgt South Dakota Department of Environment and Natural Resources Storm Water Permit for Industrial Activities 10 September 2005 lthttpwwwstatesdusdenrDESSurfacewaterstormindhtmgt South Dakota Department of Environment and Natural Resources Storm Water Permit for Municipal Storm Sewer Systems 10 September 2005 lthttp www statesdusdenrDESSurfacewaterStormSmallhtmgt Quick 14 State of California Department of Transportation Storm Water Pollution Prevention Plan Storm Water Quality Handbooks March 2003 10 September 2005 ltwwwdotca govhq construc stormwater S WPPPiPrepiManuali3703pdfgt Quick 15
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