GAR 41000 GDO GDOT’s MS4 PERMIT ’s MS4 PERMIT Presented by M. Brad McManus, P.E. GDOT Office of Design Policy & Support To The Central Georgia Erosion Control and Stormwater Quality Workshop, 2012
MS4 MS4 Overview: •Phase II Final Rule in 1999 determined that state DOTs fall under MS4 (40CFR122.32). •GDOT is the last state DOT to receive a MS4 permit (issued Jan 2012) •GDOT’s permit is different others in the state in that it has measurable goals because of EPA’s guidance
GDOT and MS4 • This is only for GDOT roadways and facilities within MS4 areas. • The Georgia Department of Transportation worked with EPD to develop the MS4 permit.
MS4 GDOT is unique in that it has a separate construction permit that became effective • before MS4. GAR100000 was in effect in 2000. GAR100002 was issued in 2003 and reissued in 2008. The new permit will be issued summer of 2013. GDOT’s permit requires monitoring of outfalls and sedimentation storage. • • MS4 requires documentation of GDOT’s compliance with GAR100002
MS4 MS4 Requirements (also known as Minimum Control Measures): 1. Public Education 2. Public Involvement 3. Illicit Discharge Detection and Elimination 4. Construction Site Stormwater Runoff Control 5. Post-Construction Stormwater Management 6. Pollution Prevention/Good Housekeeping
MS4 GDOT’s Action Plan for Compliance Public Education BMPs: 1. Create a Website 2. Develop and implement a Training Program 3. Develop and implement a program to distribute educational material 4. Develop and implement a Storm Drain Marking/Signing/Pet Waste Station Program
MS4 GDOT’s Action Plan for Compliance Public Involvment BMPs: 1. Support the Adopt a Highway Program 2. Develop and display information at Public Information Open Houses 3. Develop and where feasible enter into Memorandum of Agreements
MS4 GDOT’s Action Plan for Compliance Illicit Discharge Detection and Elimination BMPs: 1. Develop a Storm Sewer System Map showing outfall locations and state receiving waters 2. Develop and implement a policy to prohibit illicit discharge 3. Develop and implement an IDDE plan 4. Develop and implement a plan for tracing of illicit discharges 5. Develop and implement a plan for receiving and responding to complaints related to illicit discharges 6. Develop and implement spill response procedures for responding to and cleaning up spills
MS4 GDOT’s Action Plan for Compliance Construction Site Stormwater Runoff Control BMPs: 1. Develop and implement a contractual obligation mechanism to require compliance with the Manual for Erosion and Sediment Control in Georgia 2. Ensure all Erosion Control Plans meet the requirements of GAR1000002 3. Develop and implement a plan for receiving and responding to complaints related erosion and sedimentation complaints 4. Develop site plan review procedures 5. Develop site inspection procedures in accordance with the Construction Activity Permits. 6. Ensure through contracts and other mechanism that construction site operators control waste that may cause adverse water quality impacts in accordance with the Construction Activity Permit 7. Develop procedures for bringing contractors back into compliance with the contract requirements
MS4 GDOT’s Action Plan for Compliance Post ‐ Construction Stormwater Management BMPs: 1. Develop an inventory of post ‐ construction stormwater management structures designed for filtering and/or detention 2. Develop and implement a policy to address post ‐ construction runoff. 3. Develop a program for the long ‐ term operation and maintenance of post ‐ construction structures designed for filtering and/or detention. 4. Develop a program for ensuring the use of a stormwater design manual and the feasibility of inclusion of the post ‐ construction standards from section 4.2.5.1 during the project design phase. 5. Develop a program for conducting a Low Impact Development/Green Infrastructure (LID/GI)
MS4 GDOT’s Action Plan for Compliance Pollution Prevention/ Good Housekeeping for Municipal ‐ type Operations BMPs: 1. Develop an inventory of GDOT facilities in the MS4 permitted area conducting municipal ‐ type activities that have the potential to cause pollutant runoff. 2. Develop and implement a program for inspecting GDOT facilities for good housekeeping practices. 3. Develop a manual detailing procedure for routine maintenance activities at municipal ‐ type operations to prevent pollutant runoff 4. Develop and implement a plan to inventory MS4 (drainage) structures. 5. Develop and implement a program for inspecting and maintaining MS4 structures along 10% of roadway miles annually 6. Develop and implement an employee training program, with the purpose of preventing and reducing stormwater pollution from GDOT facilities and activities 7. Develop and implement procedures for receiving and responding to complaints related to MS4 structures
MS4 MS4 does not cover the following areas: 1. Any area outside existing MS4 boundary 2. Non ‐ point source discharge (I.E. sheet flows) 3. Roads not owned or operated by GDOT
MS4 Accomplishments with the Permit •Notice of Intent (NOI) was developed from February to July 2 nd . •NOI was approved on September 19 th by EPD. •Funding has been identified •Road Projects have post construction design underway •Website for GDOT MS4 is currently under construction •Four contracts for initial MS4 work currently being processed •Request for solicitations for the implementation phase was sent yesterday
MS4 Challenges faced by GDOT 1. Linear nature of highways a) Multiple outfalls and watersheds b) Limits in locating facilities (often roadways have to follow existing alignments) c) Business and residents line the rights of way 2. Slow pace of design a) Public notices b) Environmental Document c) R/W procedures d) Review Procedures 3. Limited funds (without flexibility such as Stormwater Utility Fees)
MS4 Methods used to overcome the challenges (found in the permit) 1. Linear nature of highways a) Multiple outfalls and watersheds Infeasibility guidelines were developed for post construction Each outfall examined separately b) Limits in locating facilities Infeasibility based on location such as community and environmental resources Infeasibility based on field conditions such as slope and bedrock c) Business and residents line the rights of way Infeasibility based on possible displacement of a business or resident
MS4 Methods used to overcome the challenges (continued) 2. Slow pace of design Exemptions for post construction structures were given to projects that had their environmental document approved before June 30 th 2012. 3. Limited funds (without flexibility such as stormwater utility fees) Infeasibility based on project cost (each outfall examined separately).
MS4 Other Challenges faced by GDOT 1. Limited GDOT staff Solution: Hire consultants 2. Finite resources Solution: Limit effort to items necessary, spend effort upfront to determine most efficient means and methods to use (research for new BMPs, using existing data in forms of old plans and collaborating with other MS4s on data sharing) 3. Process and Procedures with deadlines looming Solution: Walking contracts through the process, working closely with the people in other offices.
MS4 Permit is final and the NOI has been approved • There is room for flexibility in regards to GDOT’s handling of the permit. The NOI can be modified. • Many programs required by the permit have not yet been developed that will dictate GDOT policy. • Options not yet explored are regional BMPs (detention or water quality), new post construction BMPs, research of BMP effectiveness.
MS4 You may find the permit on EPD’s website, on their Watershed Protection Branch Technical Guidance page. Questions?
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