MS4 Requirements for Construction Site Storm Water

Runoff Control

Craig T. Maske, P.E., CFM

DODSON | A WALTER P MOORE COMPANY

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Presentation Topics

• Definitions

• MS4 and Construction Site Operator Requirements

• Tools for Reviewers/Inspectors

• Questions

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Definitions

• Municipal Separate Storm Sewer System

• Regulated Construction Site

– Small

– Large

• Storm Water Pollution Prevention Plan (SWP3)

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Pre-Construction Requirements

• Construction Site Operator

– Prepare Storm Water Pollution Prevention Plan (SWP3)

– Notify TCEQ of intent to discharge

– Notify MS4 operator

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Pre-Construction Requirements

• Large and Small Construction Sites

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Prepare SWP3 X X

Submit NOI to TCEQ X ---

Submit NOI to MS4 Operator X (7 Days) X (2 Days)

Post Site Notice at Entrance X X

Post NOI at Entrance X ---

Large Sites

(>=5 Ac)

Small Sites

(>1 Ac < 5 Ac)Task Notes

Fee $225/$325 (efile/paper)

(Small Sites Submit Site Notice)

Obtaining CGP Coverage

Pre-Construction Requirements

• MS4 Operator

– Review Site Plans/SWP3

– Receive and File NOI/Site Notice

– Issue Local Permits

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Pre-Construction Requirements

• Storm Water Pollution Prevention Plan Review

– SWP3 must contain all elements noted in Part III, Section F of TCEQ permit

– Many of these elements are not prepared until after permitting

– Additional elements added by Construction Site Operator prior to construction

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SWP3 Versus SWP3

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Construction Requirements

• BMPs must be planned and implemented

– Sediment and erosion controls

– Waste controls

– Other controls

• Inspections, maintenance and recordkeeping

– Construction Site Operator (regular)

– MS4 Operator (periodic)

• And assess penalties as necessary

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Inspections

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Photo Courtesy of Jon Jones, P.E., Wright Water Engineers, Inc.

Post-Construction Requirements Construction Site Operator

• Prepare and submit notice of termination (NOT) to TCEQ

• Large operators submit copy to MS4 operator

• Remove site notice and fill out bottom corner • Small operators submit copy of completed SN to MS4

• Keep copies of all paperwork for your records • At least 3 years from date of NOT

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Post-Construction Requirements MS4 Operator

• Receive NOT/completed Site Notice

• Ensure project meets termination requirements

• Ensure post-construction controls are in place

– Established vegetation, detention, etc.

– Depending on ordinance

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Tools for MS4s

• Storm Water Ordinance

– Requirements for construction operators

– Citations and fines for violations

• TCEQ Small Business/Local Government Assistance Program

– www.TexasEnviroHelp.org

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Final Thoughts…

• MS4 operators get to act as the first line of plan review and enforcement for TCEQ

• More construction site runoff requirements coming soon…

• More MS4 permit requirements coming soon…

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Questions??

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Craig T. Maske, P.E., CFM cmaske@walterpmoore.com