Federal Water Pollution Control Act (Clean Water Act) • 1972 – NPDES permits added to CWA • 1987 – Regulation of Storm Water Added • 1990 – Phase I permits (MS4s) • 1999 – Phase II permits (small MS4s) • 2004 – NOI & Plan ???
Phase II Permits CSU’s originally fell into the Phase II group as “Non-Traditional MS4’s”. Based on the 1990 census. Campus population > 10,000. and/or Area population density > 1000 people per square mile.
Submittals Notice of Intent (NOI) & Campus Plans. Application deadline will be at least 365 days after the MS4 General Permit adoption date (scheduled for April 30, 2003 SWRB meeting). Submit NOI, SWMP, and Fee to RWQCB SD Region 9 : (858)467-2988
Best Management Practices www.cabmphandbooks.com
Annual MS4 Permit Costs State Water Resource Board fee schedule: Based on RWQB designation of CSU’s coverage. Populations (Faculty, Staff, Students & Visitors) Up to 10,000 = $2000.00 per year Over 10K = $3000.00 per year for the permit application fee
Generic Plan Minimalist Plan - Minimum possible Best Management Practices (BMP’s) Share writing- originated from CSUF, CSULB, CSUS, UC Presidents Office Cost saving Reduced operational workload Attainable goals over the 5 years Let SWRB or RWRB add BMP’s to plan after submittal. Recommendation-to contact Regional board and get them involved in our plan from the beginning.
BMPs Schedules of activities, prohibitions of practices, maintenance procedures, and other management practices to prevent or reduce the pollution of waters of the United States. BMPs also include treatment requirements, operating procedures, and practices to control site runoff, spillage or leaks, sludge or waste disposal, or drainage from raw material storage.
BMP Resources • EPA’s BMP Toolbox • http://cfpub.epa.gov/npdes/stormwater/menufo/bmps/menu.cfm • CASQA’sBMP Handbooks • www.cabmphandbooks.com/ • ASCE’sBMP Database • http://www.bmpdatabase.org • Others • www.swrcb.ca.gov/stormwtr/bmp_database.html
Requirements Reduce pollutants in storm water discharges to the Maximum Extent Practicable (MEP) by implementing a Storm Water Management Program (SWMP)
Vision • Your SWMP is your vision for protecting water quality over the next five years and beyond
Along with BMPs, measurable goals, time schedules, and responsible persons define your program
SWMP • 6 Minimum Control Measures as a basis for a SWMP • BMPs to address 6 Minimum Control Measures • Measurable Goals for each BMP • Time Schedules for each Measurable Goal
Public Participation Requirements • Comply with State and local public notice requirements • Allow the public to review and comment on the permit and SWMP • Involve the public in the implementation of SWMP • Volunteers for stenciling, link on websites (PDC, RM&S and FAC) to the site that will be hosting the info on the implementation of the permit. • RM&S will promote local household hazardous waste events.
Illicit Discharge Detection and Elimination Requirements • Storm sewer system map. RM&S will seek assistance from Facility Services for this. • An ordinance prohibiting non-storm water discharges • Plan to detect and address non-storm water discharges • Educate the public on the hazards of illicit discharges
Illicit Discharge Detection and Elimination Requirements • Set up as program to identify pollutants, which will tell you what BMP’s to put in place. Prioritize these based on the type of community that you have. The EPA site has some good info about land use. • Hotline or weblink to inform enforcement party as to illicit discharges. Follow up process on these calls. • Touch base with local activities for consistency
Construction Site Control Requirements • An enforce ordinance to require erosion and sediment controls at construction sites • MS4 must require construction site operators to us BMPs • Site plan and BMP review • Public comments/complaints procedures • Site inspections and enforcement procedures
Construction Site Control • Boiler SWPP from CAL TRANS for BMP’s • Incorporate NEPA and CEQA stormwater quality specifications into our programs. • SWPP- should be part of bid package regardless of size of project. During bidding process of more than one acre have a brochure that mentions the state permit requirements • Go to EPA site in regards to land use
Many communities are similar, look at what they are doing The permittee may rely on a SIE (e.g. Vallecitos Water District) to satisfy one or more of the permit obligations if the separate entity can appropriately and adequately address the storm water issues of the permittee.
Look at what you are already doing • Restaurant inspections • Household hazardous waste day • Handling complaints • Pollution Prevention Fair-outreach , distribute logo products not stuff that becomes trash.
Annual Reports due in 2004 • Have you done what you said you would do? • In light of water quality, have you seen noticeable changes? • Are the BMPs you chose effective? • Are they implemented well? • Improvements? • Reporting form
Is what you are doing working? • Evaluation/Assessment Parameters • Use the information that you are gathering to help tailor your program • Ex: If you continually have to clean out a particular storm drains because of sediment, you should focus on construction activity in that drainage area
Develop ImplementAssess Iterative approach: Is what you are doing working?
Activity Examples • By the end of year one, we will cleanout 50% of the drop inlets. By the end of year two we will cleanout another 50%. • By the end of year one, we will adopt an enforceable ordinance prohibiting non-storm water discharges
Output Examples • By the end of year one we will produce two different brochures – one general and one targeting lawn and garden care • By the end of year two, we will have collected 5 tons of sediment/wk through street sweeping
Outcome Examples • There will be a 50% increase in the people surveyed who know the basics about MS4s between year one and year three • There will be a 25% decrease in the number of reported localized flooding incidents between years two and three (with some evaluation of rain data)
Impact Examples • 25% reduction in trash collected at creek cleanup between years 1 and 2 and between years 2 and 3 • 2 degree decrease in water temperature between years 1 and 5 due to re-vegetation of riparian corridor
Measurable Goals • Reasonable - did you reach your goal Yes/No?. Do you have direct control over it? After implementation are they still reasonable? • Relevant – Are they related to water quality? Are they producing a behavior change? • Reaching- Do they meet the MEP?
Responsibilities at CSUSM • RM&S – plan submittal, public education and outreach component of permit & training coordination. • PD&C – construction project oversight & compliance (pre thru post construction). • Facilities – annual review, reporting, hardscape & softscape maintenance • Building Marshall(Recommendation)- compliance oversight & enforcement • Funding – 1st year: VP FAS, 2nd yr Facilities or VPFAS Other sources that can be used: Utility budget, Parking, Projects.
Emergency Response • Prevent any materials other than rainwater from entering the storm drain system. • Fire Departments enjoy exemptions to this rule. • Facilities and RM&S responsible • New supplies have been purchased by RM&S for this purpose. Covers and dikes for storm drains
Board Contacts • Jarma Bennett • 916)341-5532 • firstname.lastname@example.org • Pamela Barksdale • (916) 341-5280 • email@example.com Risk Management and Safety