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HomeMy WebLinkAboutIR 7347 INFORMAL REPORT TO CITY COUNCIL MEMBERS No. 7347 P.1 """40 0 , To the Mayor and Members of the City Council anu Jaxy 24, 1989 'rFxayx OVERVIEW OF PROPOSED EPA STORM WATER PERMIT REGULATIONS Subject: UPDATE The Federal Water Quality Act of 1987 requires municipalities with popula- tions greater than 100,000 and certain industrial facilities to obtain National Pollutant Discharge Elimination System (NPDES) permits for their separate storm sewer systems. During December 1988 EPA published their proposed requirements for obtain- ing the mandated municipal/industrial NPDES permits and according to EPA, "These are not permits in the normal sense we expect them to be. These are actual programs. These are permits that go far beyond the normal permits we would issue for an industry because they in effect are programs for stormwater management." These programs will be developed by EPA' s approval of- a comprehensive two part permit application submitted by municipalities. TIMETABLE: The part one application proposal will require Fort Worth and 55 other muni- cipalities with populations in excess of 250,000 to begin the permit pro- cess in time to submit Part 1 of the application within one year of publica- tion of the final regulations anticipated to be complete May 1989. Part 2 is required within two years of the publication date. (i .e. 1991) OW PART ONE APPLICATION REQUIREMENTS: List legal authority, provide histor- ical source identification/outfall information, characterize nature of dis- charges , conduct field screening, develop plans to estimate pollutant load- ings, list existing structural and non structural controls, submit part one plus a ten year projection of population and develop growth. PART TWO APPLICATION REQUIREMENTS: Demonstrate legal authority, supplement source identification information, submit information characterizing dis- charges, propose assessment of controls, submit cost estimates of proposed management programs and source of funding, list roles and responsibilities of co-applicants, if any. In general , this is an improvement over previous EPA storm water regula- tions that would have required federal NPDES permits on each storm drain outfall pipe and required municipalities to conduct expensive chemical test- ing on each of hundreds to thousands of outfall pipes. From an environmen- tal standpoint, this approach is also an improvement, because municipal- ities will be taking an active role in pollution control management, tai- lored to local conditions, as opposed to being data collectors for EPA. This new approach will however require municipalities to commit significant funds and resources to expand existing governmental responsibilities in the water pollution control field. -ISSUED BY THE CITY MANAGER FORT WORTH, TEXAS INFORMAL REPORT TO CITY COUNCIL MEMBERS No.7347 p•2 -PAGE 2- January 24, 1989 To the Mayor and Members of the City Council 0 X Subject: OVERVIEW OF PROPOSED EPA STORM WATER PERMIT REGULATIONS These proposals will also require certain industrial and commercial activi- ties to obtain NPDES permits, unless they discharge into a municipal storm sewer system. This would encourage industry to become part of a system that has a municipality as the responsible permittee, and would decrease industry' s expense and paperwork burdens while increasing the municipal- ity's responsibility. EPA has requested comments regarding some 50 different topics associated with the proposed storm water regulations . Staff from Health, Water and Transportation/Public Works will be preparing comments to submit to EPA by March 7, 1989 deadline. Prior to submission staff will request Council to endorse these comments. For additional information, there will be a public hearing at the regional EPA headquarters in Dallas on January 26, 1989 . The morning session will be devoted to industrial and the afternoon to municipal permit require- ments. MUNICIPAL ISSUES Administrative capability Financial capability/costs Pik Legal authority Testing/Sampling requirements Permittee designation Group applications Major outfall ; definitions, maximum # for testing Characterization of discharges Field screen/inspections Prohibition of non-storm discharges Site specific management programs Industrial activity Construction sites regulation State Highway department systems Part 1 applications Part 2 applications Five Year NPDES Permit Waste oil recycling, informational efforts For additional information contact Gene Rattan, Environmental Quality Super- visor, extension 7281. m ,��.,,--Douglas Haman City Manager -ISSUED BY THE CITY MANAGER FORT WORTH, TEXAS