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HomeMy WebLinkAboutIR 7906 t INFORMAL REPORT TO CITY COUNCIL MEMBERS No. 7906 To the Mayor and Members of the City Council April 4, 1995 X Subject: 1873 OVERVIEW OF PROPOSED NPDES STORM WATER PERMIT PROGRAM BACKGROUND The Clean Water Act Amendment approved by Congress in 1987 expanded the National Pollutant Discharge Elimination System (NPDES) permit program to cover municipal separate storm sewer systems (MS4's). This new permit program requires Fort Worth to obtain a permit in order to discharge the water collected within its storm drain system and limit pollutant discharges to the "Maximum Extent Practicable" (MEP). The MS4 permits do not have numeric discharge limits like earlier NPDES permits for point discharges such as wastewater treatment plants and industrial facilities, but instead rely upon "quality factors". Phase I of the;NPDES storm water program covered all cities with a population greater than 100,000. In the Metroplex, Phase I includes Fort Worth, Dallas, Arlington, Garland, Irving, Mesquite, and Plano. To date, the EPA has not issued rules covering Phase II cities (less than 100,000 pop.), and all indications from Congress are that permitting of Phase II cities will be postponed indefinitely. It should be noted that the NPDES, storm water permit requirements also extend to industrial facilities operated by the City. As a result, the City's Southeast Landfill, Village Creek Waste Water Treatment Plant and the three City-owned airports were required to obtain individual NPDES Industrial Storm Water Permits. These industrial user permits have completely different requirements than the city-wide MS4 permit discussed in this report. PERMIT APPLICATION PROCESS Applying for a permit was a two part process. Cities with populations greater than 250,000 had an earlier deadline than those cities with populations between 100,000 and 250,000. However, the seven impacted Metroplex cities joined together and proposed a regional permitting strategy and timeline which allowed Fort Worth and Dallas, the two large cities with the earliest application deadlines, to submit Part II of their applications in accordance with the later deadline for the five other medium size cities. The regional strategy allowed the seven cities to work together through the North Central Texas Council of Governments and share the cost of many tasks and programs required of all applicants. This resulted in significantly lower application costs for the seven cities in comparison to other impacted cities in Texas and the entire country. The City of Fort Worth submitted Part I of the NPDES Storm Water Permit application in November 1991. Part 11 was submitted in August 1993, and contained a detailed discussion of the City's proposed Storm Water Quality Management Plan. This Plan includes a variety of ISSUED BY THE CITY MANAGER FORT WORTH,TEXAS INFORMAL REPORT TO CITY COUNCIL MEMBERS No. 7906 TE c+w wry To the Mayor and Members of the City Council April 4, 1995 Page 2 of 3 rEXPS Subject: OVERVIEW OF PROPOSED NPDES STORM WATER PERMIT 1873 PROGRAM programs designed to limit the amount of pollutants discharged to the City's storm drain system from the following sources: A. Residential and Commercial Sites B. Illicit Discharges and Improper Disposal C. Landfills/Hazardous Waste Facilities/Industries D. Construction Sites The Texas Department of Transportation and Tarrant County Water Control and Improvement District No. 1 are co-permittee's with the City, and will share information and/or resources in support of the City's program. PERMIT STATUS The EPA has yet to issue a draft permit to any of the seven Metroplex cities. The latest indication is that Fort Worth and Dallas should receive draft permits in April, with the remaining five cities receiving draft permits sometime this summer. Once the draft permit is received, there will be a 30 day public comment period, during which time any interested individual or organizations can make comments on the provisions of the permit. This public comment period also offers the City the opportunity to respond to the EPA in an effort to negotiate certain permit conditions. Once the public comment period is closed, EPA may make changes prior to issuing a final permit. The permit will be issued for a period of five years. While no draft permit has been issued, the EPA did send the City a "Letter of Deficiencies" in March 1994. This letter identified certain areas of the City's Part II application which the EPA felt were lacking certain information and/or needed further explanation. The City staff discussed these "deficiencies" with EPA staff and sent revised application sections to the EPA in June 1994. As a result of these discussions and other meetings between the seven cities and EPA during the previous eighteen months, staff anticipates that the draft permit will closely follow the programs included in the City's revised application. PROPOSED PERMIT PROGRAM The NPDES Storm Water Permit program is an extremely comprehensive, far-reaching program which has the potential to impact the operations of at least 12 City departments. A complete list of proposed permit programs/components and their associated compliance deadlines is included as Attachment A. A brief description of each program/component and potentially impacted departments is included as Attachment B. ISSUED BY THE CITY MANAGER FORT WORTH,TEXAS INFORMAL REPORT TO CITY COUNCIL MEMBERS No. 7906 G�pHTEgF� To the Mayor and Members of the City Council April 4, 1995 Page 3 of 3 r n6 X Subject: Ian OVERVIEW OF PROPOSED NPDES STORM WATER PERMIT PROGRAM Many of the programs, such as Street Operation and Maintenance and Spill Prevention/Containment, are already in place and should require little or no modifications or additional spending. Other programs, such as wet and dry weather monitoring and public education will require additional resources, but the mechanism and organizational structure for carrying out these programs is already in place. There are however, a few programs, New Development Regulation and Construction Site Regulation, in particular, which will require a significant amount of staff analysis, modifications to departmental functions, and City Council deliberation prior to implementation. Because various programs under this permit will not be fully implemented for up to three years, it is impossible to estimate the actual cost of this permit program. However, a fiscal analysis completed by a consultant as part of the Part II permit application estimated approximately $3.8 million dollars,in new City costs, including staff time, during the first five year permit term. However, EPA's new emphasis on cost effectiveness combined with the Storm Water Quality Division's history of identifying innovative and less costly methods and programs provides a good opportunity for the City to implement this program at a cost less than this initial estimate. Staff will notify the City Council when the draft permit is received and provide a briefing on any unanticipated provisions of the draft permit, if necessary. C1 5-3gj� Bob Terrell City Manager Eric. ISSUED BY THE CITY MANAGER FORT WORTH, TEXAS Compliance Timeline Attachment A Storm, er Per it Rea 'remen s °p, � Permit Permit Permit Perm it Permit Year 1 Year 2 Year 3 Year 4 Year 5 Adoption of Storm Water Ordinance Outfall I.D. and Update Initial Storm Drain Mapping COMPLETED Mapping Updates and Corrections Wet Weather Monitoring Dry Weather Screening Wet Weather Screening PROM Pollutant Loading Estimates >> h� 'i��' Structural Control O & M New Development R ulation: Organizational Review Identify Policy and Objectives ,` Determine Alternatives&Stds. / ➢� � °��' ° 'r , ° ° ' Assessment of Alternatives Revise Documents and Plans Implement Regulations Street Operation and Maintenance Flood Control Impacts Pesticides/HerbicidesfFertilize rs Im lement/Enforce Ordinance ' J Storm Sewer Investigations Prevent/Contain Spills Public Reporting Public Education/Oils,Toxics M mt: Annual Haz.Waste Collections Permanent Hazwaste Site Inlet Stenciling Other Public Education Sanitary Seepage M,,MILE,U Field Screening Inspections and Reporting Construction Site Regulations: Public Education Targeted Customer Education Staff Training Organizational Modifications SWPPP Submission Requirements � Land Disturbance Permit ? �' Implement Regs/Site Inspections KEY: = Implementation Period �;, = Planning/Decision Making Period AIIACHMENI' 8 ~ r• w r ?, z z z z U U A .� 3wa wE� wF a � W to r.Lj v � o y � o � � o '� w �f o O O 'v �7 �u'� F y p ,%C� y Q y y a 4 o b �. 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