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SWM-SY 890223Regional Strategy for Managing Urban Storm Water Quality 1989 -92 North Central Texas Council of Governments Adopted on February 23, 19,89 • The North Central Texas Council of Governments is the designated water quality management planning agency for the urbanizing portion of the Dallas /Fort Worth Metroplex. For the past twenty years, NCTCOG has conducted an active planning and services program with its 200 member local governments on water quality issues. A coordinated regional effort is now needed to respond most effectively to new and significant federal and state requirements regarding urban storm water quality. With the assistance of its Public Works Advisory Committee and Water Resources Council, and their joint Nonpoint Source Task Force, NCTCOG's Executive Board adopted this Regional Strategy on February 23, 1989. Federal and state mandates to address urban storm water quality This Regional Strategy is designed to address three specific statutory requirements regarding urban storm water quality. First, Section 319 of the Water Quality Act of 1987 requires each state to assess the nature and extent of nonpoint sources, and to develop a multi -year management program with Best Management Practices to address any problems identified. NCTCOG has been assisting the Texas Water Commission in this activity for this region. Second, Section 402(p) of the Water Quality Act of 1987 requires municipalities of 100,000 population or greater and industrial activities to obtain federal permits to control the quality of their storm water discharges under the National Pollutant Discharge Elimination System. The U.S. Environmental Protection Agency has drafted regulations which would require formal NPDES permit applications by local governments to EPA Region 6 in a two -step process through 1992. The five largest cities will be affected initially, and three others may be affected when the 1990 Census is completed. Depending on required EPA national studies, all cities could be regulated by 1993. Finally, Section 26.177 of the Texas Water Code requires cities with 5,000 inhabitants or more to establish water pollution control and abatement programs. Among the functions to be included are the development and maintenance of an inventory of all significant waste discharges into and adjacent to water within the city, and regular monitoring of such discharges. Another component of particular relevance is the "development and execution of reasonable and realistic plans" to control storm water discharges and urban runoff. Objectives This Regional Strategy For Managing Urban Storm Water Quality is intended to achieve the following objectives: • to negotiate as one region with the EPA and state on the interpretation of the rules and requirements • to reduce the administrative burden to each local government associated with the permit application process • to save money for each local government by conducting cooperative activities wherever possible • to share professional knowledge and experience on this complex subject through a Regional Task Force of affected local governments and others • to facilitate consistent quality in the collection, interpretation and presentation of information, thereby enhancing the chances of permit approval • to facilitate the use of available resources within the region, such as consultants and universities, in conducting cooperative activities • to maximize watershed planning under state law so as to minimize unneeded permit conditions under federal law • to extend permit requirements to smaller cities or other governmental agencies only where warranted • to evaluate together at the local level what controls are "reasonable and realistic" for managing urban storm water quality • to provide flexibility in program scheduling and implementation so as to minimize financial impacts on affected local governments • to preserve all implementation decisions to each governmental agency Three phases of regional strategy The Regional Strategy will meet these objectives in three phases as follows: • First Phase — Assessment of current storm water conditions, involving the development and submission of Part EPA permit applications by up to eight directly affected cities, due by November 1990 if final regulations are published in early 1990. • Second Phase — Development of reasonable and realistic watershed plans for managing urban storm water quality in priority watersheds, with evaluation of control measures and implementation schedules; all local governments of at least 5,000 population in a priority watershed would participate. • Third Phase — Local adoption of five-year storm water improvement programs (SWIP's), involving the development and submission of Part 2 EPA permit applications for priority watersheds, with all affected governmental agencies, co- permittees and permit conditions related to plan recommendations; applications due in 1992. First Phase Assessment of current storm water conditions and submission of individual Part 1 storm water permit applications by affected cities The directly- affected cities would cooperatively assess current storm water conditions and submit individual Part 1 applications. They would be due by November 1990 (or alternate later date if EPA specifies). Key components would include: • Legal authority of local governments to control storm sewer discharges (single regional report) Description of legal authority of local governments in Texas to control discharges associated with municipal separate storm sewer systems, prepared by a Legal Team from the affected local governments • Ten -year summary of water quality /quantity stream conditions (single regional report for discharge characterization) • Regional monthly mean rain and average number of storm events, to be determined in cooperation with National Weather Service • Any storm sewer sampling data since NCTCOG's 1987 -88 Assessment of Local Data on Nonpoint Sources" • Excerpts from state reports prepared under Sections 304(1), 305(b), 314(a), 319(a), etc. • Excerpts from federal reports such as U. /S. Fish & Wildlife toxic chemicals study, EPA studies, eta • Delineation of state segments and watersheds on 7.5- minute USGS quad series (paper or computer) • 1990 inventory of outfalls and industrial activity (maps and database for source identification) • "Major" outfalls to be delineated by each local government on USGS quad series (paper or computer) and catalogued in a computer database • "Stormsewer- sheds" to be delineated for each stream reach which has one or more major outfalls; all local governments would be identified • Relevant "industrial activity" within each stormsewer -shed to be computer catalogued in a consistent format. Information to be provided by the industrial facility would include the name, address, location, a description which best reflects the principal products or services provided (including SIC code), relevant state or federal environmental permits/ registrations, and any available discharge information • USGS Level I and II land use to be displayed and summarized for each stormsewer -shed, and imperviousness estimated (through interpretation of satellite imagery) • Location and description of each operating and closed permitted landfill /transfer station by stormsewer -shed (information already being prepared by NCTCOG as part of regional solid waste management planning program) • Cooperative screening analyses for illicit discharges (screening results from consistent sampling methods, analytical procedures and interpretation of data) • Make available to cooperating local governments, through Regional Task Force, consistent sampling methods and analytical procedures to detect illicit connections and illegal dumping • Screening to be undertaken using approved methods, procedures and timing • Results displayed and summarized using consistent graphic, table and text formats • Joint plan to characterize storm sewer discharge quality (maps and joint plan) • Each major outfall suspected of containing illicit discharges or improper disposal would be highlighted by the affected local government on the 7.5- minute USGS quads, and the affected local government would be responsible for either performing wet and dry weather sampling as established by EPA or developing a plan to detect, identify and control such discharges • Recommend to EPA a joint plan to identity, monitor and analyze for a wide range of parameters at selected major outfalls which are representative of commercial, residential and industrial land use activities for the cooperating local government systems (maKimum of 10 outfalls per system) • Recommend to EPA the specific major outfalls to be monitored Existing management programs (Two NCTCOG 1988 reports supplemented with any additional information and maps from each cooperating local government) • Updates to NCTCOG's 1988 "survey of Local Programs" summarizing typical management practices for each local government • Existing cooperative controls from NCTCOG's 1988 "Regional Initiatives for Storm Water Management" (e.g., construction runoff requirements in the adopted Standard Specifications for Public Works Construction North Central Texas) • Location of major structural controls for storm water discharges (e.g., detention basins) by each local government on quad sheets (paper or computer) Individual Part 1 EPA storm water permit applications by city (individual application by each city) • Each affected local government of 100,000 population or greater would submit the required Part 1 application forms to EPA with the above materials included Second Phase Development of reasonable and realistic watershed plans for managing urban storm water quality _ Every city in Texas with 5,000 or more inhabitants is required by Section 26.177 of the Texas Water Code to establish a water pollution control and abatement program. Among the five major services and functions to be included is: " .. the development and execution of reasonable and realistic plans for controlling and abating pollution or potential pollution resulting from generalized discharges of waste which are not traceable to a specific source such as storm sewer discharges and urban runoff from rainwater." In the second phase of this Regional Strategy, priority watersheds would be identified by the Regional Task Force based on the inventory, screening and monitoring information. All cities of 5,000 population or greater, and appropriate local, state and federal entities in each priority watershed would be expected to participate in the development of a "reasonable and realistic" plan for managing urban storm water quality, with evaluation of control measures and recommendation of implementation schedules. A database of Best Management Practices would be developed through the state or locally to aid this process. Key components would include: • Characterization of storm sewer discharges Upon approval by EPA Region 6, the joint characterization plan from the first phase would be conducted to monitor and analyze a wide range of parameters for specific major outfalls which are representative of commercial, residential and industrial land use activities. • Identification of priority watersheds Information from the first phase, such as inventories, land use and field screening, would be combined with the characterization of storm sewer discharges to estimate the annual pollutant loads and event mean concentrations of the cumulative discharges from all outfalls for selected parameters. Priority watersheds would then be identified. • Database on best management practices As part of its State Nonpoint Source Assessment Report to EPA, the state is required to describe the process, including intergovernmental coordination and public participation, for identifying best management practices and measures to control each category of nonpoint sources, including urban storm water. Either the state will provide guidance on BMP's, or the cooperating local governments will have to assess the general applicability, costs and effectiveness of a variety of structural and source controls for reducing selected pollutants from illicit discharges, commercial /residential areas, construction sites and industrial activities. • Development of reasonable and realistic plans for priority watersheds All cities of 5,000 population or greater plus appropriate local, state and federal entities in priority watersheds would be expected to participate in the evaluation of potential structural and source controls to maintain or improve urban storm water quality. Each plan would be tailored to the problems and opportunities of the watershed. Alternatives would be thoroughly evaluated and the plan would recommend an implementation schedule with legal, funding and resource requirements in five -year increments. Third Phase Local adoption of five -year storm water improvement programs and submission of part 2 storm water permit applications by watershed Part 2 storm water permit applications must be submitted within two years of publication of the final EPA rules for large systems, or by February 4, 1992 for medium systems. There would be joint applications for each priority watershed, with all affected governmental agencies as co- permittees Key components of this third phase would include: Local adoption of five -year storm water improvement programs Using the results and recommendations from a watershed plan, all affected governmental agencies with 5,000 inhabitants or greater would be asked to adopt a Five Year Storm Water Improvement Program. Each governmental agency could adopt a separate Five Year SWIP for each watershed, or one SWIP that covers all of its priority watersheds. This SWIP would serve as the focus of the required Part 2 application for an EPA storm water permit (whose initial period would be five years). Joint part 2 EPA storm water permit applications by watershed For each watershed, all affected governmental agencies would serve as co- permittees and would submit a joint Part 2 EPA permit application. The responsibilities of each co- permittee would be clearly identified in the permit, and each would be solely responsible to EPA for meeting requirements for its respective jurisdiction. Annual status reports would be required by EPA. EPA would determine whether the adopted SWIP and associated information in the Part 2 permit application meets the requirements for a comprehensive program of structural /nonstructural measures to control storm water discharges. NCTCOG Executive Board 1988 -89 President Everett Gladding Mayor Pro Tem, City of Greenville Vice President Bert Williams Mayor Pro Tem, City of Fort Worth Secretary Treasurer Marti VanRavenswaay Councilmember, City of Arlington Past President Joe Regian Former Councilmember, City of Garland What Is NCTCOG? Director John Evans Mayor Pro Tem, City of Dallas Director Ed Galligan Councilmember, City of Grand Prairie Director Lee Jackson County Judge, Dallas County Director Margie Waldrop Mayor Pro Tem, City of Lancaster Director Bill Lofland County Judge, Rockwall County Regional Citizen Representative John Stevenson TaiTant County Regional Citizen Representative Stan Lambert Ellis County General Counsel Jerry Gilmore Attorney at Law, Dallas Executive Director William J. Pitstick The North Central Texas Council of Governments is a voluntary association of cities, counties, school districts. and special districts within the sixteen -county North Central Texas region. It was established in 1966 to assist local governments in planning for common needs, cooperating for mutual benefit, and coordinating for sound regional development. The Council of Governments is an organization of, by and for local governments. Its purpose is to strengthen both the individual and collective power of local governments — and to help them recognize regional opportunities, resolve regional problems, eliminate unnecessary duplication, and make joint regional decisions — as well as to develop the means to assist in the implementation of those decisions. NCTCOG is the state designated agency for areawide water quality management planning. North Central Texas is a sixteen -county metropolitan region centered around Dallas and Fort Worth. It has a population of 4.0 million and an area of 12.800 square miles. NCTCOG currently has 204 member governments, including 16 counties. 149 municipalities, 21 independent school districts, and 18 special purpose districts. For more information contact: John Promise, NCTCOG Director of Environmental Resources, P. Q Drawer COG. Arlington, Texas 76005 -5888, (817) 640 -3300