Dr. Marty Matlock, PE, BCEE, Executive Director, Office for Sustainability, Biological and Engineering Department, University of Arkansas, undertook a presentation titled Stormwater Management Programs under USEPA Phase 1 and 2 Rules (“Presentation”) at the 17th Annual Environmental Protection Agency (“EPA”) Region 6 Stormwater Conference (“Conference”) held in Hot Springs, Arkansas.
The Region 6 Office of EPA in partnership with Hot Springs, Arkansas, along with the Municipal Separate Storm Sewer Systems and States in Region 6 hosted the Conference, which discussed the management of municipal stormwater (including new/upcoming regulations).
Dr. Matlock’s Presentation undertook a detailed discussion of both the Phase 1 and Phase 2 EPA Clean Water Act stormwater permit rules.
By way of background, Dr. Matlock discussed the connection between industry (economic capital) and society (human capital) in the roles played by:
- Ecological goods and services utilized in industry
- Recovery and recycling of some waste
- Utilization of labor by industry
- Degradation of the environment by waste and emissions
- Emissions that may harm humans
- Investment by society in protection & restoration
- Ecological amenities enjoyed by society
The Presentation also detailed EPA’s count of the number of Municipal Separate Storm Sewer System (“MS4”) permits issued through June 2014:
- 250 individual MS4 permits cover approximately 855 Phase I MS4s
- 54 general MS4 permits cover approximately 6,589 Phase II MS4s
- 100 individual MS4 permits cover approximately 106 Phase II MS4s
- 2 watershed MS4 permits cover approximately 3 Phase I and 40 Phase II MS4s
The MS4 rules are noted to have been the subject of EPA implementation through stormwater permit programs for almost 20 years. The Presentation noted:
- Focus has been on water quality based effluent limits for stormwater permits
- Approach has expanded implementation of Best Management Practices
- The use of adaptive management for BMP-based permitting has proven to be effective
In discussing MS4 permit strategies, it is stated:
- Permitting authorities such as the Arkansas Department of Environmental Quality and EPA can express water quality based effluent limits “as system-wide requirements rather than as individual discharge location requirements such as effluent limitations on discharges from individual outfalls.”
- … The inclusion of numeric limitations in an MS4 permit does not, by itself, mandate the type of controls that a permittee will use to meet the limitation (quoting from Andrew Sawyers, Director, Office of Wastewater Management, EPA, in a 2014 memorandum).
Also noted is EPA’s recommendation regarding clear/specific/measurable permit requirements and post-construction stormwater management consistent with guidance in the 1999 Phase II Rule (which are stated to need numeric requirements that attempt to maintain pre-development runoff conditions).
Measurable elements, in terms of BMP implementation include:
- Schedule for BMP installation
- Frequency of a practice
- Level of BMP performance
The numeric benchmarks for BMPs and associated monitoring protocols to determine BMP effectiveness in stormwater permits along with actions required if benchmarks are exceeded were addressed.
Modeling of LID practices and SUSTAIN LID placement criteria predicted BMP performance runoff reduction (including peak flow) were addressed. Also, LID implementation cost comparisons and resources for BMP selection were reviewed.
Conway, Arkansas LID BMPs were discussed:
- Little Creek-Palarm Creek watershed LID BMPs to reduce nutrient and sediment loads
- Modification of SWAT model
- SWAT used to identify which HUC-14s were a priority for TSS, TN and TP
- Performance modeled
Click here to download a copy of the slides.
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