Municipal Separate Storm Sewer System (MS4) National Pollutant Discharge Elimination System (NPDES) Permit Compliance Management

1
Municipal Separate Storm Sewer System (MS4)
National Pollutant Discharge Elimination System
(NPDES) Permit Compliance Management
Government of the District of Columbia

• Storm Water Administration Program
• COG Water Resources Workshop
• Preparing for Regulatory Change

2
Storm Water Pollution in DC

• Pollution generated in open space - public and
  private result in storm water pollution
• Examples of pollutants in storm water
• Trash (including leaf)
• Bacteria (animal waste)
• Sediment (land disturbing activities)
• Oil and grease (leaky vehicles, improper
  discharge of waste oil)
• Nutrient (lawn garden fertilizers)
• Heavy metals (corrosion)
• Other toxics (cleaning agents, past use PCB,
  Chlordane carried to the rivers via ground
  water)
• Deposition from air
• Main cause rise in impervious areas increasing
  storm water volume being discharged to the rivers

3
Storm Water Pollution in D.C. (continued)
4
Storm Water Pollution in D.C. (continued)
5
Storm Water Pollution in DC(continued)

• Who causes storm water pollution in DC? Every
  one!
• Most Storm Water is collected by the Separate
  Storm Sewer System and discharged directly to the
  rivers
• Two third of the city is served by the Municipal
  Separate Storm Sewer System (MS4) one third is
  served by combined sewer system (CSS)
• Some storm water enters the rivers directly by
  flowing over-land
• DC Agencies having impact on storm water
  pollution control WASA, DOH, DPW, DOT, PR, OP,
  DCRA, DHCD, OE, ( other?)
• Under the Federal Clean Water Act, USEPA is
  regulating pollution due to Municipal Separate
  Storm Sewer System (MS4) via the NPDES permit
  system

6
NPDES Permit D.C. Law

• US EPA Region III issued MS4 NPDES Permit to the
  District of Columbia Government on April 19, 2000
• The City Council enacted D.C. Law 13-311 Storm
  Water Permit Compliance Amendment Act of 2000 on
  January 22, 2001

7
Provisions of DC Law 13-311

• Enabled D.C. Water and Sewer Authority (WASA) to
  engage in MS4 Permit Compliance Activity
• Identified DOH, DPW, and DOT (added in 2002)
  along with WASA as responsible Agencies
• Created the Storm Water Administration within
  D.C. WASA, designated as the Lead Agency
• Created the Storm Water Advisory Panel consisting
  of the Mayor, Heads of the responsible Agencies
  DC OCFO
• Authorizes Administrator to ensure Agency Budgets
  are adequate to comply with the requirements of
  the Permit
• Requires the Panel to provide Agency Compliance
  Plan the Semi Annual Report to the Mayor

8
Provisions of DC Law 13-311(continued)

• Established the Storm Water Permit Compliance
  Enterprise Fund
• Section 206b.(a) of DC Law 13-311
• Restricted use of the funds to costs of
  complying with the Storm Water Permit
• Prevented use of the funds for costs
  associated with storm water activities carried
  out prior to April 20, 2000, except to the extent
  those costs increased in order to comply with the
  terms of the permit. Sec. 206b(a)
• Allowed use of the Funds by any D.C. agency that
  has activities required to comply with the permit

9
MS4 Enterprise Fund

• D.C. law 13-311 established the following Storm
  Water Fee structure
• Single-Family 7 per year
• Multi-Family 1.4 of water bill
• All other properties 2.0 of water bill
• Federal Agencies fall under All other
  properties
• Billing started in July, 2001

10
MS4 Enterprise FundFinancial Status

• Revenue started in late 2001
• Total revenue through FY 2003
• 6.4 million
• Total expenditure through FY 2003 2.8 million
• FY 2004 budget
• Personnel 798,801
• Non Personnel 2,939,158
• Total 3,737,959

11
Storm Water AdministrationProgram Activities
Summary

• The Inter-Agency Task Force was created to
  undertake needed activities to comply with DC law
  13-311 the MS4 NPDES permit operates under a
  memorandum of understanding that sets tasks
  budget for each agency meets every month.
• Program is in compliance with all the
  requirements of D.C. Law 13-311 and the MS4
  NPDES permit
• A new DRAFT Permit has been issued on November
  14, 2003 for public comment
• DRAFT Permit is satisfactory to the District
  Revenue should be adequate will depend on the
  Final Permit requirements
• Environmental groups have commented asking for
  more restrictive requirements
• If accepted by EPA, there will be need for
  additional funds and efforts by the Agencies

12
Storm Water AdministrationProgram Accomplishment
Examples

• DC WASA
• Established Storm Water Administration
• Collects storm water user fee and administers
  Enterprise Fund
• Operates floatable trash collection boat on
  Anacostia and Potomac
• Cleans catch basins on annual schedule

13
Storm Water AdministrationProgram Accomplishment
Examples

• DC DOH
• Established MS4 monitoring program
• Greatly improved sediment and erosion control at
  construction sites
• Continued inspection and elimination of illicit
  connections
• Negotiating MOU with US Arboretum for
  installation of pollution control facility on
  Hickey Run
• Expanded enforcement

14
Storm Water AdministrationProgram Accomplishment
Examples

• DC DPW
• Improved coordination of street sweeping and
  catch basin cleaning
• Established semi-annual household hazardous waste
  collection
• Developing public education program to highlight
  storm water benefits of DPW activities
• Expanded street cleaning and litter control
  program (purchased 3 litter-vacs and 500
  additional litter cans)

15
Storm Water AdministrationProgram Accomplishment
Examples

• DC DDOT
• Improved sediment and erosion control at street
  construction projects
• Completed Low Impact Development (LID) pilot
  project along 8th Street SE
• Initiating monitoring program to document storm
  water benefits of LID
• Developing improved catch basin design
• Funded CNG Buses through WMATA

16
Storm Water Administration Program Plan for FY
2004

• Ensure compliance with the MS4 NPDES permit
• Monitoring of storm water to better identify
  extent and nature of storm water pollution
• Identify all DC owned storm water outfalls and
  create data base to better plan needed control
• Document storm water pollution control activities
  by DC Agencies not under MS4 Permit
• Improve Public Education to reduce storm water
  pollution
• Continue storm water pollution control activities
  by District Agencies
• Fund Additional Storm Water Pollution Control
  Projects by various District Agencies

17
MS4 Management Issues

• Excessive paper work Permit and DC Law require
  documenting reporting
• Completing DMRs by hand is inefficient
• Storm water pollution control activities outside
  the MS4 program are not credited
• Clean Water Act 319 funds are not eligible for
  storm water pollution control under MS4 program
• Limitations of storm water pollution control in
  highly urbanized areas need to recognize
  limitations of control measures and require
  flexibility
• Threat of numerical limits on storm water
  discharge
• Incorporation of TMDL requirements in MS4 Permit
  there is no daily load from storm water discharge
• Include LID technology in the MS4 NPDES?

18
Questions?

• Contact Mohsin Siddique
• Phone [phone]
• Fasx [phone]
• Email msiddique_at_dcwasa.com