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EBC RI Chapter Program

Critical Importance of Stormwater


Management in Rhode Island

Environmental Business Council of New England


Energy Environment Economy

Welcome
Bob Atwood
Chair, EBC Rhode Island Chapter
President
Resource Control Associates, Inc.

Environmental Business Council of New England


Energy Environment Economy

Introduction
Robert M. Otoski
Program Co-Chair
Senior Project Manager
CDM Smith

Environmental Business Council of New England


Energy Environment Economy

State of RI Waters: Water Quality


Sampling Results for Narragansett Bay

Pamela Reitsma
Environmental Scientist

Christine Comeau
Environmental Scientist
Narragansett Bay Commission
Environmental Business Council of New England
Energy Environment Economy

Pamela Reitsma & Christine Comeau


Environmental Scientists
Narragansett Bay Commission

Narragansett Bay Commission

Narragansett Bay Commission


(NBC) is a quasi-state agency
which oversees the two largest
WWTFs in Rhode Island:

Bucklin Point in East Providence


Fields Point in Providence

Service area: 10 municipalities

360,000 people served


including 8,000 commercial
and industrial customers

NBC Stormwater Mitigation Program


NBC formalized their Stormwater
Mitigation Program in 2003
Prohibits the discharge of stormwater to
NBC system, unless it's the only
reasonable means available

Most
desired

(See NBC Rules & Regulations Article 4.4)

Requires commercial/industrial owners


& builders to evaluate stormwater
Stormwater Mitigation Plan is
mandatory to obtain Stormwater &
Sewer Connection Permits

Least
desired

NBC Stormwater Mitigation Program


Stormwater Mitigation Plan
Requirements:

Determine how much stormwater

is generated onsite
Investigate measures to eliminate
or reduce stormwater flows
Examine on-site flow infiltration,
retention & reuse options
Explore Low Impact Design (LID)
methods
Institute Best Management
Practices (BMPs)
Consider options to redirect
stormwater to storm system or
natural waterways if LID options
not possible

NBC Stormwater Mitigation Program


128 Stormwater

Stormwater Flows Abated


Gallons of Stormwater Mitigated

Management Plans
approved since 2003
2 year storm: 15,251,674
Gallons removed from the
combined system
3 month storm event
(basis for NBC CSO Project):
7,621,646 Gallons abated
from the combined
system
Program Eliminated the
Equivalent to ~10% of
CSO Tunnel Capacity
from Fields Point
collection system
For permit applications visit:

Permitted Year
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
Total Stormwater Projects &
Stormwater Flow Mitigated

Approved
3 Month Storm
Stormwater
Event
Projects
(1.65 inches)

2 Year Storm
Event
(3.3 inches)

8
11
10
9
16
13
9
10
6
13
8
5
10

415,900
647,154
1,062,576
517,375
1,089,332
790,865
486,852
258,719
489,519
772,336
159,149
182,047
749,822

839,800
1,294,318
2,126,351
1,034,750
2,177,905
1,580,989
973,847
517,438
979,038
1,544,672
318,828
364,094
1,499,644

128

7,621,646

15,251,674

(updated through October 2015)

http://www.narrabay.com/ProgramsAndProjects/NBC%20Sewer%20Connection%20Permit%20Program%20Overview.aspx

NBC Stormwater Mitigation Program


Award winning program -

regionally & nationally


recognized for excellence
Annually recognizes local
businesses NBC
Environmental Merit Award
for Stormwater Management
River clean-up program &
grants

CSO Abatement Program:


3 Phases - ~$1.2 Billion
Three Phases over 20 years
Design storm: 3-month - 1.6 of rain in 6 hrs

PHASE I (2001 Nov 2008)


26 ft diameter deep rock tunnel
3+ mile long, 300 ft. below ground
62 MG design capacity (actual ~65 MG)
7 drop shafts to divert flow to tunnel
Diversion structures at 8 CSOs
Relief structures at 2 interceptors

Collects sewer/stormwater from 12

CSOs in FP area
Actual Cost: ~$359 million

Phase II of CSO Abatement


Focused to improve water quality of Urban Rivers
Woonasquatucket & Seekonk interceptors

constructed to transport flow to the CSO tunnel


Two sewer separations

Construct new storm sewers via conventional


open-cut trenching methods
Extensive utility impacts

$3.6 million for gas main replacement


$4.25 million for water main replacement

Constructed wetlands facility in Central Falls

0.32 MG of storage
Pumped to sanitary sewer after rain event
Overflows to wetlands when tanks are full

Flows intercepted end of 2014


Whole project completed 2015
Projected costs: $213 million

Phase III of CSO Abatement


1998 Conceptual Design Report Amendment included:
Pawtucket Tunnel-13,000 feet long, 26 feet diameter
3 Near surface interceptors in Central Falls & Pawtucket
Sewer separation at 4 CSOs

2014 review of 1998 plan, affordability & water quality

conditions
1998 plan was best approach, but needed to lengthen
the schedule to be financially sustainable
2016-2023: CSO Tunnel, drop shafts & pump station, GI study
2024-2028: Pawtucket & Central Falls interceptors, GI creation
2029-2033: CSO Adit/CSO Storage Tank, GI installation
2034-2038: Interceptor for 2 CSOs, GI construction & sewer sep.

Estimated cost:

$815 million

Final report to RIDEM on June, 2015

CSO Abatement Tunnel: Phase I


Expected benefits:
Reduce annual CSO volume by 39%
Reduce fecal coliform bacteria

load by 40%
Reduce TSS by 30%
Reduce BOD by 31%
Reduce the acre-days of shellfish
closure in northern half of Upper
Narragansett Bay by 47% and 77% in
southern half
Combined system with the 65 million gallon CSO Tunnel, which captures & stores
stormwater until it can be treated at the WWTF.

Pollutants Removed Due To Tunnel


Tunnel captured 6.6 billion

gallons of CSO flow over past


6+ years (through 10/29/15)
Flow is pumped to FP WWTF &
receives full secondary & tertiary
treatment
~1.1 billion gallons/yr captured
50% of the CSO volume captured and

treated annually (based on design model)


50% Bacteria Load Reduction!!!

Millions of pounds of pollutants

prevented from being discharged


>2.5 Million Pounds TSS
>1.6 Million Pounds BOD
~260,000 Pounds Nitrogen
>83,000 Pounds of Metals

Contaminant

Total Volume
Captured in Tunnel
Total Suspended
Solids
Biochemical
Oxygen Demand
Total Nitrogen
Cyanide
Aluminum
Cadmium
Chromium
Copper
Iron
Lead
Nickel
Silver
Zinc

Average
Concentration CSO
Tunnel Effluent

Total Pounds Removed


by Capture in Tunnel &
Treatment at Field's Point

6,634,000,000 gallons
52.18

mg/L

2,580,929

32.15

mg/L

1,654,025

8.50
6.29
240
1.27
5.67
11.52
1,432
9.38
17.48
2.02
31

mg/L
g/L
g/L
g/L
g/L
g/L
g/L
g/L
g/L
g/L
g/L

260,722
268
12,566
66
272
535
67,632
471
298
107
1,281

Upper Bay Bacteria Monitoring


20 monitoring stations in Seekonk &

Providence Rivers
Twice a month throughout year for fecal
coliform bacteria
Pre-Phase I (2004 Oct 2008)
Post-Phase I (Nov 2008 2014)
Extra sampling conducted during March
2010 storms were excluded from analysis
(April 1 9, 2010)
Wet day rainfall 3 days prior >0.1 inches
Dry day - rainfall 3 days prior <0.1 inches
Water Quality Determination
May October
Geomean < 50 MPN/100 mL

Not more than 10% samples

> 400 MPN/100 mL

Upper Bay Bacteria Data Analysis


Providence River All Weather

51%

42%

26%
52%**

Upper Bay Bacteria Data Analysis


Providence River Wet Weather
43%

33%

66%
25%

(Rainfall totals over 3 prior days)

Upper Bay Bacteria Data Analysis


Meeting Water Quality Standards?
Providence River Post Phase I
Upper Providence River did not

meet WQ Standards
Mid Providence River:
Met more frequently after Phase I
2014: ALL stations met for first time!

Lower Providence River:


Met both criteria most years, improved
post Phase I
65% of years met pre Phase I
87% of years met post Phase I

Has Phase I Improved Upper Bay Shellfisheries?


Regulations changed in 2011:
Cond. Area A closed with 0.8 inches of rainfall
Cond. Area B closed with 1.5 inches of rainfall

RIDEM attributes closure changes to

success of Phase I CSO Project


36% increase in number of acre-days
Conditional Areas were open in 2013
compared to 2004 (Watershed Counts 2014)
This is important because, in 2012.
45% of the quahog harvest came from

Areas A & B (54% in 2014!)


Totaling 17.5 million clams
Equaling $2.48 million (Data from J. Mercer, RIDEM)

DEM reevaluating the criteria now that

Phase II is complete

Urban River Bacteria Sampling


Required by DEM RIPDES Permits

(CSO 9 Minimum Controls Program)


Data collected weekly Monday & Tuesday
(Thursday if results elevated)
Monitor Up/Downstream of CSOs
1 station on Pawtuxet River as baseline

Includes data from 2004 2014


Pre-Phase I (2004 Oct 2008)
Post-Phase I (Nov 2008 2014)
Wet day rainfall 3 days prior >0.1 inches
Dry day rainfall 3 days prior <0.1 inches
Water Quality Determination
May October
Geomean < 200 MPN/100 mL
Not more than 10% samples > 400 MPN/100 mL

Urban River Bacteria Data Analysis


Wet Weather Results Pre vs Post Phase I Tunnel
16%
6%

1%

16%

10%

23%

24%

36%
42%
7%

23%

18%

Urban River Bacteria Data Analysis


Wet Weather Results Pre vs Post Phase I Tunnel

42%

53%

5%

56%

Urban River Bacteria Data Analysis


Wet Weather Results Pre vs Post Phase I Tunnel

Moshassuck River mouth

16%

Woonasquatucket River mouth


Providence River headwaters

18%
22%

Monitoring Stations Upstream of NBC CSOs

56%
29%

24%

7%

53%

NBC monitors stations upstream of CSOs


Also samples Pawtuxet River (no CSOs on this river)
NBC Data shows frequent water quality

violations at all stations

Urban River Bacteria Data Analysis


Meeting Water Quality Standards?
No stations met water quality criteria in all

weather conditions (Wet and Dry)


Some stations met criteria using only dry
weather results, but only in some years
Woonasquatucket River station met standards

upstream of CSOs in 2008 & 2014


Blackstone River station met upstream of CSOs
in all years but 2004, 2011 & 2012
Blackstone River station met downstream of
CSOs in 2012 & 2014
Pawtuxet River station met in 2008 & 2009

Stations unaffected by CSOs are not always

meeting criteriaother pollution sources


upstream of CSOs need to be addressed

Stormwater Impairments
Average of Stormwater Samples
India San Souci
Constituent
Units
Point
Dr.
Fecal Coliform
MPN/100 mL >252,654 31,984
Enterococcus
MPN/100 mL >2,420
>2,420
Total Suspended Solids
mg/L
124.00
83.33
Total Nitrogen
mg/L
3.70
<0.54
Total Kjeldahl Nitrogen
mg/L
2.49
<0.54
Nitrite + Nitrate
mg/L
1.21
<0.1
Ammonia
mg/L
1.39
<0.11
Dissolved Aluminum
g/L
63.29
395.3
Dissolved Cadmium
g/L
0.10
0.09
Dissolved Chromium
g/L
3.01
3.05
Dissolved Copper
g/L
55.67
8.68
Dissolved Iron
g/L
182.95
505.17
Dissolved Lead
g/L
31.66
43.07
Dissolved Nickel
g/L
2.08
1.14
Dissolved Silver
g/L
<0.02
<0.02
Dissolved Zinc
g/L
116.93
53.02
Total Aluminum
g/L
1,184
724
Total Arsenic
g/L
1.54
<0.5
Total Cadmium
g/L
0.27
<2.5
Total Chromium
g/L
5.88
<10
Total Copper
g/L
122.36
13.55
Total Iron
g/L
1,828
1,188
Total Lead
g/L
158.12
38.78
Total Nickel
g/L
<10
<10
Total Zinc
g/L
255.68
59.88

India Point Park

Eastern
Outfall

Western
Outfall

Two stormwater outfall sampled


August 22, 2013 0.49 inches
September 30, 2015 2.02 inches (not first flush)

Fecal coliform:
Range: 9,300 to > 24,000,000 MPN/100 mL
Exceeded primary contact criteria

All Enterococci samples: >2,420 MPN/100 mL

Phase I Summary
Phase I CSO Tunnel Project has:
Captured ~1.1 Billion Gallons/Year of CSO flow
Reduced CSO volume and bacteria loads by ~50%
Prevented millions of pounds of pollutants from discharging

to our rivers and Narragansett Bay


Assisted in reducing beach closures
Allowed DEM to relax Shellfishing Closure standards

NBC Received Water Environment Federations

National Water Quality Improvement Award


But, monitoring stations unaffected by CSOs are
not meeting standards
NBC CSO Abatement Program WILL NOT
meet water quality standards:
CSO System will still overflow ~ 4 times per year
Other Sources of Bacterial Pollution Needs to be

addressed

Bucklin Point
Biological Nutrient Removal
Upgrade to meet seasonal

8.5 mg/L TN in 2005/2006 - $8.3M


(out of total $59M plant upgrades)
Upgrade to meet 5 mg/L complete in
2014, permit in effect on
July 15th, 2014

2014 seasonal average = 4.0 mg/L


2015 May September = 4.2 mg/L

Reduced 2,319 lbs TN/day vs. 2003

Nitrogen Upgrade Cost


~$13 Million

Fields Point
Biological Nutrient Removal
Integrated Fixed Film Activated
Sludge (IFAS)
Largest in the world achieving such a
low effluent limit!
Construction completed in 2013
5 mg/L Permit limits in effect on
May 1, 2014
2014 seasonal average = 3.4 mg/L
2015 May September = 4.1 mg/L
Reduced 4,782 lbs TN/day vs. 2003

Nitrogen Upgrade Cost


~$31 million

NBC Nutrient Monitoring


NBC monitoring program one of

the most extensive in the region


Provides data & sound science
needed to address regulatory
mandates, protect ratepayers
Nutrients are monitored in the
upper bay and tributary rivers,
including major rivers at the
state border

River Nutrient
Stations
Measured bi-monthly at

15 sites in RI & MA
Total N loading USGS
river flow data
Rivers with flow data:

Blackstone River
Moshassuck River
Woonasquatucket River
Pawtuxet River
Taunton River
Ten Mile River
Palmer River*

River Nutrients
Nutrient suite analyzed includes:
Nitrite/nitrate (NO2NO3)
Nitrite (NO2)
Total Dissolved Nitrogen (TDN)

Ammonia (NH3)
Orthophosphate
Silicate

Total Suspended Solids (TSS)

Dissolved Inorganic Nitrogen (DIN)


DIN is calculated value
Sum of NO2NO3, NH3

Most biologically available form of N

Annual River DIN Concentrations

* 2015 data until end of September 2015

Total Nitrogen/TDN Loading


from Upper Bay Rivers and
WWTFs
2006-2013 2014 - 2015
Average
Average
Values
Values
Source

Pounds

Pounds

Bucklin Point
Field's Point
Blackstone River
Moshassuck River
Woonasquatucket River
Pawtuxet River
Ten Mile River
East Providence WWTP*
Taunton River
Fall River WWTP*
Other Sources TOTAL**
Total Contribution

1,188
3,986
4,424
175
426
2,247
816
517
2,723
3,227
844
20,573

570
1,138
1,783
111
118
1,189
143
265
1,144
2,980
997
10,438

*Data for East Providence and Fall River is for May - September
**"Other Sources" includes the East Greenwich, Bristol, and Warren WWTP.

Decrease of 49.3% since 2006

Total Nitrogen Loading & Rain

NBC
= 17%

DRY Weather Days


<0.1 inch of rain over prev. 3d

WET Weather Days

2013 2014
Annual Average
Loads
NBC =
24%

NBC Bay Sampling Locations

Since 2007
Nutrients measured bi-monthly
7 stations - Surface & bottom
Collect at various stages of the tidal
cycle throughout the year
Nutrient suite includes:

Nitrite/nitrate
Nitrite
Total Nitrogen
Total Dissolved Nitrogen
Ammonia
Orthophosphate
Silicate
Chlorophyll a
Total Suspended Solids

Determine impact of NBCs BNR

systems & inform stakeholders

Nitrogen TMDL not yet


developed for Narragansett
Bay

2015 Surface DIN


May October 15, 2015
Rainfall Total: 18.58 inches
DIN (mg/L)
Good <0.1
Fair 0.1-0.5
Poor >0.5

DIN
EPA CCR
(mg/L) Category

Station

Phillipsdale Landing 0.55


India Point Park
Edgewood Yacht
Club

0.25

Pomham Rocks

0.13

Pawtuxet Cove

0.63

Bullock's Reach

0.07

Conimicut Point

0.06

0.08

Surface DIN & Rainfall


PD Correlation = 0.57
All other sites <0.48

*
*2015 data is from May Oct 15th

Surface DIN & Hypoxia


PD Correlation = 0.64
All other sites <0.43

Hypoxia & Rainfall

Summary
River DIN some decrease depending on river
Moshassuck and Woonasquatucket low concentrations
Blackstone River Stateline decreased since UBWPAD

online
Ten Mile and Pawtuxet high concentrations
Taunton About the same as Blackstone
TDN/TN loading contribution has decreased by about 50%
Contribution of N from Rivers increases in wet weather

Bay DIN - decreasing over time with 3 NBC stations now

showing average results in the good category

Hypoxia and DIN not correlated


DIN and rainfall not correlated
Hypoxia and rainfall - strong correlation
Rainfall increases point source and non-point source loads
Rainfall contributes to stratification

Any Questions?

Special Thanks to:

Tom Uva, John Zuba, John Motta, Jim Kelly, Eliza Moore, Steve Lallo, Kimberly
Kirwan & Catherine Oliver
NBC Monitoring, Lab & ESTA Staff

Data and Presentations are available on


NBC Website at
http://snapshot.narrabay.com

Phase II MS4 Permit: RI Municipalities


Permit Compliance & Permit Re-Issuance

Eric Beck
Supervising Engineer

Margarita Chatterton
Senior Sanitary Engineer
RIDEM Office of Water Resources
Environmental Business Council of New England
Energy Environment Economy

November 2015
EBC Presentation

56

Stormwater
Management in
Rhode Island
An Update on Municipal Stormwater
Management Programs
November, 2015

The Critical Importance of


Stormwater Management in RI

Stormwater Runoff from urban land is a significant


source of pollution

Impacts Shellfishing, Swimming, Recreation, Drinking


water supplies

Addressing discharges from municipal drainage systems


is the Law; required by the Clean Water Act, and
Federal and State Regulations

In RI, DEM is the delegated authority, and has


concurrent authority with EPA to enforce the Law.

RIDEM has offered Bond Funds (limited compared to


need), considerable efforts in technical assistance and
training.

Despite all of our best efforts, we will not reach the


goal of addressing the impacts from stormwater until
municipalities develop dedicated and sustainable
funding sources.

Rhode Islands MS4 Program


How well are Rhode Island Municipalities
implementing the 2003 MS4 General
Permit?
What is being done to improve
compliance?

How Does RIs 2003 Permit compare to


EPAs Proposed Permit?
What will Rhode Islands Next Generation
MS4 Permit look like?

How did RI DEM Assess the


Current State?

2009 Audit and ongoing


Compliance Assurance

Selection of Key Performance


Indicators (KPIs) and Review of
2014 Annual Reports

Evaluation of EPAs proposed MS4


Permit

RI DEM Audit: Years 1-4


Reviewed

Annual Reports Years 1-4

Assessed

only Required
Measurable Goals (e.g. map of outfalls,
ordinances adopted, structures maintained, streets swept,
plans reviewed, sites inspected, illicit discharges
identified/eliminated)

Notified

MS4s of deficiencies

Required

a response to the Audit


with Year 5 Annual Reports

Review of Audit Responses &


subsequent Annual Reports

70%

Did not meet all Required `

Measurable Goals

Six(6) MS4s met all Required Measurable Goals

Six (6) had minor deficiencies

Sixteen (16) had numerous deficiencies but not defined as


Significant

Eleven (11) had Significant Non-Compliance

Current State
10% in Significant Non-compliance

RI DEM reviewed MS4 responses, met with MS4 staff, reviewed


subsequent Annual Reports (Years 6-11)

RI DEM focuses on 4 MS4s that continue to have Significant


Non-Compliance

In addition, RI DEM issued two (2) Notices of Violation and


currently has one (1) consent agreement and is enforcing one
(1) order.

2015 EPA signs Consent Decree with RIDOT

RI DEM
participates in the three year EPA Audit Process and fourteen month
settlement discussions

Annual Reports Summary


2014 Annual Report Review
Rhode Island Municipal and Non-Traditional MS4s

November 2015

Annual Report Submissions


See RI DEMs Website for Full Report
http://www.dem.ri.gov/programs/benviron/water/permits/ripdes/stwater/pdfs/ms4ann15.pdf

Out of 41 MS4s, including non-traditional

RI MS4 Annual Report Review Summary


Select Measurable Goal

% Achieved

Annual Report Submission (Yr 11 - 2014)

68%

IDDE Outfall Mapping

88%

IDDE CB and MH Inspection for Illicit Connections

78%

IDDE Two Dry Weather Surveys of Outfalls

71%

IDDE Adopt Ordinance

76%

Construction Adopt Ordinance (ESC)

76%

Construction Annual Plan and SWPPP/SESC Plan Reviews

85%

Construction Annual Site Inspections

85%

Post-Con Adopt Ordinance

79%

Post-Con Annual Plan and SWPPP/SESC Plan Reviews

71%

Post-Con Annual Inspections for BMP Installation

76%

PP&GH Locate and List MS4-owned Structural BMPs

95%

PP&GH Annual CB Inspection and Cleaning

49%

PP&GH Annual Street Sweeping

90%

TMDL Implementation Plans (not including TMDLs approved since 2010)

67%

Conclusions

The majority of Rhode Islands MS4s have adopted the ordinances


necessary to implement the MS4 program in their community.

Areas that could use the most improvement are:

Annual catch basin inspection and cleaning

TMDL Implementation Plans

Dry Weather Surveys of Outfalls

Post-construction Plan and SWPPP reviews

A comparison of KPIs from 2010 and 2014 indicated that


compliance rates for actions that require an annual commitment
such as catch basin cleaning were declining, indicating the
effects of the economy on municipal budgeting.

Despite all of our best efforts, we will not reach the goal of
addressing the impacts from stormwater until municipalities
develop dedicated and sustainable funding sources.

RIPDES Phase II Small MS4


Permit Re-Issuance
November, 2015

RIDEM MS4 General Permit


Re-Issuance Process
Identify reporting deficiencies and Key Performance
Measures(KPIs) 2015.
Identify RIDEMs and MS4s constraints and
challenges and countermeasures to these
challenges 2015.
Identify major areas of EPAs expansion of
requirements 2015.

Internal discussion on options to EPAs model


requirements.

External workshops for presentation and discussion


of permit requirements.

Public Notice of Draft MS4 Permit.

Significant Differences between EPA 2014


Draft Permit and RIDEM 2003 Permit
Illicit Discharges Detection and Elimination
Mapping of entire system, catchment delineations, use of
thresholds to support decision making, and follow-up
confirmatory sampling, deadlines

Post-construction redevelopment and new


development
Estimate acres of impervious area and Directly Connected
Impervious Area (DCIA), track changes in DCIA. Assess MS4
owned properties for retrofitting
Assess local regulations to determine feasibility of use of LID
and green infrastructure

Impaired Waters
Detailed provisions provided for stormwater discharges for
discharges to: TMDL In State, TMDL Out of State and In State
impaired non-TMDL. Concentrated effort on nutrient impaired
waters
Provided schedule of compliance with measurable goals

IDDE Challenges:

Mapping of entire system,

Catchment delineations and ranking,

Deadlines to complete investigations

Deadlines for removing sources.

Focus will be on completing in-system


investigations.

Post-construction Challenges:
Permitting redevelopment and
new development
Tracking impervious area
Tracking BMPs
Assessing local regulations to
determine feasibility of use of
LID and green infrastructure

Impaired Waters Challenges

Tailored provisions provided for


stormwater discharges
Requirement to construct BMPs
Concentrated effort on nutrient
impaired waters
Provided schedule of compliance
with measurable goals

Next Steps
Assess if EPAs model is the best model for Rhode Island
communities RI MS4s are starting from a different point

Internal discussion on options to EPAs model


requirements, addressing internal weaknesses and
external threats
Development of new Annual Report Template
Draft General Permit
External Workshops for Annual Report Template and
discussion of new permit requirements
Public Notice of Permit

Feel free to contact us?


contact information 401-222-4700
eric.beck@dem.ri.gov

ext. 7202

margarita.chatterton@dem.ri.gov
jennifer.stout@dem.ri.gov

ext. 7605

ext. 7726

Upcoming Permit Requirements

Thelma Murphy
Regional Stormwater Coordinator
US Environmental Protection Agency
Region 1

Environmental Business Council of New England


Energy Environment Economy

Overview of 2014 Draft MS4 Permits

Thelma Murphy
EPA New England

77
U.S. Environmental Protection Agency

Presentation Overview
Brief MS4 Program Overview
MS4 Permit Requirements
MEP Requirements
Water Quality Based
Impaired Waters Requirements
TMDLs
Next Steps

Questions

Phase I Program
Stormwater management program must
reduce the discharge of pollutants to the
maximum extent practicable (MEP) and
protect water quality
Medium and large municipalities (over
100,000)
Industrial activity
(11 categories)
Construction over
5 acres

Phase II Coverage
1995 Report to Congress, EPA determined
that small municipalities also needed
regulation Regulations passed in 1999
Permitting authorities can also designate
additional small MS4s that are outside of
urbanized areas
Includes non-traditional MS4s within
urbanized areas, such as:
Military bases
Public universities
Prisons, etc.

First Massachusetts Phase II


Permit: 2003

MEP Requirements

U.S. Environmental Protection Agency

81

Six Minimum Measures


1.
2.
3.
4.
5.
6.

Public education
Public involvement
Illicit discharge detection & elimination
Construction runoff
Post-construction stormwater management
Pollution Prevention

Shared Responsibility
The regulations, 40 CFR 122.35, allow
for MS4s to share responsibility for
the implementation of the six
minimum measures

Public Education and Outreach


Four Audiences

Residents
Businesses and commercial facilities
Developers
Industrial Facilities

Two messages to each audience over the


permit term

Public Involvement and


Participation
Public review of SWMP
Make all reports available to the public

Illicit Discharge Detection and


Elimination (IDDE)
Ordinance
SSO inventory
Identification of responsibility
Outfall inventory and map
Catchment rankings
Detailed written IDDE program
Tracking progress
Screening

Construction Site
Runoff Control

Ordinance
Site Inspection procedures
Sediment control requirements
Requirements to control waste
Site Plan Review

Post-Construction
Stormwater Management

Updated Ordinance
Retain and or treat the
first 1 of runoff from IA
on site from new and
re-development
disturbing 1 acre

Street design
Parking assessment

&

Green infrastructure
Tracking impervious area

Good Housekeeping

O&M procedures
Catch basin cleaning
Street sweeping
SWPPP

Water Quality Requirements

U.S. Environmental Protection Agency

91

Impaired Waters
Stormwater discharges are causing
or contributing to at least 55% of
the impairments in all Massachusetts
assessed waters

Discharges to
Impaired
Waters
Discharges to waters
without a TMDL
Discharges to waters
with an Approved TMDL

Approved TMDLs

Long Island Sound


Nitrogen TMDL
Phosphorus and
Metals TMDLs for
Rhode Island
Waters

Bacteria and Pathogen


TMDLs
Charles River Phosphorus
TMDLs
Lake and Pond
Phosphorus TMDLs
Cape Cod Nitrogen
TMDLs
Assabet River Phosphorus
TMDL

Phosphorus TMDLs

EXCESSIVE
PHOSPHORUS

Reduced clarity
Noxious scums
Toxic blooms
Surface waters choked
with plant matter
Low dissolved oxygen for
aquatic life (e.g., fish)

Urban Stormwater Phosphorus


Tends to be associated with very fine
particles ~ 40 microns
Much is washed from impervious
surfaces with small amounts of rainfall
(e.g., 0.3 inches)

Stormwater controls must have filtration


component to be effective

5 years after 5-10 years


15-20 years
10-15 years
permit
after permit
after permit
after permit
effective
effective
effective
effective date
date
date
date

PCP Phased Approach

Create
Implement
Phase 1 Plan
Phase 1
Plan
Create
Phase 2
Plan

Year 10
25% of
required
TP reduction
met

Implement
Phase 2 Plan
Create Phase Implement
3 Plan
Phase 3
Plan

50% of required
TP reduction
met

100% of required
TP reduction met

Year 15

Year 20

P Reduction Through Enhanced BMPs

Public Education
New Development/
Redevelopment

Good Housekeeping

Additional Requirements
Phosphorus Source Identification Report
Evaluate feasibility for Potential
Structural BMPs
Plan & Install at least one structural BMP
as demo project

Tracking

NSQD urban stormwater


Parameter
Phosphorus Total
(mg/l)
Total Nitrogen
(mg/L)
Fecal Coliform
(colonies/100 ml)
Total E Coli
(colonies/100 ml)
Chloride
(mg/l)
Turbidity
(NTU)
Total Suspended
Solids (mg/l)
Oil and Grease Total
(mg/l)
Zinc Total
(ug/l)

Geometric
Count Median
Mean
Minimum Maximum

25%

75%

1967

0.25

0.26

0.02

10

0.15

0.42

1763

2.0

2.0

1.0

7.0

1.0

3.0

524

4500

3578

2.0

5230000

800

26000

25

1100

1366

10

35000

460

8500

57

6.0

7.0

1.0

350

4.0

10

12

106

98

16

630

43

176

2046

45

46

1.0

2405

22

95

390

5.0

4.8

0.2

570

2.5

8.5

1592

105

89

1.4

3050

50

190

Discharges to Waterbodies
Without an Approved TMDL

Additional requirements for


Bacteria, Nutrients, Solids,
Chloride, Metals and Oil and
Grease

Discharges To Bacteria Impaired


Waters
If discharge contains
illicits remove in 60 days
Additional BMPs
Public Education
IDDE

Discharges To Nutrient
Impaired Waters or their
Tributaries
Public Education

Enhanced
BMPs

New Development/
Redevelopment
Good Housekeeping

Discharges To Chloride Impaired


Waters
Salt Reduction Plan
Track the amount of salt
applied
New or modified equipment
Adopt application rate
guidelines
Training for applicators
Equipment Calibration
No Salt Zones

Discharges To Chloride Impaired


Waters (cont)
Additional BMPs
Mechanism to ensure private industry and
commercial sites cover salt piles
Public Education
New Development and Redevelopment

Discharges To Sediment, Metals or Oil


and Grease Impaired Waters
If discharge contains
illicits remove in 60 days
Additional BMPs
New Development/
Redevelopment
Good Housekeeping

Next Steps - Massachusetts


Comment Period ended 2/27/15
Respond to Comments
Over 160 comment letters (1700 pages)
1400 comments

Final Issuance expected December


2015

Next Steps New Hampshire


Re-notice Comment period closed
11/2/15
Respond to Comments
Final Issuance - 2016

Binoculars Credit: http://www.flickr.com/photos/gcbb/2465054692/


Sidewalk Tree Credit: http://www.flickr.com/photos/madmardign777/79436383/
Letters Credit: http://www.flickr.com/photos/calliope/234447967/
Ruler Credit: http://www.flickr.com/photos/vrillusions/5197046091/
Impaired waters, Algae, Impaired Lakes, Bacteria, Sediment/trash, Salt, LID street images, BMP
near reservoir, Catch Basin - Credit: EPA

Image
Credits
I
Cuyahoga Credit: http://blog.cleveland.com/science_impact
Maple Leaf in Rain Credit: http://www.flickr.com/photos/lanier67/184302007
Elements Cupcakes Credit: http://www.flickr.com/photos/nickbusse/4163894602/
Roseate Turn Credit: http://www.flickr.com/photos/andy_li/4862883387/
Wachusett Reservoir Credit: http://www.coreservs.com/news/wpcontent/uploads/2012/10/015-Wachusett-Reservoir.jpg
Sparrow Dock Credit:
http://www.flickr.com/photos/zim2411/3790850184/in/photostream/

Rowers Credit: MS Office Clip Art


Springfield Credit: commons.wikimedia.org
3 Ring Binder Credit: http://www.flickr.com/photos/jkfid/4333767484/
Long Island Plume - http://www.wnpr.org
Long Island Sound Watershed - USGS
Great Bay - http://www.flickr.com/photos/usfwsnortheast/5198415699/

Boston Credit:
http://cambridge.hyatt.com/content/dam/Multimedia/regency/bosrc/737x415xRiver_vie
w_2_25461_med.jpg.pagespeed.ic.FaXFY22gTt.jpg
All pictograms sourced from EPA HQ

Image Credits II

Questions

Thank you

MS4 Program Contacts:


Newton Tedder
617.918.1038
tedder.newton@epa.gov
Or
Thelma Murphy
617-918-1615
murphy.thelma@epa.gov
Draft Permit Information: http://www3.epa.gov/region1/npdes/stormwater/MS4_MA.html
U.S. Environmental Protection Agency

111

Paying For Stormwater:


Stormwater Utilities in RI

Elizabeth Scott
Deputy Chief
RIDEM Office of Water Resources

Environmental Business Council of New England


Energy Environment Economy

Paying for Stormwater:


Stormwater Utility Development in RI
Presentation to EBC Rhode Island Chapter

November 4, 2015
Elizabeth Scott, Deputy Chief
RI Department of Environmental Management
Office of Water Resources

Poorly managed stormwater creates


real problems for RI communities
Street flooding and property damage
Water Quality Impacts
Closed beaches
Closed shellfishing grounds
Polluted ponds
Sediment filled waterways
Economic Consequences
Public health & safety concerns
Hindrance to economic development
Property values negatively affected

Our current stormwater infrastructure is


no match for the intense periods of rainfall
brought on by climate change.

Managing stormwater is one


of the biggest infrastructure
challenges facing the
stateand it comes at cost.

Funding options for municipal


stormwater programs

Property Taxes > General Revenue


Fee for permit reviews & inspections
Voter approved bond referenda
Federal and/or State Grants
Loans
Create Enterprise Fund or Stormwater Utility

What is a stormwater utility?

A funding method
A program concept
An organizational entity

Preliminary Stormwater Utility


Feasibility Studies
To date, studies completed:

East Providence (2006)


Middletown (2011)
Westerly (2012)
Bristol (2012)
North Providence (2012)
West Warwick (2013)
Upper Narragansett Bay Regional Stormwater Utility
Feasibility Study (7 municipalities & NBC) (2014)
Middletown (2014)

Do Stormwater Utilities Make Sense in


Rhode Island?
Define compelling reasons to create a stormwater utility:

Street Flooding
Water Quality Problems
Undersized and/or deteriorating infrastructure
Compliance with all regulatory requirements

Describe whats currently being done and its costs


Describe priorities for enhancing stormwater management
and costs
Operation & Maintenance
Capital Improvement: Drainage projects, equipment purchases

Evaluate revenue potential via a stormwater utility


Identify any show stoppers

Ongoing Stormwater Utility


Development Efforts
Middletown Stormwater Utility Development
Upper Narragansett Bay Regional Stormwater
Utility Feasibility Study Phase II
Providence, East Providence, Central Falls,
Pawtucket, Warwick, Cranston
North Providence ERU analysis/preliminary
rate analysis
West Warwick Capital Infrastructure planning
and Phase II stormwater utility development
Bristol Stormwater Utility Study with
stakeholder involvement

Overall Approach Coordinated Tracks


Governance
Track

Public
Track

Program
Track

Funding
Track

Data
Track

Entities &
Current
Activities

Public
Involvement &
Education Plan

Problems,
Needs, Issues
& Goals

Basic Funding
Policy & Legal
Issues

Database
Policy Issues

Governance &
Program Roles
& Duties

General Public
Awareness &
Stakeholder
Process

Program
Priorities &
Basic
Objectives

Funding Policy
Development

Data, Materials
& Information
Collection &
Analysis

Budgets &
Revenue
Requirements

Cost of Service
Analysis

Rate Structure
Analysis

Master Account
File & Billing
Data
Development

Local
Approvals &
Interlocal
Agreements

Organization &
Management
Development

Rate Study &


Cash Flow
Analysis

Billing System
Development

Utility
Implementation
Plan

Rate Ordinance
& Policy
Document

Inquiry &
Complaint
Response

Establish Legal
Entity &
Staffing

Implementation
Campaign

Implementation of Stormwater Utility

Benefits of a stormwater
enterprise fund or utility
It is Stable not as vulnerable to the vagaries of
the annual budgetary process as taxes

It is Adequate the fee is based on a well


thought out stormwater program to meet the
needs and demands of the community.
It is Flexible it can adapted to changing
program and funding needs over time.
It is Equitable the cost is borne by the user
on the basis of demand placed on the drainage
system.

Benefits of a stormwater
enterprise fund or utility
Allows municipalities to pro-actively plan
and manage their systems:
Move out of crisis management and
emergency response
Enhanced planning make municipalities more
competitive in securing grants

Re-investment in community contributes to


improved quality of life, enhanced
economic opportunities, and jobs
Attractive to formation of Private/Public
Partnerships

Focus on Green Infrastructure

Multiple benefits improve quality of life


More climate resilient communities

Incentives for property owners to


manage stormwater on-site
Municipalities may offer credits
or other incentives
Creates incentives for property
owners to retrofit sites to
install Green Infrastructure
Drive physical change in how
stormwater is managed on the
ground
Reduces burden on municipally
owned drainage systems

Benefits of Regional Approach


Flooding Problems
consistent flood mitigation across the region
Water Quality Issues
watershed based, multi-jurisdictional problems
Lack of Individual Specialized Resources
difficult for everyone to have an expert
Interconnected Infrastructure
combined sanitary/stormwater, separate
stormwater, RIDOT & NBC systems

Logical Argument in support of


Regional Approach*
1. We have real, growing, shared and unresolved
stormwater problems
2. We can solve these problems and there will be
tangible benefits
3. It will cost more than we are now spending
4. It will be more efficient and effective doing so
together
5. A stormwater user fee is the best and fairest
way to pay for the improvements
*Conclusion of Upper Narragansett Bay Regional Stormwater Utility
Study Phase I

Strategic investments in infrastructure improve water


quality and contribute to a more viable economy

Bristol Town Beach uses infiltrating rain gardens and a gravel wet vegetated treatment
system to filter stormwater before it enters Narragansett Bay, reducing beach closures.

Networking Break

Environmental Business Council of New England


Energy Environment Economy

Coastal Stormwater What Goes Up and


What Comes Down: Sea Level Rise, Storm
Surge and Stormwater Impacts

Janet Freedman
Coastal Geologist
Coastal Resources Management Council

Environmental Business Council of New England


Energy Environment Economy

Coastal Stormwater:
What Goes Up and What Comes Down
Sea Level Rise, Storm Surge
and Stormwater Impacts

EBC Rhode Island Chapter


The Critical Importance of Stormwater Management in Rhode Island
November 4, 2015
Providence, Rhode Island

What do we know?
Increased frequency of extreme
precipitation events
Rising sea levels
Increased frequency of tropical and
extra-tropical storms?

http://nca2014.globalchange.gov/report/our-changing-climate/heavy-downpours-increasing

There
Therehas
hasbeen
beenaashift
shiftininReturn
ReturnFrequency
Frequency
Most significant in the 25 to 100 yr recurrence interval
1 Day Return period

TP-40 from 1961

NRCC Draft 2010


http://www.precip.net

Event in years

Inches in 24 hours

Inches in 24 hours

3.25

3.26

10

4.75

4.86

25

5.50

6.15

50

6.15

7.30

100

7.00

8.70

Arctic Amplification
The Arctic region has warmed more than twice as fast
as the global average
Less temperature difference between arctic and
northern hemisphere mid-latitude regions
Slowing of west to east speed of jet stream
More persistent weather patterns
Increased waviness of jet stream
Larger jet-stream waves (and
associated weather systems)
progress eastward more slowly
Large uncertainties regarding
the magnitude of influence

CU Sea Level Rise Research Group University of Colorado http://sealevel.colorado.edu/

HEIGHT NOW

Rate of Rise 1993-2015


> 4 mm/year

Adapted from:
http://tidesandcurrents.noaa.gov/sltrends/
sltrends_station.shtml?stnid=8452660%20Newport,%20RI

Boothroyd 2013

Why are sea levels rising?


Expansion due to higher ocean
temperatures
Melting of glaciers and
ice sheets
Changes to ocean currents
Less gravitational pull from
ice sheets due to lower
volume/mass

National Snow and Ice Data Center/Thomas Mote, University of Georgia

Greenland
Outlet Glaciers
Changing from Polythermal
to
Warm Based

A Key to Future
Sea-Level Rise

Brathwaite, 2002

US Army Corps of Engineers SLR Curves

2100
2050

http://corpsclimate.us/ccaceslcurves.cfm

Increased Frequency of coastal storms?


Tropical jury still out
Increased water
temperatures lead to
increased intensification
Extra-tropicalincrease in frequency of
high surge heights at the
Newport tide gage
(8452660)

Narragansett Pier, RI Seawall Tropical Storm Irene 2011


Storms are the Driver

Anonymous via N Vinhateiro, 28 aug 2011

oil slick

GRIP - Green and Resilient Infrastructure


Planning
URI Graduate School of Oceanography Coastal
Resources Center/RI Sea Grant
focus on landscape designs to improve coastal
resilience
three pilot communities Newport, North
Kingstown and Warwick
designs include stormwater infrastructure and
alternatives to hardened shorelines

Oakland Beach Charrette

Future efforts
Pawtuxet River watershed modeling
HUD CDGB funding
develop an operational spatially distributed
hydrological/hydraulic model for the watershed and river
map flood extent for historic events and specific return
intervals (e.g., 25-yr, 50-yr, etc.)
will be completed in February 2017
Climate change and the impacts on the Pawtuxet River
watershed
proposal submitted for funding on Oct 23rd to the RI
Research Alliance Collaborative
model changes in precipitation due to climate change
integrate with the ongoing Pawtuxet River modeling
project to assess combined effects of inland and coastal
flood inundation (both SLR and storm inundation)
use the online mapping StormTools interface.
will know status January 2016.

Questions?

Panel Discussion
Moderator: Igor Runge, GZA GeoEnvironmental, Inc.

Panelists:
Pamela Reitsma, Narragansett Bay Commission
Christine Comeau, Narragansett Bay Commission
Eric Beck, RIDEM Office of Water Resources
Thelma Murphy, US EPA - Region 1
Elizabeth Scott, RIDEM Office of Water Resources
Janet Freedman, Coastal Resource Management
Council
Environmental Business Council of New England
Energy Environment Economy

EBC RI Chapter Program


Critical Importance of Stormwater
Management in Rhode Island

Environmental Business Council of New England


Energy Environment Economy