SWPPP Compliance Rules Vary Depending on Your Location in Houston
LOCATION! LOCATION! LOCATION! Here are some facts about Municipal Separate Storm Sewer System Operators (MS4) to keep in mind for a compliant start-up.
The Facts
The MS4 is the local “enforcement” authority for stormwater regulations. The MS4 regulates discharges to the conveyances, enforces the TPDES General Permit and monitors pollutant levels within their jurisdiction.
Under new Phase II Permits, there are now +/- 50 MS4 Operators in the Houston Area. These jurisdictional boundaries mean your responsibilities may change depending on the location of your job site.
The minimum standard is the TPDES General Permit, but the local MS4 can upgrade any requirements. Meaning, with Phase II permitting regulations, each MS4 is required to implement at least the minimum standard promulgated under the Texas General Permit, but can choose to raise the bar.
Example- Cities of Baytown, Deer Park and Sugar Land require copies of the complete SWPPP narrative, prior to any disturbance.
There are multiple, overlapping enforcement jurisdictions creating multiple interpretations and enforcement nuances.
Notification to the MS4 operator must be made before construction begins, and upon final stabilization (and during construction if certain changes occur in ownership or operation of the project).
REQUIRED for the New Small MS4 General Permit
From the TCEQ: All regulated entities (new and existing) will have 180 days to apply for coverage or a waiver under the general permit, the deadline to apply is June 11, 2014. Each regulated entity must submit a Notice of Intent (NOI) and a new or revised (for existing regulated entities) Stormwater Management Program (SWMP) or a waiver if applicable.
We know the boundaries and regulations of each MS4 entity and we are here to assist you. Our Compliance Assurance Plan has you covered from start-up and filing of the Notice of Intent (NOI) through final stabilization of the site and filing of the Notice of Termination (NOT).
