[Minor revision; updated reviewer title only–posted 9/21/21 (replaces 5/25/17 edition)]
Operating Policy and Procedure
OP 60.07: Storm Water Compliance Program
DATE: September 21, 2021
PURPOSE: The purpose of this Operating Policy/Procedure (OP) is to ensure that Texas Tech University is in compliance with the Clean Water Act (CWA) requirements of the U.S. Environmental Protection Agency (EPA) and the Texas Pollution Discharge Elimination System (TPDES) requirements of the Texas Commission on Environmental Quality (TCEQ). University properties located in the city of Lubbock must comply with the EPA & TPDES Municipal Separate Storm Sewer System (MS4) permit issued to the city of Lubbock, in which the university is named as a co-permittee. University facilities in other locations must meet the requirements of the permit issued in those areas, as applicable.
REVIEW: This OP will be reviewed in September of every third year by the Assistant Vice President for Environmental Health & Safety (EH&S) with substantive revisions forwarded through the Associate Vice President for Research (Research/Integrity) to the Vice President for Research & Innovation.
Texas Tech University has the authority and responsibility for designing, implementing, monitoring, maintaining, and revising the Storm Water Management Plan (SWMP) controls where conveyances are wholly within university property boundaries. Section 109.54 of the Texas Education Code establishes the legal authority for Texas Tech University to control discharges to and from those portions of the Municipal Separate Storm Sewer System (MS4) over which it has jurisdiction. The statute confers on the Texas Tech University System Board of Regents the management and control of lands within the Texas Tech University System.
Texas Tech University EH&S is responsible for monitoring for compliance with and providing guidance on the SWMP. The SWMP will be implemented in accordance with § 402 (p)(3)(B) of the CWA, the Storm Water Regulations (40 CFR 122.26) of the EPA, and the Texas Water Code, Chapter 26, to (1) effectively prohibit the discharge of non-storm water into the municipal separate storm sewer system; and (2) to reduce the discharge of pollutants from the MS4 to the maximum extent practicable.
3. Program Requirements
a. Structural Controls and Storm Water Collection System Operation
The MS4 and any storm water structural controls shall be operated in a manner to reduce the discharge of pollutants to the maximum extent practicable.
b. Areas of New Development and Significant Re-development
A comprehensive master planning process has been developed by the city of Lubbock. The Master Drainage Plan and Drainage Design Manual establish basic hydrologic and hydraulic criteria necessary for minimization of flooding problems associated with new development. The university will develop and implement necessary controls to meet the criteria of the master plan. The goals of such controls shall be:
(1) New development: limiting increases in the discharge of pollutants in storm water as a result of development. It is the intent that infiltration will be considered to the maximum extent practical to sufficiently reduce the amount of runoff from any new development.
(2) Re-development: reducing the discharge of pollutants in storm water; furthermore, effectively reducing the total overall increase of storm water discharging into the MS4
Public streets, roads, and highways shall be operated and maintained in a manner to minimize discharge of pollutants, including those pollutants related to de-icing or sanding activities. In addition, all organic matter (e.g., leaf litter, grass clippings, mulching, excessive plant material) shall be effectively removed or prevented from becoming a potential pollutant.
d. Flood Control Projects
Impacts on receiving water quality shall be assessed for all flood management projects. The feasibility of retrofitting existing structural flood control devices to provide additional pollutant removal from storm water shall be evaluated.
e. Pesticide, Herbicide, and Fertilizer Application
Texas Tech University shall implement controls to reduce the discharge of pollutants related to the storage and application of pesticides, herbicides, and fertilizers applied by employees of Grounds Maintenance and contractors employed by the university.
f. Illicit Discharges and Improper Disposal
Non-storm water discharges to the MS4 are prohibited.
(1) Infiltration of seepage from sanitary sewers into the storm sewer system will be controlled.
(2) Every effort will be made to reduce the amount of floatables (e.g., litter and other human-generated solid refuse) from entering the storm sewer system. The collection of solid waste refuse by the university departments shall effectively reduce the introduction of liquids and solid waste from the MS4 by providing effective controls on university equipment.
(3) The discharge or disposal of used motor vehicle fluids and household hazardous wastes and the disposal of grass clippings, leaf litter, and animal wastes into the storm sewers are prohibited. EH&S has in place a hazardous waste collection system for the proper disposal of such hazardous materials (e.g., used motor oil, anti-freeze, paint, solvents, pesticides, herbicides, spent chemicals, bio-hazardous material, and radiological wastes).
(4) Power washing operations must prevent process wastewater discharges from entering a storm sewer system or into a university/city street that drains to a storm water inlet. Examples of compliance to prevent discharges to the storm sewer system include vacuuming up the process wastewater or berming the process water and allowing it to evaporate. An additional method of compliance is to discharge the water to the city of Lubbock sanitary sewer system (the city of Lubbock may have additional pre-treatment requirements before accepting the discharge).
The EPA recommends that companies or individuals take their vehicles to car washes. All properly operated car washes pre-treat discharges prior to releasing the wash water to a municipal sanitary sewer system. The public-owned treatment works operated by the municipality treats wastewater before discharging to waters of the United States. Most municipalities have a pre-treatment program requiring car washes to perform some type of pre-treatment such as discharging through a sand filter and grease trap. If a car wash is not available, NPDES permit requirements may be avoided and impacts on waters of the United States minimized if vehicles are washed in a vegetated or grassy area. This allows wash water to be absorbed into the ground instead of into a storm water conveyance. However, there may be additional requirements if chemicals (detergents, waxes, etc.) are improperly used or if the absorbed water will reach a surface or underground water body. University vehicles can be washed at the Physical Plant wash bay, which is located at the Transportation Garage. Call 742.3332 for vehicle washing service provided by Physical Plant. EH&S will conduct monitoring for compliance with storm water, power washing, and mobile car washing procedures.
(5) Construction site runoff must be controlled. The following actions, at a minimum, are required to ensure this control:
(a) The use and maintenance of appropriate structural and non-structural control measures to reduce pollutants discharged to the MS4 from construction sites;
(b) Inspection of construction sites and enforcement of control measures;
(c) Appropriate education and training measures for construction site operators; and
(d) Compliance with TPDES Construction General Permit, permit number TXR150000.
g. All interpretations regarding application of the storm water permit criteria and acceptable practices for meeting them will be made by Environmental Health & Safety.
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