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September Meeting Reports
Posted on Sep 21st, 2012

There were four presentation given that focused on Houston and Harris County illicit discharges into their Municipal Separate Stormwater Sewers (MS4s). See EPA MS4 guidance below. One was a research project presented by Steve Hupp, Water Quality Director for the Bayou Preservation Association. As a note I worked with Steve several years ago at Harris County Pollution Control.  

The purpose of Steve's study (by Exxon Chemical Interns) was to identify water body segments with excessive E.coli contamination, identify potential point source and non-point sources into the segments, and report any illicit discharges to the appropriate agencies (Harris County, City of Houston, TCEQ).  The study focused on segments around Harris County and the City of Houston.  The San Bernard River watershed was not included in this study. Segments of interest were within Cypress Creek, Dry Gully, Faulkey Gully, Hunting Bayou and Schramm Gully.  Potential pollutant sources of interest were equestrian land use, sewage treatment and collection systems, urban runoff and wildlife.  The study also included rainfall effects and turbidity on bacteria.   Details of the research project are included in Steve's presentation.  The HGAC link to Steve's and the other presentations is cited below.

The other three presentations were given by the City of Houston and Harris County.  Guymeth Williams, Environmental Investigator IV for the City of Houston's Stormwater Quality and Enforcement presentation was on identifying illicit discharges into stromwater systems.  Guymeth provided applicable environmental laws and City ordinances against unauthorized discharges into stormwater  systems. She also provided illicit discharge examples and COH findings from illicit discharges into stormwater systems.

The Harris County presentations focused on Civil and Criminal laws. Roger Haseman, Harris County Assistant District Attorney gave a great presentation on State of Texas water pollution laws (Criminal) and punishment for breaking those laws.  All of us should be familiar with these laws. Rock Owens,  Manager, Environment & Infrastructure Practice Group for Harris County also gave a good presentation on civil consequences of illicit discharges.  Rock provided applicable state laws and Harris County regulations regarding unauthorized discharges and MS4 regulations.   
I recommend that anyone having interest in stromwater regulations review all the presentations.

The September 13 presentations are available under "past presentations" tab located on the left side of the HGAC website www.h-gac.com/cwi .  The next workshop is scheduled to be held on November 14 from 8am to 12 noon, and the topic will be welcome to the Municipal Separate Storm Sewer Systems (MS4s). Registration will begin in October.

Also below is some basic information from the EPA MS4s website http://cfpub.epa.gov/npdes//munic.cfm Stormwater Discharges From Municipal Separate Storm Sewer Systems (MS4s) stormwater

Polluted stormwater runoff is commonly transported through Municipal Separate Storm Sewer Systems (MS4s), from which it is often discharged untreated into local waterbodies. To prevent harmful pollutants from being washed or dumped into an MS4, operators must obtain a NPDES permit and develop a stormwater management program.
· Phase I, issued in 1990, requires medium and large cities or certain counties with populations of 100,000 or more to obtain NPDES permit coverage for their stormwater discharges.
· Phase II, issued in 1999, requires regulated small MS4s in urbanized areas, as well as small MS4s outside the urbanized areas that are designated by the permitting authority, to obtain NPDES permit coverage for their stormwater discharges.
Generally, Phase I MS4s are covered by individual permits and Phase II MS4s are covered by a general permit. Each regulated MS4 is required to develop and implement a stormwater management program (SWMP) to reduce the contamination of stormwater runoff and prohibit illicit discharges.

An MS4 is a conveyance or system of conveyances that is:
· Owned by a state, city, town, village, or other public entity that discharges to waters of the U.S.;
· Designed or used to collect or convey stormwater (including storm drains, pipes, ditches, etc.);
· Not a combined sewer; and
· Not part of a Publicly Owned Treatment Works (sewage treatment plant).
Submitted by Al Roco
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