tjfaonline.com · BEFORE THE STATE OFFICE .'. - ,WASTE MANAGEMENT OF TEXAS, § INC. § OF : FOR MUNICIPAL SOLID WASTE § PERMIT AMENDMENT NO. § ADMINISTRATNE HEARINGS : MSW-249D

••

SOAR DOCKET NO. 582-08-2186 TCEQ DOCKET NO. 2006-0612-MSW

APPLICATION OF § BEFORE THE STATE OFFICE .'. - ,WASTE MANAGEMENT OF TEXAS, §

INC. § OF FOR MUNICIPAL SOLID WASTE § PERMIT AMENDMENT NO. § ADMINISTRATNE HEARINGS MSW-249D §

PROTESTANT CITY OF AUSTIN'S INDEX OF TESTIMONY AND EWIB:.r!S

Exhibit GG-l

Exhibit GG-2

Exhibit GG-3

Exhibit JW-l

Exhibit JW-2

Exhibit JW-3

Exhibit JW-4

Exhibit JW-5

Exhibit CL-l

Exhibit CL-2

Exhibit CL-3

Exhibit CL-4

Exhibit CL-5

Exhibit CL-6

Exhibit TF-l

Exhibit TF-2

Exhibit TF-3

.Exhibit TF-4

Exhibit TF-5

Exhibit TF-6

Exhibit TF-7

Exhibit TF-8 •

=c ,~

m -=-1 Il ", C) u:J

Direct testimony of Greg Guernsey ,- rn ::cJ ~,)

C3 -'::1Greg Guernsey's reswne o =::.:

" " i~Area map ofWMI landfill, Harris Branch PUD, and Pi~er .,_ Crossing PUD, created by City; and detailed map of Pioneer Crossing PUD, created by Pioneer Crossing PUD

Direct testimony of Joe Word

Joe Word's resume

City of Austin Resolution No. 20070517-030·

TCEQ Enforcement Action Agreed Order from June 23, 2004

CAPCOq determination of non-conformance

Direct testimony of Chuck Lesniak

Chuck Lesniak's resume

March 2003 Google Earth aerial photos of the North and South slopes of the WMI landfill .

January 6, 2009 pictures of soil stockpile taken by Chuck Lesniak during WMI landfill site visit

Pictures taken by Chuck Lesniak during July 2006 and January 6, 2009 site visits to the WMI landfill.

Picture taken by Chuck Lesniak during the January 6, 2009 site visit of the working face

Direct testimony Of'roDi Franke

Tom Franke's reswne

WMI Erosion and Restoration Site Plan (SP-05-1451D) to construct two ponds at the WMI landfill, approved July 19, 2006 by the City of Austin

Sedimentation and Detention pond analyses

TPDES Multi Sector General Permit

·Cole, William H. and Yonge, David, Sediment and Contaminant Removal by Dual Purpose Detention Basins, Washington State University, May 1993 report

Barrett, Michael E., Malina, Jr., Joseph F., Charbeneau, Randall J., An Evaluation of Geotextiles for Temporary Sediment Control, Vol. 70 Water Environment Research No.3, May/June 1998

U.S. EPA, BMP Modeling Concepts and Simulation, EPN600/R06/033, July 2006

RESPECTFULLY SUBMITTED,

DAVID ALLAN SMITH CITY ATTORNEY

ARHADI Assist City Attorney State Bar No. 24036547 City of Austin Law Department Post Office Box 1546 Austin, Texas 78767-1546 (512) 974-2310 (512) 974-6490 [FAX]

ATIORNEYS FOR CITY OF AUSTIN, TEXAS

2

••

• CERTIFICATE OF SERVICE

I hereby certify that on the ~ay of February, 2009, a true and correct copy of the Protestant City of Austin's Index of Testimon and Exhi . s as served via facsimile, hand-delivery, e-mail, or regular first-c ass ail

Via Hand Delivery Hon. Roy Scudday Administrative Law Judge State Office of Administrative Hearings 300 W. ISth Street, Suite S02 Austin, Texas 78701

Via Hand Delivery For the Chief Clerk: LaDonna Castaiiuela Texas Commission on Environmental Quality

~. Office ofChief Clerk, MC-lOS P.O. Box 13087 Austin, Texas 78711-3087

Via Regular U.S. Mail For the Executive Director: Arnie Dutta Richardson Texas Commission on Environmental Quality MC-17S P. O. Box 13087 Austin; Texas 78711-3087 [email protected]

Via Regular U.S. Mail For the Office of Public Interest Counsel: Christina Mann Office ofPublic Counsel Texas Commission on Environmental Quality MC-103 P. O. Box 13087 Austin, Texas 78711-3087 [email protected]

e ers ns r d below.

("") .:. _3 -..:) 0::c -.•jrn z

,-n ,., me ("") ~ JZO r- :_::;~--i rn

N;;;)} ~~6~~ ............ I -- (J)":';>0? -c:J ::::j o{- (;)tf)

--: ~.;: i~0 -n

~ m:.::: -n ZL c=s ~ -,

>rn .z:: r

3

mailto:[email protected]


••

-. " ;~ .-.

Via Regular U.S. Mail For Travis County: Annalyrm Cox Assistant County Attorney Tr~vis County Attorney's Office P. O. Box' 1748 Austin, Texas 78767 [email protected]

Via Regular U.S. Mail For Giles Holding: Paul M. Terrill The Terrill Finn; P.c. 810 W. 10th St.

. Austin, Texas 78701 pterrill@terrill-Iaw~com

Via Regular U.S. Mail ForTJFA, L.P. Erich M. Birch, Birch Becker & Moorman, LLP 7000 North Mopac Expressway

. Plaza 7000 SecondFloor Austin, Texas 78731 [email protected]?

Via Regular U.S. Mail For Protestants 1: Jim Blackburn Mary W. Carter Blackburn Carter, P.C. 4709 Austin ' . Houston, Texas 77004 [email protected] [email protected]

Via Regular U.S. Mail For the Applicant: Bryan J. Moore Vinson & Elkins, LLP . 2801 Via Fortuna, Suite 100 Austin, Texas 78746-7568 [email protected]

4


••

••

1 Q. Please state your name.

2 A. Greg Guernsey

3 Q. Who is your employer?

4 A. City of Austin.

5 . Q. What department do you work for?

6 A. The Neighborhood Planning and Zoning Department

7 Q. How long have you worked for the City?

8 A. 23 years, 7 months

9 Q. I am handing you what's been marked as Exhibit GG-2. Do you recognize

10 it?

11 A. Yes.

12 Q. What is it?

13 A. My resume.

14 Q. Is the information contained in it true and correct?

15 A. Yes.

16 Q. What are yourjob duties?

17 A. lam the Department director that is responsible for the City's zoning, historic

18 preservation, annexation, neighborhood planning, long range transportation

19 planning, the comprehensive plan, and urban design programs.

20 Q. What type of studies/analysis/review have you done?

21 A. I have reviewed numerous zoning, subdivision and site plan applications for

22

• residential, commercial, industrial and civic land uses. I have also contributed to

23 several neighborhood plans and zoriing studies. I· have specifically reviewed

24 and/or provided recommendations on zoning and site plans applications for

COA Exhibit GG-1 Direct Testimony ot Greg Guernsey SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 1 ot6

••

• compliance with land use compatibility between residential and non-residential

2 uses.

3 Q. How does your professional and educational experience relate to your

4 testimony and opinion in this matter?

5 A. I have more than 25 years of professional planning and zoning related experience

6 in Texas. I have received a Masters Degree and Community and Regional

7 Planning from the University of Texas at Austin in 1983 and a Bachelor of

8 Science Degree in Urban Planning from Michigan State University in 1981.

9 Q. What is the purpose of your testimony?

• 10 A. The purpose of my testimony is to assess the land use compatibility of this landfill

11 with the adjacent property and the City. My assessment is based on my prior

12 experience in planning and zoning as well as my direct observation of landfill

13 operation.

14 Q. Have you reviewed the application of Waste Management of Texas, Inc.

15 (WMTX) for a landml permit amendment that is the subject of this

16 proceeding?

17 A. Yes.

18 Q. What parts of the application did you review in particular?

19 A. Specially, I have reviewed the Austin Community Recycling & Disposal Facility,

20 Austin, Travis County, Texas, TCEQ Permit No. MSW-249D, Vol. 1 of 4, pages

21 1-34,45-57,62-66, 130-175, and 180-240.

22 Q. Why?

23 A. Because, these sections of the application pertain to land use related issues.

24 Q. Are you familiar with the proposed site?

COA Exhibit GG-1 Direct Testimony of Greg Guernsey SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-Q612-MSW Page 2016

3

• A. Yes. Over the past 20 years I have reviewed numerous land development

2 applications in the area of the landfill and conducted field trips in the area

adjacent to the landfill.

4 Q. Have you reviewed'the prefiled testimony for the applicant in this case?

5 A. Yes. I have reviewed the pre-filed testimony presented by Mr. John Worrall, and

6 Mr. Peter Boecher, AICP, ASLA.

7 Q. Does the applicant's prefiled testimony address the concerns which

8 prompted the city to contest this application?

9 A. No. The pre-filed testimony addresses some of the concerns such as it relates to

• 10 land use compatibility once the land fill is closed; however, it does not address the

11 City's concerns with the operation of the landfill prior to closure nor the City's

12 concerns with the continued existence of an active landfill in the area past

13 November 1,2015.

14 Q. Have you formed any opinions regarding the pre-filed testimony that you

15 reviewed?

16 A. Yes. I disagree with some of the pre-filed testimony of Mr. John Worrall.

17 disagree that the proposed WMTX expansion area is " ... located in an area

18 surrounded by existing land fill space." According to the· proposed WMTX

19 permit amendment application itself, the property to the north and west of the

20 proposed expansion area is open space and developed with a single family

21 residence. I would agree with Mr. Worrall that the proposed expansion area is

22 abuts active landfill sites to the east and south.

• 23 I also disagree with Mr. Worrall's conclusions that the proposed expansion

24 " ...does not bring the boundary closer to the existing residences", since an

COA Exhibit GG-1 Direct Testimony of Greg Guernsey SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 3 of6

I

• existing residence is located on the abutting John Allen Wilkin, Trustee property 1

2 to the northwest.

While I agree with Mr. Worrall's assessment that the proposed expansion of the

4 WMTX facility does not represent a significant change in the existing and

5 historical land use patterns and relationships, I disagree with Mr. Worrall's

6 statement that there is no evidence that the presence of these facilities have

7 deterred, are deterring, or will deter growth. I also disagree with Mr. Worrall's

8 generalization that developers have not been reluctant to develop projects in the

9 area of the landfill, because the growth patterns within the City of Austin do not

• 10 reflect this conclusion. The development of detached single family homes within

11 the Harris Branch Planned Unit Development (PUD) and the Pioneer Crossing

12 PUD has not occurred on parcels approved for single family uses closest to the

13 existing landfill sites, but has occurred on other parcels further away.

3

14 It is my opinion that development of these undeveloped single family parcels

15 would occur sooner, if the adjacent land fill operations ceased or had a known

16 closure date in the very near future.

17 Q. I'm handing you what has been marked as Exhibit GG-3. Do you recognize

18 it?

19 A. Yes. These are two maps that were prepared by the City and by the Pioneer

20 Crossing developer to show on a map in relation to the WMI landfill where the

21 Harris Branch PUD and the Pioneer Crossing PUD are located, and the extent of

22 development that has occurred and has not occurred within those PUDs. These

23 maps demonstrate that the development of detached single family homes within

• 24 the Harris Branch Planned Unit Development (PUD) and the Pioneer Crossing

eOA Exhibit GG-1 Direct Testimony of Greg Guemsey SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 4 of6

PUD has not occurred on parcels approved for single family uses closest to the

existing landfill sites, but has occurred on other parcels further away.

What is a PUD?

A Planned Unit Development (PUD) is intended for large or complex

. developments under unified control planned as a single continuous project, to

allow single or multi-use projects within its boundaries and provide greater design

flexibility for development proposed within the PUD. Use of a PUD district

should result in development superior to that which would occur using

conventional zoning regulations. PUD zoning is appropriate if the PUD enhances

preservation of the natural environment; encourages high quality and innovative

design and ensures adequate public facilities and services for development within

thePUD.

Please state the remaining concerns not addressed in the applicant's pre-filed

testimony and suggest any special conditions that could be added to address

these concerns?

To lessen the impact on the existing and proposed residential uses and adjacent

civic uses, I would suggest that the operation be limited to day light hours, truck

traffic be limited to Giles Road, and the closure date for the landfill to cease

accepting waste and to restrict the property on which the landfill operates from

accepting waste or from operating as a transfer station be set at or before

November 1,2015.

Do you have concerns regarding land use compatibility of the landfill with

the surrounding areas?

COA Exhibit GG-1 Direct Testimony of Greg Guernsey SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-Q612-MSW Page 5 of6

;. 1 A. The proposed application does not address the continued negative affects created

the current land fill operation on the existing and proposed residential and civic

3

2

land uses in the adjacent area. The landfill and the adjacent property are located

4 within the City's Desired Development Zone which is an area that the City has

5 designated for future growth and development. It is anticipated that additional

6 residential uses will be built within the Pioneer Crossing PUD and the Harris

7 Branch PUD located to the north, northwest and northeast over the next five to ten

8 years. Even if the landfill operations are in compliance with the minimum

9 standards established by the TCEQ, those minimum standards as set forth in the

• 10 application are notsufficient to mitigate the multitude of negative impacts created

11 by an active landfill located adjacent to the residential area. Specifically, the

12 application as proposed does not mitigate all negative impacts from odor, traffic,

13 litter, noise, visual aesthetics or the loss of additional property tax revenue by the

14 City of Austin created by the delay in land development adjacent to the land fill

15 site.

16 Q. Does this conclude your testimony?

17 A. Yes, although I reserve the right to amend or supplement my testimony as

18 additional information becomes available.

COA Exhibit GG-1 • Direct Testimony of Greg Guernsey SOAH Docket No. 582-08-2186

6 TCEQ Docket No. 2006-0612-MSW Page 6 of6

•

•

February 2006 to Present

April 2005January 2006

May 2001March 2005

June 1997May 2001

June 1995June 1997

May 1993June 1995

Gregory I. Guernsey, A.I.C.P.

Gregory I. Guernsey, A.I.C.P., Director Neighborhood Planning and Zoning Department

P.O. Box 1088 Austin, Texas 78767

EXPERIENCE

Director. Neighborhood Planning and Zoning Department, City of Austin,Texas. Responsible for a department consisting of 63 employees and an annual operating budget of $5.3 million dollars. The department administers the City's comprehensive plan, neighborhood plans. long range transportation plans, zoning, historic preservation, annexation, great streets and urban design programs.

Assistant Director. Neighborhood Planning and Zoning Department, City of Austin, Texas. Managed division activities and develop and establish goals, priorities and operational procedures. Interpret and enforce City policies and procedures, zoning regulations and related ordinances.

Development Services Manager. Neighborhood Planning and Zoning Department, City ofAustin, Texas. Responsible for the management and coordination of zoning; land use, and land development related matters for City Council consideration.

Principal Planner, Neighborhood Planning and Zoning Department/Development Review and Inspection Department, City ofAustin, Texas. Responsible for the management and coordination of zoning, land use, and land development related matters for City Council consideration.

Principal Planner, Developmerlt Review and Inspection Department, City of Austin, Texas. Manager land use review teams for zoning, historic zoning, subdivision, sign, alcoholic beverage pennit, and Board of Adjustment variance applications. Lead planner responsible for the Planning Commission, Zoning Board of Adjustment, Sign Review Board, and the Historic Landmark Commission. .

Senior Planner, Department ofPlanning and Development, City ofAustin, Texas. Reviewed site plans and development application and assisted the public with the City of Austin's land development process and the Land Development Code. .

COA Exhibit GG-2 Greg Guernsey's Resume SOAH Docket No. 582-06-2166 TCEQ Docket No. 2006-0612-MSW Page 1 of 3

• February 1988April 1993

March 1987February 1988

June 1985March 1987

June 1983June 1985

• September 1982May 1983

February 1982May 1983

June 1982August 1982

June 1981August 1981

•


Senior Planner/Planning Coordinator, Department ofPlanning and Development/Planning Department, City ofAustin, Texas. Case manager responsible for the processing and coordination of administrative site plans, Planning Commission, and City Council approved site plan applications and zoning cases.

Planner III, Office ofLand Development Services, City ofAustin, Texas. Case manager responsible for the processing and coordination of administrative, Planning Commission, and City Council approved site plan applications and zoning cases.

Planner II, Office ofLand Development Services, City ofAustin, Texas. Case manager responsible for the processing and coordination of administrative site plan applications.

Planner II, Department ofPlanning and Transportation, City ofGalveston, Texas. Responsible for the administration and creation of amendments to the City's Zoning Ordinance, Subdivision Ordinance, Beach and Dune Management Master Plan, and Oil and gas Master Plan

Planning Intern, Department of Urban Transportation, City ofAustin, Texas. Researched and wrote a draft pamphlet entitled a "Citizen's Guide to City Traffic" and conducted, vehicle windshield and traffic count surveys.

Research Assistant, School ofArchitecture, University ofTexas at Austin, Texas. Researched various structural and non-structural land use techniques to manage development over the Southern Edwards Aquifer Recharge Zone in central Texas.

Planning Assistant, Department of Community Development, Mentor, Ohio. Collected analyzed and forecasted population and housing data for an update to the City's Comprehensive Plan. Assisted in the formulation of standards for conditional use permits. Reviewed sign permit and residential permits for compliance with the City's Zoning Ordinance.

Planning Assistant, Department ofCommunity Development, Mentor, Ohio. Collected, mapped and analyzed land use and transportation data for an update to the City's Comprehensive Plan. Other duties included research and preparation of support information for the PIarming Commission and the Zoning Board of Appeals.

COA Exhibit GG-2 Greg Guernsey's Resume SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 2 of 3

• June 1980August 1980

•


Planning Intern. Planning Department. Ann Arbor, Michigan. Assisted in the creation of the Park. Recreation and Open Space Plan. Duties included research and analysis of various park plans. conducting on-site inventories surveys, designing preliminary park improvement site plans, and presentations before the Planning Commission and neighborhood associations.

EDUCATION

Master ofScience in Community and Regional Planning, School of Architecture, The University of Texas, Austin, Texas. May 1983.

Bachelor ofScience in Urban Planning. School of Planning and Landscape Architecture, Michigan State University, East Lansing, Michigan. June 1981.

PROFESSIONAL ACTIVITIES

Member of the American Institute of Certified Planners Member of the American Planning Association Member of the Urban Land Institute 1991-1993 State Board Member, Texas Chapter, APA 1991-1993 Director, Central Texas Section, Texas Chapter, APA 1992 Texas-Louisian~ State Planning Conference Coordinator

• COA Exhibit GG-2 Greg Guernsey's Resume SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 3 of 3

•

•

it

f

i ;

~i N

...,0 ~O

• CO c.<hlOII G -3 Mao of IMvlI landfill

Area I. 582-08-2186SOAH Docket No. _ -NlSV\i TCEQ Docket No 2006-0612 Page 1 of 2

-

PIONEER CROSSING P.U.D. -

I

- JU,," bM:lIt :;'.>-3 Are Map of 'NMI Landfill SOAH Docket No 582-08-2186 TCEQ ocket 0 2006-0612· lS'I'1 Page 2 of 2

1 Q.

2 A.

3 Q.

4 A.

5 Q.

6 A.

7 Q.

8 A.

9

10

11 Q.

12 A.

13 Q.

14 A.

15

16 Q.

17 A.

18 Q.

19 A.

20

21

22

• 23 Q.

Please state your name.

Joe D. Word

Who is your employer?

The City of Austin

What department do you work for?

Solid Waste Services

How long have you worked for the City?

I worked for the City for 25 years and retired in 2001. I then accepted an offer to

work part-time for the Solid Waste Services Department, which is my current

position.

I am handing you what's been marked as Exhibit JW-2 Do you recognize it?

Yes.

What is it?

It isa summary resume of my education, qualifications, and professional

expenence.

Is the information contained in it true and correct?

Yes.

What are your job duties?

I assist in the management of the City's environmental remediation program for

old landfills, including consultant selection, contract negotiation, and oversight of

the various phases of each project. I also perfonn special projects for the Director

as assigned, such as representing the City in this proceeding.

How does your professional and educational experience relate to your

COA Exhibit JW-l Direct Testimony of Joe Word

SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW

Page 1 ofl4 .

, ,,"<.' 24 testimony and opinion in this matter?

•

25 A. " I have a Bachelor of Science degree in Civil Engineering from the University of

26 Texas. I am a licensed professional engineer (#50381) in the State of Texas. In

27 my career with the City of Austin, I managed the Street and Bridge Division of

28 Public Works for six years, where I was responsible for street construction and

29 maintenance, and drainage maintenance. I assumed responsibility for the

30 management of Solid Waste Services in 1983. My responsibilities included

31 management oversight of the City of Austin's FM8l2 Type I municipal solid

32 waste landfill, as well as management of all collection and recycling operations.

33 In that position, I observed first-hand the challenges of operating a landfill in all

34 types 'of weather conditions, including high winds, flooding rains, and

35 temperature extremes. I also represented the Departrilentin the procurement of

36 disposal contracts with private landfills, including the' WMI landfill that is the

37 subject of this proceeding. I participated in numerous meetings with landfill

38 operators and neighborhood, representatives to discuss' concerns and possible

39 remedies. I therefore have an understanding of the engineering and operational

40 considerations of running a landfill, both the theoretical ideal and the practical

41 reality. I am familiar with the public's concerns regarding the operation of this

42 site. I am also familiar with the TCEQ rules governing this application.

43 Q. What is your connection with the permit application thatis the, subject of this

44 proceeding?

45 A. I am the City of Austin representative for this proceeding.

COA Exhibit JW-1 Direct Testimony of Joe Word

SOAR Docket No. 582~08-2186

TCEQ Docket No. 2006-0612·MSW Page 2 of 14

• 46 Q.

47

48 A.

49 Q.

50 A.

51

52

53

54

55

• 56

57 Q.

58 A.

59

60

61

62

63

64

65

66 Q.

67

I'm handing you what has been marked as Exhibit JW-3, do you recognize

it?

Yes.

What is it?

It is a copy of City of Austin Resolution No. 20070517-030, wherein the City

Council declared that there is not a sufficient buffer between the WMI landfill and

the surrounding uses, that the WMI landfill is located in the City's Desired

Development Zone, and that the future growth patterns anticipated by the City in

that area are not conducive to the operation of a Type I Municipal Solid Waste

Facility; and resolving that the City opposes the WMI landfill expansion

application as filed.

What is the purpose of your testimony?

To provide my best assessment of the implications of extending landfill

operations at this site beyond its current permitted capacity, and whether the

application identifies new measures or operating practices that will assure

elimination of the nuisance conditions about which nearby property owners and

neighborhoods have repeatedly complained. My assessment is based on my prior

experience in earthwork, drainage, and landfill operations, knowledge of the

TCEQ rules, direct observation of the WMI landfill facility as a customer of that

facility in the past, and in reviewing this application.

Have you reviewed the application of WMI for a landfill permit amendment

that is the subject ofthis proceeding?

• 68 A. Yes.

COA ExhibitJW-1 Direct Testimony of Joe Word


Page 3 of 14

69 Q. What type of studies/analysis/review have you done?

70 A. I reviewed the TCEQ rules and the WMI pennit amendment application in order

71 to understand what was being proposed, and looked for opportunities to improve

72 the overall operations to mitigate the impact of the facility on surrounding

73 properties, residents and businesses. I have examined records produced by the

74 TCEQ, including the enforcement and inspection reports for the facility, and

75 documents produced by WMI related to the operation of this landfill.

76 Q. What parts of the application did you review in particular?

77 A. I did a cursory review of the entire application, but paid particular attention to

78 Part I (General Information), Part III (the Site Deveiopment Plan,) and Part IV

79 (The Site Operating Plan).

80 Q. Why?

81 A. To determine where the applicant proposed to expand; to ascertain whether the

82 application proposes to exceed the minimum requirements of the TCEQ rules for

83 operations; and to detennine if the applicant proposes any operations above the

84 minimum required in order to mitigate impacts of continued operation of the

85 landfill beyond its currently permitted capacity.

86 Q. Are you familiar with the proposed site?

87 A. Yes. In my former position with the Solid Waste Services Department, I visited

88 the WMI landfill that is the subject of this application at least a dozen times

89 during which the City was a customer of the landfill. In the late 1990's, the City

90 considered entering into a 30-year contract for landfill disposal, and I visited the

landfill several times at the invitation of WMI personnel to view the facility and

• 91



Page 4 of14

discuss the proposed agreement. The City commissioned a study of the landfills

by Carter & Burgess Consultants to determine environmental compiiallce and risk

./'

issues that might be \associated with contracting with the landfill. Since my

retirement from full4ime employment, I have probably visited the area of the

northeast landfills' at least once per year to monitor conditions around the

landfills. I also participated in a site visit of the facility on January 6, 2009.

Did you have concerns about the WMI permit application that prompted a

request for party status in the matter referred for hearing? . .

Yes. The City and nearby property owners"businesses, and residents had an

expectation thatthe landfill would close upon reaching its currently permitted

capacity, at which poirttthe landfill's impacts on their quality of life and potential

uses of their property would no longer be a significant factor.

Have you reviewed the pre-filed testimony for the applicant in this case?

Yes.

Does the applicant's pre-filed testimony address the concerns which

prompted the city to contest this application?

No.

What are those concerns?

This location is in the City's Preferred Growth Corridor. The area has become

more urban in character, and the City anticipates that nearby land that is still

undeveloped may be developed in the near future. The continued existence of the

landfill will negatively impact an increasing population in the immediate area.

The old Travis County Landfill is now closed. BPI has committed to close their

COA Exhibit JW-1 Direct Testimony ofJoe Word


Page 5 of 14

• 115 landfill no later than November 1, 2015. It is my understanding that WMI has

116 capacity under their current permit to continue to accept waste until about 2015.

117 The City believes that a goal of closure of all landfills in this neighborhood by

118 November 1, 2015 gives the current landfill operators sufficient time to plan and

119 develop disposal alternatives in appropriate locations that will not negatively

120 impact the community.

121 The operation of the WMI landfill has and will continue to impact the

122 surrounding neighborhoods, as evidenced by repeated and voluminous complaints

123 regarding odors, traffic, litter, dust, erosion and sedimentation of streams, and

124 other complaints. By virtue of its recent record of operation, the applicant has

125 failed to demonstrate that the facility will not adversely impact human health or

• 126 the environment, as required by 330.61(h).

127 Q. I'm handing you what has been marked as Exhibit JW-4. Have you seen this

128 document before?

129 A. Yes, it is a copy of the agreed order WMI entered into with the TCEQ on June 23,

130 2004 in which WMI was fmed $244,420, and in which the TCEQ alleged that

131 WMI failed to maintain the leachate head on the liner below 12 inches, failed to

132 continuously maintain negative pressure at each wellhead in the landfill gas

133 collection system, failed to operate each wellhead such that nitrogen levels of less

134 than 20% or oxygen levels of less than 5% were maintained, failed to monitor

135 temperatures, failed to operate all pollution emission capture equipment in good

136 working order, discharged one or more air contaminants in concentrations and

durations that interfered with the normal use and enjoyment of property, allowed

• 137

COA Exhibit JW-I Direct Testimony of Joe Word


Page 6of!4

• 138 accumulations of sediment and landfill debris in drainage channels, and other

139 reporting violations. The fact that WMI allowed these violations to occur simply

140 reinforces the reasons why this landfill should not be granted a permit amendment

141 to lengthen the duration of its operations in an increasingly urbanized area.

142 Q. Do you have other concerns that the applicant's prefiled testimony did not

143 address?

144 A. Yes; simply complying with the 125 foot buffer requirement is not sufficient to

145 assure that there will be no impact. If all that an applicant needed to do to

146 demonstrate that a facility will not adversely impact human health or the

147 environment is provide a 125 foot buffer, there would be no reason for the rules to

148 require consideration of land use in vicinity of the landfill. Odors, litter, dust,

• 149 noise, and sediment-laden stormwater runoff can and do travel distances much

150 greater than 125 feet. Bluebonnet Trail Elementary School on Fannhaven Road is

151 located approximately 4,823 feet northwest of the site, and a licensed day care

152 facility, The Children's Courtyard, is located approximately 3,445 feet northeast

153 of the site on Harris Branch Parkway. Both of these facilities have made multiple

154 reports of odors from the landfills, and have in fact kept children inside on some

155 occasions due to complaints of children and teachers becoming ill from effects of

156 the odors.

157 Q. Are you familiar with the CAPCOG?

158 A. Yes, CAPCOG is the Capital Area Council of Governments. They are the

159 regional solid waste planning agency recognized by the TCEQ for this 10-County

regIOn. They have adopted a Regional Solid Waste Management Plan (RSWMP)

• 160



Page 7 of 14

as required by the TCEQ rules. The rules also require applicants to submit

applications to the CAPCOG for review. I served on,the Solid Waste Advisory

Committee of the CAPCOG as the City of Austin representative up until my

retirement in 2001.

I'm handing you what has been marked as Exhibit JW-5. Have you seen this

document before?

Yes, this is the letter of nonconformance that was issued ,by CAPCOG regarding

this application to expand by WMI. The CAPCOG has adopted a position that the

proposed application is'not compatible with land use in the area, does not conform

with the RSWMP, and that there are significant l~c~il concerns about the site.

CAPCOG also supports the Travis County request that the WMI facility cease

operations by November 15, 2015, and that WMI mclude adequate buffer zones

and other safeguards around any new landfills in th7'eastern portion of Travis

County. They were also concerned about the applicaI,lt's compliarice history, the

applicant's failure to go beyond minimum operating requirements in its site

operating plan, future land use compatibility, and iriadequate programs to support

community cleanup events and curtail or clean up illegal dumping.

Is the Site Operating Plan as proposed in the application sufficient for

landfill operation in this area for the next 16 years?

No. There is nothing in the applicant's proposed site operating plan that is

significantly different from their existing plan. Either the plan itself is insufficient

to prevent impacts to nearby neighborhoods, or the site operator has not been

consistent in operating in compliance with that plan. That is why I believe that



Page 8 of 14

• 184 the TCEQ regulations should be interpreted to require a much higher standard for

185 buffer zones and other site operating requirements. WMI has not significantly

186 changed their daily, intermediate, and final cover procedures and requirements.

187

•

They will continue to operate a liquid waste stabilization basin, which can be a

188 significant source of odors. The plan does not indicate any intent to improve the

189 prior and current revegetation practices, which do not call for irrigation of seeded

190 areas to ensure that vegetation can be quickly established. There is no indication

191 of a willingness or intent to exceed minimum operating standards; which is

192 essential for an active landfill with a history poor operating procedures located in

193 the middle of a developing residential community.

194 Q. Why is this important in deciding whether or not a landfill expansion

195 application should be granted?

196 A. The WMI facility has a history of poor performance even with just the TCEQ

197 minimum standards. Additionally, it is in the middle of the City's Desired

198 Development Zone and in fact neighborhoods are already nearby. The granting of

199 a permit amendment to expand this landfill could have the effect of slowing

200 development in the City's Desired Development Zone; and for those

201 neighborhoods that do develop closer to the landfill, it is likely that even more

202 legitimate complaints regarding odors, litter, noise, dust, birds, etc. will become

203 increasingly common.

204 Q. Why do you believe a landfill is no longer appropriate for this area?

205 A. The location within the City of Austin's Preferred Growth Corridor and adjacent

to the rapidly developing' US 290 East makes this area important to the' future

• 206

COA ExhibitJW-I Direct Testimony of Joe Word


Page 9 ofl4

growth and economic vitality of the Austin region. Planning for this region

assumed the eventual closure of this landfill upon reaching its capacity, allowing

the obvious adverse impacts to the area to cease. The operating record and

reputation of the landfills at this location have likely affected property values and .

the willingness to proceed with developments in this vicinity. The development

community needs to be able to rely on closure once permit capacity is reached.

Granting a substantial increase in capacity, particularly with no time-certain

closure date in the near future, will adversely affect development in this vicinity

for decades.

The TCEQ rules set minimum standards for the .operation of a landfill. They

generally assume a rural setting for a landfill, and assume that there is not a

significant population of people nearby to be impacted by the types of nuisances

that are not fully controllable by the operator. This assumption is no longer

accurate for the area surrounding the WMI landfill that is the subject of this

proceeding.

When you say "not fully controllable", can you give some examples based on

your personal observation, knowledge, and experience?

Yes. Odors are not fully controllable. Putrescible waste may very well be sitting

in a dumpster for a week or longer before it is fmally hauled to the landfill and

dumped on the open working face. Small quantities of household hazardous

waste may have also been disposed in the trash. While that waste is being spread

and compacted, it is releasing odors and possible hazardous chemicals to the air

that are being carried by the wind.. There is no 100% effective, practicable way



Page 10 of 14

that I am aware of to assure that those odors or airborne chemicals do not leave

the site.

Windblown waste is. not fully controllable. The rules recognize this by not

prohibiting windblown waste, but that it be controlled and picked up within a

reasonable amount of time. When the wind blows at 30 miles per hour, wind

screens and wind fences will not be. adequate to contain all waste, and it can travel

significant distances; certainly more than 125 feet.

Wind' will also carry dust significant distances from a construction site. This

landfill typically will have many acres of bare soil from daily cover, intennediate

cover, and [mal cover where vegetation has not been established, as well as

stockpiles of soil. During periods of dry weather,"significant amounts of wind

erosion and dust can be generated from these areas, as well as dust generated from

access and haul roads, and' from dried mud tracked from '. the landfill onto Giles

Road, which is stirred up by traffic.

Noise is not practicably controllable except by distance. Backup alarms on

garbage trucks and construction equipment, ~eavy diesel engines, and bird

abatement methods can generate considerable noise. A person standing 125 feet

from this activity will still consider it to be a very noisy loca'tiqn.

All of the aforementioned reasons are why meeting the TCEQ minimum

standards for active landfills is n9t enough for a landfill that is located in the

middle of residential and civic uses.

Are you familiar with 30 TAC §330.543 relating to Buffer Zones?

Yes.


. SOAR Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW

Page 11 of14

• 253 Q.

254 A.

255

256 Q.

257 A.

258

259

260

261

262 Q.

263 A.

• 264

265 Q.

266

267 A.

268

269 Q.

270

271

272 A.

273 Q.

274

What do these rules require?

They require that designs for a lateral landfill expansion include a minimum of

125 feet between waste disposal areas and the property boundary.

What is your understanding of the purpose of a Buffer Zone?

Buffer Zones are intended to provide visual screening of solid waste disposal

activities; to afford ready access for emergency response, maintenance, and

monitoring; to afford control of odors and windblown waste; and to provide

sufficient distance to meet the drainage and sediment control requirements

applicable to the facility.

Are these purposes stated in 30 TAC §330.543?

Yes, in section 330.543(b)(3)(B), they are stated in discussing what must be

demonstrated by an applicant proposing alternatives to Buffer Zones.

Are there other impacts from landfills that Buffer Zones might address

which are not specifically stated in the rules?

Yes. Noise, dust, other airborne chemical and disease vectors, lighting, and

rodents.

From your observation, knowledge, and experience, will 125 foot buffers, as

proposed in this application, be sufficient to prevent exposure of adjacent

property and neighborhoods to these impacts?

No, not in an increasingly urbanized setting.

Are you aware that the City of Austin has entered into an agreement with

BFI relating to their pending landfill permit amendment application?

• 275 A. Yes.

COA Exhibit JW-I Direct Testimony of Joe Word

SOAR Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW

Page 12 of 14

• 276 Q. Generally, what is that agreement?

·277 A. In exchange for BFI agreeing to improved operational requirements and a

278 restrictive covenant prohibiting waste acceptance beyond November 1,2015, the

279 City of Austin agreed to limit its participation in the contested case hearing to

280 matters supporting the agreement.

281 Q. If you believe that this location has become too urbanized to be an

282 appropriate location for a landfill, why did the City of Austin agree to limit

283 its participation in the BFI application?

284 A. It is believed that the WMI landfill currently has enough permitted capacity to

285 continue accepting waste to 2015. By getting BFI to agree to closure by

286 November 1, 2015, in the permit and enforceable via a separate restrictive

• 287 covenant, those living or owning property in the vicinity will have certainty that

288 the negative impacts from being near two active landfills will cease at or before

289 November 1, 2015 unless the WMI application for permit amendment is granted.

290 Q. Did BFI agree to support including special conditions to its permit?

291 A. Yes.

292 Q. If the TCEQ decides to approve the WMI application, would it be an

293 improvement to require those same special conditions that BFI agreed to?

294 A. It would be an improvement; however, it would be insufficient to mitigate the

295 City's concerns about this application for expansion. The special conditions that

296 the City agreed to in the BFI matter were all developed based on a mandatory

297 closure date of November 1, 2015. The City would not have entered into any

• 298 agreement with BFI without a guaranteed closure date of November 1, 2015,

COA ExhibitJW-l Direct Testimony of Joe Word


Page 13 of 14

• 299 because it would not mitigate the City's concerns related to land use In the

300 immediate vicinity of these two landfills.




•

• COA Exhibit JW-I Direct Testimony ofJoe Word


Page 140f14

• Joe D. Word, P.E.

EXPERIENCE

CITY OF AUSTIN 1/76 - Present

Coordinating Engineer for Special Projects 9/01 - Present Solid Waste Services Department

Cumently working as a part~time employee for the Solid Waste Services Department on projects assigned by the Director. Coordinated and reviewed the work of engineering consultants on closed landfill remediation projects at Mabel Davis Park, Zilker Park, Loop 360 Landfill, Rosewood Landfill, among others. Developed and managed Capital Improvement Program budgets for the Department. Coordinated with other departments regarding funding for the Environmental Remediation Fund. Participated in the drafting and provided technical advice and review for City of Austin solid waste code amendments. Assist with budget development and review. Provide technical advice and analysis regarding solid waste planning. Review landfill applications and represent the City of Austin in landfill hearings.

• Assistant Director, Solid Waste Services 7/83 - 6/01 Solid Waste Services Department Environmental and Conservation Services Department Public Works Department

Responsible for overall management, supervision, and administration of the Solid Waste Services Division (later becoming its own department). Responsible for budget development and operation, personnel administration, establishing and monitoring goals and objectives and budget performance, solid waste planning, Capital Improvement Program, environmental compliance, remediation of closed landfills, equipment specification and acquisition, and other duties in support of the City's goals and objectives. Management anq engineering oversight of garbage collection operations, landfill operations and contracting, street sweeping and anti-litter programs, composting, recycling collection, MRF development and operation, public education programs, solid waste planning, and administration.

• Worked with the Solid Waste Advisory Commission to develop the City's PayAs-You_Throw program designed to increase recycling and waste diversion/avoidance and reduce dependency on landfills.

• Participated in permitting the City of Austin's FM '812 Type I Municipal Solid

• Waste landfill In 1984.

COA Exhibit JW-2 Jow Word's Resume


Page 1 of3

• • Worked on a team with Austin Energy to build a waste-to-energy facility for the City. The project was approved and designed, but later cancelled due to changing economic conditions. .

• Participated in negotiation of 30-year landfill disposal contract for the City of Austin.

Assistant Director of Public Works 6/78 -7/83 Division Engineer, Street and Bridge Division

Responsible for overall management, supervision, and administration of the Street and Bridge Division of the Public Works Department. Responsible for budget development and operation, personnel administration, establishing and monitoring goals and objectives and budget performance, engineering oversight, equipment specification and acquisition, Capital Improvement Program, and other duties in support of the City's goals and objectives.

• Developed and won approval for the City of Austin's initial Draingage Utility, in order to fund and provide needed drainage maintenance improvements following the historic 1981 floods on Shoal Creek and Little Walnut Creek.

• • Developed and won approval for the first municipal anti-litter and street cleaning

fee in the state in order to provide adequate funding for an effective street cleaning program.

• Developed and implemented the first pavement maintenance management system for the City of Austin in order to more efficiently and effectively meet the street maintenance needs of the City..

Civil Engineer Public Works Department

Responsible for budget development and oversight for the Street and Bridge Division. Reviewed proposed subdivision plats for compliance with Department requirements. Assisted in development of the Department's 5-Year Capital Improvements Program. Provided technical and engineering assistance under the oversight of licensed engineers for minor street design and drainage projects.

EDUCATION

Bachelor of Science in Civil Engineering University of Texas 1975

Class A Solid Waste Operator Training

• Texas Engineering Extension Service (TEEX) 1996-1998



Page 2 of 3

••

CERTIFICATIONS/AWARDSIMEMBERSmpS

Licensed Professional Engineer, State of Texas #50381 Member, Texas Chapter, Solid Waste Association of America (SWANA) . Board of Directors, Texas Chl',lpter, SWANA 1994-1999 . Board of Directors, Central Texas Chapter, Texas Public Works Association 1985-1991 Guest Lecturer, Public Works Management Graduate Engineering Class, 1994-2001, Dr.

Clyde Lee and Dr. Joseph Malina ' . Capital Area Planning Council, Solid Waste Advisory Committee, 1994-2001

•



Page 3 on

•

•

•

. RESOLUTION NO. 20070517-030

WHEREAS, the City of Austin has identified the area surrounding the

aging Waste Management Community Landfill and the Allied BF] Landfill in

northeast Travis County to be within the City's Desired Development Zone; and

WHEREAS, both subject landfills are adjacent to many homes, schools

and other sensitive receptors without sufficient land buffers; and

WHEREAS, future growth patterns surrounding the subject landfills are

not conducive to the operation of Type I Municipal Solid Waste Facilities;

NOW, THEREFORE,

BE IT RESOLVED THAT THE CITY COUNCIL OF THE CITY OF AUSTIN:

Opposes both the Waste Management Community Landfill and the Allied

SFI Landfill expansion applications as filed.

BE IT FURTHER RESOLVED:

That the City Manager:

(1) formally work with Travis County and the Texas

Commission on Environmental Quality (TCEQ) in seeking

and planning for permanent closure of both subject landfills

by November 1,2015.

COA Exhibit JW-3 City of Austin Resolution No. 20070517-030 SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 1 of 3

•

•

•

(2) Work with Travis County and the TCEQ in seeking to raise

and enforce the operating standards at the subject landfills as

long as they remain open.

BE IT FURTHER RESOLVED:

That the City will seek party status before the State Office of

Administrative Hearings should a contested case hearing be granted by TCEQ.

ADOPTED: _---=-M;...;:.;a==.<y--=l:....:..7__, 2007

COA Exhibit JW-3 City of Austin Resolution No. 20070517-030 SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 2 of 3

• CITY OF AUSTIN Office of the City Clerk 301 West. 2nd Street, Suite 1120 P.O. Box 1088 Austin, Texas 78767 512/974-2210

THE STATE OF TEXAS §

COUNTY OF TRAVIS §

I, Yvonne Spence, Deputy City Clerk of the City of Austin, Texas, do hereby certify that the

foregoing instrument is a true and correct copy of Resolution No. 20070517':'030 consisting of2

page(s), and exhibits consisting of 0 page(s), for a total of 2 page(s), passed by the City Council

• of Austin, Texas, at a Regular Called Meeting on the 1i h day of May 2007, as on file in the

Office of the City Clerk.

WITNESS my hand and official seal of the City of Austin at Austin, Texas, this 23 rd day

ofApril 2008.

YVO. ENCE DEPUTY CITY CLERK

CITY OF AUSTIN, TEXAS

YS:er

• COA Exhibit JW-3 City of Austin Resolution No. 20070517-030 SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 30f3

.,., • I

i.

TEXAS COMMISSION ON ENVIRONMENTAL QUMJTY

IN THE MATTER OF AN § BEFORE THE ENFORCEMENT ACTION §

CONCERNING § WASTE MANAGEMENT OF § TEXAS COMMISSION ON TEXAS, INCORPORATED §

MUNICIPAL SOLID WASTE § PERMIT NO. 249-C; AIR §

ACCOUNT NO. TH-0502-F § E~ONMENTALQUAUTY

AGREED ORDER DOCKET NO. 2002-093S-MLM-E

I. JURISDICTION AND STIPULATIONS

At its "JUN 23 2004 agenda, the Texas Commission on Environmental Quality, formerly known as the Texas Natural Resource Conservation Commission ("Commission" or "TCEQ" or "TNRCC") considered this agreement of the parties, resolving an enforceII1entaction regarding Waste Management ofTexas , Inc~rporated ("Waste Management") under th~ authority of TEX. WATER CODE cbs. 7 and 26, and TEx. HEALTH & SAFETY CODE chs. 361 andJ82. Tbe Executive Director of the TCEQ, represented by the Litigation Division, and Waste Management, represented by John Riley of the law fIrm of Vinson & Elkins, L.L.P., appear before the Commission and together stipulate that:

1. Waste Management owns and operates a municipal solid waste landfill, referred to as the Austin Community Recycling and Disposal Facility, located at 9900 Giles Road in Austin, Travis County, Texas (the "Landfill"). .

2. The Landfill consists of one or more sources of air contaminants as' defined in TEx. HEALTH & SAFETY CODE § 382.003(12).

3. The Landfill involves or involved the management of municipal solid waste, as defined in TEx. HEALTH & SAFETY CODE ch. 361.

4. Waste Management has discharged into or adjacent to any water in the state under TEx. WATER CODE ch. 26.

• COA Exhibit JW-4 TCEQ Enforcement Action Agreed Order SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW

-----·-·------------,~-----f'age1 of 1fr -- 1-----------WM-VE-0000879

I

Waste Management of Texas, Incorporated DOCKET NO. 2002-0935·l\fi,M·E Page 2

5. The Commission and Waste Management agree that the Commission has jurisdiction to enter this Agreed Order, and that Waste Management is subject to the Commission's jurisdiction.

6. Waste Management received notices of the violations alleged in Section II (U Allegations") on or about April 7, 2002, April 28, 2002, May 11, 2002, and September 12,2003.

7. The occurrence of any violation is in dispute and the entry of this Agreed Order shall not constitute an admission by Waste Management of any violation alleged in Section 11 ("Allegations"), nor of any statute or rule. .

8. An administrative penalty in the amount of two hundred forty-four thousand four hundi'ed twenty dollars ($244,420.00) is assessed by the Commission in settlement of the violations alleged in Section n (ICAllegations"). Waste Managementhas paid one hundred twenty-two thousand two hundred ten dollars ($122,210.00) of the administrative penalty. One' hundred twenty-two thousand tWo hundred ten dollars ($122,210.00) shall be conditionally' offset by Waste Management's completion of a Supplemental Environmental Project.

9_ Any notice and procedures which might otherwise be authorized or required in this action are waived in the interest of a more timely resolution of the matter.

10. The Executive Director of the TCEQ and Waste Management have agreed on a settlement of the matters alleged in this enforcement action, subject to the approval of the Commission.

11. Tl;1e Executive Director recognizes that Waste Management has implemented the following corrective measures at the Landfill in response to this enforcement action:

a. On or before February 13, 2002, repaired or replaced three leachate collection sump pumps;

b. On or before February 13,2002, leachate levels were reduced to less than 12 inches above the landfill liner in all Subtitle D lined cells;

c. On or before February 26, 2002, sealed a flange on a pipe leading from a leachate collection sump;

d. On or before April 8, 2002, installed temperature gauges on, and began recording monthly temperature readin~s for,landfill gas collection Well Nos. 38, 39, 40,42, 43 and 44;

COA Exhibit JW-4 TCEQ Enforcement Action Agreed Order SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 2 of 16

WM-VE-0000880

Waste Management of Texas, Incorporated DOCKET NO; 2002·0935·MLM·E Page 3

e. On or before April 23, 2002, completed the installation ofapproximately 3,000 feet of additional silt fencing;

f. On or before May 1,2002, implemented a procedure for ha:ndling waste streams which have a high odor potential. Specifically, these waste streams are either redirected to an alternate landfill facility or are covered immediately upon arrival;

On or before May I, 2002, completed the installation of14 additional, and replaced 3, landfill gas colle~tion we~ls and approximately 2,800 feet ofhorizontal piping;

On or before May 1, 2002, began operation of the portable odor-neutralizing system along the southeast corner of the Landfill;

On or before August 31, 2002, completed removal of sediment from on-site channels and ditches along the southwester~ side of the LalldfJlI;

On or before February 2002, suspended use of alternate daily cover except in emergency situations;

On or before July 2002, completed relocation and upgrade of the flare system to increase operating effectiveness; .

On or before July 2002, instalied three additional horizontal gas wells;

On or before August 2002, installed and began operation ota permanent odorneutralizing system covering 2200 feet on the southeast corner of the landfill;

n. . On or before November 2002, installed 12 new vertical. gas collection wells;

o. On November 22, 2002, submitted the semi-annual deviation report for the period from April 2, 2002, to October 2, 2002;

p. . On May 1, 2003, submitted annual reports for 2001 and 2002 containing information on monitored parameters for the gas collection system; and

q. On June 23, 2003, ~ubmitted the semi-annual deviation report for the period from April 2, 2001, to October 2, 2001.

12. The Executive Director may, without. further notice or hearing, refer this matter to the Office of the Attorney General of the State of Texas ("OAG") for further enforcement

• COA Exhibit JW-4 TCEQ Enforcement Action Agreed Order SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page30ft&

WM-VE-0000881

Waste Management of Texas, Incorporated DOCKET NO.2002-0935-MLM-E Page 4

proceedings ifthe Executive Director determines that Waste Management has not complied with one or more of the terms or conditions in this Agreed Order.

13. This Agreed Order shall terminate five years from its effective date or upon compliance with all the terms and conditions set forth in this Agreed Order, whichever is later.

14. The provisions of this Agreed Order are deemed severable and, if a court of competent jurisdiction or other appropriate authority deems any provision of this Agreed Order unenforceable, the remaining provisions shall be valid and enforceable.

II. ALLEGATIONS

Waste Management, as owner and operator of the Landfill, is alleged to have violated:

1. 30 TEX. ADMIN. CODE § 330.111 by deviating from an operational requirement in the Landfill's site operating plan by allowing the leachate head to rise more than 12 inches above the landfill liner, as documented during an investigation conducted on. February 4, 2002;

2. 30 TEX. ADMIN. CODE § 113.2061(a), 40 CODE OF FEDERAL REGULATIONS (C.F.R) § 60.753(b) and TEX. HEALTH & SAFETY CODE § 382.085{b) by failing to operate the landfill gas collection system such that negative pressure was continuously maintained at each wellhead, as documented during an investigation conducted on February 4, 2002;

3. 30 TEx. ADMIN. CODE § 113.2061{a), 40 C.F.R § 60.753{c) and TEX. HEALTH & SAFETY CODE § 382.085(b) by failing to operate each interior wellhead such that the landfill gas contained either a nitrogen level of less than 20 percent or an oxygen level of less than 5 percent, as documented during an investigation conducted on February 4, 2002;

4. 30 TEX. ADMIN. CODE § 113.2061{a), 40 C.F.R § 60.755(a)(5) and TEX. HEALTH & SAFETY CODE § 382.085{b) by failing to monitor Well Nos. 38, 39, 40, 42, 43 and 44 monthly for temperature from January 1, 2001, through December 31, 2001, as documented during an investigation conducted on February 4,2002;

5. 30 TEx. ADMIN. CODE § 101.7, now 30 TEX. ADMIN. CODE § 101.221{a), and TEX. HEALTH & SAFETY CODE § 382.085(b) by failing to operate all pollution emission capture equipment and abatement equipment in good working order and operating properly during facility operations, as documented during an investigation conducted 0'0 February 26, 2002. Specifically, Waste Management failed to seal a flange on a leachate sump pipe;

COA Exhibit JW-4 TCEQ Enforcement Action Agreed Order SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 4 of 10

WM-VE-0000882

Waste Management of Texas, Incorporated DOCKET NO. 2002-093S-MLM-E PageS

6. 30 TEx. ADMIN. CODE § 101.4, and TEX. HEALTH & SAFETY CODE § 382.085(b) by discharging one or more air contaminants in such concentrations and for such duration so as to interfere with the nonnal use and enjoyment of property, as documented during an investigation conducted on April 4, 2002;

7. TEX. WATER CODE § 26. 121(a)(2) by allowing an unauthorized discharge of waste into or adjacent to any water in the state, as documented during an investigation conducted on March 28, 2002. Specifically, a TCEQ investigator observed accumulations of sediment and landfIll debris in drainage channels that flow into unnamed tributaries of Walnut Creek.

8. 30 TEX. ADMIN. CODE §§ 122.145(2)(c) and 122.146(5)(c), and TEX. HEALTH & SAFETY CODE. § 382.085(b) by failing to submit a semi-annual deviation report for the period from April 2, 2001, until October 2,2001, and from April 2;2002, until October 2,2002, and by failing to include information concerning all deviations on the annual compliance certification, as documented during a record review conducted between July 9, 2003, and August 10, 2003; .

9. 30 TEX. ADMIN. CODE § 122.165(a)(7) and TEX. HEALTH & SAFETY CODE § 382.085(b) ..by failing to include a certification of accuracy and completeness in the deviation report submitted November 22,2002, as documented during a record review conducted between July 9, 2003, and August 10,2003; and

10. 40 C.F.R § 60.757(f) by failing to submit an annual report containing information on monitored parameters for the gas collection system for the years 2001 and 2002, as documented during a record review conducted between July 9, 2003, and August 10, 2003.

III. DENIALS

Waste Management generally denies each allegation in Section II ("Allegations").

IV. ORDER

1. It is, therefore, ordered by the TCEQ that Waste Management pay an administrative penalty as set forth in Section I, Paragraph 8 above. The imposition of this administrative penalty and Waste Management's compliance with all the terms and conditions set forth in this Agreed Order resolve only the allegations in Section D. The Commission shall not be constrained in any manner from considering requiring corrective action or penalties for violations which are not raised here. Administrative penalty payments shall be made

COA Exhibit JW-4 TCEQ Enforcement Action Agreed Order SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW

t-------------------·---------."p~agrl'J'er!'!lr-rOlf"ftfIOr----------

WM-VE-0000883

i

Waste Management of Texas, Incorporated DOCKET NO. 2002·093S-l\fi.,M·E Page 6

payable to "Texas Commission on Environmental Quality" and shall be sent with the notation "Re: Waste Management ofTexas , Incorporated, Docket No. 2002-0935-MLME"~: .

Financial Administration Division, Revenues Section Attention: Cashier's Office, MC 214 . Texas Commission on Environmental Quality P.O. Box 13088 Austin, Texas 78711-3088

2. Waste Management shan implement and complete a Supplemental Environmental Project (SEP) in accordance with· TEX. WATER CODE § 7.067. As set forth in Section I, Paragraph 8, one hundred twenty-two thousand two hundred ten dollars ($122,210.00) of the assessed administrative penalty shall be offset with the conditionthatWaste Management implement the SEP defined in Attach,ment A, incorporated herein by reference. Waste Management's obligation to pay the conditionally offset administrative penalty assessed shall be discharged upon final completion of all provisions of the SEP agreement.

3. The provisions of this Agreed Order shall apply to and be binding upon Waste Management. Waste Management is ordered to give notice of the Agreed Order to personnel who maintain day.:to-day control over the Landfill operations referenced ill'this Agreed Order.

4. This Agreed Order, issued by the Commission, shall not be admissible against 'Waste Management in a civil proceeding, unless the proceeding is brought by the OAG to: (1) enforce the terDls of this Agreed Order; or (2) pursue violations of a statute within the Commission's jurisdiction, or of a rule adopted or an order or permit issued by the Commission under such a statute.

5. Under 30 TEX. ADMIN. CODE § 70. 10(b) and TEX. GOV'TCODE § 2001.142, the effective date of this Agreed Order is the date ofhand-delivery of the Order to Waste Management, or three days after the date on which the Commission mails notice of the Order to Waste M~gement, whichever is. earlier. The Chief Clerk shall provide a copy of this Agreed Order to each of the parties.

COA Exhibit JW-4 TCEQ Enforcement Action Agreed Order SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW ,"age 6 of 10

WM-VE-0000884

Waste Management of Texas, Incorporated DOCKET NO. 2002-093S-MLM-E Page 7

SIGNATURE PAGE

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY

~~ Fo e COmIDlSSIOn

I, the undersigned, have read and understand the ·attached Agreed Order. I am authorized to agree to the attached Agreed Order on behalf of the entity, if any, indicated below my signature, and I do agree to the terms and conditions specified therein.

ClvM/~s D.Dees 71I Narne (printed or typed) Authorized representative of Waste Managem~nt of Texas, Incorporated

Ly .a GonzaIez Gromatzky rJ Deputy DiJector Office of Legal Servic.es Texas Commission on Environmental Quality

Instructions: Send the original signed Signature Page and all pages of this Agreed Order with penalty payment to the Financial Administration Division. Revenues Section at the address in Section IV. Paragraph I of this Agreed Order.

COA Exhibit JW-4 TCEQ Enforcement Action Agreed Order SOAH Docket No. 582-08-2186 TCEQ Docket No. '2006-0612-MSW Page I Of 10

WM-VE-0000885

Attachment A

SUPPLEMENTAL ENVIRONMENTAL PROJECT

The Texas Commission on Environinental Quality ("TCEQ") agrees to offset a portion of the administrative penalty assessed in this Agreed Order with the condition that Waste Managementof Texas, Incorporated ("Waste Management") shall perform and comply with the follewing Supplemental Environmental Project ("SEP") provisions. The totai amount of the conditional offset for the SEP, upon completion ac~ording to the terms and schedules listed below, shall be One Hundred Twenty-Two Thousand Two Hundred Ten Dollars ($12h21O.00) ofthe payable penalty ofTwo Hundred Forty-Four Thousand FoutJHundred Twenty Dollars ($244,420.00). .

1. Project Description

A. Project

Waste Management will contribute to Travis County, Texas. The contribution will be used in accordance with the Supplemental Environmental Project Agreeme!Jibetween Travis County and the Texas Commission on Environmental Quality. Specifically, Twenty-Five Thousand Dollars ($25,000.00) of the contribution will be used by Travis County to clean up illegal dump sites located in Travis County within a three mile radius of the Austin Community Recycling and Disposal Facility, located at 9900 Giles Road in Austin, Travis County, Texas. The dump sites selected by .Travis County shall be sites on public lands where Travis County bas been unable to stop illegal dumping despite making reasonable efforts to do s6, and where no responsible party is available to clean up the property. The remaining SEP funds will be used for the Travis County Walnut Creek Erosion Control Project. All dollars contributed will be used solely for the direct cost of the SEP project nnd no portion will be spent on administrative costs. The SEPwill be done in accordance with all federal, state and local environmental laws and regulations.

'. Waste Management certifies that there is no prior commitment to make this contribution and that it is being done solely in an effort to settle this enforcement action.

This SEP will provide a discernible environmental benefit by removing and properly disposing of municipal solid wastes and household hazardous wastes from the environment that could contaminate water supplies. In addition, this SEP will provide a discernible environmental benefit by greatly reducing diseases transmitted by contaminated water supplies and non-point source pollution of ground and surface waters from raw sewage.

B. Minimum Expenditure

The offset of One HundredTwenty-Two Thousand Two Hundred Ten Dollars ($122,210.00) of the administrative penalty is based UpOD. Waste Management's agreement to contribute One Hundred Twenty-Two ThousandTwo Hundred Ten Dollars ($122,210.00) to the project described above and to comply with all other provisions of this SEP.

GOA Exhibit JW-4 TGEQ Enforcement Action Agreed Order SOAH Docket No. 582-08-2186 TGEQ Docket No. 2006-0612-MSW

+-----------------------------------,P-r.a=ge 8 0110 .

WM-VE-0000886

Waste Management of Texas.' Incorporated AGREIID ORDER . AUBchment A

2. Performance Schedule

Within 30 days after \he effective date of this Agreed Order, Waste Manageme~t will pay. the required contribution to Travis County, Texas; The contribution, with a copy of the Agreed Order, will be mailed to: .

The Honorable Samuel T. Biscoe Travis County Judge 314 West 11 th Street Suite 520 Austin, Texas 78701

3. Records and Reporting

Concurrent with the payment-of the SEP contribution, Waste Management shan provide the TCEQ SEP Coordinator with a copy of the check and transmittal letter indicating full payment of the contribution to Waste Management. A copy of the check and transmittal letter will be mailed to:

Litigation Division Attention: SEP CoordinatOr,MC 175 Texas Commission on Envirownental Quality, . P.O. Box 13087 Austin, Texas.78711-3087

4. Failure to Fully Perform'

If Waste Mahagerront does not perform its obligations under this SBP in any way, including full expenditure of all required funds and the submittal of adequate reports, the Executive Director may require immediate payment ofall or part of the One Hundred Twenty-Two Thousand Two Hundred Ten Dollars ($122,210.00) conditionally offset.

The check for any amount d!Je shall be made out to ''Texas Commission on Environmental Quality" and mailed to: .

Texas Commission on Environmental Quality Financial Administration Division, Revenues Attention: Cashier, MC 214 P.O. Box 13088 Austin, Texas 78711-3088

A copy of the check shall be mailed to the TCEQ SEP Coordinator at the address in Section 3 above.

A-2

COA Exhibit JW-4 TCEQ Enforcement Action Agreed Order SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Palle 9 9f1~

WM-VE-0000887

I

" Waste Management of Texas, Incorporated AGREED ORDER Attachment A

5. Publicity

Any public statements concerning this SEP made by, or on behalf of, Waste Management must includea clear statement that the project was performed as part of the settlement of an enforcement action brought by the TCEQ. Such statements include, but are not limited to, advertising, public relations, and press releases.

6. Clean Texas Program

Waste Management shall not include this SEP in any application made to TCEQ under the "Clean Texas" (or any successor) program(s). Similarly. Waste Management rnay not seek recognition for this contribution in any other state or federal regulatory program.

7. Other SEPs by TCEO or Other Agencies

The SEPidentified in this Agreed Orderhas notbeen, and shall not be, included as an SEP forWaste

\ Management under any other Agreed Order negotiated with the TCEQ or any other agency of the state or federal government. '

~

A-3

COA Exhibit JW-4 TCEQ Enforcement Action Agreed Order SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW

-----o-pa.ng""enlrno"'O~''t1'O'l-----------·-

WM-VE-0000888

• April 10,2008

The Honorable Roy Scudday State Office of Administrative Hearings 300 West 15th Street, Suite 504 Austin, Texas 78701

RE: Docket # 582082186, Waste Management ofTexas. Inc. Contested Case Hearing

Dear Judge Scudday:

In late 2005, the Solid Waste Advisory Committee (SWAC) of the Capital Area Council of Governments (CAPCOG) completed a review of the application for a Permit Amendment by Waste Management ofTcxas, Inc. to expand their facility at 9708 Giles Road based on the following factors:

• Land Use Compatibility • Conformance with the Regional Solid Waste Management Plan (RSWMP) • Local Facility Siting Concerns

• In January 2006, the CAPCOG Executive Committee voted to concur with the SWAC determination that the Waste Management of Texas, Inc. (WM) application was, not compatible with land ,use in the area, would not conform with the RSWMP, and that there were significant local concerns about the site. The Executive Committee also supported Travis County request that the WM facility cease operations by November 2015, and that WM include adequate buffer zones and other safeguards around any new landfills in the eastern portion of Travis County. On January 31, 2006, CAPCOG submitted a letter and documentation to Texas Commission on Environmental Quality (TCEQ) notifYing the TCEQ ofthe non-confonnance determination, a copy of which is attached.

In light of the upcoming contested case hearing regarding this matter, the CAPCOG Executive Committee voted again on April 9, 2008 to reaffirm the previously submitted CAPCOG determination of non-conformance, and the additional Travis County requests. At this time, CAPCOG respectfully resubmits the non-conforma'nce determination for your consideration.

Enclosures

co: Office of the Chief Clerk, TCEQ Judge Sam Biscoe, Travis County Ms. Brenda Foster, Waste Permits Division, TCEQ Mr. Steve Jacobs, Waste Management ofTexas, Inc.

COA Exhibit JW·5 • CAPCOG Determination of Nonconfonnance SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 1 of 8

•

•

)

C3p11at Area Couneil of Gonrnments 2li121H 35 SOuth, Suita 200 Austin. Texas 78704 512.916.6000' Fax512.918.8001 1'IMlf.c:apeag.nlg

J8lIWIrY 31, 2006

Richard C. Cannicbael, Ph.D., P.E. Mauager, Municipal Solid Waste Permils Section Waste Permits Division (MC 124) Texas Commission on Bnvil'Omnental Quality P.O. Box 13087 Austin, TX 78711-3087

RB: Waste Mauagcmcnt of TCl<as, Inc. Application for Permit Amendn1ent

Dear Mr. Carmichael.:

The Solid Waste Advisory Committee (SWAC) of the Capital Area Coaoeil of Govemmcmts (CAPCOG) bas reviewed the application for a Permit Amendment by Waste Management ofTexas, IDe. to.expand their facility at 9708 Giles Road based on the following factors:

• Land Use Compatibility • ConfOIDlaIlce with the RSWMP • Local Facility SitiDg Co=

The SWAC bas made the determination that the proposed expansion of this facility will not conform with Cuneot and future land use.in that area and furthermore,. there are significant local concerns about the site as indicated in the attached commcnlll submittedby Travis County, thehost local government ofthis projeeL Travis County has also outlinedsteps which could be taken by the applicaDt to address their coocerns: to terminate operation: of that tilciIity beyond November 2015 and to include adequate buffer zones and othtz safeguards around any new landfill sites ill the easternpartian of that County.

The CAPCOG BxeClltiw Committee agrees with the SWAC's determination of nonconformance and supports Travis County tequest for termination ofoperation in 2015 and the inclusion ofbuffer zones and other steps which maybe necessary so as to avoid incompatible land use. Therefore, the CAPCOG Bl=utive Committee voted on January 10,2006 to notify TCEQ that the Waste Mauagement ofTexas, me. pennit amendment application does not conform with the RSWMP currently being considered for adoption by TCEQ•

• COA Exhibit JW-5 CAPCOG Determination of Nonconformance SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 2 of 8

• CAPCOG Conformance Determination on the Waste Management of

Texas, Inc. MSW Permit Amendment Application

As provided on p. 34 ofthe Regional Solid Waste Management Plan that was approved by the CAPCOG Executive Committee on July 10; 2002, Waste Mauagement of Texas' application for expansloD of the Austiu Community Landfill does Dot conform for the following reaSODS:

1. Consideration will be given to confonnance with the goals and objectives of the Regional Solid Waste Management Plan. The application does not confono to "Goal #!7: Bnsure the proper management ofdisposal ofmunicipal solid waste." Specifically, the application does not confonn to this requirement in the following respects:

• "rrack and understand compliance histories ofall MSW facilities and MSW facility operators in the region."

• TCEQ assessed the applicant the highest fine ever assessed to a MSWoperator. These serious violations resulted in nuisance odors that affected neighbors and communities. Given applicant's history ofserious violations, there is a risk: offuture violations, and the applicant must demonstrate that it has taken steps to mitigate this risk. The applicant's Confonnance Checklist demonstrates no more than a winingness to comply with TCEQ minimum requirements. This is insufficient to mitigate the risk offuture violations that may result in nuisance conditions.

• "Promote siting and management offa.cilities that does not pose a nuisance to neighbors and communities:'

Adjacent land owners will suffer visual, olfactorY. and other impairments to the use and enjoyment oftheirprivate property rights from the expansion ofthe landfill. The applicant bas a history ofserious violations that resulted in nuisance odors that affected neighbors and communities. The applicant's Conformance Checklist states that there are 1163 residences within one mile of the site. Moreover, the site is in the community's preferred growth corridor, known as the Desired Development Zone. In terms of siting facilities to avoid nuisances to neighbors and communities, this site is a poor choice. Section 2.10 ofthe Confonnance Checklist requires the applicant to demonstrate that it has addressed the risk ofnuisance conditions. The applicant states that it will prepare a Site Operating Plan in the future. This is an inadequate response to the Checklist.

• COA Exhibit JW-5 CAPCOG Determination of Nonconformance SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 3 of8

• 2. Consideration will be given to proposed methods ofoperation. Specifically, the

application does not eonfonn to this requirement in the following respects:

• .TCEQ assessed the applicant the highest fine ever assessed to a MSW operator. Given applicant's history of serious violations, there is.a risk of future violations, and the applicant must

, demonstrate that its methods of operation mitigate this risk. Section 2.10 ofthe Conformance Checklist requires the applicant til demonstrate that it has addressed the'risk ofnuisanee conditions.TheaPplicant'S response to the Conformance Checklist

',demonstrates no more than a willingness to comply with TCEQ minimum operating requirements. This is insufficient to mitigate the risk of future violations that may result in nuisance conditions..

3. Consideration will be given to the compliance history ofthe company. Specifically, the application does not conform to this requirement in the following respects:

• • TCEQ assessed the applicant the highest fine ever assessed to a

MSW operator. Given applicant's history ofseriouS violations, there isa risk of future violations, and the applicant must demonstrate that its methods of operation mitigate this risk. The applicant's Conformance Checklist demonstrates no more than a. willingness to comply with TCEQ minimum operating requirements. This is insufficient to mitigate the risk of future violations that may result in nuisance conditions.

4. Consideration will be given to t!?-e general compatibility of the proposed facility with surrounding land use. Specifjcally, the application does not conform to this requirement in the following respects:

• The facility is within the Desired Development Zone of the City of AUstin and is adjacent to numerous homes, schools, historic sites, and other sensitive receptors. Specifically, the applicant's Conformance Checklist states that there are 1163 residenceS within onemile ofthe site. The land uses surrounding the site are incompatible with ongoing waste disposal activities. Moreover, Section 2.12 of the Conformance Checklist requires the applicant to provide documentation from local governments that the site is not incompatible. The applicant has not provided this documentation.

2

• COA Exhibit JW-5 CAPCOG Determination of Nonconformance SOAH Docket No. 582-08·2186 TCEQ Docket No. 2006-0612-MSW Page 4 of 8

• As provided on p. 37 of tbe Regional Solid Waste Management Plan that was approved by the CAPCOG Executive Committee on January 10, 2005, Waste . Management ofTexas' application for expansion oftbe Austin Community Landfill does not conform for the following reasons:

1. "Ensure that the use ofa site for a MWS facility does not adversely impact human health or the environment by evaluating and determining impact ofthe site upon counties, cities, communities, groups ofproperty owners, or individual in tenns of compatibility ofland use, zoning in the vicinity, community growth patterns, and other factors associated with the public interest"

•

• The facility is within the Desired Development Zone ofthe City of Austin and is adjacent to numerous existing...,..-and future-homes, schools, historic sites, and other sensitive receptors. Specifically, the applicant's Conformance Checklist states that there are 1163 residences within one mile of the site. In terms ofsiting facilities to avoid nuisances to neighbors and communities, this site is a poor choice. The existing and future land uses surrounding the site are incompatible with ongoing waste disposal activities. Applicant's Confonnance Checklist refers to a land use anaLysis. butthis provides CAPCOG and the TCEQ only with a "snapshot" view of the land use conditions existing as of today and not an analysis of ~ patterns as required by both the Conformance Checklist and TCEQ rules. Moreover, the applicant's Confonnance Checklist provides no documentation regarding compatibility from appropriate governmental agencies as required by Section 2.12 of the checklist. Applicant refers to a site plan and final plat, but these documents do not address compatibility issu.es.

2. "Ensure that MSW facilities comply with local zoning requirements, siting ordinances, and other local government land use regulations."

• The applicant has not provided the documentation required by Section 2.8 of the Checklist confirming that the applicant can obtain site development plan approval from the City ofAustin and Travis County.

3. "Ensu.re that MSW facilities' impacts on roads, drainage ways, and other infrastructure are assessed, that both existing and planned future land uses near the facility are considered, and that infrastructure problems created by the facility and the potential for land use conflicts between MSW facilities and exiSting and planned development are fitlly and adequately taken into account and addressed."

• Applicant's coordination with local governments regarding infrastructure has been minimal. The applicant is proposing only to meet TCEQ-required minimum practices. Travis County and the

3

COA Exhibit JW-5• CAPCOG Determination of Nonconformance SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 5 of8

• City ofAustin are responsible for streets, drainage, and other infrastructure in the area surrounding the site. and are governmental entities from which the applicant must obtain documentation regarding infrastructure issues as requied by Section 2.11 ofthe Checklist.

4. "Ensure that MSW facilities are good neighbors, by assessing and considering every applicant's five-year compliance history in Texas to the fullest extent allowed by TCEQ."

• TCEQ assessed the applicant the highest fine ever assessed to a MSW operator. These serious violations resulted in nuisance odors that affected neighbors and communities. Given applicant's history ofserious violations, there is a risk of future violations. and the applicant must demonstrate that it has taken steps to mitigate this risk. The applicant's Conformance Checklist demonstrates no more than a willingness to comply with TCEQ minimum requirements. This is insufficient to mitigate the risk of future violations that may result in nuisance conditions.

• 5. ''Encourage programs that provide incentives for using landfills instead ofillegal dumping including but not limited to conducting and increasing awareness of community cleanup events, efforts to curtail illegal dumping, litter abatement and waste reduction programs, public education programs, lower rates for waste collection events, etc."

• The applicant's response to Section 2.2 of the Conformance Checklist mentiops work with a couple ofanti-litter groups and makes a vague reference to work with City ofAustin and Travis County, but fails to descn'be any real program or plan to systematically address this issue. This is an inadequate response to the Checklist.

6. "Avoid ifpossible, or minimize ifavoidance is not posSJ'ble, concerns about visual and aesthetic impacts for MSW facilities on adjacent land uses by incorporating "context sensitive" design, appropriate buffers and setbacks into facility design,. Ensure that operators take reasonable and appropriate steps to avoid such impacts if possible or minimize them ifcomplete avoidance is not possible."

• The applicant's response to Section 2.13 ofthe Conformance Checklist states only that will consider or address these issues in the future. Section 2.13 clearly requires the application to address these issues at the time ofthe conformance review. A statement that the applicant will address these issues in the future is inadequate.

4

COA Exhibit JW-5• CAPCOG Determination of Nonconformance SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 6 of 8

• •

• 7. "Address lor;:alland use concerns about the long term. and cumulative effects ofMSW

facilities and protect the public interest in a natural landscape, avoid ifpossible, or , minimize ifnot possible, major disruptions to the landscape and other adverse long term and cumulative effects by ensuring that the permitted and maximum potential (theoretical geometric calculation )height and capacity of a MSW facility are accurately calculated and taken into account"

• The applicant's response to Section 2.15 of the Conformance Checklist fails to assess how the natural landscape is impacted by increasing the elevation ofthe natural ground at the site to an elevation of740 feet above MSL. The applicant's statement that the new facility will be no higher than the existing .facility is not an adequate assessment.

8. "Avoid ifpossible, or minimize if avoidance is not possible, nuisance conditions associated with MSW facilities that generate community concerns by ensuring that applicants implement reasonable and appropriate measures and best management practices to prevent and control litter, storrnwater runoff, vectors, odor, excessive noise, light pollution, and other nuisance conditions."

The facility is within the community's preferred growlh corridor, or Desired Development Zone, and is adjacent to nwnerous existing and planned homes, schools, historic sites, and other sensitive receptors. Specifically, the applicant's Conformance Checklist states that there are 1163 residences within one mile of the site. hi. terms ofsiting facilities to avoid nuisances to neighbors and communities, this site is a poor choice. The existing and :future land uses surrounding the site are incompatible with ongoing waste disposal activitieS. Furthermore, TCEQ assessed the applicant the highest fine ever assessed to a MSW operator. These serious violations resulted in nuisance odors that affected neighbors and communities. Given applicant's history ofserious violations, there is a risk of future violations, and the applicant must demonstrate that it has taken steps to mitigate this risk. The applicant's responses to Sections 2.10 through 2.15 of the Conformance Checklist demonstrates little or no coordination with local governments and states no more than that applicant will try in the future to comply with TCEQ minimum requirements. This is insufficient to mitigate the risk offuture nuisance conditions and does not satisfy the requirement ofthe ConfOllllance Checklist that the applicant address these issues at the time ofthe conformance review.

5

COA Exhibit JW-5• CAPCOG Determination of Nonconformance SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 7 of8

• The applicant can address the foregoing deficiencies in response to the Conformance Checklist in the following ways:

• The applicant must provide an adequate response to illegal dumping issues as required by Section 2.10 ofthe Conformance Checklist.

• Rather than simply stating that it intends to comply with TCEQ regulations in the future, the applicant must provide a plan for addressing the risk of nuisance conditions as required by Section 2.10 ofthe Conformance Checklist.

• The applicant must make a good faith effort to obtain the documentation from local governments regarding infrastructure issues as required by Section 2.11 ofthe Conformance Checklist.

• The applicant must make a good faith effort to obtain the documentation from local governments regarding land use compatibility as required by Section 2.12 of the Conformance Checklist.

• • Rather than simply stating that it intends to comply with TCEQ regulations in

the future, the applicant must provide an assessment ofand a plan for addressing the visual impacts as required by Section 2.13 through Section 2.15 ofthe Conformance Checklist.

Bullets added by Executive Committee in motion

• The applicant must agree that no landfill may be operated at the current site beyond November 2015.

• New landfills may be located in the Desired Development Zone if they include adequate buffer zones and other safeguards to avoid incompatible land use.

6

• COA Exhibit JW-5 CAPCOG Determination of Nonconformance SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 8 of8

• 1 Q. Pleas state your name.

2 A. Charles (Chuck) Lesniak

3 Q. Who is your employer?

4 A. City of Austin

5 Q. What department do you work for?

6 A. Watershed Protection and Development Review Department

7 Q. How long have you worked for the City?

8 A. Almost 19 years.

9 Q. I am handing you what's been marked as Exhibit CL-2. Do you recognize it?

• 10 A. Yes

11 Q. What is it?

12 A. My resume.

13 Q. Is the information contained in it true and correct?

14 A. Yes

15 Q. What are your job duties?

16 A. I work in a variety of areas, including pipelines, landfills, environmental

17 contamination (soil contamination, water pollution, environmental risk, etc.), and

18 environmental regulatory compliance. I provide technical assistance and advice in

19 these and other similar areas to the Watershed Protection and Development

20 Review Department and other City Departments.

21 Q. What type of studies/ analysis/review have you done?

COA Exhibit CL-1• Direct Testimony of Chuck Lesniak SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-06121MSW Page 1 of12

In relation to the WMI facility, I have assisted in complaint investigations and

responses to citizen complaints, performed site inspections, and led the City's

discussions with WMI regarding the monitoring of the Industrial Waste Unit.

How does your professional and educational experience relate to your

testimony and opinion in this matter?

I have a Bachelor of Science in Aquatic Biology and am the City of Austin's lead

staffer on abandoned landfills. I also have worked on many issues relating to

existing landfills and have a working knowledge of TCEQ Municipal Solid Waste

regulations. I have considerable experience as an investigator and as a technical

resource on City and private construction projects providing advice and

recommendations regarding erosion and sedimentation impacts and control

methodologies.

What is the purpose of your testimony?

To provide the best possible evaluation of the implications of the WMI landfill's

construction, operation, and closure to this site and the surrounding area in terms

of possible impacts to the environment, and in particular, surface. water quality.

My assessment is based on my prior experience in inspecting landfills,

constructions sites, and other similar facilities relative to their possible discharge

of pollutants. In addition, my assessment is based on my direct experience and

observations during visits to the WMI facility during pollution investigations and

facility inspections. My goal is to provide an evaluation of temporary and

permanent erosion and sedimentation controls, revegetation, and the overall

potential for pollution from the WMI facility"including the lWU, as part of an

COA Exhibit CL-1 Direct Testimony of Chuck Lesniak SOAH Docket No. 582-08-21116 TCEQ Docket No. 2006-0612lMSW Page 2 of 12

COA Exhibit CL-1 Direct Testimony of Chuck Lesniak SOAH Docket No. 582-08-21a6 TCEQ Docket No. 2006-061~SW Page 3 of 12

Yes. This site historically has had poor erosion and sedimentation control and, in

particular, poor revegetation of intennediate cover and problems with other

source control methodologies such as silt fencing, mulching, or limiting areal

coverage of disturbed soil. I have observed large areas of unvegetated or poorly

vegetated side slopes and "top deck" that are likely to have contributed to polluted

stonnwater runoff from the facility.

Can you identify what has been marked as Exhibit CL-3?

Yes. These are .aerial photos of the WMI landfill that is the subject of this

application that I researched using Google Earth. These are photos of the North

and South slopes of the WMI landfill from March of 2003. They illustrate

particularly well the poor erosion and sedimentation controls that have historically

occurred at the WMI landfill. The photos show significant erosion in the

intennediate cover and failure of the mid-slope erosion control benns. These

photos are typical of what I saw during my site visits to the· facility over the years.

Have you personally observed any erosion and sedimentation control

practices at the WMI facility that causes you concern with the granting of

this application?

Yes. During my site visit in January 2009 I observed a large amount of silt

fencing in use at the facility, presumably for erosion control. However, much of

this silt fencing was installed incorrectly or was inadequate in length to function

properly.

Over the years I have observed and been infonned by WMI personnel of what I

consider poor intennediate cover stabilization practices that, in my opinion, do

COA Exhibit CL-1 Direct Testimony of Chuck Lesniak SOAH Docket No. 582-08-21~6

TCEQ Docket No. 2006-061 ~SW Page 4 of 12

• not comply with the facility's TPDES pennit or City of Austin requirements and 90

91 are likely to create discharges with pollutants exceeding TPDES discharge limits

92 for Total Suspended Solids (TSS) and for sediment impacts to adjacent

93 waterways.

94 Q. I'm handing you what's been marked as Exhibit CL-4, do you recognize

95 them?

96 A. Yes. These are photos that I took during a site visit to the WMI landfill on

97 January 6, 2009. During that site visit, I observed that much of the silt fencing at

98 the base of slopes was installed parallel to the direction of water flow so that it

99 served no purpose. I also observed large areas of disturbed soil with little or no

100 source controls. These are pictures showing one of their silt fences installed

• 101 parallel to the direction of water flow, and a large unvegetated soil stockpile that I

102 believe had been in place for many months.

103 Q. Does the application mitigate your concerns regarding the poor erosion and

104 sedimentation control practices that you have seen occurring at this site?

105 A. No; the Erosion and Sedimentation Control Plan (Application Part III, Attachment

106 2, Section 4.0) nor any other part of the application or associated TPDES

107 Stonnwater Pollution Prevention Plan does not substantively improve upon the

108 current and historical erosion and sedimentation control practices sufficiently to

109 prevent the same kind ofproblems at the facility.

110 Section 4.1 says the figures in Part I/II of the application "describe in

111 detail. ..including sequencing of drainage and runoff controls, to ensure adequate

• 112 slope stability and limited erosion and soil loss." I was unable to find any detail

COA Exhibit CL-1 Direct Testimony of Chuck Lesniak SOAH Docket No. 582·08-21116 TCEQ Docket No. 2006-061:AJlSW Page 5 of 12

• 113 on temporary erosion and sedimentation controls in those figures except for one

114 temporary sedimentation pond shown in an area already occupied by already

115 partially constructed sedimentation/detention ponds and a plan note to grade to

116 drain to these ponds. So it appears the application is incorrect regarding the small

117 temporary pond. This section and others refer to "proposed" detention and

118 sediment ponds on the expansion area west boundary. These were partially

119 constructed some time ago illustrating that the application is out of date regarding

120 what are clearly the key surface water prevention controls for the expansion area

121 and adjacent portions of the facility. Furthermore, the application is lacking in

122 details regarding source or near-source erosion and sedimentation controls. It also

123 appears that the stormwater management system described in the application and

• 124 seen during my site visits relies primarily on "end of pipe" property boundary

125 controls to capture sediment prior to discharge from the facility during its active

126 waste disposal period.

127 Q. I'm handing you what has been marked as Exhibit CL-5? Can you describe

128 what it is?

129 A. Yes. These are photos that I took during July 2006 and January 6, 2009 site

130 visits to the WMI landfill. They demonstrate the "end of pipe" sedimentation

131 controls I was referring to. Specifically, in my photos you can see the very large

132 in-channel sedimentation basin on the south property line in the central drainage

133 way. The outfall from this structure showed significant sediment buildup during

134 both site visits.

COA Exhibit CL-1• Direct Testimony of Chuck Lesniak SOAH Docket No. 582-08-21 ~6

TCEQ Docket No. 20D6-061~SW Page 6 of 12

·, 135 Q. Do you have any other concerns regarding the erosion sedimentation control

136 practices at this site?

137 A. Yes. The primary control to prevent discharge of sediment laden water from the

138 expansion area is a sedimentation and biofiltration pond on the west edge of the

139 expansion area described in Section 4.1. These types of structures are generally

140 used for treating stormwater runoff from traditional, "hard" development with

141 parking lots, buildings, and landscaping. They are generally not used for

142 treatment of runoff from sites with large areas of disturbed soil like construction

143 sites or landfills. The biofiltration pond is very likely to be overwhelmed and

144 clogged up by the sediment load from the facility due to the extremely high TSS

145 load in stormwater runoff from the facility. The sedimentation and biofiltration

• 146 ponds may be appropriate for the facility once final cover is in place, but not

147 during its operation when stormwater runoff from the facility contains very high

148 sediment concentrations. The ponds will require very frequent maintenance,

149 including frequent rebedding of the filter media, during which time the pond will

150 not be operational. No specific maintenance plans or specifications for thd ponds

151 were found in the application.

152 Q. Why is it important to ensure that active landfills have adequate erosion and

153 sedimentation controls in place?

154 A. It is very important because operating landfills are in effect very large

155 construction sites with large areas of disturbed soil, often on steep slopes very

156 near the property boundaries. What is different about a facility like WMI's is that

they are "under construction" for long periods of time, often decades, whereas a

'. 157

COA Exhibit CL-1 Direct Testimony of Chuck Lesniak SOAH Docket No, 582-08-2111.6 TCEQ Docket No, 2006-0612/MSW Page 7 of 12

• 158 typical construction site is only under construction for a relatively short period of

159 time. This makes it even more critical to control erosion and sedimentation at an

160 operating landfill and comply with applicable stormwater regulations.

161 Specifically, WMI's TPDES permit contains a discharge limit of 100 mg/L TSS.

162 Without a very robust erosion prevention and sediment capture system from the

163 source areas to the property boundaries, it is highly unlikely, if not impossible,

164 that WMI can comply with or come close to complying with this discharge limit.

165 To realistically attempt to meet such a stringent requirement, in addition to the

166 described property boundary controls, the application should include detailed

167 plans for limiting areal coverage of disturbed areas, rapid revegetation and/or

168 . stabilization of disturbed areas, intermediate area controls (silt fences, berms,

• 169 matting, etc.) placed in series on slopes and ditches, irrigation plans, soil

170 specifications, maintenance schedules for temporary and permanent controls,

171 specific descriptions Of location and proper installation and use of controls, etc.

172 The WMI application does not contain such a system and it is very unlikely that

173 the facility can meet the TPDES permit requirements.

174 Q. Have you noticed any discrepancies between that application and what is

175 actually occurring at the landfill other than what you have already

176 mentioned?

177 A. Yes. During our January 2009 site visit no run-on prevention berms were seen

178 above the active waste face. The expansion application and presumably the

179 current permit include these important controls. Given WMI knew in advance of

our visit, it makes me doubt they would implement these controls in the expansion

•• 180

COA Exhibit CL-1 Direct Testimony of Chuck Lesniak SOAH Docket No. 582-08-21ll.S TCEQ Docket No. 200S-0S1~SW Page 8 of 12

area if the permit is granted. Also, the erosion and sedimentation controls

observed during my site visit were generally not consistent with those described

in the. application. For example, the expansion area sedimentation pond is

described as proposed, yet it is already built and the application plans show a

different, smaller pond in that location.

I'm handing what's been marked as Exhibit CL-6. Do you recognize it?

Yes, this is a picture I took of the top of the working face during the January 6,

2009 site visit. I took this picture to show that no run-on prevention berms were

seen above the active waste face.

Have you noticed any other discrepancies between that application and what

is actually occurring at the landfill?

Yes. Section 4.3.2.1 describes revegetation and mulching practices, however, no

topsoil or irrigation specifications are included. Past site visits and discussions

with WMI staff indicates that it is very difficult to establish vegetation on the

facility because available soil has little or no organic matter or nutrients and they

are completely dependent on rainfall to establish growth. Section 4.4.2 notes that

final cover soil will have a 6" layer of topsoil "capable of supporting native

vegetation". This seems to assume this would be necessary for good growth,

however, there is no such specification for intermediate cover soils. It has often

taken years beyond the allowed 180 days to get adequate revegetation of

intermediate cover. There is no evidence this was accounted for in the acceptable

soil loss calculations.

COA Exhibit CL-1 Direct Testimony of Chuck Lesniak SOAH Docket No. 582-08-21ll.6 TCEQ Docket No. 2006-061 tlMsw Page 9 of 12

Additionally, I was unable to fmd silt fencing described as a BMP in Section 4.3

(Erosion Control for Intennediate Cover); however, large amounts of silt fence

are currently in use at the facility and, although generally poorly placed, appear to

be one of the primary erosion control methodologies.

Section 4.3.2.1 says silt fences, rock benns, and soil benns will be "required"

around soil stockpiles. As I mentioned above when discussing Exhibit CL-4, only

incorrectly placed silt fence was noted around stockpiles during the January 2009

site visit and this is typical of observations during past site visits.

Did you review the soil loss calculations in the application?

Not the specific calculations, as I'm not an engineer, but I did review the text

description of the result of the calculations. Section 4.3.1 describes 60%

vegetation coverage for the intennediate cover and describes the acceptable soil

loss calculations. However, it doesn't indicate whether or not the calculations

take into account the 180 days allowed by the application for beginning

revegetation or the time necessary for growth during which time the erosive

potential would be much higher. In addition to the calculations probably being

inaccurate, the 60% coverage target doesn't meet City of Austin requirements and

is likely to result in erosion of the intennediate cover.

The TCEQ's Guidance for Addressing Erosional Stability During All Phases of

Landfill Operation states the operator is required to provide a "plan to minimize

erosion during all phases of landfill operations with the intent of controlling soil

loss and sediment transport from top dome surfaces and external embankment

side slopes." In my opinion, neither the facility conditions nor the documents I

COA Exhibit CL-1 Direct Testimony of Chuck Lesniak SOAH Docket No. 582-08-2.1~6

TCEQ Docket No. 2006-o6~SW Page 10 of 12

• 226

227

228

229 Q.

230

231 A.

232

233

234

235

236

• 237 Q.

238 A.

239 Q.

240

241 A.

242

243 Q.

244

245 A.

246

247

248

•

reviewed meet those· requirements because controls utilized at the facility focus

on catching sediment at the facility boundaries rather than preventing "soil loss

and transport".

Do you believe this application for permit amendment to expand the area of

the WMI landfill should be issued?

No. My review of the application and my past observations at the facility indicate

to me that continued operation of this facility is likely to chronically discharge

stormwater in violation· of their TPDES permit, and City of Austin discharge

limits and impact downstream surface water. This is particularly problematic

given the projected life of the facility until at least 2025 and should constitute a

basis for denial of the permit.

Have you reviewed the pre-filed testimony for the applicant in this case?

Yes. Specifically the prefiled testimony of Charles Dominguez.

Does the applicant's pre-filed testimony address the concerns which


No. In fact, the pre-filed testimony only reinforces my belief that the past poor

practices for control of sediment and erosion are very likely to continue.

Are there any other aspects of the WMI facility that you are concerned about

and that you believe should be considered relative to this application?

Yes. The facility contains a former hazardous waste facility known as the

Industrial Waste Management Unit, often referred to as the lWU. The IWU

received large quantities of spent acids and other hazardous wastes in the 1970's.

I helped negotiate an agreement with WMI that provided enhanced groundwater

COA Exhibit CL-1 Direct Testimony of Chuck Lesniak SOAH Docket No. 582-08-2166 TCEQ Docket No. 2006-061121MSW Page 11 of 12

• 249 monitoring and other protections for the IWU. While the negotiated agreement is

250 an improvement over the previous monitoring and management of the IWU, WMI

251 refused to include sampling and analysis of the groundwater between the IWU

252 and the drainage channel adjacent to the IWU's southern boundary. I believe this

253 presents a potential conduit for contaminated shallow groundwater to flow past

254 monitoring wells and off of the south boundary of the WMI facility.


256 A. Yes, however I reserve the right to amend or supplement my testimony as


•

' •. COA Exhibit CL-1 Direct Testimony of Chuck Lesniak SOAH Docket No, 582-08-2.1~6

TCEQ Docket No, 2006-061!2LMSW Page 120f12

• CHARLES LESNIAK: III, REM

SUMMARY OF QUALIFICATIONS

Eighteen years of experience with the City of Austin working on water quality issues, including five years of experience coordinating and overseeing the work of a team of environmental investigators. Broad range of experience and skills, including; environmental regulatory compliance (federal, srate and local), inter-agency coordination and issue resolution, multi-disciplinary technical review (surface water, groundwater, soil) and community outreach and education. Extensive e."<perience working with multiple City Departments at the executive level and City Boards and Commissions. Very familiar with the policies, regulations, and staff of many City, State and Federal agencies including the Texas Commission on Environmenral Quality, Texas Department of Transportation, Lower Colorado River Authority, US Environmental Protection Agency and the US Fish and Wildlife Service. Strong technical writing, public speaking and presentation skills.

WORK EXPERIENCE

• 2007-Present Envirol/mmtal Poliry Program Mal/ager City of Austin - Watershed Protection and Development Review Department, Austin, Texas

Responsible for advising the Watershed Protection and Development Review Department (wpDRD) and other City of Austin departments on regulatory and technical aspects of contaminated sites and remediation activities which are the City's responsibility or which may impact the City.

Coordinate with other Depanrnents, and local, State and Federal authorities on potential environmental risks and potential impacts of pipelines, landfills, and other high-risk land uses or activities.

Provide advice and recommendations on complex environmental regulatory and technical issues, including environmental risk assessment, contaminated site remediation, water quality protection, solid waste disposal facility operation, pipeline operations, and other high ris k facilities. Includes reviewing or preparing technical reports, memoranda, summaries of applicable regulations, site assessments, contracts, regulations Oocal, state, federal) and providing expert opinions and recommendations based on that review.

Prepares and provides briefings to the City Council and/Or Boards and Commissions on complex and sensitive environmental issues.

1999 - 2007 Environmental Program Coordinator

City of Austin - Watershed Protection and Development Review Department, Austin, Texas

• Provide environmenral technical expertise and assistance to many City Departments including Watershed Protection and Development Review,

COA Exhibit CL-2 • Chuck Lesniak's Resume SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 1 of 4

• C. Lesniak "age 2

Public Works and Transportation, Solid Waste Services, Parks and Recreation, and the Law Department. Major projects include the Longhorn Pipeline lawsuit, East Austin Tank Farm remediation, Mabel Davis Park landfill assessment and remediation, and Water Treatment Plant No. 4.

• Responsible for coordination with other City Departments and State agencies on a wide variety of environmental issues and developing solutions to address those issues. Coordinated and drafted an interDepartmental agreement on spill response with the Austin Water Utility. Led the development of a Spill Plan for the Barton Springs salamander to establish spill response policies for the Barton Springs Zone of the Edwards Aquifer and coordinate the activities of municipal and county agencies in the region.

• Regularly review a wide range of technical reports including environmental site assessments, groundwater monitoring reports, and remediation reports for completeness and regulatory compliance.

• Work with the City Manager, Asst. City Managers, Law Department, Dept. Directors and Asst. Directors and City Boards and Commissions on many local environmental issues such as the Longhorn Pipeline, East Austin Tank Farm and the WMI Landfill Industrial Waste Unit.

• • Routinely work with other staff in developing City ordinances and

polices. Worked as lead technical staff person in developing Austin's ordinance regulating developmen t along pipelines and City ordinance regarding development on abandoned and closed landfills.

1994 -1998 EnvironmtnfaiQuality Sp,cialiIf JIJ City of Austin - Watershed Management Department, Austin, Texas

• Team Leader for Spills and Complaints Response Program. Oversaw and coordinated the activities of 4 person team of pollution investigators. Assisted with budget and perfonnance measure development and tracking.

• Responded to and investigated hazardous materials spills and pollution complaints. Personally conducted over 2,000 pollution investigations.

• Directed spill response and remediations of all sizes and types, including remediation projects in excess of $500,000.

• Developed and managed abandoned hazardous waste disposal and remediation contracts ($50K/year), including writing bid and contract specifications.

• Designed and maintained computerized investigation report database of over 8,000 records, including management of programmer services contract.

• Assisted City departments in environmental regulatory compliance and developing environmental policy and procedures.

• Created and reviewed technical reports and correspondence.

• Developed and presented multimedia presentations to community organizations, business associations, boards, commissions, and City Council.

COA Exhibit CL-2 • Chuck Lesniak's Resume SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-Q612-MSW Page2of4

• C. Lesniak Page 3

• Developed and coordinated City's in ter-departmenral environmental justice initiative.

1992 - 1994 Environmmtal Qllaliry Specialist II City ofAustin - Drainage Utility Department, Austin, Te:tas

• Senior Investigator in Spills and Complaints Response Program.

• Responded to hazardous and non-hazardous materials spills.

• Investigated citizen pollution complaints regarding residential, industria~

commercial, and government activities, directing responsible parties in remediation and disposal activities.

• Provided technical assistance and direction to other City Departments to assist with compliance with loc~ State, and Federal environmental regulati~ns.

• Wrote and reviewed technical reports.

• Developed community education materials and gave numerous presentations to community and business organizations, including City Boards and Commissions.

• • Created and led the City's East Austin Environmental Initiative, an

initiative to coordinate and promote the City of Austin's environmental activities in East Austin and respond to the environmental concerns of this minority community. This project required extensive community relations work with neighborhood associations, East Austin businesses and environmental activist organizations.

1990 - 1992 EnvironmentalQualiry Specialist I City ofAustin - Environmental & Conservation Services Department, Aus tin, Texas

• Worked in multi-dimensional program that included spill and complaint investigation, storm~ter monitoring, and small business inspection.

• Responded to hazardous and non-hazardous materials spills, often as first responder.

• Provided technical guidance to emergency responders on environmental protection and regulatory compliance with local, State, and Federal laws.

• Investigated citizen pollution complaints regarding residential, industria~

commercia~ and government activities.

• Directed responsible parties in both spills and complaints in remediation and disposal of contaminated media.

• Operated and maintained automated stormwater samplers and collected samples during storm events.

• Inspected small businesses for compliance with pollution prevention regulations.

• Designed and programmed computerized database for investigation tracking and reporting.

COA Exhibit CL-2 • Chuck Lesniak's Resume SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 3 of 4

C. Lesniak Page 4

1989 Fitld Technician Texas Parks and Wildlife Commission. Austin. Texas

• Continued work on inscream flow project (see below) in cooperation with Lower Colorado River Authority.

• 20 hours per week while attending the University of Texas.

1988 - 1989 Fitld Techni,ian Lower Colorado River Authority. Austin, Texas

• Worked on instream flow/biological analysis project using a variety of hydrological and biological measurement techniques.

• Performed water sampling on Highland Lakes in ongoing water quality monitoring program.

• 20 hours per week while attending the University of Texas.

EDUCATION

1984 - 1989 University ofTexas Austin. Texas

Ba,htlor ofSriMa, A'll/ali, Biology

TR.\lNING

• • Hazardous Waste Operations and Response - Technician Level. 40 hour

• Confined Space Entry

• Effective Negotiating Skills

• Hazardous Materials Transportation

• Texas Environmental Law Seminars

ACCREDITATIONS

• Registered Environmental Manager #8025 - National Registry of Environmental Professionals

COA Exhibit CL-2 • Chuck Lesniak's Resume SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 4 of4

•

• Photo from Google Earth, dated March 2003, north slope ofWMI landfill.

• COA Exhl it CL·3 "'larch 2003 Coogle Eartn Aen I Photos S- AH Docket No. 5032·08-2\ 36 TCEQ Docket No 2006-0612-MSW P3g 1 of 2

•

• Photo from Google Earth dated March 2003, south slope of WMI landfill.

• :OA Exhlb.t CL-3 '" arcll 2003 Google Earth Aenal hOlOS S AH Docket No 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page2of2 7

•

• January 6, 2009, Soil stockpile to right and large area of unvegetated, disturbed soil to in background. Silt fence (arrow) at base of stockpile placed to direction of water flow,

• eOA Exhlbll (I -4 Jan ary 6, 2009 P,ct res of SCli SOA I Docket No, 532-08-2'186 TCEQ Docket No 2006-0612-MSW Page 1 of 2

•

• January 6,2009, soil stockpile showing downchute and long, steep slope.

• eOA Exh,blt CL 4 January 6 2009 PIctures of 50,1 SOAH Doc~et No 582-08-2186 TCEQ Docket No 2006-0612-MSW Page 2 of 2

•

• July 11, 2006. Outfall side of dam on central channel in-stream sedimentation basin.

• .::: A Exhibit CL-5 Pictures takan by': uc, LeSflla k SOAH Doc~el No. 582-08-21a6 TCEQ Docket No 2006-0612-MSW Pagt? 1 of?

•

• January 6, 2009, Outfall side of dam on central channel in-stream sedimentation basin .

• eOA Exhlbil CL-5 Pictures takerl by 1:; uck Le nlak SOAH Doc et No 5<32 -03-2136 TCEO Docket No 2006-0612-MSW P3ge 2 of 2

•

• January 6,2009, top of working face .

• CO,l. E'lh'bll CL·6 Plclllre taken by Chuck Lesnlal< SOArl Dockat I '0 582-08-21 Be Tl;EO Docket 1'10 2006-0612-MSW P3ge of 1

•

•

•

1 Q.

2 A.

3 Q.

4 A.

5 Q.

6 A.

7 Q.

8 A.

9 Q.

10 A.

11 Q.

12 A.

13

14 Q.

15 A.

16 Q.

17 A.

18

19

20

21 Q.

22 A.

23

Please state your name.

Thomas Franke

Who is your employer?

The City of Austin

What department do you work for?

Watershed Protection and Development Review Department

How long have you worked for the City?

8.5 years

I am handing you what's been marked as Exhibit TF-2. Do you recognize it?

Yes

What is it?

It is a summary resume of my education, qualifications and professional

experience.

Is the information contained in it true and correct?

Yes

What are your job duties?

1) Manage the design and construction of CGA-sponsored water quality treatment

projects; 2) Develop technical criteria for post-constrUction water quality and

construction phase controls; 3) Provide engineering support to all City

Department's regarding stonnwater management.

What type of studies/analysis/review have you done?

I have perfonned drainage and water quality engineering reviews of site and

subdivision construction plans to ensure compliance with the City of Austin

COA Exhibit TF-1 Direct Testimony oITom Franke SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 1 of 12

• Drainage Criteria and Environmental Criteria Manuals and the evaluation of24

25 sedimentation ponds to meet TPDES criteria.

26 Q. How does your professional and educational experience relate to your

27 testimony and opinion in this .matter?

28 A. I received a Bachelors of Science Degree in Civil and Environmental Engineering

29 from. the University of Wisconsin at Madison.

30 I am a registered Engineer In Training (# ET-29516) in the State of Texas.

31 I have worked over ten years as a landfill manager for two solid waste

32 management companies.

33 Q. What is your connection with the Application of Waste Management of

• 34

35

36 A.

Texas, Inc. for Municipal Solid Waste Permit Amendment No. MSW-249D.

that is the subject of this proceeding? ,

I am representing the City of Austin in my experience as a drainage and water

37 quality engineering reviewer and as a former landfill manager.

38 Q. What is the purpose of your testimony?

39 A. To provide my best assessment of the implications of this -landfill expansion on

40 the drainage system. My assessment is based on my prior experience in landfill

41 management, drainage and water quality review of the site plans that have been

42 submitted to the City of Austin, and my review of this application for a permit

43 amendment. I will, provide recommendations on methods to minimize soil loss

44 from the landfill, prevent off-site migration of sediment, minimize off-site

45 drainage impacts, and the inadequacy of the current erosion & sedimentation

• COA Exhibit TF-1 Direct Testimony oITom Franke SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 2 of 12

• controls to meet the Texas Pollutant Discharge Elimination System (TPDES) 10046

•

47

48 A.

49

50

51 A.

52 Q.

53 A.

54

55

56 Q.

57 A.

58

59 Q.

60 A.

61

62

63 Q.

64

65 A.

66

67

• 68

mg/l effluent benchmark value.

Have you reviewed the Application of Waste Management of Texas, Inc. for

Municipal Solid Waste Permit Amendment No. MSW-249D that is the

subject of this proceeding?

Yes.

What parts of the application did you review in particular?

I have reviewed the application, paying particular attention to volume II Part III,

attachment 2, Facility Surface Water Drainage Report. I also reviewed the

Stormwater Pollution Prevention Plan (SWPPP).

Why?

To determine the proposed provisions for drainage, water quality, and erosion

control.

Are you familiar with the proposed site?

I am familiar with the site. I have visited the site for a job interview in the spring

of 2000, during the site plan review process in 2004, and on January 6, 2009 as

part of this application process.

Did you have concerns about the WMI application for a permit amendment

that prompted a request for party status in the matter referred for hearing?

Yes. The facility surface water drainage report provided with the application does

not match the City of Austin site plan application that was approved on July 19,

2006. It is unclear which drainage report is correct.

essentially a long term construction project.

This landfill expansion is

Currently the erosion &

COA Exhibit TF-1 Direct Testimony ofTom Franke SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 3 of 12

• sedimentation controls proposed in this application and in the current SWPPP are 69

70 not designed for long term construction projects and the current sedimentation

71 and detention ponds are not effective in the removal of total suspended solids

72 removal. The current SWPPP needs to be updated to include the more robust

73 erosion & sedimentation controls that address the long term needs for this facility.

74 The proposed long term construction phase erosion & sedimentation controls need

75 to be submitted to the City of Austin Land Use Review staff for review and

76 approval.

77 Q. Have you reviewed the prefiled testimony for the applicant in this case?

78 A. Yes, I have reviewed the prefiled testimony of Charles G. Dominguez, P.E.

• 79

80

81

Q.

A.

Does the applicant's prefiled testimony address


No.

the concerns which

82 Q. Please state the remaining concerns not addressed in the applicants prefiled

83 testimony and suggest any special conditions that could be added to address

84 these concerns?

85 A. The pre-filed testimony does not address the following concerns: l)proper

86 installation and establishment of vegetative cover; 2)adequate perimeter controls

87 and sedimentation ponds to prevent off-site migration of sediment; 3) inclusion of

88 more robust erosion and sedimentation measures in the SWPPP; 4) discrepancies

89 between the hydrologic drainage calculations, FEMA 100 year floodplain

90 delineation, and hydraulic calculations associated with the drainage areas, down

• 91 chutes, and perimeter ditches on the site plan approved by the City of Austin on

COA Exhibit TF-1 Direct Testimony orrom Franke SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 4 of 12

• July 19, 2006; and 5) the sedimentation and detention/wetland mitigation ponds 92

constructed on the site do not match the ponds on the site plan approved by the

94

93

City of Austin on July 19,2006. The discrepancies between the site plan and the

95 application need to be rectified and either the site plan or permit updated to reflect

96 the correct values associated with the drainage areas, down chutes, and perimeter

97 ditches and to reflect the correct design of the sedimentation and

98 detention/wetland mitigation ponds.

99 Q. I am handing you what has been labeled Exhibit TF-3; do you recognize it?

100 A. Yes, this Exhibit is the erosion & restoration site plan (SP-05-1451D), approved

101 July 19, 2006 by the City of Austin, to construct two ponds at the WMI landfill

102 that is the subject of this application for a permit amendment.

• 103 Q. Can you be more specific regarding the discrepancies between the drainage

104 calculations on the site plan and application?

105 A. Yes, the concern is not with the methodology used to model the storm events, as

106 HEC-HMS is an acceptable hydrologic model per the City of Austin Drainage

107 . Criteria Manual, Section 2.3.0, Method of Analysis. Additionally, the concern is

108 not in regards to the methods used to determine the time of concentration, runoff

109 curve number, or drainage area acreages as these are acceptable methods per the

110 City of Austin Drainage Criteria Manual, Section 2.5.0. The concern is that the

111 peak flow values provided for drainage control points CP 1 through CP 16 for the

112 pre-developed and developed conditions for the 25 year, 24 hour and 100 year, 3

113 hour storm events in the site plan application that was approved by the City of

• 114 Austin on July 19, 2006 and the peak flow values provided for the 25 year, 24


• 115

116

117

118

119

120

121

122

123

124

125

• 126

127

128

129

130

131

132

133

134

135

136

• 137

hour and 100 year, 3 hour stonn events shown on pages 693 and 739 in Appendix

A of this application do not match. These discrepancies need. to be rectified and

the permitted site plan needs to be processed through the City of Austin

Development Assistance Center site plan correction process to ensure that the

drainage area maps, peak flows, HEC-RAS floodplain analysis, HEC-HMS

hydrologic models, and volume calculation tables are consistent.

Additionally, drainage control points CP17 and CP18 were not shown on the

approved site plan but are shown on the application. These discrepancies need to

be rectified and the permitted site plan needs to be processed through the City of

Austin Development Assistance Center site plan correction process to ensure the

drainage area map on the site plan shows the correct drainage control points and

includes the correct drainage calculations that match the application.

The above discrepancies are affected by numerous modifications in the drainage

areas or hydrologic elements, as labeled in the application, that affect the

downchute sizing design and perimeter ditch design. One example, site plan

drainage area W26 shown on sheet 10 and 11 has a drainage area of 3.84 acres

and a 100 year, 3 hour stonn equal to 23.8 cubic feet per second. On the other

hand, hydrologic element W26 on page 749 in Appendix A of the landfill

application has a drainage area of 0.007 square miles (4.48 acres) with a 100 year,

3 hour stonn equal to 36.4 cubic feet per second. Discrepancies in the flows from

the site drainage areas or hydrologic elements can greatly affect the design of the

down chutes and perimeter ditches and need to be verified to ensure they are

accurate and the correct values have been used in the design.


• 138 Also, the sedimentation and detention pond overflow werrs shown in the

139 application do not match those approved with the City of Austin' site plan. More

140 specifically, the overflow weir between the sedimentation and detention pond was

141 approved with the site plan to have a length of 90 feet and sheet ATT2-6 of the

142 application proposes a weir length of 70 feet. Additionally, the overflow weir

143 located at the outlet of the detention pond was approved to have a length of 45

144 feet and sheet ATT2-6 of the application is proposing a weir length of 43 feet.

145 These discrepancies will affect the stage-storage-discharge tables associated with

146 these ponds. These discrepancies need to be rectified and the permitted site plan

147 needs to be processed through the City of Austin Development Assistance Center

148 site plan correction process to ensure that the site plan matches the proposed

• 149 ponds and the associated stage-storage-discharge tables.

150 Q. Are there any other changes that should be made to the draft permit?

151 A. Yes. The draft permit should be amended to address the concerns mentioned

152 above. Specifically, WMI should place intermediate cover and temporarily

153 stabilize the cover over side slope areas that will not be disturbed for 60 days and

154 do the same for top. deck areas that will not be disturbed for 120 days. The top

155 deck areas should also include a buffalo grass sod vegetated filter strip from the

156 top of the downchute to 100 feet upgradient of the downchute and wide enough to

157 capture all runoff that flows down each downchute. The methods for establishing

158 vegetative cover should comply with the City of Austin's Environmental Criteria

159 Manual, Section 1.4.7. In addition, silt fences or mulch berms should be place at

• 160 the top of the side slope between the vegetated filter strip and the down chute, as

COA Exhibit TF-1 Direct Testimony otTom Franke SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 7 of 12

well as at the bottom of each downchute. Perimeter sedimentation controls (such

as silt fence, mulch berms, mulch) should be in place prior to establishment of

stockpiles. For piles that have slope lengths greater than 20 ft, a mid slope silt

fence/mulch berm should be installed within 14 days of establishment of the

stockpile. All side slopes with intermediate cover should have similar perimeter

controls installed within 14 days of installation of cover. The perimeter controls

should be at the base of all such slopes and on the top deck at a point before the

top of the adjacent slope. These changes should be included in an amended

SWPPP.

I am handing you what has been labeled Exhibits TF-4, TF-6, TF-7, and TF

8. Do you recogniie them?

Yes. Exhibit TF-4 contains three Total Suspended Solids (TSS) removal analyses

that I performed on the proposed sedimentation and detention ponds to model

particle settling analysis. Exhibits TF-6 through TF-8 are the references

associated with these analyses.

Can you describe the TSS removal analyses you performed in Exhibit TF-4?

These me three total suspended solids removal analyses using a hydraulic

efficiency value that models three types of pond systems, (1) very poor

performance, meaning a pond configuration that promotes short circuiting or

allows for sediment to move readily thru the pond to the outlet providing little or·

no settling conditions; (2) good performance, meaning a pond that is adequately

design to minimize short circuiting and promotes plug flow or ideal sediment

settling conditions, and; (3) very good performance meaning apond that promotes


• 184 plug flow or that maximizes sediment settling conditions. The values I used to

185 model the proposed ponds were conservative, meaning the analyses were

186 developed assuming that the ponds are maintained on a regular basis and very

187 little sediment is allowed to accumulate in either pond. These analyses

188 demonstrate that even if the proposed sedimentation and detention ponds as

189 proposed in the application achieve very good performance, they still are not

190 adequate to remove the amount of total suspended solids necessary to achieve the

191 TPDES 100 mg/l effluent benchmark value. Therefore, more robust erosion and

192 sedimentation controls are necessary during the long term construction of the

193 landfill.

194 The pond sizing information (average length, average width, maximum ponding

• 195 depth, slope, and average flow rate) used in these analyses were taken from the

196 pond information provided on sheet ATT2-6 and pages 653 and 654 in the

197 application, assuming both ponds are full at elevation 568.5 feet. I used the

198 calculated particle diameter, percent of total mass, and average settling velocity

199 information, shown in the analyses, as presented in Exhibit TF-6 the Cole and

200 Yonge, May 1993 report. I used the inflow total suspended solids value of 3,000

201 mgll as presented in Exhibit TF-7, the Barrett, et aI., June 1998 technical

202 document, and the hydraulic efficiency values and Fair and Geyer (1954) equation

203 as presented in Exhibit TF-8 the EPA, July 2006 document.

204 Q. Why did you rely upon the references in attached Exhibits TF-6 - TF-8?

205 A. Exhibit TF-6 is a report prepared for the Washington State Department of

Transportation for the design and maintenance of stormwater detention basins.

• 206


• 207 The City of Austin uses this report because the calculated particle diameters and

208 average settling velocities most closely match those found in construction runoff

209 within the Austin, Texas region. The City of Austin regularly uses this data to

210 model existing and future water quality retrofit ponds for sediment removal

211 efficiencies. Exhibit TF-7 is a technical document based on the results of a four

212 year study performed in Austin, Texas and provides region specific stormwater

213 TSS concentrations from various long term highway construction projects used to

214 better simulate local conditions during site construction. Exhibit TF-8 is an

215 Environmental Protection Agency publication used nationwide for the modeling

216 of stormwater best management practices (BMP).

217 Q. Do you have concerns related to erosion and sedimentation controls on the

• 218 site?

219 A. I have concerns that the amount of exposed soil will produce a sediment discharge

220 in excess of the benchmark values established by Texas Pollutant Discharge

221 Elimination System (TPDES), more than the proposed sedimentation and

222 detention ponds, measures in the application, and SWPPP can control. I have

223 concerns that the current application for permit amendment does not adequately

224 address revegetation of disturbed soils and control of sediment during the

225 construction phase of the landfill. Additionally, the site plan approved by the City

226 of Austin was reviewed only for erosion & sedimentation controls necessary to

227 construct the two ponds and not the proposed expansion for the length of this long

228 term construction project. The applicant must submit a site plan for review and

approval by the City of Austin Land Use Review staff that demonstrates

• 229


• 230 compliance with the erosion sedimentation control requirements necessary for a

231 long term construction project.

232 Q. Do you have concerns regarding the affect of this landfill on adjacent

233 property owners?

234 A. Yes. Residential areas that are adjacent to a landfill are subject to increased

235 localized flooding and degraded water quality if thestormwater is not properly

236 managed. Based upon the information provided in the application, I do not

237 believe that the landfill will be able to meet the TPDES 100 mg/l effluent

238 benchmark value; and as a result, neighboring landowners will suffer degraded

239 water quality.

240 Q. I'm handing you what's been marked as Exhibit TF-5. Do you recognize it?

• 241 A. Yes; this is a copy of the TPDES Multi Sector General Permit.

242 Q. What is the purpose behind the benchmark values established by Texas

243 Pollutant Discharge Elimination System?

244 A. Per the TPDES Multi Sector General Permit: Benchmark monitoring

245 requirements are included as a provision of this general permit for industrial

246 activities. The permittee must compare the results of analyses to the benchmark

247 values, and must include this comparison in the overall assessment of the SWPPP

248 effectiveness. Analytical results are indicators that modifications of the SWPPP

249 may be necessary. The Pollution Prevention Team must investigate the cause for

250 each exceedance and must document the results of this investigation in the

251 SWPPP within 90 days following the sampling event.

The Pollution Prevention Team inve'stigation must identify the following:

• 252


• 253 l) Any additional potential sources of pollution, such as spills that might have .

254 occurred,

255 2) Necessary reVlSlons to the Good Housekeeping Measures section of the

256 SWPPP,

257 3) Additional BMPs, including a schedule to install or implement the BMPs,

258 4) Other parts of the SWPPP for which revisions are appropriate.

259 Background concentrations of specific pollutants may also be considered during

260 the investigation. If the Pollution Prevention Team is able to relate the cause of

261 the exceedance to background concentrations, then subsequent exceedances of

262 benchmark values for that pollutant may be resolved by referencing the earlier

263 finding in the SWPPP. Background concentrations may be identified by

• 264 laboratory analyses of samples of storm water run on to the permitted facility, by

265 laboratory analyses of samples of storm water run-off from adjacent non

266 industrial areas, or by identifying the pollutant is a naturally occurring material in

267 soils at the site.




COA Exhibit TF-1 • Direct Testimony oITom Franke SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 12 of 12

• Thomas David Franke

EXPERIENCE

CITY OF AUSTIN, Austin, TX 5/00 - Present Watershed Protection and Development Review Department

Environmental Resource Management Division 2/06 - Present Water Quality Engineer Managed and provided technical assistance for the planning, design, permitting, construction, and implementation of structural and non-structural stormwater Best Management Practice projects. additional responsibilities included: development and implementation of technical criteria manual design specifications and technical training of engineering and environmental reviewers, inspection staff, and other City Departments. • Developed erosion and sedimentation criteria for the use of mulch socks, mulch berms. mUlching, and silt fence for

adoption by the City of Austin - Environmental Criteria Manual. September 2008. • Co-authored innovative water quality design criteria for biofiltration, rainwater harvesting, porous pavement, and rain

garden adopted by the City of Austin - Environmental Criteria Manual, June 2007. • Worked with Microsoft Office Project. Adams and Papa water quality modeling program, Ecapris Project Reporting

and Information System, AMANDA 4.4.21, and ArcGIS 9.3.

Land Use Review Division 5/00 - 2/06

• Drainage, Construction, and Water Quality Engineering Reviewed and approved land development plans for Engineering code compliance and feasibility, additional responsibilities included: field investigations, development and implementation of specifications, maintaining communications with developers, consultants, and·other City Departments. • Co-authored new Vegetative Filter Strip design criteria adopted by the City of Austin· Environmental Criteria Manual

January 2004. • Maintained 95% on time review of all projects. • Reviewed over 2500 site plan and subdivision land development applications for engineering compliance. • Accepted 350 additional review projects from other City review teams to assist in maintaining a consistent on time

record for the Watershed Protection Development Review Department. • Worked with HECI, HEC2, Haestad Methods Pond Pack, HEC-HMS, TR·20, HEC-RAS. and Modified Rational

Method water modeling programs.

TEXAS DISPOSAL SYSTEMS, INC., Austin, TX 11/98 - 12/99

Landfill Manager, Austin, TX Managed daily operations of a 1,000 acreJandfill that accepted over 1,800 tons per day, responsibilities included: environmental compliance, budget development and implementation, public, employee, community and customer relations. • Developed and implemented flTSt budget for facility. • Designed and initiated landfill compaction density tracking procedures. • Established site safety training program. • Created special waste approval and tracking system. • Conducted facility tours for over 300 visitors in 1999.

WASTE MANAGEMENT, INC., Oakbrook, IL 1988 -1998

Division President, Douglas County Landfill, Bennington, NE 11/92 - 1/98 Managed a landfill that accepted over 2,000 tons of solid waste per day, responsibilities included: employee, customer, community and public relations, government affairs, environmental compliance, budget development and implementation, equipment maintenance facility, Douglas County contract compliance. employee safety training and development, and special waste permitting and tracking process.

• eOA Exhibit TF-2 Tom Franke's Resume SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 1 of3

•

•

•

THOMAS DAVID FRANKE

• Increased profitability of division from 13% in 1993 to 28% in 1997. • Exceeded division financial goals four out of five years. • Negotiated a 46% increase in the contracted gate rate from Douglas County for additional costs incurred due to the

inception of Federal Subtitle D landfill regulations. • Introduced five types of Alternate Daily Cover which reduced the amount of daily soil used to cover the waste by 50%. • Setup contracts for site projects totaling over $1 million annually. • Increased landfill compaction density rate by 60%. • Worked with local citizens group and County representatives to introduce a bill to the Nebraska Unicameral to increase

the fines given for untarped vehicles traveling on State highways. Bill passed. • Created and implemented daily financial tracking system and daily operational management program to accurately

communicate current site status to regional management. • Hired, trained. and developed employee who was promoted to landfill manager within 3 years.

General Manager, Metro Transfer Station, Omaha, NE 1/97 ·11/97 Responsible for the management of a transfer station that accepted over 150 tons of solid waste per day, including business development and implementation, environmental compliance, employee relations and budget implementation. Assumed these duties in addition to that of Division President. • Reduced daily costs of operation by 20%. • Setup and managed a contract with the City of Omaha that resulted in an additional $100,000 in revenue.

Assistant General Manager, Omaha Recycling Facility, Omaha, NE 3/92 - 11/92 Responsible for management of daily transfer station and recycling operations and marketing of recyclable products. • Managed installation of $500,000 worth of upgrades to the City of Omaha Blue Bag recycling program. • Increased recycling diversion rate from 2% in 1991 to 5% in 1992.

Operations Manager, Lake Landfill, Northbrook, IL 4/90 - 3/92 Responsible for management of daily operations at a landfill that accepted over 8.000 tons of solid waste per day; additional duties inc! uded management of local Operating Engineers and Teamsters union contracts. • Implemented use of two types of Alternate Daily Cover which reduced the amount of soil used to cover the waste by

10% daily and saved $2,000 per day in operational costs. • Reduced union grievances by 50% by improving communication among employees, Teamsters, Operating engineers.

and Management. .

Operations Manager, Greene Valley Landfill, Naperville, IL 11/89·4/90 Managed and maintained a landfill that accepted over 1,500 tons of solid waste per day. Additional duties included field compliance with the Dupage County Forest Preserve operating permit. • Reduced grievances by 20% by strengthening teamwork among employees, Teamsters. Operating engineers. and

Management.

Operations Manager, Metro Landfall, Franklin, WI 4/89 . 11/89 Responsible for the management of a landfill thai accepted over 1,500 tons of solid waste per day. Additional duties included management of tire shredding operation, cardboard sorting facility, special waste permitting and tracking process, and two closing landfills. • Increased productivity of tire shredding operation by 30%. • Reduced injuries occurring at tire shredding operation by 80%. • Developed tire flTe prevention program and coordinated demonstration with local tire departments.

Staff Engineer, Oakbrook, IL. 6/88 - 4/89 Participant in the Engineer-in-Training program assigned to the, newly formed. corporate Superfund Management Department. • Initiated and organized closed landfill site lists for all corporate departments. • Assisted in the development of the Superfund Tracking System used to manage all Environmental Protection Agency

actions against company landfills.

eOA Exhibit TF-2 Tom Franke's Resume SOAH Docket No. 582-08-2186 TeEQ Docket No. 2006-0612-MSW Page 2 of3

THOMAS DAVID FRANKE• EDUCATION

University of Wisconsin - BS Civil and Environmental Engineering

State of Wisconsin - Engineer-In-Training Certification

Waste Management Inc. - Landfill University graduate

Solid Waste Association of North America - Manager Of Landfill Operations Certification

State of Texas - Engineer-In-Training Certification

Haestad Methods Certified Master Modeler Pond Pack Training

HEC-RAS Floodplain Modeling Certification

Environmentally Sensitive Streambank Stabilization Training

AWARDSIMEMBERSHIPS

• American Society of Civil Engineers

Keep Nebraska Beautiful, Board of Directors

Waste Management Inc., Regional Landfill Community Service Award

Waste Management Inc., Regional Landfill Safety Award

1988

1988

1990 and 1994

1994

2001

2003

2004

2005

2001 to Present

1993 to 1998

1995

1994

• COA Exhibit TF-2 Tom Franke's Resume SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 3 of3

• '. • -S;:7i5:"''=----- EROSION & RESTORATION ,PLAN

_a_ for--""--'"..._a_ - WASTE MANAGEMENT OF TEXAS--""--'"DOUlZI'_.-.....-=: 9900 GILES LANE-----"~ ... CITY OF AUSTIN, TRAVIS COUNTY, TEXASE=~':

SUBMlmD AUGUST 8, 2005 _l»IrIC~ClaIC.""_-~""--- lHmNJEX

, «MO .... , -... ..... ~~-:::"-' : ==~::::=:'on_

•''''''"'''''''"'''''''''~l1IQN(CIIIII1lWllJDUlll

7 ~mwIICIL~tGDt

• "'''W'I IdJIoICDIMMIClAllilr. ... 111 ~DIIoIMoW:.IMfA ... 'n1:llMWloM:III~l1li== -------- D c;a.lOI'CADIIoIMoW:.IrtAN U 0W0Ml tJEm;N TAid-~- ..."...,..."._----- 111 tJ(IINIIOIolPOlGftAN '" IS UJJCaAIlCIMa\llllEJlNC)IrIIIIGolr.1IONftAN ~z ~ ,. n'ftCALDD'AIS -- ~~- "f-LI.I 0 C:S.

Vi '"' u.. Z ~ o~ z

..... _ .. ItlIiIIlM__ IlClOaIIMII ........ !Z (j::Z6_MlG~_IIII• .ot'1.CIOUID ~"_,,,,-,_:IDNL ~ _AOI'\ft:_~_JIlIlJ __• .cn UJ ..... :sU ..- --

Yt:.===-~~:c=-.-:..-=.=:: =::.~==: ~~~5=J=.::E..==---==:J~===~=-. l) -- Ci::2~.::.-:.=.":.:.:= =. ':'=:::- - -~ ... - :=i~~-=r""":=;:._~~~~ < tic'"'~~;:;-~........~-~-_..-~....._-:t.' .. _ ...------.... z « ~z'

=~~~-=--.....:.....~=-~~. <0<:"'.. _-.:1 ....__ .. -.. _ ~ f- Iii--.--~~

...

_ft en I O&~~ .. _._-, ..---~-..-... 0<: ~ _1ftllIlm1l.' 1Mo1l I.U LU==t."~=----=r~="~=.

VICINIlY MAP f-O o :a:=....~~-.""=_~.'=..=...~- .. '" ..... >:.::..~.:.~__=..'=..r:u-==.~-ft~_zbzJ.'

..-- ..... _ ~n!!L-- ~~ o =-==-_--=:-:m...:..-r.J:t"::.~~__:_..~

":..:.--e:-~~~--•• --.,l11: ~._-.---DAoouc'et &, Associates, Inc. ......_.~_.n_ ..._-_~- ..-.--

fngileen _ PIaInt:n - ~

,4lI1 • ...,.,1I W8T. lUtE ... :...""':.=.:...~:::~,r::-.=_=.:........ ,

\ , .......... _.. _t;._~"""""""""'"

Dr ......

...-."" .-.oMmS ~ "21.-.,__ 'bW ......... GUOO><A

~:;~-..:J::::L:}'~ 11=': w·_" I

\ ~ ~ r- ~§-_.~ w =-.~1 1 Of 16

WASTI MANACIMENT • AUGUST S. 2005 ' Sf..,5-.,.510

eOA Exhibtt TF-3 Site Plan Drainage Sheets SOAH Docket No. 582-08-2186 TCEa Docket No. 2006-0612-MSW Page 1 of 16

• SVXl.1 '.uNI1Qj S1AVll 'NUs1'lV JO .un . ~ ~ J ~ ~...INV1 snrJ 0066 • III I::t A

! • N e p9lON 1'v"1.I3N3~ OW ~3mlM ~.'"• ~

SVX31 ~o IN3WDVN'fW llSVM-. ,Iii.

jll i III I! ~ III, ~ rmlli ; '11'~i I~ !11lIIIll

"If r

I.lUI-lliln

• I lillI J 11

! l!h' t W~I 'tI

I IllsI I'fI I I I k:'• • 'Ih th!. I'· 1'· l!i!llIii I,tIl : • I 'I llfi liU! i :I if.!,!Ill! j ,III Jill ,II ~nl!

---_._---- ... - .. •

• • •

I

CotSE , C&l-02"-02J5.OA

WASTE MANAGEMENT "--"'-~i'

'u" .'. . /

',~

~;'~~~;~~

.;-.

fil'tJ ~=uif'rM (aiJ ....

:(=~a.:z.r -, ~.,~" I.S.~S' ,>~ItS6)"_'3 . J. S~"s'2;b,.S()~~al3 $'"

/

O!.:.

oi"-=~~

i:i : !i5!!! '=~·tr~: r-.s

:.=.~~

r4:.-=-..u- I.:.·.. =·=':::~:_.------------

:·:t- l

&. .~"""a'£.. ..__

" __WJl _~: ..;.

"''-'.Ii;. ::-==.:.. _

':.:.~~;.&. =:--=~---=.

!

/1;1-. '. . ...... il~'- ~ I

I .;.,,:~:. == I ,-\'\ ~''''

", I ~ .-I( c-\ \,/t..

/ . -;:... '- 11&'!<.":,i;;;-~l:i~'c;

,. .~--~~ /Wf.' __.__ \.1

:;=:.-.":.n.a.-

I,!,I:, "

;WASH.MlMAdE..MENT .•.• ~ ;,: A~/r f! WASt~H\IIiNAGEMENT· -.(.. =:=r_~;':·"'-lr···:·4~'.:r ~.~~.l.

.""r: ........../i_..._--- "'" J /

kii I:ii;1 'iil§ _ ....-:,,;,·-ii'?,·.

;l~~.:

;.;L /'F:>.

~.. •:~ . . f~i

i,· '.;.., '

'\' ~4:'

"-....t-)/l-.~~~-"

\,' ._~;..-

.lJL1'~

"r:': \'

\I J:"'" jf.:..1,':" -~. ..

.,~~~r ~~ WA~niM~A%~~.[NT (D" __-=-.: Hm__ !SUI m~ ,... ~ ..,.~",. CASE _, C&l-02-Q23S.oA

COlli nr ....roIri. "'» _ oil J/~

COA ExlliM TF-3 Site Plan Drainage Sheets SOAH Docl<et No. 582-08-2186 TCEQ Docket No. 20116-11612-MSW Page 3 of 16

• 069£ YOO

~ .. IVld lVNU"I:' I 6" I .,' .• ,: ,

•

•

all . I 1;1 \ • ~i'li1Ii . ~I 11 1! ; ~ II~

!!'I If iil~! 1.!~ ~l! )~!~ II ,~: !ll l! J!~ II I~i.! ~ :~ III !

"--------

. t.~,'

•

•

•

5VXll 'AJ.NtlOJ SVlV'U 'Nusnv JO AlD lNVI 5llD 0066

DV1Il ~ID11M

SVX31 ~O IN3V113::lVNVW llSVM

SNOIlIGNOJ ~NIJ.SIX3

'I ~ Ii.!

~>i ,I,;

I'

.•• ;: en

8 :::!

'" :!l ~

'" .;ol. Z I

~=i 0° 0'"

~ ~i U I-Q.

5VX3J. '.uN/1OJ SlI\VllJ. 'NUSIlV JO AlO llW1 me llO66

DV1U 1Il0l1M SVX31 ~O lN31'\'3:)VNYW llSVM

-_.__.__- - _. _ _ .._GS : (lS3M) NVld lO"lllNO) "" ;:;..~~ ~ NOIIVIN3WIG3S/NOIS01l3

•

•

(1M) NVld lmllNO::l NOIIVLN3WlmS/NOISO~3

SIIXll 'AlNnOJ ~"V1l 'NllSflV JO AID lNVl SJ1[) 0066

DV1lllllmiM SVX31 ~o lN3ffi::JVNVW llSYM

ill OJ.. ~ [g .;:z z

0

E ~ ~ 0

J: (§ (§ " '"

•

\ \ l\

'\

) ../, , / !

.. :'

•

• ----I

SVXll '.wmcn SlAVlJ. 'NUSIlV JO AID 3I'N1 SllD 0066

NVld 3115 DVllJ. 1I30l1M

SVX31 ~o lN3W:1~VNVW llSVM

III ~~~

J ll\ll lll\ ~ l!i'!l-'JJ~IlllJ'111t11IIItlliJlll 'I II Ill'" J.1 11111

•

•

"C-Hllcnn

~ ~~~~ ~O~~~ :~§i.~~ (J)!.!.!!!.~

zZS71 !=' !=' 'i ~

~n~ g? ~~m 8'1'1;;-'" t~ rn ~

'~a~- ~.-

: §' ~ ia sa

~~I! 'Im;S§III=!l¥ a~~ e= ,g•• ·~rl.; . ~iil i!i1i!lei iiI &~ ••~lil Irl ~~I~§U, ·~m~···Iii ;:~

,~ii :~i ~~

n ~ :1 : ~ .dl

he •.. ! • • • • • P ! • • • . i mf •• i'" ;; ,! ~ i ! , 9' ii h ~ "0;1H! H-+++-H-+-I+H4-H-++--1

: eg .••••••.•• _~ •••• I , . 5 •• ~ , •• , E~ ••• ~~ i iii ~ :.. ... ~ .. :.. ~ t ... t: ~ ......... ~ l ~ & t II s ~ ~ ~ :: ~ ... I 8 8 !~ ~~ a 9 , ! H-+-I+-H++H-H-++++

d i~~' ~ !

'\.

-~

'" e'

•pi n n ~ n i niH ss pi i' ~ n : :SH : n! il ~I

•

I~!! WASTEMANAGEMENTOFTEXAS .~. n.;1 6 Q ... £'" ilr~ ", WILDER llACT EXISTING DRAINAGE AREA MAP : IIIIIA ~~:.=""'"II ~ ~ .. ~ . 1!.09S-..._ .....'" il ", 9900 GIlES lANE : 10-

IP- CITY OF AUSTIN, W.V~ COUNTY, ltXAS • ~ _ ••1

•

1J-lUlUlO

~~~:~

~g~~~ a~~og m!.S~-l zZ~71 !='!='cg

""" '" (oJ

~~i lil~l! ~'"

~~ ~

.~~- ~._-

'r'. J ~

Jih!!!!i 1111 I if11111 -." 1

11 1 I' "I I IIhll11

[tli I I -"" 11 r'll ~ I sliliim' .I I ~ II ~llffrr ri ,,1 f r II

t~!I111

!l9OD CAlIS lANEi11~s fll~'--' OlY 01 AU5n1'\ T1lA\IIS COUNTY, nXAS

I;· IfII .t~i2iL to'I i :: I

I!

'l'lllll!iilll;! li~ ,111 11111 1 ;' ~

II I

• .... II'Ill_PROI'051D-ARC< MAP lom.;...,.,..."...~ -- - --_._-,-_._

•

•

•

"'O~cncnn

~ ~~~~ _O:I:_~ ;;i?i?~_ i[i~.=

z ~ 7' ~ 'g Loa

~i om 'I'Gt '"

-----_.-==::::::::.

;.~;an;ane >,'nq rtEl::~"·1 f""I t

~E 1 llHlUlIIl1 11 III BiDi [ [(1mI~r JJ.l~H' J i ~ JJ ~ ~ •• ~ I I H

II !II m! ill! ~I !! nR. I r ~ 'it, I < I• ~ HPlj I II I'c I e "I

" ;; h =Ei e aM; i eiH ; ;i:i;~ i ; EiiH i : e;t;;~~:EiE~i:;G:i;'E;;:i:i;~U=: f ,I In Ill. I •• n a 1'1' I ••• , II 1I1;a::Jit. I III' •• It I 11."IlI'III~I.e.e:"~I"UU=!l;I:tllll!!!'!:! i i

I:: .. :: .. :: :..:: ::::- .. ::-:-:: : :::::: : ::::-::::::::::::.:::...:::::..: l: f;; :; ii g ;i c;;~ :i:: = = H~;a ~. i;=; :::Eiia:n; ,~s is .: Ii'; iii :;:! ~ (i,i'~D ~ :;-:~ =~;Si::.:=H ;;; II .t1 !.• 11_11::" a !a:::I r::d h!' G;G 81

!~!n!iulujuln'lInrunnen:~~H;~:~:it;hiQnh Ii ~Jj;1 i ii~ i ~ f~I!!!!:;!U J ,,,,- I' ~! ~" I' .e:,.,"}: 1

6H qu l!mS" :tJ! I H!

~fli nIm !~~ ! 1; ! !~.!iai ! {& 1~1

• f

Eiiij;H;HHi;;;Ha;e:i;~l~~i~iii3;;~iii'::~:i';i1;~~i;i;; 5•• ~ it & t ~:;u~Ul!: f .=.It.I.II ••• t •• ;IIII •••• IIIII •• lnl; •• 'III;tl.llll •• !. •• U: •••• Il~tliii II lUI' II' • "~I,,:!i::!i:~~~!!l i

.......................................................................... f· ............ 1I :r. .. ::l=:: !lI l:I I~t1!1= : I il.. .:I •••• , :::.= !l'l i;;Hc;:;1; ;a;;;;;&.:h=;;H~Ei;;ahE=~;Si;n=i~i·;i'=:~ :;; :s::H UI iH~eiig;;: ;;H=;~~a:~ii~~;=~=~;;;~;U;!=~=inh~;i~ =I; i:; ~:::~! U!Mi idEUU~H; iC$iU;E,;gn;e;;h;ij=H=:!!'z;g:U;:~ijii!!; =;; !:!u! !=!

iijji:'iiif ..•• 'I' "t'

hll!!!!' 'Illil 111

11 '1 I ri'ill

li ~;:; iii;; ai ~;; iici i; iii i;;; ~ iii; i" ~ S;;; i iii Ei H a iii:;' ~ i;.!i i ~;~ f u:tl.'u= •••••••• III ••• II; •••••••••••••••• IIIII.II •••••••••••••••• QI' -III1111 I '1· a~ .....................•............;........................ f· .. 10.' ' 10 ::, !,. ;:bi;;;;Ii; ;BiiE ;, .&;~ii;;;;;iii~;;t;aHe61i;a;hi;:;Hi;;if! ~Q~i~=:ii H;i: i: ;;:;a=i':'i~.;;eii;H;<B=ii: :h;~u,;;;~i

I~!!J I d.

11I:./1·'·1' I I ~ •;I!' , rrI . Hi,i;::; if .. ; ;; :i:=;;~:;~;i;piihijiiGiujl:;; UijjiUi~.~

WASTE MANAGEMENT OF TEXAS : '-1'A_.._ ...WILDER lllACT DRAINAGE AREA · _...."...... CALCULATIONS ·III~; f 9900 Cll5. ---~---

.. ·- -- OTY ~ AUSTIN, 11AVIS COUIm', TtXAS -- ... -_.__._---~

•

•

• iii

•

•

•

SVJG1 'AJNno:l SV.VIl 'NusI1V JO AlD JIoNl snr:> 0066

LlYlIl ~lOlIM

SVXll m lNlwnYNWlllSVM

I .,11 IIII j" -- ;

:1 .... :1I~ .,

Ii.!! : ..... '"ill· .

•.} ;i!i.!

~: ":II % .. '" i .... ! ~ a 0 .. I : It ...... a ...... ....

if II!!, ,.,a!illlllliilii!'l!

IIIHn ~n ' ~ "-;1 :. :z

iilHliliH;llnilil :: ;:j :I ::; ;I :I ~ :: ; ~ :: ~ ;;i ~ ';j ~ ;; ~ :l ::t

in Ii ii i i il Ii n Ii i l i ! niB i ~ i n

inn i I iiiili i liB Ii !iii nn in

iB i 6l iii iii i i III i Iii iii j I i ~ lEE ~

i~ n H ii i Ii i n j H H j i Ii H l Ii E :

Ii· : =: ======: ==• : : =: : : , =: : : : : , • i Iii. .. ... . ....................•! r ; !!~ j ! i i ! ! ! ! j l ! ! i I ! I ! ! I ! j ! j ! ! ill

II

JIlIU!!,. Ii II iii i Hii i II II II II i !I ii 11

• -- , - ..._- . __.. ll .... .., •

nOVl N~IS30 13NNVHJ--::-iwol~ m-pany .. MJf'IO(J "cI :

SVXll '.uNflOJ S1I\V1Il 'NUSnv JO AlO lNYl me 0066

DVlI! 1I3011M SVX31 ~O lN3WDVNVW llSYM

jjl iIIIHIII 1\ • f···I,"

1II'i '11IlHilll'~ '1'1 III e I" II"!I I II "II

•••••1111"111II 1I , lUI

H-H++I-+++1I-H+-I+tt-f++j++-l-++H-H H-t+HH-tt+rt+t+t+H-+++t+1-H " I

! mmii.ii:U· ii 9m.!i ! 2~ii inm-~~ - " !':,i ~

I· nH~lI_ II . e.1 'U' I n nlln 15 'j ~

I I'----'"!LLLLJ..u...L.l.J....I<J..u...L.LLW..u...L.LLLL..LLl..LJ..J<LLU..LL.L---Ll:J..

•

• -~

• III

~ '" :ll

MGJ. 'IUNIlOJ s....VU 'Nusnv JO AID lNYI 910 0066

----.~-

/--..-....~, .....

'~"'" ..

.......

-"'"

DVlU ~~0l1M

SVXll ~O !N3W3~VNWlllSVM

"11.

J . II . ',1 II -n ·-.n I ~. I I y••

I 'I'~ 11 1

1 /f~' iilll ~ '1!!l!!J

. ill

:z z0;

I- \!!

! ~ '0 c -;!

8 :cg ~

a.

[ ,,..•..•..;, .

.;:, . ·j.1

'. tii;a!....!.

• II

I

I

•

• - .-_.. . -_. -_._-_.. --

NVld NOIIV,)WW GNVl13M " NOIIV~OlS]~

5VXll 'AlNnoJ SIA'I1U 'Nusnv JO AlD lNVl rnv 0066

D~1am~

SVXll JO .lN3W3:)¥NYW 3lSVM

hI, I , 11111 II I~!I, II

!!ii ll,d~ lill 'I'J li~ II I li,l all 'I ,.j'd I hi 11 II I II I I II[i'\' I ,I.Ij I I' I II'

11\ I .~ il " !l111 h"I iii IhIll IH i "tin Ii Ill! ill Iiil~ 1'1 il 'If

• '11 I' 1IIIIIi II If \1 i ij IHIl liill!i II ; ~ III ij! j. I IlflII, . pI Illp"llill/J"d I! llil'Pili /111 ifi I!Ii! .t!q !I! Jl!'!,II II I"~""

-_.- ..

• -~~.

1 I ~

•

•

IIlIi!iil ! ni!!!!!I!!!!!l!li!!j i~n!! ili!mBn!!U~

• HIi' i i 'i' ii' Ii 5111 d Iii 1/ ,,1 Uii ii IiiiHiHi iPiii

,j

+I' 1 I I , , , • I , i

I

IYXll 'AlNno:l SLWlIl 'NUSC1V JO AID lNVl SIlO 0066

DV1I1 ~30l1M

SVX31 m lN3\1'8~VNWIllSVM

I '1"1- . ,' , .: i i n

in· oo ...

~~;~;.==,._---

._-- .-_._..-.__.

SlIV13a l'v'JldAl

I.···!o. i··I::l· .. ·I'illl ........ ,... li~~':!:t~:I~,~,,:I::!:l:!~I ~:!,'

EID if Ii I Ii iii II illll! Ii I q li l! Ill" ... ",,, ~. \>" , ""

Ir ~. !~~!!:: ~ !~:!,~::,,!~,~::!:::~ II :~~~~~~~~~:::~::~:::l Iii iii i I Iii Ii! i i 5i I Ii iii Iii 1ii i I I" . , i I .. H : H P 2' i ' i' I'I • II. Ii , ,.a, " In Ian iiliiiiiii &iilllil i Hii1l Iftiinii illini ii iniis

I HiilliiiliHilliliilllW!'!j 1:1 li liililiiiliiliiili'

l~l iill iiHiiiil mill ii iiiill i l~iiiiilmm i illmil . . I

it~":I:l:l:l:l=~:::I:I::=::l:=:I:!:I:1:r:l:l==:I,I .. rf:l=:l::I:1:1=:I:1:l:J:I::I=::!:I~:I:1i ~IF····· " ~ .. oi 1f !,lI!!.ltll!!!~ !

r

• • • Fillr and Geyer Sedimentation Equation for Modeling Particle Settling

PI-FERENCES 1 The e uation re icts efficiency ratio or re uctlon in TSS COllcentratlon for a artlc e selt ing e ocity e uation 6-11 from age 6-46

of BMP Modeling Concepts and Simulation SEPA EPA 600 R-06 033 2006 -- >

2 An evaluation of geoloxtiles for wmporary s/:leJimenl conI, ot, arrell et a. une 1998 age 286

3 Sediment and Contaminant Removal by Dllal Purpose Dr'/enrion Basins Co e onge 1993 age 4

Sedimentation and Detention PONDING CHARACTERISTICS

Maximum Pon ing De th 0 ft Pon ing Wi th W ft S,) e S tt ft I ii~ I TSS REMOVAL PERFORMANCE A erage F 0 Rate cfh 8856 nlo TSS Concentration mg 3000 N ern /fica measure of hy rau ic efficiency POll ing ength ft 8500

212500.0 A eraqe () erf 0 Rate Q A cfh s .ft 0.042

erage Pon Surface Area s .ft.

A g A erage Tra Partice Selt ing Efficiency

Si e Pct. Of e ocity nf 0 TSS Fair eyer Oulf 0 TSS _... _----- - - - - - - -- - - -

~ ~

1 dry FinE 5i I 2 20 0.03 600 600 600 600 600

42 88 79 99 100

349 73 126 3 0

2 Fine Sit 6 20 0.3 3 Me lum Sit 14 20 0.16 4 arge Si t 30 20 72 5 Fine San 90 20 66

I 82% I

COA Exhibit TF-4 Sedimentation and Oententlon Pond Analysis SOAH Docket No 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 1 of 3

• • • F'lIr and Geyer Sedimentation Equation for Modeling Particle Sertling

I~I I-FRENCES 1 file ~ uallon re icts efficiency rallo or re "Cllon in rss r.oncentralion for a artic e seiling e ocily e uation 6-11 from age 6-46

of BMP Mocle1il19 Cuncepcs and SII/lulal,O(/ . SEPA EPA 600 R-06 033 2006 -- >

2 A/I "valuatlOll olgeowxltlo,; lor tomporary se(/i,l/tJI11 <:0111((>1, affetl et a une 1998 age 286

3 Se(/lIn",/lC anti ecm/Bolmanf Removal Oy Dua/ P"r/losd D"rent/OrJ Basins Co e onge 1993 age 4

S"dim"ntation and Deltlnlion PONDING CHARACTERISTICS

Maximum Pan Ing De ltl [) ft Pon In9 WI Ih W SCI e It fl ~ f ;~~ I TSS REMOVAL PERFORMANCE A e",ge F 0 Rate eth of a rss Concentration mg

N em mea measure of Ily rau ic effiCiency ,.0 Iflg engln ft

A .:rage Pan Surface A,ea s .ft

dd5ti 3000

3 B!iO.O

2125000 - - • >~A ",age 0 erlo Rale Q A cln s .11

A g A erage Tra Partie e Sell ing Efficiency

S, e Pct. Of e oClty nlo TSS Fair eyer Outf 0 TSS

. _.._- - - --- -- .-- - .. - - - ---- - - - ~ - - - - ~

on

1 ery Fine Sit 2 20 003 600 600 600 600 600

48 97 91 100 100

2 Fine Sit 6 20 0.3 3 Me lum Sit 14 20 016 4 argeSl1 30 20 72 5 Fin", San 90 20 66

315 15 52 0 0

I 87% I

COA Exhibit TF-4 Sedimentation and Dentention Pond Analysis SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page2of3

• • • Fair and Geyer Sedimentation Equation for Modeling Particle Settling

RFFERENCES 1 The e uatlon re ICts efficiency ratio or re uction In TSS cOl'1celltration for a artic e sett ing e ocity e uation 6-11 from age 6-46

of BMP Modeling Concepts and Simulation. SEPA EPA 600 R-06 033 2006 -- >

2 An evaluation of geotextiles for temporary sediment conlml, arret! et a une 1998 age 286

3 Serilment and Contam/(/ant Removal by Dual Purpose DetentIOn Basins Co e onge 1993 age 4

Sedimentation and Detention PONDING CHARACTERISTICS

Maximum Pon in9 De th D h. Pon in9 WI th W h SoeShh I ~.~~ I TSS REMOVAL PERFORMANCE A erage F 0 Rate dh nlo TSS Concentration mg

N em irica measure of hy rau IC efficiency Pon Ing ength ft A erage Pon Surface Area 5 .ft. A erage 0 erf 0 Rate Q A dh 5 .ft.

Partic e C ass

8856 3000

5 850.0

212500.0

0.042

A 9 A erage Tra PartlC e Set! ing Efficiency

Si e Pet, Of e ocity nfo TSS Fair eyer Outfo TSS Pal1ic e Ty e microns Mass ft hr Conc. mg -E n Conc. mg

1 ery Fine Si l 2 20 0.03 600 600 600 600 600

49 99 94

100 100

306 7

36 0 0

2 Fine Sit 6 20 0.3 3 Me lurn Sit 14 20 0.16 4 argeSit 30 20 7.2 5 Fine San 90 20 66

I 88% I

COA Exhibit TF-4 Sedimentation and Dentention Pond Analysis SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 3 of 3

• TPDES GENERAL PERMIT NO. TXROSOOO()

This general permit supersedes

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY and replaces TPDES general

P. O. Box 13087 pernnt No. TXR050000, issued

Austin, Texas 78711-3087 August 20,2001.

GENERAL PERMIT TO DISCHARGE WASTES under provisions of

Section 402 of the Clean Water Act and Chapter 26 of the Texas Water Code

lndustrial facilities that discharge storm water associated with industrial activity

• located in the state of Texas

may discharge to surface water in the state

only according to etfluent 1i111ltahons, monitormg requirements and other conditions set forth in thiS general permit, as well as the rules of the Texas Commission on Environmental Quality (TCEQ) , the laws of the State of Texas, and other orders of the Commission of the TCEQ (Commission). The issuance of this general permit does not grant to the permittee the righllo use private or public property for conveyance of wastewater along the discharge route. This includes property belonging to but not limited to any individual, partnership. corporatIOn or other entity. Neither does this general pennit authorize any invasion ofpersonal rights nor any violation of federal, state, or local laws or regulations. It is the responsibihty of the pennitlee to acquire property rights as may be necessary to use the discharge route. .

This general permit and the authorization contained herem shall expire at midnight, five, years from date of issuance.

ISSUED AND EFFECTIVE DATE: AUG 1L: 2006

• COA Exhibit TF-5 TPDESMulti Sector Gerneral Permit SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 1 of 111

• Multi Sector General Pennit TPDES General Pennit No. TXR050000

TPDES GENERAL PERMIT NO. TXR050000 RELATING TO STORM WATER DISCHARGES ASSOCIATED WITH INDUSTRIAL ACTIVITY

Table of Contents

Part L Definitions 4

Part II. Pennit Applicability and Coverage 9 Section A. Discharges Eligible for Authorization by General Pennit 9 Section B. Limitations on Pennit Coverage : .. . . . . . . . . . . . . . . . . .. 18 Section C. Obtaining Authorization to Discharge 21 Section D. Alternative Coverage Under an Individual TPDES Pennit 25

Part III. Pennit Requirements and Conditions Common to All Industrial Activities 26 Section A. Minimum Stonn Water Pollution Prevention Plan Requirements 26 Section B. Inspection of Stonn Water Pollution Prevention Plan and Site 34 Section C. GeneralMonitoring and Records Requirements 35 Section D. Numeric Effluent Limitations 38 Section E. Standard Pennit Conditions 41

• Part IV. Benchmark Monitoring Requirements Common to Many Industrial Activities 48

Section A. Use of Benchmark Data 48 Section B. Sectors Subject to Benchmark Monitoring 48 Section C. Benchmark Monitoring Requirements 50

Part V. Specific Requirements for Industrial Activities 51 Section A. Sector A Timber Products Facilities 51 Section B SectorB Paper and Allied Products 54 Section C Sector C Chemical and Allied Products 54 Section D Sector D Asphalt Paving and Roofing Materials and Lubricants 57 Section E Sector E Glass, Clay, Cement, Concrete, and Gypsum Products 59 Section F Sector F Primary Metals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62 Section G Sector G Metal Mining (Ore Mining and Dressing) 63 Section H SectorH Coal Mines and Coal Mining Related Facilities 66 Section I Sector 1 Oil and Gas Extraction 68 Section J Sector J Mineral Mining and Dressing 69 Section K Sector K Hazardous Waste Storage Facilities 72 Section L Sector L Landfills and Land Application Facilities 73 Section M SectorM Automobile Salvage Yards 75 Section N Sector N Scrap Recycling Facilities 77 Section 0 Sector 0 Steam Electric Generating Facilities 79 Section P Sector P Land Transportation and Warehousing 81 Section Q Sector Q Water Transportation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 82 Section R Sector R Ship and Boat Building or Repairing Yards 84 Section S Sector S Air Transportation 85 Section T Sector T Treatment Works 87 Section U SectorU - Food and Kindred Products 88

• Page 2

COA Exhibit TF-5 TPDES Multi Sector Gerneral Permit SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 2 of 111


Section V Sector V - Textile Mills, Apparel, and Other Fabric Product Manufacturing, Leather and Leather Products. . . . . . . . . . . . . 89

Section W SectorW - Furniture and Fixtures 90 Section X Sector X- Printing and Publishing 91 Section ¥ Sector ¥- Rubber, Miscellaneous Plastic Products, and Miscellaneous

Manufacturing Industries " . . . . . . . . . . . . . . . . . . . . . . . 91 Section Z Sector Z- Leather Tanning and Finishing : 93 Section AA Sector AA- F~bricated Metal Products . . .. . . . . . . . . . . . . . . . . . . . . . . . . 94 Section AB Sector AB- Transportation Equipment, Industrial or Commercial

Machinery " 95 Section AC Sector AC- Electronic, Electrical, Photographic, and Optical Goods . . . . . . . . . . . . . 96 Section AD Sector AD- Miscellaneous Industrial Activities 96

•

Part VI. Discharge Monitoring Report (DMR) Fonns 97 Instructions for Completing a DMR 97 DMR Fonn for Hazardous Metals - Inland Waters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 99-101 DMR Fonn for Hazardous Metals - Tidal Waters " 102-104 DMR Fonn for Coal Pile Runoff, Except Sector a 105 DMR Fonn for Sector A Facilities 106 DMR Fonn for Sector CFacilities 107 DMR Fonn for Sector D Facilities 108 DMR Fonn for Sector E Facilities " 109 DMR Fonn for Sector J Facilities 110 DMR Fonn for Sector 0 Facilities 111

• Page 3

eOA Exhibit TF-5 TPDES Multi Sector Gerneral Permit SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 3 of 111

• Multi Sector General Permit TPDES General Permit No. TXR050000

Part I. Definitions

All definitions in Section 26.001 of the Texas Water Code and 30 TAC Chapter 305 shaH apply to this permit and are incorporated by reference. Some specific definitions of words or phrases used in this permit are as follows:

Best management practices (BMPs) - schedules of activities, prohibitions ofpractices, maintenance procedures, and other techniques to control, prevent or reduce the discharge ofpollutants. BMPs also include treatment requirements, operating procedures, and practices to control site runoff, spills or leaks, sludge or waste disposal, or drainage from raw material storage areas.

Co-located industrial activities - Industrial activities, conducted at a single facility, that are described by two or more sectors of this general permit.

Co-located industrial facilities - Industrial facilities, having different operators, that are located on a common property or .adjoining property and that conduct industrial activities described by one or more sectors of this general permit.

Composite Sample - a sample made up of a minimum of three effluent portions collected in a continuous 24-hour period or during the period of daily discharge if less than 24 hours, and combined in volumes proportional to flow, and collected at the intervals required by 30 TAC § 319.9 (b).

• Daily average concentration - the arithmetic average of all effluent samples, composite or grab as required by this permit, within a period ofone calendar month, consisting ofat least four separate representative measurements. When four samples are not available in a calender month, the arithmetic average (weighted by flow) of all values taken during the month shall be utilized as the daily average concentration.

Daily maximum concentration - the maximum concentration measured on a single day, as determined by laboratory analysis of a grab sample.

Discharge - for the purpose of this permit, drainage, release or disposal into surface water in the state.

Edwards Aquifer - As defined under Texas Administrative Code § 213.3 ofthis title (relating to the Edwards Aquifer), that portion of an arcuate belt of porous, water-bearing, predominantly carbonate rocks known as the Edwards and Associated Limestones in the Balcones Fault Zone trending from west to east to northeast in Kinney, Uvalde, Medina, Bexar, Comal, Hays, Travis, and Williamson Counties; and composed of the Salmon Peak Limestone, McKnight Formation, West Nueces Formation, Devil's River Limestone, Person Formation, Kainer Formation, Edwards Formation, and Georgetown Formation. The permeable aquifer units generally overlie the less-permeable Glen Rose Formation to the south, overlie the less-permeable Comanche Peak and Walnut Formations north of the Colorado River, and underlie the less-permeable Del Rio Clay regionally.

Edwards Aquifer Recharge Zone - Generally, that area where the stratigraphic units constituting the Edwards Aquifer crop out, including the outcrops of other geologic formations in proximity to the Edwards Aquifer, where caves, sinkholes, faults, fractures, or other permeable features would create a potential for recharge of surface waters into the Edwards Aquifer. The recharge zone is identified as that area designated as such on official maps located in the offices of the Texas Commission on Environmental Quality and the appropriate underground water conservation district.

• Page 4



Facility - for the purpose of this pennit, all contiguous land and fixtures (including ponds and lagoons), structures, or appurtenances used at an industrial facility described by one or more of Sectors A through AD of this general permit.

Grab sample - An individual sample collected in less than 15 minutes.

General permit - A permit issued to authorize the discharge of waste into or adjacent to water in the state for one or more categories of waste discharge within a geographical area of the state or the entire state as provided by § 26.040, Texas Water Code.

Hyperchlorination of waterlines - Treatment of potable water lines or tanks with chlorine for disinfection purposes, typically following repair or partial replacement of the waterline or tank, and subsequently flushing the contents.

Inactive Industrial Facilities - A facility where all industrial activities that are described in Part II.A.l.of this permit are suspended, and where an authorization under this general permit is maintained.

Inland water - All surface water in the state other than those defined as a tidal water.

Municipal separate storm sewer system (MS4) - A separate storm sewer system owned or operated by the U.S., a state, city, town, borough, county, parish, district, association, or other public body (created by or pursuant to State law) havingjurisdiction over disposal ofsewage, industrial wastes, storm water, or other wastes, including special districts under State law such as a sewer district, flood control or drainage district, or similar entity, or an Indian tribe or an authorized Indian tribal organization, that discharges to surface water in the state.

• National Pollutant Discharge Elimination System (NPDES) - The federal program under which the administrator of the United States Environmental Protection Agency can authorize discharges of waste to waters of the United States according to the Section 402 of the Federal Water Pollution Control Act, and may also delegate this permitting authority to the State of Texas.

Non-structural controls - Pollution prevention methods that are not physically constructed, including best management practices, used to prevent or reduce the discharge of pollutants.

No Exposure Certification (NEC) - A written submission to the executive director from an applicant notifying their intent to obtain a conditional exclusion from permit requirements by certifying that there is no exposure of industrial materials or activities to precipitation or runoff.

Notice of Change (NOC) - Written notification from the permittee to the executive director providing changes to information that was previously provided to the agency in a notice of intent or no exposure certification (NEC) form.

Notice of Intent (NOI) - A written submission to the executive director from an applicant requesting coverage under this general permit.

Notice of Termination (NOT) - A written submission to the executive director from a discharger authorized under a general permit requesting termination of coverage.

Operator - Person that is responsible for the management of an industrial facility subject to the provisions of this general permit.

• Page 5

COA Exhibit TF-5 TPDES Multi Sector Gemeral Permit SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 5 of 111


Outfall- For the purpose ofthis permit, a point source at the point where storm water runoffassociated with industrial activity discharges to surface water in the state and does not include open conveyances connecting two municipal separate storm sewers, or pipes, tunnels, or other conveyances that connect segments of the same stream or other waters of the U.S. and are used to convey waters ofthe U.S.

Permittee - An operator authorized under this general permit, either.by submission ofa notice ofintent or a conditional no-exposure exclusion form, to discharge storm water runoffand certain non-storm water discharges associated with industrial activity.

Point Source - (from 40 CFR § 122.22) any discernible, confined, and discrete conveyance, including but not limited to, any pipe, ditch, channel, tunnel, conduit, well, discrete fissure, container, rolling stock, concentrated animal feeding operation, landfill leachate collection system, vessel or other floating craft from which pollutants are or may be discharged. This term does not include return flows from irrigated agriculture or agricultliral storm water runoff.

•

Pollutant - (from Water Code, § 26.001 (13)) dredged spoil, solid waste, incinerator residue, sewage, garbage, sewage sludge, filter backwash, munitions, chemical wastes, biological materials, radioactive materials, heat, wrecked or discarded equipment, rock, sand, cellar dirt, and industrial, municipal, and agricultural waste discharged into any water in the state. The term: (A) includes: (i) tail water or runoff water from irrigation associated with an animal feeding operation or concentrated animal feeding operation that is located in a major sole source impairment zone as defined by Section 26.502; or (ii)rainwater runoff from the confinement area of an animal feeding operation or concentrated animal feeding operation that is located in a major sole source impairment zone, as defined by Section 26.502; and (B) does not include tail water or runoff water from irrigation or rainwater runoff from other cultivated or uncultivated rangeland, pastureland, and farmland or rainwater runofffrom an area ofland located in a major sole source impairment zone, as defined by Section 26,502, that is not owned or controlled by an operator of an animal feeding operation or concentrated animal feeding operation on which agricultural waste is applied.

Reportable Quantity Spill- a discharge or spill of oil, petroleum product, used oil, hazardous substances, industrial solid waste, or other substances into the environment in a quantity equal to or greater than the reportable quantity listed in 30 TAC § 327.4 (relating to Reportable Quantities) in any 24-hour period.

Separate storm sewer system - A conveyance or system of conveyances (including roads with drainage systems, streets, catch basins, curbs, gutters, ditches, man~made channels, or storm drains), designed or used for collecting or conveying storm water; that is not a combined sewer, and that is not part of a publicly owned treatment works (POTW).

Significant materials - Including, but not limited to: raw materials; fuels; materials such as solvents, detergents, and plastic pellets; final products that are not designed for outdoor use; raw materials that are used for food processing or production; hazardous substances designated under section 101(14) of CERCLA; any chemical the operator is required to report pursuant to Section 313 ofthe Emergency Planning & Community Right-To-Know Act (EPCRA), also known as Title III ofSuperfund Ameitdments and Reauthorization Act (SARA); fertilizers; pesticides; and waste products such as ashes, slag and sludge that have the potential to be released with storm water discharges.

Solid waste management unit - for the purposes ofthis permit, a storm water detention pond, storm water retention pond, or other similar dedicated pond used forremoval ofsuspended solids. Specifically excluded from this definition are other control structures, including berms, grass swales, pipes and ditches or other similar stom water conveyances, and silt fences.

Storm resistant shelter - Includes completely roofed and walled buildings or structures, and structures with only a top cover but no side coverings, provided material under the structure is not subject to any run-on and subsequent runoff of storm water. .

• Page 6

COA Exhibit TF-5 TPDESMulti Sector Gerneral Permit SOAH DocketNo. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 6 of 111


Storm water and storm water runoff - Rainfall runoff, snow melt runoff, and surface runoff and drainage.

Storm water discharges associated with industrial activity - Storm water runoff that exits any conveyance that is used for collecting and conveying storm water that is directly related to manufacturing, processing, material storage, and waste material disposal areas (and similar areas where storm water can contact industrial pollutants related to the industrial activity) at an industrial facility described by one or more of Sectors A through AD of this general permit. The definition is restricted, for the purposes of this general pennit, to those storm water discharges that qualify for authorization under the provisions of this general permit (on an outfall by outfall consideration).

Structural control- Physical, constructed features, such as silt fencing, sediment traps, and detention/retention ponds, that prevent or reduce the discharge of pollutants.

Surface Water in the State - Lakes, bays, ponds, impounding reservoirs, springs, rivers, streams, creeks, estuaries, wetlands, marshes, inlets, canals, the GulfofMexico inside the territorial limits ofthe state (from the mean high water mark (MHWM) out 10.36 miles into the Gulf), and all other bodies of surface water, natural or artificial, inland or coastal, fresh or salt, navigable or nonnavigable, and including the beds and banks of all water-courses and bodies of surface water, that are wholly. or partially inside or bordering the state or subject to the jurisdiction of the state; except that waters in treatment systems which are authorized by state or federal law, regulation, or permit, and which are created for the purpose of waste treatment are not considered to be water in the state.

Texas Pollutant Discharge Elimination System (TPDES) - The state program for issuing, amending, terminating, monitoring, and enforcing permits, and imposing and enforcing pretreatment requirements, under Clean Water Act §§ 307,402,318 and 405, the Texas Water Code and Texas Administrative Code regulations.

• Tidal water - Those waters of the GulfofMexico within the jurisdiction of the State ofTexas, bays and estuaries, and those portions of rivers and streams that are subject to the ebb and flow ofthe tides and that are subject to the intrusion of marine waters.

Waters of the United States - (from title 40, partl22, section 2 of the Code of Federal Regulations) Waters of the United States or waters of the U.S. means:

(a) all waters which are currently used, were used in the past, or may be susceptible to use in interstate or foreign commerce, including all waters which are subject to the ebb and flow of the tide;

(b) all interstate waters, including interstate wetlands;

(c) all other waters such as intrastate lakes, rivers, streams (including intermittent streams), mudflats, sandflats, wetlands, sloughs, prairie potholes, wet meadows, playa lakes, or natural ponds that the use, degradation, or destruction ofwhich would affect or could affect interstate or foreign commerce including any such waters:

(1) which are or could be used by interstate or foreign travelers for recreational or other purposes;

(2) from which fish or shellfish are or could be taken and sold in interstate or foreign commerce; or

(3) which are used or could be used for industrial purposes by industries in interstate commerce;

• Page 7

COA Exhibit TF-5 TPDES Multi Sector Gemeral Permit SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-Q612-MSW Page 7 of 111


(d) an impoundments of waters otherwise defined as waters of the United States under this definition;

(e) tributaries of waters identified in paragraphs (a) through (d) of this definition;

(f) the territorial sea; and

(g) wetlands adjacent to waters (other than waters that are themselves wetlands) identified in paragraphs (a) through (f) of this definition.

Waste treatment systems, including treatment ponds or lagoons designed to meet the requirements ofCWA (other than cooling ponds as defined in 40 CFR 423.ll(m) which also meet the criteria of this definition) are not waters of the United States. This exclusion applies only to manmade bodies ofwater which neither were original1y created in waters of the United States (such as disposal area in wetlands) nor resulted from the impoundment of waters of the United States. [See Note 1 of this section.] Waters of the United States do not include prior converted cropland. Notwithstanding the determination of an area's status as prior converted cropland by any other federal agency, for the purposes of the Clean Water Act, the final authority regarding Clean Water Act jurisdiction remains with EPA.

•

• Page 8

COA Exhibit TF-5 TPDES Multi Sector Gerneral Pennit SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 8 of 111


Part II. Permit Applicability and Coverage

This general permit provides authorization for point source discharges of storm water associated with industrial activity to surface water in the state (including direct discharges to surface water in the state and discharges to municipal separate storm sewer systems, or MS4s). The permit contains effluent limitations and requirements applicable to all industrial activities that are eligible for coverage under this general permit. Industrial activities are subdivided into 30 sectors of industry. .

Section A. Discharges Eligible for Authorization by General Permit

1. Industrial Activities Covered

Industrial activities are grouped into 30 sectors of similar activities based on either Standard Industrial Classification (SIC) codes or Industrial Activity Codes. Coverage under this general permit may be obtained to authorize discharges ofstorm water associated with industrial activity, and certain other nonstorm water discharges, from the following sectors:

• SECTOR A: TIMBER PRODUCTS

SIC Code Description of Industry Sub-sector .

Log Storage and Handling (Wet deck storage areas where no chemical additives ~re used in the spray water or applied to the logs)

2411

·2421 General Sawmills and Planning Mills

2426 Hardwood Dimension and Flooring Mills

2429 Special Product Sawmills, Not Elsewhere Classified

2431-2439 (except 2434)

Millwork, Veneer, Plywood, and Structural Wood (2434 - Wood Kitchen Cabinets, see Sector W)

2441-2449 Wood Containers

Wood Buildings and Mobile Homes 2451,2452

2491 Wood Preserving

Reconstituted Wood Products 2493

2499 Wood Products Not Elsewhere Classified

SECTOR B: PAPER AND ALLIED PRODUCTS

SIC Code Description of Industry Sub-sector

Pulp Mills

Paper Mills

Paperboard Mills

Paperboard Containers and Boxes

2611

2621

2631

2652 -2657

2671 - 2679 Converted Paper and Paperboard Products, Including Plastic Bags Produced from Plastics Film

• Page 9

COA Exhibit TF-5 TPDES Multi Sector Gerneral Permit SOAH Docket No. 582-08-2186 TCEQ Docket No. 200e-0612-MSW Page 9 of 111

• Multi Sector General Pennit TPDES General Permit No. TXR050000

SECTOR C: CHEMICAL AND ALLIED PRODUCTS

Description of Industrv Sub-sectorSIC Code

2812 - 2819 Basic Industrial Inorganic Chemicals

2821 - 2824 Plastic Materials, Synthetic Resins, Non-vulcanizable Elastomers (Synthetic Rubber), Cellulose Plastics Materials, and Other Manmade Fibers Except Glass

Medicinal Chemicals and Botanical Products, Pharmaceutical Preparations, In Vitro and In Vivo Diagnostic Substances, Biological Products (Except Diagnostic Substances).

2833 - 2836

Soaps and Detergents; Specialty Cleaning, Polishing, and Sanitation Preparations, Surface Active Agents, Finishing Agents, Sulfonated Oils, and Assistants, Perfumes, Cosmetics, and Other Toilet Preoarations;

2841 - 2844

Paints, Varnishes, Lacquers Enamels, and Allied Products 2851

Industrial Organic Chemicals (including commercial composting operations) 2861-2869

Agricultural Chemicals (Including Fertilizers, Pesticides, Fertilizers Solely from Leather Scraps and Leather Dust, and Mixing of Fertilizers, Compost, and Potting Soils)

2873 - 2879

Miscellaneous Chemical Products (Including Adhesives and Sealants, Explosives, Printing Ink, and Carbon Black)

2891 - 2899

Inks and Paints, including: China Painting Enamels, India Ink, Drawing Ink, (Limited to List)

3952 Platinum Paints for Burnt Wood or Leather Work, Paints for China Painting; Artist's Paints and Artist's Watercolors

SECTORD: ASPHALT PAVING AND ROOFING MATERIALS AND LUBRICANTS

Description of Industry Sub-sectorSIC Code

Asphalt Paving and Roofing Materials, Portable Asphalt Plants 2951,2952

Miscellaneous Products of Petroleum and Coal Includim! Oils and Greases 2992 2999

SECTOR E: GLASS CLAY. CEMENT. CONCRETE, AND GYPSUM PRODUCTS


3211 Flat Glass

Glass and Glassware, Pressed or Blown3221,3229

Glass Products Made of Purchased Glass 3231

Hydraulic Cement 3241

Structural Clay Products 3251-3259

Vitreous China Plumbing Fixtures and China Earthenware Fittings and Bathroom Accessories

3261

Pottery and Related Products 3262-3269

Cut Stone and Stone Products 3281

•

• Page 10 COA Exhibit TF-5 TPDES Multi Sector Gemeral Pennit SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 10 of 111


•

SECTOR E: GLASS, CLAY, CEMENT, CONCRETE, AND GYPSUM PRODUCTS (continued)


3271- 3275 Concrete, Lime, Gypsum and Plaster Products

3291,3292 Asbestos Products

3295 Minerals and Earth's, Ground, or Otherwise Treated

3296 Mineral Wool

3297 Non-Clay Refractories

3299 Nonmetallic Mineral Products Not Elsewhere Classified

SECTOR F: PRIMARY METALS


3312-3317 Steel Works, Blast Furnaces, and Rolling and Finishing Mills

3321-3325 Iron and Steel Foundries

3331-3339 Primary Smelting and Refining ofNonferrous Metals

3341 Secondary Smelting and Refining of Nonferrous Metals

3351-3357 Rolling, Drawing, and Extruding of Nonferrous Metals

3363-3369 Nonferrous Foundries (Castings)

3398 3399 Miscellaneous Primary Metal Products

SECTOR G: METAL ,MINING (ORE MINING AND DRESSING)


1011 Iron Ores

1021 Copper Ore Mining and Dressing

1031 Lead and Zinc Ores

1041,1044 Gold and Silver Ores

1061 Ferro alloy Ores, Except Vanadium

1081 Metal Mining Services

1094, 1099 Miscellaneous Metal Ores

SECTOR H: COAL MINES AND COAL MINING RELATED FACILITIES


1221-1241 Coal Mines and Coal Mining-Related Facilities

• Page 11 COA Exhibit TF-5 TPDES Multi Sector Gerneral Permit SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 11 of 111


SECTORI: OIL AND GAS EXTRACTION FACILITIES

Description of Industrv Sub-sectorSIC Code

.Crude P,etroleum and Natural Gas 1311

Natural Gas Liquids 1321

1381-1389 Oil and Gas Field Services

Petroleum Refineries

SECTOR J: MINERAL MINING AND DRESSING FACILITIES

2911

SIC Code

1411

1422-1429 .. 1442, 1446

1455, 1459

1474-1479

1481

1499

'",

Description oflndustry Sub-sector' ,.

Dimension Stone

Crushed and Broken Stone, Including Rip.Rap

Sand and Gravel Mining

Clay, Ceramic, and Refractory Materials

Chemical and Fertilizer Mineral Mining

Nonmetallic Minerals, Except Fuels

Miscellaneous Nonmetallic Minerals Exceot·Fuels

• o.

SECTOR K: HAZARDOUS WASTE TREATMENT, STORAGE, AND DISPOSAL FACILITIES

Activity Code Description of Industrv Sub-sector

Limited to Hazardous Waste Storage or Disoosal

SECTOR L: LANDFILLS AND LAND APPLICATION SiTES

Activity Code

HZ

Description of Industrv Sub-sector

LF Limited to Landfills, Land Application Sites, and Open Dumps that Receive or Have Previously Received Industrial Waste, including sites subject to regulation under Subtitie D of the Resource Conservation and Recovery Act (RCRA).

SECTOR M: AUTOMOBILE SALVAGE YARDS

.SIC Code Description oflndustry Sub-sector

5015 Automobile Salvage Yards

SECTOR N: SCRAP AND WASTE RECYCLING FACILITIES

SIC Code Description oflndustrv Sub-sector

5093 Scrap Recycling Facilities (Scraps include metals, paper, plastic, cardboard, glass, animal hides, used oil, antifreeze, mineral spirits, industrial solvents and other materials)

• Page 12 COA Exhibit TF-5 TPDES Multi Sector Gemeral Permit SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 12 of 111


SECTOR 0: STEAM ELECTRIC GENERATING FACILITIES

Activity Code Description of Industry Sub-sector

SE Limited to Steam Electric Generating Facilities

SECTOR P: LAND TRANSPORTATION AND WAREHOUSING

Sic Code Description of Industry Sub-sector

4011,4013 Railroad Transportation

4111-4173 Local and Highway Passenger Transportation

4212-4231 Motor Freight Transportation and Warehousing

4311 United States Postal Service

5171 Petroleum Bulk Stations and Terminals

SECTOR Q: WATER TRANSPORTATION


4412-4499 Water Transnortation

• SECTOR R: SIDP AND BOAT BillLDING OR REPAIRING YARDS

SIC Code Description oflndustry Sub-sector

3731 3732 Shin and Boat Building or Reoairing Yards

SECTOR S: AIR TRANSPORTATION


4512-4581 Air Transoortation Facilities

SECTOR T: TREATMENT WORKS

Activitv Code Description of Industry Sub-sector

TW Treatment Works

SECTOR U: FOOD AND KINDRED PRODUCTS FACILITIES


2011-2015 Meat Products

2021-2026 Dairy Products

2032-2038 Canned, Frozen and Preserved Fruits, Vegetables and Food Specialties

2041-2048 Grain Mill Products

2051-2053 Bakerv Products

Page 13• COA Exhibit TF-5 TPDES Multi Sector Gerneral Permit SOAH Docket No. 582-08-2186 TCEQ Docket No. 200B-0612-MSW Page 13 of 111


•

SECTOR U: FOOD AND KINDRED PRODUCTS FACILITIES (continued)

SIC Code Description oflndustrv SUb-sector

2061-2068 Sugar and Confectionery Products

2074-2079 Fats and Oils

2082-2087 Beverages

2091-2099 Miscellaneous Food Preparations and Kindred Products

2111-2141 Tobacco Products

SECTOR V: TEXTILE MILLS, APPAREL, AND OTHER FABRIC PRODUCT MANUFACTURING FACILITIES

SIC Code Description oflndustrv Sub-sector

2211-2299 Textile Mill Products

2311-2399 Apparel and Other Finished Products Made From Fabrics and Similar Materials

3131-3199 Leather and Leather Products exceot Leather Tanning and Finishing

SECTOR W: FURNITURE AND FIXTURES


2434 Wood Kitchen Cabinets

2511-2599 Furniture and Fixtures

SECTOR X: PRINTING AND PUBLISHING

SIC Code Description of Industry Su b-sector

2711-2796 Printing. Publishing. and Allied Industries

SECTOR Y: RUBBER, MISCELLANEOUS PLASTIC PRODUCTS, AND MISCELLANEOUS MANUFACTURING FACILITIES


3011 Tires and Inner Tubes

3021 Rubber and Plastics Footwear

3052,3053 Gaskets, Packing, and Sealing Devices and Rubber and Plastics Hose and Belting

3061,3069 Fabricated Rubber Products, Not Elsewhere Classified

3081-3089 Miscellaneous Plastics Products

3931 Musical Instruments

SECTOR Y: RUBBER, MISCELLANEOUS PLASTIC PRODUCTS, AND MISCELLANEOUS MANUFACTURING FACILITIES (continued)

• Page 14

GOA Exhibit TF-5 TPDES Multi Sector Gemeral Permit SOAH Docket No. 582-08-2186 TGEQ Docket No. 2006-0612-MSW Page 14 of111


Description of Industry Sub-sector

3942-3949

SIC Code

Dolls, ToYs, Games and Sporting and Athletic Goods

3951-3955 (except Pens, Pencils, and Other Artists' Materials 3952) SIC 3952 See Sector C

3961,3965 Costume Jewelry, Costume Novelties, Buttons, and Miscellaneous Notions, Except Precious Metal

3991-3999 Miscellaneous Manufacturing Industries

. SECTORZ: LEATHER TANNING AND FINISHING

SIC Code .Description oflndustry Sub-sector

Leather Tanning: and Finishing

SECTOR AA: FABRICATED METAL PRODUCTS FACILITIES

SIC Code'

3111

Description of Industry Sub-sector

3411-3499 Fabricated Metal Products, Except Machinervand Transportation Equipment

3911-3915 Jewelrv. Silverware and Plated Ware

• SECTOR AB: TRANSPORTATION EQUIPMENT, INDUSTRIAL OR COMMERCIAL

MACHINERY MANUFACTURING FACILITIES


3511-3599 Industrial and Commercial Machinery (except 3571-3579) (Computer and Office Equipment, see Sector AC)

Transportation Equipment (except 37313732)

3711-3799 (Shin and Boat'Building: and Repairing:. see Sector R)

SECTOR AC: ELECTRONIC, ELECTRICAL, PHOTOGRAPHIC, AND OPTICAL GOODS

SIC Code Description of Industrv Sub-sector

3571-3579 Computer and Office Equipment

3612-3699 Electronic, Electrical Equipment and Components,. except Computer Equipment

3812-3873 Measuring, Analyzing and Controlling Instrument; Photographic and Optical Goods

• Page 15

COA Exhibit TF-5 TPDES Multi Sector Gemeral Permit SOAH Docket No. 582."08-2186 TCEQ Docket No. 2006-0612-MSW Page 15 of 111


SECTOR AD: MISCELLANEOUS INDUSTRIAL ACTIVITIES

SIC Code Description ofIndustry Sub-sector

Not auulicable Miscellaneous Industrial Activities Desilmated bv the Executive Director

• 2.

3.

• Page 16

The need for a permit, and the eligibility for coverage under this general permit, is determined either by a facility's primary SICcode or by an Industrial Activity Code that is described in this general permit. This general permit includes four Industrial Activity Codes: HZ (Hazardous Waste), LF (Landfills), SE (Steam Electric Power Generation), and TW (Treatment Works). Sectors of industrial activity are divided into sub-sectors and further defined by SIC codes in Part V of this general permit.

Operators of facilities with a primary SIC code that is included in Part V of this general permit must obtain authorization for discharges of storm water associated with industrial activity and are eligible for coverage under this general TPDES permit. The requirements for federal facilities and military installations are further described below in Part II.A.5. of this general permit. Additionally, the operator of any facility that conducts activities described by an Industrial Activity Code that is included in Part V of this general permit; must obtain authorization for discharges of storm water associated with industrial activity and are eligible for coverage under this TPDES general permit.

Sector AD is used to provide permit coverage for facilities that are designated by the executive director as needing a permit to control pollution related to storm water discharges and that do not meet the description of an industrial activity covered by Sectors A-AC. A facility that is not otherwise listed in Part V of this general permit is not eligible to apply for coverage under AD unless directed to do so in writing by the executive director.

Co-located Industrial Activities

Operators are required to either obtain authorization under this general permit, under an individual TPDES storm water permit, or under an alternative general permit ifthe primary SIC code for the facility is one of those listed in Part V of this general permit or if the facility conducts any of the industrial activities described by the Industrial Activity Codes (HZ, LF, SE, or TW) listed in the table in Part II.A.I. above. If these facilities conduct additional activities that are described by a secondary SIC code that is listed in the table, then these additional activities are described as co-located activities. Storm water discharges from co-located industrial activities may be authorized under this general permit, provided that the operator complies with all of the sector specific requirements defined in Part V of this general permit for each of these co-located activities. The sector specific requirements apply only to the portion of the facility where that specific sector of activity occurs, except where runoff from different activities combine before leaving the property. In cases where these discharges combine, the monitoring requirements and effluent limitations from each sector that contributes runoff to the discharge must be met.

Co-located Industrial Facilities

Facilities are required to either obtain authorization under this general permit, under an individual TPDES storm water permit, or under an alternative general permit, if the primary SIC code for the facility is one of those listed in Part II.A.I. of this general permit, or if the facility conducts any of the industrial activities described by the Industrial Activity Codes listed in Part II.A I. Multiple industrial facilities may be described as "co-located" if they share a common property boundary. If authorization under this general permit is sought, the operator of each of co-located facility must individually submit a notice of

COA.Exhibit TF-5 TPDES Multi Sector Gerneral Permit SOAH Docket No. 582c08-2186 TCEQ Docket No. 2006-0612-MSW Page 16 of 111


intent (NOI) to obtain coverage under this general permit. Each co-located facility will be issued a distinct authorization number. Each co-located industrial facility operator may either develop a separate storm water pollution prevention plan (SWP3, or "plan"), or may participate in a shared SWP3. Colocated industrial facilities that develop a shared SWP3 must develop the SWP3 to meet the requirements stated in Parts III and V of this general permit, in addition to the following:

(a) Participants - The SWP3 must clearly list the name and authorization number (when known) for each facility that participates in the shared SWP3. Each participant in the shared plan must sign the SWP3 according to 30 TAC § 305.128 (relating to Signatories to Reports.)

(b) Responsibilities - The SWP3 must clearly indicate which permittee is responsible for performing each shared element ofthe SWP3. Ifthe responsibility for performing an element is not described in the plan, then each permittee is entirely responsible for performing the element within the boundaries of its facility and in any common or shared area. The SWP3 must clearly describe responsibilities for meeting each element in shared or common areas.

(c) Site Map - The site map must clearly delineate the boundaries around each co-located industrial facility and the boundaries around shared or common areas that are used by two or more facilities.

4. Requirements for Military Installations and Other Federal Facilities

• 5.

Storm water discharges from military installations and other federal facilities that conduct any industrial activities described by a primary SIC code or Industrial Activity Code that is listed in Part II.A.l. and Part V of this general permit must either be authorized under this general permit, an individual TPDES storm water permit, or an alternative general permit. For example, the primary SIC code of military installations is 9711, which is not listed in this general permit; however, the need for a permit will be based on any individual activities that occur at the installation.

Non-Storm Water Discharges

Industrial facilities that qualify for coverage under this general permit may discharge the following nonstorm water discharges through outfalls identified in the SWP3, according to the requirements of this general permit:

(a) discharges from fire fighting activities and uncontaminated fire hydrant flushings (excluding discharges ofhyperchlorinated water, unless the water is first dechlorinated and discharges are not expected to adversely affect aquatic life);

(b) potable water sources (excluding discharges of hyperchlorinated water, unless the water is first dechlorinated and discharges are not expected to adversely affect aquatic life);

(c) lawn watering and similar irrigation drainage;

(d) water from the routine external washing of buildings, conducted without the use of detergents or other chemicals;

(e) water from the routine washing of pavement conducted without the use of detergents or other chemicals and where spills or leaks of toxic or hazardous materials have not occurred (unless all spilled material has been removed);

(t) uncontaminated air conditioner condensate, compressor condensate, and steam condensate;

• Page 17



(g) water from foundation or footing drains where flows are not contaminated with polIutants (e.g., process materials, solvents, and other polIutants);

(h) uncontaminated water used for dust suppression;

(i) springs and other uncontaminated ground water; and

(j) other discharges described in Part V of this permit that are subject to effluent guidelines and effluent limitations.

Section B. Limitations on Permit Coverage

1. Suspension or Revocation of Permit Coverage

Authorization under this general permit may be suspended or revoked for cause. Filing a notice of planned changes 6r anticipat~d non-compliance by the permittee does not stay any permit condition. The permittee shalI furnish to the executive director, upon request, any information necessary for the executive director to determine whether cause exists for revoking, suspending, or terminating authorization under this permit. AdditionalIy, the permittee shall provide to the executive director, upon request, copies of all records that the permittee is required to maintain as a condition of the permit.

Failure to comply with any permit condition is a violation of the permit and the statutes under which it was issued, and is grounds for enforcement action, terminating coverage under this general permit, or requiring the permittee tC!apply fQr and obtain an individual TPDES permit or alternative general permit.

2. Discharges Authorize~ by Another TPDES Permit

Discharges authorized by an individual TPDES permit or another general TPDES permit may only be authorized under this TPDES general permit if the following conditions are met:

(a) the discharges meet the applicability and eligibility requirements for coverage under this general permit;

(b) the current individual or alternative general permit does not contain numeric water quality-based effluent limitations for the discharge (unless industrial activities that resulted in the limitations have ceased and any contamination that resulted in these limitations has been removed or remediated);

(c) specific best management practice (BMP) requirements of th~ current individual permit are continued as a provision of the SWP3;

(d) the executive director ha~ not determined that <;ontinued coverage under an individual permit is required based on consideration ofa total maximum daily loading (TMDL) model, anti-backsliding policy, history ofsubstantive non-compliance or other considerations and requirements 000 TAC Chapter 205, or other site-specific considerations; and

(e) a previous application or permit for the discharges has not been denied, terminated, or revoked by the executive director as a result of enforcement or water quality related concerns.' The executive director may provide a waiver to this'provision based on new circumstances at the facility or if the operations of the facility have since passed to a new operator.

• Page 18

COA ExhibitTF-5 TPDES Multi Sector Gerneral Permit SOAH Docket No. 582-08~2186 TCEQ Docket No. 2006-0612-MSW Page 18 of 111'


3. Storm Water Discharges' from Construction Activity

Discharges ofstorm water associated with construction activities are not eligible for authorization by this general permit. Discharges of storm water that are regulated under this permit and that combine with storm water from construction activities are not eligible for coverage by this general permit unless the construction site runoff meets one of the following: is authorized under a separate TPDES permit; is authorized under a separate National Pollutant Discharge Elimination System (NPDES) permit; or does not require permit coverage.

4. Storm Water Discharges from Salt Storage Piles

Storm water that contacts salt storage piles (e.g., salt for deicing or other commercial or industrial purposes) may not be discharged to surface water in the state under authority of this general permit. Storm water that contacts salt storage piles must be discharged under the authority of an individual TPDES permit, alternative general permit, or captured within a containment structure. Storm water that contacts salt storage piles and is captured must either be disposed of in a manner that does not allow a discharge into or adjacent to water in the state, or in a manner otherwise approved by the executive director.

5. Discharges of Storm Water Mixed with Non-Storm Water

Storm water discharges associated with industrial activity that combine with sources ofnon-storm water are not eligible for coverage by this general permit, unless either the non-storm water source is described in Part n.A.5. ofthis permit or the non-storm water source is authorized under a separate TPDES permit.

• 6. Compliance With Water Quality Standards

Discharges that would cause or contribute to a violation of water quality standards, or that would fail to protect and maintain existing designated uses of receiving waters are not eligible for coverage under this general permit. The executive director may require an application for an individual permit or alternative general permit to authorize discharges of storm water from any industrial facility that is determined to cause a violation of water quality standards or is found to cause, or contribute to, the loss ofa designated use of receiving waters.

7. Discharges to Water Quality-Impaired Receiving Waters

New sources or new discharges ofthe constituent(s) of concern to impaired waters are not authorized by this permit, unless otherwise allowable under 30 TAC Chapter 305 and applicable state law. Impaired waters are those that do not meet applicable water quality standard(s) and are listed on the Clean Water Act Section 303(d) list. Constituents of concern are those for which the water body is listed as impaired.

Discharges of the constituent(s) of concern to impaired water bodies for which there is a TMDL implementation plan are not eligible for this permit unless they are consistent with the approved TMDL and the implementation plan. Permitted facilities must incorporate the limitations, conditions, and requirements applicable to their discharges, including monitoring frequency and reporting required by TCEQ rules into their SWP3 in order to be eligible for permit coverage. For discharges not eligible for coverage under this permit, the discharger must apply for and receive an individual permit or other applicable general TPDES permit prior to discharging.

• Page 19



8. Discharges to the Edwards Aquifer Recharge Zone

Discharges of storm water associated with industrial activity and other non-storm water discharges can not be authorized by this general permit where those discharges are prohibited by 30 TAC Chapter 213 (relating to Edwards Aquifer). New discharges located within the Edwards Aquifer Recharge Zone, or within that area upstream from the recharge zone and defined as the Contributing Zone, must meet all applicable requirements of, and operate according to 30 TAC Chapter 213, in addition to the provisions and requirements of this general permit.

For existing discharges, the requirements ofthe agency approved Water Pollution Abatement Plan under the Edwards Aquifer Rules are in addition to the requirements of this general permit. BMPs and maintenance schedules for structural storm water controls, for example, may be required as a provision of the rule. All applicable requirements of the Edwards Aquifer Rule for reductions of suspended solids in storm water runoff are in addition to the effluent limitation requirements and benchmark goals in this general permit for this pollutant. A copy ofthe agency approved Water Pollution Abatement Plans that are required by the Edwards Aquifer Rule shall be attached as a part of the SWP3.

For discharges located within ten stream miles upstream of the Edwards Aquifer recharge zone, applicants shall also submit a copy of the NO! to the appropriate TCEQ regional office.

Counties: Contact:

• Comal, Bexar, Medina, Uvalde, and Kinney TCEQ

Water Program Manager San Antonio Regional Office 14250 Judson Road San Antonio, Texas (210) 490-3096

Williamson, Travis, and Hays TCEQ Water Program Manager Austin Regional Office 1921 Cedar Bend Drive, Suite. 150 Austin, Texas (512) 339-2929

9. Discharges to Specific Watersheds and Water Quality Areas

Discharges of storm water associated with industrial activity and other non-storm water discharges can not be authorized by this general permit where prohibited by 30 TAC Chapter 311 (relating to Watershed Protection) for water quality areas and watersheds.

10. Protection of Streams and Watersheds by Home-Rule Municipalities

This general permit does not limit the authority ofa home-rule municipality provided by Section 401.002 of the Texas Local Government Code.

11. Facilities with No Discharge to Surface Water in the State

A facility that does not discharge storm water to an MS4 nor to surface water in the state may not be required to obtain coverage under this general permit ifthe operator demonstrates that no discharges have occurred nor will occur in the future. The operator may be required to demonstrate, using engineering

• Page 20



calculations or similar methods, that the facility will not discharge storm water associated with industrial activity.

Facilities that dispose of storm water by any of the following practices would not be required to obtain coverage under this general permit nor under an individual permit:

(a) Recycling of the storm water with no resulting discharge into or adjacent to surface water in the state;

(b) Pumping and hauling of the storm water to an authorized disposal facility;

(c) Discharge of the storm water to a publicly-owned treatment works (POTW);

(d) Underground injection of the storm water in accordance with 30 TAC Chapter 331;

(e) Discharge to above ground storage tanks with no resultingdischarge into or adjacent to water in the state;

(f) Containment of all storm water within property boundaries, with no discharge into surface water in the state, including no discharge during, or as the result of, any storm event.

Section C. Obtaining Authorization to Discharge

1. Conditional No Exposure Exclusion from Permit Requirements

• Facilities regulated under this general permit may be excluded from permit requirements if there is no exposure of industrial materials or activities from precipitation or runoff. To qualify for a no exposure exclusion from permit requirements, the operator ofthe facility must provide certification that industrial activities and materials are isolated from storm water and storm water runoff by storm resistant shelters. The certification shall be submitted to tp.e TCEQ on a form provided by the executive director or using a format approved by the executive director. The facility is subject to inspection by authorized TCEQ personnel to determine compliance with the no exposure exclusion. Facilities that qualify for this exclusion and that contribute storm water discharges to a municipal separate storm sewer system (MS4) shall provide copies of the certification to the operator of the MS4.

The following materials and activities are not required to be isolated from storm water and storm water runoff in order to meet the no exposure exclusion:

(a) drums, barrels, and similar containers that are tightly sealed, in good structural condition, without operational valves, and storage tanks in good structural condition without leaking valves;

(b) final products, that are designed for outdoor use, except products that could be transported by storm water runoff (e.g., rock salt, wood chips);

(c) pallets used to store or transport final products intended for outdoor use, if the pallets are new or do not contain pollutants; and

(d) vehicles used in material handling that are adequately maintained to prevent leaking fluids.

• Page 21



Facilities which at one time qualify for the no exposure exclusion from permit requirements, but which change operating or management practices so as to result in exposure of industrial activities to storm water, must obtain permit coverage to discharge storm water before implementing the changes that result in exposure of industrial activities to storm water runoff.

2. Application for Coverage

Applicants seeking authorization to discharge under this general permit shall submit a completed NOI on a form approved by the executive director. Provisional authorization begins 48 hours after a completed NOI is postmarked for delivery to the TCEQ. If the TCEQ provides for electronic submission ofNOIs during the term ofthis permit, provisional authorization begins 24 hours following confirmation ofreceipt ofthe electronic NOI form by the TCEQ. Following review ofthe NO!, the executive director will: 1) determine that the NOI is complete and confirm coverage by providing a written notification and an authorization number; 2) determine that the NOI is incomplete and request additional information needed to complete the NOI; or 3) deny coverage in writing. Denial of coverage will be made in accordance with TCEQ rules related to General Permits for Waste Discharges, 30 TAC § 205.4.. Application deadlines are as follows:

•

(a) Existing Industrial Facilities - Facilities that are authorized under the previous Texas Pollutant Discharge Elimination System (TPDES) permit for discharges associated with industrial activity (TXR050000, issued August 20, 2001) may continue to operate under the provisions ofthat permit for 90 days after the issuance date ofthis general permit. Facilities which elect to utilize electronic NOI submittal may continue to operate under the provisions of the previous permit for 120 days after issuance of this general permit. Within 90 days following the effective date of this general permit, existing permittees must obtain coverage under this permit, except that permittees which obtain coverage by submitting an NOI electronically must obtain coverage within 120 days following the effective date of this general permit. The Executive Director may grant written request for extension for good cause ifsuch written request is received no later than 15 days before the deadline for filing a paper NO! (75 days following permit issuance).

Facilities that are authorized und~r the previous National Pollutant Discharge Elimination System (NPDES) permit for discharges associated with industrial activity (TXR050000, issued by the U.S. EPA in 1995) and that had been granted extensions by the executive director for obtaining coverage under this general permit must submit an NOI within 90 calender days of the issuance date of this general permit, or within 120 days if electronic NO! submittal is utilized.

Facilities which were required to obtain permit coverage under the previous TPDES MSGP (issued August 20, 2001) are considered to be existing facilities, regardless ofwhether an NOI or NEC had previously been submitted under that general permit. The deadline for these facilities to submit an NO! or NEC is immediately upon permit issuance. However, this permit does not preclude a facility from submitting an NOI or NEC after the permit issuance date.

(b) New Industrial Facilities - An NO! must be submitted prior to commencement ofindustrial activity that could result in a discharge of storm water runoff subject to the requirements of this general permit.

(c) New Operator - Permit coverage may not be transferred. When the operator ofa facility or portion of a facility changes, the new operator must submit an NOI at least two days before the change. The previous operator must submit an NOT at least two days after the new operator has submitted the NOI.

• Page 22



3. Storm Water Pollution Prevention Plan (SWP3)

A permittee authorized under this general permit must develop and implement a storm water pollution prevention plan (SWP3) according to the requirements ofthis permit before submitting an NOI for permit coverage. The plan must be developed according to the requirements of Part III of this general permit, must include all sector specific requirements of Part V, and must be signed according to TCEQ rules at 30 TAC § 305.128, as described in Part Ill.E.3.(g) of this general permit. The SWP3 must also contain the certification statement from 30 TAC § 305.44 as required in Part llLA.3.(c) of this general permit.

4. Contents of the Notice of Intent

The NOI must contain the following minimum information:

(a) Operator Information:

(1) the name, address, and telephone number of the operator filing the NOI for permit coverage; and

(2) the legal status of the operator (e.g., federal, state, private or public entity).

(b) Site Information - The NOI must include:

(1) the name, address, county, and latitude and longitude of the site;

• (2) a determination of whether the site is located on Indian Land;

(3) the name of the receiving water;

(4) the name of the MS4 operator if the discharge is to an MS4;

(5) a certi fication that a SWP3 has been developed and implemented according to the provisions of this permit;

(6) the primary SIC code that best describes the industrial activity of the facility and any other SIC codes or Industrial Activity Codes that describe additional activities and that are listed in Part V of this permit; and

(7) the industrial sector of this general permit for which the applicant requests coverage.

(c) Existing TPDES authorization number for facilities previously regulated under the TPDES MSGP.

5. Notice of Change (NOC)

If an applicant or permittee becomes aware that it failed to submit any relevant facts or submitted incorrect information in an NOI, the correct information must be provided to the executive director in an NOC letter within 14 days after discovery. If relevant information provided in the NOI changes (for example, facility name, phone number, or P.O. Box number), an NOC letter must be submitted within 14 days of the change. The NOC shall be submitted on a form provided by the executive director, or by letter if an NOC form is not available.

• Page 23

COA ExhibitTF-5 TPDES Multi Sector Gerneral Permit SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 23 of 111


6. Terminating Coverage

A permittee may terminate coverage under this general permit, or may terminate the conditional no exposure exclusion, by providing a Notice of Termination (NOT) to the TCEQ.· The NOT must be submitted on a form approved by the executive director. Authoriz~tion to discharge terminates at midnight on the day that an NOT is postmarked for delivery to the TCEQ. If TCEQ provides for electronic submission ofNOTs during the term of this permit, then authorization to discharge terminates 24 hours following confirmation of receipt of the electronic NOT form by the TCEQ. An NOT must be submitted within 10 days after the facility ceases discharging storm water associated with industrial activity, obtains coverage under an individual permit, obtains coverage under an alternative general permit, or within 10 days following transfer of ownership or responsibility of the facility.

An NOT shall be submitted in order to terminate coverage or to terminate a conditional exclusion based on no exposure. If a facility changes operations such that a condition of no exposure is obtained, the permittee must submitan NOTto terminate the original NO! before submitting an NEC. If a facility which changes conditions such that a condition of no exposure no longer exists, the permittee must submit an NOT to terminate the conditional exclusion, and must obtain coverage before discharge occurs.

7. Signatory Requirements

The NO!, NOT, NOC, and NEC forms (or letters, as applicable) must be signed and certified according to 30 TAC § 305.44 (relating to Application for Permit).

8. Additional Notification

• Industrial facilities that contribute storm water discharges to a municipal separate storm sewer system must provide a copy of the completed NOI or NEC to the operator of the system. These facilities must also provide a copy of all NOCs and NOTs to the operator of the system.

9. Fees

An application fee of $1 00 must be submitted with each NO! and each NEC. A fee is not required for submission of an NOT or NOC.

A facility authorized under this general permit and required to submit an NO! must pay an annual water quality fee of $200 under Texas Water Code, § 26.0291, and according to 30 TAC Chapter 205 (relating to General Permit for Waste Discharges).

10. . Permit Expiration

This general permit is issued for a term not to exceed five years. Following public notice and comment, as provided by 30 TAC § 205.3 (relating to Public Notice, Public Meetings, and Public Comment), the Commission may amend, revoke, cancel, or renew this general permit. If the TCEQ publishes a public notice of its intent to renew or amend this general permit before the expiration date, then this general permit will remain in effect for existing, authorized discharges until the Commission takes final action on the permit. Upon issuance ofa renewed or amended permit, permittees may be required to submit an NOI within 90 day·s following the effective date of the renewed or amended permit.

• Page 24

eOA Exhibit TF-5 TPDES Multi Sector Gemeral Permit SOAH Docket No. 582-08-2186 TCEQ Docket No. 200e-Qe12-MSW Page 24 of 111


In the event that the general permit is not renewed, discharges that are authorized under the general permit must obtain either a TPDES individual permit or coverage under an alternative general permit. Applications for an individual permit must be submitted at least 180 days before the expiration date of the general permit.

Section D. Alternative Coverage Under An Individual TPDES Permit

1. Individual Permit Alternative

Any discharge eligible for coverage under this general permit may alternatively be authorized under an individual TPDES permit according to 30 TAC Chapter 305 (relating to Consolidated Permits).

2. Individual Permit Required

The executive director may require an operator of an industrial facility, authorized by this permit, to apply for an individual TPDES permit because of: a total maximum daily load (TMDL) model; the antibacksliding policy; a history ofsubstantive non-compliance or other 30 TAC Chapter 205 considerations and requirements; or other site-specific considerations.

•

• Page 25



Part III. Permit Requirements and Conditions Common to all Industrial Activities

Section A. Minimum Storm Water Pollution Prevention Plan (SWP3) Requirements

1. Implementation of SWP3 and Consistency With Other Plans

(a) An applicant seeking authorization under this general permit must develop and implement a storm water pollution prevention plan (SWP3) before submitting an NOI for coverage under this general permit. The SWP3 must be maintained onsite and made readily available for review by authorized TCEQ personnel upon request. Permittees that contribute storm water discharges to a municipal separate storm sewer system (MS4) must also provide a copy of the SWP3 to the operator of that MS4 upon receiving a request from the MS4 operator. The SWP3 shall be developed according to the requirements of this general permit to:

(1) identify actual and potential sources of pollution that may reasonably be expected to affect the quality of storm water discharges from the facility;

(2) establish practices and any necessary controls that will prevent or effectively reduce pollution in storm water discharges from the facility and that ensure compliance with the terms and conditions of this general permit;

(3) describe how the selected practices and controls are appropriate for the facility and how each will effectively prevent or lessen pollution;

• (4) discuss how controls and practices relate to each other such that together they comprise an

integrated, facility-wide approach for pollution prevention in storm water discharges. The discussion may include references to literature or site-specific performance information on the selected controls and practices to demonstrate the appropriateness of each.

(b) Existing plans and measures that s.tem from other regulatory requirements, such as Spill Prevention Control Countermeasures (SpeC plans are required for certain operations under the federal guidelines of40 CFR Part 112) may satisfy in whole or in part specific requirements ofthis general permit. These plans may either be attached as a component of the SWP3, or referenced in the SWP3 and made readily available for review by authorized TCEQ personnel upon request.

2. Pollution Prevention Team

A storm water Pollution Prevention Team shall be established. The SWP3 shall be kept readily available to the members of the team, as well as all employees.

(a) Members of the Team: The SWP3 must identify the members of the storm water Pollution Prevention Team. The team may consist of a single individual or a group of individuals. If the facility is not staffed on a continuous or permanent basis, then a company employee, or employees, from outside of the facility may be identified as a part of the team. Additional members of the team may include environmental professionals that are under contract to the permittee. The responsibilities for each member ofthe team shall be listed and clearly described. The SWP3 may identify a position within the organization rather than a specific individual, if it is not feasible to provide a name, and provided that members of the organization can identify the particular individual(s) comprising the team.

• Page 26



(b) Responsibility of the Team: The team is responsible for development of the SWP3 and for assisting the operator or the operator's designee in the implementation, maintenance, and revision of the SWP3.

3. Investigation and Certification of Non-Storm Water Discharges

(a) Permit Coverage for Non-Storm Water Discharges: Non-storm water discharges eligible for coverage are described in either Part ll.A.5. or Part V ofthis general permit. All non-storm water discharges that qualify for permit coverage shall be identified in the SWP3. The SWP3 shall describe the discharge points and appropriate best management practices (BMPs) for these nonstorm water discharges.

(b) Investigation for Non-Storm Water Discharges: A survey of potential non-storm water sources shall be conducted. The facility's separate storm sewer system shall be, tested or inspected (e.g., screened for dry weather flows) for the presence of non-storm water flows. Procedures shall be evaluated and implemented to eliminate any potential sources that are discovered and are not permitted. The SWP3 must ensure that non-storm water sources are not combined with storm water discharges from the facility and are not allowed to enter the separate storm sewer system, unless they are authorized under a TPDES permi t.

• (c) Certification: The SWP3 must include a certification, signed according to Part III.E.3.(g) of this

general permit, relating to Signatory Requirements, that states that the facility's separate storm sewer system has been evaluated for the presence of non-storm water discharges and that the discharge of non-permitted, non-storm water does not occur. The certification shall include documentation of how the evaluation was conducted, results of any testing, dates of evaluations or tests, and the points in the separate storm sewer system that were observed during the investigation. The investigation· for non-storm water discharges must be completed and the certification must be prepared within 180 days of filing an NOI for permit coverage. The certification shall be made readily available for review by authorized TCEQ personnel upon request.

(d) Failure or Inability to Certify:

(1) If a part of the separate storm sewer system can not be accessed to complete the evaluation, certification shall be provided for the remainder of the system. Notice of this deficiency must be provided to the TCEQ within 180 days after the NO! is submitted. Facilities that contribute storm water discharges to an MS4 must provide notice of this deficiency to the operator of that system upon request. The notice shall include an explanation of why the evaluation could not be performed and a list of all known potential, non-permitted, nonstorm water sources that could not be included in the certification. The notification shall be submitted to the TCEQ's Enforcement Division (MC-224).

(2) If, in the course of evaluating its separate storm sewer system, the permittee is unable to certify that non-permitted, non-storm water discharges are not occurring due to noncompliance, then the certification shall identify the noncompliance issues and the steps being taken to remedy and prevent further noncompliance.

• Page 27

COA Exhibit TF-5 TPDES Multi Sector GerneraJ Permit SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 27 of 111


4. Description of Potential Pollutants and Sources

The SWP3 shall identify and describe all activities and significant materials that may potentially be pollutant sources. The SWP3 shall include, at a minimum:

(a) Inventory of Exposed Materials: An inventory shall be developed that lists materials currently handled at the facility that may be exposed to precipitation or runoff. The list must include all materials that are handled, stored, processed, treated, or disposed of in a manner that allows exposure to precipitation or runoff. Materials stored in drums, barrels, tanks, and similar containers that are tightly seaied, in good structural condition, and do not have leaking valves are not required to be listed in the inventory. The inventory of materials shall also include specific pollutants (e.g. oil and grease, copper, wood shavings, etc.) that can be attributed to those materials.

For facilities which are subject to reporting requirement under EPCRA Section 313, the SWP3 shall list all potential pollutant sources for which they have reporting requirements under EPCRA Section 313.

•

The inventory must be updated within 30 days following a significant change in the types of materials that are exposed to precipitation or runoff, or significant changes in material management practices that may affect the exposure of materials to precipitation or runoff. A significant change in the types ofmaterials is exposure ofa material, not already included in the inventory, that could be transported by precipitation or storm water runoff and subsequently discharged. A significant change in material management practices is a change that would result in either initial exposure of a material not already listed in the inventory or increased exposure of a material to the extent that the material could be transported by precipitation or storm water runoff and subsequently discharged.

(b) Narrative Description: A narrative description must be developed to describe all activities and potential sources of pollutants that may reasonably be expected to add pollutants to storm water discharges or that may result in dry weather discharges from the storm sewer system. Examples include the following activities and potential sources when they are exposed to storm water:. (1) loading and unloading areas (including areas where chemicals and other materials are

transferred);

(2) outdoor storage areas;

(3) outdoor processing areas;

(4) dust producing activities;

(5) on-site waste disposal areas;

(6) vehicle/equipment maintenance, cleaning, and fueling areas;

(7) liquid storage tank areas; and

(8) railroad sidings, tracks, and rail cars.

• Page 28



For each pollutant or material listed in the "Inventory ofExposed Materials," the direction offlow or potential flow to the final permitted outfalls shall be identified. The outfall and direction offlow must either be narratively described or identified by referencing the location on the site map. Areas of the facility that have a high potential for significant soil erosion, due to topography, activities, or other factors, shall also be identified and either narratively described or identified by referencing the location on the site map.

The narrative description must be updated within 30 days following a change in the types or quantities of materials exposed to precipitation or runoff that, in the judgement of the storm water Pollution Prevention Team, may reasonably be expected to add pollutants to storm water discharges. The narrative description must be updated to describe changes in material management practices or other factors that may affect the exposure of materials to precipitation or runoff.

(c) Site Map - A site map (or maps) shall be developed that depicts the following:

(1) the location of each outfall covered by the permit, and the location of each sampling point (if different from the outfall location);

(2) an outline of the drainage area that is within the facility's boundary and that contributes storm water to each permitted outfall;

(3) connections or discharges to municipal separate storm sewer systems;

(4) locations of all structures (e.g. buildings, garages, storage tanks);

• (5) structural control devices that are designed to reduce pollution in storm water runoff;

(6) process wastewater treatment units (including ponds);

(7) bag house and other air tre~tment units exposed to precipitation or runoff;

(8) landfills; scrapyards; surface water bodies (including wetlands);

(9) vehicle and equipment maintenance areas;

(10) physical features of the site that may influence storm water runoff or contribute a dry weather flow;

(11) locations where reportable quantity spills or leaks (as defined in 30 TAe § 327.2) have occurred during the three years before the NO! is submitted to obtain coverage under this general permit; and

(12) processing areas, storage areas, materialloadinglunloading areas, and other locations where significant materials are exposed to precipitation or runoff.

The site map shall clearly show the flow of storm water runoff from each ofthese locations so that the final outfall where the discharge leaves the facility's boundary is apparent. A series of maps must be developed where the amount of information would cause a single map to be difficult to read and interpret.

• Page 29

COA Exhibit TF-5 TPDES Multi Sector Gerneral Permit SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-Q612-MSW Page 29 of 111


(d) Spills and Leaks - The .SWP3 shall contain a list ofreportable quantity spills and leaks oftoxic or hazardous pollutants (based on TCEQ requirements at 30 TAC Chapter 327) that occurred in areas exposed to precipitation or runoff, or that occurred within the drainage area that contributes to an outfall, during the three years before the NO! was submitted. The list shall be updated on a quarterly basis and shall include all additional spills and leaks (in addition to the previously listed spills of "reportable quantity" only). The list may be limited to any spills and leaks that have occurred within the previous five years.

(e) Sampling Data - All data from the laboratory analyses of storm water.discharge samples shall be summarized.. The summary shall be updated on an annual basis to include the results of all additional analyses; The data summary shall either be included as an attachment to the SWP3 or may be referenced and maintained separately. The data summary must be readily available for review by authorized TCEQ personnel upon request.

5. Pollution Prevention Measures and Controls

Pollution prevention practices that are determined to be reasonable and effective by the Pollution Prevention Team, required by a state or local authority, or necessary to remain compliant with this general permit, shall be implemented. The SWP3 shall include detailed descriptions of the following minimum components and a schedule for implementation: .

. .

• (a) Good Housekeeping Measures: A section within the SWP3 shalLbe developed toensure that areas

ofthe facility which contribute or potentially contribute pollutants to storm water'discharges (e.g., areas around trash dumpsters, storage areas, loading docks, and outdoor processing areas) are maintained in a clean and orderly manner. Good housekeeping measures must include measures to eliminate or reduce exposure of garbage and refuse materials to precipitation or runoff prior to their disposal. Typical good housekeeping measures include activities that are performed on a daily basis by employees during the course of normal work activities. The good housekeeping measures shall be incorporated as a part of the employee training program.

(b) Spill Prevention and Response Measures: A section within the SWP3 shall be developed and implemented to prevent spills and to provide for adequate spill response. This section must:

(1) identify areas where spills could contribute pollutants to storm water discharges;

(2) develop and implement procedures to minimize or prevent contamination of storm water from spills (e.g. training equipment operators to inspect for leaks each day during operation of equipmerit; installation of secondary containment structures aro.und liquid storage tanks and drums; installation of overfill prevention devices on pumps and tanks; modification of material handling techniques; and routine inspection of drums, tanks and other containers);

(3) require drums, tanks, and other containers to be clt:arly labeled;

(4) require that hazardous waste containers that require special handling, storage, use, and disposal be clearly marked;

(5) develop and implement specific spill prevention and clean up techniques;

(6) make available to facility personnel materials and equipment necessary for spill clean up;

(7) develop and maintain an inventory of spill cleanup materials and equipment; and

• Page 30



(8) incorporate these measures as a part of the employee training program.

(c) Erosion Control Measures: A section within the SWP3 shall be developed to address soil erosion. Erosion prevention measures and controls shall be evaluated and used as necessary to reduce soil erosion in areas of the facility that have ongoing erosion or the potential for soil erosion. The following controls shall be evaluated, at a minimum: Soil stabilization through vegetative cover; contouring slopes; paving; and installation of structural controls.

(d) Maintenance Program for Structural Controls: A section within the SWP3 shall be developed to establish a maintenance program for storm water structural controls, which may include oil/water separators, catch basins, sediment ponds, grass swales, berms, and other structural controls. These controls shall be inspected on a regular basis and maintenance frequencies must be established for each of the controls at intervals that ensure effective operation. Mechanical equipment that is part of a structural control, such as a storm water pump, must also be inspected at intervals described in the SWP3 and maintained at intervals necessary to prevent failures that could result in a discharge of pollutants. This section of the SWP3 shall identify qualified personnel to conduct inspections and establish inspection and maintenance schedules. Records must document the estimated volumes ofsolids removed from catch basins, sediment ponds, and other similar control structures.

(e) Best Management Practices fBMPs): A section within the SWP3 shall be developed to establish BMPs to reduce the discharge and potential discharge ofpollutants in storm water. Development ofBMPs shall be based on the activities and potentials for contamination that are identified in Part III.A.4. of this general permit, "Description of Potential Pollutants and Sources."

(f) Employee Training Program and Employee Education: A section within the SWP3 shall be • developed to establish a training program. Training shall be provided to all employees who are responsible for implementing or maintaining activities identified in the SWP3. Employee training shall include, at a minimum:

(1) proper material management and handling practices for specific chemicals, fluids, and other materials used or commonly encountered at the facility;

(2) spill prevention methods;

(3) the location of materials and equipment necessary for spill clean up;

(4) spill clean up techniques;

(5) proper spill reporting procedures; and

(6) familiarization with good housekeeping measures, BMPs, and goals of the SWP3.

The schedule for employee training sessions must be developed based on pollutant potential, employee turnover rate, and other factors the permittee determines are applicable. Training must be conducted at least once per year and records of training activities must be maintained.

Education must be provided to those employees at the facility who are not directly responsible for implementing or maintaining activities identified in the SWP3, and who do not participate in the employee training program. At a minimum, these employees must be informed of the basic goal

• Page 31



of the SWP3 and how to contact the facility's storm water Pollution Prevention Team regarding storm water issues.

(g) Periodic Inspections - Qualified personnel, who are familiar with the industrial activities performed at the facility, shaIl conduct periodic inspections to determine the effectiveness of the Good Housekeeping Measures, Spill Prevention and Response Measures, Erosion Control Measures, Maintenance Program for Structural Controls, Best Management Practices, and the Employee Training Program. The inspection must also identify any existing BMPs that are not being properly or completely implemented. Periodic inspections must be conducted on a frequency of once per quarter, unless otherwise specified in Part V of this permit, relating to Specific Requirements for Industrial Activities. The inspections must be documented through the use of a checklist that is developed to include each of the controls and measures that are evaluated.

When revisions or additions to the SWP3 are recommended as a result of inspections, a summary description ofthese proposed changes must be attached to the inspection checklist. The summary must identify any necessary time frames required to implement the proposed changes. The periodic inspection checklists must be made readily available for inspeCtion and review by authorized TCEQ personnel upon request.

• (h) Quarterly Visual Monitoring - Storm water discharges from each outfall authorized by this general

permit must be visually examined on a quarterly basis. Where practicable, the same individual should carry out the coIlection and examination of discharges for the entire permit term to ensure consistency. Monitoring must be conducted during daylight hours during the normal hours of operation for the facility. Samples must be examined in a well lit area, and findings must document observations ofthe following: color, clarity, floating solids, settled solids, suspended solids, foam, oil sheen, other obvious indicators of storm water pollution, and any noticeable odors. Some examinations, such as an examination for odor and foam, may necessarily be conducted immediately following collection ofthe sample. All examinations must be performed within a time frame that ensures the sample is representative of the discharge.

Records ofquarterly visual monitoring must include the date and time samples were collected and examined, names ofpersonnel that collected and examined the samples, the nature ofthe discharge (e.g., runoff, snow melt), and the visual quality of the storm water discharge. Results of the examination shall be reviewed by the storm water Pollution Prevention Team. The team must investigate and identify probable sources ofany observed storm water contamination. The SWP3 shall be modified as necessary to address the conclusions ofthe storm water Pollution Prevention Team.

Part V may include alternative schedules for visual monitoring at specific industrial sectors, and may include additional requirements.

(i) Records - Records for each element described above in Part III.A.5.(a) through (h) of "Pollution Prevention Measures and Controls" shall either be included as an attachment to the SWP3 and retained on-site or made readily available for review by authorized TCEQ personnel upon request. Records shall document and describe maintenance activities, inspections, spills, discharge quality, employee training activities, employee education activities, SWP3 updates/modifications, and other events relative to each element.

• Page 32



6. Management of Runoff with Structural Controls

(a) Structural Controls: Physical structures may be used in conjunction with other pollution prevention measures and controls, as necessary, to reduce pollutants in storm water discharges. Examples of structural controls that may be utilized include vegetated swales, oil/water separators, settling ponds, catch basins, berms, and other physical structures.

(b) Velocity Dissioation Devices: Discharge velocities must be controlled to the extent necessary to prevent the destruction of the natural physical characteristics of receiving waters by erosion. Velocity dissipation devices may be constructed at discharge points or along channels and other storm water collection areas that lead to outfalls. Management alternatives to minimize runoff, such as limiting impervious cover, may also be considered.

7. Annual Comprehensive Site Compliance Evaluation

(a) Description: The comprehensive site compliance evaluation is a required. site inspection and an overall assessment ofthe effectiveness ofthe current SWP3. This evaluation is in addition to other routine inspections required by the permit (e.g., inspections of good housekeeping measures, structural controls, and for identification of non-storm water sources). This evaluation may, however, substitute for a periodic inspection (Part III.A.5.(g)) ifit is conducted during the regularly scheduled period of the periodic inspection.

• (b) General Requirements: The evaluation shall be conducted at least once per year by one or more

qualified employees or designated representatives, who are familiar with the industrial activities performed at the facility and the elements of the SWP3. The evaluation must include:

(l) inspection ofall areas identified in the Inventory ofExposed Materials section ofthe SWP3;

(2) inspection ofall structural controls, including the maintenance and effectiveness;

(3) inspection of all non-structural controls including BMP effectiveness, good housekeeping measures, and spill prevention;

(4) inspection of all reasonably accessible areas immediately downstream of each storm water outfall that i~authorized under this general permit; and

(5) a review of all records required by this general permit.

(c) Annual Site Compliance Evaluation Report - Within 30 days of performing the annual site compliance evaluation, the permittee must prepare a report which includes a narrative discussion of the permittee's compliance with the current SWP3. The report shall document the personnel

. conducting the evaluation, the dates of the evaluation, and any incidents ofnon-compliance. The following conditions relate to incidents of non-compliance:

(l) For purposes of this inspection, an incident of non-compliance is any instance where an element of the SWP3 is either not implemented, or where specific conditions of the permit are not met.

• Page 33



(2) Ifno incidents ofnon-compliance are discovered, the report shall contain a certification by the permittee that the facility, or in the case ofa shared SWP3, the portion ofthe facility the permittee is responsible for, is in compliance with the SWP3.

(3) If an incident or incidents of non-compliance is identified, then the report shall include all necessary actions to remedy the non-compliance and update the SWP3 in accordance with Part m.A.7.(d) of this permit. The identified actions must be completed as soon as practicable, but no later than 12 weeks following the completion of the report.

(4) The report shall either be included as a part of the SWP3 or referenced in the SWP3 and be made readily available for inspection and review by authorized TCEQ personnel upon request.

(d) Revision of the SWP3 - Within 12 weeks following the completion ofthe Annual Site Compliance Evaluation Report, the permittee shall revise and implement the SWP3 to include and address the findings ofthe Site Compliance Evaluation Report. Revisions must include all applicable changes that result from the report and all applicable updates to:

(1) elements of the SWP3 that require modification for effectiveness;

(2) any additional elements (e.g. structural controls or BMPs) that should be added or modified for prevention of pollution;

(3) the site map;

• (4) the inventory of exposed materials;

(5) the description of the good housekeeping measures;

(6) the description of structural and non-structural controls; and

(7) any other element of the plan that was either found to be inaccurate or that will be modified.

8. Copy of Multi-Sector General Permit (MSGP)

A copy of this general permit shall be included either as part of the SWP3 or as an attachment to the SWP3. The permittee need not include the sections in Part V ofthis general permit which are not related to the industrial activities atthe site.

Section B. Inspection of the Storm Water Pollution Prevention Plan (SWP3, or Plan) and Site

(a) Site Inspection -Inspection and entry shall be allowed under Texas Water Code Chapters 26-28, Health and Safety Code §§ 361.032-361.033 and 361.037, and 40 Code of Federal Regulations (CFR) §122.41(i). The statement in Texas Water Code § 26.014 that commission entry ofa facility shall occur according to the facility's rules and regulations concerning safety, internal security, and fire protection is not grounds for denial or restriction ofentry to any part of the facility, but merely describes the commission's duty to observe appropriate rules and regulations during an inspection.

• Page 34

GOA Exhibit TF-5 TPDES Multi Sector Gemeral Permit SOAHDocket No. 582-08-2186 TGEQ Docket No. 2006-0612-MSW Page 34 of 111


(b) SWP3 Review - The SWP3 shall be maintained, with a copy of this general permit, either at the site or be readily available for review by authorized TCEQ personnel upon request. The SWP3 must be modified by the permittee as often as necessary. Each revision must be dated and all revisions must be retained according to Part III.C.6. The executive director may determine, following a review or site inspection, that the SWP3 is not sufficient and may require that the SWP3 be revised to correct all deficiencies.

Section C. General Monitoring and Records Requirements

1. Representative Storm Events

(a) Monitoring, sampling, examinations, and inspections of storm water discharges that are required as a provision of this general permit shall be conducted on discharges of runoff from a representative storm event. For the purposes of this general permit, a representative storm event is an event with at least 0.1 inch of measured precipitation that occurs with a minimum interval of at least 72 hours from the preceding measurable storm event. The 72-hour interval requirement does not apply if the preceding storm event did not yield a discharge that was sufficient for obtaining a sample, or if it is documented in the SWP3 that an interval of fewer than 72 hours is representative for local storm events for the sampling period.

(b) A facility which uses retention ponds as a BMP may not experience a discharge immediately following a representative storm event. If any storm events occurred prior to discharge from the outfall, regardless ofthe time period between the last storm event and the discharge, the permittee may consider the discharge to be the result of the previous qualifying storm event.

• (c) Permittees must maintain a rain gauge on-site, or utilize a rain gauge located in the immediate vicinity ofthe site, in order to determine when a representative storm event occurs. The rain gauge shall be monitored a minimum of once per week, and once per day during storm events. Records shall be retained on-site or made readily available for review. Rain gauge monitoring and recordkeeping may be temporarily suspended during a given monitoring period if a representative storm event has occurred and the required sampling and analyses has been conducted.

2. Representative Discharges from Substantially Similar Outfalls

(a) Ifdischarges ofstorm water through two or more outfalls are substantially the same, then sampling and monitoring may be conducted at one of the outfalls, and the results may be reported as representative of the discharge from the substantially similar outfall. Before results may be submitted as representative of discharges from substantially similar outfalls, the SWP3 must include a description of outfall locations and provide a detailed justification of why the discharge qualities from the outfalls are substantially similar. To determine if outfalls are substantially similar, the following characteristics of each outfall must be compared:

(1) the industrial activities that occur in the drainage area to each outfall;

(2) significant materials stored or handled within the drainage area to each outfall; and

(3) the management practices and pollution control structures that occur within the drainage area of each outfall.

• Page 35

GOA Exhibit TF-5 TPDES Multi Sector Gemeral Permit SOAH Docket No. 582-08-2186 TGEQ Docket No. 2006-0612-MSW Page 35 of 111


(b) Substantially similar outfalls may be established for the following monitoring requirements described in this general permit:

(1) Quarterly Visual Monitoring

(2) Hazardous Metals Monitoring

(3) Benchmark Monitoring

(c) Substantially similar outfalls may not be established for non-storm water discharges.

3. Representative Discharge Samples

All samples must be representative. of the discharge. Sampling shol,lld be conducted within the first 30 minutes of discharge using agrab sample. Ifit is not practicable to collect the sample or to complete the sampling within the first 30 minutes, then sampling must be completed within the first hour ofdischarge. Ifsampling is not completed within the first 30 minutes ofdischarge, the reason must be documented and

. attached to all required reports and records of the sampling activity.

(a) Sampling for Compliance with Specific Numeric Effluent Limitations - Any requirements specific to sampling for compliance with numeric effluent limitations are defined in the permit where the numeric effluent limitations have been established.

• (b) Authorized Storm Water Discharges that Combine with Other Flows - If storm water discharges

authorized under this general permit combine with other stormwater orwith wastewater authorized under a separate permit, then sampling must be conducted at a point before the waters combine.

(c) Analytical Test Procedures - All procedures must comply with the standards specified in 30 TAC §§ 319.11 - 319.12. .

4. Monitoring Periods

(a) Sampling, inspections; and examinations that are required on a quarterly basis shall be conducted during the following periods:

First quarter - January through March; Second quarter - April through June; Third quarter - July through September; and Fourth quarter - October through December.

Applicants shall begin required sampling, inspections, and examinations on a: quarterly basis in the first full quarter following submission of a NOT. .

(b) Sampling, inspections, and examinations that are required on a semiannual basis shall be conducted during the following periods:

First period - January through June; Second period - July through December.

• Page 36



Applicants shall begin required sampling, inspections, and examinations on a semiannual basis in the first full period following submission of a NOI.

(c) Monitoring, inspections, and examinations that are required on an annual basis shall be conducted before December 31 51 of each year, beginning with the calendar year that includes the first full quarter following submittal of an NOI.

5. Temporary Suspension and Waivers from Monitoring Requirements

(a) Temporary Suspension - Requirements to sample, inspect, examine or otherwise monitor storm water discharges within a prescribed monitoring period may be temporarily suspended for adverse weather conditions. Adverse weather conditions are conditions that are either dangerous to personnel (e.g., high wind, excessive lightning) or weather conditions that prohibit access to a discharge (e.g., flooding, freezing conditions, extended periods of drought). Adverse conditions that result in the temporary suspension of a permit requirement to sample, inspect, examine, or otherwise monitor storm water discharges must be documented and included as part of the SWP3. Documentation shall include the date, time, names of personnel that witnessed the adverse condition, and the nature of the adverse condition.

Waivers - When monitoring is temporarily suspended, that monitoring must be conducted in the next monitoring period, in addition to any monitoring required for that period. If the temporarily suspended monitoring requirement cannot be fulfilled during the next monitoring period, then it is permanently waived.

• (b) Inactive Industrial Facilities - Permitted facilities in this inactive status must provide written notice

to the executive director ofthis status. Following this notification, permit requirements to sample, inspect, examine, or otherwise monitor storm water discharges are waived during the period that a facility maintains inactive status, unless the requirements in Part V. ofthis permit include specific requirements for inactive facilities.

Inactive facilities must notify the executive director in writing at least 48 hours before commencing industrial activities and transferring to active status.

6. Records Retention

Monitoring and reporting records, copies ofall other records required by this general permit, and records of all data used to complete the application for this general permit shall be retained at the facility or shall be made readily available for review by authorized TCEQ personnel upon request for a period of three years from the date of the record or sample, measurement, report, application, or certification. This period may be extended at the request of the executive director. The SWP3 shall be maintained, and be made readily available for inspection and review by authorized TCEQ personnel upon request. Additionally, a copy of all SWP3s for the preceding three-year period must be maintained and made readily available for review. In circumstances where the number of revisions to the SWP3 make this requirement burdensome, a log or record of revisions for the preceding three-year period may be maintained and made available. Ifthe general permit is terminated or allowed to expire without renewal, the SWP3 must be maintained and made readily available for review for a minimum period of one year.

• Page 37



Section D. Numeric Effluent Limitations

1. Discharges of Storm Water Runoff

(a) Numeric Limitations for Discharges of Storm Water to Inland Waters

Hazardous Daily Daily Daily Metal Average Composite Maximum Monitoring (Total) (mglLl (mglLl (mglLl Frequency

Arsenic 0.1 0.2 0.3 1Near Barium 1.0 2.0 4.0 1Near Cadmium 0.05 0.1 0.2 1Near Chromium 0.5 1.0 5.0 lfYear Copper 0.5 1.0 2.0 lNear Lead 0.5 1.0 1.5 lfYear Manganese 1.0 2.0 3.0 lNear Mercury 0.005 0.005 0.01 1Near Nickel 1.0 2.0 3.0 lNear Selenium 0.05 0.1 0.2 lfYear Silver 0.05 0.1 0.2 lNear Zinc 1.0 2.0 6.0 lfYear

(b) Numeric Limitations for Discharges of Stonn Water to Tidal Waters

• Hazardous Daily Daily Daily Metal Average Composite Maximum Monitoring (Total) (mgILl (mgilJ (mgf!J Frequency Arsenic 0.1 0.2 OJ lNear Barium 1.0 2.0 4.0 IfYear Cadmium 0.1 0.2 0.3 lfYear Chromium 0.5 1.0 5.0 lfYear Copper 0.5 1.0 2.0 lfYear Lead 0.5 1.0 1.5 lfYear Manganese 1.0 2.0 3.0 1Near Mercury 0.005 0.005 0.01 lfYear Nickel 1.0 2.0 3.0 l/Year Selenium 0.1 0.2 0.3 lfYear Silver 0.05 0.1 0.2 1Near Zinc 1.0 2.0 6.0 lNear

(c) Daily Maximum Effluent Limitation - Grab samples of stonn water discharges are required to be taken at a minimum frequency of once per year. Samples must be taken of discharges at the final outfall, either immediately prior to entering surface water in the state or immediately prior to leaving the pennitted facility property. Analyses must be compared to the daily maximum numeric effluent limitation for compliance purposes.

• Page 38



Daily Composite Effluent Limitation - Sampling to meet these limitations is not required. However, these numeric effluent limitations will apply to any samples that are composed of a minimum ofthree grab samples taken throughout the storm water discharge period and combined proportional to flow into a single sample for laboratory analyses.

Daily Average Effluent Limitation - Sampling to meet these limitations is not required. However, these numeric effluent limitations do apply to the arithmetic average of laboratory results of analyses when more than one discharge sample is collected and analyzed in a single calendar month.

(d) Reporting Requirements - Results ofmonitoring for determining compliance with numeric effluent limitations must be recorded on a discharge monitoring report (DMR). The DMR must either be an original EPA No. 3320-1 form (Part VI of this general permit), a duplicate of the form, or as otherwise provided by the executive director.

Monitoring must be conducted prior to December 31 5t for each annual monitoring period and the results must be reported as required in Part III.E.4(c) of this permit. A copy of the DMR must either be retained at the facility or shall be made readily available for review by authorized TCEQ personnel upon request by March 31 st following the annual monitoring period.

If the results indicate the violation of one or more of the numeric limitations listed above at Part D.l.(a) and (b), the permittee must also submit the DMR to the TCEQ's Information Resources Center (MC 212) by March 31 51 following the annual monitoring period in which the violation(s) occurred.

• (e) Waiver from Numeric Effluent Limitation - Permittees qualify for a waiver from hazardous metal monitoring requirements ifone or more ofthe following criteria are met, and the waiver is obtained by certifying the conditions exist. This certification must be completed on a form provided by the executive director and must be either maintained onsite or made readily available for review by authorized TCEQ personnel upon request. Waivers may be obtained on a metal by metal basis, or on an outfall by outfall basis: .

(i) the permittee certifies that the regulated facility does not use a raw material, produce an intermediate product, or produce a final product that contains one of the hazardous metals listed at Part D.l.(a) or (b); or

(ii) the permittee certifies that any raw materials, intermediate products, or final products which contain a hazardous metal are never exposed to storm water or runoff(final products are not considered to expose hazardous metals to storm water or runoff if the final product is designed for outdoor use, unless it is a product that could be transported by storm water runoff or unless the final product will be used as a material or intermediate product); or

(iii) the permittee collects a sample ofthe discharge from the facility, analyzes the sample for one or more of the listed hazardous metals, and the results indicate that the metal(s) is/are not present in detectable levels. Test methods utilized shall be sensitive enough to detect the following parameters at the minimum analytical level (MAL) specified below, and results of sampling must be retained on site and available for review by TCEQ personnel:

• Page 39



POLLUTANTS MAL (mg/L) Arsenic, total 0.010 Barium, total 0.010 Cadmium, total 0.001 Chromium, total 0.010 Copper, total 0.010 Lead, total 0.005 Manganese, total 0.002 Mercury, total 0.0002 Nickel, total 0.010 Selenium, total 0.010 Silver, total 0.002 Zinc, total 0.005

When an analysis of a discharge sample for any of the parameters listed above indicates no detectable levels above the MAL, and the test method detection level is as sensitive as the specified MAL, a value ofzero (0) may be used for that measurement, and a waiver may be obtained for that parameter that measures zero (0).

• (f) Relation to Benchmark Monitoring - If a facility is required to sample for any of the above

hazardous metals as part ofthe benchmark requirements in Part V ofthis permit, then the permittee is subject to the effluent limitations listed in Part HI.D.I. ofthis general permit for those hazardous metals sampled at a final outfall as part ofbenchmark monitoring. There are no waivers available for pollutants that are required in Part V of the general permit. If sampling for benchmark metals is not performed at a final outfall, then the above effluent limits may not apply for the benchmark sample if the sample is not representative of the discharge from the site. In this situation, the discharge must also be sampled at each final outfall to comply with the sampling and analyses requirements of this section.

2. Coal Pile Runoff

(a) Numeric Effluent Limitations - The following numeric effluent limitations and monitoring frequency apply to storm water runoff from coal pile storage areas located at facilities other than steam electric generating facilities, that discharges storm water associated with industrial activity:

Limitations Monitoring Parameter Daily Maximum Frequency Total Suspended,Solids 50 mgIL I/Year pH between 6 and 9 standard units IlYear

Sampling requirements for coal pile runoff at steam electric generating facilities are listed in Part V.O.5. of this general permit.

(b) Sample Type - At a minimum, one grab sample shall be taken, prior to combining with other flows, for analysis.

(c) Reporting Requirements - Results ofmonitoring for determining compliance with numeric effluent limitations must be recorded on a discharge monitoring report (DMR). The DMR must either be an original EPA No. 3320-1 form (Part VI of this general permit), a duplicate of the form, or as otherwise provided by the executive director.

• Page 40

COA Exhibit TF-5 TPDES Multi Sector Gerneral Permit SOAH Docket No. 582-08-2186 TCEQ DOcket No. 2006-0612-MSW Page 40 of 111


Monitoring must be conducted prior to December 31 5t for each annual monitoring period and the results must be reported as required in Part III.E.4(c) of this permit. A copy of the DMR must either be retained at the facility or shall be made readily available for review by authorized TCEQ personnel upon request by March 31 st following the annual monitoring period.

If the results indicate the violation of one or more ofthe numeric limitations listed above at D.2., the permittee must also submit the DMR to the TCEQ' s Information Resources Center (MC-212) by March 31 51 following each annual monitoring period.

(d) Waiver from Numeric Effluent Limitations - Numeric effluent limitations for runofffrom coal pile storage areas do not apply to discharges that overflow from structural control facilities that are designed to contain and treat runofffrom a 1O-year 24-hour storm event. Rainfall records are only required to document events that equal or exceed a 10-year 24-hour event. The operator shall maintain, as a part of the SWP3, the following information in order to receive this waiver:

(i) engineering design records that demonstrate structural controls are adequate to intercept, contain, and treat the volume of runoff from a 1O-year, 24-hour storm event; and

(ii) records ofrainfall from a either a rain gauge that is located onsite or a rain gauge maintained in the immediate area of the facility.

3. Discharges Subject to Federal Categorical Guidelines

Part V of this general permit includes additional effluent limitations for certain storm water discharges as required under 40 CFR Subchapter N (Parts 400-474). The permittees are subject to the sampling and reporting requirements as stipulated in the applicable sections of Part V of this permit.

• Section E. Standard Permit Conditions

Title 30 Texas Administrative Code (TAC) Chapter 305 requires certain regulations appear as standard conditions in waste discharge permits. 30 TAC §§ 305.121 - 305.129, Subchapter F, "Permit Characteristics and Conditions," as promulgated under the Texas Water Code §§ 5.103 and 5.105, the Texas Health and Safety Code §§ 361.017 and 361.024(a), and those sections of40 Code ofFederal Regulations (CFR) Part 122 adopted by reference by the Commission, establish the characteristics and standards for waste discharge permits. This section of the general permit inCludes these conditions and incorporates them into this general permit. More specific requirements for some of these standard permit conditions may be defined for specific sectors of industrial activity that are authorized to discharge under this general permit.

1. General Conditions

(a) Duty to Comply

(1) Submission of an NOI for permit coverage is an acknowledgment that the applicant agrees to comply with the conditions of the general permit. Acceptance of authorization under the provisions of this general permit constitutes acknowledgment and agreement that the permittee will comply with all the terms and conditions embodied in the permit, and the rules and other orders of the Commission.

(2) The permittee has a duty to comply with all conditions ofthe permit. Failure to comply with any permit condition constitutes a violation ofthe permit and the Texas Water Code or the Texas Health and Safety Code, and is grounds for enforcement action, for revocation or suspension of coverage under this general permit, and for requiring a permittee to apply for a TPDES individual permit or coverage under an alternative general permit.

• Page 41

eOA Exhibit TF-5 TPDES Multi Sector Gemeral Permit SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 41 of 111


(b) Toxic Pollutants

(1) If any toxic effluent standard or prohibition is promulgated according to the Texas Water Code § 26.023 for a toxic pollutant that is present in the discharge and that standard or prohibition is more stringent than the conditions of this general permit, this general permit shall be modified or revoked and reissued to conform to the toxic effluent standard or prohibition.

(2) The permittee shall comply with effluent standards or prohibitions established according to the Texas Water Code § 26.023 for toxic pollutants within. the time provided in the regulation~ that e,stablished those standards or prohibitions, even if this general permit has not yet been modified to incorporate the requirem'erit.

(c) Permit Flexibility

Authorization under this general permit may be modified, suspended or revoked for cause according to 30 TAC§§ 305.62 and305.66 and the Texas Water Code Section § 7.302. The filing of a notice of planned changes or anticipated noncompliance does not stay any permit condition.

(d) Property Rights

A permit does not convey any property rights of any sort, or any excll.;lsiv(: privilege.

(e) Duty to Provide Information

• The permittee shall furnish to the executive director, upon request, any information, including records that are ma~ntairi.edas a requirement of this permit, neces'sary to ,determine whether cause exists for revoking,suspending, or terminating authorization under this general permit.

(f) Criminal and Civil Liability

(1) As provided by state law, the permittee is subject to admini.strative, civil and criminal penalties, as applicable, for negligently or knowingly violating the Clean Water Act, the Texas Water Code, Chapters 26, 27, and 28, and Texas Health a,nd Safety Code, Chapter 361, including but not;limited to: knowingly making !iny false statement, representation, or certification on any report, record, or other documentsubmitted or required to be maintained under this permit, including monitoring reports or reports ofcompliance or noncompliance; falsifying or tampering with or knoWingly rendering inaccurate any monitoring device or method required by this permit; or violating any other requirement imposed by state or federal regulations. Nothing in this permit shall be construed to relieve the permittee from civil or criminal penalties for noncompliance. '

(2) Any false or materially misleading representation or concealment of information required to be reported by the provisions of the permit or applicable regulation, which avoids or effectively defeats the regulatory purpose of this general permit, may subject the permittee to criminal enforcement. . .

(g) Severability

The provisions ~f this general permit are severable and if any provision of this permit or the . application of any provision of this permit to any circumstance is held invalid, the application of

• Page 42

COA ExhibitTFc5 . TPDES Multi Sector Gerneral Permit SOAH Docket'No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 42 of 111


such provision to other circumstances, and the remainder of this general permit, shall not be affected thereby.

2. Proper Operation and Maintenance

(a) Need to Halt or Reduce Not a Defense

It is not a defense for a permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions ofthis general permit. The permittee is responsible for maintaining adequate safeguards to prevent the discharge of untreated or inadequately treated wastes during electrical power failure either by means of alternate power sources, standby generators, or retention of inadequately treated effluent.

(b) Duty to Mitigate

The permittee shall take all reasonable steps to minimize or prevent any discharge or other permit violation that has a reasonable likelihood ofadversely affecting human health or the environment.

(c) Operation of Treatment and Control Systems

• (1) The permittee shall at all times ensure that the facility and all of its systems of collection,

treatment, and disposal are properly operated and maintained in a manner that will minimize discharges of excessive pollutants and will achieve compliance with the conditions of this permit. Proper operation and maintenance also include adequate laboratory controls and appropriate quality assurance procedures. This provision requires the operation of backup or auxiliary systems that are installed by a permittee only when the operation is necessary to achieve compliance with the conditions of this permit.

(2) The permittee shall provide an adequate operating staffthat is duly qualified to carry out operation, maintenance, and testing functions required to ensure compliance with the conditions of this general permit.

(d) Anticipated Noncompliance

The permittee shall give advance notice to the executive director of any planned changes in the permitted facility or activity that may result in noncompliance with permit requirements.

3. Monitoring and Records

(a) Inspection and Entry

(1) Inspection and entry shall be allowed as prescribed in the Texas Water Code Chapters 26, 27, and 28, and Texas Health and Safety Code Chapter 361.

(2) The members ofthe Commission and employees and agents ofthe Commission are entitled to enter any public or pri vate property at any reasonable time for the purpose of inspecting and investigating conditions relating to the quality of surface water in the state or the compliance with any rule, regulation, permit or other order ofthe Commission. Members, employees, or agents of the Commission and Commission contractors are entitled to enter public or private property at any reasonable time to investigate or monitor or, if the responsible party is not responsive or there is an immediate danger to public health or the

• Page 43



environment, to remove or remediate a condition related to the quality of surface water in the state. Members, employees, Commission contractors, or agents acting under this authority who enter private property shall observe the establishment's rules and regulations concerning safety, internal security, and fire protection, and if the property has management in residence, shall notify management or the person then in charge of his presence and shall exhibit proper credentials. If any member, employee, Commission contractor, or agent is refused the right to enter in or on public or private property under this authority, the Executive Director may invoke the remedies authorized in Texas Water Code § 7.002.

(b) Representative Sampling

Samples and measurements taken for the purpose of monitoring shall be representative of the monitored activity.

(c) Monitoring Procedures

Sampling, monitoring, and analyses must be conducted according to procedures either specified in 30 TAC §§ 319.11 - 319.12 or 40 CFR Part 136 unless otherwise specified in this general permit.

(d) Additional Monitoring by the Permittee

• If the permittee monitors any pollutant more frequently than required by this general permit using approved analytical methods, all results of the monitoring shall be included in the calculation and reporting ofthe values recorded on the DMR form and shall be included in any other calculation, record, or reports required to be maintained as a provision of this general permit. Increased frequency of sampling shall be indicated on the DMR.

(e) Retention of Records

(1) The period records are required to be retained shall be automatically extended to the date of the final disposition of imy administrative or judicial enforcement action that may be instituted against the permittee.

(2) Monitoring and reporting records, including records of calibration and maintenance, and copies of all records and reports required by this permit, shall be retained at the facility or shall be readily available for review by a TCEQ representative for a period of three years from the date ofthe record or sample, measurement, report, application or certification unless otherwise specified in this permit. This period may be extended at the request of the Executive Director.

(t) Record Contents

Records of monitoring shall include, at a minimum, the following:

(1) the date, time, and place of sample or measurement;

(2) the identity of the individual who collected the sample, made the measurement or observation, or performed the analysis;

(3) the date and time the sample, measurement, or observation was made, and the analysis conducted;

• Page 44

eOA Exhibit TF-5 TPDES Multi Sector Gerneral Permit SOAH Docket No. 582-08-2186 TeEQ Docket No. 2006-0612-MSW Page 44 of 111


(4) the identity of the individual and laboratory who performed the analysis;

(5) the technique or method of analysis;

(6) the results of the measurement, observation, or analysis; and

(7) quality assurance/quality control records.

(g) Signatory Requirements for Reports and Certifications

All reports and certifications requested by the Executive Director shall be signed by the person and in the manner required by 30 TAC § 305.128 (relating to Signatories to Reports).

4. Reporting Requirements

(a) Self-Reporting

•

Monitoring results shall be provided at the intervals specified in this general permit. Unless otherwise specified in this general permit, or otherwise ordered by the Commission, the permittee shall conduct effluent sampling and reporting according to 30 TAC §§ 319.4 - 319.12 or 40 CFR Part 136. Results of analyses for determining compliance with numeric effluent limitations must be recorded on a discharge monitoring report (DMR). The DMR must either be an original.EPA No. 3320-1 form (Part VI ofthis general permit), a duplicate of the form, or as otherwise provided by the executive director. Monitoring must be conducted prior to December 31 st for each annual monitoring period and the results must be recorded and made availablefor review upon request by March 31 st following each annual monitoring period. If the permit requires submission of the DMR to TCEQ, the form must be submitted to the TCEQ by March 31 st following each annual monitoring period.

(b) Noncompliance Notification

(1) According to 30 TAC § 305.125(9) any noncompliance which may endanger human health or safety, or the environment, shall be reported by the permitteeto the TCEQ. Report of such information shall be provided orally or by electronic facsimile transmission (FAX) to the TCEQ regional office within 24 hours of becoming aware of the noncompliance. A written report shall be provided by the permittee to the TCEQ regional office and to the TCEQ Enforcement Division (MC-224) within five working days ofbecoming aware ofthe noncompliance. The written report shall contain:

(i) a description of the noncompliance and its cause;

(ii) the potential danger to human health or safety, or the environment;

(iii) the period of noncompliance, including exact dates and times;

(iv) if the noncompliance has not been corrected, the anticipated time it is expected to continue; and

(v) steps taken or planned to reduce, eliminate, and prevent recurrence of the noncompliance, and to mitigate its adverse effects.

• Page 45



(2) In addition to the above, any violation that deviates from the permitted effluent limitation by more than 40% shall be reported in writing to the TCEQ regional office and to the Enforcement Division (MC-149) within five working days of becoming aware of the noncompliance.

(c) Other Noncompliance

Any noncompliance with permitted effluent limitations not specified in Part III.E.4.(b) shall be recorded on a DMR form and provided at the following intervals:

(1) Non-compliance with an effluent limitation for a discharge subject to federal numeric effluent limitations guidelines (40 CFR Parts 400-474) must be recorded on a DMR. All DMRs recording the annual sampling results must be submitted to the TCEQ by March 31 st

of the following year, including results that are below the effluent limits.

(2) Non-compliance with an effluent limit for any of the hazardous metals required in Part III.D.1 of this permit, or for TSS and pH as required in Part III.D.2 of this permit, shall be recorded on a DMR and reported at a frequency of once per year. The DMR must be submitted to the TCEQ's Information Resources Division (MC-212), by March 31 st of the following year. Analytical results that do not exceed an effluent limitation for a hazardous metal in Part III.D. must be recorded on a DMR and retained onsite.

(d) Other Information

• When the permittee becomes aware that it either submitted incorrect information or failed to submit any relevant facts on an NOI, NOT, NEC, NOC, or any report, it shall promptly submit the facts or information to the executive director.

5. Solid Waste

Industrial facilities that generate industrial solid waste as defined in 30 TAC § 335.1 shall comply with these provisions:

(a) Any solid waste generated by the permittee during the management and treatment ofstorm water, as defined in 30 TAC § 335.1, must be managed according to all applicable provisions ono TAC Chapter 335, relating to Industrial Solid Waste and Municipal Hazardous Waste.

(b) Storm water that is being collected, accumulated, stored, or processed within a solid waste management unit, before discharge through any final outfall authorized by this permit, is considered to be solid waste unti I the storm water passes through the actual point source discharge, and must be managed according to all applicable provisions 000 TAC Chapter 335.

(c) The permittee shall provide written notification, pursuant to the requirements of 30 TAC § 335.6(g), to the Corrective Action Section (MC-127) of the Remediation Division informing the Commission of any closure activity involving a Solid Waste Management Unit, at least 90 days prior to conducting such an activity.

• Page 46



(d) Construction of any solid waste management unit requires the prior written notification of the proposed activity to the Registration and Reporting Section (MC 129) of the Registration, Review, and Reporting Division. No person shall dispose of industrial solid waste, including sludge or other solids from storm water treatment processes, prior to fulfilling the deed recordation requirements of 30 TAC § 335.5.

(e) The permittee shall keep management records for all sludge or other waste removed from any storm water treatment process. These records shall fulfill all applicable requirements of 30 TAC Chapter 335 and must include the following, as it pertains to wastewater treatment and discharge:

(i) volume of waste and date generated from treatment process;

(ii) volume of waste disposed of onsite or shipped off-site;

(iii) date of disposal;

(iv) identity of hauler or transporter;

(v) location of disposal site; and

(vi) method of final disposal.

• The above records shall be updated on a monthly basis. The records shall be retained at the facility or shall be readily available for review by authorized representatives of the TCEQ for at least five years.

• Page 47



Part IV. Benchmark Monitoring Requirements Common to Many Industrial Activities ~ . . . .

Benchmark monitoring requirements are included as a provision of this generaipermit for industrial activities. The following table defines the sectors and sub-sectors that are required to monitor and also identifies specificpollutants that must be monitored. The specific benchmark values are identified in Part IV of the permit with the other requirements that are specific to each sector or sub-sector 6findustrial activities. .

Section A. Use ofBenchmark Data

The permittee mustcompare the results ofanalyses to the benchmark values, and omst include this comparison in the overall assessment oftheSWP3s effectiveness. Analytical rC?sults that exceed a benchmark value are not a violation ofthis permit, as these values are not numeric effluent limitations; however, ifa permittee is required to sample for any of the hazardous metals listed in Part Ill.D.I. ofthis general permit as part of the benchmark requirements in Part V ofthispermit, then the permittee is subject to the effluent limitations in Part Ill.D.I. for those samples that are collected at a final outfall. Results of analyses are indicators that modifications of the SWP3 may be necessary. The Pollution Prevention Team must investigate the cause for each exceedance and must document the results of this investigation in the SWP3 within 90 days following the sampling event.

The Pollution Prevention Team investigation must identify the following:

1) any additional potential sources of pollution, such as spills that might have occurred, 2) necessary revisions to the Good Housekeeping Measures. section of the SWP3, 3) additional BMPs, including a schedule to install or implement the BMPs, 4) other parts of the SWP3 for which revisions are appropriate. '

• Background concentrations of specific pollutants may also be considered during the investigation. If the Pollution Prevention Team is able to relate tile cause of the exceedance to background concentrations, then subsequent exceedances of benchmark values for that pollutant may be resolved by referencing the earlier finding in theSWP3. Background concentrations may be identified by laboratory analyses ofsamples ofstorm water runon to the permitted facility, by laboratory analyses of samples of storm water run-off from adjacent non-industrial areas, or by identifying the pollutant is a naturally occurring material in soils at the site.

Section B. Sectors Subject to BenchD!ark Monitoring

MSGP Sector

Industry Sub-sector 'Required Parameters for Benchmark . Monitoring

A General Sawmills and Planing Mills COD, TSS, Total Zinc

Wood Preserving Facilities Total Arsenic, Total Copper

Log Storage and Handling TSS'

Hardwood Dimension and Flooring Mills COD,TSS

B Paperboard Mills COD

C Industrial Inorganic Chemicals Total Aluminum, Total Iron, Nitrate:t- Nitrite N, TSS

Plastics, Synthetic Resins, etc. Total Zinc

Soaps, Detergents, Cosmetics, Perfumes Nitrate + Nitrite N, Total Zinc

.Agricultural Chemicals Nitrate + Nitrite N, Total Lead, Total Iron, Total Zinc, Total Phosphorus

0 Asphalt Paving and Roofinl! Materials TSS

• Page 48

COA Exhibit TF-5 , TPDES Multi Sector Gemeral Permit SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 48 9f 111


•

Momtormg IS only requIred for aIrports WIth delcmg actIvItIes that are utIlIzed for delCmg more than 100 tons of

MSGP Industry Sub-sector Required Parameters for Benchmark Sector Monitorine:

Clay Products Total Aluminum, TSS, pH E

Concrete Products TSS, Total Iron, oH

F Steel Works, Blast Furnaces, and Rolling Total Aluminum, Total Zinc, TSS and Finishine: Mills

Iron and Steel Foundries Total Aluminum, TSS, Total Copper, Total Iron, Total Zinc

Non-Ferrous Rolling and Drawing Total Copoer, Total Zinc

Non-Ferrous Foundries (Castings) Total Coooer, Total Zinc

G Metal Mining and Dressing Refer to Part V Section G

H Coal Mines and Coal-Mining Related TSS, Total Aluminum, Total Iron Facilities

J Dimension Stone, Crushed Stone, and TSS, pH Nonmetallic Minerals (exceot fuels)

Sand and Gravel Minim! Nitrate + Nitrite N, TSS

K Hazardous Waste Treatment Storage or Ammonia-Nitrogen, Total Magnesium, COD, Disposal Total Arsenic, Total Cadmium, Total Cyanide,

Total Lead, Total Mercury, Total Selenium, Total Silver

L Landfills, Land Application Sites, and Total Iron, TSS Ooen Dumps

M Automobile Salvage Yards TSS, Total Aluminum, Total Iron, Total Lead

N Scrap Recycling Total Copper, Total Aluminum, Total Iron, Total Lead, Total Zinc, TSS, COD

a Steam Electric Generatin!! Facilities Total Iron, TSS

Q Water Transportation Facilities Total Aluminum, Total Iron, Total Lead, Total Zinc, TSS

S Airoorts with deicin!! activities I BOD, COD, Ammonia-Nitro!!en, oH

T Treatment Works BOD

U Grain Mill Products TSS

Fats and Oils BOD, COD, Nitrate + Nitrite N, TSS

Y Rubber Products Total Zinc

AA Fabricated Metal Products Except Coating Total Iron, Total Aluminum, Total Zinc, Nitrate + Nitrite N, TSS

Fabricated Metal Coating and Engraving Total Zinc, Nitrate + Nitrite N ... .. . .

urea or more than 100,000 gallons of ethylene glycol in any calendar year for the three years prior to submittal of an NOI for coverage under this general permit. .

• Page 49

eOA Exhibit TF-5 TPDES Multi Sector Gerneral Permit SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 49 of 111


Section C. Benchmark Monitoring Requirements

Benchmark monitoring must be conducted once every six months following permit issuance. Monitoring must be continued throughout the permit term for all facilities subject to benchmark sampling.

1. Monitoring Periods

Semi-annual sampling must be conducted at least once during the first full monitoring period (January through June or July through December) following permit issuance, and then once during each monitoring period for the term of the general permit.

2. Reporting Requirements

Results of analyses for sampling shall be submitted to the TCEQ before March 31st of each year. The reported values shall be the average yearly result ofanalysis for each specific pollutant discharged under a specific SIC code, rather than an outfall-by-outfall, basis. Substantially similar outfalls may be established for benchmark monitoring, in accordance with Part III.Co2. of the general permit. The report must be completed on a form provided by the executive director and mailed to the TCEQ's Wastewater Permitting Section (MC-148).

If sampling during any six month period is not conducted for a pollutant due to adverse weather conditions or drought in accordance withPartIII.C.5.(a) ofthis general permit, then the reported average annual result shall be based on data collected for that year.

•

• Page 50



Part V. Specific Requirements for Industrial Activities

Section A. Sector A oflndustrial Activity - Timber Products Facilities

The requirements in Part V of this general pennit are sector specific and are in addition to the requirements in Parts III and IV ofthis general pennit.. Where co-located industrial activities occur (refer to Part II.A.2. of this general pennit) the additional conditions and requirements in Part V of this general pennit for each of these activities also apply.

1. Description oflndustrial Activity

The requirements under this section apply to stonn water discharges from activities identified and described as Sector A. Sector A industrial activities are described by the following Standard Industrial Classification (SIC) codes:

•

SECTOR A: TIMBER PRODUCTS


2411 Log Storage and Handling (Wet deck storage areas where no chemical additives are used in the spray water or applied to the logs)

2421 General Sawmills and Planning Mills


2429 Special Product Sawmills, Not Elsewhere Classified

2431-2439 (except 2434)

Millwork, Veneer, Plywood, and Structural Wood (2434 - Wood Kitchen Cabinets, see Sector W)

2441-2449 Wood Containers

2451,2452 Wood Buildings and Mobile Homes

2491 Wood Preserving

2493 Reconstituted Wood Products

2499 Wood Products Not Elsewhere Classified

2. Definitions

Debris - For the purposes of Sector A of this general pennit, debris is any woody material (e.g. bark, twigs, branches, heartwood or sapwood) that will not pass through a I-inch diameter round opening.

Wet decking water - Water sprayed on timber storage piles to deter decay or infestation by insects.

3. Limitations on Permit Coverage

This general pennit does not authorize the discharge of stonn water that has come in contact with areas where chemical fonnulations designed to provide wood surface protection and wood preservation were sprayed. Stonn water discharges from these areas must either be captured within a containment structure and disposed of in a manner that does not allow a discharge into or adjacent to water in the state or discharged under authority of an individual TPDES pennit.

• Page 51



4. Non-Storm Water Discharges

Wet Decking Water: In addition to the non-storm water discharges allowed under Part II of this general permit, wet decking water may be discharged from lumber and wood storage yards where the wet decking process does not include chemical additives and where chemicals are not applied to the wood during storage.

5. Description oIPotential Pollutants and Sources

Facilities that use, or have previously used, chlorophenolic compounds, creosote, chromium, copper, or arsenic formulations for surface protection of wood or wood preserving activities shall address these activities in the SWP3 according to the requirements of Part III.A.4. of this general permit. The following areas must be included in the inventory of exposed materials:

(a) areas where treatment chemicals have contaminated soils;

(b) areas where wood treatment equipment remains; and

(c) areas where treatment chemicals and treated materials remain.

6. Pollution Prevention Measures and ControlslManagement of Runoff with Structural Controls

The following requirements shall be included in the SWP3 according to the requirements ofPart III.A.4. and Part III.A.5. of this general permit:

• (a) BMPs and good housekeeping measures shall be implemented to limit the discharge of wood

debris, minimize the leachate generated from decaying wood materials, and minimize the generation of dust.

(b) Structural controls may be used to limit the discharge of wood debris, minimize the leachate generated from decaying wood materials, and minimize the generation of dust.

(c) Facilities that surface protect or preserve wood products shall develop specific BMPs, including an implementation schedule, to reduce pollution in runoff from these areas of industrial activity. The SWP3 must provide for monthly inspections of wood treatment areas, treated wood storage areas, and treated wood transport loading and unloading areas to assess the effectiveness ofspecific BMPs and controls. Runoff from wood treatment areas must be prevented or authorized by an individual TPDES permit.

(d) Periodic Inspections - Periodic inspections for facilities that surface protect or preserve wood products shall include additional inspection procedures for processing areas, transport areas, and treated wood storage areas. The inspection procedures must provide an assessment of the effectiveness ofBMPs in minimizing the amount oftreatment chemicals that drip on unprotected soils and on other areas that come in contact with storm water.

(1) Although inspections are required on a quarterly basis, monthly inspections should be conducted, in the same manner as developed for quarterly inspections, whenever possible.

(2) Results and records of inspections shall be evaluated, maintained, and incorporated into the standard periodic inspection reports as described in Part III.A.5.(g), regardless of the frequency that the inspections are conducted.

• Page 52

COA Exhibit TF-5 TPDES Multi Sector Gemeral Permit SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612~MSW Page 52 of 111

• Multi Sector General Permit TPDES General Pennit No. TXR050000

(3) Follow-up procedures shall be identified to ensure that appropriate actions are taken in response to the evaluations of the inspections.

7. Numeric Effluent Limitations - Applicable to Sector A facilities discharging Wet Decking Water

(a) The following numeric effluent limitations, based on guidelines from the Wet Storage Subcategory ofthe Timber Products Processing Point Source Category (40 CFR § 429.103), apply to discharges ofwet decking water. These discharges shall not exceed the following numeric effluent limitations and monitoring requirements:

Monitoring Parameter Limitation Frequency Debris Less than I" diameter IlYear pH between 6 and 9 standard units IlYear

(b) Sample Type - Grab samples shall be taken prior to combining with other flows, for analyses.

(c) Reporting Requirement - Results ofmonitoring for determining compliance with numeric effluent limitations must be either retained at the facility or shall be readily available for review by authorized TCEQ personnel upon request. Results must be recorded on a discharge monitoring report (DMR). The DMR must either be an original EPA No. 3320-1 form, a duplicate ofthe fonn, or a self generated fonn that is comparable.

• Monitoring must be conducted prior to December 31 51 for each annual monitoring period and the results must be reported as required in Part III.EA.(c) of this permit. In addition, a copy of the DMR must either be retained at the facility or shall be made readily available for review by authorized TCEQ personnel upon request by March 31 51 following the annual monitoring period.

8. Benchmark Monitoring Requirements

The following subsectors inust conduct benchmark monitoring on discharges of storm water associated with industrial activities according to the requirements in Part IV of this general permit.

SIC Code Description of Industrial Activity Benchmark Parameter

Benchmark Value

2421 General Sawmills and Planning Mills

COD TSS Zinc, Total

55 mg/L 100 mg/L 0.16 mg/L

2491 Wood Preserving Arsenic, Total Copper, Total

0.17 mg/L 0.030 mg/l

2411 Log Storage and Handling (Wet deck storage areas where no chemical additives are used in the spray water or applied to the logs)

TSS 100 mg/L


COD TSS

55 mg/L lOa mg/L

• Page 53



Facilities sampling for the fol1owing pollutants as part of benchmark sampling are also subject to the numeric effluent limits and reporting requirements listed in Part III.D.1. of the permit: total zinc, total arsenic, and total copper.

Section B. Sector.B of Industrial Activity - Paper and Allied Products'Manufacturing Facilities

The requirements in Part V of this general permit are sector specific and are in addition to the requirements in Parts III and IV. Where co-located industrial activities occur (refer to Part II.A.2. of this general permit) the additional conditions and requirements in Part V of this general permit for each of these activities also apply.

, 1. Description of Industrial Activity

The requirements under this section apply to storm water discharges from activities identified and described as Sector B. Sector B industrial activities are described by the fol1owing SIC codes:

SECTOR B: PAPER AND ALLIED PRODUCTS


2611 Pulp Mills

Paper Mills

Paperboard Mills

Paperboard Containers and Boxes \

Converted Paper and Paperboard Products, Including Plastic Bags Produced from Plastics Film

2621

2631

2652 - 2657

2671 - 2679 • 2. Benchmark Monitoring Requiremen~s

The fol1owing subsectors must conduct benchmark monitoring according to the requirements in Part IV of this general permitand must conduct evaluations on the effectiveness of the facility SWP3 based on the following benchmark values:

SIC Code .Description of Industrial Activity Benchmark Parameter

Benchmark Value

2631 Paperboard Mills COD 55 mgIL

Section C. Sector C of Indus.trial Activity - Chemical and Allied Products Manufacturing Facilities

The requirements in Part V of this general permit are sector specific and are in addition to the requirements in Parts III and IV. Where co-located industrial activities occur (refer to Part II.A2. of this general permit) the additional conditions and requirements in Part V of this general permit for each of these activities also apply.

1. Description of Industrial Activity

The requirements under this section apply to storm water discharges from activities identified and described as Sector C. Sector Cindustrial activities are described by the following SIC codes:

• Page 54 COA ExhibitTF-5 TPDES Multi Sector Gemeral Permit SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612cMSW Page 54 of 111


SECTOR C: CH~MICAL AND ALLIED PRODUCTS


2812-2819 Basic Industrial Inorganic Chemicals

2821 - 2824 Plastic Materials, Synthetic Resins, Non-vulcanizable Elastomers (Synthetic Rubber), Cellulose Plastics Materials, and Other Manmade Fibers Except Glass

2833 - 2836 Medicinal Chemicals and Botanical Products, Pharmaceutical Preparations, In Vitro and In Vivo Diagnostic Substances, Biological Products (Except Diagnostic Substances).

2841 - 2844 Soaps and Detergents; Specialty Cleaning, Polishing, and Sanitation Preparations; Surface Active Agents, Finishing Agents, Sulfonated Oils, and Assistants; Perfumes, Cosmetics, and Other Toilet Preparations;

2851 Paints, Varnishes, Lacquers, Enamels, and Allied Products

2861 - 2869 Industrial Organic Chemicals (including commercial composting operations)

2873 - 2879 Agricultural Chemicals (Including Fertilizers, Pesticides, Fertilizers Solely from Leather Scraps and Leather Dust, and Mixing of Fertilizers, Compost, and Potting Soils)

2891 - 2899 Miscellaneous Chemical Products (Including Adhesives and Sealants, Explosives, Printing Ink, and Carbon Black)

3952 (Limited to List)

Inks and Paints, including: China Painting Enamels; India Ink; Drawing Ink; Platinum Paints for Burnt Wood or Leather Work; Paints for China Painting; Artist's Paints; and Artist's Watercolors •


Non-storm water discharges are not eligible for coverage except according to the conditions of Part ILA.5. of this general permit. The following non-storm water discharges are specifically prohibited: discharges containing inks, paints, and other substances resulting from an onsite spill; contents from drip pans; washwaters from material handling and processing areas; and wash waters/rinsewaters from drums, tanks, and other containers.

3. Pollution Prevention Measures and ControlslManagement of Runoff with Structural Controls

The following requirements shall be included in the SWP3 according to requirements ofPart IILA.4. and Part IILA.5. of this general permit:

(a) Security System - A security system shall be developed to prevent accidental or intentional discharges by unauthorized individuals. The system may include fences, lights, traffic controls, building security, and equipment security.

(b) Practices for Material Handling and Storage Areas - Practices shall be developed to conform with the following:

• Page 55 COA Exhibit TF-5 TPDES Multi Sector Gemeral Permit SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 55 of 111


I. Diking, curbing, benns, or other appropriate controls shall be used in areas where liquid or powdered materials are stored to reduce the potential of contamination of stonn water from these materials.

2. Curbs, culverts, gutters, sewers, or other fonns ofdrainage control must be used to minimize contamination of stonn water in all other outside storage areas, including areas for machinery, scrap and construction materials, and pal1ets.

3. Roofs, covers, or other types of protection shall be used in all other outside storage areas to limit or prevent exposure of materials to precipitation or runoff.

4. In areas where liquid or powdered materials are transferred in bulk from truck or rail cars, pennittees shal1 develop and implement measures to minimize contact of materials with precipitation or runoff. Hose connection points at storage containers shall be located within containment areas and drip pans or other measures shall be used outside the containment area (e.g. at hose reels, connection points with rail cars, tank trucks) to prevent spills from contacting precipitation or runoff.

5. In areas where materials are transferred as packaged materials, permittees shall consider providing appropriate protection such as overhangs or door skirts to enclose trailer ends at truck loading docks, or equivalent controls.

• 6. Structures used to limit pollution at material handling and storage areas should control

drainage through the use of manually operated valves or other similar positive control devices. Flapper-type gate valves are not allowed. Pumps may be used to empty containment areas, but pumps must not be automatically activated. If a facility is not engineered with such controls, the facility's separate stonn sewer system should be equipped to prevent or divert a discharge of spilled materials until the materials can be recovered.

4. Numeric Effluent Limitations - Applicable to Sector C Facilities Discharging Stonn Water from Phosphate Manufacturing

(a) The following numeric effluent limitations, based on guidelines from the Phosphate Subcategory ofthe FertilizerManufacturing Point Source Category (40 CFR § 418.13) apply to any stonn water runoff that has corne into contact with any raw materials, intennediate product, finished product, by-product or waste from areas of industrial activity described by SIC code 2874 (Phosphatic Fertilizers). Samples of these discharges shall be obtained before the runoff combines with other stonn water runoff. Discharges shall not exceed the following numeric effluent limitations, and are subject to monitoring as follows:

Limitations Monitoring Parameter Daily Avg Daily Max Frequency Total Phosphorus (as P) 35 mg/L 105 mg/L INear Fluoride 25 mg/L 75 mg/L INear


(c) Reporting Requirement - Results ofmonitoring for detennining compliance with numeric effluent limitations must be either retained at the facility or shalI be readily available for review by authorized TCEQ personnel upon request. Results must be recorded on a discharge monitoring report (DMR). The DMR must either be an original EPA No. 3320-1 fonn, a duplicate ofthe fonn, or a self generated fonn that is comparable.

• Page 56



Monitoring must be conducted prior to December 31" for each annual monitoring period and the results must be reported as required in Part III.EA.(c) of this permit. In addition, a copy of the DMR must either be retained at the facility or shal1 be made readily available for review by authorized TCEQ personnel upon request by March 31 st following the annual monitoring period.


The followingsubsectors must conduct benchmark monitoring according to the requirements in Part IV of this general permit and conduct evaluations on the effectiveness of the facility SWP3 based on the following benchmark values:

•

SIC Code Description ofIndustrial Activity

Benchmark Parameter

Benchmark Value

2812-2819 Basic Industrial Inorganic Chemicals

Aluminum, total Iron, total Nitrate + Nitrite N TSS

1.2 mg/L 1.3 mg!L 0.68 mg/L 100 mg/L

2821-2824 Plastics, Synthetic Resins, Non-vulcanized Elastomers (Synthetic Rubber), Cel1ulose Plastics Materials, and Other Manmade Fibers Except Glass.

Zinc 0.16 mg/L

2841-2844 Soaps and Detergents; Specialty Cleaning, Polishing, and Sanitation Preparations; Surface Active Agents, Finishing Agents, Sulfonated Oils, and Assistants; Perfumes, Cosmetics, and Other Toilet Preparations

Nitrate + Nitrite N Zinc

0.68 mg/L 0.16 mg/L

2873-2879 Agricultural Chemicals (Including Fertilizers, Pesticides, Fertilizers Solely from Leather Scraps and Leather Dust, and Mixing of Fertilizers, Compost, and Potting Soils)

Nitrate + Nitrite N Lead Iron, total Zinc Phosphorus TSS

0.68 mg/L 0.010 mg/L 1.3 mg/L 0.16 mg/L 1.25 mg/L 100 mg!L

Facilities sampling for the fol1owing pollutants as part of benchmark sampling are also subject to the numeric effluent limits and reporting requirements listed in Part III.D.l. ofthe permit: total lead and total zinc.

Section D. Sector D of Industrial Activity - Asphalt Paving and Roofing Materials and Lubricant Manufacturing Facilities

The requirements in Part V of this general permit are sector specific and are in addition to the requirements in Parts III and IV. Where co-located industrial activities occur (refer to Part II.A.2, of this general permit) the additional conditions and requirements in Part V of this general permit 'for each of these activities also apply.



1. Description ofIndustrial Activity

The requirements under this section apply to storm water discharges from activities identified and described as Sector D. Sector D industrial activities are described by the following SIC codes:

SECTORD: ASPHALT PAVING AND ROOFING MATERIALS AND LUBRICANTS


2951,2952 Asphalt Paving and Roofing Materials, Portable Asphalt Plants

2992,2999 Miscellaneous Products of Petroleum and Coal Including Lubricating Oils and Greases


The following facilities are not eligible for coverage under Section D of this general pennit:

(a) petroleum refming facilities, including those that manufacture asphalt or asphalt products, including facilities described by SIC 2911 (also see Sector I);

(b) oil recycling facilities; and

• 3.

(c) fats and oils rendering facilities.

Pollution Prevention Measures and Controls

Periodic Inspections - Inspection procedures must be developed according to the standard periodic inspection requirements described in Part IILA.5.(g) of this general permit and conducted at least once per month in the following areas:

(a) material storage and handling areas;

(b) areas containing liquid storage tanks, hoppers or silos;

(c) vehicle and equipment maintenance, cleaning, and fueling areas; and

(d) material handling, equipment storage, and processing areas.

Results of the inspections shall be evaluated and records of inspections maintained. Follow-up procedures shan be identified to ensure that appropriate actions are taken in response to the inspector's findings.

4. Numeric Effluent Limitations - Applicable to Sector D Facilities Discharging Storm Water from Asphalt Emulsion Manufacturing Production Areas

(a) The following numeric effluent limitations, based on guidelines from the Asphalt Emulsion Subcategory of the Paving and Roofing Materials (Tars and Asphalt) Manufacturing Point Source Category (40 CFR § 443.13) shall apply to all storm water runoff from asphalt paving and roofing

• Page 58

COA ExhibilTF-5 TPDES Multi Sector Gemeral Permit SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 58 of 111


emulsion production areas. Samples of these discharges shall be obtained before the runoff combines with other stonn water runoff. Samples shall be analyzed as follows, and must not exceed the following numeric effluent limitations:

Limitations: Monitoring Parameter Daily Avg Daily Max Frequency Total Suspended Solids 15 mg/L 23 mg/L l/Year Oil and Grease 10 mg/L 15 mg/L l/Year pH between 6 and 9 S.u. l/Year


(c) Reporting Requirement - Results ofmonitoring for determining compliance with numeric effluent limitations must be either retained at the facility or shall be readily available for review by authorized TCEQ personnel upon request. Results must be recorded on a discharge monitoring report (DMR). The DMR must either be an original EPA No. 3320-1 fonn, a duplicate ofthe fonn, or a self generated fonn that is comparable.

Monitoring must be conducted prior to December 31 st for each annual monitoring period and the results must be reported as required in Part IILE.4(c) of this pennit. In addition, a copy ofthe DMR must either be retained at the facility or shall be made readily available for review by authorized TCEQ personnel upon request by March 31 sl following the annual monitoring period.

s. Benchmark Monitoring Requirements

• The following subsections must conduct benchmark monitoring on discharges ofstonn water associated with industrial activities according to the requirements in Part IV of this general permit.

SIC Code Description of Industrial Benchmark Benchmark Value Activity Parameter

2951,2952 Asphalt Paving and Roofing TSS 100 mg/L Materials, Portable Asphalt Plants

Section E. Sector E of Industrial Activity - Glass, Clay, Cement Concrete, and Gypsum Product Manufacturing Facilities

The requirements in Part V of this general pennit are sector specific and are in addition to the requirements in Parts III and IV. Where co-located industrial activities occur (refer to Part II.A.2. of this general pennit) the additional conditions and requirements in Part V of this general pennit for each of these activities also apply.


The requirements under this section apply to stonn water discharges from activities identified and described as Sector E. Sector E industrial activities are described by the following SIC codes:

• Page 59


Multi Sector General Pennit TPDES General Perinit No. TXR050000 .' SECTOR E: GLASS, CLAY, CEMENT, CONCRETE, AND GYPSUM PRODUCTS


3211 Flat Glass

Glass and Glassware, Pressed or Blown'

Glass Products Made of Purchased Glass ' ,

Hvdraulic Cement

Structural Clay Products

Vitreous China Plumbing Fixtures andChiria Eaithemvare Fittings ~nd Bathroom Accessories

Pottery and Related Products

Concrete, Lime, Gypsum and Plaster Products (includes Ready-Mix Concrete Plants) ,

Cut Stone imd Stone Products

Abrasive Products'

Asbestos Products ..' .,'

.Mirieralsand Earth's, Ground, or Otherwise Treated

3221,3229

3231

3241

3251-3259

3261

3262-3269

3271-3275

3281

3291

3292

3295

3296 Mineral Wool

Non-Ciay Refractories

Nonmetallic Mineral Products Not Elsewhere Classified

3297

3299• 2. Non-Storm Water Discharges

In addition to the certification requirements required by Part IILAJ.(c) of tins generalpennit, facilities that produce ready-mix concrete, concrete block, and other concrete products shall provide additional certification that process Wastewater resulting from washing oftrucks, mixers, transport buckets, concrete forms, and other equipment will riotdischarge into surface water in the state, or shall provide certification that such process wastewateris discharged under authority ora separate TPDES or NPDES pennit.

3. POllution Prevention Measures and Controls

The following requirements shall be included in the SWP3 according to requirements ofPart IILA.5. of this general pennit:

(a) Specific good housekeeping measures shall be developed to minimize and prevent exposure of spilled cement and aggregate, kiln dust, fly ash, and other dust to precipitation or runoff.

(b) .. Wherever possible, fme solids suchas cement, fly ash, andkilp. dust must be stored in enclosed silos, hoppers, buildings or other structures to prevent expos'ureto preCipitation or runoff.

(c) Periodic Inspections - Inspection procedures must be developed according to the standard periodic inspection requirements dC?scribed in Part IILA.5.(g) of this general permit, but inspections must be conducted at least once per month.

• Page 60

COA Exhibit TF-5 TPDES Multi Sector Gerneral Permit SOAH Docket No. 582-08-2186 TCEQDocket No. 2006-0612-MSW Page 60 of 111 .


4. Numeric Effluent Limitations - Applicable to Sector E Facilities Discharging Stonn Water from Cement Manufacturing

(a) The following numeric effluent limitations, based onguideIines from the Material Storage Piles Runoff Subcategory ofthe Cement Manufacturing Point Source Category (40 CFR § 411.32) shall apply to any stonn water runoff that has come into contact with raw materials, intennediate products, fmished products, by-products, or waste materials that are either used or derived from the manufacture of cement. These effluent limitations do not apply to Sector E facilities that are not subject to federal guidelines at 40 CFR Part 411. Samples ofthese discharges shall be obtained before the runoff combines with other stonn water runoff, analyzed, and shall not exceed the following numeric effluent limitations:

Limitations Monitoring Parameter Daily Max Frequency Total Suspended Solids 50 mg/L l/Year pH between 6 and 9 S.U. l/Year


(c) Reporting Requirements - Results ofmonitoring fordetennining compliance with numeric effluent lirnitationsmust be recorded on a discharge monitoring report (DMR). The DMR must either be an original EPA No. 3320-1 fonn (Part VI of this general pennit), a duplicate of the fonn, or as otherwise provided by the executive director.

• Monitoring must be conducted prior to December 31st for each annual monitoring period and the results must be recorded and reported as required in Part.IILE.4.(c) of this pennit. In addition, a copy of the DMR must either be retained at the facility or shall be made readily available for review by authorized TCEQ personnel upon request by March 31 Sl following the annual monitoring period.

(d) Waiver from Numeric Effluent Limitations:

Any untreated overflow from facilities designed, constructed, and operated to treat the volume of runoff from materials storage piles which is associated with a 10cyear, 24-hour rainfall event shall not be subject to the pH and TSS limitations.

Rainfall records are required to document events that equal or exceed a lO-year 24-hour event. The operator shall maintain, as a part of the SWP3, the following infonnation in order to receive this waiver:

(i) engineering design records that demonstrate structural controls are adequate to intercept, contain, and treat the volume of runoff from a 10-year, 24-hour stonn event; and

(ii) records of rainfall from a either a rain gauge that is located onsite or a rain gauge maintained in the immediate area of the facility.

• Page 61

COA Exhibit TF-5 TPDES Multi Sector Gemeral Permit SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 61 of111



The following subsections must conduct benchmark monitoring according to the requirements in Part IV of this general permit and conduct evaluations on the effectiveness of the facility SWP3 based on the following benchmark values:

SIC Code Description of Industrial Activity

Benchmark Parameter Benchmark Value

3251-3259 Structural Clay Products Aluminum, total 1.2 mg/L 3262-3269 Pottery and Related TSS 100 mglL

Products pH 6.0-9.0 std. units

3271-3275 Concrete, Lime, Gypsum TSS 100 mglL and Plaster Products Iron, total 1.3 mg/L

Section F. Sector F oflndustrial Activity - Primary Metals Facilities

The requirements in Part V of this general pennit are sector specific and are in addition to the requirements in Parts III and IV. Where co-located industrial activities occur (refer to Part II.A.2. of this general pennit) the additional conditions and requirements in Part V of this general pennit for each of these activities also apply.


• The requirements under this section apply to stonn water discharges from activities identified and described as Sector F. Sector F industrial activities are described by the following SIC codes:

SECTOR F: PRIMARY METALS



3321-3325 Iron and Steel Foundries

3331-3339 Primary Smelting and Refining of Nonferrous Metals

3341 Secondary Smelting and Refining of Nonferrous Metals

3351-3357 Rolling, Drawing, and Extruding of Nonferrous Metals


3398 3399 Miscellaneous Primarv Metal Products


The inventory of exposed materials must include areas where material handling and air emissions may result in deposits of particulate matter.


(a) Good Housekeeping Measures - This section ofthe SWP3 must include a program for cleaning and maintaining alI impervious areas of the facility where dust, 4ebris, or other particulate matter may

• Page 62

COA Exhibit TF-5 TPDES Multi Sector Gerneral Permit SOAH Docket No. 582-08"2186 TCEQ Docket No. 2005-{)612-MSW Page 52 of 111


accumulate, especially areas where materialloadinglunloading, storage, handling and processing occur. Areas where materials are stored, or where there is vehicular traffic, should be paved if vegetative and other stabilizationmethods are not practical. For areas where paving and vegetative measures are not practical, structural controls shall be developed to trap and limit transport of sediment offsite. Sediment traps, filter fabric fences, arid other equivalent measures may be considered.

(b) Periodic Inspections - The periodic inspections shall specifically include areas of the facility that contain' air pollution control equipment, such as bag houses, electrostatic precipitators and scrubbers. Process material handling equipment must be inspected for leaks and problems that may result in material loss and spills. Material storage areas, such as piles or bins that contain coal, scrap, and slag, must be inspected for material loss due to wind and precipitation or runoff.



• SIC Code Description of Industrial

Activitv Benchmark Parameter

Benchmark Value


Aluminum, total Zinc, total TSS

I.2mgIL 0.16 mglL 100 mgIL

3321-3325 Iron and Steel Foundries Aluminum, total TSS Copper, to~al

Iron, total Zinc, total TSS

1.2 mgIL 100 mglL 0.030 mgIL 1.3 mglL 0.16 mglL 100 mglL

3351-3357 Rolling; Dra,wing, and Extruding' of Nonferrous Metals

Copper,total Zinc, total

0.030 mglL 0.16 mglL


Copper, total Zinc total

0.030 mgIL 0.16 mQ'1L

Facilities sampling for the following pollutants as part of benchmark sampling are also subject to the numeric effluent limits and reporting requirements listed in Part III.D.l. ofthe permit: total zinc and total copper.

Section G. Sector G oflndustrial Activity - Metal Mining (Ore Mining and Dressing)

The requirements in Part V of this general permit are sector-specific and are in addition to the requirements in Parts III and IV. Where co-located industrial activities occur (refer to Part II.A.2. of this general permit) the additional conditions and requirements in Part V of this general permit for each of these activities also apply.

• Page 63

COA ExhibitTF-5 TPDES Multi Sector Gemeral Permit SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 63 of 111



The requirements under this section apply to storm water discharges from activities identified and described as Sector G. Sector G industrial activities are described by the following SIC codes:

SECTOR G: METAL MINING (ORE MINING AND DRESSING)


1011 Iron Ores

1021 Copper Ore Mining and Dressing

1031 Lead and Zinc Ores

1041, 1044 Gold and Silver Ores

1061 Ferro alloy Ores, Except Vanadium

1081 Metal Mining Services

1094 1099 Miscellaneous Metal Ores

• 2.

3.

The requirements of Section G apply to storm water discharges from active and inactive metal mining operations and from facilities engaged in developing mines or exploring for metallic ores if the storm water comes into contact with any overburden, raw material, intermediate product, finished product, byproduct, or waste product. The requirements also apply to storm water discharges from ore dressing facilities and processing operations, whether performed at mills operated in conjunction with the mines or at separately operated "custom" mills, if the storm water comes into contact with overburden, raw material, intermediate product, finished product, byproduct, or waste product.

Definitions

The following definitions apply only to Section G of this general permit:

(a) Active metal mining facility - a facility where work is conducted to extract, remove, or recover metal ore or where work directly related to the extraction, removal, or recovery of metal ore is conducted.

(b) Inactive metal mining facility - a facility where metal mining or milling activities occurred in the past, but that does not meet the definition of an active metal mining facility, and for which there is no active mining permit issued by the Railroad Commission of Texas.

(c) Temporarily inactive metal mining facility - a facility or portion of a facility where metal mining or milling activities occurred in the past, but currently are not taking place, and the facility has an active ~ining permit issued by the Railroad Commission of Texas.

Limitations on Permit Coverage

(a) For storm water discharges from active and temporarily inactive facilities, coverage under this section is limited to storm water that contacts the following areas:

(1) topsoil piles;

• Page 64



(2) haul or access roads not located on active areas, not constructed of waste rock or spent ore, and not where mine water is used for dust control;

(3) onsite haul and access roads not constructed of waste rock or spent ore, and where mine water is not used for dust control;

(4) runoff from tailings dams and dikes when not constructed of waste rock or tailings, and where no process fluids are present;

(5) concentration building and mill site, ifno contact with material piles;

(6) chemical and explosive storage areas;

(7) docking areas, if the storm water does not contact any waste product; and

(8) reclaimed areas released from reclamation bonds before December 17, 1990, and partially or inadequately reclaimed areas or areas not release from reclamation bonds.

(b) The following discharges are not covered by this general permit:

(1) Discharges from active metal mining facilities subject to effluent limitation guidelines for the Ore Mining and Dressing Point Source Category (40 CFR Part 440); and

• (2) adit drainage, contaminated springs, and seeps from active, temporarily inactive, and inactive

mmes.


In addition to requirements of Part III.AA. of this general permit, the following is required:

(a) Inventory of Exposed Materials - This section of the SWP3 must contain a summary of any existing ore, waste rock, and overburden characterization data. The summary must include results of all testing for acid rock generation potential. The inventory and the SWP3 shall be updated if the characterization is updated due to a change in the type ofore mined. For inactive metal mining facilities the inventory must identify any significant materials that remain at the facility and include any available characterization data of the material.

(b) Narrative Description - For inactive metal mining facilities, this section of the SWP3 must include a description of the mining and associated activities that took place at the site. The description shall define the dates of operation, total acreage within the mine, total acreage within the processing area, an estimate of the acres of remaining disturbed area, and any current activities at the site (e.g. reclamation)

(c) Site Map - A topographic site map (or maps) shall be developed to indicate mining or milling site boundaries; access and haul roads; equipment storage, fueling, and maintenance areas; an outline of the overburden, materials, soils, tailings or wastes storage areas; points of discharge from the property of mine drainage or any other process wastewater, a depiction ofthe discharge route, and a listing ofthe type ofwastewater; location ofexisting and proposed tailings piles and ponds; heap leach pads; locations of springs, streams, wetlands, and other surface waters; and boundaries of tributary areas that are subject to effluent limitations and guidelines for the Ore Mining and Dressing Point Source Category (40 CFR Part 440). .


Multi Sector General Pennit TPDES General Pennit No. TXR050000

5. Management of Runoff with Structural Controls

The elimination ofa contaminant source through capping ofthe source may be the most effective control measure. Where capping is'used, the source being capped shall be identified and the materials and procedures used to cap the source shall be described within theSWP3.


Active copper ore mining or dressing facilities must conduct benchmark monitoring according to the standard benchmark monitoring requirements in Part IV of this general pennit and conduct evaluations on the effectiveness of the facility SWP3 based on the following benchmark values:

SIC Code Description of Industrial Activity Benchmark Parameter

Benchmark Value

1021 Copper Ore Mining and Dressing COD TSS Nitrate + Nitrite N

·55 mg/L 100mg/L 0.68 mQ/L

All storm water discharges from waste rock and overburden piles, resulting from active ore mining or dressing operations. included in Sector G, must collect one benchmark monitoring sample according to the requirements in Part IV oftliis general permit for the following pollutants. For parameters measured above the benchmark value, monitoring must be continued throughout the term of the pennit.

• Benchmark Parameter Benchmark Value

TSS 100 mg/L ,

Turbidity (NTUs) 5 NTUs above background pH 6.0 - 9.0 standard units Hardness (as CaC03) no benchmark value Total Antimony 0.636 mg/L Total Arsenic 0.17 mg/L Total Beryllium 0.13 mg/L Total Cadmium 0.016 mgIL Total Copper 0.030 mg/L Total Iron 1.3 mg/L Total Lead 0.010 mg/L .Total Manganese 1.0 mg/L Total Mercury 0.0019 mg/L Total Nickel 1.417 mg/L Total Selenium 0.05 mg/L Total Silver 0:0318 mg/L Total Zinc 0.16 mg/L

Facilities sampling for the following pollutants as part of benchmark sampling are also subject to the numeric effluent limits and reporting requirements listed in Part III.D.1. ofthe permit: total arsenic, total cadmium, total copper, total lead, total manganese, total mercury, total nickel, total selenium, total silver, ·and total zinc.

Section H. Sector H ofIndustrial Activity - Coal Mines and Coal Mining Related Facilities

The requirements in Part V ofthis general pennit are sector-specific and are in addition to the requirements in Parts III and IV. Where co-located industrial activities occur (refer to Part ILA.2. of this general pennit) the additional conditions and requirements in Pan V of this general permit for each of these activities also apply.

Page 66

COA ExhibitTF-5 TPDES Multi,Sector Gerneral Permit

. SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 66 of111



The requirements under. this section apply to stonn water discharges from activities identified and described as Sector H. Sector H industrial activities are described by the following SIC codes:

SECTOR H: COAL MINES AND COAL MINING RELATED FACILITIES

SIC Code Description ofIndustrv Sub-sector

1221-1241 Coal Mines and Coal Mininl!-Related Facilities

The requirements of Section H apply to stonn water discharges from the following portions of coal mining-related areas: haul roads; access roads; railroad spurs, sidings, and tracks used to transport coal; areas around conveyor belts, chutes, and trams that convey coal; equipment storage and maintenance areas; all coal handling areas, including buildings; waste disposal areas; inactive coal mines; and all onsite areas where coal mining/processing activities take place.


The following discharges are not covered by this general pennit:

(a) discharges from coal mining activities subject to effluent limitation guidelines for the Coal Mining Point Source Category (40 CFR Part 434);

• (b) seeps and underground drainage from inactive coal mines and refuse disposal areas that may

constitute dry-weather flows and do not occur as a direct result of precipitation or runoff; and

(c) discharges from floordrains in maintenance buildings and similar drains in mining and preparation plant areas.


Erosion Control Measures- Erosion, siltation, dust, and other pollutant control regulations administered by the Railroad Commission ofTexas shall either be included as components ofthis section ofthe SWP3, or shall be incorporated by reference. The Erosion Control Measures shall provide for minimizing disturbed areas and preserving vegetated areas to the maximum extent practicable and must include the following at a minimum:

(a) Stabilization Measures - Temporary and pennanent stabilization measures shall be employed to minimize erosion and may include: maintaining existing native vegetative cover; seeding for temporary or pennanent cover; temporary mulching, matting, or netting; sodding; soil binding; using non-acid material for road surfacing; planting trees; and preserving existing trees.

(b) Structural Measures - Structural measures may include: silt fences; earthen dikes; straw bales; graded terraces; pipe slope drains; porous rock check drains; sedimentation ponds; vegetated drainage swales; capping of contaminant sources; and physical or chemical treatment of stonn water.

• Page 67

COA Exhibit TF-5 . TPDES Multi Sector Gerneral Permit SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 67 of 111


4. ComprehensiveSite Compliance Evaluation

The SWP3 shall be revised to reflect the fmdings ofthe comprehensive site compliance evaluation within a maximum of 12 weeks following completion of the evaluation for inactive mining facilities.



SIC Code Description of Benchmark Benchmark Value Industrial Activity Parameter

1221-1241 Coal Mines and Coal Mining-Related Facilities

TSS Aluminum, total Iron total

100 mg/L 1.2 mg/L 1.3 mQ/L

Section I. Sector I of Industrial Activity - Oil and Gas Extraction Facilities

• The requirements in Part V of this general permit are sector-specific and are in addition to the requirements in Parts III and IV. Where co-located industrial activities occur (refer to PartII.A.2. of this general permit) the additional conditions and requirements in Part V of this general permit for each of these activities also apply.


Sector I facilities include facilities with activities directly related to: oilllnd gas exploration, production, processing, or treatment operations; oil and gas transmission facilities prior to refining; and to oil and gas field service operations.

SECTOR I: OIL AND GAS EXTRACTION FACILITIES

SIC Code Description of Industry Sub-sedor

1311 Crude Petroleum and Natural Gas

1321 Natural Gas Liquids

1381-1389 Oil and Gas Field Services

2911 Petroleum Refmeries


General permit coverage for industrial activities described by Sector I is limited to oil and gas field service companies performing industrial activities described by SIC codes 1381-1389 and petroleum refineries performing industrial activities described by SIC code 2911. Facilities described by SIC codes 1381-1389 are not required to obtain authorization under this permit if the facility has not had a release ofa reportable quantity in storm water for which notification has been required any time since November

• Page 68



16, 1987. General permit coverage for oil and gas field service companies is limited to the industrial activities that occur at the service company headquarters, permanent offices, or similar base ofoperations.

General permit coverage for other storm water discharges associated with industrial activity described by Sector I are not eligible for coverage under this general permit. Discharges not eligible for coverage under this permit must be authorized through the following mechanisms:

(a) Petroleum Refmeries - Discharges of storm water from petroleumrefmeries subject to federal guidelines found at 40 CFR Part 419 must be authorized by an individual TPDES wastewater discharge permit. Only discharges of non-process area storm water runoff that are not subject to 40 CFR Part 419 guidelines may be authorized under this general permit.

(b) This general permit does not authorize storm water discharges from facilities with SIC codes 1311, 1321, and 1381-1388. Authorization for these discharges must be ohtained through application for a National Pollutant Discharge Elimination System (NPDES) permit under the U.S. EPA and authorization from the Railroad Commission ofTexas (i(applicable).

(c) This general permit does not cover storm water discharges from oil and gas field service activities described by SIC code 1381-1389 that occur in the field. Authorization for these discharges must be obtained through application for a National Pollutant Discharge Elimination System (NPDES) permit and authorization from the Railroad Commission of Texas (if applicable).

Section J. Sector J of Industrial Activity - Mineral Mining and Processing Facilities

• The requirements in Part V of this general permit are sector-specific and are in addition to the requirements in Parts III and IV. Where co-located industrial activities occur (refer to Part II.A.2. of this general permit) the additional conditions and requirements in Part V of this general permit for each of these activities also apply.


The requirements under this section apply to storm water discharges from activities identified and described as Sector J. Sector J industrial activities are described by the followmg SIC codes:

SECTORJ: MINERAL MINING AND DRESSING FACILITIES


1411 Dimension Stone

1422-1429 ;

Crushed and Broken Stone, Including Rip Rap

1481 Nonmetallic Minerals, Except Fuels

1442,1446 Sand and Gravel Mining

1455,1459 Clay, Ceramic, and Refractory Materials

1474-1479 Chemical and Fertilizer Mineral Mining

1499 Miscellaneous Nonmetallic Minerals Excent Fuels

• Page 69

COA Exhibit TF-5 TPDES Multi Sector Gerneral Permit

·SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 69 of 111


2. Definitions

Aggregates - any commonly recognized construction material originating from a quarry or pit by the disturbance of the surface, including dirt, soil, rock asphalt, granite, gravel, gypsum, marble, sand, stone, caliche, limestone, dolomite, rock, riprap, or other nonmineral substance. The term does not include clay or shale mined for use in manufacturing structural clay products.

Inactive mining facilities or operations - mining sites which are not being actively mined, but which have an identifiable operator.

Quarry - the site from which aggregates for commercial sale are being or have been removed or extracted from the earth to form a pit, including the entire excavation, stripped areas, haulage ramps, and the immediately adjacent land on which the plant processing the raw materials is located. The term does not include any land owned or leased by the operator not being currently used in the production ofaggregates for commercial sale or an excavation to mine clay or shale for use in manufacturing structural clay products.

3. Annual Comprehensive Site Compliance Evaluation

The SWP3 shall be revised to reflect the findings ofthe annual comprehensive site compliance evaluation within a maximum of 12 weeks following completion of the evaluation for inactive mining facilities.


• This general permit does not authorize the discharge of storm water runoff described in the Texas Water Code, Section 26.553 (related to certain quarries located in the John Graves Scenic Riverway, in the Brazos River Basin), where TCEQ rules require coverage under an individual permit or alternative general permit. These facilities must obtain coverage under an alternative TPDES permit as described in applicable TCEQ rules. IfTCEQ rules are promulgated after issuance of this general permit, these quarries may obtain coverage under this general permit until a rule is promulgated or an alternative general permit is issued to address the discharges. Coverage under this general permit will expire 90 days following issuance of the rule, or following the time frame specified in the rule or an alternative general permit.

5. Numeric Effluent Limitations - Applicable to Sector J facilities discharging storm water from sand, gravel, and crushed stone mining operations subject to federal effluent limits.

(a) The following numeric effluent limitations, based on guidelines for mine dewatering from the Mineral Mining and Processing Point Source Category (40 CFR Part 436), shall apply to mine dewatering operations (discharges from the mine pit ofaccumulated storm water and ground water seepage) at construction sand and gravel, industrial sand, or crushed stone mining facilities. Samples of these discharges shall be obtained before the runoff combines with other storm water runoff, analyzed, and shall not exceed the following numeric effluent limitations:

(i) For mine dewatering discharges from facilities regulated under 40 CFR Part 436, Subpart B (Crushed Stone Subcategory) and Subpart C (Construction Sand and Gravel Subcategory), the foHowing effluent limits apply:

• Page 70


•• Multi Sector General Pennit TPDES General Pennit No. TXR050000

Limitations Monitoring Parameter Daily Avg Daily Max Frequency pH between 6 and 9 S.U. l/Year

(ii) For mine dewatering discharges from facilities regulated under 40 CFR Part 436, Subpart D (Industrial Sand Subcategory), the following effluent limits apply:

Limitations Monitoring Parameter Daily Avg Daily Max Frequency Total Suspended Solids 25 mg/I 45 mg/I l/Year pH between 6 and 9 S.U. l/Year

These limitations do not apply to Sector J facilities that are not subject to federal guidelines at 40 CFR Part 436.


(c) Reporting Requirements - Results ofmonitoring for determining compliance with numeric effluent limitations must be recorded on a discharge monitoring report (DMR). The DMR must either be an original EPA No. 3320-1 form (Part VI of this general permit), a duplicate ofthe form, or as otherwise provided by the executive director.

• Monitoring must be conducted prior to December 31 51 for each annual monitoring period and the results must be recorded and reported as required in Part.III.EA.(c) of this permit. In addition, a copy of the DMR must either be retained at the facility or shall be made readily available for review by authorized TCEQ personnel upon request by March 31 51 following the annual monitoring period.

(d) Waivers from Numeric Effluent Limitations

Numeric effluent limitations for mine dewatering do not apply to discharges that overflow from structural control facilities that are designed, constructed, and maintained to contain or treat the volume ofmine dewatering wastewater that would result from a 1O-year, 24-hour storm event. The permittee shall maintain, as a part of the SWP3, the following information in order to receive this waiver: engineering design records that demonstrate structural controls are adequate to intercept, contain, and treat the volume ofrunofffrom a 10-year, 24-hour storm event; and records ofrainfall from either a rain gauge that is located onsite or a rain gauge maintained in the immediate area of the site. Rainfall records are only required to document events that equal or exceed a 10-year, 24hour event.


The following subsectors must conduct benchmark monitoring on discharges of storm water associated with industrial activities according to the requirements in Part IV of this general pennit.

• Page 71

GOA ExhibitTF-5 TPDES Multi Sector Gerneral Permit SOAH Docket No. 582-08-2186 TGEQ Docket No. 2006-0612-MSW Page 71 of 111

Multi Sector General Permit TPDES General Permit No. TXROSOOOO

SIC Code Description of Industrial Benchmark Benchmark Value Activitv . Parameter

1411 Dimension Stone TSS 100 mg/L 1422-1429 Crushed and Broken pH 6.0-9.0 S.u.

1481 Stone, Incl. Rip Rap Nonmetallic Minerals, Except Fuels

1442,1446 Sand and~Gravel Mining Nitrate + Nitrite N 0.68 mglL TSS 100 m!!II.


Ouarterly Visual Monitoring ~ fuactive industrial facilities must conduct visual examinations on'at least an annual basis, instead oftheregularly scheduled quarterly baskas described in Part III.A:S:(hrofthis permit. Inactive Sector J facilities may not obtain a waiver from this annual 'visual monitoring.

Section K. Sector K ofIndustrial i\etivity- Hazardous Waste Storage Facilities

The requirements in Part V of this general permit are sector-specific and are in addition to the requirements in Parts III. and IV. Where co-located industrial activities occur (refer to Part II.t\7: pfthis general permit) the additional conditions and requirements in Part V of this general permitfor.eachofthese activities also apply.


• Sector Kfacilities inClude those facilities with activities directly related to the 'treatment, storage, and disposal of hazardous wastes, including those that are operating 'under the regulatory authority and authorization of subtitle C of the Resource Conservation and Reco~ery Act (RCRA).

SECTOR K: HAZARDOUS WASTE STORAGE FACILITIES

Activitv Code DescriDtion of Industrv Sub2sector, ,

; "

HZ Limited to Hazardous Waste Treatment Storage imd DisDosal

2. Limitations on Permit Coverag'e " . ..;

Coverage is limited to those facilities that treat, store, or dispose of hazar'dous waste. The executive director may require an individual TPDES permit for any discharge~under thissector.if conditions warrant.


The following subsections must conduct benchmark monitoring according to the requirements in Part IV of this general permit'and conduct evaluations on the effectiveness of the facility SWP3 based on the following benchmark values: .

• Page 72

COA Exhibit TF-5 TPDES Multi Sector Gerneral Permit SOAM Docket No, 582-08-2186 TCEQ Docket No, 2006-0612-MSW Page 72 of 111


Activity Code

Description of Industrial Activity Benchmark Parameter

Benchmark Value

HZ Hazardous Waste Treatment, Storage, and Disposal

Ammonia-Nitrogen Magnesium, total COD Arsenic, total Cadmium, total Cyanide, total Lead, total Mercury, total Selenium, total Silver total

8.11 mg/L 0.064 mg/L 55 mg/L 0.17 mg/L 0.016 mg/L 0.064 mg/L 0.010 mg/L 0.0019 mg/L 0.05 mg/L 0.032 mg/L

Facilities sampling for the following pollutants as part of benchmark sampling are also subject to the numeric effluent limits and reporting requirements listed in Part III.D.l. ofthe permit: total arsenic, total cadmium, total lead, total mercury, total selenium, and total silver.

Section L. Sector L of Industrial Activity - Landfills and Land Application Sites

The requirements in Part V of this general permit are sector-specific and are in addition to the requirements in Parts III and N. Where co-located industrial activities occur (refer to Part II.A.2. of this general permit) the additional conditions and requirements in Part V of this general permit for each of these activities also apply.


• The requirements under this section apply to storm water discharges from activities identified and described as Sector L. Sector L industrial activities are described by the following Industrial Activity Code:

SECTOR L: LANDFILLS AND LAND APPLICATION SITES


LF Limited to Landfills, Land Application Sites, and Open Dumps that Receive or Have Previously Received Industrial Waste, including sites subject to regulation under Subtitle D of the Resource Conservation and Recovery Act (RCRA).

2. Definitions

The following definitions apply only to Section L of this general permit:

Final Stabilization - For the purposes of this permit, includes all requirements needed to achieve final regulatory closure of the site.

Inactive landfill - A facility that no longer receives waste and has completed closure according to all applicable federal, state, and local requirements, but where an authorization under this general permit is maintained.

• Page 73



Landfill - a disposal facility or part of a facility where solid waste is placed in or on land and which is not a pile, a land treatment facility, a surface impoundment, an injection well, a salt dome formation, a salt bed formation, an underground mine, a cave, or a corrective action management unit.

Land Application Site, or Land Treatment Facility - A facility or part of a facility at which solid waste is applied onto or incorporated into the soil surface and that is not a corrective action management unit; such facilities are disposal facilities if the waste will remain after closure.

Open Dump - a facility for the disposal of solid waste which is not otherwise defined in this section.

Temporary Stabilization - A condition where exposed soils or disturbed areas are provided a protective cover, which may include temporary seeding, geotextiles, mulches, and other techniques to reduce or eliminate erosion until either final stabilization can be achieved or until further construction activities take place.


This general permit specifically does not authorize the discharge oflandfill wastewater subject to federal effluent guidelines at 40 CFR Part 445 (Landfills Point Source Category), including but not limited to: leachate; gas collection condensate; drained free liquids; laboratory derived wastewater; contaminated storm water and contact wash water from washing truck, equipment and railcar exteriors; and storm water from surface areas that have come in direct contact with solid waste at the landfill facility. Discharges subject to federal effluent guidelines at 40 CFR Part 445 must be authorized under an individual TPDES or NPDES permit.

• 4. Description of Potential Pollutants and Sources

Site Map - The site map shall depict the locations ofactive and closed landfill cells or trenches, locations of active and closed land application areas, and the locations of any known leachate springs or similar uncontrolled leachate sources that could contact storm water. The site map shall also depict the location of leachate collection and treatment systems.


(a) Periodic Inspections

(1) For inactive landfills and land application sites, this section of the SWP3 must include inspection procedures for evaluation ofstabilization and structural erosion control measures, and leachate collection and treatment systems.

(2) For active landfills and land application sites:

(i) inspection procedures must be developed according to the standard periodic inspection requirements described in Part III.A.5 .(g) ofthis general permit, but inspections must be conducted at least once per week;

(ii) inspection procedures must be developed according to the standard periodic inspection requirements described in Part III.A.5.(g) of this general permit, but inspections must be conducted at least once each month where sites are located in areas where annual average rainfall is less than or equal to 20 inches (based on long-term meteorological data).

• Page 74

GOA Exhibit TF-5 TPDES Multi Sector Gerneral Permit SOAH Docket No. 582-08-2186 TGEQ Docket No. 2006-0612-MSW Page 74 of111


(3) For areas of landfill sites where landfill activities are completed and soils are finally stabilized, and for land application sites where land application has been completed, inspection procedures must be developed according to the standard periodic inspection requirements described in Part III.A.5.(g) of this general permit, but inspections must be conducted at least once every month. .

(b) Erosion Control Measures - Landfill operators shall provide temporary stabilization ofall materials that are stockpiled and stored for future use. Inactive areas of the landfill with stockpiled materials that have intermediate cover, but no ,final cover, shall be stabilized. Inactive areas that have received final cover shall be temporarily stabilized until final stabilization measures are completed. Inactive land application areas shall be temporarily stabilized until final stabilization measures are completed.

(c) Records - Land application site operators shall maintain a tracking system to define the types and quantities of wastes applied within specific areas of the application site. These records shall either be included in the SWP3 or be referenced and made readily available for review by authorized TCEQ personnel upon request.



• Activity Code Description of Industrial Activity Benchmark

Parameter Benchmark Value

LF Landfills, Land Application Sites, and Open Dumps that Receive or Have PreviousIy Received Industrial Waste, including sites subject to regulation under Subtitle D of the Resource Conservation and Recoverv Act (RCRA).

Iron, total TSS

1.3 mg/L 100 mg/L

7. Closed Landfins

Permit Coverage is not required where a site has achieved final regulatory closure with respect to solid waste regulations, and where the entire landfill area has been filled in, regraded, and finally stabilized.

Section M. Sector M oflndustrial Activity - Automobile Salvage Yards



The requirements under this section apply to storm water discharges from activities identified and described as Sector M. Sector M industrial activities are described by the following SIC code:

• Page 75



SECTOR M: AUTOMOBILE SALVAGE YARDS


5015 Automobile Salvage Yards


Site Map - The site map must include the locations of the following activities if there is potential exposure to storm water: \

(a) vehicle and vehicle parts storage areas;

(b) vehicle dismantling areas;

(c) vehicle and equipment fueling and maintenance areas;

(d) vehicle, parts, and equipment cleaning areas;

(e) waste treatment, storage and disposal areas; and

(f) areas where fluids or fuels are stored in drums, tanks, or other containers.


• Spill Prevention and Response Measures - Vehicles shall be inspected for leaking fluids upon arrival at the facility. Actions shall be immediately taken to prevent the discharge of fluids according to specific measures established by the operator within the Spill Prevention and Response Measures section of the SWP3. All vehicles received for salvage shall be drained of fluids before being routed to crushers for disposal. Vehicles that are stored, and that are not drained of fluids, shall be inspected for leaks at least once per quarter. These inspections may be incorporated as part of the standard periodic inspections. The Spill Prevention and Response Measures shall be developed with specific guidelines for inspecting stored vehicles and measures to be taken when vehicles are identified as leaking or in danger of developing leaks. All fluids must be handled and disposed ofaccording to all applicable state and federal regulations.

Periodic Inspections - Equipment containing hydraulic or other fluids shall be inspected for leaks during the periodic inspections.

Good Housekeeping Measures Equipment operators must conduct inspections of equipment on a daily basis when equipment is in use.

Employee Training Program and Employee Education - The employee training program shall include training on the following operations at facilities where these activities occur or wastes are generated:

(a) used oil and spent solvent management;

(b) management ofmetal filings and dust from welding, grinding, and similar operations that produce metal waste; and

(c) lead-acid battery management.

• Page 76





SIC Code Description of Industrial Benchmark Benchmark Value Activity Parameter

5015 Automobile Salvage Yards TSS Aluminum, total Iron, total Lead total

100.0 mg/L 1.2 mgIL 1.3 mgIL 0.010 mg!L

Facilities sampling for the following pollutant as part of benchmark sampling are also subject to the numeric effluent limits and reporting requirements listed in Part III.D.1. of the permit: total lead.

Section N. Sector N oflndustrial Activity - Scrap and Waste Recycling Facilities

The requirements in Part V of this general permit are sector specific and are in addition to the requirements in Parts III and IV, Where co-located industrial activities occur (refer to Part II.A.2. of this general permit) the additional conditions and requirements in Part V of this general permit for each of these activities also apply.


• The requirements under this section apply to storm water discharges from activities identified and described as Sector N. Sector N industrial activities are described by the following SIC Code:

SECTOR N: SCRAP AND WASTE RECYCLING FACILITIES

SIC Code Descrintion of Industrv SUb-sector

5093 Scrap Recycling Facilities (Scraps include metals, paper, plastic, cardboard, glass, animal hides, used oil, antifreeze, mineral spirits, industrial solvents, and other materials)


Storm water discharges from areas where metal turnings previously exposed to cutting oils are stored or stockpiled, and where these materials are not isolated from storm water by storm resistant shelters, are only eligible for coverage if:

(a) dedicated containment areas are used that include a perimeter barrier to prevent storm water run-on and runoff; .

(b) containment areas and perimeter barriers are constructed ofconcrete, or other similar impermeable oil-resistant materials; and

(c) if discharges only occur following treatment through an oil/water separator or similarly efficient treatment unit.

• Page 77




•

Site Map - The site map shall clearly show containment areas for metal turnings that are exposed to cutting fluids.


Best Management Practices - A scrap material inspection procedure shall be developed for inbound scraps to minimize the receipt of materials that are significant sources of pol1utants to stonn water discharges. Procedures may include advising scrap suppliers which materials will not be accepted, educating scrap material providers to drain all residual fluids before delivery, and training personnel to recognize significant pollutant sources so that materials may either be rejectedor handled in a manner so as to minimize the potential for contamination of stonn water. Facilities that receive separated materials from the general public for recycling shall minimize the. acceptance of hazardous scrap materials and non-recyclable scrap materials by clearly marking public drop-off containers. The Best Management Practices section of theSWP3 shall identify specific procedures for collecting, handling, and disposing ofresidual fluids that are recovered from scrap materials, inc!uding cutting fluids recovered before discharge from dedicated metal turnings containment areas, and for disposing of non-recyclable scrap materials.

BMPs shall be defined to minimize storm water contact with outdoor stockpiled materials, including any materials that may contain residual fluids. Measures may include pennanent or semi-pennanent covers, diversion ofrunoffaway from materials through the use ofbenns, trenches, culverts, or similar controls.

Specific BMPs shall be defined to ensure proper handling, storage, and disposal of scrap lead-acid batteries. BMPs must minimize exposure of lead-acid batteries to storm water, and must provide procedures for handling cracked or leaking batteries.



SIC Code Description oflndustrial Activity Benchmark Parameter

Benchmark Value

5093 Scrap Recycling Facilities (Scraps include metals, paper, plastic, cardboard, glass, animal hides, used oil, antifreeze, mineral spirits, industrial solvents, and other materials)

Copper, total Aluminum" total Iron, total Lead, total Zinc, total TSS COD

0.030 mgIL 1.2 mgIL 1.3 mgIL 0.010 mg/L 0.16 mg/L IOOmgIL 55 mgfL

Facilities sampling for the following pollutants as part of benchmark sampling are also subject to the numeric effluent limits and reporting requirements listed in Part I1I.D..1. ofthe pennit: total lead and total zinc.

• Page 78



Section O. Sector 0 of Industrial Activity ~'Steam Electric Generating Facilities

The requirements in Part V of this general permit are sector specific and are in addition to the requirements in Parts ill and IV. Where co-located industrial activities occur (refer to Part II.A.2. of this general permit) the additional conditiclns and requirements in Part V of this general permit for each of these activities also apply.


The requirements under this section apply to storm water discharges from activities identified and described as Sector O. Sector 0 industrial activities are described by the following Industrial Activity Code:

SECTOR 0: STEAM ELECTRIC GENERATING FACILITIES


SE Limited to Steam Electric Generating: Facilities

The requirements of Section 0 apply to storm water discharges from steam electric power generating facilities, including duel fuel co-generation facilities, and to storm water discharges from coal handling areas located at these facilities.


• Heat capture co-generation facilities and ancillary facilities that are not contiguous to a facility that is covered by this sector (e.g. gas turbine stations, vehicle fleet centers) are not covered by this general permit.


Best Management Practices - Measures shall be implemented to limit fugitive dust emissions and offsite tracking of dust and residue from coal and ash handling areas. All residue hauling vehicles must have a proper cover over the load, adequate gate sealing, and good structural integrity to prevent spillage and to minimize fugitive emissions. Ifthe facility's storm water Pollution Prevention Team identifies wetting the surface of the load as an effective BMP for minimizing fugitive dust emissions, this practice may substitute for covering the load. The Best Management Practices section of the SWP3 shall define procedures to prevent or minimize contamination of storm water during delivery of fuel oil and other chemicals. Containment measures at the unloading areas (e.g. drip pans, perimeter containment) shall be used wherever appropriate and a facility employee familiar with spill prevention, containment, and clean-up shall be on site during deliveries. The Best Management Practices section of the SWP3 shall define measures to prevent or minimize contamination of storm water runoff from oil bearing equipment in switchyard areas.

Periodic Insoections - In addition to the standard periodic inspection requirements described in Part ill.A.5.(g) of this general permit, visual inspections must be conducted at least once per week to determine the structural integrity of above-ground storage tanks, pipelines, pumps and other related equipment.

• Page 79



4. Comprehensive Site Compliance Evaluation

In addition to the standard site compliance inspections described in Part III.A.6 of this general pennit, personnel must inspect coal handling areas, loading/unloading areas, switchyard, fueling areas, bulk storage areas, ash handling areas, disposal ponds and landfills, maintenance areas, liquid storage tanks, and material storage areas at a minimum frequency of once per month.

5. Numeric Effluent Limitations - Applicable to Sector 0 Facilities Discharging Coal Pile Runoff

(a) The following numeric effluent limitations, based on guidelines from the Steam Electric Generating Point Source Category (40 CFR Part 423.12 (b)(1) and (9)) shall apply to any stonn water runoff from coal pile storage areas. Samples of these discharges shall be obtained before the runoff combines with other stonn water runoff, analyzed, and shall not exceed the following numeric effluent limitations:

Limitations Monitoring Parameter Daily Max Frequency Total Suspended Solids 50 mgIL I Near pH between 6 and 9 S.u. INear

(b) Sample Type - Grab samples shall be taken prior to combining with other flows, for analyses..

• (c) Reporting Requirements - Results ofmonitoring for detennining compliance with numeric effluent

limitations must be recorded on a discharge monitoring report (DMR). The DMR must either be an original EPA No. 3320-1 fonn (Part VI of this general pennit), a duplicate of the fonn, or as otherwise provided by the executive director. Monitoring must be conducted prior to December 31 st for each annual monitoring period and the results must be recorded and reported as required by Part IILE.4.(c) of this pennit. In addition, copy of the DMR must either be retained at the facility or shall be made readily available for review by authorized TCEQ personnel upon request by March 31 51 following the annual monitoring period.

(d) Waivers from Numeric Effluent Limitations

Numeric effluent limitations for runoff from coal pile storage areas do not apply to discharges that overflow from structural control facilities that are designed to contain and treat runoff from a 10year, 24-hour stonn event. The pennittee shall maintain, as a part of the SWP3, the following infonnation in order to receive this waiver: engineering design records that demonstrate structural controls are adequate to intercept, contain, and treat the volume of runofffrom a 1O-year, 24-hour stonn event; and records of rainfall from either a rain gauge that is located onsite or a rain gauge maintained in the immediate area ofthe site. Rainfall records are only required to document events that equal or exceed a la-year, 24-hour event.


The following subsections must conduct benchmark monitoring according to the requirements in Part IV of this general pennit and conduct evaluations on the effectiveness of the facility SWP3 based on the following benchmark values:

• Page 80


• Multi Sector General Permit TPDES General Permit No, TXR050000

Activity Code Description of Industrial Benchmark Benchmark Value Activitv Parameter

SE Limited to Steam Electric Iron, total 1.3 mg/L Generating Facilities TSS 100 mg/L

Section P. Sector P of Industrial Activity - Land Transportation and Warehousing (Motor Freight Transportation Facilities, Passenger Transportation Facilities, Petroleum Bulk Oil Stations and Terminals, Rail Transportation Facilities, and United States Postal Service Transportation Facilities)



The requirements under this section apply to storm water discharges from activities identified and described as Sector P. Sector P industrial activities are described by the following SIC codes:

• SECTOR P: LAND TRANSPORTATION AND WAREHOUSING


4011,4013 Railroad Transportation

4111-4173 Local. and Highway Passenger Transportation

4212-4231 Motor Freight Transportation and Warehousing (Except 4221-4225)

4221-4225 Public Warehousing and Storage

4311 United States Postal Service

5171 Petroleum Bulk Stations and Terminals

Except for SIC codes 4221 through 4225, the requirements of this general permit apply only to storm water discharges froin areas of Sector P facilities where vehicle and equipment maintenance activities, vehicle and equipment rehabilitation, mechanical repairs, painting, fueling and lubrication, and cleaning activities are performed.

For facilities described by SIC codes 4221-4225 (Public Warehousing and Storage), permit coverage is required for all areas of the facility. Facilities described,by these SIC codes must submit an NO! or obtain a no exposure exclusion for the facility except as described below for facilities described by SIC code 4225 (General Warehousing and Storage).

If a facility described by SIC code 4225 has any areas for vehicle and equipment maintenance activities, vehicle and equipment rehabilitation, mechanical repairs, painting, fueling and lubrication, and cleaning, then the facility must submit an NOI or obtain a no exposure exclusion. Discharges ofstorm water from facilities described by SIC codes 4225 which do not have areas for vehicle and equipment maintenance activities, vehicle and equipment rehabilitation, mechanical repairs, painting, fueling and lubrication, and

.cleaning activities, are authorized under this general permit and are not required to submit an NOI for coverage nor implement a SWP3 according to the requirements of the general permit. These facilities must comply with the following permit requirements only, and are not subject to additional requirements that are listed in this permit:.

,e Page 81


. Multi Sector General Permit TPDES General Permit No. TXR050000

(a) The facility must maintain a condition which ensures that there is no exposure of industrial activities to storm water;

(b) The facility operator must comply with the requirements of Part lilE. of this permit, related to Standard Permit Conditions (except that references to submittal ofan NOI are not applicable); and

(c) The site must not contain any areas that are used for vehicle and equipment maintenance activities, vehicle and equipment rehabilitation, mechanical repairs, paintiilg, fueling and lubrication, and cleaning.

The facility operator must apply for coverage if any of the requirements listed above in Part V.P.l.(a) through (c) are not met. If the TCEQ determines that additional controls are required other than those listed above, or that there is a concern regarding the discharge of elevated levels of pollutants, then the TCEQ may require a facility described by SIC code 4225 to obtain coverage and meet all permit conditions through submittal of an NOI or an individual permit application.

This general permit does not cover facilities described by SIC code 5171 that store crude oil and that are under the regulatory authority of the Railroad Commission ofTexas. Authorization for these discharges must be obtained through application for a National Pollutant Discharge Elimination System (NPDES) permit with the U.S. EPA and authorization from the Railroad Commission of Texas.


• Spill Prevention and Response Measures - Vehicles and equipment that are scheduled for maintenance and that have potential fluid leaks shall be confined to a designated area. The Spill Prevention and Response Measures section of the SWP3 shall define specific measures to prevent spills (e.g. mandatory use of drip pans) and to confine spills (e.g. berms or dikes) within this area. This section of the SWP3 shall also define specific measures to prevent or minimize contamination of storm water from fueling areas.

Best Management Practices - This section of the SWP3 must identify specific measures to prevent or minimize contamination of storm water from vehicle and equipment cleaning and maintenance operations. The SWP3· must define specific procedures to ensure that vehicle wash water does not discharge to the storm water collection system or otherwise contact storm water runoff. Railroad transportation facilities that maintain stockpiles of sand to be used for traction purposes (locomotive sanding) shall define specific measures to reduce or prevent offsite transport of sand in storm water runoff.

Section Q. Sector Q oflndustrial Activity - Water Transportation Facilities



The requirements under this section apply to storm water discharges from activities identified and described as Sector Q. Sector Q industrial activities are described by the following SIC codes:

• Page 82


••


SECTORQ: WATER TRANSPORTATION


4412-4499 Water TransDortation

The requirements of this general permit apply only to storm water discharges from areas of Sector Q facilities that perform vehicle imd equipment maintenance or cleaning activities.


This permit does not authorize the discharge of process wastes associated with a dry dock activity.


Boat Rinse Water - In additi(:m to the non-storm water discharges allowed under Part II of this general permit, boat rinse water may be discharged from water transportation facilities such as marinas, where the boat rinse water does not contain chemicals, surfactants, or elevated temperatures. Discharge from pressure washing of boats is not authorized under this general permit.


• Site Map - The site map shall clearly show the locations of the following activities if the activities are exposed to precipitation or runoff: fueling; engine maintenance and repair; vessel maintenance and repair; pressure washing; painting; sanding; blasting; welding; metal fabrication; loading and unloading areas; locations used for the treatment, storage or disposal of wastes; liquid storage tanks; liquid storage areas (e.g.,paint, solvents, resins); and material storage areas (e.g., blasting media, aluminum, steel, and scrap iron).


Best Management Practices ~,This section of the SWP3 must define specific procedures to ensure that wash water, including high pressure wash water and solids that result from pressure washing vessel hulls, do not discharge to the storm water collection system or otherwise contact storm water runoff. This section must define specific procedures to prevent abrasives, paint chips, and paint overspray from contacting storm water runoff. Methods for collection, storage, and disposal ofspent abrasives and other solids waste, resulting from blasting and painting activities, shall be desCribed in this section of the SWP3.

Employee Training Program and Employee Education - The program shall include training on used oil management, spent solvent management, disposal of spent abrasives and vessel wastewater, fueling procedures, painting and blasting procedures, and lead-acid battery management.

"

Periodic Inspections - Inspection procedures must be developed according to the standard periodic inspection requirements described in Part III.A.5.(g) of this general permit and conducted at least once per month in the following areas:

(a) pressure wash areas;

(b) abrasive blasting, sanding and painting areas;

(c) material storage or handling areas;

Page 83

COA Exhibit TF-5 TPDES Multi Sector Gerneral. Permit SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 83 of 111


(d) engine maintenance or repair areas;

(e) drydock areas; and

(f) the general yard area.



SIC Code Description of Industrial Activitv Benchmark Parameter Benchmark Value

4412-4499 Water Transportation Aluminum, total Iron, total Lead, total Zinc, total TSS

1.2 mg/L 1.3 mg/L 0.010 mg/L 0.16 mg/L 100 ml!/L

Facilities sampling for the following pollutants as part of benchmark sampling are also subject to the numeric effluent limits and reporting requirements listed in Part III.D.1. ofthe permit: total lead and total ZInC.

Section R. Sector R of Industrial Activity - Ship and Boat Building or Repair Yards

The requirements in Part V of this general permit are sector specific and are in addition to the requirements in • Parts III and IV. Where co-located industrial activities occur (refer to Part II.A.2. of this general permit) the additional conditions and requirements in Part V of this general permit for each of these activities also apply.


The requirements ofthis section apply to storm water discharges from activities identified and described as Sector R. Sector R industrial activities are described by the following SIC codes:

. SECTOR R: SHIP AND BOAT BUILDING OR REPAIRING YARDS


3731 3732 Shin and Boat Buildinl! or Renairinl! Yards


This permit does not authorize the discharge of process wastes associated with a dry dock activity.


Site Map - The site map shall clearly show the locations ofthe following activities where such activities are exposed to precipitation or runoff: fueling; engine maintenance and repair; vessel maintenance and repair; pressure washing; painting; sanding; blasting; welding; metal fabrication; loading and unloading areas; locations used for the treatment, storage or disposal of wastes; liquid storage tanks; liquid storage areas (e.g.,paint, solvents, resins); and material storage areas (e.g., blasting media, aluminum, steel, scrap ~~. .

• Page 84 eOA Exhibit TF-5 TPDES Multi Sector Gerneral Permit SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 84 of 111



Best Management Practices - This section of the SWP3 must define specific procedures to ensure that wash water, including high pressure wash water and solids that result from pressure washing vessel hulls, does not discharge to the storm water collection system or otherwise contact storm water runoff. The SWP3 shall define specific procedures to prevent abrasives, paint chips, and paint overspray from contacting storm water runoff. Methods for collection, storage, and disposal ofspent abrasives and other solids waste, resulting from blasting and painting activities, shall be established as BMPs.

Emoloyee Training Program and Employee Education - The program shall include training on used oil management, spent solvent management, disposal ofspent abrasives and vessel wastewater, management ofmetal filings and dust from welding and grinding operations, fueling procedures, painting and blasting procedures, and lead-acid battery management.

Periodic Inspections - InspeCtion procedures must be developed according to the standard periodic inspection requirements described in Part II1.A.5.(g) of this general permit and conducted at least once per month in the following areas:

Section S. Sector S oflndustrial Activity - Vehichi Maintenance Areas, Equipment Cleaning Areas, or Deicing Areas located at Air Transportation Facilities

The requirements in Part V of this general permit are sector specific and are in addition to the requirements in Parts III and IV. Where co-located industrial aCtivities occur (refer to PartU.A.2. of this general permit) the additional conditions and requirements in Part V of this general permit for each of these activities also apply.


The requirements of this general permit apply to storm water discharges from acti vities identified and described as Sector S. Sector S industrial aqtivities are described by the following SIC codes:

SECTOR S: AIR TRANSPORTAnON


4512-4581 Air Transoortation Facilities

The requirements of this general permit apply only to storm water discharges from those portions of facilities described by SIC codes 4512-4581 that are involved in vehicle maintenance (including vehicle rehabilitation, mechanical repairs, painting, fueling and lubrication), equipment cleaning operations, or deicing operations.

• Page 85




This general permit does not authorize the dry weather discharge ofdeicing chemicals. Ifthese discharges occur, they must be authorized under a separate TPDES or NPDES permit.


Site Map - The site map shall clearly show the location of each tenant at the site that conducts industrial activity subject to coverage under this section ofthis general permit. The map shall clearly delineate areas where aircraft deicing and anti-icing activities occur.

4. Pollution Prevention Measures and Controls/Management of Runoff with Structural Controls

The following requirements shall be included in the SWP3 according to requirements ofPart Ill.AA. and Part III.A.5. of this general permit:

Good Housekeeping Measures - This section of the SWP3 must describe specific measures to prevent or minimize contamination ofstorm water from areas used for the maintenance or cleaning of equipment, aircraft, and other vehicles, and for areas where aircraft deicing and anti-icing activities occur. Cleaning shall occur in defined, designated areas only. The SWP3 must describe specific measures to prevent or minimize contamination of storm water, and discharges to the storm sewer system from fuel servicing activities and from other operations conducted in support of the airport fuel system.

• Spill Prevention and Response Measures - The Spill Prevention and Response Measures section of the SWP3 must include specific measures to be taken in the event of fuel spills and accidental discharges of fuel to the storm sewer system. Measures shall be developed that will minimize and contain the spill, and that outline spill clean-up procedures.

Best Management Practices - Operators that conduct deicing or anti-icing operations shall evaluate operating procedures on an annual basis to consider alternative practices that may reduce the overall amount of chemical used, or otherwise .Jessen the environmental impact of the pollutant. This annual review must include a consideration of alternative chemicals for this use. The Best Management Practices section of the SWP3 shall include a narrative discussion of the annual alternative practices review that includes the rationale for changes in practices or the lack ofchanges in practices. BMPs shall be developed and implemented to ensure against over application of chemicals used as a part of deicing and anti-icing operations

Periodic Inspections - Inspection procedures must be developed according to the standard periodic inspection requirements described in Part Ill.A.5.(g) of this general permit conducted at least once per week during deicing or anti-icing activities in the areas where these operations take place.

Records - Facilities that conduct deicing/anti-icing operations shall maintain a record of the types of chemicals used for these activities and maintain monthly records of the amounts ofchemicals used. The material safety data sheet (MSDS) for each chemical shall be included as a part of the record. Tenants that conduct deicing/anti-icing operations shall provide this information to the airport authority for inclusion in the SWP3. Records of weekly inspections, when they occur, shall be maintained.

Structural Controls - Operators that conduct deicing or anti-icing activities shall consider controls to capture and contain chemicals used in this activity. Containing activities to specific areas where runoff may be captured and either treated, hauled away for disposal, or disposed of to the sanitary sewer, shall be considered. A narrative description of these considerations, including a rationale for why certain alternatives were either chosen or rejected, shall be incorporated as an element of the SWP3 .

• Page 86




Benchmark monitoring is only required for permittees conducting deicing activities which have used more than 100 tons of urea, or more than 100,000 gallons of ethylene glycol, in any calender year in the three years prior to submittal of an NOI for coverage under this permit. These volumes of deicing materials refer to the combined activities and usage at the airport as a whole, and not independently to each carrier or operator. Benchmark monitoring is only required to be performed at those outfalls from the airport facility which col1ect runoff from areas where deicing and/or anti-icing activities occur. The following subsector must conduct benchmark monitoring according to the requirements in Part IV ofthis general permit and conduct evaluations on the effectiveness ofthe facility SWP3 based on the following benchmark values:


Benchmark Parameter

Benchmark Value

4512-4581 Airports with Deicing Activities BOD COD Ammonia-Nitrogen pH

30 mg/L 55 mgIL 8.11 mg/L 6.0 to 9 S.u.

Section T. Sector T oflndustrial Activity - Treatment Works

• The requirements in Part V of this general permit are sector specific and are in addition to the requirements in Parts III and IV. Where co-located industrial activities occur (refer to Part n.A.2. of this general permit) the additional conditions and requirements in Part V of this general permit for each of these activities also apply.


The requirements of this general permit apply to storm water discharges from activities identified and described as Sector T. There are no additional requirements under this section that apply to storm water discharges from activities identified and'described as Sector T. SectorT industrial activities are described by the following Industrial Activity Code:

SECTOR T: TREATMENT WORKS


TW Treatment Works (Wastewater Treatment Plants)

The requirements of this general permit apply to storm water discharges from areas ofSector T facilities with: treatment plants or systems that treat, store, recycle, or reclaim domestic sewage, wastewater or sewage sludge (including dedicated lands for sewage sludge disposal located within the onsite property boundaries), with a design flow of 1.0 million gallons per day or more; or that are required to have an approved pretreatment program (under 40 CFR Part 403).


Coverage is limited to those wastewater treatment facilities having a design flow of 1.0 MGD or greater and to facilities with an approved pretreatment program.

• Page 87

eOA Exhibit TF-5 TPDES Multi Sector Gemeral Permit SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-Q612-MSW Page 87 of 111


Facilities which route all storm water runoffto the plant head works in accordance with an authorization issued through an individual TPDES permit are not required to obtain additional coverage through this general permit.


The following subsections must conduct benchmark monitoring according to the requirements in Part IV of this general permit and conduct evaluations on the effectiveness of the f~cility SWP3 based on the following benchmark values:

Activity Code Description of Industrial Benchmark Benchmark Value Activitv Parameter

TW Wastewater Treatment Plants BODs 30 mgIL

Section U. Sector U ofIndustrial Activity - Food and Kindred Products Facilities

The requirements in Part V of this general permit are sector specific and are in addition to the requirements in Parts III and IV. Where co-located industrial activities occur (refer to Part II.A.2. of this general permit) the additional conditions and requirements in Part V of this general permit for each ofthese activities also apply.


• The requirements under this section apply to storm water discharges from activities identified and described as Sector U. Sector U industrial activities are described by the following SIC codes:

SECTOR U: FOOD AND KINDRED PRODUCTS FACILITIES


2011-2015 Meat Products

2021-2026 Dairy Products

2032-2038 Canned, Frozen and Preserved Fruits, Vegetables and Food Specialties

2041-2048 Grain Mill Products

2051-2053 Bakery Products

2061-2068 Sugar and Confectionery Products

2074-2079 Fats and Oils

2082~2087 Beverages

2091-2099 Miscellaneous Food Preparations and Kindred Products

2111-2141 Tobacco Products


Inventory of Exposed Materials - The inventory shall include a list of the pesticides, herbicides, and fungicides applied or stored on the facility property.

• Page 88

GOA Exhibit TF-5 TPDES Multi Sector Gemeral Permit SOAH Docket No. 582-08-2186 TGEQ Docket No. 2006-0612-MSW Page 88 of 111


Narrative Description - A narrative description of all activities and potential sources of pollutants that may reasonably be expected to add significant amounts ofpollutants to storm water discharges from pest control and chemical storage procedures must be included.

Site Map - The site map shall clearly show the location of vent stacks for cooking, drying, and similar operations, dry product vacuum transfer lines; animal holding pens; spoiled product and broken product container storage areas; and any other processing or storage areas exposed to storm water.


Best Management Practices - This section of the SWP3 shall include BMPs to ensure that cleaning methods for vent hoods; storage and baking racks, bins and refuse containers, and other similar cleaning activities do not contribute pollutants to storm water runoff.

Employee Training Program and Employee Education - The program shall include training in pest control application procedures and chemical storage procedures.


The following subsections must conduct benchmark monitoring according to the requirements in Part IV of this general permit and conduct evaluations on the effectiveness of the facility SWP3 based on the folIowing benchmark values:

• SIC Code Description of Industrial Benchmark Benchmark Value

Activity Parameter

2041-2048 Grain Mill Products TSS 100 mg/L

2074-2079 Fats and Oils BOD COD Nitrate + Nitrite N TSS

30 mg/L 55 mg/L 0.68 mg/L 100 mg/L

Section V. Sector V of Industrial Activity - Textile Mills, Apparel, and Other Fabric Product Manufacturing Facilities

The requirements in Part V of this general permit are sector specific and are in addition to the requirements in Parts II and IV. Where co-located industrial activities occur (refer to Part II.A.2. of this general permit) the additional conditions and requirements in Part V of this general permit for each of these activities also apply.


The requirements under this section apply to storm water discharges from activities identified and described as Sector V. Sector V industrial activities are described by the folIowing SIC codes:

• Page 89 eOA Exhibit TF-5 TPDES Multi Sector Gerneral Permit SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 89 of 111


SECTOR V: TEXTILE MILLS, APPAREL, AND OTHER FABRIC PRODUCT MANUFACTURING FACILITIES


2211-2299 Textile Mill Products

2311-2399 Apparel and Other Finished Products Made From Fabrics and Similar Materials

3131-3199 Leather and Leather Products exceot Leather Tanning: and Finishing


Narrative Description - A narrative description of all activities and potential sources of pollutants that may reasonably be expected to add significant amounts of pollutants to storm water discharges from industry specific activities, including the following, shall be included: backwinding; beaming; bleaching; backing; bonding carbonizing; carding; cut and sew operations; desizing; drawing; dyeing; flocking; fulling; knitting; mercerizing; opening; packing; plying; scouring; slashing; spinning; synthetic-felt processing; textile waste processing; tufting; turning; weaving; web forming; winging; yam spinning; and yam texturing.


• Spill Prevention and Response Measures - This section of the SWP3 shall include measures to inspect, evaluate, and replace connections, valves, transfer lines and pipes that carry chemicals, dyes, or waste. All chemicals shall be stored in a protected area, away from drains, and clearly labeled. The SWP3 shall include specific measures to prevent or minimize contamination ofstorm water runofffrom above ground storage tank areas.

Periodic Inspections - Inspection procedures must be developed according to the standard periodic inspection requirements described in Part III.A.5.(g) ofthis general permit, but must be conducted at least once per month in material storage areas, material transfer areas, and transmission areas.

Employee Training Program and Employee Education - Employee training shall include training in the management and disposal of any solvents, other petroleum products, dyes, and other chemicals used at the facility.

Section W. Sector W oflndustrial Activity - Wood and Metal Furniture and Fixture Manufacturing Facilities


Description of Industrial Activity

The requirements under this section apply to storm water discharges from activities identified and described as Sector W. There are no additional requirements under this section that apply to storm water discharges from activities identified and described as Sector W. Sector W industrial activities are described by the following SIC codes:

• Page 90



SECTOR W: FURNITURE AND FIXTURES


2434 Wood Kitchen Cabinets

2511-2599 Furniture and Fixtures

Section X. Sector X of Industrial Activity - Printing and Publishing Facilities



The requirements under this section apply to storm water discharges from activities identified and described as Sector X. Sector X industrial activities are described by the following SIC codes:

SECTOR X: PRINTING AND PUBLISHING


2711-2796 PrintinQ. PublishinQ. and Allied Industries


• Narrative Description - A narrative description of all activities and potential sources of pollutants that may reasonably be expected to add significant amounts of pollutants to storm water discharges from industry specific activities, including blanket wash and solvent mixing operations.


Spill Prevention and Response Measures - The Spill Prevention and Response Measures section of the SWP3 shall include measures to inspect, evaluate, and replace connections, valves, transfer lines and pipes that carry chemicals or wastes. All chemicals (e.g. fuels, solvents, dyes, inks) shall be stored in a protected area, away from drains, and clearly labeled. This section of the SWP3 shall include specific measures to prevent or minimize contamination of storm water runoff from above ground storage tank areas and fueling areas.

Employee Training Program and Employee Education - The program shall include training in the management and disposal of any solvents, other petroleum products, dyes, and other chemicals used at the facility.

Section Y. Sector Y of Industrial Activity - Rubber and Miscellaneous Plastic Products, and Miscellaneous Manufacturing Facilities





The requirements under this section apply to storm water discharges from activities identified and described as Sector Y. Sector Y industrial activities are described by the following SIC codes:

SECTORY: RUBBER, MISCELLANEOUS PLASTIC PRODUCTS, AND MISCELLANEOUS MANUFACTURING FACILITIES


3011 Tires and Inner Tubes




3081-3089 Miscellaneous Plastics Products

3931 Musical Instruments

3942-3949 Dolls, Toys, Games and Sporting and Athletic Goods

3951-3955 (except 3952 facilities as

specified in Sector C)

Pens, Pencils, and Other Artists' Materials

3961,3965 Costume Jewelry, Costume Novelties, Buttons, and Miscellaneous Notions, Except Precious Metal

3991-3999 Miscellaneous Manufacturing: Industries • 2. Descriptionof Potential Pollutants and Sources

Narrative Description - The description shall include a review of the use of any zinc at the facility and possible pathways where zinc could contaminate storm water runoff.


Good Housekeeping Measures - This section of the SWP3 shall include specific measures to minimize potential exposure ofzinc to storm water and to minimize or prevent the discharge ofplastic resin pellets in storm water.

Best Management Practices - This section of the SWP3 shall include BMPs to minimize or prevent the discharge ofplastic resin pellets in storm water runoff. All rubber manufacturing facilities must include specific BMPs and controls to minimize the contamination ofstorm water from the handling and storage ofzinc. Potential sources of zinc must be identified and the accompanying BMPs must be evaluated and incorporated into the SWP3, as appropriate.

(a) zinc bags must be stored indoors;

(b) consider the use of 2,500 lb bags of zinc, rather than 50 or 10 lb bags;

(c) consider the use of chemicals purchased in pre-weighed, sealed polyethylene bags;



(d) consider the use of automatic dispensing and weighing equipment;

(e) ensure headspace in containers to minimize "puffing" losses when the containers are opened;

(t) consider storing waste disposal dumpsters indoors, providing a cover and liner for the dumpster; and

(g) consider alternatives to zinc.

Spill Prevention and Response Measures - This section of the SWP3 shall address dust generation from rubber grinding operations and install dust collection systems where necessary to prevent the potential contamination of storm water. Specific measures shall be identified for cleanup of zinc spills so that the cleanup may be completed without washing the spill into the storm drain.



• SIC Code Description of Industrial

Activity Benchmark Parameter Benchmark Value

3011 Tires and Inner Tubes Zinc, total 0.16 mgJL


Zinc, total 0.16 mg/L


Zinc, total 0.16 mgIL


Zinc, total 0.16 mg/L

Facilities sampling for the following pollutant as part of benchmark sampling are also subject to the numeric effluent limits and reporting requirements listed in Part m.D.I. of the permit: total zinc.

Section Z. Sector Z of Industrial Activity - Leather Tanning and Finishing Facilities

The requirements in Part V of this general permit are sector specific and are in addition to the requirements in Parts m and IV. Where co-located industrial activities occur (refer to PartII.A.2. of this general permit) the additional conditions and requirements in Part V of this general permit for each of these activities also apply.


The requirements under this section apply to storm water discharges from activities identified and described as Sector Z. SectorZ industrial activities are described by the following SIC codes:

• Page 93



SECTOR Z: LEATHER TANNING AND FINISHING


3111 Leather Tannin!!: and Finishin!!:


Site Map - The site map shall clearly show the location of the following activities, if these activities are exposed to storm water: beamhouse, tanyard, retan-wet and dry finishing operations; haul roads; access roads; and rail spurs.


Good HousekeeoingMeasures - Storage areas and storage containers must be labeled.

Best Management Practices - This section ofthe SWP3 must contain a narrative consideration ofmethods to isolate the following facility areas and materials from contacting storm water runoff:

(a) raw, semi-processed, and finished tannery by-products;

(b) leather dust from buffing or shaving operations;

(c) receiving, unloading, and storage ~reas;

• (d) equipment that is contaminated with tannery process materials and from waste management operations (e.g. waste storage areas, dumpsters, waste piles).

Section AA. Sector AA oflndustrial Activity - Fabricated Metal Products Facilities



The requirements under this section apply to storm water discharges from activities identified and described as Sector AA. Sector AA industrial activities are described by the following SIC codes:

SECTOR AA: FABRICATED METAL PRODUCTS FACILITIES


3411-3499 Fabricated Metal Products, Except Machinery and Transportation Equipment

3911-3915 Jewelrv. Silverware and Plated Ware


Best Management Practices - This section of the SWP3 must define practices to prevent or minimize exposure of storm water to metal fines and iron dust, solvents and paints, and also from sand where sandblasting operations are conducted.

• Page 94



Spill Prevention and Response Measures - This section of the SWP3 shall include specific spill prevention and response guidelines to address chromium, toluene, pickle liquor, sulfuric acid, zinc, and other water prioritylhazardous chemicals that are used at the facility. The installation of perimeter controls to contain spills (e.g. berms, dikes) shall be considered for areas where lubricating and hydraulic fluids, chemicals, paints and other similar liquids are stored.




Benchmark Parameter

Benchmark Value

3411-3471 3482-3499 3911-3915

Fabricated Metal Products Except Coating

Iron, total Aluminum, total Zinc, total Nitrate + Nitrite N TSS

1.3 mg/L 1.2 mg/L 0.16 mglL 0.68 mglL 100 mg/L

3479 Fabricated Metal Coating and Engraving

Zinc, total Nitrate + Nitrite N

0.16 mglL 0.68 mglL

• Facilities sampling for the following pollutants as part of benchmark sampling are also subject to the numeric effluent limits and reporting requirements listed in Part III.D.l. of the permit: total zinc.

Section AB. Sector AB of Industrial Activity - Transportation Equipment and Industrial or Commercial Machinery Manufacturing Facilities

The requirements in Part V of this general pertnit are sector specific and are in addition to the requirements in Parts III and IV. Where co-located industrial activities occur (refer to Part II.A.2. of this general permit) the additional conditions and requirements in Part V of this general permit for each of these activities also apply.

1. Description ofIndustrial Activity

The requirements under this section apply to storm water discharges from activities identified and described as Sector AB. Sector AB industrial activities are described by the following SIC codes:

SECTOR AB: TRANSPORTATION EQUIPMENT, INDUSTRIAL OR COMMERCIAL MACHINERY MANUFACTURING FACILITIES


3511-3599 (except 3571-3579)

Industrial and Commercial Machinery (except Computer and Office Equipment - see Sector AC)

3711-3799 (except 3731,3732)

Transportation Equipment (except Ship and Boat Building and Repairing - see Sector R)

• Page 95




Site Map - The site map shall clearly show the location of vents and stacks from metal processing and similar areas.

Section AC. Sector AC of Industrial Activity - Electronic and Electrical Equipment/Components, and Photographic/Optical Goods Manufacturing Facilities

The requirements in Part V of this general permit are sector specific and are in addition to the requirements in Parts III and IV. Where co-located industrial activities occur (refer to Part ILA.2. of this general permit) the additional conditions and requirements in Part V of this general permit for each of these activities also apply.

Description of Industrial Activity

There are no additional requirements under this section that apply to storm water discharges from activities identified and described as Sector AC. Sector AC industrial activities are described by the following SIC codes:

SECTOR AC: ELECTRONIC ELECTRICAL, PHOTOGRAPHIC AND OPTICAL GOODS


3612-3699 Electronic, Electrical Equipment and Components, except Computer Equipment

3812-3873 Measuring, Analyzing and Controlling Instrument; Photographic and Optical Goods

3571-3579 Computer and Office Eauioment

• Section AD. Sector AD of Industrial Activity - Miscellaneous Industrial Activities


Sector AD is used to provide permit coverage for facilities that are designated by the executive director as needing a permit to control pollution related to storm water discharges and that do not meet the description of an industrial activity covered by Sectors A-AC. Where co-located industrial activities occur (refer to Part II.A.2. of this general permit) the additional conditions and requirements in Part V of this general permit for each of these activities also apply.


(a) Facilities may not request general permit coverage under Sector AD. Coverage under this sector is reserved for those facilities that are designated by the executive director as eligible for coverage under this sector of this general permit.

(b) Facilities that are determined by the executive director to need controls in addition to the requirements in Part II and Part III of this general permit will be required to obtain an individual TPDES permit.

• Page 96



Part VI. Discharge Monitoring Report (DMR) Forms

Many facilities authorized under this general permit must sample and analyze discharges of storm water for specific pollutants to determine compliance with numeric effluent [imitations. For results that must be submitted to the TCEQ, permittees may use the DMR forms provided in this section of the general permit, a duplicate of the form, or as otherwise provided by the executive director.

Section A. Instructions for Completing a DMR

1. Permittee Name/Address Section - Enter the permittee name and facility name if it is different than the permittee name, in the space [abeled "Name." Enter the address of the facility in the space labeled "Address." Enter a description of the physical location of the facility (e.g., on Smith Road, approximately 1/4 mile east of the intersection of Smith Road and Lost Pines Avenue).

2. Permit Number - Enter the permit number. The number must start with the TXR05 prefix and be followed by 4 values that were assigned by TCEQ to specifically identify the authorization under the general permit (e.g., TXR05KOOl). This number must also be entered in the upper right hand comer of eachDMR.

3. Discharge Number - The field for discharge number is not applicable and is pre-coded with a "N/A" designation.

• 4. Monitoring Period - The monitoring period is pre-coded as January 1 through December 31. However,

the two digit number for the specific year that the monitoring period covers (e.g., 01 for calendar year 2001) must be entered.

5. Parameter - The parameters to be sampled and analyzed are pre-coded on the form.

6. Qua[ity or Concentration - Maximum Column - The permitted value is pre-coded in the shaded area of this column. In the unshaded spaces in this column, enter the highest measured value for each parameter. If a permittee sampled more frequently than once per year, then the permittee should enter the highest value from all of the sample results. Results must be entered in the units [isted on the form.

7. No. Ex Column - Indicate the number of measurements that did not comply with the daily maximum permit limit for each of the listed parameters in the unshaded space.

8. Frequency of Ana[ysis Column - Enter the actual frequency of analysis that you performed for each of the listed parameters in the unshaded space. If the permittee sampled once per year as required by the permit, then enter "INear." If the permittee sampled more frequently, enter that information.

9. Sample Type Column - Enter the actual sample type that was used to collect samples for each parameter (e.g., grab or composite).

10. Comments and Explanations ofAny Violations Section: The permittee must include an explanation for any results that do not meet the permit requirements, and should identify the cause of the noncompliance and corrective measures. This section may also be used to provide any other pertinent information related to reported data. If additional space is necessary, a written report may be attached.

• Page 97



11. Namerritle Principal Executive Officer, Telephone, and Date: Each form must be signed and dated by a Principal Executive Officer. A principal executive officer is a high ranking official that has overall management responsibility for the facility (e.g., Company President, General Partner, Environmental Manager, etc.). The telephone number for the signing individual must be included on the form. The date is the date when the DMR is signed by the principal executive officer.

Section B. Discharge Monitoring Report (DMR) Forms

•

• Page 98

GOA Exhibit TF-5 TPDES Multi Sector GemeralPermit SOAH Docket No. 582-08-2186 TGEQ Docket No. 200S-Q612-MSW Page 98 of 111

• • • HAZARDOUS METALS - INLAND WATERS STW / TXROS / CO PERM nEE NAME ADDRESS

NAME

ndu e Fecitily Nome ocetion IIDillerent NAT ONA PO TANT 0 SCHARGE E M NAT ON S STEM NPDES D SCHARGE MON TOR NG REPORT DMR

NOTE: Enter your permit number in the underlined space in the upper right hand corner of this page.

ADDRESS I 2-16 I I Example: STWI TXROSJI021 CO

lonlY f re uiremail to TCEQ MC 212 PERM TN M M ER P.O. ox 13087

FAC T I Austin T 78711-3087

OCATON ~R M 31 o

20-21 30-31 PARAMETER 3 Car Only Q ANT T OR OAD NG 4 Car Only Q A FREQ ENe

32-37 46-53

A ERAGE

54-61

MA M M

38-45

M N M M

NO.

~2-OF

ANA S5

SAMP E T PE 69-70

Arsenic SAMP E 53 54.08

MEAS REMENT

:~~~~k~~t:;I}:.:~tt:;D·'? ":1' .', I:;b~i~.~~\ ·1:1i·e~r}F,~~b< arium SAMP E

MEAS REMENT

:':~~~A~~MI~~fl'::"'" .~•..,. ...•. :l,· I····· r: ,A.O •... . Daily'Max,

mgl I' '··'1' 1"ear I. G~b Ca mium SAMP E

MEAS REMENT

.~E~~M~~/'· ..

0.2 . Daily Max "

mgl 1 ear .Grab

Chromium SAMP E MEAS REMENT

.REJA~~M1;h:.:I· I ,';5.0 Daily Max mgl 1,1·1.,earL Grab('

Co er SAMP E MEAS REMENT

;.~~~~~~~~~.;I~'}·~"r.,< .D,ii!s··f1~:: '~"'" .,. ""'1' ;_ <I~b~i~~a;;al mg I I: ·.1:;1. ear ;1\Grab.,•.~: ' .':":..< ". ":,". '';'.: ,'._".~

I NAME T T E PR NC PA E EC T E OFF CER I <£RTF IQIlPENA T Of AWlW\TTHSOOC ""NT"""A mACl80ENTS TE EPHONE DATE WERE PREPARED NDER iii D REel CN OR & PER 5 CN NACCCIRDANCE W TH

I~&::~~~T~~~:':Q :~~~ ..PR':'R c;.n:; =~'i:~a::=~E~c:..:~ ~n:~-=D':~I-"'S"G=N;-;A"'T;'-:R:;'E;::-;O"'F;:-::P:::R=N"'C"P=A--1 ~i: ES:"OFAW~r:T~~Ea:F~~"'i~ = E EC T E N M ER EAR I MO I DAAREA I'~"=:"AF: ~ru:.'~ A'f~NQ THE PaSS 'CE FHE AND OFF CER OR A THOR ED

CODET PEO OR PR NTED AGENTI I

COMMENTS AND E P ANAT ON OF AN o AT ONS Reference all attachments here

EPA Form 3320-1 3-99 REP ACES EPA FORM T-40 WH CH MA NOT E SED PAGE OF

Page 99 COA Exhibit TF-5 TPoes Mulli Sector Gerneral Pennit SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 99 of 111

• HAZARDOUS METALS - INLAND WATERS • STW I TXROS I CO • PERM nEE NAME ADDRESS ndu a Facility Na... _cation I' l);llerent NAT ONA PO TANT 0 SCHARGE E M NAT ON 5 STEM NPDES NOTE: Enter your permit number in the underlined

D SCHARGE MON TOR NG REPORT DMR space in the upper right hand corner of this page. NAME 2-16 17-19 EIample: STWI TXROSJI02lCO

ADDRESS

FAC T I 1 I NA 10nlY f re uire

~~P~E:!!R~M~T~N~M~E:!R~~_~~D~S~C~H~A~R~G~E=N==M~E~R~= IMON TOR NG PER 00

mail to TCEQ (MC 212)

P.O. Box 13087Auslln T 78711-3087

OCATON EAR DA EAR DA 01

2""0-""2""1-1-"";"=-+-:2"';:4-;';'2~5-l 31

30-31 o

FREQ ENCPARAMETER 3 Car Only 0 ANT T OR OAD NG 4 Car Only a A NO. SAMP E32-37 46-53 5~1 38-45 E OF T PE 62A ERAGE MA M M M N M M N TS ANA SS 611-70

ea SAMP E MEAS REMENT

'~~~~~M~~~~lt': .. ,' .';; ,,; , \-1,, '. I .," . :1'6~i1t~~} Jl'ea~Jp~b' Manganese SAMP E

MEAS REMENT

RE~~$~EE.~f; I: .I . .".

'1' ....:. 3.0 .,'. .. 'DaiIYMSx mgl IL:.,.•'·

,,~>,L.1 ,.ear Grab, •

Mercury SAMP E MEAS REMENT

.- 0.01 mgl I': Grab.e,ar:RE~~~~EE~t I~ .. ,." DaiIY·Max.

Nickel SAMP E MEAS REMENT

Grtlb ::1\: ear ".mgl .".... REJ~~~E~~I ;"ri' 'D~i~~ll~ Selenium SAMP E

MEAS REMENT

·~~~~~MEE~~!~I·' ..... NAME T T E PR NC PA E EC T

OFF CER E

, 0.2' •... DiiiIYMax.•

mgl

TE EPHONE

I.,'.?JI;,l.~~i:~ I;c'?rtIb ;'

DATE

AREA I CODE

N M ER EARl MO IDA

COMMENTS AND E P ANAT ON OF AN o AT ONS Reference all allachments here

EPA Form 3320-1 3-99 REP ACES EPA FORM T-40 WH CH MA NOT E SED PAGE OF Form A ro e OM No. 204Q..004

Page 100 COA Exhibit TF-5 TPDES Mulli Sector Gerneral Permit SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 100 of 111

• • •

••••••• ••••••• •••••••

•••••••

••••••• •••••••

••••••• ••••••• •••••••

•••••••

••••••• •••••••

•••••••

HAZARDOUS METALS - INLAND WATERS STW I TXR05 I CO PERM TTEE NAME ADDRESS nclu. FaclJity Nama ocatlon K Ditlarant NAT ONA PO TANT 0 ~~~~GE E M NAT ON S STEM NOTE: Enter your permit number in tbe NAME D SCHARGE MON TOR NG REPORT DMR underlined space in tbe upper right band corner

ADDRESS 2-16

I PERM T N M ER

17-19

I ID SCHAR~: N M

oftbis page. Eumple: STWI TXROSJI02/CO

ERlonlY fre uiremail to TCEQ MC 212

FAC T MON TOR NG PER OD P.O. ox 13087 OCATON EAR I MO I DA I I EAR I MO I DA Austin T 78711-3087

I 01 I 01 I I I 12 I 31 0 20-21 22-23 24-25 26-27 28-29 30-31

FREQ ENe 32-37

PARAMETER 3 Car Only a ANT T OR OAD NG 4 Car Only Q A NO. SAMP E E

46-53 54-61 38-45 OF T PE

A ERAGE MA M M MN M M N TS 62 ANA SS 69-70

Silver 63 64-08SAMPLE MEASUREMENT

.,...•.~'; ;~/Q},.:, ;:>..~f.I;,£:':! '.~ ..••... mgIJDaily,Max ':

Zinc !tEQ~E ",:',t:.i' ;,:,.."-,':: .

SAMPLE

MEASUREMENT

'6.0 Grab~~~~~ ,::' ,'.·tj0··: _.. >1 c.,~.~~ ••• ,; . :Daily Mait: I mgIJ

p··~':(I:~:·I0'ear·.·:I::0!l'

I··' :I:r/Y~ ." '.,.\,<,.r;:~; .. 'i'~'··~··~

NAMEffITLE PRINCIPAL EXECUTIVE TELEPHONE DATE OFFICER I'CERTIFY UNDBPENALTYOf lAW THATnnS [X)Cl.IWDfT ANDAU.ATTACIlMENTSI1--------....;;.;........;;....;.--------1~~~:~~~~==~~~~~~:~~~~~

I EVALUATE THE INJ'OIMATION SUBNnTED. BASEDON MY INQUIIlY OF THE PEIlSON oa PEiISONS WHO MANAOE nasySJEM,OR lHOSEPEIlSON!I D1lECTLY IlESPONSIBl..E 0& GATHFlUNO TH£INFOIJotATION.THE[Nf()aMATlONSUBw.InWIS.TO THE B£ST1---:c=-:- =:-:-= -=---4

OFMYk.NQWLEOOIiAHDREI...lFJ'. TllIJIi.ACCUaAT£.ANDCOMPL£TE. IAMAWAR£ SIGNATURE OF PRINCIPAL ~~~~~::~~P~~f~S=~~~E:~~'ii EXECUTIVE

AREA NUMBER YEAR MO DAY _____===-=====,.- ~ VIOlATION>. OFFICER OR AlITHORIZED CODETYPED OR PRINTED AGENT

COMMENTS AND EXPLANAnON OF ANY VIOLATIONS (Reference all attachments here) ' EPA Fonn 3320-1 (3-99) (REPLACES EPA FORM T-40 WHICH MAY NOT BE USED) PAGE OF Fonn Approved OMB No. 2040-004

Page 101

COA Exhibit TF-5 TPDES Multi Sector Gemeral Pennit SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 101 of 111

• HAZARDOUS METALS - TIDAL WATERS • STW / TXROS / CO • PERM TTEE NAME ADDRESS ndu 0 FBCIlIty Nome ocoliQn If OIR....n. NAT ONA PO TANT D ~:~GE E M NAT ON 5 STEM NOTE: Enter your permit number in tbe NAME D SCHARGE MON TOR NG REPORT OMR underlined space in the upper right hand corner of

2-16 17-19 tbis page. Example: ~WI TXROSJ1021 CO ADDRESS IpERM T N M ER I ID SCHAR~: N M ERI Only f re uiremail to TCEQ MC 212

FAC T MON TOR NG PER 00 P.O, ox 13087 OCATON EARl MO J DA I I EAR I MO I DA Austin T 78711-3087

I 01 I 01 I I I 12 I 31 0 20-21 22-23 24-25 26-27 28-29 30-31

PARAMETER 3 Car Only Q ANT T OR OAO NG 4 Car Only Q A NO, E

32-37 46-53 54-61 38-45 A ERAGE MA M M MNM M NTS 62

FREQ ENe

OF ANA 55

SAMPE T PE 69-70

Arsenic I SAMP E MEAS REMENT

.R~6~~EE~;J;> ) ;;' " " :,/,I~. '," anum SAMP E

MEAS REMENT

~E6~:ME~~Tl, •

Ca mium SAMPE MEAS REMENT

·-~~6,r~M~JT:tX.,.<' ~:~~,:I" . Chromium SAMP E

MEAS REMENT

;~~~~~~~~f!,I;!L--). Co er SAMP E

MEAS REMENT

i~~~~~J~~~,ji'i_~:t~~~; ."t(rh. J,'.'

63 64-66

, :'~..

mgl /::"1'" 1.' ear rGrab':~~i~~~ ..J",' ' ~:' ;', :.:, . .' "~,,,

4;0:,; mgl :ear,j'Grab,Daily,Max',

0:3 Grabmgl eaL'Daily Max,

:5;~: ,', mglDailyM~ " ,. :';~:;~~->:,

"iL;,,:t'[;Ji~~~-jl mg I 1::,:""· ,1~~r";,If;.G~~;,, NAME T T E PR NC PA E EC T E TE EPHONE DATE

OFF CER ~_TF oaR"'" T 01' AWTHI\TTHlllOC IIEHT""A ArrACHolENTS -------~....;......;......;..;....-------~~~~...: ~~Tc:r::~~~~

AN) £ A AlE 1WE N'ONMTON B MTTED. ASfD ON.. NO R c.: llE PERSONORPERSClNSWHOMA*GE 1ME 8 lTUf OR THOSE PERSONS D RECT I ~Tl£ E:~:~~~~ONE~ ~~;~~:~I--;:S~G=N;-;Ac;T;-;R:;CE~O"'F;O-;::P:::R~N=C"P"A"--; ~~FA~A:~~ ~D=~G~~rE:~:= E EC T E

N M ER EARl MO IDA,.... SClNlEHT .... NOW'" 0 ATONS, OFF CER OR A THOR ED AREAlCODEI T PED OR PR NTED AGENT


EPA Fonn 3320-1 3-99 REP ACES EPA FORM T-40 WH CH MA NOT E SED PAGE OF Form A ro e OM No, 204G-004

Page 102 COA Exhibit TF-5 TPDES Multi Sector Gernersl Permit SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-D612-MSW Page 102 of 111

• • • HAZARDOUS METALS - TIDAL WATERS STW I TXR05 I CO

PERM nEE NAME ADDRESS nclu e Foclllty Name ocaIian~ NAT ONA PO TANT 0 SCHARGEE MNAT ON S STEM NPDES NOTE- Enter your permit number in the D SCHARGE MON TOR NG REPORT DMR •

NAME underlined space in the upper right hand

ADDRESS I 2-16

PERM T N M ER

1~-19

II D SCHARG: N

corner of this page. Example: fITWI TXROSJI021 CO

M ER 10nlY f re uiremail to TCEQ MC 212 -FAC T MON TOR NG PER OD P.O. ox 13087 OCATON EAR I MO I DA I I EAR I MO I DA Austin T 78711-3087

I 01 I 01 I I I 12 I 31 0 20-21 22-23 24-25 26-27 28-29 30

FREQ ENe

32-37 PARAMETER 3 Car Only Q ANT T OR OAD NG 4 Car Only Q A

NO. SAMP E E

46-53 54-61 36-45 T PE OF

A ERAGE MA M M MNM M NTS 62 ANA SS 69-70 53 fl4.ti5

SAMP E MEAS REMENT

ea

01 01:5.,.:. 1·:/: 1'<ear ""Grab-'~~~~~MEE~t k3:·~·(:; c;.,~. '..' ,,:zd >c ..,;; . ~." .• ' :0:: ,.,:•. ::,.,:; ..~:,-".:.,-.":,, -:~ '.Y .',: ID~ilyMax'

Manganese .~'

SAMP E MEAS REMENT

...·.,:3;0.:):r·· ''''., mg I 1;(·Jhr;.~ar:1Grab,R~~0t~M~NiI..·· . .DailYMliX

Mercury SAMP E MEAS REMENT

SAM~'E ,0.01 '.. '.' mgl If. earl Grab. ,..,;REO:REMEtolT Daily~ax'"

Nickel SAMP E MEAS REMENT

3.0.·... '·.SAMP, E':' "1:':' ..' I: '. mgl, '1' '~~rd' ~ralf. Daily Max REq/;~E~ENT, :",:", : II Selenium SAMP E

MEAS REMENT \. '-, .-', ,',,'.,",>,1. ear '.: 7Gf.,ib>·t,·, '1I":6~i~~ti'~J mg I 1-I . ·1····

I'·'~k~~~U=J~tJ~,';;r'{;!;Df/;,:{;;:jk .'.>, >.- - ~ .: :", • •...; -. ~ ',~:, , :, .;'::{", ~, ':.

"

NAME T T E PR NC PA E EC T E TE EPHONE

I DATE

OFF CER CERTF N:£APENA T OF AWTl-I.\TTHIDOC IlEHTANlA ATTACHMENllI.-------------------1'WERE PREPARED NJERM 0 RECTONORS PER 8 ON NACCORDANCE W TI-l A.S SlEMIESGNEDTOA.SS RETl-I.'TQ A FEDPER8CWNE ~OPER GATt£R N4fJ IE A An: 1l1E N"ORMAT ON S M TTEO. A&Ul ON M NO R Of n£ PERSON ORPERSON$WHOtMNAGE 1l1E 8 SlEM ORlHOSE PER80H$O MECT RESPCWS EFORGATHERNGTHE NfORlMTON 1l1E N"ORMATONS "TTEDt-"=",==;-;===-="=",=-=~--f • TO THE E'T 0If.. NOW EDGE "'" E EF TR E Ace ..... _ S GNAT RE OF PR NC PA ~~NGFA.'::~~ ~O:-:~~c;wrT~~:= E EC T E N M ER EAR I MO DAAREAl.... ·O•••El<TFORNOWNG OATONS OFFCERORA THOR ED

CODEI T PED OR PR NTED AGENT

o AT ONS Reference all attachments here

I

1 COMMENTS AND E P ANAT ON OF AN

I

EPA Fonn 3320-1 3-99 REP ACES EPA FORM T-40 WH CH MA NOT E SED PAGE OF Form A ro e OM No. 2040-004

Page 103 COA Exhibit TF-5 TPDES Multi Sector Gemeral Permit SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-Q612-MSW Page 103 of 111

• HAZARDOUS METALS - TIDAL WATERS • STW / TXROS / CO • PERM T1EE NAME ADDRESS ndu 0 Fodllty Nomo ocation II NAT ONA PO TANT 0 SCHARGE E

NPDES M NAT ON S STEM NOTE: Enter your permit number in the

NAME D SCHARGE MON TOR NG REPORT DMR underlined space in the upper right hand

ADDRESS 2-16

I PERM TN M ER II 17-19

D SCHAR~: N M ER

corner of this page. Example: STWI TXROSJI021 CO

10nlY f re uiremail to TCEQ MC 212 -FAC T MON TOR NG PER 00 P.O. ox 13087 OCATON EAR I MO I DA II EAR I MO I DA Austin T 78711·3087

I 01 I 01 II I 12 I 31 0 20-21 22-23 24-25 26-27 28-29 30

FREQ ENe

32-37 3 Car Only a ANT T OR OAD NG 4 Car Only a APARAMETER

SAMP E OF

46-53 54-61 38-45 NO. T PE

A ERAGE MA M M MNM M ~2- 6&-70ANA SS ~ tl4-8llSil er SAMP E

MEAS REMENT

mgl~f~~~~~~~l;2i-:;(:',;:;,). S·';~n~{i,:i" ','.:1 \"::~~i~~~'~; inc SAMP E

MEAS REMENT

.r.' :.. 'I' 6:0' mgl,,'SAM.'~:~<:::I""

1·;.\:I,:,1!(~~~:;11:$~~.···'

'1:~ar ,I;,?g~b:,I';} Daily;MaxREa \REMENT, '"

TE EPHONE DATENAME T T E PR NC PA E EC T E OFF CER IeatTF ~PENA T OF AWTHATT11SDOC IiENTANDA AnA~8II-----------'"-....;;---------;~~=~~~~~~T~r::ED%::;:~~

lAND E A An: T1-E NfORtMTOH 5 MTTED_ AS.EO ON" NO R OF TI1E PERSON ORPE.RSONS WHO~Q£ TtE 8 STEW OR THOSE PERSCWS 0 RECT

~~TtE E~~:~':c::~~ONE~~~~~:~I--=S;-G=N:-:A-=T:-:R=-E=-:O"'F=-=P"'R,...,.,N"'C;-P=-A-:---1 I~,;~FA~A..:=-~~D~~GN~~AN\~;:~ E EC T E

AREA N M ER EAR MO DA

I"""SCMENTFOIl NOW"" QAT""S OFFCERORA THOR EDI CODET PED OR PR NTED AGENT


EPA Form 3320-1 3-99 Farm A '" e OM No. 2040-004

REP ACES EPA FORM T-40 WH CH MA NOT E SED PAGE OF

Page 104 COA Exhibit TF-5 TPDES Multi Sector Gerneral Permit SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-Q612-MSW Page 104 of 111

• • •

•••••••

•••••••

•••••••

•••••••

•••••••

••••••••

•••••••

•••••••

•••••••

•••••••

•••••••

•••••••

••••••••

COAL PILE RUNOFF EXCEPT FOR SECTOR 0 STWI TXROS I CO

PERM nEE NAME ADDRESS nclu e FecilbyNamo ocetionWOifIerent NAT ONA PO TANT 0 SCHARGE E M NAT ON S STEM NOTE· Enter your permit number in the NPDES •

NAME D SCHARGE MON TOR NG REPORT DMR underlined space in the upper right hand :'2-16~ ~7-1 ~ corner of this page. Example: STWI TXROSJI021 CO

ADDRESS I PERM TNI MBER II PISCH];': IMBER IOnlY fre uiremail to TCEQ (MC 212) -

FACILITY MONITORING PERIOD P.O. Box 13087 LOCATION YEAR MO DAY YEAR Austin, TX 7871 1-3087

01 01 D (20-21) (22-23) (24-25)

FREQUENCYPARAMETER (3 Card Only) QUANTITY OR LOADING NO. OF SAMPLE(32-31) (46-53) (54-61) EX ANALYStS TYPE

UNITSAVERAGE MAXIMUM (62-63) (69-70)(64-68)

Total SAMPLE Suspended MEASUREMENT Solids

tor;.' ~;'••'••_.'::. ···'-'}c:;~o·: mgll "I!Y" '. '1' Grab';i:.· -', ..". . .. '" ":.~...~:~~ ..,' . I,' ." " ear ••.•.•.,".·····OailyMiiX.·~J;i~~Nt:;I·•.·.'.··:··~·"·~f··5:\~,:1·~,;~,~··;b·\~\ . ·'t,··'. ,".'

pH SAMPLE MEASUREMENT

. ~6.0 -.9:0...~... .jlYe'ai: ·.1 ..GrabS.U. RE6~~Jfk,:· j.~ ••••~.+~;; .. '...•~..;:,. . "Range'

SAMPLE MEASUREMENT

I:;~~~t~+:·I;r:.·,. I TELEPHONE DATENAMEITITLE PRINCIPAL EXECUTIVE

I

OFFICER IICEKTIFY UNDEll PENALTY Of LAW THAT THIS OOC\JMENT ANDI\L.LATTACHMENTS _WERE PIlEPAllED UNDEilMY DlRECTlON 01 SUPEIlVWOH 1)1 ACCORDANCE WITH A SYStaI: DESIGNEDTO ASSUJE THATQUAUFlEDPEIlSONN£I,.PRDPE1lLYGATHER AND EVALUATE THE: INFOIJotATION SUBMmED. BASED ON MY INQUliY OF THE PEIlSON ORPERSONS WHO WANA£lE fHESYSTEM. OR THOSE PEIlSONS DlIlECTLY RE5PONSlBLE

~~R..a:=~~=~~~~~=~~~~~·~~w~I--:S:-:IC::G:::N-;-A~T=U:::RE::::-O=F::P:-:R:-:IN=C:::I:::P::A::L---l ~~~;::;S~~.:i:~P~~~~F~SIJ==WF::E~:O~~~ci EXECUTIVE

NUMBER YEAR MO DAYAREA IVlOlAnoN~ OFFICER OR AUTHORIZED CODEI TYPED OR PRINTED I AGENT

COMMENTS AND EXPLANAnON OF ANY VIOLAnONS (Reference all attachments here)

EPA Form 3320-1 (3-99) (REPLACES EPA FORM T-40 WHICH MAY NOT BE USED) PAGE OF Form Approved OMB No. 2040-004

Page 105 COA Exhibit TF-5 TPDES Multi Sector Gemeral Permit SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 105 of 111

• • • SECTOR A FACILITIES STWI TXROS I CO

PERM nEE NAME ADDRESS nclu eFeclJilyNemo ocetionWDiIlerent NATONA PO TANT DSCHARGEE M NAT ON S STEM NOTE· Enter your permit number in the NPDES •

NAME D SCHARGE MON TOR NG REPORT DMR underlined space in the upper right hand (2-16) (17-19) corner ofthis page. Example: STWI TXROSJI021 CO

ADDRESS N/A ~I II , , ERMIT NUMBER , , D1SCHAR' - n

" It t I U '!...II' '} n ::"""." .." "w·...."" 'Only f re uire mail to TCEQ(MC212) FACILITY MONITORING PERIOD P.O. Box 13087 LOCATIO YEAR MO DAY YEAR I MO IDAY Austin T 78711-3087 N 01 01 I 12 I 31 0

(20-21) (22-23) (24-25) (26-27) I (28-29) I (30PARAMETER >< (3 Cord Only) QUANTITY OR WADING (4 Cord Only) QUALITY OR CONCENTRATION FREQUENCY

(32-37) (46-53) (54-61) (38-45) (46-53) (54-61) NO. OF SAMPLE EX ANALYSIS TYPE

AVERAGE MAXIMUM UNITS MINIMUM AVERAGE MAXIMUM UNITS (62-63) (64-68) (69-70)

Debris SAMPLE ••••••• ••••••• ••••••• •••••••MEASUREMENT ••••••• .. SAMPlE • . .....l,..•!!.:':;c ':~--'~~ ..... •••••••

......, ... ,.. . I .••••~••. '. :~<~i~~~<{ Inches <'.. .;ZVear.' Gra"t,\"

I REQUIRatENT ' . .'". -. ~>.". :r'.>;-'·'/' ','c '

• • • - ~ c • " ..;";, ""," .,-, ,.

pH SAMPLE ••••••• ••••••• ••••••• ••••••• MEASUREMENT •••••••

SAMPLE ,.; /~...... ,'-. '.. , ........ ';.. / .' 6.0: 9:() ......

"'Grab-'; ..•.•..... ' ••••••• ........... S.U. ' . ".' IIYear . 'REQUiRIiM:ENT ~ .. c,.,' , .- RJiiige' .."",: I',., ,

':.,.. , "'.,

SAMPLE MEASUREMENT

·:~Jt~~~(: " . ". '.;'.-, :. i." :'." ',:,:... '.

• • ,'.i ' "•. i·;;;{:.:X,- '. " ..... '.

NAMEITITLE PRINCIPAL EXECUTIVE TELEPHONE DATE OFFICER leERnFY UNDER nNALTY OF LAWlltATTIUS IXX..l.JMENT AND AUATTACHMEJoIB

WERE PREPARED lIJ'IOEk MY DDU:CI1ON OR 5UPERV15ION [N AC'C'ORDANCE WITH A SYSTEMDESIONEDTOASSURElHATQUAUFU:DPERSONNaPROP£R!.YOATHERAND EVAUIATE np;: rNFORMAllON Sl..IB.MInED. RoUEDON W'I' INQUlRY OF TIlE PERSON ORPERSONS WHO totANAOE lliESYSTEM.OilTHOS£PERSONS DIREc:I1.Y IlEIPONSl8J.J1 FOJlOAntElUNQ THE INFORMATION. THE INfORMATION SUBMIITEDlS. TO THE BEST Of MY KNOW1..EIXIE AND BE.UEf, TlWE,ACC\.JKATE.AND WMPLE1'£. 1 AW AWARE SIGNAlURE OF PRINCIPAL 1HAT THERE ARE SIONlFlC"ANT PENALTIES fUll WBMJTI1NO FALSE IJIIFOJU.tATlON,

EXECUTIVEINCU.IDINO THE POSSIBIUTY OF FINE AND IMPRISONNENT FOil ICNOWlNO AREA NUMBER YEAR MO DAYV101A.T1ONS. OFFICER OR AlJfHORIZED TYPED OR PRINTED AGENT

CODE

COMMENTS AND EXPLANATION OF ANY VIOLAnONS (Reference all attachments here)

EPA Fonn 3320-1 (3-99) (REPLACES EPA FORM T-40 WHICH MAY NOT BE USED) PAGE OF Fonn Approved OMB No. 2040-004

Page 106

COA Exhibit TF-5 TPDES Multi Sector Gemeral Pennit SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 106 of111

• • • SECTOR C FACILITIES STWI TXR05 I CO

PERM nEE NAME ADDRESS net". FBd6ty Nome ocstlon" Dllleren. NAT ONA PO TANT 0 SCHARGE E M NAT ON S STEM NOTE' Enter your permit number in the NPDES •

NAME D SCHARGE MON TOR NG REPORT DMR underlined space in the upper right hand 2-16 17-19 corner of this page. Eumple: STWI TXROSJ1021 co

ADDRESS I PERM TN M ER I ID SCHAR~: N M ER 10nlY he uiremail to TCEQ (MC 212)

FAC T MON TOR NG PER OD P,O. Box 13087 OCATON EAR1 MO 1 DA 1 1 EAR f MO IDA Austin T 76711-3067

PARAMETER C><(3 Card Only)

1 01 I 01 I (20-21) (22-23) (24-25)

QUANTITY OR LOADING

1 (26-27)

1 12 1 31 (28-29) (30

0 FREQUENCY

(32-31) (46-53) (54-61) NO, OF SAMPLE EX ANALYSIS lYPE

AVERAGE MAXIMUM UNITS (62-63) (64-68) (69-70)

TolllJ Phosphorus

(As P)

••••••••••••••SAMPLE MEASUREMENT

,','~;~~~~-i{;:'"":~ •••••• \ ,'REQl}lREMEI':lTl

•••••••

•••••••

•••••••

< -~.~.;~•••"

•••••••

,135; ,', 'I ':',1 05~", , Daily Avg', "Daily)dlix"

mg/l I " " I' " ,,' I'", ;~iI1yiaT <Grl.Ii .;, . ," ';::'''''--',. ".",-. -'

Fluoride I SAMPLE MEASUREMENT

••••••• ••••••• ••••••• ••••••• •••••••

,,~J~~"il'; '/'~~"~~~~ ",1'/ ~;.;~~~." ••••••• •••••••• 25 ' DailyAvg

75, , "Dwly Max mg/l I .' I; INear,JGrab ,

SAMPLE MEASUREMENT

:,~ti~~T*t'e .:' I:",.... , .., :1 " 'I,· ' NAMFJTITLE PRINCIPAL EXECUTIVE TELEPHONE DATE

I 0 FFICER 11C'EJtJ1FY UNDIil\ PENALTY OF ~w TKATntlS OOC\.IMENT /oM) AU..ATTACNMENfS W£RE PjWlAR£[) UNDER wv DIRECTlON OR SUPER.VlSlON IN ACX'ORDANCE WITH A SVSTEMDESIONEDTOASSlJRETHATQUAlJF1EDPERsONNELPROJ'£IU..YOA1HEllAND EVAUJATE THElNFOllMATlONSlfBI,IJfTUl,. BASED ON MY JNQlJlRYOF11IE PERSON

IOA.PERSONSWHOMANAOElHESYSTEM,OlllHOSEPERSONSD1IlECJ1.YRESPONSlBl£

~~===~~~,:,,~~~~~~m;w~I-"'S"'I:::G:;;N"A=TIJ=RE=-;:O:::F"'P::R=IN"C=Ip::-A::-L:---t ~RE::::.s::~~p~=~~=EF:U== EXECUTIVE

AREA I NUMBER VIOLATION£. OFFICER OR AUfHORIZED

YEAR I MO DAY

I I CODETYPED OR PRINTED AGENT

COMMENTS AND EXPLANATION OF ANY VIOLATIONS (Reference all attachments here)

EPA Form 3320-1 (3-99) (REPLACES EPA FORM T-40 WHICH MAY NOT BE USED) PAGE OF Form Approved OMB No, 2040-004

Page 107

COA Exhibit TF-5 TPDES Multi Sector Gemeral Permit SOAH Docket No. 562-06-2166 TCEQ Docket No. 2006-Q612-MSW Page 107 of111

• • • SECTOR D FACILITIES STW/ TXR05 / CO

PERM TTEE NAME ADDRESS nclu. Fedlity Name ocetion ~ DlII...nl NAT ONA PO TANT 0 5CHARGE E M NAT ON NOTE' Enter your permit number in the 5 STEM NPDE5 •

NAME D SCHARGE MON TOR NG REPORT DMR underlined space in the upper right hand corner 2-16 17-19 ofthis page. Example: STWI TXR05J1 021 CO .

ADDRESS IPERM T N M ER liD SCHAR~:N M ERlonlY f re uiremail to TCEQ MC 212

MON TOR NG PER OD FAC T P.O. ox 13087 EAR I MO I DA I I EAR I MOOCATON IDA Austin T 78711-3087

1 01 1 01 I I I 12 131 0 20-21 I 22-23 I 24-25 I I _26-27 I 28-29 I 3

PARAMETER~3 Car Only a ANTT OR OAD NG 4 Car Only a A FREQ ENC

32-37 ~ 46-53 54-61 38-45 NO,

I A ERAGE MA MM MNMM NTS E 62

OF ANA 55

Total I SAMP E b~ b4-bb

MEAS REMENT

su~~~ Se 1:~~~~;~~~I,'\t~,{.;;:~!~$~i~"-;~~it'/·:.. i. b1i~5ACIl,1 ~J~il~3J~:, mgl

Oil SAMP E IGrease MEAS REMENT

1·'·R~g~~~1~1.·",· I 10.

DailyAg . "oHL" pailyMax·.··

mgl I '." ' .. '

H SAMP E MEAS REMENT

~ii~~~~M1~:¥'~:r/;ii//,.::; 6:0-9.0 Range ';;."

S.. "I'~., ::. . '" I'" .:'1 .... ear· !

SAMP E MEAS REMENT

$AMP E T PE 69-70

1'?:;··'·I·j!;,:~~rfl,;;.~~b,.

I'1~ea(·I····Gra.b . .' 'i

. .' :"'."I' Grab.

,.~E~gi.f~r:ri-:·If<. ,-;;,1:· I ,"I

NAME T T E PR NC PA E EC

I OFF CER/-.----=---------T E

ICERTF NCEAPENA T Of AWTHATTH8DOC Y£NTNilDA ATTACHIIENTI -1_WEREPREPARED NDERM DRECTONOR8 PER SOIl NACCORDiUlCEWTH

A5 STEMDESGHEOTOASS RETHATQ A FEDPER80fllNE PROPER GATHER

TE EPHONE DATE

AND E A ATE THE NFORIIAT ON Ii .. TTED. ASE.D ON.. NQ R 0# THE PEIl$C»lORPERSONSWHOMANAGETHEI ITBI ORTHOSEPERIONSDRECT

I T PED OR PR NTED AREA ICODE

RESPONS EFORQATHEANOTHE NFORlMTON THE NFORlMTOfrlS yrn;DI---=-=-=::--c=-==-==-:-:-:::-::,.,...--! S TO THE EST 0# Y NCIIN EDGE NilO E EF TR E ACe RATE AND S GNAT RE OF PR NC PA ~::;O FA -: =~~ ",:~RED:E:'EG~CMTTP£:~: ~ E EC T E

1 - SON."TF,," NOW NO 0 AT ONS OFF CER OR A THOR ED

AGENT

N MER EAR MO 1 DA

COMMENTS AND E P ANAT ON OF AN OAT ONS Reference all attachments here

EPA Form 3320-1 3-99 REP ACES EPA FORM T-40 WH CH MA NOT E SED PAGE OF Fonn A ro e OM No, 2040-004

Page 108


• • • SECTOR E FACILITIES STWI TXR05 I CO

PERM nEE NAME ADDRESS ndu e Fecilly Name ocetionllDillerenl NAT ONA PO TANT 0 SCHARGE E NPDES

M NAT ON 5 STEM NOTE' Enter your permit number in the •

NAME D SCHARGE MON TOR NG REPORT DMR underlined space in the upper right hand

ADDRESS I 2-16 , I I 17-19 N A

corner of this page. Enmple: STWI TXROSJI021 COI PERM T N M ER D SCHARGE N M ER Only fre uiremail to TCEQ (Me 212)

FAC T MON TOR NG PER OD P.O. Box 13087 OCATON EARl MO I DA I I EAR I MO I DA Austin T 78711-3087

I 01 I 01 I I I 12 I 31 0 20-21 I 22-23 I 24-25 I L 26-27 I 28-29 i 30

FREQ ENC NO,

PARAMETER 3 Car Only a ANT T OR OAO NG 4 Car Only a A SAMP E

E 32-37 46-53 54-61 38-45

OF T PEA ERAGE MA M M M N M M N TS 62 ANA 55 69-70

t);j b4-btJTotal SAMP E Sus en e MEAS REMENT

mgl I' ' Soli s ,R~~~ME~~T::I/,'"" 1El~rl~rab"I' .. _{,;' "'1> 6~jl~OMaX H SAMP E

MEAS REMENT

6;0~~,~., S, , 1"0:> 1',>1:;E!ar I'Grab"Range',; ;"R~~~~~~~l{ I'~\,;'

SAMP E MEAS REMENT

'I 't"

'" "'/',·',1·:,I,' ......; I" ':~ig~~~~NTJ ':;'

SAMP E MEAS REMENT

'0" -,I .":1'':''''''.,.,V~EJ%~MEE~f':ik:" I;:".,

I TE EPHONE DATE OFF CER

NAME T T E PR NC PA E EC T E CfRTF NDERPENA T Of AWlHA,TTHSDOC lIIE.NTAHDA ATTACHMENTS

1---------'------='----==---=------- ~:,::~:~~~AS~ ~::~Tc:~:E=R:c:N:=~::~~ AND £ A ATE THE NFOA.....T aN S .. TIED. MEO ON" NO R Of THE PalSOHOAPER8ONSWHOMANAG.ETHE8 STEM ORTHO$f; PERSONS 0 RECTI ~E~EE~::n:.ERN;~EE~:~OHE~~N~~~~:...;~gt--;S:;-;:;G:;:N~A;-:T~;:;R:;:E:-O=F:-;P"R=N"C;:;OP""Ao---t

I~~:r~ FA-: ~~~~ ':CEREO:e":~~T ,PE: ~ ~~ :: E EC T E J-,A'"'R""EA=-.....-..,.,....,.,....,=--I-------I---=-+'"'O""A.,--l YPR SONMEHT FOR NOW N. 0 AT <NI8. OFF CER OR A THOR ED

I-I-----=T,..,P=:E::::D""'O=:R:-P=:R"..,.,NT::E::::D=----~ AGENT CODE


EPA Form 3320-1 3-99 REP ACES EPA FORM T-40 WH CH MA NOT E SED PAGE OF Form A ro e OM No, 2040-004

Page 109

COA Exhibit TF-5 TPDES Multi Sector Gemeral Permil SOAH Docket No. 582-08-2186 TCEO Docket No. 2006-Q612-MSW Page 109 of 111

• • • SECTOR J FACILITIES STW/ TXROS / CO

PERM TTEE NAME ADDRESS ndu. Facility N.me oc:ation if Dllf...nt NAT ONA PO TANT 0 SCHARGE E NPOES

M NAT ON S STEM NOTE: Enter your permit number in tbe NAME D SCHARGE MON TOR NG REPORT DMR underlined space in tbe upper rigbt hand corner

2-16 17-19 oftbis page. Example: STWI TXR05JI021 CO ADDRESS I PERM T N M ER II p SCHAR~: N M ER 10nlY f re uire maillo TCEQ MC 212

MON TOR NG PER OD P.O. ox 13087 OCATON

FAC T EAR I MO I DA I I EAR I MO I DA Austin T 78711-3087

I 01 I 01 I I I 12 I 31 0 20-21 I 22-23 T 24-25 1 r 26-27 T 28-29 T 30-31

PARAMETER 3 Car Only Q ANT T OR OAD NG 4 Car Only Q A 32-37 46-53 54-61 38-45

A ERAGE MA M M MNM M NTS

NO. E 62

FREQ ENC

OF ANA SS

SAMP E T PE 69-70

Total SAMP E Sus en e MEAS REMENT Soli s

~;~~~MEEN-rJ'·'::,,:, ~ ·.·,}1·"\, lEi-f'" H SAMP E

MEAS REMENT

:~:E~fJ~E~~T;"I.' SAMP E

MEAS REMENT

·~~~t~~~E~~~;I"·.; SAMP E

MEAS REMENT

;SAM.~E'. ". , ~...... .-;~.'''I('".RE9!f~REMI=:NT

···I":b~:i~5k"rf·I'b~~5Ma~<

I ·······.,;,10 Ie 6.0 ~9.0· Range.' .

,,. I .' ..

63 64-68

mgl . 1·1~~:r·I···Grab-, :. '--:',', • > •• ::~;'.<~,~I

S.. I ,t1 1 ear.:I Grab

I:> ,:·~L';i.:~I:· NAME T T E PR NC PA E EC T E TE EPHONE DATE

OFF CER ICEATF NDERPENA. r OF AWlHATTH &DOC MENTAHDA. ATTACHMENTSI1-----'----------------t~:~E~~~~~~ ~:~Tc:~:e~R:c:N:=~:~~~ AND E A ATE THE NFOR.....r ON S II TTED. AlED ON II HQ II. Of THE PER$ON OR f1ERSONSWHOllMNAaE THE 8 STEM OR THO$E PERSONS D RECT

~E~~ E~:c:n:.ERN;::EE~:~ONE~~N:..OR:"'~~;~gl--S;-G=NA=T;;-cR=E~O=F-:P:::R::-:N7.C~P:-:A,.....-1

~~G FA~ =~~ ~ED:ET~~~~T T~ ~~: ~~ E EC T E N M ER EAR I MO I DA

I--TFOO NOWNG OAT'*" OFFCERORA THOR ED AREA 1

CODEI T PED OR PR NTED AGENT


EPA Form 3320-1 3-99 REP ACES EPA FORM T-40 WH CH MA NOT E SED PAGE OF Fonn A ro e OM No. 204D-004

Page 110


• • •

••••••• •••••••

••••••••

•••••••

•••••••

••••••• •••••••

••••••• ••••••• •••••••

•••••••

••••••• •••••••

SECTOR 0 Facilities STW/ TXR05 / CO

PERM nEE NAME ADDRESS ndu eFedityNeme ocetiontilllllerent NATONA PO TANT 0 SCfiARGE E M NAT ON S STEM NOTE· Enter your permit number in the NPDES •

NAME D SCHARGE MON TOR NG REPORT DMR underlined space in the upper right hand ~2-16~ ~7-1~ corner of this page. Eumple: STWI TXROSJI021 CO

ADDRESS I PERM TN\ MBER II D1SCHA~: MBER IOnlY f re uiremail to TCEQ MC 212 - FACILITY MONITORING PERIOD PD. ox 13087 LOCATION YEAR I MO I DAY II YEAR I MO IDA

I 01 I 01 II I 12 L31 0 (20-21) I (22-23) I (24-25) 11 (26-27) i (28-29U(30

PARAMETER1><(3 Card Only) QUANTITY OR LOADING (4 Card Only) QUALITY OR CONCENTRATION (32-37)

Total Suspended Solids

pH

(46-53) (54-61)

AVERAGE MAXIMUM

SAMPLE MEASUREMENT

REg~~kfd:.·: ~·t:~~·~~, SAMPLE

MEASUREMENT

rik~~~~ r.:' ····:1 ,'. .••••••• SAMPLE

MEASUREMENT

. SAMPLE' .1 ,:,.:' ..:..•. '.' REQUIREMENT}.

SAMPLE MEASUREMENT

. SAMPLE, .•. ,.. .

REQUIREMENT ",' , ·1 ..

(38-45)

MINIMUM

....... :

~:~f···

(46-53) (54-61)

AVERAGE MAXIMUM

... ~.~.~.:.. X~I~OMlIX'

. ,6.0 c,9.0 ........... •• Range.'

"I.'

Austin T 78711-3087

UNITS

mgll

S.U.

FREQUENCY NO. OF SAMPLE El( ANALYSIS TYPE

(62-63) (69-70)(64·68)

, Gr.ibI!Year

'I, lIYear '·1 Grab

"

NAMEffITLE PRINCIPAL EXECUTIVE TELEPHONE DATE OFFICER I'c....T1FY UNDD. PENALTY ()I: UW THAT nus IJOCl.lWM AND ALLA1TAl'HME.NTS

1-.----'----------------;.wEl.EPilEPAlU:iDlJND£I.WYDlafiCTIONOa SUPEJt.VWONflrf1llC"COIlDANCEVr1IHA Sysra"D£SJONEDTOASSURETHA.TQUAl..lF1IDPEISONNaPROPERLYOATHEllAHD

I EVALUATE THE INFORMATION SUBMITTED. BASED ON ..V INQVlJ.Y OF THE PEaSON ORPEUO/lt!JWHOMANAOETHESYSTEM,OaTHOSEPERSONSOOlECILYIl£SPONSIBI.Ji

~~~~"i=~~~I:~~~~:'~~VI~t--:S:;;IC;:G;;:N-;-A;cT:;;U=RE=O;;:F=P"'R"IN=C;;:JP:;;A-:-:'L--1 '~~::~~~P~~~S~~~E':~~:: EXECUTIVE

AREA I NUMBER YEAR I MO I DAY

I IVIOIATION. OFFICER OR AUTHORIZED CODETYPED OR PRINTED AGENT

COMMENTS AND EXPLANATION OF ANY VIOLATIONS (Reference all attachments here)

EPA Form 3320- I (3-99) (REPLACES EPA FORM T-40 WHICH MAY NOT BE USED) PAGE OF Fonn Approved OMB No. 2040-004

Page 111

COA Exhibit TF-5 TPDES Multi Sector Gerneral Permit SOAH Docket No. 582-08-2186 TCEQ Docket No, 2006-Q612-MSW Page 111 of 111

• Draft Final Report for

Research Project GC 8720 Sediment and Contaminant Removal by Dual-Purpose Detention Basins

SEDIMENT AND CONTAMINANT REMOVAL BY DUAL PURPOSE DETENTION BASINS

• by

William Howard Cole and Dr. David Yonge Civil and Environmental Engineering Department

Washington State University Pullman, Washington 99164-2910

Prepared for

Wahington State Transportation Commission Department of Transportation

May 28, 1993

COA Exhibit TF-6 • Sedimentation and Contaminant Removal SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 1 of 57

•

•

COA Exhibit TF-6 • ii Sedimentation and Contaminant Removal SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-Q612-MSW Page 2 of 57

• DISCLAIMER

The contents of this report reflect the views of the authors, who are responsible for the

facts and the accuracy ofthe data presented herein. The contents do not necessarily

reflect the official views or policies of the Washington State Transportation

Commission, Department of Transportation, or the Federal Highway Administration.

This report does not constitute a standard, specification, or regulation.

•

COA Exhibit TF-6 • iii Sedimentation and Contaminant Removal SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 3 of 57

• TABLE OF CONTENTS

LIST OF TABLES vi

LIST OF FIGURES vii

SUMMARY viii

CHAPTER

1. INTRODUCTION AND RESEARCH APPROACH 1

Removal Efficiencies of Wetlands .4

Removal Efficiencies of Grassy Swales and Grass

Lined Channels 6

Design of Dual-Purpose Detention Basins 7

• Discrete PartieIe Settling 8

Camp's Removal Theory 10

Basin Modification to Minimize Short-Circuiting 12

2. RESEARCH OBJECTIVES 15

3. RESEARCH APPROACH 17

Scale Model Development 18

Scale Model Flow Range Determination 20

Scale Model Construction 21

Scale Model Configuration 22

Wet Testing 24

Selection of Contaminant Concentrations for Simulated

Storm Water 25

Metal Sorption Internal to System 26

• Sediment used in Simulated Storm Water

COA Exhibit TF-6 iv Sedimentation and Contaminant Removal SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 4 of 57

27

28 • Simulated Storm Water Mixing and Introduction to the Basin

Flow Measurement 30

Suspended Solids Percent Removal Determinations 30

Metals Percent Removal Determination 32

TSS Analysis 33

Metals Quantification 33

3. INTERPRETATION, APPRAISAL AND APPLICATION 35

Particle Size Defined 36

Settling Velocity Distribution 37

Suspended Solids Percent Removal Determinations .40

Comparison of Experimental Values with Camp's Theory

Predicted Values 41

Metals Removal 43

4. CONCLUSIONS AND RECCOMENDATIONS .45• 5. LITERATURE CITED 48

• COA Exhibit TF-6 v Sedimentation and Contaminant Removal SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 5 of 57

• LIST OF TABLES

1. Calculated Particle Diameter for Particles in Urban Runoff .4

2. Grass Channel Removal as a Function of Length for TSS and VSS 6

3. Grass Channel Removal Efficiencies 7

4. Estimated SOR for Prototype and Scale Model and Corresponding

Flow Rate for Scale Model 20

5. National Average Metals and TSS Concentrations 25

6. Initial Metals Concentrations for Internal Adsorption Experiment.. 26

7. Sampling Scheme used for Removal Efficiency Determinations 31

8. Calculated Removal Efficiency 39

9. Experimental Removal Determinations for Prototype Configuration .40

• 10. Experimental Removal Determinations for Optimum Configuration .40

II. Comparison of Experimental Results to Theoretical Predictions .41

12. Percent Removal of Total Metals at 9 GPM .43

13. Percent Removal of Solid Phase Metals at 9 GPM .44

• COA Exhibit TF-6 vi Sedimentation and Contaminant Removal SOAH Docket No. 582-08-2186 . TCEQ Docket No. 2006-0612-MSW Page 6 of 57

• 1.

2.

3.

4.

5.

6.

7.

8.

9.

• 10.

11.

12.

13.

LIST OF FIGURES

Concentrations of Four Metals in Street Dust by Particle Size Ranges 5

Type 1 Settling Curve 10

Basin with Short-Circuiting Piping Configuration 13

Basin Modified to Minimize Short-Circuiting 13

Schematic Representation of Basin 22

Prototype Piping Configuration 23

Optimum Configuration - Modified Basin Piping Configuration 24

Schematic of SSW Introduction to Basin 29

Schematic of Dilution Tank Used for Preparation of SSW 29

Particle Size Distribution for Sediment Used in Removal Experiments 36

Type 1 Settling Curve with SOR Indicated for Given Experimental

Flow Rates 37

Settling Velocity Distribution for 100 Percent of Particles 38

Flow Pattern for Prototype Configuration .42

COA Exhibit TF-6 • vii Sedimentation and Contaminant Removal SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 7 of 57

•

•

SUMMARY

The Washington State Department of Transportation (WSDOT) designs, operates, and

maintains stormwater detention basins. These basins are used to control storm water

runoff from highways, thereby controlling flows in down gradient areas. Historically,

storm water basin design has been based solely on hydraulic considerations. Recent

initiatives by the Washington State Department of Ecology have indicated that storm

water quality has become a high priority. Consequently, future design must consider

water quality as well as flood control.

To have control of the variables associated with removal efficiencies (flow rate,

contaminant type, contaminant concentrations, particle size' distribution, and basin

configuration) a scale model of a typical detention basin was constructed. Model

scaling was based on surface overflow rate equivalency between the prototype and

model. Experiments to determine. removal efficiencies for suspended solids with

diameters < 75 ~ms were conducted and the results were compared with the Type 1

sedimentation theory for an ideal basin. In addition to the sediment removal

experiments, preliminary investigations into the removal efficiencies for Pb, Zn, Cd,

and Cu were performed at a single flow rate under an optimized piping configuration.

\

The removal of suspended solids ranged from 65-80%. Type 1 sedimentation theory

for an ideal basin yielded good predictions of sediment removal. The removal of

metals ranged from 28-40%, indicating that small particle removal is necessary for

enhanced metal removal.

• COA Exhibit TF-6 VIII

Sedimentation and Contaminant Removal SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 8 of 57

•

CHAPTER 1

INTRODUCTION

•

• COA Exhibit TF-6 Sedimentation and Contaminant Removal SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 9 of 57

• INTRODUCTION

Contaminants in highway runoff can have a deleterious impact on aquatic

environments of receiving waters. Several investigations have been conducted to

determine the effects of contaminants associated with highway runoff. In one study,

Portle, et al. reported the adverse effects of the soluble fractions on zooplankton and

algae, while suspended solids caused high mortalities of rainbow trout fry. [1] In a

separate study, increased lead concentrations were reported in barn swallows nesting

near highways. [2] Reports detailing the adverse effects of contaminants in highway

runoff have increased awareness of the potential impacts associated with highway

runoff. Recent initiatives by the Washington State Department of Ecology have

indicated that limiting contaminants in highway runoff has become a high priority.f3]

• Several studies have been conducted to quantify contaminants found in highway

runoff and to examine the best management practices for contaminant

removaI.f4,5,6,7] Management; practices include wetlands, grassy swales,

retention/infiltration basins, and dual-purpose detention basins.

Wetlands and grassy swales function as natural water filtration and purification

systems. One of the most valuable features for stormwater contaminant removal is

the wetland's ability to trap suspended solids.f8] Removal effici~ncies for grassy

swales have been shown to be a function of the distance traveled in the channel and

channel slope. Although grassy swales can be effective, they require significant

maintenance to control sediment accumulation and subsequent deterioration in

performance. [9]

COA Exhibit TF-6 • 2 Sedimentation and Contaminant Removal SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 10 of 57

RetentionlInfiltration basins contain runoff in a basin with a highly permeable bottom.

A large volume is required for retention/infiltration basins due to the storage capacity

necessary for storm events. The basin must be able to accommodate an entire stonn

event since perculatiori to the groundwater system occurs at a notably slower rate than

accumulation of storm water. One problem associated with retention/infiltration

basins is the need for periodic removal of accumulated sediments to prevent clogging

and to maintain the recharge capacity.

Historically, detention basins for stonn water runoff have been designed solely for

hydraulic considerations. The Washington State Department of Transportation

(WSDOT) designs, operates, and maintains many such basins. These basins are

generally designed for peak flow rate control where water quantity, not quality, has

• been the governing design parameter. Periodic cleaning requirements reveal that these

basins capture sediment, however, the sediment and contaminant removal efficiencies

are typically unknown.

Removal of suspended solids is a practical and cost-effective approach to treatment. It

is well documented that the removal of total suspended solids (TSS) from highway

runoff will remove partitioned contaminants such as metals. Consequently, the

removal ofTSS has been the physical treatment process used most often. Information

exists regarding the removal efficiencies for the systems mentioned above. However,

little infonnation exists regarding the removal of size fractions less than 751-lm. Table

1 shows the best estimate of particle size distribution in highway runoff from several

studies across the USA. Calculated particle diameters are based on the settling

velocity ofdiscrete particles and Stokes LawD 0, 11]


• Table 1. Calculated particle diameter for particles in urban runoff. [1 0, II]

Size Fraction Percentage of Mass

Average Settling velocity (m/hr)

Calculated particle

diameter(um) 1 00-20 0.01 2 2 20-40 0.09 6 3 40-60 0.48. 14 4 60-80 2.2 30 5 80-100 20 90

•

From 60-80% of the particles are less than 30 11m in diameter and all particles are less

than 90 11m in diameter. Yousef{lO] states, the failure to remove the small particulate

would prevent achievement of target concentrations for contaminants. This is due to

the smaller diameter particles' ability to adsorb the metals more efficiently than larger

size fractionsJ1 2,I3,I4,15] Thus, the metals partitioned onto the smaller particles

may be discharged in the effluent. Better understanding of the mechanisms of

removal for the smaller size fractions could enhance contaminant removal from

highway runoff. Results from a study quantifying metals associated with particle size

ranges can be seen in Figure I.

Removal Efficiencies of Wetlands

Establishing and maintaining wetlands is an effective management practice for

controlling contaminants associated with highway runoff. The ability of these systems

to trap suspended solids can be attributed to three basic mechanisms: water velocity

reduction, filtering effects of vegetation present in wetlands, and electrochemical

flocculation effects,[16] Wetiand removal efficiencies as high as 94% for TSS have

• COA Exhibit TF-6 4 Sedimentation and Contaminant Removal SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 12 of 57

• been reportedJl7] However, the long-term concentration of contaminants, including

heavy metals, and their potential bioaccumulation has not been addressedJ8]

600

500

400 _Zinc

1300 II Chromium

200 o Copper

100

0

<104 104-246 246-495 >495

Particle size (microns)

•

<104 104 - 246 246-495 >495

Pa rticle size (microns)

Figure 1. Concentrations of four metals in street dust by particle size ranges. [12]

5000

4500

4000

3500

13000

I ~ Lead I2500

2000

1500

1000

500

0

• Removal Efficiencies of Grassy Swales and Grass Lined Channels

COA Exhibit TF-6 5 Sedimentation and Contaminant Removal SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 13 of 57

• The mechanisms of particle removal for grassy swales and grass-lined channels are

similar to wetiandsJ8] Yousef reports metal removal rates of grass-lined swales for

Pb, Zn, Cu, and Cd of 2.61, 5.76, 0.60, and 0.26 mg/m2'hr, respectively. In another

study, respective removals for Pb, Zn, and Cu were reported as 1.14, 1.85, and 0.42

mg/m2·hd I8] It is important to note that removal efficiencies are related to many

site specific conditions including storrnwater characteristics and swale design. For

example, removal as a function of swale length for TSS, VSS, Pb, Cu, Cd, and Zn

reported by Wang [9] are summarized in Tables 2 and 3.

Table 2. Grass channel removal as a function of length for TSS and VSS,£9]

• Swale Len2th (m) TSSI VSS2

21 90.4 90.9

43 93.2 86.4

67 94.5 100 I total suspended solIds 2volatile suspended solids

Table 3. Grass channel removal efficienciesJ9]


•

•

Site Distance (m)*

number of

samples

Cadmium Removal (percent)

Copper Removal (percent)

Lead Removal (percent)

Zinc Removal (percent)

I 15-21 6 51.4 24.6 59.3 35.5 31.0 1 60 53.5 70.4 31.4

40-50 6 80 39.2 72.0 69.7 67.0 6 100 63.1 83.8 69.7

2 15-20 2 100** 40.1 37.5 23.6 30-40 2 100** 51.1 54.1 50.8 50-60 2 34.8** 20.3 66.9 64.2 67.0 1 ** 43.4 90.2 65.4 77.0 2 ** 57.5 80.6 72.1

3 2.5 1 ** <0 2.9 2.1 10.0 1 ** 29.3 58.6 16.6 15.0 1 ** 51.9 68.1 19.4 20.0 1 ** 63.7 77.3 45.9 25.0 1 ** 70.7 86.7 57.1

4 2.5 1 <0 <0 2.1 12.9 5.0 1 45.8 34.4 72.4 60.2 15.0 1 100 68.1 78.5 93.2 25.0 1 100 53.3 82.4 94.0

* -distance in channel from beginning of vegetated area. ** -One or more values were below detectable limit.

Design of Dual-Purpose Detention Basins

The design of basins for water quality can differ from flood protection design. A

basin designed for flood prevention is sized for a storm event that rarely occurs.

Conversely, the major pollutant load results from the cumulative effects of

contaminants contained in smaller events that occur frequently throughout the year.

Consequently, the need for dual-purpose detention basins is growing. A dual-purpose

detention basin should be designed to: (1) retain the design runoff long enough to


• achieve the targeted level of treatment; and (2) to evacuate the design runoff quickly

enough to provide available storage for the next floodJ19]

The removal efficiencies for dual-purpose detention basins vary considerably. This is

due primarily to the site specific character of highway runoff and the different

methods employed for basin design. One aid for design considers the sight specific

character of runoff by relying on locally monitored data. [20] Other aids for design

include mathematical models to estimate removal efficiency, [21] design charts based

on reservoir-routing equations, [19] and application of computer models such as

SWMM, ILLUDAS, and UDSWMJ22] Whipple [23] applied an approach for basin

design that incorporated sedimentation theory as proposed by Camp,[24]

• Two detention basins involved in this study were modified by constructing outlets that

provided prolonged retention of stormwater. Observed removal efficiencies of various

pollutants were compared to predicted removal efficiencies. The predicted removal

efficiencies were determined using laboratory settling data and application of discrete

particle settling assumptions, as described by Camp.

Discrete Particle Settling - Type 1 sedimentation

The removal of sediment from highway runoff is best described by Type

sedimentation. Type I sedimentation is gravity separation of non flocculating discrete

particles (particles that retain their individual characteristics) in a dilute suspension.

Under such circumstances, the settling is unhindered and a function only of fluid

properties and the characteristics ofthe particle.


I

• A discrete particle in water accelerates until the drag force reaches equilibrium with

•

the gravitational force; the settling velocity then becomes constant. Since equilibrium

is reached rapidly, this terminal settling velocity is the parameter of interest in Type I

settling. [25] For a given particle, the terminal settling velocity is a function of

particle diameter, angularity, and density. At Reynolds numbers less than one, the

settling velocity can be determined from Stokes law presented below.

(1)

where:

Vs=settling velocity [m/s]

g=acceleration due to gravity [m/sec2]

ps=density of particle [kg/m3]

p=density of water [kgim3]

d=diameter of particle [m]

J.l=dynamic viscosity of water [kg/m·s]

Using Stokes law to calculate a settling velocity for each size fraction from a particle

size distribution a type 1 settling curve (settling velocity distribution) can be

generated to aid in removal predictions see Figure 2.


•

Settling Velocity

en en G)

~~ :t:·o F o~ 0 en-G) Ql - >.!:: "C t:: Ql lCIi XQ,.... ~~~~~~~~_ CIl

o C c ICI

.9 -= t:: o

C. o

V s

•Figure 2. Type 1 settling curve.

· .

Camp's Removal Theory

Sedimentation in an ideal basin, as described by CampJ26,27] uses the settling

velocity distribution, surface 'area, and flow rate to estimate the percentage removal

for discrete particles. Use·ofthis theory is based upon the following assumptions:

1. Discrete particle settling. 2. An even distribution of flow entering and leaving the basin. 3. An idealized settling, entrance, outlet, and sludge zone. 4. Uniform distribution of particles throughout the entrance zone. 5. Particles entering the sludge zone remain there. 6. All particles entering the outlet zone are carried out in the basin

effluent.

The total removal is estimated by Equation 2:

R ii(1 s!F;,) ~ FBF (2)

• v" 0

COA Exhibit TF-6 10 Sedimentation and Contaminant Removal SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 18 of 57 .

• where:

R=total percentage removal

Vo=surface overflow rate expressed as velocity

I-Fo=fraction of particles \\:,ith velocity greater than Vo F

~ ZlF=fraction of particles removed with velocity less than V0

v" 0

To estimate total percent removal for a given basin the surface. overflow rate (SOR)

must first be calculated.

SORiiR (3)SA

where:

• SOR=surface overflow rate [l/min'm2]

Q= flow rate [l/min]

SA = surface area of sedimentation basin [m2]

By appropriate unit conversion, the surface overflow rate can be expressed as a

velocity:

v" iiiSOR (4)

where Vo is equivalent to the settling velocity of the smallest particle that exhibits 100

percent removal. The y-axis coordinate of the intersection of V0 with the settling

velocity distribution curve defines F0 as seen in Figure 2. A fraction of the particles

with settling velocities less than stated surface overflow rate will be removed as a

function of the initial depth of the particle upon entering the basin. This fraction can

be determined analytically as defined by the integral portion of Equation 2. More

• COA Exhibit TF-6 I I Sedimentation and Contaminant Removal SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 19 of 57

• frequently however, an approximate solution is obtained by graphical integration as

shown in Figure 2.

Basin Modification to Minimize Short-circuiting

Historically detention basin design has not been governed by contaminant removal.

The main purpose of the basins was to retain runoff from a storm event and discharge

it gradually so that the capacity of the receiving stream was not exceeded. As a result,

piping configurations in these basins have been a function of cost-efficiency and

constraints imposed by system specific conditions such as highway design and local

topography. To maximize contaminant removal, stormwater retention time should be

maximized and short-circuiting minimized. If short-circuiting occurs, contaminant

removal efficiencies would be less than the theoretical optimum. • INFLUENT

I I I I FLOW

m+ ,

EFFLUENT

Figure 3. Basin with short-circuiting piping configuration.

• COA Exhibit TF-6 .12 Sedimentation and Contaminant Removal SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-Q612-MSW Page 20 of 57

• A schematic representation of a short-circuiting system is presented in Figure 3.

Clearly, the flow entering the basin is not being retained as long as is possible.

Modification of basin piping configuration to minimize short-circuiting and enhance

removal efficiencies is shown below.

---H~~ INFLUENT EFFLUENT -+----:-.FLOW=!

• Figure 4. Basin modified to minimize short-circuiting.

Retention time is increased by eliminating short-circuiting and as a result removal

efficiency is enhanced.


•

CHAPTER 2

RESEARCH OBJECTIVES

•


•

•

RESEARCH OBJECTIVES

The purpose of this project was to generate a data base that can be used in the

development of a rational design approach for storm water sedimentation basin design.

A scale model of an existing dual purpose detention basin was constructed so the

variables of concern could be varied under controlled conditions. These variables

include flow rate, contaminant type, contaminant concentrations, particle size

distribution , and basin configuration. The model was modified to minimize short

circuiting. Removal efficiencies were compared to the existing configuration. Results

from both configurations were compared to Camp's type I settling theory for an ideal

rectangular basin to detennine if this theory can be used to predict sediment removal.

Preliminary investigations were performed to evaluate the removal potential of metals

common to highway runoff (Pb, Cu, Cd, and 2n).


•

CHAPTER 3

RESEARCH APPROACH

•


•

•

RESEARCH APPROACH

The scale model constructed as part of this project replicates an existirig detention

basin located on the NE corner of the Henderson Blvd. interchange on 1-5 in Olympia,

Washington. This basin was selected as a prototype because of it's geometric

similarity to many basins in the region. An initial field survey of the basin was

performed and the resulting basin dimension data used to design experimental

parameters for scale model construction and testing.

Scale Model Development

The prototype basin flow was used as the basis for developing the scale factor.

Prototype flow estimation was based on effluent pipe length, pipe type, slope, and

hydrostatic head. The maximum head above the effluent pipe was defined as the

height at which water would top over the lowest point in the basin berm. Using

Manning's equation for closed-conduit flow, the maximum allowable flow was

estimated, and the resulting maximum surface overflow rate (SOR) was calculated.

Theoretically, removal efficiency of discrete particles is dependent on SOR only.

Consequently, removal for the prototype can be predicted in scale model testing by

equating the SORs of the prototype and scale model as indicated by Equations 5 and

6.

• (5)


• (6)

where:

Qp=flow rate to prototype

SAp=surface area of prototype

Qm=flow rate to model

SAm=surface area of model

• It is important to note that scale model development can be based upon many

parameters. The mechanism to be studied by modeling dictate the parameter chosen

for scaling. The most common approach used when predicting the hydraulic

responses of a particular system is to keep the ratio of forces in the prototype and

model constant throughout the flow field. This requirement is necessary in addition to

maintaining geometric similarity. The dimensionless force ratios used to accomplish

dynamic similitude are chosen based on the forces that will be acting on the system.

In a free surface hydraulic model, such as the one considered in .this study the

dimensionless force ratio used to accomplish dynamic similitude is the Froude

number.

The objective of this study was to determine the removal rates of suspended solids and

metals sorbed onto them. Consequently, flow rate determinations for the scale model

were based solely upon sedimentation basin design theory, Equations 5 and 6. As a

result, the removal efficiencies predicted by the scale model can be applied to the

prototype at corresponding surface overflow rates. Howevefthe hydraulic responses

COA Exhibit TF-6 18 Sedimentation and ContaminantRemoval SOAHDocket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 26 of 57

• acting throughout the flow field may not be accurately predicted because Froude

number similarity was not considered.

Scale Model Flow Range Detennination

A range of model flow rates were detennined from calculated surface overflow rates

in the existing basin. The maximum SOR was detennined by calculating the flow rate

out of the prototype at maximum capacity and dividing by the surface area of the

basin. The scale model flow rate was determined using Equation 6.

The minimum SOR was detennined using Camp's Theory to calculate the SOR

corresponding to an 80 percent removal efficiency. This removal efficiency was

• selected to minimize analytical problems at TSS concentration of less than 100 mglL.

Using the SOR from Camp's theory approximations in Equation 6, the minimum scale

model flow rate was determined. The range of SORs and corresponding basin flow

rates are summarized below:

Table 4. Estimated SOR for prototype and scale model and corresponding flow

rate for model.

Surface Overflow rate rJ,lm/sl

Surface area of model[m2]

Flow rate [L/min]/[gpm]

0.3542 2.14 45.42/12 0.2655 2.14 34.07/9 0.2066 2.14 26.50/7 0.1475 2.14 18.93/5

Scale Model Construction


• Based on the topographical information obtained from the field survey and estimated

basin flow rates, a scale of I: 15 was selected. The model was constructed using a

vermiculite concrete slurry, wire mesh, and plywood templates housed in a 16' x 4' x 2'

box made from half inch plywood. Using the contour map created from the field

survey, cross-sections were drawn at 15 foot intervals. Elevations were then

determined at intervals that were sufficient to define the basin topography. After each

cross-section had been converted to scale they were traced onto plywood and cut into

templates. These templates were placed at one foot intervals (corresponding to the 15

foot intervals from contour map) in the plywood box, thus defining the shape of the

basin. A #900 wire mesh was tacked to the templates and acted as a support for a 4: 1

vermiculite:concrete slurry. After drying, the vermiculite mix was covered with a

concrete slurry to minimize roughness. Outfall pipes were positioned at the

• appropriate elevation within the basin and were made of 2" schedule 30 PVC piping.

The outfall pipes were sealed with silicone to minimize leakage between the concrete

and pipe wall. A schematic representation of the basin is shown in Figure 5.

• COA Exhibit TF-6 20 Sedimentation and Contaminant Removal SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-Q612-MSW Page 28 of 57

•

• Figure 5. Schematic representation of basin.

Scale Model Configuration

Simulation ofPrototype Configuration

Determining the removal rates for the prototype configuration was necessary so that

the effects of piping configuration modification could be 'determined. For this phase

• of the study, the basin inflow and outflow pipes were positioned at the same locations

COA Exhibit TF-6 21 Sedimentation and Contaminant Removal SOAH Docket No, 582-08-2186 TCEQ Docket No, 2006-0612-MSW Page 29 of 57

• and elevations as in the prototype. Flows for each pipe were determined by personal

communication with WSDOT as percentage of total flow and adjusted for each flow

rate. The configuration is represented in Figure 6.

In 2 In 3 /

In 1 '\,.

Outl

1• Moxlie Creek

Figure 6. Prototype piping configuration.

The percentage of total flow for each pipe was

Inl ==20% In2 == 20% In3 == 60%

Optimum configuration

The influence of piping reconfiguration on sediment removal efficiency was

investigated by performing a series of tests using the model represented in Figure 7.

The piping configuration was intuitively based; utilizing the full length of the basin

• and potentially reducing short-circuiting. To optimize the removal rates, short-


• circuiting of flow should be eliminated. The basin was configured as in Figure 7 to

take advantage of basin dimensions and to minimize short circuiting occurring when

inflow and outflow pipes are placed in close proximity.

•

,.-+-~ In 1 Out 1

Max/ie Creek

Figure 7. Optimum configuration - modified basin piping configuration

Wet Testing

After the concrete set, wet testing was initiated. The basin was configured as in

Figure 6. Tap waterwas pumped into the basin at the highest flow rate; 12 GPM used

in this study.

• The main objectives ofthe initial wet test were to:

COA Exhibit TF-6 23 Sedimentation and Contaminant Removal SOAH Docket No. 582-08-2186 TCEQ Docket No, 2006-0612-MSW Page 31 of 57

• 1. Check for leakage within the basin.

2. Confirm that actual volume and HRT data corresponded with

design values.

3. Confirm the equivalency of SOR between the model and prototype.

Selection of Contaminant Concentrations for Simulated Storm Water

A comprehensive literature review was conducted to determine average TSS and

metals concentration in highway runoff. The results of this search are summarized

below:

Table S. National average metals and TSS concentrations [27]

• Cadmium (m2/L)

Copper (m2/L)

Lead (mg/L)

Zinc (mg/L)

TSS (m2/L)

Range (High) 0.032 0.1'55 1.457 2.892 406

Range (Low) 0.001 0.005 0.011 0.040 9

Mean 0.017 0.052 0.525 0.368 143

Preliminary calculations showed that removal efficiencies within the basin would

range from 65-80 percent. Consequently, a TSS concentration of 500 mg/l was used

in all removal experiments to ensure that there were sufficient solids in the effluent to

accurately define removal efficiencies and accurately assess· the effects of flow and

basin modification on changes in removal efficiencies.


• The simulated storm water (SS W) metals concentrations were based on the national

averages listed in Table 5. Preliminary experiments showed high levels of variability

in liquid and solid phase equilibrium concentrations for Pb and Cu at the levels

indicated for national averages. To maintain liquid phase concentrations above the

lower detectable limit and minimize the variability of Pb and Cu concentrations the

national average concentrations were increased by 350 percent. This resulted in

concentrations of 0.06, 0.18, 1.8, 1.3 mg/L for Cd, Cu, Pb, and Zn, respectively.

Metal Sorption Internal to System

Unintentional loss of heavy metals due to sorption on the feed system components, the

basin, and/or the inlet and outlet structures was evaluated by a series of experiments

• utilizing tap water containing Pb, Cu, and Cd. The data in Table 6 summarizes the

selected metal concentrations.

Table 6. Initial metals concentration for internal adsorption experiment.

Metal Concentration (mg/L)

Lead 100

Copper 35

Cadmium 4

The lowest experimental flow rate, 5 gpm, was selected to maximize the contact time

within the system. Influent and effiuent samples were taken every five minutes over

the course of one hour. These samples were analyzed using the methods detailed in


• Metals Quantification to allow comparisons to be made between basin influent and

effluent concentrations.

Sediment used in SSW

The sediment used in the SSW was obtained at Wallowa lake in Eastern Oregon. This

site was selected to minimize the background metal contamination level as there is no

known upstream road access. The sediment was transported to the laboratory and

stockpiled on a tarp at a depth of approximately 0.5 feet and air dried. The soil was

undisturbed during drying to minimize unintentional stratification. From the stockpile

a 1 ft2 block was collected and dried at 103° for 24 hours. The dried sediment was

shaken on an a US standard #28 sieve using a Soiltest hammer type shaker for 15

• minutes to remove larger size fractions (pebbles, sticks, bark, etc.). The fraction

passing through the US standard #28 sieve was then ground on a Cincinnati muller

type grinder for 30 minutes to reduce the sediment to elementary particles. After

grinding, the soil was put on the sieve shaker for 30 minutes and all sediment that

passed the 200 series sieve (75 microns) was used for preparing the SSW.

Particle size fractions are determined by two methods, sieve analysis and hydrometer

analysis. The sieve analysis is used for particles with a diameter greater than 75

microns. Particles whose diameters are less than 75 microns are evaluated using

hydrometer analysis. This test is based on Stokes law for falling spheres in a viscous

fluid. No particles larger than 75 microns were used for removal efficiency

determinations. Consequently hydrometer analyses were used to define the particle

size distribution. The hydrometer analysis procedure used was - ASTM (1980),

• Designation D 422 .


• Simulated Stonn Water Mixing and Introduction to Basin

Due to the particles tendency to settle within the 1000 gallon Nalgene holding vessel

used for SSW containment, it was necessary to develop a system that was able to

introduce the SSW into the basin at a unifonn concentration. Problems encountered

included settling within hoses and the holding vessel and non-homogenous mixing

within the holding vessel. To overcome these obstacles, a small slurry tank was used

to contain a concentrated SSW (CSSW). The CSSW tank used was a 30 gallon

Nalgene container with a 113 horsepower motor and 3 inch impellers arranged so that

a downward velocity was created enhancing scouring and mixing. The concentration

of solids in the slurry tank was 16.2 gil. The volume required to contain the CSSW

• was considerably smaller than that required for the SSW and the motor was sufficient

to maintain sediment homogeneity in the slurry tank. Using a variable speed

peristaltic pump to regulate flow of CSSW to the dilution tank the predetermined

levels of solids concentration for the SSW were obtained. A schematic representation

of the configuration is presented in Figure 8.

'I' "

motor

rIh Holding pump

Tank Slurry Tank

J-7n--0 \pump

Dilution Tank Model Basin

Figure 8. Schematic of SSW introduction to basin.


• Preliminary mixing tests indicated that impeller placement toward the bottom of the

tank minimized air entrainment and maintained a homogeneous solution. Air

entrainment within the CSSW tank had to be avoided to maintain a constant influent

flow rate and sediment concentration. The dilution tank was a 4 L plexiglass tank

placed on a magnetic stirrer with a 3" Teflon coated stir bar.

• Figure 9. Schematic of dilution tank used for preparation of SSW.

All outlet ports on the dilution tank were located at equal distances from the bottom of

the tank to maintain equivalent concentrations in all exit hoses. It is significant to

have all influent concentrations equal so that accurate flow adjustments will give the

desired loading rates. Sedimentation in the tubing was prevented by use of 0.25 inch

tubing which maintained sufficient flow through velocity.

Flow Measurement

Tap Water From Holding Tank

CSSW

From Slurry Tank

SSW To Basin


• The flow was measured for the influent hoses using a graduated cylinder and

stopwatch. Each flow was adjusted until the flow was stabilized, and measurements

could be triplicated over a period of two minutes. The CSSW hose goi~g into the

dilution chamber was connected via a flow splitter so that the head of the holding tank

would not affe~t the flow measurement. The CSSW flow was then measured with a

graduated cy linder and a stopwatch following the same procedure described above.

Suspended Solids Percent Removal Determinations

•

To eliminate the loss of volume due to sludge accumulation, the basin was cleaned of

all sediment following the termination of each run. In addition, the CSSW tank was

emptied. An appropriate amount of soil was added to the CSSW tank that resulted in

a concentration of 16.2 gIl, and the volume was adjusted to 30 gallons. Dilution

water flow rate from the holding tank was then adjusted. During this adjustment

period the scale model was filled with clean water. A hose used to fill the holding

tank was adjusted to the corresponding basin flow rate so that a constant head would

be achieved. A solids mass balance was used to determine the flow rate for the CSSW

to the dilution tank to achieve 500 mg/L solids concentration. Following CSSW flow

rate adjustment the basin inflow was allowed to run for a time equal to four HRTs to

approach steady state conditions. To prevent air entrainment, adequate amounts of

water and soil were added to the slurry tank so that the level of CCSW in the tank

remained at or above half capacity. Sampling was initiated following the four HRT

time period. The sampling scheme followed during each test is illustrated in Table 7

Table 7. Sampling scheme used for removal efficiency determinations.


•

•

Sample Time Volume Purpose Type

Inl 4HRT 300 mls Solids Analysis Grab

In2 5HRT 300 mls Solids Analysis Grab

Outl 5HRT 300 mls Solids Analysis Grab

In3 6HRT 300 mls Solids Analysis Grab

Out2 6HRT 300 mls Solids Analysis Grab

Out3 7HRT 300 mls Solids Analysis Grab

LMI 4HRT 150 mls Liquid phase

metals analysis

Composite

LM2 4HRT+ Imin 150 mls Liquid phase

metals analysis

Composite

TMI 4HRT 150 mls Total Metal

Analysis

Composite

TM2 4HRT+lmin 150 mls Total Metal

Analysis

Composite

Metals Percent Removal Detenninations

The same procedure was followed for the metals runs as in the suspended solids runs

with the following exceptions. Before the run was started the metals were added to

the CSSW tank and allowed to equilibrate with sediment for 24 hours. After 24 hours

the run was started as in the previous procedure. The liquid phase samples were

collected in 150 mL Nalgene bottles, filtered immediately, and preserved with an

appropriate amount of concentrated acid to make a 1 N solution.


• The total metals samples were collected in a similar manner to the liquid phase

samples, instead of filtering they were digested according to the procedure outlined in

Metals Quantification.

The method used for collection of the composite samples for liquid and solid phase

was the same. The effluent was collected in a 3.5 gallon bucket. The contents of the

bucket were completely mixed and a sample taken.

Sufficient salts of the metals were added to the slurry tank to result in metal

concentrations of 2, 6, 60, and 40 mg/l for Cd, Cu, Pb, and Zn, respectively. The

sediment concentration in the slurry tank of 16.2 gIL was identical to previous

sediment removal experiments. Three replicates metal removal experiments were

• performed at a flow rate of 9 GPM and optimum configuration.

TSS Analysis

Preliminary tests showed that repeatability of TSS analysis could be enhanced by

modifying the Standard Methods procedures. This modification was necessary to

maintain a homogeneous suspension during pippetting. The modifications include

shaking the sample thoroughly and transferring to a baffled 500 mL beaker. 100 mL

aliquots were taken from the beaker and filtered through a Whatman 47 mm glass

fiber filter.

• Metals Quantification


• Investigations were conducted to determine a digestion procedure which removed

partitioned metals without damaging the mineral structure of the sediment. A 1N

nitric acid digestion was shown to produce the best results. The sample taken from

the basin was mixed and an aliquot was removed from the sample bottle and

transported to another sample bottle that contained an appropriate amount of

concentrated nitric acid to make a 1N solution. The sample bottle was placed on a

wrist shaker at a speed sufficient to keep particles in suspension. The samples were

allowed to digest for thirty minutes. At the completion of the digestion the samples

were gravity filtered through a Whatman 47 mm glass fiber filter and the filtrate used

for analysis on the Atomic Adsorption Spectrophotometer.

• The Atomic Adsorption methods used were Standard Methods - 3111 B. for flame

analysis and Standard Methods - 3113 B for flameless Atomic Adsorption analysis

when greater sensitivity was necessary.

An exception to Standard Methods procedure for preservation of samples was made to

minimize matrix effects observed in flame less Atomic Adsorption analysis. The

samples were preserved with IN nitric acid.

In all cases blanks were run to check for contamination within sample bottles, stock

solutions (metals and acid), filter paper, and all glassware.


•

CHAPTER 4

INTERPRETATION, APPRAISAL AND APPLICATION

•


• INTERPRETATION, APPRAISAL AND APPLICATION

•

Particle Size Defined

Hydrometer tests were run on several different samples collected from different

locations within the sediment stockpile to evaluate the homogeneity of the stockpile.

Five samples from the stockpile were analyzed and compared. The results of the five

samples produced similar particle size distributions. The results from all tests were

averaged to give a particle size distribution used for application in Camp's theory.

This distribution is shown in Figure 10 .

Particle Size Distribution

60 o ~ 50 o G) 408, a. J!I E 30 c III G) UI 20 ~ 8!. 10

o 75- 32- 23.5- 17.0- 12.5- 9.0- 6.5- < 1.5 32 23.5 17.0 12.5 9.0 6.5 1.5

Particle size (microns)

Figure 10. Particle size distribution for sediment used in removal experiments.

• Settling Velocity Distribution


• After determining a particle size distribution for the sediment used in the SSW a Type

1 settling curve was constructed using Stokes law, Equation I.

Type 1 Settling Distribution

1Il 0.35 1Il a!

:;;; ~ 0.3 :t: '0 ~ c 0.25 lIla! a! - > 0.2 .!:!~ 't: a!

12GPMa:li 0.15 _ 1Ilc,.

c c 0.1 c a:l c.c.-'t: . 0.05

c C.• 0

0 100 200 300 400 500

Settling Velocity (microns/sec)

Figure 11. Type 1 settling curve with SOR indicated for given experimental flow

rates.

Figure 10 shows 55% of the particles were determined to be larger than 32 /-lms. From

Figure 11 it can seen that the largest SOR was 354 /-lms/sec corresponding to a settling

velocity for a particle 19.9 /-lms in diameter. Therefore it was not necessary to define

the particle size distribution for the particles above 19.9 "",ms in diameter since these

particles are 100 percent removed at the highest SOR and all subsequent lower SORs.

The particles with a diameter less than 19.9 "",ms will be the particles partially

discharged in the effluent. The percentage of these particles discharged in the effluent

• can be determined by evaluating the second term of Equation 2. For the experimental


0.2

• SORs used and the particle size distribution of the sediment used in the SSW, this

contribution to the overall percentage removal was negligible.

Figure 12 shows an interpretation of the entire settling velocity distribution for the

sediment used in the SSW.

Type 1 Settling Distribution

• .,

0+-....l..-----1~------t----__+_---__t_--__+

oSORm 1000 2000 3000 4000 5000

Settling Velocity (microns/sec)

Figure 12. Settling velocity distribution for 100 percent of particles

The dark portion of the curve represents the portion for which values were obtained

from the hydrometer tests. The dotted line is an interpretation of the best fit between

the two points. The highest experimental surface overflow rate corresponding to a

model basin flow rate of 12 GPM is indicated in Figure 12. The shaded area above the

curve is the area to be integrated as indicated in the second term of Equation 2. The

• removal calculated by this term of contributes only 0.078% to the overall removal of


• 80% see Table 8. This indicates that the second term of Equation 2 is not significant

for the system studied. Camp's theory indicates that a portion of those particles with

less than stated SOR will be removed due to their position upon entering the basin.

For this system that portion is low with respect to total removal. Table 8 shows the

total removal determined by Camp's approximation including the portion contributed

by both terms of Equation 2. In addition, the surface overflow rate expressed as a

velocity is shown for each experimental flow rate.

Table 8. Calculated removal efficiencies.

• Flow Rate

fL/min lIfGPMl

SOR

(Ilms/sec)

Removal

(l-Xo )

Integral

2nd Term

Total

Removal

18.93/5 147 80 0.078 80.1

26.50/7 207 76 0.088 76.1

34.07/9 265 74 0.103 74.1

45.42/12 354 71 0.11 71.1

Suspended Solids Percent Removal Determinations

• COA ExhibitTF-6 37 Sedimentation and Contaminant Removal SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 45 of 57

• Prototype configuration

Table 9. Experimental removal determinations for prototype configuration.

Flow Rate

[L/min]/lGPMl

Trial #1

(% removal)

Trial #2

(% removal)

Trial #3

(% removal)

18.93/5 78.73 76.12 nla

26.50/7 76.62 76.5 nla

34.07/9 67.12 66.45 nla

45.42/12 64.22 65.16 66.86

• Optimum configuration

Table 10. Experimental removal determinations for optimum configuration.

Flow Rate

rL/minl/GPMl

Trial #1

(% removal)

Trial #2

(% removal)

Trial #3

(% removal)

18.93/5 76.91 72.31 n/a

26.50/7 73.68 75.64 78.09

34.07/9 71.22 67.73 n/a

45.42/12 69.55 66.45 n/a

• As expected the higher flow rates produced a lower percentage removal of suspended

solids due to increased SORs.

Comparison of Experimental Values with Camp's Theory Predicted Values


• Average experimental values for prototype and optimum configurations are compared

to removal predictions made by application of Camp's Theory in Table 11.

Table 11. Comparison of experimental results to theoretical predictions.

Flow Rate

fL/min lIfGPMl

Prototype

(% removal)

Optimum

(% removal)

Predicted Values

(% removal)

18.93/5 77.4 74.6 80.1

26.50/7 76.6 75.8 76.1

34.07/9 66.8 69.5 74.1

45.42/12 65.4 68.0 71.1

• The effects of altering piping configuration to minimize short-circuiting did not show

a significant increase in removal efficiencies. This may be due in part to the flow

pattern established in the scale model basin at prototype piping configuration. The

flow pattern qualitatively determined from visual observations is shown Figure 13.


~ 1= In3 c= -f"n 2 r

In 1 •

• ~

Dun Sragnamk6a .....

r-

I Nux/Ie Creek

• Figure 13. Flow pattern for prototype configuration.

The flow pattern established may be preventing short-circuiting of flow from In2 to

Outl . As a result, solids entering the system at In 2 are not transported directly to the

outfall but are given the opportunity to settle due to increased residence time in the

basin dictated by the established flow pattern. This would suggest that the basin is

approximating ideal conditions as described by Camp for both configurations studied.

However predictions for flow patterns established in the prototype cannot be made

because the model study was not designed in accordance with Froude number

similarity criteria.


• Metals Removal

The percentage removal determinations based on total metals analysis are presented in

Table 12. The total metals are defined as the sum of metals partitioned to sediment

and the metals remaining in the liquid phase after equilibrium. was established. The

results of two separate experiments (Trial 1 and Trial 2) are presented in Table 12.

Table 12. Percent removal of total metals at 9 GPM.

Metal Trial 1 percent removal Trial 2 percent removal

Lead 34.6 35.3

Zinc 33.8 33.1

Cadmium 40.0 32.5

Copper 37.5 28.2• The solids percentage removal for Trial 1 and Trial 2 was 74.8 % and 71.0 %,

respectively. Clearly, the total metals removal is not as good as solids removal.

By calculating the solid phase removal it becomes clear that removal of the smaller

particles is necessary to achieve higher removal efficiencies for metals. The solid

phase is defined by the difference oftotal analysis and liquid phase analysis.

Table 13. Percent removal of solid phase metals at 9 GPM.


• Metal Trial! percent removal Trial 2 percent removal

Lead 36.1 35.4

Zinc 40.3 35.8

Cadmium 41.7 25.0

Copper 36.8 33.3

Liquid phase analysis showed that more than 80 percent of the Cadmium and Zinc had

partitioned to the sediment after equilibrium. While, Lead and Copper had greater

than 93% in the solid phase. An average of 27.1 % of the solids that were not removed

in the basin had adsorbed greater than 58% of the available Cadmium and 64% of the

available Lead.

• The liquid phase analysis suggest that better removal of solids could result in metals

removal as high as >93% removal for Pb and copper and >80% removal for Cadmium

and Zinc. Research is currently being conducted at Washington State University that

is investigating increased removal potential of chemical addition to enhance settling.

Preliminary results indicate that chemical addition will increase the removal rates of

suspended solids.


•

CHAPTERS

CONCLUSIONS AND RECCOMENDATIONS

•


• CONCLUSIONS AND RECCOMENDATIONS

The removal efficiency of suspended solids from highway runoff can be reasonably

predicted using Camp's Theory for discrete particle settling under the simulated field

conditions studied. The SOR studied were low and percentage removals ranged from

64% - 78%. However the removal calculated for metals was not as high. This is due

to the smaller particle's ability to more efficiently adsorb metals. Failure to remove

the small diameter particles will result in a disproportionally high level of partitioned

contaminants in the effluent.

To avoid short-circuiting care must be taken in design of influent and effluent piping

configurations. By maximizing the distance between influent and effluent structures

• the effects of short-circuiting can be minimized. If existing conditions do not allow

for maximum distance between influent and effluent structures short-circuiting could

be decreased by installing baffles to minimize short-circuiting.

To maximize the removal of metals, the smaller diameter particles must be removed

from the discharge stream. This can be accomplished by lowering the SOR of the

basin and thus increasing the percent removal. The SOR can be lowered by

decreasing the flow to the basin or by increasing the surface area of the basin. The

flow to the basin is a function of the storm event and the surface area of the drainage.

The storm event can not be controlled. The surface area of the drainage can be

effectively decreased by dividing the drainage and constructing additional basins for

each new drainage. This may be cost prohibitive however and additional solutions

may be more applicable and cost-effective. One possible solution is the addition of

• grassy swales between the basin and the receiving water to polish the effluent.

COA Exhibit TF-6 44 Sedimentation and Contaminant Removal SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW

. Page 52 of 57

• Another alternative would be to add coagulants to runoff to enhance small particle

removal and possibly further remove metals by co-precipitation.

•


•

CHAPTER 6

LITERATURE CITED

•


• LITERATURE CITED

1. Portele, G. J., Mar, B. W., Homer, R R, Welch, E. B. Effects of Highway Stormwater Runoff on Aquatic Biota. Washington State Department of Transportation Report, 1982.

2. Grue, C.E., O'Shea, T. 1., Hoffman, D. 1. Condor 86, 1984;pp. 363-369.

3. Washington Department of Ecology, Puget Sound Highway Runoff Program, Chapter 173-270 WAC.

4. Taylor, H. N. Enhancing Effluent Water Quality of Sedimentation Basin Using Constructed Wetlands Technology. Proc. Am. Soc. Civ. Eng., 1991, pp. 746.

5. Pittman, R. A. Conventional Stormwater Which Recharges the Groundwater. Proc. Am. Soc. Civ. Eng., 1991, pp.l032.

• 6. Yousef, Y. A., et at. Maintenance Guidlines for Accumulated Sediments in RetentionlDetention Ponds Receiving Highway Runoff. NTIS PB 91236042, 1991.

7. Yousef, Y. A., Wanielista, M. P., Harper, H. H., Pearce, D. 8., and Tolbert, R. D. Best Management Practices- Removal of Highway Contaminents by Roadside Swales. Final Report submitted to Florida Department of Transportation, FLHPR # E-II-81, Tallahassee, Florida, 1985.

8. Gavin, D. V., and Moore, R K. Toxicants in Urban Runoff. Metro Toxicant Program Report No.2, 1982.

9. Wang, T. S., Spyridakis, D. E., Mar, B. W., Homer, R. R. Transport, Deposition and Control of Heavy Metals in Highway Runoff. Washington State Department of Transportation Report, 1980.

10. Hvited- Jacobson, T., and Yousef, Y. A. Highway Runoff Quality, Environmental Impacts and Control. Chapter 5 from Highway Pollution, 1991, pp.165.

• 11. Driscoll, E. D. Performance of Detention Basins for Control of Urban

Runoff Quality. Proc. ofTwelfth International Symposium on Urban Hydrology, Hydraulics, and Sediment Control, University of Kentucky, Lexington, 1983


• 12. Amy, G., Pitt, R., Singh, R., Bradford, W., and Lagraff, M. Water Quality Management Planning for Urban Runoff. Washington, D.C.: U. S. EPA, Office of Planning and Standards ( EPA 440/9- 75

004),1974, pp. 247.

13. Shaheen, D. Contibutions of Urban Roadway Usage to Water Pollution. Washington,D;C.: U. S. EPA. Office of Research and Development (EPA-600/2-75-004), 1975, pp. 346.

14. Hopke, P., Lamb, R., and Natusch, D. Multielemental Characterization of Urban Roadway Dust. Environ. Sci. Techno!. 14(2), 1980, pp. 164-172.

15. Svensson, G. Modelling of Solids and Heavy Metal Transport from Small Urban Watersheds, Ph.D. thesis, Chalmers University of Technology, Department of Sanitary Engineering, Gothenburg, Sweden, 1987.

16. Shapiro and Associates, Inc. An Assessment of Wetlands Research and

• Regulations in King County. Unpublished report for Municipality of

Metropolitan Seattle (Metro), 1979.

17. Hickok, E. A. Wetlands for the Control of Urban Staormwater. In: Proceedings-- National Conference on Urban Erosion and Sediment

Control: Institutions and Technology (W. L. Downing,ed.). Washington, D. C.: U.S. EPA (EPA-905/9-80-002), 1980, pp. 79-88.

18. Yousef, Y. A., Hvitved- Jacobsen, T., Wanielista, M. P., and Harper, H. H. Removal of Contaminants in Highway Runoff Flowing Through Swales. The Science of the Total Environment, 1987, pp. 59,391-399.

19. Akan, O. Storm Runoff Detention for Pollutant Removal. Journal of Environmental Engineering, Vol. 118, No.3, May/June, 1992.

20.· Griffin, D. M., Jr., Randall, C.W., and Grizzard, T. J. Efficient Design of Stormwater Holding Basins Used for Water Quality Protection. Water Res., 14(10), 1980, pp. 1549-1554.

• 21. Curtis, D.C., and McCuen, R. H. Design Efficiency of Stormwater

Detention Basins. 1. Water Resour. Planning and Mgmt Div., ASCE,103 (1),1977, pp. 124-140.


• 22. Stahre, P. and Urbonas, B. Stonn water Detention For Drainage, Water

Quality, and CSO Management, Prentice Hall, Englewood Cliffs, New Jersey, 1990.

23. Whipple, W., Jr., and Hunter, J. V. Detention Basin Settleability of Urban Runoff Pollution Phase II., 1980.

24. Camp, T. R. Sedimentation and the Design of Settling Tanks. Trans. ASCE, 1946, 111:895

25. Viessman, W., Jr., and Hammer, M. Water Supply and Pollution Control Fourth Edition, Harper and Row, New York, N. Y., 1985, ppJ02.

26. Reynolds, T. D. Unit Operations and Processes in Environmental Engineering, PWS- Kent Publishing Company, Boston, Mass., 1982.

27. Beynum, R. V. Enhancement of Heavy Metal and Sediment Removal Master's Degree Special Project. Washington State University,

• 1993


• ('\lrvn!-'h, a ... p.Jrt (,I !\byllufl~' IlNl-:. Vfd 7(1 ~\ . .\. ""(~,h'r 1:Il\lnlllllWIlI RL· ...cdrl.:h

W:l~hlll.~lllll. D.t· 200.\7 I'r:II\\:,.I11'(·; ,

An evaluation of geotextiles for temporary sediment control Mic!lael E. B8ITett. ,Jm~eph F. Malina. Jr .. Randelll J. CilarbeneclLJ

\USTI{.\CT: rill' pt'It"111111:lI1lT {If ,gt·"k·.~(il~~ hlr ....:di1lh.·111 ':lllllnJ!

\',";1:"> ~·\;llll:I1 ..'d III lIll' lil:ld dill I 1.1!l(\r,:t1\lf.\'. RlIIlllt't '<lllIp!.:' ... l"\ll,k\'ll'd til

(hI' ril'hl ;l1dll.:all'd Ikll l:;'o'(,llli~dl~ Il~' .,cditnl'lll l"l'mp\al \I,-ol:-. ;UlribllJahk

til till1ati'ln fl~ !Ill' f,lhril', ,,,ill (..:lll'l'" .11,,) had lilll\.." illtiu\'!H'L' llll IhL: lurhi,lil.\ Ill" Illl' lli"l.'har~l..·d rUll\lll. T,II:11 "lI,p~IIi,Jl:d :"(lliJ~ ft.'IIl-I\;,I, III

fiX [;1'111' I \\ ~r": IpUlld in thUlh..' 1t.: .... I-' ill ,\ hu.:11 ,ill klll:l'~ well.' ill:,J;ilkd

rh~ rL'Pl'\\'al ~,nil.."i~'rIL·~ W.I" (,'prn:l:lll'd willi lIll' :1\.l.'r:t~I" d,'ll'nli(ln lin,,·

nf Illl: im/h'unJ"d rUllI/I"; hehind 1!l~~ (~'JI""L' 1-'1\1\\' "..tIL' .. !lllpugh the kIlL'~:-:

undt'r lidd .:lIlhlili~II1' \\-.:'I"L' lw'l ord\.·/:,> uf !lIa~niIUJt,' Ie", .. Lh.lll \\,puld hL' 1,:;!lI.:I,ilall"d 1I:"illg .. l;llllhrd :\."\"1'.\1 inJl:'.\. L"hM:lCI...·riMlc... oj lh...: f.thl'i,: ... rlli .. di~I.::\·P:1l1("} r\~"ld\L'd ffllill ,.. Ip~gill~ til 11l1.' r:lhril.· \\1111 ·;..·dllll\.·I1~

;1fl(J lrpfll till' lurllllll'l1f 11.\\\ Ihr"lI~l1lhv j";dwiL' IIp<.,,·l1il1,:! .....It tilL' h~dr:llI!I\,·

Iw:td .. 1111 till' r;JhllL":" v.1lt'1I 11 ....'11 <I", :'oill klkl·... , BartT /-:11\';1'''/1. HI·v.. 7U,

..!SJ (lljtJJ:\/

J\EY\\'OWDS: ... ill t'L'lk·\,;'. !'illrr (~ll-'triL: ....<.,,·dil1\l·1l1 ,:nnrnd. :.~~·lil\·,(Iil~·.

·.:l.l11qm...·lillll nlllillt ...;,[nl'ln\\;II"';1" runillf JlIIl1P'lllll pllllUlitl1l

Introduction

• l\lIblrlll·,illn ill lhc ,.1,[I ..... lin. Tl.·.'i.~I~. ,Hl:,l tll" .....c\'cr,d Ill'\\" tll~h

'.\ ;lyS 111.11 LTlh" thL' 1"l.:dli1r~1.:" '/IInL' Ill' till: r.t.h,,·anb ,·\qul!"!,;'r kd III ;I4·y~;11 -"tuJ~· nltlh,: cffl'L'''' Ill' rLll1pll from hi~hw<lY \.·n" .... lllIl" linn ~IllJ pper~lljtln (J1arrdl ('I (rI.. II)(J:=;'~~). One l;.'!L'lllL'n1 or tlli ...

ill\ c.",i~.([ilill Wil" ;HI ..:v;.sluallllll nl" 1111.': pcrtnrlll~II1L:L' nl' t!l"nh.·Xll k'

r~lhric.. for Il.·mrhllary (\)nJro/ ~Ir l.·lIll,"ilru .... li(l/l rUI1t1l"1. The lk'rrl'r· 1I1~lIlL''': or 'lilt ft.:nn' .... inilially \"as t'V,IIUillL'd during \.'ull\prchcn·

,.. i\'c lldd 1lI(lllil\lrifl~; hu\\'c\'cr. diftiL'lIlli\~~ ill uhwilling: n:pfL'

:'ol.'lltaliv\.' wah:r 411alil! :-,wllpk':" It'd Il' llle lin dllPl1h~l1t ut d

lahuralory ,,:,<pI.Timclllali\11l prpgr;Hll. TilL' rClTlo\'a[ llrlut.d .. us

pL'111k-d 'olil1...; ITSSi by I Ill.' rah,i\.· \Vtl~ IllL·.;I .... UI'LJ in th..: tidd ;lIld ill a lahpr;llnry 11ulfU:. ~Ild thl.' hyUr':llrlil.· pl"ll(lLnic ... Ill" lhc.'>I·

l.·lllllrtl!,.... \Io.L·rL· dth,:UlllCnlt.:d. J

Background TIlL' llIilj~i1lipll HI pnl1l1linll frlllH l111npoinl :"ouru.~~ i .... ail lin·

plln;1/1I L'Il\ IrOIlIl1L:1l1al issuc JnlTCaSl.·d puhl iL' a\\'an':lll ."S ;llld4

....·11 tld II Il.·n I uf .. lalc .llld kdcl'l.Il rcgulillions have n~l'l1 the fl"

~Pllll:,CS III ht.:ightL'I1l'J l.:lllll"elll .... l1\";r thi", 1~""1.I1'". St()rlll\\~lLl'r nUl

off rfPlll cPllslnll.·lillll ..;jll:"; j" :tll impOrl;l1l1 l.'(llll pLtI1L'1l I (II nun·

point ~(lllrL:e !1(lllulinll nCl';uhl' :';1111 1"" ..t,.'''' I"rolllunprnh:·l'lCd CllrI··

"rl'l.lrtloll ,ilL''; i.lIl.' c:\tll11~tlL'd to lIPP/o~l.·h I 1)(10 lime", Ihe "vcra~l:

llalural r~ltl.' nf "I.>ilero"illn ISnHHll 1'1 al.. /lJt.J21.

Till' ekall \Valer A~I ft'quilt:.:'o lhat a NalilJl1;!1 P~dlU1;lIH Di,,· dl;II'gl~ Elillllllalioll Sy.... tl'llI PlTlllilhl.' (}htail1L:d tll uisL:!1argc rUIl(Iff fl\llrl 1:(1n~tl1lL·tjun .. il~" \\,lllTl.· IllUfL' than], h;] (5 ac/ Ill' lalld

j.:.; di,lurbL'd it ..S. EII\'ll"lllllllcntal Prtllc'\.·lilll1 {\~.!..... nL"~', I ()IJ11. Pari til" IlIl' I'>t'nllllling proL"c .... ~ i., thl' dl'\'L'ltlprlll'BI and illlplL:1l1LlIla

til)" or tI SILlnll \V;dl'l' Polllltioll Prl'\,cllli\11l Pli.lll. 'Ilti~ plan n1u:-.1 dC .... t..TihL· Ii'lL' projl'cI and 1111..: appnlpl'lalC ~L'diJrll.·I!1 and ero.... ipll

'lllllnlb Ihal "'ill bc u.. ed nil till' CUllstnll·tinn ... iIL·. Sill t\..·I1I.'l' ... ~Irt' llllt: fype or It.:ll1puwr.\' ~cdllnelll ((llllrlli ac·

Ct:ph::d h~' tilL" l'IIIl ... II'1h.:lioll inJu... lry and r~gulilll1ry :.tgl.'llL'j~;~. Silt

"1.."1I.'C~ ,lrl? lhCd l:'xh.'t1:-.i\L'!y Dil hi,:!hway and tltlwr l·OIl~rnh:t;on

rrpjl,;.·C1 ..... '11"lL.~~~ lcmpur;II'y l.·PlllfC·I-... arl.' rl.~inrl\rl.'l~d and ... upPOf(<.,,·u

~ ....p/t,.·\llk rLlI"lril.~ Ihal rl:lhll"l' s~l!id,... h)adin~~ lhl'(lll~h lihralilHl

allJ h~ ill1["lIIIlIHlillg rlllllJfr. \\hi..:h L(lUSI,,:' \'l.·h,city n.:dtl":li~11l and

th~n.:h~ l'lIhanl'c"" St:dllllL'llt<ll illll. The h.'l·hnn!ogy fl,)J· ."l.'dilllcni

~lIld l.'ro"j(lll L'Plllrol is still ill thl' dL'\'l"!tlpnlL'IlI~:1 ~I;lge.... i.lnd

,:!uiddines fill' in..;lallalinn ulIJ 1I1~lil1!L'Il:lIICC Ill' tClllpllrar~ L'l'IIl·

[!"(l!:\ ~I"t' llflL'1l \':.Igll\.' and h;I........d LIIl rlll..:s PI' thllmh. Silt fl·'1t..·I:~

IU\'l: ht'cl1 ... t.·ll.'l.'lL:d prd'L:rclltially and 11l... t:lih:d widely ht'l';lll";L'

of Ihcir purporrcd ;li.h"'IIlt"lge'. ~lIdl ,IS cffccti\'1..·lll·~'" rUI p~,rlod:-.

(It" m(ln.:' th~1I1 (1 IIhlrllh ... ..;(r\ln~.!cf .... lln~lrUl.'li(}ll. f"n':;'ltcr pPllding dl.'plh. rCIIIII\:l1 t:'frklt.:llcics 01 7~(:';. Jasy ,hsclTlhl~. and n:la~

1i, ely Ill\\" Ctlsl tGoldman ("I Ill.. I l),l{(ll.

Thret' raclnl".... a/Tcl.·t the fl.'lIltl\·;" ...:ftiril.·!lL'Y uf ~t..'diml'lll n) 1c1l11ltH~lry Llll1lrlll .... : ."lI ... p\.·nul.'u-~l)lid~ dlar;.ILl..:ri .... lil·"'. h~·dr'.HJliL:

dill! tiltraliull dlaraCICrisliL: .... PI" thL: fabric. imd 11IailllenalKe or lht: "y"'!l'lIl. The p,lflklc .. il'L' di ... lrihutiull oJ IhL: Ilhlhili/cd .... l.·dililt: II I i:-- dd,:nllinL'd hy 111(' l.·har;h':ll~ri ... (il.·s of Ihl.' palcnl ~llil.

... \111'111 inh:n,..;il) and dur~ltinl\" anu path ul' lhL:' no\\". Thi..; di .. ,rihu·

lipll dl'ILrrllilll.·:-' .'1l."ltlillg r;u..:" and the ~ll~Pt.'IHkd -';CJiI1lCIII hlad

011 tilL' hllL'1 ranriL. SlIIalkr parlidL's ,In: di~pl'h':l.'d llIore l'a~i1 .....,

Lhan largL'r partidl.' ..... in l.'ornp"ILk'd :\llih. and rCl\lain in :'ouspcn

..,jurl ,"PI' IUIl~l'r pLrioJ~ Dr linlL' hC'ltk slowly J. ThL:refnrl·. SII"

jlCllUt'J :-,\.·\,lil1ll:1ll l.·~IITit.:·u hy "illlnllw..H.l.·r 1l1l1P!r fHllU l.·'"hlruc

tUlIl "llc... IYl'ic;rlly l·(ln .. isl~ Ill' a Llrgt:r p..:rcL·J1wgc (If lilll' parll..:11..'" r1wn Ulll"'> Ill...: pal'l~1I1 "nil (Hinman !\s....... lciaIC:'i. II1L· .. I (}7h,

and Srh"dcr and 1.1Igl l ;l!. I<JX') I. Fillt.·1 f'lhl ir~ h;tvc a lillratl~lI1 eflkil'llL'! djd~ttt..:d ny thL' I\llll\

hl'r. si/.;':. ami dl~lr~Il.·(t'1' 01" ~Icces:"ihk por\.·~. :1110 lhil'l..:lIc...... Ill' tIll' I"ahril'. Fahril'~ with largt'r pure .;i/l's pnIIl1D!L' gll'<.Ill.'1' Tillt..':"

01" 1I1H\ ami alII,,\" lar!~cl' p;'lrliL'!c~ 10 pa~ ..... through as l'lltllparl'd

ret fahric..; Vdlh .. mallL'r (Ipclling,.;. bill \A ith a Cnlllp~Jr:lhl..: pcrl."elll

a~e or UpL'T1 ;'ll"l::'l. Smaller pore,.. inhibil How >Iud jr1L.Tl~a~t..' rl'1l:n·

11I11l linll's. Thickt.:" r~lhr1cs ha\l.-' ItlllJ:!cr IllI\\' p;'llh" and .11(' lIlL'n:· I'll!'\.' characlL:rized by Ill\.\'CI pl'nncahilitit.'s. li'lllg~r 111,lding

lime...;. i.wd ;1 1.1Tl,;.·'IlCr tc.:l1dl.'fll')' for parlidt' illll·rt,.·l~plilH1 Ihan arlO L'nmparahlc thill I'ahril.':" ICl'l'hhiu. I'JXK I

Tht:rl..: ar~' ~t..'\·l.·ral c\i,"ling ll'... t IHL~rhlllh for l" ,rlll<lling Ihl'

('l'rfOflllalll'c charal'tL.:ri~lil.·:-' of gl'Ptl':"lilL' I'abrk's. 1\-li.l11) IIf lh~· ... \.· Ilh.'thillis lllea~lJr~ ilHk~ dlar:h.:It,.·ri .... lil·S th'll prn\'idc inl'oflllalil)11

;d)\Il11 lht:" t"ahrir bUI do nut llloJI::1 rield pl:.·rfnnnanl."c. CUrrCrll

illdtl~lry-accl'pt..:d :-:'l~lIld:ll'd Icst IIIl.·\lll.ld... art: lypi~:aJly indL'.'\ in

lI;tIUrL·. and l·PI!."1:.:4u .... tlfl). mnst or lhl' ,,,pt'ciliL'atio!l," fOl geol~.\

tilL' fahl'il"~ an: hi.I:-iCJ Ill} {hl.'~~ Icsh pl'rt'onllLd h,Y rnanul':,h,:turcf... III" ,lal~-tc.. l.il1g i.lgt."flcks The hJdraulit..· ..:ha"~J(kri .... lics of t!l'U

lL''\lill;:'~ arC' nflt:11 (k~,crih~d hy app:Jrcl11 upL'lling- si:l.l' lAOS' and

pl.'.rlllitl i \ lIy \ '(1 l. Apparent (lpenin~ .... ilL~ lypic-;i1I), j:-; r-epOrlt'd a...

• COA Exhibit TF-7 Barrell Evaluation of Geotextiles SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 1 of 8

•

•

•

a "jn~' ... i/l' ,I IlLI i .... Illl' L'~ilillilkd LJr~l'''l plln... "i/~~ ill 1111.:' LlhriL' T'~L' tJj,IlIIL'Il:r Hi" 11K IJpL'nillg~ is ":\ll\lllllllll~ 1lL'~\\"""~1l H\l) alld I

1100 (i1H. T11\.' I'cnnitli\lf~ J\fl) l}t :1 ~~=Oll.'.'\llIL· i .... a 1l1("I~llrl· I}I

rhL' I.::l"t: \\ ith \\ hidl Wa[L'r Ho\\'s Ihrpu~h Ihl..' l";Jhril', In Thl' [L'''1.

;1 fahflt :-;pL'L:illll:1I t,l" /...r1\1\\Cl i1n.:~t i p"H..:c.:U ill ~l hori/llllt~lIl1,.il'n

laliull~ a k.1I,'\~·1l !h,:ad ,It \\~u~r , ilpr1jcd umJ lhe /low C'-W.:

lhrull~h Ihe.: boric 1;-. I1IL~lI,"'llrcd.

["hi: \'nhlllll..' ~If \\'all~r. the ril1w it till\\";'. and tl$' hC~H.I :!rL'

n':LHflkd hll IhL' cul1:-;I:IT\! 'h..:ad t(' ...;1. Th ..., p~~rl1lilti\'ily tIl!) i~

L';dl'ublnl ,l";

\11 ~ "1\, 'IR, (I)

idl "

\11 pt.·nnilti\'ll~. '" \. l/uantlly Ilf 1111L\'. 1111"11';

II .-= hl'ad lin Ilw r~lblil'. IllIr\;

/\ ':" LTO' .... ·"l·U1PII:lI Llrl.·.:.I oj fabril·. Jl)m~:

1 ~ limc n( 1111\\" .... ;

/( .;,; l~rnpl:rall..lr~~ l,.'(lrr('l;fiull (';Il.:cllr; ,Iud

". "pcl.:i1k di:'l~hur~c (J)an;y'~ \'doclly f!)1' pornu;.; ll1L'di;1

l1\,)wI,

Till' l'ull:-.larll fll:i.ld kSl IYril.·all~ i~ rUIl ~It a hCiuJ df ..:;0 111111.

Prl:\·iuu... rL's.."an.:h lin lh(' "'l~dimcl1l r~JII~lioll l'~lIl"'Ld hy "ill

kIlCl::, h... :-. ,hll\\,1) lugh r~nlo\ \.\1 in lahol'i.ltory setting... (Crl'hhlrl,

1~IXs" i.lnd KI.HI\\"L·II. IYlJ()1. TCllill ;,;uspcllJcd ....olid:-. rellhl\al ill lhe'L" sIlIlJi~;-; JangL'u l'nlln appn"illlJldy :.(-;t;"( III I()()f:~ H\lWe\'L·r. 'he :.;()Iills u:'o~J 1$ tTL',lk ~I s('dilllLLnt ~Iurry \\CI'l.:" Ill' Illllch !aq;l'l didIlH:rL" 'h..m lilt:" r;lnidL' .... gcn~,.aJly CIlI'l)lllllcrCu ill l'\)II' ~tn'L'lion iUllolf. Fur in~t;.(rh:c, (t1l.' .... Iller) 1l."L·d by KllU\vcn 11~)0f)

W;I.'i l'rt'ah:d with a rood) gl'.:.IlkJ ~i1jCl -';':lI1u with all ;'Ivcragc

pi.lltidc .,,;ilc lit' }ot) IJrll (11Wlliul1I ... ;H\dl. Ct)n~elIIH:nlly IIlL's""

~Illllil'" 111:\)' ha\·\.· (l\'cr~lalt'u lhe \cdime!H··renll,l ... al cHiL:i ...ney

Ilwl l'~111 hI:.' L'xJlcrl~d UIlt.h:r lidd l'~}IIJitillJl:-',

SL'dil1\~J11 n:l11l'\ all.,rkctivl:IlL's' in till' Ikld i ... nul wd~ l!Pl'U'

flICllh:d. HprnL'r t'l ill. ll~l()ll) il)\e~ti(!i.IICd thl.: r~rftlflllan .... t.· III

"ill knn.: .... by pitll'illt! lhL'1ll F'l"rpL·lIJit.:-uJal III slopes Illl 1\\'11 Il',... t

plOlS. Thl: d'l1uL'!I( 1'01 thcs.... (\\'(1 pldls \\'.;J:-> compared \'\';111 lht.'

t.'tfluclil frolll t",,·o hare-soil umtl'ol pluh th'-lf did riot hJ\'L.· .:.111)

..:UI1Jru! measllll:: .... ill~';Jlh..d. Turbidity rt'dtldilll1 Wa~ cah:l.llalcd as perccnt lInit rcl!th.:lil>lb ralhL'1' Ihan til 1t.~rIll:\ of l1la .... :-. loauill);:-

reuLlcti, In,",. Tht rc:'\ults indic:.lkd n;.·mnva!s or X:;.7':1 \JI'TSS ilnd ~.lJt:~: l~f lUrhiuily. ThC's~ data dt:ltlPll ...tr~lI": thai :-:>ih rl.:'l\(:t'~ ,lIl'

Lllrl)' ~fh't:,i\."t' :..1\ {f;'}pping ~UsrclluL"d :->l.·uirnen(:,\ hut un IlIlt rl> dw.;(' IUrhjdll~ t '·fl,'ftler I" III.. J ()lIO)

Field Monitoring of Temporary Controls E\':llllalioll of lhe PLLllulTllann: (.... f temporary .... l.llllrof:.;. ill ~lll \l(1l:r,

i\tion~tI :-.crting relluired an t.:xt..:n:'I\t.: hdd'Jl1t1niloriJlg prugr~IlH. 111.,,:'

sl.~LljJllCIII .. rt:nH)\ ill l·nkkll .... )l·~ PI' "ill 1't"llL'C'" w..:-rc uctcnnlllt:d from

...amp)...:s liJ)..l:n dLirill.~! "Ic'nu ~;\'cnts 111\ highway l·nl"trll.... t1un pwj

l:Ch. Only rill' TSS rl.:"lUl\\"al t,ftideJll:Y f~Sllltill~ frlllll tiltralillll l'\IUJd he' c·\·alui.t{nl in rhL" hdd ht...l,.·iIU ....cofthc diflldllfy ifll:olkctint:

a rcprL'("jL'l1(;ltj\L' sample \If'liL''' inHI.lt:llI nllwtf

Hil!hwi.l\' (y,n..:.tru(lion sift.: ;.;ekctflill \....J~ t';ISl,'(j (111 '-.:'I."'L· I" iJCl..'l'S:. a:-.'dL'l!lled hy pn.l\il11ily, aL'i.:e~~ibilil)', ('{iup\~ralilJlI cd

Ihe L·l.ln ...lrudion .""pcr\'i"lIpio of tlw Tl!'.\il' ()~~)al'tll1~jll nf Tr~ln"iportallll1l tInt.! the .... olllrac.:lur. auJ IhL: availability ot' sih-IC1\L:": in ... tallalit.\lb The impnl\,crl1l'nl (lr BL"T! ,"'hill: Bouh.·vard 1ll.S

~t)n.l t'nlll1 n'H1i:--I.I.'r Lilll~ (0 Inkr:,aalL 35. in ,.\0,"1111. T\..·X:l:-.. "~l'"

"L'k·L:I~d ;1:-' ~Ill approprii.lll.' ... Iudy afl:;1 ha~ct.I U1i thl..'Sl,' ;,.·olhll.krd

lilln;.;. Sill r...-1lL'~:-' liwi rClL'ln:d llniy limilcd dllllllllll,'" \It" .... 11 ...·1.:1

Illl\\' wcre 11~)1 ... Uil.lhk for c\'aluali(lIl. ()111~ installalillll" "ilh

m\)d\:r~ltL" Ill)"'> l)l' 1~u.·ll(illll \'l)llIIllC:-' ~lInkicllt hI ralllli :-.aI11·

jllill~~. \\·er,_' ft.::l."ih!l' lor C'\·;lllI~ltil)ll. Nl.lrmal l'PII"'lnlLlilln proLL·~."'I.'''; gtH l'rIlcd in!'-I<iHalillu JOU majll1t:mJJlL'~ til IhL" ....!I..:.... "'L.

kl'lcJ. Th~ Inng'L'\ it) (If ~Uly particular site wa..; not ~tW"~U1h?l'd

a:-. L(Jlk,tl'lIctiun Jltivilic.... rr\lg.n:~ ... ;'\ ...·J. The lr:tn;';l1c,,'~ nalll!L' ~d

t.:(111:-.tnlt.:li'.l1l ;lL'tivitic, rCi\Hlk"d ill 1'..:111\\\ al pl' !>ill {\:Ill"L· ... (rlllll

pper.ni\lll. .... hangL·:-- ill L·llnli~lIral,ilJn. nr lill\\ lli\ ,~r,iun~ r,~,ultin~~

t'rPIll til ..' I)!'ngrcs.sioll of l,.·(ln ... ll'llL:tioll.

Sample.... \"'L'I'(' COlltTll'd frolll si.\ .... pccilil· L'tmslfllclillll" ."itc'" tl~;n~ .... ill knL'l·;-'. T\\'fl in:-.I:.dlalinlls il1l.",H"pOralcd nom....o\'cn l'i.Ib fie and rOIll lbL'd "'\"j)\."l~n r~lhrl",·. <.irah "i.llllpk ... \\.'1.'1''': cldkL"h:d

lIIilllually iu /·1. pla.'!l\..' t,.'l)nlai,lcl-':. Thi ..., IW..'lh.,d III "~lnJpJin1!

fL't.luir..:d tIll:' pn.: ...~n\..·1:" oflhL' rL'.<.;c~rdwr and .'lllo\.. t'U IhI' oppnrfU'

nil) 101' llr~rational oh~l~r\'alion!-' Juring rUl10ff c\'l:nls. [kptlt

rl'Ljlllrl~rn\!llt:-; for sampling rDulJ h~ ;-';'.l1i,tl..:u only tilrnut!h runtlll

l:l'L':.lt..:t.! fl'tlll1 rainfall l'\· ..·nts til' IlHH.ICI"i.llc to !l..:avy intL'nsily OJ

dllralioll, UIIl'\1t1lrolkd Jisdtarg~:-. \:;"llI:'oL'tl hy lems, p\'crlupring. L'nu nlll alld 1IIHh:rt!o'J.; failllIL'S wert..: 1101 :-.ampk'c.L 1111\\''':\'l~r.

their prL· cllL·l" jl1tlit.:aIL'~ Iht: ilnpl1rtanL'l! {If proper in:-.ralLullJlI

alld m;Jtllll'I).:lIh.·",'. /""1 11' ~Il·hit... \'ifl~ I)ptllllllln pL"rtl\rm.lJlL·t'. The anal, )'..;i~ nf TSS :lIld (LJrhidlf~' \\'0.1,,\ cllndul'll..'U ~fc""trrd;lIg If) th...· prll...·l'

JurL~~ in Sllme/l/nl Il/n!l(lJ, I~n ,!ll' f ..rumiltaljoff t~( 1V({I{'1' ({lid

1\'cI\l"\I<lICI tl\PI L\ d <II" Iq'l~ I

\ValL'r·qualily sal lip1c... wc=rL· .... nllL:l'tcd during. 10 I"lIn(ll"(c\'L~Ill:"

tiwi i,ll,'ClIITL'd hd\\'cl!1l fehruary 1 allu JUIIl: 1-4, I ()lJ:\ P;lirl.'d

':lInpk~ \\'IT'': l:nlkL·tcu rrl)1l) I\\'P IlX..":JtitHl ... at silt .. rCIlL·C in:-.l;llbrions' ill lhl' pllll\ hl:hind Ihc ~ih felll'\: ami dl)\\.I\;-.U\'arn of IIll" .. ill 1~·II(,I'. SpcdiiL' illt"nrmalinlt reg~lrdil)g lht: iJl(l'n~iry. UlIl"ilti\ll\,

(11 q{(;.Huil~ of each minfall L'\'~nt W~I,'" Oil' llhta;nLLd bCG1US': pj

limikd L'lluilllllen( on sill', Th\;.' ...ampk;.. \\'CI\: ~m;lIYI.\;."d for T.sS. llirhidity" and ~ctJim~llt p:lnkk Si/.!:, II wa~ tlo( plJ:.;:-.ihk: III

L'plkCI rcprl':\L'nt,l1ivl" ~i.lIl1pks of [hL' th.,,,· heliwc re:wliillg 'IlL'

I'll III 1hrhilld thl" :iilt··f~nL·(' in:-.t:.lIl:.\lilHl ht:l'au~e PI' shi.llIu\\' Waler

lk·plh .... and Ihl~ rtumel"UUS iuno\\' poinl:-;. :\11 a.... L'uralc chal'adt.:r

ilalltlll \\";I~ pll~sibll' nr IhL' l'ffllll:111 di ....dwr~;:u "rPITI thl: "iii· knl.'\.' \.·llnlJ'llh. The 1Il("Jn TSS l'lHIVl'IHralilll1 Ill' lilt? di~\.:h:lrg\~

\\"i.I~ I iT}" 1ll~!1... w;lll;1 IIlL'di<lll l.'onL'cl1tr;u;!H1 of approxiJ11i.lldy

:i70 IIIg/l... '1 Ill.' largl,' dill~rcIH.;l..' b..:lwl:":-Il (ht: t\-\n \',alllt· .... r,,:slIllL,d

I"rolll a ... in:;k ,ampk wid, an ..:-x(n:l11e1y high L:lIlk·cIHratil.lll

(I:) 100 11Ig/L).Jt.'lllonsll,;uing Lh~ ",id\: \I:ari~thilily illl:\lIblil.lJl:nl

l"()lll'cllirarinns a,... sot.:ii.lh:~u willl "'1 •. llnl·!:!cncl"akU 110"' .... The 111l:·

dian llIay bl.' !IlIll",:' reprL~:-'clllalivt of till: \1o';~IL'r llll ..L1ily tyl)' .... ~llly

dischi.lrt~l'd I'rlirn Illl'se :-.lnll..'lufC,.

ThL' efht.:lL'nc)" 111'111..: gl'Ul":Xlill' ... ill fL'nl'l::-' \\4.1" hilSt.::d lIli a

utmp;,tfi ... lIl) pJ tilt' rss \.:llnL·L·l1lratiDII., ill Ih~ IIp ... ln:am pund

illid (hc l'flluCIlI dtlWn... lrL·arll of the ..;ill knl·t'. The TSS (PIKUl

Ir~ltiolls fnr lht.:: ~<'lll1pk.'i ;Ire "h(H\ n in Figufe I. CIlOlparing lilt:

pail'l:J ~alllplL' I..:lInl·L'lllratll 11l'" allo\\'cLi thL' dclL'rntirwliotl of !tIL' rcmoval L·fliL·ll.'Ih':y of the sill fcllr .... ~t1tllle UIlU igntllL'd 1\.'l1hl\'.d

allrihllltt.l to s.~lllm~lIlatHl{1. Till' TSS fL'mq\,al ('Hkll..:l\"':) Wil"

l·aiL'lIlalt.·d as fulhl\-"'s'

TSS l'CdUl..'li()11 ((:'r }

~''.!.~·~~II TSS (11lg./~~~~~,I.~lrl:~~.~~~~.~S j Ul!.!iL I

[I i',lre,"" TSS I \ll~/I)

,. 10(t".:; I'!. I

Water Environment Research, Volurn~ 7f). NUl n,I)~1

COA Exhibit TF-7 Barrett Evaluation of Geotextiles SOAH Docket No. 582-08-2186 TCEQ Docket No, 2006-0612-MSW Page 2 of8

•

•

•

..:l t:!OClO lEi Upslrear,;6· E :0000. .OCMflsltearn;

~ooo

GOOO

4000

20011 '"

0- .. I!II. 3 4 7 R 9 1G l' 12 1:1 14 15

Storm Oesign3ticn

Figure 1-Comparison of paired TSS concentrations at silt fence installations.

Th.... IllcJii.l1l rl:l11o\'~" c(lii..:il.'f1cy rc...;uhing from hllrauon \\'~t."

or:; , \\-ith ;1 :'ola"d'lrJ Jl.~\'ialilH1·(lr ~hc.:,;. Thl' ran~l' ill calL'ulah..'d

cntdclh.:il's \\·a:-. ... hI In )~l.t;·;. i\ nq!iltiv..: rCdul'linn "i,~lli1il~"i all (lh~cr\,c,;d IIlcn:a:-.I.' in TSS d()v.:n~II'~~lIn pI" the .. ill fc'IKC. :\(iIlPr

l'rr(lr~ for in .riw .... ,"npling .::ll:OII,rrw:rion sitl".' arc 'ypir;IJ. OtllL'J" "l)lIn.:c~ llf error (hal l'llllid n:..... uh in 11l'~~lli\'l.' fc"IIHlval dlicielll'

ic:-. illl.;lude di~rurhilJll'c of hnllulll sl'dilill'llls dllrint! ...ampk col, k'12tiun anti 1IIltn.."llL'u flll\"s cnlt:ring th..: s~unrrin~ :1I\:a hdfl\V the ~ill knee. The TSS L'HIlL:Cl1ll':.lJioll.' or lndi\'iLiUlll .... unplt":-. wcrt.' n:p()f'h:t1 hy BalTcl1 cr .d, IllJ1)';bL

ThL' !!t'llcrally pOOl' rClIllivall:rlieieney uuriouh.'U to lilH;llilln c':tfl hI..' c\plaillcu My all anuly:.;i .... of the pill lick s.i/ .... Ill' IhL'

s~lmpks. Silt- .md day-slLcd partich..',,; lri.lrtil·k~ Willi dianh:'I('r:-.

Ie"" Ihan h2 tiTll) L·(lll.~ti(uh.::t1 Ihe majnrily lit" Ih\,., :--olid .... lulll.'l·!('d

1'111111 1111: pomJ ;'IIH.1 hdow (h .... sil' (...·IH:C. Th~ p.... r...·...:tH.;.,~'" (If .... ili alld dJ\'\ ran!..~....J from ()!"l to IlJ()fii-. with it nwdiall \-lillie lit j)h(:;. TOile prL'~I(lmin:.lncc of ~l1lall partH:k... in the samplc:-. 1:\ aliribUlahh: III the n'llun: 01 [hL' IlI\"'al :"'llil ;,tlHI 1t1 s~,.'tlkl1p. oj" the h1rgt:r p.-z[lick~ in lht' pOllds·hefore sWllrling. lh~ ..... ilr ;'1Jl.! cia} si/,cd panil"k~ remained ill ."llSPl·I~:...illl1 and WcrL· ahh: to pas:... lhwlIgh Ille :-;ill (t:ncl' bl'l'all~l' lhc diallll..'tcr:-. PI' tht...' pill·lide .....

wer,' ,mallcr Iha" rhe i\()S lIf lilt' lahri,'. The lLJrhidll,\ n:dItL'li(11l attr;hlllL:d lt~ IIH' ~ilt fclll'l':- \\"<1:-0 dek;l~

minctl hy l'lllllp~lri)lg L·OJ1l·cnlritlipll..... in th.." pond t..:r~alt·d n) till,' silt fcm:l: am! cUIlt..:tnlralion:- in :-;i.1ll1ph:- .... ellileded hdll\" thl;.' ,ill (enc...,. Thl: Il1I..~dian l\~nlO\'al for;.lll ;"~1I11rh."':,> \\'<l~ only 11

,(. \\jtll II stand;lnl dl'vi,alioll of It)q~. RClllll\ ~~ls ran~t'd in llla!!HiIUdl' frorn· .~~':~. hi ..I'Y::(. lncrL·a .... \,.·~ in lurhidity hel(,W till' tt.·lIlpl.lr~lr)"

conlrol (l'nc\,.' Wl'r\,.· li~d'y a H:s~lItIJr Uk' ~~unl.: sour...·(;,.'1 (If (,:n'Oj

Ih;d h:d (II nq;alive rL'rnllv~d:-.: for TSS Iil'Cau:"l' llIrhldily I~ Il

IUll...·tilln ur tht' l1ulllh...·r of slIlall p~lrtidt':-- in a ";'Imrle. IIIe:... L'

rl..':--ul"" are L'llIlSISIL'llt witll tile IiIl~iJl~ Ihal .111 01 till'rartide:...

ft,::rnainin~ ill "lISr~II.'i;Oll aho\"e..· tht.: .ft..'llL·t' are ."i1l1aliL'r thJn fh~

AOS l\l"thc r~lbri(; l"\tlbl"ql1cntly. lillie rL'dULlillll should b...· t...'\

pl:l"lt...'d.

Th...· ~~e,)t..::~tile.'.; u:o.l.:d III ~ilt-lt~Bc\'" app'iGlli(JtI~ {llkn ~(,.c l';IIktl

.. JilIl'r hlhric .... <'· 1-1. 1\\'I.:\'l·l'. l·Dlllpal'J:--(l1l III \\ ;1lL'f qual il y "i.lmple:

l·tilk(·l\,.'d til Ihl..' pond dln:'l'lly Ill'hind till..' fl'lll'C with thll'.;l' l'(II·

kd..-d inllllt:di'-.lll."l~ dll\...·nslr.... ;un Ill' 111L' rcrK:.? indit.:;'lkd dear!) Ih'l1 tiilr~Jlipn hy lhl' Llbric p);l~" link or 1111 rnk III ,h...· r\,.·dUL"lillll

PI" ..... lllid" Cllllll:ntnllil.lll:- ill t.·on:...lrudil,ln rllllOn. CIH1mh~Hh frrlnl ..... lIrc'"\"I~or~ lll' lll~ c(lIl'ltrll~·tilill pn'Jl't.:1 lIHh

ealt:d lhdl lIli.linh:l1,mL"c'of 1~l1lp{lrary L:1.l[llrlll~ "iJ~ 1I11( ,I L:on:-idl:'ratillTl They n·pllrr ....d rhat c\,.lnlroJ:.; w("rc r~movcd or l'1.·pl:lt.'cd

fr\"~lILlclllly ht.'callst...' or chal1g.inf!, cDnJitinn~ at 111l: l'llJlslrUl'lioll

:-;ilL'_ Sll LII~II mailllt·Il;JIILI.' wlIlIlJ ~ellklm nl" n.... ..:(lL·d. Hll\\,cvt:r,

....~Iriml~ illSlall\llllJll and l1lilinlt·n;,lnc ..... dchcii.·l1ne ..... Wltllh WLT\,."

C,Hl .... L" for (Olll'lTIl. werl' IHllt:d durin,?; Ihe liuraliol\ pf 1I1L' ."llIJ~.

The'ot' delkicncies inl·lwJcu inildeql.lah: I'uhnc SpItL·I..':"', failure In

L"DITt'U fence' J~II1l;I~C rcslllrin~ l"Wlr1 llvcrl0l'pinr IPOIHkd \val.... "

depth c'\(('t...'ding Ihl..' helghl llf the r':Il...·1..' I. hok:o in Ihl.' Llh,it:. in;\l_I~qu;JI\'" hll'·IIlS l fabnl" pttl)r!y "t.:cur",·d in Ih.... grulIlld I. and knce ..... dama~t...'d '-Illd parti.dly co\ erl'd hy till..' lt~1l1p()raf} pLLC\,.'1111..'111 of .'ill )c~ptle .....

These .'.;;IJ·fl.:rlcc ill.'-;I.:tJltujpn ..... \\'crc 11111 dc:"i~nt...'d as hydr:niliL' slrudlll't::o. hI aCL'{)lllllludalC I'UtloU· fl'urtl a rainfall t...'\t:rtl (II piJni ..:

ubI" rn:l_llh:':I\"'·~. ami faihl(·c:-- l·~I.U:-l·d hy \l~IIlI1lC:'" tlf nllhlfj thai t...'.\ ...·L·t...'dt'\IIII......:Jpacit)" "-'ere cornrnon. A n:lc:\hl.' around the end PI" a ,-,ill l"t.:Ilt.'t.' \\'~I:-- I)b~cl'\'cd ~ll OI1\,.' sirL'. and fJ\-'l:rtupplng..; al 1\\'\llllhl."l" ~ill::-' \"'· .... n: oh~ .... r\'l..'d. In all casl..'~. i:1l1.\iliary in:'Llllaliun" wert...' III rLiu: d()\\'lbtrL'al1l Itl ...·onlflll st':dill1t...'111 r~ka"'c.

Laboratory Tests of Silt Fences F1UIIlt, T~sts. Th,~ ~l.·diHlcnl-l"t:lI\\I\al p.... rrUn\l~1I1 ...·\,.· (II :...ill

I"l:'IIl.·\:s \\o~l"; iflvc.... ttgakd wldt...'1 clll1lrulkd olfldil;un..; ill all (lUI

door flume. \.1,)nilnriJl~ the:-L' d('\'it...'t...' .... in a Ihun\..' allowt...'d I..'tHllfOI

(,\·('r "lIdl \·ari.lnks as influent 110\\ rale ~llId TSS t.·oIlCl.:ntnlllO!l,

!\Il OUII,flllll flUIIlL' ill lhl.: Ct'lll~l' fur Rl':o'~i1fdl ill \Vakr RL'< .'iPIJrL:l.'S...\u'lill. Tl.:)'~\s. W'i:-; lI~cd " .... lht.' h.~ .... t bed for till..' .... l,d) "

Int...'III~L:(lnlrl)1 t..:.\pL"riIIlCllb, Till.? "1~l.'I tlun1l.' W:l~ (ll 111 11I1l~ with

a t.TlI'S ~l'cllun 0,7601 WlI..k allli O,h 111 lkcll. Tl1l' ..... Iopt.· 01" lht.·

l1u/Ilc \\~J:-' appHP.:illwrdy D.. tV·; .." IO~~'m ,~l!ld ami ~r;n'L'l bed Wa... lhl..'d tn :--imillah: ildd soil "'"OnJiliufls. The Ihin byt...'r llf

hlghl~ pcrn1l..'~lhk :...od all\\wl..'d ~'J1nc intlllralilln. ",hid, tr1i~~hl

hl..' C,\pL't..:lcd ill th...: lil'ld. TfK" llul11e and W;HCl ddl\l.·r~ "~.""I~~I\I lIst.·d fOI" fh ...' "'t.:'diIIll·nl-\.'OIHfi11 IC"I~ i" "Ill I\\' II ~dl\"·1\I~lli....alh ill

Fl~lIrt...' 2 . Bulk wall"!" \\:1 .... \.'irl..'lll;.tl ....d lhr()u~h lhe ek\-"'Ilcd water (anh.

111..';11 'hI.' hL'o:.ld (If fhe !JUIHl.·. The W;lfc..~r kV(;'1 ill ,hi ... 1'1Il1, W~I.""

";Ul"hLiclll to dri ... (' lhe ~inlUl.llt...'J runoff lhn1u!:!h JIll' miXing l.:lnk.

1111111 ...•. and .......din1l.·!]( cnlltrllb. \Valcl' rut each t........ t wa" drainL'd

(nlm rhe ..:1c\·~lh.:d tank (lH'r a V ·llllll'h ~\'I..·ir ~InJ illin trw rarid mJxiJll! t;JIlk JI rhl.· Iw~)(1 iii Ihe IllIJl1l..· ..-\ l"lllbralll IWild in lh .... dC\·~IIc-d wal .... r lank \\a" mainlJlIll.'d 10 pro\ ill ...' it LlIIl.\lanl 110\\ ratc t4\ Ihe rni,\ill,;! lanL TIll..' V~lhHdl \\'cir wa:o lI ....cd (ll 1rJ"':~I ... lIrt...' thl.' hulk W;'Ifc..'r inlllfl.'111 flo\\- rate III the !lum.... TIll' wcil \\;h

•.'alihratcd by fillin;? :J .... ('~Ikd :o.cclillil ~lr 11K' fluTlW .11 dill~rt.~nl

110\\' rill.... ~ amlllll}nilprill~ th\,.· rak Ill" l'hangl' ill tilt." \\'ll(\,.'j In·d

i

mt~~~~--~,··

Figure 2-Flume and testing apparatus.

COA Exhibit TF-7 Barrett Evaluation of Geotextiles SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Pa e 3 of8

• lUll

80

c

'" ]

..0

.U

~(I

\....:.- Sie\'e An3Iy"i~ .

. -e-llydromder An,]I\'5i~

-

IU 0.1 11.01

Figure 3-lnfluent particle size distribution.

I ht.: ,ill kllt.:l..'" were rl~IL·,,'d ill lh~ IIUlllL" at ;l di"lanCl: o( i ,h

III fn'l1l I Ill' llli~llJg tank. \ValL"r 1c\"~:I, III rhe tlllltll' \\'L~rc mul1l

lon:tl ll\'L'r flllll' alld u:-.cd tIl l,,;~dCllli.He /lo\\' r~ll~:" thrilug.h Ill..:

CtHlIrol.' hy lIlulLipliL'i.\tiD/I Ill' tht.:" pOlld :--urLIL'e ~tn:a 1.1: til,-, rare Ill' Lh~II1t;L' in thl' \\-'alt'l" ."lIlf~ll'l' k\"L'!. TIlL' filling pCliod Ill' tht: tl.'sl .... tllpped WIWfl 1,.'1111('1' Ih~ w<lkr k'\"t" 111 lhe tllllTlL' l'l';,chcd

0.15 III or till' "II.ILTy lallk \Va" cmptil..'d.

•

Tnf1 :'lljl t ·",wain ,"'ill) I.: lay I \\';1;-' lI .... cd 10 l,:I'..·ilk the sillllJlat('cl

rUllull. The ,.... (til \Va' ..... cn.:l.·ned 1I1rnugll;. irS sic\'\? (.11l1Illi bL'!PI\.'

bl,jng mixl'd \vllli watcr Ip makL" a _... lurfY, "'\pproximatl'ly II.){) L III the :-.Iurry wa:, constantly Illixl'd illlhl~ ShIlT) 101111-. and ..iraill\.:d

intll thl' rapiJ'lIli,\in~ tallk dUfin~ tJll~ 'illin~ j1pr!;un Df l·:!L·h It.::-.I. TIll: ",usrll'ndcd sDil ... lulT~ and hill" water \\·en.: Illi.\~d \lo'ith

J r(lLlr~ paJdle. Thl' ... IlIrI)" "'a:-. mi:\L:d wilh the hull.: w~\h:r HI

crC~itl' runorf with ~1I1 inl1l1cnl TSS l'III)LClllratinn of apprllxi,·

IHalely ~ oon Illg/L. whidl \\o·as In llw Ilppcr rallgc or TSS lon· (clllralilllh \lb;-,en'L'U in rUlltlll in Ill" lit:ld and is Ihe l'PIlCl'l1lra·

,i,," 11".'.1 in ,\ST~1 n :" 1-11 ,\TM·:; I Ie" melll"d IWyallt. I 'J'J, II.

TI1\"~ fUl1o,.f llowcd HllollJ:!.h ~\ ndflk wall intll tilt': IlUltlt,: ~lIHI

down hI thc "'Ldilll~nl cpntl'ol. Thc' I'csufrillg. pOI)1 of rllllllff

dr;lifll·d rhn1ugh ttlL' ;-,l'diIflCnl clIlllrol. aTllI IhL~ \\oakr !L'\·t·. in lIlt'

f1umL' Up;-,Il'l'alrl Ill' rhe "'l?dimenl ctllltrnl ... \Va...; Illollittln'" v./ilh

..Ill ISC.·U II.jlll'nln, Ncpr:J~k'll r~l:llrding Ilt)\\' I1Wlcf. Grah ~alll'

pk:-. (II' lilt' inllut'llt wcre tl.lkl..:l1 l'nllrl lhc Illi\ill.!:! lilU" dllrill~ IhL'

litlillg porliliO of L'J~h h:~l. On lilllL'J intL'rval...:. ..:rIlUL'.UI samplt.:~ \\crL' L"lJlkctcu UOWnSll\~ill11 I)r fIll' l'nlllfl.,1 dllrill~ lht' Idling and Jri.linill~ p\lrlh\lh nl each teS!.

i\ pilrtick -;il.L' gr~IJalit)JI 'lIlaly~i~ Wi.b performed on lhe :->olid:-. .... lI~pct1dL'J ill till' ... iIlH11~1,\,.'J runoff lIsed in fhe ttlllllt: rests. Prnl'L"

tlure, We'!"e r"lh>wed '" ""llined III ASTM D -122 "nd f) ~:"-I

j -\STM, ll)q~J. Tllc ~~lITlI'Ic~ WL're IIU:-.hL'd \Vifh di"lilkd \\o:'lIcT'

IhrPll~1l ;1 "crlt.::-. Dr ,'1it.'\ I..:S r;~llging in "ill' frolll 11~) hi .t1~{)()

(0.T2 to 0.075 lnll1J, and tIll; .... nlhJ~. rCTained 1l!1 c;lch Sil'h~ alld p;l:.... in~ tilL' IL~Otl :-.it:vl.: \\'-crc dried ;llld \·n~ig.hl·d t\ pi 'l"litlU llr

Table 1-Tested silt fence fabric properties.

AOS, sieve Type of fabric size, 1,m

BeHt,ll '-I.".1\I!.:1"I Inu (UUc)j

f.;(;(on ·f-/Il'J?n :,;::,0 ((jOO! M:rali I'Wlr,'NI'yH(1 IT lCJLI j1 ~':(11

AI fl()Ct) 'N11"'01l )120 (850i

•

tIll.: ...ulid..; lill~:r t!l;U\ lite #~IJ() ";lC\l~ \-\ i1:-i "'llh)l.·l:[L'U I' \ gri.ldatipil

;1Il;i1~"/;" h;' 1l.l'drt 11lI..:'tL'1'. Till' parlil'k- .. ill' ui:-.tr:hl/[j'lll ul lill·'... ldld ... ~1.I"p\~Il,kd in tit..: SilllllbtL'{,1 rlllloll i ... prl''''l.·ll1cd III h~

urt: _'.

Tltl' (:lian~l' ill 1'L'llltl\'al l'rfil:iefl(\ ~l\'el tilIll' W;.l:-. pb;..\~n l'd h~

running a ~~ri~'\ Ilf 11:... 1", IlJnlu~h lh~ -.:jt!l\t: ~'(\lllrol Filur t~IlL':-i til

~ilt kIlL·l'.., \\"L'rl' ~Ub.il·dcd t.. L'yL:ks or :-.imul'Hl'd rUllllfr cl·~·nL".

Pr{lpel1il'S or tht~ fahnc:-, a:-. rt'runl~d h~ lhl' lIlall\ll'~I(llJrlT:-; arl"

",ulllmaril.l'd tn Tahk I..-\n i.Hll..:lIlpl W.:\S made 10 delet"lllllll: lhl'

j1L'fe..;III·tllk·ll Url:'a l,f Ille \\1l\l:'11 bhriL:-' 1L::-.ll·d, TIll..' j1l·"L:L:HI-IlI'cn

~ll"l';1 1;-- 11IL: Pl:TCl·lltag\,.· L)f hHal LLhrie al\~~l Ihat l'an pa:-. ... \V.Ht-'r,

\\;11Ik' appan:nI'llpt~lliJlg ..;i/.l'· i:-, a IIlCa~llIl· ur lhc ... ilL" ut" Ihe

Ilfll'lllllg:-.. (nl"onnatilll\ un Ihl.';--c l.'haract~ri~liL';-- ;,dlll\\':, c:Jlt.:ula

linll l1f a.. ·lual I1U" \'\.·J(lcili\"~;-, Ihrough tilL: rJ.hnL"~ SpcclIlIens of ull IhL: \\P\'l'lI :-.ih·t'cnn· !";Ihnc... \101.:1"..: :-'l'~lnlh:d ilnd l·llpicd III

lI1il"rplidle: hll\\\,.'Vl·l. 1IIlly Ilit' ,.\'1111(11 ~ I'~) t~lhriL' had \\L'II

ddilled 01.lt.'llillg,;-,. rIll' magllilil'L! POI\~ Ilpl~l1illg;-, wen:: rnci.lstll\~·d

:11111 "W are;1 I)r "'-1 lid ... l·~tlL·lllat~d. Thrt.'L' .... GIIlS til' Ilw rahril' \\"t're

JlIi.uk IHl U hl;l ... aL:l'o,,:s thl' ..;;,pc..:-illll·n St) Ih~11 nl) \1111.:" warp lll"

we;!\ ~ \\'nulL! appl'ar lin jIlll ,tlwl" ~e'lIl. Till' ;I\"t;:rilgL' Pl.'I\'CIII-0l'l'n ~ll\~;[ rl)r three "can ... fir lhi:-. "~lhric wa, J.Y:";.

rhc Wal('r k\'cl LlrhlrL'alll oj thl~ controb \\1;1:-. mnnitnrL'(! lor

tIl\: durillllHl til cUdl llullll· 1t.:\L Chilltt~t.:" ill The !L'$'l lll' till'

pnllJeu wall'r ;--lIrl~Il'I.~ \\"L'l'l' l.'t1Il"'-I.'r1cd inln VOlllllk':- PI" rUllllff

r~l ....sillg \hn"j~h Ihe ~l'djlllCn( ClIlllrlll in a gi\'l~ll lilllc IIlfL'r\'al.

nw... c \·olunll" \\ r:fC uSl·..llt, l';d'-:ui:lt:,: dl'h:llliI111 linK', dl1UL:lll

....U:'rL·/hkd ...oliJ...; I~)ad, ~IIlJ TSS rl'lllu\'al l'I'ficil'IlL:~ for L:adl

lL'sl. In lit" lillin.s poltit"\f1 or lile Il':-'(. 11lL' inl'n'nh~mal vol!mll:'"

Illlwmg nul 1\( thL.' L"(\1lI1"1l1 Wl're cah.:ulall'd ~I;-' tilt, difh.:rcllL·c

11l'(\\('L'1l lhc \Illumt' 01 rundll guing lilt$ lhc tJUllll.' and lilL:

dWlIgc in \·IllumL.' \\ithin the tlulllL.' \lVt:r that lime inl\"'r\"~d

tkL:asit.'Il;t1ly, LdlnJiakd \"<lltll.'S III Ihest: \'(l1I1(IH::-. \\1..:1"1.' f1l.'galivl'

hcclIlI,";c Ill' ill;JccuI';tt.:y in thL' nh.::aSllr~mL"l1l~ Ilf thl:' lar~er in1111~111

I1n\\o rail'''.

()nc Ihulle tL'~l W\l,"" cunJuL:lt:d \Vilh Ilo L'PlIlrnl Je\'llT in tht.:

lIull1c The inlhll'IH Iln\\' nile \Vas lllalL'lll.'U III Ihat nr lhc ",hlWl~SI

lilliflf! ll'st III dl'll.'rminc the high..:-st n~I1l(l\'~d ~:.\rL"l."t~d Irolll s~dlTlWl1laTi(\1l ill rht' kSlin~' apP~lra(u" i.... l·lf. Sunil' "'l'lIllng \11" till'

"'U-.:rl·lllkU p,JrliLk· .... oL"t.:UITcd as till' runoff rih.,\,.'d frolTl Illl'

highl)- agilillcti 11li\in~ l:Jl1k !\) rhL' r~I~li\'e1y lJlllL'~l'enl HUIIK·.

Thi" rlll'jlllllWIlOII i... "imililf [II .... cdillll..'nl-I;)J~1I runoff I1tl\\'il1~

dilwil ;1 ~lllPL' in a lldJ al hl~h \'L'!pcily ScdimL'nt j., Jep"sik,'d

ill tht: loc 1)1" rill' "hlpL' when Ille .'!npe gradient ~lIld nWllrr \'L'lucil y lk'~:r\"'a~l.'. ,\ T."iS rt..:l!udioll Ill' J-It.~, \,V;'\~ ob....erv~d with

oW an) LOflln,1 ill llle llllltlL'

Flllw rale~ Ilh"l'(,\'l'd in tIlL' fhlrl'll' 1t:~fS n "hie ~ l \V('l"c aprro:\. iIllilh,:ly 2 order;-- 1\1" l11;1gniwdl' k ....... 111'-111 IIH; \ .. llIe ... I'l:p0l'l~d

11Y thL' 1I1:JIlUrad urL'1 ". Hl'COlll1J1cndl'J nnw r.. II\'s I)r II.~ Lilli' . ;-

r \V)';'III1. I fJx II :-..t:elll II) I't:'Ikcl al'llla" perforlllann:: bl'lkr 111;\Il /l1any t1~cd in \.:unt.'1ll pr:l~rit:L'. Tht.: plTlllinivicy Ih'll wtlulu pru~

Permittivit;', S ' reported/observed No. of tests

................_-_.._--- ....._-----_.----

G el'',) () r~)

G. \:'(: (J(l2 1.50 OOl);1

O.:.!,O (;12

Water Environment Rese;::uch, VUIUifll.-:' 7n f'lurnl;8[ :~

COA Exhibit TF-7 Barrett Evaluation of Geotextiles SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-Q612-MSW Page 4 of 8

• [-:;;]r'rr.U ui .Ii

Table 2-FJow per area of silt fence (Urn" sl as a function of head,

Head, m Belton woven Exxon woven

llUL't· till' nh",L'!\'L'd IJp\\ rate .... Wil,'-; ..' .... \Itllilled fllr ~adl 1)1 III .....

r~lhriL'_"', r\ 1.:l\l1Ip~tri;-"11l o( rcp"rLeJ ;lIId e,\lillli.llt'U pL'rmitl!\'itil:"

I" ~h'l\\11 in T:lblL' I t\·hlt:l, ot the Jinert':I1L'~ h~Iv.'et'll IllC~lsurL'd lUll! prct!ll.:tcu I"lll\\

raiL':- i" l'UlI"cd hy ..;cuilllcnt L'I()~gil1g the fi..lbric OPCIlt!lg.~ TIlt•.: \\,p\'l:.'n i\.lirali rahriL' ex.hihilt:.'d ....uch L1t}~~in~ aft ..T a ..;criL" .... 01

lc .... ts \\dll dCiJll \\:akl' Ipr~)h~hly fnJlll :~(ltl'~ 01 the .... andl In sUhSt:LjLll:nt Illllll~ h:~h. till,.' L:lhrlC hd1il\t.-'d a ... if II \\Cll' dogb'cd

I"rPIlI the: bcginlllll;;. llli ~ .... ample \\a:-. dc.... igll.lIL·d i\[;rali i\. ~lIId

nnufhcr si.t111pk. rVlirali B. "'as pli.Il.:cd in lhL' llull1c III ~dl(l\\

(lb:-.~r\"lttLlJl lit' Il1l~ pC'rf\lrrn;llll:~: \ll dean fnbriL' RUllOI r did /101 l1ow.lhnlugh appT(J\illli.llr:ly .:! elTl "r I IlL" upper p1lnillll ... 0/ tilL'

silt··fL'lleL' J""hnf":",, Juril1:; thL' 11.::"';1.',. TIll" hclw\ !(Ir "bo \\ a." nolil:L'd

h~ l'rc\lh" Il'iXX I i" hi" experiments I krL~lllllln time .... were caklllalt.:J !"()l each ll"q (II' lhc ~ill

rl'llLT"'. All a\'lT~l~(" deTeJlllon lime. 1'",.". \\":, ... llcll'rminnl IIlI

each illlTcllwnlal VP(UIl11:: 01 TUJlOn ra ... sin,;.: lhroul!h Ilw l·nnlnl!...

in a .'·'lllinUll' pt.'ri(ld (.:3. V" A V()\UJIIL'-VI'·L'ig.lltL'f,! dClL'nlt(Jl} lilflC,

7!, 1'111' c;ldl h..'st ""·a:-. cakul<l1cd a.... ridhl\\."':

• T, ~\,'

hach (If Iht~ 1~."'I:-' "\ a~ lUll hIT 4:;; hnur"; 1·!i.I\...·C\ t'L ill "llmll' l'a"'C~

the rlllHlfl h'lll !Iol 1'1IrnpklL'ly Jrainl'u thnll.t~h !hL' ~j/I·knn.'

f.d.wiL: .... Th..: water kvd..; artcr thiS lin.l~.' were apprtlxll11<1Ii..~d wlLh :l linear fundHHl. TilL: rL'."illH"i or a lypiL:i.d k~l and the proJL'cted lilll~ In L'"OlllpklL'" ur~llllat!c whl.:':n: runllil n:nJ~litlcd in'the 1l11llle

l(l,,~cr Ihan .t~ IUllll"" tire prl'~t.::nlcd III f\glll"C 4. The tillll' l'lIr

11lL' l1ulI\I: In dr~lIl1 \.'umph.'k'ly wa..; c.... rill1atcd (i I he appro\ illl~tl('l~

=' d.ly .... f7 2()(J lllillUlt'i'>' hy t'XIT~IJllll.llioll JinearJ!' frotll Ihe I..J:-.l fl'\\-' dal'l p~,inb. ThL' TSS l'(ITIL'elllraliorl"> aflL'r 4~ hnurs \\l'n,;' IYPlc~dly IIcar lcrll: thcn.:fllrl'. ~alllplt.:... tal...~n at'ter .... X hl)lll'S h.ld

1111 l=1lct:1 llll i,.'ulcL":'ltcd TSS removal l~n,l'icll~;ics,

The f,ln",;cfvc.;dTSS n':1111.lval Cl'hCIL'lll'y r::IIl,~L" III('an, IIH.:Jiall,

milt sland::II'J JL'Vi::'ltioll I'lll ~~\l'h ... lIt ftllct.' are prt':,,>t'nted ill I'able

0.40 ,-------,._-'---------, 0.35 -+- Ob~er \let!

-a- bLim,Het!OW

1I.~5

~ o.~u. j [} 15

o.In

(/.ll"

0.011

14qO '2Nhtl -H20 C;76iJ nOli

Tlnl(', min

Figure 4-0bserved levels during a flume test and the extrapolated time for complete drainage,

Mirafi B nonwoven Amoco woven "-------~'-"-,-----'---------,

(J :,CJ ( •4 ] r, ~" 11,]'

,------,-----

3, HeIllP\;!1 L'ftj(.'ll.,.'l1l'h.~." w.:J'e h~ISL'd tlll !nlluL'.llI and l~mLll'nt

"lI~p~ndL't1"'tllJd... mas ... l(laJ" Jnd were 11111 ~,d.lll."IL·d ((I ;tL·t:clllnl

for thL' .l4'-;., r('r1Hwul,hal OL·,~"lI"fi.·d in Ihl= f"lUJlll~ \\lth!1o L'f.lIltI"I,1

JJhl~dled, Tilt' hi!!h~SI removal l.'Hicicncie'l \\ crt' nh"LT\ ~d lor thL' ll(ln\\'I\\-L't\ ~..1ifah filnrlL:. Th\;-. fahri ' ",,",0 h.\\1 \hc $1\... L:.';~

Ho\\' r~ltc." :Jlld 11ll' !(lll.\'!l' .... t udL'ntiOIl liIllL· ul' IIIL' f.:lhll l ·" [('..;lcd

Thl' rd~lIil\l1ship hclv"l:cn u.CICI1IU l !l \illlL and TSS rCITIIl\i1lertJ

Cll'IH.:~ l'll'..:'<lch Ie'sll" ,!JOWll in FigUI'L'';;; A ci.IITcbliu!l hl'l\\'l'l'lI

7", aJlu TSS rCIlHl\al cflil·Ie/h..') is appan:nl. l.O\VL''- no"'. laLL'~

resull in itt(,;n:a~ed Lll.;'l·cnli~ln timc~ and S$tlt\" rClllP\al Cfhl::1CHn

The r\liraii r~lhril' rrmluL:cd l\lfl~t'r dett.'lIlil.\ll lillIe" thall Lr"li.: Piller l;lbrlc"i in (l1i:-. seric'''i 1-"1' L~'''lts ("\'eo thotJ~h thl,"i Jahric h:H.l

thl' higllL'"SI n:rnnl..:d pL'rmilli\'II~ fT~lhk II. Thl"i t'ahflL' id:-.t1 haJ tile srn,dfe,,[ A( )S, l"iug,l!e;-'Il!l~' tll,II·L'IIlg'g1ll.~.! Ill' ,Ill' fahriL' \\ IIIl ......:dilHl..:H\ W;'\S r~\)p(\ns~hk ('{Il" lhi.? lInL'xpc"':\l~d hydrauhc pC'rrnl

1ll~II1L'L' Thl" nh"Cr\'alhlll di..'nl(J1i ... lr<lh.~"i Ihal fil'ld p,:rfurlllanL't

111(1) IH\I h l, di..'tL'rutil1~d l'r\lnl l'l1lTt.:nl P~H~lllk'tL'r" U"t'd u, l'hill"ih.:

lei i/c IIIL' h~·Jrauli...: prllpcnil:." 01 llll.:' .... l: I"ahril'."i.

In Flt!lllC k the ddt'nlilln tillW .... with IC"ipl'L:1 1(1 IIlL' lime It!

l\:'·;llllg J.rc pn.'~~ntL'd I'm, ~adi \c~\. The ri.llnl"i.1U d.H.l lrorn ~I

nearl") IlHJI1itormf,! ."tal.iuli ~i1'''tl "l1l~ pliltlL'"d, \VllL'll llw "l.. ,iL' .... PI'

11..:'';1... or all indi\ idll.al ;-oil!. "CIlL"t' an;, CUmpi.II"l:J, ~uh"..:qLJL'1l1 li..' .... h

"Ihl\\' an ini..."'t'a:-.c ill the dctClllilltl (inll..", Thi.:., pl1~lltllllClh)1l is

likd.\· L':JII ...ed hy scdinlL'nl :lL'ulfllldatJng ill thL" ranriL. III lltl'" neill, lhi:-. dugg:ing dl~i..'\ may hL' m\ln~ prDllUlIlll"ed hLL'all"'L~ or L:OllS{I"UClillll anJ Ir;'ll"lk Jl:hri~ 19ra",..;, paper. r1a"ilic. and ~u

lul111" TL'..;t:. llll WII\('11 LJbnv's thai \\~Il:' fI.lll \"illll,lut ::1 1ll"IIH

r.ainJ:lll cn:nt oL'l'un.. iJl~ in"lle ilJ(\.'rv.t1 all shp\\" thi" heha\'It'») Afici Illajl)r ,.ailll~l1J :.:\l:flh, dt'lenli(m tiIl1t:'" dn'rr:a·:L.:d (I{' till'

\VP\l'll I'ahrit.: ..... Till" \lhsC'natillO ."Ug;::'L' .... J..; lha\ 'l'dillll:1I11!l,11 had at.:unlllll::ll~d III Lilt' 1,1, U\"LTI ~jlt-rcncL' fithrit.:,,, WH" \\ t",h~d (If!

rl= .... ullil1~ ill illu\.:a"lt.'d Jt(l\\' ral~."" Th~ \\'(\\"t:n Heltol\ lilhric L'\

hibilt:d Jelt.'lllip'n lillle"s on t\-lay ·t and JUIIL' 7 L'i() alld 60 llIilllltl~".

!'(:spl.'cli\'c!y) LJllitt.: ... illlilaJ III tilt' Initial JL'lt,·IHIUII Wilt' Ilh',L'1\nl

IOU •• :l 11(1 .....: •• • • •

4

C d •

'b c .. -.!--j c • • fJ/1 .• lklt(ln ....

• Exwn w'" ~ .0 • •• .Mlr.l!i /\nw•€ • A M.;r,lli nn .... it.

Cl"trHl••:",.'J. .~(Ir./':'.. .RJJo..J Berm

'0 Iflllt,II']

Figure 5-Total suspended solids removal efficiency as a function of detention time (w woven and nw nonwoven),

• COA Exhibit TF-7 Barrell Evaluation of Geotextiles SOAH Docket No, 582-08-2186 TCEQ Docket No, 2006-0612-MSW Page 5 of 8

• Table 3-Total suspended solids removal efficiencies, %. ---_.

Control Mean Median

D!:!lli.'f"I \:'It,.·/erl

C.X V.~·!f) ";'.. U./t.'1)

~J,ir;:lrj Ililn"f','f1'.fl)r:

P·.'II'.I-:"'U '1,/( 'I'l"',n

llil April II I~X llIinll(C~l. I'hi~ \,a~hi,,~ tlr Ill;,: r~lbrif".· lllay al,p

'If...'l:lIr II) till..' 1i~ld wll .... 11 raillf:tli pr{_'c~'dt'" Ilk' pOl1ding HI rLllllJn

f~i\llIt;dl diJ llfll "'CL'm 10 atlL'I..:f thl.:.' Ill)'''' rw~ lh"\'lI~h [ilL' IhillW{l

q:n Llhri~' I.'\ugu .... , x) T1h: n(J1I\\(l\'~n LlhriL' ~l·,... mcd In ha\l.'

rL'!'IlIll'd 1l\II'.....• nl dlL' lfi.lprl('li "'l~'dimt'nI ill (hL' Ihn:e·Jilllcn..;i()t1~lI

... trlll:lllr~, \,hL'rL'll \\'i..l:-' 1IIll a ... l'a,ily 1\~l1ll)\'..:d hy rai(lfl.llll.:\~llt:-.

P~rlJlc~lIl1cfcr Tesls. Sampll:"; \,f :-.jll~f~lll·L' {ahril Iv ..... rc '1Ih1f".'L'lL"d hI l:lll1 .... lanl~hl:ad pcnllt'ability ll·..... C~ bL·,.:~1U:-'L· of thi: e\·

(fl.'lndy hJ\v tluw raf.:s I)h~l'n"l'J in tb ..~ IlUIllC tC~IS. Pl'rl1leaTn~lcr

le~ls p(,flllilh:d ~l gr~alt?r insighl into till' hydr;.wli(' hehavior lJI

..;iJl-ft.'llCl: Ldll'il\"i Ih~1Il did tlulUl.: t~SI.'i. Till: rdalilHlShip Ix'{wL'l'll

IH:i1d JoJ lit IW raIl: \\'a." IlhHt appar\:1ll hc~alJ:-.t' l'l)II,,-l.ltll hL'~ll.h

\\cre: 11.... \.:1..1 ;lnd (I v,/ilk'l" raogl".' pf head.. Wl".'I"L· pll.r.;.:-ihk.

•

Thr::c s~L1npk'~ \\.l.:.'IC dHl...ell J"rollllhl.' Llhric.. IL'stcd ill thl' IIUllh..'

1\ Jll{ldilh.:d ';,Ii! p\..'nnc.llllt:lL:r allllVt\..'d the Ilil\\.· ri.II\.~~ hi h\.., JdL'r

Illlll~d for hc·:lll., \If (I.O.~. 0_1. 11.2. (1..1. O.-t O..'i. all" 0.1> III Th~

,.\STM () ~4'l1 k<l I NiT"!. 1')92) i" rlIll ;II a Il~"d "I O.O~ Ill.

\\'hik' ... ill lelll·;'" in Ill\..' tidd C;}11 l"."qx:riclll:l..' ht~~lds III up lu tJ.()

Ill. Th(' Pl'rlll~:lIl\~(er initially W.I:-. ,t'l up 1(1 nUl nlfl~tanl·hl.:~ld

h..'>,I .... \':ilh :t ~·1~,rripl IU'-"IC. The lirs.1 trial test, \\.·itll sill-lcJIL'c {~lhriL·

ill lieLi of ~I L:olunm of ...nil dr~linl:J too mpidly. TIll.' tlnw thf\llIgh Ill\..' lahric \1,,-':1' ....n Illrhuk'nt iJlltJ r,tpid th;,ll errors in liming the !l".'st

\"'·t:r..• tl\·tT\~.. hl'll1lillg. This ..... itU:LliClIl \V;:IS 1\.·I1lt::dit:d by thl.? fahril.:~I

tinnllr 1\\" :--l<linh.:ss :"ll.'d pli,ll\..'~ lhal I"l·dlll..:cd til\..' dimn~",:r l,f Ihl'

"'pt:l'illl\.::n lrom 15.2 l.:1l1 hi ~.)4 \..'111. Til..: columll \Vas Illodilil.:d

h~ dj:--\..·\lnn~\..·tlng IhL: (\;brrint tuhe and ill~l:Jllll1g a Wall·" supply ~,'ntnllkd hy :J Ill:l.'dk· \'i1h'~. The~t..· Illlluitit::Jlilln~ alillwed. a fine adjtl"'IIIlI,,~Jlllll the On\\' rati.:.'~ (lilt..! r~lt.:ilil.U~J ~llUII"'lallt hL":ld 'durill~

'll\..' £\,,':--h The 1I111Jili::d ..nil pt'nnl".'l1ll1':k~r with 1111~r f;lhril".' 'pl.:ci· ml'n insr.dh:d i~ illll:~tr;tleJ in Fig,llrc 7.

DUI ,n~~ k~tillg, IhL: .....d" 1..' W;,I.... ildjuSIl:d until a "\h:ad.,,·,tak

IlI'1,,\' rail." w:, ... ;:\l".'hic\ eJ at lht: ~pcL'iticd hl:ad. 1\ I'Pll1aill\..·r 01 kill 1\1" t1 \'nIUIIll: \Va.... plill'c.:J hl..'lIcalh lhl: Ji..;chargc frolll fht, 1,.'01

1111111, ;lnd rh~~ linK' rcquil'\~d III lill Iht: l.:oIlIJin..... r \\' ..1:> 1'\..'I..'un.k'u

Figure 6-Detention times as a function of testing schedule.

•

Standard deviation Range

II

....................-----

l:::Jkch nf L'lllr:lilll.·l1 air 1111 How IhrmJgh a ~.!"t'IHc\{ik \\-l'fC d\..'ll'r lIlint'J h~ using 1\\'11 .... t...[ ..... t)f I~:-.t, (n PII\..' Il~.'L Ihl:' :llr v.as l"l'lIh1\·t..,d rrom the r..Jhri('~ hy applklllinn nl" a ~·;.Jt..'llllill hefon: c:ll.:h dl;lllgt..'

ill ll\..'ad. \Villl.'f \\~L'" dri.I\\/l th,.pu~h thL' fahrlc hcrilrl~ lilt..' k~t

\\'ith a ltnsl".· CPlllh.'t.'(cd 1\) a vacuurn 1"l~lsk hI "~TllO\'l~ ;In) trapp,..'J

air frilm Ill\..' fahriL:. In lht.: olher It'S!. Jhl: sarnpks \\'t,:r~ 111)1 \·at..'lIl1T1lcd. rtlr t.'aL'h Dr lhrt.'t.' fahri\..· "iamplr.:-.. C\\,o IcSt.... 1.\ Lrl' run:

un..... \\·iLh and nlll~ wiillOLiI applicitlillll of a \·at..lltlill In Ill\..' fahric "pcl'll1lt:n". Con~ralll ht.!~ld .... \· .. lriL'd frolll 0.0." (() O.h m.

Thl~ p~:nllifti\ lIit:s t 1[' I (lh:-;~~n'cd in lht.:' lc ... ts. ~tl heaJ...; of 0.0:'

III Wl.'rl· ll( thl.:' :'><In1(, orlk'r or l1laglllfud ..... hUl shghlly grl':tll.'!' 111 .. 111

!Ill" pL'rnlilli\I[LL'S rep1lncd hy Ihe Illallllral,.'WrCr,,, I:"cL' T~lblL' .~)

Thi~. llt.)~t.'r\';lli()n l1l;1y ha\'~ be~1l tht.' resull or s.... :-.tL'f1l~Hic diner·

~IIU:' h<:IIWCII Ih~ pe"nC'lIl1dcr lc',1 :1I1J AST~I D 4-1') I '\ IYPll'~11 plLlI tlf !low r:llc \'cr",!'" head i .... pn:~\..'lltl.:d ill Figure H

l'lll..... \.., d~I~1 J\..'lIllillslfatl".' a nOl1lill~ar rd;llipn:-lli[1 tX'lwt..'t:'n 11,1\\

rah.· allJ 11l:;.,d. rh~ b~:-.t~lil L'lIuali(}ll~ relating tlo\\ 10 hl.:':ld :-.ho\.\"

111<11 11\1"" i...; H row~:1' fUIlCli'UI 01 hC;IJ wilh C\pllnl:llt ... L.lnging II'<"n ()-1h 1" () 71 .

rlk q:lnuly lhl'tlllgh lhL' /\IlHI.....n 1125 fahril".' dunn,:! thl..· pl..'" Illl'ailh-:-rcr Lt· .... l Wil!'i calculah.:d 11."lin~ Equ<llinn .~.

(!1'""'=

.-\,

Wh~r~

l' ~ vc!pl".·il\". 111/.... :

(..J pt:nlle:II11\..·ll.:r ilnw rail.:. III (/ ... , and

A -:- IOlal area (If Ilpt:nings ill lhe lahril· "'[1l'l'iHll".'n, m'

THead

1 Fabric Specimen

Figure 7-Modified soil permeameter.

Water Environment Research, lJoltlnllC: 7~:, I,JllIl1tJ,u( ,1

COA Exhibit TF·7 Barrett Evaluation of Geotextiles SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 6 of 8

• Table 4-Comparison 01 '1' lor three fabrics using a permeameter (h - 0.05 mI.

Fabrics (not ASTM D 4491 Permeameter vacuumed) "'.. "'. S 1--_...__.._---- .......•_--_ .•.._-

I', All In,-D ',\<jvGrl 02 DHJli)j ~ ·~'.'C)ll0' \ O-l 0.[7

Thl: hllal arL'~1 01 011l'llill~s i .... lhl: produl...·' PI' tilL' ~pel·ill1en ~In.:~l

,IUd lhc fril<.:I;on ~)i ll""1.:n art:a (0.0.-;:1,1.

The Ih")'lItlld~ tlllll1hL'r I'llI' L':ldl tL- ..;L I"lh.: \\;j", cakulall:J frolll

RI' :=.

l' .~

d .~ {' :::: IJ

Rl:YIl(lld ... nUlIlber. \'~h 'l"il\ 1"'1" t..';,\l;!1 I~sl. 111/s;

pl)fl' di#;:JrIlc-ll'r IX5fl 'x' In I· Ifll:

density nf W;'IILT: lind dynamic \'1,cu~It).

ThL' 1<,-=\ 111\I<..Is numhers call,.:lll~lh:d an..' ...;111)\\,11 III Tahk ~

• The ~'\STi\1 IIlcrhDl! ~"'''''lIllll'' lhiJl 111,1\\ i.1.; laminar {fhill 1:--.

\·j:-;cuu,"o l'fTt'L'I.' ~lulllinaLe1. l!l,:rl"!'lll\':. the llu\.\' !"llL: ~Il\lllid he a

linl.'~lr fUI1L"litlll t..lt the head ~L·.\pl\llent cLjual hI I l. It" ilh:ni,11

force.... dOfllinnh: lturhu)clll l}(l\n. th~ J1&'I\'I.' nate shplIld be ;1 fUnL"'

lic)1l of thl' ~quan: nlllt or the 11..'aJ 'I iiI,;.' {bt;J llll~crv ...d 1~lr [hl'

rcrrllCallldCI' ll:Sls ..;110\\1 thai ttll...' aL:'lll~d dl'aillagt.:' hdl~l\'i(J1' 11<:.\

";Ol1lt·wJa-n.' hl'IWL·l·" Ihl::'l' r...... ll L:OJ'iL· .... 'rhe dr;dnag....• "t:rf,lnllann:'

illll"lr;jl~d in ri~un: 4 al....D L'Plllirnh this h<:ha\'lor Al IhL' Ill\\

11~",h IN'J ill i\ST~f D ·\..191 ,If) \(\ 7) 1111111. Iii,' rdalio'hl1il' IWl\o\'L'CIl JJnw rall.' and head could he aplw\'1\illlaIL'd hy a lil1l:~lr

rllll~:tiOIl

Conclusions and Recommendations Field l'\'::iluautlll pi ,hl' L,niciclll::'- {II "ill l'...·llrl.':-; in rL'llltl\'ill~

,,\L'dilllt=lJt III rUlloff frolll high\""~j)- I.:tlllqI'U,,·Uilll sill.:~ :"IWV,l.'d tlt;ll

rL'IlIII\':!1 \\'~I" nol :mrrhlll:Jhk l(lliltr~lIhul hy th;: flJbriL·. Rl.:lTUH·;11

W;.I'" thl' n:slIlt ut" rarti...:h: :-'~lIling hut was Ilnl quanliliL'd in thL' tidd ptlrlitHl ut' lh~ Iud). Tilt' llIedian tOlH':l.:nlraliofl or ';\I1iu:-;

Ji:-.ch:Jrct'd fn)1ll the ilt-klKL' conlrllb was i1ppr(lximat\.·h :,nn I1IL~/L. l'hi ... L'OnL'~nll'~llllll i ... :-:igllilic,mlly lowl:1' 'hall llll' 3 OliO 1ll~/L PI' rss Ill'tt.'ll reponed ill L·ofl."truclillll 1'1Innff ;lIh.t sHg~ ...~~t:-.

.'J ~

5 30

~ ~fl<

~ c. ~ 'II c Li:

r O' ~2 12ZXu ~(':

R!=O.lJ9S1

V-01 (l.2 0,3 04 OJ

Level. III

Figllre 8-Flow versus head for Belton woven fabric.

•

Table 5-Velocities and Reynolds number (Re) for flow through Amoco woven fabric.

Head. m Velocity, mls Re --------_.._--

():-,·.l

l.CJ

1.4 1>1 1 G1n

1 p·rn " 'I ~) OArl

2.G

~1WJ~~'i~~.~a:~·{~~~~~~:rr:~, s:~'..1~ia'k~~M~;~~fl:}f~~::~j~~~~~~~~~..,

·f;> lCtlll: ... lik .... i/f kn...:c ... prll\'t,:J t'l bl' il\l.:n(',,·(i\~ ill rl'dll"'ill~

turnidi,y ThL' partidt· ... rcspon~ibk tor crl:l.lling llll'hidily Were nJainl~ silt and day-si/,t:'d (palliL'l~ di~U1ll'kr k"i" Ihall (12 ,Lim ,I

<Ind ;.III (lrdl~r (If f1l;I~,~n;lml~ sl1Ialk,. lhon Ihe .\i/~ uf ehc opcnin:;....

ill the Lthr;,' [approximatel, ()()() 11m). Til" o",~ned .1"(;1 indio valL'd that "ill- ;Ind ehly .. ..;i7eJ partir"::.. L·(lll:'.tilUll.'d tl2.r:r.; Ill' lilt::

TSS rhL':-'L' pan;,:!..·, also h';lh' vcry 1rJ\\ sdlling \·dol".'iliL''' and L'OIbL'(lIlcntJ~ a1'...' nlll remll\'cd P)' "il'dllllL'r1li.llinn.4Q1.~~..:.j

uj;.<;i~"'l.">Il ...........b..""·""'il..IlI,,,Mld-ser.m,,",,)-.Jere>lll,maiH""""" ~1.:.Jw...:oll"'bl!Jl},I.:.Uj:·lho'FlIO"ff·hehtm"r+>to.ot'H,,",,)I"""he"<leren·',

liull"1'im"'...'.el'ln!l'<lflert-t>y"fl!...g ..,"I,,~..ll"""f'~tre""",.ffl1~ .. ,1l¥..Iri.\lllli:"llr;Qp"rlie£,uJ..LI,""'-..b[i.:. ,.L..\\i1'Il ........ I1......nt·t~••". "In~.-

All\)t1llgh projl:cl Sllr~n;l~lIr, Illlted Ih~l Iiuk llli.linlL·lIalll'I;· "I'

L'\lJ)trol" \\a~ r...'quin.:d. IlUI1H::nlU:-. illstalkHiol1 ~l1ld lllaiIlICnal1l'l'

ddiL·;eIlL·;l,· ... "'ere 1l0h.'U duri",:! till' -,Iudy. Hille... in Ihe t':lhrll

and in,lIlt'ljU:lll' hl(:-·ill;" thal rl.!:-.ullL'U in 1I111lcrnlll" I WaleI' 1111\\

hL'n~~l1h (abriL' thaI i~ not sL'L'lIn.·L1 10 thl: gr(lUlldl n.:dtll:cd Ihl'

t!...·k·nlinll lim.... uvailahk I'DI' P~lrl;L'1e sL'IlJing. III adJilll)'l. lilL' ui;-.charge n.:k~L."'L'J tllnlllgh lilt' llpl:ning.s n.'sulll,;.·u in a nllll"l'11

traled /1ow Ih~J1 prnrlll\lt'd l~rl\:\i\1ll heln\\' l!Ie ~Iruetlln..' alit! rv

~lIllL'u in ~I")l'f ...·;n:u;liJll; in lht' pl'lntkd ~lrl'<I. The.... L· nWiIlLL'n;JI)LT

pn1hklll:" Illil)' ;-.igllill...:al1tl~ Teuun' llic sL'Jill1~nl rt.'lIhl\·al ~ITL:l"

Ii \'1.·IlL'S~ 01 lill.· ... l· l,.·ontrpl:\.

High "'l"'djHlL~nl fL'IIIO\'al Llliul,.'nnl·.... \\'('fl' adlIL·\'I.'U wi!h .... llt

knt.: ...·... III thr: llllllle 'Iudie'. Th~ g~t 111I~.. try of lhl.· 1l1iTlIL' LT~~ltl.'d

a largL: ponded an:a hdlilltJ lllr: 1.'0111"01,.... rl.':"ultin.;; ill lput: (holCIl

lillll lilJK· ...; ~lI1d :>i~lliIiLIIJ' pilrljt'k st:ltlillg. t:'\'~Jl with llll: tint:FI ailwd ...t'dillk·nl u~~J ill thl.~ lI.,:sb. \1t:ill\ ,;(,:dilllC'lll rt.·lll!l\ ~L1

.... rllck:nL·y in lhl,,:' tlLJlllL· ral1,I.~~d from 6~ {•. I (JUe;, :l!IJ IX;I:" cnlTl'

la\;,:d ",ilh Iht: delL'llIioJl time PI' th(.· rUllllfl' This oh...en';llillll

illdicilk ... that ."ill ren ...·~:-; should he ..;ilcd 11) lht' lidd 10 !ll~I'"ilTllll.'

lh~ plllldt.'li \·,dlllllc h~liind tilt, l'eJlI,'l'. Unt'(IftUllal('!:V. IflL' TSS

L'I,nct:nlralinn ill Ulll ... Lrlll'llnn rune)!T i..; high uYJ'lc.t1ly .' UOIl

mg/L or gre~llL'rJ :--f) lhat rCnll Ivai lll' i:l~ much ~I:-- 7Y:~' of 111(' .......'tll 1111.'1)1 ';lin It.·:l\'l:'" (;lr:;L' lJuautilie ... in 11ll' di..;dwr~c (7:'0 1l1~~/I.).

ptltenliiJlIy k~;ldil1g StlnlC oh:-,cl\'cr:-. II) lJlIl~,"'linll lilt' lIsefulnL·:.; .... (II' Ihc.:.· ... c Jevii.'c:-,.

H)draulil' pLrt'orlllann.: PI' t'ahriL·s ill the (idd I.·JIlIHH hI.:' dCIl.:r

millL'd frt\llll:urrl.·nl par:'llllclers used 10 t.'hurarLcrllt llll.:ir prupl:r·

Iic '•. &wm(}nt;.t:ulell>Wilol'f-t1o......~ale·,""thT~)lI ~~rhFt'!;m1f\l'~'\{"c1t"

~UfiI"~d'~,.lI;.;."""''''".lh,lS ....~)';;iC'ft1W''''fit'FtIit'W4'l.l IMc:I.~uht"'t~i'itge,,~~lrZ..;,. Tile tlo\\' raiL' or a ~L'dill)t'lll ~lufT~

thnlll~iJ g'.l'''l~.\lik r~IIL'l;.·'" i:- i.l rllm.:lilllt.,r ,l\(}S a... \\'ell " ... pl,,:'{

COA Exhibit TF-7 Barrett Evaluation of Geotextiles SOAH Docket No, 582-08-2186 TCEQ Docket No, 2006-Q612-MSW Page 7 of 8

• Illllli'il.\ (In ~llilcr lJll:a:-.lIl"i.:' llf L"kan \\'atL'J' Illi\\ r~lh::i I The References \ll1L·lit.:~ln Publl:': HL:~t1(h ..\.":-11.... 1<1111111 .. \llll'rlC-1II W~IIL:r \\"·.nh." \~,:-(l"':laLihn ....· (11~ll had thl' Ipn~L''''l JL'tL'1I1illll llUll''-; in tll1~ ....:elle ..... ill' IlUllh...

ti,;";'(' had I Ill' hi~hc"l n:p\lrL ...:J pl'rlllluj,ity 11.5" I). but It al...,u h"d Ih,' 'll1all",I\()~ 11511 lin". ~~ge;mn1PlnUt"'er'tfg'gtllg,,,,,f

i<Il,,".lahrn."wirlr',edirtlen!l'affetletl.mC;;'h\7iffiinffG''fli!n.Wffl~lfeel''

'rL'~h uf",Jll-li:ncl' r.lllliv-. ill a IlHldilicd pl:r1lll'~IIl1l:IC" ,huwcd lhal !'hnv r~lh:" Ihr{ltL~~h lht' Lthril W\..'rl,;." nl.!{ lillL'~II'ly rd~ll,-=d In

II,'"J. "s i, ;'''lllncd in Ille '!'ST"I dctinilHll1. '1'1,;, di,ercpallcv rl'."ulI ...'d from llJrblllcnl 110\\" [hf(llI~h lhl;;" l"abrj(s .11 high hL':.u.b.

)iclJing IllllL'h l'l\\':1" 1111,.... rate,"'. DL'\'l'1oplllt.:lit pf :1 n~\" IL'sl or '1L'ric.'" dl Il.:'sl'l III L'hi.,rilctL'l"I/L'

lhl~ t.:\pL'lh..'d rcrfurJllaJlCl:' nf ~L;url'Xt1k bhrh:~ \\'hL'n u:'>..:d a." "Iii k'nL:I".':-' i~ Ill:c~kd_ Thl: \h(, \\1 curn:11I pi.lr.tnh.~tL'r...; fl::-.Ul1s ill

an ('\'l:n:'~lilll;UL' or the ,I/('a PI' a "ill: from Whldl Ill\..' 1l1Ilt,,'r Gin

hL' In:.1ICll WlIllplIltWCrlllpping. Knll\\ IL'dgl' or IIIL' pt:rl"c'nn'lI1L"\: ulllkr held cnnditilln~ \\Puld alltl\\' Illl' dCVt'lllPIllCI1I (II' r:llion,,1

~Hid('IIllC:-' !!llh'nllng ilh~ pIaL'L'IlIt:111 ol' Iht:se I".'(llltrob. TI.'.";Jill~

nl" l""hr;L::-' lbll1~ s~dil1ll.:I\l-~i/.l· Ili."lrihulinl1o., Ilf l"llllSll'lILliull "it..: ~~d,nh.'n[ ~ idd ..;llIJulf.1 S~I\"l' a~ the fouLldallull 1"01 fwun.' ... rudiL's.

Acknowledgments

•

t'rcelils. This ,tlllly wa, f'lntkd hy the T,·,,\., U,'p'"I11'Clll "I' Trallspunalil.H1 (PTujt.'L'I # Il).J31111l"{lu~~h I,he (\.'lItl~r fnr Tr;lI1:-,p{lj"·

!;ltjpll Rl.:.';"L'arL'll ~It fll.: llni\'L'rslly of TI".'.\a... ;.tL Austin. Projcl't

~llid~llll'(' durillg thL' qud~ \\.\.... pru\llkd hy thL' TI.:.\;\:-' Dq1an· rn~lIl (lrTr~1I1~ptirl~lltt.lU (I lid the Harlem Sprillg."/I··.l!\\'arJ,, ,:\quilL'1

t 'un"'L:l"\"atlllll Di..;(nL·1. Gradll~lll." .... tudt.'llh in lhL' rkparlllll'ill Ilf

Ci\'11 [·,lIgin~l."nn!:, ri.lrticipa(J[I~ 1Il1hL' ."tuuy ml"."]ulk'd Julin KL"lr·

Ik'~ i.lluj Ti..:rry \kellY. l.ahpn1(ory ..... tlLuies and dll:l1Iit..:al allal)

~L'."" WL'l'c L·lllldurll:d al ThL' t\~nkl' for R.c.",;c;ITL'!1 ill \Vall."r Re· "t'tlrn'" "I TilL.' \.rUi\lT"jly of Tt:,\a:-. ,'il Aw.. lin

Authof,t.i. -'liL·lwd E Harrert 10.; !\s...."cialc l1irl".'ctur nl' Tilt.: (',·lIlcr f'" I{l"C;'ICh ill Wulcr RC,'"llle,·, . .I"'eph F t'.1,dillu. Jr.. I..... L·.\V C(l\I!.; PrtlfL:!oo ....or ur Ci .... il EIl~illL'('l"illg. ~Uld RanJalJ J ChllrhL.'Ill.:au i:-. Dir('~tl)r PI' Thl.:.' CL'-Ilkr 1'01" Rl':"'L'arL'J1 ill \Vakr I(L.'."OIlJTCS. The UnlvL'fSil) pI Tc,xa:-. at Austill, Cl1rrl·~r(llld~ncc.

"IICiUlu he addrc";:";L:d to f\lidl.U.:1 BalTctt. CL'llll'r rtlr R.co.;v<.lrL.'h in

\Valt.'J' Rl.' .... I.Hln~l' ...... PlH.' #lllJ. 'The Uni\'t~r"I(Y pfTcxas;.\I All:-tin.

,\u:·"in TX 7'l:i71~.

!';"llmffln//or /mhltf'tfllf'" 1t1l1fllln' ':8. j<}lJ7: 1"I,\,1.'1(,d II/Will'

.11'1";/" Hlhmirrn/ ;Hell 1 ( jl)4 7: d'·ft'/Jln.l.!iJ!· ptlhlil'crflill/ Jlllle

.i. I ()(I;

/lIt tll'Ud//flC /1' l'lI/lmil Di,'ln/,I.'·I(11/.\ f~/ ,lri.' arfit /e i, 5iejJft'111

/.>",. /.5. jV'18

\jHtl .tlld \V:lh'l Ellvirllllllh::lll h ..·lh.:lillilill I JlN.~1 ...·'<llIdl,," \I. ill'JiI,

tor ,Itt· [\aIIlIJl.tr!I'1I '-'f iblTer wll! lFiI'l/I"II'<J!("/' II.l!11 Ld .. \\I:I:...l1\11:-'

[illi D.!' \ST\I \ 11)1'2) ·\//1/1101 I.tl'''~ pI Vi]]., .\""III/IU·'/\ PlllladdplH:I. l-'a

H~llr"tI. \1.[. r.l.lhlla. IY II .. CIJ.Ir!'l:IIL.IlI. ILl.: .Illd \\·~lrJ. (r.H ('tlll):ll \V.llL'r (lll~tlll~ ,111I! ()u;lIlllty Imp;ILI" \It Hi~.'.h\, .I.~· (·1111 .... lfU(·

lU In ;uld ('f1L:r~lrhlll· SUlllmary al1L1 C()m:lu:,illn~. Ct.'IH~'r j'pr Rl.:"'c:lr,-'I,

ill W.,LL·" R"·"lllll\.C" TL:L·hniL·;t! K,:p'ln :f,(~. tltll Tc\.....\ll .... rin.

H.t1l"cll.. f\I.E .. Kl:;lI'lll~~ .1.1.'.: ~:kCd:. l.U . \Ldill.l . .II: .11": Cbalh'

l1L'au. R I. . .JIIU W~\I"(1. C; II. Illjl)Shl .. \n E\·~llu.HIOll dl" till' P"':II·I'n

rll;lllL'l' ,d' 1"1:llljlnrary s..:dllllt'lli (\11111"01" ('Cll11'j 1111 R~~""':;llL'h III

\\":HI..'r R""lIUILL·" T'.:dIIIlLid Ikptlrl ~tlj. Lllli\ "l"L''{ ...·\U:~{111

(., L'hhin. C IlqS:-l J LII\t\r:llor~' F\ alu:lIill!! "I' (;.... IIIL:Xlik· fl,,:l'1i1IfO;lftL ~ 1I~

')tll h,.'IlLL' _·\ppltl·illillll'~ {hin~ a Sub";lIi1 Ill" Cjhll'i~d ()n~lfl. \1 "i

l"L:p., I 'nil' Wa'ih .. SL';lllk

CinJdm<Lll. S.1 .. J.: ...·k"lJlI. K....IUJ Hl,!' .... /I~n..;ky, T ..\. (l');.jf,l L'ro.llfJII '1fI" \". rlilJ/l/lI ( ,'llr(lJ{ J-Il.Il!dh'IUI.. .\kCir.l\\· ·Hili. IIlL .. :"J~'\\ '1{\lrl- .•'\; Y X )~.

Illllrn,1Il .\ ...... lll·I~ILC". Illc. lll)7()) ~ldlJlld~ til Comrol hllc G,alllL'd Sl',1i lll~nl~ Rl''.;ulllllg 1'1"'1111 ('ull"rnlcIIOll :\\.·[i .... ir~ \V.\-RD 2t10.1, t·.S LPi\. ()fli..:c \ViIIL'" PI~lIl1l. Stand. \\'a ...,hiJl~I(lll. D.C.

IIllnh:r R.R: (iUL·dl'~. L anJ KOIk'nl1loi, \J.H. (l\ltJO) 11llf.)hH·III.::! Illl'

Cp ...;1 F.rr..:L·liH:lh.:" .... ill I rlgln\-;,: ('oll...;lnIClitlil Sill' I-:n1 ... lflD .1llJ PI)I lUIII\11 (\1111f\11 \\',l"ll. SI~H~' Tr:lll ....pilnali\l[l f'l'lH, \\":I'·;.h. Sialo.' [)~.p

l"r:lll:-.\'1ll\;Irjt111. "L:,llll~

K\1UW"':II. r\. Illllj()J Silt h:ncL's In ('Plund SeJiml'nl .\lll\L·lllL'PI I'll

('i'II:...lruLlh1ll Sil~·,~. Rq10n ~L\T_I)lI-lIJ. R~:. [k\ Iktlll:11 (Jill

~lll\j"Lry Tr:Hl~j1l1nallnll. Lhl\\-fh\·ll·\A,. (lIlt. C;lll

.";;\hll~ler. T.R. ,llld I tl~hlll .I. t.1(H<ql PL·rtnnll;lIIL·~ 111 C'lIrrc"1I1 S,·dlllll·lll

("Pfund \h~a",llw:-, at ~V1;lr} I,wd CtI!I"lrllclHlll Sill'';. PrL·p:"...~d fl'r

Ih~~ \hl Dtp F.Jl' II fill. hy I Ill..' \ktropt1litilll \\';1;..11. ('\lllikil Clln

\\ ;1',lltllt~rl1l1, D.C. ."lllPIl! 1.1..: .\lpnrL:. T-I) lk<JlIlL:rd.~l'. .1.11.. <InJ I\dwllt/. IL\. I Illt)~)

R.~d\lL·ln~ 'llllPPlIll SllmCL' WaleI' Pnllurllill Ii) PrL'\l:llIJnS: SI111

I":rl)..,llln ilild Cl'lltrol!ing St'Jiml'nt (.In Cllll .... lructi,'1I Sill!'" rl'~:hlljuj

1~t'p\'I'1 R01·2SI::'· )1)~(lOI·<')~. Tr~u'~(l(lrr.llillll C\'JH. I :lll\'. ]"t'I1f1.

I\nI1.'\\ jllL:

(I" [Il,IIUlllllt'lll,d Pnll,:vll'll1 '\~.!"':l1"':Y il l)l)21 ."rtmn W~l1...... l\1;lIli.iJ.~L'·

1\1.,."01 rlll" C('ll~lnh':liu(1 :\\.:liviIlL· .... I)Cl'l'lopin,:; (10111l1111l\ r'1t'vL"IlIlI"1

Plan:. (Illd 13...-"1 ro"f.IJl;I.:!-\·Tlh:nl Pr:\L·\lL·l''':. 1·'P,\·i"i.\.?/R .I}"~ (l().';;. ()lIILl'

III \\ ~1;"h.:\"';IllT Ellfpn:':lfIl'lIl :llld <." 1l111pli~111l"l'. Wa~hln~l(ln, [l (

\\)am. DC. (jqq3) rk\·i.·loplll~ VT~1-'i1 illll] ,til ,\.')"],\1 "1'..'''1 t\.1t'lh"d 1<\:'P(lr1 \II) F11 \\' ..\/V '\ .IH· Ie V:1. rrall.,-;purf:lflOIl Rt:' ..,, CPUlh."II .

V~1. Dl:p. Tr;lJl."plIfI.ltillll ;md Fl'd. Ihghw;ly ,..\thl1ill. Wa"hillgltHI 1),('

\\yaflt. D.(· (jl.JSJ I E~;dua[ll\n \)1' r:ihL'!" Fahril'''' t;Jf t,,\"· til Silt 1·:.:lll·l!''''

1"'-111/,\('/11"/(/1/1"11 }{< s. J(cc!ln/. S~"Z. fl.

:--:··I(} Water EnVironment Research, VI)i1 ln1f-! ro, f'jl ~r nL8r "J

• GOA Exhibit TF-7 Barrett Evaluation of Geotextiles SOAH Docket No. 582-08-2166 TGEQ Docket No. 2006-0612-MSW Page 6 of 8

nited States Office of Research EPA 600 R-06 033 Environmental Protection and Develo ment July 2006 Agency Washington DC 20460

e BMP Modeling Concepts andoEPA Simulation

•

e COA Exhibit TF-8 BMP Modeling Concepts and Simulation SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 1 of 166

• EPN600/R-06/033

July 2006

BMP Modeling Concepts and Sinlulation

by

Wayne C. Huber LaMarr Cannon and Matt Stouder

Oregon State University Corvallis, Oregon 97331-2302

In support of:

• EPA Contract No. 68-C-OI-020 University of Colorado at Boulder

Project Officer

Dr. Fu-hsiung (Dennis) Lai

Water Supply and Water Resources Division National Risk Management Research Laboratory

Edison, New Jersey 08837

National Risk Management Research Laboratory

• Office of Research and Development

U.S. Environmental Protection Agency Cincinnati, OH 45268

COA Exhibit TF-8 BMP Modeling Concepts and Simulation SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 2 of 166

• Notice

The U.S. Environmental Protection Agency (EPA) through its Office of Research and Development perfonned and managed the research described here. It has been subjected to the Agency's peer and administrative review and has been approved for publication as an EPA document. Any opinions expressed in this report are those of the authors and do not, necessarily, reflect the official positions and policies of the EPA. Any mention.ofproducts or trade names does not constitute recommendation for use by the EPA.

•

• COA Exhibit TF-8 BMP Modeling Concepts and Simulation SOAH Docket No. 582-08-2186

11 TCEQ Docket No. 2006-0612-MSW Page 3 of 166

• Foreword

The U.S. Environmental Protection Agency (EPA) is charged by Congress with protecting the Nation's land, air, and water resources. Under a mandate of national environmental laws, the Agency strives to formulate and implement actions leading to a compatible balance between human activities and the ability of natural systems to support and nurture life. To meet this mandate, EPA's research program is providing data and technical support for solving environmental problems today and building a science knowledge base necessary tomanage our ecological resources wisely, understand how pollutants affect our health, and prevent or reduce environmental risks in the future.

The National Risk Management Research Laboratory (NRMRL) is the Agency's center for investigation of technological and management approaches for preventing and reducing risks from pollution that threaten human health and the environment. The focus of the Laboratory's research program is on methods and their costeffectiveness for prevention and control of pollution to air, land, water, and subsurface resources; protection of water quality in public water systems; remediation of contaminated sites, sediments and ground water; prevention and control of indoor air pollution; and restoration of ecosystems. NRMRL collaborates with both public and private sector partners to foster technologies that reduce the cost of compliance and to anticipate emerging problems. NRMRL's research provides solutions to environmental problems by: developing and promoting technologies that protect and improve the environment; advancing scientific and engineering infonnation to support regulatory and policy decisions; and providing the technical support and infonnation transfer to ensure implementation of environmental regulations and strategies at the national, state, and community levels.

• This document has been produced as part of the Laboratory's strategic long-tenn research plan. It is made available by EPA's Office of Research and Development to assist the user community and to link researchers with their clients.

Sally Gutierrez, Director. Nat,ional Risk Management Research Laboratory

GOA Exhibit TF-8 • BMP Modeling Concepts and Simulation SOAH Docket No. 582-08-2186

iii TCEQ Docket No. 2006-0612·MSW Page 4 of 166

•

Abstract

In order to minimize impacts of urban nonpoint source pollution and associated costs of control (storage and treatment) associated with wet-weather flows (WWFs), stonnwater runoff volumes and pollutant loads must be

• reduced. A number of control strategies and so-called "best management practices" (BMPs) are being used to mitigate runoff volumes and associated nonpoint source (diffuse) pollution due to WWFs and include ponds, bioretention facilities, infiltration trenches, grass swales, filter strips, dry wells, and cisterns. Another control option is popularly termed "low impact development" (LID) - or hydrologic source control- and strives to retain a site's pre-development hydrologic regime, reducing WWF and the associated nonpoint source pollution and treatment needs.

Methodologies are needed to evaluate these BMPs, their effectiveness in attenuating flow and pollutants, and for optimizing their costJperfonnance since most models only partially simulate BMP processes. Enhanced simulation capabilities will help planners derive the least-cost combination for effectively treating WWFs. There is currently a confusing array of options for analyzing hydrologic regimes and planning for LID. Integrating available BMP and LID processes into one model is highly desirable.

This work analyzes several current modeling methods to evaluate BMP performance with the intention of facilitating the integration of improved BMP modeling methods into the U.S. Environmental Protection Agency (EPA) Storm Water Management Model (SWMM). Several other models are examined as part of this study. Options for enhancement ofSWMM's LID simulation capabilities are also presented. Two extensive case studies in Portland, Oregon help to clarify current SWMM capabilities and needs for enhancement. The effort documented in this report is linked to a parallel effort at the University of Colorado related to optimization strategies for WWF control.

COA Exhibit TF-8 • BMP Modeling Concepts and Simulation SOAH Docket No. 582-08-2186

iv TCEQ Docket No. 2006-0612-MSW Page 5 of 166

•

Contents

• Abstract. iv Contents v List of Figures ix List of Tables xi List of Acronyms and Abbreviations xiii Acknowledgments xvi Project Publications xvii 1 Introduction 1-1

1.1 The Needs : 1-1 1.2 Statement of Task 1-2 1.3 Fundamental Process Categories and Urban BMPs 1-3 1.4 Current BMP Approaches 1-7 1.5 Summary of Current SWMM BMP Simulation Capabilities 1-9

2 Study Area Options 2-12 2.1 Objectives 2-12 2.2 Portland, Oregon 2-12 2.3 Vallejo, California 2-12 2.4 Happy Acres 2-13 2.5 Wonderland Creek in Boulder, Colorado 2-13 2.6 Fair Oaks Estates in Carol Stream, Illinois 2-13 2.7 Summary 2-13

3 BMP Evaluation Options 3-14 3.1 BMP Perfonnance Evaluation 3-14 3.2 Identification of Common EMC-Based Methods 3-15 3.3 Event Mean Concentration 3-16 3.4 Efficiency Ratio 3-16 3.5 Regression Models 3-17 3.6 Effluent Probability Method 3-18 3.7 Simulation Models 3-22

• 4 Current SWMM Simulation Capabilities 4-24

BMP Modeling Concepts and Simulation

4.1 The Model 4-24

COA Exhibit TF-8

SOAH Docket No. 582-08-2186 v TCEQ Docket No. 2006-0612-MSW

Page 6 of 166

•

•

4.2 Storage 4.3 SIT Generalized Removal Equation 4.4 Modified Streeter-Phelps Option

4.4.1 Objectives 4.4.2 Theory 4.4.3 Reaeration 4.4.4 Summary

4.5 Infiltration 4.6 Other Wet-Weather Control Options 4.7 LID Simulation Options 4.8 SWMM LID Modeling Needs 4.9 Time and Space Resolution Issues 4.10 Examples of SWMM BMP Simulation ~

5 Alternative Models and Approaches 6 Ponds

6.1 Introduction 6.2 Simulation of Ponds with P8

6.2.1 The Model : 6.2.2 Second-Order Reactions 6.2.3 Particle Removal Scale Factor 6.2.4 Pollutant Removal.

6.3 Simulation of Ponds with SLAMM 6.4 Pond Simulation with MUSIC 6.5 Pond Simulation with SWMM 6.6 Extended Detention

7 Wetlands and Bioretention Facilities 7.1 Introduction 7.2 Difficulties with Modeling Multiple Processes 7.3 Bioretention in WMM and P8 7.4 Simulation of Wetlands with the WETLAND Model

7.4.1 Introduction 7.4.2 WETLAND Cycles and Sub-models 7.4.3 WETLAND Output.

7.5 Simulation of Wetlands with VAFSWM 7.5.1 Introduction 7.5.2 VAFSWM Components 7.5.3 Implications for SWMM Improvements

7.6 Simulation of Wetlands with PREWET 7.6.1 Introduction 7.6.2 PREWET Removal Mechanisms 7.6.3 PREWET Usefulness for Urban BMP Evaluation

7.7 Simulation of Wetlands with DMSTA 7.7.1 Introduction 7.7.2 DMSTA Model Features 7.7.3 DMSTA Phosphorous Cycling Model... 7.7.4. DMSTA Usefulness for Urban BMP Evaluation

7.8 Simulation of Wetlands and Other BMPs with MUSIC 7.8.1 Introduction 7.8.2 MUSIC Algorithms

4-24 .4-25 4-28 4-28 4-29 4-33 4-33 4-33 4-34 4-34 4-35 4-36

,: 4-36 5-37 6-39 6-39 6-40 6-40 6-40

: 6-42 6-42 6-44 6-45 6-45 6-48 7-50 7-50 7-51 7-51

; 7-52 , 7-52

7-52 7-54 7-55 7-55 7-55 7-55 7-56 7-56 7-56 7-57 7-57 7-57 7-58 7-58 7-59 7-59

, 7-59 7-59

• 7.8.3 MUSIC Evaluation 7-64

7.9 SWMM Simulation of Wetlands and Bioretention Devices 7-65

COA ExhibitTF-8 8MP Modeling Concepts and Simulation SOAH Docket No. 582-08-2186

VI TCEQ Docket No. 2006-0612-MSW Page 7 of166

• 8 Infiltration Trenches 8-66 8.1 Introduction 8-66 8.2 Simulation ofInfiltration Trenches with SLAMM 8-66

8.2.1 Introduction ; 8-66 8.2.2 SLAMM Calculation Procedures for Infiltration Devices 8-66 8.2.3 Infiltration in Disturbed Urban Soils 8-68 8.2.4 SLAMM Procedures for SWMM 8-70

8.3 Simulation ofInfi1tration Trenches in SWMM 8-71 8.4 Transition to Simulation of Rain Gardens and Green Roofs 8-72

9 Grass. Swales and Filter Strips 9-73 9.1 Introduction 9-73 9.2 Simulation of Grass Swales with P8 9-73 9.3 Grass Swale Performance Calculations in SLAMM 9-74 9.4 Simulation of Vegetated Filter Strips with REMM 9-75 9.5 Simulation of Grass Swales with SWMM 9-76

10 Dry Wells : ; 10-78 10.1 Introduction 10-78 10.2 Simulation of Dry Wells with SWMM 10-78

11 Cisterns 11-79 11.1 Introduction 11-79 11.2 Simulation of Cisterns within SWMM 11-79

12 Porous pavement 12-80 12.1 Introduction 12-80

• 12.2 SLAMM Calculation Procedures for Porous Pavements 12-81

, 12.3 Simulation of Porous Pavement with SWMM : 12-81 13 Hydrodynamic Devices 13-83

13.1 Introduction 13-83 13.2 Simulation of Hydrodynamic Devices with P8 13-83 13.3 Simulation of Hydrodynmic Devices with SWMM 13-83

14 Case Study: LID Simulation In Portland 14-85 14.1 Objectives 14-85 14.2 Portland Combined Sewer Study Area 14-85 14.3 Data Preparation Methods 14-88

14.3.1 Required Parameters 14-88 14.3.2 Directly Connected, or DCIA Subcatchments 14-88 14.3.3 Surface Water Subcatchments 14-91

14.4 The Models 14-92 14.4.1 Two Model Types 14-92 14.4.2 Width and Slope ; 14-97 14.4.3 A-Model Input Data 14-98

14.5 Modeling Results : 14-98 14.6 LID Simulation 14-100 14.7 Summary and Conclusions 14-102

15 Case Study: BMP Simulation in Portland 15-103 15.1 Objectives : 15-103 15.2 Lexington Hills Area Background 15-103 15.3 SWMM Modeling 15-109

15.3.1 Background Information 15-109 15.3.2 Initial Modeling 15-116

• 15.3.3 Quantity Modeling Results 15-117

BMP Modeling Concepts and Simulation

15.3.4 Quality Simulations 15-118

COA Exhibit TF-8

SOAH Docket No. 582-08-2186 vii TCEQ Docket No. 2006-0612-MSW

Page 8 of 166

• 15.4 Summary , 15-120 16 Recommendations for SWMM BMPModeling Improvements 16-121

16.1 Introduction 16-121 16.2 Ponds 16-122 16.3 Wetlands and Bioretention Facilities 16-124 16.4 Infiltration Trenches ; 16-124 16.5 Grass Swales 16-125 16.6 Dry Wells 16-125 16.7 Cistems 16-125 16.8 Porous Pavement 16-126 16.9 Hydrodynamic Devices 16-126 16.10 LID and Other Related Needs 16-126 16.11 Final Summary ofSWMM BMP Simulation Needs 16-127

17 Conclusions 17-130 Appendix: Using REMM to Predict Riparian Buffer Perfonnance A-132

Riparian Ecosystem Management Model (REMM) A-132 Buffer Hydrology A-133 Erosion and Sediment. A-134 Nutrient Dynamics A-134 Recommendations A-135

References R-136

•


Vlll TCEQ Docket No. 2006-0612-MSW Page 9 of 166

•

•

•

List of Figures

Figure 3-1. Probability plot for TSS removal at the Seton Pond facility, Austin, Texas (Brown 2003) 3-19

Figure 3-2. Probability plot for nitrate removal at the Seton Pond facility, Austin, Texas (Brown 2003) 3-20

Figure 3-3. Probability plot for total zinc removal at the Seton Pond facility, Austin, Texas (Brown 2003) 3-21

Figure 4-1. Conceptual routing from the impervious sub-area of a subcatchment to the pervious sub-area of a subcatchment (Huber 2001a) 4-35

Figure 6-1. Removal efficiency, R, as a function of dimensionless forms of rate of treatment or loading 6-48

Figure 7-1. Relationship between the MAIN CODE and respective sub-models for an entire simulation run (Lee et al. 2002) 7-53

Figure 7-2. Theoretical residence time distribution (Equation 7-7) for unit impulse to N tanks in series 7-61

Figure 7-3. Pond shapes simulated by Persson et al. (1999) 7-62 Figure 8-1. Schematic of SLAMM model area breakdown 8-67 Figure 8-2. 3-D plots showing interactions affecting infiltration rates in sandy soils

(Pitt and Voorhees 2000) 8-70 Figure 8-3. 3-D plots showing iriteractions affecting infiltration rates in clayey soils

(Pitt and Voorhees 2000) , 8-71 Figure 9-1. TSS removal effectiveness of vegetated filter strips, based on total mass of suspended

solids entering and leaving the strip (Huber et a1. 2000) 9-77 Figure 14-1. Sullivan area (Carollo Engineers, 1999) , 14-86 Figure 14-2. Combined sewer study area, south of Grant Park (Carollo Engineers 1999).

See color codes in caption to Figure 14-1.. 14-87 Figure 14-3. Aerial photo of combined sewer study area 14-87 Figure 14-4. ArcView map of study area showing individual house parcels and rooftop

imperviousness' 14-90 Figure 14-5. Example slope and aspect grids from the digital terrain model. 14-91 Figure 14-6. Pipesegment ID for the study area, as simulated in Extran 14-93

COA Exhibit TF-8 BMP Modeling Concepts and Simulation SOAH Docket No. 582-08-2186

IX TCEQ Docket No. 2006-0612-MSW Page 10 of 166

• Figure 14-7. Aggregated areas for three street subcatchment includes roads, sidewalks and grass strips 14-93

•

Figure 14-8. The highlighted sub-basin 28349056 (referred to as 56) has four DCIA Subcatchments 14-94

Figure 14-9. Individual parcels for the disaggregated model. 14-94 Figure 14-10. Close-up of parcels draining to pipe 62 14-95 Figure 14-11. Dark areas (blue) are DCIA and are surrounded by lighter (lavender)

pervious areas 14-96 Figure 14-12. The dark (blue) DCIA connected outside the sub-basin is not included in the

model as the runoff effects are not noticed at the monitor 14-96 Figure 14-13. Parce11and surface definitions; 14-97 Figure 14-14. Five-day comparison of simulated and measured flows at the monitoring site 14-99 Figure 14-15. Simulated and measured flows for seven-hour period on January 17, 1999 14-99 Figure 14-16. Comparison between Model I and Model I-LID simulations for a seven-hour

interval, January 17, 1999 14-101 Figure 15-1. Location map for Lexington Hills BMP site (Liptan 2001) 15-104 Figure 15-2. Lexington Hills pond vicinity photo (Liptan 2001) 15-105 Figure 15-3. Lexington Hills pond site photo (Liptan 2001). Pond 3 is to left of intersection 15-105 Figure 15-4. Lexington Hills BMP site in relation to catchment (Liptan 2001 ) 15-106 Figure 15-5. Details of Lexington Hills extended detention Pond 3 (Liptan 2001) 15-107 Figure 15-6. Location of influent (Site 1) and effluent (Site 2) monitoring (Liptan 2001) 15-108 Figure 15-7. Regional subcatchments used in BES modeling of Johnson Creek Watershed 15-110 Figure 15-8. Localized view of Johnson Creek Watershed subcatchments 15-111 Figure 15-9. General map ofBES raingage network for Johnson Creek near Lexington Hills

(Lexington Hills is between the Holgate and Pleasant Valley School gages) 15-112 Figure 15-10. Comparison of recorded and simulated flows vs. rainfall for the five simulated

events 15-117


x TCEQ Docket No. 2006-0612-MSW Page 11 of 166

•

•

•

List of Tables

Table I-I. Needs for publicly owned wastewater treatment facilities and other eligibilities, January 1996 dollars 1-2

Table 1-2. Structural BMPs categorized by fundamental unit processes 1-4 Table 1-2 (concluded) 1-5 Table 1-3. Representative structural stonnwater BMPs 1-6 Table 1-3. (concluded) 1-7 Table 1-4. Wet-weather controls and SWMM suitability (after Huber 200lb) 1-10 Table 3-1. Primary urban hydrologic, hydraulic and water quality models commonly used in the

United States 3-23 Table 4-1. Symbols and parameters for linked DO-BOD-NOD simulation, Equations 4-9 - 4-12 4-30 Table 5.1. Simulation models that can simulate urban BMP perfonnance 5-38 Table 6-1. Particle class default values in P8 (Walker 1990) 6-43 Table 6-2. Example ofP8 calibrated runoff concentrations (Walker 1990) 6-44 Table 7-1 Wetlands/ponds pollutant removal mechanisms 7-51 Table 7-2. Numerical results of Persson et al. (1999) for pond shapes of Figure 7-3 7-62 Table 7-3 Calibrated k' and C· values from MUSIC based on limited model simulations 7-64 Table 7-4. First-order decay values converted from k' values for TSS in Table 7-3 for assumed depths 7-64 Table 8-1. Ranked double ring infiltration test results and observed urban soil infiltration rates from

Oconomowoc, WI (Pitt and Voorhees 2000) 8-69 Table 8-2. Categories tested for infiltration rates (Pitt and Voorhees 2000) 8-69 Table 8-3. Percolation rates for different soil texture and moisture used in SLAMM (Pitt and

Voorhees 2000) 8-69 Table 9-1 Infiltration rates used in P8 9-74 Table 14-1. Constant model parameters 14-88 Table 14-2. Extran Block conduit input data. Conduits are identified in Figure 14-6 14-89 Table 14-3. Subcatchment input data for aggregated models (A-Models) 14-98 Table 14-4. Model total flow comparison for five-day event, Jan 13-Jan 18, 1999 14-100 Table 15-1. Storm events used in SWMM simulations 15-104 Table 15-2. Runoff Block input for Lexington Hills Pond 3 simulation (Stouder 2003) 15-113 Table 15-3. Rating curve development for Pond 3 at Lexington Hills 15-116


Xl TCEQ Docket No. 2006-0612-MSW Page 12 of 166

• Table 15-4. SWMM simulated inflows and outflows versus measured data for Pond 3 at the Lexington Hills BMP site 15-117

Table 15-5. Measured and simulated quality results for Lexington Hills Pond 3 15-118 Table 15-6. Particle size distribution for event of October 9-10, 2000 15-119 Table 16-1. Clarification of method applicability to modeling BMPs 16-123 Table 16-2. Summary of proposed SWMM BMPILID simulation enhancements 16-128 Table 16-2. (Continued) 16-129 Table A-I. REMM wet-weather controls program suitability 133

•


xii TCEQ Docket No. 2006-0612-MSW Page 13 of 166

•

•

•

AGNPS AMC APWA ASCE BES BMP BOD BODu

C CalTrans CDF cfs CBOD CFSTR COD CRCCH CSO CU CV DCIA DMSTA DO DOC DON DP DTM EPA ED EMC EPM ER

List of Acronyms and Abbreviations

Agricultural Nonpoint Source Model antecedent moisture condition American Public Works Association American Society of Civil Engineers Bureau of Environmental Services best management practice biochemical oxygen demand ultimate carbonaceous oxygen demand carbon California Department of Transportation cumulative distribution function cubic feet per second carbonaceous biochemical oxygen demand continuous-flow, stirred-tank reactor chemical oxygen demand Cooperative Research Centre for Catchment Hydrology combined sewer overflow University of Colorado coefficient of variation directly connected impervious area Dynamic Model for Stormwater Treatment Areas dissolved oxygen dissolved organic carbon dissolved organic nitrogen dissolved phosphorus digital terrain model U.S. Environmental Protection Agency extended detention event mean concentration effluent probability method efficiency ratio

eOA Exhibit TF-8 BMP Modeling Concepts and Simulation SOAH Docket No. 582-08-2186

xiii TCEQ Docket No. 2006-0612-MSW Page 14 of 166

• ET FPC FWS G-A GIS GUI HRT HSPF LID MS4 MSL MUSIC N NCOB N03-N NH3

NOD NRCS NRMRL NURP O&M OSU P

• P8 PCSWMM PFR POC PPCC PREWET PVC REMM RTC RTD S-I SCS SLAMM SS SSF SOD SSO srr STA SW SWMM TDS TIS TKN TMDL TN

• TOC TP

evapotranspiration fundamental process category free water surface Green-Ampt geographic infonnation system graphical user interface hydraulic residence time Hydrologic Simulation Program - Fortran low-impact development· municipal separate stonn sewer system mean sea level Model for Urban Stonnwater Improvement Conceptualization nitrogen nitrogen, carbon, DO, bacteria (in WETLAND model) nitrogen as nitrate ammonia nitrogenous oxygen demand Natural Resources Conservation Service National Risk Management Research Laboratory Nationwide Urban Runoff Program operation and maintenance Oregon State University phosphorus Program for Predicting Polluted Particle Passage through Pits, Ponds and Puddles Personal Computer Stonn Water Management Model plug flow reactor particulate organic carbon probability plot correlation coefficient Pollutant Removal Estimates for W~tlands

polyvinyl chloride Riparian Ecosystem Management Model real time control residence time distribution storage-indication Soil Conservation Service Source Loading and Management Model suspended solids sub-surface flow sediment oxygen demand sanitary sewer overflow storage/treatment stonnwater treatment area surface water Stonn Water Management Model total dissolved solids tanks in series total Kjeldahl nitrogen total maximum daily load total nitrogen total organic carbon total phosphorus


xiv TCEQ Docket No. 2006-0612-MSW Page 15 of 166

• TSS USDA USGS USLE USTM UWRRC VAFSWM WASP WEF WETLAND WMM WWC WWF

•

•

total suspended solids United States Department of Agriculture United States Geological Survey Universal Soil Loss Equation Universal Stonnwater Treatment Model Urban Water Resources Research Council Virginia Field Scale Wetland Model Program Water Quality Analysis Simulation Program Water Environment Federation Wetland Water Balance and Nutrient Dynamics Model Watershed Management Model wet-weather control wet-weather flow

COA ExhibitTF-8 BMP Modeling Concepts and Simulation SOAH Docket No. 582-08-2186 TCEQ Docket No. 2006-0612-MSW Page 16 of 166

xv

•

Acknowledgments

The author acknowledges the assistance of EPA Contract No. 68-C-01-020 in support of this research and the assistance of Project Officer Dr. Fu-hsiung (Dennis) Lai. The opinions expressed herein do not necessarily reflect those of the EPA.

• Ms. LaMarr Clannon (who changed her name upon matrimony), a graduate research assistant employed on this project, performed most of the Portland LID modeling work described in this report and initiated the comparative model evaluations. Another graduate research assistant, Mr. Matt Stouder, performed most of the Portland BMP modeling work and provided additional evaluation of alternative models. The Oregon State University team is grateful to Dr. James Heaney and his colleagues at the University of Colorado for their partnership in this EPA project. Chapter 2 was written in cooperation with this group. The report content was improved by the comments of two external reviewers.

The project team is indebted to Mr. Joe Hoffman of the Portland Bureau of Environmental Services (BES) for his considerable help in providing and explaining the study area data. Information on the subcatchments in Johnson Creek as well as subcatchment data for the Lexington Hills BMP area came from Mr. Tom Liptan and Mr. Tim Kurtz at the BES. Mr. Kurtz provided much additional help, and many thanks are due to him for his help in this regard.

During the course of this EPA study, the OSU investigators also participated in National Cooperative Highway Research Program Project 25-20(01) related to evaluation ofBMPs for highway applications and in Water Environment Research Foundation Project 02-SW-1 related to more general evaluation of urban BMPs. Efforts on both of these projects contributed to an improved understanding ofBMP evaluation, especially that it related to analysis of event mean concentration data.

~. COA Exhibit TF-8 BMP Modeling Concepts and Simulation SOAH Docket No. 582-08-2186

xvi TCEQ Docket No. 2006-0612-MSW Page 17 of 166

•

Project Publications

Publications resulting wholly or in part from Task B project activities (documented in this report) are listed by authors below:

• Cannon, L. (2002). Urban BMPs and their Modeling Formulations, Master of Science Project Report, Dept. of Civil, Construction, and Environmental Engineering, Oregon State University, Corvallis, August.

Huber, W.C. (2001). Wet-weather Treatment Process Simulation Using SWMM. Proc. Third International Conference on Watershed Management. National Taiwan University, Taipei, Taiwan, pp.253-264.

Huber, W.C. and Cannon, L. (2002). "Modeling Non-Directly Connected Impervious Areas in Dense Neighborhoods," In Global Solutions for Urban Drainage, Proc. Ninth International Conference on Urban Drainage, E.W. Strecker and W.e. Huber, eds., Portland, OR, American Society of Civil Engineers, Reston, VA, CD-ROM, September (2002b).

Huber, W.C., Lai, F., Clannon, L. and Stouder, M. (2004). "Modeling Concepts for BMP/LID Simulation," Best Management Practices (BMP) Technology Symposium: Current and Future Directions, World Water and Environmental Resources Congress, Salt Lake, City, UT, Environmental and Water Resources Institute, American Society of Civil Engineers, Reston, VA, June, 11 pp.

Stouder, M. (2003). Simulation Methodsfor Wetland/Pond BMPs, Master of Science Project Report, Dept. of Civil, Construction, and Environmental Engineering, Oregon State University, Corvallis, June.

COA Exhibit TF·8 • BMP Modeling Concepts and Simulation SOAH Docket No. 582-08-2186

xvii TCEQ Docket No. 2006-0612-MSW Page 18 of 166

•

1 INTRODUCTION

1.1 THE NEEDS

• Pollution problems stemming from combined sewer overflows (CSOs), sanitary sewer overflows (SSOs), and stormwater discharges are extensive throughout the nation, with the Northeast, Midwest, and Far West being the principal areas of concentration. Nationwide, approximately 1, I00 municipalities have combined sewers, 85% of which are in eleven states serving 43 million people; there are over 15,000 overflow points within these systems. SSOs occur in more than 1,000 municipalities, and stormwater discharges occur in as many as 1.2 million municipal, industrial, commercial, institutional and retail sources (EPA NRMRL 1996).

National cost estimates have been developed to control contamination from these three sources of wet weather flow (WWF). According to the most recent 1996 EPA Clean Water Needs Survey (http://www.epa.gov/owmitnet/mtb/cwns/1996rtc/toc.htm). projected costs for CSO pollution abatement totaled $44.7 billion, and stormwater contributes $7.4 billion out oftotal clean water needs estimate of $139.5 billion (Table 1-1). SSO costs are included in categories I, III and IV in the table and "EPA believes that the needs estimates in these categories related to SSOs underestimate the total costs associated with preventing SSOs" (http://www.epa.gov/owmitnet/mtb/cwns/1996rtc/toc.htm). Indeed the EPA Research Plan for wet-weather flows (EPA NRMRL 1996) estimates SSO costs in the "tens of billions." The document also cites an American Public Works Association (APWA) study indicating that costs of controlling stormwater pollution are much higher, at more than $400 billion for capital investment and capitalized costs of $540 billion for operation and maintenance (O&M) of stormwater control facilities, in order to meet water quality standards for stormwater discharges. These large capital and O&M costs pose severe financial difficulties to cities and municipalities throughout the nation.

During wet weather periods, urban sewer systems often become overloaded. This can be alleviated, for example, by providing additional storage in the system or by providing additional treatment, either downstream at the treatment facility or upstream within the watershed. Since WWF impacts and controls are complex and the costs of abatement alternatives are enormously large, there are tremendous opportunities for significant cost savings as a whole if an "optimal" cost-effective combination of storage and treatment alternatives can be objectively formulated. EPA is developing a multi-year research program aimed at devising tools that can be used to evaluate sewerage systems and determine the optimal combination of WWF control alternatives for the most cost-effective operation of the system.

• A related need deals with EPA's total maximum daily load (TMDL) program, by which pollutant loads are to be reduced on a watershed basis, with a goal to meeting water quality standards in receiving water


I-I TCEQ Docket No. 2006-Q612-MSW Page 19 of 166'

• systems. Management of stonnwater quality is usually perfonned through a combination of so-called "best management practices" (BMPs) and a fonn of hydrologic source control popularly known as "lowimpact development" (LID). Reliable simulation ofBMPs and LIDs is needed for the modeling efforts that usually are a part ofTMDL development.

Table 1-1. Needs for publicly owned wastewater treatment facilities and other eligibilities, January 1996 dollars. (http://www.epa.gov/owmitneUmtb/cwns/1996rtcltoc.htm)

Needs Category Total Needs, Billion $

Title II Eligible Proiects I Secondary Treatment 26.5 II Advanced Treatment 17.5

InfiltrationlInflow Correction 3.3 IIIB

I IlIA Sewer ReplacemenURehabilitation 7.0

IVA New Collector Sewers 10.8 IVB New Interceptor Sewers 10.8 V Combined Sewer Overflows 44.7 VI Stonnwater* 7.4

Total Categories I-VI 128.0 Other Eligible Projects (Sections 319 and 320) VIIA-C Nonpoint Source (agriculture and silviculture only)* 9.4 VIID Urban Runoff 1.0 VlIE-G Ground Water, Estuaries, Wetlands 1.1

Total Category VII 11.5 Grand Total 139.5• *Modeled needs only. Estimated Category VI needs documented by the States are $3.2 billion.

Estimated Category VIIA-C needs documented by the States are $0.5 billion. Costs for operation and maintenance are not eligible for federal funding and therefore are not included.

Municipal separate stonn sewer system (MS4) owners and operators need to identify effective BMPs for improving stonnwater runoffwaterquality; owners and managers of other highly-impervious land (e.g., highways and industries) have similar needs. Evaluation of perfonnance involves the use of computer models and tools, and empirical relationships describing a quantitative estimate of pollution removed by BMPs. This infonnation will help planners derive an effective combination of control strategies for WWFs. Because of the current state of the practice, however, very few sound scientific data are available for making decisions about which structural and non-structural management practices function most effectively under what conditions, and, within a specific category of BMPs, to what degree design and environmental variables affect BMP efficiency.

1.2 STATEMENT OF TASK

Models for simulation ofBMP and LID options must consider antecedent runoff conditions for both a single rainfall event and continuous rainfall and simulate the physical processes of rainfall, evapotranspiration, soil infiltration to groundwater, and overland sheet-flow processes from individual lots to streets, then from streets to sewers and eventually to their outfalls. The EPA Stonnwater Management Model (SWMM) is a state-of-the-art urban runoff proce~s model and may be used as the process model of choice (Huber and Dickinson 1988, Roesner et al. 1988). It uses well-known

• hydrologic and hydraulic concepts to simulate the urban watershed. Moreover, the software itself has undergone an evolutionary upgrade to a user-friendly, object-oriented version called SWMM5 (http://www.epa.gov/ednnrmrVmodels/swmm/index.htm).This program, which includes a graphical user

COA ExhibitTF-8 BMP Modeling Concepts and Simulation SOAH Docket No. 582-08-2186

1-2 TCEQ Docket No. 2006-Q612-MSW Page 20 of 166

• interface (GUI), was prepared within the EPA itself and provides the framework for enhancements necessary to better model WWF control alternatives, especially BMP and LID options. SWMM5 enhancement needs are addressed herein through a goal of better tools for quantifying the effectiveness of various WWF control alternatives. The effectiveness of each control alternative constitutes essential input to analysis of management alternatives.

This report is half of a larger project, "Optimization of Urban Sewer Systems during Wet-Weather Periods" (EPA Contract No. 68-C-OI-020), to the University of Colorado (CU) and a subcontract to Oregon State University (OSU) dealing with the related issues of optimization and simulation of wetweather controls. Simulation can provide performance estimates of controls such as BMPs and LIDs that can be coupled to analytical tools to optimize life-cycle costs of capital and O&M investments as well as overall performance, e.g., as measured by effluent characteristics, amount of runoff treated, etc. The issue of performance measures will be discussed in detail in subsequent chapters.

A companion report (Heaney and Lee 2005) deals with the optimization efforts. This report deals with the simulation component of the project. It is based in part upon unpublished progress reports during the course of the project as well as OSU master's project reports by Cannon (2002) and Stouder (2003).

1.3 FUNDAMENTAL PROCESS CATEGORIES AND URBAN BMPS

• A fundamental process is essentially the same as a unit process in environmental engineering (Metcalf and Eddy 2003). There is no single universal list of fundamental process categories (FPCs); Minton (2002) provides a useful taxonomy, oriented toward stormwater treatment. Common structural BMPs are grouped by nine FPCs in Table 1-2, but alternatives are possible, and one BMP may fall under different FPCs.

Similarly, there are many types of BMPs. Modelers interested in describing BMP effectiveness may wish to model BMP types (typical swale or pond), or instead model the fundamental processes that occur in a BMP (sedimentation, infiltration, etc.). For purposes of this investigation,representative structural stormwater BMPs are listed in Table 1-3, adapted from a taxonomy prepared by the Minnesota Pollution Control Agency (http://www.pca.state.rnn.us/water/pubs/sw-bmpmanual.html).This list is one of many from similar sources that could be used.

If modeling BMP by type, a method for determining performance parameters must be described. This may be done by investigating BMP effectiveness as reported, for instance, in the EPN ASCE BMP Database (http://www.bmpdatabase.orgl)andapplyingsimilareffectivenessmeasurestothemodel.This leads to many questions about measuring and reporting BMP performance. Modeling BMPs by simulation of FPCs requires extensive data on stormwater treatability as well as site and design descriptions, and raises issues about data availability. As will be described in this report, most BMPs are modeled by a heuristic combination of FPC simulation and empirical performance measures.


1-3 TCEQ Docket No. 2006-0612-MSW Page 21 of 166

• Table 1-2. Structural BMP.s categorized by fundamental unit processes. Adapted from: BMP manual http: www.pca.state.mn.us water1pu II I I bs swm I

•

Process Definition BMP

Sedimentation Gravitational settling of suspended particles from the water column.. It can be a major mechanism of pollutant removal in BMPs because pollutants often adsorb to particulate matter, especially clay or organic soils. Detention systems intercept runoff for gradual release later. Most are designed to empty between events and treat water quantity rather than quality. These systems can provide limited settling, which can often be resuspended with a subsequent event.

Dry pond, wet pond, other basin, small storage devices, wetland, underground pipes, vaults, tanks

Flotation Separation of particulates with a specific gravity less than water. Trash, Styrofoam, oil and hydrocarbons can be removed from BMPs designed with an area for these to accumulate.

Oil-water separators, density separators, dissolved-air flotation

Filtration Filtration devices remove particulates by passing water through a porous medium like sand, gravel, soil, peat, compost, or combinations thereof.

Trash racks, bar racks, screens, sand filters, compost filters, vegetation and soil, may be part of filtration systems. Modular or drop in filter systems

Infiltration Infiltration systems capture runoff and provide a means of infiltration into the ground. Infiltration is the most effective means of controlling storm water runoff because it reduces the volume discharged to receiving waters. Filtration by soil removes TSS and associated pollutants, and dissolved nutrients are removed by adsorption.

Infiltration basins, porous pavement, infiltration trenches or wells, ponds, constructed wetlands

Adsorption Contaminants are bound (to clay particles or macrophytic vegetation). Adsorption is not a common mechanism used in stormwater BMPs, although it can occur in infiltration systems with clayey soils, in organic filters, or in wetland systems.

Infiltration systems with clay soils, adsorption to macrophytes in constructed wetlands, compost filters



• Table 1-2 (concluded)

•

Biological Uptake and Conversion

Biological uptake is an important nutrient control mechanism in BMPs treating urban runoff that typically contains high levels of nutrients. This occurs as aquatic plants and microorganisms utilize nutrients for growth. Maintenance and harvest of these plants is essential, otherwise as plants die and decay, they re-release nutrients. Biological conversion happens when microorganisms and bacteria break down organic contaminants into less harmful compounds.

Pond, bioswale, wetland

Chemical Treatment Chemicals such as alum are added to promote flocculation and settling. Chlorine disinfection is sometimes used to treat combined sewer overflows.

Precipitation, flocculation, disinfection

Degradation (volatilization, hydrolysis, photolysis)

Degradation happens in open pool BMPs where contaminants volatilize, hydrolyze or photolyze.

Pond, wetland, open pool BMPs

Hydrodynamic Separation Varies by device. Swirl concentrators, secondary current devices, oil-water separators

Combination (Retention) Retention systems .hold and treat runoff until displaced by another volume of water. These can be very effective in treating both quality and quantity of runoff. Several processes can occur, such as sedimentation, filtration, infiltration, biological uptake, conversion and degradation.

Wetlands, bioswales



• Table 1-3. Representative structural stormwater BMPs.*

•

BMP Definition

Bioretention Facilities Similar to other facilities (pond, basin or channel) with more than 50% of its (constructed wetlands, surface or bottom covered by emergent wetland vegetation. A wetland channel wetland basins and is a channel designed to flow very slowly, probably less than 2 ftls at the 2-year wetland channels) flood peak flow rate. It has, or is designed to develop, dense wetland vegetation

on its bottom.

Dry Wells Dry wells are drilled often through impervious layers to reach lower pervious layers, filled with porous media designed to percolate surface water to Igroundwater.

Filter Strips

Grass filter strips, sometimes called bio-filters, bioswales, or buffer strips, are vegetated areas designed to accept sheet flow provided by flow spreaders, which accept flow from an upstream development. Vegetation may take the form of grasses, meadows, forests, etc. The primary mechanisms for pollutant removal are filtration, infiltration, and settling.

Grass Swales A swale, sometimes also called a bio-filter or bioswale, is a shallow grass-lined channel with little bottom width, designed for shallow flow near the source of storm runoff.

Ponds

Retention ponds are also commonly known as "wet ponds" because they have a permanent pool of water, unlike detention basins, which dry out between storms. The permanent pool of water is replaced in part or in total by stormwater during a storm event. The design is such that any runoff captured during a storm event is released over time. The hydraulic residence time (HRT) for the permanent pool over time can provide biological treatment. A dry-weather base flow, pond liner and/or high groundwater table are required to maintain the permanent pool.

Cisterns Rain barrels or cisterns act as storage devices and retain a portion of runoff for later use, such as irrigation or use as grey water.

Infiltration Trenches

Percolation or infiltration trenches can generally be described as ditches filled with porous media designed to encourage rapid percolation of runoff to the . groundwater. An infiltration basin can capture a given stormwater runoff volume and infiltrate it into the ground, transferring this volume from surface flow to groundwater flow.

Extended Detention (ED)

ED dry basins are designed to completely empty at some time after stormwater runoff ends. These are adaptations of the detention basins used for flood control. The primary difference is in outlet design; the extended detention basin uses a much smaller outlet that extends the detention time for more frequent events in order to facilitate pollutant removal. The term "dry" implies that there is no significant permanent water pool between storm runoff events. Multiple uses (e.g., recreation) are possible for land occupied by ED facilities .

COA Exhibit TF-8 • BMP Modeling Concepts and Simulation SOAH Docket No. 582~08-2186


• Table 1-3. (concluded)

Porous Pavement

lHydrodynamic Device

Modular-block porous pavement is composed of perforated concrete slab units underlain with gravel. The surface perforations are filled with coarse sand or sandy turf. It is used in low traffic areas to accommodate vehicles while facilitating stormwater runoff at the source. The units should be placed in a concrete grid which restricts horizontal movement of infiltrated water through the underlying gravels.

Poured-in-place porous concrete or asphalt is generally placed over a substantial layer of granular base. The pavement is similar to conventional materials, except for the elimination of sand and fines from the mix. If infiltration to ground water is not desired, a liner may be used below the porous media along with a perforated pipe and a flow regulator to slowly drain the water stored in the media over a 6 to 12 hour period.

These devices are BMPs such as oil-water separators, sand interceptors, swirl-type concentrators, sedimentation vaults, and other prefabricated and package-type treatment devices.

*BMP definitions are from the ASCE BMP database: webSite, www.bmpdatabase.org

• 1.4 CURRENT BMP APPROACHES

Traditional stormwater controls have strongly emphasized large spatial scales for flood and water-quality analyses. Runoff volume is usually the most important hydrologic parameter in water quality studies, while peak flow rate and time of concentration are usually the most important hydrologic parameters for flooding and drainage studies. The relationships between these different hydrologic parameters and storm parameters are significantly different for different classes of rains. Runoff models for water quality investigations should therefore have additional capabilities beyond those of runoff models for flooding and drainage investigations.

Common, small storms (also termed "micro-storms" in the literature) are responsible for most of the annual urban runoff discharge quantities throughout North America (Heaney et al. 1977, EPA 1983, Pitt 1987, WEF and ASCE 1998, Wright et al. 2000). However, some existing urban runoff models originate from drainage and flooding evaluation procedures that emphasize very large design storms (several inches in depth). These large storms only contribute small portions of the annual average discharges. Several authors have suggested that stormwater quality can be managed by treating the flows associated with small storms (Heaney et al. 1977, EPA 1983, WEF and ASCE 1998, Wright et al. 2000, Pitt and Voorhees 2000, Sample et al. 2001). These storms occur many times a year and are responsible for the majority of the pollutant discharges. Runoff from about 70 to 80% comprises these frequent discharges of the annual precipitation onto urban areas, the effects of which are mostly chronic in nature (such as contaminated sediment and frequent high flow rates). Pitt and Voorhees (2000) use the breakdown bulleted below for various storms. It should be noted that relationships between depth and cumulative percentages vary regionally (Heaney et al. 1977, WEF and ASCE 1998).

• • Frequent storms having relatively low pollutant discharges are associated with depths of less than 0.5 in. (12 rom). These are key events in which runoff-associated water quality violations, such as for bacteria, are of concern. In most areas, runoff from these rain storms should be totally captured and either

COA Exhibit TF-8 8MP Modeling Concepts and Simulation SOAH Docket No. 582-08-2186


• re-used for on-site beneficial uses or infiltrated in upland areas. For most areas, the runoff froin these rains is relatively easy to remove from the surface drainage system.

• Rains between 0.5 and 1.5 in. (12 and 38 mm) are responsible for about 75% of the nonpoint source pollutant discharges and are key rains in terms of addressing mass pollutant discharges. The small rains in this category can also be removed from the drainage system and the runoff re-used on site for beneficial means or infiltrated to replenish the lost groundwater infiltration associated with urbanization. The runoff from the larger rains should be treated to prevent pollutant discharges from entering the receiving waters.

• Rains greater than 1.5 in. (38 mm) are associated with drainage design and are only responsible for relatively small portions of the annual pollutant discharges. Typical storm drainage design events fall in the upper portion of this category. Extensive pollution control designed for these events would be very costly, especially considering the relatively small portion of the annual runoff associated with the events. However, discharge rate reductions are important to reduce habitat problems in the receiving waters. The infiltration and other treatment controls used to handle the smaller storms in the above categories would have some benefit in reducing pollutant discharges during these larger, rarer storms.

• • In addition, extremely large rains also occur infrequently that exceed the capacity of the drainage system and cause local flooding. Two of these extreme events were monitored in Milwaukee during the Nationwide Urban Runoff Program, NURP (EPA 1983). Such storms, while very destructive, are sufficiently rare that the resulting environmental problems do not justify the massive stormwater quality controls that would be necessary for their reduction. The problem during these events is massive property damage and possible loss of life. These rains typically greatly exceed the capacities of the storm drainage systems, causing extensive flooding.

This interest in smaller storms requires modeling approaches that can properly account for losses (hydrologic abstractions such as infiltration, d~pression storage, and evapotranspiration) for low rainfall depths. SWMM is one such model with this capability. However, as noted elsewhere in this report, even though SWMM provides the option for vadose zone simulation, interaction with subsurface hydrologic processes could be improved with respect to the overall water balance. Alternatively, better opportunities to interface with subsurface models could be provided.

The micro-scale (spatially) is defmed as a fundamental hydrologic unit, that is, a sub-parcel of an individual tract of land. A sub-parcel could be a roof, sidewalk, grass lawn, driveway, garden, or other landscape area. LID, also known as hydrological source control, is based on reducing hydrologic impacts and incorporating micro-scale BMPs throughout the subcatchment (Prince George's County 2000). Reducing runoff by incorporating storage and infiltration onsite improves the quality and reduces the quantity of runoff produced by a developed site.

The LID philosophy is that runoff controls based on the micro-scale may be an important component of a stormwater management plan, and stormwater control at the micro-scale may effectively mitigate the effect of urban areas within the long-term hydrologic cycle. While not a panacea (Strecker 2001), this volume-based approach to management of runoff has great potential to reduce the runoff volume, sediment loads, and floatables that can reach receiving waters. By reducing runoff (and hence the associated pollutants) municipalities stand to substantially reduce the estimated billions of dollars associated with pollution abatement from WWF.

• One question is whether the existing stormwater models designed for drainage and flood control can be adapted for evaluating these small-storm events at the sub-parcel scale. Flood design is usually based on



• a single design event. However, there are no accepted criteria for selecting a design small-stonn. Rather, the appropriate strategy should incorporate continuous simulation over multiple years so that the integrated behavior of the system can be evaluated over all of the stonns that can be the dominant source of water onto pervious areas. SWMM is one such model with this capability; others are discussed in Chapter 5.

1.5 SUMMARY OF CURRENT SWMM BMP SIMULATION CAPABILITIES

The heart of the research described herein has been to document SWMM capabilities needs with regard to BMP and LID simulation. The current SWMM (version 4.4h) as well as previous versions are each divided into four primary computational "blocks" or "modules": Runoff (converting rainfall to runoff and generating nonpoint source runoff quality), Transport (kinematic wave flow routing and water quality routing through conveyances and storage), Extran (dynamic wave flow routing), and StoragelTreatment (SIT) (treatment and storage devices). The object-oriented SWMM5 will not refer to "blocks" but rather to hydrologic, hydraulic, and other descriptive "objects" such as watersheds, channels, storages, land use, etc. To set the stage for the report that follows, capabilities and limitations of the current (SWMM4.4h and SWMM5) model have been identified and are summarized in Table 1-4 (Huber 2001 b). Reference is made in Table 1-4 to the four SWMM blocks just described.

The implications of Table 1-4 are: 1. Storage is well simulated in any of the four current SWMM blocks, although the Runoff Block offers

the leastflexibility.

• 2. The SIT Block offers the most flexibility in tenns of mimicking conventional and high-rate treatment

devices, e.g., for combined sewers. 3. Removal fractions (applied to incoming loads) may be used for Runoff Block overland flow segments

and Transport Block channel/pipes. 4. First-order decay may be applied in the Runoff, Transport, and SIT Blocks. 5. Settling velocities may be used in the Transport Block to simulate sedimentation (but no related

effects, such as build-up of solids or resuspension). 6. Particle size ranges (or settling velocity ranges) can be tracked through the current Runoff and

Transport Blocks as separate constituents. However, there is no linkage with the SIT Block, which provides the most sophisticated sedimentation routines, including application of Camp's (1946) sedimentation theory to up to five settling velocity ranges.

7. Overland flow rerouting options inherent in LID can be simulated in the Runoff Block, although one subcatchment per surface tYPr might be necessary. SWMM can be applied at the parcel (individual lot) level on the basis of the modeling shown in this report.

8. Infiltration from channels is not simulated, except artificially, e.g., by an imposed "negative hydrograph" or through monthly evaporation.

9. Biological interactions (e.g., in bioswales, wetlands) may be simulated only through first-order decay (Runoff, Transport, SIT) and/or removal equations in the SIT Block.

10. There are few mechanistic, fundamental treatment processes included in the SWMM model, except for sedimentation in the SIT Block.



• Table 1-4. Wet-weather controls and SWMM suitability (after Huber 2001b).

WWCOption SWMM Suitability

Storage and Associated Treatment, e.g., Ponds

Simulation of most storage options, with several options for hydraulic controls. Treatment by removal equations, first-order decay, or sedimentation. Removal in Transport Block channel/pipes by first-order decay or sedimentation (constant settling velocity) or removal fraction applied to incoming loads.

Screening and Filtration Simulation by removal equations. Chemical Treatment, Chlorination

Simulation by removal equations.

Wetlands, Bioretention Simulation to the extent that wetland or biological channel behaves like a storage device.

Source Controls Simulated by reduced loadings. Street Cleaning Simulated directly through removal fractions or by reduced

loadings. Cisterns Can divert water to storage but cannot arbitrarily retrieve it. Dry Wells Can divert water to well, but it then goes "out of simulation"

unless tracked using groundwater options. Overland Flow, Swales, Infiltration, Porous Pavement, Filter Strips

Simulation in Runoff Block only. Optional quality removal by first-order decay or removal fraction applied to incoming load. Infiltrating water carries pollutants with it.

Infiltration Trench Can simulate infiltration from overland flow "trench" in Runoff. Maintenance, e.g., Sewer Flushing

Simulation by reduced loading, with simplistic option for sediment scour/deposition in Transport Block.

Illicit Connection Removal Simulation through modification of drainage system connectivity. Inlet Constrictions Hydraulic control, simulated in Extran Block. Real-Time Control Orifice and weir settings in Extran can be controlled as function of

time and10r head changes.

• Within this report, modeling concepts and, where appropriate, mathematical formulations are identified for viable BMPILID alternatives that have been identified as missing from SWMM (Table 1-4). The effort to prepare this information is based on the assumption that such formulations are, in fact, available, which has not always been born out. Generally, BMP alternatives include (Table 1-3): storage (ponds, dry detention), bioretention facilities, infiltration trenches, grassed swales, filter strips, dry wells, cisterns, and hydrodynamic devices. Some theoretical and/or heuristic processes/equations that are based on stateof-the-engineering knowledge and information are proposed for possible inclusion in SWMM - probably in version 5 (SWMM5). The use of some BMPs to attenuate stormwater in upland locations as LID options, including rain gardens and roof-top green areas, is also gaining much attention. Necessary modeling parameters, e.g., soil characteristics and antecedent moisture content, which reflect local sitespecific conditions, are identified in the discussion and in the examples of Chapters 14 and 15. SWMM modeling limitations for various BMP/LID alternatives are summarized in Chapter 16. The areas that have been addressed include:

• Spatial resolution to allow application of micro-management of flows in a residential lot (Section 4.9).

• Overland flow movement in pervious and impervious surfaces within a residential lot, and from lots

• to street gutters, swales, buffer strips, channels, and sewers (Sections 4.7 and 4.8).



• • Subsurface flow movement of rainwater infiltration through unsaturated (aeration) zone and interaction of surface and ground waters (Chapters 8 - 11).

• Routing and attenuation of pollutants in overland and subsurface flow movement considering subsurface adsorption, absorption, and dispersion processes (needs identified in Chapter 16).

• Routing of flows and pollutants from lots to swales/street gutters/inlets/sewers (Sections 4.7 and 4.8). • Hydraulic efficiency of storage-routing for pollutant removal (Sections 6.5 and 7.8). • Runoffi'storage/infiltration/treatrnent BMPILID process designs (Chapters 4, 6-8).

Generally, the first part of this report deals with BMPs and their simulation options, followed by Chapters 14 and 15, which are devoted to two detailed case studies. Note: generic reference to "SWMM capabilities" will refer to version 4.4h (April 2002) since SWMM5, which was officially released in October 2004, will continue to be enhanced in thefuture.

•



•

2 STUDY AREA OPTIONS

2.1 OBJECTIVES

• BMP and LID simulation may be more easily grasped in the context of examples. A component of this project is to provide locations for which case studies may be possible. Case studies with enough intraevent data for BMP simulation are just emerging (July 2003) from examination of the EPAIASCE BMP Database (http://www.bmpdatabase.org/), and no attempt has been made to simulate only "real" BMPs for this reason. However, regarding LID, are there hypothetical residential lots (either conceptual or an actual residential lot) for which alternative BMPILID stormwater management techniques could be demonstrated? The SWMM model could then be applied to these hypothetical lots to demonstrate how alternative scenarios would affect the model's WWF control simulation capabilities. Case studies based on these locations should include typical urban land uses and include a mix of combined and separate sewer systems. The locations should have detailed data on soils, land use, precipitation, infrastructure components, etc., and ideally should have been modeled (perhaps by the agency supplying the data) using SWMM or a similar program. Cost and performance data are also important - if unlikely to be available.

Five locations were identified during the course of this study that might be suitable for LID evaluation and/or simulation. They are summarized briefly below.

2.2 PORTLAND, OREGON

Portland, Oregon is a city containing many CSO areas with serious problems in terms of flooded basements and overflows to receiving waters. The Portland Bureau of Environmental Services (BES) is using a wide variety of BMPs and has been a leader in applying simulation models to their problems. Their CSO control program is embedded in a watershed plan for the entire area. Good cost data and excellent internet links for accessing data are available (http://www.cleanrivers-pdx.org/). Portland can be studied at micro and macro scales. Additional information is deferred to the extensive case studies presented in Chapters 14 and 15.

2.3 VALLEJO, CALIFORNIA

Vallejo, California is an SSG area with serious basement flooding and overflow problems. An excellent database on flows, sewer infrastructure, failure rates, control costs, and SWMM modeling results is available. A good general description of the Vallejo Sanitation and Flood Control District SSO

• elimination program can be found on their consultant's web site, http://www.carollo.com/vsfcd/. Technical information and data may be found in Carollo Engineers and CH2M Hill (2000). Results of risk optimization for Vallejo can be found in Wright et al. (2001 a, b).



• 2.4 HAPPY ACRES

•

A hypothetical 105-ac study area called Happy Acres has been used extensively for research and teaching at the University of Colorado. This study area is comprised of low and medium density residential land use, a shopping center, and a school. It has been used as a single study area to evaluate water supply, wastewater, and stormwater options. Optimized designs have been done for the water, wastewater, and stormwater infrastructure. ArcView files have been generated to summarize the geographic information system (GIS) information. An Access database has also been developed for each parcel, and a facilities database is being developed. Results of analyses have been published in previous reports and papers dealing with costs (Heaney et ill. 1999a, Fan et al. 2000, Sample et al. 2001), GIS (Heaney et al. 1999b, Sample et al. 2001), and optimization (Heaney et al. 1999c,d; Heaney et al. 199ge). A good benchmark of alternative designs is available for Happy Acres based on its extensive use in both research and teaching.

2.5 WONDERLAND CREEK IN BOULDER, COLORADO

Wonderland Creek in Boulder is a 14-ac residential neighborhood that has been evaluated in great detail regarding the nature of the imperviousness and its effect on runoff. Various levels of spatial detail may be obtained from the GIS coverage for this study area. SWMM has been set up and run for this neighborhood using 1-, 15-, and 60-minute rainfall data for Boulder (Lee 2003). The results of an accurate determination of the nature of imperviousness in urban areas indicate that existing estimates can be very inaccurate. The error in estimating imperviousness causes major changes in the accuracy of the predicted hydrographs (Lee 2003).

2.6 FAIR OAKS ESTATES IN CAROL STREAM, ILLINOIS

The Fair Oaks storm sewer and detention pond is used as a design example in the second edition of the Hydrology Handbook (ASCE 1996). Fair Oaks Estate is a subdivision ofCarol Stream, Illinois, a suburb west of Chicago. The total area of the subdivision, which includes 13 lots, is 13.4 ac. Details of the detention pond design are shown in Burke (1979), Burke and Gray (1979), Burke and Burke (1994), and ASCE (1996). The design was done in the 1970s and the system has been in operation since that time. It is a conventional design and appears to be working fine after 20 years of operation. In his original MS thesis, Burke (1979) evaluated the impact of using the Rational Method (Dooge 1973) vs. the ILLUDAS (Terstriep and Stall 1974) model to solve the Fair Oaks problems. The use ofILLUDAS showed the hydraulic inadequacy of some of the pipes selected based on the Rational Method. Similar comparisons were done for other hydrologic and hydraulic models.

2.7 SUMMARY

Two locations in Portland were selected for SWMM simulations in this study for several reasons:

• Proximity to OSU: the project team performed most of the SWMM simulations. • Existence of good flow monitoring data, rainfall data, and catchment. characterization data for

multiple sites.

• Willingness on the part of the Portland BES to share data and simulation results. • Lack of some key information from the other sites, plus the fact that Happy Acres is hypothetical.

Using the two Portland locations, SWMM simulation examples are presented in Chapter 14 for LID and Chapter 15 for a pond.



•

3 BMP EVALUATION OPTIONS

3.1 BMP PERFORMANCE EVALUATION

• If a model such as SWMM is used to simulate BMP perfonnance, on what basis will the BMP's effectiveness be measured? A simulation model has the capability to produce simulated influent and effluent concentrations for thousands of stonn events. Statistical methods used to evaluate monitored BMPs might also be used to evaluate simulated BMPs. If so, what conclusions can be drawn from evaluation efforts to date ofmonitored BMPs? This chapter discusses options for BMP evaluation based on measured concentrations and flows. Some of these options could also be applied to simulation model output.

A fundamental statistic of a quality monitoring program is the event mean concentration, or EMC. Although it is defined as the total constituent mass for an event divided by the total flow volume for the event, it is usually computed by preparing one'flow-weighted composite sample from the several quality samples taken during a stonn, and sending the one sample to the laboratory for analysis. The BMP "perfonnance" is then usually - but not always - computed on the basis of the relationship between the influent and effluent EMCs, hopefully for many monitored stonn events. In essence, the BMP is considered to be a "black box," to which several statistical and mathematical procedures might be applied to deduce the "transfer function" (Chapra 1997) that relates input to output. The most widely used statistical methods will be listed in the next section.

The issues involved in selecting methods for quantifying BMP efficiency, perfonnance, and effectiveness are complex. It is also important to appreciate that the reliability and perfonnance of many of these controls have not been well established. Accurate reporting ofBMP effectiveness is important to modelers wishing to calibrate to actual practices.

The EPA/ASCE BMP Database (http://www.bmpdatabase.org/) currently characterizes BMP perfonnance as EMC (i.e., a single representative concentration). Although some groups believe that a better method for measuring perfonnance is amount of flow treated and effluent quality, (Strecker et al. 2001), an outlet EMC value is probably the simplest single measure ofBMP perfonnance.

While analyzing the EPA/ASCE BMP Database, Strecker et al. (2001) observed a trend indicating higher removal efficiency in BMPs with higher influent concentrations. Strecker et al. (2001) aver that several

• BMPs can be characterized by the effluent EMC distribution, that is, the effluent probability method (EPM), rather than a heuristic or process model of the system. However, current data available are insufficient to tie BMP design to effluent quality using the EPM, and it would be difficult to model BMPs



'. in series (treatment train) with this method. As the EPAIASCE BMP Database evolves, the EPM method (discussed below) may be enhanced.

Before discussing some EMC methods in more detail, it is important to note that quality is not the only performance measure. Strecker et a1. (2001) proposed that there should be a threefold metric for BMP characterization: • How much catchment runoff is averted by a control measure (hydrologic source contro!), e.g., by

infiltration or evapotranspiration?

• Of the runoff that enters the BMP, how much is treated and how much is bypassed or routed through the BMP at rates exceeding treatment rates?

• What are the quality characteristics of the treated BMP effluent?

A fourth metric can be added:

• How much downstream flow management is provided by the BMP?

Metrics one, two, and four are hydrologic and depend strongly on regional patterns of storm events and dry-weather intervals (and of course, local catchment's characteristics such as soils). It will be seen in this report that SWMM is capable of good short-tenn and long-term hydrologic perfonnance characterization - except for infiltration from channels. SWMM can also produce the event EMCs that can be used to characterize effluent quality. Finally, the viability ofBMPs such as constructed wetlands and biofilters depends in part upon the nature of the entering stormwater.Whether or not the BMP can support healthy and diverse vegetation may depend on issues related to nutrient dynamics and subsurface

• water quality, which SWMM mayor may not be able to address. The bulk of this report identifies ways in which SWMM deficiencies can be overcome in order to enhance the model's already powerful capabilities.

3.2 IDENTIFICATION OF COMMON EMC-BASED METHODS

The difficulty in selecting measures of efficiency stems from the desire to compare a wide range of BMPs and the large number of methods currently in use. There is much variation and disagreement in the literature about what measure of efficiency is best applied in specific situations; however, it is generally accepted that the EMC and long~tenn loading provide the best data for observing the effects of the BMP on acute and chronic pollution, respectively (GeoSyntec et a1. 2002). ,

Ten methods for evaluating BMP performance using EMC data are summarized by GeoSyntec et a1. (2002) in documentation for the ASCEIEPA BMP Database. These methods are used when the input database consists of event mean influent and effluent concentrations. 1. Efficiency ratio 2. Summation of loads 3. Regression of loads 4. Event mean concentration 5. Efficiency of individual storm 6. "Irreducible concentration" and "achievable efficiency" 7. Percent removal relative to water quality standards 8. Lines of comparative performance 9. Multi-variate and nonlinear models 10. Effluent probability method

• All of these methods appear to be statistical models that are appropriate to use when the only input data that are available are stonn event mean influent and effluent concentrations. They do not provide a process level characterization ofperformance. Four methods are described below, however, the ASCE


3-15 TCEa Docket No. 2006-0612-MSW Page 33 of 166

• study team (Strecker et a1., 2001) does not recommend any of the first three (EMC, efficiency ratio, regression). In fact, the team recommends that a better measure of BMP performance is the amount of runoff prevented, the amount of flow treated (and bypassed) and the effluent quality of the treated flow. They have observed that BMPs tend to produce a fairly narrow range in effluent quality, and, therefore, percent removal is merely a function of how polluted the inflow is. Characterization of effluent quality is one feature of the EPM, also discussed below, and recommended by the team.

Additional work to standardize BMP monitoring protocols and calculations is needed to make monitoring data comparable from site to site (GeoSyntec et al. 2002). In addition to the EPAIASCE BMP Database reports, documents that summarize BMP efficiency information include the National Pollutant Removal Performance Database (Brown and Schueler 1997), the Terrene Institute's report The Use o/Wetlands/or Controlling Stormwater Pollution (Strecker at al. 1992), and the recent text by Minton (2002).

3.3 EVENT MEAN CONCENTRATION

The term event mean concentration (EMC) is a statistical parameter used to represent the flowproportional average concentration of a given parameter during a storm event. It is defined as the total constituent mass divided by the total runoff volume, although it is usually computed in practice by compositing multiple samples on the basis of the flow rate at the time the sample was taken, prior to sending the samples to the laboratory. The single flow-weighted composite then provides EMCs upon chemical analysis. When combined with flow measurements, the EMC can be used to estimate the pollutant loading from a given storm. Under most circumstances, the EMC provides the most useful means for quantifying the level of pollution resulting from a runoff event. Collection of EMC data has

• been the primary focus of the EPAIASCE BMP database project.

The EMC for an individual event or set of field measurements, where discrete samples have been collected, is dermed as:

(3-1)

= volume of flow during the period j, = average concentration associated with the period and volume Vj, and = total number of measurements taken during event.

Currently, SWMM can easily produce a constant concentration (EMC value) in the Runoff Block and as the output of a treatment device in the SIT Block. However, storage and quality control devices in Runoff and Transport cannot easily (Le., without odd data manipulations) produce a constant outflow concentration different from the inflow concentration. That is, it is not easy to have a constant inflow concentration of, say, 20 mg/L and a constant outflow concentration of, say, 8 mg/L from a Runoff or Transport flow element.

3.4 EFFICIENCY RATIO

The efficiency ratio (ER) is most often used to report BMP efficiency. While this may be appropriate for determining the reduction in pollution for an event, it may not indicate performance of a BMP over time,

• or for events of varying intensity and volume (GeoSyntec eta!' 2002). Another reason is because the ER approach does not consider the statistical significance of the result. Most researchers assume that ER has the meaning of "percent removal." While this method is not recommended for monitoring the



• effectiveness of BMPs, because of the data availability and the wide spread analysis with this method, ER values are often reported in the literature. If modeling with a "black box" approach, average EMC and ER values are simple to implement, e.g., in spreadsheets. The efficiency ratio is defined in terms of the average EMC of pollutants over some time period:

ER =1- average outlet EMC average inlet EMC - average outlet EMC (3-2)

average inlet EMC average inlet EMC

This method (GeoSyntec et al. 2002):

• Weights EMCs from all storms equally regardless of relative magnitude of storm. For example, a high concentration/high volume event has equal weight in the average EMC as a low concentration/low volume event.

• Minimizes the potential impacts of "smaller/cleaner" storm events on actual performance calculations. For example, in a storm-by-storm efficiency approach, a low removal value for such an event is weighted equally to a larger value.

• Allows for the use of data where portions of the inflow or outflow data are missing, based on the assumption that the inclusion of the missing data points would not significantly affect the calculated average EMC.

Comments:

• • Many studies use the ER method to characterize performance, but it fails to take into account some of

the complexities of BMP design, especially media filters and other BMPs that treat to relatively constant levels and are independent of inflow concentrations.

• This method also assumes that if all storms at the site had been monitored, the average inlet and outlet EMCs would be similar to those that were monitored.

• Under all circumstances this method should be supplemented with an appropriate non-parametric (or, if applicable, a parametric) statistical test indicating whether the differences in mean EMCs are statistically significant (it is better to show the actual level of significance found, rather than just noting whether the result was significant, assuming a 0.05 level).

Currently, SWMM can use an efficiency ratio (based on inflow concentration) to simulate BMP performance in the SiT Block. The Runoff and Transport Blocks allow application of a removal fraction to the incoming load, which is similar, but not the same. (It would be the same if the outflow equaled the inflow at the particular time step.)

3.5 REGRESSION MODELS

Regression methods may also be used to evaluate BMPs. These include regression of outlet load vs. inlet load ("load regression") and regression of ER values vs. inflow concentration. The former method has been used with some successto characterize performance (GeoSyntec et al. 2002), although there are many assumptions involved. The current version of SWMM provides this capability in the SIT Block through the use of its "universal removal equation" (Section 4.3). However, regression ofER values against inflow concentration produces spurious correlation (Benson 1965) since it amounts to regression ofEMCou/EMCin vs. EMCin • A seemingly significant regression is inevitable (Benson 1965). That is, the dependent variable includes as a divisor the independent variable EMCin• The resulting relationship implies that removal efficiencies depend on influent concentration, but such a relationship mayor may not exist. It always indicates a spurious relationship between percent removal and influent quality, and

• can lead to misguided "lines of comparative performance" (GeoSyntec et al. 2002, Minton 2002). Regression models are useful in doing preliminary investigations into cause-effect relationships, but they should be restricted to functional forms of how the BMP should work.



• 3.6 EFFLUENT PROBABILITY METHOD

The effluent probability method (EPM) is straightforward and provides a clear, but qualitative picture of BMP effectiveness. The EPM consists of a lognormal probability plot (although any distribution could be used for which probability paper exists, including normal) of EMC vs. either probability of occurrence or percent exceedance (equivalent to the cumulative distribution function, or CDF). Probability plots are among the most useful pieces of information that can result from a BMP evaluation study (Burton and Pitt 2001). The authors of the EPAIASCE BMP Database Monitoring Manual strongly recommend that the stormwater industry accept this approach as a standard "rating curve" for BMP evaluation studies, as it provides a visual representation of the frequency distribution of both influent and effluent quality (GeoSyntec et al. 2002).

Lognormal plots are ordinarily used because the lognormal distribution has been found to be a good fit to most stormwater EMC data (USEPA 1983, Driscoll 1986, Van Buren et al. 1997). One advantage of normality, either of the logs or of the untransformed data, is that parametric statistical tests can be applied, such as the t-test, chi-square test, and analysis of variance. Statistical tests used to compare the difference between data sets typically require normality among the data sets, and some also require the sets to have the equal variances. Lognormal (and normal) probability plots can be used for qualitative guidance, since the same slope of two such curves indicates the same variance of the data.

• The most basic test for normality is whether or not the data plot is a straight line on normal probability paper (or vs. equivalent values of the standard normal variate, z) (Burton and Pitt 2001, Bedient and Huber 2002). Tests for normality itself include tests directly related to probability plots, such as the probability plot correlation coefficient (PPCC) (Vogel 1986) and the Shapiro-Wilk test (Helsel and Hirsch 1992). Tests not related to probability plots include the Kolomogorov-Smirnov test and the chi-square test (Benjamin and Cornell 1970, Helsel and Hirsch 1992). However, the latter are less powerful, in a statistical sense, than tests that use probability plots, not to mention that the plots themselves yield great qualitative information, as discussed below. It is of interest that if ranked data are plotted against standard normal variates ("z-values") obtained from the inverse of the plotting position probability (Bedient and Huber 2002), using Excel, the linear fit of data (untransformed or logarithms) obtained using Excel's "trend line" option provides the required PPCC. The PPCC can then be tested for statistical significance (Vogel 1986, Helsel and Hirsch 1992). The critical values of the correlation coefficient account for the inherent correlation between two ranked data sets (order statistics). If normality, and in some cases equal variance, is ensured among the respective data sets, parametric tests can be employed to test the difference between the means/medians of the data sets.

Parametric and nonparametric statistical tests should be conducted after the probability plots are generated to indicate whether perceived differences in influent and effluent mean EMCs are statistically significant (it is preferable to provide the level of significance, instead ofjust noting whether the result was significant, such as at a 95% confidence level). Helsel and Hirsch (1992) provide an excellent primer on such methods, with applications to water resources and water quality. Many parametric and nonparametric tests are included in standard statistical software.

Regarding the effluent probability plots, there are limited quantitative assumptions that can be made simply on the basis of the plots themselves. As the data rarely enter into the plots as matched pairs (if the quantiles did occur as storm-event pairs, it would be sheer coincidence), there are limited inferences that can be made regarding BMP effectiveness over a particular concentration range. That is, one cannot make such inferences simply on a comparison of quantiles. Only when the data sets are entered as

• matched pairs, as for instance, in a simple scatter plot ofEMCout vs. EMCin, can a quantitative assessment of the removal over specified concentration ranges be conducted. Other authors (Burton and Pitt 2001, p. 584) have discussed the EPM plots, drawing such inferences as "shows that SS are highly removed over


3-18 TCEO Docket No. 2006-0612-MSW Page 36 of 166

•

•

•

influent concentrations ranging from 20 to over 1,000 mg/L." Unless the data are entered as matched pairs, such statements cannot be justified. For example, there may be one particular stonn event in which no removal was observed (the influent and effluent EMC values are the same), but by plotting quantiles, the outcome of any single storm event may not be readily observed. There may be some effluent EMCs that are greater than the effluent data points for stonn events, even though the generated trend line for the influent data set is still higher than the trend line generated for the eft1uent data set. Therefore, removal is not always guaranteed.

However, the relative range of both influent and effluent quality can be determined based upon the concentration range between given percentile values. [n addition, the normality and equal variance among the data sets can be qualitatively observed, although any inferences about variance must be confirmed through quantitative statistical testing. Separation between the trend lines, an indication of removal, may be tested parametrically with a t-test if both lines are lognormal, or by using the nonparametric Kruskal- Wallis or Hodges-Lehmann tests, for example (Helsel and Hirsch 1992). Examples (Brown 2003) of effluent probability plots are shown as Figures 3-1 to 3-3, using data for an extended dry detention facility (Seton Pond) in Austin, Texas (Keblin et al. 1997).

The effluent probability plot for TSS at the Seton Pond facility is shown in Figure 3-1. From the figure, one can gage the relative range of influent and effluent EMCs, as signified by the concentration range between the loth and 90th percentile. The slopes of the influent and effluent trend lines are similar, thus indicating similar variance between the logs of the two data sets. Both slopes appear somewhat flat, indicative of a relatively low coefficient of variation. But of considerable interest, contrary to what might be expected from a visual evaluation, the logs of the effluent TSS EMCs fail two normality tests (Brown 2003). Hence, the parametric t-test cannot be used to compare means. Finally, by comparing the data points plotted, it appears the lowest influent data point is still greater than the highest effluent point. Therefore, this BMP is projected to achieve removal, based upon the relative distance between the influent and eft1uent trend lines and the fact that there is no overlap among influent and effluent data points. This may be conftnned through the non-parametric Kruskal- Wallis test.

.-.~-~---_.----~-.-'--'-'-~I;---,;tI~~-;;t--~-----~--1

! II Effluent I

! - -r. - Method of moments influent ! 1000

'1' j - --- - Method of moments effluent i__ east S !Jares fit affluent

; "",--,__--:lr- • i-===-:~--=-~~_~~~~:~~~~.:~_l_~ :J 1GO l~,.--- .~ ~! __"_. ~_~_: ' I

C, I g [

IIu l· , •• ::it I , ; y 26 Sa7e"'B'.

en w

I 0 L_-_._·_~.,----- -~-- -~-~-~:=.~__I:... -----.•.ren f-

r I i 1 i' , · '-+~-I

-2 17S 1.5 125 1 -0.75 -05 025 0 025 0") 075 1.25 1.5 1.75

Figurr 3-1. Probability plot for TSS removal at the Seton Pond facility, Austin, Trxas (Brown 2003).

In comparison, Figure 3-2 shows the effluent probability plot for nitrate at the Seton Pond facility. Both the influent and effluent EMCs are confinned to be lognonnal (Brown 2003) The range of influent and

COA Exhibit TF-8 BMP ivlodeling Concepts and Simulation SOAH Docket ,'Jo. 582-08-2186

3-19 TCEQ Docket No 2006-0612-MSW Page 37 of 166

• effluent concentrations can still be observed, but the range of effluent concentrations actually exceeds the range of influent concentrations so little can be said about the system perfonnance. The slopes of the influent and effluent generated trend lines are quite dissimilar, indicating differing variance among the logs of the nitrate data sets, and as trend lines intersect, there is little to be said about the removal at any range. With the trend line intersection, it is easily observed that the lowest influent data point is much lower than the highest effluent data point. Therefore this BMP is not predicted to achieve removal of nitrate, based upon the overlap and intersection of data points and generated trend lines. Indeed, the parametric t-test indicates that equality of the means of the logs cannot be rejected as does the nonparametric Kruskal- Wallis test (Brown 2003).

: :

j j

l .Influent l • Effluent

-,- "'000" ~~'" I'"'''"') I 10 -,

II - 1-'" - Method of moments (effluent) iI

I [ Least squares fit (effluent) I

--Least squares fit (Influent) i --------~---I

I I

• i 01 __ ~---i...r_'_______"___~, -'...,...-~_r__----"-_4__'__"_,~_+___"_.~-'--r'.- I----T~__r'_~.

I·2 -1.75 -15 -125 -I -0,75 -05 -025 0 025 05 0.75 125 1.5 1.75 I

I Frequency factor (z)

!

Figure 3-2. Probability plot for nitrate removal at the Seton Pond facility, Austin, Texas (Brown 2003).

The final example in Figure 3-3 shows the enluent probability plot tor total zinc at the Seton Pond facility, The lognormality of both the influent and eftluent EMCs may bi: continni:d by statistical tests. Like the previous plots, the range of inJ1ui:nl and eft1uenl concentrations is easily observed, with only a minimal overlap between influent and enluent ElvICs. The slopes of the trend lines appear dissimilar, indicating differing variance among the data sets. But appearances can be deceiving! The hypothesis of equality of variance bdween influent and eftluent EMCs is not rejected by three statistical tests (Brown 2003). The magnitude of the effluent slope is greater than the magnitude of the influent slope; therefore, the effluent data set is predicted to have a larger coefficient of variation (because the emuent mean of logs is also lower than the innuent mean of logs). Comparing the data points themselves, it appears that the lowest int1uent data point is slightly lower than the highest eftluent data point. Theretore. removal for this BMP can only be ensured through appropriate statistical examination, to detennine whether a signiticant difference does exist between the two data sets, as it can not readily be shown through the plots. Tn fact, removal is continned by both the parametric t-test and non-parametric Kruskal-Wallis test (Brown 2003).

• COA, EXhibit TF-8 BMP ivlodeling Concepts and Simulation SOAH Docket No. 582-08-2186

3-20 TCEQ Docket No. 2006-0612-MS\fII Page 38 of 166

•

•

•

• Influent

• Effluent

- ... - - Method of moments (influent)

. -..- - Method of moments (effluent) 1

I 1--Least squares fit (effluent)I y =a 1517e0 538J• I

R' =08828 --Least squares fit (influent)I

..JI •

0.1 1---en .§.

i • u :;; w t-I <..> 0.01J::

III N •

11 a001 L~~~t--"--r~. --r--f--~~--~~~~>-I -'----,~~

-2 -1.75 -15 -125 -1 -075 -05 -025 0 025 05 0 75 1 125 15 175

Frequency factor (z)

Figure 3-3. Probability plot for total zinc removal at the Seton Pond facility, Austin, Texas (Brown 2003).

In many WilYS, the qualitative inferences from the EPM may also be obtained from other descriptive statistics, such as box plots, as well as quantitatively through the parametric t-test and non-parametric comparisons of medians. However, the EPM has the advantage of illustrating the lognormal (or other distribution) fit of the data, rather than simply certain quantiles, as with box plots. The primary problem with the EPM is that certain quantitative assumptions, such as removal and performance at or around a certain concentration value, cannot be made unless data points are entered as matched pairs (e.g., as in scatter plots of effluent vs. intluent EMC). This discrepancy was noted in the CalTrans BMP study and ilSSeSSl1lent (CillTrans 2003), indicating that interpretation of these plots should be performed in conjunction with related analyses, such as scatter plots. Another concern raised with the EPM is its ability to provide sufficient information regarding BMP selection. In areas requiring a set removal percentage, use of the EPM may not adequately portray whether a BMP is capable of meeting that perfonnance standard (CalTrans 2003). However, the EPM retains the advantage of being able to deal easily with iln unequal number ofin£luent and eft1uent EMC data points.

Currently, SWMM is not capable of simulating a prescribed lognonnal (or any) frequency distribution, either for intluent concentrations or for BMP outtlows. That is, it is not possible to enter parameters ot-a lognornlal distribution as a Runoff Block option instead oC say. a buildup-washoffformulation. [n principle, such a distribution could be obsef\!ed over the period ot- a long-term continuous simulation from constituent quality generated by buildup-washotT or another mechanism (Huber et al. 1987), but the need here is to specify a distribution a priori_ Equally useful would be a method to simulate the water quality of runoff on the basis of a specified frequency distribution. This would be an option to be used instead of buildup-washoff, constant concentration, etc. Likewise, the frequency distribution of BM P eftluent EtvlCs could be prescribed, on the basis of observed data. However, it should be noted that the SWMM Statistics Block is capable of analyzing any tlow or quality timt: series that can be placed on an "interface file" as the output of as WMM Block, to generate frequency distributions and identify lognormal parameters through the method of moments. This could easily be enhanced through the SWMM5 GUl.

COA Exhibit TF -8 BMP Modeling Concepts and Simulation SOAH Docket No. 582-08-2186


••

• 3.7 SIMULATION MODELS

•

Simulation models allow evaluation of long-tenn rainfall to assess volumes of stonnwater treated by BMPs and how much is bypassed, or processed at rates that result in non-effective treatment. Thus, in principle, a simulation model can provide all the infonnation needed to evaluate a BMP that would be prohibitively expensive to collect in a monitoring program - if the model is to be believed. This includes information such as much of the rainfall record is treated or controlled. The dynamics of the filling and emptying of these BMPs is vital to understanding treatment efficiencies and runoff removal rates.. The bulk of this report will be devoted to evaluating the effectiveness of SWMM in this regard and examining alternative simulation algorithms from other models.

In the event that a model such as SWMM has not been specified a priori, searching for a model that characterizes BMP effectiveness is not simple. The lack of consistent and concise evaluation ofmodeling abilities makes choosing a model quite complex and time consuming. Just as BMP effectiveness monitoring is currently being standardized, so is model evaluation. Model descriptions may be found in texts and reports (e.g., Singh 1995, Field et al. 2001, Debo and Reese 2002, Field and Sullivan 2003, Field et al. 2004), but anything printed may soon lose currency. One such listing is shown in Table 3-1. Web pages, such as a circa-1998 site provided by the Great Lakes Sediment Management Program (http://www.glc.6rg/tributary/pdf/allweb32.pdf), can provide lengthier and timelier model infonnation - if they are updated!

Some models listed in Table 3-1 do not perfonn quality calculations; they are included in this listing because 1) they are commonly used in urban areas of the U.S. and Canada, and 2) quality loads are often computed after an accurate hydrologic and hydraulic model is run, simply by multiplying flows by EMCs. Additional, less common models evaluated as part of this study are listed in Chapter 5.

COA Exhibit TF-8 BMP Modeling Concepts and SimulaUon SOAH Docket No. 582-08-2186


• • • Table 3-1. Primary urban hydrologic, hydraulic and water quality models commonly used in the United States•

---- ...-, ...._ ----- .. ................ __..... .............._.... --- --, -..,..,_.~

Graphical Hydrology/

Continuous Complete QualityModel Agency/Source Primarily Simulation? User

Hydraulics Dynamic Flow Simulation or

Interfacel ANNIE",d

Storm Event Routine? Hydrology No Yes

FEQa,b DR3M-OUAL" CS/SEUSGS

No No HEC-I/HMSc

Hydraulics YesUSGS SE Hydrology No Yes

HEC-2/RASc HECNendors SE No

Yes HSPP",d

Hydraul. (backwater) Steady state No NoHECNendors ANNIEa,d,Hydrology CS/SE Yes EPA BASINS

InfoWorks cst

EPA No

Yes Montgom. Watson in US

MIKE llf

HR Wallingford in UK, Hydrology/Hydraulics CS/SE Yes Yes

Hydraulics (open Yes Yes channels)

MOUSEl

Danish Hydraulics Inst. SE Yes

Hydrology/Hydraulics Yes Yes P8g

Danish Hydraulics Inst. CS/SE Yes Wm. W. Walker, Jr. Hydrology No Yes Menu

Santa Barbara CS/SE

HydrologyVendors No No 3rd party SCSh

SE HydrologyNRCSNendors 3rd party

*SewerCAT' SE No No

.Yes SLAMM1

Reid Crowther Consult. Hydraulics SE Yes No Hydrology No

*STORMc R. Pitt CS No Yes HECNendors Hydrology NoCS No Yes

SWMMd,l,k Hydrology/Hydraulics 3rd party UNETc

EPNOSU CS/SE Yes Yes HydraulicsHECNendors SE No HECDSSYes

Web addresses for models begin with prefix: http:// a. h2o.usgs.gov/software/surface_water.html b. www.dilurb.er.usgs.gov/proj/feq/ c. www.hec.usace.army.miV d. www.epa.gov/ceampubl/softwdos.htm e. www.hrwallingford.co,uk/ f. www.dhi.dk g. www.wwwalker.net/p8/ h. www.ncg.nrcs.usda.gov/tech_tools.html i. www.ccee.orst.edu/swmm (not currently available, contact Dr: C. Vitasovic at DHI) j. 3p == 3rd party (e.g., an outside vendor) k. www.epa.gov/ednnrmrl/swmm/index.htm (for SWMM5) I. www.eng.ua.edu/-rpittiSLAMMDETPOND/WinSlamm/WINSLAMM.shtml *May not be currently available.



•

4 CURRENT SWMM SIMULATION CAPABILITIES

4.1 THE MODEL

The EPA SWMM is a dynamic rainfall-runoff simulation model, primarily but not exclusively for urban areas, for single-event or long-term (continuous) simulation. Flow routing is performed for surface and sub-surface conveyance and groundwater systems, including the option of fully dynamic hydraulic routing in the Extran Block. Nonpoint source runoff quality and routing may also be simulated, as well as storage, treatment and other BMPs.

• Version 40f the SWMM evolution is currently (March 2004) at version 4.4h (Huber and Dickinson 1988, Roesner et al. 1988). The most current release of version 4.4h can be downloaded from the Oregon State University website (www.ccee.orst.edu/swmm). Simulation of storage and treatment was generalized in Version III of the model (Nix et al. 1978) so that algorithms were not specific to individual devices. SWMM has been through many modifications'since Version II, and since the first version 4 release in 1988, it now includes several options that enhance the model's ability to simulate BMPs and general control options for management of stormwater and combined sewers (Huber 1996, Huber 2001 b). Version 4.4h will gradually be replaced by SWMM5, developed by the EPA, as that object-oriented model and its GUI gain functionality (hUp://www.epa.gov/ednnrmrl/swmm/index.htm). However, most of the BMP and LID simulation capabilities described for version 4.4h also apply to SWMM5.

SWMM capabilities regarding simulation of wet-weather control (WWC) alternatives have been discussed in Chapter 1 and summarized in Table 1-4. The following text discusses significant control options and consequent SWMM simulation capabilities.

4.2 STORAGE

Storage in an urban catchment may occur on the ground surface, in the drainage system, and in specific storage devices (e.g., ponds, tanks, secondary flow removal devices). Pollutant removal occurs primarily through sedimentation and decay. SWMM is most effective at simulating storage-type BMPs because such devices have been extensively studied and information about them is widely available. Flow routing through storage is easily performed using a variety of methods, and multiple outlets (and bypass) may readily be simulated. SWMM also has the ability to simulate hydraulic controls and time-dependant regulators (such as weir and orifice settings that depend on stages in specified locations), although these options are primarily located within the Extran block, which does not model water quality. Storage

• options are available in the Runoff, Transport, Extran and Storage/Treatment (S/T) Blocks.



•

•

•

SIT quality removal may be based on a fIrst-order process, for which simple fInite difference formulations exist for well-mixed (i.e., continuous-flow, stirred-tank reactors or CFSTRs) or plug-flow systems. (However, see discussion of possible errors in the manner in which the SIT Block simulates well-mixed, fIrst-order decay, in Section 4.3 below.) A second mechanism consists of a generalized removal equation designed such that most empirical or other results can be mimicked (Section 4.3). For example, removal of a given pollutant can be computed as a function of concentration of any pollutant, removal fraction of any other pollutant, and/or detention time. A third removal option is by sedimentation using Camp's (1946) theory for quiescent conditions, modifIed for turbulence by Chen (1975). For this formulation up to fIve settling velocity ranges must be defIned and then routed through a progression of up to fIve SIT units. While this third option is ideal for simulation of SIT units in series (e.g., a treatment train), unfortunately, such pollutant characterization is not generated elsewhere (upstream) in the model. That is, treatability data are typically not generated by the model upstream of the SIT Block and cannot be linked - unless the user specifIcally simulates discrete particle size ranges as separate constituents in upstream blocks, which certainly is an option.

Removal by fIrst-order decay may also be simulated in the Transport, and Runoff Blocks, assuming complete mixing (in accordance with their quality routing methods) within conveyance and storage elements. Constituents in Transport and Runoff Block channels, pipes, and storages are also subject to removal based on constant removal fractions applied to incoming loads and settling with a constant settling velocity (Huber 200 1b).

Interactions among water quality constituents are simulated minimally in the SIT Block (e.g., removal of one pollutant can depend upon removal of another, in the manner of sorption). The Transport Block has a relatively untested capability to simulate linked BOD-NOD-DO dynamics, essentially using a modifIed Streeter-Phelps analysis (Huber 2001b) in the manner of WASP (Wool et al. 2001). There is only limited capability in SWMM to simulate combined physical-biological removal processes in wetlands and bioswales except to the extent that such removal can be characterized by the processes to be described.

To summarize, fundamental process categories of sedimentation, biological removal, sorption, f1ltration, flotation, chemical treatment, high-rate biological treatment, degradation, hydrodynamic separation may all be mimicked by the SIT Block as long as removal characterization relations are available. However, the only FPCs simulated explicitly in storage are fIrst-order decay (e.g., for degradation) and sedimentation.

4.3 SIT GENERALIZED REMOVAL EQUATION

Because the generalized removal equation or "universal removal equation" or "one-equation-fIts-all" may be used for several purposes, additional information is provided here.

The "universal removal equation" within the SIT Block is

where Xi = removal equation variables (model state variables), aj = coeffIcients, R = removal fraction, 0 ~ R ~ RMX ~ 1.0, and RMX = maximum removal.



• The removal fraction is applied to the load (mass) in a plug (for plug flow), at each time step. The removal fraction can thus be made a function of selected state variables, Xi. Each removal equation variable (selected state variable), Xi, may represent one of several variables available in the program at each time step, such as an inflow concentration or residence time, described further below. With these variables and the coefficients, ai, the user can develop the desired removal equation.

An example of the application of Equation 4-1 for plug flow is provided by the common exponential removal equation characteristic of tank reactors and ponds observed in EPA Nationwide Urban Runoff Program (NRUP) studies (USEPA 1983). For suspended solids (SS) this might be:

R =R (1- e-kId) (4-2)ss max

where Rss = suspended solids removal fraction, a:$ Rss :$ Rmax :$ RMX,

= maximum removal fraction in fitted equation, Rm""

RMX = maximum removal, an SIT input variable, :$ 1.0., td = detention time (sec), and k = first order decay coefficient (lIsec).

This equation can be constructed from Equation 4-1 by setting al2 = Rmax, al3 = -Rm"", a3 = ok, al6 = 1.0, and letting X3 = detention time, td (by setting INPUT(I,IP,3) = 1 on data group G2 in SWMM SIT). All other coefficients, aj would equal zero. RMX would not be necessary, as Rm"" limits the value ofR.

Well-mixed storage units are simulated by a finite-difference solution to the conservation of mass• equation for a CFSTR (Chapra 1997):

dVC =IC I -QC-kCV (4-3) dt

where C = well-mixed concentration in storage unit, V = volume in storage unit, I = inflow to storage unit, CI =inflow concentration in inflow to storage unit, Q = outflow from storage unit, t = time, and k = first-order decay coefficient, lItime,

All variables except k are functions of time for a variable-volume storage device. Since storage routing is performed before the quality computations, inflows, outflows, and volumes are known at the beginning and end of each time step, leading to a finite difference formulation used in SWMM SIT,



• Change in Mass entering Mass leaving

mass in ba sin = Decay during ~t during ~t during ~t

during~t

C~In +C~+lIn+l ~t CnQn + Cn+1Qn+l ~t k CnVn + Cn+1Vn+1~t 2 2 2

(4-4)

where subscripts nand n+1 refer to the beginning and end of a time step, ~t. Equation 4-4 is then solved for the unknown CFSTR (and effluent) concentration Cn+b

(4-5)

When a CFSTR is simulated, the equation (Subroutine EQUATE, called from Subroutine UNIT in the SIT Block) returns the product ofk-~t, where k = first order decay coefficient (l/time) and ~t = time step.

• This is done mechanistically by setting the X2 variable = 1 on the SIT G2 line such that it will equal ~t

when Equation 4-1 is evaluated. Then set a2 and al6 = 1.0, and al2 =k.

However, there are some undocumented time step limitations to this process with the current Fortran coding. The first is that the maximum value of the product k·~t is input parameter RMX (maximum removal per time step, useful for plug flow but also used for complete mixing), which in tum has a maximum value of 1.0. Hence, the maximum 'value of k that the program will end up using is RMXIM or 1/~t. Thus, ifk·~t > 1.0, an effective k value will be used, lI~t, that is smaller than that input by the user. The other consideration is the nature of the finite difference form of Equation 4-3, namely Equation 4-4. For constant inflow, outflow and, therefore, constant volume, the finite difference solution (Equation 4-5) can be reduced to:

CIQ-~t 1_~t(Q+k)

C = V +C 2 V (4-6)n+l ~t Q n ~t Q1+-(-+k) 1+-(-+k)

2 V 2 V

where n,n+l = previous and new time steps, respectively, C = concentration in outflow and in storage unit,

Cl= average inflow concentration over the time step,

~t = time step,

Q = constant inflow and outflow, and V = constant volume.

• It can be seen that if 1- ~t (Q + k) < 0, negative concentrations can result, and if the term is 2 V



• < -1, unstable computations can result. Because Q and V vary during a real SIT simulation, it is not necessarily easy to predict whether or when this will occur.

The conclusion is that Equations 4-4 and 4-5 are a.poor method for solving Equation 4-3. Better would be to use a standar.d 4th order Runge-Kutta (RK4) numerical solver for the ordinary differential Equation 4-3. This is the method that will be implemented in SWMM5.

In passing, it should be observed that the current SWMM solution for complete mixing in Runoff and Transport channels, pipes, and storage elements does not use the SIT finite difference method. Instead, an integrated form of Equation 4-3 is used, wherein the analytical solution is obtained for a duration ofone time step, as explained in Appendix IX of the User's Manual (Huber and Dickinson 1988). The method has proven stable and non-negative with respect to the time step. However; the only removal option is first-order decay except for the largely untested implementation of a settling velqcity and constant removal fraction, provided to SWMM version 4.4h in spring 2002 and described in the next subsection.

Considerable additional concepts for simulating storage in SWMM are provided during the discussion of ponds, in Section 6.4. The transition between plug flow and complete mixing is also discussed therein.

4.4 MODIFIED STREETER-PHELPS OPTION

4.4.1 Objectives

• The Transport Block is typically applied for urban drainage systems consisting of conduits and open channels, but there are often instances in which it would be useful to have a simplified receiving water quality simulation capability available. This is available with the modified Streeter-Phelps option, for which parameters are input in data groups F3 - F6 (with reference to SWMM version 4.4h). These options permit dissolved oxygen (DO) to be linked to decay of carbonaceous biochemical oxygen demand (CBOD) and nitrogenous oxygen demand (NOD). This option is probably warranted only when Transport is used to simulate a stream extending several miles downstream from the urban loading. Most sewer systems remain saturated with DO because of their high turbulence, in spite of the heavy oxygen demand. Nonetheless, this modified Streeter-Phelps option may be run for any Transport channel, conduit, or storage unit. In fact, quality routing is performed for any element containing a volume of water, including wet wells and manholes containing surcharge. As explained earlier, use ofSWMM version 4.4h will diminish with the release of SWMM5, hence, the descriptions that follow may be considered as candidate algorithms for inclusion in SWMM5 flow objects.

The modified Streeter-Phelps method is included as a WASP model option (Wool et al. 200 1), and the theoretical formulation (described below) in SWMM is very similar. The WASP model itself is another (much more comprehensive) option for simulation of receiving water quality. A special hydrodynamic link from the version 4.4h Transport Block allows Transport to "drive" the WASP water quality model by providing the needed file of flows, velocities, and storages. A similar option is available in the Extran Block. Although the SWMM Transport formulation is based on the WASP model, classic DO kinetics apply (e.g., Thomann and Mueller 1987, Chapra 1997).

The presentation in this subsection also serves the purpose of introducing a more general form of CFSTR kinetics than is provided by Equation 4-3. Although the kinetics to be demonstrated in Equations 4-9 - 412 are specifically for the Modified Streeter-Phelps formulation, it will be seen that variants on Equation 4-9 (for just one constituent) are used in the model algorithms of several models that are discussed in Chapters 6 and 7. .



• 4.4.2 Theory

Classic Streeter-Phelps simulation of water quality applies to steady-state flows and considers only input of ultimate biological oxygen demand (BODu or CBOD in notation that follows), linked to DO through its first-order decay. In turn, DO is depleted by BOD and replenished by reaeration. The so-called modified Streeter-Phelps includes an additional nitrogenous oxygen demand, wherein total Kjeldahl nitrogen (TKN) decays to nitrate-nitrogen (N03-N). Formally,

Organic-N ---+ Ammonia ---+ Nitrite ---+ Nitrate (4-7)

during which Nitrosomonas bacteria convert ammonia to nitrite and Nitrobacter bacteria convert nitrite to nitrate. Hence, there are three reactions to consider. The reactions are usually considered to be firstorder, but Michaelis-Menten (or Monod) kinetics may also be employed (Chapra 1997), an option in WASP (Wool et al. 2001) but not SWMM. The modified Streeter-Phelps method simplifies the process by ignoring the conversion of organic-N to ammonia and using their sum, TKN = organic-N + ammoniaN, as total nitrogenous oxygen demand, or NOD. The NOD is decayed directly to nitrate, without the typically-brief intervening nitrite step. Hence, the true three-reaction process is reduced to one. Chapra (1997, p. 425) points out the shortcomings of this method, including the fact that because of the delay in converting organic-N to ammonia, there is usually a delay in the appearance of a nitrogenous oxygen demand relative to CBOD. Nonetheless, the objective was not to develop the Transport Block as a sophisticated receiving water quality simulation model, but rather to provide for at least a minimal DO simulation capability, similar to this intermediate (modified Streeter-Phelps) option in the WASP model.

• When ammonia is oxidized to nitrate, oxygen is used according to

(4-8)

From the ratio of molecular weights, 64/14 = 4.57 mg of oxygen are needed to convert one mg ofNH3-N to N03, where 64 = 2 x molecular weight of O2 and 14 is the atomic weight ofN. This stoichiometric factor is included in the coupled conservation equations.

The SWMM Transport Block simulates the linked DO-BOD-CBOD process in four steps for every element containing storage (including pump wet wells and surcharged manholes), as follows (symbols are defined in Table 4-1 following the four equations):

Step 1, for CBOD =C\:

(4-9)

(Equation 4-9 will also serve as a more general reference equation for CFSTR kinetics in sections that follow, wherein C j would be any constituent ofinterest.)

Step 2, for NOD =C2:

(4-10)



• (4-11 )

Step 4, for DO deficit D == Cs - DO:

dD dV io Q k C V 4 k V k SODV-+D-=Q;D - D+ 1 I + .57 NC2 - 2D -----=-V (4-12)ili ili d

•

T hi 41 Sa e - . hidm 0 s an tparame ers ~ r k d DO-BOD NOD' I tior lD e - slmu a on, E f~aua Ions 4 9 - - 4 12-Equation SWMM Units· . Definition Input Value Symbol v.4.4h Para- RangeC

Name meter V VOL fe Volume Ci CPOL mg/L Concentration of constituent i D DEFICIT mg/L DO deficit = Cs DO DO CPOL(4) mg/L Dissolved oxygen conc. Cs CSAT mg/L Saturation DO conc.

Oi 01 cfs Inflow to element

0 00 cfs Outflow from element dV/dt DVDT cfs Change in volume of element during

one time step C/o CPOL mg/L Concentration of inflow Li cfs·mg! Other loads. In SWMM, these are due

L to possible scour and deposition Ri TREMOVE none Removal fraction for constituent i Y 0-0.9

applied to incoming load to element, k l DECAY(1) l/day First-order BOD deoxygenation Y 0.1 ·5

coefficient, sometimes known as kd•

Vsi VSETL ftls Settling velocity for constituent i Y As AS fe Water surface area of element F; FDIS none Dissolved fraction of constituent i (does Y

not settle) kN DECAY(2) l/day First-order NOD deoxygenation Y 0.1 - 2

coefficient. k2 DECAY(4) l/day Reaeration coefficient, sometimes y b I - 5

known as k•. SOD SOD g!ft2

• Sediment oxygen demand Y 0.006 - I day

d DBAR ft Average depth = cross sectional area I top width =volume I surface area

•Umts are for those required for input If an input parameter, else, for internal use in the Transport Fortran code. ~he reaeration coefficient may also be computed by the program as a function of velocity, depth, and wind speed. cValue ranges are given only for input parameters. When no range is entered, values are too site specific

• to list. Good sources for parameter estimates include Mills et al. (1985), Schnoor et al. (1987), Thomann and Mueller (1987), Chapra (1997) and Wool et al. (2001).



• When the modified Streeter-Phelps option is used, CBOD, NOD, N03-N and DO must be the first four constituents simulated. Additional quality constituents can be identified starting with constituent 5, etc.

The total mass of a constituent consists of a dissolved and particulate form, i.e.,

(4-13)

where Clot = concentration of total mass of constituent, mg/L, Cdis = concentration of dissolved component, mgdis/L, and Cpart = concentration of particulate component, mgpart/L.

The dissolved fraction may be determined if the partition coefficient, Kd, is known (Chapra 1997):

(4-14)

where r = ratio of mass in particulate (adsorbed) form to mass in dissolved form, mgpart/mgdis, and ~ = partition coefficient, Llmgdis.

The relationship (isotherm) for r between the particulate and dissolved fraction may be in a linear, power function (Freundlich), or Monod-type (Langmuir) form (Chapra 1997) and may be determined

• experimentally. The particulate concentration is related to the concentration of suspended solids, Css, by

Cpart = r Css = Kd Cdis Css (4-16)

Hence, the total concentration is

(4-17)

and the ratio of dissolved to total is

(4-18)F=---

1+ KdC SS

and the particulate fraction is

(4-19)I-F= KdCSS

1+ KdC SS

Hence, the dissolved and particulate fractions in Equations 4-9 - 4-12 and more generally for any constituent can be determined if the partition coefficient is known.

Equations 4-9 - 4-12 illustrate the typical way of linking the decay of CBOD and NOD to oxygen demand through first-order rate processes. The equations are solved in order, and the solution to earlier equations (e.g., 4-9 for C, and 4-10 for C2) are inserted into later equations; all of which are solved analytically using average values for flow and volume over a time step. The solution process is described in the version 4 documentation (Huber and Dickinson 1988) Appendix XI and documented with comment

• statements in the Fortran subroutines QUAL, QUALPARM, QUALSOLN, and REAERATE. Conceptually the solution process is likely to be simpler in SWMM5 (if implemented) through the use of a Runge-Kutta solution for the four simultaneous equations.



• The equations have similar parameters, with the exception of equation 4-12 for DO deficit. No removal fraction is assumed to be available for DO, nor is there a scour-deposition load. Both effects are accounted for in the relation of DO to CBOD and NOD. Although nitrate is allowed to be nonconservative, in natural waters this is usually manifested by uptake by algae. While a non-conservative effect could be simulated with Transport, this model is unable to "close the loop" involving conversion to organic nitrogen, etc. A complete ecological model that includes algal and phosphorus dynamics is needed if such effects are to be simulated, such as WASP (Wool et al. 2001) or HSPF (Bicknell et al. 1997).

Additional assumptions include: • First-order rate constants are not differentiated in Transport between sewage or "bottle" rates and in

stream rates. However, a different k1 value can apply along stream segments than applies for conversion of BOD5 to CBOD. The value used to convert 5-day BOD (BOD5) to ultimate BOD (CBOD) is the DECAY value entered for CBOD. The conversion is (Chapra 1997):

(4-20)

with units of day' I for k1• Hence if BOD loads are provided for BOD5 rather than for CBOD, inflows will be converted to CBOD by Transport using Equation 4-20. Differing in-stream values for k1 and kN may be entered for desired elements, else earlier values entered serve as the default values.

• • Differentia,tion of k1 values used in the stream into stream decomposition and stream settling rates

(day·I) must be made by the user. But since settling is included directly as a removal process, this should not be necessary.

• The simplification of nitrogen dynamics into one first-order process has already been discussed. This is the fundamental assumption of the modified Streeter-Phelps equations.

• "Travel time" commonly encountered in S'treeter-Phelps formulations here is volume/flow, V/Q, for an element, each of which is treated as a CFSTR. Concentrations are averages for the entire volume of the element, and the same as the outflow concentration.

• It is important to consider the volume change term, dV/dt, especially for situations in which an element is only draining (no inflow) or only filling (no outflow). The dV/dt term can also act to concentrate constituents when there is evaporation. Evaporation is not currently included in the Transport Block, but the same equations apply in the Runoff Block where the effect of evaporation can be seen to concentrate pollutants in very shallow flows.

• Settling is allowed for every constituent except DO (or DO deficit). For a constituent that is normally dissolved, such as N03-N, simply set Vsi = 0 and/or the dissolved fraction, f j = 1.0.

Temperature corrections may be applied to the k1 and kN values according to the Arrhenius equation (Chapra, 1997):

(4-21)

where 6 is a dimensionless temperature coefficient. Typical values are 1.047 for BOD (Le., for K1) and 1.08 for NOD (i.e., for KN) (Thomann and Mueller 1987). "Theta values" THETA 1 for BOD and THETA2 for NOD must be provided as input values to the program.



• 4.4.3 Reaeration

Oxygen is replenished by flow-driven and wind-driven reaeration. Options for both are similar to those of the WASP model (Wool et al. 2001), which uses Covar's (1976) formulation for the flow-driven reaeration coefficient, K2, and O'Connor's (1983) formulation for wind-driven reaeration. Flow-driven options allow a reaeration equation of the form,

(4-22)

where U = average velocity in flow element, ft/s,

and Coefl, Coef2, and CoeD are empirical coefficients commonly employed in reaeration equations (Rathbun 1977). The user may input his/her own values for the three coefficients or use the Covar (1976) option for which the coefficients are set to values corresponding to three different equations depending on the flow regime. For wind-driven reaeration, O'Connor's (1983) methods are followed, involving an iterative solution for the drag coefficient.

4.4.4 Summary

• The Modified Streeter-Phelps solution just described is applicable to the discussion of BMP simulation since treatment (e.g., decay, settling) can occur along any flow path. Apart from the linked constituents represented by Equations 4-9 - 4-12, the current Transport and Runoff quality routing formulations are of the form of Equation 4-9 and permit decay, settling, and removal (with load fraction R) within any flow element. To the extent that a BMP may be represented by a fundamental process such as decay or settling, or by a load removal fraction, Equation 4-9 is applicable, and several variations on this basic equation will be seen in sections that follow, particularly for ponds and wetlands. Ifwarranted, the equation could be adapted to one-dimensional ,analysis instead of the CFSTR formulation, through inclusion of an advective term. Equation 4-9 may be solved analytically (over one time step, with average flow parameters, e.g., Medina et al. 1981, Huber and Dickinson 1988, Appendix IX) or numerically for the downstream concentration. Hence, BMP simulation in SWMM5 wi111ikely include computations involving fundamental processes as well as simple, empirical removal fractions.

4.5 INFILTRATION

Infiltration into the soil is simulated only for Runoff Block overland flow planes. With the capability to route overland flow from one overland flow plane to another, infiltration of runoff diverted to large surfaces such as lawns and vegetated buffers may be simulated easily (see Section 4.6). Miniature overland flow surfaces as might be found in rain gardens, roof vegetation, and infiltration trenches may also be simulated with this option; the key assumption is one of vertical "walls." Hence, many LID options can be simulated in this manner, especially since overland flow planes are also subject to evapotranspiration (ET) and possible groundwater interaction. Since overland flow is also subject to firstorder decay, constant removal fractions (based on load), and constant settling velocities, these plane segments offer several options for simulation of infiltration BMPs. However, the lack of infiltration from more general channel segments limits SWMM's ability to simulate swales and infiltration from porous channels, not to mention storage devices in general. Part of the difficulty is determining the effect of sedimentation and water depth on infiltration rates. In real systems, some measure of maintenance and perhaps seasonality should also be considered.

• Porous pavement is an important option for reduction of runoff volumes. The current SWMM can simulate porous pavement to the extent that the infiltration through the pavement (or paving stones) can



• be modeled using Horton or Green-Ampt infiltration equations (see Section 12.3). Subsurface drainage (e.g., out a highway embankment) may be simulated using the groundwater option (James et al. 2001). But SWMM does not simulate quality processes in groundwater.

To summarize, infiltration may be simulated only for overland flow planes, not for channels. This still pennits a wide variety of LID and BMP options to be modeled, but the lack of combined infiltration and channel flow routing is a SWMM limitation.

4.6 OTHER WET-WEATHER CONTROL OPTIONS

Other wet-weather control options include non-structural measures such as street cleaning, catch-basin cleaning, and pollutant load re.duction. Street cleaning may be simulated directly in the SWMM Runoff Block. Catch-basin cleaning and other pollutant load reduction measures (e.g., "good housekeeping") may be simulated only by a reduction in buildup rates or assumed EMC values.

Several hydraulic control options may be simulated in the Extran Block and to a lesser degree in the Transport, Runoff, and SIT Blocks. Within Extran for instance, flow regulation based on stages and timed orifice settings may be. simulated, as well as complex combinations of storage, pumping, and bypassing. The Extran capability points toward real-time control (RTC) simulation, but such capability awaits future enhancements in SWMM5. SWMM5's ability to be stopped in the middle ofa simulation for a change in regulator settings and/or other variables is especially intriguing for RTC simulation. Although flow rates and volumes may be tabulated along various pathways, corresponding water quality is not yet simulated within Extran. If a constant EMC can be assigned to various pathways, after-the-fact

• estimates of loads may be made.

Continuity checks can be used to reflect various removal pathways including infiltration. Iterative application ofSWMM can be used to design a facility with the desired combination of quantity and quality control (Huber 2001 b) - within the limits of the model to simulate such controls.

4.7 LID SIMULATION OPTIONS

Hydrologic source control is at the heart of LID, for which every effort is made to retain stonnwater at or near its source and dispose of it via infiltration and ET. For LID technologies, modeling options are needed that allow runoff to be directed from one subcatchment to another (for areas with differentslopes, soil types or ground cover), and that allow impervious areas to be routed over pervious areas (and vice versa), e.g., rooftop run'offto be routed over lawns. Overland flow infiltration-based controls may be simulated in the SWMM Runoff Block by redirecting runoff from impervious areas onto pervious areas, and from one subcatchment to another (Huber 2001 a), in the manner shown in Figure 4-1. It shows routing from the impervious sub-area of a subcatchment to the pervious' sub-area of a subcatchment. The scheme is similar for flow from pervious to impervious sub-areas, and subcatchment outflow can also be directed to another subcatchment. Lee (2003) demonstrates the model's efficacy for analysis of distributed stonnwater quantity and quality control alternatives.

COA Exhibit TF-8 . • BMP Modeling Concepts and Simulation SOAH Docket No. 582-08-2186


• Width

(

mpervious

)

To channel pipe inlet or another subcatchment

Figure 4-1. Conceptual routing from the impervious sub-area of a subcatchment to the pervious sub-area of a subcatchment (Huber 200la).

• This rerouting also allows for the simulation of buffer strips or riparian zones. Inflow to the downstream subcatchment is distributed uniformly over the downstream subcatchment in the same manner as rainfall. This can be done because of the nonlinear reservoir flow routing method in which there is no longitudinal variation through the subcatchment. Runoff Block overland flow planes simulate surface infiltration and evaporation. Soil moisture accounting is possible if the subsurface flow option is used. In this case, ET from the upper unsaturated zone and lower satj,lrated zone may both be simulated. However, the link with surface infiltration is indirect, affecting infiltration only if the soil becomes completely saturated. Otherwise, infiltration capacity for the Horton or Green-Ampt method is regenerated heuristically, and not as a function of ET. A direct link between regeneration of infiltration capacity and ET is needed. However, the current SWMMcan still simulate most LID options for hydrologic source control. This has been shown by Lee (2003) and will be demonstrated in the discussion of SWMM simulation capabilities for infiltration that follow, as well as in a detailed example for Portland, Oregon (Chapter 14).

As mentioned earlier in this report, overland flow planes may be used to simulate any surface with an assumed plane surface and vertical "walls" such as roof top vegetation, vegetated buffers, and infiltration trenches. Redirection of flow from impervious areas to pervious (simulating the effects of downspout disconnection, for instance) has a major impact on the predicted downstream hydrograph. Not only does this affect the peak flow, but also the total flow volume and corresponding pollutant load.

4.8 SWMM LID MODELING NEEDS

A significant feature lacking from the Runoff and Transport Blocks is the ability to simulate infiltration from channels. This means that swales or porous channels in which routing and cross-sectional shape effects may be important cannot yet be easily simulated in SWMM. This capability is lacking primarily because of lack of information on the effect of water depth on infiltration rates and because of the need for a heuristic method to simulate the effects of sedimentation and clogging of pores and possible periodic

• maintenance.

Apart from processes that truly are first-order, sedimentation in storage or flow devices is the only



• fundamental treatment process simulated in the model; all other fundamental treatment processes must be mimicked through manipulation of removal equations. Biological processes, chemical and physical processes that occur in wetland, bioswales, and riparian zones can only be simulated to the extent that they may be characterized as defined above.

Infiltration through porous (or penneable) pavement may be perfonned adequately with current SWMM algorithms for infiltration and groundwater flow (James et al. 2001). This will be explained later in the chapter on porous pavement (Section 12.3).

Finally, sediment transport can barely be simulated in SWMM - only in the Transport Block, and only through the use of simple scour-deposition criteria. Hurdle (2001) reviews options for improving SWMM sediment transport routines, none of which are straightforward. However, for the model to be able to characterize treatment based on solids settling, improvements in the overall ability of SWMM to erode, transport, deposit, and scour sediment need to be provided.

4.9 TIME AND SPACE RESOLUTION ISSUES

•

The Runoff Block is very stable with regard to size of simulated subcatchments. SWMM can model very small parcels (current research has taken catchment size down to 0.03 ac, but there really is no lower limit); however, the time step needs to be adjusted to be smaller than the retention time (V/Q). For instance, a time step S I min might be used, compared to the more typical 5-min value routinely employed. With personal computer power this should not be an issue. Finding rainfall data on a small enough time can be a problem, as most data come at a minimum of 15-min intervals. Fifteen-minute data are much too coarse to simulate micro-scale hydrologic processes, but from the point of view of assessment of the vertical water balance storage options (as opposed to peak flow rates), such data may suffice. This is because the vertical ~ater balance processes that are characteristic of small-scale LID options (ET, infiltration, soil moisture routing) typically occur much more slowly than do overland flow runoffprocesses. Some of these issues will be clarified through additional experience with application of SWMM continuous simulation to miniature subcatchments (e.g., rain gardens). For a process model like SWMM, the issue of temporal and spatial variability is largely an issue of data availability and the amount of detail desired in the simulation run. In case that rainfall data shorter than 15-minute interval is desired, a data disaggregation procedure is presented in the companion project report (Heaney and Lee 2006).

4.10 EXAMPLES OF SWMM BMP SIMULATION

While some additional SWMM capabilities for BMP simulation will be described while discussing the various BMP options, example SWMM simulations reflecting LID and BMP simulation capabilities will be provided in Chapters 14 and 15 toward the end of this report. This is done in lieu of incorporation of examples into each BMP section since these two examples are lengthy.

eOA Exhibit TF-8 • BMP Modeling Concepts and Simulation SOAH Docket No. 582-08-2186


•

5 ALTERNATIVE MODELS AND APPROACHES

For each of the viable BMP/LID alternatives defined in Tables 1-1 and 1-2, modeling concepts and mathematical formulations need to be developed that can be used in applying alternatives to the SWMM model based on the state-of~the-engineering knowledge and information. The modeling parameters, e.g., soil characteristics and antecedent moisture content that reflect local site-specific conditions as well as possible seasonal effects; should be incorporated into the formulations whenever possible, and the

• modeling limits of each BMP/LID alternative that can be incorporated into SWMM based on present knowledge should be well defined.

Several models were evaluated for their ability to simulate the quantity and quality processes in urban BMP alternatives; a useful review of candidate models is provided by Trepel et al. (2000). For the sake of brevity, only models found to be most appli~able in urban areas were evaluated during this study; these are listed in Table 5-1. Hence, a number of models that might be suitable for agricultural BMP analysis are not included (Donigian et al. 1995), nor are models that do not simulate water quality. Also, models that primarily deal with water quality in receiving streams are also not considered here; such as WASP (Wool et al. 2001) and HSPF (Bicknell et al. 1997). The point is made later that it would be very useful to provide an easy method to transfer hydrographs and pollutographs from SWMM to models such as WASP and HSPF.

Models reviewed are: • DMSTA: Dynamic Model for Stormwater Treatment Areas (Walker 1995, Walker and Kadlec 2002) • MUSIC: Model for Urban Stormwater Improvement Conceptualization (Wong et al. 2002) • P8: Program for Predicting Polluting Particle Passage through Pits, Puddles, and Ponds (Walker

1990) • PREWET: Pollutant Removal Estimates for Wetlands (Dortch and Gerald 1995) • REMM: Riparian Ecosystem Management Model (Inamdar 1998a,b) • SLAMM: Source Loading and Management Model (Pitt et al. 1999b, Pitt and Voorhees 2000) • VAFSWM: Virginia Field Scale Wetland Model (Yu et al. 1998) • WETLAND: Wetland water balance and nutrient dynamics model (Lee et al. 2002) • WMM: Watershed Management Model (Wayne County, MI 1998)

• Components of these models will be discussed in following sections with regards to methods for simulating BMPs. As part of each method-related chapter, current (version 4.4h) SWMM simulation options will also be provided.



• Most of the models in Table 5.1 can simulate the performance of a variety of BMPs. In some cases, a model will be discussed primarily within the framework of just one BMP. For example, MUSIC will be discussed primarily in Chapter 7 under the wetlands category, even though some of that discussion will relate to other BMPs as well.

Although WMM has proven very useful for screening analyses, it is a spreadsheet model, not a process model. That is, WMM simulates removal through the use of seasonal or annual removal coefficients, during a static simulation. Hence, WMM procedures will not be discussed in detail in this report. On the other hand, the model and its documentation may well be valuable for data and coefficients.

•

MPTable 5.1. simulation models that can simulate urban B erformance.

Model Ponds Infiltration Grass Extended Trenches Swales Detention

Bioretention and Wetlands

Dry Wells

Filter Strips

Porous Pavement

Other Devices

DMSTA X X MUSIC P8

X X

X X X

X X X

PREWET X REMM X SLAMM X X X X X X VAFSWM WETLAND

X X

WMM X X X X

COA ExhibitTF-8 • BMP Modeling Concepts and Simulation SOAH Docket No. 582-08-2186 .


•

6 PONDS

6.1 INTRODUCTION

Modeling ponds as a BMP involves storage and release of excess stonnwater capture volumes based on hydraulic controls (Urbonas and Stahre 1993). Ponds may be classified in three ways: 1. Wet retention or '\vet pond," in which there is a continuous pool of water that will fluctuate up and

down during stonn events.

• 2. Dry detention or "dry pond," which fills during a storm event and drains soon after. Dry detention

areas are often designed primarily for flood control and usually serve multiple purposes, such as recreation.

3. Extended dry detention is essentially the same as a dry pond except that it is deliberately designed to drain more slowly, thus providing more of a water quality benefit.

The word "retention" implies that some water retained in a pond and between storms is subject only to the vertical water balance of ET and infiltration. The word "detention" implies that water is only detained, and storage is temporary. Wet ponds will typically include detention storage above the permanent pool for purposes of flood control and additional water quality benefits.

Although this chapter is entitled "ponds," the principles described apply to most types of storage devices, that is, wet-weather control devices that provide storage, including wetlands, overland flow and flow in swales, concrete tanks (as for combined sewer overflow contro!), in-system storage in pipes or channels, and any control that may enhance sedimentation.

Many processes are responsible for the pollutant removals observed in retention and detention ponds. Physical sedimentation is the most significant removal mechanism (Pitt and Voorhees 2000) and is traditionally modeled based on the hydraulic overflow rate (described below, Metcalf and Eddy 2003). However, biological and chemical processes can also contribute important pollutant reductions. The use of aquatic plants, in a controlled manner, can provide still more pollutant removal. Wet ponds also are suitable for enhancement with chemical and advanced physical processes. Infiltration mayor may not be an issue with ponds; often a liner or high groundwater table is required to maintain a permanent pool (hence, infiltration is discussed in the Infiltration Trenches section of this report.)

SWMM currently models storage devices quite well, simulating settling and first-order decay directly,

• with SIT removal equations for other processes. When searching for improvements to SWMM for pond simulation one issue is biological treatment based on second-order reactions. This would be useful if trying to model a type of activated sludge process or flocculation within a pool, although this may be a



• minor issue. Mineral suspensions and primary sedimentation are best characterized as discrete-particle sedimentation and are often sufficient for characterizing water quality (Tchobanoglous and Schroeder 1985).

The models investigated have few methods for simulating biological treatment directly. Of the models investigated, only P8 has the limited ability to simulate second-order rates of reaction directly. P8 may also calibrate pond performance with a "particle scale removal factor" that may be used to emulate pond processes indirectly. .

Simulation of ponds as a CFSTR is a two-part process. At each time step, flow continuity is maintain, in a variant of the lumped continuity equation,

dV-=Q -Q+A(P-ET-G) (6-1)dt I

•

where V =pond volume, Qi = summation of surface inflows,

Q = pond outflow to surface, e.g., through outflow structures, A = pond surface area, P = precipitation on pond, ET = evapotranspiration from pond, and G = percolation or infiltration into soil beneath the pond (could be negative).

This same equation applies to all surface BMPs, including wetlands, swales, etc. The change in volume term, dV/dt, appears in theCFSTR kinetic equation 4-9 and is an important component of any numerical solution. Variations of Equation 4-9 will be seen in presentations of the several pond (Chapter 6) and wetland (Chapter 7) models that follow. .

6.2 SIMULATION OF PONDS WITH P8

.6.2.1 The Model

The Program for Predicting Polluting Particle Passage through Pitts, Puddles and Ponds, or P8, is used to' model generation and transport of stormwater runoff pollutants in an urban setting (Walker 1990). Calculations are performed on continuous water-balances and mass-balances. Primary applications are for evaluating site plans for compliance, with treatment objectives expressed in terms ofremoval efficiency for TSS, and BMP design to achieve treatment objectives. Secondary (and less accurate) predictions from this model are runoff quality, loads, violation frequencies, water quallty impacts due to proposed development and generating loads for driving receiving water quality models (Walker 1990).

6.2.2 Second-Order Reactions

A fundamentally different approach to simulating contaminant behavior and partitioning in devices currently under investigation is to assign each contaminant to a separate particle class and use secondorder decay kinetics instead of first-order settling. This would reduce removal rates as concentrations decreased. Second-order kinetics are consistent with removal mechanisms involving particle interactions (e.g., flocculation) as opposed to discrete settling. The applicability of second-order kinetics has been

• demonstrated for hydrocarbons in Nationwide Urban Runoff Program (NURP) settling column tests (EPA. 1983, Volume ll), phosphorous removal in reservoirs (Walker 1985) and TSS, phosphorous and zinc removal in settling columns (Walker 1990). The user is required to input decay coefficients, which



• can make the model more flexible in modeling regional performance differences in devices at the expense of the extra data requirements. But the limits of usefulness in using the second-order decay stem from the lack of parameter estimates for such coefficients currently available in the model and in the literature.

In P8 the rates of reaction are used to calculate device (pond) concentrations, Each device is assumed completely mixed for computing concentrations and outflow loads. This is essentially the same way that SWMM currently calculates concentration in its Runoff and Transport Blocks except for the integration of the second-order rate constant, K2 (not to be confused with the reaeration coefficient), and inclusion of the particle scale removal factor, f.

Device mass balances are calculated as follows (definition of symbols follows the four equations);

dM dYe -- =W-OeM

(6-2)cIt dt

The right hand side of Equation 6-2 is the following variant of Equation 4-9 that includes first and second-order decay, plus settling:

(6-3)

• Assuming a constant volume, and average values over a time interval, 6.t, the analytical solution for mass Mis:

w ( W) -D~t 'f 0M 2 = D + M1 - Del D> (6-4)

ifD=O (6-5)

where D = sum of loss terms (l/hr), Cm = average concentration during step (mg/L), V = average device volume during time step (ac-ft), M=C-V = mass in device, (ac-ft'mg/L), with subscripts 1 and 2 indicating beginning and

end of time step, respectively, 6.t = time step length (hours), W = total inflow load to device (ac-ft'mgIL/hr),

Q = average outflow from device, from flow balance (ac-ft/hr), = particle settling velocity (ft/hr), = average device surface area during time step (acres), = first-order decay coefficient (1/hr), = second-order decay coefficient (1/hr-mglL), and = device-specific particle removal scale factor.

• Notice that the analytical solution is not "exact" since an average concentration, Cm, is used to evaluate the nonlinear second-order decay term. The addition of a user-defined second-order rate equation can be



• used to simulate flocculation or biochemical reactions, but this is limited by a lack of defmed secondorder rate constants in the literature. No default decay coefficients are provided in P8, and if desired must be supplied by the user. Most typical K2 values available are for activated sludge processes and have specified ranges of usefulness based on temperature and mixed liquor suspended solid concentrations (Tchobanoglous and Schroeder 1985). These parameters are difficult to control in BMPs, and therefore limit this modeling option's usefulness.

6.1.3 Particle Removal Scale Factor

Another P8 approach is to use the particle removal scale factor, f, which allows for the easy calibration of an increase or decrease in pond removal efficiency. The f-values adjust the sum of removal rates for each device, and are usually set to 1.0. The f-values can be used to account for effects of vegetation or other factors that affect particle removal, e.g., macrophytes can increase particle removal by increasing surface area, stabilizing bottom sediments, and through biological mechanisms. Removal efficiency curves developed in Australian ponds with macrophytes (Phillips and Goyen 1987, Lawrence 1986, as presented by Walker 1990) correspond to removal scale factors of 2-3 for suspended solids and 3-4 for total phosphorous attributed to macrophyte presence in wet detention ponds. Alternatively, a removal scale factor f < 1 can account for short circuiting or other poor hydraulic designs. See Section 6.5 for an alternative heuristic approach leading to similar results.

6.1.4 Pollutant Removal

• Pollutant removal under dynamic conditions occurs when particle settling velocities exceed the basin overflow rate. Removing solids will also remove much of the pollutants of interest. Notable exceptions of potential concern include dissolved forms such as nitrates, chlorides, soluble zinc, pathogens, 1,3dichlorobenzene, fluoranthene, and pyrene (Pitt and Voorhees 2000). The P8 model uses the traditional hydraulic loading rate method for dynamic settling (e.g., Fair et al. 1968, Minton 2002, Metcalf and Eddy 2003) for all devices modeled (ponds, swales, bioretention facilities, filter strips), in which particles with settling velocities greater than the hydraulic loading rate (or sometimes, the "overflow rate") are removed. That is, particle removal occurs when .

(6-6)

where Vs = settling velocity, q =overflow rate or hydraulic loading rate, flow rate/area or length/time, Qi = inflow, and A = surface area.

The method is used to determine removal in all devices modeled by P8 (ponds, grass swales, bioretention facilities and filter strips). In some applications, the outflow is used instead of the inflow to determine the overflow rate (Sections 6.3 and 6.5).

Within P8, the inflow is computed using a mean storm intensity and watershed area, so that:

• (6-7)



• where q = average overflow rate (ft/hr), A = pond surface area (acres), Aw = watershed area (acres), Rv =watershed runoff coefficient (runoff volume/rainfall volume), i = mean stonn intensity (in/hr); - 0.06 in/hr is used as default in P8, and 12 = conversion factor from inches to feet.

An assumed particle size distribution (Table 6-1) is then used to detennine the amount of settling that occurs. The first class represents the dissolved (non-settling) fraction of water quality constituents. The remaining classes are based on NURP settling velocity distributions. Ideally, these would be supplied by the user with site-specific stonnwater treatability data, but such data are usually sadly lacking.

Particle fractions (mglkg), sometimes called "potency factors," are used to translate particle concentrations of total suspended solids (TSS) into associated pollutant values. These fractions are similar to SWMM's constituent fractions in the J4 data group of the Runoff Block and are one way to simulate adsorption. That is, a "particle fraction" or "potency factor" or "constituent fraction" is related to the partition coefficient, Kt, used in sorption kinetics through Equation 4-16 (Chapra 1997). These particle fractions have been calibrated in P8 to "typical urban runoff' so that the median SS EMC corresponds to the values reported by NURP, based primarily on runoff concentrations and settling velocity distributions (USEPA 1983, Walker 1990).

• Table 6-1. Particle class default values in P8 (Walker 1990).

Class Description % ofTSS Settling Velocity (ft/hr)

PO% Dissolved 0 0

PlO% 10Ul Percentile 20 0.03

P30% 30Ul Percentile 20 0.3

P50% 50m Percentile 20 1.5

P80% 80Ul Percentile 40 15

Buildup-washoffparameters have been calibrated for both pervious and impervious areas to produce an EMC of 100 mg/L TSS for a median site, and 300 mg/L for a 90th percentile site as per NURP. This method is independent of stonnwater volumes and ignores any variation in concentration (first-flush effects) with large stonn events and due to possible construction site runoff, which can yield much higher TSS concentrations.

Particle compositions (mglkg) are then used to translate particle concentrations into concentrations of total suspended solids (TSS), total Kjeldahl nitrogen (TKN), total phosphorous, copper, lead, zinc and hydrocarbons. These compositions have also been calibrated so that median, event-mean runoff concentrations correspond to values reported by NURP (USEPA 1983) as listed in Table 6-2.

This calibration is based on a simulation of 1983-1987 Providence Airport rainfall. High site-to-site variability is reflected in the 2 to 3-fold differences between the median and 90th percentile sites, and

• implies considerable uncertainty in predicting actual contaminant concentrations. Calibration with local or regional runoff data will help to reduce this uncertainty (Walker 1990).


6-43 TCEQ Docket No. 200S-Q612-MSW Page 61 of 166

•

•

•

Table 6-2. Example of P8 calibrated runoff concentrations (Walker 1990).

Component

total suspended solids total phosphorous

total Kieldahl nitrogen

total copper

total lead total zinc hydrocarbons

Median, EMC, mgIL

NURP Median Site 90th % site % Dissolved 100 300 0 0.33 0.7 30 1.5 3.3 40

0.034 0.093 40 .020 (a) 0.05 (a) 10

0.16 0.5 40 2.5 (b) 5.0 (b) 10

a - NURP lead values reduced to account for> 1O-fold reduction in gasoline lead content

b- Hydrocarbons estimate from load factors reported by Hoffman (1985)

6.3 SIMULATION OF PONDS WITH SLAMM

SLAMM (Pitt and Voorhees 2000) calculates particle deposition in wet detention ponds using the same hydraulic loading rate methodology just described for P8, although SLAMM's authors refer to it as the "upflow velocity method" (Linsley and Franzini 1964). It is the same as hydraulic loading rate except that Pitt and Voorhees (2000) define it as the ratio of outflow rate to surface area. This is reasonable since pond outflow rates generally govern the time required to drain the dry pond or return a wet pond to its permanent poollt:vel. Hydrograph routing through the pond is first performed using the storageindication method (see also Section 6.5) as implemented in the RESVOR reservoir routing subroutine of the Natural Resources Conservation Service in Technical Releases 20 and 55 (SCS 1986).

SLAMM expands on the storage-indication procedure by calculating incremental upflow velocities (hydraulic loading rates) for each calculation interval. SLAMM automatically determines the most efficient calculation interval. Any particle that has a settling velocity greater than this upflow velocity will be retained in the pond. The user describes a particle size distribution for the inflowing water that SLAMM uses to calculate the particle settling rates from Stokes' law modified for deviations from laminar flow (e.g., Fair et al. 1968).

Stokes' equation (Fair et al. 1968), used to compute the terminal fall velocity, or settling velocity, Vs (ft/s), for a sediment particle in laminar flow is:

d 21 V =-(8 -1)g (6-8)

s 18 p V

where d = sediment diameter (ft), Sp = specific gravity of sediment, v = kinematic viscosity (function of water temperature), (fi2/s), g = acceleration due to gravity (ft/s2

).

Limitations of Stokes' law are discussed below, in Section 6.5. SLAMM calculates the critical particle sizes retained in each calculation interval and sums the retained particles for the complete event. Hydraulic performance of an outfall pond is also summarized by giving the peak flow rate reduction factor and the pond flushing ratio (ratio of incoming runoff volume to normal pond volume) for each event. Peak flow reduction affects downstream impacts, a BMP evaluation criterion (Section 3.1).



• 6.4 POND SIMULATION WITH MUSIC

This model simulates sedimentation using methods similar to those described for SWMM in the next section. Since a primary application of MUSIC is to simulate the treatment obtained by storage in wetlands, discussion of the MUSIC algorithms will be deferred to Chapter 7.

6.5 POND SIMULATION WITH SWMM

Hydraulic and water quality procedures for simulation of "storage" in SWMM are explained in considerable detail in the documentation (Huber and Dickinson 1988, James et al. 2002a,b) as well as in texts such as Nix (1994), Stephan Nix being the primary author of the SWMM Storage/Treatment Block. Flow routing through storage is performed using the storage-indication (S-I, also known as the Modified PuIs) method (McCuen 1982, Huber and Dickinson 1988, Bedient and Huber 2002). The S-I method is simply a convenient numerical scheme for solution of the combined continuity and reservoir outflow equations for the two unknowns, storage and outflow. As shown in the detailed SWMM example of Chapter IS, required data include surface area vs. depth (from which volume vs. depth may be computed) and an outflow rating curve (flow vs. depth). The latter may be in the form of a table, pump curve, or power equation (e.g., for a weir or orifice). The S-I scheme is also used in the Transport Block for flow routing through storage, whereas storage in the Runoff Block is evaluated by the mathematical solution of the nonlinear reservoir equation, and in the Extran Block, by solution of the Saint-Venant equations applied to the storage device (Roesner et al. 1988). Since the SIT Block (and sometimes the Transport Block) is the primary module used for simulation of quality in storage devices, focus will be upon its application for ponds.

• As described in Sections 4.2 and 4.3, quality transformation may be simulated in three ways: 1. first-order decay with either plug flow or complete mixing, 2. a general "all-purpose" removal equation (Equation 4-1), or 3. sedimentation theory, for use with plug flow.

Considering the third option briefly, sedimentation is obviously a function of settling velocity. While Stokes' equation 6-8 could be used, more accurate is to compute settling velocity as a function of turbulence level, as indicated by the particle Reynolds number, R,

R= vsd (6-9) v

where Vs = settling velocity (ft/s), d = particle diameter (ft), and 1) = kinematic viscosity (ft2/s).

Settling velocity is then defined by the balance between gravity and drag force,

4gd (S -1) (6-10)vs = 3C pD

where

• g = gravitational acceleration, e.g., 32.2 ft/s2

,

CD =drag coefficient, a function of R, and Sp = particle specific gravity.



• The iterative process to determine v. is explained by Fair et al. (1968) and Minton (2002) and was implemented by Sonnen (1977) in a past version of SWMM. The current SIT Block uses Sonnen's method (Huber and Dickinson 1988). This is in lieu of settling velocities entered directly by the user, from a stormwater treatability analysis. Stokes' law is valid for R less than approximately 0.5, for which CD = 241R, and for which Equation 6-10 reduces to Equation 6-8.

Two options exist for pond(or any storage) simulation in SWMM: plug flow or complete mixing (CFSTR, discussed in Section 4.3). Most ponds behave in an intermediate fashion between plug flow and complete mixing due to short-circuiting, dead zones, and incomplete mixing (Thackston et al. 1987). There are also two- and three-dimensional effects, including diffusion and dispersion that SWMM cannot simulate. One cornmon heuristic solution is to use Fair and Geyer's (1954) "tanks in series" (TIS) method for analysis of imperfect sedimentation basins for water and wastewater treatment, in which the fraction captured of particles that have settling velocity v. is:

sR=l-(l+ 'J-NV (6-11)NQ/A '

where R = 1 - Cou/C in = fraction captured or retained in pond,

Q =pond outflow rate,

• A = pond surface area, and N = empirical measure of hydraulic efficiency, or number of CFSTRs in series.

The hydraulic efficiency factor, N, can reflect short-circuiting, for example, and ranges from 1 for "very poor performance," to 3 for "good performance," to 5 or higher for "very good performance" (Fair et al. 1968, Driscoll1986b, Pitt and Voorhees 2000,' Minton 2002). Another interpretation ofN is the number of CFSTRs or "tanks" in series, as an approximation leading up to plug flow (LevenspieI1972, Kadlec and Knight 1996, Chapra 1997). That is, Equation 6-11 is the removal efficiency for N CFSTRs in series, all with the same flow rate, and each with lIN of the total pond area Ab• (The ratio, v.NQ can be expressed in several related forms, as will be discussed below in relation to Equation 6-14.) When N = 1, the equation gives the steady-state performance of one CFSTR (solution of Equation 4-3 for dC/dt = 0). The case N- OC) corresponds to perfect horizontal plug flow representation for a tank or pond (Chapra 1997),

-~

, lim(Eqn.6 -11) =1- e Q/A (6-12)

N~oo

The removal efficiency, R (fraction), due to quiescent settling (e.g., in the permanent pool ofa wet pond), is given by

(6-13)

• where td = detention time, and



• h = pond depth.

All particles with settling velocity Vs will be removed as long as the storm inter-event time is greater than the detention time (neglecting resuspension and several other side effects). Note that Equation 6-13 is a special case of Equation 6-11 with N = -1.

The effect of N is shown in Figure 6-1. Several options for the dimensionless abscissa are shown that represent equivalent design conditions, depending on the nature of the removal process being simulated, including

(6-14)

where k = first-order decay coefficient (l/time), k' = k·h = rate constant (depth/time), q = hydraulic overflow rate (depth/time), and V = volume.

Various relationships are implied among the parameters, including the fact that settling behaves as a firstorder removal process ifk = v/h. Kadlec and Knight (1996) define the Damkohler number, D., as

• D.= k'/q (6-15)

Thus, the various dimensionless forms shown in Equation 6-14 are variations of the Damk6hler number.

Regarding Figure 6-1, so-called "very poor performance" corresponds to complete mixing in a pond, or N = 1 CFSTR. This means that some entering pl1rticles can move "instantaneously" to the outlet, as in short-circuiting. The other extreme is plug flow, in which particles settle while moving on one continuous, horizontal path to the outlet, thereby maximizing their opportunity for removal. The range of perfect mixing to plug flow corresponds to dynamic settling, that is, settling while outflow from the pond is occurring. Quiescent settling corresponds to still water and no outflow (although this may be assumed for discrete plugs, as indicated below). Given enough time, and neglecting turbulence and resuspension due to wind, all particles for which vs'h/td 2: 1 will settle out.

SWMM SIT currently simulates the extremes of complete mixing and plug flow. For plug flow, an enhancement is used to account for non-ideal settling conditions that were characterized by Camp (1946) in the form of sediment trap efficiency (removal fraction) as a function of a turbulence factor. (This is the "sedimentation theory" or third SIT option listed earlier.) The procedure was simplified by Chen (1975), and its SWMM implementation is described in Appendix IV of the User's Manual (Huber andiDickinson 1988). In essence, removal in plugs corresponds to ideal quiescent conditions (Equation 6-13) when the turbulence factor is low, and follows a reduced efficiency curve given by Chen (1975) for higher levels of turbulence. However, this still assumes plug flow conditions. A possible enhancement to the simulated removal efficiency would be to use Equation 6-11 to represent the reduction of efficiency as plug flow conditions "deteriorate" to those of complete mixing, with its inherent short circuiting. The user would need to supply the value ofN or make an equivalent judgment regarding "very good" to "very poor" performance, as defined for unit operations by Fair et al. (1968) and for ponds by Pitt and Voorhees

• (2000) and Minton (2002). Additional guidance is provided in Section 7.7.



• 1.0

0.9

0.8

0.7 - -' .!::

U 0.6 .... ::::l

U o

0.5 ..... II 0.4

c::: 0.3

0.2

0.1

0.0

• 0.0 1.0 4.0

V s I (Q/A) =

--+- Plug flo N 1 CFSTR - N 3 I I ~N 8 --+-N -1 Q~ --N ~ __ ~ J

Figure 6-1. Removal efficienc ,R., a. a function of dimensionlc s form') of rate of treatment or loadinj!,.

The partlclc- scale I'en val ["cIctor, [', in the PS model S I've the same purposl. as the hydLlUll':: effi.::ien..:y parameta, N Both may be used in a highly empirlcal fashion to account for increases or decreases in removal efti 'ieIK)', with plug flow as a starting point (Equation 6-12) For lntan e, values of -I ~ N> if) represent still another set of curv s on Figure 6-1 for which removal etTiciency IS improved to a value between plug flow and qui scent settling (et'ficlencies for N = -2 are shown on the Jigure). Hence, use orEquation 6-11 for plug tlow in SWMM might be a very versatile way to represt;nt performance. albeit still empirica I and 0 f a curve- fi tting nature

6.6 EXTENDED DETENTION

• In orJ I' lu enh nee ,;~dim-'l1t, l' )n, e:dcl1 led dcknlion basilh' r-: d '"igneu 10.:'1 ply th,,'r briJ 1-1'111

volume in 24 to 48 hours, with no more than 50% of this volume being released during the first onequarter to one-third of the emptying period (Urbonas and Stahre 1993). Of course. local regulations may modify these timing requirements, but these are typical of today's practice. "Vater quality processes In extended detention (and detention) ponds obey the same principles as just discLissed, including dynamic: sdtling flowever. it is important to remember that ther' is n "u~f1ow" veloeil. (at least not after

COA Exhibit TF·8 B,'vIP Modeling Concepts and Silnulallcn SOAH Docket No 582-08-2186

2.0 3.0

= k t d =k'/q

6-4:'\ TCEQ Docket No. 2006-0612-MSW Page 66 of 166

• possible spillway flow has ceased); the "overflow rate" is due to water draining horizontally or downward toward a drain that is usually on or near the pond bottom. In essence, this is the procedure used in SWMM SIT for plug flow with sedimentation. Water is assumed to move horizontally toward the outlet, with pond depths gradually decreasing. Removal is always a function of detention time and may be modified according to ~amp's (1946) and Chen's (1975) adaptations for turbulence.

Of special interest is the behavior of dry detention and extended detention basins over the long term of hydrologic events, during which a detention area will fill and empty according to the arrival of storms and duration of inter-event dry periods. For instance, if another storm arrives before the detention area has drained completely, the incoming flowwill mix with the remaining water, and the removal analysis must begin anew. The EPA probabilistic analysis (Driscoll 1986b, Urbonas and Stahre 1993), later enhanced and expanded by Adams and Papa (2000), provides a statistical methodology for analyzing detention performance by coupling rainfall and runoff statistics, e.g., storm duration and inter-event times, determined by local meteorology, with detention drainage characteristics, determined by the hydraulic design of the outlets. SWMM and other continuous simulation models provide the same type of analysis by using long-term historic· rainfall time series as drivers for the stormwater runoff that enters (and drains) from detention and retention ponds. Hence, the complex interaction between storm events and filling and

. drying of detention areas is analyzed empirically, through continuous simulation, with a statistical analysis (e.g., using SWMM's Statistics Block) of the results.

•



•

•

•

7 WETLANDS AND BIORETENTION FACILITIES

7.1 INTRODUCTION

Bioretention facilities include constructed wetlands, wetland basins, bioswales, and wetland channels. Bioretention is a combination of processes served by other BMP types, and the processes that might enhance SWMM's ability to model bioretention facilities are a combination of those previously listed. Sedimentation resulting from storage is a fundamental unit process that occurs in these facilities. Infiltration, filtration, flocculation, biochemical interaction, increased settling and decreased erosion due to the presence of macrophytes also occur and have been discussed in conjunction with Tables 1-2 and 13. A highly comprehensive analysis of the use of wetlands for storrnwater treatment is provided by Kadlec and Knight (1996).

Pollutants in storrnwater can be removed by wetlands and ponds through a combination of 1) incorporation into or attachment to sediments or biota, 2) degradation, and 3) export to the atmosphere or groundwater (Strecker et al. 1992). The wetland hydroperiod (the seasonal pattern of water levels) defines the rise and fall of surface and subsurface water that in some cases can lead to export of pollutants to groundwater. In general, removal mechanisms are known to be physical, chemical and biological in nature. Some important removal mechanisms include sedimentation, filtration, oxidation, adsorption, volatilization, precipitation, nitrification and microbial decomposition. Removal mechanisms and which pollutants they affect (Homer 1995) are shown in Table 7-1.

The mechanisms shown in Table 7-1 are not assumed to be independent from one another. Sedimentation due to reduced flow velocities, adsorption, and filtration by vegetation are three of the major removal mechanisms in many wetlands. However, it should be noted that anyone of the eight mechanisms of Table 7-1 can be dominant depending on the wetland's characteristics (e.g., as influenced by its hydrology and hydraulics). Strecker et al. (1992) note this as a major reason why wetlands differ so greatly in their pollutant removal efficiencies. Yu et al. (1998) also note differences in removal efficiencies attributable to design parameters such as inlet and outlet configuration, length to width ratio, and consequent residence times. Yu et al. (1998) reported greatest removal for sites that maximized the length to width ratio. These factors obviously play an important role when designing a wetland or pond system. Several options exist to an engineer who is interested in designing a wetland/pond that will maximally remove pollutants from urban storrnwater. These include increasing the hydraulic residence time (HRT), providing an environment that encourages flow at a low level of turbulence so sedimentation can be maximized, propagating [me, dense, and herbaceous plants, and establishing the system on a medium-fine textured soil (Homer 1995, Kadlec and Knight 1996).



• Although a two or three-dimensional model could be used for simulation of surface flows through wetlands, in all cases evaluated in this report, the lumped storage approach of Equation 6-1 has been used for water volumes. Constituent kinetics are simulated through assumption of a CFSTR, through variations on Equation 4-9, as for ponds.

Table 7-1 Wetlands/ponds pollutant removal mechanisms. (After Homer 1995.) Mechanism Pollutants Affected Promoted By Physical Sedimentation Solids, BOD, pathogens,

COD, P, N, metals Low turbulence

Filtration Solids, BOD, pathogens, COD, P, N, metals

Fine, dense herbaceous plants. Outflow through porous media also has an obvious filtration effect.

Chemical Adsorption Dissolved P, metals, synthetic

organics High soil AI, Fe; high soil organics, circum-neutral pH

Oxidation COD, petroleum, hydrocarbons, synthetic organics

Aerobic conditions

Volatilization Volatile petroleum hydrocarbons and synthetic organics

High temperature and air movement

Precipitation Dissolved P, metals High alkalinity Biological Nitrification NHrN Dissolved oxygen >2 mg/L,

Low toxics, temps. >5-7 'C Circum-neutral pH

Microbial Decomposition BOD, COD, petroleum hydrocarbons, synthetic organics

High plant surface area and soil organics

• 7.2 DIFFICULTIES WITH MODELING MULTIPLE PROCESSES

The difficulty in modeling multiple processes comes from choosing the order in which each process occurs, or trying to model processes concurrently. Some pollutants increase during some processes and decrease during others (e.g., BOD in activated sludge vs. sedimentation). The order in which these processes are modeled will affect the estimated effluent concentrations as well as the removal efficiency in each process. Coupling standard removal efficiencies for multiple processes may also overestimate pollutant removal. Many BMPs cannot remove pollutants below a certain level. Some BMPs output consistent effluent quality that is not strictly dependant on influent concentrations (Strecker et a!. 2001). Two simple methods are described in the next sub-section, followed by descriptions of three more comprehensive models for wetlands treatment.

7.3 BIORETENTION IN WMM AND P8

One simple method for performance simulation is to use overall device efficiency. For example, WMM

• (not a process model) uses an assumed efficiency for removal that is only suitable for annual load reduction predictions rather than for individual events. P8's use of a particle removal scale factor



• calibrated for simulation of the bioprocesses that occur during bio-filtration is quite simple. The presence of macrophytes can increase the removal factor (usually f=1) to 2 or 3, as discussed in the Section 6.2.

7.4 SIMULATION OF WETLANDS WITH THE WETLAND MODEL

7.4.1 Introduction

One of the newer models available, WETLAND has been designed to model constructed wetlands and can be adapted to model natural wetlands as well. WETLAND is a dynamic, compartmentalized simulation model (Lee et al. 2002) and was designed as a continuous-flow, stirred-tank reactor (CFSTR), so complete mixing is assumed to occur. Two input fonns are accepted for this model. First, daily values for hydrologic parameters and nutrients can be input, in either user-defined data or from output from a nonpoint source model (e.g., SWMM hydrographs and pollutographs). Secondly, data can be input based on the SCS curve number method (McCuen 1982, SCS 1986). The SCS method detennines the amount of daily runoff from the watershed, which is then multiplied by an EMC for each respective nutrient parameter to detennine nutrient inflow to the wetland system (Lee et al. 2002).

Written in Fortran 77, WETLAND models both free-water surface (FWS) and subsurface flow (SSF) wetlands, and is designed in a modular manner that gives the user the flexibility to decide which cycles and processes to model (Lee et al. 2002). This model has one main program that calls upon and manages the sub-models and options that need to be simulated (Lee et al. 2002). The relationship between WETLAND's main code and its sub-models is shown in Figure 7-1 (Lee et al. 2002).

• 7.4.2 WETLAND Cycles and Sub-models

Within the model, there are many wetland cycles that can be modeled. These include the hydrologic, nitrogen, carbon, dissolved oxygen (DO), bacteria, vegetative, phosphorous and sediment cycles. In the hydrologic sub-model, WETLAND uses a vertical water balance to account for surface storage. Treating the wetland as a storage unit, the spatially-lumped continuity equation (Equation 6-1) used is (Lee et al. 2002) in the following fonn:

dV/dt = Qc + Qp - Q + dVt/dt + dVp/dt + (P - PI - ET)· A (7-1)

where: dV/dt = change in surface storage (m3/day), Qc = watershed catchment runoff additions (m3/day), Qp = additions from point sources (m3/day), Q = daily outflow rate (m3/day), dVt/dt = change in living biomass water volume in the surface water (m3/day), dVp/dt = change in standing dead plant water volume in the surface water (m3/day), P = daily precipitation rate (m/day), PI = percolation/infiltration rate (m/day), ET = evapotranspiration rate (m/day), and A = wetland surface area (m\

Evaporation may be computed from pan data - the primary model option. ET may also be modeled using Thornthwaite's method (Dingman 2002). An hourly time step is used for the hydrology sub-model.

The vegetative sub-model simulates biomass growth and death rates. At the beginning of the growing

• season, biomass growth rate is assumed to increase linearly for up to 20 days until a maximum rate for the growing season is obtained (Lee et al. 2002). After 20 days, the biomass growth rate remains constant



DELTAH (T)2,3

• BASE (ONE TINIE) 1

PHOSPHORUS VEGETATION (S + T) 3 (S + T)2,3

MAIN CODE

SEDIMENT CARBON (S + T) 3 (S + T)2

• 1 Sub-model is called whenever WETLAND runs a simulation 2 If the NCOB cycle is simulated, then sub-model is called by the main code 3 If the phorphorous cycle is simulated, then sub-model is called by the main code

one time - Sub-model is called only once for the entire simulation run T Sub-model is called once every time period

S +T Sub-model is called by main code once every season and time period

Figure 7-1. Relationship between the MAIN CODE and respective sub-models for an entire simulation run (Lee et al. 2002).

until the end of the growing season, when the growth rate decreases linearly to zero over a period of 10 days.

Unlike most wetland models, WETLAND explicitly accounts for the effects of biomass and microbial dynamics in a wetland system using the dynamically-linked NCOB (nitrogen, carbon, DO, and bacteria) cycle (Lee et al. 2002). Carbon/nitrogen ratios are accounted for in this model. WETLAND is unique in that nitrification and denitrification are modeled using Monod kinetics, not just empirical relationships.

There are five different state variables in the carbon (denoted as "C") sub-model. They are biomass C, standing dead C, particulate organic C (POC), dissolved organic C (DOC), and refractory C (Lee et al. 2002). The vegetative sub-model is connected to the standing dead C and the biomass C, respectively. Biomass C is determined by multiplying a biomass C concentration by the existingbiomass in the wetland. Standing dead C is determined similarly; however, physical degradation and DOC leaching also are taken into account. A mass balance for POC is constructed for FWS wetlands. This depends on particulate BOD influx, microbial death, peat accumulation, and POC mineralization. The mass balance for DOC depends on soluble BOD influx, DOC mineralization, DOC leaching, and diffusion (Lee et al. 2002).



•

•

•

The nitrogen sub-model simulates processes such as ammonification, denitrification, immobilization of nitrogen, and peat accumulation. Inclusion ofNH3 volatilization, atmospheric deposition and nitrogen fixation in the modeling of the overall nitrogen cycle is optional (Lee et al. 2002). Variables included in the nitrogen sub-model are dissolved organic nitrogen (DON), particulate organic nitrogen (PON), ammonia (NH3), ammonium (NH4+), nitrate (N03-), immobilized N and refractory N. DON influent may enter a wetland from point sources, direct catchment runoff, atmospheric deposition and percolation. The physical degradation of decaying plant mass can add to the accumulation of DON. PON modeling is similar to DON, except that PON is also assumed to accumulate in peat as refractory N (Lee et al. 2002). Nitrogen fixation is also an available option for modeling as a way to increase DON and is modeled with a zero-order equation. Nl-Lt+ enters a wetland from catchment runoff, seepage, atmospheric deposition and point sources. Immobilized N is the sum of DON and PON immobilization, N03- uptake and ~+

uptake. Increases in nitrate in wetland waters come from influent and nitrification, whereas decreases come from plant uptake and denitrification.

In the dissolved oxygen (DO) sub-model, oxygen is assumed to be added to the wetland by point sources, incoming streamflow, precipitation, reaeration from the atmosphere, and biomass flux. Dissolved oxygen is the only state variable in the DO sub-model. Oxygen is assumed to be passed from vegetation to the wetland bottom at a constant rate during the growing season.

The bacteria sub-model describes the microbial interactions within the wetland and includes all of the microbial activity of the model. Both autotrophic and heterotrophic bacteria are modeled in WETLAND. pH is not modeled because wetlands are known to drive pH towards neutrality (pH = 7). The growth rate of bacteria is modeled using Monod kinetics (Chapra 1997). Heterotrophic bacteria are modeled using Monod kinetics where growth is dependent on TOC.

Sedimentation is modeled in the sediment sub-model of WETLAND. There are five different sediment classifications in this sub-model. They are inflow, outflow, deposition, resuspension and decomposition (Lee et al. 2002). Sediment inflow depends on the option chosen, while outflow is a function of the resuspension, settling velocity, and total amoun.t suspended in the water. A first-order user-defined rate equation is used to model decomposition of sediment.

The remaining sub-model is the phosphorous sub-model and is based on the assumption that all of the suspended sediment particles provide surface area to which phosphorous can be attached and consequently settled, resuspended, or transformed (Lee et al. 2002). Phosphorous coming into the wetland is modeled as a direct input, or by sorption using the Freundlich or linear isotherms (Chapra 1997). Additions of phosphorous from biomass decomposition and mineralization can also be modeled. Input phosphorous concentrations are used to determine the particulate phosphorous concentrations when modeling with Freundlich or linear isotherms. Mineralization is modeled with first-order equations for each particle class (Lee et al. 2002). Settling and resuspension of particulate phosphorous is related to the quantity of sediment particles. The amount of phosphorous from physical degradation is directly related to plant biomass.

7.4.3 WETLAND Output

Time series of concentrations in the effluent (and within the well-mixed wetland) are provided for: NH4,

N03, Org-N, DON, PON, DO, BOD5, TSS, DP (dissolved P), and TP (total P). Hydrologic state variables include water depth (implying a water volume) and the outflow hydrograph. In comparisons with measurements, all predicted chemical constituents except DO had a significant correlation with measured data in the example presented by Lee et al. (2002). Wetland effectiveness as a BMP is computed as the reduction of effluent loads relative to influent loads, i.e., percent removal based on loads. The strength of the model is its linked Monod kinetics for the chemical state variables. In this respect it is



• similar to EPA WASP model capabilities (Wool et al. 2001). Weaknesses include the need for requisite kinetic parameters (similar to the need of most models) and the well-mixed assumption, which does not allow the study of hydraulic short-circuiting and shape effects.

7.5 SIMULATION OF WETLANDS WITH VAFSWM

7.5.1 Introduction

The Virginia Field Scale Wetland Model (Yu et al. 1998) was developed with the help of extensive monitoring of constructed wetlands and detention ponds in eastern Virginia. The model is available through the Virginia Transportation Research Council in Charlottesville and was developed to fill a gap in analytical tools perceived on the basis of the Virginia studies.

7.5.2 VAFSWM Components

The water balance is essentially that ofEquation 6-1. Constituents are simulated in three forms: 1) water column suspended solids, 2) water column constituerit, for which the particulate form is a fraction of the SS concentration, and 3) sediment/substrate concentration. The substrate consists of sediment and nearsurface root zone for the aquatic vegetation. The substrate water volume must account for the porosity of this zone. The model is simpler than WETLAND inasmuch as nutrient kinetics are not linked; each constituent is simulated in each of the three forms in the manner of a CFSTR using a variant of Equation 4-9. Suspended solids simulation includes only settling as a removal mechanism. Water column constituent simulation includes the following removal mechanisms:

• • Settling of the particulate fraction (Equation 4-19) • First-order decay of the dissolved fraction (Equation 4-18) by adsorption to plants and plant uptake

• Adsorption to substrate

Substrate concentrations are affected by:

• Settling from the water column • Settling within the substrate area (using a different settling velocity) • Adsorption and plant uptake from the water column

Dissolved and particulate fractions are based on a partition coefficient, K.i (Equations 4-18 and 4-19). The three CFSTR equations are solved simultaneously using a fourth-order Runge-Kutta (RK4) integration scheme. Insufficient data were available for the authors to fully verify the model, but TSS and TP simulations provided removal efficiencies (efficiency ratio, Section 3-4) in the range values observed at the test site.

7.5.3 Implications/or SWMM Improvements

The principal contribution of the VAFSWM formulation is explicit inclusion of settling, adsorption, and first-order kinetics for the water column and substrate in a simpler form (i.e., one that does not involved the linked nutrient dynamics of WETLAND). Although there are approximately 15 required input parameters (for simulation of just one constituent in addition to TSS), some guidance is available for parameter estimates, and the overall formulation is amenable to inclusion in SWMM, since the fundamental processes are already included in Equation 4-9 (currently implemented in SWMM 4.4h). The main additional effort would be to include a representation of substrate concentrations, with possible complications in linkages to subsurface flow pathways.



• 7.6 SIMULATION OF WETLANDS WITH PREWET

7.6.1 Introduction

Another program used to model wetlands is the Pollutant Removal Estimates for Wetlands (PREWET) model, developed at the Waterways Experiment Station of the Anny Corps of Engineers. Online help is available to answer some questions about the model, and a brief description is available from the website http://www.wes.anny.mil/el/elmodels/index.html#wgmodels. PREWET uses equations and logic that are programmed in C++, and a commercially available graphical user interface (GUI) library, "Zinc," which is also written in C++, is used (Dortch and Gerald 1995).

PREWET contains algorithms to model a wetland's ability to remove contaminants such as TSS, BOD, total nitrogen, total phosphorous, total colifonn bacteria and other contaminants. PREWET does not model microbial growth and decay or seasonal/annual processes like vegetation growth and decay. Therefore, this model cannot be used to assess seasonal/annual effects. In fact, because it is a steady-state model, its usefulness is limited primarily to help in parameter estimation, as will be seen. Hydrological parameters are input into the model based on knowledge about the wetland.

7.6.2 PREWET Removal Mechanisms

The main assumption made in PRETWET is that the modeled wetland is at steady-state. This means flows and concentrations of pollutants are constant over time. Obviously wetlands are rarely at steadystate. However, average values or long-tenn values are the goal ofPREWET, for which the steady-state

• assumption is valid. There are two conditions for which this model works. It assumes the wetland is either a CFSTR, or plug-flow reactor (PFR). The mass balance equation PREWET uses for a CFSTR is essentially the same as Equations 4-3 and 6-2 under steady-state conditions,

d(VC)/dt = 0 = W - QC - kVC (7-2)

where: V = volume of the wetland (volume) C = pollutant concentration leaving the wetland (mass/volume) t = time W = loading of pollutant entering wetland (mass/time)

Q = flow rate (volume/time) k = first-order biological degradation rate of pollutant (lltime)

Equation 7-2 can be solved for the steady-state concentration (Chapra 1997),

c= W/Q (7-3)l+kV/Q

The ratio V/Q is recognized as the hydraulic residence time. Sedimentation is modeled in PREWET by total suspended solids removal (settling velocity) based on a balance among settling, resuspension, and sediment layer burial (Thomann and Mueller 1987). BOD removal occurs through settling of the particulate fraction ofBOD from the water column to the sediments, and adsorption to benthic biota (Dortch and Gerald, 1995). These removal processes are combined into a first-order rate constant, k,.

• Total colifonn bacteria are also modeled using a first order decay rate. This is due to death, settling, and predation of the bacteria (Dortch and Gerald, 1995). First-order decay rates, such as kB for bacteria, are



• adjusted for temperature using the customary Arrhenius formulation, Equation 4-21, with a recommended value for eof 1.07 for bacteria.

In PREWET, the only phosphorus component modeled is total phosphorous (TP). The model only considers the natural, long-term removal mechanism of sediment burial (Dortch and Gerald 1995). TP retention decreases with time in wetlands due to the sediments becoming saturated with phosphorous. After a period of time, the sediment reaches saturation equilibrium, reducing the rate of phosphorous uptake. A net first-order removal rate is obtained from the coupled water column processes of settling, resuspension, burial, and diffusion from the bed.

Total nitrogen (TN) is the only nitrogen variable considered with this model, and denitrification is the only TN process modeled. A nitrate balance cannot be used to compute the loss of TN because nitrate may also be gained through nitrification (Dortch and Gerald 1995). Instead, TN is estimated through loss of nitrate via denitrification. The steady-state relationship between TN and N03-N is used to help determine the TN loss rate from better knowledge of the denitrification rate, by

dTN/dt = 0 =-kTN TN = -kw, N03 (7-4)

where: kTN = first-order removal rate for TN, kw, = denitrification rate, N03 = concentration of N03-N

• Equation 7-4 is then used to estimate the TN first-order removal rate, kTN, on the basis of better-known values for kw, and representative TN and N03-N concentrations. Finally, wetlands removal efficiency, R (%), as a BMP is evaluated on the basis of steady-state load reduction,

R (%) = 100 x (W - QC)IW (7-5)

7.6.3 PREWET Usefulnessfor Urban BMP Evaluation

Steady-state hydrology and water quality are of little usefulness in the urban stormwater setting. However, the value of PREWET is in its array of parameters (beyond those discussed above) related to sorption, settling, phosphorus cycling, and decay and other degradation processes. As a model it could also be used to check order-of-magnitude removal efficiencies on an annual basis to those computed using a continuous simulation model such as SWMM.

7.7 SIMULATION OF WETLANDS WITH DMSTA

7.7.1 Introduction

The Dynamic Model for Stormwater Treatment Areas (DMSTA) simulates daily water and mass balances in a user-defined series of wetland treatment cells, each with specified morphometry, hydraulics, and phosphorous cycling parameters (Walker and Kadlec 2002). An in-depth description of this model can be viewed at http://wwwalker.net/dmsta/index2.htm. However, the web site does not fully explain all the processes included in the model, and there appears to be no more detailed explanation available short of obtaining the model code. DMSTA was designed primarily to model total phosphorous concentrations in Everglades stormwater treatment areas (STAs) near Lake Okeechobee, Florida that receive agricultural runoff and releases. The goal of the STA project is to achieve TP outflow concentrations of 50 Ilg/L or

• less by 2007. The DMSTA model will help predict outflow phosphorous concentrations through the means of sedimentation, filtration, and adsorption. Within this model, up to six stormwater treatment areas (STAs) can be linked together at one time. STAs are areas capable of treating stormwater that



• contain vegetation, and are often wetlands, though not always. These STAs can be linked in either parallel or series systems to show compartmentalization and management to promote specific vegetation types (Walker and Kadlec 2002). Furthermore, each STA is broken down individually as a CFSTR and can be modeled as such. This model has been coded in Visual Basic for Applications, and the user interface is a Microsoft Excel workbook (Walker and Kadlec 2002).

7.7.2 DMSTA Model Features

The primary purpose ofthis model is to predict phosphorous cycling in STAs. Several of the input parameters required by the model are given below (Walker and Kadlec 2002): • Linkage of treatment cells (up to 6 cells in series and/or parallel) • Morphometry (length, width, area and cell configuration) • Number of stirred tanks in series for each treatment cell • Daily time series (for calibration runs only)

Inflow and outflow volume Inflow and outflow TP concentration Mean depth Rainfall Evapotranspiration

• Descriptive data Seepage rates Community description Phosphorous storage (metadata: macrophytes, periphyton, and soil)

• Other factors considered by the model include (Walker and Kadlec 2002): • Temporal variations in inflow volume, load, rainfall, and evapotranspiration • Hydraulic compartments (cells, flow distribution levees) • Residence time distribution • Water level regulation • Compartmentalization of biological communities • Dry-out frequency and supplemental water needs • Bypass frequency, quantity and quality • Inflow pulse modulation by upstream storage reservoir • Seepage collection and management

The model is operated on a daily time step and has been run for periods of up to 31 years. Required input time series include daily values for inflow, inflow phosphorus concentration, rainfall, and ET. Seepage and outflows are computed through a model specific to the Everglades STAs being simulated. Spatial variation within a cell (i.e., within an STA) can be approximated by breaking the cell into a series of CFSTRs.

7.7.3 DMSTA Phosphorous Cycling Model

TP computations within DMSTA are similar to those within WETLAND and are essentially a dynamic version of PREWET. That is, phosphorus parameters are very similar to those required by PREWET, but unlike PREWET, DMSTA is a dynamic model, not a steady-state model. However, DMSTA output has been compared to steady-state simulations of the same areas (Walker 1995).

• DMSTA considers storage of phosphorus in biomass, and nonlinear relationships (typically second-order kinetics) are used to simulate the exchange of phosphorus between the water column and the biomass. Biomass itself is essentially wetland vegetation (emergent macrophytes, submerged aquatic vegetation, and periphyton). It appears that DMSTA does not include growth models for the three types of vegetation



•

•

•

and instead represents their biomass only by a long-term means. Many coefficients have been obtained for the Everglades region through calibration using several monitored systems.

7.7.4 DMSTA Usefulness for Urban BMP Evaluation

This model is useful in similar ways to PREWET, that is, for evaluation of coefficients that might be included in a similar algorithm in SWMM. WETLAND, PREWET and DMSTA all include complex, nonlinear kinetics for phosphorus cycling in the manner of WASP (Wool et al. 2001). Inclusion of such terms in SWMM might be warranted for large wetland BMPs with standing water throughout the year. But such complexity is probably not warranted for simpler devices such as bioswales.

7.8 SIMULATION OF WETLANDS AND OTHER BMPS WITH MUSIC

7.8.1 Introduction

The Model for Urban Stormwater Improvement Conceptualization (MUSIC) was developed by the Cooperative Research Centre for Catchment Hydrology (CRCCH) in Melbourne, Australia. MUSIC is capable of continuous simulation, with time steps ranging from 6 minutes to 24 hours. The model was designed to operate over a range of temporal and spatial scales, suitable f~r catchment areas from 0.01 km2 to over 100 km2 (Wong et al. 2002). It is important to note that MUSIC was developed as a decision support system and is not a detailed design tool (Wong et al. 2002). The model is intended to be a tool used in conjunction with other techniques to evaluate differing strategies for treating urban stormwater. MUSIC is capable of modeling wetlands, ponds, infiltration strips, buffer strips, swales, sedimentation basins, and gross pollutant traps. For the purpose of this report, only the wetland and pond portion of the model will be reviewed. Output from the model includes time-series graphs of flows, pollutant loads or concentration, statistical summaries, and cumulative probability plots (Wong et al. 2002). MUSIC does not contain the necessary complex algorithms for runoff routing, catchment contaminant build-up and wash-off processes, and does not enable the detailed sizing of structural stormwater quantity and/or quality facilities. Additional general and specific information about MUSIC is available at the web site: http://www.toolkit.net.au/products/music/index.htm.

7.8.2 MUSIC Algorithms

The algorithms used in MUSIC are based on the recognized routine characteristics of known stormwater quality improvement measures. The rainfall-runoff algorithm used in MUSIC was developed by Chiew et al. (1997). This is a water-balance equation similar to those used in models such as WETLAND and PREWET. MUSIC routes runoff using the Muskingum-Cunge equation (Bedient and Huber 2002, Dingman 2002).

TSS, TP, and TN concentrations are generated using a stochastic process involving cross correlation between TSS and TP and serial correlation of water quality time series (Wong et al. 2002). Pollutants that enter a stormwater treatment area (e.g., wetland or pond) in MUSIC are treated in CFSTRs. The option exists to treat the wetland/pond as either a series of CFSTRs or as a plug flow reactor (PFR), as discussed in Section 6.5. Plug flow implies a very small amount or no short-circuiting of flow.

Wong et al. (2001) present the background for the estimate of the parameter, N, the number of CFSTRs in series (Equation 6-9). Hydraulic inefficiency, i.e., the tendency to deviate from the ideal of plug flow and not to realize the full potential residence time of a wetland or pond can be due to at least two primary factors (Thackston et al. 1987): • Dispersion effect caused by unsteady flow rates, wind, entrance and outlet effects, shear stresses at

the sides and bottom, etc.



• • Volume effect caused by "dead zones" in which velocities toward the outlet are considerably less than average and in which recirculation currents exist. Dead zones are not part of the volume through which water flows; hence, the effective volume is less than the total volume, V, and the effective residence time is less than the theoretical residence time, V/Q (Thackston et al. 1987).

These effects can be quantified through tracer tests described by several authors, including Fair et al. (1968), Levenspie1 (1972), Thackston et al. (1987), and Kadlec and Knight (1996). Some of these studies attempt to derive an overall indicator of "hydraulic efficiency" such that a number near 1.0 indicates good hydraulic efficiency (close to plug flow) and a number near zero indicates poor hydraulic efficiency (close to complete mixing). Recall that the number ofCFSTRs (or "tanks in series," TIS), N = 1 (Equation 6-11) for complete mixing and 00 for plug flow. Thus a natural efficiency indicator for mixing is

emix = 1 - lIN, typically: O:s; emix :s; 1 (7-6)

The value for N can be estimated from tracer data from moments of the residence time distribution (RTD). There is a continuous analog to N discrete tanks in series, for which the analytical solution for the unit impulse response is a gamma distribution (Kadlec and Knight 1996, Eqn. 9-108),

( IN-l tN t -N

f(t)=-- N- e' (7-7)f(N) t

• where f = mean of tracer distribution, not necessarily = V/Q for real data, f(N) = gamma function = (N-l)! ifN is an integer (N is not required to be an integer).

The function is plotted in Figure 7-2. The concept is that each "tank" contributes a fractional residence time fIN. The mean of the distribution is at t ~ f, or equivalently, t/ f = 1. It is clear that as N increases, the distribution becomes more peaked, approaching a PFR. The special case N=l corresponds to the exponential distribution for complete mixing in one tank,

thf(t) =e- (7-8)

If the mode (temporal location of peak) is tp, then from the moment relationships (Kadlec and Knight 1996),

t - t 1p 1 t p= or 1-- =- =E . (7-9)N t mIXt N

where Equation 7-7 has been included to indicate one measure of mixing efficiency. Equation 7-10 provides one way to evaluate N from moments of the tracer distribution (Kadlec and Knight 1996, Eqn. 9111), although Kadlec and Knight offer Levenspiel's (1972) assessment that another moment relationship is preferable for flat observed distributions where the mode may be difficult to identify,

(7-10)

• where



= variance of tracer distribution, and • = coefficient of variation of tracer distribution

1.4

§ 1.2 +::; ::::l

.J:l ... +-' til

"'C 0.8 C1)

E ~ 0.6

C1) u l:

~ 0.4 til C1)

a::: 0.2

o o 0.5 1 1.5 2 25

• Dimensionless residence time, t/tau

Figure 7-2. heoretical residence time distribu tion (Eq uation 7-7) for unit impulse to .. tanks in . eries. Values of N are given in the It:gend.

Persson et al (1999) discus difuculties of obtaining moments from rent tracer dnta and provide al temati ves to equations 7-9 and 7·10 ba,cd on perc ntlk~ or the distribution. Ho vever, th" author end up using Equation 7-9 to evalual mixing crficiency on the bastS ofsil11ulaLed flow' (using the 11K .. 21 model, http:'lww",",.dhi oftwarec0lTVmike2 L) I'or 'v irriL1us geome ric lay ut· of 'vi, L1ands (or pond') Th' ulhvr Sll 1 lat'd 13 hyP theli..:n) p<>nd:> (Fi.':!ur-: "-3) ll1U genaate:J all tpu tra""r disl ibuli m (rom a "spike" l unit impulse) input. MOl lent" of the simul:llecltra..:er di::.lribut 'on 'vv re anal. Led LO 'ompuLe Ill' from Equation 7-9. The effective volume ralio, [ .. ,I Vi S comput'd in the m,lnner of Thackston el al

(19157) fora through-flow Q,

(7 - \ 1)

\. h r

V<fkclI"c = effective volume through which pas'es the tlow. Vlol,1 = total volume of wetland or p nJ, nOl all of which i~ cncounkrecl by the tlow. T = mea, detenli( n lim<;: L'f ti.; mcm nt !'th. IL!C r di~'rih i( 11, - 'n.... /,.' nJ ld ,- nomi al or theoretical deten ion time = VI",.,I/Q.

• eOA Exhibit TF 8 BI~IP ~,lcdelillg COf1<:epls and Simulation SO,.l,,'i Cockel ~,O 5032-08-2 i86

7-6 i TCEQ Docket 0 2006-0612-MSW P'lge 79 :)f 166

3

• if 1 G[!ill 1 0 } ~ +0 1 +eO

0

}~ + ~ 1 rJ-& ~

j +E1J Figure 7-3. Pond shapes simulated by Persson et at. (1999). Pond G has baffles, ponds 0 and P have islands, and pond Q has a sill.

• Again, the measured mean detention time, T, is usually less than the nominal detention time, 1<1, due to dead zones. Hence, the volume efficiency is usually a number between 0 and 1 (Thackston et al. 1987). Finally, Persson et al. (1999) arrive at an overall "hydraulic efficiency," A, as the product of the mixing and volume efficiencies,

A= Emix' Eval (7-12)

Values orA. for the 13 shapes in Figure 7-3 are. given in Table 7-2, ranked in order of decreasing hydraulic efficiency. Highest efficiencies are for ponds with a distributed inflow (pond E), baffles (pond G), and very elongated flow or high length to width ratio (pond J).

Table 7-2. Numerical results of Persson et at. (1999) for pond shapes of Figure 7-3. The qualitative rating of hydraulic effi

COA Exhibit TF-8 • BMP Modeling Concepts and Simulation

. . bIClency IS Persson e t a.1 Pond N:::::1/(l-i..)i.. Qualitative

Ratin2 J

Emlx&vol

0.90 10.01.00 0.90 Good G 4.2 E

1.00 0.76 0.76 0.89 0.85 0.76 4.1

P 0.96 0.64 0.61 2.6 Satisfactory 0.93 0.64 0.60 2.5Q

I Poor1.00 0.41 0.41 1.7 K 0.78 0.46 0.36 1.6 A 0.74 0.41 0.30 1.4 B 0.79 0.33 0.26 1.4 0 0.35 0.260.73 1.3 D 0.34 0.52 1.2 H

0.18 0.25·0.44 0.11 1.1

C 0.46 0.23 0.11 1.1

SOAH Docket No. 582-08-2186 7-62 TCEQ Docket No. 2006-0612-MSW

Page 80 of 166

• From an analysis of the data of Persson et al. (1999), Wong et al. (2001, 2002) recommend for MUSIC an approximation for N, the number of CFSTRs or tanks in series, .

N:::: 1 -1/A. (7-13)

Values ofN from Equation 7-13 are included in Table 7-2. In effect, this attributes all imperfect mixing just to the dispersion effect and none to the volume effect. Thus, Table 7-2 and Figure 7-3 provide a qualitative estimate for N for us~ in Equation 6-11. The application of the numerical results of Persson et al. (1999) to real wetlands is also discussed by Wong and Breen (2002).

The pollutants described by MUSIC are modeled using a first-order kinetic model. This is Kadlec and Knight's (1996, Eqn. 9-103) k'-C* model and is expressed similarly as:

(COUI - C*) / (Cin - C*) = e-k'/q (7-14)

where C* = background concentration (mg/L), Cin = input concentration (mg/L), COUI = output concentration (mg/L), k' = rate constant (mly), and q = hydraulic loading or overflow rate (mly).

• The argument of the exponential in Equation 7-15 is the Damk6hler number, discussed in relation to Equation 6-14.

Equation 7-14 was adapted from another, earlier Australian model, the Universal Stormwater Treatment Model (USTM), and is used to simulate pollutants as they pass from one CFSTR to another (Wong et al. 2001,2002). This equation is computed separately for each time step at each CFSTR. The main difference between this equation and ordinary 'first-order decay modeling is the inclusion of C*, the equilibrium or background concentration. This means that effluent concentrations will notbe reduced below C*. It may be noted from Equation 6-14 that

(7-15)

That is, using depth, h, as a linking variable,

k' kh -=--=ktd (7-16) q h/t d

where k = first-order decay coefficient = k'/h (l/time), h = average depth, and td =nominal detention time = V/Q.

• Some recommended k' and C* values are given in Table 7-3, based on limited model calibration for TSS, TP, and TN in urban areas near Melbourne (Wong et al. 2002). If depths were used to compute k' values, they are not reported. In fact, one advantage of the formulation using rate constant k' (depth/time) is that it avoids having to specify an average depth for odd natural configurations.

COA Exhibit TF-8 BMP Modeling Concepts and Simulation SOAH DOCKet No. 582-08-2186

7-63 TCEQ DOCKet No. 2006-0612-MSW Page 81 of 166

• Table 7-3 Calibrated k' and C* values from MUSIC based on limited model simulations Treatment k' (m/yr) C* (m2IL) Measures TSS TP TN TSS TP TN Sedimentation Basins

15,000 12,000 1,000 30 0.18 1.7

Ponds 1,000 500 50 12 0.13 1.3 Vegetated Swales 15,000 12,000 1,000 30 0.18 1.7 Wetlands 5,000 2,800 500 6 0.09 1.3

Refinement of the parameters for the k' -C'" model to suit local conditions (particle size distributions in particular) and treatment measure design specifications, is currently being undertaken (Wong et al. 2002). It is expected that the parameter C* will vary with discharge and the influence of chemical and biological processes during the inter-event period. Derived k values for ordinary CFSTR modeling that result from using the TSS and k' values in Table 7-3 are shown in Table 7-4 for three representative depths. But it will be seen in Chapter 15 that these values are probably too high for simulation of "decay" of TSS in most ponds.

k'rt d Iid dT bl 74 F'a e - . Irst-or er ecay va ues conve e rom Treatment Measures Depth = 1 ft

TSS k, l/dav Sedimentation Basis 134.8 Ponds 8.99 Vegetated Swales 134.8 Wetlands 44.9•

va ues Iior TSS'ID Table 7 3 - fi Depth = 5 ftTSS k, l/day

27.01.8027.08.90

or assumed d eplths, Depth = 3 ft TSS k, l/dav

44.9 3.0

44.9 15.0

The same k' -C* model is used for ponds, wetlands (Wong and Breen 2002), grass swales (Fletcher et al. 2002), and gravel filters (Wong et al. 2002). It has proven adaptable to fitting of many observed BMP performance data in Australia (Wong and Breen 2002).

7.8.3 MUSIC Evaluation

MUSIC has been calibrated and tested for its ability to predict pollutant removals by various different companies and consultants. The equations used in MUSIC are fairly simplistic and are first order. It appears to predict the removal ofTSS and TN well, and TP moderately well. The uniqueness of this model is its ability to link together different treatment options such as a wetland coupled with a swale, or a wetland coupled with a pond, through a convenient GUI. This type of simulation (known as a "treatment train") yields higher pollutant removal efficiencies than from just one BMP alone. Presently, SWMM is capable of simulating treatment devices in series in the Storage/Treatment Block, or in Runoff and Transport channels and storages. However, sufficient information is not stated within the MUSIC training manual or other references reviewed as to whether or not correct simulation of the treatment train occurs. Correct simulation depends upon recognition that the upstream device removes the easiest materials (e.g., heavy solids). Downstream devices are left to remove fine particles and dissolved constituents. Therefore, downstream removal efficiencies will progressively lessen, and it is not clear from the documentation whether or not this is observed in MUSIC.

Once again, another model recognizes the efficacy of multiple CFSTRs or the tanks in series approach (Equation 6-9). The use of tracer data to identify the number, N, of the series ofCFSTR would be helpful for parameter estimation, should such an approach be implemented in SWMM.

The way MUSIC models first-order decay (Equation 7-14) may be worthy of implementation into • SWMM. Specifically, the inclusion of the C* term (the background concentration) might be included in COA Exhibit TF-8 BMP Modeling Concepts and Simulation SOAH Docket No. 582-08-2186


• SWMM fIrst-order decay modeling. However, C· is a constant for the simulation. A better alternative might be a distribution of effluent concentrations (S trecker et al. 1991).

7.9 SWMM SIMULATION OF WETLANDS AND BIORETENTION DEVICES

As described in Chapter 1, SWMM simulates wetlands in the same manner as it simulates storage or ponds (Chapter 4 and Section 6.5). Hydraulic effIciency options range from plug flow in the SIT Block, to complete mixing (CFSTR) in SIT or in any Runoff or Transport Block channel or storage device. Similarly, bioretention devices may be also be simulated in the manner of storage (Minton 2002) as discussed in Section 6.5. First-order decay and settling are readily simulated, and the "universal removal equation" (Equation 4-3) provides the option for curve-fItting of observed removal performance. What is missing is interaction among state variables, as exemplifIed by the WETLAND model, and performed more simply with the VAFSWM model. However, the complex nutrient dynamics involved in a model like WETLAND might be much too sophisticated for the typical analysis and design employed by stormwater engineers. The EPA WASP model (Wool et al. 2001) provides an alternative should such complex dynamics need to be considered. Hence, the most useful recommendation regarding SWMM is probably to enhance the linkage between land-surface runoff models, such as SWMM, and receiving water quality models, such as WASP or HSPF.

• Interfacing of different models is not necessarily an easy task; Lin and Medina (2003) present one example of linking (through appropriate interface fIles) three USGS models: a stream transient model (DAFLOW), a groundwater flow model (MODFLOW), and a solute transport model (MOC3D plus a one-dimensional stream solute transport model. Even for models from the same agency, time-step and other considerations made the interfacing diffIcult. Interpolation in time series in order to match time steps between models can be a particularly diffIcult problem. There is an opportunity for leadership with the development of SWMM5: an interface fIle "standard" could and should be developed to facilitate exchange of time series data between models that are primarily watershed runoff models, such as SWMM, with models that are primarily receiving water quality models, such as WASP.

• COA ExhibitTF-8 BMP Modeling Concepts and Simulation SOAH Docket No. 582-08-2186


•

8 INFILTRATION TRENCHES

8.1 INTRODUCTION

Modeling infiltration trenches involves storage and release of stonnwater capture volumes to groundwater. Infiltration is the major process and is simulated in several models.

8.2 SIMULATION OF INFILTRATION TRENCHES WITH SLAMM

• 8.2.1 Introduction

Infiltration devices are one of the control practices evaluated by SLAMM (Pitt and Voorhees 2000). Volume reduction from infiltration is dependant on the study area, runoff rates, infiltration rates and physical trench parameters. One approach is to take infiltration rates from SCS data, altered to reflect infiltration during micro-stonns (stonns with depths less than about 0.10 in.), and to adjust volumetric runoff coefficients. Similarly, the SWMM Hotton or Green-Ampt methods could be used. But infiltration in trenches, swales, and channels may also depend upon the depth of water in the device, depth to shallow groundwater, clogging, etc. and thus require additional simulation efforts. The SLAMM procedure essentially ignores these complications, and is discussed below.

8.2.2 SLAMM Calculation Procedures for Infiltration Devices

Infiltration devices are assumed to affect water volume, but not pollutant concentrations. As the water volume is reduced, the pollutant yield (load) is obviously decreased. SLAMM calculates the runoff volume reductions for each source area (served by an infiltration device) for each individual rain event in the study period. Figure 8-1 shows the spatial breakdown for the SLAMM model.

Runoff volume reduction fraction is assumed to be:

(8-1)fractiooal volume reduction =(6: )(~: : =the percolation volume rate of the device (cfs), = the runoff rate to the device (cfs), = the area draining to the device (acres), and

= the total study area (acres).



• It can be seen that the fractional volume reduction is the product of the fraction of runoff infiltrated times the fraction of area served.

runoff to device (Qr) area not draining to swale

percolation (Qp)

total study area (At)

Figure 8-1. Schematic of SLAMM model area breakdown.

The ratio QrJQr used in this equation can never be greater than 1.0, because the device cannot infiltrate

• more water than is delivered into the device. The percolation volume rate, Qp, is the capacity of the infiltration device to infiltrate runoff, expressed as cfs. Pitt and Voorhees (2000) assume (no other basis given) that each side wall of a vertical trench infiltrates 113 of the rate along the trench bottom. For a vertical-walled (rectangular) trench of depth h, width w, and length L, and infiltration rate (percolation rate) f(depth/time), the volume rate ofpereolation is thus:

2 2hQp == Lwf +-Lhf = Lwf(1+-) (8-2)

3 3w

This yields the version cited by Pitt and Voorhees (2000) in which percolation area == Lw,

Q == 0.67 . .) (percolation rate)(percolation area) (8-3)[1 +. p Width to depth ratlo

No specifications are given for trench design (trapezoidal or vertical side walls are not specified) in SLAMM.

Much of the effort within SLAMM is involved in generation of runoff, including the use of runoff coefficients obtained from extensive analysis by Pitt (1987) based on the evaluation of data obtained from NURP (EPA 1983), the EPA's Urban Rainfall-Runoff-Quality Data Base (Huber et al. 1982), and from the Humber River portion of the Toronto Area Watershed Management Study (Pitt and McLean 1986). Since runoff generation is already provided by SWMM and not the main thrust of this presentation about BMPs, runoff generation by SLAMM is not included herein.

• However, for purposes of presenting a brief SLAMM example, volumetric runoff coefficients, R" are defined conventionally by


8-67 TCEQ DOCket No. 2006-0612-MSW Page 85 of 166

• runoff volume =Rv (area draining to device) (rain depth), (8-4)

and Pitt (1987) presents empirical data relating the duration of runoff (hours) to the duration of rainfall as

Runoff duration =0.90 + 0.98 (rain duration, in hours) (8-5)

An example of use of this procedure follows: Percolation rate = 3 in./hr Total rain = 1.7 in. Rain duration = 6 hours Volumetric runoff coefficient = 0.35 Area served by infiltration trench = 1.3 acres Total area in study = 5.6 acres Trench bottom area (percolation area) = 5500 fr Trench width/depth ratio = 2

Therefore:

runoff volume = 0.35 (1.7 in.)(1.3 acres) = 0.774 acoin. runoff duration = 0.90 + 0.98(6 hours) = 6.78 hours Qr = 0.774/6.78 = 0.114 ac-in./hr = 0.115 fe/sec. Qp = [1 + 0.67/2] (3 in./hr) (5500 ft2) (ft/12 in) (hr/3600 sec) = 0.510 fe/sec.

• Therefore Qp!Qr = 0.51/0.114 = 4.43, which is greater than 1.0, so 1.0 must be used in Equation 8-1.

In this example the infiltration trench is oversized for this event since all of the runoff from the service area is infiltrated. This means that Pitt's effectiveness criterion is simply the ratio of area served to the total area. The study area volume reduction p~rformance is therefore: 1.3 acres/5.6 acres = 0.23 (23 % of the runoff and pollutant load are infiltrated).

8.2.3 Infiltration in Disturbed Urban Soils

Disturbed urban soils do not behave as indicated by typically used models. More rain infiltrates through pavement surfaces and less rain infiltrates through soils than typically assumed (Pitt et al. 1999a, Pitt and Voorhees 2000). Double-ring infiltrometer test results from urban soils in Oconomowoc, WI (Table 8-1) indicated highly variable infiltration rates for soils that were generally sandy (NRCS NB hydrologic group soils).

Many infiltration rates actually increased with time during these tests. In about one third of the cases, the observed infiltration rates remained very close to zero, even for these sandy soils. Areas that experienced substantial disturbances or traffic (such as school playing fields) had the lowest infiltration rates, typically even lower than concrete or asphalt (Pitt and Voorhees 2000). These values indicate the large variability in infiltration rates that may occur in areas having supposedly similar soils.

In an attempt to explain much of the variation shown in the Wisconsin tests, Pitt and his students conducted tests of infiltration through disturbed urban soils in the Birmingham, AL area (Pitt and Voorhees 2000). Eight categories of soils were tested, with about 15 to 20 individual tests conducted in each of eight categories (comprising a full factorial experiment). Numerous replicates were needed in

• each category because of the expected high variation in infiltration rates. The eight categories in Table 82 were tested. These tests resulted in the default infiltration parameters distributed with SLAMM (Table 8-3).



•

• TabIe 8-2 Cateeories tested for infiltration rates (Pitt and Voorhees 2000).

Cateeory Soil Texture Compaction Moisture 1 ' Sand Compact Saturated 2 Sand Compact Dry

3 Sand ~on-compact Saturated 4 Sand Non-compact Dry , 5 Clay Compact Saturated 6 Clay Compact Dry

7 Clay Non-compact Saturated 8 Clay Non-compact Dry

Table 8-3 Percolation rates for different soil texture and moisture used in SLAMM (Pitt and Voorhees 2000).

Soil Description Number of

tests

Average lJit1ltration rate

(inlhr) CV

Non-compact sandy soils 29 17 0.43

Compact sandy soils 39 2.7 1.8

!Non-compact and dry clayey soils 18 8.8 1.1

All other clayey soils 60 0.69 2.1



• The CV, or coefficient of variation, is the ratio of the standard deviation for a variable to the mean value of the variable. This is used by Pitt and Voorhees (2000) to measure the imprecision in survey estimates introduced by sampling. A coefficient of variation of 1% would indicate that an estimate could vary slightly due to sampling error, while a coefficient of variation of 50% means that the estimate is very imprecise.

Although the CV values shown in Table 8-3 for the infiltration tests are generally high, Pitt and Voorhees (2000) claim that they are much less than if compaction was ignored. The high variation within each of the four main categories makes it difficult to identify legitimate patterns, implymg that average infiltration rates within each event maybe most suitable for predictive purposes. Other infiltration rates for clayey and sandy soils can be taken from Figures 8-2 and 8-3.

8.2.4 SLAMM Procedures for SWMM

Infiltration trench procedures used in SLAMM appear to have little value for SWMM except for the very positive aspect of providing infiltration rate data (previous section). Runoff generation is already performed in SWMM using a dynamic procedure not involving runoff coefficients or regression. The latter work well in SLAMM and may be additionally useful in spreadsheets, but do not appear to usefully enhance the current SWMM Runoff Block procedures. Infiltration itself is also dynamic (Horton or Green-Ampt), and a work-around procedure is available to simulate trenches, explained in the following section.

• 20 -._.----------- -----J;

-------_._----I

Figure 8-2. 3-D plots showing interactions affecting infiltration rates in sandy soils (Pitt and Voorhees 2000).

COA Exhibit TF-8 • BMP Modeling Concepts and Simulation. SOAH Docket No. 582-08-2186


• -.;r:. C :.::.

~ a: c: 0

~ ~

£

-~-~--l

l ---_ I

----~_l

4

2

Corn"~ct

10

• Figure 8-3. 3-D plots showing interactions affecting inrdtration rates in clayey soils (pitt and Voorhees 2000).

8.3 SIMULATION OF INFILTRATION TRENCHES IN SWMM

In spite of the fact that the current SWMM flow routing procedures do not allow infiltration from channels, the ability to route flow from one overland flow plane onto another (Section 4.7) allows runoff block subcatchments to serve as vertical-walled infiltration trenches. The procedure in SWMM (current or SWMM5) is as follows:

1. Simulate subcatchment runoff by usual procedures and route it downstream to the infiltration trench subcatchment. 2. Simulate an infiltration trench as a 100% pervious subcatchment of width w and length L (trench dimensions). The depth is implicitly infmite since there is no maximum subcatchment water depth for overland flow planes. However, depression storage could be set equal to the trench depth, thus ensuring no horizontal outflow for water depths less than or equal to the depression storage depth. But the modeler would have to ensure that the trench could accept all inflow (that is, not flood), unless there was provision to accept such "overflow" as legitimate flow to an auxiliary drain. 3. Infiltration may be simulated by Horton or Green-Ampt; if a constant rate is desired, it is easier to manipulate the Horton equation (maximum infiltration rate = minimum infiltration rate). Note that water depth will have no effect on infiltration within the SWMM model formulation. The infiltration rate might be adjusted higher to reflect the fact that there will be some infiltration out through the side walls that the model cannot simulate. Alternatively, a larger planar area than the actual length and width could be used, but both methods are judgmental. 4. A combination of low slope, high Manning's n, and/or very small conceptual width should be provided to eliminate horizontal outflow out of the trench - unless such outflow actually occurs, into a drain, say,

• when the water level is above the depression storage. If this work-around procedure does produce water depths higher than the trench depths, results should be carefully checked.



• Drainage from the infiltration trench subcatchment can be directed to a groundwater component if further tracking is desired, an advantage. Note that water in the trench will also be subject to evaporation and rainfall on the trench itself. There is no ready way to simulate reduction of infiltration capacity due to sedimentation apart from running the model with different parameter sets.

A better formulation would consist of a channel (with the option of a weir, to prevent outflow for water levels below the weir level = trench depth). This would permit other cross sections besides vertical walled, such as trapezoidal. But the model needs to be modified to allow infiltration from channels, including the possibility that infiltration might increase with water depth, and some consideration of clogging over time. Infiltration methods, including SWMM's Green-Ampt procedure, which might be suitable for this purpose, are reviewed by Williams et al. (1998).

8.4 TRANSITION TO SIMULATION OF RAIN GARDENS AND GREEN ROOFS

In the same manner that SWMM may currently be used to simulate infiltration trenches, the model can be used to simulate rain gardens and green roofs. Here, the conceptualization is more accurate than for infiltration trenches because the drainage is confined between vertical walls (i.e., the walls of the vegetated plots, as in a planter). The vegetated area may simply be a source subcatchment or a subcatchment to which flow is directed from an upstream source, such as an impervious portion of the roof. It is important to include the groundwater modeling option in order to obtain a vertical water balance and to provide for vertical drainage through subsurface geo-fabrics, screens, or other soil structures.

• Another, more indirect simulation of green roofs can be performed by modeling each soil layer as an SIT unit. The upper unit drains to a lower unit on the basis of a prescribed rating curve. The advantage of this conceptualization is that quality parameters may be tracked through the units. The disadvantage is that the vertical water balance must be simulated indirectly, as in a prescribed time series ofET and/or outflow hydrograph.



•

•

•

9 GRASS SWALES AND FILTER STRIPS

9.1 INTRODUCTION

Grass swale drainages can be used in place of concrete curb and gutter drainages in most land uses, except strip commercial, manufacturing industrial, and high-density residential areas (Pitt and Voorhees 2000). Grass swales reduce urban runoff problems by a combination ofmechanisms. Infiltration of the runoff and associated pollutants is probably the most important process of removal in grass swales. Filtering of particulate pollutants in grassed waterways may also occur, but the flows are usually too large (and deep) to permit effective filtering by grass (Pitt and Voorhees 2000). However, Minton (2002) points out that settling is a primary unit process as water flows through swales, and in fact, as long as there is storage (water depth) along the swale, solids removal may be simulated in the same way as for

. ponds; see Section 6.5. This will be explored further at the end of this section.

Filter strips differ from swales in the sense of not necessarily consisting of a channel, rather just an overland flow path. A large swale may be conceptualized as having its upper banks consist of filter strips, whereas the active channel is the swale. Performance data are sometimes differentiated on this basis.

Groundwater contamination concerns are frequently raised whenever stormwater infiltration is proposed. Pitt et al. (1996) reported that groundwater contamination is not a major concern for most stormwater if using surface spreading (such as occurs in grass swales). Pitt et al. (l999b) also reported on the accumulation of stormwater pollutants in the surface soils of swales, minimizing groundwater contamination problems.

9.2 SIMULATION OF GRASS SWALES WITH P8

P8 uses the same methods to describe settling and decay in swales as in ponds. Particle and pollutant removal are also calculated similarly, although runoff velocities in swales are calculated with M~ing's equation. An added process modeled in swales is infiltration, and the associated filtration. For pervious areas, infiltration is calculated with the SCS runoff curve number technique, and thus does not include the additional complexities of depth and sedimentation mentioned earlier. Infiltration rates used in P8 are listed in Table 9-1.

Filtration efficiencies for all infiltration particle fractions are assumed .to be 100%, and 90% is assumed for the dissolved fraction to account for the adsorption, precipitation and other reactions between dissolved contaminants and the soil matrix. There is no method to calculate resuspension of particulates



• if critical velocities for incipient motion are reached. Therefore, surface water outflows from grass swales have reduced pollutant mass due to the reduction in water volume from infiltration.

This method for tracking groundwater may be useful if modeling BMP interactions with a shallow groundwater system, although a 90% removal rate of all dissolved pollutants seems optimistic. This should strongly be a function of the soil type and the pollutant in question. For instance, nitrate does not sorb strongly, but heavy metals might. This would only be important to modelers wishing to track pollutants in groundwater, which is not available in SWMM (but is in HSPF).

Table 9-1 Inflltration rates used in P8.

References: (a) (b) (a) (c) InfIltration rate (in/hr) InfIltration rate (inlhr)

Soil Textures SCS soil group sand 4.64 8.27 A 0.43 .30-.45

•

loamy sand 1.18 2.41 B 0.26 .15-.30 sandy loam 0.43 1.82 C 0.19 .05-.15 silt loam 0.26 0.27 D 0.03 .00-.05 loam 0.13 0.52 silt loam 0.27 sandy clay loam 0.06 0.17 clay loam 0.01 0.09 silty clay loam 0.04 0.06 sandy clay 0.03 0.05 silty clay 0.02 om clay loam 0.01 0.02

Sources: a- Rawls et al. (1983) values for saturated hydraulic conductivity. b-Shaver (1986) cMusgrave(l955)

9.3 GRASS SWALE PERFORMANCE CALCULATIONS IN SLAMM

SLAMM calculates the performance of grass swales in a similar manner as other infiltration devices, by assuming (Q""Qr) (As/At) as indicative of swale infiltration (refer to Equation 8-1).

The water percolation rate in the swale is calculated by:

Qp ~ (dynamic percolatio~ rate) (percolation area) (9-1)

where percolation area = swale length times the swale width, and percolation rate in the swale is for dynamic flow conditions and has been found to be about one-half of the typically measured static infiltration rate in some Florida locations (Wanielista et al. 1983).

This procedure is generally independent of swale routing; it assumes that the water is in the swale long

• enough to be infiltrated. "Long" swales serving "small" service areas encourage infiltration. Grass swales include infiltration as a function of flow distance for different slopes and infiltration rates and can therefore be used to estimate needed flow length in swales (Pitt 1985, 1987). Obviously, swale design

, COA Exhibit TF-8 BMP Modeling Concepts and Simulation SOAH Docket No. 582-08-2186


• (like all other controls) must be carefully done to encourage performance. As an example, these procedures would not be appropriate for steep swale gradients. The ratio of area served by swales to total area therefore needs to be reduced if steep swales are present,or if the swales are "short."

An example of the calculations for swale performance follows: Total contributing flow volume = 1140 fe Rain duration = 5.5 hours Dynamic percolation rate in swale = 3.5 in.1hr (1/2 of measured static infiltration rate) Swale density = 350 ftJacre Wetted swale width = 5 ft Area draining to swales = 1.5 acres Study area = 3.3 acres

Therefore the runoff duration (Equation 8-5) = 0.90 + 0.98 (5.5 hours) = 6.29 hours, and Q, = 1140 ft3/6.29 hrs = 181 felhr = 0.050 cfs Qp = (3.5 in.Ihr)(350 ft/acre)(1.5 acre)(5 ft)(hr/3600 sec)(ft/12 in.) = 0;21 cfs

Therefore QplQ, = 0.213/0.05 = 4.26, which is greater than 1.0 and the swale is larger than necessary for this rain (total infiltration). The study area runoff reduction is therefore 1.5 acres/3.3 acres =0.46 (46 percent reduction in flows and pollutant yields due to the swales).

• Once again, SLAMM procedures for swales appear to offer little to be added to SWMM, except for good data. A review of output from SLAMM also suggests that SWMM might be improved through additional tables of effectiveness measures, such as volume reduction, etc.

9.4 SIMULATION OF VEGETATED FILTER STRIPS WITH REMM

The processes that occur in filter strips are sedimentation, filtration, infiltration and biochemical interactions. Discussions of these processes in the previous sections are applicable to this BMP. A model that thoroughly investigates the biochemical processes in filter strips is the Riparian Ecosystem Management Model (REMM), developed by the USDA in partnership with the Southeast Watershed Research Laboratory at Tifton, GA. It was developed for natural resource agencies and researchers as a tool that can help quantify the water quality benefits of riparian buffers in response to changes in upland agricultural use (Inamdar et al. 1998a,b; Inamdar et al. 1999a,b; USDA 1999; Lowrance et al. 2000). The following discussion is based on portions of all of these six references. Additional discussion of this model is in the Appendix. REMM simulates: (a) the movement of surface and subsurface water; (b) sediment transport and deposition; (c) transport, sequestration (capture) and cycling of nutrients; and (d) vegetative growth.

The strengths of the REMM model are its ability to deal with subsurface fate and transport of nutrients. REMM can be applied to: • Quantify nitrogen and phosphorus trapping in riparian buffer zones and to determine buffer width for

a given set of riparian conditions and upland loadings. • Determine buffer effectiveness under increased loads. • Evaluate influence of vegetation type on buffer effectiveness. • Determine impacts of harvesting on buffer effectiveness. • Investigate long-term fate of nutrients in riparian zones, sequestration in vegetation, or loss to

atmosphere (denitrification in case ofN).

• • Investigate NIP saturation in riparian buffers.



• The REMM model is the only model reviewed that integrates subsurface flow (three layers) and groundwater interaction when simulating buffers. REMM also closely models the N, P, and C cycles in the buffer that is broken into three zones: 1) closest to stream, 2) middle, and 3) farthest from stream. Although determining site-specific nutrient cycling parameters requires extensive field data to simulate accurately, the most useful information from the REMM model may be the default rate constants used in these calculations.

The model operates on a daily time step and requires daily loadings from upland areas and daily meteorological data. Output includes daily time series of surface and subsurface flows and water quality. Comparison of outflow and influent loads yields BMP effectiveness. The model can be used to study the effectiveness of buffer strips of various lengths (in the direction of water flow), for instance. If subsurface outflow to an adjacent stream is important, REMM can also provide those fluxes.

Because the writers were unable to obtain feedback from the USDA at Tifton, current support for this model is minimal and algorithms used for modeling calculations are unavailable. As documentation for REMM becomes available the model should be revisited. But overall, the nutrient dynamics algorithms appear to be beyond what would be reasonably expected of SWMM, in the manner of the WETLAND model. A more general description of this model is presented in the Appendix.

9.5 SIMULATION OF GRASS SWALES WITH SWMM

• The "obvious" way to simulate grass swales in SWMM is to model them as channels that infiltrate. Unfortunately, SWMM version 4.4h cannot infiltrate directly from open (or closed) channels. Workarounds for infiltration include the option for entering a negative hydrograph upstream of the channel, to simulate outflows, but this is not very satisfactory. Alternatively, a swale could be modeled as a rectangular channel by simulating it as a subcatchment, as discussed in Section 8.3 for infiltration trenches. Again, since real swales are usually trapezoidal and since infiltration might depend upon water depth, this is less than satisfactory., but perhaps the best current option since pollutant routing across downstream subcatchments does reflect first-order decay, a constant settling velocity, and/or constant removal fraction.

Still another option within the current SWMM is to simulate swales with the SIT Block, as a storage device. Infiltration may be simulated either as 1) monthly evaporation, or 2) residuals outflow. The latter could be adjusted to provide infiltration as a function of depth through a rating curve. Minton (2002) indicates that swales are essentially shallow clarifiers, and sedimentation occurs by dynamic settling, which is therefore a function of hydraulic loading rate, as discussed in Section 6.5. This is supported for TSS removal by data from Brisbane by Fletcher et al. (2002), for which the k'-C· model discussed in Section 7.7 provides a good fit: SIT simulation is probably the most accurate, ifleast intuitive method available in the current SWMM for simulation of pollutant removal in swales. It also has the advantage of providing options for simulating removal of soluble pollutants, should any such removal be noted in swale BMPs.

It is discouraging that the literature review for this and related projects has not uncovered simpler functional relationships to represent removal in buffer strips or along overland flow. Overland flow and riparian removal effectiveness intuitively would depend upon the length of the overland flow pathway. An example is shown in Figure 9-1 (Huber et al. 2000) and is similar in principle to pollutant reduction in swales observed by Fletcher et al. (2002). As one would intuitively expect, removal efficiency does increase with length of overland flow, but there is no unifying result from this set of experiments, at any

• rate. Overland flow removal effectiveness data tend to be found in the agricultural literature, although the data of Barrett et al. (1997) are from a highway median. A problem in analysis of such data is the lack of consistent reporting of the physical conditions of the filter strips, such as slope, soil type, vegetation,



• antecedent conditions, etc. In addition, agricultural experiments often utilize animal wastes as loading materials and thus may not be reasonable approximations ofstonnwater characteristics for urban runoff. Additional review of the literature may yield better data in an effort in support ofSWMM algorithm improvement.

----------~,-----_.__ ._._----~ ..__._-~_ ..__.~------_.---_._-----_._-_ .......,100 , i

-90

80~ 0-~ 70 CJ c (I) 60.CJ

t 50

Iw ~ 40

D WetAMC

~

,

>0 30 -+- Ba ett et al. 19971E

• (I)

0::: 20 I ""'*- Magette et al. 1989 I

10 ~ ~ J

o ------ f-I----t-------I-- I

o 2 4 6 8 10 12

Filter Length (m)

Figure 9-1. TSS removal effectiveness of vegetated filter strips, based 011 total mass of suspended solids entering and leaving the strip (Huber et al. 2000). ("A1V{C" refers to antecedent moisture condition.)

• COA Exhibit TF-8 BrvlP Modeling Concepts and Simulation SOAH Docket ~Io. 582-08-2186

9-77 TCEQ Docket No. 2006-0612-MSV'I Page 95 of 166

•

10 DRY WELLS

10.1 INTRODUCTION

• Dry wells are usually holes several feet deep, that are filled with porous material and that fill with water, which then infiltrates. The P8 method for modeling storage and infiltration would adequately describe storage and removal in dry wells that capture a given stonnwater runoff volume and infiltrate it to the ground. In P8, infiltration is simply subtracted from the device flow according to the device dimensions and the SCS infiltration rates. However, in reality, infiltration of moderately deep water in a dry well is a three-dimensional problem of unconfined flow from a partially penetrating well and can involve very complex analytical techniques (Freeze and Cherry 1979). Under suitable soil conditions, however, it may be possible to design dry wells that infiltrate the entire design inflow over the duration of a stonn or somewhat longer, and thus may be modeled simply by assuming all the water will infiltrate, without becoming bogged down in groundwater modeling efforts. In any event, SCS infiltration rates are very unlikely to be appropriate for infiltration from the bottom and sides of a dry well.

10.2 SIMULATION OF DRY WELLS WITH SWMM

In SWMM, dry wells can be modeled as a pipe or inlet with a specified inflow capacity (in the manner of a combined sewer overflow regulator). This assumes that the well has the capacity to accept the diverted flow from the "regulator." Another option is to follow exactly the same procedure as outlined in Section 8.. 3 for infiltration trenches. This would provide one way in which flooding of the well could be simulated if infiltration capacity were exceeded. But for the case of deep dry wells with a small surface area, the one-dimensional model of infiltration is even more inappropriate.

Still another means of simulation is as a storage device with constant or head-driven outflow. This could be done using 1) a Transport Block storage element, 2) a SIT Block storage unit, or 3) an Extran Block orifice or rating curve. (Rating curves in the current Extran must be mimicked using a pump Q vs. h curve, which works well but is not intuitive.) It is unlikely that the quality of the water in the dry well would need to be simulated, but if it were, Extran could not be used. SWMM offers the option for continuous simulation in all cases, with which to characterize the perfonnance and operation of the well.



•

11 CISTERNS

11.1 INTRODUCTION

Cisterns are usuaily a barrel or other tank placed beneath a downspout, with outflow controiled by a valve. The difference between a cistern and, say, a dry well, is that the cistern has a fixed capacity, and excess or bypassed runoff must be accounted for. In addition, the emptying of cisterns is more complex from a modeling viewpoint since they are usuaily drained very deliberately, for use for irrigation, for example. Hence, information on the timing of releases is required.

• In a modified version ofSLAMM (Pitt and Voorhees 2002), it is possible to designate only a fraction of flow to treatment areas. As an example, a fraction of the roof runoff and driveway runoff can be directed to a cistern for storage for later use during dry weather for on-site irrigation, toilet flushing (gray water), boiler feed water, etc. On-site water treatment might be required to improve quality for some uses, such as gray water. In the rain barreVcistern "outlet/discharge" option in SLAMM, monthly water uses are entered so the model can track water use and re-filling of the tanks during storms. Hence, a storage accounting method is needed for the cistern storage units including supply and use schedule.

11.2 SIMULATION OF CISTERNS WITHIN SWMM

A cistern may be simulated in the manner of any storage device, but since cisterns usually collect relatively clean runofffrom roofs, quality simulation may not be necessary. Outflows and bypasses may be directed downstream in the catchment as well. The principal need in SWMM is the ability to input a water use schedule, as described above for SLAMM.



•

12 POROUS PAVEMENT

12.1 INTRODUCTION

Porous or penneable pavement is a "hard" surface that can support a certain amount of activity, while still allowing water to pass through. Porous pavement is generally used in areas of low traffic, such as service roads, storage areas, and parking lots. Several different types of porous pavement exist (Pitt and Voorhees 2000). Open mixes ofasphalt have a much higher porosity than regular asphalt, and concrete grids can have open holes up to several inches wide, possibly containing sand, gravel or planted with

• grass. This kind of surface is often marketed as "pavers," i.e., concrete paving stones designed to allow easy passage of water between joints. Porous pavements can be effectively used in areas having soils with adequate percolation characteristics. The percolation rates of the soils underlying the porous pavement installation only need to exceed the rain intensity directly. In most cases, several inches of storage is available in the pavement base to absorb short periods of very high rain intensities. Diniz (1980) states that the entire area contributing to the porous pavement can be removed from the surface hydrologic regime if all runoff infiltrates. Porous pavement can be designed to eliminate all of the runoff from paved areas, and recent tests have found few problems with porous pavement in areas having severe winters (Pitt and Voorhees 2000). Work at the University ofGuelph in Ontario (Thompson and James 1995) has shown that porous pavement systems can also be effective filters to remove particulate pollutants from runoff.

Experiments in Bordeaux and Paris, France have shown that porous pavements were very efficient in reducing the pollutant loads discharged into the receiving water (Balades et al. 1995a,b). These French studies have shown that the pollutant removal efficiencies for suspended solids can be between 50 and 70%, between 54 and 89% for COD, and between 78 and 93% for lead. These reductions were associated with the high amount of infiltration of water, and associated pollutants, through the pavements, away from the surface drainage. These experiments confinn results from previous studies in other countries (Hoglandetal.1987,Prattetal.1989,Prattetal.I995).

The primary objective of using porous pavements is to mimic natural flow and infiltration conditions as closely as possible. It is therefore very important to pay attention to the following aspects to reduce groundwater contamination potential (Pitt et al. 1996):

• Depth to groundwater • Groundwater uses

• • Risks due to industrial activities in the catchment • Use and traffic levels on the porous pavement



• • Use of de-icing salts on the street

12.2 SLAMM CALCULATION PROCEDURES FOR POROUS PAVEMENTS

SLAMM (Pitt and Voorhees 2000) uses a calculation procedure for porous pavement perfonnance that is almost identical to the general infiltration device procedure of Chapters 8 and 9. However, porous pavements are only assumed to treat the paved area, with no additional flows from upland areas discharging to the pavement. Therefore:

fractional volume reduction ~[t r::J (12-1)

where f = the percolation (infiltration) rate of the porous pavement: the pavement base, or the

soil, whichever is less (depth/time), = the rain intensity = total rain/rain duration, = the paved area, and = the total study area.

Again, the ratio f/i ofEquation 12-1 must be less than or equal to 1.0.

• An example follows: Percolation rate = 3 in./hr Total rain = 1.7 in. Rain duration = 6 hrs Porous pavement area = 0.7 acres Total study area = 5.3 acres

Therefore i = 1.7 in.l6 hrs = 0.283 in.lhr The ratio of fli therefore =3/0.283 = 10.6 which indicates an over-design for this rain, requiring the use of 1.0 in the perfonnance equation.

The volume reduction is therefore 0.7 acres/5.3 acres = 0.13 (13% reduction in flow and pollutant yield).

SLAMM documentation does not cite a source for porous pavement percolation rates. The example used in the SLAMM inputs a percolation rate of 3 in./hr. Use of this method to detennine porous pavement perfonnance requires the user to have a percolation value, which may be equal to the underlying substrate percolation rate.

12.3 SIMULATION OF POROUS PAVEMENT WITH SWMM

When using SWMM, porous pavement may be treated as a pervious surface and either the Horton or Green-Ampt infiltration equations employed. Because porous pavement installations often have provision for subsurface drainage, laterally away from the paved area, the SWMM subsurface flow routines may be used for this purpose. James et al. (2001) demonstrate how SWMM can be used effectively in this manner. These authors discuss the key parameter choices necessary to simulate surface and subsurface runoff from the current Runoff Block hydrologic routines and include an extensive discussion of parameter selection. For ease of use, an interface for parameter selection has been included in the PCSWMM graphical user interface (www.chLon.ca). The reader is referred to James et al. (2001)

• for details. One limitation is that the SWMM groundwater routine does not perfonn routing of infiltrated quality constituents. Instead, the quality of effluent groundwater is input as a constant concentration in



• the current SWMM. If linked surface-groundwater quality routing must be performed, HSPF is one model that does this (Bicknell eta!. 1997).

•


12-82 TCEQ Docket No. 2006-0612-MSW Page 100 of166

•

13 HYDRODYNAMIC DEVICES

13.1 INTRODUCTION

Hydrodynamic devices range from oil-water separators, which are essentially flotation devices but may be simulated on the basis of distinct pathways for one portion of the flow vs. another portion of the flow, to much more complex and often proprietary devices, such as a swirl concentrator, StormCeptor™, Vortechs™, etc. (Minton 2002 provides a description of several such devices). These latter devices often rely on a vortex or similar secondary flow pattern to separate heavier grit from a cleaner overflow.

• Modeling these devices by process would be difficult due to the individual variation between devices. When trying to describe performance of this widely varying group, a black box method may be the most realistic choice that identifies volume treated vs. volume bypassed and manufacturer specifications. This approach neglects maintenance, malfunctioning, or poorly sized devices, and would probably reflect maximum treatment rates. The EPAIASCE BMP Database is currently collecting performance information on such devices. In the future this may be a good source for treatment efficiencies, although currently there are few listed.

13.2 SIMULATION OF HYDRODYNAMIC DEVICES WITH P8

Particle (and associated pollutants) removal from hydrodynamic devices can be modeled in P8 with a particle scale removal factor. Hydrodynamic devices only work for particulates (no dissolved nutrient removal, no decay). Loading rate, particle size, and maximum treatment rates are all of concern when modeling these devices.

Just as this parameter was adjusted in the Pond Section, the Particle Removal Scale Factor allows for the calibration of an increase or decrease in device removal efficiency. This adjusts the removal rates for each device, and is usually set to 1.0. Other values can be used to account for effects of filters or other factors that affect particle removal and can be calibrated to the manufacturer's specifications (essentially outflow concentration =removal factor times inflow concentration). However, the possible usefulness of the particle scale removal factor in SWMM has already been discussed (Chapter 7). It may be preferable to use the tanks in series model (N CFSTRs, Equation 6-11) as a more conventional empirical tool for unit process design.

13.3 SIMULATION OF HYDRODYNMIC DEVICES WITH SWMM

• The SWMM SIT Block is currently able to use performance data (i.e., removal equations) to simulate these kinds ofdevices. The Extran Block is often able to simulate the complex hydraulics of such



• devices, but without corresponding water quality computations. Nonetheless, flow treated vs. flow bypassed could likely be computed with Extran.

Although the data are seldom presented in terms of overflow rate, because residence time in a secondary flow device increases as volume and surface area increase, so must sedimentation. A brief review of vortex separation by Minton (2002) indicates that performance increases as the diameter of the vortex chamber increases. Hence, removal based on overflow rate (Equation 6-6) will likely work, if performance data are available.

•



•

•

•

14 CASE STUDY: LID SIMULATION IN PORTLAND

14.1 OBJECTIVES

To aid in identifying strengths and weaknesses ofSWMM's ability to simulate LID and BMP options, application to real basins is most useful. Various locations for LID simulation were discussed in Chapter 2, including locations in Portland, Oregon, for which monitoring data are available for both catchments and BMPs, although the latter are more limited, as will be seen in Chapter 15. Advantages of the Portland location were discussed in Chapter 2, including proximity to Oregon State University (OSU), good cooperation and information by the operative agency, the Bureau of Environmental Services (BES), and most of all, an extensive data collection and archival effort (http://www.cleanrivers-pdx.org/).

This chapter discusses a Portland study area used for LID simulation in detail, and the application of SWMM for this purpose. A different Portland area is described in Chapter 15 for a BMP simulation example. In this chapter, the Runoff and Extrlln Blocks are used to represent a portion of the Sullivan area combined sewer system down to the parcel (individual lot) level using actual rainfall-runoff data monitored by the BES during fall 1998 - spring 1999. The ability of SWMM to simulate LID scenarios is demonstrated. In the next chapter, the Runoff and Transport Blocks are used to perform quantity and quality simulation of a detention pond serving a small catchment in the Lexington Hills area of southeast Portland, including water quality simulation. LID and BMP simulation capabilities and limitations are noted on the basis of these simulations.

14.2 PORTLAND COMBINED SEWER STUDY AREA

The Portland, Oregon Sullivan combined sewer basin is a 1,700-ac area located on both sides of the Banfield Freeway (Interstate 84), from about NE 25th to NE 55th Avenue in northeast Portland. The land use is primarily single-family residential with localized zones of commercial properties. The overall basin imperviousness is about 46%. Detailed information on the Sullivan area and neighboring Stark and Holladay areas is provided by Carollo Engineers (1999). Additional information is provided by Adderley and Mandilag (2000a, 2000b) and Hoffman and Crawford (2000). Additional information on the study area and modeling is given by Huber and Cannon (2002). A portion of the Sullivan Basin is shown in Figure 14-1.

The City of Portland's BES has been modeling this area since the late J990s. The area has been targeted for the City's Downspout Disconnection Program, and the program has very detailed information on percentages of roof area that are currently disconnected, including a complete description of each parcel. Hence, optimization for LID can be studied using this monitored, real system.



• Initial efforts to use BES data resulted in huge amounls of data in formats not readily accessible to researchers at OSU. BES has modeled much of the City's combined sewers and uses MapInfo for their GIS infonnation. With the help of BES personnel, OSU staff were able to define a usable study area for modeling and convert GIS infonnation from MapInfo into the ArcView format usable at OSU. The BES perfonned much of the basic data preparation described subsequently, and the OSL: study described belo'.',' is a subset of the larger Sullivan area evaluat.:d by the BES .

• ~r . . L..:-~ _ .1

I

1 Figure 14-1. Sulliyun area (Carollo [n"ineer', 1999). 1he 'ub-area used fur lhi. study is JU~l ,0 lh of eJl" nl Par~.

Color code relate5- to basement tlooding risk. R J: very high risl-.. ;.",110\\': high risk: ~rccn 111 diuln risk; gray: s me risk: white: low risk.

The sekcte I study area is betwt:en 33rd Ave and 37th Ave (we't and east bnundari ) and betwe~n th' Banfield Freeway (I-R4) on the south and Grant Park 011 the n nh (Fig res 14-2 and 1~-2). A six-block area of I IS single- fami ly residential lots (also rer rred to as parcels or lax lots) totaling 16.9 acres with 35% impervious area was modeled. Average lot size is just over 0 I acre- An aerial photo of the area is "h\.)\\11 in ig ~ 1~-3, ",hich em hdsiL.:'s th\? lknsily vrlH.1u~ing ,I, l1l.lll10t ::.iLe.

This area has been monit red e, tensi·t:! becau e ot' base lent flooJll1g in the area. There i a tloVv

• monitor in a 16-in. pipe draining th study' r a and a tippil g buckd rain gage a k\ bt cks away (FigLln: 1~-4) Mllllit( ring data al'~ a"ailabk froll '01,.0' mbt:r ')X - Mav t)l.J al 3-minutc inter als haluation of

cop., 8hiblt TF-8 S/VIP Modeling Concepts ana Simulalil)(1 SOAH Dockat No. 582·08·2136

I -, n TCEQ ocKet 0 2006-0612-MSW Page 104 of 166

rating curves indicated flows measured at depths greater than 2.3 inches, corresponding to 2 cfs, were• more reliable than lower flows; hence most reliance was placed on these higher flows. The ArcYiew layer in Figure 14-4 also shows the roof density of the neighborhood and the main sewer laterals

·N~ 11·.1 :\-,j-)

Figure 14-2. Combined sewer study area, south of Grant Park (Carollo Engineers 1999). See color codes in caption to Figure 14-1.

•

Figure 14-3. Aerial photo of combined sewer study area .

• COA Exhltllt TF 8 BMP Modeling Concepts 3n SI(l1ulalior .sOAH Dockal No 532-013-2 86

I -i'\7 TCEO Docket No 2006-0612· ~IS\N

Page 105 of 166

• 14.3 DATA PREPARATION METHODS

14.3.1 Required Parameters

The SWMM Runoff Block converts rainfall into runoff using a nonlinear reservoir technique (Huber and Dickinson 1988). Each subcatchrnent is characterized by the following parameters:

• Area • Imperviousness

• Width • Slope • Depression storage (pervious and impervious subareas) • Manning's roughness (pervious and impervious subareas) • Three Green-Arnpt (G-A) infiltration parameters

These parameters were developed for both an aggregated and disaggregated schematization of the 16.9acre basin, as described in the following sections. However, the same values for depression storage, roughness, and infiltration parameters were used for all subcatchrnents, as indicated in Table 14-1. These values are based on BES simulations and data. All model runs shown are uncalibrated! Although this report's authors relied on BES estimates for baseflow, there was no attempt to improve upon the parameter estimates described below to obtain better fits, mostly because the initial comparisons were very good. In fact, all comparisons of simulated and monitored flows are generally good, due in part to the relatively high imperviousness of the overall basin.

• Table 141 Constant mod I parameters.- e Parameter Depression storage, in. Manning roughness G-A suction, in. G-A hydraulic conductivity, in./hr

Impervious Area Pervious Area 0.03 0.25

0.013 0.25 nla 2.56 nla 1.1

G-A initial moisture deficit nla 0.08

The Runoff Block was used only for surface runoff simulation; the sewer network was simulated in the Extran Block. Hence,while most of the discussion that follows deals with the Runoff Block, simulated vs. monitored flows rely upon Extran Block output at the monitor location. Extran block input for all pipes in the system is shown in Table 14-2.

14.3.2 Directly Connected, or DCJA Subcatchments

14.3.2~1 Introduction.

•

Directly connected impervious area (DCIA) consists of the impervious area of each parcel that is directly connected to the sewer through laterals. DCIA subcatchments are delineated for each pipe with service laterals, i.e., for every parcel with a sanitary sewer connection. They contain only the impervious area of a parcel and are therefore 100% impervious (except for the disconnection program described below). It is assumed that the pervious areas of the parcels (and impervious areas not directly connected to the sewer system) drain to the street and are therefore included in the Surface Water (SW) Subcatchments. Although this is generally the case for single-family parcels it may not always be the case for commercial areas - but there are no commercial areas in the small study area.


14-88 TCEQ Docket No. 2006~0612-MSW Page 106 of 166

BI k cond"U1t IDput ata. Cd' 'd 'fi d' F'Table 142- Extran oc d on Ults are I enti e JD 12ure 14-6.•

,

Conduit No. 62 61 57 58 56 60 55 54 51 49 50 52

Upstream Junction

Downstream . Junction

Diameter, ft Len2th, ft ZP1*, ft ZP2*, ft

Manning n

62 64 1.33 130 0 0 0.013 61 62 0.67 433 0 0.31 0.013 57 62 1.17 109 0 0 0.013 58 57 0.67 526 0 0.31 0.013 56 57 1.17 108 0 0 0.013 60 56 0.67 427 0 0.64 0.013 55 56 1.00 133 0 0 0.013 54 55 0.67 477 0 0 0.013 51 55 1.00 129 0 0 0.013 49 51 0.67 429 0 0.3 0.013 50 51 0.67 97 0 0 0.013 52 50 0.67 580 0 0.3 0.013

·ZP = vertIcal dIsplacement of pIpe Invert above Junchon Invert. ZPl =upstream end, ZP2 = downstream end.

14.3.2.2 Delineation

• Two primary models will be described below. In one model ("disaggregated"), every individual house parcel (lot) is considered individually, and separated into directly connected impervious area (DCIA) and the remainder (pervious plus non-DCIA imperviousness). Although the computation ofDCIA is reasonably precise, through a combination of aerial photos and GIS analysis, it is complicated by Portland's downspout disconnection program (described below), which applies to the study area. The second basic model is one in which DCIA and the remaining surface area is aggregated into 14 bigger subcatchments, to test the effect of aggregation.

Parcels draining to multiple sewers (i.e., along a low ridge, such that front and back yards drain in different directions) were divided into smaller areas, each with its own (sewer) lateral pointer in the GIS. Runoff from the DCIA Subcatchments is typically inserted into the model at the upstream manhole of each major sewer lateral.

14.3.2.3 Impervious Area

The impervious roof and parking areas for each parcel (see Figure 14-4) were obtained from photogrammetric maps of the City. The model was based on actual impervious areas only; no impervious area assumptions were made based on land use. However, the City of Portland has an active downspout disconnection program, with incentives for homeowners of $53 per disconnected downspout (http://www.c1eanrivers-pdx.org/get_involved/downspout_disconnection.htm). Hence, some of the roofs and parking lots (none of the latter in this study area) are disconnected from the service laterals and flow to vegetated areas or drywells. Areas with drywells are termed "sumped" areas in text below. DCIA imperviousness was then modified, as follows, based on information provided by the BES that applies to the whole Sullivan area, not just this small study area:


14-89 TCEQ Docket No. 2006-0612·MSW Page 107 of 166

•

• Figure 14-4. ArcView map of study area showing individual bouse parcels and rooftop imperviousness. Aggregated subcatchments used by BES are sho\\fJ1 in heavy black. The sewer network is shown in heavy blue. The monitoring station on NE 35th Ave. is shown with a star and the raingage with an asterisk (*). The top (north) eastwest street is Tillamook, the next is Hancock, and the east-west street above the monitoring station is Schuyler. The north-soLlth street on the east is 37th Ave The north-south street on the west, not drawn. would be 33rd Ave. Dim nsions Oflh figure border are approximately 1050 n(32 en) wide by 59011 (180 m) high.

I) Twenty percent (20%) of single-family roofs are disconnected from the combined sewer in unsumped areas. This disconnection is a 'sumed tf' be 70% effectjy~ (i.e, some of the di. c lillceled water now' over the curb and into the sewer through a street inld) The effective disconnection rate accounting 1"01' 1[!J f these factors is l-+'~u, 1-\ ith th" slIl"bce \V~lt...:r sllbcatchmelll receil lOb tt1\' 1\::01ainl 6 fl" u. .1.)

discus'ed in the next secti( n

2) Thirty p..::rc 'nt (30r~. ) of singl -f: miJy roof- an: disc nn cted in "urn eo ar U:>. clod this Ji co necti, n is 100% elTecliv sin..e the sumps (dr, '. Ils) ar' assumed to have capacity to accept al the roof run tT

3) Twenty percent (20%) ol'commercial roofs and parking [I)ts are diS 'onnectcd to a dry\\ell in slimped an:as, but this is irr... levant to this small :5tudy area

Based on disconnection survey data, the impervIOus area for the DCIA ·ubcatchment::. was computed by the BES as outlined below. The liJllowing equations use the existing impervioLls areas (measured from aerial photos Llsing the GIS) and assumed disconnection rates to calculate the impervious area, subcatchment area, and tmpe ious percentage of each parcel that is directly connected to the sewer (assuming no commercial or parking areas in the catchment). That i.. each D .'{ area is scaled ba'k uniformly for each lot \~\cr the study mCQ.

• eOA EXhibit TF-8 8MP ~,Iodehng Concepts and S,mUlauofl SO H Docket 0 532-08-218F. TeE Docket No 2006·06 2 '" SIN Page 108 ~f 166

• In an unsumped area: Impervious Area = 0.86 x Area Single Family Roofs (14-1 )

In a sumped area: Impervious Area = 0.70 x Area Single Family Roofs (14-2)

The assumptions are incorporated into the Runoff Block subcatchment data supplied by BES and incorporated into the SWMM runs described subsequently. The remaining area of each parcel may include some imperviousness and is described below under "Surface Water Subcatchments" (SW Subcatchments). DCIA runoff enter's the sewer system in the model at the upstream end of each main lateral.

14.3.3 Surface Water Subcatchments

14.3.3.1 Introduction

•

Surface Water Subcatchments(SW Subcatchments) are delineated for each of six sub-basins. Street and sidewalk pavement and pervious areas from the parcels are included in the SW Subcatchments. All surface water runoff is collected by sub-basin and delivered to the six corresponding nodes. When this is broken down to the parcel level, each parcel has a SW Subcatchment associated with it. However, they do not include the impervious areas (DeIA) of each parcel that are connected to the sewer through service laterals (i.e., sewer pipes connected to individual homes). These areas are already included in the DCIA Subcatchments, as discussed in the previous section. Delineation of subcatchments and determination of impervious area, width, and slope with the GIS are discussed below.

14.3.3.2 Delineation

The SW Subcatchments were delineated by the BES with the aid of a digital terrain model (DTM). The DTM was created from contour maps of the project area using Vertical Mapper, a third party application for MapInfo. Slope and aspect grids were created from the DTM. The aspect grids show the direction that each grid drains expressed as degrees from north. A vector representation of the aspect was created for each grid to assist with delineation of the SW Subcatchments; an example is shown in Figure 14-5.

~t. ,

--jo ~ 'J. " ~ ~1/. :.c v... ~.J,- \/.". ".l,.'~ , ~~ ~A....

~ . ..: .c ~ " "... ...

~~0 ,

~ a.

Ir: ~~,. _. ,.,. ~ ~ l' 1

k:: "" " ~ i. .. .~ ,

~J ~ k oE ~- f'I.; Jv.:. 1\ f'.. ..".k T I, . \ ".

V

"~ ~ \,0 k:' Ie ... ~ I" , ~ .~ ~ ,~ ':::.l ." ,

:- IL - "" . lL IoC .

~ -': 1 I<:'" ~: - .~ .... '="' k::"

L-.i. ...-" .... // '.-""' ...... ":;.~'"""--lz.~, k' V'\" - ' "

"

71 4. " J." t- f- f... K. lL

l". .' k' f .... Il 'ir. -J., ~ " L.7\ k .---::; , ~. -'!~I"""'"' ~

, ,"':'" ;- , , 1--'-1' ' ,

71 -7,r- It .1\ I'\. f 1", ff' " l' l' 't ( I i\, it"

" .~~~ 'I' '1\ ~ " r 1<:: \' )" fj• 'I' __l~ 1 -I" '1' ;

~~ . 11\ i'F' ' .

~ fI 1'. l' '\ 'j 1\ J\ %l'

~ I \

.." '1" I i\ 1" '~f- i 'f f- k t-' f-f. ~ f . \.; lC

" "'l~~ !I!.':

Figure 14-5. Example slope and aspect grids from the digital terraanmodel.

COA Exhibit TF-8 BMP Modeling Concepts and Simulation SOAH Docket No, 582-08-2186


•

• 14.3.3.3 Impervious Area

SW Subcatchments with infiltration sumps that were installed prior to the date being modeled were given a data flag so that they would not be included in the SWMM Runoff model. This assumes that 100% of the runoff is taken by the sump and removed from the combined sewer system. Otherwise, parcel imperviousness was computed for SW Subcatchments as follows:

Unsumped area:

Parcel Impervious Area = Inefficient Portion of Disconnected Single Family House = 0.14 x Area Single Family Roof (14-3)

Sumped area:

Parcel Impervious Area =0 (14-4)

For both areas:

Parcel Pervious Area = Area of Parcel- Impervious Area (14-5)

• Imperviousness in sumped areas is just the street pavement since the sumps are assumed to be 100% effective. The pervious area includes sidewalks and driveways that drain onto adjacent lawns. "Parcel Impervious Area" above is treated like DeIA in the model.

Aggregated and disaggregated subcatchment models were run, as described below. For the aggregated simulation,

Impervious Area = Parcel Impervious Area + Street Pavement Area (14-6)

14.4 THE MODELS

14.4.1 Two Model Types

Two models have been created for this area: 1. Aggregated subcatchment model (A-Model): 11 DCIA subcatchments plus three combination (pervious plus impervious) subcatchments = 14 total subcatchments. The main purpose of these runs was to compare OSU's efforts with prior BES efforts, and to compare aggregated vs. disaggregated simulation results. 2. Disaggregated subcatchment model (I-Model); 115 house parcels (containing DCIA and pervious area) plus three street subcatchments =118 total subcatchments). The purpose of these runs was to determine the added value of a highly discretized and detailed subcatchment schematization and to be able to separate impervious from pervious area more accurately.

Both models contain three sub-basins (moving north to south) that correspond to the three east-west cross streets (north to south: Tillamook, Hancock and Schuyler, Figure 14-4). Each sub-basin has a north-south

• sewer main line and two east-west service laterals on either side of the main line (Figure 14-6). Pipe sizes range from 6 to 16 inches throughout the study (Table 14-2). The street and sidewalk components for the aggregated and disaggregated models are shown in Figure 14-7.


14-92 TCEQ Docket No. 2006-o612-MSW Page 110 of 166

• ~

J

)//

? / ,I

""i ///

<" '1

simulated in Extran. The aggregated subcatchment model . t ID for the study area, as . <) 5" 54 58 60 and 61. Five smaller

!1g:::-;d~:;~;:':::':::~:";~lA 'e ,,,,,,, i" th' ,ix '''''' :~~e:;"~ ~':~~i: ;", 57;"';62, Fo, th, ,gg"g~t<>d DCIA areas (not shown) drain to north-south ,t,runk sewseare~ are lumped into three surface subcatchments. The

' ,'d walks and a pervlOu. " 14 7subcatchment model, streets, Sl e. . t., b atchments are shown In Figure _.street and sidewalk components ot these sur ace su c

\; \52 l49 50

//

.,....." s{ 54

l ,...".,5560 ,1

/1,

/ /'........, I-

~A I56

61 57 \,

"'......,---..62'.. lor --::1/

Figure 14-7. Aggregated areas for three street sUbcatchments include roads, sidewalks and grass strips. The

•

three areas shown are the actual areas used tor the disaggregated modeling and conceptual areas tor the aggregated modeling. since the aggregated modeling adds all pervious area from house parcels into the three surface subcakhmencs. SUbcatchmenr 28349051 dr~j ns to pipe 5 I (Figure 14-6). etc. (Th e first tour digi lS 0 f the subcatchment IDs are not inclUded in the model data.)

Model A aggregates all DCIA for each of the six main laterals (49,52,54, 58.60 and 6 [ in Figure J4-6) into one DCIA SubcatchmenL plusjust one SvV SUbcatchment tor the entire sub-basin. SWMM input

eOA Exhibit TF-8

B,I,IP MOdeling Concepts and Simulation /4-93 SOAH Docket No. 582-08-2186

TCEQ Docket No 2006-0612'MSW Page 1 , , of 166

• J

../~/" :.: ,

""

J

// I

(

/

<' "

'"

"J Figure 14-6. Pipe segment ID for the study area, as simulated in Extran. The aggregated subcatchment model (A-model) includes the DeIA in parcels in the six areas draining to laterals 49, 52, 54, 58, 60 and 6l. Five smaller DCIA areas (not shown) drain to north-south trunk sewer segments 51,55,56,57 and 62, For the aggl'egated subcalchment model, streets, sidewalks and all pervious areas are lumped into three surface subcatchments. The street and sidewalk components of these surface subcatchments are shown in Figure 14-7.

"""\ -49 50 52 )

/I'/' "" 1-------51 " 54 ~--(

60 55 "'>t'1----// ...." /' --

56 fiR 1

61 57

-----62"'''- 1'-........ / "'II" --l'

• I I f----j I ILi I I I I I II r-

l '1 -~ .. '. 2¥t /

lliHf I r ~ I ~~1~1

. I i I I ,

I

I -. • 28349056 ~I I II ,In-,T[~j I I

I I I--

J I! I I.L~L~! I !1- 1 1 I

K I IT'./'r-. ~t'~31.006LL -'-,-. lA.

I • /

, t

• • •I II I L J

Figure 14-7. Aggregated areas for three street subcatcbments melude roads, SIdewalks and grass strips. Tile three are~s shown are the actual areas used for the disaggregated modeling and conceptual area~ for the ggrcgaled modeling. since the aggregated modeling add;; .111 pervious area fror house parcc:ls into the thr ,;urface subcatchmel1l.-;. Su carchmel1l 2 34'iU51 drai n" In pipe.5 (rig re l-l-(»). d (TIl": 1- r,l fOUl c1i~i(, 0 Cthe subcalchment ID~ are not included in the model dara.)

• Model A aggregates all DCIA for each of the 'ix main laterals (49.52. :4, __ . on and 61 ir hgure 14-6) into nc DCIA Subcatchment. plu: just on S\V SubcJlchm nt for the ntir ·ub-b<.lsin. SWMM input

20A Ex ibil TF-8 B~IP Modeling Concepts nd Simulatior S')Arl Dcckell'l 532 08- ! 86 T JE Docket ~ c 2DOF,-0612-MS"'! Page '1 of 166

data for Madej A are heavily based on earlier BES SWMM runs The SW Subcatchment aggregates aJl• surface water in the sub-basin (over both pervious and impervious areas) and concentrates it into the sewer mainline for the sub-basin (see example in Figure 14-8). The three SW Subcatchment for the 1Model are shown in Figure i 4-7. Model I takes the catchment down to the parcel level, as shown in Figure 14-9. SWMM input data for Modell were prepared entirely by OSU personneL

• ."

.,

ttl

¥

,,'

."

• I

•• IIII., ..,.~ ... ltl~(\-II{ hi..., ••• .,......-""'-"" ,.~."n '''11 LJ

• ·1 ..... '" ....,.. ,."... -I ,..,... J .........

N "~.. "l_)o.... ' ",~..

_ m x

1 b~~(

I ,.-...2 ' 17~ t!22' 5187 ,-1'3"7

~~IpO'. 437 .4]" 52J15C ; 191 .25 3 '- ~~J' J.l3( }l~:;' I 50: '348125,$ 2608• '41~. fi

~- 109? ~19' 218-i 1 1241 ~.l5'l D<;L"1 r1587 I" _' ~)' . I ~;.r • b4jt 4" 12~2~

, f ". "if \2~

.~?~ "I • i- ':'4;

r- '091 191 '=~~ '21 , .1 • '10~

44:?

l~ I '13 !2,~! 410 '4~,: 52l

I '.37 , 4.'<1 eSt)! ~:.4.1

• •• ~O81 ~: 1: b27a V"'I~174

bl~l. 215(

~ IgC ·~Sr '-'3ll'

• r-l~L1l?4 ~ 11'

_I" 21t4

' -I",. ~m'5

~2'OiHr • ~ • )

!

t>J3~ I~I~ t:i'l·' ~.l;

I'OB" ~21)c ~7Gi '17 I 3Ut ......

\

~

<.le:S

L I • ~5S

Figure 1-l-9, IndiVIdual par 10'1. t r the disaggreg<lll.>d model. COA EXl'1lb.1 TF-i3 BIIJIP ,lilodeling COrlCept5 and Simuia Ion

30AH Doc et No 58208-2186 rCEQ Docket No 006-013 12 IvISW Page 11 of 11)6

Ilnihlf'2_,Cloh,t ...... ..:.

A lling ~I).~_p.,,(ol ;1

-Ij..

· AI'''' '~"' .." ",1. f ",,'

rl .....I_ 'Ir", .. ,hr'

ffIU_'. ) ...... ,'.

-iii "JI~I", .... ~. 1\'''.

vll~ I •,,'M. ,

lI"c\l,·1 .ltl~ • • t-

PoIrr.!':

0 OJ'

.,. I

~j"lU:_'(JHL"I'I'

• Pj~"_V.;lh'lt. I r)IJ

Hoil":..~ mllhp

• . "ft,,'_.I>.lel.l!.oIh.

-;

2146 "'::OS 2-13

bA.4i 1:2<1154

'''01

f>1' C4 rS7[

;~t1'.: >

h~>,.l7 37{'-I(I~

~4.3

2-l4t3 'J9~

461 .Slr

~5-10 S66

• Although it may appear that subcatchment 2268 should drain south (to the bottom of Figure 14-9), in fact, the surface drainage is north across subcatchments 2306 and 2270, as indicated in Figure 14-10. Similarly, it appears in Figure 14-9 that the DCJA of subcatchments 2268 and 2305 drains to the sewer line below the monitor, but according to the BES this is not true and is only an artifact of the Maprnfo schematic.

The SWMM Runoff Block simulates a subcatchrnent as having pervious and impervious ( CIA) subareas. Alternatively, each subcatchment could be split into t\.vo, for each surface type. The !:\.v0

methods were compared for the I-Model runs, that is, 115 parcel subcatchments with both perviolls and impervious subareas vs. I 15 pervious subcatchments plus I 15 impervious subcatchments totaling the same area. (Because some individual parcel subcatchrnents were already 100% impervious, the total number of subcatchrnents for the latter option was actually 216 + 3 = 219 instead of the expected I 15 + 1\5 + 3 = 233.) Since results were identical, the] 15 combined land surface subcatchments were used for most of the simulations. The parcel sub-area distinction is shown in Figure 14-11. Runoff from both the impervious and pervious subareas is routed to the upstream end of the main sewer lateral for the street. Remaining area in the sub-basin not associated with an individual plot (streels, sidew~tlks, grass strips, etc.) is aggregated as one of three additional SW Subcatchment (Figures 14-7 and 14-8) and routed to the top of the sewer lateral serving the sub-basin.

A II DCJA that is within the sub-basin but directly connected to a lateral outside of the study area was omitted in the I Models (Figure 14-12), which had the effect of reducing the total area from 16.9 acres in the A Models to 164 acres in the I-Models. Surface runoff from the portion of these plots draining into the modeled sub-basins is included in the aggregated SW Subcatchment (Figure 14-13) .

• r"' '-1.~. ,

100_ ......1.',

2338~306

2305

1

• t ~ • •• ,

•

..... "111. •

., ~. , ...

-Y I ••.• ,I.

r

*f' ~,...... ..... ~

Figure 14-10. Closl...... up of pan'els draining to pipe oZ. Mt~. ilor (st:.lr) i-; C UJlly downstream of entry f 0('1 \ drainJge from 'ubcatchments :226, :.Ind 2 05. likel'l is . l e 'urface area of thest:: t\\lLl ·ubc.tlchmc-nls drain::. nor b (up in ~lg n:) to enter pipe 112 abol,e its drainage divid" .

• eGA Exhlbll TF 8 arvlP lodeling Can pi and S,mulallon SOAH Docket N<J 53 ·C8 2186

1-+-95 TCEQ Doc~et No Z006-D1312-MSW P ge 1, J of 166

• R~I_~O ,1~tI_I1(lIIIlt.,Hlr

-· Tr4 U1_' .,~",,-,l'I; - /' /;r"'.Il".t.,.",. ~,,~

•¥ .... 'r.'IiI_l."NJI'I rhl'

o ¥ NIJ'.l~2_"PI"11t1V

•

~1~1l.'':_''~Irrt.j ~p

•

•

i I-I I I 11j.I.fl

figure 14-11. Dark areas (blue) are DCJA and are surrounded by lighter (lavender) pervious areas. Both subareas are represented for each parcel in the disaggregated modeling. For the aggregated modeling, the pervious

• (lighter) areas are combined and added to the appropriate one of five street subcatchments and the DCJA (darker) areas are combined to form six DCJA subcatchments .

/

ttl a\lJ~J • • J'\I1.1"-" I1Clol1.l1_~ .,tIl""'r'.

t{ ~"rll~._t jt~ .. l~t,rr

CJ

rigure 14-12. The dark (blue) DCJ.\ cooneCled outside the sub-basin is not induded in the model as th<.' runoff en cts are not noticed at the monitor. The DCJA connected to ~eJ"\,ice laterals in the highlighted sub-!X\'iin i' all model d wilhin individuGI DCl.'" Subcatchmt'nts (I-Model,) or" lmlned for the appropriate aggregated subcatchlllent ( -Models) .

• CO" Ex Ibit TF-8 S'-IP Modeling Concept; and 3u."ul;ItIOI SOAn Doco<e! ~o 582-J8-2:86 -CEQ Oflcket 0 2006-0612 ISIN Page I 14 lJf 166

• ,. """'II"' Ui .. ....P 0\:1'11 I II ~

-·

P".'I"I", '.(I'Iil';flr

¥' H"1l'Ell_pn'1I1 .,tp · Y N_uh.ltn•• hP

1-I(Io~lI_t_p(o,ftt..J"1>

.r '!!lI1f ..... · 'I!_"ltlt .. "',.".

o

Figure 14-13. Parcel land surface definitions. The pervious (light, pink) parcel area adjacent to the highlighted sub-basin (yellow, at bottom) is included in the aggregated SW Subcatchment for the sub-basin in the A-Model, Pervious area (within the watershed, Figure /4-11) is included within each of the liS individual parcels for the 1Model.

• /4.4.2 Width and Slope

The Runoff Block requires a modeling parameter width to indicate the shape or flow path of the subcatchment.

Width = Parcel Area/Flow Length ( 14-7)

where, for individual parcels in the I-Models, Flow Length was assumed to be:

Flow Length (ft) = 25 Ct 0 f 0\ erland /low + subcatcbment hou -e connection length/tJ ( 14-81

Thr' c U lioll t' r width generally attempt. l di 'count the chdnndi/,cu 1101" in the pipe and 111 ke th<:: ocr ubcatchmcnts concentrate faster then the S\V Subcatchmcnts. In the I-Model runs, most widths were rounded to 50 ft in order to facdltate sensitivity analysis. The width parameter do\:s not have a great in!luence on model results for thl; 'C relatively small subcatchments, since the time of concl:ntration of the subcatdunent i' much less then the duration of most storms. Hence, equilibrium (peak) Dow is reached ('or each hyetograph interval regardless of the width.

For aggregated A-Model subcatchments, the length of overland !low was assumed to be 150 ft of flow from the back of a lot to the street plus the distance from the (-arthest pay 'ment POlTIt in the subcatchment to the;L rf' "c 'Aata inld. The dist i .:c Crom the lJI"th ~l pa~cn enl P<Jllll ~ a; ddcnnined \ tth the GIS by u,'ing a routine to create points at 5-ft intervals along a street centerline map and querying for the farthest point within th ·ubcatchment. Again. Equation 14-7 was used tn compute the 'A iclths for the aggr galed 'ubcatchrnents

• eOA exhibit TF-8 BrvlP odeling Concepts ar~d 51muiatiGn SOAH Doc~et ~ 0 582 ·08·2 11\6

I -t- 7 TCEQ Docket No 2006-0612-MSW Page 115 of 166

• The slope of all DCIA Subcatchments is assumed to be 6%, a combination of single-family roof slopes and lawns. The slope ofeach SW Subcatchment was calculated from the slope grid (Figure 14-5). The average slope of all of the 40-ft grids within the subcatchment was used as the subcatchment slope.

14.4.3 A-Model Input Data

Because there are only 14 subcatchments for the aggregated model, Runoff Block subcatchment data are shown for this simulation in Table 14-3. This includes the three SW Subcatchments (labeled with 9000numbers) and the 11 DCIA subcatchments (labeled with 8000-numbers). The numbering scheme corresponds to the last two numbers of the sewer segments shown in Figure 14-6. For instance, SW Subcatchment 9056 flows to pipe 56 and drains the entire middle, yellow-highlighted sub-basin shown in Figures 14-7 and 14-8. DCIA Subcatchment 8060 drains to pipe 60, etc. All DCIAs drain to the top end of the lateral. It is assumed that the pervious areas of the parcels drain to the street and are therefore included in the surface water catchments. The remainder of each of the three main sub-basins is aggregated into one SW Subcatchment representing all pervious areas and the impervious area not directly connected to the sewer system (but including the streets, since this was the scheme used by BES). These drain to the sewer mainline for the sub-basin. All slope, hydraulic connectivity, infiltration, and other parameter variables (Table 14-1) are taken from BES data.

Table 14-3. Subcatchment input data for aggregated models (A-Models). Other parameters are the same for all subcatchments and listed in Table 14-1

• Subeatehment ill

Flow to pipe:

Width, ft

Area, ae

Imperviousness, 0/0

Slope

9051 51 248 4.38 16.8 0.077 9056 56 276 4.7 18.1 0.072 9062 62 274 4.6 18.2 0.08 8049 49 190 0.42 100 0.06 8051 51 18 0.02 100 0.06 8052 52 181 0.51 100 0.06 8054 54 226 0.54 100 0.06 8055 55 21 0.02 100 0.06 8056 56 25 0.02 100 0.06 8057 57 36 0.04 100 0.06 8058 58 221 0.57 100 0.06 8060 60 215 0.47 100 0.06 8061 61 245 0.55 100 0.06 8062 62 116 0.12 100 0.06

Since the basin is a combined sewer area, baseflow (dry-weather flow) nee4s to be considered. BES data indicate an average of about 0.032 cfs at the monitor. The BES provided distributed baseflow estimates for each sub-basin, and these were added to the upstream end of each lateral in the Extran simulation. However, the 0.032 cfs baseflow is almost impossible to discern during storm events.

14.5 MODELING RESULTS

• Uncalibrated SWMM output, including baseflows, for January 13-18, 1999 for the aggregated and disaggregated model representations is shown in Figure 14-14. This time period corresponds to a high 5

COA ExhibitTF-8 BMP Modeling Concepts and Simulation SOAH Docket No. 582-08-21 B6


------ -- ---

• day rainfall total of 2.42 in. (61 mm) and was used because BES focused strongly on this time period during their modeling efforts. There is good correlation with monitor t10w data, but the comparison is difficult to make visually when the five days are compressed into just one plot. Hence, the event of January 17 is considered in more detail in Figure [4-15, wherein it may be seen that there is practically no difference between the aggregated and disaggregated model simulations. This is good news for continuous modelers, for whom an aggregated model representation will require much less computer time.

1.6 -lJ---:o:~: :IO,t::~ fI0-1- .--...- ....- ...-...- ..----.--.---.--.--..... - ..._-.--.._...-- --.,

1.4

-- Included -- 1.2 ~ .-Model ith base flo I~ .._.__~ 1.0 i included J

--; 0.8 o

oi:L 0.6 -1--

0.4

0.2

O. 0 -l=====""=~~

01 1399

• Date

Figure 14-14. Five-day comparison of simulated and measured flows at the monitoring site. A visual comparison is difficult because of the crowded scale.

01 1499 01 1599 01 1699 01 1799 01 1899

---r----~

1.2

1.0

08 ~

82400 93600 104800 120000 13 1200 142400

Time -- . -"_._---------------,

i-Manito Flo --A-Model Flo agg egated model . ~.:.:..:.....::.'."IOd.':I~. dlsagg egaled mOdel j

Figure 14-15. Simulated and measured flows for seven-hour period 011 January 17, 1999. The aggregated and disaggregated models show very little difference .

• COA. Exhibit TF-8 BMP Modeling Concepts and Simulation SOAH Dockell~o. 582·08-2186

14-99 TCEQ Docket No 2006-0612·MSW Page 117 of 166

• Generally, the model vs. monitor comparison is good with regard to shape, but the rising limb of the modeled hydrographs is somewhat high, and the modeled recession limb is somewhat low. This might be better simulated by detaining a little more water on the land surface prior to letting it run off. Recall that no calibration or adjustment has been attempted. Extran continuity is very good for all runs, on the order of 0.4%.

Another method for comparison is total runoff volume; these values are shown in Table 14-4. Baseflow is necessary in order to obtain close to the monitored runoff volume. Runoffvolumes are comparable for the aggregated and disaggregated models, as would be expected from the inspection of the hydrographs. This confirms the utility ofaggregated simulations for long-term simulation.

Table 14-4. Model total flow comparison for five-day event, Jan 13-Jan 18, 1999. In bottom row, K. is the saturated hydraulic conductivity. (After Huber and Cannon 2002.)

•

Total flow comparison for 5day event, Jan 13-Jan 18, 1999

l7-hour interval, 7:00 am to 2:00 ~Dl,January17,1999

(cubic ft) (in.) (cubic ft) (in.)

Rainfall for event 148,987 2.42 37,555 0.61

Monitored flow 58,130 0.94 14082 0.23 lBaseflow volume, @ 0.032 cfs 13,824 0.22 806 0.01

"Model A (aggregated ~atchments)

No baseflow 47,244 0.77 12,492 0.20 !With baseflow included 60,459 0.98 13,365 0.22 "Model I (disaggregated, ~eparate subcatchment for "ach parcel)

lWith baseflow included 60,492 1.02 13,416 0.23 "Model I-LID (re-routing ~mpervious runoffover pervious area) !With baseflow included 26,829 0.45 4,494 0.076 Same as above but with Ks = III 0 previous value 27,762 0.47 4,872 0.082

•

14.6 LID SIMULATION

The essence of LID is to retain as much water on site as possible at the parcel level (Prince George's County 2000, Wright et al. 2000). One essential technique is to minimize direct connections to the drainage system by routing runoff from roofs, driveways, etc. over pervious areas to promote infiltration. The SWMM Runoff Block has been adapted for this purpose by Huber (2001a) as discussed in Section 4.7. As indicated in Figure 4-1, overland flow can be rerouted internally within subcatchment subareas (i.e., from pervious to impervious and vice versa) and also may be routed from one subcatchment onto another. The simulation shown below simply routes the impervious area runoff from each of 115 parcels over the pervious area within the same parcels, sort of a massive, hypothetical LID effort for the neighborhood.



• The I-LID simulation uses the I-Model as the base and reroutes 4.0 ac of impervious area runoff from rooftops and driveways over 7.9 ac of pervious areas of each parcel. Street surface runoff (and sidewalk and grass strip runoff from the three street subcatchments is unaffected. A drastic reduction in the runoff hydrograph (Figure 14-16) and runoff volume (Table 14-4) is produced by the LID option. The 5-day runoff volume is reduced by 56% and the 7-hr runoff volume by 67% (Table 14-4). This is to be expected for this hypothetical simulation for which the saturated pervious area hydraulic conductivity of I. I in./hr will accept any intensity of runotf associated with typical western Oregon rainfall, including the additional non-DeIA runoff from the roofs, etc.

1.2 r \

-~---------tA.\..-----

,

-\~--i

0.0 +-----''---------,-------,--.--''-----,----------,-------,

0.2

0.4

I

10[

~0.8L

-; 0.6 -~----f .2 u..

71200 82400 93600 104800

_____ Time 1- Manito Flo -.- -model ith baseflo -_~..:..-.E MO~~

Figure 14-16. Comparison between Modell and Modell-LID simulations for a seven-hour interval, January 17, 1999.

Soil is often compacted in urban developments, with a lower hydraulic conductivity than for predevelopment conditions (Pitt el al. 1999a). An additional run \vas made with a value of saturated hydraulic conducti vity, Ks, equal to one-tenth of the value used for the rest of the modeling. That is, the new value of K, = 0.11 in.!hr compared to the previous value of K, = 1.1 in.!hr. The much lower hydraulic conductivity resulted in only slightly higher runoff volumes Crable 14-4) for the 5-day and 7-hr duration events. (The hydrograph is also a little higher but very close to the loUD hydrograph shown in Figure 14-16 and has not been plotted.) This reflects generally low rainfall intensities in western Oregon (typically less than 0.11 in./hr, but of long duration). Thus, an even lower infiltration rate would be necessary to reduce the effectiveness of the UD option simulated. This is to say that this LID option is likely to be even more effective in climatological regions with rainfall (and runoff) intensities that are characteristically low in magnitude.

This LID simulation is not completely hypothetical. Disconnected flows due to the downspout disconnection program are directed to dry wells. Although this program mainly affects rooftop runoff, its impact could be signiticant if implemented over a large area.

Intiltration is assumed to remove quality constituents as well, either through advection of dissolved

120000 131200 142400

• constituents into the soil, or by sedimentation of particulates as water enters the soil. Hence. intiltration is

COA Exhibit TF-8 SivlP Modeling Concepts 3nd Simulaiion SOAH Docket No. 582-08-2186

14-1 I) I TCEQ Docket No 2006-0612-MSIN Page1190f166

•

•

effective in cleaning up surface water. There may be concern, however, about the impact of infiltration on groundwater (Pitt et al. 1996).

14.7 SUMMARY AND CONCLUSIONS

Version 4.4h ofSWMM has been applied to a l6.9-ac combined sewer catchment in the Sullivan Basin in northeast Portland, Oregon. With the aid of prior modeling work performed by the Portland Bureau of Environmental Services, the SWMM Runoff and Extran Block simulation of the area compares well with monitoring data for a l18-subcatchment disaggregated simulation (I-Model) of every house parcel (tax lot). The simulations are uncalibrated and could easily be improved through additional effort, including a better definition of baseflow in the combined sewers. In addition, the disaggregated simulation of every individual house parcel compares well with an aggregated simulation that uses only 14 subcatchments to simulate all the parcels, pervious areas and street surfaces. This suggests that long-term modeling (i.e., continuous simulation, if performed) can conveniently be done with a less detailed model representation.

When a typical LID option of routing non-directly connected impervious area runoff over pervious areas is simulated, the hypothetical SWMM Runoff Block output indicates an expected reduction in discharge. Although no hypothetical quality simulation was performed for this study area, quantity reductions by infiltration induce corresponding quality reductions (Huber 200la,b).

To summarize the key points presented in this chapter (Huber and Cannon 2002): • SWMM may be used to simulate LID options that involve routing of runoff from non-directly

connected impervious area (non-DCIA) over pervious areas, e.g., roof and driveway runoff over lawn surfaces.

• SWMM may also be used to direct surface runoff from one subcatchment over another. • Simulation of an aggregated model representation (14 subcatchments) performed about as well as a

disaggregated model representation (118 subcatchments) for the Portland, Oregon test area. • A hypothetical LID option that infiltrates all roof and driveway runoff in the dense Portland study

area is predicted to result in over a 50% reduction in runoff volumes and peak flows in the combined sewer system. Although a reduction would be expected, the modeling allows a better quantification of the potential results.

COA Exhibit TF-8 • BMP Modeling Concepts and Simulation SOAH Docket No. 582·08·2186


•

•

•

15 CASE STUDY: BMP SIMULATION,IN PORTLAND

15.1 OBJECTIVES

A detailed example of a hypothetical LID simulation in a real, well-monitored Portland, Oregon catchment was presented in Chapter 14. A similar, if somewhat less detailed example is presented in this chapter for simulation of a detention pond, representing a very typical BMP (Chapter 6). Once again, excellent cooperation was received from Portland BES personnel, including extra help with interpretation of data and graphics. Additional details of the simulation are provided by Stouder (2003).

15.2 LEXINGTON HILLS AREA BACKGROUND

The modeled area was the Lexington Hills BMP area, which is an area with a constructed pond located in the Johnson Creek drainage in southeastern Portland (Liptan 2001). The actual site is just to the west of SE 162nd Avenue, approximately ~-mile south ofSE Foster Road (Figure 15-1). While there are two ponds on the site and one planned, data was collected only for the northernmost pond (Pond 3), constructed in 1996, which is located at SE 162nd Avenue and SE Flavel Drive. Aerial photographs of the pond area are shown in Figures 15-2 and 15-3.

Although during the wet season there can be a small pool below the orifice outlet, Pond 3 is intended to act as extended detention and is designed to fill for a stonn size of 0.83 in. of rainfall in a 24-hr period. It receives runoff from a 26.57-ac residential neighborhood with 8.75 ac of (Figure 15-4) impervious area. The pond has approximately 3,000 fe of dead storage plus another 8,000 fe of active storage (Figure ISS) above the outlet orifice. Influent stonnwater enters via a 24-in. concrete pipe, and outflow is discharged through a 6-in. PVC pipe fitted with a 2.5-inch reducer (orifice), designed to empty the live storage (extended detention storage) in about 24 hrs. There is also an overflow weir. Both the orifice and the weir then discharge into a stilling well. After the stilling well, water is routed approximately 75 ft down an open channel to Kelly Creek, a tributary to Johnson Creek.

In 2000 and 2001, pollutant samples were taken by the Portland BES at the inlet and outlet of the pond (Figure 15-6) during seven different stonn events (Liptan 2001) in order to test the pond's effectiveness at pollutant removal. Stonn events 1,4,5,6 and 7 were the focus of the SWMM modeling. Events 2 and 3 were discarded due to minimal rainfall. All stonns except event 7 were selected by the BES so that 24hour antecedent rainfall was minimized in order to get results for a "first flush" of pollutants. The sampling dates are shown in Table 15-1.



• Table 15-1. Storm events used in SWMM simulations. Event Date Event Rain*, in. Pond inflow, re Pond outflow, re

1 4/13/00 0.73 8,275 8,075 4 10/9-10/00 0.81 8.276 6,815 5 3/1/01 0.49 7,538 6,217 6 5/14/01 0.56 10,688 13,364 7 5/15-16/01 0.30 7,898 8,917

*Ho1gate rain gage.

•

ENVlRO~ALSERVICES CIT"t' OF PoRTLAN-o

VIcinity Map Lexington Hills

BMP Monitoring

Figure 3-1

• Figure 15-1. Location map for Lexington Hills BMP site (Liptan 2001).



•

._L"'_'__., l' , •

Lexington Hills pond vicinity photo (Liptan 2001).

•

• eGA ExhibIt F-8 S/,;IP Modeling Concepts and S,mula, lJr'

S A.... Docket No 582, 8-2186 IS-IDS TCEO Docket No 2006-0612-MSW

Page 12'} of 100

Figure 15-3. Lexington Hills pond site photo (Liptan 2001). Pond 3 is to left of intersection.

• • •

11

liL I ::i' it=;~~l;)=-~1 i , 1:1 ." . '~'~!I[ril Hl··· . i I ;', i

..

i.1 . .. ~._~ _. u._~:-;;..L._.,.J ' ':'.. II _.l:~..= L~.~..l.l~:"'."~. ~ i.· ...•~l~l )~~~~L'.b-:::~::d:';;:f:·..,.<

1'-"1 JF'" .~ "-···='·.I':i'l'f···f·~T-·~r·i"'T'·-r rl',,,,,-::~; . ! ~ I· : .,I . '-'."1---+/.'1, - .

:LL~~, .. ,!, ; ~.il; '.,. _J<6'~JL~._ r: u:~~"CT~~lr''[~"CrCTu'llT"u \ -, H-Ir -Iii" 11' jl,,'-1-----·-T i "11[-- I----'-'T

:flr='---'t~~frtut~-? ,.-::" ~ I, ) i ! I ~ I [ ! . ~ ::I}f'

~i\.~~~J.:_!~l~l;_. . ... ~..,.....-"'"HJ..-_,_:Y~~ _~',_~~:::'~...;_ ,..:t'.,.L.,;. ..

," ,I!:!J(;~-~)I 'I-~-" T-·~Tllr··=·- .~ ,!~.-:~ :7:~~~ .,I"~ L:,--'+-:~iii4 I~ , _

'Ill i1 li .!..

Sf'()1IJ/ [)R.~N Pi.A.~· KAT JIAP

-" .•• ~);.at<:;.:.,

UlI'A1HULHI Of

d

@ £.

__• ,';;;;-;il, PLlUIJl; UUllIllS ... -. '.. •.••~~~-~~-~~ ._~;-""!-~-'.-

.:..(_,'111_.. !.. ';.....................' M,'Io;lA r ...u-l. l'l He. I .......... ~ .'-. ~..

nt- loW" r,.l.f.A.A~~'"

',•.. '

'1--

Il,

", 1, ~ ._

.l"L't'iJJ"f.?"1i. "~Y/"'~ iIlon"ro.I,~'\'T7i1~~1i

Jll:.lII J:tWt"-lL :~...~'i':.e

~ r~-"

!~

, ~ i

Iii!

~~ /~~~~~if!.\ !)"i:. '6}'~!J A·,~. _'WX,..l1-i Of ,~05'f" RO. HA.WTHOIINE RIDGE - PHA.SE I

"b;.~._i'....._ STOR~ D.~.A,' N L ,'1.'£ KEY MAP ~?34

........... ~ .......:;-- ~'~~;~~J SDIO

7383 lh:ff~-f,....,:a.::tl

Figure 15-4. Lexington Hills BMP site in relation to catchment (Liptan 2001). Pond 3 is at upper right comer of figure, to the left of the upper-right intersection.

COA Exhibit TF-8 BMP Modeling Concepts and Simulation SOAH Docket No. 582·08·2186


• • • .0:')-.

'''I\i,~ .:i:;~ 1),~' ~ ...·ly

'..:(.~.

f~Si\~.i~;;~~J~~--.\ '\ ~~._2;~ JI,

,~ -- ' ••M

;."r_:~I~ .r~.'\oA.,-;~:'S'~"';'

~" ••"n~'.",

\ _.;1... ,..........\00 .... , ",vr

/)<,::~~~\:i5!D :::8 ~'=:~:~~~~~~ ~,~~:~~~:~: :'~\,~ ~._~

...... /~>.,."" ... j ..,.J

, '", '" '- ~~<L)b'" • '"':'•• ' :::-< ~ .~..

~~ ~i~.... mr ~'" --' ~ .. '.... .l;:~ ....... ......., ~ --.... ............~",. ~ ...,~, " :~ '" "'.; 'lit ", ;_'1) ; ~ " '- - -..: ,'", \;\ \, \\:«:;-.x .~.- <v, ',/'"<" '_.•_, ~~'\~ \<'~~ .:t~~

, • )", 'V"",-__ r~J I ,,~\ 1- " . :. -...." '\' \'}t\, '\. ,lI:.tI.:~~' , \. \', '. \ - '-~ \ '\' \. \ ':'1:.•,.\: '>~n:-~'t

~q" • ...,,~,'," r \\\\ \ 'qAn",,,,,,,,~\ \ \,,,.\\"t,~~\ \ .~\ \ \~'r d~"l.:"'''''' ~'\. ~ \"\~"~ 'Y\\ ,"" ~ ~\ \, 1\ •• 1 ..1_Ul.....-~ " "\-\-." -_••

_ C:~!t'-h-_." "f\\ '. \, ,:-:;~;-,:'.. J.::~. ,~\':::- \ ~,\ I ':---;;;''''\,__.._ ,I' ..... ~ .... • ..?" .....~.~. "':-\'11.\& l~ '~l"'0CI"l.')"""~- ~\ '1'\ 1'1I,~ " ~-"--"'~X"·"."~'~·t~: ..,'. • • \ 1 I 1....::"1 I ~ / I ""'. A..... .IJol$O .~ • _ ~ "'Q' .q-.;.~, .:- :nn "'.... ,:...1:\'i" I' '1 I, A·" «/ / ' 1 ' !.\ •••, d . II";:" ""l' "'fl..... ~~-~ I.! .',T'''' _"I.'3!',....-:.:;;:.1l ....~.,l '\ 1'1'1'!i'l~ I" 't.~~J -I;~Q ~~~"'\ ..<~, i~'///~. ~.- -:. ,...... - ,.I ""-''J ':.'~ :'~: ~'~>;~,;" ..:.~.- ,'~~:~.'o'

.... »I.~~);.r:'j "' 'j'1111I,I' I I . " [,i6 1,., ....1.;//.. ,/ ~. ~I.,~~;:~\':'~~,r. ":'~ ~~ }~~~U''oN I" ", 1 ..'".' > -' A", • , 't I i I' ~ I I ,.~, ' ,'" , ''\ -' , 'I / -,' ,<'< • "':Ii. '.".~ ~~~::.·""l ~.";:'..~', /,1 ' , J I I ,r f 'r I / ",',',' " // .. " -..,: . ...·"'·UH tJ r t' i ' tJi IJi'\ . 'd,:' /" -' ':"/ ~ "./ / ), I ~9. :;s ~L._r

~~7"i,:...II· ..·I!~11"t·, 1..... '·....///.-',>-""("' ( ·'·'·<:l."~·· '~:....... . .... --."o r, • ,', fL." ~ \ /"-~ - ' ',,<.! \,' >' ~ 1'/ .. ,',' I 'l'I \'.\\_\--- ~IX:»U'F I ,i,....-. ~\-); ,'F _ '.\

" ... ~~ , /,.',L(L+ ~-r~~~~:;.'1.:-· ::Y:-=::~"-'l ~~"~~:''''''' ''''~,('~'''''/ __-~-'k''.-.~ .......' __ --;-,rt,f/' . I I I \ \ ......~~ _...~~;~;~;:-:;...~! •.;.... " " ..I ,~ ...\.~ lo: \ I-' "~':I.'~'~ll:JI ". ',. ~;'.: I·.~!V'""ft)-cur~ I"'" .. I I \_o.;....-~., ....._-~~~~.}.' '-, \ ,~..., __\--- ---_\j

0:11' \;WO:~ ,: !! /j__ ~ _ __ -1-':- \ ",'<.-; }j; ("- ' '~:' ".. :r.:<--' _~\.~_ - r ...... ',j (.. '.\ . .........'0:+'0.- _--i-:....tt"l,' I ..:,- \ >'\.,. "••/" ,; Y.J,'" ",' ~.. " " \ __ ~ "

, \

r = = = F' - ~ ~~: :~.-: :i '~~~, :~~~~-," _. _~.~~_ ,;JI0Q..,.'t ~ , 't I : ; " I' \ " I, \ ':\ \ " ' ~. "'if~;~'" "".. . '~.' .' c _ \- '.; .. \

"=4~.~- ~ \\\\~:2 " \ \ .... \... './~),~ _"~"'\~"" ".... ". _= :"__ . -~ --.... \ \ .". ... \, \",'1";' \ , " \ \ \ / / ,~'''-\~~~ '-- - ..'-- :,1'- '~',

'I~,\\\\\ -\ \ ", \ '\; >)...: .......;{I\.·"..,...v.... ~~.· -- ... :::..~"_~~ .. ,., "\" .?

. "''',:J~:.i~'''',::'i1''''';,s,d/ :.''':;:;:'~:

",', ~" '.. "~' ... , \, ,)(,r"'-. ,~~_, ~u,·...iI\ij,.".... \1,\\ " ....... \ I~~I " v,.-; ,~ ....>:~~.... --~~____ ;r":.,:.\"""",,,,,~" \'"", '\ \ ' ' .• ' 1)<, '>" v: ,:'~-' '. -',_ ' ----_. ::!;;.":.."~!l. , '

',' ;'. Q/irUT STIIIJCTIlRE'.: /'. f?\\:,;;;:'~:\,~<}~>~'y;~~.:,:.:.~" ..\:.~"~::::- -. - ,\":\, ."---\iiE) ..

. ~.. t '." '~);,,, ,If<. "" ~):~sr- /,,1\. \ ,;::;;:;;~::'. ,- \.." j\ ....... ~), f " ...... - . ' Y , Ii: .... 11 ~... - ,

'''i.0'·''fo.- :,'..... " ... i}'!"w) ", ,",~""'~:~.!~J.al ... ~.I .... ;, ';.,'\.~ ... I" ....... .HI.T.-..... ..t'~~w ... :.,·...

I,

I.

.,- i II ''/ " r _.:.. ..~':t1 ,.-,..: ...-11\1 Ii', \ ;,

\.I' I .1 I;' if ~ .~).I._. \, ! II ., I! I ~ ',- ,':" ~w

~."._-'----._. M.;,.",-ypfa· .F!\Willl._ /fh!/fVo rl'\\'7\U"IJ~"ir-...... ~., 1POND NO ,1 PU.V _~. 1 I ....- '~ ow......"n. I~_~~~~,l ~~. :~~. r~·.':\<,Q&'1'1hI\!>~.'W

~DZI ~ : 1./ 1 I.r;~~.~.;.~_ S/: Uj:i'i.l .... ~·t soo,r..' CF rOSlER RD,

--""-,.~ . .. ,,,·.,_·,~o·, ~ .,.

UII'J\M'''•• Nl VI • -l'""

~"-".~~.'~ ...... _':.',,- _._. HAWTHORJoI£ RIDGE: - PHASC I...~i~~S~l~\.~.' ..919IsI'ljl'U IC UllllIll'l 'j ~ " --.. :::-";"i,,",,·,.~.:ii''' ,'5'l':~:4_5:,raQt.fW4 rEf? .~4CI·i; r,'ES~.~:.6"" . r- '.." _" '~'1

;~. % '1 ~:OND ".J to· ;,;;;.-.' • ;: . ..:,; ...... ";,,.;.' '·""I.:Il.. I_"'- .. I~IIoCNI.. ~

... ')t '~>J~~.:';~::~:'..l;~1f."w -...... ,_ ......... ......... ..-. 5D21 ?JOO II'·hl·. '';.'''.-'-l,;fw.c..; H<olJ.L ".J." f'o,o.1A

Figure 15-5. Details of Lexington Hills extended detention Pond 3 (Liptan 2001).



• • • "I \

\.. . .. ----1\ \ \ \

' , f, ;::.'.••~~~~y. \'1 1"d ro...,~,: , 'fJ '\

Se.'\6 " " , \ \ \, '", "" ............

~ \'\\' /'" '~

/ //

\\ ;X:::::"":::"Outl~ '.

~i~i11liw"\ .. \

..........,-,-...............

,

\ \.

'\, \,

"

" ~, ...

'" \,/i..<::"'--,.//

\

\"

\

\,I "

\ \ ~

~&u~

::Ail City of Portland

Environmental Services

Site Map

Lexington Hills BMP Monitoring

_.. .

Figure 3-2

Figure 15-6. Location of influent (Site 1) and effluent (Site 2) monitoring (Liptan 2001).



• Flow-weighted composites were prepared from sample bottles in order to determine event mean concentrations (EMCs) at the influent and effluent of the pond. Flow measurements were conducted at the pond entrance and in the stilling well of the pond exit (thus measuring the sum of the orifice and weir flows). Details of the sampling methods are provided by Liptan (2001).

15.3 SWMM MODELING

15.3.1 Background Information

Fortunately for this project, the BES had performed prior SWMM modeling of the overall Johnson Creek watershed. A map of Johnson Creek subcatchments is shown in Figure 15-7, with a more localized view shown in Figure 15-8. BES SWMM data were used as the starting point for simulations described herein. PCSWMM (http://www.computationalhydraulics.comJ) was used as the graphical user interface (Gill) to run SWMM version 4.4h.

The City of Portland has an extensive, cooperative network of tipping bucket rain gages (with the U.S. Geological Survey, USGS) that provide rainfall at 5-min. intervals (http://oregon.usgs.gov/non-usgs/bes/). The SWMM Rain Block provides the ability to process such long-term data for input to the model. Rain values were supplied from the Holgate rain gage ("gage 21"), located approximately 2 miles to the northwest of the site (a general map, from the web site, is shown in Figure 15-9). Continuous 5-min. rainfall data for the period from January 1, 2000 to December 31, 2000 were imported into the Rain Block. Rain Block output was then linked to the Runoff Block. At first, actual rainfall values used for the measured data were averaged from the Holgate and Pleasant Valley rain gages (Figure 15-9).

• However, after reviewing the rainfall data, it was determined that no significant changes in simulated rainfall occurred that warranted the averaging of the two rain gages for SWMM modeling; hence, just the Holgate data were used for all runs.

Next, a Runoff Block input file was generated using the subcatchment data provided by the BES. Interestingly, the BES used an imperviousness percentage of 14, compared to the ratio 8.75/26.57 = 33% given in the BES report (Liptan 2001). The 14% value was used in the simulations because it gave much more reasonable results than the 33% value (see discussion of volumes below). Another slight discrepancy is in catchment area: 26.98 ac in the BES SWMM data vs. 26.57 ac in the data report. The former was used in these simulations.

The wet time step simulated was 15 minutes, while the dry time step was set to 24 hrs. Dates of simulation were set to correspond to the storm events in which sampling took place by the BES. The SWMM 4.4h Runoff Block input file is provided in Table 15-2.



• • • ~-----... .

.... .-... ,. j ....

l

r-' }

_\ I '", I ..... I

"'.1'CHI_'.

":'rt ~ B

/

'I

.J1_l .... -J---,-'--~

" '/

~.

~ ........./

(jrr;$1!

1,.01

'>

I

.-~-'"

,1"', ".~.-- "" I.I 1'11.0.) ," [,' ...~ ,c.rt:.~...

\~J",,",~'

f/ .r

I) ......·' f --".I -

-I",m2 I "," J""'1.>' I! t'AO'I .

':'., I"'''' ,[~.. -... , ," /I, r . ,"' , { \ ~.' -.(

( ".",,, ..

r·-·

\,

1\-;1_-4 . "T~' __.....- L •

,l./"L1''b

''',IH~" ...moi

III '101'11, \\

)'.'wUJii..

1I.'I·til. ,m,/

.\ .... I

''-,.~.

rl

I I \ r .~m1

,-JI

j ··1 i,

~ .....,

,),/

Figure 15-7. Regional slIbcarchments usell ill BES modeling of Johnson Creek Warershed. Lexington Hills is at subcatchmenr JC35 in cent~r of the map, .I,,!ln,nn Creek runs 111 I·cd. from rig!lr (east) to len (II cst).

.----# ,I l,.'- """'-.'- '-'"

\ ~~

,I, ' \ I

' .---

f, ... OJ

..'

---"',-, /..-.0'; It '-. , \

"''- " '" -'-- -1

\' " .... 0"2

/'

rc::to' ,.. .... .."--

J

! I

[

I , r ~'

, ,," .I_~··L__) , {

COA Exhibit TF-8 BMP Modeling Concepts and Simulation SOAH Docket No. 582-08·2186

j 5·110 TCEO Docket No. 2006-0612-MSW Page 128 of 166

• • •

. ) P053 ~,L\

, _._JRIVO~3

JC34 \. ./I·" .I ! ...1 GresH" I,! I JCJ2

• ".'f'RlV911:!' ,I

~,~ ..RIVO 10t / ~. ',-----~,'

"'-

JC37 / RIV046 ~1 . ~"

1IVQ~27~-1 !

..-''i-- ~\'"CC3i, 7 \ \ .-. '-s;.J'_

/ rl, " 'rr- , ", --'

~---_ .....o 4, - ~_J >~/ ' ( I .~/~-5 '---------------~'--~-':IRIV037 /!'·-<C \ RIV044II ' jC36 ,f

RIV038RIV039 '" ------f ,i1--~{ / _, ... -,.-~.~L-:~--.-( ~

II_.~_-- RIVQ4D·- \, '- "RIV045 \1 ,"

1 ./. .i

V022 ,. Rlvo'J1 - Ii" , \JC35 \ ',' - !./", RIV036 1 ,.-- -' I

'---'- j-'

,1 II __ r--~-' KAI07\ ~1'\ l '

018 \ RIV024I , ': RIV035,.

I ' ,7,_\RIV041 I, I I !RIVOi6 \

19 .RIV029 ' ,/!-' " -~.-- I ......._~__ ,

, ...J

I- ", __ -- -._--. ~-_. 28 [ RIV034 ~ KA

~. {RIVD 2':1 RIV026 R IVO (r --Ji 101

020 k·--' --: KAIOS_',RLVJl32 /

Figure is-H. Localized view of JohnsOil Creek W'lh-rshed suhcatchments. Johnson Creek is shown in red and tlows west (i'ight TO left) in upper portion of llhlp, file Le,x.lllglOl1 Hills subcatchmenl IS llull1h,T J(j:- in center of map,

COA EXhibit TF-8 BMP Modeling Concepts and Simulation SOAH Docket No, 582-08-2186

1)·11 ] TCEQ Docket No 2006-0612-MSW Page 129 of 166

• • •

'.,.. \

Gresham

.,. ". • .. , .-I 1_ - - i . I

.'il!.ure 15_'). Gelleral map of BES raingage network for Johnson CrN:k near Lexington Hills (Lexington Hills is between the Holgate and Pleasant Valley Schoul gages). The large !'iver on rhe !c'lt (Wc',';l) j.; the \VillaJTI~lle. dr'aining to the nOlth,

COA EXhibit TF-8 BMP Modeling Concepts and Simulation SOAH Docket No 582-08-2186

15-1 12 TCEQ Docket No, 2006-0612-MSW Page 130 of 166

• • • Table 15-2. RunotTBlock input for Lexington BiDs Pond 3 simulation (Stouder 2003).

* File control and file linkages not needed with PCSWMM *SW 1 0 9 *MM 9 11 12 13 14 15 16 17 18 19 $ANUM $RUNOFF * Title Lines Al 'Lexington Hills' A2 'BMP Pond 3, April 13, 2000' *========================================================================= * Run Control *========================================================================= * METRIC ISNOW NRGAG INFILM KWALTY IVAP NHR NMN NDAY MONTH IYRSTR IVCHAN B1 0 0 1 1 1 0 0 0 13 4 2000 0 * IPRN1 IPRN2 IPRN3 IRPNGW B2 0 1 0 * WET WET DRY DRY LUNIT LONG B3 900 900 86400 3 365 * PCTZER REGEN B4 0 0 *========================================================================== * ROPT 01 1 *Rainfall for November 26 2000 through November 29 2000 *Entered from PCSWMM Meteorological module. *=============================================================================== * Evaporation Data *=============================================================================== * VAP(l) VAP(2) VAP(3) VAP(4) VAP(5) VAP(6) VAP(7) VAP(8) VAP(9) VAP(10) VAP(ll) VAP(12) * Use default of 0.1 in./day *=============================================================================== * NAMEG NGTO NP GWIDTH GLEN G3 GS1 GS2 G6 DFULL GDEPTH *=============================================================================== * Conduits/Channels *=============================================================================== * None used in this simulation. *=============================================================================== * Subcatchments *===========================================================================~===



• • • Table 15-2 (Continued. Please note wrap-around on HI - H3 and J2 lines.) * JK NAMEW NGTO WIDTH WAREA IMPERV WSLOPE IMPER N PERV N WSTORE1 WSTORE2 SUCT HYDCON IMD HI 1 'KC00372#2 ' 'KC00372' 160 26.98 14 0.06 0.15 0.25 0.03 0.1 9.0 0.4 0.00005 * NMSUB NGWGW ISFPF ISFGF BELEV GRELEV STG BC TW H2 'KC00372#2' 'KC00372' 0 0 0.0 8.5 8 7 9 * Al B1 A2 B2 A3 POR WP Fc HKSAT TH1 H3 0.0014 1. O. 1.0 0.0 .35 0.1 0.15 0.15 0.15 * HCO PCO CET DP DET H4 0.1 5. .5 0 1.0 *================================================================================ * Water Quality *================================================================================

* IMUL JJ 0 * NQS JLAND IROS IROSAD DRY DAY CBVOL DRYBSN RAINIT REFFDD KLNBGN KLNEND J1 4 1 0 0 5.00 3.00 5.00 0 0 0 0 * LNAME METHOD JACGUT DDLIM DDPOW DDFACT CLFREQ AVSWP DSLCL J2 'Residential' 0 1 1.0E04 1.0 1.0 7.0 1.0 0 * PNAME PUNIT NDIM KALC KWASH KACGUT LINKUP QFACT1 QFACT2 QFACT3 QFACT4 QFACT5 WASHPO RCOEF CBFACT CONCRN REFF J3 'TSS' 'mg/L' 0 1 0 1 0 0 0 0 0 0 2.0 0 0 125 0 J3 'Nitrate' 'mg/L' 0 1 0 1 0 0 0 0 0 0 2.0 0 0 0.23 0 J3 'BOD' 'mg/L' 0 1 0 1 0 0 0 0 0 0 2.0 0 0 15 0 *J3 'TotPh' 'ug/L' 1 1 0 1 0 5 1 0.1 0 0 0.8 5 1.0 0 0 J3 TotZn 'ug/L' 1 1 0 1 0 0 0 0 0 0 2.0 0 0 65.8 0 * KTO KFROM F1 J4 2 1 0.02 * TSS Nitrate BOD TZn J5 125 0.23 15 65.8 * NAMEW KL BASINS GQLEN NDIM P(TSS) P (Nit) P(Cu) P(Pb) P(Zn) L1 KC00372#2 1 0 0 0 0 0 0 0 0 *=================================================================================== * Print Control *===================================================================================



• • • Table 15-2 (concluded)

* NPRNT INTERV M1 1 8 * NDET STARTP1 STOPPR1 M2 1 20000412 20000413 * IPRNT M3 KC00372 * MDEEP KDEEP *M4 0 0 *================~==================================== ===============================

*ENDPROGRAM



• The Transport Block was used to simulate the pondsince it has the ability to simulate both storage and first-order decay within the storage. Inflow and loads from Runoff occurred at an upstream "manhole" in Transport. The pond was then simulated as a storage unit, draining to another "manhole" for tracking. Bathymetry measurements were obtained from the construction drawings provided by the BES, which showed detailed contour lines (Figure 15-5). These were used to develop stage-area-volume-outflow data that Transport uses for storage-indication flow routing. However, additional effort was needed to develop the outflow rating·curve, as described below.

Effluent from the pond exits through a 2.5-in. orifice, which is designed to drain to the orifice level in about 24 hrs. When there is more water than can exit through the orifice, water spills over a broadcrested weir located above the orifice (Figure 15-5). A rating curve was developed by summing the theoretical orifice and weir equations,

(15-1 )

•

where Q = outflow (ft3/s), Cd = orifice discharge coefficient, assumed:::: 0.9, Ao = area of orifice = 0.0341 ft2 for a diameter of2.5 in., g = gravitational acceleration = 32.2 ftls

2 ,

h = elevation of water in pond (ft), above pond bottom at elevation:::: 305.0 MSL, ho = elevation of orifice centerline = 306.0 ft, Cw =broad crested weir coefficient (ft°.5/s), assumed:::: 3.3,

Lw = length of weir =4.0 ft, hw = weir crest elevation = 307.7 ft.

Surface areas were p1animetered and interpolated from the Pond 3 geometric p1ans,Figure 15-5, yielding the information in Table 15-3 for input into the Transport Block storage element. It should be noted that the outflow rating curve in the stilling well used by BES for monitoring is useful for hydrograph verification but not for modeling, since the stilling well is downstream of the orifice and weir used in the model (Figure 15-5).

Depth, h, ft

0.00 0.50 1.00 1.25 1.50 2.00 2.70 3.00 3.25

a e - Ii Pond 3 t L ' t IT bl 153 Ra ' tin2 curve deve opment or a eXID21on 0'11s, Area,fr 2124 3152 4180 4350 4844 5510 6350 6850 7200

Volume,fe

Q orifice, cfs

Q weir, cfs

Q total, cfs

0 0 0 0 1319 0 0 0 3152 0 0 0 Orifice sill 4218 0.12 0 0.12 5367 0.17 0 0.17 7956 0.25 0 0.25

12107 0.32 0 0.32 Weir sill 14087 0.35 2.17 2.52 15843 0.37 5.38 5.75

15.3.2 Initial Modeling

Inflows from the five storm events modeled were compared with actual flow volumes recorded during the

• sampling events. This is illustrated by comparing recorded and simulated inflows to rainfall, as shown in Figure 15-10.



• •

• 12000 - ----- ---- -------- ------. --------------.-----------.

• 10000

- --------------.-------_._--~-------------BOOO IIQl II•

~ ...:c :::l 6000 -------.-----~.-------

~ II~

o ~

11 ---= 4000 t----------------

---------~--- ----- ------ --~-------------,2000 II

o 0.1 02 0.3 04 0.5 0.6 0.7 0.8 0.9

Rainfall (in.)

• eco ded data • SWMM simulation

• Figure 15-10. Comparison of recorded and simulated flows vs. rainfall for the five simulated events.

It is clear from Figure 15-10 that recorded inflows to the site vary only slightly with rainfall. This leads to questions about the confidence and reliability of the measured data. SWMM simulations indicate a steady increase of inflow with increased rainfall, which is what is expeded. Because rainfall amounts were exactly the same for the recorded and SWMM data, it was decided that only the closest two events would be used for further modeling These were event I (April 13,2000) and event 4 (October 9-10, 2000).

15.3.3 Quantity Modeling Results

Quantity modeling results are summarized in Table t 5-4_ in which it may be seen that ponel intluent (catchment runoff) and pond efnuent measured and simulated volumes agree well. For the two simulations ot'the pond, estimates of initial volume \vere made on the basis of the delay in the starting time of the outllow hydrographs_

Table 15-4. S\VMM simulated inflows and out11ows versus measured data for Pond 3 at the Lexington Hills BMP site. Storm Date Initial Vol. Measured Simulated Measured Simulated

Estima te, re Inflow, fe Inflow, ft3 Outflow, fe Outflow, ftl

April 13, 2000 2692 8275 8058 8075 7749

October 9-10, 2000 2629 8276 8208 6815 7339 ~

• COA Exhibit TF-8 BrvlP rvlodeling Concepts and Simulation SOAH Docket No_ 582-08-2186

15-1 17 TCEQ Docket No. 2006-0612-MSW Page 135 of 166

• SWMM predicts slightly higher outflow for the October 2000 stonn than was measured. However, the actual measured outflow value was assumed to be low by the BES sampling crew due to clogging of the orifice from debris such as leaves, needles, etc. (Liptan 2001).

15.3.4 Quality Simulations

Modeled constituents were TSS, BOD, N03-N, and total zinc, from a much longer list of samples for which EMC values were available from BES monitoring (Liptan 2001). No attempt was made to calibrate Runoff Block nonpoint source water quality values. Instead, Runoff Block concentrations were set equal to measured BES influent concentrations (pond influent = subcatchment effluent) by setting Runoff Block rainfall and groundwater concentrations to the measured influent EMC values. This was done to avoid a time-consuming calibration process when the point of the study was to simulate the BMP, not the watershed. Results are summarized in Table 15-5.

Table 15-5. Measured and simulated quality results for Lexington Hills Pond 3. Concentrations are EMCs. Loads (lb) are computed as product ofEMC and measured or simulated volumes (Table 15-4). Pond influent is same as catchment effluent

•

TSS, TSS, BOD, BOD, N03-N, N03-N, Tot. Zn, Tot. Zn, I mgIL lb mgIL lb mgIL lb ugIL lb

Event I, April 13, 2000 Influent, measured 125 64.5 15 7.7 0.23 0.119 65.8 0.034 Influent, simulated 125 64.4 15 7.5 0.23 0.118 65.8 0.034 Effluent, measured 35 17.6 8 4.0 0.28 0.141 28.9 0.0146 Effluent, simulated 98.5* 47.6* 15 7.3 0.23 0.111 55.3* 0.027* Event 4, October 9-10,2000 Influent, measured 222 115 5 2.6 0.25 0.128 52.4 0.0271 Influent, simulated 222 114 5 2.6 0.25 0.129 52.4 0.0268 Effluent, measured 114 48.5 6 2.6 0.36 0.153 38.2 0.0162 Effluent, simulated 138* 63.5* 5 2.3 0.25 0.115 35.0* 0.0160*

*See text regarding "decay" used for simulated TSS and total ZInC in pond effluent.

Pond effluent EMCs for TSS and total zinc are less than influent EMCs for both stonns. The pond would not be expected to remove much, if any, nitrate; in fact, measured effluent nitrate values are higher than influent values. The BES (Liptan 2001) offers no explanation for higher effluent nitrate values, but some could be hypothesized, such as nitrification in standing water during interevent times. The quality of any water standing below the orifice at the start of an event was not measured, so there is no way to detennine if the initial pool added mass to the effluent. Influent BOD values are higher than for the effluent for event 1 and about the same for event 2. Although some BOD decay might be expected, the relatively short detention time would not yield much change. Thus, for the simulations, bothEOD and N03-N were treated as conservative constituents, and it may be seen that inflow concentration is the same as outflow concentration in Table 15-4.

The reduction in TSS and total zinc is expected by sedimentation, of the solids themselves and of the adsorbed zinc. The only decay in the Transport Block is by a first-order process (not including the relatively untested July 2001 modifications to Transport that include a settling velocity). Hence, an equivalent first-order decay coefficient was created from a settling velocity by (see also Equation 6-14),

• k = v.lh (15-2)



where• k = decay rate (S·I), v. = settling velocity (ft/s), and h = average depth (ft).

The average depth of outflow was determined to be about 1.2 ft from review of the Transport output files. A particle size distribution is provided by BES for the October 9-10, 2000 and later events (not for the April 13,2000 event). These data are presented in Table 15-6, from which a weighted average diameter can be computed of 25.2 11m, using range midpoints as representative diameters. From this a typical diameter of 25 11m was used in Stokes' law (Equation 6-6).

Table 15-6. Particle size distribution for event of October 9-10, 2000. Counts are in units of particles per 100 mL.

Size range,

um

Range midpoint, um

Influent Number

Effluent Number

Total particles 75100 29000

5-15 10 32400 26800

15-25 20 4500 1600

25-50 37.5 36900 500

50-100 75 1300 100

>100 nJd* nJd*

• *nJd = not detected

For a measured temperature of 15°C, kinematic viscosity, U = 0.0115 cm2/s (Chapra 1997). Using g = 981 cm2/s and a diameter of 25 11m = 0.0025 cm, Equation 6-8 gives a settling velocity of 0.0444 crn/s = 0.00146 ftls = 126 ftlday. Dividing by an aver'age depth of 1.2 ft gives a first-order decay coefficient of 105 day"l. It may easily be recognized even without any simulation that any constituent with such a large coefficient will be completely removed in just an hour or so, e.g., the half-life,

tl/2 = In2 I k = 0.0066 day = 0.16 hr (15-3)

In fact, this value of 105 day·1 is in same order of magnitude as values derived in Table 7-4. But not all of the Pond 3 TSS and total zinc is removed.

Another approach would be to use the SWMM SIT Block with a particle size distribution, but the particle counts would have to be converted to concentrations. Logistical constraints prevented this approach (this work was done too late in the project period). In the interest of expediency, overall removal percentages (Liptan 2001) were used to compute approximate first-order decay coefficients for Pond 3. For the seven monitored events, average TSS removal was 57%, average total zinc removal was 45%, average BOD removal was 6%, and average nitrate removal was -II %. BOD and nitrate were treated as conservative, especially since the model has no physically realistic mechanism for increasing the concentration of a pollutant, other than starting with a higher concentration in the permanent pool (discussed earlier). Assuming TSS and total zinc reduction occurs in t = I day, an equivalent first-order decay coefficient can be computed from

• C/Co = I - removal fraction = e· 1ct (15-4)

yielding a TSS decay coefficient of0.84 day·1 and a total zinc decay coefficient of 0.60 day· I .



•

•

The effluent TSS values predicted by SWMM are above the measured effluent EMCs for both events, although closer for the October event. Simulated total zinc EMCs are higher for the April event and slightly lower for the October event. Refinements could be made, but it would simply amount to a curvefitting exercise. Instead, the kind of results made possible by use of the somewhat maligned removal fraction (Section 4.3) can be imagined. Constituents treated as conservative reflect this fact through equality of influent and effluent EMCs in Table 15-5.

15.4 SUMMARY

It is difficult to obtain good data sets for testing ofBMP simulation, including monitoring of influent and effluent flows and concentrations. The Lexington Hills Pond 3 monitoring conducted by the BES comes close, inasmuch as influent and effluent flows were monitored along with composite quality sampling. However, the flow monitoring itself is somewhat suspicious on the basis of the lack of a relationship of inflow to rainfall (Figure 15-10). A water quality sample from any standing water in the pond would· have been useful, as well as noting the depth of the pond at the start of a storm event. Liptan (200 I) notes a few other monitoring problems, such as issues of orifice clogging and rating curve generation. Nonetheless, the data set has served a valuable function in evaluating SWMM pond simulation capabilities.

Some conclusions follow: • Using SWMM Runoff Block catchment data supplied by the BES, seemingly reasonable simulations

of runoff hydrographs were obtained. However, the influent monitoring appears to give similar total volumes for all events, which is unexplained. Quality simulations were conducted for the two events for which simulated and measured runoff volumes most closely agreed (Figure 15-10).

• SWMM simulation of the pond hydraulics worked well even while using an outflow rating curve based on theoretical equations for the weir and orifice outlets. This is based on the comparison of simulated and measured total outflow volumes (Table 15-4).

• Approximation ofTSS and total zinc losses in a SWMM Transport Block storage unit through an equivalent first-order decay coefficient is crude and serves only to demonstrate that the measured outflow EMCs could be replicated by the model. Better would be to attempt to simulate sedimentation processes in the srr Block using the limited particle size distribution information provided, but time did not permit this approach.

• COA ExhibitTF-8 BM? Modeling Concepts and Simulation SOAH Docket No. 582-08-2186


•

16 RECOMMENDATIONS FOR SWMM BMP MODELING IMPROVEMENTS

16.1 INTRODUCTION

Evaluating the methods for model BMPs by process and type have much overlap. A breakdown of applicable methods for modeling each BMP is given in Table 16-1, followed by recommendations by type. While nearly all BMPs may be described using removal coefficients or with the effluent probability method (EPM), these methods do not model processes, Le., fundamental unit processes of environmental

• engineering. Neither would they predict overloaded or undersized BMPs, or describe failing BMPs. This makes these methods less useful for sizing and design of BMPs. Nonetheless, if the EPM is the best representation of BMP performance for an otherwise hopelessly complicated set of processes, it would be a useful option to include in SWMM. This would be implemented by enhancing the statistical analysis capability, currently in theSWMM Statistics (Stat) Block, to provide comparative lognormal plots of influent and effluent EMCs. In addition, an option for specifying a lognormal (or other distribution) for influent and/or effluent EMCs is heeded.

A somewhat general CFSTR formulation of fundamental source-sink processes that can be used to represent BMP impacts was provided.in Section 4.4, with regard to Equation 4-9, which is repeated here:

(16-1)

where C = constituent concentration, V = volume of conveyance/storage object, t = time,

Qi = inflow to object, Cin = inflow concentration, L = other loadings, e.g., from sediment or precipitation, R = removal fraction due to BMP, Q = outflow from object, k = first-order decay rate,

• vs = settling velocity, F = fraction of constituent in soluble (non-settleable) form, and As = surface area.



• The source-sink terms of this equation can be readily adapted to a one-dimensional advective-dispersion equation, if desired. Of course, the equation is solved immediately after the flow routing equation for the corresponding conveyance/storage object. Flow routing accounts for all inflows and outflows, including ''vertical'' processes of precipitation, ET, and infiltration. For CFSTR routing, these are reflected in the dV/dt term. If Equation 16-1 were used for a particular settling velocity range, it would be well-suited for treatment-train simulation as well, since particles with higher settling velocities would settle sooner, upstream. The settling velocity formulation could easily be enhanced to something other than a constant Vs as well, as in the current SWMM SIT Block.

16.2 PONDS

SWMM currently does a good job of modeling storage devices based on hydraulic controls, including settling and first-order decay. When searching for improvements to SWMM for pond simulation, one remaining (minor) issue is biological treatment based on second-order reactions. The use of second-order rate reactions used in P8 is novel to SWMM, but much less useful without a default set of reaction constants. The effectiveness of macrophytes on pollutant removal might be simulated with the use of a removal factor similar to the particle scale removal factor, f, in P8 (Section 6.2.3).

Although sedimentation in the SWMM SIT Block can be simulated with reasonable sophistication at the moment, input is not phrased in common environmental engineering terms such as overflow rate. Use of terminology that is more consistent with the profession might be helpful to the model user.

• Environmental engineering texts and references often refer to the "tanks in series" model, i.e., a series of N CFSTRs, Equation 6-11, as a useful transition between one extreme of plug flow to the other extreme of complete mixing in a storage device (or chemical "reactor"). This could readily be implemented as an option for treatment in a SWMM5 "object" that includes storage, such as a channel, pipe, or storage unit. However, it will still require user judgment as to whether mixing is "good," "very good," etc., thus retaining the empiricism that seems difficult to avoid (see discussion of Equation 6-11). On the other hand, if tracer data are available, quantitative inferences about the degree of mixing can be made - see discussion in Section 7.8.2 regarding the MUSIC pond algoritruns. The MUSIC implementation of Equation 6-11 provides qualitative guidance as to the number ofCFSTRs that would be a good start for any SWMM implementation.

SWMM is well equipped to deal with detention and extended detention storage from the standpoint of timing issues. The relationship of storage availability and draw-down to local meteorology and catcrunent conditions may be analyzed quantitatively via continuous simulation. The principal enhancements for SWMM would be more useful statistics, e.g., analyze statistics of the time series of volume (or depth), in addition to inflows and outflows from storage. This only requires the ability to create additional time series of model state variables.

The hydrology of most extended detention ponds can be modeled in the same way as for wet ponds. However, a missing hydrologic component for both extended detention and for ponds in SWMM is infiltration and evaporation (at better than monthly averages). The vertical water balance may only be simulated crudely, through the input of "negative rainfall."



• • • Table 16-1. Clarification of method applicability to modelin2 BMPs.

Bioretention Infiltration Grassed Dry Porous Hydrodynamic Simulation Practices Ponds Facilities Trenches Swales Wells Cisterns Pavement Devices

Effluent probability method X X X X Removal coefficient X X X X X Second-order decay X X X Particle scale removal factor X X Tanks (CFSTRs) in series X X Fractional volume reduction* X X X X X Substrate modeling** X X Ecological and nutrient cycling modeling X X

*As implemented in SLAMM, e.g., Equation 8-1. **As implemented in VAFSWM.


16-123 TCEQ Docket No. 2006-0612-MSW Page 141 of166

•

•

•

16.3 WETLANDS AND BIORETENTION FACILITIES

The particle scale removal factor in P8 (usually set to 1) is applied as a calibration parameter for devices. This can be increased to represent better treatment and removal in bio-filtration facilities. Increased removal by macrophytes is documented in the P8 manual wherein the removal factor is set to 2 or 3 based on improved removal rates. But modeling multiple processes can lead to conflicts and difficulties with sequence of treatment. Moreover, the particle scale removal factor is akin to heuristic removal efficiencies and is difficult to represent as a fundamental unit process.

A more conventional alternative within the unit process literature is the tanks-in-series model (Equation 6-11), discussed just above and in Section 6.5 with regard to ponds and Section 7.8 with regard to wetlands. Parameter N, the number of CFSTRs in series, may be estimated somewhat quantitatively from tracer studies (Kadlec and Knight 1996, Persson et al. 1999), or qualitatively on the basis of an estimate of short-circuiting and dead zones (Fair et al. 1968, Pitt and Voorhees 2000, Wong et al. 2001, Minton 2002). Kadlec and Knight's (1996) k' -C* modification of exponential decay used in MUSIC (Section 7.8) is a useful means by which to provide a lower bound (C*) from a CFSTR with first-order decay. The lower bound could also be in the form of a frequency distribution of effluent EMCs.

Certainly wetlands, bioswales, and similar storage areas where there is strong interaction between water quality and biological processes within the area (e.g., vegetation, sediment) are one of the most difficult challenges for BMP simulation. Three models that perform this kind of simulation (WETLAND, PREWET, DMSTA) include complex kinetic formulations and several state variables to represent nutrient cycling. Whether or not this effort is needed or can be supported for SWMM is to be determined. The VAFSWM simplifies the process by simulating only a "substrate" (in addition to the constituent in the water column) consisting of water in sediment and vegetation, and without the linked nutrient kinetics. This concept would be easier to implement in SWMM. A useful enhancement regardless of whether physical and biological process options are updated to better represent wetlands is the ability to link SWMM time series output to other models. For instance, wetland quality processes may be simulated for the most part with the EPA WASP model (Wool et al. 2001), with HSPF being another option (Bicknell et al. 1997). A standard for protocol interfacing is required to facilitate such linkages. That is, SWMM simply may not be the best choice for a "universal treatment model" when it comes to simulation of natural receiving water processes.

16.4 INFILTRATION TRENCHES

One of the biggest needs for SWMM with regard to infiltration trenches and swales (below) is the ability to simulate infiltration from channels as well as for overland flow planes. All conveyance and storage options within the model need to include a full vertical water balance that includes precipitation, ET, and infiltration. Within this framework, SWMM conveyance and storage elements should be able to simulate quality processes characteristic of infiltration devices, bio-swales, etc. Notwithstanding the need to be able to infiltrate from channels, infiltration trenches can be simulated with the current SWMM as small overland flow planes, with the ability to receive runoff from an upstream overland flow plane. Depression storage is used to define the depth of the trench, as described in Section 8.3.

Other models perform this function using highly empirical, though often useful, methods. For instance, the methods described for SLAMM produce a fractional volume reduction based on adjusted watershed runoff coefficients that reflect smaller storms, and adjusted percolation rates that account for soil moisture and compaction. Unfortunately, infiltration rates themselves must be known a priori; however, SLAMM's reference base is helpful in this regard, e.g., for disturbed soils.



• 16.5 GRASS SWALES

Regarding grass swales, filter strips, and similar BMPs that feature flow through vegetation, the same needs for a vertical water balance in conveyance and storage devices just discussed apply here. However, to the extent that flow through swales behaves like a sedimentation device for which performance is a function of hydraulic overflow rate (Minton 2002), swales can be simulated in the current SWMM SIT Block. But a ready means of simulating infiltration from SIT storage is still needed. The simplified infiltration procedures in SLAMM are applicable to grass swales (see infiltration trenches section), but these procedures do not seem to offer many SWMM enhancement opportunities. P8's assumption of adsorption of some dissolved constituents while traveling through swales is an implementation possibility for SWMM, easily simulated through the SIT removal equation.

REMM closely models the N, P, and C cycles in three surface buffer zones (linked to three subsurface layers), which may be applicable to SWMM, although this will require extensive field data to simulate. The most useful information from the REMM model when good documentation becomes available may be the default rate constants used in calculations.

•

The REMM techniques are certainly applicable in vegetated filter strips, but the REMM methods are complex in the same way as the nutrient cycling simulations are complex in the wetlands models. Moreover, REMM includes a linked surface-subsurface hydrologic model for the riparian zone. This quasi-2D model (three horizontal by three vertical zones) is beyond the capability of SWMM at the moment and likely not worth the effort of implementation given SWMM's common stormwater design applications. Nonetheless, similarly to the wetlands models, there is good opportunity for parameter estimation help from REMM publications, and such a model could be used to calibrate simpler techniques that might be added to SWMM.

What the literature review of this study has not yet uncovered - which is not to say that they are not available - are functional relationships between performance and design parameters for filter strips, although this kind of information does exist for swales (Fletcher et al. 2002). For instance, one expects removal to be proportional to flow path length, type of vegetation, type of soil, etc. (Huber et al. 2000). While SWMM can now simulate load removal associated with infiltration, concentrations are not changed through sedimentation or biological processes in the Runoff Block overland flow routines, although they may be changed using a constant settling velocity, first-order decay rate, or removal fraction. When empirical or theoretical relationships are found with causative parameters - e.g., length, vegetation, soil, slope, and maintenance - they should probably be implemented in SWMM.

16.6 DRY WELLS

Modeling dry wells can involve complex analytical techniques for both quantity and quality for simulation of the groundwater flow regime. Under suitable soil circumstances, though, it may be possible to infiltrate the entire design inflow over the approximate storm duration. SWMM is currently capable of accepting flows into a device that represents a dry well but not capable of simulating the complex flow net that results as water enters the soil. This latter effort is probably not necessary to simulate dry wells as BMPs as long as their capacity can be provided as a function of time or other simple relationship (e.g., a rating curve). If current SWMM infiltration routines are used (from subcatchments), a linkage to groundwater routines can be made to follow the pathway of water further, should that be desired.

16.7 CISTERNS

• For cisterns what is needed in SWMM and similar models is an overall water use simulation capability that includes all sources (e.g., cisterns, city water supply) and an irrigation schedule (as in SLAMM) in order to dispose of runoff collected in cisterns. Water stored in cisterns can also be used for gray water



supply in buildings and boiler feed water, both of which might require some on-site treatment. The• irrigation schedule might in turn be linked to a soil moisture accounting model, leading to greater complexity. Otherwise, SWMM is capable now of simulating the storage associated with cisterns - just not the timed release!

16.8 POROUS PAVEMENT

SLAMM models porous pavement with infiltration rates and rainfall events manipulated to focus on the micro-storm effect. SWMM currently can simulate porous pavement by using its Horton or Green-Ampt infiltration equations, and the resulting infiltrated water can be tracked through use of the groundwater routines, except for water quality. James et al. (2001) demonstrate how the current version of SWMM can be used to simulate roadways and parking lots with porous pavement or permeable pavers.

16.9 HYDRODYNAMIC DEVICES

Because of the variability between devices in this category, the effects may best be simulated with , removal equations based on the manufacturer's specifications, or with data from the EPA/ASCE BMP

Database. On the other hand, removal as a function of overflow rate may work just as well. Checks need to be established to determine if devices are overloaded or for maximum treatment values. Extran is capable of simulating the hydraulics of some common devices through proper use of orifice settings in particular, but water quality is not tracked.

16.10 LID AND OTHER RELATED NEEDS

• Almost all BMP design is linked to a description of the influent stormwater. A characterization of solids is especially important, i.e., treatability data on settling velocities and/or particle size and specific gravity distributions. The SWMM SIT Block requires this information to perform sedimentation computations, but this is entered only for the SIT Block and as a constant for the inflowing stormwater or combined sewage. Upstream blocks should supply this time series - a very complicated process since it relates to erosion, scour, deposition, and sediment transport, all of which are poorly represented in SWMM and in most any alternative model. Nevertheless, typical particle size distributions are available from several sources (e.g., Minton 2002) that can be provided as a default, in lieu of site-specific data. Within the rest of SWMM, particle sizes can be tracked by treating a size range as a separate constituent subject to a constant settling velocity. This is not too bad an assumption in the current Runoff and Transport Block routines for which settling in essence can be simulated as a function of residence time, V/Q. Even without improved scour and deposition routines, simply linking the constituents grouped by particle size (or settling velocity) range to the SIT Block would be a huge enhancement to the overall SWMM simulation capability. If SWMM5 can perform this linkage, then it will immediately provide an improved BMP simulation capability.

Several of the models discussed in this report include heuristic parameters (e.g., efficiency ratio, particle scale removal factor). While these parameters do not represent fundamental unit processes and are difficult to evaluate a priori, if they gain favor in the profession, SWMM might include them as options for simulation ofBMPs. The N tanks-in-series model (Equation 6-11) would be relatively easy to implement as a treatment option within any device that incorporates storage, including any conveyance element.

Regarding the suitability of LID simulation, the ability to route flows from one overland flow plane to another is useful (e.g., see Section 4.7) but insufficient. Infiltration and ET simulation are also required for open channels and for ponds and storage devices. The vertical water balance is critical in infiltration

• devices such as swales as well as in wetlands. SWMM currently has only limited capabilities in these areas. Another useful LID simulation procedure would be to provide a way in which stored water could



• be distributed seasonally, as from a cistern. An irrigation schedule would be useful here, and coupling with other components of the urban water cycle (e.g., water supply, wastewater removal) should be provided.

SWMM does not simulate water quality in the subsurface zone, i.e., in the Runoff Block groundwater routines. Examples of models with this capability include HSPF and REMM. This would require a major renovation of model capabilities, but it would be useful for simulatinf all water budget components in an area subject to infiltration. However, alternative models, e.g., HSPF and REMM, already provide this capability.

Another useful addition to SW:MM would be the ability to prescribe a lognonnal (or other) frequency distribution to represent EMCs in surface runoff and/or effluent quality from BMPs, e.g., as characterized by the effluent probability method. The modeling challenge would be in part to ensure conservation of constituent mass if EMCs and hence loads are inserted into the effluent (or nonpoint source runoff) from a prescribed frequency distribution.

Finally, SWMM is unlikely ever to perfonn all the functions that a user might need. Particularly for complex nutrient dynamics and subsurface water quality, alternative models such as WASP, HSPF, REMM or WETLAND should be considered. In order to interface one model with another, standards for time series transfer are needed. Such standards would facilitate many multi-media modeling needs within the environmental community in general and Environmental Protection Agency in particular.

16.11 FINAL SUMMARY OF SWMM BMP SIMULATION NEEDS

• For the convenience of the reader, proposed BMPILID simulation enhancements are summarized in Table 16-2. A summary commentary is provided in Chapter 17. The priority assigned in the table is purely the opinion of the authors of this report. In their opinion, probably the highest priority enhancement should be item 10 of the table: inclusion of the vertical water balance (precipitation, ET, infiltration) for all flow objects, especially channels: This is urgently needed for proper simulation of any porous conveyance or storage, such as bioswales and wetlands.



• Table 16-2. Summary of proposed SWMM BMPILID simulation enhancements. These are listed generally in d fd' "Ch 16 P' , H = h' h M or er 0 ISCUSSlOn In apter nonty: 1l!1 , = medium, L = low.

•

1

2

Simulation proposal Emphasize fundamental unit processes.

I Pwvide for automated evaluation of inflow and outflow EMCs by effluent probability method.

Comment Most flexible regarding "real world" settings. Will facilitate comparisons with published evaluations using this method, often recommended for BMP performance evaluation.

Priority M

M

I

3 Provide for lognormal and other frequency distributions of watershed runoff EMCs and BMP effluent EMCs.

BMP influent and effluent EMCs are often characterized by a lognormal distribution and performance may sometimes best be characterized simply by the effluent distribution, rather than, for example, a removal fraction.

M

4 Provide a generalized source-sink formulation of the type given in Equation 16-1 for conveyance and storage objects.

This formulation provides for first-order decay, settling, and generalized "removal."

H

5 Second-order decay is useful for some constituents.

A significant problem with implementation is lack of data.

L

6 Particle removal scale factors as used in P8 These scale factors amount to a linear L

7

8

I

1

9

can help with calibration.

The "tanks in series" model provides a useful bridge between simulation of conveyance and storage objects as well-mixed (worst performance) and plug flow (best performance). A lower bound on exponential decay through a first-order process in a CFSTR can be provided with the k' -C* model.

Upgrade SWMM statistical analysis options.

increase in settling and first-order decay terms. This effect can also be provided for in other ways. Adapting this formulation, often used in environmental engineering practice and implemented in the MUSIC model, might be one of the most useful enhancements to SWMM. The lower bound, C*, could be specified in a numerical solution. The lower bound could also be in the form of a frequency distribution. Related to item 1, graphical, regression, and other statistical evaluation options would make a model such as SWMM5

I

H

M

H

I

10 The "vertical" water budget must be available for all flow objects, including overland flow on subcatchments,

I conveyance channels, and storage objects. This implies inclusion of precipitation, ET,

i and infiltration for all flow objects.

even more powerful as an analysis tool. Implementation of this vertical water budget is essential for simulation of conveyances such as swales, bioswales, and wetlands. Load reduction associated with infiltration, for instance, cannot be ignored.

H



• Table 16-2. (Continued)

•

II A ready method with which to interface SWMM to other models is urgently needed, including a standard format for time series files.

This will facilitate linkage of SWMM to models better suited to certain kinds of receiving water and subsurface water analysis, such as WASP and WETLAND. SWMM cannot "do everything," and the ability to link SWMM's watershed processes with the receiving water simulation strengths of other models will facilitate use of the right model for the right task.

H

12 Settling velocity ranges should be tracked through the runoff-transport-treatment pathwavs.

This will facilitate proper simulation of "treatment trains."

M

13 Related to item 12, even though stormwater treatability data are relatively uncommon, SWMM should be adapted to use such information when available.

The model must be able to track particle ranges based on settling velocities (or size - specific gravity ranges) throughout the whole model: sources, transport, and treatment.

H

14 Improved mechanisms for simulation of sediment, including scour and deposition, will facilitate item 13.

This is one of the most difficult set of physical processes to simulate in the context of urban hydrology.

M

15 Although dry wells can be simulated as an outflow or storage within SWMM, a link to groundwater routines would provide additional continuity.

Water leaving the surface through dry wells could be tracked similarly to infiltration from subcatchments.

L

16 Storage of water in cisterns can be simulated with the addition of a water distribution (water use) algorithm or input table.

Stored water can be used for irrigation, gray water, boiler feed water, etc. A schedule is needed for such distributions.

L

17 Data and parameters from other models should be adapted for use in SWMM to the extent possible.

Other models reviewed in this report have different ways of conceptualizing processes such as infiltration and porous pavement, but parameter values from such models may be very useful in SWMM simulations. The effect of disturbed soils on infiltration parameters is particularly important.

M

18 Additional information is needed on hydrodynamic devices to determine how well they can be simulated· using fundamental processes. Simpler removal fractions might be used in the meantime.

Proprietary devices are especially difficult to evaluate simply on the basis of manufacturers' information.

M

19 Simulation of subsurface water quality would be useful for continuity of constituent loads as well as flow.

But this can be very difficult, with the need to account for sorption, etc. Linkage to groundwater quality models is another option.

L



•

17 CONCLUSIONS

The EPA Stonn Water Management Model was developed in 1968-71 to simulate combined sewer systems, including evaluation of management strategies. The user community immediately, and logically, applied the model to separate stormwater systems as well as combined sewer systems and eventually into the entire spectrum of urban and non-urban watershed response. All of this was facilitated by EPA support for continuous enhancement and development of the model in the intervening years. The Storage/Treatment Block within the original model included algorithms that allowed it to mimic removal for a few specified pollutants and for an array of CSO controls available at that time; these algorithms were generalized and enhanced to pennit broader simulation of series-parallel arrangements of SIT units beginning with SWMM III (Nix et aI. 1978). In 2004, municipalities and their consultants are increasingly under pressure to implement BMPs for control of both stonnwater quantity and quality. As new information and data are collected about the performance of BMPs, SWMM and similar models must be updated further to reflect this new technology. LID (hydrologic source control) offers yet another opportunity for stormwater management through distributed and localized control options, with emphasis upon infiltration, evapotranspiration, and water reuse. This report evaluates a number of alternatives for simulation of conventional BMP and LID options, with emphasis upon incorporation of fundamental unit processes into the algorithms wherever possible. Several ways in which SWMM can successfully accomplish these simulation goals are summarized below, along with several more areas in which improvements are needed.

When modeling BMPs, the ability of SWMM to redirect flow from impervious areas to pervious (simulating the effects of downspout disconnection) greatly enhances the model's ability to simulate LID. This has been shown in the literature (Lee 2003) and is demonstrated in an extensive case study for Portland (Chapter 14). However, for the model to be able to characterize treatment based on solids settling, improvements in the overall ability ofSWMM to erode, transport, deposit, and scour sediment (i.e., to incorporate scarce treatability data) need to be provided, as well as the ability to simulate infiltration in channels and ponds. The vertical water balance must be computed for all conveyances and storages, not just for overland flow planes.

The Runoff Block is very stable with regard to size of subcatchments that are simulated. SWMM can model very small parcels (and consequently BMPs and LID facilities on an individual lot scale or smaller). An immediate consequence of simulation ofareas on the order of a fraction of an acre is the

• need for a smaller Runoff Block (or SWMM5 subcatchment object) time step (e.g., S 1 minute), compared to the more typical5~minute value routinely employed. For a process model like SWMM, the issue of temporal and spatial variability is largely an issue of data availability and the amount of detail



desired in the simulation run. For long-term (continuous) simulations, aggregated subcatchment • schematizations can work just about as well as highly discretized schematizations, as demonstrated in the Portland case study presented in Chapter 14. However, this advantage becomes less relevant as computer speeds continue to increase. .

Regarding BMP simulation, the SIT Block has the most capabilities for fundamental unit process simulation but is unsophisticated hydraulically and hydrologically. Insertion of fundamental processes into any conveyance or storage "object" in SWMM5 should make the model much more useful, especially if quality routing can be performed when dynamic routing (as in the current Extran) is being used for pipes and channels. The current Transport Block provides simpler but somewhat flexible mechanisms for simulation of storage BMPs, as demonstrated for a Portland detention pond in Chapter 15. The Transport Block also permits simulation of decay, settling, and removal within any conveyance or storage element, as described in Section 4.4. The general form of source-sink terms used in this formulation (Equation 4-9) is suitable for SWMM5 conveyance and storage objects.

'.

When considering the options for modeling BMP performance that can be integrated into SWMM, the most applicable improvements would be infiltration from swales and trenches, storage and reuse in cisterns, storage and infiltration in dry wells, and inclusion of infiltration from porous pavements (although current SWMM infiltration and groundwater routines can be made to simulate porous pavement satisfactorily - Section 12.3). The SLAMM documentation has an extensive review of case studies and many default parameters, which may be useful when modeling these BMPs. P8's use of the particle scale removal factor may be a simple method for calibrating BMPs to actual performance data. The tanks-inseries model from environmental engineering practice appears to supply a similar qualitative parameter in N, the number of CFSTRs. REMM has the potential for useful algorithms and default parameters when modeling nutrient cycling in buffers. However, models such as REMM, WETLAND and DMSTA likely contain more complex nutrient cycling descriptions than need to be supported in SWMM and for which parameter estimates would be even more difficult than they are now. In this case, linkage to "downstream" receiving water models or groundwater models should be considered. Standards for transfer of time series from one model to another will facilitate such linkages and are urgently needed.

Modeling multiple BMPs in a "treatment train" (several BMPs in series) is difficult unless solids removal is represented through fundamental sedimentation processes - and separate solids "ranges" (i.e., characterized by settling velocity or else particle size and specific gravity) are carried from one part of the model to another, e.g., from the current Runoff to the Transport to the SIT Block. Difficulties with using removal rates in series can easily lead to over prediction of removal (if the first BMP removes 90% TSS, it is unlikely that the second BMP in series will remove 90% of the remaining suspended solids). Often, instead, the output may be relatively constant compared to influent concentrations. Some BMPs may increase effluent concentration (such as BOD or nitrate in biological systems) if influent concentrations are low. None of these were considered in the models surveyed in this report. Nor would the current SWMM be able to simulate this effect in other than "work-arounds." One option to handle this effect would be to input a frequency distribution of effluent EMCs.

Another issue is the malfunctioning or maintenance issues associated with BMPs. Reduced removal efficiencies are likely without regular maintenance, and effects of clogging or other reduction in proper performance should be included in any modeling procedure.

The United States Environmental Protection Agency can be proud of the current state of stormwater modeling using SWMM. Of the models surveyed in this study, SWMM has the most extensive and

• versatile capabilities for simulation ofBMPs. Implementation ofSWMM5, the "next generation" version of SWMM, should enhance the model's overall status for use by practitioners in stormwater and wetweather flow management.



••

•

APPENDIX: USING REMM TO PREDICT RIPARIAN BUFFER PERFORMANCE

RIPARIAN ECOSYSTEM MANAGEMENT MODEL (REMM)

This appendix is intended to supplement the information on the Riparian Ecosystem Management Model (REMM) provided in Chapter 9. Source material is taken primarily from USDA-ARS (1999) and Inamdar et al. (1998a,b).

REMM has been developed for natural resource agencies and researchers as a tool that can help quantify the water quality benefits of riparian buffers. REMM simulates: (a) the movement of surface and subsurface water; (b) sediment transport and deposition; (c) transport, sequestration, and cycling of nutrients; and (d) vegetative growth.

When looking at the processes REMM is capable of modeling and applying those processes to all applicable BMPs, the strengths of the REMM model are the ability to deal with movement of subsurface water and fate and transport of nutrients, neither of which are currently available in SWMM. The applicable wet-weather control (WWC) and program suitability are listed in Table A-I.

REMM can be applied to: • Quantify nitrogen and phosphorus trapping in riparian buffer zones and determine buffer width for a

given set of riparian conditions and upland loadings. • Determine buffer effectiveness under increased loads. • Evaluate influence of vegetation type on buffer effectiveness. • Determine impacts of harvesting on buffer effectiveness. • Investigate long term fate of nutrients in riparian zones, sequestration in vegetation, or loss to

atmosphere (denitrification in case ofN) investigate N / P saturation in riparian buffers.


A-132 TCEQ Docket No. 2006-0612-MSW Page 150 of 166

• Table A-I. REMM wet-weather controls projzram suitability.

WWC Option REMM

Source Controls Modeled as reduced input from adjacent lands.

Overland Flow, Swales, Infiltration, Porous p,avement

Useful for grass swales. Infiltration simulated with a modified Green-Ampt equation, vertical unsaturated conductivity with Campbell's equation. Simulates surface and subsurface water, sediment transport and deposition, transport, sequestration and cycling of nutrients. Capable of modeling hydrology budget with losses to seepage, transpiration and interception. Porous pavement is not modeled.

Major Benefits Detailed analysis on nutrient cycling in buffer strips including grass filter strips. Can determine effects of vegetation type on buffer effectiveness.

Major Drawbacks While REMM does model complex nutrient cycling for grass and forested buffers, it is most applicable to rural areas.

BUFFER HYDROLOGY

• The riparian system is characterized in the model as consisting of three zones parallel to the stream and representing increasing levels of management away from the stream. These zones include a narrow, undisturbed forest area adjacent to the stream for protecting the stream bank and aquatic environment, an area with managed woody vegetation for sequestering sediment and nutrients from upland runoff, and a grass strip for dispersal of incoming upland surface runoff and sediment and nutrient deposition.

The soil is characterized in three layers through which vertical and lateral movement of water and associated dissolved nutrients are simulated. Water movement and storage are characterized by processes

, of interception, evapotranspiration, infiltration; vertical drainage, surface runoff, subsurface lateral flow, upward flux from the water table in response to evapotranspiration losses, and return flow. These processes are simulated for each of the three zones. The storage and movement of water between the zones is based on a combination of mass balance and rate controlled approaches.

Each of these processes is simulated on a daily basis and described briefly in the following paragraphs. For a more complete description of the processes and the equations used, the reader is referred to Inamdar et al. (I 999a).

Canopy interception is an exponential function of the canopy storage capacity and the amount of daily rainfall and is simulated using a modified form of the Thomas and Beasley (1986) equation. Potential rates of leaf evaporation and transpiration are both computed using a modified form of the Penman

.Monteith equation (Running and Coughlan 1988). Unsaturated soil hydraulic conductivity is described by Campbell's (1974) equation. Soil evaporation is computed in two stages (Gardner and Hillel 1962).

Infiltration in the model is simulated using a modified form of the Green-Ampt equation (Stone et al. 1994). Surface runoff entering the riparian area is routed downslope using a simplified procedure based on the depth of runoff and flow velocity.

Evapotranspiration flux is determined using the Darcy Buckingham equation as described by Skaggs

• (1978). Actual transpiration loss is limited by the availability of moisture in the soil and competition among the roots of the various plant types present. As the soil dries, water extraction depends on both the root distribution and the rate at which water can move to the roots. The maximum rate of water uptake


A-133 TCEQ Docket No. 2006-Q612-MSW Page 151 of 166

• from a layer is limited by its soil hydraulic conductivity. Vertical unsaturated conductivity is simulated as a function of the soil moisture content using Campbell's equation (Campbell 1974). This allows any excess demand that is not realized by a layer to be transferred to the layer below.

Subsurface lateral movement is assumed to occur when a water table builds up over the restricting soil layer. The lateral movement of the water is simulated using Darcy's equation. In the model, saturated lateral soil conductivity is assumed the same as vertical saturated conductivity. Down-slope subsurface flow between the component zones is driven by the gradient of the water table. The potential hydraulic gradient that determines the subsurface movement from zone 1 to the stream is assumed equal to the smaller of the surface slope of zone 1 and the gradient from the water table elevation from the mid point of zone 1 to the stream thalweg. Stream thalweg is a user-defined input.

Vegetation and associated litter material provide physical barriers to water and sediment transport over the ground surface. Deposition of organic matter by plants provides a substrate supporting important biological transformations of chemicals in the soil. Plants also sequester nutrients such as nitrogen and phosphorus that contribute to water pollution. The zone immediately adjacent to the stream helps to protect the stream bank and aquatic habitat.

The litter layer is important as the locus for the mixing of surface water with the soil surface. This mixing process results in an equilibrium of dissolved and adsorbed chemical concentrations, which determines amounts of chemicals that are subsequently leached, deposited on the ground surface, or carried along in surface runoff. Concentrations of dissolved and adsorbed chemicals are recalculated as water moves through each of the other soil layers.

• Climate parameters required are the following: rainfall amount and duration, solar radiation, maximum and minimum air temperatures, dew point temperatures. If actual measured data are not available the model uses a subroutine, CLIGEN! to generate climate data. The model operates on a daily time step.

EROSION AND SEDIMENT

Erosion and sediment is calculated separately for each of the three riparian zones. The Universal Sojl Loss Equation (USLE) is used to predict erosion for each storm event (Wischrneier and Smith 1978). Parameterization of the USLE for forested area is accomplished using guidelines presented by Dissmeyer and Foster (1984). The method used for sediment routing uses equations developed by Foster et al. (1981) and Lane (1982) and is as applied in the AGNPS model (Young et al. 1989). The effective transport capacity is computed using a modification of the Bagnold stream power equations (Bagnold 1966). A detailed presentation is made in Young et al. (1989).

NUTRIENT DYNAMICS

REMM is also capable of modeling nutrient dynamics. Simulation of the carbon dynamics is based on the Century Model (Parton et al. 1984, Inamdar et al. 1999b). Stoichiometric relationships are assumed among C, N, and P in organic matter. Nand P are released and immobilized in proportion to transformations of C. The decomposition rates of the organic matter pools area calculated according to first-order rate equations modified by temperature, moisture and C:N and C:P ratios (Inamdar et al. 1999b).

Nitrification is calculated with a first-order rate equation modified by temperature, moisture and pH. Rate coefficients are determined following the approach of Reuss and Innis ( 1977) and Godwin and Jones

• (1991) based upon a Michaelis-Menten (Monod) function.


A-134 TCEQ Docket No. 2006-0612-MSW Page 152 of 166

• Phosphorous is simulated using the EIPC model (Jones et al. 1984) with two pools of inorganic P unavailable to plant uptake, and a labile fonn that may be dissolved or adsorbed according to a partitioning coefficient (Williams et al. 1984).

REMM rate constants may be a good source of K values for process modeling. Sources for upland data may be from site monitoring or from the use of an upland model such as GLEAMS (Knisel et al. 1993).

Output from REMM includes predicted sediment yields, depth to groundwater, and predicted C-N-P distribution throughout the system in many fonns. BMP effectiveness may be evaluated on the basis of comparison of incoming and outgoing loads.

RECOMMENDATIONS

The REMM model is only model reviewed that integrates subsurface flow and groundwater interaction when simulating buffers. REMM also closely models the N, P, and C cycles in the three buffer zones, although this requires extensive field data to simulate. The most useful infonnation from the REMM model may be the default rate constants used in these calculations. Its overall structure is likely beyond what is required in SWMM.

•

COA ExhibitTF-8 • BMP Modeling Concepts and Simulation SOAH Docket No. 582-08-2186

A-l35 TCEQ Docket No. 2006-0612-MSW Page 153 of 166

•

REFERENCES

Adams, BJ. and Papa, F. (2000). Urban Stormwater Management Planning with Analytical Probabilistic Models, John Wiley and Sons, NY.

Adderley, V.C. and Mandilag, AM. (2000a). "Detailed Design Modeling for large Scale CSO Facilities Facing our Fears and Simplifying Assumptions," Bureau of Environmental Services, Portland, OR.

• Adderley, V.C. and AM. Mandilag, A.M. (2000b). "Decisions," Water Environment and Technology, pp. 35-44, December.

American Society of Civil Engineers (1996). Hydrology Handbook, Second Edition, ASCE Manuals and Reports on Engineering Practice No. 28, Reston, VA

Altier, L.S., Lowrance, R.R., Williams, R.G., lnamdar, S.P., Bosch, D.D., Sheridan, J.M., Hubbard, K.K. and Thomas, D.L. (Undated). Riparian Ecosystem Management Model (REMM): Documentation. USDA Conservation Research Report, Tifton, GA

Bagnold, R.A (1966). An Approach to the Sediment Transport Problem from General Physics. Prof. Paper 422-J. U.S. Geological Survey. Reston, VA

Balades, J.D., Bourgogne, P. and Gourioux, (1995a). "A Reservoir Structure Pavement for the Urban Storm Drainage of a Supermarket Area of 120.000 m2 in Bordeaux." (in French) International Conference NO VA TECH 95, Lyon, pp. 329- 336.

Balades, J.D., Legret, M. and H. Madiec, H. (1995b). "Porous Pavements as Tools to Control the Pollutant Loads on Urban Streets." (in French) International Conference NOVA TECH 95, Lyon, pp. 345352.

Barrett, M.E., Walsh, P.M., Malina, J.F. and Charbeneau, Jr. R.J. (1997). Performance ofVegetative Controls for Treating Highway RunofJ, University ofTexas, Department of Civil Engineering, Austin, TX.

Bedient, P.B. and Huber, W.C. (2002). Hydrology and Floodplain Analysis, Prentice-Hall, Upper Saddle River, NJ, Third Edition.

eOA Exhibit TF-8 • BMP Modeling Concepts and Simulation SOAH Docket No. 582-08-2186

R-136 TCEQ Docket No. 2006-0612-MSW Page 154 of 166

• Benjamin, J.R. and Cornell, C.A (1970). Probability, Statistics, and Decision for Civil Engineers, McGraw-Hill Book Co., NY.

Benson, M.A (1965). "Spurious Correlation in Hydraulics and Hydrology," PrOc. American Society of Civil Engineers, Journal ofthe Hydraulics Division, 91(HY4):35-42.

Bicknell, B.R., Imhoff, J.C., Kittle, J.L., Jr., Donigian, AS., Jr. and Johanson, R.C. (1997). Hydrologic Simulation Program - Fortran (HSPF): User's Manual for Release 11, USEPA, Office of Research and Development, Athens, GA (Available from: http://water.usgs.gov/softwarelhspf.htm1)

Bosch, D.D., Sheridan, J.M. and Lowrance, R.R. (1996). "Hydraulic Gradients and Flow Rates ofa Shallow Coastal Plain Aquifer in a Forested Riparian Buffer." Trans. ofthe ASAE, 39(3):865-871.

Brown, A (2003). Development ofa BMP Evaluation Methodology for Highway Applications. Master of Science Project Report, Dept. of Civil, Construction, and Environmental Engineering, Oregon State University, Corvallis.

Brown, W. and Schueler, T. (1997). National Pollutant Removal Performance Database for Stormwater BMPs. Center for Watershed Protection. Chesapeake Research Consortium, Ellicott City, MD.

Burke, C.B. (1979). The Comparative Performance ofSeveral Methods for Storm Sewer Design. M.S. thesis, School of Civil Engineering, Purdue University, West Lafayette, IN.

• Burke, C.B. and Burke, T.T. (1994). HERPICC Stormwater Drainage Manual. Highway Extension and Research Project for Indiana Counties and Cities (HERPICC), Purdue Research Foundation, West Lafayette, IN.

Burke, C.B. and Gray, D.D. (1979). A Comparative Application ofSeveral Methods for the Design of Storm Sewers. Purdue University Water Resources Research Center Technical Report No. 118, West Lafayette, IN.

Burton, G.A, Jr. and Pitt, R.E. (2001). Stormwater Effects Handbook: A Toolboxfor Watershed Managers, Scientists, and Engineers. Lewis Publishers, Boca Raton, FL.

CalTrans (2003). Stormwater BMP Handbook-New Development and Redevelopment, Appendix B: General Applicability of Effluent Probability Method. January. Available at http://www.cabmphandbooks.com

Camp, T.R. (1946). "Sedimentation and the Design of Settling Tanks." Trans. Am. Soc. ofCivil Eng., Ill, paper 2285,895-958.

Camp Dresser & McKee Inc. and Larry Walker Associates. (1993). California Storm Water Best Management Practice Handbooks, California State Water Resources Council Board, Alameda CA, March.

Campbell, G.S. (1974). "A Simple Method for Determining Unsaturated Conductivity from Moisture Retention Data," Soil Science, 117:311-314.

• Cannon, L. (2002). Urban BMPs and their Modeling Formulations, Master of Science Project Report, Dept. of Civil, Construction, and Environmental Engineering, Oregon State University, Corvallis, August.



Carollo Engineers, (1999). Sullivan, Stark, and Holladay Basins, Sewer Reliefand Reconstruction • Predesign. Draft Problem Characterization Report, Report to City of Portland, Bureau of Environmental Services, Portland, OR, October.

Carollo Engineers and CH2M Hill (2000). Sanitary Sewer System Condition Assessment for Sanitary Sewer Overflow Elimination Program. Vallejo Sanitation and Flood Control District, Vallejo, CA

Chapra, S.C. (1997). Surface Water-Quality Modeling, McGraw-Hill, NY.

Chen, C. (1975). "Design of Sediment Retention Basins." In: Froc. National Symposium on. Urban Hydrology and Sediment Control. University of Kentucky, Lexington, 28-31 July 1975. Parsons, Brinkerhoff, Quade & Douglas, NY. pp. 285-298.

Chiew, F.H.S., Mudgway, L.B., Duncan H.P. and McMahon, T.A (1997). Urban Stormwater Pollution, Industry Report 97/5, Cooperative Research Centre for Catchment Hydrology, Melbourne, Australia, http://www.catchment.crc.ore.au/index.shtm1 (1997).

Covar, AP. (1976). "Selecting the Proper Reaeration Coefficient for Use in Water Quality Models," Proceedings ofthe Conference on Environmental Modeling and Simulation, W.R. Ott, ed., Cincinnati, OH, EPA-600/9-76-016, Environmental Protection Agency, Washington, DC, July, pp. 340-343.

Debo, T.N. and Reese, AJ. (2003). Municipal Storm Water Management, Lewis Publishers, Boca Raton, FL, Second Edition.

• Dingman, S.L. (2002). Physical Hydrology. Prentice-Hall, Upper Saddle River, NJ, Second Edition.

Diniz, E.V. (1980). Porous Pavement; Phase 1, Design and Operational Criteria, EPA-600/2-80-135. Environmental Protection Agency, Cincinnati, OH, August.

Dissmeyer, G.R. and Foster, G.R. (1984). A Guide for Predicting Sheet and Rill Erosion on Forested Land. United States Department of Agriculture, Forest Service Southern Region, Technical Publication R8-TP 6.

Donigian, A.S., Jr., Huber, W.C. and Barnwell, T.O. Jr. (1995). "Modeling of Nonpoint Source Water Quality in Urban and Non-urban Areas," Chapter 7 in Nonpoint Pollution and Urban Stormwater Management, V. Novotny, ed., Technomic Publishing Co., Inc., Lancaster, PA, ,pp. 293-345.

Dooge, J.C.I. (1973). Linear Theory ofHydrologic Systems, Technical Bulletin No. 1468, Agricultural Research Service, U.S. Department of Agriculture, Washington, D.C.

Dortch, M.S. and Gerald, J.A. (1985). Screening-Level Modelfor Estimating Pollutant Removal by Wetlands. Wetlands Research Program Technical Report WRP-CP-9. U.S. Anny Corps of Engineers, Waterways Experiment Station, Vicksburg, MS.

Driscoll, E.D. (1986a) "Lognormality of Point and Non-Point Source Pollutant Concentrations," in Proc. Stormwater and Water Quality Users Group Meeting, T.O. Barnwell and W.C. Huber, eds., Orlando, FL, EPA/600/9-86/023 (NTIS PB87-117438/AS), Environmental Protection Agency, Athens, GA, September.

• Driscoll, E.D. (1986b). Methodology for Analysis ofDetention Basins for Control ofUrban Runoff Quality, EPA-440/5-97-001, Environmental Protection Agency, Office of Water, Washington, DC.



• Fair, M.F. and Geyer, J.C. (1954). Water Supply and Waste-water Disposal, John Wiley and Sons, NY.

Fair, M.F., Geyer, J.C. and D.A. Okun, D.A (1986). Water and WasteWater Engineering, John Wiley and Sons, NY.

Fan, C-Y., Field, R., Lai, F., Heaney, J.P., Sample, D.l and Wright, L.T. (2000). "Costs of Urban Stonnwater Contro1." Proc. ASCE's 2000 Joint Conference on Water Resources Engineering, Minneapolis, American Society of Civil Engineers, Reston, VA, CD-ROM.

Field, R., Heaney, J.P. and Pitt, R.E., eds. (2000). Innovative Urban Wet-Weather Flow Management Systems, Technomic Publishing Co., Lancaster, PA. (See also Web site: http://www.epa.gov/ednnrmrl/publish/book/main.htm for Adobe Acrobat copy.)

Field, R. and Sullivan, D., eds. (2003). Wet-Weather Flow in the Urban Watershed. Lewis Publishers, Boca Raton, FL.

Field, R., Sullivan, D. and Tafuri, AN. eds. (2004). Management ofCombined Sewer Overflows. Lewis Publishers, Boca Raton, FL.

Fletcher, T.D., Peljo, L., Fielding, J., Wong, T.H.F. and Weber, T. (2002). "The Perfonnance of Vegetated Swales for Urban Stonnwater Pollution Control," In Global Solutions for Urban Drainage, Proc. Ninth International Conference on Urban Drainage, E.W. Strecker and W.C. Huber, eds., Portland, OR, American Society of Civil Engineers, Reston, VA, CD-ROM, September (2002).

• Foster, G.R. (1982). "Modeling the Erosion Process," In: C.T. Haan, H.P. Johnson, and D.L. Brakensiek (ed.). Hydrologic ModelingofSmall Watersheds, ASAE Monograph Number 5, pp. 297-380.

Freeze, R. A and Cherry, J.A (1979). Groundwater. Prentice Hall, Inc, Englewood Cliffs, NJ. (1979).

Gardner, W.R. and Hillel, D.I. (1962). "The Relation of External Evaporative Conditions to the Drying of Soils," J. Geophysical Research, 67:4319-4325.

GeoSyntec Consultants, Urban Drainage and Flood Control District, and Urban Water Resources Research Council ofASCE (2002). Urban Stormwater BMP Performance Monitoring. A Guidance Manualfor Meeting the NationalStormwater BMP Database Requirements. EPA-821-B-02-021 (CDROM), Environmental Protection Agency, Washington, DC, April, or at: http://www.bmpdatabase.org/docs/Utban%20Stonnwater%20BMP%20Perfonnance%20Monitoring.pdf.

Godwin, D.C. and Jones, C.A (1991). "Nitrogen Dynamics in Soil-plant Systems." In: J. Hanks and J.T. Ritchie (ed.) Modeling Plant and Soil Systems. Agronomy Monograph no. 31. ASA-CSSA-SSSA, Madison, WI.

Heaney, lP., Huber, W.C., Medina, M.A, Jr., Murphy, M.P., Nix, S.J. and Hasan, S.M. (1977). Nationwide Evaluation ofCombined Sewer Overflows and Urban Stormwater Discharges, Volume II: Cost Assessment and Impacts. EP2-600/2-77-064b. NTIS PB-266005, Environmental Protection Agency. Cincinnati, OH. March.

Heaney, lP. and Lee, lG. (2006). Optimization ofUrban Sewer Systems during Wet Weather Periods,

• Final Report to Environmental Protection Agency, Contract No. 68-C-01-020, Dept. of Civil, Environmental, and Architectural Engineering, University of Colorado, Boulder.



• Heaney, J.P., Sample, DJ. and Wright, L.T. (1999a). Costs of Urban Stormwater Systems. Final Report to USEPA, National Risk Management Research Laboratory, Cincinnati, OH.

Heaney, lP., Sample, D.l and Wright, L.T. (1999b). Geographical Information Systems, Decision Support Systems, and Urban Stormwater Management. Final Report to USEPA, National Risk Management Research Laboratory, Cincinnati, OH.

Heaney, lP., Sample, DJ. and Wright, L.T. (1999c). "Integration of GIS and Optimization for Evaluating Urban Storm Water Quality Options," Proc. ASCE Conference on Water Resources Planning and Management, Tempe, AZ, American Society of Civil Engineers, Reston, VA, June.

Heaney, J.P., Sample, DJ. and Wright, L.T. (1999d). "Robust Optimization of Urban Stormwater Systems," In Proc. 8th International Conference on Urban Storm Drainage Joliffe, I. and lE. Ball, Eds., Sydney, Australia, Institution of Engineers, Canberra, Volume 4, pp. 1896-1903, August.

Heaney, J.P., Wright, L.T. and Sample, D.l (199ge). Innovative Methodsfor Optimization ofUrban Stormwater Systems. Final Report to US EPA, National Risk Management Research Laboratory, Cincinnati, OH. .

Helsel, D.R. and Hirsch, R.M. (1992). Statistical Methods in Water Resources, Elsevier, Studies in Environmental Science 49, NY.

• Hoffman, E.J. (1985). "Urban Runoff Pollutant Inputs to Narragansett Bay: Comparison to Point Sources." EPA-440/5-85-00l, Environmental Protection Agency, pp. 159-164.

Hoffman, J. and Crawford, D. (2000). "Using Comprehensive Mapping and Database Management to Improve Urban Flooding Modeling," Bureau of Environmental Services, City of Portland, OR.

Hogland, W., Niemczynowicz, J. and Wahlmail, T. (1987). "The Unit Superstructure during the Construction Period." The Science ofthe Total Environment, 59:411-424.

Homer, R. (1995). Constructed Wetlands for Urban RunoffWater Quality Control. Dept. of Civil Engineering, University of Washington, Seattle, WA.

Huber, W.C., (1996). "BMP Simulation Using the EPA Storm Water Management Model (SWMM). "Proc. Seventh International Conference on Urban Storage Drainage, University of Hannover, Hannover, Germany, September, Vol. III, pp. 1629-1633.

Huber, W.C. (2001a). "New Options for Overland Flow Routing in SWMM," Urban Drainage Modeling, R.W. Brashear and C. Maksimovic, eds., Proc. of the Specialty Symposium of the World Water and Environmental Resources Conference, ASCE, Environmental and Water Resources Institute, Orlando, FL, May, pp. 22-29.

Huber, W.C. (200lb). "Wet-weatherTreatment Process Simulation Using SWMM," Proc. Third International Conference on Watershed Management. National Taiwan University, Taipei, Taiwan, pp. 253-264.

Huber, W.C., Borst, M. and Koustas, R.M. (2000). "SWMM Modeling in the New Century," Proc. Joint

• Conference on Water Resources Engineering and Planning and Management, Minneapolis, MN, American Society of Civil Engineers, Reston, VA, CD-ROM; July.

GOA Exhibit TF-8 BMP Modeling Concepts and Simulation SOAH Docket No. 582-08-2186


• Huber, W.C. and Cannon, L. (2002). "Modeling Non-Directly Connected Impervious Areas in Dense Neighborhoods," In Global Solutions for Urban Drainage, Proc. Ninth International Conference on Urban Drainage, E.W. Strecker and W.C. Huber, eds., Portland, OR, American Society of Civil Engineers, Reston, VA, CD-ROM, September.

Huber, W.C. and Dickinson, R.E. (1988). Storm Water Management Model Version 4, User's Manual, EPN600/3-88/00Ia (NTIS PB88-236641/AS), Environmental Protection Agency, Athens, GA.

Huber, W.C., Driscoll, E.D. and Ink, P.L. (1987). "Use of Monitored Water Quality Frequency Characteristics for SWMM Quality Calibration," in Urban Storm Water Quality, Planning and Management, W. Gujer and V. Krejci, eds., Proc. Fourth International Conference on Urban Storm Drainage, Lausanne, Switzerland, September, pp. 208-213.

Huber, W.C., Heaney, J.P., Aggidis, D.A., Dickinson, R.E., Smolenyak, K.J. and Wallace, R.W. (1982). Urban Rainfall-Runoff-Quality Data Base, EPA-600/2-81-238 (NTIS PB82-221 094), Environmental Protection Agency, Cincinnati, OH, July.

Hurdle, J. (2001). Improving the Modeling ofSediment Transport in Sewers in SWMM: A Feasibility Study, Master of Science Project Report, Department of Civil, Construction, and Environmental Engineering, Oregon State University, Corvallis.

Inamdar, S.P., Altier, L.S., Lowrance, R.R., Williams, R.G. and Hubbard, R. (1998a). "The Riparian

• Ecosystem Management Model: Nutrient Dynamics." Proceedings ofthe First Federal Interagency Hydrologic Modeling Conference, Las Vegas, NY, April, pp. 1.73-1.80.

Inamdar, S.P., Sheridan, J.M., Williams, R.G., Bosch, D.D., Lowrance, RR., Altier L.S. and Thomas, D.L. (1998b). "The Riparian Ecosystem Management Model: Evaluation of the Hydrology Component." Proceedings ofthe First Federal Interagency Hydrologic Modeling Conference, Las Vegas, NY, April, pp. 7.17-7.24. .

Inamdar, S.P., Sheridan, J.M., Williams, R.G., Bosch, D.D., Lowrance, R.R., Altier, L.S. and Thomas, D.L. (1999a). "The Riparian Ecosystem Management Model (REMM): I. Testing of the Hydrologic Component for a Coastal Plain Riparian System." Transactions ASAE, 42(6):1679-1689.

Inamdar, S.P., Sheridan, J.M., Williams, R.G., Bosch, D.D., Lowrance, RR, Altier, L.S. and Thomas, D.L. (1999b). "The Riparian Ecosystem Management Model (REMM): II. Testing of the Water Quality and Nutrient Cycling Component for a Coastal Plain Riparian System." Transactions ASAE, 42(6): 16911707.

James, W, Huber, W.C., Pitt, R.E., Dickinson, R.E. and James, W.R.C. (2002a). Hydrology. A Guide to the rain, Temperature, Runoff, Combine and Statistics Modules ofthe USEPA SWMM4, Water Systems Models [I], Computational Hydraulics International, Guelph, ON, Version 2.4, October.

James, W, Huber, W.C., Pitt, R.E., Dickinson, RE., Roesner, L.A., Aldrich, J.A. and James, W.R.C. (2002b). Hydraulics. User's Guide to SWMM4 Transport, Extran, and Storage Modules and to PCSWMM4, Water Systems Models [2], Computational Hydraulics International, Guelph, ON, Version 2.4, October.

• James, W.R.C., James, W: and van Langsdorff, H. (2001). "Stormwater Management Model for Environmental Design of Permeable Pavement," Chapter 26 in Models and Applications to Urban Water



• Systems, Proc. Conference on Stonnwater and Urban Water Systems Modeling, W. James, ed., Computational Hydraulics International, Guelph, Ontario, pp. 423-445.

Jones, c.A., Cole, C.B., Sharpley, A.N. and Williams, J.R. (1984). "A Simplified Soil and Plant Phosphorous Model: 1. Documentation." J. Soil Science Society ofAmerica, 48:800-805.

Kadlec, R.H. and Knight, R.L. (1996). Treatment Wetlands, Lewis Publishers, Boca Raton, FL.

Keblin, M., M. Barrett, J.F. Malina, and RJ. Charbeneau, (1997). The Effectiveness ofPermanent Highway RunoffControls: Sedimentation/Filtration Systems, Center for Research in Water Resources, Bureau of Engineering Research, University of Texas at Austin.

Knisel, W.G., Leonard, R.A. and Davis, F.M. (1993). "Nutrient Component Documentation," In: W.G. Knisel (ed.) GLEAMS (Groundwater Loading Effects on Agricultural Management Systems) Model Documentation, Version 2.10, UGA-CPESBAED Publication #5, University of Georgia, Tifton, GA.

Lane, L.J., (1982). "Development of a Procedure to Estimate Runoff and Sediment Transport in Ephemeral Streams," In Recent Developments in the Explanation and Prediction ofErosion and Sediment Yield. Pub. No. 137. International Association for Hydrological Science, Wallingford, England, pp. 275282.

• Lawrence, 1., (1986). "Source and Fate of Urban Runoff Constituents and Their Management," Proc. of 12lh Symposium on Stormwater Quality in Urban Areas, Water Research Foundation of Australia, University ofWoollongong, New South Wales, Australia, July.

Lee, E.R., Mostaghimi, S. and Wynn, T.M. (2002). "A Model to Enhance Wetland Design and Optimize Nonpoint Source Pollution Control," Journal ofAmerican Water Resources Association, 38(1): 17-32, February.

Lee, J.G., (2003). Process Analysis and Optimization ofDistributed Urban Stormwater Management Strategies, Ph.D. Thesis, Department of Civil, Environmental and Architectural Engineering, University of Colorado, Boulder.

Levenspiel, 0., (1972). Chemical Reaction Engineering, John Wiley and Sons, NY, Second Edition.

Lin, YC. and Medina, M.A., Jr. (2003). "Incorporating Transient Storage in Conjunctive Stream-Aquifer Modeling." Advances in Water Resources, 26(9):1001-1019.

Lindsay, W.L. (1979). Chemical Equilibria in Soils. John Wiley and Sons. NY.

Linsley, R.K. and Franzini, J.B. (1964). Water Resources Engineering, McGraw-Hill Book Co., NY.

Liptan, T. (2001). Storm Summary Report, Lexington Hills BMP Monitoring, Bureau of Environmental Services, City ofPortland, OR.

Lowrance, R.R., Altier, L.S., Williams, R.G., Inamdar, S.P., Sheridan, J.M., Bosch, D.D., Hubbard, R.K. and Thomas, D.L. (2000). "REMM: The Riparian Ecosystem Management Model." J. Soil and Water Conservation. 55(1):27-34. .

• Magette,W.L., Brinsfield, RB., Palmer, R.E. and Wood, J.D. (1989). "Nutrient and Sediment Removal by Vegetated Filter Strips," Transactions ofthe ASAE, Volume 32, No.2, pp. 663-667.



• Malmquist, P. (1978). "Atmospheric Fallout and Street Cleaning - Effects on Urban Stream Water and Snow," Prog. Wat Tech., 10(5/6): 495-505. Pergamon Press, Great Britain, September.

McCuen, R.H. (1982). A Guide to Hydrologic Analysis Using SCS Methods, Prentice-Hall Inc., Englewood Cliffs, NJ.

Medina, M.A, Huber, W.C. and Heaney, J.P. (1981). "Modeling Storrnwater Storage/Treatment Transients: Theory," Journal ofEnvironmental Engineering Division. Proc. ASCE, 107(EE4): 781-797.

Metcalf and Eddy, Inc. (2003). Wastewater Engineering. Fourth Edition, McGraw-Hill, NY.

Mills, W.B., Porcella, D.B., Ungs, M.1., Gherini, S.A., Summers, K.V., Mok, L., Rupp, G.L., Bowie, G.L. and Haith, D.A. (1985). Water Quality Assessment: A Screening Procedure for Toxic and Conventional Pollutants in Surface and Ground Water (Revised 1985), Parts 1 and 2, EPN600/6-85/002a (NTIS PB86122496) and EPN600/6-85/002b (NTIS PB86-122504), Environmental Protection Agency, Athens, GA, September.

Minton G.R. (2002). Stormwater Treatment; Biological, Chemical and Engineering Principles, Resource Planning Associates, Seattle, WA.

Musgrave, G.W. (1955). "How Much of the Rain Enters the Soil?" In: Water, U.S. Dep. Ag. Yearbook. Washington, DC, pp.155-159.

• Nix, S.1. (1994). Urban Stormwater Modeling and Simulation, Lewis Publishers, Boca Raton, FL.

Nix, S.1., Heaney, J.P. and Huber, W.C. (1978). "Revised SWMM Storage/Treatment Block," Proc., Storm Water Management Model Users Group Meeting, Annapolis, Maryland, H.C. Torno, ed., EPA-600/9-79-003 (NTIS PB-290742/6BE), Environmental Protection Agency, Washington, DC, November, pp. 1-27.

O'Connor, D.J. (1983). "Wind Effects on Gas-Liquid Transfer Coefficients," J. Environmental Engineering, 109(3):731-752.

Parton, W.J., Stewart, J.W.B. and Cole, C.V. (1988). "Dynamics ofC, N, P and S in Grassland Soils: A Model," Biogeochemistry 5: 109-131.

Persson, J., Sommes, N.L.G. and Wong, T.H.F. (1999). "Hydraulics Efficiency of Constructed Wetlands and Ponds" Water Science and Technology, 40(3):291-300.

Phillips, B.C. and Goyen, AG. (1987). "Guidelines for Improving Urban Storrnwater Quality Using Control Structures," Proc. Seminar on Urban Run.ofJWater Quality, Institution of Engineers Australia, AW.W.A Sydney, July 12.

Pitt, R.E. (1986). "The Incorporation of Urban Runoff Controls in the Wisconsin Priority Watershed Program." In: Advanced Topics in Urban RunofJResearch, (Edited by B. Urbonas and L.A. Roesner). Engineering Foundation and ASCE, NY. pp. 290-313.

• Pitt, R.E. (1987). Small Storm Flow and Particulate WashofJContributions to Outfall Discharges. Ph.D. dissertation, Department of Civil and Environmental Engineering, the University of Wisconsin - Madison, November.



• Pitt, R.E., Clark, S., Panner, K. and Field, R. (1996). Groundwater Contaminationfrom Stormwater. Ann Arbor Press, Inc. Chelsea, MI.

Pitt, R.E., Lantrip, l, Harrison, R., Henry, C.L. and Xue, D. (1999a). Infiltration Through Disturbed Urban Soils and Compost-Amended Soil Effects on RunoffQuality and Quantity, EPA/600/R-00I016, Environmental Protection Agency, Cincinnati, OH.

Pitt, R.E. and McLean, J. (1986). Toronto Area Watershed Management Strategy Study - Humber River Pilot Watershed Project. Ontario Ministry of the Environment, Toronto, Ontario, June.

Pitt, R.E., Lilburn, M., Nix, SJ., Durrans, S.R., Burian, Voorhees, l and Martinson, l (1999b). The Source Loading and Management Model (SLAMM) Guidance Manual for Integrated Wet Weather Flow (WWF) Collection and Treatment Systemsfor Newly Urbanized Areas (New WWF Systems). U.S. Environmental Protection Agency, Edison, NJ, December.

Pitt, R.E. and Voorhees, J. (2000). The Source Loading and Management Model (SLAMM), A Water Quality Management Planning Model for Urban Stormwater Runoff. University of Alabama, Department of Civil and Environmental Engineering, Tuscaloosa, AL.

Pratt, C.l, Mantle, J.D.G. and Schoffield, P.A. (1989). "Urban Stonnwater Reduction and Quality Improvement through the Use of Permeable Pavements." Urban Discharges and Receiving Water Quality Impacts. Pergamon Press, Oxford, 1989, pp. 123-132.

• Pratt, C.l, Mantle, J.D.G. and Schoffield, P.A. (1995). "UK Research into the Performance ofPenneable Pavement, Reservoir Structures in Controlling Stonnwater Discharge Quantity and Quality," International Conference NOVA TECH 95, Lyon, pp. 337-344.

Prince George's County (2000). Low-Impact J)evelopment Design Manual. Dept. of Environmental Resources, Prince George's County, Laurel, MD.

Rathbun, R.E. (1977). "Reaeration Coefficients of Streams - State-of-the-Art," J. Hydraulics Division, Proc. ASCE, 103(HY4):409-424.

Rawls, W.J., Brakensiek, D.L. and Miller, N. (1983). "Green- Ampt Infiltration Parameters from Soils Data," Journal ofHydraulic Engineering, 109(1):62-70.

Reuss, J.O. and Innis, G.S. (1977). "A Grassland Nitrogen Flow Simulation Model." Ecology. 58:379388.

Roesner, L.A., Aldrich, J.A. and Dickinson, R.E. (1988). Stormwater Management Model User's Manual. Version 4: Extran Addendum. EPA/600/3-88/ll0b (NTIS PB88-236658), Environmental Protection Agency, Athens, GA.

Running, S.W. and Coughlan, lC. (1988). "A General Model of Forest Ecosystem Processes for Regional Applications I. Hydrologic Balance, Canopy Gas Exchange and Primary Production Processes." Ecol. Model. 42:125-154.

• Sample, D.J., Heaney, J.P., Wright, L.T. and Koustas, R.M. (2001). "Geographical Infonnation Systems, Decision Support Systems, and Urban Stormwater Management" Journal ofWater Resources Planning and Management, 127(3):155-161.



Schnoor, J.L., Sato, C., McKechnie, D. and Sahoo, D. (1987). Processes, Coefficients. and Modelsfor Simulating Toxic Organics and Heavy Metals in Surface Waters, EPA/600/3-87/0l5, Environmental Protection Agency, Athens, GA, June.

Schueler, T.R (1987). Controlling Urban RunofJ: A Practical Manualfor Planning and Designing Urban BMPs, Metro Washington DC Council ofGovemments, July (1987).

Shaheen, D.G., Contributions ofUrban Roadway Usage to Water Pollution. 600/2-75-004. U.S. Environmental Protection Agency, Washington, DC, April.

Shaver, H.E. (1986). "Infiltration as a Stonnwater Management Component," Urban RunofJQuality Impact and Enhancement Technology, B. Urbonas and L. Roesner, eds., American Society of Civil Engineers, NY.

Singh, V.P., ed. (1995). Computer Models of Watershed Hydrology, Water-Resources Publications, Highlands Ranch, CO.

Skaggs, RW. (1978). A Water Management Modelfor Shallow Water Table Soils. WRRI, Report no. 134, University of North Carolina, Durham.

Soil Conservations Service (SCS,nowNRCS, Natural Resources Conservation Service) (1986). Urban

• Hydrologyfor Small Watersheds. U.S. Dept. of Agriculture Tech. Release No. 55 (revised), June. Available at: http://www.wcc.nrcs.usda.gov/hydro/hydro-tools-models-tr55.html.

Sonnen, M.B. (1977). "Subroutine for Settling Velocity of Spheres," Journal oftheHydraulics Division, ASCE,103(HY9):1097-ll01.

Stone, U., Hawkins, R.H. and Shirley, E.D. (f994). "An Approximate Fonn of the Green Ampt Infiltration Equation," J. Irrigation and Drainage, 120(1):128-137.

Stouder, M. (2003). Simulation Methodsfor Wetland/Pond BMPs, Master of Science Project Report, Dept. of Civil, Construction, and Environmental Engineering, Oregon State University, Corvallis, June.

Strecker, E.W. (2001). "Low~Impact Development (LID): Is It Really Low or Just Lower?" In Linking Stormwater BMP Designs and Performance to Receiving Water Impact Mitigation, Proc. Engineering Foundation Conference, B.R. Urbonas, ed., American Society of Civil Engineers, Reston, VA, pp. 210222.

Strecker, E.W., Kersnar, J.M., Driscoll, E.D. and Homer, RR. (1992). The Use ofWetlands for Controlling Storm Water Polllition. The Terrene Institute, Alexandria, VA.

Strecker, E.W., Quigley,M.M., Urbonas, B.R., Jones, J.E. and Clary, J.K. (2001). "Detennining Urban Stonn Water BMP Effectiveness," Journal ofWater Resources Planning and Management, 127(3): 144149.

Tchobanoglous, G., and Schroeder, E.D. (1985). Water Quality, Addison-Wesley Publishing Co. Inc. Englewood Cliffs, NJ. .

• Terstriep, M.L. and Stall, J.B. (1974). The Illinois Urban Drainage Area Simulator, ILLUDAS, Bulletin 58, Illinois State Water Survey, Urbana, IL.



• Thackston, E.L., Shields, F.D., Jr. and Schroeder, P.R. (1987). "Residence Time Distributions of Shallow Basins," Journal ofEnvironmental Engineering, 113(6): 1319-1332, December.

Thomann, R.V. and Mueller, J.A. (1987). Principles ofSurface Water Quality Modeling and Control, Harper and Row, NY.

Thomas, D.L., and Beasley, D.B. (1986). "A Physically-based Forest Hydrology Model I: Development and Sensitivity of Components." Trans. ofthe ASAE, 29:962-972.

Thompson, M.K. and James, W. (1995). "Provision of Parking Lot Pavements for Surface Water Pollution Control Studies." Modern Methods for Modeling the Management ofStormwater Impacts. Edited by W. James. Computational Hydraulics International, Guelph, Ontario. pp. 381 - 398.

Trepel, M., Dall'O', M., Dal Cin, L., de Wit, M., Opitz, S., Palmeri, L., Persson, J., Pieterse, N.M., Timmermann, T., Bendoricchio, G., Kluge, W. and J0rgensen, S.E. (2000). "Models for Wetland Planning, Design and Management." EcoSys 8:93-137. Available at: http://www.ecology.unikie1.de/-michaeVwetimod.pdf.

Urbonas, B.R and Stahre, P. (1993). Stormwater: Best Management Practices and Detentionfor Water Quality, Drainage, and CSO Management, Prentice Hall, Englewood Cliffs, NJ.

USDA-ARS-Southeast Watershed Research Laboratory (1999). Riparian Ecosystem Management Mode/,

• U.S. Department of Agriculture, Agricultural Research Service; Tifton, GA, http://www.cpes.peachnet.edu/remmwww/remm/remmoldwww/default.htm

U.S. Environmental Protection Agency (EPA) (1983). Final Reportfor the Nationwide Urban Runoff Program. Water Planning Division, Washington, DC, December.

U.S. Environmental Protection Agency, National Risk Management Research Laboratory (EPA NRMRL). (1996). Wet-Weather Flow Research Plan, Edison, NJ, http://www.epa.gov/ednnrmrl/repository/wwfplan/wwtplan.pdf.

Van Buren, M.A., Watt, W.E. and Marsalek, J. (1997). "Application of the Log-Normal and Normal Distribution to Stormwater Quality Parameters," Water Research, 31 (1 ):95-1 04, (1997).

Vogel, R.M. (1986). "The Probability Plot Correlation Coefficient Test for the Normal, Lognormal, and Gumbel Distributional Hypotheses," Water Resources Research, 22(4):587-590, April.

Walker, W.W., (1985). "Empirical Methods for Predicting Eutrophication in Impoundments Report 3. USAE Waterways Experiment Station, Vicksburg, MS, March.

Walker, W.W. (1990). P8 Urban Catchment model Program Documentation Version 1.1, Prepared for IEP, Inc. and Narragansett Bay Project, October. (http://wwwalker.netlp8/)

Walker, W.W. (1995). "Design Basis for Everglades Stormwater Treatment Areas." Water Resources Bulletin, 31(4):671-685, August.

Walker, W.W. and Kadlec, R.H. (2002). Dynamic Modelfor Stormwaier Treatment Areas, Sponsored by

• U.S. Department of the Interior. (http://wwwalker.netldmsta/).



• Wanielista, M.P., Kersten, R. and Eaglin, R. (1983). Water Quantity and Quality Control. Ann Arbor Press, Ann Arbor, MI.

Water Environment Federation and American Society of Civil Engineers (1998). Urban RunoffQuality Management, WEF Manual of Practice No. 23, ASCE Manual and Report on Engineering Practice No. 87, Water Environmental Federation, Alexandria, VA.

Wayne County, Michigan (1998). User's Manual: Watershed Management Model Version 4.0, Rouge River National Wet Weather Demonstration Project, Technical Memorandum RPO-NPS-TM27.01, Detroit, MI, September.

Williams, J.R., Jones, C.A. and Dyke, P.T. (1984). "A Modeling Approach to Determining the Relationship Between Erosion and Soil Productivity," Trans. ASAE, 27:129-144.

Williams, J.R., Ouyang, Y, Chen, J-S. and Ravi, V. (1998). Estimation ofInfiltration Rate in the Vadose Zone, Volume II: Application ofSelected Mathematical Models, EPAl600/R-97/128b, Environmental Protection Agency, National Risk Management Research Laboratory, Ada, OK. Available at: http://www.epa.gov/adalcsmos/ninflmod.html.

Wischmeier, W.H. and Smith, D.D. (1978). Predicting Rainfall Erosion Losses-A Guide to Conservation Planning. USDA Agriculture Handbook No. 537, Washington, DC.

• Wong, T.H.F. and Breen, P.F. (2002). "Recent Advances in Australian Practice on the Use of Constructed Wetlands for Stormwater Treatment," In Global Solutions for Urban Drainage, Proc. Ninth International Conference on Urban Drainage, E.W. Strecker and W.C. Huber, eds., Portland, OR, American Society of Civil Engineers, Reston, VA, CD-ROM, September.

Wong, T.H.F., Duncan, H.P., Fletcher, T.D. and Jenkins, G.A. (2001). "A Unified Approach to Modelling Urban Stormwater Treatment," Proc. 2nd South Pacific Stormwater Conference, Auckland, New Zealand, pp. 319-327, June.

Wong, T.H.F., Fletcher, T.D., Duncan, J.P., Coleman, J. and Jenkins, G.A. (2002). "A Model for Urban Stormwater Improvement Conceptualisation," In Global Solutions for Urban Drainage, Proc. Ninth International Conference on Urban Drainage, E.W. Strecker and W.C. Huber, eds., Portland, OR, American Society of Civil Engineers, Reston, VA, CD-ROM, September.

Wool, T.A., Ambrose, R.B., Martin, J.L. and Comer, E.A. (2001). Water Quality Analysis Simulation Program (WASP), Version 6.0 Draft User's Manual. Environmental Protection Agency, Environmental Research Laboratory, Athens, GA.

Wright, L.T., Dent, S., Mosley, C., Kadota, P. and Djebbar, Y. (2001 a). "Comparing Rainfall Dependent Inflow and Infiltration Simulation Methods," Chapter 16 in Models and Applications to Urban Water Systems, Proc. of User's Group Conference, W. James ed., Monograph 9, Computational Hydraulics International, Guelph, Ontario, pp. 235-258.

Wright, L.T, Heaney, J.P., Dent, S. and Mosley, C. (2001b). "Optimization of upstream and downstream controls for sanitary sewer overflows," In Urban Drainage Modeling, Proc. of the Specialty Symposium of the World Water and Environmental Resources Congress, R.W. Brashear and C. Maksimovic, eds.,

• Orlando, FL, American Society of Civil Engineers, Reston, VA, pp. 156-164.



• Wright, L.T., Heaney, J.P. and Weinstein, N. (2000). "Micro-scale Modeling and Monitoring of Low Impact Development Management Strategies for Wet weather Flow ControL" ASCE 2000 Joint Conference on Water Resources Engineering and Water Resources Planning and Management-Building Partnerships, Minneapolis, MN, American Society ofCivil Engineers, Reston, VA, CD-ROM, 11 pp.

Yang, C.T. (1996). Sediment Transport Theory and Practice. McGraw-Hill Series in Water Resources and Environmental Engineering, NY.

Young, R.A., Onstad, D.D., Bosch, D.D. and Anderson, W.P. (1989). "AGNPS, Agricultural Non-PointSource Pollution Model: A Watershed Analysis Tool." J. Soil and Water Conservation. 44: 168-173.

Yu, S.L., Fitch, G.M. and Earles, T.A. (1998). Constructed Wetlands for Stormwater Management, VTRC 98-R35, Virginia Transportation Research Council, Charlottesville, VA. Available at: http://www.virginiadot.org/vtrc/main/online reports/pdf/99-r l4.pdf

Websites

• US EPA Center for Exposure Assessment Modeling, HSPF, May 2002 http://www.epa.gov/ceampubllhspf.htrn,.

EPAIASCE BMP Database http://www.bmpdatabase.org/

Riparian Ecosystem Management Model REMM: http://www.cpes.peachnet.edu/remmwww/remm/remmoldwww/default.htrn

New Jersey Standard for Bioretention Systems http://www.state.nj.us/dep/watershedmgt/DOCSIBMP_DOCS/chapter5.PDF

Characterization of models from the USEPA, USDA / ARS / NRCS, Federal Highway Administration, Universities and others. model characterization.pdf, May, 2002. http://www.glc.org/projects/sediment/allweb32.pdf

Minnesota BMP manual http://www.pca.state.mn.us/water/pubs/swm-appendices.pdf

The most current version of SWMM (version 4.4h) can be downloaded from the Oregon State University website: http://www.ccee.orst.edu/swmm.

SWMM5 is available from the EPA web site: http://www.epa.gov/ednnrmrl/models/swmrn/index.htm



Documents

tjfaonline.com · BEFORE THE STATE OFFICE .'. - ,WASTE MANAGEMENT OF TEXAS, § INC. § OF : FOR MUNICIPAL SOLID WASTE § PERMIT AMENDMENT NO. § ADMINISTRATNE HEARINGS : MSW-249D