Transportation agencies focus mainly on their core mission: providing safe and efficient mobility for people and goods. However, since the early to mid-1990s, water quality regulations have demanded increasing attention from transportation agency staff. As water quality regulations continue to expand, this trend is not likely to reverse. Phase II storm-water regulations are one of the significant emerging compliance challenges driving the trend.
To deal with increasing compliance requirements, many transportation agencies are turning to computer and information technologies for assistance with required reporting, compliance tracking and field data collection. Technologies, such as hand-held computers, geographic information systems (GIS), global positioning systems (GPS) and relational databases, deployed in other sectors of the economy for data collection, data management and decision support, are finding their way into the transportation sector to help save time and streamline compliance.
Phase in
The Clean Water Act requires that storm-water dischargers obtain a National Pollutant Discharge Elimination System (NPDES) permit. Failure to obtain permit coverage or comply with NPDES permit conditions can result in civil or criminal penalties and exposure to third-party lawsuits.
Until March 2003, storm water permitting requirements were limited to municipal separate storm sewer system (MS4) operators serving populations over 100,000. In what has become commonly known as “Phase II,” any MS4 operator located in a U.S. Census-defined “urbanized area” must obtain a permit to discharge pollutants in storm-water runoff to waters of the U.S.
Since transportation agencies own and operate storm-water facilities and meet the legal definition of an MS4, and since these transportation MS4s are located within rights-of-way that crisscross through defined urbanized areas, transportation agencies must comply with Phase II storm-water regulations or face legal repercussions.
Fulfilling obligations
The Phase II regulations require the development and implementation of a Stormwater Management Program (SWMP) designed to reduce pollutants in storm water to the maximum extent practicable. The SWMP must address control measures including public involvement, education and outreach; illicit discharge detection and elimination; construction runoff and post-construction storm-water management for new development and redevelopment; and good housekeeping.
For each of these measures, the MS4 operator must identify best management practices (BMPs) that will be used. The operator also must establish measurable goals, define an implementation schedule, determine implementation responsibility for each program element and conduct annual reporting to its permitting authority.
Illicit discharge detection and elimination is perhaps one of the most labor-intensive and time-consuming compliance obligations to fulfill. First, an inventory of storm-water outfall points must be developed using field verification techniques. Then, during dry weather, outfall inspections must be periodically conducted and documented to verify that no inappropriate discharges from the MS4 are occurring. Sources of dry weather discharges can include landscape irrigation water or groundwater infiltration. Illegal discharges include drainage from unlicensed commercial car wash operations, leaking sanitary sewers or industrial discharges that may have been improperly plumbed.
If any illicit discharges are found, follow-up investigations and possible third-party notifications must be made. Notification of any neighboring MS4 operators is required if no source is found inside the right-of-way and if the source has been traced to the edge of the right-of-way.
On a tech high
With careful, up-front planning, many, if not all, of a transportation agency’s compliance obligations can be managed, tracked and reported using any desktop computer with Internet access. Web-based reporting, map viewing and data mining is possible with modern web servers, essentially computers connected to the Internet that house all types of data and information viewable through an Internet browser application. Anyone with a web browser can view the data and print reports and maps. This gives data access to many more agency employees without more expensive GIS software and new training requirements.
Field data used in the web application can be collected electronically. Hand-held or tablet computers can be programmed with forms to electronically collect data including discharge flow rates, pollutant levels, color or outfall site conditions, such as the presence of distressed vegetation. Using GPS, field survey staff can record the coordinates of a storm-water structure, such as an outfall. Digital cameras provide digital images to record the condition of the structure and the downstream conveyance. All information can be automatically and electronically linked to create a complete electronic inventory without any retyping or manual file management.
Field data plays a central role in helping agencies track potential discharge sources as required by the regulations and their NPDES permits. Automated sampling technology added to the mix can provide additional information on runoff characteristics and can comply with permit-required monitoring. Of course, observed odor or turbidity, noted without sampling, can often narrow down possible discharge sources.
In full view
Following the field work, survey data is linked to GIS software and web-server technology to allow information mapping. All outfalls, for example, can be located on a map showing roadways, streams and other features. A relational database application merged with the GIS incorporates observations and other data collected in the field. Using GIS in this way makes the application more than a mapping tool. Its data mining and integration capabilities correlate information to reveal patterns and help staff visualize the meaning of the collected information, which otherwise might be stored in large three-ring binders of hard-copy inspection forms. GIS can be used further to identify potential illicit dischargers by mapping industrial sites that can have elevated pollutant levels by Standard Industrial Classification (SIC) codes and physical address.
To facilitate required compliance tasks and reporting, a web-based GIS application can be developed using proprietary software such as ArcInfo, ArcGIS and Microsoft Access. The result is an enterprise-wide means of viewing inventory data and mapped information. An integrated database allows staff to create interim and annual reports and to actively manage required tasks. Compliance schedules can be developed with automatic e-mail notifications sent as deadlines approach. Information is moved from paper forms and files into a centralized system to minimize errors. Data is entered once in the web-based application and applied as required throughout the system. Access is available from anywhere with an Internet connection, and password protection limits users’ access as needed.
These applications can be as complex or scaled down as an agency requires. One example is the compliance system developed by consulting firm PBS&J for Bexar County, encompassing the San Antonio area. The county sought a “starter” system with open architecture that could expand along with its growing GIS application. A Microsoft Access database was designed and implemented to provide custom data entry and report generation. Users could view control measures and BMPs identified in the SWMP and update activities completed in any of its service centers. The county’s environmental director could then merge updates from each service center into a master database where county-wide activities could be tracked and reported.
