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Storm Water Permitting

Contact

Robert Karesh
Division of Water Resources
William R. Snodgrass Tennessee Tower
312 Rosa L. Parks Avenue, 11th Floor
Nashville, Tennessee 37243
615-532-5402
Questions? Ask TDEC

UPDATE!

QLP

QLP OPEN ENROLLMENT! The QLP program goes live after July 1, 2013, and applications will be accepted at any time after this date.

Please note that the Division of Water Resources, Central Office, will be moving to a new address as of July 29, 2013. Please forward any correspondence after this date to:

William R. Snodgrass Tennessee Tower
312 Rosa L. Parks Avenue, 11th Floor
Nashville, TN 37243

Five MS4s applied for and received active status under the Qualifying Local Programs (QLPs) during the QLP Pilot Program which ended June 30, 2013.

Developers of any and all proposed construction activity located within the following jurisdictional boundaries (listed below) will submit only to the QLP for both coverage under the CGP and the local stormwater program:

City of Bristol
City of Cookeville
City of Knoxville
Knox County
Washington County

Congratulations to these 5 MS4 programs!

Contact information for the 5 Pilot QLPs is as follows:

QLP

Stormwater Mgr.

Phone #

Email Address

Bristol

Tim Beavers, P.E.

423-989-5566

Tbeavers@bristoltn.org

Cookeville

Tracy Meggs, P.E.

931-520-5282

tmeggs@cookeville-tn.org

Knox County

Chris Granju, P.E.

865-215-5840

chris.granju@knoxcounty.org

Knoxville

David Hagerman, P.E.

865-215-2148

dhagerman@cityofknoxville.org

Washington Co.

Mike Rutherford

423-753-1753

mrutherford@wctndevelopmentservices.org

The QLP program was developed through a grant-funded stakeholder driven process, with the intent of creating an effective program that incentivizes participation.  Resultant incentives include streamlined QLP minimum requirements, a standardized interagency enforcement protocol, and recognition of QLP status as an alternative measurement of MS4 permit effectiveness. Obtaining QLP status is optional, but all regulated Municipal Separate Storm Sewer Systems (MS4) are encouraged to consider participation.

Some of the most significant benefits of a QLP include:  

  • A more streamlined and efficient process for managing construction stormwater by eliminating permit and review duplication at the local and state levels;
  • Eliminating additional effort at the state level for construction site operators by providing only one set of requirements to follow; and
  • A more effective construction stormwater program resulting in greater water quality protection.

For more information, please contact Robert Karesh at (615) 253-5402, or Jennifer Watson at (615) 532-0359, or by e-mail at storm.water@tn.gov.


DOCUMENT DOWNLOAD
QLP Application (CN-1374) PDF
July 5, 2013 Press Release
Open Enrollment for QLP's Construction Stormwater Permitting
PDF

Below is the Timetable with Tasks Information:

Tasks Outputs Date
Pilot QLP Program Work with volunteer MS4 programs and monitor June 2012
Finalize QLP Program Modification based on experience with pilot period. Open enrollment. July 2013
Deliver replicable solution to other states Develop final guidance materials for delivery to EPA September 2013

Introduction to the QLP

The promulgation of the Phase I and Phase II National Pollutant Discharge Elimination System (NPDES) stormwater regulations established federal requirements for state and municipal control of stormwater runoff from construction activity. As a result, the division was required to develop NPDES permits to regulate stormwater discharges associated with construction activity, such as Tennessee's General NPDES Permit for Discharges of Stormwater Associated with Construction Activities (CGP). Municipalities identified as a regulated MS4 were required to develop programs consistent with the CGP to address construction site runoff within their jurisdictions.

Per CFR 122.44(s), the division can formally recognize an MS4 as a QLP that has been shown to meet or exceed the provisions of the CGP. If a construction site has submitted a program specific Notice of Intent (NOI) to a participating QLP, and has obtained a Notice of Coverage (NOC), the operator of the construction activity is authorized to discharge under the CGP without the submittal of an NOI, Stormwater Pollution Prevention Plan (SWPPP), or related permit fee to the division.

QLP Minimum Requirements

Regulated MS4s must implement and maintain a construction site stormwater runoff control program that addresses stormwater runoff from construction activities, as identified in sub-section 4.2.4 of the MS4 general permit. In addition, a QLP program must also include the following:

1.  Requirements for construction site operators to prepare and submit an NOI, and related comprehensive SWPPP, as identified in Section 3 (SWPPP Requirements) of the CGP,

2.  Specific procedures for SWPPP review, approval and NOC issuance,

3.  Requirements for construction site operators to perform inspections as identified in sub-section 3.5.8, and site assessments as identified in sub-section 3.1.2, of the CGP,

4.  A system for reporting to the division, information related to construction sites authorized by the QLP.

Application for QLP Status

An MS4 seeking QLP status may notify the division at any time, indicating the municipality's commitment to implement the QLP program as described. In addition to administrative information, the applicant will be asked to provide copies of their construction stormwater ordinances, site plan review and approval procedures, project inventory and tracking procedures, and enforcement response plan.

Review of applicant information will be performed by the division's Central Office and Environmental Field Office personnel. Meetings will be scheduled with the applicants to discuss their application's content and answer any related questions. Once the applicant has been approved, the MS4 receives provisional QLP status, which establishes time for any program modifications necessary to satisfy all QLP elements. Modifications may include revision of ordinances and policies, hiring or training of personnel, or purchasing related equipment.

The provisional period also provides the time necessary to educate all stakeholders, and procedurally move construction activities from a dual permit system to a single administered by the QLP. Stakeholder education is expected to be critical to the success of a smooth MS4 to QLP transition. There is no minimum amount of education required during the provisional period. However, it is expected that the provisional QLP will target appropriate internal and external stakeholders, and utilize various educational methods such as e-mail and mailing lists, public meetings, signage and website content.

The length of the provisional period will differ for each applicant based on the nature of the program at the time of application. Once the provisional period is complete, the applicant will receive notification that they have successfully received full QLP status and may begin NOC issuance.

We would like to formally recognize the following MS4s for their participation and valuable contributions to developing the QLP program:

Knox County Shelby County
City of Farragut City of Franklin
City of Nashville Bradley County
City of Knoxville City of Elizabethton
City of Chattanooga City of Kinsport
City of Memphis City of Brentwood
City of Bartlett City of Cleveland
City of Jackson Ft. Campbell
City of Johnson City TN Department of Transportation
Hamilton County  

We would also like to thank the University of Tennessee, Municipal Technical Advisory Service (MTAS) for the grant's facilitation and the following stakeholder groups for their invaluable participation:

Associated General Contractors, Home Builders Association of TN, Road Builders Association, TN Society of Professional Engineers, TN Municipal League, American Public Works Association, TN Chamber of Commerce, UT-Water Resources Research Center, TVA, Harpeth River Watershed Association, Cumberland River Compact

**Thank you to Jason Scott, with the Town of Farragut for designing the QLP Logo to be used on materials, applications, letterhead and signage.**

Additional Resources:

EPA: Code of Federal Regulations citation for Qualified Local Program authorization

Tennessee Stormwater Permitting

Tennessee NPDES Storm Water Construction Permit

Tennessee Phase II MS4 Program

Tennessee Stormwater Association