creating a new toolbox for site development under emerging
TRANSCRIPT
Creating a New Toolbox for Site Development
under Emerging State/Federal Rules
Presented by:
Gregory P. Kacvinsky, P.E.
OHM Advisors
MWEA Annual Conference
June 24, 2014
OHM 34000 Plymouth Road Livonia, Michigan 48150 T 734.522.6711 F 734.522.6427 www.ohm-advisors.com
MDEQ – New MS4 Rules
New permits phased in between 2013-2017
First permits submitted to MDEQ in early 2013
Permits issued by watershed
2010 Census increases coverage areas
• Treatment for first 1 inch of runoff – Not necessarily infiltration
– Could be mechanical separation, filtration
• TSS Reduction (80% reduction or 80 ppm max concentration) – A bit onerous, especially, 80 ppm max
– Typically, treating first inch of rainfall helps to achieve this goal
– 80% reduction probably an easier goal than 80 ppm max
• 2-year volume control – May be most significant requirement in new rule
– Generally requires infiltration unless site conditions prevent infiltration
– Relaxed and clear standard for redevelopment
• What tool(s) can we use to demonstrate site-specific compliance??
MDEQ – New MS4 Rules
• Rules based on measures successfully tested in other states (i.e. Maryland,
Wisconsin, Minnesota, Washington, etc.) through years of regulation and
compliance.
• This is the first set of rules that really addresses pollution resulting from
development. New rules now address runoff volume, which is a key driver of
stormwater quality and stability of receiving streams.
MDEQ – New MS4 Rules
Designing for water quality (‘first flush’ treatment):
• What is a ‘first flush’ event?
Small Storm Hydrology
Designing for water quality (‘first flush’ treatment):
• Treat runoff resulting from 90% of precipitation events (MDEQ
requirement)
• In Michigan, this is typically 0.75 – 1.0 inch of rainfall, typically
occurring over a 1-2 hour period
• DEQ Rules – applies to entire area, whether new or
redevelopment
• Municipality can provide statistics to substantiate a different
rainfall depth (other than 1 inch)
Small Storm Hydrology
• We’re accustomed to designing for a flood control event
• Water quality design requires the use of a much smaller storm
0
1
2
3
4
5
6
0 2 4 6 8 10 12 14 16 18 20 22 24
Inch
es
of
Rai
nfa
ll
Hours Into Storm
Large Storm v Small Storm Hydrology
100-yr 24-hrSCS Type II
1-yr 2-hr Huff1st Quartile
Small Storm Hydrology
Small Storm Hydrology - TOOLBOX
How do we meet the 1-inch ‘first flush’ requirement?
• Some existing design practices may partially or fully address this
• (e.g. wet detention ponds)
• Rain gardens and bioretention are an obvious tool to meet this objective,
especially in redevelopment areas without wet detention option
• Pervious pavement
• Mechanical separation (swirl chamber)
• Applies to entire site (whether greenfield or redevelopment)
How do we meet the 2-year volume control requirement?
• This will be harder to implement, as many stormwater BMPs are designed
for a smaller event
• Only applies to increased runoff volume, which lowers the hurdle for
redevelopment sites
• Requires storage volume and good in-situ soils
• Modeling approach is critical to demonstrate how BMP(s) will function
• Adapting to this rule is going to have a major impact on the
development community, because it:
• Requires a new skill set for site planning, modeling, and design
• Impacts developable footprint
• Impacts economics of development
Small Storm Hydrology - TOOLBOX
• Updating stormwater rules should include the consideration of
updated rainfall statistics:
• TP40: 1960 (last 50 years of rainfall not represented)
• Bulletin 70: 1992 (last 20+ years of rainfall not represented)
• NOAA Atlas 14: 2013 (most up-to-date and relevant statistics for Michigan)
Rainfall Statistics
1.00
1.50
2.00
2.50
3.00
3.50
4.00
1 2 4 8 16 32
Tota
l Rai
nfa
ll (i
n)
Duration (hrs)
TP40 5-yr
Bulletin 71 5-yr
NOAA 5-yr
TP40 10-yr
Bulletin 71 10-yr
NOAA 10-yr
TP40 25-yr
Bulletin 71 25-yr
NOAA 25-yr
2h
ou
rs
3 h
ou
rs
6 h
ou
rs
12
ho
urs
24
ho
urs
Rainfall Statistics – NOAA Atlas 14
• 100-yr storm (flood control) statistics have changed significantly
• Comparing TP40 to NOAA Atlas 14 (all storms 24-hr duration):
• Central Oakland County:
• TP40: 4.5 inches
• NOAA14: 5.4 inches (20% increase)
• Central Wayne County:
• TP40: 4.5 inches
• NOAA14: 5.2 inches (16% increase)
• Central Washtenaw County:
• TP40: 4.75 inches
• NOAA14: 5.1 inches (7% increase)
Rainfall Statistics – NOAA Atlas 14
• Recent analysis of rainfall in Ann Arbor
• Comparing the 1951-1980 and 1981-2010 periods:
• Increase of ~25% in total annual precipitation
• Frequency of the heaviest 1% of storms (as determined for
the 1951-1980 period) has increased by 38%
• From 1958 to 2010:
• Throughout Michigan, both the volume and frequency of
extreme storms have increased
• The magnitude of the largest 1% of storms has
increased by 4%-8%
• The volume of precipitation in the largest 1% of
storms has increased by 37%
Source: (Technical Oversight and Advisory Group (TOAG), June 2014
Rainfall Statistics – Climate Change
• The rules are changing, and the old reliable programs may no longer
give us all the tools we need:
• HEC-HMS
• TR-55 / TR-20
• PondPack
• These tools are ok for traditional stormwater design (conveyance and
flood control, but they have limitations):
• No water quality modeling capabilities
• Based on older rainfall statistics
• In most cases, these older tools do not have BMP modeling capabilities
Modeling Tools
• Many free (or inexpensive) tools exist to efficiently size and design
stormwater treatment facilities
• EPA SWMM • ideal for larger developments with complex drainage systems
• EPA National Stormwater Calculator • Ideal for small sites, especially redevelopment areas
• RECARGA • Ideal for sizing and design of rain gardens / bioretention
• WinSLAMM • Ideal when pollutant removal calculations are required
Modeling Tools
• All-in-one modeling solution for hydrology and hydraulics
• Grey Infrastructure (pipes, inlets)
• Flood control (ponds, outlet structures)
• Green Infrastructure
• Can be used to evaluate BMP effectiveness at runoff volume control
and pollutants of concern
• Program is more complex, requiring training and understanding of
hydraulic/hydrologic theory
• LID Module allow for analysis of typical range of structural and non-
structural BMPs
Modeling Tools – EPA SWMM
• Useful tool to quickly estimate water quality impacts of site-specific
design
• Automatically imports key hydrologic data:
• Soil type(s)
• Slope
• Precipitation
• Evaporation
• User inputs stormwater BMPs
• 10 years of continuous rainfall/evaporation data used to quantify
impacts of on-site controls (uses SWMM runoff routine)
Modeling Tools – National SW Calculator
• Developed at the University of Wisconsin, used by Wisconsin DNR to
size bioretention facilities
• Single event modeling (i.e. SCS Type II storm)
• Continuous modeling (for annual rainfall series)
• Important to know on-site soil characteristics
• Calculates:
• Ponding times
• Total runoff volume
• Total rainfall volume retained on site
• Evaporation / root uptake
Modeling Tools – RECARGA
• Proprietary software (relatively inexpensive)
• Focus on pollutant concentrations (pre vs. post)
• Uses continuous modeling (one year rainfall series)
• Based on decades of field data for pollutant buildup and washoff
• Calculates:
• Pollutant concentrations (TSS, N, P, heavy metals, etc.)
• Pollutant yields (lbs)
• Total runoff volume
• Before/after comparison to demonstrate MS4 compliance
• Cost efficiencies of individual BMPs
Modeling Tools – WinSLAMM
• EPA SWMM, RECARGA, National Stormwater Calculator, and
WinSLAMM are all good options
• Models need to demonstrate:
• Total runoff volume (existing and proposed conditions)
• % of runoff retained (infiltration, evaporation)
• TSS removal (if infiltration cannot be used)
• Models should reference the latest rainfall statistics (NOAA Atlas 14)
• Limiting model options helps to streamline review process and keep
everyone playing by the same rules
Modeling Tools – Overview
• National Stormwater Calculator is best for early design stages only
(‘quick and dirty’ evaluation)
• RECARGA and WinSLAMM are good for BMP sizing
• EPA SWMM is still the best overall option to include both BMP sizing
and system design (pipes, detention ponds, etc.)
• None of these models give you reasonable results if you don’t have:
• Soil conductivity for native soils
• Prevailing groundwater level
Modeling Tools – Overview
• Why are rainfall statistics and
modeling techniques so important?
• Infiltration BMPs can cost in excess
of $15-$25 per square foot (life
cycle costs can exceed $30/sf)
• BMP costs in an urban
environment can approach $50,000
per developed acre
• Developers may bear initial burden,
but permitees are ultimately
responsible for perpetual function
of BMPs
ECONOMICS OF BMPs
Footprint for stormwater quality controls
• Infiltration
• Generally, about 3% - 5% of total contributing
impervious area
• Can be <3% if soil conditions are favorable
• Filtration (all flow exits through underdrain)
• 1%-2% of total drainage area (in residential
areas, less than 1% of total area)
Nuts & Bolts – ‘Rules of Thumb’
• Geotechnical Investigation
• Geotech is critical to identify which BMPs will work and those that won’t
• IN-SITU INFILTRATION CAPCITY (3-4 feet below surface)
• Most important factor in models that define runoff volume control
and stormwater quality
• A minimum acceptable infiltration capacity is about 0.4 – 0.5 in/hr
Nuts & Bolts – ‘Rules of Thumb’
• Groundwater Depth
• Generally, infiltration BMPs are not practical when the groundwater is
within 4-5 of the surface.
• Local rules should require groundwater depth determination
• Alternative BMPs necessary when groundwater is high
Nuts & Bolts – ‘Rules of Thumb’
• Soil Contamination
• New MDEQ rules prohibit
infiltration BMPs in
contaminated areas
• Other stormwater control
options necessary in
contaminated areas:
• Mechanical separation
(i.e. swirl concentrators)
• Filter media
• 2-year storm volume
control may be impractical
• Need flexibility in local
ordinances
Nuts & Bolts – ‘Rules of Thumb’
• Underdrain or no underdrain?
• Underdrains help to dewater when soil
conditions do not permit, BUT
• Underdrains flow back into storm sewer
system, thus reducing impact of volume
reduction for 2-year requirement
• In most cases where infiltration
capacity is 0.4-0.5 in/hr, underdrains
aren’t needed
Nuts & Bolts – ‘Rules of Thumb’
• We’re addressing stormwater quality, and that’s increasing the
footprint necessary for stormwater controls. How does this impact the
economics of site development?
• Zoning flexibility and Low Impact Development
• Relaxation of flood control hurdles
• Current detention pond requirements often cause overdesign
• Peak flow limitations (x cfs per acre) are typically lower than actual runoff
potential
• GOALS
• Mimic pre-development hydrology
• Overdesign (reducing flows relative to existing conditions) can have harmful
downstream impacts
Impact on Flood Control
100 Year 24 Hour Storm
0
20
40
60
80
100
120
140
160
180
1/1 1/1 1/2 1/2 1/3 1/3 1/4
Time
Existing Conditions
Proposed Conditions
Flo
w (
cfs
)
Midwest site designed to 0.20
cfs/acre
Peak flow reduced, BUT excess
storage results in prolonged
discharge to receiving stream
Do we need a prescriptive
discharge rate? How about
basing design on actual runoff
potential?
Impact on Flood Control
On-site BMPs provide storage volume, even for
big events (i.e. 10-yr, 100-yr storms)
Modeling should account for this volume and it
should be subtracted from the required flood
storage volume
Local ordinances should provide more flexibility on
design (i.e. 100-yr) discharge rate to provide a
balance between development costs and water
quality needs
Impact on Flood Control