municipal operations 10/9/20151 municipal operations

Municipal Operations

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Common Program Components of Municipal Operations

• MS4 Operation and Maintenance

• Public Facilities

• Roadways

• Standards and Training

• Pesticides, Herbicides, and Fertilizer Application

• Field Activities


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Requirements

• MS4s are required to:Develop an O&M program to prevent or reduce

pollutant runoff from operations

Include employee training to prevent and reduce storm water pollution from activities such as the maintenance of park and open space, buildings, and storm water systems


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Auditing and Inspecting an MS4 Maintenance Program

Focus on four main areas:

• Operation and maintenance activities and recordkeeping Storm drain system and structural controls Public facilities Streets

• Standard operating procedures Routine maintenance Spill prevention and response Pesticide, herbicide, and fertilizer application

• Staff training

• Facility inspections


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Maintenance activities and schedules, and long-term inspection procedures

Controls on the discharge of pollutants from streets, salt/sand storage areas, waste transfer stations, etc.

Procedures for disposing of waste from the MS4Ensure new flood management projects assess

impacts on water quality

Pollution Prevention/Good Housekeeping for Municipal Operations


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MS4 Operations and Maintenance

• Does the MS4 have a program to regularly inspect, clean and repair components of the infrastructure?

• Does the MS4 measure and track the amount of pollutants removed from the storm drain system and structural stormwater practices?


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MS4 Operations and Maintenance

• Subtopics typically addressed include:

Infrastructure Mapping and Characterization

Catch Basin CleaningStormwater Management

Structures


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• Do maps show all inlets, outfalls, storm drain conduits, stormwater management facilities receiving water bodies, catch basins, and structural stormwater controls?

This map should be readily available and the maintenance field staff should be referencing it to perform maintenance activities.

• Are infrastructure assets or components named and/or numbered to allow tracking of maintenance and repairs?


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• Does the MS4 have a database or mapping system to organize data?

The types of data should include, but not be limited to:

• Type of structure or asset• Location (address, latitude/longitude)• Photo• Date built• Date last inspected• Date last cleaned/maintained

How does the MS4 update the data and maps when new outfall structures are added or as new data are collected?


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Catch Basin Cleaning

• Does the MS4 regularly clean catch basins?Is the cleaning schedule frequent enough to

minimize pollution?Are cleanings documented and evaluated to

ensure that the schedule is targeting problem areas?

Are pollutants removed from the catch basins should be disposed of in an environmentally friendly manner?

• Are storm drain pipes routinely inspected and maintained to remove pollutants and debris and ensure proper drainage?


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Structural Stormwater Controls

• Are structures inventoried in terms of location, type, and inspection and maintenance needs?

• Does the MS4 perform maintenance on vegetation in grassed swales, rain gardens, pond perimeters, and other vegetative stormwater controls?

• Are structural stormwater controls regularly inspected and maintained? Does the MS4 document these activities?


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Public Facilities

• Does the SWMP describe a process for inventory and assessment of the impact of stormwater runoff from municipal facilities?

• This inventory should include:

All facilities that treat, store, or transport municipal waste

Municipal maintenance yards

Park and landscape maintenance facilities

• Are BMPs implemented at sites that are determined to have a potential to affect stormwater quality?


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Facility Inventory• Does the MS4 have an inventory of all public facilities, including the

following: Public works yards Public transit facilities Wastewater and domestic water treatment plants Sanitary sewer system overflow locations Public parks/open areas Public parking lots Public buildings Landfills and hazardous waste disposal sites, transfer locations, or storage

facilities

• Are these facilities inspected for water quality impacts?• Do facilities required to apply for coverage under a general industrial

stormwater permit have a SWPPP? Have they filed an NOI?


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Maintenance Yard Management

• Does the municipality’s public works yard have a SWPPP?

• Is there an individual or department responsible for implementing and maintaining the SWPPP?

• Does the responsible party periodically inspect the yard for stormwater compliance?


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Parks Operations and Maintenance

•Do parks have trash enclosures that are emptied regularly?

•Do parks have pet waste disposal stations equipped with baggies and signs?

•What BMPs are implemented at parks (e.g., streamside buffers, reduced mowing frequency, integrated pest management etc.)?

•When facilities like public restrooms are cleaned, how is clean-up water disposed?

•What is the municipality’s procedure for disposing of chlorinated water from swimming pools?


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Building Operation and Maintenance

• How often are parking lots swept?

• Are enclosed parking structures and other public buildings cleaned in a manner that minimizes polluted runoff?

• What BMPs are used to protect storm drain inlets when power washing is used for cleaning?


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Sanitary Sewer System Maintenance, Overflow, and Spill Prevention

• Is a program in place to mitigate or prevent sanitary sewer overflows (SSO) from entering the MS4?

• Are flow pathways from SSO locations to catch basins or other points of entry to the MS4 identified and regularly monitored?

• Are spill prevention and clean-up plans designed to ensure that the MS4 is protected from sewage overflow or spill?

• Do these plans include a reporting protocol to ensure that the appropriate authorities are aware of any incidents that occur?

• Are residents with septic tanks educated about the proper maintenance of their systems to avoid leakage into the MS4 or receiving waters?


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Water Supply Operation and Maintenance

• What procedures do field staff follow that integrate stormwater management BMPs into their operation and maintenance activities?

• BMPs should be implemented when:

Testing and flushing of new existing water lines

Hydrant testing

Maintaining underground water lines (e.g., trenching, excavation)

• Are source water protection efforts coordinated with the stormwater program?


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• Does the permittee document the type of chemicals and hazardous materials used during municipal operations?

• Are procedures in place that require chemicals to be stored and disposed of as directed on the label?

• Does the permittee have an alternative materials program to reduce the use of potentially hazardous materials?

Data should be kept to evaluate the effectiveness of the program

• Does the permittee sponsor or support a household hazardous waste collection system for the public? How is it publicized?

Chemical and Hazardous Material Use and Disposal


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Roadways

• Does the MS4 have procedures for operating and maintaining public streets, roads and highways that reduce stormwater pollution?

• These practices should include regular street sweeping and proper use of BMPs during street maintenance activities


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Roadways

• Subtopics typically address:

Street SweepingPublic Streets, Roads, and Highways MaintenanceDeicing Activities


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Street Sweeping

• Are streets swept regularly and is the schedule based on reducing/removing pollutants and stormwater impacts?

• Is street sweeping debris disposed of in an environmentally friendly manner? If dewatering occurs, is the decanted water disposed of correctly?

• Are records kept that document the amount of debris collected?

• Are pollutant removal data used to evaluate the effectiveness of the program?


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Public Streets, Roads, and Highways Maintenance

• Are environmentally friendly maintenance practices used?

• Which BMPs are used by field crews to minimize stormwater impacts during road maintenance or repair activities, including

Ditch cleaning

Sidewalk repair

Asphalt patching

Curb and gutter repair

Street striping

Sign painting


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Deicing Activities

• What BMPs does the permittee incorporate into its anti-icing and deicing activities to reduce stormwater pollution?

• Has the feasibility of using environmentally friendly alternatives to road salt been assessed?

• Are deicing agents and abrasives stored in a covered or bermed area to prevent runoff?

• Are application rates and locations being tracked?

• Are abrasives and residual deicing materials collected after snow and ice have melted?


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Standards and Training

• Subtopics typically include:

Standards for Municipal StaffStandards for Contracted Services StaffTraining and Education


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Standards for Municipal Staff

• Are standard operating procedures in place to ensure that municipal field staff integrate stormwater quality BMPs into their daily activities?

• Are BMPs and standards adopted for use by the municipal staff?

• Are reference materials and guidance documents provided to field staff describing BMP specifications and details?

• How do managers ensure that their staff are implementing standard operating procedures?


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Standards for Contracted Services Staff

• How does the permittee ensure that contractors incorporate stormwater quality BMPs into their activities?

• Are BMP requirements outlined or included in the contract or proposals?

• Are BMP reference materials and guidance documents provided to contractors?

• Are inspections performed or reports submitted that would indicate whether the contractors are fulfilling their contractual responsibilities?


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Training and Education

• Are municipal staff not directly involved in maintenance activities educated about general stormwater awareness?

• How are new employees trained on stormwater BMPs?

• Are field staff given activity-specific training with information on specific BMPs applicable to their work sites?


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Pesticides, Herbicides, and Fertilizer Application

• How are pesticides, herbicides, and fertilizers used in municipal operations?

• What type of training, licensing or certification is required for municipal or contracted pesticide applicators?

• What BMPs are used to reduce the likelihood of stormwater contamination from chemical storage and use?


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• Are chemicals stored and disposed of as directed on the product labels?

• Does the permittee have a pesticide, herbicide, and fertilizer application plan?

• Does the permittee use integrated pest management (IPM)?

• Are native or non-turf plants used to minimize the use of fertilizers and pesticides?

• Does the permittee conduct training for chemical applicators?

Pesticides, Herbicides, and Fertilizer Application


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In-Field Activities

• The primary in-field evaluation activity is an inspection of the permittee’s municipal maintenance yard(s) or other type of permittee-owned or operated facility

• The intent of these inspections is to identify maintenance and housekeeping problems at the site(s)

TIP:

Other MS4 facilities, such as parks, marinas, and household hazardous waste collection facilities, should be visited if time allows.


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In-Field Activities

• Inspection criteria:

Are chemicals, bulk materials, or other potential pollutants covered and stored properly?

Are wash racks and dewatering areas plumbed to sanitary sewers (if allowed)? If not allowed, is wastewater prevented from entering the MS4?

Is there outside maintenance and/or storage? Do vehicle maintenance areas have BMPs to protect

the MS4 from polluted runoff?Does the facility have structural BMPs (e.g.,

stormwater detention ponds, stormwater filter devices)? How well are they maintained?


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In-Field Activities

• Inspection criteria cont.:

Are inoperable vehicles stored to prevent polluted runoff and leaching of contaminants to groundwater?

Are storm drain inlets free of debris?

Has the yard been swept? Are there oil stains or other evidence of spills?

• Document findings with photos and as much detail as possible

• The following slides show common problems at maintenance yards


1. Poor housekeeping practices – paint cans left exposed


2. Batteries and drums left exposed to stormwater


3. Poor housekeeping practices – sloppy road paint storage


4. Poor housekeeping practices – failure to clean storm drain inlets


5. Poor housekeeping practices – failing to clean storm drain inlets


6. Wastewater discharge to the MS4


7. Clear signage for employees


8. Stormwater treatment practices in-use and maintained


9. Stockpiles covered


10. Stockpiles covered


11. Catch basin cleaning


12. Video inspection of storm drains


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Common Compliance Problems

• Maintenance yards lack adequate controls

• Lack of SWPPP or equivalent plan

• Municipal staff lack adequate stormwater guidance

• Stormwater BMPs not used for routine maintenance activities

• Lack of training/awareness of stormwater BMPs


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MS4 Maintenance Resources

• CASQA’s Municipal BMP Handbook www.cabmphandbooks.com/Municipal.asp

• North Texas Council of Governments Stormwater Pollution Prevention Training Module Series http://www.nctcog.org/envir/ SEEclean/stormwater/program-areas/pollution_prevention/CD/Version_1/P2_Training_ Materials.asp

municipal operations 10/9/20151 municipal operations

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