Good Housekeeping and Municipal Pollution Prevention

Good Housekeeping and

Municipal Pollution Prevention

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www.chesapeakestormwater.net

The Latest from CSN!

➢ Annual CSN Network Survey Results!

➢ Fall Inspection and Maintenance Workshops

➢ Webcast Archives

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Upcoming Webcasts

The Last of 2017!!

Thursday, December 14th:

The Impervious Cover Model: Revisited

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Poll Question #1

Tell us a little about yourselves…who are you representing today?

▪ Local government

▪ Private sector

▪ Regulatory agency

▪ Non-profit

▪ Academia

▪ Other…tell us in the chat box

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Poll Question #2

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What is your greatest Municipal Good Housekeeping challenge?

▪ Lack of training

▪ Limited staff/resources

▪ Attitude/buy-in from municipal staff

▪ Getting my kids to clean their rooms

▪ N/A

▪ Other…tell us in the chat box

Today’s Agenda

▪ Municipal Good Housekeeping Basics

▪City of Charlotte’s Municipal Good Housekeeping Program

▪ Municipal Hotspots

▪ CSN Benchmarking Tool

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What is Good Housekeeping?

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MCM #6: Municipal Pollution Prevention and Good Housekeeping

➢Train municipal employees on pollution prevention

➢Pollution prevention plans for municipal hotspot operations

➢Review municipal maintenance operations (e.g., street sweeping, catch basin cleanouts)

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Why is it important?

▪It effectively prevents or reduces stormwater pollution▪ Prevention > Mitigation▪ Our stormwater BMPs can’t do all the work

▪It is required:▪ Municipal Separate Storm Sewer System (MS4) Program

▪Other Benefits:➢Helps reduce future maintenance/clean up burden ➢Minimizes health risks to residents and workers ➢Reduces regulatory liability➢Allows you to lead by example

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Maintain Roads for Water Quality

▪ Review current sanding/salting practices

▪ Check pesticide application in road right of way

▪ Change truck washout procedures

▪ Optimize street sweeping programs for water quality improvement

▪ Targeted storm drain cleaning Bay

BMP

Bay

BMP

Landscape/Turf Management

▪Review your procurement contracts for routine landscape maintenance on public lands to ensure these crews are trained and qualified to implement UNM plans

▪Plant trees on municipal lands like parks, cul-de-sac islands and parking lots.

▪Consider benefits besides water quality improvement when planning your project locations, such as opportunities to create habitat corridors for wildlife

Bay

BMP

Bay

BMP

BMPs in New Public Construction

•Exceed the minimum required for the private sector•Demonstrate innovative stormwater practices •Green roofs, bioretention, water harvesting, etc.

•Utilize projects for stormwater education

Bay

BMP

Maintenance of Public Stormwater BMPs

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BMP performance is inextricably linked to maintenance

Establish Pollution Hotline and Respond

▪Single phone number or website where citizens can easily report illicit discharges and pollution concerns

▪Cross-trained staff

▪Response within 24 hours

▪Watershed addressing

Municipal Good Housekeeping & Pollution Prevention program

November 16, 2017

Date

Program Drivers

NPDES Permit

Setting the example

for the community

Environment Focus

Area Plan

Develop a Facility Inventory

• From permit: Facilities that are “determined by the permittee to have significant potential for generating polluted stormwater runoff”

• Facilities on the inventory are included in inspection program and have Stormwater Pollution Prevention Plan (SWPPP)

• Currently 31 facilities (plus 42 fire stations)

Facility Inspection Program

• Semi-annual inspections at all facilities on inventory – One combined (Stormwater staff and facility staff)

– One independent (facility staff)

• Fire stations on 5-year rotation

• Inspection includes: outdoor storage & operations (tanks, dumpsters, fueling, etc.), outfalls, spill response, erosion, structural SCMs

• We use an inspection checklist– To ensure nothing is missed

– To facilitate proper documentation and consistency

Facility Inspection Program

• SWPPP review– Are they keeping up with requirements/documentation?

– Does it need to be updated?

• All info entered into database – generates a report

• Written report sent to facility staff

• Corrective action follow-up and documentation

Inspection Report

• All info entered into Cityworks

database

• Stores all information for

reference and audits

• Automatically generates report

• Database was customized by staff to fit our needs

Corrective Action Documentation

• Corrective action recommendations made; work with staff to implement

• Actions tracked in spreadsheet (partial shown below)

Facility Inspections

• Instill a sense of program/permit ownership among facility management (not just Stormwater’s permit)

• Educate department leaders and obtain their commitment to program goals (top-down approach)

• Copy leaders on inspection reports

• Designate SWPPP responsibilities and do training on its content

• Develop & maintain collaborative relationships w/ key facility staff

• Follow up on problems found and work with staff on solutions

• Pollution prevention is first priority over treatment solutions

Permitted Facilities

• 11 facilities have their own NPDES Stormwater permits (plus 2 “No Exposure” certificates)

• We provide turnkey permit management:

– Application preparation/submittal

– SWPPP preparation and updating

– Inspections

– Monitoring requirements

– Training

• Previously left up to facility staff – led to frequent non-compliance with permit requirements

Stormwater Pollution Prevention Plans

• Created condensed (10-12 pages)

SWPPPs for non-permitted facilities

• Reviewed and updated annually

• Spill Prevention & Response Plan

(permit requirement) is included

• Section on vehicle & equipment

washing

• Forms included:

– Reportable spill documentation

– Semi-annual inspection

Training

Topics to cover - depends on the audience

All staff:

o General awareness – stormwater pollution, water quality

o Illicit discharge detection and reporting

Municipal facility & field staff:

o Pollution prevention BMPs specific to facility & operation

o Problems found during recent inspection(s) and in field

o NPDES Permit and SWPPP (awareness/general)

o Spill prevention and response procedures

Training

• We deliver a combination of annual classroom and online training

• Includes Power Point slides, video, pictures

• Have used several purchased videos

• Customized to site and operations – point out

issues from recent inspections

Training

• Use existing staff resources to share the workload

• Use professionally-created resources if suitable

• Use online training if available

• Use lots of pictures, preferably from your own sites and operations

• Mix it up – both within the presentation and from year to year

• Customize as much as possible

• Keep training sessions to reasonable time limit

• Make it fun – give away prizes

Field Operations

• Many focus on pollution prevention at facilities –don’t forget about field operations

• LOTS of potential for improvements in water quality when considering operations done all over the city

Field Operations

Many different operations & activities:

– Construction: roads, sidewalks,

buildings, stormwater, sewer, water

– Maintenance: roads, buildings,

stormwater, sewer, water

– Landscape operations

– Street sweeping

– Storm drain cleaning

– Road salt application

– Solid waste & recycling collection

– Bus shelter cleaning

– Event/festival cleanup

– Hazardous materials response

– Graffiti removal

Field Operations

• Can be an intense and time-consuming effort

• Determine priority operations and develop a schedule

• Developed point system to determine priorities based on:

– Does operation generate priority pollutants?

– Does operation generate other pollutants?

– Frequency of operation

– Geographic expanse of operation

– Proximity of operation to surface waters or storm drains

– Degree of pollution prevention program development

Field Operations

• Currently working with stormwater construction team

• Major focus is on sedimentation & erosion control

• Visited many projects, took photos

• Met and discussed practices with project inspectors & supervisors

• Determining what our best practices will be for many different elements of project construction

• Researched training programs and working on specialized in-house training (combo field training, classroom, videos)

Example BMP document

Field Operations

Cyclical Process

Field Operations

• Determine priorities

• One operation at a time, go in depth, to develop BMPs

• Involve operations staff in every step to ensure buy-in

• Spend plenty of time observing what they do – ask lots of questions

• Research what other municipalities have done and learn from them

• Develop final written BMPs document and have leadership sign it

• Conduct initial training and incorporate BMPs into annual training

• Re-visit and follow up with management and staff from time to time

Contractors

• Contractor training isn’t an explicit permit requirement, but is very important nevertheless

• We’ve done:

o Workshops – resource intensive; need to offer something “extra” (CEUs/PDHs, face time w/ staff, food)

o Presentations – as part of already-scheduled meetings

o Mailings – do they even read what is sent?

o Contract language – this is one of the best things you can do

➢ not as easy as it sounds – met with some resistance

➢ train relevant staff so they know about requirements

➢ requirements are only as good as level of enforcement

Municipal SCM Inspection & Maintenance (I&M)

• Currently 120+ SCMs

• Departments that built the facility/SCM are responsible for I & M

• Require annual report

• Most work with Landscape Mgmt & Building Services to do I & M – several staff certified

• Stormwater staff receive and enter reports, send reminders, serve as expert resources

Municipal SCM I & M

• Staff doing I & M don’t feel qualified (reports tend to reflect that)

• Funding for proper maintenance is an issue

• I & M reports not always submitted – requires follow up and staff time

• De-centralized approach doesn’t appear to be sustainable

Municipal Hotspot Facilities

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6 Common Hotspot Operations

Vehicle Operations

Outdoor Material

Waste Management

Physical Plant

Turf / Landscaping Areas

Unique Operations

Start with the Public Works Yard

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What Works at Municipal Hotspots?

Pollution Prevention Plans that. . . ◦ Involve and list all responsible departments

◦ Focus on specific activities and include achievable BMPs

◦ Focus on maintenance of controls

◦ Clearly show link between pollutants and storm drains

◦ Address pollutants of concern

◦ Consider seasonal variations

◦ Reflect staff input and ideas

FACILITY DESCRIPTION & CONTACT INFO SITE MAP

POTENTIAL POLLUTANT SOURCE LOCATIONS

STORMWATER CONTROL MEASURESPILL PREVENTION & RESPONSE

▪ Location of response materials

▪ Training

▪ Container labeling

▪ Containment

▪ Reduce exposure

▪ Personnel

▪ Notification procedures

Training for Municipal Staff

▪Provide general and activity specific training

▪General awareness training for all city employees (impact on water quality, illicit discharge identification and response, etc.)

▪Regular and targeted training for employees based on the activities they perform

▪Provide materials for easy, frequent refreshers

Training for Municipal Staff

▪Teach employees that their actions have an impact on water quality and they are examples for the community

▪Link your employee training with your public education message

▪Create recognizable links between pollutants of concern and uses they enjoy/value

CSN Stormwater Benchmarking Tool

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Objectives of the Benchmarking Tool

✓Takes only a few hours to complete

✓Identifies correctable stormwater problems

✓Increases staff awareness about stormwater, watersheds and community stewardship

✓Done outside the building and is kinda fun

✓Leads to action not just paperwork

✓Create a quantitative scorecard of overall site performance

The Benchmarks

▪ 22 Benchmarks assessed inside and outside the building and the stream the site discharges to

▪ Specific tasks or activities performed to earn individual benchmark points

▪ 100 points maximum for the site as a whole

▪ Recommended minimum score is 95 points

1. Define Your Watershed Address

Benchmarks:

▪ Google Earth to find location of the facility in relation to nearest stream and watershed

▪ Do a web search to identify local or regional watershed groups

▪ Contact them to learn more about key water quality and habitat issues

Activity: Use the internet to determine the stream to which the facility ultimately drains to, as well as the larger watershed in which it resides

2. Derive a Stormwater Profile for Your Site

Benchmarks:

▪ Estimate total site area, impervious cover and runoff coefficient

▪ Compute the annual stormwater runoff volume produced at your site.

▪ Compute the annual phosphorus, zinc, and oil/grease loads produced by your facility

Activity: Analyze site layout to estimate key land cover variables to compute stormwater runoff volume and pollutant loads generated by your facility.

Stormwater Profile for Facility

▪ Site Area = 24.1 acres

▪ Estimated % Impervious = 92%

▪ Average Annual Runoff = 50 inches

▪ Total Phosphorus = 56 lbs/yr

▪ Sediment = 8.7 tons/year

▪ Total Nitrogen = 452 lbs/yr

▪ Oil and Grease = 865 lbs/yr = 104 gallons/yr

▪ Zinc = 43 lbs/year

3. Enhance Employee Training

Benchmarks:

▪ Include them in the benchmark assessment

▪ Customize stormwater training

▪ Include personal stewardship at home

Activity: Involve employees to increase their stormwater pollution prevention IQ

Benchmarks:▪ Find and review your last pollution

prevention plan.

▪ Update it to reflect findings from benchmarking assessment

▪ Designate lead individual at facility to track it

▪ Prominently post current score

4. Upgrade Your Stormwater Plan Activity: Check to make sure that you have an approved Stormwater Pollution Prevention Plan (SWPPP) for your site, and develop annual work plan to improve the total benchmark score

5. Understand the Plumbing at Your Site

Facility Evolution: Not Always Sure Where Stormwater Goes

Activity: This involves a careful analysis of the site plan followed by a walk through to find out exactly how and where stormwater flows across the site… followed by marking of all storm drains on the site

5. Understand the Plumbing at Your Site

Activity: Inspect the rooftop to determine roof materials and conditions and potential to disconnect or treat roof downspouts

Benchmarks▪ Assess Rooftop Materials▪ Check for Downspout

Disconnects▪ Look for Rooftop Retrofit▪ Retain Design Consultant

6. Retrofit Roof Runoff

Activity: Investigate the interaction of pollutants, practices and storm drains at the building interface (truck and rail)

Benchmarks▪ Sweeping versus wash-

downs▪ Covering loading docks▪ Redesign drainage

7. Investigate Loading/Unloading Areas

Activity: Evaluate the condition, drainage and maintenance of the parking lot to reduce runoff and reduce pollutants

Benchmarks▪ Stabilize un-paved lots

▪ Walk lots monthly to find and fix leaks

▪ Weekly trash and litter pickup

▪ Monthly sweeping of the lot

▪ Special care with seal-coating and power-washing

8. Prevent Parking Lot Pollution

Activity: Inspect Pollution Prevention Practices at all Fueling Areas at the Site

Benchmarks▪ Cover Fueling Islands

▪ Dry Spill Response Kits

▪ Redesign Flows to Prevent Storm Drain Entry

9. Prevent Spills at Fueling Areas

Activity: Assess seasonal operations at the site with the potential to produce polluted runoff or wash-water out of the storm drain system

Benchmarks

▪ Review winter snow removal and salting and salt storage

▪ Off-site truck washing▪ Block storm drains when doing

outdoor washing/hosing

10. Seasonal Operations/Outdoor Wash-water

Activity: Investigate where vehicles are repaired/maintained to make sure fluids and other pollutants do not reach storm drain system

Benchmarks:▪ No outdoor truck

repairs

▪ Check indoor shop drains

▪ Proper fluid disposal/recycling practices

11. Vehicle Repairs and Fluids

Activity: Walk the site to find areas of greatest spill risk,, and critically evaluate how to improve plant spill capability

Benchmarks:

▪ Provide spill kits at high risk areas of site

▪ Update emergency contact numbers

▪ Create an unannounced “fake” spill

12. Evaluate Spill Control and Response

Activity: Walk the site to look for materials stored outside on a temporary or permanent basis that could come into contact with rainfall

Benchmarks:▪ Place materials on pallets▪ Temporary cover ▪ Secondary containment

and berms ▪ No streak or stain lines on

way to storm drain

13. Prevent Runoff From Outdoor Storage

Activity: Walk the site to look for dumpster/compactor juice and spillage

Benchmarks:▪ Dumpster covered, have lids

and are water tight ▪ Schedule pickups with solid

waste contractors frequently ▪ Disconnect dumpsters from

storm drain

14. Exterior Dumpster Management

14. Exterior Dumpster Management

Activity: Inspect the open and landscaped areas of the site and look for opportunities to stormwater treatment or convert turf to trees

Benchmarks:

▪ Evaluate all turf and landscaping for potential for:

▪ Reduced Mowing▪ Soil Restoration▪ Reforestation▪ Filter Strips▪ Rain Gardens

▪ 1 point for each 3% turf converted

15. Turf Management and Conversion

Activity: Do a quick retrofit reconnaissance investigation to identify possible locations to treat runoff from al or part of the parking lot, and retain an engineering consultant to assess the feasibility and cost of building them.

16. Investigate Parking Lot Retrofits

Activity: Modify landscaping contracts to reduce inputs of fertilizer, pesticides and water

Benchmarks▪ Reduce fertilizer &

pesticides ▪ Avoid herbicides on

fence lines▪ Shift to stormwater as

source of irrigation water

▪ Use native species in landscaping

17. Adopt Green Landscaping Practices

Benchmarks:▪ Look for dry weather flow ▪ Do outfall investigation▪ Trace the source and fix it

Activity: Follow the storm drain system until it outfalls to a ditch or stream and look for evidence of illicit discharges or dry weather flow

18. Check for Dry Weather Flows in Drain

Activity: Check all storm drain inlets, sumps and stormwater best management practices (if present) for excessive sediment accumulation.

19. Regularly Maintain Stormwater Infrastructure

Benchmarks▪ Perform semi-annual maintenance

inspection of your stormwater infrastructure

▪ Clean out storm drain inlets annually

▪ Perform recommended maintenance on any stormwater treatment practices

Activity: Assess the condition and habitat needs of any forests, wetlands, buffers or conservation areas present at the site and to improve their ecological function and diversity

Benchmarks:

▪ Resource inventory and mapping

▪ Implement conservation and restoration practices

20. Natural Area Conservation

Activity: Meet with a local or regional watershed group to find ways to strengthen their efforts through volunteer work, product donations, board service or other measures

Benchmarks:

▪ Meet at least once with the local or regional watershed group

▪ Provide tangible evidence of support to the group in first year

21. Become a Local Watershed Partner

Activity: Walk the closest thousand feet of stream to the bottling facility with safe access to identify need for stream cleanup or adoption

Benchmarks:

▪ Take employees on a stream walk at the nearest accessible stream segment

▪ Help plan a stream cleanup or adoption for that segment with the local watershed organization

22. Stream Walk and Cleanup

Interpreting Your Initial Score

Score Rating Comments

95 to 100 Excellent Congratulations…Your activities and practices make you an industry leader in stormwater compliance…you go way beyond the minimum and deserve recognition in your community

85 to 94 Good Great Start…You run a good clean operation and only have a handful of areas for improvement to meet the goal

75 to 84 Fair Needs Work…Although you are doing a lot of things right, there are many areas where you can do more

65 to 74 Poor Not so Good. Your site is probably a hotspot for stormwaterpollution….and your team needs to get cracking to get the work done to meet the standard.

35 to 64 Very Poor Shame on You: Your site is probably a severe hotspot and you are almost certainly noncompliant with your stormwaterpermit. The team and plant manager need a real action plan

Less than 35 Unacceptable Shred the Evidence (just kidding): Your site is truly bad and you are exposing your company to regulatory risks, fines and citizen suits! Improving your score should be an immediate facility wide priority

Webcast Resourceswww.chesapeakestormwater.net

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Title of Resource Web link

CSN Benchmarking Tool http://chesapeakestormwater.net/2012/12/technical-

bulletin-no-7-stormwater-pollution-benchmarking-tool/

[Webcast] Stormwater Pollution

Prevention Plans

http://chesapeakestormwater.net/events/webcast-

swppp-training-monitoring/

USWR Manual 9: Municipal

Practices and Programs

https://owl.cwp.org/mdocs-posts/urban-subwatershed-

restoration-manual-series-manual-9/

Pollution Prevention/Good

Housekeeping for Municipal

Operations: A Guidance Document

of Best Management Practices and

Inspection Checklists

https://www.epa.gov/sites/production/files/2015-

11/documents/guidance_document.pdf

“Dumpster Juice” Disposal Fact Sheet https://www.hamiltoncountyhealth.org/wp-

content/uploads/dumpster.pdf

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