III'4 Municipal Operations

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III.4 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 OM 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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Pollution Prevention/Good Housekeeping for
Municipal Operations

• 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 MS4
• Ensure new flood management projects assess
  impacts on water quality

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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 Cleaning
• Stormwater Management Structures

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Infrastructure Mapping and Characterization

• 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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Infrastructure Mapping and Characterization

• 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 municipalitys 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 municipalitys 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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Chemical and Hazardous Material Use and Disposal

• 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?

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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 Sweeping
• Public Streets, Roads, and Highways Maintenance
• Deicing 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 Staff
• Standards for Contracted Services Staff
• Training 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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Pesticides, Herbicides, and Fertilizer Application

• 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?

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In-Field Activities

• The primary in-field evaluation activity is an
  inspection of the permittees 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)

T I P 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

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1. Poor housekeeping practices paint cans left
exposed
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2. . Batteries and drums left exposed to
stormwater
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3. Poor housekeeping practices sloppy road
paint storage
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4. Poor housekeeping practices failure to
clean storm drain inlets
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5. Poor housekeeping practices failing to
clean storm drain inlets
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6. Wastewater discharge to the MS4
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7. Clear signage for employees
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8. Stormwater treatment practices in-use and
maintained
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9. Stockpiles covered
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10. Stockpiles covered
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11. Catch basin cleaning
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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

• CASQAs 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/p
  rogram-areas/pollution_prevention/CD/Version_1/P2_
  Training_ Materials.asp