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Municipal Stormwater Illicit Discharge Programs, Stormwater System Maintenance and Management, and Recent Regulatory Developments
The document discusses the management and regulatory aspects of municipal stormwater systems, emphasizing the importance of asset management, maintenance programs, education on illicit discharges, and evolving regulatory frameworks. It outlines best management practices, the benefits of green infrastructure, challenges in implementation, and the need for community education to promote compliance and cooperation. Additionally, it highlights the shift from traditional stormwater management approaches to more sustainable practices that treat runoff as a resource.
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Municipal Stormwater Illicit Discharge Programs, Stormwater System Maintenance and Management, and Recent Regulatory Developments
- 1. Municipal Stormwater IllicitDischarge Programs, Stormwater System Maintenance and Management, and Recent Regulatory Developments September 25, 2014
- 2. Panel Ryan Janoch,PE Mapistry Wendy Manley, Esq. Wendell Rosen Black & Dean LLP Jamie Cint GaiaTech
- 3. Overview ●Asset Management ●Maintenance Program ●Treatment Considerations ●Illicit Discharges ●Education and Outreach Programs ●Paradigm Shift of Stormwater Management ●Regulatory Controls ●Cost & Funding Challenges
- 4. Asset Management andMaintenance Ryan Janoch, PE
- 5. NPDES MS4 Permits Phase II 1999 small cities Phase I 1990 cities pop.100,000+
- 6. Stormwater Management Plans(SWMP) ●Both Phase I and II ●Annual report ●Monitor discharges/streams ●Use Best Management Practices (BMPs)
- 7. Asset Management ●Permitrequired ●Field data collection - maintenance crews, staff, consultants, and citizens ●New records and update existing records ●Consistency in naming conventions ●Training field teams
- 8. Field Data Collection ●What is the necessary info? ●Who does the collection? ●How to collect it? ●Where is it stored? ●What do we do with it?
- 9.
- 10. Benefits of GoodAsset Programs ●Targeted maintenance ●Plan for repairs and upgrades ●Better models (e.g. planning, expansion, upgrades) ●Reduce long-term maintenance costs ●Permit compliance
- 11. Example: SF BayRegion Phase I MS4 1.Develop and publicize a stormwater system map 2.Conduct surveys on at least one waterbody each year 3.Submit an annual Urban Creeks Monitoring Report with maps of sampling locations and data for a waterbody 4.Submit an annual Pilot Green Streets Program Report showing drainage areas treated by Low Impact Development (LID) controls
- 12. Example: SF BaySmall MS4 (Phase II) Map Requirements 1.Outfall locations (coordinates and ID) 2.Receiving waterbody locations 3.Priority areas (e.g industrial/commercial) 4.Field sampling locations 5.Permit boundary
- 13. Maintenance Programs ●Startwith system maps (planning) ●Routine - set schedule and stick to it ●Non-routine - as-needed based on complaints and inspections ●Update records on site (photos, notes) ●Documentation (records)
- 14. Treatment Considerations ●Long-TermMaintenance Costs ●Constituents of Concern (metals, TSS, trash) ●Flow reduction ●Size constraints ●Capital Costs ●Aesthetics
- 15. Treatment Options •Bioretention •Underground Storage •Infiltration •Hydrodynamic Separators •Media Filtration •Retention Ponds •Swales
- 16. Compliance and Benefitsof Education: Stormwater Ponds and Illicit Discharges Jamie Cint
- 17. My Experience asan Inspector •24 years of inspecting •Education/certifications not required to inspect industrial facilities •Inspectors and regulators not trained on how to educate the community
- 18. Inspector Experience #1 Most people do not know what the following are: ●stormwater ●illicit discharge ●best management practice (BMP) ●National Pollution Discharge Elimination System (NPDES) Municipal Separate Storm Sewer System (MS4) permit
- 19. Inspector Experience #2 Some that believe that the stormwater system (e.g. curb inlets, infrastructure, drainage ditches) drains to the sanitary sewer system and stormwater is treated
- 20. Inspector Experience #3 Many look at what they are doing to the environment (e.g. wash water, cigarettes, drinks, trash, pesticides) as minor. (It can’t be that bad, its only a….)
- 21. Education is aBMP Stormwater education programs are to inform citizens, commercial, and industrial facilities about: ●their permit requirements ●importance of stormwater pollution prevention ●environmental impact of stormwater runoff ●methods to reduce environmental impact
- 22. Illicit Discharge Education Illicit (illegal) discharges Examples: motor oil, grass clippings, sediment, pet waste, pool water Stormwater Discharges “Nothing goes in the drain but rain!!” Certain “Allowable” Non-Stormwater Discharges
- 23. Allowable Non-Stormwater Discharges ●Uncontaminated groundwater ●Foundation drains ●AC condensate (no added chemicals) ●Uncontaminated potable water ●Waterline and fire hydrant flushing ●Irrigation water or lawn watering runoff ●Exterior building wash water (no detergents)
- 24.
- 25. The Good…. theBad… and the Ugly!!
- 26. What do wefind at Industrial Facilities? Best Management Practices Employee Training Spill Prevention and Response Good Housekeeping Preventative Maintenance Program On-site Contractor Responsibilities Exposure Minimization Daily Visual Observations Scrap Material Storage and Salvage Management of Runoff
- 27. One on OneTraining •During baseline visit •Walk the entire site - every corner •Boldly go where no person has gone before! •Point out the good, the bad, and the ugly •Daily, quarterly, and annual visits get easier
- 28. Cooking Grease WasteProcessing •Daily odor violations and complaints about the staining •Contaminating the stream (200 feet from the building) •Department going there for ten years with little results •I was requested by another department in the county •By the first hour, the owner asked if I had to be there ☺
- 29. The Bad andthe Ugly
- 30. The Good andthe Kick Butt
- 31. Commercial and Residential ●Education is more difficult ●They don’t want to hear what they can and cannot do at their facility or at home ●Education material and information does help ●Many do not know what is hazardous waste
- 32. Brochures and InformationPackets
- 33. What is ahazardous substance?
- 34. Biodegradable and No.1 in Litter What does biodegradable mean? Capable of being broken down by microorganisms Per the USEPA, for 1 ounce of biodegradable soap to be safe for fish it has to be diluted by almost 20,000 ounces of water (156.25 gallons) Per the USEPA, what is the most number one littered item in America? Cigarette butts
- 37. Storm Water PondsCommercial, Residential, and Landscapers •Commercial and residential areas have detention or retention ponds •Most HOAs and commercial owners have no idea what the purpose of a stormwater pond is or how to maintain it properly •How to educate instead of giving violations? ◦College extension office ◦HOA meetings ◦Maintenance companies
- 38. Retention & DetentionPonds Retention Ponds (wet) Retain water and have a permanent pool of water Detention Ponds (dry) Detain water 24-48 hours after a rain event then are dry again.
- 39. Landscaper Enforcement LeavesBlown into the Creek Leaves in the Manhole
- 40. With Education ComesGreat Responsibility and Commitment Education takes a lot of time and effort Training Preparation Streamline your program Offer classes to industry Target violators such as landscaping companies, pool installers, HOA, contractors…
- 41. Benefits of Education •Less violations •More cooperation •Promote financial growth (e.g. landscapers, clean up companies) •Less contaminated stormwater (e.g. lakes, stream, rivers, oceans) •More recreation in the community (e.g. boating, swimming) •Regulators have a better relationship with the community •It’s fun!
- 42. The Paradigm Shiftof Municipal Stormwater Management Wendy Manley, Esq.
- 43. Hydromodification Evapotranspiration Runoff Infiltration Traditional storm drain design driver
- 44. Paradigm Shift: FromGray Infrastructure … Designed to quickly drain water away from development to prevent flooding.
- 45. Paradigm Shift: …to Green Infrastructure •Designed to mimic natural processes: •Reduce runoff rates and volumes that scour streambeds •Reduce discharge of pollutants to receiving waters
- 46. LID & GreenInfrastructure •Low Impact Development uses site design and storm water management to maintain the site’s pre-development runoff rates and volumes. •Green Infrastructure carries this approach to a larger, community scale and presents similar, sustainable opportunities to local governments and regional projects. SWRCB, Storm Water Management Fact Sheet
- 47. Drivers of Change •Storm Water Permits –Requirements –Monitoring –Numeric Standards •Drought –Strained water supplies –Water efficient landscaping •CA Green Building Code •Carbon emission reductions
- 48. Paradigm Shift: Stormwater:From Waste to Resource •Water Supply –Capture and reuse –Groundwater recharge •Energy savings •Parks and open space •Multi-benefit projects
- 49. Regulatory Framework CleanWater Act Municipal SW Permit Industrial SW Permit Municipality Industrial sites Construction SW Permit Construction sites Development & Redevelopment
- 50. Regulatory Controls &Incentives Examples •LID required where feasible •LID required for first 0.5 inches of precipitation •LID required on development/redevelopment projects that create/replace > 5,000 sq feet impervious surface •TMDLs, Numeric Effluent Limits, •Discounts on SW fees for LID features •Benchmark exceedances allowed where reduced flows lower mass loads to below the mass load at benchmark
- 51. Regulatory Controls SpecificExamples (CA Municipal General Permit) •Concentrate development on portions of the site w/ less permeable soils, preserve areas that can promote infiltration •Replicate the site’s natural drainage patterns •Detain & retain runoff throughout the site •Limit impervious surfaces •Preserve significant trees
- 52. Paradigm Shift:Climate Change •Change over time, & change in the rate of change •Increasing variability •Mentally adjusting to dynamic systems from static (sort of) systems •Sizing projects – shifting targets •Design storms – using running averages
- 53. Municipal Implementation Challenges •Retrofitting existing infrastructure – systematic or piecemeal •On-site features vs. Regional facilities; Watershed planning •Groundwater protection; Water quality standards •Standardized requirements vs. site-specific approaches •Capture and reuse may conflict with water rights •Establishing legally enforceable programs and standards –Ordinances –Contracts –Leases –Construction specifications •Long term maintenance •Lack of technical knowledge
- 54. Costs & FundingChallenges •Project Costs –May be less using LID –Economic benefit - greater market value for green space & “sustainable” development •Municipal Implementation costs –Regulatory (ordinances, permit approvals) –Administrative (collecting fees, tracking, inspections) –Operation & Maintenance •Municipal Funding –Stormwater utilities –Service fees –Legislative funding
- 55. Questions? Ryan Janoch,PE [email protected] Wendy Manley, Esq. [email protected] Jamie Cint [email protected]