CT DEEP MS4 Permit & Good Housekeeping Practices Eastern CT - - PDF document

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CT DEEP MS4 Permit & Good Housekeeping Practices Eastern CT - - PDF document

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1/22/2020 January 22, 2020 CT DEEP MS4 Permit & Good Housekeeping Practices Eastern CT Stormwater Collaborative ENVIRONMENTAL | ENGINEERING | COMPLIANCE Why are we here? Many of the small towns in CT are covered under the CT

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ENVIRONMENTAL | ENGINEERING | COMPLIANCE January 22, 2020

CT DEEP MS4 Permit & Good Housekeeping Practices

Eastern CT Stormwater Collaborative

CT DEEP MS4 Permit & Good Housekeeping Practices

Why are we here?

  • Many of the small towns in CT are covered

under the CT DEEP General Permit for the Discharge of Stormwater from Small Municipal Separate Storm Sewer Systems (MS4 Permit)

  • This permit is the local enforcement mechanism
  • f the US EPA NPDES Stormwater Phase II

Rule

  • Pollution Prevention and Good Housekeeping is
  • ne of the 6 Minimum Control Measures of the

permit

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CT DEEP MS4 Permit & Good Housekeeping Practices

What is Stormwater & why do we care about it?

  • Runoff from rain and

snowmelt that flows

  • ver impervious

surfaces instead of soaking into the ground.

  • Storm drains/pipes can

carry pollutants in runoff to the nearest body of water.

CT DEEP MS4 Permit & Good Housekeeping Practices

Why is Stormwater runoff a problem?

Flooding

  • Overland and stream

flooding=damage to property and yards, stream erosion

Pollution

  • Pollutants can impair

aquatic ecosystems

  • Potentially harm drinking

water sources

  • Impact waterbodies used

for recreation.

First photo: iiseagrant.org

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CT DEEP MS4 Permit & Good Housekeeping Practices

Sources of Stormwater Pollution

Stormwater runoff can pick up debris, chemicals and other pollutants as it flows into storm drains, piping and into waterways.

Sources:

  • Debris/Garbage - solids
  • Oils & Grease
  • Metals
  • Other Chemicals
  • Sediment
  • Stormwater Pollutants of

Concern (POC)

– Bacteria – Nutrients-Nitrogen & Phosphorus

Photo: freewebs.com CT DEEP MS4 Permit & Good Housekeeping Practices

Pollution from Soil Erosion

Satellite image of sediment pollution in CT River post Hurricane Irene – August 28th 2011 Sediment carries a heavy amount

  • f silt. Heavy silt

concentration forms a large sandbar near the mouth.

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CT DEEP MS4 Permit & Good Housekeeping Practices

Presentation Outline

  • Stormwater Management Plan (SMP)
  • MS4 Permit 6 Minimum Control Measures

– Definition of illicit discharges and improper disposal and Best Management Practices (BMPs) & Procedures – Pollution Prevention and Good Housekeeping BMPs

  • Spill response protocols and potential

responsibilities of involved personnel

CT DEEP MS4 Permit & Good Housekeeping Practices

Stormwater Management Plan (SMP)

  • designed to reduce the discharge of pollutants from

the MS4

  • utlines a program of best management practices

(BMPs), measureable goals, responsible individuals

  • r departments, and implementation schedules for

6 Minimum Control Measures (MCMs)

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CT DEEP MS4 Permit & Good Housekeeping Practices

Impaired Waters

  • The goal of the permit and the SMP is to protect water quality

in general and in the Town’s waterbodies.

  • SMP includes a list of each Town’s waterbodies already

impaired due to pollution and their associated Pollutants of Concern.

  • The permit’s goals and objectives are focused in these areas.

CT DEEP MS4 Permit & Good Housekeeping Practices

MS4 Permit – 6 Minimum Control Measures

  • Public Education and Outreach
  • Public Participation and Involvement
  • Illicit Discharge Detection and Elimination
  • Construction Site Runoff Control
  • Post-Construction Runoff Control
  • Pollution Prevention and Good Housekeeping
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CT DEEP MS4 Permit & Good Housekeeping Practices

MCM-1 Public Education & Outreach

Goals:

  • Raise public awareness that polluted runoff is the

most significant source of water quality problems

  • Motivate residents to use BMPs that reduce polluted

runoff, and

  • Reduce polluted stormwater runoff in town as a

result of increased awareness and utilization of BMPs BMPs:

  • Implement Public Education Program
  • Address education/outreach for pollutants of

concern

CT DEEP MS4 Permit & Good Housekeeping Practices

MCM-1:Examples of BMPs

  • Stormwater management info on website
  • Educational materials (pamphlets) for residents,

developers and contractors

  • Outreach activities for schools
  • Distribute information on common sources of

phosphorus, nitrogen and bacteria and how to reduce these pollutants in runoff

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CT DEEP MS4 Permit & Good Housekeeping Practices

Pollutants of Concern

CT DEEP MS4 Permit & Good Housekeeping Practices

MCM-2: Public Involvement & Participation

Goals:

  • Involve the community in planning and

implementing the Town’s stormwater management activities BMPs:

  • Comply with posting public notice requirements for

the SMP & Annual Reports

  • Regular Cleanups at Parks by Conservation

Commission

  • “Household Hazardous Waste Day” Events
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CT DEEP MS4 Permit & Good Housekeeping Practices

MCM-3: Illicit Discharge Detection & Elimination (IDDE)

Goal:

  • Find the source of illicit discharges (IDs); eliminate; & ensure
  • ngoing screening/tracking to prevent & eliminate future IDs

BMPs:

  • Written IDDE Plan
  • List & Map of all MS4 outfalls/interconnections
  • Develop citizen reporting program
  • Establish legal authority to prohibit ID
  • Develop record keeping system for IDDE
  • Address IDDE in areas with POC
  • Detailed MS4 infrastructure mapping

CT DEEP MS4 Permit & Good Housekeeping Practices

What is an Illicit Discharge?

  • Unpermitted discharge that does not consist entirely
  • f stormwater or uncontaminated groundwater
  • Can be consistent or intermittent
  • Direct or indirect
  • Examples:
  • Illegal floor drain connection
  • Illegal sewage connections
  • Leaking sanitary sewers and SSOs
  • Failing septic system overflow
  • Spills and dumping
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CT DEEP MS4 Permit & Good Housekeeping Practices

Illicit Discharge = anything that’s not stormwater

CT DEEP MS4 Permit & Good Housekeeping Practices

Restaurant Grease

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CT DEEP MS4 Permit & Good Housekeeping Practices

Paint Dumped in Street or Drain

CT DEEP MS4 Permit & Good Housekeeping Practices

IDDE Best Management Practices & Procedures

  • Evidence of illicit connections – hard piped connections, dry

weather flows, wet weather flows with odor, discoloration, or evidence of sewage.

  • Evidence of illicit dumping – staining or discoloration near storm

drains, empty containers, hoses, etc.

  • Report to supervisor or Public Works Department immediately
  • Take notes (date, time & location), photographs
  • Public Works Dept. fills out record keeping tracking sheet
  • Follow procedures in written IDDE Plan – sampling, investigation,

source isolation and confirmation and removal/elimination, and in accordance with timeframes in the permit

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CT DEEP MS4 Permit & Good Housekeeping Practices

MCM-4: Construction Site Stormwater Runoff Control

Goal:

  • Minimize polluted stormwater runoff from

construction sites and prevent it from carrying sediment into waterways via MS4 infrastructure BMPs:

  • Implement, upgrade & enforce land use regulations

to meet permit requirements

  • Development & implement plan for

interdepartmental coordination of site plan review and approval

CT DEEP MS4 Permit & Good Housekeeping Practices

MCM-4 Construction Site Stormwater Runoff Control

BMPs (continued):

  • Review site plans for stormwater quality concerns
  • Conduct site inspections
  • Implement procedure to allow public comment on

site development

  • Implement procedure to notify developers about

DEEP’s construction stormwater permit

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CT DEEP MS4 Permit & Good Housekeeping Practices

Sediment Erosion from Construction

CT DEEP MS4 Permit & Good Housekeeping Practices

Sediment Control

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MCM-5: Post-Construction SW Management in New Development or Redevelopment

Goal:

  • Mitigate the long term impacts of new and re-

development projects on water quality through proper use of low impact development and runoff reduction practices BMPs:

  • Establish legal authority & guidelines regarding LID &

runoff reduction in site development planning

CT DEEP MS4 Permit & Good Housekeeping Practices

MCM-5 Post-Construction SW Management in New Development or Redevelopment

BMPs (continued):

  • Enforce LID/runoff reduction requirements for

development and redevelopment projects

  • Implement long term maintenance plan for stormwater

basins and treatment structures

  • Directly Connected Impervious Area (DCIA) calculations

and mapping

  • Address post-construction issues in areas with POCs
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CT DEEP MS4 Permit & Good Housekeeping Practices

MCM-6: Pollution Prevention/Good Housekeeping

Goal:

  • Implement an operations and maintenance program to

prevent or reduce pollutant runoff as a result of municipal operations (from town properties), and to protect water quality BMPs:

  • Develop and implement formal employee training

program

  • Implement MS4 property & operations maintenance
  • Implement coordination with interconnected MS4s
  • Develop/implement program to control other sources of

pollutants to MS4

CT DEEP MS4 Permit & Good Housekeeping Practices

MCM-6: Pollution Prevention/ Good Housekeeping

BMPs (continued):

  • Evaluate additional measures for discharges to

impaired waters

  • Track projects that disconnect DCIA
  • Develop/implement infrastructure repair/rehab

program

  • Develop/implement plan to identify/prioritize

retrofit projects

  • Establish/implement street sweeping program, catch

basin cleaning program, and snow management practices

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CT DEEP MS4 Permit & Good Housekeeping Practices

MS4 Property & Operations Maintenance BMP

Parks & Open Space – optimize the application of

fertilizers by municipal employees, institutional staff, or private contractors on property for which the Town is responsible for Optimization practices:

  • Soil phosphorus testing
  • Reduction of fertilizer use
  • Adhering to manufacturer’s instructions
  • Alternative fertilizer forms
  • Proper storage and application
  • Application schedule and timing

CT DEEP MS4 Permit & Good Housekeeping Practices

Nutrients – Pesticides & Fertilizers

Photos: Chicagotribune.com & chqdaily.com

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CT DEEP MS4 Permit & Good Housekeeping Practices

MS4 Property & Operations Maintenance BMP

Parks & Open Space- Continued

  • SOPs for Pesticide and Herbicide handling, storage,

application and disposal

  • Evaluate reduced mowing frequencies and use of alternative

landscaping materials

  • Establish procedures for management of trash containers at

parks (scheduled cleanings and sufficient #)

CT DEEP MS4 Permit & Good Housekeeping Practices

Debris –Garbage Entering MS4

Photos: vbaltv.com & EPA

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CT DEEP MS4 Permit & Good Housekeeping Practices

MS4 Property & Operations Maintenance BMP

Pet Waste Management – where inappropriate pet waste

practices are apparent and pose a threat to a nearby waterbody:

  • Public education – signage, pamphlets
  • Town owned recreational areas – pet waste baggies and

disposal receptacles

  • Enforcement – increased patrol for violators

CT DEEP MS4 Permit & Good Housekeeping Practices

Pet Waste (Bacteria)

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CT DEEP MS4 Permit & Good Housekeeping Practices

MS4 Property & Operations Maintenance BMP

Waterfowl Management – identify lands where waterfowl

congregate and feeding by the public occurs…which leads to feces deposition (another bacteria source)

  • Public education – signage
  • Discourage congregation of waterfowl or isolate direct

drainage away from storm system and waterbodies

CT DEEP MS4 Permit & Good Housekeeping Practices

CT DEEP Pamphlet

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CT DEEP MS4 Permit & Good Housekeeping Practices

MS4 Property & Operations Maintenance BMP

Town Buildings & Facilities – schools, town offices, police

& fire stations, pools, parking garages (i.e. = town owned or

  • perated)
  • Petroleum and non-petroleum products – evaluate & provide

training for proper use, storage and disposal

– SOPs for Fuel and Oil Handling/Deliveries

  • Spill Prevention Plans in place
  • Dumpster/Waste Management
  • Parking Lot Sweeping
  • No Floor drains connected to the MS4

CT DEEP MS4 Permit & Good Housekeeping Practices

Containers stored outside

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Leaking dumpsters or grease bins

CT DEEP MS4 Permit & Good Housekeeping Practices

Leaking dumpsters or grease bins

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CT DEEP MS4 Permit & Good Housekeeping Practices

Cover Dumpsters

  • Keep dumpsters and roll-offs

closed at all times

  • Check area for spills &

clean up

CT DEEP MS4 Permit & Good Housekeeping Practices

No hot tubs or pools drained to street

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CT DEEP MS4 Permit & Good Housekeeping Practices

MS4 Property & Operations Maintenance BMP

Vehicles and Equipment – Establish procedures for storage

  • f town-owned or operated vehicles
  • Require leaky vehicles to be stored indoors or in a contained

area

  • Evaluate town-owned fueling areas – if possible place fueling

areas under cover, fueling SOPs

  • Ensure vehicle wash waters are not discharged to MS4 or

surface waters

  • Ensure interior floor drains are appropriately permitted, and

do not connect to the stormwater system

CT DEEP MS4 Permit & Good Housekeeping Practices

MS4 Property & Operations Maintenance BMP

  • Oil/Water Separators

– Semi-annual inspections, at a minimum – Cleaning at least 1x/year

  • Licensed OWS maintenance company
  • Materials removed disposed of properly

– Maintain a log of inspections, cleanings and service

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Leaking vehicles & spills

CT DEEP MS4 Permit & Good Housekeeping Practices

Wash Vehicles in a Wash Bay

  • Wash area must drain to sanitary sewer
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MS4 Property & Operations Maintenance BMP

Leaf Management –minimize or prevent the deposition of leaves in catch basins, streets, or other paved surfaces that discharge to the MS4. This also applies to leaves collected by the Town.

  • Proper disposal of leaves and grass clippings at town
  • wned lands

CT DEEP MS4 Permit & Good Housekeeping Practices

Debris – Leaves/Sticks

Photos: cjsweep.com & NOLA.com

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CT DEEP MS4 Permit & Good Housekeeping Practices

Catch Basin Inspection and Cleaning Program BMP

  • At least once by end of 3rd year of permit in priority areas,

and by the end of 5th year for CBs outside or priority areas

  • More frequently if excessive sediment
  • Prioritize if catchment drains to an impaired waterbody, near

construction activities

  • Ensure meeting 50% goal
  • Procedures (record findings, work upstream to downstream,

keep a log)

  • Proper disposal of catch basin cleanings
  • Documentation in Annual Report

CT DEEP MS4 Permit & Good Housekeeping Practices

Street Sweeping Program BMP

  • Streets and parking lots within priority areas inspected, swept

and/or cleaned at least 1x/yr in spring

  • More frequent if presence of construction activity or potential

pollutant sources

  • If outside priority areas either meet criteria above or develop

and implement a targeted plan by July 1, 2018

  • Conducted during dry weather, minimizing the use of water
  • Proper disposal of street sweepings
  • Documentation in Annual Report (curb miles swept,

volume/mass material, reuse/disposal method, etc)

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CT DEEP MS4 Permit & Good Housekeeping Practices

Snow Management Practices BMP

Deicing Material Management

  • SOPs for the use, handling, storage, application and disposal

(salt and sand)

  • Minimize use and optimize application of chloride-based

products

  • Secondary containment (110% largest, 10% total volume)

CT DEEP MS4 Permit & Good Housekeeping Practices

Snow Management Practices BMP

Snow and Ice Control Practices

  • SOPs for snow and ice control to minimize discharges to stormwater
  • Establish goals for optimization of application rates
  • Maintain records of the application to document the reduction of

chemicals to meet goals

  • Training
  • Manage and dispose of snow in accordance with DEEPs Best

Management Practices for Disposal of Snow Accumulations from Roadways and Parking Lots

  • Document in Annual Report
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Additional Measures for Discharges to Impaired Waters

Waters with POC = Nitrogen or Phosphorus:

  • On town owned or operated lands, implement a turf

management practices and procedures policy

  • Procedures for proper fertilizer application
  • Planting of native plant materials to lessen the amount of turf area

requiring mowing and the application of chemicals

Waters with POC = Bacteria:

  • On town owned or operated lands with high potential to

contribute bacteria, develop, fund, implement and prioritize a retrofit or source management program to correct the problem(s)

CT DEEP MS4 Permit & Good Housekeeping Practices

Spill Response Protocols

  • Each Town should have an Emergency Procedures Flow Chart

for spills/releases of chemicals or oils

  • Town Staff should be trained in spill response procedures and

respond to the spill if it can be absorbed, neutralized or

  • therwise controlled
  • Reporting
  • Prevention

– Inspections – Containment – Maintenance

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Call 911 for emergency discharges!

  • Can the spill be

controlled without jeopardizing health and safety?

CT DEEP MS4 Permit & Good Housekeeping Practices

Solutions

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CT DEEP MS4 Permit & Good Housekeeping Practices

Solutions

CT DEEP MS4 Permit & Good Housekeeping Practices

Spill Clean Up

  • Have a stocked spill kit readily

available

  • Clean up spill promptly
  • Control the source
  • Contain spill
  • Absorb spill
  • Dispose of used materials properly
  • Report spills
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CT DEEP MS4 Permit & Good Housekeeping Practices

Spill Response

CT DEEP MS4 Permit & Good Housekeeping Practices

Sources & Resources

  • Portions of this presentation, including photos without sources listed, were taken

from the Training Presentation “Stormwater 102: Stormwater Pollution Prevention for Facility Maintenance Employees” and can be found at https://www.pacepartners.com/program-areas/water/municipal-stormwater-

  • perations/#1528829690034-cdef0c08-5007
  • General Permit for the Discharge of Stormwater from Small Municipal Separate

Storm Sewer Systems

  • IDDE Workshop Materials found at https://nemo.uconn.edu/ms4/tasks/idde.htm
  • SOPs found on https://www.centralmastormwater.org/toolbox/pages/standard-
  • perating-procedures
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CT DEEP MS4 Permit & Good Housekeeping Practices

Questions?

Correne M. Auer Senior Project Engineer HRP Associates, Inc. 197 Scott Swamp Road Farmington, CT 06032 860.674.9570 correne.auer@hrpassociates.com