September 22, 2015 IDDE & Storm Drain Maintenance Requirements Steve Teravskis, WGR Southwest, Inc.
IDDE & Storm Drain Maintenance Requirements What is an illicit discharge? Non-storm water discharge Not including the list of allowable nonstorm water discharges (ordinance exceptions to discharge prohibition or IGP allowable list)
IDDE & Storm Drain Maintenance Requirements Common Illicit Discharge Sources Dry weather flows containing pollutants and/or pathogens. Unique frequency, composition and mode of entry into the MS4. Sanitary Sewer Overflows (SSOs) Generating sites
IDDE & Storm Drain Maintenance Requirements Common Discharge Flow Types Sewage and septic flows Washwater flows Liquid waste flows Tap water flows
IDDE & Storm Drain Maintenance Requirements Physical Indicators of a potential illicit discharge: Color Odors Turbidity Sheens Floatables Growth Staining or Damage
IDDE & Storm Drain Maintenance Requirements Source investigations Sensory monitoring Indicator monitoring Storm drain network investigations ( trunk investigations) Drainage area investigations On-site investigations Septic system investigation
IDDE & Storm Drain Maintenance Requirements Once the source of the spill / illicit discharge has been determined Attempt to stop the source of the discharge ASAP. Determine the size and scope of potential pollutant impact. Attempt to locate the responsible party (if applicable). Develop specific mitigation measures and timelines for the responsible party (if applicable). Field verify compliance with cleanup & mitigation. Further enforcement (if applicable). Document incident and actions.
IDDE & Storm Drain Maintenance Requirements Phase II MS4 Permit IDDE Timelines Report immediately the occurrence of any flows believed to be an immediate threat to human health or the environment immediately report to the local Health Department. Non-storm water discharges suspected of being sanitary sewage and/or significantly contaminated shall be investigated within 24 hours. MS4s are required to conduct investigations of all other sources of any suspected illicit discharges within 72 hours of becoming aware of the suspected illicit discharge. Prioritize investigations of SSOs and/or significantly contaminated discharges over flows such as cooling water, wash water, or natural flows.
IDDE & Storm Drain Maintenance Requirements MS4 Storm Drain System Maintenance (E.11.g.)
IDDE & Storm Drain Maintenance Requirements During Year 2 MS4s were required to implement procedures to assess and prioritize MS4 storm drain system maintenance. A high priority was to be assigned to catch basins meeting any of the following criteria During Year 3 MS4s are required to begin maintenance on all high priority storm drain systems on an ongoing schedule.
IDDE & Storm Drain Maintenance Requirements Storm Drain System Inspections Starting with drainage areas determined to be high priority develop and implement a system to inspect storm drain systems within the MS4 s jurisdiction. At a minimum, inspect all high priority catch basins and systems annually. Suggested Approach Develop a inspection schedule. Perform inspections of high priority areas first. Don t procrastinate on completing the minimum inspections! Develop, beg, steal, or borrow an inspection form to document inspections.
IDDE & Storm Drain Maintenance Requirements Clean Storm Drains Develop and implement a schedule to clean high priority catch basin and other systems. Frequencies should be set with high priority drainage areas receiving more frequent maintenance. Suggested Approach Develop a maintenance plan and an if/then matrix. Log all maintenance visits (Priority and other). Document type of maintenance performed, amount of material removed, and other observations. Develop, beg, steal, or borrow an inspection form to document inspections.
IDDE & Storm Drain Maintenance Requirements Labeling Catch Basins Each catch basin in high foot traffic areas must be labeled with a legible storm water awareness message such as drains to river or only rain in the drain. Catch basins with illegible or missing labels shall be recorded and re-labeled within one month of inspection. Suggested Approach Add a field onto the outfall inspection form for labels. Create some type of verification that label was re-labeled within 30 days of discovery. In some instances drain labeling is a great way to get your public involved (also a permit requirement).
IDDE & Storm Drain Maintenance Requirements Maintain Surface Drainage Structures High priority facilities, such as those with recurrent illegal dumping, shall be reviewed and maintained annually as needed. Non-priority facilities shall be reviewed as needed. Removal of trash and debris from high priority areas shall occur prior to the rainy season (typically Oct. 1 May 31 st ). Suggested Approach Speak with your senior maintenance personnel to help identify the areas of frequent illegal dumping. Use the data gathered during Year 2 outfall inspections and subsequent inspections to further identify high priority facilities. Document each visit with maintenance performed, condition of facility, and amount of materials removed.
IDDE & Storm Drain Maintenance Requirements Dispose of Waste Materials Develop and implement a procedure to dewater and dispose of materials extracted from catch basins. Ensure water and waste materials removed during catch basin maintenance activities will not reenter the MS4. Suggested Approach Develop written procedures/practices for drain maintenance, vac ops, sweeper ops, and applicable contractor ops. Train staff on procedures and documentation. Ensure staff has adequate proper disposal options. Re-evaluate and replace procedures, equipment, and situation in which wastewater or material is not fully captured.
IDDE & Storm Drain Maintenance Requirements Documentation Priority catch basins, inspections, cleanings, missing labels/30 day applications, pre-season system and facility trash removals, material removal amounts, and dewatering procedures all must be thoroughly documented. Complete documentation will assist with annual reporting, performance effectiveness assessment and improvement evaluations, and audits.
IDDE & Storm Drain Maintenance Requirements Guidance California Stormwater Quality Association s (CASQA s) - California Stormwater BMP Handbook (Municipal) Suggested protocols for various drainage system configurations; Maintenance implementation guidance; Training suggestions; and Implementation costs and man power analysis.
O&M PRACTICES BMP ASSESSMENT O&M Activities/BMP Assessment Requirements (E.11.h.)
O&M PRACTICES BMP ASSESSMENT During Year 3 the MS4 will need to assess their O&M activities for potential to discharge pollutants in storm water, implement BMPs based on pollutant potential, and inspect all implemented BMPs on a quarterly basis.
O&M PRACTICES BMP ASSESSMENT The Permit requires the MS4 to develop and implement a program to assess O&M activities and develop applicable BMPs. To effectively do this each MS4 will need to tabulate O&M activities which they perform.
O&M PRACTICES BMP ASSESSMENT The Permit actually calls out several O&M activities which shall (note: not limited to) be included in the pollutant assessment Road and parking lot maintenance Sidewalk repair Curb and gutter repair Pothole repair Pavement marking, sealing, and re-paving Bridge maintenance (including re-chipping, grinding, saw cutting, and painting)
O&M PRACTICES BMP ASSESSMENT O&M activities which shall be included in the pollutant assessment (Cont.) Cold weather operations: Plowing Sanding Application of deicing compounds Maintenance of snow disposal areas
O&M PRACTICES BMP ASSESSMENT O&M activities which shall be included in the pollutant assessment (Cont.) Right-of-way maintenance: Mowing Herbicide & pesticide application Planting vegetation
O&M PRACTICES BMP ASSESSMENT O&M activities which shall be included in the pollutant assessment (Cont.) Storm water relevant MS4-sponsored or sanctioned events: Large outdoor festivals Parades Street fairs
O&M PRACTICES BMP ASSESSMENT O&M activities which shall be included in the pollutant assessment (Cont.) Green waste deposited in the street Graffiti removal Hydrant flushing
O&M PRACTICES BMP ASSESSMENT Great, we have tabulated our O&M activities now Determine what pollutants are common with each activity. Determine if pollutants are present in current practices. Determine what BMPs are currently being implemented.
O&M PRACTICES BMP ASSESSMENT (Cont.) Determine if currently implemented BMPs are being effective.
O&M PRACTICES BMP ASSESSMENT Hold on Steve, I m still not too sure how to determine my activity s pollutant potential https://www.casqa.org/resources/bmp -handbooks/municipal-bmp-handbook
O&M PRACTICES BMP ASSESSMENT Backside https://www.casqa.org/resources/bmp -handbooks/municipal-bmp-handbook
O&M PRACTICES BMP ASSESSMENT My assessment said I could use some BMPs. Where can I find some ideas? CASQA cut sheets Cut sheets for almost every municipal op Suggested approaches and protocols (BMPs) CASQA Handbook or equivalent required to be used by the MS4 for BMP selection and implementation.
O&M PRACTICES BMP ASSESSMENT To recap we have now Tabulated our MS4 s O&M activities. Assessed all (permit listed and others) O&M activities for potential to discharge pollutant to storm water. Identified all materials that could be discharged from each identified O&M activity and which material may contain pollutants. Developed, implemented, or improved BMPs to reduce pollutants in storm water and non-storm water discharges.
O&M PRACTICES BMP ASSESSMENT And finally The MS4 shall evaluate all BMPs implemented during O&M activities quarterly. Develop a system for the evaluation (responsible person, triggers, reminders) Document the evaluation and corrective actions