Pollution Prevention/Good Housekeeping Program Development • Guidance on scoping and developing a pollution prevention/good housekeeping program • Our approach: Use a seven step process to rapidly identify, prioritize and investigate municipal operations to determine what improvements can be made • Remember, the approach can be tailored to the needs of and resources available to your http: / / www.cwp.org community 34
Program Program Program Development Development Development Process Process Process
Step 1: Identify Existing Municipal Operations • Purpose – Scope the program • Key tasks – Inventory and categorize existing municipal operations 36
Park and Landscape Street Repair and Maintenance Maintenance Residential Employee Stewardship Hotspot Facility Training Management Street Sweeping Storm Drain Stormwater Hotline Maintenance Response Utility Maintenance 37
Step 1: Identify Existing Municipal Operations • 10 major municipal operations that can impact stormwater quality: – Hotspot Facility Management – Construction Project Management – Street Repair and Maintenance – Street Sweeping – Storm Drain Maintenance – Stormwater Hotline Response Create a simple list of Create a simple list of Create a simple list of – Park and Landscape Maintenance municipal operations municipal operations municipal operations – Residential Stewardship – Stormwater Management Practice Maintenance – Employee Training 38
Stormwater Hotspots Produce high levels of Produce high levels of Produce high levels of stormwater pollutants stormwater pollutants stormwater pollutants Present a high risk for spills, Present a high risk for spills, Present a high risk for spills, leaks or illicit discharges leaks or illicit discharges leaks or illicit discharges 39
Potential Municipal Stormwater Hotspots • Public Works Yards • Vehicle Storage and Maintenance Yards • Equipment Storage and Maintenance Yards • Water and Wastewater Treatment Facilities • Landfills • Solid Waste Handling and Transfer Facilities • Composting Facilities • Public Buildings (e.g. Schools, Libraries, Police and Fire Departments) • Public Parks • Public Golf Courses • Public Swimming Pools 40
Questions 44
Program Program Program Development Development Development Process Process Process
Step 2: Collect Information About Each Operation • Hotspot facilities: – Location • Street address • Watershed information • Map – Facility type – Facility manager information • All other operations: – Area/locations served Build on list you Build on list you Build on list you • Watershed information created during Step 1 created during Step 1 created during Step 1 • Map – Operation manager information 46
Step 2: Collect Information About Each Operation • Coordinate with operations managers • Learn specific information about the operations they manage • Educate them on: – The requirements of the NPDES MS4 permit Program – The link between municipal Development operations and stormwater quality • Build relationships and cooperation… 47
The Indiana Experience • Statewide move towards coordination – Successful communities: • Have support from elected officials • Develop a communications chart • Define staff responsibilities • Include superintendents and department heads in program planning – Unsuccessful communities: • Are a one man operation • Have no program planning or internal coordination • Have no support from elected officials 48
The Indiana Experience • Statewide move towards coordination – IDEM encourages making employees part of the team: • Consistent training • Eyes in the community (e.g., spill kits & emergency response numbers in vehicles) • Seek input • Recognize outstanding employee performance – Organize efforts through training workshops and partnership building – IDEM has developed an annual statewide stormwater meeting 49
Program Program Program Development Development Development Process Process Process
Step 3: Complete the Municipal Operations Analysis • Desktop assessment to help you focus your housekeeping program • Identify the operations in your community that should be the focus of your initial efforts Moa Constrictor Should be completed by program Should be completed by program Should be completed by program coordinator… …with assistance! with assistance! coordinator ( Moa municipalis ) coordinator…with assistance! 51
Step 3: Complete the Municipal Operations Analysis • Start with a total score of 100 • Answer a series of questions about each operation – Points are deducted from total score when negative answers are given – May require additional conversations with operations managers – May also require site visits • MOA provides a metric for comparing the significance of each operation Manual 9, Page 22 Manual 9, Page 22 Manual 9, Page 22 52
MO ‐ 1: Hotspot Facility Management • How many hotspot facilities are located in your community? • Has basic information been collected about each facility? • Have all the hotspots been the subject of on ‐ site investigations? • Has a pollution prevention plan been created for each facility? 53
MO ‐ 3: Street Repair and Maintenance • Do you have procedures in place that prevent paving materials and other pollutants from entering the storm drain system? • Are road salts and other deicers properly covered and stored? • Is training provided to municipal employees and contractors? 54
MO ‐ 4: Street Sweeping • Do you have a street sweeping program? • Do you schedule sweeping in the spring to pick up sand, salt and other winter debris? • Do you use modern sweeper technology that is capable of picking up fine ‐ grained sediments (e.g. regenerative air, vacuum assist)? 55
MO ‐ 9: Stormwater BMP Maintenance • Is your community responsible for the maintenance of stormwater BMPs? • Has your community established an inspection and maintenance program for these practices? • Is there a dedicated funding source that can be used to fund the program? 56
MO ‐ 10: Employee Training • Do you provide regular pollution prevention training to municipal employees and contractors? • Do you track your employee education efforts? • Have training efforts increased awareness about the link between municipal operations and stormwater quality? 57
Program Program Program Development Development Development Process Process Process
Step 4: Focus Pollution Prevention/ Good Housekeeping Efforts • Identify operations that will become the focus of your initial efforts • List operations in order of how your community will address them based on: – MOA results – Scale of operations – Available resources – Pollutant(s) of concern ‐ identified through watershed planning or other regulations (e.g., TMDLs) 59
The Indiana Experience • Prioritizing good housekeeping efforts – Efforts prioritized based on SWQMP – Analyzing existing operations takes time and is a step that is often skipped; more training on completing the MOA is needed 60
Poll Question #5 • What municipal operation is the top priority in your community? – Hotspot Facility Management – Street Repair and Maintenance – Street Sweeping – Stormwater Management Practice Maintenance – Employee Training – Other 61
Program Program Program Development Development Development Process Process Process
Step 5: Investigate Municipal Operations and Select Source Control Practices • Begin with operation at the top of your list • Identify pollution sources and appropriate control and/or treatment practices 63
Investigative Methods • Use desktop and field assessments to investigate existing municipal operations • Take lots of pictures!!! Municipal Operation Primary Supplementary Hotspot Facility Management MO-1 (9) HSI (11) Construction Project Management MO-2 (9) Street Repair and Maintenance MO-3 (9) Street Sweeping MO-4 (9) SSD (11) Storm Drain Maintenance MO-5 (9) SSD (11) Stormwater Hotline Response MO-6 (9) Park and Landscape Maintenance MO-7 (9) USA (10), PAA (11) Residential Stewardship MO-8 (9) NSA (11) Stormwater Management Practice MO-9 (9) Inspection Maintenance Checklists Employee Training MO-10 (9) 64
Poor Chemical Storage 65
No Secondary Containment 66
Good Secondary Containment 67
Spill 68
The Indiana Experience • Investigating municipal operations – Checklists are essential to collecting information about individual operations – Partnering and sharing resources has been successful, particularly for employee training and self ‐ inspections – Municipal Facility Field Inspection Worksheet has also been helpful 69
Selecting Pollution Source Control and Treatment Practices 70
Step 5: Investigate Municipal Operations and Select Source Control Practices • Once you’ve completed your investigation, summarize your results in an implementation plan: – Basic operation information – Pollution sources – Photographs – Recommended improvements – Measurable goals and implementation milestones – Cost estimate • Develop in coordination with operation manager • Can take form of stormwater pollution prevention plan (SWPPP) 71
Richland Co. Good Housekeeping Program • Result of CAP requirements • Stormwater Pollution Prevention Plans (SWPPPs) for 34 facilities • Spill Prevention Control and Countermeasure Plans (SPCCs) for 6 facilities 72
Richland Co. Industrial Facility SWPPPs • Richland Co. has 4 facilities regulated by the NPDES Industrial Stormwater Program – Richland Co. Landfill – Columbia Owens Downtown Airport – Public Works Maintenance Facility – Broad River Wastewater Treatment Facility • Detailed SWPPPs for these industrial facilities developed in 2006; updated as needed • Certified by plan preparer and facility manager • Implementation in progress 73
Richland Co. Industrial Facility SWPPPs • Contents – Basic facility information – Site map – Potential pollution source assessment – Materials inventory – Record of previous spills and leaks – Risk identification – Pollution source control measures – Total Maximum Daily Load (TMDL) analysis, if applicable – Sampling and monitoring requirements – Inspection and evaluation forms and checklists • Pollution prevention team at each facility – Updated as turnover occurs 74
Richland Co. Industrial Facility SWPPPs • Pollution Source Control Measures – General Housekeeping – Preventive Maintenance – Spill Prevention, Response & Reporting – Non ‐ Stormwater Discharge Assessment & Certification – Pollution Source Control Practices – Sediment & Erosion Control – Post ‐ Construction Stormwater Management – Employee Training – Monthly Inspections – Annual Comprehensive Site Compliance Evaluation – Record Keeping 75
Richland Co. Municipal Facility SWPPPs • General SWPPPs developed for 30 smaller municipal, non ‐ industrial facilities – Fire Stations – EMS Stations – Sheriff Stations – Lower Richland Wastewater Treatment Facility – Lower Richland Drop ‐ off Center – DPW Maintenance Camps • Not required, but developed as a way to better manage pollution at municipal facilities • Semi ‐ annual inspections • Annual comprehensive compliance evaluation 76
Richland Co. SWPPP Resources • All of Richland County’s SWPPP inspection forms, checklists and Standard Operating Procedures are available online at: http://richlandonline.com/departments/publicworks /NPDES_Industrial.asp 77
The Indiana Experience • Stormwater Pollution Prevention Plans – Communities develop SWPPPs along with Fuel Spill Prevention Standard Operating Procedures – IDEM is creating tools to assist in this process • Worksheet for use on self ‐ audits based on the US EPA Program Evaluation Guidance • Recommends adapting and using CWP Guidance – IDEM compliance assistance during facility inspections • Office of Water Quality through coordination with Office of Pollution Prevention 78
Questions 79
Program Program Program Development Development Development Process Process Process
Step 6: Implement Source Control Practices • Work with operation managers to implement prescribed practices Pollution Source Pollution Source Control Practices Vehicle operations (maint.) Drip pans, tarps, secondary containment Vehicle operations (fueling) Covered fueling areas, spill response Outdoor materials (loading) Covered loading/unloading areas Outdoor materials (storage) Secondary containment, inventory control Waste management Liquid/solid separation, covered dumpsters Physical plant (parking lot) Dry clean up methods, street sweeping Turf/landscaping areas Careful pesticide and fertilizer applications Stormwater runoff On-site stormwater retrofit Any Employee training 81
Richland Co. Employee Training Program • Addresses NPDES Phase I permit requirements – Part of CAP requirements • Important part of County’s Pollution Prevention/Good Housekeeping Program • All employees receive annual training on a variety of topics 82
Employee Training Program • Annual training on various topics – Safety FIRST – SWPPPs and SPCCs – Stormwater BMPs (BMP Manual) – Illicit Discharge Detection and Elimination – Industrial Stormwater Discharges and Facility Inspections – Erosion and Sediment Control – Pesticide, Herbicide and Fertilizers Control – Good Housekeeping – Materials Handling – Data Management 83
Employee Training Program • Training materials developed both in ‐ and out ‐ of ‐ house – Decision based on expertise and resources • Example: Brochures for various activities and operations • Training materials available online: http://richlandonline.com/departments/publicworks /NPDES_Industrial.asp 84
Training…Beyond Employees • Demonstrates municipal leadership • Examples – Developers conference – Industrial operators conference – Carolina Clear Program Stormwater Consortium events Lead Participation by Target Service Activity Target Pollutant(s) other Service Geography Provider Providers Partnering for Water Quality sediment, Clemson Carolina presentation to the Chamber of nutrients, bacteria, Richland Cooperative Clear Commerce ‐ how businesses can debris, household County Extension Service, Program get involved in water quality hazardous waste, Richland County protection oil and grease 85
Srini’s Top 10 Training Tips 1. Assign responsibility for conducting employee training 2. Spend some time planning an employee training program and document in stormwater management plan 3. Schedule training events and develop an annual training calendar 4. Provide training at employee orientation and on an annual basis 5. Only properly trained employees should clean up spilled materials; incorporate “spill cleanup” into job descriptions 86
Srini’s Top 10 Training Tips 6. Provide on ‐ the ‐ job training 7. Explain the reason for the training and why it is important; don’t just tell an employee what to do (i.e., ownership stake) 8. View employee training program as a “living” program; revise as necessary 9. Make records and track training activities for reporting purposes 10. Document, Document, Document! 87
Questions 88
Program Program Program Development Development Development Process Process Process
Step 7: Evaluate Progress in Implementation • Important, but often overlooked step in the process • Annual (or more frequent) review of measureable goals and implementation milestones – Can also use to satisfy NPDES MS4 permit reporting requirements – Use results to revise and improve program 90
Step 7: Evaluate Progress in Implementation • Variety of methods can be used – Implementation surveys – Program effort – Employee awareness surveys – Water quality surveys • Find an effective way to figure out what’s been done and what still needs to be done… 91
The Indiana Experience • Evaluating progress in implementation – MS4s are required to establish specific reduction percentages and timetables – Reductions are identified in each individual SWQMP – MS4s demonstrate at evaluations, with proper documentation, that reduction goals have or have not been met – Better recordkeeping equals easier evaluation process 92
Program Program Program Development Development Development Process Process Process
Budgeting and Scoping Your Effort • Decent planning level estimates can be obtained using a two step process: – Develop measurable program goals and implementation milestones – Estimate level of effort required to meet measurable goals • Program goals should be consistent with: – Program resources – Existing practices and programs – Scope and diversity of municipal operations See Manual 9 for Guidance See Manual 9 for Guidance See Manual 9 for Guidance 94
Manual 9, Page 17 ‐ 18
Manual 9, Page 20
Reggie’s Top 11 Program Building Tips 1. Develop interest and support from elected officials 2. Develop support from department heads and superintendents 3. Develop a communications chart and assign responsibilities 4. Internal pollution prevention team should meet on a regular basis 5. Engage employees and recognize their contributions; they are the eyes of the community 97
Reggie’s Top 11 Program Building Tips 6. Provide regular employee training 7. Develop partnerships with other MS4s; maximize funding 8. Develop partnerships with SWCDs and watershed organizations 9. Document, document, document! 10. Never be afraid to ask for help 11. Use existing materials and resources; don’t re ‐ invent the wheel 98
Resources • Last installment of USRM series • Resource for building pollution prevention/good housekeeping programs • Information on: – Municipal operations – Pollution prevention/good housekeeping practices – Program scoping and development http: / / www.cwp.org • Also see Resource List 99
Resources • Operations and facilities notebooks, example SWPPPs and educational posters developed by the North Texas Council of Governments: – http://www.nctcog.org/ – http://www.nctcog.org/envir/SEEclean/stormwater/program ‐ areas/pollution_prevention/index.asp • SWPPP and employee training materials developed by Richland Co., South Carolina: – http://richlandonline.com/departments/publicworks/ NPDES_Industrial.asp – http://richlandonline.com/departments/publicworks/ NPDES_Industrial.asp 100
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