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Matthew Lake, M.S., CMS4S - Executive Director
MERRILLVILLESTORMWATER UTILITY
Good Housekeeping Success with Implementing BMPs for Municipal Operations
MCM 6 IDEM AUDIT
PRE-AUDIT PREPARATIONS
Review IDEM MCM 6
audit preparation
worksheet.
Compile all relevant
documentation.
Coordinate with all
departments.
AUDIT PREP WORKSHEET
REQUIRES WRITTEN RECORDS
327 IAC 15-13-17(b)(1) A-F
Written documentation (activities, schedules, inspection) for:
Litter pickup
Structure cleaning
Pavement sweeping
Roadside ditch & shoulder stabilization
Planting/care of roadside shoulder vegetation
Remediation of outfall scouring
327 IAC 15-13-17(b)(2) A-H
Controls and SWP3 to reduce or eliminate pollutants from the following:
Salt/sand storage piles
Snow disposal areas
Containment of polluting materials
SOPs for spill prevention/cleanup during fueling
BMPs for vehicle maintenance
Prohibit vehicle wash water into storm sewers
Minimize pesticide & fertilizer use
Proper disposal of animal waste
327 IAC 15-13-17(b)(3)
Procedures for proper disposal of waste materials removed from separate storm sewer system & operational areas
327 IAC 15-13-17(b)(4)
Documentation of new MS4 owned flood management projects assessed for impacts on water quality
Documentation that existing MS4 owned flood management projects are examined for additional BMP devices or
practices
327 IAC 15-13-17(b)(5)
Written documentation that MS4 employees are properly trained with periodic refresher training
327 IAC 15-13-17(c)
Develop measurable goals for this MCM (reduction percentages, timetables)
MEASURABLE GOALS DOCUMENTATION REVIEW
Provide Measureable Goals for MCM 6?
SWQMP – PART C
Written goals and timelines within
your approved Part C
Review commitments in Part C
Assess performance
Update periodically
Personal program
management goals
Will soon revise list of
goals to reflect
program updates
MANAGEMENT GOALS
Incorporating goals for stormwater
quality:
LID retrofit for existing businesses
(goal = 10 businesses by June
2018)
Wetland enhancement and
expansion (goal = increase wetland
habitat by 10% by June 2018)
Convert mow zones to natraulized
areas (goal 10% area by June
2018)
IDEM CLEAN COMMUNITY CHALLENGE
EMPLOYEE TRAINING DOCUMENTATION REVIEW
Provide employee training, documentation, material used, sign-in sheets, agendas, long term schedule?
EMPLOYEE TRAINING
Keep records of all
relevant training
Include webcasts,
certifications, workshops,
conferences etc…
TRAINING SCHEDULE
Plan future
tentative training
sessions and
target audiences
Ensure to train
new employees
within the first 6
months of hire.
STORMWATER INFRASTRUCTRE DOCUMENTATION REVIEW
Provide mapping and characterization of MS4 system and facility maps with
conveyances/outfalls, catch basin cleaning?
Survey grade
GIS mapping
of municipal
infrastructure.
Recommend
getting
additional
data including
inverts,
material type,
condition etc…
INFRASTRUCTURE MAPPING
FACILITY SITE MAP
Maps identify buildings/structures, materials, inlets,
outfalls, conveyances and receiving waters
Ensure outfalls are
inspected, and dry
weather screened.
Conduct sampling to
detect pollutants of
concern
Characterize outfalls
by cataloging
physical parameters Type
Material
Size
Dimensions
OUTFALL INSPECTION
STRUCTURE CLEANING
Jet Vac Schedule (post in facility)
Training (copy in training log
binder)
Proper debris storage and
disposal
Keep “Maintenance Log Binders”
(keep in vactor truck)
MAINTENANCE RECORDS
Merrillville has 6063 inlets and
804,713 feet of storm drains that
are routinely cleaned with our Jet
Vac and viewed with the camera
truck to assess condition. Video
footage is saved for our records.
Information is utilized to identify and
prioritize routine maintenance
projects
INFRASTRUCTURE MAINTENANCE
After market pipe nozzles can
be 30-50% more efficient than
conventional sewer nozzles.
Removes more debris and
saves time so more drains can
be cleaned.
IMPROVING INFRASTRUCTURE MAINTENANCE
INLET PROTECTION PROJECT FOR MUNICIPAL
FACILITIES & STREETS Permanent inlet treatment devices are
becoming more common for
hydrocarbon filtration.
Requires maintenance, monitoring
and replacement.
Also have vortec separators for new
municipal roadway projects.
FLOOD MANAGEMENT DOCUMENTATION REVIEW
Provide inventory of flood management structures and inspection?
Municipally-owned
detention facilities
are part of MCM 6
Identify and inspect
each facility and
consider options for
BMP retrofits to
enhance stormwater
treatment
MAP AND IDENTIFY ALL DETENTION
FACILITIES
EXISTING DETENTION INSPECTIONS
Hard copies of all inspections are kept in a binder and separated as either municipal or private ownership.
INSPECTION RECORDS
SIGNAGE FOR PONDS AND WATERWAYS
NATURALIZED DETENTION PONDS
Plantings and hydrology shall replicate a more natural environment.
Plantings, including tall prairie grass stands along shorelines of wet ponds, installed as a goose deterrent mechanism.
Different type of O&M compared to traditional basin design.
Total Cost = $2.0 M
Total Flood Storage = 20 acre-ft
TAFT STREET DRAINAGE IMPROVEMENT PROJECT
NATIVE VEGETATION
Project Components Two flood storage basins
Wetland Bottom
20 acre-ft
1,200 linear feet of channel
stabilization
3 major culvert crossing
6’ x 4’ Box culverts
1,400 linear feet of 54-inch
storm sewer
Planted with native wetland
and upland seed mix
Modular plan with drainage studies for each
sub-watershed area identifying proposed
improvements and recommendations
“Grant –Ready”
All data is part of a geodatabase
Project prioritization matrix
Identified and prioritized capital
improvement projects estimated over 24
million dollars
Incorporates stormwater quality!
STORMWATER MASTER PLAN
STORMWATER QUALITY
PROPOSED DRAINAGE & WATER
QUALITY PROJECTS
Stream Restoration
Flood Storage Wetland Basins
Conveyance Improvements
Many communities are
installing/retrofitting green practices to
manage stormwater and increase
sustainability of roadways.
Many are roadway redesign with
adjacent rain gardens.
Public works maintenance will be vastly
different.
How to maintain compared to pre-
construction conditions
GREEN STREETS PROJECTS
BEFORE AFTER
Vegetation Management O&M Before:
Mow area weekly.
Keep grass clippings out of the street.
Vegetation Management O&M After:
GREEN STREETS O&M
BEFORE AFTER
Maintenance Activities for Bioretention Area
Activity Schedule
Supplement normal rainfall (at least 1”/week). Replace plants as needed. Inspect all plants to assess additional needs. Inspect site for proper drainage after each 2” or more rain event. Mow non-woody perennial plant dead stalks/dieback in the spring.
First Season
Prune and weed to maintain appearance. Mulch replacement when erosion is evident. Remove trash and debris.
As needed
Inspect inflow points for clogging (off-line systems). Remove any sediment. Inspect filter strip/grass channel for erosion or gullying. Re-seed or sod as necessary. Trees and shrubs should be inspected to evaluate their health and remove any dead or severely diseased vegetation.
Semi-annually
Inspect and remove any sediment and debris build-up. Inspect inflow points and bioretention surface for build-up of road sand associated with spring melt period. Remove as
necessary and replant areas that have been impacted by sand/salt build up. Mow non-woody perennial plant dead stalks/dieback in the spring.
Annually
Replace mulch over the entire area. The planting soils should be tested for pH to establish acidic levels. If the pH is below 5.2, limestone should be applied.
If the pH is above 7.0 to 8.0, then iron sulfate plus sulfur can be added to reduce the pH. (slow release fertilizer)
2 to 3 years
FACILITY MAINTENANCE DOCUMENTATION REVIEW
Facility SWP3, materials inventory, SOPs for stockpiles, composting, maintenance?
FACILITY SWP3 & INSPECTIONS
Ensure essential aspects of
facility SWP3 for inside the
facility is incorporated such
as spill kits,
vehicle/equipment
maintenance, secondary
containment etc…
Ensure essential aspects of
facility SWP3 for outside of
the facility is incorporated
such as BMPs for
stockpiles, infrastructure,
dumpsters, salt/deicing
materials, vehicle/equipment
maintenance, general
cleanup etc…
VEHICLE MAINTENANCE & FUELING DOCUMENTATION REVIEW
Vehicle maintenance practices, washing, inspections, training, inside drains, spill
kits/response, fueling area BMPs?
Ensure there is a designated area for
vehicle maintenance & proper are for
vehicle washing.
Post all MCM 6 posters, labels etc.
Ensure proper documentation is
collected for any spills.
VEHICLE MAINTENANCE AREAS
VEHICLE FLUID STORAGE/CONTAINMENT
Ensure all vehicle fluids are properly
stored labeled and handled.
Train employees on proper spill response
and documentation
FLOOR DRAINS
All facility drains
are marked, enter
triple basin and
outlets to sanitary
system.
Ensure fueling BMPs
include information
regarding automatic shut off,
spill clean up, protection of
nearby storm drains etc…
PUBLIC STREETS OPERATION & MAINTENANCE DOCUMENTATION REVIEW
Sweeping schedule, SOPs for sweeping, roadside ditch, shoulder stabilization and
vegetation, use and storage of deicing materials, snow disposal areas?
STREET SWEEPING
Street Sweeping Schedule (post in facility)
Keep “Maintenance Log Binders” (keep in each sweeper)
Training (copy in training log binder)
SOP factsheet (post in facility)
Stockpile profiling, proper storage and disposal
SWEEPINGS/DEBRIS PROFILING
Collect composite sample
from stockpile
Send to lab for toxicity
characterization by
testing:
Metals
Cadmium
Chromium
Lead
Volatile Organic Carbons
Benzene
Ethyl benzene
Xylene
Toluene
Complete Special Waste
Profile Form and submit
to contracted waste
hauling company to
classify as non-
hazardous.
CONTROLS TO REDUCE DEICING
POLLUTANTS Alternative Deicing Materials
(Beet Juice “Eco Friendly Deicer”)
Known commercially as GEOMELT, the
beet juice is made from the carbohydrate
extract of sugar beets, and when mixed
for use on roads can reduce the amount
of salt needed by 30%
Salt Spreader Calibration
Covering Stored Equipment
Salt Barn
Loading/Unloading Procedures
Annual Snow Fighter Training
Snow Plow Routes (post in facility)
Keep “Maintenance Log Binders” (keep in
plow truck)
Proper snow disposal areas
Minimize use of fertilizers
Consider no-mow zones
Direct mowers away from
street to minimize grass in
the streets and catch basins.
Consider native vegetation
and low maintenance trees
Properly maintain trees
(natural target pruning)
Ensure public works are properly
pruning trees = “natural target pruning”
Proper cuts are made at a branching node (where one branch is attached to another) just outside the branch collar
Be sure to cut branch tissue and not stem tissue.
Better to cut too far than risk making a flush cut.
ENSURE PROPER PRUNING
CONSIDER LOW MAINTENANCE
Hazard potential - avoid planting
brittle species that are prone to
breakage during storms/ high winds
Ex: Silver Maple, Siberian Elm,
Weeping Willow….
Small leaves/leaflets - reduces
clogging of sewer drains
Ex: Honey Locust, Cypress...
Cultivars - developed for desired
features like resistance to pest &
disease, leaf/flower color, form,
size, lack of fruits…
RIPARIAN ZONE PLANTING – IDNR
GRANT
Survey areas that need
armoring or reconstruction.
Look at alternative green
streets design to change the
profile and cross-section of
the ditch and/or roadway.
Show examples of these
projects during audit.
DELAWARE DRAINAGE PROJECT
Partnership with Public
Works
Enhanced drainage, water
quality and pubic safety
Status: Complete
BRICK LAYER UNION HALL (Marshall St. & Route 30)
Drainage enhancements to
improve drainage for Marshall
St. and Route 30
Status: Complete
IDEM Office of Land
inspects permitted
compost facilities.
Good additional
information to have for
your records and the audit.
COMPOST STOCKPILE
PESTICIDE, HERBICIDE AND FERTILIZER APPLICATION DOCUMENTATION REVIEW
Certifications for application of restricted pesticides/herbicides?
NUTRIENT & PEST MANAGEMENT
Tracking Pesticide and Fertilizer Application
Parks Department
Outsourced
Public Works Department
Larvacide
Certifications?
Adopt Integrated Pest Management (IPM) Strategies
All containers properly labeled
No application within 25’ of storm drain inlet or 50’ of
ditch/water body
No Phosphorus Fertilizers?
Perform a soil testing to determine actual fertilization
needs and application rate
Calibrate fertilizer spreaders to avoid excessive application
Facility SWP3 includes BMPs to minimize negative impacts
to stormwater
GOOD HOUSEKEEPING LABELS
• KEEP OPEN CONTAINERS IN SECONDARY CONTAINMENT
• REGULAR GARBAGE ONLY
• USED OIL
• USED OIL FILTERS
• DON’T TOP-OFF TANKS
• CLEAN SPILLS IMMEDIATELY
• DON’T BLOW GRASS CLIPPINGS INTO THE STREET
• CLOSE LID AFTER USE
• SPILL KIT
• DRIP PANS
• CALIBRATE SPREADER BEFORE USE
• USED ANTIFREEZE
• FILL CONTAINERS IN THIS SECONDARY CONTAINMENT
• CHECK VEHICLE FOR FLUID LEAKS DAILY
• WASH VEHICLES INSIDE BUILDING
• SALT BRINE
• HERBICIDE (FOLLOW MANUFATURER’S SPECS.)
Strategic labeling for daily
reminders
NEXT STEPS
Specialized Resource
Planning, LID/Green Streets
No mow zones/natural areas
management
Eco-friendly Deicing
Urban Forest Management
Land conservation (land
purchase, conservation
easements etc…)
QUESTIONS?
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