SCM Inspection and Maintenance Certification · 7/9/2020 · The owner/operator shall maintain...

transcript

July 9, 20201 pm CST, 2 pm EST

Presented by:

Don Green, LEED APdgreen@wkdickson.com615.308.1014

SCM Inspection and MaintenanceCertification

Why do I need to develop a Post Construction Certification program like the EPSC Level 1 and 11 that has been a requirement for almost 20

years now

SCM Permanent Stormwater Certification

Corona Chaos

https://www.wkdickson.com/news

Living inInteresting

Don Green, LEED APWK Dickson Senor Water Quality Consultant(38 years Environmental field)(18 years in Stormwater)

WATER QUALITY SUPERVISOR(Retired)City of Chattanooga, Chattanooga, TNPhase 1 MS4 (10.5 years)

STORMWATER COORDINATORCity of Franklin, Franklin, TNPhase II MS4 (5 years)

Tennessee Stormwater AssociationPast President and Board Member(Current SE Regional Chair)

TENNESSEE 319 NONPOINT SOURCE PROGRAMAssistant Manager: TDEC & TDA

Tennessee Department of Transportation Field Biologist/Environmental Planner (8 yrs.)

MTSU: BS & MS Biology 3

Don Greendgreen@wkdickson.com615.308.1014

Office LocationsCurrently maintain 11 offices with 175 employees ESTABLISHED

1929 – Charlotte

1989 – Columbia

1993 – Raleigh

1994 – Atlanta

1996 – Hickory

1998 – Wilmington

2005 – Augusta

2015 – Charleston

2017 – Greenville, SC

2018 – Knoxville

2019 - Chattanooga

Aviation

Water/Sewer

Watershed Services

Land Development

Wkdickson.com

NPDES Program Six Minimum Control Measures1. Public Information and Education

2. Public Participation

3. Illicit Discharge – “effectively eliminate non-stormwater discharges” – Only Rain in the Drain

4. Construction Activities – MEP on pollutants

5. Permanent Construction – MEP on pollutants

6. Pollution Prevention/Good Housekeeping of Municipal Operations

What are we talking about?Development adds impervious (hard) surface, andImpervious surface changes pre-development runoff conditionsThese impacts can be related to percentages of hard surfaces, andWe experience water quality impacts when percentage of hard surfaces

goes over 10%We experience loss of water uses when percentage goes over 30%

Impervious surface changes

It’s About Runoff Controls

Center for Watershed Protection

It’s About Runoff Controls

Growth

Why do we need to do ‘Proper’ Stormwater Control Measures (SCM) Maintenance?

First: What is a SCM?

EPA defines Stormwater Control Measures as "techniques”, “measures”, or “structural controls” that are used for a given set of conditions to manage the quantity and improve the quality of stormwater runoff in the most cost-effective manner.

INFRASTRUCTURE

Why do we need to do ‘Proper’ Stormwater Control Measures (SCM) Maintenance?

Permeable pavement comes in many forms

INFRASTRUCTURE

Why do I need to ensure that the MS4 Permanent SCMs are being maintained properly!

It’s the Law!

State NPDES 2016 PermitIt’s the Law!

(i) Requirements for permittee inspectors who conduct inspections ofconstruction sites must maintain certification under the TennesseeFundamentals of Erosion Prevention and Sediment Control, Level 1 (orequivalent).Construction site plan reviewers must receive a certificate ofcompletion from the Tennessee Erosion Prevention and SedimentControl Design Course, Level 2 or equivalent.It is recommended that permittee construction staff receive trainingunder both courses.

4.2.4. Construction Site Stormwater Runoff Pollutant Control2016 TN MS4 Permit: Permanent Stormwater

Level 1 Certification

(i) Requirements for permittee inspectors who conduct inspections ofconstruction sites must maintain certification under the TennesseeFundamentals of Erosion Prevention and Sediment Control, Level 1 (orequivalent).Construction site plan reviewers must receive a certificate ofcompletion from the Tennessee Erosion Prevention and SedimentControl Design Course, Level 2 or equivalent.It is recommended that permittee construction staff receive trainingunder both courses.

4.2.4. Construction Site Stormwater Runoff Pollutant Control2016 TN MS4 Permit: Permanent Stormwater

Already have Existing Certification

requirements

The permittee must implement a permanent stormwater management program focused on removing pollutants from stormwater discharges through management practices, control techniques and system, design and engineering methods (SCMs) implemented to the maximum extent practicable (MEP).

4.2.5. Permanent Stormwater Management at New Development and Redevelopment Projects4.2.5.1 Program Requirements

2016 TN MS4 Permit: Permanent Stormwater

• Permittees must develop and implement, or modify as necessary, an ordinance or other regulatory mechanism to address permanent stormwater pollutant management for New Development Projects. It is recommended that permittees include a mechanism for administrative appeal of site-specific stormwater determinations.

• Typical aspects of the program are expected to include codes and ordinance implementation, procedures for plans review and criteria for approval; procedures for conducting and tracking site inspections, and SCM maintenance policies.

Ordinance

Appeal process

Track SCMMaintenance

• Permittees must develop and implement, or modify as necessary, an ordinance or other regulatory mechanism to address permanent stormwater pollutant management for New Development Projects. It is recommended that permittees include a mechanism for administrative appeal of site-specific stormwater determinations.

• Typical aspects of the program are expected to include codes and ordinance implementation, procedures for plans review and criteria for approval; procedures for conducting and tracking site inspections, and SCM maintenance policies.

Ordinance

Appeal process

Track SCMMaintenance

4.2.5.5 Maintenance of Permanent Stormwater Control Measure Assets

Permanent SCMs, including SCMs used at mitigation projects, must be installed, implemented, and maintained to meet the performance standards of sub-section 4.2.5.2 and provide full treatment capacity within 72 hours following the end of the preceding rain event.

The permittee must develop a program to ensure implementation of appropriate SCM maintenance procedures to sustain pollutant removal efficiency for the life of the New Development Project.

I&M Agreement

Right to access the property

4.2.5.5 Maintenance of Permanent Stormwater Control Measure Assets

Permanent SCMs, including SCMs used at mitigation projects, must be installed, implemented, and maintained to meet the performance standards of sub-section 4.2.5.2 and provide full treatment capacity within 72 hours following the end of the preceding rain event.

The permittee must develop a program to ensure implementation of appropriate SCM maintenance procedures to sustain pollutant removal efficiency for the life of the New Development Project.

I&M Agreement

Right to access the property

It’s the Law!

TDEC is expecting MS4s to inspect Private SCMs

TDEC Permanent Stormwater: Audits Form

□ SCM maintenance procedures, reports, documentation in SCM (Sec 4.2.5.5, p. 21)

Ordinance languageOrdinance Language

A. All developments installing new stormwater or water quality facilities, retrofitting existing facilities or other stormwater management facilities shall be required to execute an Inspection and Maintenance Agreement for Private Stormwater Management Facilities.

B. The owner/operator shall perform quarterly inspections, at a minimum, in accordance with practices and requirements to ensure that the SCMs function properly. Inspections shall entail visual observations and/or other specific measurements of the SCMs performance conducted by a person familiar with control measures implemented at a site. The owner/operator shall maintain inspection documentation as the City may require its submittal. Ancillary documents included in the IMA that help the property owner & the City to better

keep up with maintenance needs:

Exhibit A: Legal Description of property

Exhibit B: Plan for maintenance procedures, called a Long Term Maintenance Plan (LTMP).

Exhibit C: Map of the site with SCMs labeled.

IMA Requirement

IMA Plan!!

Ordinance languageOrdinance Language

A. All developments installing new stormwater or water quality facilities, retrofitting existing facilities or other stormwater management facilities shall be required to execute an Inspection and Maintenance Agreement for Private Stormwater Management Facilities.

B. The owner/operator shall perform quarterly inspections, at a minimum, in accordance with practices and requirements to ensure that the SCMs function properly. Inspections shall entail visual observations and/or other specific measurements of the SCMs performance conducted by a person familiar with control measures implemented at a site. The owner/operator shall maintain inspection documentation as the City may require its submittal. Ancillary documents included in the IMA that help the property owner & the City to better

keep up with maintenance needs:

Exhibit A: Legal Description of property

Exhibit B: Plan for maintenance procedures, called a Long Term Maintenance Plan (LTMP).

Exhibit C: Map of the site with SCMs labeled.

IMA Requirement

IMA Plan!!

I & M Agreement with PLAN!!

POST CONSTRUCTION I&M AGREEMENTSI&M

Agreement

EXAMPLES

POST CONSTRUCTION I&M AGREEMENTSI&M

Agreement

5 yearComprehensive

Inspection Report

In new language

INSPECTION AND MAINTENANCE PLAN

I&M Agreement

Important Plan

Teeth in I&M

Owner knows

Inspector Knows

EXAMPLES

INSPECTION AND MAINTENANCE PLAN

I&M Agreement

Important Plan

Teeth in I&M

Owner knows

Inspector Knows

EXAMPLES

If you don’t have Specifications how do you know what you want or what you are getting?

EXAMPLES

Detention pond

WQ Unit

Enforcement letterAs-BuiltRecord Drawings

What does a Certification Look like?

Part oneSpecifics on what the Municipality requiresCodesEnforcement Response ProtocolI&M Agreements Inspection formsSCMsEducate and back up from Admin/Lawyers/City Council/Stormwater BoardEducate: Community/Developers/Engineers, etc.

Regulations

Support

Education

Three Parts

• IV By January 1, 2020 and before an Inspection and Maintenance Agreement ("Agreement") is approved the property owner(s) must develop at least a two (2) year maintenance contractThe Maintenance Contract shall contain a detailed scope of inspection and maintenance to be performed by the property owner(s), practices to be maintained, planting plan, if any, timeline of maintenance for each SCM and certified person or company responsible. This scope should come from the SCM Maintenance Plan included with the Agreement.

• V By January 1, 2021, property owner(s) shall submit any reports for Inspection Maintenance of private SCMs, including Water Quality Fee Reports, to the Water Quality Manager, which shall be signed by a certified inspector with up-to-date certification.

Certification Ordinance

2 year contract

Certified inspector

Three PartsPart Two The City Workshop - SCM I&M WorkshopA free 3 hour workshop providing an introduction of stormwater,

stormwater control measures, & the City's program. This Workshop is meant to train individuals on the completion and

submission of inspection and maintenance forms.

Certification

City Workshop

Three PartsPart Three Technical training:What is an SCMHow do they functionWhat does inspections look likeExample: Stormwater Control Measures (SCM) Inspections & Maintenance Workshop:• A two day course. The University of Tennessee program offers classes around the state to

help train this new SCM workforce. Through the engaging teaching of Dr. Jon Hathaway, P.E., University of Tennessee, Dept. of Civil and Environmental Engineering and Bill Lord (retired from NC State), University of Tennessee, Water Resources Research Center, attendees learn the necessary skills for SCM management.

Certification

Technical Training

GREEN JOBS

Two PartsThe City Workshop - SCM I&M Workshop

• is a free 3 hour course providing an introduction of stormwater, stormwater control measures, & the City's program. This course is meant to train individuals on the completion and submission of inspection and maintenance forms.

SCM I&M Workshop: March 25, 2020 @ Development Resource Center 1250 Market St. room 1A 9:00 am-11:00 am

Certification

The TN Dept of Environment and Conservation has partnered with the University of TN to establish the TN Stormwater Management Training program. Each year the program offers classes around the state to help train this new SCM workforce. Through the engaging teaching of Dr. Jon Hathaway, P.E., University of Tennessee, Dept. of Civil and Environmental Engineering and Bill Lord, University of Tennessee, Water Resources Research Center, attendees learn the necessary skills for SCM management.

https://tnpermanentstormwater.org/class1.asp

http://tnpermanentstormwater.org/class1.asp

Two PartsThe City Workshop - SCM I&M Workshop

Certification

The TN Dept of Environment and Conservation has partnered with the University of TN to establish the TN Stormwater Management Training program. Each year the program offers classes around the state to help train this new SCM workforce. Through the engaging teaching of Dr. Jon Hathaway, P.E., University of Tennessee, Dept. of Civil and Environmental Engineering and Bill Lord, University of Tennessee, Water Resources Research Center, attendees learn the necessary skills for SCM management.

https://www.bae.ncsu.edu/workshops-conferences/stormwater-bmp/September 17, 2020:8:30 am - 5:00 pmSeptember 18, 2020:8:30 am - 2:30 pmRaleigh, NC

What does a Certification Look like?Two PartsThe City Workshop - SCM I&M Workshop

Certification

CERTIFIED VENDOR lIST

GREEN JOBS

Certain that it’s being

maintained

SCM Maintenance RequirementsBasis of enforcement: Ordinance or other regulatory options Enforcement Response Plan Tracking SOP Good People Inspection and Maintenance Agreements Requirements with Teeth Stormwater Board for enforcement and appeal Education. Education. Education.

• Public• Target developers/Inspectors• Board• Staff

SCM Maintenance Requirements OrdinancePrivate Property Owner Responsibilities.The owner(s) of stormwater management facilities and/or SCMs shall ensure their proper operation. All facilities, system components and related components, and all SCMs must be maintained to ensure full functionality per design. The property owner(s) is solely responsible for the cost of maintaining privately-owned facilities and SCMs and this applies to all property types.

Property owner(s) shall conduct quarterly (four (4) per year) self- inspections of the stormwater structures to ensure maintenance and continued functionality, per design. Self-inspection records shall be kept and made available to City inspectors upon request for a minimum of three (3) years. These should include the date of inspection, inspector's name, SCM condition, and general systems conditions and maintenance. (e.g. trash, sediment, erosion, blockages).

The City Engineer, or his/her designee, shall have the authority to inspect private drainage systems within the City, and to order such corrective actions to said private drainage systems as are necessary to maintain properly the major and minor drainage systems within the City.

Owner’s responsibility

to ensure functionality

Per design

Quarterly inspections

Documentation

City authority

2016 TN MS4 Permit: Permanent Stormwater• The program must consist of plans review, site inspection, and a

means to ensure permanent stormwater control measures (SCMs) are adequately maintained. The permittee shall identify and make information available for a suite of SCMs to be used in various situations.

• Application of innovative SCMs is encouraged. • If the permittee decides to significantly limit the number of SCM

options, it must document in the SWMP how the performance standards in section 4.2.5 can be met with the limited set of control measures that are allowed. ID SCMs

Site Inspection

system

https://tnpermanentstormwater.org/manual.asp

2016 TN MS4 Permit: Permanent Stormwater• The program must consist of plans review, site inspection, and a

means to ensure permanent stormwater control measures (SCMs) are adequately maintained. The permittee shall identify and make information available for a suite of SCMs to be used in various situations.

• Application of innovative SCMs is encouraged. • If the permittee decides to significantly limit the number of SCM

options, it must document in the SWMP how the performance standards in section 4.2.5 can be met with the limited set of control measures that are allowed. ID SCMs

Site Inspection

system

https://tnpermanentstormwater.org/manual.asp

* You need a Design Manual with local requirements and specifics with what you want.

*If you let the developers do the designing you’ll get what they want ----not what you want.

* And what they want might be SCMs that are the easiest to install and/or hardest to maintain….or

* the SCMs that they install are the ones they have always put in for the last 20 years!

SCM Maintenance RequirementsOrdinance The owner/operator shall have comprehensive inspections conducted of all stormwater management facilities and practices at least once every five (5) years. Such inspections must be conducted by either a licensed professional engineer or landscape architect practicing within their range of competency.include:

i. Facility type;ii. Inspection date;iii. Latitude and longitude and nearest street address;iv. SCMs owner information (e.g., name, address, phone number, fax, and email);v. SCMs condition and functionality vi. Photographic documentation of SCMs;vii. Specific maintenance items or violations to be corrected by the SCMs owner along with deadlines and re-inspection dates; andviii. Owner/operators shall maintain documentation of inspections. The City may require submittal of this documentation.

Part of litigation language

BUT….• Who inspects the SCMs? • What do they know about the SCMs on site? • What do they know about any SCM?• Are the inlets and outlets sound? • Did they inspect or remove sediment, or both? • What did they clean?• Does the pervious payment needs sweeping or still infiltrate?On and on. If you receive an inspection report like

EXAMPLES

INSPECTION CHECKLISThttp://www.chattanooga.gov/images/citymedia/publicworks/WQ/ResourceRain

/Manual/Chapter_8_with_Checklists.pdf

EXAMPLES

Why Do we need to do ‘Proper’ SCMMaintenance?

RequireColor

pictures

Inspection Pictures

But pictures alone do NOT always tell the story

Inspection Pictures

Inspection and Maintenance

Is the detention pond as it was designed? • As-Built• Inspection and Maintenance Plan• Sediment build upIs it functioning?Is it a nuisance?Is it going to continue to be a problem?

Do you have vegetative practices now or the future?

Do you have companies or inspectors that know what they are doing?

Designing Vegetated SCMs…•Manage this!

Landscaping Dollars• Where do you spend it?• How many existing GI/Landscape/stream buffer sites do you have to

maintain?• How many coming down the pike?• Do you have an In-house crew and a good knowledgeable landscape

professional to plan and over see itOr

• Do you hire landscape companies?• Do you have companies in the area that know GI and are reliable?• Do you have certification or training workshops for them?• Do you have a good landscape professional to oversee in-house plans so

you can design for maintenance and function?• Do you have a good landscape professional or two that can oversee

landscape companies contracts?If so, lucky you!! Can you keep them happy: give them good pay, benefits, and upward mobility to keep them?

Green Infrastructure:A Hybrid Field

• Landscapers are not Stormwater Engineers or Landscape Architects.

• Designers are not Arborists, Land Managers, or Sustainable Landscapers. These people will have to collaborate!

• Include the maintenance staff in your design process.

• Your site will fail without knowledgeable input and management

65Sparse plant cover

Good plant cover

Surface infiltration testing in accordance with ASTM C1781, Standard Test Method for Surface Infiltration Rate of Permeable Unit Pavement Systems, has been conducted within 60 days post-installation, and results exceed 100-inches/hour.

https://www.youtube.com/watch?v=sV-VccSr-P4 2 mins

PERMEABLE PAVEMENTSPre and post inspections

Underground

Service the Oil Skimmer/Water Quality Unit when the buildup is about 4 inches deep in the inlet chamber

Capture and Reuse

Vegetative Roofs

NJDEP Certified Proprietary Units TNSA’s

Board unanimously approved ”A Guide to Stormwater Manufactured Treatment Devices”

InspectionsCity Requirements

Service the Oil Skimmer/Water Quality Unit when the buildup is about 4 inches deep in the inlet chamber

Jet-VacProcess

Inspection & Maintenance

Design and Maintenance Staff

• Safety concerns• Practicality, steep slopes• Access, parking, water, etc.

Confined Space EntryOSHA permit-required confined space protocols must be followed during the inspection and/or maintenance (I&M) of certain stormwater quality underground detention units. General safety precautions and appropriate personal protection equipment should be utilized by personnel when accessing such units. Please consult the City's practice manual and manufacturer for more information.https://www.osha.gov/Publications/osha3138.pdf

Upcoming TNSA Talks on Zoomhttps://www.tnstormwater.org/tnsatalks

Thursday, July 16, 2020, 1 pm EST, 12 pm CDTSpeaker: Aaron Rogge, CDM SmithStormwater Modeling 101

TBAPollution Prevention/Good Housekeeping of Municipal OperationsSpeaker: Don Green, WK Dickson

Thursday, July 23, 2020, 1 pm CDT, 12 pm EDTSpeaker: Gerald Burnette, CEC, Inc.Data Management Best Practices

Don Green, LEED APSenior Water Quality ConsultantWK Dickson & Co., Inc.615.308.1014dgreen@wkdickson.com

QUESTIONS

SCM Inspection and Maintenance Certification · 7/9/2020 · The owner/operator shall maintain...

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