Internalizing Stormwater Requirements Between TBR and Facilities

Construction Projects and Permanent Stormwater Treatment Mgmt.

Steve Casey, PE, CPESC

Phase 2 Requirements Review

Public Education Public Participation and Involvement Illicit Discharge Detection and Elimination Construction Site Runoff Control Post Construction Runoff Control Municipal Good Housekeeping

Annual reporting on meeting “BMPs”

Today’s topics

Construction Site Runoff Control

Traditional MS4s: Ordinance Plan review Routine site inspections/audits Enforcement

Non-traditional MS4s: Policies and procedures to require plans,

inspections Internal enforcement auditing process Inclusion in contracting documents

Post Construction Runoff Control

Traditional MS4s: Ordinance BMP manual, technical guidance Plan review Routine site inspections/audits Enforcement Long term operations and maintenance

Non-traditional MS4s: Policies and procedures to require plans, inspections Design standards Internal enforcement auditing process Inclusion in contracting documents Long term operation and maintenance

Post-Construction (Permanent) Site Runoff Control

Permitrequirement

Description Implementation date Calendar Date

4.2.4 a Ordinance or other regulatory mechanism for construction site runoff control program.

Within 18 months followingthe reissuance of theConstruction General Permit.

November 23, 2012

4.2.3 Ordinance prohibiting illicit discharges.

Within 18 months of coverage under this permit.

November 23, 2012

4.2.4 All components of construction site runoff control program, including plans review and inspections and staff training.

Within 24 months of coverage under this permit (12 months for inventory of all active public and private construction sites)

September 1, 2013 (assuming Notice of Coverage date of 9/1/2011)

4.2.5 Ordinance or other regulatory mechanism for permanent stormwater management including green infrastructure BMPs.

Within 48 months of coverage under this permit.

September 1, 2015 (assuming Notice of Coverage date of 9/1/2011)

4.2.5.6 Inventory and Tracking of BestManagement Practices.

Within 180 days of coverage under this permit.

February 28, 2012 (assuming Notice of Coverage date of 9/1/2011)

Summary MS4 Permit Req’ts

How to incorporate permit req’ts into current TBR processes?

• Statewide standards for MS4-permitted and non-MS4 permitted campuses

• MS4-permitted campuses will “self-regulate” to demonstrate compliance with MS4 permit

• NonMS4-permitted campuses will ensure CGP compliance at a minimum but may have permanent stormwater practices, as well

TBR Project Designer

Design, including

stormwater

Stormwater “how-to” for TBR project managers

CGP application

TDEC NOC

Contractor: twice weekly inspections

Monthly Audit checklist: Campus Rep

Plans review checklist

Notice of Termination: TBR Project Manager

Design includes permanent SW treatment practices

List of acceptable practices

Design guidance

Standard operation and maintenance

plans

Maintenance SOP by campus Long term maintenance

Construction begins

As built certification

Construction complete

As Built Certification

form

Stormwater “How-to” for TBR PMs during design

Guidance document with summary “cheat sheet”

Used to help PM understand process and help educate DesignersPlans review checklist

Part of TBR “Construction Runoff Control Program” for universities

Will help to ensure CGP compliance for universities and other campuses

List of Acceptable Practices

Statewide list May be practices certain campuses choose

not to allow Based upon current BMP Manuals available

across the State Designer could propose non-listed practice

Designer would need to provide O&M plan

Insert “List of Acceptable Practices”

Design Guidance

Used by Designers for the proper design of the acceptable practices (BMPs)

Will apply statewideMay be regionally specific

Designer can provide justification for designing practices not in DG

Update Chapter 3:

Design

Add “As-Built Certification

Form”

Oversight During Construction

Campus rep responsible for completing monthly audit checklist and verifying CGP compliance

Contractual language may need revision to provide “enforcement” tools to campus rep

Construction Completion

Revise F704 Certificate of Substantial Completion to include NOT submission requirementO&M Manuals with certified as-built survey

provided to campus and TBR by designerPermanent stormwater practice logged into

database for tracking and annual inspections

Standard O&M Plans

Standard O&M Plans for each listed practice

Designer provides O&M Plan for unlisted practice

4.2.5.7 Owner/Operator Inspections

In order to ensure that all stormwater BMPs are operating correctly and are properly maintained, the MS4 shall, at a minimum, require owners or operators of stormwater management practices to:a. Perform routine inspections to ensure that the BMPs are properly

functioning. These inspections shall be conducted on an annual basis, at a minimum. These inspections shall be conducted by a person familiar with control measures implemented at a site. Owners or operators shall maintain documentation of these inspections.

MS4 Permit Req’t

Maintenance SOP by Campus

Maintenance of permanent stormwater practice may look different at each campus

Need for “Activity Owner” who:Logs inspections per MS4 permitFollows-up to ensure maintenance is

performed as deemed necessary during inspection

Questions?Discussion & Feedback