Presentation from a webinar by Ryan Janoch (Mapistry), Wendy Manley (Wendel Rosen Black & Dean LLP) and Jamie Cint (GaiaTech) that focused on municipal stormwater, from program management to permit compliance. Technical considerations, including identifying, reducing and eliminating illicit discharges, and developing and conducting effective asset management (mapping) and maintenance programs are covered. In addition, recent regulatory developments involving municipal stormwater programs are included.

1. Municipal Stormwater
Illicit Discharge Programs, Stormwater System Maintenance and Management, and Recent Regulatory Developments
September 25, 2014

2. Panel
Ryan Janoch, PE
Mapistry
Wendy Manley, Esq.
Wendell Rosen Black & Dean LLP
Jamie Cint
GaiaTech

3. Overview
●Asset Management
●Maintenance Program
●Treatment Considerations
●Illicit Discharges
●Education and Outreach Programs
●Paradigm Shift of Stormwater Management
●Regulatory Controls
●Cost & Funding Challenges

4. Asset Management and Maintenance
Ryan Janoch, PE

5. NPDES MS4 Permits
Phase II
1999
small cities
Phase I
1990
cities pop.100,000+

6. Stormwater Management Plans (SWMP)
●Both Phase I and II
●Annual report
●Monitor discharges/streams
●Use Best Management Practices (BMPs)

7. Asset Management
●Permit required
●Field data collection - maintenance crews, staff, consultants, and citizens
●New records and update existing records
●Consistency in naming conventions
●Training field teams

8. Field Data Collection
●What is the necessary info?
●Who does the collection?
●How to collect it?
●Where is it stored?
●What do we do with it?

9. Stormwater System Mapping

10. Benefits of Good Asset Programs
●Targeted maintenance
●Plan for repairs and upgrades
●Better models (e.g. planning, expansion, upgrades)
●Reduce long-term maintenance costs
●Permit compliance

11. Example: SF Bay Region Phase I MS4
1.Develop and publicize a stormwater system map
2.Conduct surveys on at least one waterbody each year
3.Submit an annual Urban Creeks Monitoring Report with maps of sampling locations and data for a waterbody
4.Submit an annual Pilot Green Streets Program Report showing drainage areas treated by Low Impact Development (LID) controls

12. Example: SF Bay Small MS4 (Phase II) Map Requirements
1.Outfall locations (coordinates and ID)
2.Receiving waterbody locations
3.Priority areas (e.g industrial/commercial)
4.Field sampling locations
5.Permit boundary

13. Maintenance Programs
●Start with system maps (planning)
●Routine - set schedule and stick to it
●Non-routine - as-needed based on complaints and inspections
●Update records on site (photos, notes)
●Documentation (records)

14. Treatment Considerations
●Long-Term Maintenance Costs
●Constituents of Concern (metals, TSS, trash)
●Flow reduction
●Size constraints
●Capital Costs
●Aesthetics

15. Treatment Options
•Bioretention
•Underground Storage
•Infiltration
•Hydrodynamic Separators
•Media Filtration
•Retention Ponds
•Swales

16. Compliance and Benefits of Education: Stormwater Ponds and Illicit Discharges
Jamie Cint

17. My Experience as an Inspector
•24 years of inspecting
•Education/certifications not required to inspect industrial facilities
•Inspectors and regulators not trained on how to educate the community

18. Inspector Experience #1
Most people do not know what the following are:
●stormwater
●illicit discharge
●best management practice (BMP)
●National Pollution Discharge Elimination System (NPDES) Municipal Separate Storm Sewer System (MS4) permit

19. Inspector Experience #2
Some that believe that the stormwater system (e.g. curb inlets, infrastructure, drainage ditches) drains to the sanitary sewer system and stormwater is treated

20. Inspector Experience #3
Many look at what they are doing to the environment (e.g. wash water, cigarettes, drinks, trash, pesticides) as minor. (It can’t be that bad, its only a….)

21. Education is a BMP
Stormwater education programs are to inform citizens, commercial, and industrial facilities about:
●their permit requirements
●importance of stormwater pollution prevention
●environmental impact of stormwater runoff
●methods to reduce environmental impact

22. Illicit Discharge Education
Illicit (illegal) discharges
Examples: motor oil, grass clippings, sediment, pet waste, pool water
Stormwater Discharges
“Nothing goes in the drain but rain!!”
Certain “Allowable”
Non-Stormwater Discharges

23. Allowable Non-Stormwater Discharges
●Uncontaminated groundwater
●Foundation drains
●AC condensate (no added chemicals)
●Uncontaminated potable water
●Waterline and fire hydrant flushing
●Irrigation water or lawn watering runoff
●Exterior building wash water (no detergents)

24. Old A/C condensate line

25. The Good….
the Bad…
and the Ugly!!

26. What do we find at Industrial Facilities?
Best Management Practices
Employee Training
Spill Prevention and Response
Good Housekeeping
Preventative Maintenance Program
On-site Contractor Responsibilities
Exposure Minimization
Daily Visual Observations
Scrap Material Storage and Salvage
Management of Runoff

27. One on One Training
•During baseline visit
•Walk the entire site - every corner
•Boldly go where no person has gone before!
•Point out the good, the bad, and the ugly
•Daily, quarterly, and annual visits get easier

28. Cooking Grease Waste Processing
•Daily odor violations and complaints about the staining
•Contaminating the stream (200 feet from the building)
•Department going there for ten years with little results
•I was requested by another department in the county
•By the first hour, the owner asked if I had to be there ☺

29. The Bad and the Ugly

30. The Good and the Kick Butt

31. Commercial and Residential
●Education is more difficult
●They don’t want to hear what they can and cannot do at their facility or at home
●Education material and information does help
●Many do not know what is hazardous waste

32. Brochures and Information Packets

33. What is a hazardous substance?

34. Biodegradable and No. 1 in Litter
What does biodegradable mean?
Capable of being broken down by microorganisms
Per the USEPA, for 1 ounce of biodegradable soap to be safe for fish it has to be diluted by almost 20,000 ounces of water (156.25 gallons)
Per the USEPA, what is the most number one littered item in America?
Cigarette butts

37. Storm Water Ponds Commercial, Residential, and Landscapers
•Commercial and residential areas have detention or retention ponds
•Most HOAs and commercial owners have no idea what the purpose of a stormwater pond is or how to maintain it properly
•How to educate instead of giving violations?
◦College extension office
◦HOA meetings
◦Maintenance companies

38. Retention & Detention Ponds
Retention Ponds (wet)
Retain water and have a permanent pool of water
Detention Ponds (dry)
Detain water 24-48 hours after a rain event then are dry again.

39. Landscaper Enforcement
Leaves Blown into the Creek
Leaves in the Manhole

40. With Education Comes Great Responsibility and Commitment
Education takes a lot of time and effort
Training
Preparation
Streamline your program
Offer classes to industry
Target violators such as landscaping companies, pool installers, HOA, contractors…

41. Benefits of Education
•Less violations
•More cooperation
•Promote financial growth (e.g. landscapers, clean up companies)
•Less contaminated stormwater (e.g. lakes, stream, rivers, oceans)
•More recreation in the community (e.g. boating, swimming)
•Regulators have a better relationship with the community
•It’s fun!

42. The Paradigm Shift of Municipal Stormwater Management
Wendy Manley, Esq.

43. Hydromodification
Evapotranspiration
Runoff
Infiltration
Traditional
storm drain
design driver

44. Paradigm Shift: From Gray Infrastructure …
Designed to quickly drain water away from development to prevent flooding.

45. Paradigm Shift: … to Green Infrastructure
•Designed to mimic natural processes:
•Reduce runoff rates and volumes that scour streambeds
•Reduce discharge of pollutants to receiving waters

46. LID & Green Infrastructure
•Low Impact Development uses site design and storm water management to maintain the site’s pre-development runoff rates and volumes.
•Green Infrastructure carries this approach to a larger, community scale and presents similar, sustainable opportunities to local governments and regional projects.
SWRCB, Storm Water Management Fact Sheet

47. Drivers of Change
•Storm Water Permits
–Requirements
–Monitoring
–Numeric Standards
•Drought
–Strained water supplies
–Water efficient landscaping
•CA Green Building Code
•Carbon emission reductions

48. Paradigm Shift: Stormwater: From Waste to Resource
•Water Supply
–Capture and reuse
–Groundwater recharge
•Energy savings
•Parks and open space
•Multi-benefit projects

49. Regulatory Framework
Clean Water Act
Municipal SW Permit
Industrial SW Permit
Municipality
Industrial sites
Construction SW Permit
Construction sites
Development & Redevelopment

50. Regulatory Controls & Incentives
Examples
•LID required where feasible
•LID required for first 0.5 inches of precipitation
•LID required on development/redevelopment projects that create/replace > 5,000 sq feet impervious surface
•TMDLs, Numeric Effluent Limits,
•Discounts on SW fees for LID features
•Benchmark exceedances allowed where reduced flows lower mass loads to below the mass load at benchmark

51. Regulatory Controls
Specific Examples (CA Municipal General Permit)
•Concentrate development on portions of the site w/ less permeable soils, preserve areas that can promote infiltration
•Replicate the site’s natural drainage patterns
•Detain & retain runoff throughout the site
•Limit impervious surfaces
•Preserve significant trees

52. Paradigm Shift:Climate Change
•Change over time, & change in the rate of change
•Increasing variability
•Mentally adjusting to dynamic systems from static (sort of) systems
•Sizing projects – shifting targets
•Design storms – using running averages

53. Municipal Implementation Challenges
•Retrofitting existing infrastructure – systematic or piecemeal
•On-site features vs. Regional facilities; Watershed planning
•Groundwater protection; Water quality standards
•Standardized requirements vs. site-specific approaches
•Capture and reuse may conflict with water rights
•Establishing legally enforceable programs and standards
–Ordinances
–Contracts
–Leases
–Construction specifications
•Long term maintenance
•Lack of technical knowledge

54. Costs & Funding Challenges
•Project Costs
–May be less using LID
–Economic benefit - greater market value for green space & “sustainable” development
•Municipal Implementation costs
–Regulatory (ordinances, permit approvals)
–Administrative (collecting fees, tracking, inspections)
–Operation & Maintenance
•Municipal Funding
–Stormwater utilities
–Service fees
–Legislative funding

55. Questions?
Ryan Janoch, PE
ryan@mapistry.com
Wendy Manley, Esq.
wmanley@wendel.com
Jamie Cint
Jamie.cint@rpsgroup.com