Municipal Stormwater

Illicit Discharge Programs, Stormwater

System Maintenance and Management,

and Recent Regulatory Developments

September 25, 2014

Panel

Ryan Janoch, PE

Mapistry

Wendy Manley, Esq.

Wendell Rosen Black & Dean LLP

Jamie Cint

GaiaTech

Overview

● Asset Management

● Maintenance Program

● Treatment Considerations

● Illicit Discharges

● Education and Outreach Programs

● Paradigm Shift of Stormwater Management

● Regulatory Controls

● Cost & Funding Challenges

Asset Management and

Maintenance

Ryan Janoch, PE

NPDES MS4 Permits

Phase II

1999

small cities

Phase I

1990

cities pop.100,000+

Stormwater Management Plans

(SWMP)

● Both Phase I and II

● Annual report

● Monitor discharges/streams

● Use Best Management Practices (BMPs)

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

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?

Stormwater System Mapping

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

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

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

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)

Treatment Considerations

● Long-Term Maintenance Costs

● Constituents of Concern (metals, TSS, trash)

● Flow reduction

● Size constraints

● Capital Costs

● Aesthetics

Treatment Options

• Bioretention

• Underground Storage

• Infiltration

• Hydrodynamic Separators

• Media Filtration

• Retention Ponds

• Swales

Compliance and Benefits of

Education: Stormwater

Ponds and Illicit Discharges

Jamie Cint

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

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

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

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….)

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

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

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)

Old A/C

condensate line

The Good….

the Bad…

and the Ugly!!

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

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

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 ☺

The Bad and the Ugly

The Good and the Kick Butt

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

Brochures and Information Packets

What is a hazardous substance?

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

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

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.

Landscaper Enforcement

Leaves Blown into the Creek

Leaves in the

Manhole

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…

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!

The Paradigm Shift of

Municipal Stormwater

Management

Wendy Manley, Esq.

Hydromodification

Evapotranspiration

Runoff

Infiltration

Traditional storm drain design driver

Paradigm Shift:

From Gray Infrastructure …

Designed to quickly drain water away from

development to prevent flooding.

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

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

Drivers of Change

• Storm Water Permits

– Requirements

– Monitoring

– Numeric Standards

• Drought

– Strained water supplies

– Water efficient landscaping

• CA Green Building Code

• Carbon emission reductions

Paradigm Shift: Stormwater: From

Waste to Resource

• Water Supply

– Capture and reuse

– Groundwater recharge

• Energy savings

• Parks and open space

• Multi-benefit projects

Regulatory Framework

Clean Water Act

Municipal SW Permit

Industrial SW Permit

Municipality Industrial sites

Construction SW Permit

Construction sites

Development & Redevelopment

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

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

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

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

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

Questions?

Ryan Janoch, PE

ryan@mapistry.com

Wendy Manley, Esq.

wmanley@wendel.com

Jamie Cint

Jamie.cint@rpsgroup.com