Internalizing Stormwater Requirements Between TBR and Facilities Construction Projects and Permanent Stormwater Treatment Mgmt. Steve Casey, PE, CPESC.

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Presentation transcript:

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 Todays topics

Construction Site Runoff Control Traditional MS4s: Traditional MS4s: Ordinance Ordinance Plan review Plan review Routine site inspections/audits Routine site inspections/audits Enforcement Enforcement Non-traditional MS4s: Non-traditional MS4s: Policies and procedures to require plans, inspections Policies and procedures to require plans, inspections Internal enforcement auditing process Internal enforcement auditing process Inclusion in contracting documents 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

Permit requirement DescriptionImplementation date Calendar Date a Ordinance or other regulatory mechanism for construction site runoff control program. Within 18 months following the reissuance of the Construction General Permit. November 23, Ordinance prohibiting illicit discharges. Within 18 months of coverage under this permit. November 23, 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) 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) Inventory and Tracking of Best Management Practices. Within 180 days of coverage under this permit. February 28, 2012 (assuming Notice of Coverage date of 9/1/2011) Summary MS4 Permit Reqts

How to incorporate permit reqts 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 ProjectDesigner 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 Designers Plans 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 statewide May 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 requirement O&M Manuals with certified as-built survey provided to campus and TBR by designer Permanent 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

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 Reqt

Maintenance SOP by Campus Maintenance of permanent stormwater practice may look different at each campus Need for Activity Owner who: Logs inspections per MS4 permit Follows-up to ensure maintenance is performed as deemed necessary during inspection

Questions? Discussion & Feedback