internalizing stormwater requirements between tbr and facilities construction projects and permanent...
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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
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
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