Radford University MS4 Staff Training. - Good Housekeeping/Pollution Prevention - Illicit Discharge Detection & Elimination

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Vivien Nicholson
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1 Radford University MS4 Staff Training - Good Housekeeping/Pollution Prevention - Illicit Discharge Detection & Elimination

2 MS4 TRAINING PROGRAM MS4 QUICK OVERVIEW MS4 REGULATORS MS4 GENERAL PERIMT TOTAL MAXIMUM DAILY LOAD (TMDL) DEQ/EPA AUDIT VIOLATIONS IN VIRGINIA CLOSING THE COMPLIANCE LOOP GOOD HOUSEKEEPING/POLLUTION PREVENTION SCREENING & REPORTING GOOD HOUSEKEEPING/POLLUTIONPREVENTION BEST MANAGEMENT PRACTICES

MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)

(outfall) Activities/operations draining to

3 MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) Collects & conveys stormwater Potential to convey pollutants downstream Ultimately leads to a point discharge at a natural drainage way (outfall) Activities/operations draining to outfalls are regulated if within a Census Urbanized Area (MS4 Area)

MS4 General Permit Localities & State Entities within

4 STORMWATER REGULATORS Clean Water Act (CWA) authorization to regulate point source discharges Compliance & Enforcement MS4 General Permit Localities & State Entities within urbanized areas Minimum Control Measures Special Conditions for TMDLs

5 MS4 GENERAL PERMIT Requires the operator to: develop, implement, and enforce a MS4 Program designed to reduce the discharge of pollutants from the regulated small MS4 to the maximum extent practicable Maximum Extent Practicable (MEP) Ensures compliance to water quality standards in the MS4 Program: o o Addresses Minimum Control Measures with Best Management Practices (BMP) implementation Structural and nonstructural BMPs Addresses Special Conditions for TMDLs

6 MS4 GENERAL PERMIT Special Conditions 1. Local Waterbody TMDLs Minimum Control Measures 1. Public Education & Outreach 2. Public Involvement/Participation 3. Illicit Discharge Detection & Elimination 4. Construction Site Runoff Controls 5. Post-construction Runoff Controls 6. Pollution Prevention/Good Housekeeping

TOTAL MAXIMUM DAILY LOAD (TMDL) Waterbody not meeting water quality standards New River (from below Claytor Lake Dam downstream ~ 68 miles to the VA/ WV state line near the town of Glen Lyn in Giles

7 TOTAL MAXIMUM DAILY LOAD (TMDL) Waterbody not meeting water quality standards New River (from below Claytor Lake Dam downstream ~ 68 miles to the VA/ WV state line near the town of Glen Lyn in Giles County, VA) TMDL is a plan (pollution diet) that establishes the maximum amount of a pollutant the waterbody can hold and meet water quality standards. WLA is the quantity of the pollutant (sediment, nitrogen, bacteria, etc.) that may bedischarged.

8 PAST DEQ/EPA AUDIT VIOLATIONS IN VIRGINIA DEQ audits approx. 10 MS4s per year (100 MS4s total) Common violations include failure to: Implement/enforce illicit discharge program Adequately address runoff from construction sites/implement ESC regs Adequately manage stormwater discharges from maintenance facilities Adequately document Reduce pollutants to the Maximum Extent Practical Penalties Not to exceed $32,500/day/violation Typically include a consent order

9 CLOSING THE COMPLIANCE LOOP Program Inspection Guidance COMPLIANCE to the Maximum Extent Practical Training Good Housekeeping Manual Scrub with broom Remove in timely manner Retain for 3 Years Documentation Guidance

GOOD HOUSEKEEPING/POLLUTION PREVENTION Develop and implement written procedures to minimize or prevent pollutant discharge from daily operations to: 1.

Prevent discharge of wastewater to storm sewer 5. Require BMPs to filter water pumped from maintenance activities 6.

10 GOOD HOUSEKEEPING/POLLUTION PREVENTION Develop and implement written procedures to minimize or prevent pollutant discharge from daily operations to: 1. Prevent illicit discharge 2. Ensure proper disposal of waste (including landscape wastes) 3. Prevent discharge of vehicle wash water to storm sewer 4. Prevent discharge of wastewater to storm sewer 5. Require BMPs to filter water pumped from maintenance activities 6. Require BMPs to prevent pollutants in runoff from bulk storage (salt storage, topsoil stockpiles) 7. Prevent pollution discharge from leaking college automobiles/equipment 8. Ensure proper application of pesticides and fertilizers

GOOD HOUSEKEEPING #1 PREVENT ILLICIT DISCHARGE

Administrative Code and determined by Radford

11 GOOD HOUSEKEEPING #1 PREVENT ILLICIT DISCHARGE Illicit Discharge - Any discharge to an MS4 that is not composed entirely of stormwater, except discharges specifically identified in the Virginia Administrative Code and determined by Radford University not to be a significant contributor of pollutants to the MS4.

12 REPORTING AN ILLICIT DISCHARGE Detecting and Responding to Illicit Discharges An illicit discharge, as defined by the EPA, is any discharge to the Municipal Separate Storm Sewer System (MS4) that is not composed entirely of stormwater, except for discharges allowed under a VPDES permit or waters used for firefighting operations. If an illicit discharge of sewage or other pollutants, typified by high turbidity, odors, floatables and unusual colors are encountered, notify Facilities Management at (540) If you know that a toxic substance was released, call the Radford University Police at (540) and Facilities Management at (540)

GOOD HOUSEKEEPING #1 PREVENT ILLICIT DISCHARGE An illicit discharge can: 1. Be a measurable flow from a storm drain during dry weather that contains pollutants or pathogens; 2.

13 GOOD HOUSEKEEPING #1 PREVENT ILLICIT DISCHARGE An illicit discharge can: 1. Be a measurable flow from a storm drain during dry weather that contains pollutants or pathogens; 2. Have a unique frequency, composition, and mode of entry in the storm drain system; 3. Be caused when the sewage disposal system interacts with the storm drain system; and 4. Can be discharges from pollutants from specific source areas

14 GOOD HOUSEKEEPING #1 PREVENT ILLICIT DISCHARGE

15 QUICK QUESTION AND ANSWER Question # 1:Illicit discharges are A. True > B. False Question # 2: Which of the following are sources of an illicit discharges? > A. Vehicle wash-water > B. Air conditioner condensate C. Areas of erosion or sediment transport D. Discharge from foundation drains

16 QUICK QUESTION AND ANSWER Question # 3: Vehicles can be washed under the following conditions > A. In a designated wash bay that drains to sanitary sewer B. Near a storm drain > C. Over grass with no soap or detergents > D. At a commercial car wash Question # 4: What would you do if hydraulic fuel is observed on the ground beneath stored/parked equipment? A. Hose it down with water to a storm drain. B. Leave it there for the rain to wash it off. > C. Place absorbent, sweep it all up and dispose of it in a container. > D. Fill out a Findings and Follow up form.

17 GOOD HOUSE KEEPING #2 ENSURE PROPER DISPOSAL OF WASTE (including landscape wastes) Best Management Practices: Direct mowing operations away from open water bodies, streets, or storm drains so grass clippings/debris do not enter the storm sewer system. Avoid mowing grass below 3 inches tall for optimal infiltration. Potential Waste Materials Leaves Brush Weeds Grass Clippings Leaving clippings on the lawn to reduce water loss and lessen the need for fertilizer. Properly time fertilizing, weeding, pest control, and pruning. Do not apply fertilizers to the landscape before a predicted rain event. Do not stockpile or dispose of vegetation near waterways or storm drain systems. Use bagging equipment to contain landscaping waste, manually pick up the material, and/or creating a temporary stockpile. Place temporarily stockpiled material away from watercourses and storm drain inlets. Cover stockpiles to prevent the release of materials to the storm sewer system.

18 GOOD HOUSEKEEPING #3 PREVENT WASH WATER INTO THEMS4 Designated Wash Areas: Wash all vehicles in designated washing bays or on containment pads designed to collect and hold wash water before discharging into the sanitary sewer system. Wash vehicles inside whenever possible and ensure that all floor drains lead to the sanitary sewer system. If outdoor cleaning is absolutely necessary, wash equipment over flat, grassy/pervious areas and as far away as possible from watercourses and storm drains. Potential Pollutants Pathogens Excess Nutrients Chlorine Compounds Hazardous Chemicals Cleaning Products Fats, Grease,Oil Additional Best Management Practices: Do not dump any toxic substances or liquid waste on the pavement, ground, or towards the storm drain. Conserve water when rinsing and washing vehicles. Consider power washing. Avoid detergents/toxic chemicals or solvents whenever possible. No water containing detergents should be discharged into the storm sewer system.

19 GOOD HOUSEKEEPING #4 PREVENT DISCHARGE OF WASTEWATER INTO THE MS4 Collecting & Disposing of Wastewater Best management practices regarding the proper collection and disposal of wastewater from campus activities including Dining Services, Housekeeping, and Research Laboratories. Containment Methods: Equipment or material washing should be performed in a designated wash area designed to collect and hold wash water before discharging it into the sanitary sewer system. Contain wash water using absorbent socks or other containment methods if NOT in a designated wash area. Conduct any cleaning of oily materials, steam cleaning, or pressure washing inside a building or on a contained area, such as a containment pad. Collect wastewater in water tight storage containers, preferably with a firm-fitting lid. Wastewater with no hazardous chemicals may be directed to the sanitary sewer system if hazardous chemicals are suspected, DO NOT wash down the sanitary sewer, contact Facilities Management (540) for further guidance and pickup. Potential Pollutants Pathogens Excess Nutrients Chlorine Compounds Hazardous Chemicals Cleaning Products Fats, Grease,Oil

Wash water that does NOT contain toxic chemicals, may be disposed into the sanitary sewer system.

20 GOOD HOUSEKEEPING #4 PREVENT DISCHARGE OF WASTEWATER INTO THE MS4 Collecting & Disposing of Wastewater Disposal Methods: All equipment and materials should be washed in the aforementioned designated areas. Wash water that does NOT contain toxic chemicals, may be disposed into the sanitary sewer system. If outdoor cleaning is absolutely necessary, wash equipment, materials, or containers over flat, grassy/pervious areas and away from watercourses and storm drains

GOOD HOUSEKEEPING #5 REQUIRE BMPs TO FILTER WATER PUMPED FROM MAINTENANCE ACTIVITIES Best management practices regarding the discharge of water pumped from construction and maintenance activities.

21 GOOD HOUSEKEEPING #5 REQUIRE BMPs TO FILTER WATER PUMPED FROM MAINTENANCE ACTIVITIES Best management practices regarding the discharge of water pumped from construction and maintenance activities. RADFORD UNIVERSITY Facilities Management and Planning and Construction include erosion and sediment control requirements in contracts when dewatering or water pumping takes place on any RADFORD UNIVERSITY construction or maintenance activity. Coordination of any construction or maintenance activity is required where land disturbance is involved prior to beginning the work. Dewatering Best Management Practices: Consider discharge areas carefully in regards to the downstream receiving watercourses and the landscape s ability to filter effluent from the dewatering process. A wooded buffer (with sufficient underbrush) or turf are preferred areas to discharge. Pay special attention to the buffer area for signs of erosion and concentration of flow that may impact the buffer area. Minimize dewatering discharge velocity in order to avoid scouring the receiving area. Use structural controls to handle the anticipated flow/discharge (See General Erosion and Sediment Control Practices). Perform visual inspection of the effluent at the dewatering discharge point to determine additional filtration needs. Inspect the dewatering site regularly to ensure adequate discharge control. Inspect filtering bags for clogging and replace as necessary. What is Dewatering? Dewatering is the practice of removing water from a work area through portable water pumps and considered effluent. Effluent water is typically pumped out of the work area and into a filtering device(s) before being discharged from the site. Use filtering devices and general erosion control practices to manage water from the work area.

22 GOOD HOUSEKEEPING #5 REQUIRE BMPs TO FILTER WATER PUMPED FROM MAINTENANCE ACTIVITIES Best management practices regarding the discharge of water pumped from construction and maintenance activities. General Erosion and Sediment Control Practices: Protect Existing Features: Minimize existing vegetation removal and amount of exposed soil at the discharge point. Stabilize the area receiving discharge: Utilize techniques such as sodding, seeding/ mulching and stone cover to reduce the erosion of soil. Storm Drain Inlet Protection: Use and maintain inlet protection. Rock Check Dam: Use a temporary or permanent erosion and sediment control measure constructed to filter sediment from runoff which can also be used for filtering effluent from dewatering activities. Temporary Diversion Dike: Use a temporary erosion and sediment control measure to direct sediment-laden stormwater to a sediment trapping or storm water management facility.

23 GOOD HOUSEKEEPING #6 BMPs TO PREVENT POLLUTANTS IN RUNOFF FROM BULK STORAGE STOCKPILES Managing Storage Areas for Bulk Quantities of Materials Best management practices for storing bulk quantities of materials, including storage techniques and erosion control practices for preventing the runoff of material from rain events. Bulk quantities of materials should be stored: In a recommended 4 walled covered area/roofed structure preventing direct contact with rainfall, snow, and wind. In a 3-walled structure utilizing a temporary fourth wall such as plastic sheeting when the area is not in use. On a roofed or covered paved surface to prevent rainfall from contacting stored material. Utilize appropriate control measures to direct runoff around the storage area. Covered with plastic sheeting secured with substantive weights placed uniformly over the stockpile to prevent shifting and exposure. Potential Bulk Storage Materials Topsoil Sand Compost Metal Products Gravel Mulch Concrete Construction Materials

24 GOOD HOUSEKEEPING #7 PREVENT POLLUTION DISCHARGE FROM LEAKING COLLEGE AUTOMOBILES Vehicle and Equipment Maintenance Best management practices regarding vehicle and equipment maintenance, storage and spill response. Equipment Storage: Store vehicles, equipment, and related fluids under covered areas to prevent exposure to precipitation. Leak Prevention: Do not dump toxic substances or liquid waste on the pavement, the ground, or in adjacent areas draining to the storm drains. Inspect vehicles and equipment regularly for leaks and when possible, perform vehicle and equipment maintenance inside or in a covered area. Use funnels with tray/drip pan underneath vehicle when pouring or performing maintenance and promptly transfer used fluids to the proper waste or recycling drums. Fluids open and exposed to precipitation: Recycle whenever possible. Store recyclable material in a non-leaking drum or covered container. This includes used motor oil, diesel oil, oil Filters & and other vehicle fluids: Keep caps and covers on chemicals and storage materials and ensure all containers are properly labeled. Potential Pollutants Solvents (Paint Thinner) Fuel (Gasoline, Diesel, and Kerosene) Battery acid Brake fluid Windshield washer fluid Brake pad dust Antifreeze coolant Lubricating oil & grease Motor oil

25 GOOD HOUSEKEEPING #8 ENSURE PROPER APPLICATION OF PESTICIDES & FERTILIZERS Best management practices for fertilizer and pesticide application. Nutrient runoff pollution is one of the most severe problems facing local waterways. Runoff that carries excess nutrients increases the growth of algae, which stresses underwater plant and animal life. Best practices: Use products only as directed. Provide cleanup supplies near designated maintenance areas to facilitate immediate cleanup. Use dry cleanup methods (e.g., rag, damp rags, and absorbent materials) rather than hosing down the area to prevent discharge to storm drains. Avoid application over impervious surfaces; sweep granular fertilizer back onto the grass to prevent it from washing into the storm sewer system. Do not apply herbicides, fertilizers, or pesticides to bare or eroding soil. No pesticides near open waters such as streams and creeks unless the product is specifically designed for use in shoreline or aquatic environments. Never apply chemicals before a predicted rainfall event, during periods of high wind speeds or within close proximity to surface water. Select the least toxic products available to minimize waste and chemical exposure to the applicator. Inspect, maintain, and calibrate equipment used for mixing and application. Ensure all containers are watertight after each use. Do not prepare herbicides, pesticides, or fertilizers near storm drains and never apply chemicals directly to water Nutrient Management Plans Radford University has a nutrient management plan governing how nutrients are applied to the soil. Nutrient management plans have been developed by a certified nutrient management planner in accordance with of the Code of Virginia on all lands owned or operated by the MS4 operator where nutrients are applied to a contiguous area greater than one acre.

26 QUESTIONS? Radford University Neal Thompson (MS4 ProgramAdministrator)

Kay Cabe, P.E. EEE Consulting, Inc.

Kay Cabe, P.E. EEE Consulting, Inc. NVCC 2016 MS4 Staff Training - Illicit Discharge Detection & Elimination - Good Housekeeping/Pollution Prevention - Stormwater Facility Inspections & Maintenance May