Pollution Prevention for Municipal Operations

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Pollution Prevention for Municipal Operations

• Chris Kallis IEPA

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NPDES Storm Water Programs

• Industrial
• Based on Standard Industrial Classifications
  and exposure to storm water
• Construction
• Land Disturbances gt 1 acre
• Municipal
• Communities in urbanized areas
• Includes non traditional entities such as
  IDOT.

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Municipal Operations Not Covered Under the Ms4
Permit

• Wastewater Treatment Plants in excess of 1 MGD.
• Landfills
• Marinas
• Airports
• Steam Electric Plants

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Storm Water Management Programs

• Public Education and Outreach
• Public Involvement
• Illicit Discharge and Elimination
• Construction Site Storm Water Control
• Post Construction Storm Water Management
• Pollution Prevention and Good Housekeeping for
  Municipal Operations

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Developing an OM Program for Municipal
Operations

• Park and Open Space Maintenance
• Fleet and Building Maintenance
• Operation of Storage Yards
• Snow Dispersal
• New Construction and Land Disturbances
• Storm Water System Maintenance Procedures
• Addressing Impacts from Flood Management Projects

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Developing an OM Program for Municipal
Operations

• The program should be designed to prevent and
  reduce the discharge of pollutants to the maximum
  extent possible.
• Training of employees is required
• Should address ways flood management projects
  impact water quality.

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Landscaping and Lawn Care

• Planting vegetation that needs minimal amount of
  care
• Implementing landscaping techniques that minimize
  water usage
• Watering just enough to supplement rainfall
• Consider the possibility of using compost,
  natural or slow release fertilizers
• Avoiding fertilizer or pesticide application
  before or during rain events
• Consider adopting Integrated Pesticide Management
  Techniques

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Integrated Pest Management (IPM)

• The four steps are
• 1. Setting Action Thresholds
• 2. Monitoring and Identifying Pests
• 3. Prevention
• 4. Control

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Vehicle and Equipment Maintenance

• The changing of fluids and washing of vehicles
  being conducted indoors with floor drains being
  diverted to a holding tank or sanitary sewer.
• If going to a sanitary sewer, an oil separator
  should be considered.
• Avoiding the use of detergents as they emulsify
  oils and render oil separators ineffective.

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Vehicle and Equipment Maintenance

• Using drip pans when changing fluids
• Keeping oily wastes separate from other wastes,
  especially solvents
• Keeping coolant (antifreeze) containers covered
• Using spigots or funnels to minimize drips or
  leaks

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Vehicle and Equipment Maintenance

• Keeping hydraulic equipment in good repair
• Considering containment for fuel Islands
• Making sure Spill Prevention and Response
  Procedures are in place and staff is adequately
  trained

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Operation of Storage Facilities

• Confining liquid and dry material storage to a
  specific indoor location.
• Separation of potentially volatile materials.
• Assuring drums are covered and properly stored,
  preferably indoors.
• Assuring that drum washings are diverted to
  holding tanks or sanitary sewer.
• Developing a disposal plan for waste materials.

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Operation of Storage Facilities

• Assuring that dumpsters be lidded and well
  maintained
• Limiting the storage of scrap materials
• Assuring that lead batteries are not in contact
  with storm water
• Check for illicit connections to storm sewers

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Compost Facilities

• Making sure that the facility is located outside
  of a floodplain boundary and not placed within
  five feet of any water table
• Insuring adequate control of runoff from the site
• Collecting any leachate and disposing properly

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Road Salt Storage

• Storing road salt and sand mixtures in properly
  sized and covered structures or waterproof tarps
• Making sure that the surface of the storage area
  is impervious and sloped to prevent runoff
• Ordering salt early and unloading salt deliveries
  directly into storage area
• Inspecting salt storage area to address immediate
  clean-up of spillage and exposure to runoff
• Refer to Salt Storage Handbook from the Salt
  Institute (www.saltinstitute.org)

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Road Salt Application

• Minimizing salt spillage by not exceeding
  capacity of equipment during loading
• Minimizing salt usage by periodically calibrating
  salt application equipment
• Consider plowing before de-icing
• Applying salt brine as a pre-treatment prior to
  impending storms
• Using chemical application charts
• Refer to the Chloride Reduction Study from the
  Dupage River Salt Creek Workgroup

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Snow Removal

• Making sure that street cleaning is a priority on
  snow removal routes
• Placing snow piles in appropriate areas to
  minimize direct release of sediment and
  contaminants
• Consider diverting drainage to grassy swales fro
  both primary treatment and velocity control

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New Construction and Land Disturbance

• All construction projects initiated by the MS4
  Permit are automatically covered. No Notice of
  Intent is required. A Storm Water Pollution
  Prevention Plan must be implemented in accordance
  with NPDES Permit conditions for each project
  that disturbs over an acre.

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SWPPP Requirements

• Site description that includes nature and
  sequence of construction activity and a site map
  showing activities, areas of disturbance,
  drainage, slopes and receiving waters
• A description of stabilzation, structural and
  storm water management practices
• Compliance with stabilization requirements and be
  at least as protective as the requirements in the
  Illinois Urban Manual 2002 edition

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SWPPP Requirements

• Inspections to be conducted every 7 calendar days
  or within 24 hours after a storm event of 0.5
  inches or greater
• Incidence of Non Compliance to be sent to the
  Agency for any violation of the SWPPP
• Insure that all contractors and sub-contractors
  identified in the SWPPP sign a certification
  statement tin accordance with NPDES Permit
  conditions.

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Catch Basin and Storm Drain Cleaning

• Identifying catch basins that require frequent
  maintenance in order to proritize
• Identifying the need for repair of structures
  such as manholes and piping
• Cleaning catch basins when debris has filled over
  one third of the way to the outlet
• Coordinating catch basin cleaning with sweeping
  events checking for excessive siltation in
  ditches tributary to catch basins

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Street Cleaning and Maintenance

• Prioritize areas and performing maintenance
  routinely
• Covering storm water inlets while performing
  maintenance, especially blacktopping
• Collecting leaves in autumn
• Sweeping salt and sand residues in the spring
• Maintaining roadside vegetation

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Flood Management Projects

• Impacts to consider
• Water Quality
• Non Point Source Pollution
• Maintaining aquatic habitats including the
  protection of riparian environments

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Water Quality Protection Options

• Ponds and Lakes in series
• Wetland plantings
• Aerators
• Structural devices such as vortex units,
  oil/water separators and trash screens
• Vegetated ditch bank programs

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Septic System Management

• Site Drawings should be kept of the system
  including locations of septic tank, distribution
  box and lines, seepage field or sand filter,
  chlorination tank and outlet
• To prevent damage, avoid allowing heavy equipment
  to travel on top of the system
• Minimize solids loading by avoiding the use of a
  garbage disposal
• Avoid introducing materials that are not readily
  decomposed such as plastic items and trash

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Septic System Management

• Maintaining vegetation (preferably grass) by
  mowing regularly and removing woody vegetative
  growth
• Inspecting systems, looking for evidence of
  problems such as sewage odors, backups of
  wastewater in lines or distribution box and
  ponding of wastewater on ground over seepage
  field
• Pumping out septic tanks as needed
• Coordinate with local Health Departments on
  monitoring of private systems

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Assessing Your Program

• Documenting Stormwater Program Activities
• Raising Awareness
• Changing Behavior
• Reducing Loads From Sources
• Improving Runoff Quality
• Protecting Receiving Waters

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Assistance for Municipal Operations Program

• USEPA webcasts at http//www.epa.gov/npdes/trainin
  g
• -Financing a Municipal Storm Water Program
• -Killing Two Birds With Stone Building a
  Local Program to Maintain Storm Water BMPS and
  Pollution Prevention for Municipal Operations
• -Additional MS4 guidance on Illicit Discharge
  and Elimination, Public Education and
  Involvement, Construction and Post Construction
  and other MS4 issues

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Websites

• General Ms4 information
• http//epa.state.il.us
• USEPA document on developing SWPPPs and BMPs
• http//epa.gov/npdes/pubs/owm0236a.pdf
• Integrated Pest Management Guidance from the
  Safer Pest Control Project
• http//spcpweb.org

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Websites

• The Chloride Reduction Study from the Dupage
  River Salt Creek Workgroup
• http//www.drscw.org
• Publications including Highway Salt and Our
  Environment and The Salt Storage Handbook can
  be downloaded at
• http//www.saltinstitute.org/34.html

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• Questions?