Operation & Maintenance Requirements: Tips for Keeping Your Agency in Compliance

1. Operation & Maintenance Requirements: Tips for Keeping Your Agency in Compliance Kristin Kerr, P.E., QSD EOA, Inc. New Development Workshop May 22, 2013

2. Outline of Presentation • Permanent Stormwater Controls that Require O&M Verification Inspections • O&M Requirements in the Municipal Regional Stormwater Permit • The O&M Verification Inspection Plan • Tools for Conducting, Tracking and Reporting O&M Inspections • For more information…

3. Permanent Facilities that Require O&M Inspections • Provision C.3.h of the MRP requires agencies toconductinspectionstoverifyoperation & maintenance (O&M) of: • Stormwatertreatmentmeasures, and • Hydromodificationmanagementmeasures

4. Stormwater Treatment Measures • Low impact development (LID) treatment systems (biotreatment, infiltration, rainwater harvesting systems) Bioretention Area (biotreatment)

5. Stormwater Treatment Measures • Vault-based systems (hydrodynamic separators, media filters, proprietary tree well filters) Hydrodynamic Separator Media Filter Cartridge

6. Hydromodification Management (HM) Facilities • Basin, tank, pipe, orvaultwithspeciallydesignedoutlettoslowlyreleasewater. Detention basin with outlet structure

7. O&M Requirements(Provision C.3.h) • Agencies subject to the MRP must: • Require facility owners to conduct ongoing maintenance (e.g. , maintenance agreement). • Prepare and implement plan for annual O&M verification inspections, including new installations. • Conduct O&M verification inspections; provide enforcement as needed. • Track and report on inspections.

8. Model Maintenance Agreement • Requires property owner to assure ongoing operation and maintenance

9. WhataboutMunicipality-ownedFacilities? • O&M inspectionrequirements do notdistiguishbetween municipal and non-municipal facilities. • Inspect, track and reportonfacilitiesthatyourmunicipalityisresponsible for maintaining.

10. O&M VerificationInspection Plan • Each fiscal year, inspect: • Allnewlyinstalledstormwatertreatment and HM controlswithin 45 days of installation • 20% of the total number of installedstormwatertreatment and HM controls(whenrounding, round up!) • 20% of allinstalledvault-basedsystems(round up) • Allinstalledtreatment and HM facilitiesmust be inspected at least once every 5 years.

11. Lessons Learned from NOVs • Round up whencalculating 20 % of treatment/HM facilities per year, AND whencalculating 20 % of vaultsystems. • Ifyouragency has fewerthan 5 facilities, be suretoinspect at leastone per year. • AnnualReportingyearJuly 1 - June 30th • Nowis a good time toverifyyouhaveyourinspectionscompleted

12. Mosquito Abatement District Coordination • List of newly-installed facilities submitted each year: • To Mosquito Abatement District (MAD) • Also to Regional Water Board • Submitted before October 1 • Countywide Program makes the MAD submittal based on info in your Annual Report

13. Tools for Inspecting, Tracking & Reporting • O&M VerificationInspectionChecklist • AnnualReport O&M InspectionTable • Eachagencyshouldhaveaninternal tracking table • NOT submittedwithAnnualReport • Can berequestedby Regional Board at any time

14. O&M VerificationChecklist

15. AnnualReportFormC.3.h ReportingTable

16. Annual Report Form • Name of facility/site inspected • Address • If newly installed • Party responsible for maintenance • Date of inspection • Type of inspection (initial, annual, follow-up, spot) • Type of stormwater treatment/HM control • Inspection findings/results • Enforcement actions taken • Comments/Follow-up

17. Data Tracking • Similar to AR Data Except…… • Name of facility/site inspected • Address– specific description of location of treatment/HM controls • If newly installed – date of installation • Party responsible for maintenance • Date of inspection • Type of inspection (initial, annual, follow-up, spot) • Type of stormwater treatment/HM control – type and size • Inspection findings/results • Enforcement actions taken • Comments/Follow-up– corrective actions

18. For More Information… • Countywide Program Password Protected ND page www.flowstobay.org (click on “Municipalities,” then “ND”) • O&M Verification Inspection Plan Template • O&M Verification Inspection Checklist • Model maintenance agreement • Municipal Regional Stormwater Permit www.flowstobay.org (click on “Municipalities,” then scroll to “Municipal Stormwater Permit”)

19. Common Issues in Inspections of Newly-Installed Treatment Measures • Purpose of inspection • Whentoinspect • Whatto look forduringinspection • Commonissues • Checklistfor “45-day inspection”

20. Purpose of Inspection • Verifytreatmentmeasures and/orhydromodificationmanagementcontrols are installed per approvedplans. • At a minimum, inspectthosecomponentsthat are visible in thefinishedcondition. • Ifpossible, alsoinspectbelow grade componentsduringconstruction.

21. WhentoInspect • Within 45 days of installation • May conduct as part of overall final inspection of constructed project • May conduct during different construction phases (e.g. inspect underground elements, i.e. underdrain, while visible)

22. Prepare for the Inspection • Reviewprojectplanstoidentify: • Thenumber of treatmentmeasures and/or HM systemsto be installedonthesite. • Thelocations of treatmentmeasures and/or HM systems. • Thedimensions of treatmentmeasures and/or HM systems.

23. Prepare for the Inspection • Reviewprojectplanstoidentify: • Howhighflowswill be managed/diverted • Locations of underdrains and cleanouts • Type and extent of plantcover • Type of approvedirrigationsystem In thissystem, highflowswillenterraisedinlet.

24. During the Inspection • Confirmthatinstallationmatchesapprovedplansregarding: • Total number and type(s) of facilities • Location of facilitiesonthesite • Components and dimensions of facilities • Requestconfirmationfromsitesuperintendentthatbiotreatmentsoilis per MRP specifications

25. During the Inspection • Confirmthatinstallationmatchesapprovedplansregarding: • Type and extent of plantcover • Functionalirrigationsystem (ifprovided) • High-flow bypass oroverflowpath Overflowdraindesignedtokeepouttrash and debris.

26. Common Issues • Is there exposed soil? • Exposed soil should be covered with 2” of mulch, except for area immediately surrounding tree trunks (roots need air). • Will vegetation block inlets to the treatment measure when mature? Turf is blocking inlet; insufficient drop between pavement and top of grade in planting area.

27. Common Issues • Is there positive drainage to the treatment measures? • Is there permanent erosion control at points of concentrated flow? Cobbles reduce erosion at entrance to bioretention area.

28. Common Issues • Are plantshealthy? • Isthereaccumulation of sedimentfromconstructionactivity? • Accumulatedsedimentmust be removed.

29. O&M VerificationChecklistMay be usedfor “45-Day inspections”; willhaveto use Commentssection

30. Questions? JillBicknell, P.E. 408-720-8811 x1 jcbicknell@eoainc.com KristinKerr, P.E., QSD 510.832.2852 x 122 kakerr@eoainc.com