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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
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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 Post-Construction (Permanent) Site 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
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 Stormwater “how-to” for TBR project managers Design, including stormwater Plans review checklist List of acceptable practices Design includes permanent SW treatment practices CGP application Design guidance TDEC NOC As Built Certification form As built certification Construction begins Monthly Audit checklist: Campus Rep Standard operation and maintenance plans Contractor: twice weekly inspections Construction complete Notice of Termination: TBR Project Manager Maintenance SOP by campus Long term maintenance
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
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
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
MS4 Permit Req’t 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: 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.
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