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Webcast 1:

Municipal Pollution
Prevention/ Good
Housekeeping

1
Webcast 1:
Municipal Pollution Prevention/Good
Housekeeping

May 14, 2009

Michael Novotney, Center for Watershed Protection


Reggie Korthals, Indiana Department of Environmental
Management
Srinivas Valavala, Richland Co. (SC) Department of Public Works
Dave Hirschman, Center for Watershed Protection
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Welcome to the Webcast
• To Ask a Question – The lower left-hand corner of the screen
contains a chat box. Click on the “Private” tab and then
“Leaders & Assistants.” Type your question in the box and
click on the arrow to submit it. If you use “Private” chat, your
question won’t be visible to all attendees. We will try to
answer as many questions as possible during the webcast.
• To Answer a Poll Question – Polling questions will appear
throughout the webcast. To answer a poll question, click on
the radio button to the left of your answer and click submit.
Do not type your answer in the chat box.
• To Adjust How the Slides Appear on Your Screen – On the top
of your screen, click on the small down arrow next to the
button that looks like . Scroll down to “Zoom” and
click on “Auto Fit.”

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Welcome to the Webcast
• To Complete the Webcast Survey – After the
webcast, we will have a short multiple choice survey
to get feedback on your experience. Please take a
few minutes to fill the survey out so we can identify
areas for improvement.
• Continuing Education Credits – We are offering CEUs
for our watershed and stormwater management
webcast series. A total of 1.0 CEU can be earned for
attending five webcasts. Only the registered attendee
is eligible to earn the CEU. The registered attendee
must watch the entire webcast. Email
webcast@cwp.org if you are interested in earning
CEUs and did not indicate this during the registration
process.
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Webcast Outline
• Introduction
• Pollution Prevention/Good Housekeeping
Basics
• Developing an Effective Program
– Program Scoping
– Focusing Your Efforts
– Selecting and Implementing Pollution Source
Control and Treatment Practices
• Case Study
– Richland County, South Carolina
• Helpful Tips for Building a Better Program
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What is Good Housekeeping?
• Some may think that it’s just a monthly magazine
• Others may offer up the following answers:
– Part of a community’s overall stormwater program
– Use of municipal facilities and operations to
demonstrate better stormwater management (i.e.,
leadership)
– Training municipal employees to prevent pollution in
their everyday activities
• In practice, it’s all of these…

6
What is Good Housekeeping?
• So, let’s agree on a working definition…
• Pollution prevention/good housekeeping is:
– The assessment and subsequent alteration of
municipal operations to reduce the amount of
pollution entering the storm drain system and,
eventually, receiving waters
• Why undertake such a challenging task?

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Why Good Housekeeping?
• It is required! Stormwater TSS (%) TP (%)
Management
– NPDES Municipal Separate Storm Practice
Sewer System (MS4) Permit
Dry Ponds 49 20
• It effectively prevents and
reduces stormwater pollution Wet Ponds 80 52
– Our stormwater BMPs can’t do all
the work… Wetlands 72 48
– Benjamin Franklin probably put it
best when he said: “an ounce of Filtration Practices 86 59
prevention is worth a pound of
cure” Infiltration 89 65
Practices
Open Channels 81 24

Source: NPRPD, Version 3 (CWP, 2007)

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Pollution Prevention/Good
Housekeeping Program Requirements
• What do the NPDES Phase II stormwater rules
require?
– Develop and implement a program with the
ultimate goal of preventing or reducing
polluted runoff from entering the storm drain
system and receiving waters
– Train municipal employees on incorporating
pollution prevention/good housekeeping
practices into municipal operations
• How does a community go about addressing
this task?
9
Guest Speaker
• Reggie Korthals
– Program Coordinator, Indiana MS4
Rule 13 Program
– Wetlands and Stormwater Section,
Office of Water Quality, Indiana
Department of Environmental
Management
– Works with Indiana communities on
permit compliance and Stormwater
Quality Management Plan
implementation

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Indiana Department of
Environmental Management
• Office of Water Quality,
Wetlands and Stormwater
Section
– http://www.in.gov/idem
– http://www.in.gov/idem/4900.htm

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Guest Speaker
• Srinivas Valavala
– Stormwater Manager
– Stormwater Management
Division, Department of Public
Works, Richland Co., South
Carolina
– Making great strides in building
and improving the Richland Co.
stormwater management
program

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Richland County, South Carolina
• Population
– 357,734
• Area
– Land: 756.41 sq. mi
– Water: 15.3 sq. mi
• Stormwater Management
Program
– Funded through millage
tax
– 2008 mill rate = 3.3 mills
• NPDES Phase I Permit
– First Issued in 2001
– Renewed in 2006

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Stormwater Management Program
• Stormwater Management Division,
Department of Public Works
– Implements stormwater management program to
meet NPDES Phase I permit requirements
– Coordinates with other divisions and departments
• Administration Division
• Engineering Division
• Roads and Drainage Division
• Department of Planning & Development Services
• Special Services
• Utilities & Services Division

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NPDES Phase I Permit
• Has been a bumpy ride
– EPA Audit in Dec 2003
– Consent Order in 2005
– Penalty of $830,549.00
– Quarterly payment plan of $41,500 till April 15,
2011
– Corrective Action Plan (CAP) incorporated into
reissued permit
• Good housekeeping program (e.g., SWPPPs,
SPCCs, employee training program) is result
of CAP requirements
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Good Housekeeping Program
• SWPPPs and SPCCs for publicly-owned or
-operated hotspot facilities
• Post-construction stormwater inspection and
maintenance program
– Publicly-owned or -maintained ponds and ditches
– Maintenance of public stormwater infrastructure
• Other pollution prevention programs
– Publicly-owned or -maintained parking lots
– Publicly-owned or -maintained dirt roads
– Publicly-owned parks and recreational areas to control
pesticides, herbicides and fertilizers
• Employee training program

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Poll Question #1
• I work for ________?
– Phase I MS4 (city, county)
– Phase II MS4 (town, city, county, other)
– State/Federal Government
– Consulting Firm
– Nonprofit Organization
– Other
– Next to nothing

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Poll Question #2
• How many people are participating in the
webcast today at your location?
– Just me
– 2 to 5
– 6 to 10
– 10 to 20
– More than 20

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Poll Question #3
• How did you hear about this webcast?
– CWP Runoff Rundown
– CWP Website
– US EPA Website
– NPS Information Exchange Email
– NPDES News Email
– CWP Presentation/Staff
– Colleague
– Other

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Poll Question #4
• How would you characterize your community’s
good housekeeping program?
– Bought our magazine subscription this year
– Just getting started
– Has already started, but could use some guidance in
scoping and developing the program
– Has already started, but could use help evaluating
and expanding the program
– Has been in place for some time, looking for a few
new tips

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Municipal Operations Tour
• The nature, scope and distribution of
municipal operations can vary greatly
– Within a single community
– From one community to the next
• To get a sense of this diversity, let’s take a
tour of the fictional community of
Cleanwater, Maryland

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Municipal Operations Tour
• As we hit each stop on the tour, ask
yourself these questions:
– What facility or operation is shown?
– What impact does it have on water quality?
– Is it a good example or bad example of
municipal pollution prevention/good
housekeeping?
– What, if any, improvements could be made?

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STOP 1
STOP 2
STOP 3
STOP 4
STOP 5
STOP 6
STOP 7
STOP 8
Take Home Points
• Communities typically conduct many different
operations that can influence water quality
– Some for better, some for worse
• Although there are some easy “fixes”, it’s difficult
for a community to assess and improve all of its
operations
– Particularly with limited resources
• These complexities make building a good
housekeeping program a challenging task!

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The Indiana Experience
• Challenges in Indiana include:
– Huge diversity in municipal operations
– Limited program planning and scoping
– Level of effort based on available staff and funds
– Developing realistic program goals and milestones
– Limited training for both large and small communities
to help them address these challenges
– Both IDEM and consultants provide training and
resources to MS4 communities
• Solution: Guidance, Guidance, Guidance!

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Pollution Prevention/Good
Housekeeping Program Development
• Take a strategic approach to developing or
improving your community’s pollution
prevention/good housekeeping program…

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Pollution Prevention/Good
Housekeeping Program Development
• Guidance on scoping and
developing a pollution
prevention/good housekeeping
program
• Our approach: Use a seven step
process to rapidly identify,
prioritize and investigate
municipal operations to determine
what improvements can be made
• Remember, the approach can be
tailored to the needs of and
resources available to your
community http://www.cwp.org

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Program
Developme
nt Process
Step 1: Identify Existing Municipal
Operations
• Purpose
– Scope the program
• Key tasks
– Inventory and categorize existing
municipal operations

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Park and
Street Repair Landscape
and Maintenance
Residential Maintenance
Stewardship Employee
Training Hotspot Facility
Management
Street
Sweeping

Storm Drain Stormwater


Maintenance Hotline Response

Utility
Maintenance

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Step 1: Identify Existing Municipal
Operations
• 10 major municipal operations that can impact
stormwater quality:
– Hotspot Facility Management
– Construction Project Management
– Street Repair and Maintenance
– Street Sweeping
– Storm Drain Maintenance
– Stormwater Hotline Response Create a simple
– Park and Landscape Maintenance list of municipal
– Residential Stewardship operations
– Stormwater Management Practice Maintenance
– Employee Training

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Stormwater Hotspots
Produce high levels
of stormwater
pollutants

Present a high risk for


spills, leaks or illicit
discharges
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Potential Municipal Stormwater
Hotspots
• Public Works Yards
• Vehicle Storage and Maintenance Yards
• Equipment Storage and Maintenance Yards
• Water and Wastewater Treatment Facilities
• Landfills
• Solid Waste Handling and Transfer Facilities
• Composting Facilities
• Public Buildings (e.g. Schools, Libraries, Police and
Fire Departments)
• Public Parks
• Public Golf Courses
• Public Swimming Pools

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Questions

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Program
Developme
nt Process
Step 2: Collect Information About Each
Operation
• Hotspot facilities:
– Location
• Street address
• Watershed information
• Map
– Facility type
– Facility manager information
• All other operations:
– Area/locations served Build on list you
created during
• Watershed information
Step 1
• Map
– Operation manager information
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Step 2: Collect Information About Each
Operation
• Coordinate with
operations managers
• Learn specific
information about the
operations they manage
• Educate them on:
– The requirements of the
NPDES MS4 permit
– The link between Program
Development
municipal operations and
stormwater quality
• Build relationships and
cooperation…
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The Indiana Experience
• Statewide move towards coordination
– Successful communities:
• Have support from elected officials
• Develop a communications chart
• Define staff responsibilities
• Include superintendents and department
heads in program planning
– Unsuccessful communities:
• Are a one man operation
• Have no program planning or internal
coordination
• Have no support from elected officials
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The Indiana Experience
• Statewide move towards coordination
– IDEM encourages making employees part of
the team:
• Consistent training
• Eyes in the community (e.g., spill kits &
emergency response numbers in vehicles)
• Seek input
• Recognize outstanding employee
performance
– Organize efforts through training workshops
and partnership building
– IDEM has developed an annual statewide
stormwater meeting
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Program
Developme
nt Process
Step 3: Complete the Municipal
Operations Analysis
• Desktop assessment to
help you focus your
housekeeping program
• Identify the operations
in your community that
should be the focus of
your initial efforts
Should be completed by
program coordinator… Moa Constrictor
with assistance! (Moa municipalis)

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Step 3: Complete the Municipal
Operations Analysis
• Start with a total score of 100
• Answer a series of questions about each
operation
– Points are deducted from total score when negative
answers are given
– May require additional conversations with operations
managers
– May also require site visits
• MOA provides a metric for comparing the
significance of each operation Manual 9,
Page 22
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MO-1: Hotspot Facility
Management
• How many hotspot
facilities are located in
your community?
• Has basic information
been collected about
each facility?
• Have all the hotspots
been the subject of on-
site investigations?
• Has a pollution
prevention plan been
created for each
facility?

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MO-3: Street Repair and
Maintenance
• Do you have
procedures in place
that prevent paving
materials and other
pollutants from
entering the storm
drain system?
• Are road salts and
other deicers properly
covered and stored?
• Is training provided to
municipal employees
and contractors?
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MO-4: Street Sweeping
• Do you have a street
sweeping program?
• Do you schedule
sweeping in the spring
to pick up sand, salt
and other winter
debris?
• Do you use modern
sweeper technology
that is capable of
picking up fine-grained
sediments (e.g.
regenerative air,
vacuum assist)?
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MO-9: Stormwater BMP
Maintenance
• Is your community
responsible for the
maintenance of
stormwater BMPs?
• Has your community
established an
inspection and
maintenance program
for these practices?
• Is there a dedicated
funding source that can
be used to fund the
program?
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MO-10: Employee Training
• Do you provide regular
pollution prevention
training to municipal
employees and
contractors?
• Do you track your
employee education
efforts?
• Have training efforts
increased awareness
about the link between
municipal operations
and stormwater
quality?
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Program
Developme
nt Process
Step 4: Focus Pollution Prevention/
Good Housekeeping Efforts
• Identify operations that will become the
focus of your initial efforts
• List operations in order of how your
community will address them based on:
– MOA results
– Scale of operations
– Available resources
– Pollutant(s) of concern - identified through
watershed planning or other regulations (e.g.,
TMDLs)

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The Indiana Experience
• Prioritizing good housekeeping efforts
– Efforts prioritized based on SWQMP
– Analyzing existing operations takes time and is
a step that is often skipped; more
training on completing the MOA is needed

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Poll Question #5
• What municipal operation is the top
priority in your community?
– Hotspot Facility Management
– Street Repair and Maintenance
– Street Sweeping
– Stormwater Management Practice Maintenance
– Employee Training
– Other

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Program
Developme
nt Process
Step 5: Investigate Municipal
Operations and Select Source Control
Practices
• Begin with operation at the top of your list
• Identify pollution sources and appropriate control
and/or treatment practices

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Investigative Methods
• Use desktop and field assessments to investigate
existing municipal operations
• Take lots of pictures!!!
Municipal Operation Primary Supplementary
Hotspot Facility Management MO-1 (9) HSI (11)
Construction Project Management MO-2 (9)
Street Repair and Maintenance MO-3 (9)
Street Sweeping MO-4 (9) SSD (11)
Storm Drain Maintenance MO-5 (9) SSD (11)
Stormwater Hotline Response MO-6 (9)
Park and Landscape Maintenance MO-7 (9) USA (10), PAA (11)
Residential Stewardship MO-8 (9) NSA (11)
Stormwater Management Practice MO-9 (9) Inspection Checklists
Maintenance
Employee Training MO-10 (9) 64
Poor Chemical Storage

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No Secondary Containment

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Good Secondary Containment

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Spill

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The Indiana Experience
• Investigating municipal operations
– Checklists are essential to collecting
information about individual operations
– Partnering and sharing resources has been
successful, particularly for employee training
and self-inspections
– Municipal Facility Field Inspection Worksheet
has also been helpful

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Selecting Pollution Source Control
and
Treatment Practices

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Step 5: Investigate Municipal
Operations and Select Source Control
Practices
• Once you’ve completed your investigation, summarize
your results in an implementation plan:
– Basic operation information
– Pollution sources
– Photographs
– Recommended improvements
– Measurable goals and implementation milestones
– Cost estimate
• Develop in coordination with operation manager
• Can take form of stormwater pollution
prevention plan (SWPPP)

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Richland Co. Good Housekeeping

Program
Result of CAP requirements
• Stormwater Pollution Prevention
Plans (SWPPPs) for 34 facilities
• Spill Prevention Control and
Countermeasure Plans (SPCCs)
for 6 facilities

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Richland Co. Industrial Facility
SWPPPs
• Richland Co. has 4 facilities regulated by the
NPDES Industrial Stormwater Program
– Richland Co. Landfill
– Columbia Owens Downtown Airport
– Public Works Maintenance Facility
– Broad River Wastewater Treatment Facility
• Detailed SWPPPs for these industrial facilities
developed in 2006; updated as needed
• Certified by plan preparer and facility manager
• Implementation in progress

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Richland Co. Industrial Facility
• Contents
SWPPPs
– Basic facility information
– Site map
– Potential pollution source assessment
– Materials inventory
– Record of previous spills and leaks
– Risk identification
– Pollution source control measures
– Total Maximum Daily Load (TMDL) analysis, if applicable
– Sampling and monitoring requirements
– Inspection and evaluation forms and checklists
• Pollution prevention team at each facility
– Updated as turnover occurs
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Richland Co. Industrial Facility
SWPPPs
• Pollution Source Control Measures
– General Housekeeping
– Preventive Maintenance
– Spill Prevention, Response & Reporting
– Non-Stormwater Discharge Assessment & Certification
– Pollution Source Control Practices
– Sediment & Erosion Control
– Post-Construction Stormwater Management
– Employee Training
– Monthly Inspections
– Annual Comprehensive Site Compliance Evaluation
– Record Keeping

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Richland Co. Municipal Facility
SWPPPs
• General SWPPPs developed for 30 smaller
municipal, non-industrial facilities
– Fire Stations
– EMS Stations
– Sheriff Stations
– Lower Richland Wastewater Treatment Facility
– Lower Richland Drop-off Center
– DPW Maintenance Camps
• Not required, but developed as a way to better
manage pollution at municipal facilities
• Semi-annual inspections
• Annual comprehensive compliance evaluation

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Richland Co. SWPPP Resources
• All of Richland County’s SWPPP inspection
forms, checklists and Standard Operating
Procedures are available online at:
http://richlandonline.com/departments/publicw

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The Indiana Experience
• Stormwater Pollution Prevention Plans
– Communities develop SWPPPs along with Fuel
Spill Prevention Standard Operating
Procedures
– IDEM is creating tools to assist in this process
• Worksheet for use on self-audits based on the US EPA
Program Evaluation Guidance
• Recommends adapting and using CWP Guidance
– IDEM compliance assistance during facility
inspections
• Office of Water Quality through coordination with Office
of Pollution Prevention

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Questions

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Program
Developme
nt Process
Step 6: Implement Source Control
Practices
• Work with operation managers to
implement prescribed practices
Pollution Source Pollution Source Control Practices
Vehicle operations (maint.) Drip pans, tarps, secondary containment
Vehicle operations (fueling) Covered fueling areas, spill response
Outdoor materials (loading) Covered loading/unloading areas
Outdoor materials (storage) Secondary containment, inventory control
Waste management Liquid/solid separation, covered dumpsters
Physical plant (parking lot) Dry clean up methods, street sweeping
Turf/landscaping areas Careful pesticide and fertilizer applications
Stormwater runoff On-site stormwater retrofit
Any Employee training

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Richland Co. Employee Training

Program
Addresses NPDES Phase I permit
requirements
– Part of CAP requirements
• Important part of County’s Pollution
Prevention/Good Housekeeping Program
• All employees receive annual training on a variety
of topics

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Employee Training Program
• Annual training on various topics
– Safety FIRST
– SWPPPs and SPCCs
– Stormwater BMPs (BMP Manual)
– Illicit Discharge Detection and Elimination
– Industrial Stormwater Discharges and Facility
Inspections
– Erosion and Sediment Control
– Pesticide, Herbicide and Fertilizers Control
– Good Housekeeping
– Materials Handling
– Data Management
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Employee Training Program
• Training materials developed both in- and
out-of-house
– Decision based on expertise and resources
• Example: Brochures for various activities
and operations
• Training materials available online:
http://richlandonline.com/departments/publicw

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Training…Beyond Employees
• Demonstrates municipal leadership
• Examples
– Developers conference
– Industrial operators conference
– Carolina Clear Program Stormwater Consortium events

Lead Activity Target Target Participation by


Service Geography Pollutant(s) other Service
Provider Providers

Carolina Partnering for Water Richland sediment, Clemson


Clear Quality presentation to County nutrients, Cooperative
Program the Chamber of bacteria, Extension
Commerce - how debris, Service,
businesses can get household Richland County
involved in water quality hazardous
protection waste, oil and
grease 85
Srini’s Top 10 Training Tips
1. Assign responsibility for conducting
employee training
2. Spend some time planning an employee
training program and
document in stormwater
management plan
3. Schedule training events and develop an
annual training calendar
4. Provide training at employee orientation
and on an annual basis
5. Only properly trained employees should
clean up spilled materials; incorporate
“spill cleanup” into job descriptions 86
Srini’s Top 10 Training Tips
6. Provide on-the-job training
7. Explain the reason for the training and
why it is important; don’t
just tell an employee what
to do (i.e., ownership stake)
8. View employee training program as a
“living” program; revise as necessary
9. Make records and track training activities
for reporting purposes
10. Document, Document, Document!
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Questions

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Program
Developme
nt Process
Step 7: Evaluate Progress in
Implementation
• Important, but often overlooked step in
the process
• Annual (or more frequent) review of
measureable goals and implementation
milestones
– Can also use to satisfy NPDES MS4 permit
reporting requirements
– Use results to revise and improve program

90
Step 7: Evaluate Progress in
Implementation
• Variety of methods can be used
– Implementation surveys
– Program effort
– Employee awareness surveys
– Water quality surveys
• Find an effective way to figure out what’s
been done and what still needs to be
done…

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The Indiana Experience
• Evaluating progress in implementation
– MS4s are required to establish specific
reduction percentages and timetables
– Reductions are identified in each individual
SWQMP
– MS4s demonstrate at evaluations, with proper
documentation, that reduction goals have or
have not been met
– Better recordkeeping equals easier evaluation
process

92
Program
Developme
nt Process
Budgeting and Scoping Your Effort
• Decent planning level estimates can be
obtained using a two step process:
– Develop measurable program goals and
implementation milestones
– Estimate level of effort required to meet
measurable goals
• Program goals should be consistent with:
– Program resources
– Existing practices and programs
– Scope and diversity of municipal operations
See Manual 9 for
Guidance
94
Manual 9, Page 17-18
Manual 9, Page 20
Reggie’s Top 11 Program Building Tips
1. Develop interest and support from
elected officials
2. Develop support from department heads
and superintendents
3. Develop a communications chart and assign
responsibilities
4. Internal pollution prevention team should
meet on a regular basis
5. Engage employees and recognize their
contributions; they are the eyes of the
community
97
Reggie’s Top 11 Program Building Tips
6. Provide regular employee training
7. Develop partnerships with other MS4s;
maximize funding
8. Develop partnerships with SWCDs and
watershed organizations
9. Document, document, document!
10. Never be afraid to ask for help
11.Use existing materials and
resources; don’t re-invent the wheel

98
Resources
• Last installment of USRM
series
• Resource for building
pollution prevention/good
housekeeping programs
• Information on:
– Municipal operations
– Pollution prevention/good
housekeeping practices
– Program scoping and
http://www.cwp.org
development
• Also see Resource List
99
Resources
• Operations and facilities notebooks, example
SWPPPs and educational posters developed by
the North Texas Council of Governments:
– http://www.nctcog.org/
– http://www.nctcog.org/envir/SEEclean/stormwater/program-ar
• SWPPP and employee training materials
developed by Richland Co., South Carolina:
– http://richlandonline.com/departments/publicworks/
NPDES_Industrial.asp
– http://richlandonline.com/departments/publicworks/
NPDES_Industrial.asp

100
Questions

101
Webcast Archive
• We will make every effort to post the
archive as quickly as possible. The
archive should be available on the first
Monday following the webcast, pending
any edits.
• Registered participants will receive email
instructions for accessing the archived
webcast.
• The archive will be downloadable and
can be saved on your local machine.
102
Next Webcast
• Managing Stormwater in the Age of
Budget Cuts
• June 17, 2009, 12:00 – 2:00 PM EDT
• Free!

• Register at
http://www.cwp.org/Webcasts

103
Upcoming Webcasts
• Stormwater Retrofitting
• October 14, 2009, 12:00 – 2:00 PM EDT
• Urban Watershed Forestry
• November 18, 2009, 12:00 – 2:00 PM EST
• Erosion and Sediment Control
• December 15, 2009, 12:00 – 2:00 PM EST

• Register at http://www.cwp.org/Webcasts

104
Post Webcast Information
• Continuing Education Credits – We are offering CEUs for our
watershed and stormwater management webcast series. A
total of 1.0 CEU can be earned for attending five webcasts.
Only the registered attendee is eligible to earn the CEU. The
registered attendee must watch the entire webcast. Email
webcast@cwp.org if you are interested in earning CEUs and
did not indicate this during the registration process.
• Participation Certificate – Participation certificates are also
available. If you have multiple attendees, please save the
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• To Complete the Webcast Survey – We will be providing
you with a short multiple choice survey to get feedback on
your experience. Please take a few minutes to fill the
survey out so we can identify areas for improvement.

105