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Webcast 1: Municipal Pollution Prevention/ Good Housekeeping. Webcast 1: Municipal Pollution Prevention/Good Housekeeping. May 14, 2009 Michael Novotney, Center for Watershed Protection Reggie Korthals, Indiana Department of Environmental Management

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Webcast 1:

Municipal Pollution Prevention/ Good Housekeeping


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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 [email protected] 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…


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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!

    • NPDES Municipal Separate Storm Sewer System (MS4) Permit

  • It effectively prevents and reduces stormwater pollution

    • Our stormwater BMPs can’t do all the work…

    • Benjamin Franklin probably put it best when he said: “an ounce of prevention is worth a pound of cure”

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?


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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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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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http://www.cwp.org

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



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Step 1: Identify Existing Municipal Operations

  • Purpose

    • Scope the program

  • Key tasks

    • Inventory and categorize existing municipal operations


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Park and Landscape Maintenance

Street Repair and Maintenance

Residential Stewardship

Employee Training

Hotspot Facility Management

Street Sweeping

Storm Drain Maintenance

Stormwater 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

Park and Landscape Maintenance

Residential Stewardship

Stormwater Management Practice Maintenance

Employee Training

Create a simple list of municipal operations


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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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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

      • Watershed information

      • Map

    • Operation manager information

Build on list you created during Step 1


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Program Development

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 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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Moa Constrictor

(Moa municipalis)

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…with assistance!


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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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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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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 Control Practices

Use desktop and field assessments to investigate existing municipal operations

Take lots of pictures!!!


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Poor Chemical Storage Control Practices


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No Secondary Containment Control Practices


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Good Secondary Containment Control Practices


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Spill Control Practices


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The Indiana Experience Control Practices

  • 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 Control PracticesTreatment 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 Control Practices

  • 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 Control Practices

  • 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 SWPPPs Control Practices

  • Contents

    • 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 Control Practices

  • 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 Control Practices

  • 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 Control Practices

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


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The Indiana Experience Control Practices

  • 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 Control Practices


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Program Development Process Control Practices


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Step 6: Implement Source Control Practices Control Practices

  • Work with operation managers to implement prescribed practices


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Richland Co. Employee Training Program Control Practices

  • 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 Control Practices

  • 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 Control Practices

  • 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/publicworks/NPDES_Industrial.asp


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Training…Beyond Employees Control Practices

  • Demonstrates municipal leadership

  • Examples

    • Developers conference

    • Industrial operators conference

    • Carolina Clear Program Stormwater Consortium events


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Srini’s Top 10 Training Tips Control Practices

  • Assign responsibility for conducting employee training

  • Spend some time planning an employee training program and document in stormwater management plan

  • Schedule training events and develop an annual training calendar

  • Provide training at employee orientation and on an annual basis

  • Only properly trained employees should clean up spilled materials; incorporate “spill cleanup” into job descriptions


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Srini’s Top 10 Training Tips Control Practices

  • Provide on-the-job training

  • Explain the reason for the training and why it is important; don’t just tell an employee what to do (i.e., ownership stake)

  • View employee training program as a “living” program; revise as necessary

  • Make records and track training activities for reporting purposes

  • Document, Document, Document!


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Questions Control Practices


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Program Development Process Control Practices


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Step 7: Evaluate Progress in Implementation Control Practices

  • 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


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Step 7: Evaluate Progress in Implementation Control Practices

  • 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 Control Practices

  • 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


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Program Development Process Control Practices


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Budgeting and Scoping Your Effort Control Practices

  • 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


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Manual 9, Page 17-18 Control Practices


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Manual 9, Page 20 Control Practices


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Reggie’s Top 11 Program Building Tips Control Practices

  • Develop interest and support from elected officials

  • Develop support from department heads and superintendents

  • Develop a communications chart and assign responsibilities

  • Internal pollution prevention team should meet on a regular basis

  • Engage employees and recognize their contributions; they are the eyes of the community


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Reggie’s Top 11 Program Building Tips Control Practices

  • Provide regular employee training

  • Develop partnerships with other MS4s; maximize funding

  • Develop partnerships with SWCDs and watershed organizations

  • Document, document, document!

  • Never be afraid to ask for help

  • Use existing materials and resources; don’t re-invent the wheel


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http://www.cwp.org Control Practices

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 development

  • Also see Resource List


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Resources Control Practices

  • 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-areas/pollution_prevention/index.asp

  • 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


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Questions Control Practices


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Webcast Archive Control Practices

  • 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.


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Next Webcast Control Practices

  • 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


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Upcoming Webcasts Control Practices

  • 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


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Post Webcast Information Control Practices

  • 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 [email protected] 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 certificate to your computer. You can type the attendees name in the name field and then print the certificate.

  • 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.


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