Script for Module 2: What is a SWPPP



Script for Module 2: Enhanced Systems

Slide 1: Today’s focus is on structures designed specifically to reduce pollution of runoff and/or runoff volumes.

Slide 2: We’ll review the Good Housekeeping goals of identifying and describing those Best Management Practices (BMPs), and also inspecting and maintaining them.

Slide 3: Throughout this series, we’ll read each Good Housekeeping Goal as it’s written in the General Permit. Then we’ll review some background that may help clarify or expand on the intent of the goal. Next will be a discussion on what our MS4 (Municipal Separate Storm Sewer System) does to meet that goal, and how we report progress. As you think about how your work meshes with the goal, you may come up with some ideas on how to improve the way we do things – please write them down on the sticky notes and stick them on the flip chart. If they don’t come up beforehand, we’ll review your ideas at the end of the session.

Slide 4: The first goal of the Operation and Maintenance (O&M) program is that our MS4 have procedures for the identification of structural BMPs that we own or operate. “The operator must identify and list the specific location and a description of all structural BMPs in the SWMPP at the time of application and update the information in the Annual Report.” (Remember SWMPP stands for Stormwater Management Program Plan.)

Slide 5: Examples of structural BMPs include storage practices such as wet ponds and detention basins, filtration practices such as swirl separators or grass filter strips, and infiltration practices such as retention basins. At present, most of our BMPs are basins.

Trainer: Change the bold italicized text to reflect your dominant BMP.

Slide 6: Their purpose is to mitigate some of the problems that arise in the quantity and quality of runoff as land is more intensely developed.

Slide 7: At first we were looking to control flooding problems, then later recognized the importance of removing pollutants in runoff by allowing settling of suspended solids. As our understanding of runoff and treatment techniques continues to evolve, we’re now rethinking the conventional “collect and treat” approach to storm system design to focus on small, vegetated systems designed for better filtering and treatment of runoff pollutants and infiltration to reduce runoff volume.

Slide 8: As a matter of fact, the RI Legislature passed a law last year that requires the use of low-impact design techniques to the maximum extent practicable for any regulatory program that looks at stormwater impact.

Slide 9: So who’s responsible for making sure these BMPs are providing the treatment they were built to provide? Let’s step back for a minute and consider the “system” of runoff in a watershed. There’s an area of our MS4 where water is making its way to (insert local water body, i.e. Narragansett Bay). Some gets there directly, without entering any pipe or swale or road. Some gets there via a private system, for instance a catch basin in a parking lot right next to the water. Some of the rain falls on the state highway, and is RIDOT’s responsibility, some becomes the responsibility of quasi-public agencies such as (insert name of quasi-public agencies in your area that handle their own stormwater, such as URI or Quonset/EDC). A large percentage enters the system owned by the local city or town. And some starts in one MS4 and ends up in another because the systems are interconnected.

Note To Trainer: Change bold italicized text to indicate the local water body where drainage in your municipality discharges to up in the text. Change bold italicized text to indicate which quasi-public agencies are responsible for drainage within your municipality.

Slide 10: Most of the runoff our drainage system receives goes directly to a surface waterbody. But some goes first to a BMP. And some of those are publicly-owned, and others are private. Private BMPs are in most cases owned by a homeowners association created to meet subdivision regulations.

Note to trainer: If your system does not connect to any private BMPs, skip the last sentence and the next 2 slides.

Slide 11: The municipality gave permission to the developer to build on the assumption that BMPs would be installed and maintained, either by a homeowners association or the owner of a commercial lot.

Slide 12: Whether the private BMP discharges to the municipal system or directly to water, we now have a responsibility under another section of the General Permit to make sure they are also functioning properly.

Slide 13: So, the ideal stormwater manager can point to any area in the MS4 and tell you where the water goes and how it gets there. They know who to call when there’s a problem.

Slide 14: This ideal manager also knows which systems have been enhanced by structural BMPs, where those structures are, what type they are, what condition they’re in and who’s responsible for maintaining them.

Slide 15: Unfortunately, the ideal manager left our employ awhile back, and forgot to write everything down. So we’ve had to recompile the information to answer these concerns.

Slide 16: (Talk about your inventory, how it meshes with the maps of outfalls and catch basins required under the Illicit Discharge Minimum Measure, how you differentiate between public-owned and private-owned [covered under Post-Construction Minimum Measure], what’s used as a database and how info is shared among departments, etc).

Slide 17: Hopefully, we’ve learned a lesson from the loss of the ideal stormwater manager, and no longer rely on someone keeping everything in their head. The aim is to have a user-friendly database that reminds you when it’s time to schedule inspection or maintenance, allows you to report your activities and findings, and gives the supervisor enough information to prepare short- and long-term budgets.

Slide 18: Under another state law, we now have to include a field in the database that designates whether or not there are flooding problems associated with the structure. As you’ll see later in the presentation, this designation should affect how we schedule inspections.

Slide 19: Both the map and the database will need to be constantly kept up to date in order to remain useful over the long-term. The MS4 also needs to supply those updates to RIDEM as part of the Annual Report.

Slide 20: So, if you see something out there as you drive around, and it’s not shown correctly on the map that you keep in your vehicle, make note of it and report the correction as soon as you get back.

Note to trainer: You may want to ask staff to take a look at the map/database now, and note any omissions/errors that they see. Update this slide to reflect how you wish for updates to the map to be recorded (ie: fill out a specific form and send it to a specific person/office)

Slide 21: So we think we know where everything is. Now we need to show RIDEM that we’re keeping everything in good working order. The Permit requires “procedures for inspections, cleaning and repair of detention/retention basins, storm sewers and catch basins with appropriate scheduling given intensity and type of use in the catchment area. The operator must develop a maintenance schedule for inspection and maintenance of BMPs. The maintenance program must at a minimum incorporate all permit requirements and maintenance specifications of the particular BMP. Maintenance schedules must address issues related to the performance of BMPs observed during their inspection. The operator must make changes to the frequency of maintenance of structural BMPs when dry weather surveys of outfalls and inspections of the system and BMPs reveals that the maintenance frequency is not adequate. The operator must maintain records on inspections and maintenance performed on structural BMPs.” In other words, make sure all the structural BMPs are working like they’re supposed to work.

Slide 22: So just how are they supposed to work? Each type works a little differently, but they all have a few things in common. For instance, they all receive runoff from a particular area, called a catchment.

Slide 23: They all let that water back out, although it’s usually metered in some way. The structure holds a certain amount of water until the chance of flooding and/or the pollutant load diminishes, depending on its design.

Slide 24: How well the structure does its job is highly dependent on how well it was designed in the first place, how closely installation followed the design, and how well it is maintained. It will not function as designed if it has been forgotten.

Slide 25: The structure may overfill, for example, backing up or overtopping because it simply isn’t large enough. This could be due to design or installation errors, or someone expanding the drainage system without exploring where the water goes…

Slide 26: But the most common problem is lack of maintenance. In this photo the volume of the structure is completely filled, so water backs up across the street, exacerbating flooding problems.

This particular structure was supposed to be a “bio-swale” – sediments were to drop out in this first cell, then wetland plants would take up nitrogen and other pollutants. In its current condition, runoff by-passes the swale so the pollutants are instead delivered to an estuary.

Slide 27: Other issues associated with BMPs may be due to problems with the outlet control structure; the water isn’t getting metered as intended. Many retention basins, for example, are slow to infiltrate because too many construction vehicles drove over the bottom, compacting the soil. Once again water quality benefits are diminished, and downstream areas can be flooded or otherwise damaged. Repair can become very expensive.

We are not alone in experiencing more flooding as the area is developed. Remember that State law passed in 2006 – the legislature wants us to note the problem systems, inspect them at least once a year, and maintain them as necessary.

Slide 28: Just one more thing about flooding problems: I want to mention cumulative impact, which is really a design problem. Sophisticated hydrology models are needed to look at how multiple control structures work together to affect stream flow; it’s really beyond the scope of any one application for construction. So even if everything is working as designed, there can be problems because we’re still at the early stages of managing runoff on a watershed basis. The best we can do at this point is develop a good database that will eventually provide the information needed to consider such an evaluation.

Slide 29: Reviewing for adequacy of design and ensuring proper installation fall under other Minimum Measures of our stormwater General Permit. As Good Housekeepers of BMPs, we can assume that the structure is doing its job if we’ve been diligent in following an Operations & Management Plan, and/or it looks similar to its design or approved as-built drawings. That means we have to go and look at it.

Slide 30: Talk about your inspections of structural BMPs: how and when they are scheduled, where to find site-specific or generic forms, what is done during inspection, how field reports are entered into a database for evaluation and scheduling maintenance, how information is incorporated into the Annual Report.

The following 4 slides may assist in describing your program, or use them as suggestions for enhancing your program.

Slide 31: While the MS4 General Permit does not require annual inspections, the 2006 State law does require them for flood-prone storm systems. So you’ll see that our Inspection Schedule takes that into account.

Slide 32: If budget and staff time were no problem, we’d routinely inspect each MS4 BMP at least twice a year, with a cursory check after each major storm to make sure the inlets and outlets are flowing freely. We’d also be asking private owners to submit inspection reports, and conducting spot checks on them. If our inspection flagged the need for something more than routine maintenance, we’d schedule a thorough inspection, based on whether the structure is failing or just needs some beefing up, whether flooding is occurring, and the potential effect on downstream water quality. This level of inspection is estimated to need 1 FTE (Full-time equivalent) for every 250-500 BMPs, according to the Center for Watershed Protection.

Note to Trainer: Remove the sentence in bold italics above if you have no private BMPs

Slide 33: Routine inspections are essentially a check to make sure everything is in good working order. For most basins it would involve a simple “walk-around” to make sure water is getting in and out OK, slopes are stable with no trees on the dam or invasive species running rampant, pipes and controls are in good condition and litter is minimal. Also take note if the neighbors are encroaching on the easement, especially if they’re blocking access.

Before heading out to do an inspection, check the files for a BMP-specific inspection form, or we (will) have general forms based on the type of structure. We need to have the forms filled out, to document that we are indeed inspecting. Inspection dates and results will get entered into the database, and any additional maintenance will get added to the schedule.

Note to Trainer: Two sample inspection forms for basins is included in the workshop materials. The form RIDOT uses is located: Resources\RIDOTDatabase\RIDOT_BMP_Inspection_Forms and the other form is located: \Module2_Final\Resources\Pond Inspection Checklist

Slide 34: For an in-depth inspection, we need to know what the original designs or as-builts say. We’d then take the time to measure what’s out there today, and evaluate how important any differences are in terms of meeting the original goal of pollutant reduction and flood control. This would take a lot of time, so we need to carefully select which structures need this amount of work.

Slide 35: Maintenance schedules for a specific BMP are developed by reviewing a specific O&M plan, or the conditions attached to any permits issued at the time of construction, and the results of the latest inspection.

Slide 36: Routine maintenance is often scheduled to be performed at the time of the inspection. It includes removal of trash and excess vegetation, repairing minor erosion or sediment problems, and maintaining access to inlets and outlets. You can note actions taken right on the inspection form.

In your packet is a quick guide from Virginia that you can refer to before you head out to a particular type of BMP, to give you a sense of what you’ll be doing and what equipment you’ll need.

Note to trainer: Quick guide is located: \Module2_Final\Resources\BMP Maintenance Quick

Slide 37: Inspection may reveal additional work that needs to be done, including replacement of mechanical parts or removal of collected sediments. Hopefully, routine inspections will not be indicating the need to replace, although a number of structures are nearing the end of their designed lifetime.

Sediment removal may not require detailed engineering designs, but most other non-routine maintenance will probably require re-design. Most non-routine maintenance is also likely to require a permit or certification from Freshwater Wetlands or CRMC. Records of permits and actions taken should be part of the permanent file for the structure.

Slide 38: Keep safety in mind as you inspect and perform maintenance. Hopefully none of our structures look like this, but steep slopes can be slippery, and many are too steep for equipment. Make sure you have harness, gloves, face shield and safety line in the vehicle. Check OSHA requirements before entering any underground structures.

Slide 39: And wastes need proper disposal. We’ll talk about this again in Module 4.

Slide 40: Keeping track of what is seen and done around these structures should eventually pay off. Within a few years we should have a better sense of which structures need more attention, and where we can stretch out the time between inspections. We can pass on persistent problems to Planning and Engineering, so they can make sure new structures avoid those concerns. We’ll have a better sense of how much time and equipment is needed for maintenance, and we’ll have the backup information needed for budget requests. And we’ll have more information available to determine the need for retrofitting within a watershed.

FYI: RIDOT has an on-line presentation on some of the retrofitting it has done. Go to

Slide 41: The bottom line is that these structures were built for a purpose, a purpose that can affect the health and well-being of our citizens. And it’s our job to make sure that these structures are doing what they’re supposed to do. In most cases it’s not that difficult to keep them in good shape, so LET’S DO IT!

Slide 42: Thanks for your attention. Shall we see what we have or want to add to the flipchart, in terms of suggestions for improving our current procedures?

Note to trainer: Discuss any ideas that come up from discussions with the trainees regarding possible improvements to maintenance procedures.

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