C. Construction Site Storm Water Runoff Control (MCM #4)
1. The Permit Requirement (per Ohio EPA draft NPDES Permit) The BMPs, measurable goals, and responsible parties in this Construction Site Storm Water Runoff Control Plan are detailed in Table 3. In addition to Table 3, per Ohio EPA draft NPDES permit requirement 4.2.4.2, we are documenting our decision process with the following information required by the draft permit.
3.2.4.2.1 The regulatory mechanism you will use to require E&SC at construction sites and why you chose that mechanism. If you need to develop this mechanism, describe your plan and schedule to do so. If your mechanism is already developed, include a copy of the relevant sections with your SWMP.
Moreland Hills will work with the CRWP to develop an ES&C legislation to be applied to construction sites over one acre in size. This method is chosen since it will be a Codified Ordinance that will be enforceable by penalties for non-performance.
3.2.4.2.2 Your plan to ensure compliance with your E&SC regulatory mechanism, including the sanctions and enforcement mechanisms you will use to ensure compliance. Describe your procedures for when you will use certain sanctions. Possible sanctions include non-monetary penalties (such as a stop work order), fines, bonding requirements, and/or permit denials for non-compliance.
Enforcement mechanisms will be explored by the Stormwater Management Committee, the Law Director, Village Engineer, Building Commissioner and Council. Mechanisms listed above will be considered.
3.2.4.2.3 Your requirements for construction site operators to implement E&SC BMPs and control waste at construction sites that may cause adverse impacts on water quality. Such waste includes discarded building materials, concrete truck washouts, chemicals, litter, and sanitary waste.
The ES&C legislation will address the proper disposal of construction site debris and waste products.
3.2.4.2.4 Your procedures for site plan review, including the review of pre-construction site plans, which incorporate considerations of potential water quality impacts. Describe your procedures and the rationale for how you will identify certain sites for site plan review, if not all plans will be reviewed. Describe the estimated number and percentage of sites that will have pre-construction site plan review.
Site plan review is required for all new residential, commercial site that requires earth disturbing activity in an area over one acre. Construction sites that are less than one acre, but adjacent to a water resource will require plan review. The Village Engineer is responsible for plan review. If necessary, the Engineer will request a review by SWCD.
SWCD will provide review service per the MOU enclosed.
3.2.4.2.5 Your procedures for receipt and consideration of information submitted by the public. Consider coordinating this requirement with your public education and involvement plan.
All information submitted by the public will be disseminated from the Village Hall personnel to the Village Engineer and Building Commissioner. Residents will be alerted, through the public education portion of the Plan, to contact the Village with sites that are being disturbed. The Building Commissioner/Engineer will review information and act to enforce the ES&C Ordinance.
3.2.4.2.6 Your procedures for site inspection and enforcement of control measures, including how you will prioritize sites for inspection.
Sites will be inspected during each visit by the Building Commissioner for inspections of the structure. This inspection will be a general inspection to review that E&SC control measures are in place. Any deficiencies will be reported to the Village Engineer, who will then perform a detailed inspection and notify the Permit holder of deficiencies.
Enforcement shall be per the E&SC legislation that will be adopted.
3.2.4.2.7 Who is responsible for the overall management and implementation of your construction site storm water control plan, and if different, who is responsible for each of the BMPs identified in this plan.
The Village Engineer will be the main designee for the management of the plan. The Building Commissioner will assist the Engineer.
3.2.4.2.8 Describe how you will evaluate the success of this minimum measure, including how you selected the measurable goals for each BMP.
The E&SC program will be evaluated utilizing the following criteria:
Best Management Practice Schedule Measurable Goals Responsible Party Adopt erosion and sediment control ordinance: This will provide performance criteria, enforcement and penalty actions for construction site > 1 acre Adopt CRWP model ordinance in 2003. Enact enforceable legislation encompassing all issues of erosion and sediment control CRWP: Provide Phase II compliant model ordinance. Storm Water Management Committee: Review model, tailor to community needs, and recommend adoption to Council. Council: Adopt zoning ordinance.
Enter into Memorandum of Understanding (MOU) with SWCD: Through this MOU SWCD will provide support to Village on site plan review, inspection, and enforcement. Enter into MOU by Mid 2003. SWCD: Provide MOU for Village consideration. Storm Water Management Committee: Review model MOU with SWCD, modify as necessary for Community needs, and recommend adoption to Council. Council: Adopt MOU.
Attend SWCD trainings: Village staff attends regular SCWD training on erosion and sediment control to review site plans and inspect sites. Training in 2003 with annual refresher courses. Responsible Village Staff to attend at least one training seminar every two years SWCD: Provide training & be available to assist Village staff as needed. Storm Water Management Committee: Ensure training and annual updates occur. Village staff: Attend training and updates.
Review site plans: Village staff will review site plans of construction sites. Reviews begin after ordinance and MOU adopted and training complete. Plans for regulated sites reviewed prior to granting building permits. Review E& SC plans of all sites >1 acre or smaller sites if near high quality water body. Village Engineer: Review plans for regulated sites. SWCD: Provide review as requested by Village.
Inspect active sites: Village staff will inspect active construction sites. Inspections begin after ordinance and MOU adopted and training complete. Inspect sites at least once per month. Building Commissioner to perform general inspection during each building inspection visit. Village staff: Inspect active sites. Enforcement actions: Actions stated in E&SC ordinance Enforcement actions begin after ordinance and MOU adopted and training complete and as necessary. Notify violating party within 48 hours of inspection of violation. Village staff: Determine necessary enforcement and issue stop work orders and corrective action requirements consistent with E&SC ordinance. 
a) 3.2.4.1 Develop, implement, and enforce a program to reduce pollutants in any storm water runoff to your small MS4 from construction sites that result in a land disturbance of greater than or equal to 1 acre. Reduction of storm water discharges from construction activity disturbing less than 1 acre must be included in your program if that construction activity is part of a larger common plan of development or sale that would disturb 1 or more acres. Your program must include the development and implementation of, at a minimum:
1. 3.2.4.1.1 An ordinance or other regulatory mechanism to require erosion and sediment controls, as well as sanctions to ensure compliance, to the extent allowable under State or local law.
2. 3.2.4.1.2 Requirements for construction site operators to implement appropriate erosion and sediment control BMPs.
3. 3.2.4.1.3 Requirements for construction site operators to control waste such as discarded building materials, concrete truck washout, chemicals, litter, and sanitary wastes at the construction site that may cause adverse impacts to water quality.
4. 3.2.4.1.4 Procedures for site plan review which incorporate consideration of potential water quality impacts.
5. 3.2.4.1.5 Procedures for receipt and consideration of information submitted by the public.
6. 3.2.4.1.6 Procedures for site inspections and enforcement of control measures.
2. Construction Site Storm Water Control Plan