E. Pollution Prevention / Good Housekeeping for Community Operations (MCM #6)
1. The Permit Requirement (per Ohio EPA draft NPDES Permit)
2. Pollution Prevention and Good Housekeeping Plan
The BMPs, measurable goals, and responsible parties in this Pollution Prevention and Good Housekeeping Plan are detailed in Table 5. In addition to Table 5, per Ohio EPA draft NPDES permit requirement 3.2.6.2, we are documenting our decision process with the following information required by the draft permit.
3.2.6.2.1 Your operation and maintenance program to prevent or reduce pollutant runoff from your community operations. Your program must specifically list the community operations that are impacted by this operation and maintenance program. You must also include a list of industrial facilities your community owns or operates that are subject to the Ohio EPA's Industrial Storm Water General Permit or individual NPDES permits for discharges of storm water associated with industrial activity that ultimately discharge to your MS4. Include the Ohio EPA permit number or a copy of the Industrial NOI for each facility.
3.2.6.2.2 Any government employee training program you will use to prevent and reduce storm water pollution from activities such as park and open space maintenance, fleet and building maintenance, new construction and land disturbances, and storm water system maintenance. Describe any existing, available materials you plan to use. Describe how this training program will be coordinated with the outreach program developed for the public education and involvement minimum measure and the illicit discharge minimum measure.
3.2.6.2.3.1 Maintenance activities, schedules, and long-term inspection procedures for controls to reduce floatables and other pollutants in your MS4.
3.2.6.2.3.2 Controls for reducing or eliminating the discharge of pollutants from streets, community parking lots, maintenance and storage yards, waste transfer stations, fleet maintenance shops with outdoor storage areas, and salt/sand storage locations and snow disposal areas you operate.
3.2.6.2.3.3 Procedures for the proper disposal of waste removed from your MS4 and your community operations, including dredge spoil, accumulated sediments, floatables, and other debris.
3.2.6.2.3.4 Procedures to ensure that new community flood management projects are assessed for impacts on water quality and that existing projects are assessed for incorporation of additional water quality protection devices and practices.
3.2.6.2.4 Who is responsible for overall management and implementation of your pollution prevention/good housekeeping program and, if different, who is responsible for each BMP identified in this program.
3.2.6.2.5 How you will evaluate the success of this minimum measure, including how you selected the measurable goals for each of the BMPs.
Table 5: Pollution Prevention and Good Housekeeping Plan
Best Management Practice & Strategy
Schedule Measurable Goals Responsible Party Operation and maintenance program to prevent or reduce storm water pollution from community operations. Develop program in 2003. Implement program in 2004. Storm Water Management Committee: Working with Service Director/Road Superintendent, develop an O&M program. Service Director/Road Superintendents: Assist in O&M program development. Implement O&M program. Community staff education program on pollution prevention. Develop program in 2003 Implement program in 2004 Storm Water Management Committee: Working with Service Director/Road Superintendent, develop education program. Service Director/Road Superintendents: Assist in education program development. Implement education program. Catch Basin Cleaning: Community will continue current catch basin cleaning program. Catch basins are cleaned once every 3-4 years . Village Enginer/Service Director/Road Superintendent. Salt Storage and Applications: Community uses an average of 1,500 tons per season. The Community does not have a "bare pavement policy" but does experience constant pressure to have roads running water at all times. In snow situations, hills and intersections are salted on the first pass and roads with heavier volume receive more attention. Applications include a combination of salt, cinders, and ice grits. These are stored under roof. Current practices will be continued. Review salt application/storage for pollution prevention options in 2003. Service Director/Road Superintendent Storm Water System Maintenance: Ditches are maintained to control storm water. When cleaned, back slopes are cut where necessary to make maintenance easier and to prevent erosion. New ditches are lined with erosion control matting. Continue current ditch maintenance program. Review storm water system maintenance for pollution prevention options in 2003. Service Director/Road Superintendent: Fleet Maintenance: Oil is drained from equipment into drain pans and transferred to an above-ground tank. Continue existing fleet maintenance. Review fleet maintenance for pollution prevention options in 2003. Service Director/Road Superintendent Disposal of Waste Collected through Community Operations: Collected leaves are composted at the Community composting facility. Waste collected from storm water system maintenance is made available to interested residents. Used motor oil and antifreeze are collected for recycling. Continue existing activities. Review waste disposal for pollution prevention in 2003 Service Director/Road Superintendent
a) 3.2.6.1.1 Develop and implement an operation and maintenance program that includes a training component and has the ultimate goal of preventing or reducing pollutant runoff from community operations; and
b) 3.2.6.1.2 Using training materials that are available from Ohio EPA or other organizations, your program must include employee training to prevent and reduce storm water pollution from activities such as park and open space maintenance, fleet and building maintenance, new construction and land disturbances, and storm water system maintenance.
3.2.6.2.3 Your program description must specifically address the following areas: