Stormwater Management Plan

Introduction

UA Little Rock is committed to eliminating pollution brought about by stormwater discharges as runoff from rain events on campus. Stormwater Discharge is defined by the Arkansas Department of Environmental Quality (ADEQ) as: “runoff from paved surfaces including streets, parking lots, and other impervious areas (e.g., buildings) during rainfall and snow events, which often contain pollutants in quantities that could adversely affect water quality.” UA Little Rock holds an individual, non-point source MS4 permit (ARR040020) granted by ADEQ that allows us to responsibly discharge runoff into storm sewers that empty into Coleman Creek and subsequently other waterways downstream. It is UA Little Rock’s responsibility to ensure that activities on campus are managed in such a way as to prevent harmful runoff.

As UA Little Rock constructs new, renovates existing, or demolishes old buildings, these activities create opportunities for rain events to collect sediments or harmful pollutants and discharge them into Coleman Creek. In an ongoing effort to minimize and eliminate pollution from stormwater, UA Little Rock Environmental Health and Safety (EHS) adopted policy and procedure to directly control construction activities on campus that may result in stormwater discharge pollution. These control measures, known as Best Management Practices (BMPs), include prevention measures that are carefully planned to eliminate sediment and/or chemical runoff from construction sites.

In addition to construction, EHS monitors other activities on campus that may cause pollution by stormwater discharge. Chemical waste and accidental spills offer opportunities for pollution. Automotive leaks in parking lots, building mechanical and electrical systems, and any process waste is monitored to ensure that no adverse materials are released into campus waterways or groundwater.

Purpose & Intent

The purpose of this Stormwater Management Program (SWMP) is to comply with the Arkansas Department of Environmental Quality (ADEQ) General Permit ARR040000 pursuant to Environmental Protection Agency (EPA) code 40 CFR 122.32. In accordance with the Arkansas Water and Air Pollution Control Act (Act 472 of 1949, as amended, Ark. Code Ann. 8-4-101 et seq.), and the Clean Water Act (33 U.S.C. 1251 et seq.), the discharge of stormwater from the Municipal Separate Storm Sewer System (MS4) at the University of Arkansas at Little Rock (UA Little Rock) is authorized. UA Little Rock holds an MS4 Individual Permit ARR040020 in which ADEQ grants, by primacy, UA Little Rock this authority to discharge stormwater runoff under the terms and conditions specified in ARR040000. UA Little Rock has completed a Notice of Intent (NOI), and this SWMP complies with Parts 2, 3, and 4 of the permit. The UA Little Rock Facilities Management (FM) department’s Associate Vice Chancellor (AVC) is responsible for administering the SWMP. Policy and program development is managed by the UA Little Rock Environmental Health and Safety (EHS) Director in conjunction with the UA Little Rock Environmental Health and Safety Committee (EHSC).

UA Little Rock consists of approximately 13,360 students, staff, and faculty. Universities are, within their borders, essentially a small community where people live and work every day. It is therefore each community member’s responsibility to recognize why and how stormwater pollution is generated and transported to affected waterways. In addition, contractors who work at UA Little Rock are under requirements to maintain practices that prevent runoff pollution from their activities. It is Facilities Management’s goal to monitor, inform, and train those in the community as to the best methods to maintain the integrity of the waters on campus and downstream. UA Little Rock has evaluated the permit requirements for the six minimum control measures specified in Part 3.2 of the general permit. Based on that review, UA Little Rock has selected Best Management Practices (BMPs) for each control measure that UA Little Rock believes will accomplish the overall goal of reducing pollution from stormwater runoff to the Maximum Extent Practicable (MEP). The Director of EHS is responsible for developing goals and identifying/implementing BMPs under ARR040020. The EHSC reviews and assists with program development.

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Sharing Responsibilities

UA Little Rock has the sole responsibility to implement all measures described in this program.

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Reviewing & Updating the SWMP

The EHSC will review the SWMP annually and evaluate the implementation and effectiveness of the SWMP components. If the SWMP needs to be revised, those revisions will be performed by EHS under advisement of the EHSC. When finalized, a revision(s) will be sent to ADEQ along with an explanation for and description of the changes. ADEQ will be notified in writing before any additions to goals, BMPs, authority or other pertinent processes occur and in accordance with section 3.4 of the general permit.

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Monitoring

UA Little Rock will evaluate program compliance, the appropriateness of identified BMP’s, and progress towards achieving identified measurable goals. The UA Little Rock campus has retention areas for stormwater that eventually drain to the Coleman Creek, which runs into the Fourche Creek Wetlands, which runs into the Arkansas River, which runs into the Mississippi River and on to the Gulf of Mexico. For UA Little Rock at this time, a Total Maximum Daily Load (TMDL) has not been established for the receiving waters. In addition, none of the steam areas on campus is 303(d) listed for impaired waters. UA Little Rock is not under any TMDL requirement per the individual permit. In addition, no discharges into 303(d) listed waters are applicable. Therefore, UA Little Rock will not sample and analyze the discharge from the small MS4 under an established program; however, if circumstances dictate the need for sampling and analysis, UA Little Rock will act appropriately. In addition, UA Little Rock may wish to sample according to construction site stormwater management protocol.

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Performance Standards

BMPs and other mechanisms will be reviewed at least annually and as needed to validate whether current methods are effective. Each method under the six minimum control measures have different and separate BMPs, and each will be qualified on its own merit by the EHSC. Recommendations will be forwarded to EHS and FM.

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BMPs & Measurable Goals

BMPs and measurable goals are established by assessment of needs based on project parameters and specific conditions. EHS, the EHSC, and FM work together to establish the best methods and goals to mitigate runoff pollution and achieve a desired outcome. These three entities represent a cross section of expertise in environmental, chemical, biological, engineering, and construction ideologies. Long-term goals are coordinated by the AVC of FM according the master design plans.

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Recordkeeping & Reporting

All plans, inspections, SWPPPs, NOIs, NOTs, NOCs, and any other relevant documentation regarding stormwater management will be kept on file at FM for a period of not less than 3 years. UA Little Rock will submit an annual report to ADEQ by June 1, 20XX, for the previous year. UA Little Rock will report information required in Parts 3.2 and 4.3 of the general permit.

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Public Education & Outreach on Stormwater Impacts (Permit Section 3.2.1)

Rationale Statement & Decision Process

UA Little Rock consists of approximately 13,360 students, staff, and faculty. UA Little Rock has multiple channels with which to communicate information to the campus community on both large and small scales. The EHS office, being the primary source of information for the public, will consult with the EHSC to maintain or develop ideas for the best methods to communicate stormwater management policies to and to receive comment from the campus. The operation of chemical and biological labs creates the opportunity to release hazardous material that may enter Coleman Creek if not properly controlled. In addition, the operation of a motor pool, grounds maintenance, and building maintenance activities also create similar opportunities. Contractor activities also provide disruptions to the landmass that could cause stormwater pollution. EHS developed this Stormwater Management website as an adjunct to the EHS website for the purposes of communication. This site is solely dedicated to providing information and resources for stormwater related topics and to provide a method for the public to comment on stormwater management. BMPs utilized to facilitate communication between EHS and the campus community are listed below.

BMPs – Measurable Goals – Responsible Person(s)

BMP Measurable Goal Responsible Person(s)
Website Creation & Maintenance Provide information to public with comment section – quantify responses Director of Environmental Health & Safety
Policy Development Policies in place that address possible forms of pollution Environmental Health & Safety Committee
Contractor Management; Meet with and inform contractors of UA Little Rock policies Participation and compliance Director of Planning, Construction & Development; Chemical Hygiene Officer
Training Attendees and recipients of HazMat, Chemical Hygiene, Biosafety, MSDS, & HazComm Training Chemical Hygiene Officer, Director of EHS

Performance Standards

The mechanisms to reach the campus community are predominantly electronic. For sustainability reasons, EHS and FM opt to utilize paperless communication wherever possible. Campus email, website postings, and the UA Little Rock “Get Informed” newsletter are alternative methods of written communication. The entire campus community is targeted in this effort, and it is expected that 100% of the recipients receive messages. It cannot be determined, at this time, how many recipients actually read and understand any content. Training modules that address pollutants, such as hazardous material management, are being developed; there are, however, ongoing training activities in labs and on job sites that address the proper handling of hazardous materials. Documentation of recipients of training will be maintained by EHS. Staff is instructed on accidental releases mitigation. Contractors being the primary source of potential runoff pollution are informed and required by FM and EHS to comply with ADEQ regulations and university policies pertaining to stormwater.

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Public Involvement & Participation (Permit Section 3.2.2)

Rationale Statement & Decision Process

UA Little Rock encourages input and comment from the campus community regarding all facets of stormwater management. The EHS Stormwater Management Plan website is the predominant manner in which community members can access information and provide comment on stormwater related topics. EHS, in conjunction with the EHSC and FM, makes recommendations as to how, when, and why to solicit public involvement. BMPs for facilitating public involvement are listed below.

BMPs – Measurable Goals – Responsible Person(s)

BMP Measurable Goal Responsible Person(s)
Website Access – links to ADEQ, EPA, and UA Little Rock policy regarding stormwater; comments can be made on the website Number of comments; quality of involvement Director of Environmental Health & Safety
Coleman Creek annual cleanup activity Number of Participants Leslie Hutchins
Earth Day Celebration Volume of traffic to stations; pounds of recyclables collected; number of computer components/batteries collected Sandra Vail
Recycling – bins are located throughout the campus to collect paper, plastic, and aluminum Annual pounds collected Sandra Vail
UA Little Rock Sustainability Committee – encourages participation through seminars/webinars to increase awareness Number of Participants Sandra Vail

Performance Standards

The above listed BMPs will be evaluated for effectiveness as needed. Data is stored for reference.

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Illicit Discharge & Elimination (Permit Section 3.2.3)

Rationale Statement & Decision Process

Illicit discharges have not been problematic on campus in recent years; however, programs need to be in place to address the possibility. Illicit discharges on campus are strictly prohibited to include illegal dumping. The UA Little Rock Department of Public Safety (DPS) enforces pollution laws and responds to any incidences. FM and EHS work closely with DPS to ensure that any detected incidences of illicit discharge is thoroughly investigated and mitigated.

All student chemical activity is monitored by faculty and staff at the class/lab level. Any waste generated by chemical, biological, or physical means is collected and disposed of according to federal and state regulations and per the UA Little Rock Chemical Hygiene Plan, Biosafety Manual, Radiation Safety Policy, Recycling Program, and general waste management practices.

The EHS office and the Chemical Hygiene Officer (CHO) manage the day-to-day operations for chemical safety and hygiene by routine inspections, training, and lab design. UA Little Rock prohibits improper waste disposal per the Chemical Hygiene Plan, Biosafety Manual, and Hazardous Waste Management Policy (under construction). In addition, UA Little Rock’s designation as a Conditionally Exempt Small Quantity Generator (CESQG) by ADEQ requires that UA Little Rock follow waste management protocols and procedures dictated by Regulation 23. Plans and programs are available to the community through the EHS website that outline in detail chemical and biological hazardous material handling procedures.

The Director of Facility Services coordinates operations that may result in pollutant runoff. Oil from auto-maintenance operations is collected and stored in a 500 gallon above ground tank until the oil is picked up for recycling. UA Little Rock uses green cleaning products wherever practical. Fertilizers and herbicides are used at a minimum, and lawn irrigation is performed only as necessary to maintain the grounds.

FM maintains a map of all systems including storm sewers and outfalls. This map is updated as needed by the FM Engineer. Additionally, EHS is developing current stormwater topical maps using GIS technology and up-to-date aerial photography to assist in planning efforts. Architects are consulted when new structures are erected and are charged with developing adequate drainage plans for stormwater. In addition, EHS will work with Environmental Health Science to review samples collected during appropriate semesters. Readings for pH, dissolved oxygen, 5-day biological oxygen demand (BOD5), total suspended solids (TSS), and phosphorus will be referenced that can reveal quantitative data useful for developing and enhancing program BMPs.

Identified Sources of Illicit Discharge

No identifiable sources of runoff significantly affect water quality at UA Little Rock; however, there are possible sources. Lawn irrigation, HVAC condensate, roof/building drainage to grade, and accidental releases of chemical and biological agents are monitored and controlled to mitigate release. It is the responsibility of EHS, the FM Mechanical Engineer, and the FM Director of Capital Planning and Construction to formulate mapping of all stormwater flows and outfalls. In addition, UA Little Rock FM staff must be cognizant of developments that could influence stormwater control. UA Little Rock considers the discharges listed in Part I.C.2 of the permit to be allowable non-stormwater discharges. These discharges will be unregulated unless UA Little Rock identifies them as a significant contributor of pollutants to the MS4. DPS patrols the campus 24 hours a day and any activity that may be construed as “illegal” is addressed immediately. In addition, UA Little Rock installs and monitors video surveillance cameras at construction sites and other sites on campus.

BMPs – Measurable Goals – Responsible Person(s)

BMP Measurable Goal Responsible Person(s)
DPS to enforce pollution laws Number of violations UA Little Rock Police Chief
Lab inspections Number of violations Chemical Hygiene Officer
Lab-Pak – chemical waste collection, storage, and disposal Amount of material Chemical Hygiene Officer
Policy development and review Affective and effective to specific areas EHSC
Street sweeping (collection of debris), green chemical use, lawn irrigation, fertilizer use Active monitoring by FM and EHS Sandra Vail, Chemical Hygiene Officer
Update maps as needed Identify collection areas and outfalls Robin Sipes, Chemical Hygiene Officer
Collect sample data Maintain reasonable parameter levels Chemical Hygiene Officer

Performance Standards

All data regarding performance will be assessed at least annually and actions will be taken according to effectiveness.

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Construction Site Stormwater Runoff Control (Permit Section 3.2.4)

Rationale Statement & Decision Process

Construction activities are perhaps the most obvious source of runoff pollution. In order to ensure that BMPs are observed, UA Little Rock established requirements for community members and contractors. FM and EHS will oversee all construction sites and SWPPPs for control of sediments, erosion, and waste (particularly concrete wastes) by monthly inspection throughout the course of construction. If inspection violations are not corrected, UA Little Rock will refer non-compliance activities to ADEQ. Likewise, any illicit discharges discovered from non-construction activities will be referred to the proper authorities.

Procedures for Construction-Site Inspection

Inspections begin with a review of maps and familiarization with area roads, land uses, and natural features. Inspectors will review any documents pertaining to the construction of the area such as SWPPPs, site plan maps, other permits granted to the contractor, records of previous compliance, and NOIs. Inspections will be conducted according to the contract documents and as deemed necessary by UA Little Rock Environmental Health and Safety. The inspection will be conducted as described below, and the inspector will do the following:

  1. Introduce himself/herself as the UA Little Rock SWPPP inspector, and communicate to the contractor’s representative that an inspection is occurring.
  2. Request or locate the on-site copy of the SWPPP, and become familiar with any changes that have been made to the SWPPP.
  3. Walk (or slowly drive) the perimeter of the site, and note outfalls to water and/or drainage channels.
  4. Inspect outfalls for signs of wastes and sediment. Document any waste or sediment.
  5. Inspect active and inactive portions of the construction areas for properly installed BMPs and material storage.
  6. Communicate with the contractor the status of compliance, and make recommendations for any corrections.
  7. Follow up on corrections, and communicate to the contractor if the violations should be referred to ADEQ for further investigation.

BMPs – Measurable Goals – Responsible Person(s)

BMP Measurable Goal Responsible Person(s)
Perform dry weather field screening by qualified personnel Number of violations Chemical Hygiene Officer
Construction site SWPPP management and inspection Number of violations Chemical Hygiene Officer
Maintain and update topographical maps Efficiency of and ability to ID outfalls and predict flow patterns Chemical Hygiene Officer, Robin Sipes, Director of Planning, Construction & Development
Police patrols, surveillance cameras, discharge monitoring Number of violations or pollution instances Chemical Hygiene Officer, UA Little Rock Police Chief, Director of Planning, Construction & Development

Performance Standards

As the campus grows, more requirements will be made of stormwater management programs. UA Little Rock will continually enhance programs as necessary and implement changes required to mitigate pollution. As the topography changes, so must UA Little Rock adapt existing and new systems. Construction activities will continue to be monitored and pre-construction conferences held to identify expectations for stormwater control for all applicable projects.

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Post-Construction Stormwater Management (Permit Section 3.2.5)

Rationale Statement & Decision Process

UA Little Rock has and updates the Campus Master Plan for campus and community long-range renewal and growth opportunities. The plan consists of two companion documents, the university’s strategic plan and a plan for the University District that focuses on revitalizing the immediately surrounding city areas. Both documents include strategies for stormwater management. Post-construction BMPs will ultimately conform to drainage and runoff strategies associated with the Master Plan.

Post-construction stormwater management is a key activity to ensure that when BMPs used during construction are removed, runoff is monitored and evaluated for possible pollutants. The requirements to correct any deficiencies with stormwater runoff will be the responsibility of the contractor under the direction of FM and EHS. Any corrections not addressed by contractors will be reported to ADEQ. EHS will inspect and evaluate runoff under the following conditions:

  1. Dry-weather screening
  2. Following rain events
  3. Building systems drainage
  4. Activity based pollution opportunities
  5. Sampling, where applicable

These parameters will be assessed by a qualified staff member, and any deficiencies and corrections will be forwarded to the contractor for immediate rectification. In addition, it is UA Little Rock’s goal to assure post-construction TSS levels are within 20% of TSS pre-construction levels. Landscaping activities, which follow construction, will incorporate non-structural BMPs to mitigate runoff such as riparian buffer zones, natural abstractions, preserving undeveloped land areas (natural settings), continue to maximize development of green areas, and minimize impervious areas where possible.

BMPs – Measurable Goals – Responsible Person(s)

BMP Measurable Goal Responsible Person(s)
Develop BMPs that work in confluence with the Master Plan Administrative approval of direction of SWMP Leslie Hutchins
Post-Construction inspection & evaluation Number of violations & corrections Chemical Hygiene Officer, Director of Planning, Construction & Development
Sample pre & post construction Maintain acceptable TSS levels Chemical Hygiene Officer
Utilize non-structural BMPs Reduction in runoff pollution opportunities Sandra Vail, Chemical Hygiene Officer

Performance Standards

Post-review of pre-construction runoff plans will be evaluated for consistency of the design of drainage strategies. Regular inspections and buildings and grounds maintenance will ensure maximum runoff mitigation effects. FM and EHS will oversee long-term management of BMPs.

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Pollution Prevention & Good Housekeeping (Permit Section 3.2.6)

Rationale Statement and Decision Process

It is important to maintain the campus in a manner that reduces the opportunity for stormwater pollution. Many campus activities could affect water quality if left unmonitored and controlled. UA Little Rock has in place buildings and grounds maintenance operations that are designed to enhance the beauty of the campus and prevent pollutants from entering Coleman Creek and subsequent water bodies.

Streets are swept and grounds are kept clean of trash and debris by FM. All materials collected are either recycled or disposed of as waste. Building systems are maintained to prevent fluid leakage, and any byproducts of processes or spills are collected and disposed of in accordance with ADEQ Regulation 23. Automobiles are regularly maintained, and waste petroleum products are collected in an above ground storage tank. The tank contents are collected by a professional waste management company. Daily cleanup activities ensure that debris is disposed of before it can get into Coleman Creek. Grounds are landscaped to enhance the natural beauty of the campus, which in turn provides natural abstractions that mitigate runoff. Employees are trained on how to recognize hazards to protect themselves and the campus grounds. Parking lots are maintained routinely, and any leaks/spills are absorbed and collected whenever possible. UA Little Rock has an aggressive recycling program that includes paper, plastic, aluminum, batteries, computer components, fluorescent lamps and HID/MV bulbs, and other miscellaneous recyclables.

Each FM employee has a basic understanding of safety data sheets (SDS) and biological hazards so they can report possible hazards to their supervisor. Under direction of the EHSC, EHS oversees the UA Little Rock HazMat Response Team. This team is certified under OSHA HAZWOPER 24-hour criteria. The team leader holds a 40-hour certification.

BMPs – Measurable Goals – Responsible Person(s)

BMP Measurable Goal Responsible Person(s)
Custodial operations & grounds maintenance – landscaping Number of community complaints, overall cleanliness maintained Sandra Vail
Building systems & automobile maintenance Tracking of systems for malfunction, leaks, etc Mike Seamon
Employee training Overall awareness Chemical Hygiene Officer,  Director of Environmental Health & Safety
Recycling Amounts collected Sandra Vail, Chemical Hygiene Officer,  Director of Environmental Health & Safety

Performance Standards

General housekeeping standards are maintained by the FM Director of Facility Services. Each employee receives annual, or as needed, training relevant to maintaining a clean work environment, which influences good stormwater management. The SWMP is reviewed by the EHSC at least annually for appropriateness and effectiveness.

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Contact Information

Information Desired Contact Department Phone # Email or Website
To report any suspected water pollution activity Operations Center Facilities Management 916-3390 N/A
For information or questions regarding UA Little Rock stormwater Director of Environmental Health & Safety EHS 916-6351 ehs@ualr.edu
Program Events Participation Sandra Vail Facilities Management 916-6355 slvail@ualr.edu
Program Administration Leslie Hutchins Facilities Management 916-6347 lkhutchins@ualr.edu
Illegal Dumping Reporting Dispatch Public Safety 916-3400 UA Little Rock Public Safety
State Requirements ADEQ Stormwater Water Division – MS4 Permits 682-0923 ADEQ MS4 Permit
Federal Requirements EPA Region 6 NPDES Stormwater Programs 800-887-6063 EPA Region 6 Stormwater Program

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Stormwater Management Plan Comment Form

This form collects comments regarding UA Little Rock's Stormwater Management Plan.

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