University of Arkansas at Little Rock
Policy Name: Stormwater Management
Policy Number: LR 701.32
Effective Date: August 1, 2010
Revised Dates: August 1, 2010
Most Recent Review Date:
Introduction
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 (UALR) is authorized. UALR holds an MS4 Individual Permit ARR040020 in which ADEQ grants, by primacy, UALR this authority to discharge stormwater runoff under the terms and conditions specified in ARR040000. UALR has completed a Notice of Intent (NOI) and this SWMP complies with Parts 2, 3, and 4 of the permit. The UALR Facilities Management (FM) department’s associate vice chancellor (AVC) is responsible for administering the SWMP. Policy and program development is managed by the UALR Environmental Health and Safety (EHS) assistant director in conjunction with the UALR Environmental Health and Safety Committee (EHSC).
Stormwater Management Program
Purpose and Intent
UALR 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 UALR 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. UALR has evaluated the permit requirements for six minimum control measures specified in Part 3.2 of the general permit. Based on that review, UALR has selected Best Management Practices (BMPs) for each control measure that UALR believes will accomplish the overall goal of reducing pollution from stormwater runoff to the Maximum Extent Practicable (MEP). The Assistant Director of EHS is responsible for developing goals and identifying/implementing BMPs under ARR040020. The EHSC reviews and assists with program development.
Reviewing and 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.
Monitoring
UALR will evaluate program compliance, the appropriateness of identified BMP’s, and progress towards achieving identified measurable goals. The UALR 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 onto the Gulf of Mexico. For UALR 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. Therefore, UALR 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, UALR will act appropriately. In addition, UALR may wish to sample according to construction site stormwater management protocol.
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.
BMPs and 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 to the master design plans.
Annual Reports
UALR will submit an annual report to ADEQ by June 1, 20XX for the previous year. UALR will report information required in Parts 3.2 and 4.3 of the general permit.
Control Measures (Permit Section 3.2)
1. Public Education and Outreach on Stormwater Impacts (3.2.1)
Rationale Statement and Decision Process
UALR consists of approximately 13,360 students, staff, and faculty. UALR 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 a 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. The site is located at https://ualr.edu/facilities/index.php/home/environmental-health-safety/116. 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 the public with a comment section – quantify responses | Vince Rodgers |
| Policy Development | Policies in place that address possible forms of pollution | Environmental Health and Safety Committee |
| Contractor Management – Meet with and inform contractors of UALR policies | Participation and compliance | Andrijana Vukovich, John McMains, Vince Rodgers |
| Training | Attendees and recipients of HazMat/Chemical Hygiene/Biosafety/ MSDS/HazComm Training | Vince Rodgers |
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 UALR “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.
2. Public Involvement/Participation (3.2.2)
Rationale Statement and Decision Process
UALR encourages input and comment from the campus community regarding all facets of stormwater management. The EHS Stormwater Management 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 UALR policy regarding stormwater; comments can be made on the website | Number of comments; quality of involvement | Vince Rodgers |
| Coleman Creek annual cleanup activity | Number of participants | Dave Millay |
| 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 |
| UALR 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.
3. Illicit Discharge and Elimination
Rationale Statement and 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 UALR 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 UALR 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. UALR prohibits improper waste disposal per the Chemical Hygiene Plan, Biosafety Manual, and Hazardous Waste Management Policy (under construction). In addition, UALR’s designation as a Conditionally Exempt Small Quantity Generator (CESQG) by ADEQ requires that UALR 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. UALR uses green cleaning products wherever practical. Fertilizers and herbicides are used at a minimum and lawn irrigation 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 UALR; 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, UALR FM staff be cognizant of developments that could influence stormwater control. UALR considers the discharges listed in Part I.C.2 of the permit to be allowable non-stormwater discharges. These discharges will be unregulated unless UALR 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, UALR 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 – Enforces pollution laws | Number of violations | Brad King |
| Lab inspections | Number of violations | Vince Rodgers |
| Lab-Pak – chemical waste collection, storage, and disposal | Amount of material | Vince Rodgers, Leslie Coop |
| 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, Vince Rodgers |
| Update maps as needed | Identify collection areas and outfalls | Robin Sipes, Vince Rodgers |
| Collect sample data | Maintain reasonable parameter levels | Vince Rodgers |
Performance Standards
All data regarding performance will be assessed at least annually and actions will be taken according to effectiveness.
4. Construction Site Stormwater Runoff Control (3.2.4)
Rational Statement and Decision Process
Construction activities are perhaps the most obvious source of runoff pollution. In order to ensure that BMPs are observed, UALR 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, UALR will refer non-compliance activities to ADEQ. Likewise, any illicit discharges discovered from non-construction activities will be remanded 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 UALR Environmental Health and Safety. The inspection will be conducted as described below.
The inspector will:
- Introduce himself as the UALR SWPPP inspector and communicate to the contractor’s representative that an inspection is occurring.
- Request or locate the onsite copy of the SWPPP and become familiar with any changes that have been made to the SWPPP.
- Walk (or slowly drive) the perimeter of the site and note outfalls to water and/or drainage channels.
- Inspect outfalls for signs of wastes and sediment. Document any waste or sediment.
- Inspect active and inactive portions of the construction areas for properly installed BMP’s and material storage.
- Communicate with the contractor the status of compliance and make recommendations for any corrections.
- 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 | Vince Rodgers |
| Construction site SWPPP management and inspection | Number of violations | Vince Rodgers |
| Maintain and update topographical maps | Efficiency of and ability to ID outfalls and predict flow patterns | Vince Rodgers, Robin Sipes, Andrijana Vukovich, John McMains |
| Police patrols, surveillance cameras, discharge monitoring | Number of violations or pollution instances | Vince Rodgers, Brad King, John McMains |
Performance Standards
As the campus grows, more requirements will be made of stormwater management programs. UALR will continually enhance programs as necessary and implement changes required to mitigate pollution. As the topography changes, so must UALR 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.
5. Post-Construction Stormwater Management (3.2.5)
Rationale Statement and Decision Process
UALR 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:
- Dry-weather screening
- Following rain events
- Building systems drainage
- Activity-based pollution opportunities
- 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 UALR’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 | David Millay |
| Post-construction inspection and evaluation | Number of violations/corrections | Vince Rodgers, Andrijana Vukovich, John McMains |
| Sample pre and post construction | Maintain acceptable TSS levels | Vince Rodgers |
| Utilize non-structural BMPs | Reduction in runoff pollution opportunities | Sandra Vail, Vince Rodgers |
6. Pollution Prevention and Good Housekeeping (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. UALR 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. UALR 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 material safety data sheets (MSDS) and biological hazards so they can report possible hazards to their supervisor. Under direction of the EHSC, EHS oversees the UALR HazMat Repsonse 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)
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. UALR 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. UALR 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 material safety data sheets (MSDS) and biological hazards so they can report possible hazards to their supervisor. Under direction of the EHSC, EHS oversees the UALR 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 & ground 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 | Vince Rodgers |
| Recycling | Amounts collected | Sandra Vail, Vince Rodgers |
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.
Sharing Responsibilities
UALR has the sole responsibility to implement all measures described in this program.
SWMP Review and Update
Annual evaluations, reviews, and updates will be managed by EHS and under the direction of the EHSC. ADEQ will be notified in writing before any additions to goals, BMPs, authority, or other pertinent processes occur and in accordance with sections 3.4 of the general permit.
Monitoring
UALR is not under any TMDL requirement per the individual permit. In addition, no discharges into 303(d) listed waters are applicable.Recordkeeping and ReportingAll 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. Annual reports will be submitted by EHS to ADEQ in accordance with section 4.3 of the general permit.
Exhibit A Inspection and Maintenance Report Form
Exhibit B SWPPP Inspection Form
Source: Environmental Health and Safety, February 12, 2009
Status: Active
Approved By: Environmental Health and Safety Committee, Aug. 1, 2010
Originator:
Custodian: Environmental Health and Safety