THE UNIVERSITY OF MICHIGAN – FLINTEnvironmental Compliance Environmental Compliance

with… with… 1- New NPDES Storm Water Management 1- New NPDES Storm Water Management

Permits Permits 2- SPCC & Michigan PART 5 Requirements2- SPCC & Michigan PART 5 Requirements

3- Environmental Due Care3- Environmental Due Care

Env., Health and Safety & Facilities ManagementEnv., Health and Safety & Facilities Management March 2010March 2010

Portions of Training materials adopted from UM OSEHPortions of Training materials adopted from UM OSEH

Storm Water Mgt. is strictly regulated… it dates back several decades

Federal Clean Water Act of 1972CWA amendments of 1987 required permits for

storm water discharge (Phase I and II).Federal Phase I SW Regulations began 1990

Industrial Sites: certified ISW operator Construction sites over 5 acres: requires SESC plans, weekly

inspections by certified CSW operator Municipalities over 100,000: public education, illicit

connections, maximum extent practicable measures Federal Phase II SW Regulations (1999)

Industrial Sites: about the same as above, certified operator Construction sites 1-5 acres: w/ certified operator Municipalities under 100,000:

Three permit options under Phase II: General permit, Individual permit, or Modification –MS4UM ‘s renewed 2009 Combined Permit (AA, Dearborn &

Flint)UM-Flint’s pool discharge permit

Michigan Env. Protection RegulationsPart 31, Water Resources Protection of NRP Act of 1994

Empowers Director of MDEQ to protect & conserve water resources… adopt, establish/enforce rules, penalties

Prohibits pollution of state’s waters, etc.Part 91, Soil Erosion and Sedimentation Control of NRP

Act of 1994 Requires control of soil erosion and sedimentation Permits, SESC plans for “earth Changes” of one acre or more or any “earth

change” within 500 feet of river, lake, stream… Regulated by local, county or state Authorized Public Agency (APA)

Part 301, Inland Lakes and Streams (1994) Regulates activities in lakes/streams, requires permit, i.e dredging, SESC,

etcPart 303 Wetland Protection Act (1994)

Protected like other surface water from SW contaminationPart 17, Michigan Environmental Protection Act

Provides for citizens to bring legal action “for conduct that may pollute, impair, or destroy the air, water, or natural resources.”

Part 305 Natural Rivers Act (1970) Regultes activities w/in 400 ft of “Natural River District” … building,

removal of vegitation, land alteration, bridge work…

The “Big Picture” of Storm Water

Discharges

So what does this mean for UM-Flint?* UM-Flint is in the Flint River Watershed * Stop pollutants from entering the Flint River… through storm drains or by runoff directly to the river or ditches that lead to the river* Report illicit discharges & spills immediately to Public Safety/EHS* Always use best management practices at work, home and play* Attend trainings and workshops * Encourage others to do the right thing

UM Ann Arbor has been operating under a UM Ann Arbor has been operating under a “Voluntary” NPDES permit dating back to “Voluntary” NPDES permit dating back to the Federal Phase I (1990’s)the Federal Phase I (1990’s)Flint and Dearborn were required to comply Flint and Dearborn were required to comply w/ SW Regulations under Phase II by March w/ SW Regulations under Phase II by March 2003.2003.

UM has petitioned MDEQ to include the Flint UM has petitioned MDEQ to include the Flint and Dearborn campuses into the existing and Dearborn campuses into the existing permit… all under “The Regents of UM”.permit… all under “The Regents of UM”.

NOW, All THREE campuses fall under one NOW, All THREE campuses fall under one MDEQ (new renamed MDNRE) permit.MDEQ (new renamed MDNRE) permit.

Increased documentation, inspections, Increased documentation, inspections, education/training for employees, education/training for employees, contractors and the general public.contractors and the general public.

Authorized Discharges - ONLY STORM WATER!Some minor exceptions… irrigation, uncontaminated

groundwater, potable water, foundation drains, lawn water runoff, water line flushing and discharge of potable water, non-commercial car washing, residual street wash waters, flows from emergency fire fighting activities.

Discharges Requiring AuthorizationUse of Tracer DyesUse of Water Treatment AdditivesWaste Water associated with concrete activitiesRequires written authorization from MDNRE office, must

coordinate with EHS &OSEH-EM to receive authorizationDechlorinated swimming pool discharge

requires separate NPDES permit- August 2009. Discharge of “any pollutants” is prohibited.

UM Storm Water Permit Requirements (NPDES Permit # MIS049000)

MDNRE Requires SWM Program

~ Minimum Measures ~identify and map discharge locationsillicit discharge detection and eliminationpollution prevention and good housekeeping

for site operations- Best Management Practices

construction site storm water runoff controlpost-construction storm water managementemployee and contractor trainingpublic education and outreachpublic involvement and participation

NOTE: The current SWMP (Jan 2010) has been recently revised and comments on the document are being encourage over the next 30 days please be sure to participate in the review and provide your suggestions, etc. http://www.oseh.umich.edu/stormwater/SWMP2010.pdf

UM-Flint’s Role (EHS, FM & others) complying w/ MDNRE Permit conditions

Review & adopt UM’s written SWMP (Jan 2010)Implement & enforce best management

practices with UM employees and contractorsFind & Eliminate Illicit Discharges and

ConnectionsPost-Construction SW Mgt. for (Re)Development

> equal to 1 acre… or < 1 acre but part of a larger development With in 500 feet of the River Require to include structural and nonstructural BMPS i.e buffers,

minimal disturbance of soil & vegetation, detention ponds, Ensure isolation of storm drains from polluting materials… use of

secondary containment, fabric filters, silt sacks, absorbent pads, etc.Conduct & Participate in Public Education

residents, faculty, staff, students, visitors Partner w/ City of Flint, FRWC, CAER & Outreach, others Household Haz Waste and e-Waste Collection - 2x year

complying w/ MDNRE Permit conditionsConstruction Storm Water Runoff Controls

SESC requirementProcedures to receive complaints from the public

Pollution Prevention & Good Housekeeping Material storage & containment– drums, bags, dumpsters, stockpiles,

etc. Maintenance of Structural Controls – catch basins, sedimentation or

infiltration basins, manage waste from drainsStreet cleaning & catch basin maintenance, Reduce discharge of

pollutants associated with maintaining streetsEnsure vehicle maintenance activities do not impact SW… discharge of

wash water to SW drains is not authorized under permit.Pesticides and Fertilizers – minimize discharge of pollutants related

to handling, application and storage of chemicals BMPS required include employee training, soil testing to minimize application and treatments,

Assess Program, Annual Reporting to OSEH & MDEQIdentify measurable goals, monitor progress and document

everything… BMPS, spills, purchases, training, compliance expenses, etc

complying w/ MDEQ Permit conditions

Inlet Fabric Inlet Fabric Filters and Filters and Silt SacksSilt Sacks

EHS and Facilities Mgt. preparation for UM SWM Annual Report to MDNRE

Time period April 2009 – July 2010Track frequency of storm/sanitary repairsMap outfalls and test water quality at point of dischargeStreet sweeping and related activitiesWaste management – litter collection/disposalInspection and Maintenance on catch basinsUse of protective measures on drainsSpills and clean upParking lot & ramp cleaning/maintenanceEducation and training, classes, brochures, bulletin boards,

website, special events, etc.Pesticide Management and related testingPublic outreach… FRWC, CAER, County planning boards,

etc.

EPA/MDEQ Requires 6 Minimum EPA/MDEQ Requires 6 Minimum Measures in UM SW Mgt. Program Measures in UM SW Mgt. Program

EPA/MDEQ Requires 6 Minimum EPA/MDEQ Requires 6 Minimum Measures in UM SW Mgt. Program Measures in UM SW Mgt. Program • public education and outreachpublic education and outreach• public involvement and participationpublic involvement and participation• illicit dischargeillicit discharge detection and elimination detection and elimination• construction site construction site storm water runoffstorm water runoff control control• post-construction storm water management, post-construction storm water management,

and and • pollution prevention and good housekeeping pollution prevention and good housekeeping

for site operationsfor site operations..

Video Video Storm Water Storm Water

Pollution PreventionPollution Prevention Everyday Best Management Everyday Best Management

Practices (BMPs)Practices (BMPs)

1. Identify five (5) Best Management Practices that can be implemented by Housekeeping Staff? by Grounds keeping staff? Other staff?

2. Identify three (3) past practices that should be avoided in the future?

3. What material is permitted to be discharged down the UM storm drains?

4. When do you need to call EHS? When do you call your supervisor?

Spill Prevention Control and Countermeasure Plan (SPCC)

Plan required by the United States Environmental Protection Agency under 40 CFR part 112

UMF SPCC Plan - 2003, rev 2006, rev 2009

PURPOSE:Plan outlines measures to prevent the discharge of OIL into the navigable waters.

Spill Prevention Control and Countermeasure Plan (SPCC)Definition of OIL – oil of any kind or in any

form, including but not limited to:Petroleumfuel oilsludgeoil refusekitchen greaseanimal fatsoil mixed with wastes

Spill Prevention Control and Countermeasure Plan (SPCC)Who is Required to Implement a SPCC Plan?A facility that exceeds:

Total UNDERGROUND storage capacity greater than 42,000 gallons or

An aggregate or combined aboveground storage capacity greater than 1,320 gallons, and

Reasonable expectation that a discharge could reach a navigable waterway.

Spill Prevention Control and Countermeasure Plan (SPCC)What is required of a Facility under the

regulations?1. A written plan certified by a Professional Engineer (PE) every 3 years.2. Oil storage management and control3. U-M Facility Personnel involvementRoutine inspectionsSpill prevention and spill controlBest Management Practices Record keeping

SPCC Plan RequirementsWritten PlanState general information of the facility

Facility Response Coordinator and AlternateName of facility, address, phone numbersNearby surface water body/ distance

Facility DescriptionDescription of campusFacility drainage areas (storm water discharges to streams,

creeks)Oil storage, distribution and use (explain type of containers)Spill history Potential releases and prevention controlsLoading and unloading operations

SPCC Plan RequirementsWritten Plan - ContinuedSpill Response Plan

UMF has a effective ERP that serves as a guidance document. The ERP incorporates the criteria for oil removal contingency plans specified in 40 CFR Part 109.

Approximately 30 U-M personnel have completed the 32-hour Hazardous Waste Operations Emergency Response Technician/ Incident Command Level training.

Remedial action – Plan distinguishes between incidental spill nad emergency release

ERP available online at www.umflint.edu/ehs/ Inspection schedule –(monthly, quarterly & annually)

Describe the routine inspection scheduleCurrent schedule was approved by the EPA in 2001

SPCC Plan RequirementsWritten Plan - ContinuedPersonnel training

Oil handling personnel trained inBecome familiar with laws and

regulations regarding spills, releases, and pollution control

Contents of the UMF SPCC plan (rev 2009)

Operation and maintenance of equipment to prevent discharges including performing the routine inspections.

SPCC Plan RequirementsOil Storage Management and Control

Oil storage management and control as stated in the regulations and in the written plan.

LightingSecuritySecondary ContainmentCatchment during loading and

unloading fuel

SPCC Plan RequirementsOil Storage Management and ControlLighting

Per the EPA, as long as the oil storage area is accessible with a flashlight, this is considered adequate lighting.

Security To assist in preventing spill or release from being caused by accidental or unknown entry or vandalism.Fenced area PadlocksSecurity guards Stored inside building

SPCC Plan RequirementsOil Storage Management and ControlSecondary ContainmentSecondary containment is required for OIL containers

with the capacity of 55 gallons or greater and is to prevent any spills from any leaking or damaged containers.

The secondary containment must have the capacity to hold the volume of the largest container or 10% of the combined containers, whichever larger. If room has no floor drains, then the room itself may be

considered sufficient secondary containment. If the room is considered the secondary containment ensure there is a lip at the door so no liquids can exit the room in the event of a leak.

Secondary Containment

SPCC Plan RequirementsOil Storage Management and ControlFuel Catchment

The SPCC plan requires catchment to be in place during refueling operations from a tanker truck to an aboveground or underground storage tank that will hold the capacity of the largest inner single compartment of the delivery truck.

Fuel Catchment

SPCC Plan RequirementsUM-Flint Personnel InvolvementContainer Inspections

Monthly and quarterly inspectionsTrained oil-handling personnel should perform the routine

inspections. OSEH & EHS provides assistance to the Facility Managers and Supervisors by explaining the environmental regulatory requirement and therefore relies on the FM and Supervisors to ensure the routine inspections are being performed on time.

Container Capacity Frequency PersonnelAST >= 55 gallons Quarterly Facilities Mgt.UST >= 55 gallons Quarterly* Facilities Mgt.Drums >= 55 gallons Monthly Facilities Mgt..Transformers >= 55 gallons Quarterly Facilities Mgt./Electricians• Except FWT Library UST must be inspected monthly per Part 211 EHS & OSEH will monitor & inspect at least annually

SPCC Plan RequirementsUM-Flint Personnel Involvement

Inspection Checklist Example (In handout)

UMF Facilities Management has incorporated the monthly/quarterly inspections into their PM program

Completed & signed inspections forms are forwarded to EHS, copies are kept with FM

U-M Flint Oil Storage locations

Total of 12 Tank inspections Total of 6 drums inspections

Tank ID Location/Building Type of Construction Capacity in gallons Substance stored in tank

1 Adjacent to the Central Energy Plant (CEP) UST – Double Walled -FG 30,000 #2 heating oil

2 Adjacent to the Central Energy Plant (CEP) UST – Double Walled -FG 30,000 #2 heating oil

3 Adjacent to the Central Energy Plant (CEP) UST – Double Walled -FG 30,000 #2 heating oil

4 FWT Library UST -FG 1000 diesel fuel

5 University Center basement AST 275 diesel fuel

6 French Hall AST 275 diesel fuel

7 Theater Basement AST 50 diesel fuel

8 Hubbard Compound AST- plastic 5000 deicing solution

9 Murchie Science Building (MSB)

AST 250 diesel fuel

10 Central Energy Plant (CEP) AST 250 diesel fuel

11 Hubbard Compound adjacent to the Central Energy Plant (CEP) AST 1000 diesel fuel

12 Hubbard Compound adjacent to the Central Energy Plant (CEP) AST 500 gasoline

13 University Pavilion Drum 30 grease

14 University Center Drum 30 grease

NA Central Energy Plant (CEP) Drum 55 oil

NA Hubbard Building (interior) Drum 55 oil

NA Hubbard Building (exterior) Drum 55 oil

NA Hazardous Materials Building Drum 55 Wastewater, and upon occasion other materials

SPCC Plan RequirementsUM-Flint Personnel Involvement

Spill prevention and spill controlImmediately block nearby drains. Contain all releases with absorbent material if the scene is safe. If the scene is not safe, contact DPS at 762-3335 and EHS at 766-6763.

Record keepingAll records must be kept on site for at least three years.

SPCCTEST

1. The SPCC Plan regulates the following pollutant.a. Waterb. Saltc. Oild. Soil

2. Which of the following is a form of oil that is regulated by 40 CFR 112?a. Kitchen greaseb. Gasolinec. Diesel Fueld. All the above

3. How many years do the records need to be kept on file?a. 3 yearsb. 3 months c. foreverd. 7 years

4. Which containers are required to be inspected monthly?a. Underground storage tanksb. Aboveground storage tanksc. 55-gallon drumsd. All the above

5- Whenever loading/unloading oil products from a tanker truck, the FM employee must do which of the following: a. Apply drain blockers to the near by storm drains prior to fuelingb. Stay with the vehicle while fueling All the above

6- Who do you call FIRST in the event of an emergency release into the storm drain?d. DPS & EHSe. Young’s Environmentalf. City of Flintg. Supervisor

MI Part 5 RulesSpillage of Oil and Polluting MaterialsPURPOSE:

The MI Part 5 Rules are intended to prevent releases of polluting materials to surface waters or ground waters of the state.

MI Part 5 RulesChemicals affected by the MI Part 5 Rules

OilSaltAny material specified in table 1 ( ~ 964 chemicals)Any compound or product that contains 1%, or more, by weight, of oil, salt or any material listed table 1.

MI Part 5 RulesMain Requirements1. Secondary containment

Oil, Salt, or Compounds or products containing > 1% of any material listed in the Polluting Materials list and exceed the threshold management quantities of the following:

Salt, in solid form, at any location in a quantity greater than 5 tons

Salt, in liquid form, at any location in a quantity great than 1,000 gallons

Oil, stored aboveground in quantities greater than 1,320 gallons or in a single AST with a capacity of 660 gallons. NOTE: Oil storage and use does not need to be addressed in a the PIPP if a facility complies with 40 CFR 112 (SPCC Plan)

All other polluting materials at any discrete outdoor location in aggregate quantities greater than 440 pounds

All other polluting materials at any discrete indoor location in aggregate quantities greater than 2200 pounds.

MI Part 5 RulesMain Requirements

NOTE:

Even without threshold quantities, secondary containment may still be neededLocal Sewer Use Ordinance to protect

accidental release to the City of Flint sewers

MI Part 5 Rules Main Requirements2. Pollution Incident Prevention Plan (PIPP)

Required if a facility exceeds the threshold management quantity for oil, salt, or any of the 964 polluting materials.

Threshold management quantity is the total amount of chemical in one discrete area that determines if a facility is required to implement a PIPP and provide secondary containment.

Contents of a PIPP (similar to SPCC Plan requirements)A. Identification Information

Facility Parent corporation and owners Facility description and operations Spill clean-up responders

MI Part 5 Rules Main Requirements2. Pollution Incident Prevention Plan

(PIPP)Contents of a PIPP Cont’d

B. Materials used or stored on the polluting materials list.C. Storage tanksD. Spill prevention and controlE. Spill response and clean up proceduresF. Chemical InventoryG. Secondary Containment Structures

MI Part 5 Rules (PIPP) Vs. SPCCSummary

SPCC40 CFR Part 112

(FEDERAL)Regulate oil products

onlyRequire routine

inspections on containers of OIL greater than 55 gallons

Plan required if storing 42,000 gal underground or an aggregate of 1320 gal of oil

PIPPMI Part 5 Rules

(STATE)Regulate oil, salt,

and ~964 polluting materials

Don’t require routine inspections

Plan required if exceed threshold management quantity for oil (same as SPCC), salt, or the polluting materials

PIPP TEST

1. The PIPP Plan regulates the following pollutant(s).a. Waterb. Saltc. Oild. All the above

2. Where are the your department MSDSs located?a. CEP Control Roomb. Hubbard Building front officec. Lunch roomd. Tim Barden Joel Ellis’ office

3. The PIPP is intended to prevent releases of polluting materials to surface waters or ground waters of the state.a. Trueb. False

4. Which of the following is part of the FM/CEP spill clean up procedures?a. Notify the appropriate response coordinatorb. Sound the alarm and evacuate personnelc. Attempt to control the situationd. All the above

5 Who do you call FIRST in the event of an emergency release into the storm drain?a. Young’s Environmentalb. DPS & EHSc. Supervisord. Director

Due Care Regulatory Requirements:

ENVIRONMENTAL ENVIRONMENTAL DUE CARE DUE CARE

AT AT UM-FLINTUM-FLINT

Due Care Regulatory Requirements:UM-Flint is subject to due care obligations for all activities that

may disturb the soil/earth i.e. construction, maintenance, subsurface activities at the following properties: WSW Building and surrounding areas including former Horse Barn Former Perry Printing Site Parking Lot A and all surrounding areas (CE/MGP) Hubbard Compound Northbank Center, NBC Parking Ramp and surrounding areas Proposed Student Hosing Site and surrounding areas

The properties are classified as a “facility” (Part 201 of Act 451) because contamination has been detected in soil and/or groundwater at concentrations exceeding generic residential cleanup criteria.

UM and its contractors have legally enforceable responsibilities for ensuring that: Its actions do not exacerbate existing contamination The intended use of the property will not result in unacceptable exposures to

hazardous substances It takes reasonable precautions with regard to acts or omissions of third parties.

These requirements are a result of previous existing environmental site conditions that existed prior to UM acquiring the property.

Due Care Regulatory Requirements:

WSWSWW

NBCNBC

PERRYPERRY

CE MGPCE MGP

STUDENT HOUSINGSTUDENT HOUSING

CEP USTsCEP USTs

Due Care Regulatory Requirements:Notification to adjacent property owners, utility

workers, contractors, state and local agencies.Develop and implement property specific Due Care

Plans for the contaminants found in the soil or groundwater at that location.

Internal/institutional controls… letter to FM Director, internal policies, distributed Due Care Plans, contractual language for construction projects…

Monitoring of site conditions, protective barriers, odors, staining of soil, sheen on water outfalls, etc.

Monitoring of site activities by employees and contractors… FM, Project Mgrs., EHS

Soil/groundwater sampling and analysisManagement of soils, groundwater, dewatering

activities, spoils, decontamination, personal hygiene Documentation

How does this effect routine activities or planning projects at

UM-Flint?Notify EHS of subsurface work on campus…

participate in preplanning of project/activity.Proper selection of PPE for UMF employees… know

the specific contaminants, their location and hazards in the work the area

Management of soils on site, replace protective cap/barrier

Manifest soils leaving site… Contact EHS.Test/document clean soils on site…. Contact EHS 5-15

days ahead of time to allow for sampling of the source. Monitor protective barriers that are in place

ECDC Playgrounds: GeoFabric at 12-18 inches below grade WSW: 6-9 inches of clean topsoil NBC: paved parking areas PERRY: 2-4 feet of clean fill across the site CE MGP: paved surface Lot A, some replaced soils near Rec Center, impacts and

contamination is found DEEP under River and WSW Site 60-100 feet. Housing & Kearsley Street- GeoFabric at 9 - 12 inches below grade

Inform contractors in writing, monitor compliance w/ established Due Care requirements

SUMMARYNothing but water permitted down storm drains!

Report spills immediately, protect drains if you can do so safely.

Due Care, SWM, SESC, SPCC, BMPs are all related…… protecting our natural resources, preventing degradation of the surface water, reducing exposure to potentially harmful pollutants and ultimately protecting the public’s health .

Implement Best Management Practices into everyday work practice to comply with NPDES Permit and SWM Program. Provide feedback to EHS on SWMP over the next 30 days.

Plan ahead… incorporate BMPs into projects ahead of time regardless of the size of the project.SESC Plan required for >1 acre or within 500 feet of River

Project Managers and Supervisors incorporate these requirements into SOPs, project specifications, monitor and enforce compliance with contractors and employees.

Use a Team Approach when complying with Env. Regulatory Requirements… FM, EHS/OSEH, Supervisors, Project Managers, Contractors, MDNRE…

Notify EHS of any subsurface work on campus.

QuestionsQuestionsPlease contact Environment, Health and Safety Please contact Environment, Health and Safety

at 766-6763 or 919-1709at 766-6763 or 919-1709

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Soil Erosion &Sedimentation Control

EROSIONEROSION = Soil particles dislodged by wind, water, or gravity

SEDIMENTATIONSEDIMENTATION = Soil particles deposited on land or in water bodies

Rill Erosion

Gully ErosionGully Erosion

WashoutWashout

Clogs Ditches and Culverts…

Muddy Muddy Streams…Streams…

Reduced recreational Reduced recreational valuevalue

Damage to plants & Damage to plants & animals…animals…

Soil Erosion &Sedimentation Control (SESC)

UM applied for Authorized Public Agency (APA) status for Soil Erosion & Sedimentation Control (SESC) June 2003…granted APA status from MDEQ effective 9/22/04

The City of Flint and Genesee County will no longer issue SESC permits or conduct inspections for sites owned by the University;

UM-Flint EHS, UM OSEH-EM, and the UM Planning Office will now review SESC plans for sites involving earth activity >1 acre or within 500 feet of water bodies.

Plans must be approved before any earth change activities begin (demolition, grading, clearing, tree removal, etc.).

SESC plans are not required for project sites <1 acre or greater than 500 feet from water bodies (Flint River) but notification to EHS must be made prior to beginning and most importantly, all SESC regulatory requirements and protective measures must be followed, no matter the size of the project..

SESC ExemptionsEarth disturbances that are completed/closed

within 24 hours Earth disturbances that are less than 225 sq.

ft. (otherwise approx. 15’ X 15’ area) Both exemptions are important to the Flint

Campus because the majority of our earth disturbances will be simple landscaping, tree planting, sidewalk install/repair, or utility related projects that would be either completed w/in 24 hours or less than the 225 sq.ft exemption.

Project Managers must evaluate All activities employ the appropriate Best Management Practices or BMPs to protect the river and “Waters of the State”… storm drains.

Submit SESC Plans to EHS… Project managers must compile/forward four (4) completed

copies of SESC plans for review/approval. One copy to EHS Department (204 UPAV) Two copies to UM OSEH-EM Environmental Specialist / SESC Inspector

Occupational Safety & Environmental Health - University of Michigan 1239 Kipke Drive , Ann Arbor, MI  48109-1010

Please allow 45 days for review and comments on plans.After EHS, OSEH-EM and University Planning have

completed their review UM OSEH-EM will issue final approval of SESC plans for Flint projects >1 acre and/or within 500 feet of river.

Approved plans will be stamped accordingly, one set will be retained by OSEH-EM and one set will be kept at the site.

Weekly inspections and inspections after significant rain events for all sites involving earth activities must be conducted & documented.

For large projects, inspections may be contracted out with the approval/coordination of EHS/OSEH. This could be an additional cost to the project.

12 Components of SESC PlansDESIGN DEVELOPMENT REQUIREMENTS

Scaled Map including: 1. Legal description 2. Site location sketch 3. Proximity to waters of the state. 4. Predominant land features 5. Contour intervals or slope descriptions 6. Soil survey / written description of soil types of the exposed land

area Details for the proposed earth change including:

7. Description & location of physical limits of each proposed earth change

8. Description and location of all existing and proposed on-site drainage and dewatering facilities.

9. Timing and sequence of each proposed earth change. 10. Location & description for installing/removing all temporary SESC

measures. CONSTRUCTION DEVELOPMENT REQUIREMENTS

11. Description and location of all permanent SESC measures. 12. Program for the continued maintenance of all permanent SESC

measures that remain after project completion. Include the designation of the person responsible for the maintenance.

Best Management Practices - BMPsControl erosion first, THEN sedimentationDesign a project specific SESC Plan

incorporate the SESC plan into the project specs for contractors (and employees)

small projects… still enforce BMPsRoutine Inspections

WeeklyWithin 24 hours after precipitation event MDEQ Certified Construction Site SWM OperatorDocument inspections

Immediately repair/replace any failed protective devices

Project is not complete and inspections must continue until all permanent controls are in place and site is stabilized.

Keep it on the Site!Keep it on the Site!

Inlet Fabric Inlet Fabric Filters and Filters and Silt SacksSilt Sacks

Spoil Pile Protection

Soil Piles on site >24 hoursSoil Piles on site >24 hours• Piles must be covered to prevent Piles must be covered to prevent

erosion from winderosion from wind• Piles must be protected from Piles must be protected from

water erosion due to precipitation water erosion due to precipitation eventsevents

Silt Fence

Grade Stabilization

Check Dam

Retention Basin

Vegetative Buffer / Basin

Anti-tracking pads

Street Sweeping

• Non U-M streets cannot show any signs Non U-M streets cannot show any signs of trackout. Sweeping must occur any of trackout. Sweeping must occur any time trackout is visible.time trackout is visible.

• UM streets should be swept daily, at a UM streets should be swept daily, at a minimum during construction projects, minimum during construction projects, and when trackout is visibleand when trackout is visible..

Silt Fences require regular inspections and Silt Fences require regular inspections and maintenance… built up sediment MUST be removed if maintenance… built up sediment MUST be removed if it reaches 1/3 – ½ the height of fenceit reaches 1/3 – ½ the height of fence

Silt fencing must be toed in to a depth of 6 Silt fencing must be toed in to a depth of 6 inches and backfilled.inches and backfilled.

Inform Contractor, reinstall silt fence that has Inform Contractor, reinstall silt fence that has been run over by machinery. Consider been run over by machinery. Consider additional control measures siltsack in closest additional control measures siltsack in closest catch basin for additional protection catch basin for additional protection

UM SESC Program Guidelines & Forms…

First point of contact: UM-Flint EHS, 766-6763 or

mjlane@umflint.eduOnline forms and resources: OSEH Ann Arbor Website:

www.oseh.umich.edu Soil Erosion and Sedimentation Control Procedure Appendix A – Project Notification Form Appendix B – Design & Review Checklist for SESC Plans Appendix C – Field Inspection Report Appendix D – Preferred SESC Design Elements Appendix E – Regulations in Brief

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