Loading...
HomeMy Public PortalAboutCity of Ladue OPERATION AND MAINTENANCE PROGRAM FOR THE PREVENTION AND REDUCTION OF POLLUTION IN STORMWATER RUNOFF FROM MUNICIPAL OPERATIONS WTI'NIN THE CITY OF LADUE RECEIVED 4' F # FEB 17 2021 '4 DIVISION OF ENVIRONMENTAL COMPLIANCE r, L. I.J.Li tJJNITY,, missouf' I (-1\fr))$ c'(\.) ))Y—n.s i aiL:PI ‘,-- ' F itli , err 9 LJ r i1 Adopted: October 21, 2019 Page 1 of 56 r\i\ D MAINT7 NJ FOR THE PREVENTION AND REDUC'!!r_)i‘1 tJr P D!!U J1 )N IN STORMW'ATE ;)_..rJ 11 MUNICIPAL OPERATIONS WITHIN THE CITY OF CITY OF LADUE CITY OF LADUE T. LOUIS COUNTY, MISS ID u; r €-P 2., G tl I 1- FF ( , ' ,r/ //,/ Adopted: October 21, 2019 Page 1 of 56 TABLE OF CONTENTS Chapter 1 — Program Administration 3 Chapter 2 — General Housekeeping, Operation and Maintenance 5 Chapter 3 —Vehicle/Equipment Repair and Maintenance Operations 13 Chapter 4 — Vehicle/Equipment Washing 18 Chapter 5 — Facility Repair, Remodeling and Construction 20 Chapter 6 — Cleaning and Maintenance of Roadways, Highways, Bridges 24 And Parking Facilities Chapter 7 — Maintenance of Parks, Green Spaces, Trails and Landscaping 28 Chapter 8 — Cleaning and Maintenance of Drainage Channels, Storm 33 Sewers and Inlet Structures Chapter 9 — Operation and Maintenance of Recycling and Yard Waste 36 Facilities Chapter 10 — Water Quality Impact Assessment of Flood Management 38 Projects Appendix 2-F1: Recycling Policy 40 Appendix 2-F2: Green Procurement Policy 42 Appendix 2-F3: St. Louis County Waste Management Code 45 Appendix 5-F1: Corps of Engineers 404 Permit & MDNR 401 Certification 50 Glossary: Definitions of Terms Used in This Document 52 For More Information 56 Page 2 of 56 Chapter 1 - Program Administration A. Introduction: The Missouri Department of Natural Resources (MDNR) issued Phase II Stormwater Permit MO-R040005 to the City of Ladue and other co-permittees in St. Louis County, effective December 14, 2016. The area served by the co-permittees is collectively known as the St. Louis Metropolitan Small MS4. One of the minimum control measures in the permit that must be addressed by the co-permittees includes pollution prevention and good housekeeping for municipal operations. Specifically, MCM 6 section of the permit requires each co-permittee to "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 municipal operations." A Stormwater Management Plan (SWMP) for the St. Louis Metropolitan Small MS4 Stormwater is implemented under the Phase II permit. As a co-permittee under the state permit the City of Ladue is bound by the commitments contained in the SWMP. The SWMP requires a model operation and maintenance program template and that each co-permittee implement a written operation and maintenance program. This document represents the City of Ladue implementation of the model operation and maintenance program as applicable and tailored to specifically meet City of Ladue needs and goals. This program impacts all facets of municipal operations. It is the City of Ladue intent to adhere to the policies and procedures stated herein in order to prevent pollution, to safeguard the environment for the health and benefit of all city employees, residents and visitors and to serve as a model for the entire regulated area. Where the municipal operations described in this manual are contracted, rather than performed by municipal employees, the best management practices (BMPs) will be imposed to the maximum extent practicable on the contractor through purchasing or contract mechanisms by including BMPs in the scope of work or job/service specifications. Contractors will be required to obtain all applicable local/state/federal environmental permits. B. Policies: The City of Ladue has adopted several policies regarding the purchase of recycled products; janitorial and other supplies exhibiting lower toxicity; utilization of integrated pest management practices; and other pollution prevention policies. Copies of policies are contained in Appendix 1-B1. C. Organization of Manual: The SWMP contains nine major categories of municipal operations/activities. Based on its size and the nature of its municipal services each co-permittee may have activities in only some or in all nine categories. For consistency within the Plan area, each of the nine categories is addressed in the following Chapters 2 through 10. A statement of non- applicability is contained in those chapters where the City of Ladue is not engaged in the subject activity. ONLY RAIN r Page 3 of 56 ' D. Administration: The responsible party for administration of the operation and maintenance (O&M) program is the Director of Public Works. This person is responsible for ensuring the program is kept up to date, and that employees are trained on the procedures implementing the program. The City of Ladue will train all staff associated with activities that can impact pollution in stormwater runoff. Each chapter will identify employees who should be subject to training on that particular chapter. Employees will receive general stormwater pollution prevention training provided by the Missouri Department of Natural Resources, Environmental Assistance Office or others. Upon implementation of specific procedures, management will review the new procedures that incorporate stormwater BMPs, proper waste management and applicable NPDES permit requirements with all employees affected. New employees will be trained on applicable procedures within the first three months of employment. Contractors working for the municipality and implementing BMPs for municipal work, as described in Section A., must train their employees on applicable BMPs before work begins. To maintain proficiency, a schedule of periodic retraining will be implemented, or provisions made for an employee awareness campaign to ensure employees remain aware of the BMPs and proper waste management. Records documenting the training of employees and contractors must be maintained in file. E. Industrial Facilities No Exposure List The SWMP requires that each co-permittee list regulated industrial facilities (subject to NPDES permit) that it owns or operates that are subject to "No Exposure Certification." No exposure means all the materials and activities at a regulated facility are indoors or protected from exposure to rain, snow, snowmelt and runoff. Guidance for no exposure certification is located at: https://dnr.mo.gov/pubs/pub2729.htm A list of City of Ladue No Exposure Certifications follows: Facility Name Facility Address No Exposure Certification Expiration Date • 1 City of Ladue Public 9345 Clayton Road 10/13/2021 Works Page 4 of 56 Chapter 2 - General Housekeeping, Operation and Maintenance A. Description of Activities: Municipal operations include a variety of activities conducted to maintain City owned property and facilities. This chapter will cover those activities that are not specifically covered in the other chapters of this document. This chapter covers custodial and building maintenance activities, materials management and storage, safe material substitutions, spill plans, establishment of general O&M procedures, scheduling, record keeping and housekeeping practices in general. This chapter also covers general municipal housekeeping issues, which include illegal dumping, littering, pet wastes, trash storage, and recycling. B. Locations: 1. City Hall Complex — 9345 Clayton Road. This facility is situated on 6.2 acres, with a total of six buildings (City Hall, Building Department, Police Department, and 3 Public Works' buildings). The City Hall Building has a size of approximately 5,450 square feet and houses the Finance and Administration Department. The Building Department Building has a size of approximately 4,245 square feet. Descriptions of the other buildings are located in the sections below. The complex provides paved parking for visitors and employees, and all City vehicles, including police cars. Materials and supplies utilized in performing all building maintenance, including custodial work, are stored within the buildings. A total of 12 employees report to this facility. 2. Public Works Facility — 9345 Clayton Road. This facility houses the Street Maintenance Division and the Vehicle Maintenance Department of the Public Works Department. The facility is situated within the City Hall Complex. It contains a main building, two covered equipment storage buildings (Building B and Building C), a covered bulk storage bin, and a municipal garage. The municipal garage building has nine (9) vehicle work bays, an enclosed vehicle wash bay, a sign shop, shower/locker facilities, lunchroom, administrative offices, a conference room and a fueling station. The fueling station has two underground storage tanks with a capacity of 10,000 gallons each (one diesel and the other unleaded gasoline). A 61-foot diameter salt dome, with a capacity of 1,400 tons, is also located on the site. A paved parking lot is provided for visitors and employees. All equipment associated with street maintenance activities are stored within the covered equipment storage building or on the paved yard storage area. All materials utilized in performing street maintenance are either stored within the main building or within the covered bulk storage bin. All fleet maintenance activity is done inside the municipal garage, within the vehicle work bays. The Vehicle Maintenance Department maintains the entire City fleet, including police cars. The Public Works Facility typically operates from 7 a.m. to 3:30 p.m. The hours vary during emergency operations such as snow removal. A total of 14 employees report to this facility. Page 5 of 56 3. Yard Waste Transfer Station — 9810 S. Forty Drive. This facility is located on approximately 14.5 acres of which approximately 4 acres are developed for the City's storage of collected yard waste materials. Stormwater runoff at the site flows to two onsite basins that are covered under its own NPDES permit. During the year, employees monitor the site periodically for routine maintenance tasks. 4. Police Department — 9345 Clayton Road. This facility is situated within the City Hall Complex. The Police Department houses the police officers and dispatchers. Materials and supplies utilized in performing all building maintenance, including custodial work, are stored within the building in the first floor custodial closet. A total of 33 employees report to this facility. 5. Fire Department (Engine House No. 1) — 9213 Clayton Road. This station houses a pumper truck, ambulance, and firefighter/EMS quarters. Materials and supplies utilized in performing all building maintenance, including custodial work, are stored within the building. A total of 21 employees report to this facility. 6. Fire Department (Engine House No. 2) — 9911 Clayton Road. This station houses a pumper truck, a reserve pumper truck, and firefighter/EMS quarters. Materials and supplies utilized in performing all building maintenance, including custodial work, are stored within the building. A total of 12 employees report to this facility. C. Responsible Parties: 1. City Hall - The City Clerk and Public Works Director have authority over City Hall and the Building Department. The building is actively managed by the Public Works Superintendent. City Clerk (Laura Rider): (314) 993-3439 Director of Public Works (Anne Lamitola): (314) 993-5665 Public Works Superintendent (Scot Bollinger): (314) 993-5665 2. Public Works Facility — The Director of Public Works has authority over the Public Works Facility. The facility is actively managed by the Public Works Superintendent. Director of Public Works (Anne Lamitola): (314) 993-5665 Public Works Superintendent (Scot Bollinger): (314) 993-5665 3. Police Department - The Chief of Police has authority over the Police Department. Chief of Police (Ken Andreski): (314) 993-1214 4. Fire Department - The Fire Chief has authority over the Fire Department. Fire Chief (Steve Lynn): (314) 993-0181 Page 6 of 56 D. Materials/Supplies acquisition, storage and usage: City Hall Complex: Material/supply needs are determined by the Janitorial Vendor that performs the cleaning of the City Hall Complex under contract. Material Maximum Quantity Kept On For Use Storage Location Hand Within Various Cleaning Supplies only amount needed 4 months Various custodial closets Aerosol Cans (various only amount needed 4 months Various custodial products) closets Fluorescent Lamps only amount needed 4 months Various custodial closets Public Works Facility: Material/supply needs are determined by the Janitorial Vendor that performs the cleaning of the Public Works facility by under contract. The Public Works Superintendent has on-site responsibility. Material/supplies used in vehicle/equipment maintenance and repair operations are listed in Chapter 3. Materials/supplies used in roadway/bridge maintenance are listed in Chapter 6. Material Maximum Quantity Kept On Hand For Use Within Storage Location Various Cleaning Supplies only amount needed 4 months Various custodial closets Police Department: Material/supply needs are determined by the Police Department Staff. Material Maximum Quantity Kept On Hand For Use Within Storage Location Window Cleaner 2 gallons 3 months 1st floor material closet Aerosol cans (cleaners) 5 3 months 1st floor material closet Hand soap 2 gallons 3 months 1st floor material closet General purpose cleaner 3 gallons 3 months 1st floor material closet Fluorescent lamps 65 1 year 2nd floor electrical room Lighting ballasts 12 1 year 2nd floor electrical room Fire Department (House 1): Material/supply needs are determined by Fire Department Staff. Material Maximum Quantity Kept On Hand For Use Within Storage Location Various cleaning supplies 29 gallons 6 months Various custodial closets Flourescent lamps 4 boxes 1 year Attic Oil-based paints 2 gallons 6 months Various custodial closets Spray paint 6 cans 6 months Various custodial closets Organic solvents 5 cans 3 months Various custodial closets Page 7 of 56 Fire Department (House 2): Material/supply needs are determined by Fire Department Staff. Material Maximum Quantity Kept On Hand For Use Within Storage Location Various cleaning supplies 4 gallons 3 months Various custodial closets Flourescent lamps 2 boxes 6 months Attic Oil-based paints 2 gallons 6 months Various custodial closets Organic solvents 2 cans 2 months Various custodial closets E. Waste generation, storage, disposal, recycling: City Hall: Standard office waste is generated along with waste from custodial operations. Public Works Facility: Standard office waste is generated, along with waste from custodial operations. Additional waste generated from vehicle maintenance activities and street maintenance activities is included in Chapters 3 and 6 of this document. Police Department: Standard office waste is generated, along with waste from custodial operations. Fire Department (House 1 & 2): Standard office waste is generated, along with waste from custodial operations. Waste Maximum Storage Storage Method Of Contractor Frequency Capacity Location Disposal Standard Office Waste dumpster parking lot landfill Progressive weekly White Paper& Cardboard Recycle dumpster parking lot recycle Progressive weekly Recycle tubs (18 Aluminum Cans & Plastic gallon) then to recycling recycle Progressive weekly Bottles recycle dumpster bin Custodial Waste (mop buckets, auto scrubber, N/A N/A closet drain N/A daily water based cleaners) Lamp (green tip 50 Building A recycle Deliver to when fluorescent) Home Depot needed when Computer Monitors, CPUs 2 closetage r recycle varioussto needed Page 8 of 56 F. Best Management Practices (BMP): FACILITIES • Ensure grease traps and oil/water separators in kitchens and food service areas are maintained. Avoid sanitary sewer grease-blockage by regularly pumping out traps and separators. • Maintain site plumbing plans showing sanitary and storm sewer connections. Ensure wastewater is discharged only to the sanitary sewer, and stormwater to the storm sewer. Label storm drain inlets to ensure they are used only for stormwater drainage. • Minimize the use of pesticides through an Integrated Pest Management (IPM) Program. An IPM Program uses monitoring of pest populations compared to an action threshold, and then choosing the proper tactics, using nonchemical pest control practices, such as mechanical and biological controls, when possible, or less toxic products when needed. IPM does not rely on routine applications of pesticide based on a calendar date. Reduce the risk of West Nile Virus by reducing stagnant water (mosquito breeding grounds) caused by cans, containers and tires present in litter and junk piles. Keeping stormwater drainage gutters and drains clean will also reduce conditions suitable for mosquito breeding. Refer to MU Extension IPM Guides at: https://ipm.missouri.edu/pubs/ (See Chapter 7 for additional BMPs.) • Minimize the use of herbicides through an Integrated Pest Management Program for weed control. With turf grass, prevention of weed infestation begins with practices to promote healthy grass through proper planting, watering, fertilizing, mowing, aerification, and thatch control. Refer to MU Extension Publication IPM1009: https://extension2.missouri.edu/MX399 (See Chapter 7 for additional BMPs.) MATERIAL MANAGEMENT ._ `~. Reduce `� 414k • Develop a policy to purchase M� then Recycle recycled products or products with : lw- high post-consumer waste content whenever practical. Many resources are available from the EPA WasteWise Helpline: 800 EPA-WISE. Website https://www.epa.gov/smm/wastewise (See Appendix 2-F1 for a sample waste reduction and recycling policy.) • Collect and recycle, to the maximum extent practicable, wastes generated by municipal operations. (See the policy in Appendix 2-F1.) • Develop policy to purchase environmentally preferred products whenever practical. For a "Database of Environmental Information for Products and Services," see EPA website: https://www.esa.gov/governmentwide-initiatives/sustainability/buy-green- products-services-and-vehicles (See Appendix 2-F2 for a sample green procurement policy or https://www.calrecycle.ca.gov/buyrecycled/policies). Provide for the proper disposal of all wastes generated or collected in the course of municipal operations, in accordance with all applicable local, state and federal laws. • Inspect facilities for litter on a regular basis, and clean up as needed. • Keep trash container lids closed to keep rain out. Do not dispose of liquid waste in the trash container. • Ensure that the collection frequency of trash containers is appropriate to avoid overflows. • Outdoor material stockpiles at both permanent locations and at job sites should be covered to protect from rainfall and prevent contamination of stormwater runoff. Page 9 of 56 • Material stockpiles which cannot feasibly be covered should be surrounded by a berm or otherwise contained so that stormwater runoff can be captured. Petroleum products, fuels, chemicals, hazardous and toxic materials, and all wastes should be properly labeled to ensure appropriate handling and disposal. • Petroleum products, fuels, chemicals, hazardous and toxic materials, and all wastes should be stored and handled with appropriate safeguards to prevent contamination of stormwater from drips and spillage from the transfer of materials (for example, cover storage containers, use collection trays for drips, maintain spill kits and floor drain plugs to contain spills, etc.). Liquid containers should be stored under roof; or if outdoors, containers should be kept clean and sealed water-tight. • Prevent spills of hazardous materials by selecting storage areas that avoid traffic to minimize accidental contact, and select areas that are away from storm drain inlets and streams to minimize the impact of a spill. Storage areas should be kept clean and organized. • Contain and clean up all spills immediately. Ensure employees are familiar with spill response procedures and the location of spill kits to enable them to stop the spills at the source and contain the spilled material. With training on hazards from a material safety data sheet, minor spills can be addressed by employees, however, significant spills will require evacuation and contacting emergency responders. • Keep material safety data sheets (MSDS) for chemicals onsite for information on reportable spill quantities, proper handling, and health and safety issues. • Maintain and post a list of emergency contact numbers for spill reporting and spill clean-up contractor response, including: Missouri Department of Natural Resources (MDNR) — 573-634-2436, National Response Center — 800-424-8802, and for releases to the sewer, MSD — 314-768-6260. Reportable quantities (RQ) for chemicals are listed on the MSDS, and petroleum RQs include: any amount released to a storm sewer or waterway causing a sheen, 25 gallons from an underground tank, and 50 gallons from all other sources. • Prepare for appropriately handling the clean-up of the spilled material and disposal of waste. Do not hose down spills to the storm sewer system. Clean up spills with dry methods, using absorbent to pickup fluids. • Spill response plans are recommended for all areas of municipal operations. Spill Prevention Control and Countermeasure (SPCC) plans are required to meet regulatory criteria in 40 CFR 112 for sites with a storage capacity over 660 gallons oil in one container or 1,320 gallons on site. • Establish at all municipal facilities materials management and inventory controls to include the proper identification of hazardous and non-hazardous substances, and proper labeling of all containers. • Regular inspections and inventory of material storage and use areas should be performed to ensure BMPs are being used. Page 10 of 56 COMMUNITY • Develop/enforce ordinances for waste containers which regulate size, type, covers and water-tightness for residential, commercial and industrial areas. (See Appendix 2-F3 for language from the St. Louis County Waste Management Code.) • Develop/enforce ordinances against illegal dumping, littering and improper yard waste disposal, providing for corrective action, enforcement and penalties. (See Appendix 2-F4 and 2-F5 for Model Ordinances.) • Develop/enforce ordinances requiring pet owners, property owners, and equestrian and animal boarding facilities to clean up wastes from their pets and other animals. (See Appendix 2-F6 for Model Ordinance). • Provide pet waste scoop dispensers and signage in parks and other public areas frequented by pet walkers to promote the proper disposal of pet waste and notify the public of ordinance requirements. • Provide recycling and yard waste services for residential waste. • Provide sufficient numbers of appropriately-sized waste receptacles at municipal facilities and in public areas with regularly scheduled servicing, collection and disposal. • Educate citizens on trash and pet waste issues to promote compliance with ordinances using available methods such as resident newsletters, brochures, internet sites, storm drain marking projects, etc. • Promote and assist in neighborhood and stream clean-up activities. • Develop/enforce municipal ordinances against illegal discharges to stormwater from sources such as failing septic tanks, septic tanks discharging to stormwater, etc. Ordinances to address illegal connections of sanitary sewers should be at least as stringent as the Missouri Department of Health regulations in 19 CSR 20-3 and County requirements, such as St. Louis County Plumbing Code Section 1103. • Develop/enforce municipal ordinances requiring the proper maintenance of septic tanks and other small onsite sewage disposal systems. For a model ordinance, see: http://www.anjec.orq/pdfs/Ord-ModelSeptic.pdf O&M PROGRAM • Establish standard operation and maintenance procedures, maintenance schedules and long term inspection procedures in accordance with this program manual with emphasis on safety, efficiency, and compliance with applicable laws and good environmental stewardship. • General housekeeping inspections of facilities and storage areas should be performed once a month and records kept of the inspections. • Develop record keeping procedures that effectively track implementation of program elements and that provide the information necessary to meet the reporting requirements of the MS4 permit. G. NPDES Permit status: Applicable MDNR general stormwater permits must be obtained if the (city) engages in the following activities described by the following categories: Airports (R80F) — Stormwater runoff from airports that use deicers or conduct uncovered vehicle or aircraft maintenance, washing, or fueling. Page 11 of 56 Equipment/Vehicle Washing (G75, See also Chapter 4) - Car wash wastewater treatment systems for design flows of 50,000 gallons per day or less. This includes no-discharge land application systems. Provides for 500 gallons per day de-minimis exemption under certain conditions. Recycling facilities (R8OH, See also Chapter 9) - Solid waste transfer stations, and solid waste recovery facilities. Yard Waste compost facilities (G97, See also Chapter 9) - Yard Waste Composting operations between 2 to 5 acres. Solid Waste Transfer — requires a site specific stormwater permit. Swimming pools (G76) — Discharges of filter backwash and pool drainage from swimming pools and lined ponds. Transportation Operations (local bus, etc.) — requires a site specific stormwater permit. Trucking (R80C) - Motor freight transportation (garbage, refuse, etc.). Vehicle Maintenance (R80C, See also Chapter 3) - Motor freight transportation and warehousing. Warehousing and storage (R80C) - Motor freight transportation and warehousing. If the above categories describe (city) operations, but the activities and materials stored or handled are not exposed to stormwater, a "No Exposure Certification" must be submitted in lieu of obtaining a permit. Further descriptions and a copy of the general permits are available at: https://dnr.mo.gov/env/wpp/permits/issued/wpcpermits-stormwater.htm The discharge of process waste water to a stormwater inlet from any (city) facility requires an NPDES Operating Permit from MDNR's Water Pollution Control Program. All permit conditions and limitations must be complied with. H. Training: All employees involved in maintenance operations, construction, purchasing, facility or site design, or building or facility management will be trained on this chapter, including the following Departments and work units: • Public Works Department • Police Department • Fire Department In addition to training on the housekeeping BMPs and proper waste management, employees will be provided general awareness of NPDES discharge requirements. Page 12 of 56 Chapter 3 - Vehicle/Equipment Repair and Maintenance Operations A. Description of Activities: The Vehicle Maintenance Division of the Public Works Department is responsible for the maintenance and repair of equipment and vehicles ranging from chain saws and light vehicles to loaders and tandem dump trucks. Preventative maintenance or PM's include oil and filter changes, tune ups and tire rotations. Repairs include brake and welding work. There is a fueling site at the municipal garage. Outside contractors perform services such as glass repair or replacement and all bodywork. B. Locations: The municipal garage is located at 9345 Clayton Road at the City Hall Complex. It is responsible for approximately 40 pieces of equipment. This location has a welding area and nine work bays. One of the work bays has an above ground lift and one has a service pit. The materials/ supplies used at this facility are all stored inside. The floor drain is connected to sediment/oil traps. The bulk oils and fluids that are used are stored in 55-gallon drums in Building B. The drums are kept on spill containment pallets to provide protection from leakage or spills. All bottled oils and spray chemicals are stored inside in the parts room. The majority of repair and maintenance work is done inside however, due to the difficulty in moving certain pieces of equipment, some work is done at the job site. The above location performs vehicle and equipment maintenance for all City of Ladue Departments except for the Fire Department. The Fire Department performs periodic maintenance on the Fire Department vehicles, but often maintenance is either out-sourced to a vendor or performed by Fire Department personnel or vendors at the Public Works building. C. Responsible Parties: The Public Works Director oversees all aspects of fleet administration and operations. This person is responsible for the day-to-day operations of the municipal garage. The garage has one full-time employee and one part-time assistant as needed. D. Materials/Supplies acquisition, storage and usage: Public Works: Materials/supplies for vehicle maintenance and repair are ordered through the Public Works Department. The following materials and quantities are typically kept on hand for main garage operation: Material Maximum Quantity Kept On Hand For Use Within Storage Location 5w20 Oil 55 gallons 6 months Building B 15w40 Oil 55 gallons 6 months Building B 30w Oil 1 case 6 months Building B Trans Fluid 55 gallons 6 months Building B Hyd Fluid 55 gallons 6 months Building B Page 13 of 56 Anti-Freeze(Reg) 55 gallons 6 months Building B Gasoline 10,000 gallons 3 months Underground Tank++ Diesel 10,000 gallons 3 months Underground Tank++ Brake Solvent 1 case 6 months Building B Penetrating Oil 1 case 6 months Building B Brake Clean 1 case 6 months Building B Carb Cleaner 1 case 6 months Building B + Bulk containers are double walled ++ Underground fuel tanks meet all 1998 UST standards and are insured by UST Insurance Fund Fire Department: Materials/supplies for fire truck maintenance are ordered through the Fire Department. The following materials and quantities are typically kept on hand for fire truck maintenance: Material Maximum Quantity Kept On Hand For Use Within Storage Location 5w30 Oil 5 quarts 6 months Storage area 10w30 Oil 5 quarts 6 months Storage area 15w40 Oil 5 quarts 6 months Storage area 30w Oil 5 quarts 6 months Storage area Hyd Fluid 1 gallon 6 months Storage area Anti-Freeze 1 case 6 months Storage area Gasoline 3 gallons 6 months Storage area Penetrating Oil 4 cans 6 months Storage area Brake Cleaner 4 cans 6 months Storage area Carb Cleaner 4 cans 6 months Storage area E. Waste generation, storage, disposal, recycling: Waste generated by municipal garage operations is as follows: Maximum Storage Method Of Waste Storage Location Disposal Contractor Frequency Capacity Used Motor Oil, Hydraulic 250 gallons maintenance recycle Safety Clean As needed and Transmission Fluid yard maintenance Oil Filter Used Oil Filters N/A yard recycle Recyclers of As needed Illinois Equipment Batteries N/A Building B recycle SS Automotive as needed (Lead-acid and NiCd) mai yardance Tires < 25 recycle Wedge Tire as needed Scrap Metal N/A maintenance recycle metal recycler as needed yarPage 14 of 56 Oil Filter Shop Towels N/A Building C recycle Recyclers of as needed Illinois Organic Solvent for Parts 55 gallons Building B recycle Safety Kleen as needed Cleaning Sand Blasting Grit (no N/A Building C landfill waste hauler as needed lead based paint) F. Best Management Practices (BMP): OPERATIONS • Institute a preventive maintenance program to minimize fluid leaks and equipment failures. Inspect vehicles and equipment frequently for leaks, collecting leaks with pans or absorbent, and repairing leaks. • All routine vehicle maintenance and repairs at City of Ladue facilities are performed indoors. On occasion and when necessary, outside maintenance work will be performed in a paved area with provisions made to contain and clean up all drips and spills. • Use non-hazardous, environmentally safe products when possible. Avoid use of chlorinated organic solvents. • Environmentally safe detergents are used instead of caustic cleaning solutions. • Flammable liquids are kept in a vented fire-rated cabinet. • All supply material and waste containers are marked clearly and properly to identify the contents. • Keep material safety data sheets (MSDS) for chemicals onsite for information on reportable spill quantities, proper handling and health and safety. • All supply material and waste containers are stored under cover to prevent contact with rainfall; or when uncovered, containers are clean and sealed. • Tops of containers have absorbent mats and are free of standing liquid, and stored containers are kept closed. • Waste oils, filters, antifreeze, and other wastes are collected in designated, labeled containers and recycled to the maximum extent practicable. • Wheel weights are kept in a container marked "scrap lead". • Records of waste pick-ups are logged and maintained in file. • Drain pans are labeled for specific types of fluid. Use pans under vehicles and equipment with fluid leaks. Always use drip pans when making and breaking connections. • Used oil filters should be gravity drained for 24 hrs with the anti-drain back valve or filter dome punctured to facilitate the draining process. Crushing the oil filter and recycling is preferred. • Batteries, waste oil, etc. having spill/leak potential are stored indoors and are in secondary containment, when possible. • Neutralizer and absorbent are kept by both new and used batteries. • All floors are clean of oil and grease. Page 15 of 56 • Immediately clean up all spills of chemicals or vehicle fluids using dry methods (absorbents), minimizing the use of water whenever possible. • Vehicle operators should be instructed to remain with the vehicle during fueling, and not to top-off the fuel tank to avoid overflows and spills. • For painting or sanding activities outdoors, use a tarp enclosure to contain and capture material. Collect and dispose of paint chips and sand blast waste in the trash for non- lead based paint, or evaluate lead based paint for hazardous waste disposal. • Keep the facility and surrounding area clear of litter. SPILL PREVENTION • Spill control plans should be in place with procedures for proper spill response to minimize environmental impacts. SPCC plans must meet regulatory criteria in 40 CFR 112 for sites with a storage capacity over 660 gallons oil in one container or 1,320 gallons on site. • Procedures for loading, unloading and transfer operations should be developed to prevent overfilling and spills. • In areas where spills could occur, such as fueling and loading areas, keep spill kits with absorbent materials nearby and display signage indicating the location of those spill kits. Storm drain plugs or covers are recommended to prevent the flow of spilled material from entering the storm drain. • Regularly inspect all tanks and containers to ensure physical integrity. • Maintain equipment to ensure the proper operation of automatic shutoff devices on pumps and, overfill protection and spill buckets on tanks. • Emergency phone numbers are clearly posted in the shop and near material storage areas. FACILITY • All floors in work areas are sloped to floor drains that are connected to an MSD- approved sediment/oil trap prior to discharge into the sanitary sewer system. Trap is pumped out quarterly, or as needed. • A site-plumbing schematic showing all drains, traps, and shut offs for utilities should be posted in shop. Employees should be made aware of sanitary and storm sewers to ensure all wastewater is discharged to the sanitary sewer. • Storm drains/inlets can be labeled to help protect from improper usage. • All above ground storage tanks have secondary containment in accordance with SPCC requirements and are covered with a roof. If containment is not roofed, inspect accumulated rain water for contamination prior to discharge. • Fueling areas are recommended to be designed with a roof to prevent contact with storm water. The area should be graded and sloped to direct storm water runoff away from the site and to prevent runoff from flowing over the fueling area. • Storm water treatment devices can be used to treat runoff from fueling areas. • No smoking" signs are posted in the shop, and near hazardous waste and flammable material storage areas. Verify that fire extinguishers are charged and inspected yearly. G. NPDES (National Pollutant Discharge Elimination System) Permit status: Vehicle maintenance facilities of this type are considered "municipal industrial" facilities under Page 16 of 56 the Missouri Storm Water Regulations and are subject to separate NPDES storm water (Phase I) permitting requirements under MDNR general permit R80C. As stated above, all of the City of Ladue's vehicle repairs and maintenance are preformed indoors or are otherwise done without exposure to storm water. Therefore, a NPDES Storm Water permit is not required and a no-exposure certification has been filed with the Missouri Department of Natural Resources. H. Training: Training on storm water BMPs will be provided to mechanics, storekeepers, material handlers, laborers, equipment operators, janitors, and management staff working at facilities identified in Section B. All employees will be provided safety training and training on written procedures pertaining to general housekeeping. Implement quarterly safety meetings to include environmental training and HAZMAT training. Page 17 of 56 Chapter 4 - Vehicle/Equipment Washing A. Description of Activities: The City of Ladue Public Works Department will wash vehicles and equipment at wash bay facilities designed according to this chapter. The Fire Department washes its vehicles at Fire Stations #1 & #2. Police Department vehicles and equipment will be taken to commercial facilities when washing is required. B. Locations: The City of Ladue's wash bay facilities are located in Building B at the Public Works Facility at 9345 Clayton Road. Fire House #2 also has facilities for the indoor washing for Fire Department apparatus. C. Responsible Parties: The Public Works Superintendent is responsible for ensuring that City Public Works vehicles are washed at the locations specified in Section B and that Police vehicles are taken off-site to approved commercial facilities. The Fire Chief is responsible for the Fire Department's vehicle washing operations. D. Materials/Supplies acquisition, storage and usage: The wash soap to be used is a non-phosphate, biodegradable detergent. E. Wash bay design and waste disposal: Wash water from vehicle and equipment washing must be disposed in the MSD sanitary sewer, with pretreatment using a sediment/oil trap. The accumulated solids in the sediment/oil trap must be pumped out and properly disposed of, such as at a wastewater treatment plant by an MSD approved waste hauler. If floating oils and grease accumulate in the sediment/oil trap, the contents must be disposed by a permitted waste hauler at a commercial facility able to handle oily waste. F. Best Management Practices (BMPs): OFF-SITE WASHING • All vehicles are taken to a commercial facility (Gas House Car Wash) when washing is needed. • Commercial facilities used are to be in compliance with MSD sewer discharge requirements. Facilities must discharge wastewater to the sanitary sewer system, and wash bays must be covered to prevent storm water in the sanitary system. Page 18 of 56 MUNICIPAL WASHING • Wash bay facilities are designed to collect wash water, pretreat with a sediment/oil trap (interceptor), and discharge to the sanitary sewer system. The trap must be pumped quarterly, or as needed. • Job-site mud removal is performed without detergent in a contained, permeable (gravel) area with wash water infiltrating into soil or gravel. H. Training: Employees responsible for operating fleet vehicles and equipment will be made aware of BMPs regarding washing, and the proper, designated locations for washing. Page 19 of 56 Chapter 5 - Facility Repair, Remodeling and Construction A. Description of Activities: On an as-needed basis, city personnel perform minor renovations/repairs and small capital improvements on city facilities, such as erecting or removing partitions, replacing a door or window, painting, etc. Major projects are typically contracted out to commercial firms specializing in the type of work required. B. Locations: The Public Works Facility contains a shop and material storage areas for facility repair, remodeling and construction; and city employees are involved in these activities. Repair, remodeling, construction and capital improvements are periodically performed on all types of municipal facilities. C. Responsible Parties: The Building Inspector is the responsible party that will ensure all repairs, remodeling and construction will be performed without subjecting the storm water system to any new contaminant streams. They are responsible for the construction practices of the contractors that work for them on municipal facilities. D. Materials/Supplies acquisition, storage and usage: This varies with the nature of the job. Materials are purchased on an as-needed basis and in quantities expected to be completely consumed in the process of completing the project. Materials used for every project will vary. The majority of the materials are purchased on a project basis and are consumed during that project. Materials should be stored indoors or under cover so they are protected from rainfall and runoff. All unused portions of materials should be properly secured to prevent loss, such as bagged cement. Tarps should be used on the ground to collect fallen debris and other spilled material. Waste should be cleaned up on a daily basis and properly disposed of as noted below in section "E". Routinely stocked materials are identified in the following table. Material Maximum Quantity Kept Onsite Storage Location Limestone Rock 30 tons Public Works/9810 S. 40 Drive Oil-Based Paint 10 gallons Building C Latex Paint 100 gallons Building C E. Waste generation, storage, disposal, recycling: Waste generation varies with the nature of the job. Typically, wastes consist of small amounts of lumber cut-offs, wallboard scraps, empty paint cans, etc. Order and mix only the amount of Page 20 of 56 materials necessary for the work to be completed. Dispose of all waste properly, recycle whenever possible. Never bury waste material or leave material in the street, gutter, or near a creek or streambed that would allow the material to enter the storm water system. Such materials are disposed in the city hall dumpster for pick-up by the city contracted waste hauler. Listed below are the disposal methods for various types of materials that are generated from facility repairs and remodeling: Waste Storage Requirements Method Of Disposal Contractor Latexpaint waste closed containers in Building C powder until hard waste hauler Oil based paint waste closed containers in hazardous waste hazardous waste vendor Building C (Superior) Lead-based paint removal waste closed containers in hazardous waste hazardous waste vendor Building C (Superior) General trash dumpster or container sanitary landfill waste hauler Steel, Iron, Copper Scrap metal bin recycle metal recycler Leaks, drips, or spills should be cleaned up immediately. Clean up using '`dry" methods, absorbent materials or rags, or remove the contaminated soil or material. Clean up of equipment is to be performed in designated areas. Never clean up concrete equipment or paint brushes and allow the washout into the street, storm drains, drainage ditches, or streams. F. Best Management Practices (BMP): FACILITY DESIGN • Consider designing facilities for "Low Impact Development" to reduce the volume and rate of stormwater runoff from impervious areas to improve water quality. Refer to information on Low Impact Development from EPA's web site at: https://www.epa.gov/nps/urban- runoff-low-impact-development for more information about Low Impact Development methods. • In designing stormwater drainage facilities, use the following BMPs, in accordance with MSD's stormwater drainage facility design regulations, to improve the water quality of site drainage: wet detention ponds, wetlands, structural filter systems, grass swales, vegetative filter strips, and riparian buffers along streams. MSD's design regulations are contained in the "Rules and Regulations and Engineering Design Requirements for Sanitary Sewage and Stormwater Drainage Facilities". Fact sheets on stormwater management practices are available from the Stormwater Manager's Resource Center at the following web site: https://www.sustainable.orq/environment/water/319-stormwater-managers-resource- center-smrc • Carefully design and install plumbing and stormwater systems to code, eliminating cross- connections between sanitary and storm drain systems. • Design material storage and handling areas to avoid rain and stormwater runoff contacting stored material. • Design landscaping that uses native vegetation to reduce the need for irrigation, fertilizer and pesticide. Page 21 of 56 LAND DISTURBANCE • Comply with municipal land disturbance ordinance and programs implemented under the St. Louis County Phase II Storm Water Management Plan. For projects less than the land disturbance program thresholds, prevent erosion of soil from bare ground at the site by employing erosion and sediment control BMPs, such as: soil stabilization with mulch or seeding, settling basins, sediment traps, vegetated buffer strips, and silt fencing for perimeter controls. For details concerning these BMPs, see the City of Ladue's Code of Ordinances link on the following web page: www.cityofladue-mo.gov. St. Louis County's website is also a resource: https://www.stlouisco.com/YourGovernment/PublicWorks/Permits/Land Disturbance • All construction or maintenance activities that excavate in or discharge any dredge or fill material into a "water of the United States" requires a Corps of Engineers 404 permit and a MDNR 401 water quality certification. Waters of the United States include ditches, creeks, rivers, lakes, ponds and wetlands. See Appendix 5-F1 for a summary of permit requirements. CONSTRUCTION/REMODELING • In accordance with city purchasing policies as stated in Chapter 1 and 2, every effort is made to purchase materials that are manufactured with recycled materials. • Properly store materials as far away from storm inlets and streams as practical, and cover stored materials to avoid stormwater impacts. • Recycle or properly dispose of wastes, as indicated in Section E above. • Never clean out or wash out paint or concrete mixers in the street or near a gutter, storm drain or stream. • Small quantities of inert demolition wastes and construction scraps are disposed in the city hall dumpster. If larger quantities are generated, arrangements are made with a city- contracted hauler for a special pick-up. • Keep work sites clean, pick up trash that can be windblown daily. • Utilize certified asbestos inspectors to inspect floor tile, ceiling tile, fire-proof barriers and doors, roofing material and insulating materials for asbestos content prior to demolition. Manage material using certified asbestos personnel. • Utilize certified inspectors to inspect for lead based paint on structures older than 1978. Use only state certified removal contractors for lead based paint abatement. • When scraping or washing to remove non-lead based paint, collect paint chips in a tarp for proper disposal. Use water-based paint instead of oil-based paint whenever possible. • Ensure that facility plumbing connects all sanitary wastewater discharges to the sanitary sewer, and that stormwater is sent to the storm sewer system. G. NPDES Permit status: Land disturbance projects over 1 acre require a Land Disturbance Permit MO-R100A (if regulated under a Phase II compliant land disturbance program) or Permit MO-R101 from the MDNR. Stormwater operating permits will not apply unless process water will be discharged to stormwater and not to the sanitary sewers. H. Training: Page 22 of 56 All employees involved in facility construction, facility repair and remodeling activities will be trained on the BMPs presented in this chapter. Personnel should be trained in the items noted below: General housekeeping Material storage, cleanup, and disposal Material reuse and recycling Equipment cleanup Land disturbance erosion control Reduction of material for disposal through storage, reuse, or recycling can greatly reduce material and disposal costs, long term liability, preserve environmental quality, improve workplace safety and provide a positive public image. Page 23 of 56 Chapter 6 - Cleaning and Maintenance of Roadways, Highways, Bridges and Parking Facilities A. Description of Activities: Most highway agencies and municipalities are responsible for the cleaning and maintenance of roadways, highways, and parking facilities under their maintenance purview. Activities include, but may not be limited to, street sweeping, flushing, applying surface seals, patching, snow removal, and emergency response to spills and accidents. Street sweeping operations normally involve self-contained and powered collection devices, utilizing belt conveyors or vacuum systems. This work may be performed on a scheduled basis, or when requested, and is usually conducted on roads with curbs where debris can accumulate in the gutter line. Many agencies flush bridge decks and parking structures in the spring to remove de-icing chemicals and to clean the drainage structures. Also, flushing operations are performed on sections of pavement where mud or debris accumulates after flooding, creating hazardous conditions. Bridge decks and parking structures are normally sealed on a five-to-seven year cycle to protect the concrete and steel reinforcement from corrosive elements. Patching operations involve the preparation of potholes and the fill of either hot mix or cold patching material. Highway agencies plow and salt the roadways under their maintenance jurisdiction during winter snow events. Typically, 200 to 400 pounds of salt per lane mile is used to de-ice the pavement. Other chemicals, such as calcium chloride, are used when prevailing temperatures fall below 20° Fahrenheit. Most highway agencies are required to respond to emergency situations involving spills and debris from vehicles. This work is performed if it is determined that the material which will be removed from the public road right-of-way is of a non-hazardous nature. Hazardous material is handled through hazardous material removal procedures not specified in this chapter. B. Locations: All City accepted public roads, bridges and public parking lots. C. Responsible Parties: The responsible parties involved in the cleaning and maintenance of streets and parking lots include: • Public Works Director (Anne Lamitola) — (314) 993-5665 Page 24 of 56 • Public Works Superintendent (Scot Bollinger) - (314) 993-5665 D. Materials/Supplies Acquisition, Storage and Usage: Large quantities of materials are expended in the performance of work. Some material is purchased and used immediately, while other material is stockpiled. Agencies working within the constraints of their budget weigh fiscal responsibility against the immediate and long- range needs for such materials, and adjust their purchasing habits accordingly. Material Maximum Quantity Kept On Hand For Use Within Storage Location Sodium Chloride 1,200 tons 6 months salt dome Calcium Chloride 1,300 gallons 6 months storage tank Aggregate (various sizes) 60 tons 6 months storage bins Cold-Patching Material 5 tons 6 months Building B Concrete Bag Mix 50 bags 6 months Building B E. Waste Generation, Storage, Disposal, Recycling: A certain amount of construction spoil and waste is generated during the performance of maintenance operations on our road network. Recycling methods are employed if they are determined to be cost-effective; however, in many instances, waste material must be removed from the work site by various disposal methods. Waste Maximum Storage Storage Method Of Frequency Capacity Location Disposal Concrete &Asphalt Rubble 3 truck loads Mulch site landfill monthly Trash, Grit and Debris from Street 3 truck loads Mulch site landfill monthly Sweeping and Road Clean Up F. Best Management Practices (BMP): k 4 f W MAINTENANCE • If certain road maintenance activities are ""` ' °i-- i' ', prone to produce pollutants that can be 4-' . ) n . carried off with stormwater runoff, - ` --� ., _ � � . schedule these maintenance activities = — �� � _ _ •_- ''l during times of dry weather if possible. ,,;r.. • Capture scrapings/rust/dirt/sandblasting 1 ,..104'-~ grit/over spray/drips, etc., from. ' Page 25 of 56 preparation and painting of bridges/structures/traffic control devices. • For steel girders on bridges, utilize certified inspectors to inspect for lead based paint on structures older than 1978. Use only state certified removal contractors for lead based paint abatement. • Used asphalt is recycled when it is cost-beneficial. • Block scuppers and drains when sealing bridge decks. • On asphalt overlays, ensure stormwater drainage capacity of curbs and inlets is maintained by milling down into the street at the curb, or using open graded thin bonded overlay. • Comply with municipal land disturbance ordinances and programs implemented under the St. Louis County Phase II Stormwater Management Plan. For projects less than the land disturbance program thresholds, employ BMPs for erosion and sediment control. • All construction or maintenance activities that excavate in or discharge any dredge or fill material into a "water of the United States", which includes ditches, creeks, rivers, lakes, ponds and wetlands, requires a Corps of Engineers 404 permit and a MDNR 401 water quality certification. Examples of construction or repair activities requiring a permit include: bridge work, culverts under road crossings, dredging or placing rip rap in creeks. See Appendix 5-F1 for a summary of permit requirements. DE-ICING • Use calibrated chemical applicators for salt and brine applications. �° G'"',��a,- it 4 • Minimize the use of salt without compromising public - safety. a — *. • Stop salt feed on trucks at stop signs, where equipped. p •• ' t+ • Stored salt is on an impervious surface and is covered. - • As available, use road weather information such as ' p . weather forecasts, meteorological data, and � : pavement sensors to maximize the efficiency and effectiveness of resources. CLEANING • Remove as much mud, grit, salt and debris : t. as possible (by scraping, brooming, etc.) prior fi to roadway flushing on bridges. • Evaluate the need for street sweeping to remove grit and trash at facility parking lots and roadways within jurisdiction. Implement -, n f , street sweeping, when feasible, focusing on heavy traffic patterns, seasonal variations (spring/fall), and problem areas. Record the volume of trash/debris removed to identify the priority of areas being cleaned and the effectiveness of resources used. Investigate to determine sources of litter in areas of excessive accumulation. • The environmentally preferred sweepers are those with an integral collection device and fugitive dust control. Properly dispose of trash/debris as indicated in Section E above. Page 26 of 56 • Do not hose down parking lots in a manner that discharges wash water to the storm drain untreated. G. NPDES Permit status: Not Applicable H. Training: (EXAMPLE TEXT) Employees involved in Street and Highway maintenance and repair will be trained on the BMPs in this chapter. Page 27 of 56 Chapter 7 - Maintenance of Parks, Green Spaces, Trails and Landscaping A. Description of Activities: The City of Ladue has responsibility for the maintenance of a limited amount of green space within the City, which includes one small park and the lawn areas within the City Hall complex. In addition, the City maintains the turf areas at several interstate highway interchanges within the community even though these are within the jurisdiction of the Missouri Department of Transportation. The City also maintains the portion of Centennial Trail within the City of Ladue. Maintenance activities include mowing of grassy areas, pruning trees, removing fallen limbs, mulching, emptying trash receptacles, trail maintenance, parking lot maintenance, and general landscaping. The creation and design of parks and open space can assist in management of stormwater by providing green infrastructure and a means of absorbing rainwater, slowing its release in to streams, storing, filtering and slowing stormwater runoff down and thus preventing or reducing flash flooding downstream. Local governments have an opportunity to use their park lands to benefit the environment and to demonstrate best practices for stormwater management. B. Locations: Rodes Park is located near the intersection of Clayton and Warson Roads. City Hall is located at 9345 Clayton Road. Potential Future Location for Park Space: 9810 S. 40 Drive Green spaces are interlaced throughout the community and are maintained by the Parks Department and local volunteers. C. Responsible Parties: The Director of Public Works has authority over the City Hall greenspace and Rodes Park. MoDOT has authority over the interstate highway interchanges. Volunteers donate their time to assist in community beautification. D. Materials/Supplies acquisition, storage and usage: The following materials and quantities are typically kept on hand for landscaping and park maintenance operations. Material Maximum Quantity For Use Within Storage Location Comments Kept On Hand Mulch 20 ydA3 6 Months Material Storage Bins Fertilizer 1 pallet 1 year Garage Keep covered Herbicide 10 Gallons 6 Months Garage Page 28 of 56 Rock 50 Tons 1 Year i i E. Waste generation, storage, disposal, recycling: Wastes generated by landscaping and mowing operations are as follows. Waste Storage Location Method Of Disposal Contractor Frequency Leaves, Grass, brush 9810 S. 40 Drive Hauled off site Hansen Three times annually F. Best Management Practices (BMP): PARK DESIGN AND SITING • Creating undeveloped, natural open space and preserving established trees and other natural vegetation, particularly around natural drainage areas, such as creeks, is recommended. Tree buffers and tall grass filters around streams improve water quality, slow runoff and prevent erosion. A minimum buffer width of 50 feet is recommended. • Avoid site development and placing facilities in the flood pslin, . • y w, • Design park sites to preserve natural resources such as c - `- wetlands and existing natural draining areas, minimizing ? , .k,''',-.4‘... - \-, their loss and maintaining existing trees and a riparian :'- 4, .e.,.;, ri. corridor next to creeks to the degree possible. Minimize `" ' tir ` , , creek crossings, and place them only after consideration .-- — of the stream features to enable natural flow. -_ 1' , " 132,'_., • Design landscaping that uses native vegetation to ttf ,e reduce the need for irrigation, fertilizer and pesticide. ! '' ' Select plants appropriate for site conditions for sun, moisture, and soil type. • Utilize low impact development to minimize impervious surfaces, See Chapter 5. • In designing stormwater drainage facilities, use the following BMPs to improve the water quality of site drainage and slow the release of water to streams: wet detention ponds, micro detention basins, wetlands, rain gardens, vegetative filter strips and riparian buffers along streams, structural filter systems, pervious pavement and green (vegetated) roofs. The use of swales instead of curbs along roads and parking lots is beneficial to filter pollutants and reduce the volume and rate of stormwater flow. Fact Sheets on stormwater management practices are available from the Stormwc` - ! r. - r' ~~'~- ~a the following web site: https://www.sustainable.orq/env ;4 : , . manaqers-resource-center-smrc b� 4 2/44 Dog Rest Stop ' COMMUNITY PROGRAMS :k`° • • Sponsor activities and annual events that involve the g , c•c.. i,,,, ,,,�anJ , , . groups, stream teams, etc., providing hands-on activiti,. ( 2 oc.up cKey Yalu adopted parks and greenways. Typical activities incluc 1lttcnrbdy um...7+,,i<.0M. programs, restoration projects, stream monitoring, stor ,i Urgtox b..g�n , Page 29 of 56 ":��"'° p` i • Organize or participate in reforestation programs, planting native trees to buffer streams, create shade, and beautify parks. Support community volunteer group efforts in these programs. • Require pet owners to pick up and properly dispose of pet waste in parks. Provide pet waste scoop dispensers and signage in parks to notify visitors of the requirement. PARK/LANDSCAPE MAINTENANCE • Remove litter and debris regularly. • Properly dispose of yard waste, for example, by composting. Do not dump yard waste into creeks. • Minimize mowing of open space sites, depending on site objectives. • Mow grass higher and leave grass clippings on the lawn to retain moisture and provide nutrients. • Remove exotic invasive vegetation and replace with native plantings as resources are available. • Perform soil tests to determine the optimum fertilizer application rate. • • Apply fertilizer only in cool weather, preferably fall Avoid application before a rain, and do not apply ' fertilizer at rates higher than indicated in on label instructions. Apply slow release fertilizers such as methylene urea, IDBU or resin coated fertilizer. • When disturbing land, such as clearing vegetation and destroying the root zone, employ BMPs for erosion and sediment control. For details concerning these BMPs, see the SWPPP link on the following web page: https://www.stlouisco.com/YourGovernment/PublicWorks/Permits/Land Disturbance • All construction or maintenance activities that excavate in or discharge any dredge or fill material into a "water of the United States", which includes ditches, creeks, rivers, lakes, ponds and wetlands, requires a Corps of Engineers 404 permit and a MDNR 401 water quality certification. Examples of activities that require a permit include: placing culverts in creeks, constructing outfalls, and stream restoration activities. See Appendix 5-F1 for a summary of permit requirements. INTEGRATED PEST MANAGEMENT • Use Integrated Pest Management (IPM) techniques to minimize the use of pesticides. Pesticide application should be timed carefully and combined with other pest management practices. Pests and their development stage should be identified accurately and pesticide applications made only when necessary, using the least amount needed and the least toxic product for adequate pest control. • Use mechanical controls to keep pests in check, such as species specific, pheromone based traps. Remove pests by hand. Eliminate conditions favorable to pests and place barriers to control pests and weeds. • Use natural, biological controls, when feasible, including natural enemies of pests, such as: predators, parasites, pathogens, pheromones, and juvenile hormones. Reduce the risk of West Nile Virus by reducing stagnant water (mosquito breeding grounds) caused by cans, containers and tires present in litter and junk piles. Keeping stormwater drainage gutters and drains clean will also reduce conditions suitable for mosquito breeding. Refer to MU Extension IPM Guides at: https://ipm.missouri.edu/pubs/ Page 30 of 56 Minimize the use of herbicides through an Integrated Pest Management techniques for weed control. This includes practices that keep plants healthy, such as selecting disease and pest resistant varieties and maintaining good growing conditions. For turf grass, prevention of weed infestation begins with practices to promote healthy grass through proper planting, watering, fertilizing, mowing, aerification, and thatch control. Refer to MU Extension Publication IPM1009: https://extension2.missouri.edu/MX399 PESTICIDE/HERBICIDE USE • When pesticide or herbicide use is required, select pesticides carefully, avoiding highly water soluble and very environmentally stable products to minimize potential for leaching from soils into waterways. Environmentally friendly products readily degrade in the environment and/or bind to soil particles. • Consider the vulnerability of the area in which pesticides are applied, avoiding areas with streams, ponds, sinkholes or wells. Sinkholes are an environmentally sensitive area because they allow surface water to reach groundwater quickly with little natural soil filtering. • Apply pesticides when the target pest is at its most vulnerable life stage, and use site specific rather than wholesale application. Page 31 of 56 • Read pesticide labels carefully for information and restrictions about the rate, timing, and placement of the pesticide in that container. Calibrate equipment to apply at the proper rate. Apply when the threat of rain is low to avoid wasting material and washing pesticide into the waterways. Carefully calculate how much pesticide concentrate is needed to treat the specific site with the equipment being used, to eliminate disposal of excess spray mix. • Store pesticides in their original containers in a cool, well-ventilated building with a concrete floor. Handle pesticides carefully to avoid spills. • Dispose of pesticide waste properly, following label instructions. G. NPDES Permit status: Not applicable H. Training: All employees directly involved in the design, construction and maintenance of landscaping, trails, green spaces and parks will be trained on the BMPs in this chapter. Page 32 of 56 Chapter 8 - Cleaning and Maintenance of Drainage Channels, Storm Sewers and Inlet Structures A. Description of Activities: The storm drainage system functions to collect and convey surface runoff to receiving waters during storms in order to prevent flooding. The system consists of improved and unimproved drainage channels, culverts, bridges, trench drains, gutters, ditches, swales, storm sewers and storm inlet structures. Maintenance of the system is necessary to ensure it functions hydraulically as intended. MSD has the major responsibility for the cleaning and maintenance of improved channels and storm sewers in the Plan Area. Maintenance responsibilities are defined in MSD's "Statement of Policy for Maintenance of Stormwater Sewer Systems and Facilities". Many of the co-permittees are responsible for maintaining the storm sewer systems on their property, and on systems not dedicated to the MSD system. In addition, municipalities are responsible for maintaining bridges, storm culverts, ditches and gutters along the streets in their city. MSD does maintain road inlets and culverts on systems dedicated to MSD. MSD does not maintain detention and retention basins or yard swales. Maintenance of basins and yard swales is the responsibility of property owners, as addressed in MSD's "Rules and Regulations and Engineering Design Requirements for Sanitary Sewage and Stormwater Drainage Facilities". B. Locations: The separate storm system within the City of Ladue is maintained by MSD. All structures are identified on MSD facility base maps. The inlets on the storm system are not constructed with traps to capture oil, grease or debris. C. Responsible Parties: • Metropolitan St. Louis Sewer District Director of Operations: (314) 768-6260 / (314) 768-6200 • City of Ladue Public Works Department: (314) 993-5665 D. Equipment/Materials/Supplies acquisition, storage and usage: The City of Ladue Public Works Department has a back hoe and skid loader for maintenance in road culverts. MSD and contractors are used for channel clearing and brush blockages. E. Waste generation, storage, disposal, recycling: Wastes generated from maintenance of the storm drainage system must be disposed of properly, as indicated in the table. All waste being disposed of in a landfill must not contain free liquid. Water draining from waste destined for a sanitary landfill is considered wastewater and must be disposed of in a sanitary sewer system. Page 33 of 56 Storage Method Of Waste Contractor Requirements Disposal Catch Basin Grit& Trash dewater and place in sanitary landfill Waste Management Contractor— dumpster Waste Connections Trash and Debris from dewater and place in sanitary landfill Waste Management Contractor— Channel Cleaning dumpster Waste Connections Wastewater sanitary sewer sanitary sewer MSD Yard Waste and Trees from designated drop area Yard waste City of Ladue — 9810 S. 40 Drive Channel Cleaning transfer facility F. Best Management Practices (BMP): GENERAL • Within budgetary constraints and responsibilities, perform preventative maintenance of the storm drainage system to remove flow obstructions to reduce flooding and erosion problems and improve water quality. • Utilize care in cleaning catch basins, storm sewers and drainage channels, to properly collect and dispose of waste as indicated in Section E to minimize contaminants discharged into stormwater. Note in the work order the volume of waste collected and disposed of. Investigate into the source of increased maintenance needs, if excessive. When possible, focus cleaning efforts before rainy seasons. • If storm inlets/catch basins, storm sewers and drainage channels are impacted by non- stormwater discharges or illegal dumping of waste, contact MSD, Division of Environmental Compliance at 314-436-8710 for investigation and enforcement. • Implement Phase II public education efforts; public participation efforts to mark inlets with "No Dumping, Drains to Stream"; or organize public stream clean-up events. • Identify failing detention or retention basins and report them to MSD Customer Service at 314-768-6260. • Comply with St. Louis County or municipal land disturbance ordinances and programs implemented under the St. Louis County Phase II Stormwater Management Plan. For projects less than the land disturbance program thresholds, employ BMPs for erosion and sediment control. CATCH BASINS • Prioritize catch basins for routine maintenance on a F.: specified frequency based on need. Identify areas for additional maintenance to coincide with litter ' ; *. k I .�4; from major public events, and based on work orders .��:,=� . generated by customer complaints and/or flooding. r . ' • �.. Increase maintenance of inlets that are fully blocked hY � r f or 75% full of trash or debris when maintained. Reduce maintenance of catch basins that do not - • result in waste generation. -, ti'"„'1. f# • Consider installation of catch basin inlets in areas ffi .:. ; ' '/' `• where storm sewers will be known to receive excessive amounts of litter or sediment. STORM SEWERS Page 34 of 56 • Prioritize storm sewers for routine maintenance on a specified frequency based on flat grades, low flow, or review of work orders. Identify areas for additional maintenance based on work orders generated by customer complaints and/or flooding. • Utilize care in cleaning storm sewers by flushing, to properly collect waste using debris/sediment traps. • Seal/repair joints in structures to prevent root intrusion and soil wash-out. • Minimize or avoid the use of chemical root/vegetation killers, and use the least toxic alternatives when necessary. DRAINAGE CHANNELS • All construction or maintenance activities that excavate in or discharge any dredge or fill material into a "water of the United States", which includes ditches, creeks, rivers, lakes, ponds, and wetlands, requires a Corps of Engineers 404 permit and a MDNR 401 water quality certification. Examples of construction or repair activities requiring a permit include: sewer creek crossings, outfall structures, stream bank stabilization, and all channel modifications. See Appendix 5-F1 for a summary of permit requirements. • Consider downstream conditions prior to spot channel stabilization efforts to avoid simply moving problems downstream. Revegetate stabilized areas with native plants whenever possible, and as soon as possible. • MSD's Division of Environmental Compliance will inspect all open drainage channels under its Illicit Discharge Detection Program, and will notify MSD's Operations Department, St. Louis County, the municipality or MoDOT, as applicable, regarding maintenance needs concerning damaged structures or blockages requiring removal. MUNICIPAL DETENTION BASINS • Existing control structures undergoing renovation are modified to the maximum extent practicable to meet new construction criteria in MSD's "Rules and Regulations and Engineering Design Requirements for Sanitary Sewage and Stormwater Drainage Facilities". • Inspect facilities to insure proper operation and maintain as needed, including: trash and debris removal, vegetation control, vector control, structural and erosion repair, and sediment removal to restore capacity. G. NPDES Permit status: Not applicable H. Training: MSD collection system operators, contractors and municipal employees involved in maintenance of drainage systems will be trained on the BMPs in this chapter. Page 35 of 56 Chapter 9 - Operation and Maintenance of Yard Waste Facility A. Description of Activities: The City has scheduled curbside pickup of leaves and brush. These materials are transported to a City owned property located at 9810 S. Forty Drive where they are then stock-piled for a short period of time. The 9810 S. Forty Drive property is permitted separately by the Missouri Department of Natural Resources and has a Storm Water Pollution Prevention Plan. B. Locations: The City's mulch site operation is located at 9810 S. Forty Drive. The site is paved for the general public use of the site. C. Responsible Parties The Public Works Director has authority over the facility. The facility staffed with Public Works employees on a temporary basis when needed. • Director of Public Works (Anne Lamitola), Telephone: (314) 993-5665 • Attendant (Craig Schwalbert), Telephone: (314) 993-5665 D. Materials/Supplies acquisition, storage and usage: The following materials and quantities are typically stored onsite: Recyclable Maximum Quantity Stored Storage Location Contractor Handling Shipment Method Frequency Leaves, Brush 30,000 cubic yards Yard waste facility City backhoe weekly Aggregate 50 tons Yard waste facility City backhoe monthly Mulch 20 cubic yards Yard waste facility City Backhoe monthly E. Waste generation, storage, disposal, recycling: No dumping or disposal of trash is allowed on the site. F. Best Management Practices (BMP): Page 36 of 56 • Yard waste operations and material piles should be located away from storm water drainage systems, and must not be located within 100 feet of a natural creek or man- made storm water drainage channel, 300 feet from a water well or 1,000 feet from a sinkhole, under MDNR permit G97. • Yard waste is confined by an impervious base with curbing or otherwise stored to prevent leachate and runoff from contaminating storm water, and to prevent storm water drainage running into the pile. • Do not discharge leachate to storm water. As necessary to manage leachate, design a system to collect and properly treat leachate or incorporate into the early stages of the composting process. • Materials that will pollute storm water are collected under a roofed structure or in an enclosed dumpster. • The public is notified on the City's website of materials accepted at the facility and those unauthorized items that are not acceptable. • The facility is gated to ensure unauthorized items are not deposited by the public. • The Police Department routinely patrols the facility to prevent unauthorized use of the facility. • No fluids are drained into any storm water system. • Every effort is made to ensure the facility is clean and that no unauthorized or contaminated materials are deposited at the facility. • Materials easily moved by wind must be stored in a manner to prevent the material from becoming airborne and scattered. • A phone is available at the site for attendants to promptly report any problems to the supervisors or the Police. G. NPDES Permit status: Facilities involved in the recycling or composting of materials are considered "municipal industrial" facilities under Missouri Storm Water Regulations and are subject to separate NPDES Storm Water (Phase I) permitting requirements, unless they are collection points only and completely protected from storm water (run-on and run-off). Potentially applicable MDNR NPDES General Permits include: R8OH for Recycling facilities and G97 for Yard Waste Compost sites. H. Training: All City employees conducting leaf and brush pick up using the mulch site operation will undergo initial City-provided training upon employment. All employees are regularly instructed on the use of equipment and handling of problem situations. Page 37 of 56 Chapter 10 - Water Quality Impact Assessment of Flood Management Projects A. Description of Activities: New flood management projects located within the co-permittees jurisdiction must be assessed for impacts on water quality. Existing projects must be assessed for incorporation of additional water quality protection devices or practices, where feasible. Flood management projects in the Plan Area can include: regional stormwater control (retention basins, detention basins); flood control levees and associated pump stations; stormwater drainage conveyance capacity improvements; projects involving land buyouts; and designated uses of flood plain land. Stormwater management projects in both development and re-development will be assessed for water quality impact, according to MSD's "Rules and Regulations and Engineering Design Requirements for Stormwater Drainage Facilities", which address the Stormwater Management Plan water quality requirements under MCM 5. Projects within designated levee districts, such as Monarch-Chesterfield, Earth City and Riverport will be based on the Stormwater Master Plan for these districts. All flood management projects involving channel modification will also be assessed for aquatic and water quality impacts through the Corps of Engineers 404 permit and MDNR 401 water quality certification process. B. Locations: Existing projects located within the Plan Area include those in the City of Ladue's Storm Water Management Implementation Plan: C. Responsible Parties: All co-permittees that plan, design or install flood management projects are subject to this chapter. MSD has general responsibility for stormwater drainage facilities in the Plan Area. St. Louis County, municipalities, and property owners have responsibility for the drainage facilities not dedicated to, and maintained by MSD. St. Louis County and municipalities maintain control over planning and zoning, land use regulations, and flood plain management through ordinances. D. Materials/Supplies acquisition, storage and usage: Not applicable. For construction phase of work, land disturbance requirements will apply. See Chapter 2 and 8 for construction and maintenance. E. Waste generation, storage, disposal, recycling: Not applicable. See Chapter 2 and 8 for maintenance. F. Best Management Practices (BMP): Page 38 of 56 • Implement and enforce ordinances and/or procedures requiring that water quality factors be incorporated into the design and operation of stormwater/flood control structures. • Inspect existing flood management facilities on a specified frequency to determine water quality impacts and exploit opportunities for improvement. • Existing control structures undergoing renovation are modified to the maximum extent practicable to meet new construction criteria in MSD's "Rules and Regulations and Engineering Design Requirements for Sanitary Sewage and Stormwater Drainage Facilities". • Design new flood management projects to prevent or minimize adverse water quality impacts, exploring alternative programs utilizing non-structural flood damage reduction and stream bank stabilization measures to the maximum extent practicable, such as flood proofing houses, and buy outs. • Use models based on fully developed conditions, and adopt a free board above base flood elevation for development. • Identify existing wetlands or other natural open space areas, particularly around streams, and preserve them from development so they can provide natural attenuation, retention or detention of runoff. • Survey watersheds downstream from proposed projects to determine potential water quality impacts. Design proposed projects to minimize downstream impact. • Work closely with local governments, environmental organizations and others to develop multi-use open space corridors along streams which will allow for overbank floodplain storage. • Floodplains are preserved to the maximum extent practicable. • Use non-structural flood management practices to the maximum extent practicable, utilizing acquisition of flood-prone property where possible. • Open stormwater conveyance systems are used to the maximum extent practicable to preserve natural conditions and habitat. • Channel improvement projects are to use natural approaches rather than concrete, riprap or other "hard" techniques to the maximum extent practicable. • Inlets and outlets from closed portions of conveyance systems are designed to minimize scour and erosion. • Trash racks are provided at outlet structures of detention ponds and other flood control structures to capture trash and floatables. • Employ natural solutions and use controls that preserve the hydrology of a site as a first line of flood control to the maximum extent practicable. G. NPDES Permit status: Not applicable H. Training: (EXAMPLE TEXT) Employees and contractors responsible for the planning and design of the flood management projects identified in Section A will be trained on the BMPs in this chapter. In addition, employees performing this work will be familiar with MSD's rules and regulations and engineering design requirements for stormwater drainage facilities. Page 39 of 56 Appendix 2-Fl : The City of Ladue Waste Reduction and Recycling Policy Statement 1. Policy The City of Ladue is committed to good stewardship of the environment. A key element of that stewardship is the reduction of the amount of solid waste going from the city into landfills. Solid waste landfills have negative long-range environmental impacts, drain community resources, and have limited capacity to accept the large quantities of waste generated by our society today. The City of Ladue will make every effort to reduce the solid waste generated at our facilities. Four methods will be used to implement this policy: source reduction, reuse of materials, recycling, and purchase of recycled materials. Every City department and individual employee has a personal responsibility for implementing this policy. 2. Methods to Achieve Solid Waste Reduction A. Source Reduction: All members of the City staff are responsible for implementing operational practices that prevent waste from being produced. Examples include printing reports and documents on both sides of the paper; printing appropriate numbers of documents; using email rather than printed correspondence; and using products that are reusable, refillable, repairable, non-toxic, and recyclable. Products with reusable, returnable packaging or items requiring the least possible packaging should be purchased when practical. Every effort should be made to prevent excess or unneeded materials from being purchased. B. Reuse of Materials: All employees of the City are responsible for reusing products whenever possible. An example would be to use dishes, glasses, and reusable flatware rather than disposable paper and plastic ware. C. Recycling: All City employees are responsible for separating identified recyclable materials and placing them in appropriate recycling containers. City Recycling includes aluminum cans, steel cans, batteries, cardboard, glass bottles and jars, hard back books, newspapers, phone books, catalogs and magazines, brown paper bags, microfiche, news blend, office blend, plastic bottles (#1 and #2 only), styrofoam and peanuts, toner cartridges, transparencies, videotapes, and additional items as implemented. Facilities Management Recycling includes construction/demolition debris, fluorescent light bulbs, motor oil, oil filters, paint, pallets, refrigerants, scrap metal, solvents, tires, yard waste, and additional items as implemented. D. Purchase of Recycled Content Material: All City departments are responsible for making efforts to purchase and use products manufactured from or containing recycled materials. All recycled content purchases will be reported to the Purchasing Department for record-keeping and reporting purposes. Page 40 of 56 3. Procedures The Director of Public Works will be responsible for implementing this Policy by: A. Designating departments and employees responsible for the task of developing and implementing a waste reduction and recycling program in accordance with this Policy. B. Designating personnel in the Purchasing Department to ensure recycled content products are purchased when feasible and that criteria for recycled content products are included in the purchasing bid process. C. Designating personnel in Facilities Management to ensure that all new construction includes designated areas for recycling and solid waste collection and removal. D. Designating personnel to promote recycling and waste reduction in employee events and materials. E. Encouraging all contractors to adhere to City recycling policies and procedures. F. Taking other appropriate action as he/she deems necessary to implement this Policy. Source: https://legal.uncc.edu/policies/up-713 Page 41 of 56 Appendix 2-F2: The City of Ladue Green Procurement Policy 1. Policy Objective The objective of this policy is to provide direction for greening City of Ladue's procurement. 2. Policy Statement As set out in this Policy, priority in procurement will be given to green products and services, including construction. 3. Definitions Green procurement is the procurement of products and services that have a lesser or reduced effect on human health and the environment when compared with competing products or services that serve the same purpose. This comparison may consider raw material acquisition, production, manufacturing, packaging, distribution, operation, maintenance, disposal and re-use of the product or service. Green procurement encompasses the concept of the procurement of goods and services that provide for basic human needs and bring a better quality of life, while minimizing the use of non-renewable natural resources and toxic materials and the emission of wastes and pollutants over the life cycle, so as not to jeopardize the ability of future generations to meet their own needs. A green product is one that is less harmful than the alternative, having characteristics including, but not limited to, the following: • Recyclable - local facilities exist that are capable of recycling the product at the end of its useful life. • Biodegradable - will not take a long time to decompose in landfill. • Contain recycled material (post-consumer recycled content). • Minimal packaging and/or for which there will be take-back by the manufacturer/supplier of packaging. • Reusable or contain reusable parts. • Minimal content and use of toxic substances in production. • Produce fewer and/or less polluting by-products during manufacture, distribution, use and/or disposal. • Produce the minimal amount of toxic substances during use or at disposal. • Make efficient use of resources - a product that uses energy, fuel or water more efficiently or that uses less paper, ink or other resources. • Durable - have a long economically useful life and/or can be economically repaired or upgraded. Sustainable (preen) service - A service acquired from a supplier who has a green operational policy and whose internal practices promote sustainability. Page 42 of 56 Threshold - the dollar value of contracts, above which a formal record is kept on file showing that environmental criteria were considered when requirements were defined. 4. Policy Procedures Where available and cost effective, green products and services, including construction, that are of equal or better performance and quality, will be purchased. In determining cost effectiveness, a department should give consideration to the costs and benefits that accrue, in the shorter and longer term, to the City of Ladue. For all bid solicitations (e.g. requests for proposal, requests for quote, and requests for standing), environmental factors or impact will be considered when requirements are defined. In addition, bid solicitations will include instructions asking bidders to identify any environmental benefits over the life cycle of their products and/or services. Green procurement principles will be applied to construction projects beginning with the design stage. Departments will determine the contract dollar value (hereafter referred to as the threshold) above which a formal record is kept on file showing that environmental criteria were considered when requirements were defined. In determining their threshold, departments may wish to consider contracting volumes, training requirements and budgetary constraints. For all procurement, consideration will be given to environmental factors or impact. For requirements: A. Valued in excess of a threshold, a formal record of the evaluation will be kept on file. In the case where a green purchase was made, the record will list the environmental criteria included in the bid solicitation. In the case where a green product or service was not acquired, the reasons for not selecting an environmentally preferable product or service will be documented. See Documentation Form attached. B. Valued at or below the threshold, a formal record of the evaluation is not required. Each department will be responsible for ensuring that its personnel have sufficient training about the environment and green procurement to carry out the directives in this policy. 5. Guidelines 5.1 The life cycle approach and the environment Applying the four R's (Reduce, Reuse, Recycle and Recover) at each phase of the material management life cycle helps protect the environment and reduce costs. 5.1.1 Planning During the planning process, managers will assess the need for a given purchase and, whenever possible, • Reduce consumption. Page 43 of 56 • Consider acquiring second-hand or used material. • Consider products that are less damaging to the environment, such as those made with resource-saving materials or processes. • Consider the environmental cost of purchases during each phase of the life cycle. 5.1.2 Acquisition As much as practical, products selected should: • Be reusable and contain reusable parts. • Be recyclable and contain recycled materials (e.g. recycled paper, reconditioned laser printer cartridges). • Include second-hand or used material. • Use resources and energy efficiently. • Have a long service life or be economical to repair. • Contain minimal packaging, or use returnable or reusable shipping containers. • Be non-toxic and non-polluting. 5.1 .3 Maintenance and Operations A. Ensure that products are properly maintained and used. This will extend the service life of a product. When economically feasible, equipment should be repaired, refinished and reused. B. Hazardous material must be shipped, stored and handled in accordance with applicable federal and provincial law, and regulations. 5.1.4 Disposal Consider alternatives to disposing of material, such as reusing, recycling or recovering it. Try to minimize the amount of waste generated. 5.2 Combine environmental actions with fiscal responsibility A. Government interest in economy of operations is fully compatible with environmental interests. Many sound environmental practices have resulted in savings. B. Most environmental actions can be phased in gradually without additional cost. When these actions may entail additional costs for the government, managers should accommodate them within existing budgets. C. Government should lead by example. In light of the volume of government procurement, the government can play a significant role in promoting the development and marketing of green products and services. As demand for these products and services increase their prices will drop and become more affordable to all consumers. Source: https://www.tpsgc-pwqsc.qc.ca/app-acq/ae-qp/index-enq.html Page 44 of 56 Appendix 2-F3: St. Louis County Waste Management Code St. Louis County Waste Management Code, Chapter 607, contains provisions related to the proper disposal of trash. The County Waste Management Code is effective in all portions of incorporated or unincorporated St. Louis County, except municipalities with populations of 75,000 and an organized health department. Municipalities are encouraged to enact ordinances that correspond to those portions of the Code included in this appendix. Waste Management Code, Chapter 607 SUBCHAPTER B. DUTIES IMPOSED IN CONNECTION WITH THE GENERATION AND STORAGE OF WASTE ON PREMISES 607.050 On Whom Duties Are Imposed for Storage of Waste. Section 607.050 through 607.145 describe conditions that shall exist, conditions that must not exist, actions that must be taken and actions that must not be taken, all in connection with the storage and disposal of waste upon the premises where the waste is generated. The persons responsible for seeing that the conditions and actions described in Sections 607.050 through 607.145 are complied with depends upon the type of premises involved, and are described as follows: 1 . On residential premises or premises with mixed uses but containing at least one residence, it shall be the responsibility of every person the age of seventeen (17) years or older residing on the premises to see that Sections 607.050 through 607.145 are satisfied with respect to the storage and disposal of residential waste generated on the premises, regardless of whether the noncompliance was occasioned by the action or failure to act of the person charged. 2.On nonresidential premises or premises with mixed uses but containing at least one nonresidential use, it shall be the responsibility of the person in possession of the premises as well as each manager, agent or employee of a person in possession of the premises to see that Sections 607.050 through 607.145 are satisfied with respect to the storage and disposal of nonresidential waste generated on the premises, regardless of whether the noncompliance was occasioned by the action or failure to act of the person charged. 3.On all premises, it shall be a violation of Sections 607.050 through 607.145 to do any act which would make the premises fail to comply with such sections, whether or not the person charged resides on the premises or is in possession of the premises or is the agent or employee of a person in possession of the premises. (O. No. 23221 , 5-29-07) 607.060 Waste Containers Required. There shall be provided on each premises where waste is generated, whether such premises are residential or nonresidential, containers for the storage of all municipal waste (except bulky waste), yard by-products, and recovered materials. The municipal waste containers shall conform to the requirements of Section 607.070 if for use on residential premises and shall conform to the requirements of Section 607.080 if for use on nonresidential premises. Containers for curbside collection of Recovered Materials and Yard By-products shall conform to the requirements of the Page 45 of 56 person providing collection services. The containers must be sufficient in quantity and size to hold all waste and recovered materials (except bulky waste and demolition and construction waste generated on the premises) between the times when the waste and the recovered materials are generated and removed from the containers and the premises. The premises surrounding the containers shall be maintained in a neat, clean, odor free and sanitary condition. (O. No. 23221, 5-29-07) 607.070 Waste Containers for Residential Waste Other Than From Multifamily Residences of Four or More Units--Use of Waste Containers required. Residential waste, other than residential waste from multifamily premises of four (4) or more units or from premises having mixed uses but containing at least one (1) residence, shall be deposited and stored in galvanized metal containers or rubber fiberglass or plastic containers which are nonabsorbent and do not become brittle in cold weather or in plastic containers or plastic bags of not less than twenty (20) gallons nor more than thirty-five (35) gallons in capacity unless container size is approved otherwise by the person that provides hauling services. Containers shall be leak-proof, waterproof, and fly-tight and shall be properly covered at all times except when depositing waste therein or removing waste therefrom. The container, other than plastic bags, shall have handles, bails or other suitable lifting devices or features. Containers shall be of a type originally manufactured for residential waste, with tapered sides for easy emptying. They shall be lightweight and of sturdy construction. Plastic bags used to contain waste shall be of sufficient strength to be used one (1) time to store the waste actually deposited therein. Waste generated on the premises shall be deposited in the containers and shall be deposited in such a manner that the area surrounding the containers and the exterior of any such containers is and remain clean, neat, odor free and sanitary. This section does not apply to demolition and construction waste. (O. No. 23221, 5-29-07) 607.080 Waste containers for Nonresidential Waste and Waste From Multifamily Residences of Four or More Units; Use of Waste Containers Required. Nonresidential waste and residential waste from multifamily residences of four (4) or more units, as well as residential waste from premises having mixed uses but containing at least one (1) residence. shall be stored in containers which are spill proof, leak-proof, and shall be covered at all times except when depositing waste therein or removing waste therefrom. Waste generated on the premises shall be deposited in the container(s) and shall be deposited in such a manner that the area surrounding the container(s) and the exterior of any such container(s) is and remains clean, neat, odor free, and sanitary. This section does not apply to demolition and construction waste. (O. No. 23221, 5-29-07) 607.100 Waste Not To Be Deposited in Waste Container of Another. Page 46 of 56 No person shall deposit waste in any waste container other than a waste container on the premises where the waste was generated without the consent of the owner of such waste container. (O. No. 23221, 5-29-07) 607.120 Placement of Waste Containers and Bulky No containerized Waste. 1.Residential waste and/or recovered material containers and bulky/non-containerized waste shall be stored upon the premises where the waste was generated, unless written permission for storage on other premises is obtained from a person having authority to grant such permission. The containers and bulky/non-containerized waste shall be stored at least three (3) feet behind the front of the main residential structure. Waste containers used for the storage of residential waste and bulky/non-containerized waste, other than waste from multifamily premises having four (4) or more units, shall be placed at the curb or mailbox or backyard or side yard as required by the person responsible for collection. Waste and recovered material containers and bulky/non-containerized waste shall be placed at the collection point if in front of the premises or on a street not earlier than dusk of the day prior to the regularly scheduled collection day. Waste and recovered material containers shall be returned to their appropriate storage places following collection and on the same day as collection. 2.Nonresidential waste and recovered material containers, bulk source separated material and bulky/non-containerized waste generated on nonresidential premises shall be stored upon the nonresidential premises where the waste or source separated material was generated, unless written permission for storage on other premises is obtained from a person having authority to grant such permission. (O. No. 23221, 5-29-07) 607.130 Demolition and Construction Waste. 1. No person shall store in or place additional demolition and construction waste in a mobile waste container which is full. 2.The person who has requested that a mobile waste container be located to receive demolition or construction waste or container be removed from a site shall require that a mobile waste container which is full be removed and the waste deposited at an appropriate facility. 3.Demolition and construction waste shall be stored in a secure container or otherwise secured to prevent dispersal by the wind. 4.Demolition and construction waste shall not be stored in a floodplain unless it is stored in a mobile waste container. 5.A mobile waste container is full if no more waste can be added to it without making it unsafe or illegal to transport. (O. No. 23221, 5-29-07) 607.140 Waste To Be Collected. If waste collection service is reasonably available for a premises where waste is generated, an agreement shall be in effect for the collection of waste generated on the premises with a Page 47 of 56 waste collection service having waste collection vehicles licensed by the Director for the collection, transportation, and disposal of waste. It shall be the responsibility of the property owner and the person generating the waste to assure that an agreement for the collection of waste is in effect. (O. No. 23221, 5-29-07) 607.145 Frequency of Pickup. Residential and Commercial Waste: Waste collection service shall provide for the collection of all solid municipal waste (other than demolition and construction waste and bulky residential waste) from the premises not less often than once per week. In the event no waste hauler serves the area, the Director has determined that collection service is not reasonably available, waste (other than demolition and construction waste and bulky residential waste) must be removed from the premises not less often than once per week, and deposited at a licensed sanitary landfill, waste processing facility or transfer station, unless exempted from the requirement of weekly pickup under the terms of Section 607.145. (O. No. 23221, 5-29-07) 607.270 Waste Spilled During Transportation. Waste spilled or blown during the transportation of waste shall be re-collected immediately if such re -collection may be made safely, and as soon as possible otherwise, and placed in the transportation vehicle or mobile waste container by the employees of the waste hauler, or by the person transporting the waste, whether or not such person is engaged in the business of hauling waste and whether or not the vehicle is licensed or required to be licensed under this Chapter. (O. No. 23221, 5-29-07) 607.280 Waste Spilled by Hauler During Collection. Waste spilled or blown during the movement of waste from the point of collection into the waste transportation vehicle shall be re-collected and placed in the transportation vehicle by the waste hauler whether or not the waste was placed by the generator in proper waste containers as required by this Chapter. Waste haulers are not obligated to collect waste that has not been placed in waste containers as required by this Chapter. (O. No. 23221, 5-29-07) SUBCHAPTER D. DISPOSAL OF WASTE 607.310 Waste Must be Deposited at a Licensed Landfill, Licensed Waste Processing Facility, Licensed Transfer Station, Licensed Compost Facility, or Licensed Yard By-Product Compost Facility Page 48 of 56 1. No person shall deposit waste on any real estate or permit waste to be deposited on any real estate for which there is no valid and current license, and, if appropriate, renewal license, for the operation of a landfill, waste processing facility, transfer station, compost facility, or yard by-product compost facility issued by the Director, nor shall any person deposit waste on or at any such landfill, waste processing facility, transfer station, compost facility, or yard by- product compost facility in a manner which does not comply with the waste facility plan or material facility plan approved by the Director and the license issued therefor by the Director, nor in a manner which does not comply with the provisions of this Chapter describing the manner or operation of the landfill, waste processing facility, transfer station, compost facility, or yard by-product compost facility. Exception: Yard by-products generated and handled as provided in Section 607.1005, Residential (backyard) by-product composting. 2.If the Director has a reasonable belief that waste burial or filling exists on any property not licensed to accept such waste, the Director may require in writing, the exploration and/or the test drilling or excavation of such area for such waste burial or filling. If waste filling or burial is evident, in violation of this section, the Director may require complete removal or other remedial work. Remedial work may also include a correction plan. If the operator or owner or person in possession refuses to correct the condition, the County will be authorized to correct any condition so noticed. Cost of such work shall be collectible under Section 607.770. (O. No. 23221 , 5-29-07) SUBCHAPTER M. WATERS 607.810 Waste Not To Be Deposited in Waters Within County. No person shall dump or deposit or permit dumping or depositing of any wastes into any stream, spring, body of surface or ground water, whether natural or artificial, within the boundaries of St. Louis County except as provided herein or as allowed by another jurisdiction concerned with matters of health and having authority to regulate such dumping or depositing and which in fact regulates such dumping or depositing (O. No. 23221 , 5-29-07) SUBCHAPTER R. PENALTIES AND ENFORCEMENT 607.940 Citation for Violations of Provisions of This Chapter; Form of Citation. 1. Any person designated by the Director to enforce provisions of this Chapter may issue a citation to any person when having probable cause to believe that such person has committed a violation of Sections 607.050, 607.060, 607.070, 607.080, 607.090, 607.100, 607.110, 607.120, 607.130, 607.135, 607.140, 607.145, 607.150, 607.181 , 607.182, 607.183, 607.184, 607.185, 607.210, 607.230, 607.240, 607.250, 607.260, 607.270, 607.280. 607.290, 607.300, 607.310, 607.340, 607.720, 607.730, 607.740, 607.750, 607.755, 607.760, 607.800, 607.810, 607.860, 607.865, 607.1000, 607.1005, 607.1020, 607.1040, 607.1145, 607.1155, 607.1200, 607.1203 and 607.1205 of this Chapter. The citation shall require the person in whose name the citation is issued to pay a fine either by mail or in person at the offices of the Department of Health within ten (10) days after receipt of the citation. O. No. 23221 , 5-29-07) Page 49 of 56 Appendix 5-F1 : Corps of Engineers 404 Permit & MDNR 401 Certification All construction or maintenance activities that excavate in or discharge any dredge or fill material into a "water of the United States" requires a Corps of Engineers 404 permit and a MDNR 401 water quality certification. The permitting and certification process is shared between the Corps and the MDNR. If you are considering a project that may involve placing materials in a lake, river, stream, ditch or wetland (including dry streams, ditches or wetlands) contact the Corps to find out if the project you are planning is in jurisdictional waters and is a regulated activity. The Corps has the sole authority to determine whether the activity is regulated; whether a site specific, individual 404 permit is required, or whether a Nationwide Permit (NWP) applies for projects with minor impacts. If a NWP does apply, contacting the Corps of Engineers is recommended to determine thresholds for notification under the NWP, and to obtain additional regional requirements imposed by the Corps' St. Louis Office. The MDNR requires any project that needs a 404 Permit from the Corps (individual or NWP) to also obtain a 401 Water Quality Certification (401 Certification) from MDNR. The 401 Certification is verification by the state that the project will not violate water quality standards. The department may require actions on projects to protect water quality in the form of certification conditions. For some of the NWPs, the MDNR has published their conditions that must be met in addition to the NWP conditions. After you contact the Corps about your project and, if applicable, submit an application, they will send you a letter authorizing your project under a particular permit. If the Corp's letter to you indicates that you must obtain an individual 401 certification, you must send an application to MDNR also. If they state that MDNR has `conditionally certified' your activity, and have enclosed certification conditions, then nothing further is needed. Questions about permit applicability and procedures for obtaining individual permits can be found by calling the Corps of Engineers at 314-331-8575 or 314-331-8186. Permit application forms and procedures for applying to the Corps and the MDNR can be found on the following web pages: https://www.usace.army.mil/Missions/Civil-Works/Regulatory-Program-and-Permits/Obtain-a- Permit/https://dnr.mo.gov/env/wpp/401/ The following is a list of NWPs commonly applicable to municipal operations. For most of these NWPs, the MDNR has conditionally certified these activities. The NWPs will list numerous thresholds for applicability and notification in terms of linear feet and acreage of the project. • NWP 3 Maintenance — repair or replacement of an existing structure, and removal of accumulated sediment or placement of riprap to protect a structure. • NWP 7 Outfall Structures — construction of new outfall and intake structures, and removal of accumulated sediment blocking these structures. • NWP 12 Utility Lines — construction, maintenance, and repair of utility lines (sewer, water, electric or communication), including outfalls and excavations for the utility line. • NWP 13 Bank Stabilization — stabilization projects for erosion protection. • NWP 14 Linear Transportation — construction or modification of linear transportation crossings, such as bridges and culverts for roads and trails. Page 50 of 56 • NWP 27 Stream and Wetland Restoration Activities — activities associated with the restoration of former waters, or the enhancement or creation of wetlands and riparian areas, or the restoration and enhancement of streams, including activities associated with flow modification, habitat and vegetation. • NWP 31 Maintenance of Existing Flood Control Facilities — dredge or fill activities associated with maintaining existing flood control facilities such as retention/detention basins and channels. • NWP 41 Reshaping Existing Drainage Ditches — dredge or fill activities to modify the cross-sectional configuration of drainage ditches, not modifying capacity beyond the original design. • NWP 43 Stormwater Management — construction, maintenance, and dredging of stormwater management facilities, such as ponds, detention/retention basins, outfalls, and emergency spillways. Page 51 of 56 Glossary: Definitions of Terms Used In This Document The following definitions are specific to the St. Louis Metropolitan Small MS4 and to the (municipality). Best Management Practice (BMP) means: Schedules of activities, prohibitions of practices, maintenance procedures and other management practices to prevent or reduce the pollution of streams within St. Louis County from urban runoff. BMPs also include treatment requirements, operating procedures and practices to control site runoff, spillage or leaks, sludge or waste disposal or drainage from raw material storage. BMPs may be structural or non-structural. (This definition adapted from Section (1)(C)1 of Missouri Storm water Regulation 10 CSR 20-6.200) Coordinating Authority means: The municipal entity, which is one of the co-permittees to a state issued Phase II stormwater permit, that is recognized by the Missouri Department of Natural Resources (MDNR) as the party which will coordinate the activities of all of the co- permittees in meeting the requirements of the permit. For the St. Louis County Plan Area, the Metropolitan St. Louis Sewer District (MSD) has been identified in the permit as the coordinating authority for the co-permittees. One of the coordinating authority's responsibilities is to prepare and submit an annual report to the MDNR on the status of compliance of all the co-permittees with the permit and approved SWMP. Co-permittee means: An individual permittee named in a Phase II permit that is issued to multiple entities within a single urbanized area such as St. Louis County. Within the St. Louis County Plan Area, each co-permittee is responsible only for the permit conditions relating to the discharges for which it is the owner or operator and for carrying out the responsibilities for which it has been designated within the SWMP. The co-permittees share in the financial and administrative responsibilities under the permit and cooperate with each other and with the coordinating authority in complying with the terms of the permit and with meeting the commitments in the SWMP. The co-permittees are listed in the SWMP Green Procurement - the procurement of products and services that have a lesser or reduced effect on human health and the environment when compared with competing products or services that serve the same purpose. Green Product— a product that is less harmful than the next best alternative, having characteristics such as: • Being recyclable. • Being biodegradable. • Containing recycled material (post-consumer recycled content). • Having minimal packaging and/or for which there will be take-back by the manufacturer/supplier of packaging. • Being reusable or contain reusable parts. • Having minimal content and use of toxic substances in production. • Producing fewer and/or less polluting by-products during manufacture, distribution, use and/or disposal. • Producing the minimal amount of toxic substances during use or at disposal. Page 52 of 56 • Making efficient use of resources - a product that uses energy, fuel or water more efficiently or that uses less paper, ink or other resources. • Being durable or having a long economically useful life and/or can be economically repaired or upgraded. Green Space - planned and preserved open land; an interconnected system of open land, determined to have cultural, ecological, developmental, agricultural, and/or recreational value. Maximum Extent Practicable (MEP) — the technology-based discharge standard for Municipal Separate Storm Sewer Systems to reduce pollutants in stormwater discharges that was established by CWA §402 (p). A discussion of MEP as it applies to regulated small MS4s is found at 40 CFR 122.34. MCMs means: Minimum Control Measures. The six MCMs are: Public education and outreach; Public participation/involvement; Illicit discharge, detection and elimination; Construction site runoff control; Post-construction site runoff control; and Pollution prevention/good housekeeping. Municipal Industrial Facility means: An industrial facility, as defined in the federal and state stormwater regulations, which is owned or operated by a municipality. The regulations define covered industrial facilities by their Standard Industrial Classification (SIC) codes as published by the U.S. Office of Management and Budget. From this extensive list of covered SIC codes, the following operations have been identified as those most likely to be owned or operated by a municipality: Transportation Operations, Landfills, Hazardous Waste Treatment/Storage/Disposal facilities, Vehicle Maintenance or Fueling facilities, Vehicle Washing facilities, Solid Waste Transfer facilities, Wastewater Treatment facilities, Recycling facilities, Yard Waste/Composting facilities and certain types of Warehousing & Storage facilities. Municipal Separate Storm Sewer System (MS4) means: A conveyance or system of conveyances including roads and highways with drainage systems, municipal streets, catch basins, curbs, gutters, ditches, paved or unpaved channels or storm drains designated and utilized for routing of stormwater which is contained within the municipal corporate limits or is owned and operated by the state, city, town, village, county, district, association or other public body created by or pursuant to the laws of Missouri having jurisdiction over disposal of sewage, industrial waste, stormwater or other liquid wastes and is not a part or portion of a combined sewer system. (This definition adapted from Section (1)(C)16 of Missouri Storm water Regulation 10 CSR 20-6.200). Each of the co-permittees operates its own MS4. In addition, the term is used to refer to the entire St. Louis County Plan Area which is identified in the Phase II permit as the St. Louis Metropolitan Small MS4. Municipality means: Any public entity as described in the definition of Municipal Separate Storm Sewer System. St. Louis County and the Metropolitan St. Louis Sewer District are considered "municipalities" for the purposes of the Phase II stormwater permit along with the cities, towns and villages who are co-permittees. The Missouri Department of Transportation (MoDOT) is also a "municipality" and operates an MS4 within the Plan Area. However, MoDOT is covered by a separate state permit and is not a co-permittee under the St. Louis Metropolitan Small MS4 permit. Page 53 of 56 NPDES means: National Pollutant Discharge Elimination System. This term was introduced in Section 402 of the federal Water Pollution Control Act of 1972 (last amended in 1987 and now known as the Clean Water Act). Section 402 provides for the issuance of NPDES permits for the discharge of pollutants to waters of the United States and specifies the conditions under which permits may be issued. The 1987 amendments established the phased permitting requirements for municipal stormwater discharges. In Missouri, the Missouri Department of Natural Resources has been delegated the authority to issue NPDES permits. Phase I means: The first phase of the federal stormwater regulations. These took effect December 17, 1990. Phase I regulations provide for stormwater permitting for industrial facilities, for land disturbance sites 5 acres or greater in size and for MS4s having populations greater than 100,000 (medium and large MS4s). Industrial facilities operated by municipalities, regardless of size, are included under Phase I. See definition of "Municipal Industrial Facility." Phase II means: The second phase of the federal stormwater regulations. These took effect February 7, 2000. Phase II regulations provide for stormwater permitting for MS4s, in urbanized areas as defined by the Bureau of the Census, with populations below 100,000 (Small MS4s) and for land disturbance sites between 1 acre and 5 acres in size. Each of the individual municipal entities within the St. Louis County Plan Area has a population below 100,000 and is, therefore, a Small MS4 subject to Phase II requirements. Phase II Permit means: Stormwater permit # MO-R040005 issued by the Missouri Department of Natural Resources to the St. Louis County co-permittees. This permit was issued pursuant to the provisions of Missouri Stormwater Regulation 10 CSR 20-6.200. Plan Area means: The portion of St. Louis County served by separate storm sewers and within the corporate boundaries of the Metropolitan St. Louis Sewer District. The Plan Area includes the cities, towns and villages who are co-permittees as well as unincorporated St. Louis County. The Plan Area is identified in the Phase II permit as the St. Louis Metropolitan Small MS4. Recycling Facility means any co-permittee-owned or operated facility which collects, for recycling, common household recyclables such as paper, plastic, glass, cardboard, etc. or which collects and processes yard wastes for use as mulch or compost. Separate Storm Sewer means: A pipe, conduit, conveyance or system of conveyances (including roads with drainage systems, municipal streets, catch basins, curbs, gutters, ditches, manmade channels or storm drains) designed and intended to receive and convey stormwater and which discharges to waters of the state and which is not part of a combined sewer system. Stormwater means: rainfall runoff, snow melt runoff and surface runoff and drainage. Stormwater Management Plan (SWMP) or Plan means: The Plan developed for the St. Louis County Plan Area by the St. Louis Municipalities Phase II Stormwater Planning Page 54 of 56 Committee and approved by the Missouri Department of Natural Resources through the issuance of NPDES permit MO-R040005. Sustainable (green) Service - A service acquired from a supplier who has a green operational policy and whose internal practices promote sustainability. Threshold - the dollar value of contracts, above which a formal record is kept on file showing that environmental criteria were considered when requirements were defined. Urban Runoff means: Stormwater and other runoff from streets, parking lots, rooftops, residential, commercial and industrial areas and any areas that have been rendered impervious through development activities. Such runoff becomes contaminated with fertilizers, pesticides, vehicle drippings and emissions, animal wastes, street litter, yard wastes, silt, chemical spills and other urban wastes. These contaminants are carried through the separate storm sewers and discharged into area streams where they degrade the water quality, harm aquatic life and other wildlife, reduce aesthetic and recreational values and make the waters unsafe for human use. Page 55 of 56 For More Information... • Metropolitan St. Louis Sewer District — Stormwater management BMPs https://www.stlmsd.com/what-we-do/stormwater-management https://www.stImsd.com/what-we-do/what-can-i-do • MDNR Stormwater Information Clearinghouse https://dnr.mo.gov/env/wpp/stormwater/ • Spill Response and Reporting — For EPA contacts and reporting instructions: https://readycontainment.com/technical-library/epa-emergency-spill-response/ MDNR contact and reporting instructions: https://dnr.mo.qov/env/esp/esp-eer.htm • EPA - Stormwater BMPs https://www.epa.gov/npdes/national-menu-best-management-practices-bmps- stormwater#poll • Stormwater Waste Management Guidance — Pollution Prevention Guidance publications: https://www.epa.gov/p2 Page 56 of 56