Operation & Maintenance
Requirements:
Tips for Keeping Your Agency
in Compliance
Kristin Kerr, P.E., QSD
EOA, Inc.
New Development Workshop
May 22, 2013
Outline of Presentation
 Permanent Stormwater Controls that
Require O&M Verification Inspections
 O&M Requirements in the Municipal
Regional Stormwater Permit
 The O&M Verification Inspection Plan
 Tools for Conducting, Tracking and
Reporting O&M Inspections
 For more information…
Permanent Facilities that
Require O&M Inspections
 Provision C.3.h of the MRP requires
agencies to conduct inspections to verify
operation & maintenance (O&M) of:
• Stormwater treatment measures, and
• Hydromodification management measures
Stormwater Treatment
Measures
 Low impact development (LID) treatment
systems (biotreatment, infiltration,
rainwater harvesting systems)
Bioretention Area (biotreatment)
Stormwater Treatment
Measures
 Vault-based systems (hydrodynamic
separators, media filters, proprietary
tree well filters)
Media Filter Cartridge
Hydrodynamic
Separator
Hydromodification
Management (HM) Facilities
 Basin, tank, pipe, or vault with specially
designed outlet to slowly release water.
Detention basin with outlet structure
O&M Requirements
(Provision C.3.h)
 Agencies subject to the MRP must:
• Require facility owners to conduct ongoing
maintenance (e.g. , maintenance agreement).
• Prepare and implement plan for annual O&M
verification inspections, including new
installations.
• Conduct O&M verification inspections;
provide enforcement as needed.
• Track and report on inspections.
Model Maintenance
Agreement
 Requires property owner to assure ongoing
operation and maintenance
What about Municipalityowned Facilities?
 O&M inspection requirements do not
distiguish between municipal and nonmunicipal facilities.
 Inspect, track and report on facilities
that your municipality is responsible for
maintaining.
O&M Verification Inspection
Plan
 Each fiscal year, inspect:
• All newly installed stormwater treatment and
HM controls within 45 days of installation
• 20% of the total number of installed
stormwater treatment and HM controls
(when rounding, round up!)
• 20% of all installed vault-based systems
(round up)
 All installed treatment and HM facilities must be
inspected at least once every 5 years.
Lessons Learned from NOVs
 Round up when calculating 20 % of
treatment/HM facilities per year, AND
when calculating 20 % of vault systems.
• If your agency has fewer than 5 facilities, be
sure to inspect at least one per year.
• Annual Reporting year July 1 - June 30th
• Now is a good time to verify you have your
inspections completed
Mosquito Abatement
District Coordination
 List of newly-installed facilities
submitted each year:
• To Mosquito Abatement District (MAD)
• Also to Regional Water Board
• Submitted before October 1
 Countywide Program
makes the MAD submittal
based on info in your
Annual Report
Tools for Inspecting, Tracking
& Reporting
 O&M Verification Inspection Checklist
 Annual Report O&M Inspection Table
 Each agency should have an internal
tracking table
• NOT submitted with Annual Report
• Can be requested by Regional Board at any
time
O&M Verification Checklist
Annual Report Form
C.3.h Reporting Table
Annual Report Form
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Name of facility/site inspected
Address
If newly installed
Party responsible for maintenance
Date of inspection
Type of inspection (initial, annual, follow-up,
spot)
Type of stormwater treatment/HM control
Inspection findings/results
Enforcement actions taken
Comments/Follow-up
Data Tracking
 Similar to AR Data Except……
• Name of facility/site inspected
• Address – specific description of location of
treatment/HM controls
• If newly installed – date of installation
• Party responsible for maintenance
• Date of inspection
• Type of inspection (initial, annual, follow-up, spot)
• Type of stormwater treatment/HM control – type
and size
• Inspection findings/results
• Enforcement actions taken
• Comments/Follow-up – corrective actions
For More Information…
 Countywide Program Password Protected
ND page www.flowstobay.org (click on
“Municipalities,” then “ND”)
• O&M Verification Inspection Plan Template
• O&M Verification Inspection Checklist
• Model maintenance agreement
 Municipal Regional Stormwater Permit
www.flowstobay.org (click on
“Municipalities,” then scroll to “Municipal
Stormwater Permit”)
Common Issues in Inspections
of Newly-Installed Treatment
Measures

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Purpose of inspection
When to inspect
What to look for during inspection
Common issues
Checklist for “45-day inspection”
Purpose of Inspection
 Verify treatment measures and/or
hydromodification management
controls are installed per approved
plans.
 At a minimum, inspect those
components that are visible in the
finished condition.
 If possible, also inspect below grade
components during construction.
When to Inspect
 Within 45 days of installation
 May conduct as part of overall final
inspection of constructed project
 May conduct during different construction
phases (e.g. inspect underground
elements, i.e. underdrain, while visible)
Prepare for the Inspection
 Review project plans to identify:
• The number of treatment measures and/or
HM systems to be installed on the site.
• The locations of treatment measures
and/or HM systems.
• The dimensions of treatment measures
and/or HM systems.
Prepare for the Inspection
 Review project plans to identify:
•
•
•
•
How high flows will be managed/diverted
Locations of underdrains and cleanouts
Type and extent of plant cover
Type of approved irrigation system
In this system, high flows will enter raised inlet.
During the Inspection
 Confirm that installation matches
approved plans regarding:
•
•
•
•
Total number and type(s) of facilities
Location of facilities on the site
Components and dimensions of facilities
Request confirmation from site
superintendent that biotreatment soil is
per MRP specifications
During the Inspection
 Confirm that installation matches
approved plans regarding:
• Type and extent of plant cover
• Functional irrigation system (if provided)
• High-flow bypass or overflow path
Overflow drain designed to keep out trash and debris.
Common Issues
 Is there exposed soil?
• Exposed soil should be covered with 2” of
mulch, except for area immediately
surrounding tree trunks (roots need air).
 Will vegetation block inlets to the
treatment measure when mature?
Turf is blocking inlet; insufficient drop between
pavement and top of grade in planting area.
Common Issues
 Is there positive drainage to the
treatment measures?
 Is there permanent erosion control at
points of concentrated flow?
Cobbles reduce erosion at entrance to bioretention area.
Common Issues
 Are plants healthy?
 Is there accumulation of sediment from
construction activity?
• Accumulated sediment must be removed.
O&M Verification Checklist
May be used for “45-Day inspections”; will have
to use Comments section
Questions?
Jill Bicknell, P.E.
408-720-8811 x1
jcbicknell@eoainc.com
Kristin Kerr, P.E., QSD
510.832.2852 x 122
kakerr@eoainc.com