Transcript PIPP Presentation - University of Michigan

THE UNIVERSITY OF MICHIGAN – FLINT
Environmental Compliance
with…
1- New NPDES Storm Water Management Permits
2- SPCC & Michigan PART 5 Requirements
3- Environmental Due Care
Env., Health and Safety & Facilities Management
March 2010
Portions of Training materials adopted from UM OSEH
Storm Water Mgt. is strictly regulated…
it dates back several decades
 Federal Clean Water Act of 1972
 CWA amendments of 1987 required permits for storm
water discharge (Phase I and II).
 Federal Phase I SW Regulations began 1990
 Industrial Sites: certified ISW operator
 Construction sites over 5 acres: requires SESC plans, weekly
inspections by certified CSW operator
 Municipalities over 100,000: public education, illicit connections,
maximum extent practicable measures
 Federal Phase II SW Regulations (1999)
 Industrial Sites: about the same as above, certified operator
 Construction sites 1-5 acres: w/ certified operator
 Municipalities under 100,000:
 Three permit options under Phase II:
 General permit, Individual permit, or Modification –MS4
 UM ‘s renewed 2009 Combined Permit (AA, Dearborn & Flint)
 UM-Flint’s pool discharge permit
Michigan Env. Protection Regulations
 Part 31, Water Resources Protection of NRP Act of 1994
 Empowers Director of MDEQ to protect & conserve water resources… adopt,
establish/enforce rules, penalties
 Prohibits pollution of state’s waters, etc.
 Part 91, Soil Erosion and Sedimentation Control of NRP Act of
1994
 Requires control of soil erosion and sedimentation
 Permits, SESC plans for “earth Changes” of one acre or more or any “earth change”
within 500 feet of river, lake, stream…
 Regulated by local, county or state
 Authorized Public Agency (APA)
 Part 301, Inland Lakes and Streams (1994)
 Regulates activities in lakes/streams, requires permit, i.e dredging, SESC, etc
 Part 303 Wetland Protection Act (1994)
 Protected like other surface water from SW contamination
 Part 17, Michigan Environmental Protection Act
 Provides for citizens to bring legal action “for conduct that may pollute, impair, or
destroy the air, water, or natural resources.”
 Part 305 Natural Rivers Act (1970)
 Regultes activities w/in 400 ft of “Natural River District” … building, removal of
vegitation, land alteration, bridge work…
The “Big Picture” of
Storm Water Discharges
So what does this mean for UM-Flint?
* UM-Flint is in the Flint River Watershed
* Stop pollutants from entering the Flint
River… through storm drains or by runoff
directly to the river or ditches that lead
to the river
* Report illicit discharges & spills
immediately to Public Safety/EHS
* Always use best management
practices at work, home and play
* Attend trainings and workshops
* Encourage others to do the right thing
UM Ann Arbor has been operating under a “Voluntary”
NPDES permit dating back to the Federal Phase I (1990’s)
Flint and Dearborn were required to comply w/ SW
Regulations under Phase II by March 2003.
UM has petitioned MDEQ to include the Flint and
Dearborn campuses into the existing permit… all under
“The Regents of UM”.
NOW, All THREE campuses fall under one MDEQ (new
renamed MDNRE) permit.
Increased documentation, inspections, education/training
for employees, contractors and the general public.
UM Storm Water Permit Requirements
(NPDES Permit # MIS049000)
 Authorized Discharges - ONLY STORM WATER!
 Some minor exceptions… irrigation, uncontaminated
groundwater, potable water, foundation drains, lawn water
runoff, water line flushing and discharge of potable water, noncommercial car washing, residual street wash waters, flows
from emergency fire fighting activities.
 Discharges Requiring Authorization
 Use of Tracer Dyes
 Use of Water Treatment Additives
 Waste Water associated with concrete activities
 Requires written authorization from MDNRE office, must
coordinate with EHS &OSEH-EM to receive authorization
 Dechlorinated swimming pool discharge
requires separate NPDES permit- August 2009.
 Discharge of “any pollutants” is prohibited.
MDNRE Requires SWM Program
~ Minimum Measures ~
 identify and map discharge locations
 illicit discharge detection and elimination
 pollution prevention and good housekeeping
for site operations- Best Management Practices
 construction site storm water runoff control
 post-construction storm water management
 employee and contractor training
 public education and outreach
 public involvement and participation
NOTE: The current SWMP (Jan 2010) has been recently revised and comments on the document
are being encourage over the next 30 days please be sure to participate in the review and provide
your suggestions, etc. http://www.oseh.umich.edu/stormwater/SWMP2010.pdf
UM-Flint’s Role (EHS, FM & others)
complying w/ MDNRE Permit conditions
 Review & adopt UM’s written SWMP (Jan 2010)
 Implement & enforce best management practices
with UM employees and contractors
 Find & Eliminate Illicit Discharges and Connections
 Post-Construction SW Mgt. for (Re)Development
 > equal to 1 acre… or < 1 acre but part of a larger development
 With in 500 feet of the River
 Require to include structural and nonstructural BMPS i.e buffers, minimal
disturbance of soil & vegetation, detention ponds,
 Ensure isolation of storm drains from polluting materials… use of secondary
containment, fabric filters, silt sacks, absorbent pads, etc.
 Conduct & Participate in Public Education
 residents, faculty, staff, students, visitors
 Partner w/ City of Flint, FRWC, CAER & Outreach, others
 Household Haz Waste and e-Waste Collection - 2x year
complying w/ MDNRE Permit conditions
 Construction Storm Water Runoff Controls
 SESC requirement
 Procedures to receive complaints from the public
 Pollution Prevention & Good Housekeeping
 Material storage & containment– drums, bags, dumpsters, stockpiles, etc.
 Maintenance of Structural Controls – catch basins, sedimentation or
infiltration basins, manage waste from drains
 Street cleaning & catch basin maintenance, Reduce discharge of
pollutants associated with maintaining streets
 Ensure vehicle maintenance activities do not impact SW… discharge of
wash water to SW drains is not authorized under permit.
 Pesticides and Fertilizers – minimize discharge of pollutants related to
handling, application and storage of chemicals BMPS required include
employee training, soil testing to minimize application and treatments,
 Assess Program, Annual Reporting to OSEH & MDEQ
 Identify measurable goals, monitor progress and document
everything… BMPS, spills, purchases, training, compliance expenses, etc
complying w/ MDEQ Permit conditions
Inlet Fabric
Filters and Silt
Sacks
EHS and Facilities Mgt. preparation for
UM SWM Annual Report to MDNRE
 Time period April 2009 – July 2010
 Track frequency of storm/sanitary repairs
 Map outfalls and test water quality at point of discharge
 Street sweeping and related activities
 Waste management – litter collection/disposal
 Inspection and Maintenance on catch basins
 Use of protective measures on drains
 Spills and clean up
 Parking lot & ramp cleaning/maintenance
 Education and training, classes, brochures, bulletin boards,
website, special events, etc.
 Pesticide Management and related testing
 Public outreach… FRWC, CAER, County planning boards, etc.
EPA/MDEQ Requires 6 Minimum
EPA/MDEQ
Requires
6
Minimum
Measures in UM SW Mgt. Program
Measures in UM SW Mgt. Program
Video
•
•
•
•
•
public education and outreach
public involvement and participation
illicit discharge detection and elimination
construction site storm water runoff control
post-construction storm water management,
and
• pollution Best
prevention
and goodPractices
housekeeping
Everyday
Management
(BMPs)
for site operations.
Storm Water
Pollution Prevention
1. Identify five (5) Best Management Practices
that can be implemented by Housekeeping
Staff? by Grounds keeping staff? Other
staff?
2. Identify three (3) past practices that should
be avoided in the future?
3. What material is permitted to be discharged
down the UM storm drains?
4. When do you need to call EHS? When do
you call your supervisor?
Spill Prevention Control and
Countermeasure Plan (SPCC)
 Plan required by the United States Environmental
Protection Agency under 40 CFR part 112
 UMF SPCC Plan - 2003, rev 2006, rev 2009
PURPOSE:
Plan outlines measures to prevent
the discharge of OIL into the
navigable waters.
Spill Prevention Control and
Countermeasure Plan (SPCC)
 Definition of OIL – oil of any kind or in any form,
including but not limited to:
Petroleum
fuel oil
sludge
oil refuse
kitchen grease
animal fats
oil mixed with wastes
Spill Prevention Control and
Countermeasure Plan (SPCC)
Who is Required to Implement a SPCC Plan?
A facility that exceeds:
Total UNDERGROUND storage capacity greater than
42,000 gallons or
An aggregate or combined aboveground storage capacity
greater than 1,320 gallons, and
Reasonable expectation that a discharge
could reach a navigable waterway.
Spill Prevention Control and
Countermeasure Plan (SPCC)
What is required of a Facility under the regulations?
1. A written plan certified by a Professional
Engineer (PE) every 3 years.
2. Oil storage management and control
3. U-M Facility Personnel involvement
Routine inspections
Spill prevention and spill control
Best Management Practices
Record keeping
SPCC Plan Requirements
Written Plan
 State general information of the facility
 Facility Response Coordinator and Alternate
 Name of facility, address, phone numbers
 Nearby surface water body/ distance
 Facility Description
 Description of campus
 Facility drainage areas (storm water discharges to streams, creeks)
 Oil storage, distribution and use (explain type of containers)
 Spill history
 Potential releases and prevention controls
 Loading and unloading operations
SPCC Plan Requirements
Written Plan - Continued
 Spill Response Plan
 UMF has a effective ERP that serves as a guidance document. The
ERP incorporates the criteria for oil removal contingency plans
specified in 40 CFR Part 109.
 Approximately 30 U-M personnel have completed the 32-hour
Hazardous Waste Operations Emergency Response Technician/
Incident Command Level training.
 Remedial action – Plan distinguishes between incidental spill nad
emergency release
 ERP available online at www.umflint.edu/ehs/
 Inspection schedule –(monthly, quarterly & annually)
 Describe the routine inspection schedule
 Current schedule was approved by the EPA in 2001
SPCC Plan Requirements
Written Plan - Continued
 Personnel training
 Oil handling personnel trained in



Become familiar with laws and regulations
regarding spills, releases, and pollution
control
Contents of the UMF SPCC plan (rev 2009)
Operation and maintenance of equipment
to prevent discharges including performing
the routine inspections.
SPCC Plan Requirements
Oil Storage Management and Control
Oil storage management and control as stated
in the regulations and in the written plan.
 Lighting
 Security
 Secondary Containment
 Catchment during loading and unloading
fuel
SPCC Plan Requirements
Oil Storage Management and Control
Lighting
Per the EPA, as long as the oil storage area
is accessible with a flashlight, this is considered adequate
lighting.
Security
To assist in preventing spill or release from being caused by
accidental or unknown entry or vandalism.
Fenced area
Padlocks
Security guards
Stored inside building
SPCC Plan Requirements
Oil Storage Management and Control
Secondary Containment
 Secondary containment is required for OIL containers with
the capacity of 55 gallons or greater and is to prevent any spills
from any leaking or damaged containers.
 The secondary containment must have the capacity to hold
the volume of the largest container or 10% of the combined
containers, whichever larger.
 If room has no floor drains, then the room itself may be
considered sufficient secondary containment. If the room is
considered the secondary containment ensure there is a lip at the
door so no liquids can exit the room in the event of a leak.
Secondary Containment
SPCC Plan Requirements
Oil Storage Management and Control
Fuel Catchment
The SPCC plan requires
catchment to be in place
during refueling operations
from a tanker truck to an
aboveground or
underground storage tank
that will hold the capacity
of the largest inner single
compartment of the
delivery truck.
Fuel Catchment
SPCC Plan Requirements
UM-Flint Personnel Involvement
 Container Inspections
 Monthly and quarterly inspections
 Trained oil-handling personnel should perform the routine inspections.
OSEH & EHS provides assistance to the Facility Managers and
Supervisors by explaining the environmental regulatory requirement and
therefore relies on the FM and Supervisors to ensure the routine
inspections are being performed on time.
Container
AST
UST
Drums
Transformers
Capacity
>= 55 gallons
>= 55 gallons
>= 55 gallons
>= 55 gallons
Frequency
Quarterly
Quarterly*
Monthly
Quarterly
Personnel
Facilities Mgt.
Facilities Mgt.
Facilities Mgt..
Facilities Mgt./Electricians
• Except FWT Library UST must be inspected monthly per Part 211
 EHS & OSEH will monitor & inspect at least annually
SPCC Plan Requirements
UM-Flint Personnel Involvement
Inspection Checklist Example (In handout)
UMF Facilities Management has incorporated the
monthly/quarterly inspections into their PM program
Completed & signed inspections forms are forwarded
to EHS, copies are kept with FM
U-M Flint Oil Storage locations
Tank ID
Location/Building
Type of Construction
Capacity in gallons
Substance stored in tank
1
Adjacent to the Central Energy Plant (CEP)
UST – Double Walled -FG
30,000
#2 heating oil
2
Adjacent to the Central Energy Plant (CEP)
UST – Double Walled -FG
30,000
#2 heating oil
3
Adjacent to the Central Energy Plant (CEP)
UST – Double Walled -FG
30,000
#2 heating oil
4
FWT Library
UST -FG
1000
diesel fuel
5
University Center basement
AST
275
diesel fuel
6
French Hall
AST
275
diesel fuel
7
Theater Basement
AST
50
diesel fuel
8
Hubbard Compound
AST- plastic
5000
deicing solution
9
Murchie Science Building
(MSB)
AST
250
diesel fuel
10
Central Energy Plant (CEP)
AST
250
diesel fuel
11
Hubbard Compound adjacent to the Central Energy Plant (CEP)
AST
1000
diesel fuel
12
Hubbard Compound adjacent to the Central Energy Plant (CEP)
AST
500
gasoline
13
University Pavilion
Drum
30
grease
14
University Center
Drum
30
grease
NA
Central Energy Plant (CEP)
Drum
55
oil
NA
Hubbard Building (interior)
Drum
55
oil
NA
Hubbard Building (exterior)
Drum
55
oil
NA
Hazardous Materials Building
Drum
55
Wastewater, and upon occasion other
materials
Total of 12 Tank inspections
Total of 6 drums inspections
SPCC Plan Requirements
UM-Flint Personnel Involvement
Spill prevention and spill control
Immediately block nearby drains. Contain all releases
with absorbent material if the scene is safe. If the scene
is not safe, contact DPS at 762-3335 and EHS at 766-6763.
Record keeping
All records must be kept on site for
at least three years.
SPCC
TEST
1.
The SPCC Plan regulates the following pollutant.
a.
Water
b.
Salt
c.
Oil
d.
Soil
2.
Which of the following is a form of oil that is regulated by 40 CFR 112?
a.
Kitchen grease
b.
Gasoline
c.
Diesel Fuel
d.
All the above
3.
How many years do the records need to be kept on file?
a.
b.
c.
d.
4.
Which containers are required to be inspected monthly?
a.
b.
c.
d.
5-
Underground storage tanks
Aboveground storage tanks
55-gallon drums
All the above
Whenever loading/unloading oil products from a tanker truck, the FM
employee must do which of the following:
a.
b.
d.
6-
3 years
3 months
forever
7 years
Apply drain blockers to the near by storm drains prior to fueling
Stay with the vehicle while fueling
All the above
Who do you call FIRST in the event of an emergency release into the storm
drain?
a.
b.
c.
d.
DPS & EHS
Young’s Environmental
City of Flint
Supervisor
MI Part 5 Rules
Spillage of Oil and Polluting Materials
PURPOSE:
The MI Part 5 Rules are intended to prevent
releases of polluting materials to surface waters
or ground waters of the state.
MI Part 5 Rules
 Chemicals affected by the MI Part 5 Rules
Oil
Salt
Any material specified in table 1 ( ~ 964
chemicals)
Any compound or product that contains 1%, or
more, by weight, of oil, salt or any material
listed table 1.
MI Part 5 Rules
Main Requirements
1. Secondary containment
 Oil, Salt, or Compounds or products containing > 1% of any
material listed in the Polluting Materials list and exceed the
threshold management quantities of the following:





Salt, in solid form, at any location in a quantity greater than 5 tons
Salt, in liquid form, at any location in a quantity great than 1,000
gallons
Oil, stored aboveground in quantities greater than 1,320 gallons or in
a single AST with a capacity of 660 gallons. NOTE: Oil storage and
use does not need to be addressed in a the PIPP if a facility complies
with 40 CFR 112 (SPCC Plan)
All other polluting materials at any discrete outdoor location in
aggregate quantities greater than 440 pounds
All other polluting materials at any discrete indoor location in
aggregate quantities greater than 2200 pounds.
MI Part 5 Rules
Main Requirements
NOTE:
Even without threshold quantities, secondary containment
may still be needed
 Local Sewer Use Ordinance to protect accidental release
to the City of Flint sewers
MI Part 5 Rules
Main Requirements
2. Pollution Incident Prevention Plan (PIPP)
Required if a facility exceeds the threshold
management quantity for oil, salt, or any of the 964
polluting materials.
Threshold management quantity is the total amount of chemical in one discrete area that
determines if a facility is required to implement a PIPP and provide secondary
containment.
Contents of a PIPP (similar to SPCC Plan requirements)
A. Identification Information
 Facility
 Parent corporation and owners
 Facility description and operations
 Spill clean-up responders
MI Part 5 Rules
Main Requirements
2. Pollution Incident Prevention Plan (PIPP)
Contents of a PIPP Cont’d
B.
C.
D.
E.
F.
G.
Materials used or stored on the polluting materials list.
Storage tanks
Spill prevention and control
Spill response and clean up procedures
Chemical Inventory
Secondary Containment Structures
MI Part 5 Rules (PIPP) Vs. SPCC
Summary
SPCC
 40 CFR Part 112
(FEDERAL)
 Regulate oil products
only
 Require routine
inspections on containers
of OIL greater than 55
gallons
 Plan required if storing
42,000 gal underground
or an aggregate of 1320
gal of oil
PIPP
 MI Part 5 Rules
(STATE)
 Regulate oil, salt, and
~964 polluting materials
 Don’t require routine
inspections
 Plan required if exceed
threshold management
quantity for oil (same as
SPCC), salt, or the
polluting materials
1.
The PIPP Plan regulates the following pollutant(s).
a.
b.
c.
d.
2.
Where are the your department MSDSs located?
a.
b.
c.
PIPP
TEST
d.
3.
True
False
Which of the following is part of the FM/CEP spill clean up
procedures?
a.
b.
c.
d.
5
CEP Control Room
Hubbard Building front office
Lunch room
Tim Barden Joel Ellis’ office
The PIPP is intended to prevent releases of polluting materials
to surface waters or ground waters of the state.
a.
b.
4.
Water
Salt
Oil
All the above
Notify the appropriate response coordinator
Sound the alarm and evacuate personnel
Attempt to control the situation
All the above
Who do you call FIRST in the event of an emergency release
into the storm drain?
a.
b.
c.
d.
Young’s Environmental
DPS & EHS
Supervisor
Director
Due Care Regulatory Requirements:
ENVIRONMENTAL
DUE CARE
AT
UM-FLINT
Due Care Regulatory Requirements:
 UM-Flint is subject to due care obligations for all activities that may
disturb the soil/earth i.e. construction, maintenance, subsurface
activities at the following properties:






WSW Building and surrounding areas including former Horse Barn
Former Perry Printing Site
Parking Lot A and all surrounding areas (CE/MGP)
Hubbard Compound
Northbank Center, NBC Parking Ramp and surrounding areas
Proposed Student Hosing Site and surrounding areas
 The properties are classified as a “facility” (Part 201 of Act 451)
because contamination has been detected in soil and/or
groundwater at concentrations exceeding generic residential
cleanup criteria.
 UM and its contractors have legally enforceable responsibilities for
ensuring that:
 Its actions do not exacerbate existing contamination
 The intended use of the property will not result in unacceptable exposures to hazardous
substances
 It takes reasonable precautions with regard to acts or omissions of third parties.
 These requirements are a result of previous existing environmental
site conditions that existed prior to UM acquiring the property.
Due Care Regulatory Requirements:
PERRY
WSW
NBC
CE MGP
CEP USTs
STUDENT HOUSING
Due Care Regulatory Requirements:
 Notification to adjacent property owners, utility
workers, contractors, state and local agencies.
 Develop and implement property specific Due Care
Plans for the contaminants found in the soil or
groundwater at that location.
 Internal/institutional controls… letter to FM Director,
internal policies, distributed Due Care Plans,
contractual language for construction projects…
 Monitoring of site conditions, protective barriers, odors,
staining of soil, sheen on water outfalls, etc.
 Monitoring of site activities by employees and
contractors… FM, Project Mgrs., EHS
 Soil/groundwater sampling and analysis
 Management of soils, groundwater, dewatering
activities, spoils, decontamination, personal hygiene
 Documentation
How does this effect routine activities or
planning projects at UM-Flint?
 Notify EHS of subsurface work on campus… participate in





preplanning of project/activity.
Proper selection of PPE for UMF employees… know the
specific contaminants, their location and hazards in the
work the area
Management of soils on site, replace protective cap/barrier
Manifest soils leaving site… Contact EHS.
Test/document clean soils on site…. Contact EHS 5-15 days
ahead of time to allow for sampling of the source.
Monitor protective barriers that are in place
ECDC Playgrounds: GeoFabric at 12-18 inches below grade
WSW: 6-9 inches of clean topsoil
NBC: paved parking areas
PERRY: 2-4 feet of clean fill across the site
CE MGP: paved surface Lot A, some replaced soils near Rec Center, impacts and
contamination is found DEEP under River and WSW Site 60-100 feet.
 Housing & Kearsley Street- GeoFabric at 9 - 12 inches below grade





 Inform contractors in writing, monitor compliance w/
established Due Care requirements
SUMMARY
 Nothing but water permitted down storm drains! Report
spills immediately, protect drains if you can do so safely.
 Due Care, SWM, SESC, SPCC, BMPs are all related…
protecting our natural resources, preventing degradation of the
surface water, reducing exposure to potentially harmful
pollutants and ultimately protecting the public’s health .
 Implement Best Management Practices into everyday work
practice to comply with NPDES Permit and SWM Program.
Provide feedback to EHS on SWMP over the next 30 days.
 Plan ahead… incorporate BMPs into projects ahead of time
regardless of the size of the project.
 SESC Plan required for >1 acre or within 500 feet of River
 Project Managers and Supervisors incorporate these
requirements into SOPs, project specifications, monitor and
enforce compliance with contractors and employees.
 Use a Team Approach when complying with Env. Regulatory
Requirements… FM, EHS/OSEH, Supervisors, Project
Managers, Contractors, MDNRE…
 Notify EHS of any subsurface work on campus.
Questions
O
S TO RI
V
FL
W
ER
Our M ichigan
Waters BLUE!
E
DU
NO W A
P Keep
ST
M
Please contact Environment, Health and Safety
at 766-6763 or 919-1709
EROSION = Soil particles
dislodged by wind, water, or
gravity
Soil Erosion &
Sedimentation Control
SEDIMENTATION = Soil
particles deposited on land or
in water bodies
Rill Erosion
Gully Erosion
Washout
Clogs Ditches and Culverts…
Muddy Streams…
Damage to plants & animals…
Reduced recreational value
Soil Erosion &
Sedimentation Control (SESC)
 UM applied for Authorized Public Agency (APA) status for Soil




Erosion & Sedimentation Control (SESC) June 2003…granted APA
status from MDEQ effective 9/22/04
The City of Flint and Genesee County will no longer issue SESC
permits or conduct inspections for sites owned by the University;
UM-Flint EHS, UM OSEH-EM, and the UM Planning Office will
now review SESC plans for sites involving earth activity >1 acre or
within 500 feet of water bodies.
Plans must be approved before any earth change activities begin
(demolition, grading, clearing, tree removal, etc.).
SESC plans are not required for project sites <1 acre or greater than
500 feet from water bodies (Flint River) but notification to EHS
must be made prior to beginning and most importantly, all SESC
regulatory requirements and protective measures must be
followed, no matter the size of the project..
SESC Exemptions
 Earth disturbances that are completed/closed
within 24 hours
 Earth disturbances that are less than 225 sq. ft.
(otherwise approx. 15’ X 15’ area)
 Both exemptions are important to the Flint
Campus because the majority of our earth
disturbances will be simple landscaping, tree
planting, sidewalk install/repair, or utility related
projects that would be either completed w/in 24
hours or less than the 225 sq.ft exemption.
 Project Managers must evaluate All activities
employ the appropriate Best Management
Practices or BMPs to protect the river and “Waters
of the State”… storm drains.
Submit SESC PlanS to EHS…
 Project managers must compile/forward four (4) completed
copies of SESC plans for review/approval.
 One copy to EHS Department (204 UPAV)
 Two copies to UM OSEH-EM
 Environmental Specialist / SESC Inspector
Occupational Safety & Environmental Health - University of Michigan
1239 Kipke Drive , Ann Arbor, MI 48109-1010
 Please allow 45 days for review and comments on plans.
 After EHS, OSEH-EM and University Planning have completed
their review UM OSEH-EM will issue final approval of SESC plans
for Flint projects >1 acre and/or within 500 feet of river.
 Approved plans will be stamped accordingly, one set will be
retained by OSEH-EM and one set will be kept at the site.
 Weekly inspections and inspections after significant rain events
for all sites involving earth activities must be conducted &
documented.
 For large projects, inspections may be contracted out with the
approval/coordination of EHS/OSEH. This could be an additional
cost to the project.
12 Components of SESC Plans
DESIGN DEVELOPMENT REQUIREMENTS
Scaled Map including:
1. Legal description
2. Site location sketch
3. Proximity to waters of the state.
4. Predominant land features
5. Contour intervals or slope descriptions
6. Soil survey / written description of soil types of the exposed land area
Details for the proposed earth change including:
7. Description & location of physical limits of each proposed earth change
8. Description and location of all existing and proposed on-site drainage
and dewatering facilities.
9. Timing and sequence of each proposed earth change.
10. Location & description for installing/removing all temporary SESC
measures.
CONSTRUCTION DEVELOPMENT REQUIREMENTS
11. Description and location of all permanent SESC measures.
12. Program for the continued maintenance of all permanent SESC measures
that remain after project completion. Include the designation of the
person responsible for the maintenance.
Best Management Practices - BMPs
 Control erosion first, THEN sedimentation
 Design a project specific SESC Plan
 incorporate the SESC plan into the project specs for contractors
(and employees)
 small projects… still enforce BMPs
 Routine Inspections
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


Weekly
Within 24 hours after precipitation event
MDEQ Certified Construction Site SWM Operator
Document inspections
 Immediately repair/replace any failed protective
devices
 Project is not complete and inspections must
continue until all permanent controls are in place
and site is stabilized.
Keep it on the Site!
Inlet Fabric
Filters and Silt
Sacks
Spoil Pile Protection
Soil Piles on site >24 hours
• Piles must be covered to prevent
erosion from wind
• Piles must be protected from
water erosion due to precipitation
events
Silt Fence
Grade Stabilization
Check Dam
Retention Basin
Vegetative Buffer / Basin
Anti-tracking pads
Street Sweeping
• Non U-M streets cannot show any signs
of trackout. Sweeping must occur any
time trackout is visible.
• UM streets should be swept daily, at a
minimum during construction projects,
and when trackout is visible.
Silt Fences require regular inspections and
maintenance… built up sediment MUST be removed if
it reaches 1/3 – ½ the height of fence
Silt fencing must be toed in to a depth of 6
inches and backfilled.
Inform Contractor, reinstall silt fence that has
been run over by machinery. Consider
additional control measures siltsack in closest
catch basin for additional protection
UM SESC Program
GuidElinES & FormS…
First point of contact:
UM-Flint EHS, 766-6763 or [email protected]
Online forms and resources:
OSEH Ann Arbor Website: www.oseh.umich.edu
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Soil Erosion and Sedimentation Control Procedure
Appendix A – Project Notification Form
Appendix B – Design & Review Checklist for SESC Plans
Appendix C – Field Inspection Report
NO W A
P Keep
Our M ichigan
Appendix D – Preferred SESC Design Elements
Waters BLUE!
Appendix E – Regulations in Brief