The permit requirements for Pollution Prevention and Good Housekeeping for Municipal Operations for Storm Water Minimum Control Measure 6 (MCM 6) are defined in Section 4.2.6-4.2.6.9 of the Jordan Valley Municipalities (MS4) Permit; No. UTS000001

MCM Regulation Summary
1.5, 1.6.5.1, 2.2, 2.2.5, 4.1, 4.5, 4.1.2.2, 4.1.3.2
Show permit accountability, provide a description of program elements, minimum SWMP programs annual review, identifying inefficiencies, making necessary changes, and reporting overall program performance. 

Programs
6.1: Long-Term Stormwater Management Plan Riverton Facilities
6.2: Service Contract Operation and Maintenance
6.3: Sweeping
6.4: Drainage System Maintenance
6.5: Public Infrastructure Retrofit
6.6: Right of Way Encroachment Permit



 6.1:  Long-Term Stormwater Management Plan Riverton Facilities
Year Executed: 2011
Currently only the Public Works Facility at 4150 West has a fully operational LTSWMP.  However, the other City facilities are operating under draft level LTSWMPs and functioning SOPs specifically written to protect the quality of runoff and the environment.
Reference Regulation:
4.2.6.1, 4.2.6.2, 4.2.6.3, 4.2.6.4, 4.2.6.5, 4.2.6.6.6, 4.2.6.7, 4.2.6.10
Target Pollutants:
Including but not limited to: Loose trash, sediment and debris, salt, pesticides, herbicides, nutrients, organic matter, metals, hydrocarbons, detergents, bacteria, chlorine…
Audiences:
City field operators, UPDES personnel
Description:
The City LTSWMPs describes each facilities unique flood and water quality drainage system and its abilities and limitations at containing and controlling pollutants generated by operations and maintenance.  The LTSWMP SOPs are written to specifically compensate for the flood and water quality systems limitations for pollution generated by operations and maintenance.   The City facility LTSWMP program follows the same model used for private property.
Measure of Success:
Evaluate of SOP compliance and site inspections.  
Responsible Staff:
Public Works Director, Flood Control Engineer
Funding:
Storm Drain Fee, General Fund
Long-Term Stormwater Management Plans:
Water Department Facility 3323 West Sanborn Drive; NOT COMPLETE
Riverton City Hall 12830 South Redwood Road; NOT COMPLETE
Park Department Facility 12700 South 1300 West; NOT COMPLETE
Cemetery Facility 1500 West 13200 South; NOT COMPLETE
Standard Operations Procedures:
Appendix:
 Conclusion:
2021-2022
The Public Works Facility LTSWMP is complete.  The LTSWMP's for the Water Department Facility, City Hall, Park Department Facility and Cemetery Facility are incomplete.  
Monthly Visual and Semi-Annual Comprehensive inspections for all sites are incomplete for all sites and Annual Visual Observation of Storm Water Discharge inspections for priority sites are incomplete.  The Monthly Visual Inspections that were completed and discussion with staff field operators indicate many City maintenance operations are following SOPs.
  



6.2: Service Contract Operation and Maintenance
Year Executed: 2015
Reference Regulation:
4.2.6.7, 4.2.6.10
Target Pollutants:
Sediments, concrete, pesticides, herbicides, organics etc.
Audiences:
Service Contractors, City Staff
Description:
City construction and service contracts follow the City’s Standard Contract Terms and Conditions form.  This document facilitates construction projects include the terms of the ENC, LDPs and LTSWMPs, facilitating stormwater project controls and best management practices.
Measure of Success:
Inspect construction projects facilitated by this program and evaluate effectiveness and staff conformity.
Responsible Staff:
Contract Administrator & Purchasing Manager, Flood Control Engineer
Funding:
Storm Drain Fee, General Fund
Contract Terms and Conditions Form:
Conclusion:
2021-2022
This program did not function properly this report period.  City service contracts are managed by the departments and divisions requesting the service and notice to begin was issued without UPDES SOP review of the service contractors O&M Plan resulting in non-conforming SOPs.  



6.3: Sweeping
Year Executed: 2000
Reference Regulation:
4.2.1.5, 4.2.6.6, 4.2.6.6.1, 4.2.6.6.2, 4.2.6.6.3
Target Pollutants:
Sediment, organics, trash
Audiences:
City maintenance staff
Description:
The Street Sweeping Program includes regular sweeping all Riverton Public Right of Way roads.   Sweeping Program is intended to collect natural tree and shrubbery shedding, roadway raveling, removal of sediment left by winter snow and ice removal operations and fugitive trash and debris.  Generally, private construction is intended to manage their own project impact and usually City sweeper involvement with private operations are coupled with enforcement.  The swept tailings are separated from other right of way management operations and sweeper operation performance is measured annually at end of the fiscal year.  
Measure of Success:
Evaluate sweeping program performance and draw conclusions.
Responsible Staff:
Stormwater Manager, Purchasing Manager, Related Departments and Divisions
Funding:
Stormwater Utility
Standard Operations Procedures:
Appendix: Conclusion:
2021-2022  
3.9 tons were removed from roads resulting is a considerable amount of pollution from impacting canals, creeks and the Jordan Riverton, see Street Sweeping Annual Report. This program is successful not only for reducing pollutant loads to our water ways but also fulfilling expectations from the general public.  The City went with a new vehicle GPS contract this year this resulted in revisiting how the City measures production.  Staff reported the new approach is more accurate.  
 


6.4: Drainage System Maintenance
Year Executed: 2011
Reference Regulation:
4.2.1.5, 4.2.6.6, 4.2.6.6.1, 4.2.6.6.2, 4.2.6.6.3
Target Pollutants:
Sediment, organics, trash
Audiences:
City Maintenance Staff
Description:
The Hydrovac Program involves cleaning all public stormwater pipes as weather allows.  The hydrovac truck tailings are separated from other right of way management operations and Hydrovac Truck Operation performance is measured annually at end of the fiscal year.  
Measure of Success:
Evaluate hydrovac and channel maintenance operations performance and draw conclusions.
Responsible Staff:
Flood Control Engineer, Maintenance Staff
Funding:
Storm Drain Fee, General Fund
Standard Operations Procedures:
Conclusion:
2021-2022
First full report period with new hydrovac truck see report for program performance.   The Drainage System Maintenance crew operate the hydrovac and camera truck resulting in only 50% production.  In addition, the hydrovac discharge facility is too small for a full time hydrovac operations resulting in production inefficiencies and water weight charges at the landfill.


6.5: Public Infrastructure Retrofit
Year Executed: 2010
Reference Regulation:
4.2.6.8, 4.2.6.9
Target Pollutants:
Trash, debris, organics, and sediment. 
Audience:
Riverton Public Works Department, and Engineering & Stormwater Division staff
Description:

The UPDES regulation requires municipalities to retrofit existing public flood control infrastructure that adversely impacts water quality with systems that infiltrate, achieves evapotranspiration or harvest and reuse stormwater runoff.  Permit reference UTS000001, 4.2.6.9.

Riverton City’s Retrofit program consist of a list of retrofit projects identified and described by Table 1 and Figure 1.

Table 1 Identifies retrofit projects by rank.  This is a working Table and is updated with design descriptions and budgets as approved.  The Table also shows water quality retrofits already completed.

Figure 1 Shows the Riverton City drainage basins and risk indicators warranting retrofits.  The Figure also shows water quality retrofits already completed.

Figure 1 is divided into 4 drainage system types.  Traditional Systems, Detention LID, Retention Systems and Retention LID.  Figure 1 also includes water quality devices.  Water quality devices(WQD) help trap pollution but most of these systems do not infiltrate, evapotranspire or reuse stormwater runoff as required by the UPDES Retrofit Requirement, however, WQD’s do improve water quality and comply with other UPDES requirements.

Figure 1 Riverton City Drainage System Description Summary.

  1. Traditional systems are concrete curb, inlets, pipe and detention systems with low flow type infrastructure. These systems efficiently carry runoff and all contaminates carried with it to water bodies.  These systems also increase runoff volumes because smaller volumes of runoff are infiltrated into the ground. 
  2. Detention LIDs are traditional concrete curb, inlets, and pipe systems but runoff and all urban pollution is discharged onto the detention ponds surfaces that spill, infiltrate and filtered through their vegetated or pervious xeriscape surfaces. Detention LIDs trap urban pollution but during high flow events pollution can be scoured and discharged downstream.
  3. Retention systems are concrete curb, inlets and pipes that drain directly into subsurface soils usually into subsurface open type structures or gravel pore space but do not use surface pervious landscaping or vegetation to help distribute infiltration and filter urban pollution on the surface and more effect above ground biology. Retention systems do a good job and preventing urban pollution from reaching surface water bodies but municipalities who do not require adequate pretreatment will increase the risk of contaminating subsurface water bodies.
  4. Retention LIDs drain runoff through pipes or over the surface to pervious xeriscape or vegetation landscaping resulting in a portion of the runoff infiltrating or to evapotranspire prior draining into the subsurface soils or offsite. Retention LID that distribute runoff evenly across the project site mimic the predevelopment hydrologic condition better than retention LIDs the direct all runoff to a single pocket pond in the low corner of the property.  Well designed retention LIDs can be more effective for managing urban pollution by increasing infiltration biofilter rates.   Retention LIDs also reduce runoff volumes better reducing flood and nuisance water risk by improving overall infiltration capacity.
  5. Water quality devices (WQD) are structure devices that separate urban pollution from runoff. WQD vary widely from cartridge filters, centrifugal and siphon type separate systems.  Filter cartridges can be designed to filter to any level but are expensive.  Siphon systems remove floating material and heavy sediments from runoff but are not effective at removing pollution that dissolves in water and more more susceptible to scour. Centrifugal types are usually more effective at preventing scour, however are also more expensive but neither centrifugal or siphon types will remove water soluble pollutants and both are still susceptible to high flow scour.  WQD were required by City standards from 2003 and the vast majority are siphon types and only a handful are centrifugal types. 

Ranking System

Traditional drainage systems are the most common drainage design of urbanizing communities but most adversely impact runoff quality.  Traditional flood control systems are very efficient at carrying all contaminates in its path directly to water bodies that floats or can be scoured from the roadway and pavement surfaces.  In other words, any urban pollutants like oil, detergents, fertilizers, pesticides and organics intentionally or unintentionally ending up on pavements will be picked up with runoff and dumped directly to our creeks, canals and the Jordan River.  Organics, in fact, despite being natural have a significant negative impact on water bodies simply because of the enormous volumes that collect on roadways.  Organic material decomposes and draws oxygen from the water, in addition, this excess organic material, heat and slow moving water are the primary ingredients of algal blooms we experience almost annually.

The e coli TMDL should also be considered with the retrofit program simply because the overall e coli TMDL reduction regulation.  E coli has many sources including wild animals.  The e coli contribution rank will focus on impacts by pet, farm and equestrian animals.

Riverton began to urbanize 1970’s and the traditional drainage system was the flood control development standard until 2020.  Consequently, 90% of the City flood control system consist of varying levels of the tradition type systems that warrant retrofits as do most cities across the State.  After 2002,  as a result of UDPES regulations most traditional systems were design with water quality devices but only occasionally detention LID.  UDOT had a good detention LID program which was included with the 12600 South Design Build Project.

Since most drainage basins are traditional types the retrofit ranking is pollution risk as a function of land use type and basin size but also flood control and cost metrics.  Basins with more retention, detention LID and retention LID systems and basins effective WQD are ranked lower.

Measure of Success:
Evaluate the success and failure of retrofit projects. 
Responsible Staff:
Flood Control Engineer, Public Works Director
Funding:
Storm Drain Fee, General fund
Standard Operations Procedures:
Stormwater Design Standards and Regulations
Appendix:
Conclusion:
2021-2022
The program is functioning but the program does not currently include a retrofit site ranking system and budgeted projects as expected by State USWAC retrofit guidance document.  Some City projects were designed without an site retrofit evaluation.  More City Department and Division support is necessary.  The Public Works Department and Stormwater Division have retrofitted two properties, see Retrofit Log.



6.6 Right of Way Encroachment Permit
Year Executed: 2010
Reference Regulation and Summary:
4.2.1.5, 4.2.6.6, 4.2.6.6.1, 4.2.6.6.2, 4.2.6.6.3
Implement programs that require compliance with construction activities indicated by UTS00001; including but not limited to; Developoment review standards, templates, checklist and enforcement.
Target Pollutants:
Sediment, fugitive dust, cementitious material, trash, non-stormwater liquids, and nutrients.
Audiences:
Developers, Contractors, Utility Companies, Right of Way Encroachment Officer, UPDES Staff, Flood Control Engineer
Description:
The Right of Way Encroachment Permit program involves a traditional permitting process using a permit application form as a document for creating a contractual relationship and establishing terms and conditions that are supported by ordinance.  The Right-of-Way Encroachment Program facilitates a safe project environment and public infrastructure restoration details and other needs.   As right of way encroachment work exposes drainage systems to construction pollution, the Right of Way Encroachment Program has been expanded to include requirements that facilitate containment of construction related impacts and pollution.  The program facilitates construction related submittals including best management practices (BMPs).   In addition, the program facilitates pre-construction meetings and communication where operational and structural BMPs are explained and reinforced.    The permitting process also facilitates obtaining a Land Disturbance Permit for longer term projects, projects warranting NOI regulation and more detailed SWPPPs.  The criteria for Land Disturbance permits are described by the Right of Way Encroachment Permit SOP.
Measure of Success:
Maintain contractor communication log for site exposures and operation concerns, the BMP direction provided and the response by the contractor.
Responsible Staff:
Right-of-Way Encroachment Officer, Flood Control Engineer
Funding:
Storm Drain Fee and General Fund
Program Documents:
Conclusion:
2021-2022
The Right of Way Encroachment Program is adequate.   Most permit applicants still need regular BMP maintenance reminders, but overall non CGP construction exposures and operations are adequately contained.    
 



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