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STORMWATER POLLUTION PREVENTION PLAN THE UNIVERSITY OF MICHIGAN - FLINT FACILITIES & OPERATIONS COMPLEX Central Energy Plant Building, Hubbard Building and Adjacent Parking Lot 602 and 502 Mill Street Flint, MI 48502 December 2016

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Page 1: STORMWATER POLLUTION PREVENTION PLAN · 2.3 CERTIFIED OPERATOR AND STORMWATER MANAGEMENT ... requires that the Stormwater Pollution Prevention Plan ... which now serves as UM-Flint’s

STORMWATER POLLUTION PREVENTION PLAN

THE UNIVERSITY OF MICHIGAN - FLINT

FACILITIES & OPERATIONS COMPLEX Central Energy Plant Building, Hubbard Building and Adjacent Parking Lot

602 and 502 Mill Street

Flint, MI 48502

December 2016

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STORMWATER POLLUTION PREVENTION PLAN

UNIVERSITY OF MICHIGAN-FLINT

Facilities and Operations Complex

Flint, Michigan

TABLE OF CONTENTS

SWPPP CERTIFICATION..............................................................................................................3

1.0 INTRODUCTION.....................................................................................................................4

1.1 PURPOSE......................................................................................................................4

2.0 SITE MAP AND FACILITY DESCRIPTION.........................................................................5

2.1 UNIVERSITY OF MICHIGAN-FLINT (UMF) CAMPUS DESCRIPTION..............5

2.2 FACILITY DESCRIPTION..........................................................................................6

2.3 CERTIFIED OPERATOR AND STORMWATER MANAGEMENT TEAM............8

3.0 SOURCE IDENTIFICATION...................................................................................................9

3.1 BEST MANAGEMENT PRACTICES.......................................................................10

3.2 FACILITY DRAINAGE.............................................................................................10

4.0 SPILL AND LEAK HISTORY...............................................................................................10

5.0 STORMWATER DISCHARGE SAMPLING DATA............................................................11

6.0 SWPPP MAINTENANCE......................................................................................................11

6.1 PREVENTATIVE MAINTENANCE.........................................................................11

6.2 COMPREHENSIVE SITE INSPECTION..................................................................11

6.3 HOUSEKEEPING PROCEDURES............................................................................12

6.4 MATERIAL HANDLING AND STORAGE REQUIREMENTS..............................12

6.5 SPILL PREVENTION AND RESPONSE..................................................................13

6.6 EROSION AND SEDIMENT CONTROL.................................................................13

6.7 EMPLOYEE TRAINING............................................................................................13

6.8 SIGNIFICANT MATERIALS EXPECTED TO BE IN STORMWATER

DISCHARGES............................................................................................................13

6.9 STRUCTURAL CONTROLS FOR PREVENTION AND

TREATMENT.............................................................................................................14

6.10 REVISIONS...........................................................................................................14

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STORMWATER POLLUTION PREVENTION PLAN

UNIVERSITY OF MICHIGAN-FLINT

Facilities and Operations Complex

Flint, Michigan

TABLE OF CONTENTS CONTINUED

FIGURES

Figure 1 Site Location Map..................................................................................................16

Figure 2 Campus Map..........................................................................................................17

Figure 3 Aerial Photo of Facilities and Operations Complex..............................................18

Figure 4 Significant Materials Map......................................................................................19

Figure 5 Outfall Map............................................................................................................20

TABLES

Table 1 Facilities and Operations Significant Materials.....................................................22

Table 2 Facilities and Operations Best Management Practices..........................................26

Table 3 Facilities and Operations Significant Spills and Leaks..........................................27

Table 4 Facilities and Operations Stormwater Discharge Sampling Data..........................27

Table 5 Facilities and Operations Preventive Maintenance Tasks.....................................28

RESOURCES

Resources.......................................................................................................................................29

APPENDICES

Appendix A Certificate of Coverage and General Permit MIS040090

Appendix B Stormwater Operator Certification

Appendix C SWPPP Inspection Forms (Annual and Quarterly)

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STORMWATER POLLUTION PREVENTION PLAN

UNIVERSITY OF MICHIGAN-FLINT

Facilities and Operation Complex

Flint, Michigan

SWPPP CERTIFICATION

The University of Michigan National Pollutant Discharge Elimination System (NPDES) permit

requires that the Stormwater Pollution Prevention Plan (SWPPP) shall be reviewed and signed

by the Certified Stormwater Operator(s) and by either the permittee or an authorized

representative in accordance with 40 CFR 122.22. The SWPPP shall be retained on-site at the

facility which generates the stormwater discharge.

I certify under penalty of law that this document and all attachments were prepared under my

direction or supervision in accordance with a system designed to ensure that qualified personnel

properly gathered and evaluated the information submitted. Based on my inquiry of the person

or person who manages the system, or those persons directly responsible for gathering the

information, the information submitted is, to the best of my knowledge and belief, true, accurate,

and complete. I am aware that there are signification penalties for submitting false information,

including the possibility of fines and imprisonment for knowing of violations.

Stormwater Program Manager and Permit Contact, Ann Arbor Campus

Signature: __________________________________ Date:__________________

Name (printed): Stephen M. O’Rielly, U-M Ann Arbor

UMF SWPPP Facility Manager

Signature: __________________________________ Date:__________________

Name (printed): George Hakim, UM-Flint

UMF Stormwater Program Manager and Certified Stormwater Operator

Signature: __________________________________ Date:__________________

Name (printed): Michael Lane, UM-Flint Certification No.: I-07420, C-10193

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1.0 INTRODUCTION

In 2001, The University of Michigan-Ann Arbor (UMA2) received coverage under the Michigan

Department of Environmental Quality (MDEQ) National Pollutant Discharge Elimination

System (NPDES) Municipal Separate Stormwater drainage System (MS4) (Permit No.

MI00053902 issued September 26, 2001). This 2001 permit did not include the University of

Michigan-Flint (UMF) campus.

On April 15, 2009, UMA2 received coverage under the MDEQ, NPDES, MS4 Jurisdictional

General Permit (Permit No. MIS040090). This is the first permit that included UMF in its

coverage. As a condition of the coverage under MIS040090, The University of Michigan (U-M)

updated its Stormwater Management Program Plan (SWMPP) in May 2010 to include the

regional campuses (Dearborn and Flint).

MIS040090 was withdrawn on November 30, 2010, and coverage was continued under

MI0053902, which does not require the implementation of SWPPPs for municipal fleet

maintenance and storage yards/facilities. However, the SWMPP prepared in association with

MIS040090 was approved by MDEQ, and therefore UMF is required to develop the SWPPP as

directed in the SWMPP.

The UMF is required to prepare a SWPPP to comply with Section 8.3.3 of the U-M’s 2010

SWMPP. Section 8.3.3 specifically requires all municipal fleet maintenance and storage

yards/facilities that are not regulated as industrial activities to develop and implement a SWPPP,

therefore this plan encompasses the UMF Facilities and Operations (F&O) complex area. The

SWPPP will be developed in accordance with the Appendix to MDEQ NPDES MS4 Permit No.

MIS040090.

1.1 Purpose

This SWPPP has been developed in accordance with the requirements for fleet

maintenance and storage yards detailed in Section 8.3.3 of The U-M’s 2010 SWMPP.

The goal of this UMF SWPPP is to improve water quality by maximizing control of

significant materials and reducing the level of such materials in stormwater so the

discharges from the F&O complex site will not cause a violation of Michigan’s surface

water quality standards. Section 8.3.3 of The U-M’s 2010 SWMPP specifically requires

that a SWPPP include:

A. Source Identification

i. A site map

ii. A list of all significant materials that could pollute stormwater

iii. An evaluation and written description of the reasonable potential for contribution of

significant materials to run off

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iv. Identification of the discharge point(s) through which material may be discharged if

released

v. A listing of all significant spills and significant leaks of significant polluting

materials

vi. A summary of existing stormwater discharge sampling data (if available)

B. Preventative Measures and Source Controls, Non-Structural

i. A preventative maintenance program

ii. A schedule for comprehensive site inspection

iii. A description of good housekeeping procedures to maintain a clean, orderly facility

iv. A description of material handling procedures and storage requirements for

significant materials

v. Identification of areas which, due to topography, activities, or other factors, have a

high potential for significant soil erosion

vi. A description of employee training programs

vii. Identification of significant materials that may be present in stormwater discharges

following implementation of the non-structural preventative measures and sources

controls

C. Structural Controls for Prevention and Treatment

a. A description of the structural controls

D. Compliance

i. Ensure the plan is regularly evaluated and updated

ii. Ensure only stormwater is discharged from the facility or that an NPDES permit

covers non-stormwater discharges for such discharges.

2.0 SITE MAP AND FACILITY DESCRIPTION

2.1 University of Michigan-Flint Campus Description

The UMF is located at 303 East Kearsley Street, Flint, Michigan. The institution is

located on 70 acres in the downtown area of the city of Flint, Michigan and has

property immediately adjacent to the Flint River (see Figure 1 and Figure 2). UMF is

a full service institution involved in higher education that also provides housing,

power, maintenance, medical, transportation, and food services. This SWPPP is for

the F&O complex which consists of the 1) Central Energy Plant, 2) Hubbard

Building, and 3) adjacent parking lot (see Figure 3), which are all located south of

the river, on the east side of the campus.

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2.2 Facility Description

The UMF Central Energy Plant (CEP) is located at 502 Mill Street in Flint, Michigan,

approximately 100 feet from the Hubbard Building and adjacent parking lot. The CEP

building is a single story facility with multi-level catwalks throughout and a full-

functioning basement. CEP provides steam and hot water for the infrastructure of the

institution. Natural gas fired boilers are used to power the institution’s operations.

250-gallons diesel fuel and 500-gallons ethylene glycol are located inside the building

with secondary containment. 200-gallons of ethylene glycol are located on the roof of

the building.

The UMF Hubbard Building and adjacent parking lot is located at 602 Mill Street in

Flint, Michigan. The Hubbard Building is a single story building above ground, with

a partial basement. The Hubbard Building houses the following service units:

Architectural and Engineering Services, Building Maintenance, Business Operations,

Custodial Services, Fleet Maintenance, Grounds Maintenance, Materials

Management, and Skilled Trades. In addition, F&O and DPS administrative offices

are also located in the Hubbard Building. Chemicals used to support service unit

activities in the building are stored inside the Hubbard Building. These materials are

ordered as needed. Quantities are variable, but typically are stored in volumes of five

gallons or less. The exceptions are the four to six larger containers of motor oil and

related vehicle fluids stored in 55-gallon drums and on spill pallets with secondary

containment.

The Architectural and Engineering Services Unit provides a wide range of services

related to renovation and construction design and energy management and

conservation studies. Architectural and Engineering services does not utilize any

significant materials which would be of concern to this SWPPP.

The Building Maintenance Unit provides general building maintenance and

installation services such as lock/door hardware, plumbing, window, ceiling, wall,

and floor repair and replacement; classroom equipment, office furniture and

departmental equipment repair; core assembly; and minor installations, This unit also

operates a woodshop in the building. Environmental control and energy management

is implemented by building control and management systems located in the Hubbard

Building. All supplies, including paints, primer, solvents, adhesives, cleaners and

other related materials, and equipment needed for Building Maintenance are located

in the Hubbard Building and outdoor storage shed. As described above, materials are

ordered as needed. Quantities are variable, but typically are stored in volumes of five

gallons or less. More accurate accounts of materials can be found in the EHSA

system, which now serves as UM-Flint’s Chemical Inventory System.

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The Business Operations Unit is typically the first contact from the University

community when service is requested. Business Operations include clerical and

secretarial services which don’t utilize any significant materials.

The Custodial Services Unit provides routine housekeeping services to the University

related to the cleaning of restrooms, locker rooms, pool areas, public spaces, dining

areas, classrooms, general labs, lecture halls, offices, and non-hazardous material spill

clean-up. Some custodial chemicals such as cleaners, degreasers, floor stripper,

solvents, etc. are stored in the building. As described above, materials are ordered as

needed. Quantities are variable, but typically are stored in volumes of five gallons or

less, and are accounted for within the Chemical Inventory System.

The Fleet Maintenance Unit is based in the Hubbard Building shop area and provides

routine and emergency maintenance of University vehicles and motorized equipment

on the UMF campus. Chemical supplies stored in this area include motor oil, grease,

cleaning solvents, some paint, lubricating fluids, coolants, etc. As described above,

materials are ordered as needed. Quantities are variable, but typically are stored in

volumes of five gallons or less, and are accounted for within the Chemical Inventory

System. The exceptions are the four to six larger containers of motor oil and related

vehicle fluids stored in 55-gallon drums and on spill pallets with secondary

containment.

The Grounds Maintenance Unit provides landscaping care for campus grounds which

include walkway, roadway and parking lot maintenance; snow/ice removal; turf care

programs; irrigation system installation and maintenance; tree, shrub and flower

planting and maintenance; exterior signage, installation and maintenance; and pest

control. Equipment used for these services is stored and maintained at the F&O

complex. Chemicals used by this unit are stored in the Hubbard building as well as in

the Hazardous Material Storage building within the complex. Chemicals include

deicing solutions, salt, oils, oils, herbicides, pesticides, fuel, cleaners, etc. As

described above, materials are ordered as needed. Quantities are variable, but

typically are stored in volumes of five gallons or less and are accounted for within the

Chemical Inventory System.

The Materials Management/Mailroom Unit is responsible for receiving, shipping and

delivering packages, stocking and dispensing maintenance materials, and tracking

capital equipment throughout campus. The central receiving area is located at the

Hubbard Building and is used campus wide for all items where a purchase order is

issued. Packages are inspected for visual damage by the Material Services staff. Spill

kits are located in the shipping/receiving area for spill prevention.

The Skilled Trades Unit provides maintenance and installation services related to all

utilities which include: maintenance of the Central Energy Plant and the Utility

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Distribution Systems which supply steam and chilled water, domestic water, and

primary electrical services; heating, ventilation, and air conditioning (HVAC)

maintenance and service; operation or repair of domestic water and wastewater

systems; operation of other piped utilities (natural gas, compressed air, vacuum and

high purity water); electrical and lighting repair and circuit breaker reset; thermostat

and building environmental control repair and recalibration; Energy Management

System operation and maintenance; installation, relocation and repair of lighting,

outlets, and switches, etc.; and laboratory fume hood operation and maintenance.

An outdoor storage shed is located along the northeast portion of the complex and is

used to store road salt (maximum of 50 tons), as well as, grounds landscaping and

maintenance equipment, such as mowers, plow blades, tools, applicator equipment,

Bobcat, earth moving equipment, carts, and vehicles (if there is room).

The chemicals stored in the Hazardous Materials (HazMat) Building and additional

ASTs and USTs in the adjacent parking lot support the activities and operations

related to the Hubbard Building and CEP. The HazMat building stores regulated

waste, Grounds Maintenance chemicals and fuels, and have a built in secondary

containment. Beneath the adjacent parking lot area are three USTs that each have the

capacity of containing 30,000-gallons of heating oil. The three ASTs contain 5,000-

gallons of magnesium chloride brine solution, 500-gallons of gasoline, and 1,000-

gallons of diesel fuel.

Disposal of any waste chemicals and hazardous materials is coordinated by UMF

Environment, Health and Safety (EHS). Other maintenance, repair, renovation, and

construction related activities not mentioned above are typically managed/overseen

by F&O. Outside contractors may be hired to assist in campus related work activities

such as pest control, equipment installation, electrical/mechanical equipment repairs,

plumbing problems, constructions/renovations.

Waste disposal of non-hazardous waste is provided by a commercial waste hauler

through contracts administered by F&O. Regular trash is placed in compactors and

containers by the Housekeeping Services Unit during daily operations. Other large

objects, construction waste, or hazardous materials are never placed in trash

receptacles.

2.3 Certified Operator and Stormwater Management Team

In addition to the SWPPP, the University also operates under an Emergency

Response Plan (ERP) for safely and effectively responding to emergencies on the

campus, a Spill Prevention Control and Countermeasure (SPCC) plan for bulk oil

storage, and a Pollution Incident Prevention Plan (PIPP) for polluting materials.

Current copies of the ERP, SPCC, PIPP and SWPPP are provided to key individuals

in F&O, particularly those with responsibility over the purchase, use, and storage of

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significant materials used in the Hubbard and CEP buildings. Additionally, copies

are stored by EHS and are available for review. A copy of the SWPPP is also stored

and available for review in the UMF Hubbard Building F&O administration offices.

Individuals involved in implementing the UMF SWPPP and their contact information

are as follows:

Permit Contact, Ann Arbor Campus

Mr. Stephen M. O’Rielly

Manager, Environmental Protection and Permitting

Occupational Safety and Environmental Health

The University of Michigan

1239 Kipke Drive, Ann Arbor, MI 48109

Phone: (734) 615-4642

Email: [email protected]

UMF SWPPP Facility Manager

Mr. George Hakim, Director

Alt: Mr. Tim Barden, Manager

Facilities and Operations

The University of Michigan-Flint

602 Mill Street, Flint, MI 48502

Phone: (810) 762-3223

Direct: (810) 762-3226

Email: [email protected]

UMF Stormwater Program Manager and Certified Stormwater Operator

Mr. Michael Lane, Director

Environment, Health and Safety

The University of Michigan-Flint

303 East Kearsley Street, Flint, MI 48502

801 Northbank Center

Phone: (810) 766-6763

Cell: (810) 919-1709

Email: [email protected]

3.0 SOURCE IDENTIFICATION

This section describes potential sources and significant materials that may pollute stormwater

(See Table 1 and Figure 4 for specific significant materials relevant to the F&O complex).

Significant materials include any material which could degrade or impair water quality,

including, but not limited to: raw materials; fuels; solvents, detergents, and plastic pellets;

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finished materials, such as metallic products; hazardous substances designated under Section

101(14) of the Comprehensive Environmental Response, Compensation, and Liability Act

(CERCLA); any chemical the facility is required to report pursuant to Section 313 of the

Emergency Planning and Community Right-to-Know Act (EPCRA); polluting materials (oil and

any material, in solid or liquid form, identified as a polluting material under the Part 5 Rules

[Rules 324.2001 through 324.2009 of the Michigan Administrative Code]); Hazardous Wastes as

defined in Part 111 of the Michigan Act; fertilizers; pesticides; and waste products, such as

ashes, slag, sludge, and plant and animal wastes that have the potential to be release with storm

water discharges. These sources include identification of residual contaminants that may be

found in items stored outside (example: oil, rust, or debris from vehicles; fertilizer; salt; air

particles which have settled). Reference Table 1.

3.1 Best Management Practices

Best management practices (BMP) are implemented at the facility to prevent or

reduce the potential pollutants from entering the stormwater network and migrating

off-site. The BMPs identified in Table 2 should be followed and maintained for each

significant material source identified. Refer to Section 6.1 on tracking methods.

3.2 Facility Drainage

The topography of the F&O complex is generally flat. The parking lot between the

Hubbard Building and the CEP is completely paved so that all stormwater flows into

the onsite stormwater system. There are five stormwater catch basins on the F&O

complex. The facility’s stormwater system discharges through a series of outfalls

directly to the Flint River. Floor drains inside the F&O buildings discharge to the City

of Flint sanitary sewer system. (See Figure 5 for storm drain outlets and

connections.)

4.0 SPILL AND LEAK HISTORY

A listing of significant spills and leaks of polluting materials that occur at the F&O complex site

will be provided in Table 3. No releases of oils or other polluting materials in excess of

reportable quantities under Michigan’s Part 5 rules, CERCLA or the Clean Water Act have

occurred at the F&O complex in the three years prior to the effective date of the Stormwater

Certificate of Coverage (MIS040090), April 15, 2009 to present.

Spill Reports are submitted to the MDEQ, copies are forwarded to UMA2 OSEH, and filed at

UMF EHS and are available for review at any time. All releases to stormwater systems will be

controlled in accordance with the SWPPP. The SWPPP is reviewed following significant spill

events to the storm sewer and updated as appropriate within 14 calendar days of obtaining

knowledge of the spill or leak.

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5.0 STORMWATER DISCHARGE SAMPLING DATA

UMF has not done any stormwater discharge sampling at the outfalls. In 2012-2013, Soil &

Materials Engineers, Inc. (SME) conducted dry weather inspections which consisted of

analytical testing in the catch basins. The January 2013 Dry Weather Screening Report is

available through EHS.

Consumers Energy is currently investigating a historical Manufactured Gas Plant (MGP) site.

The MGP site is not located within the boundaries of the F&O SWPPP site, however, there is a

storm drain network originating from the above referenced F&O site that does go through the

MGP site before reaching the outfall at the Flint River. Part of this active investigation involves

looking at the conditions along the Flint River and evaluating the release of petroleum and MGP

related material. Consumers Energy is planning a remediation response in and along the river in

2017. This activity is being closely monitored by the MDEQ. If outfall data from the F&O site is

collected by the university, it will be summarized in Table 4.

6.0 SWPPP MAINTENANCE

SWPPP maintenance describes the non-structural stormwater controls implemented at the F&O

complex to prevent polluted stormwater discharge. The controls consist of an active preventive

maintenance program that involves the inspection and maintenance of stormwater management

devices and routine inspections of various facility operations to ensure compliance.

6.1 Preventative Maintenance

The U-M’s 2010 SWMPP requires a preventative maintenance program that includes

routine inspection and maintenance of stormwater management devices. The

maintenance procedures are employed as needed, or at least annually, to ensure

proper function of the stormwater system. Inspection records and corrective actions

will be maintained electronically through the Work Order System for a minimum of

three years. F&O will provide copies of inspection records and supporting documents

to EHS upon request and on an annual basis.

A description of the preventative maintenance tasks for the F&O complex, along with

responsible person/department, and frequency are included in Table 5. The tracking

mechanism used for all maintenance tasks is F&O’s Work Order System, an

electronic record keeping database.

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6.2 Comprehensive Site Inspection

Quarterly inspections will be implemented as BMPs to further minimize the potential

for stormwater pollution. Inspections will be conducted by an employee who has been

trained and is familiar with the contents and purpose of this plan, as well as the site’s

operations and maintenance activities, and the inspection checklist. Stormwater

compliance inspections may be combined with the SPCC/PIPP inspections.

If an inspection indicates the need for corrective action, it will be noted on the

appropriate form, and the date the corrective action is completed will be recorded and

initialed by the inspector. Copies of completed inspection documents will be provided

to EHS.

6.3 Housekeeping Procedures

Good housekeeping procedures are maintained at the F&O complex to ensure the

facility is clean and orderly, promoting a safe work environment and decreasing

pollution exposure potential. Spills or leaks will be cleaned up in a timely manner.

Quarterly facility inspections are conducted to verify good housekeeping procedures

are conducted. These inspections are completed in conjunction with the quarterly

preventative maintenance inspections.

6.4 Material Handling Procedures and Storage Requirements

It is a shared responsibility of all F&O employees to follow environmentally sound

material handling procedures and storage requirements. Each UMF employee

receives an appropriate level of training dependent on their specific job duties.

Hazardous waste material handling procedures and storage requirements are detailed

in the UMF Hazardous Waste Management Program. Emergency spill procedures are

outlined in the UMF Emergency Response Plan and through the Hazard

Communication Program. UMF’s SPCC and PIPP provide guidelines for preventing

the release of petroleum substances and polluting materials into the environment.

(These documents can be found at www.umflint.edu/ehs.) Spill response and

containment equipment is readily available in a number of areas including the

Hubbard loading dock, Hazardous Material (HazMat) storage building, CEP, and

adjacent to the above-ground storage tank (AST) location in the Hubbard parking lot,

to increase preparedness and response time if a spill were to occur.

During loading and unloading activities, designated personal are present, drains are

protected, and spill kits are available throughout the facility. Any leaks or drips are

cleaned up immediately. Materials are directly unloaded into buildings and are stored

within the building to prevent exposure to stormwater. Contractors are required to

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comply fully with the University’s Contractor Safety requirements. F&O project

managers, employees, as well as EHS, will monitor and enforce these requirements.

Outdoor storage units are covered and closed. Containers are properly labeled, stored,

sealed/closed, and protected from weather/rain. Additionally, as part of the

SPCC/PIPP, the University incorporates secondary containment for bulk storage

containers.

6.5 Spill Prevention and Response

The UMF has a well-established campus-wide ERP and SPCC/PIPP. The ERP

includes response guidelines for incidental and large hazardous material spills and

releases. The SPCC/PIPP plan provides guidelines for preventing the release of

petroleum substances and polluting materials into the environment, especially to

stormwater which may discharge to the surface waters of the state. The SPCC/PIPP

provides guidelines for inspections (including bulk materials stored in these areas),

preventative maintenance, commitment of resources, and emergency response

procedures that will be implemented consistent with the ERP in the event of a spill at

the UMF campus. In the event that a spill is beyond the response capability of UMF

staff, an outside environmental contractor will be contacted to assist in the response.

6.6 Erosion and Sediment Control

As required in Part 91 (Soil Erosion and Sedimentation Control) of the Natural

Resources and Environmental Protection Act (NREPA), the U-M has an integral Soil

Erosion and Sediment Control (SESC) procedure as part of the stormwater program.

Preventative soil erosion measures such as silt fencing, erosion blankets, and street

sweeping are practiced during times of construction. The vegetative landscaping

along the Flint River helps keep the potential for soil erosion low. Currently, the F&O

complex does not have any areas with a high potential for significant erosion due to

topography, activities, or other factors.

6.7 Employee Training

Employee training is provided annually to key personnel working at the site to teach

the basics and goals of this SWPPP. This is a BMP that raises awareness about

stormwater protection, and further reduces the potential for stormwater pollution.

Specific topics include: 1) the purpose and goals of the UMF SWPPP, and 2) current

BMPs including good housekeeping, spill prevention and response, preventative

maintenance, and inspections. SWPPP training may be in conjunction with general

stormwater awareness training provided to employees and contractors.

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General employee training conducted by EHS will be maintained by EHS. Job

specific training above and beyond EHS employee training will be maintained by

F&O.

6.8 Significant Materials Expected to be in Stormwater Discharges

The non-structural controls previously described, which include maintenance of the

structural stormwater controls, are expected to minimize or eliminate discharge of

significant materials from the site via stormwater. The most likely significant

materials to be discharged are petroleum compounds from leaking vehicles parking

outdoors at the F&O complex, deicing materials from the storage shed, and/or from

spill during loading/unloading operations of the above ground storage tanks.

6.9 Structural Controls for Prevention and Treatment

When non-structural controls do not adequately protect surface waters from

significant materials, structural controls are implemented. The structural controls

address these situations in Table 1. There are several storm drain catch basins in the

parking lot area. The stormwater network leads to outfall ST07-01 into the Flint

River.

6.10 Revisions

The SWPPP was developed in close consultation with F&O. Revisions to this

SWPPP are completed by EHS and shared/discussed with F&O personnel. Michael

Lane will administer the implementation of the SWPPP on the UMF campus.

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STORMWATER POLLUTION PREVENTION PLAN FIGURES

Figure 1 Site Location Map..................................................................................................16

Figure 2 Campus Map..........................................................................................................17

Figure 3 Aerial Photo of Facilities and Operations Complex..............................................18

Figure 4 Significant Materials Map......................................................................................19

Figure 5 Outfall Map............................................................................................................20

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FIGURE 1: Site Location Map

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FIGURE 2: Campus Map

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FIGURE 3: Aerial Photo of Facilities and Operations Complex

Hubbard

Central Energy Plant

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FIGURE 4: Significant Materials Map

(see attachment)

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FIGURE 5: Outfalls

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STORMWATER POLLUTION PREVENTION PLAN TABLES

Table 1 Facilities and Operations Significant Materials.....................................................22

Table 2 Facilities and Operations Best Management Practices..........................................26

Table 3* Facilities and Operations Significant Spills and Leaks..........................................27

Table 4* Facilities and Operations Stormwater Discharge Sampling Data..........................27

Table 5 Facilities and Operations Preventive Maintenance Tasks.....................................28

*Note: Table 3 and Table 4 are available for record keeping

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Table 1 - Facilities and Operations Significant Materials

Permit No. MIS049000 Appendix

1.b.2

Storage Areas and

Activity Areas

Significant Materials

Exposure Method

Reasonable Potential

Evaluation (high,

medium, low)

Specific Non-Structural

Control

Specific Structural Control

Reasonable Potential Description, Other Notes

a) Loading, unloading, and other material handling operations

Shipping and receiving areas at Hubbard and CEP buildings, the small/contained HazMat building, storage sheds, AST and UST

Deicing material (solid and liquid brine <5,000-gal), diesel fuel and gasoline for fleet, fuel, oil for CEP (250-gal diesel fuel, 700-gal ethylene glycol), bulk lubricating oils, waste oil, and misc. pesticides/ insecticides, stored inside the HazMat storage building (<5-gal), AST (5,000-gal magnesium chloride, 500-gal gasoline,1,000-gal diesel fuel), and UST (90,000-gal fuel oil), 50 tons road salt

Spillage during material handling operations

Medium

Material handling procedure for loading/unloading, SPCC training, HazCom training, and routine inspections

Materials are stored with secondary containment. Cover drain prior to loading and unloading activities Road salt stored inside

The greatest risk for spills is when loading/unloading materials. Otherwise, all materials stored outdoors are stored in secondary containment or stored indoors

Employees are provided training and spill catchment and clean up equipment are in close proximity to loading/unloading operations

Area is secured/locked after hours and is

under camera surveillance. Typical hours are Monday-Friday, 6:00AM-6:00PM with some limited weekend and evening hours

Other quantities of chemicals are variable, but typically are stored in volumes of five gallons or less. Materials ordered as needed.

b) Outdoor storage including secondary containment structures

1,500-gal. ASTand 1, 1000 gal AST for vehicle fuel

Gasoline and diesel fuel Outdoor storage and loading/unloading operations

High Material handling procedure/ inspections

Double-walled fuel tanks and overfill alarm/auto shutoff

See above comments, materials stored in secondary

containment, etc.

1, 5000-gal. AST deicing material/pump

MgCl brine solution Outdoor storage and loading/unloading operations

High Material handling procedure/ inspections

Secondary containment on deicing solution

3, 30,000-gal back-up/ emergency underground storage tanks

#2 fuel oil for CEP Potential during loading/unloading operations

High

Routine inspections and operational controls

Double-walled fuel tanks, and overfill alarm

Outside service and employee vehicle parking

Fuel, vehicle fluids Outdoor storage

Low General area awareness and visual Inspections

None

c) Outdoor manufacturing or processing activities

Welding, repair, and assembly of large equipment, staging

Potential Debris Outdoor maintenance activities

Low Material and equipment handling procedure

Storm drain in area has protective fabric filter insert

Occasional outdoor welding, but exposure is very limited and pollution potential is very low.

No discharge associated.

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Table 1 - Facilities and Operations Significant Materials

Permit No. MIS049000 Appendix

1.b.2

Storage Areas and

Activity Areas

Significant Materials

Exposure Method

Reasonable Potential

Evaluation (high,

medium, low)

Specific Non-Structural

Control

Specific Structural Control

Reasonable Potential Description, Other Notes

d) Significant dust or particulate-generating processes

Street sweeping or brushing

Dust

Outdoor maintenance activities

Low

Material handling procedure

Equipment

UMF Grounds Team sweeps/cleans area covered

by this SWPPP at least in the spring, mid -summer, and fall, or more frequently, if needed.

Street sweeping across the campus and adjacent areas/roadways is performed in conjunction with the City of Flint and UMF Grounds Team in the

spring, mid -summer, and fall on all campus roads.

e) Discharge from vents, stacks, and air emission controls

CEP boilers are covered under an air permit through MDEQ

Combustion of natural gas and oil (used only for emergency purposes)

Through stack emission onto pavement

Low

Permitted and operated through MDEQ

None No exposure.

A chance of air particles settling onto pavement is very insignificant and unlikely.

f) On-site waste disposal practices

General refuse dumpsters, recycling containers, and grounds and landscaping debris.

Potential for rainfall accumulation in refuse container (which could cause rust and then cause a hole in the container and leak)

Spillage during loading and unloading, adequate cover of dumpsters, sweeping of area

Medium

Waste handling procedures/ inspections

All refuse containers have covers, frequent sweeping and cleanup of storage compound, storm drain in area has protective fabric filter insert

Surrounding drains are protected to prevent runoff

from rain/snow

Hubbard lot is swept on a quarterly basis to prevent debris from entering storm drains.

Construction and landscaping 40 yard open top is

covered every time the container is emptied. Additionally, the cover is always available to contain waste and debris to prevent pollution in the storm drains.

Empty trash containers, drums, and pails are

stored upside down to avoid accumulation of stormwater.

Materials could drain to ST07 outfalls.

Waste oil (55 gallon containers)

Waste oil Spillage during loading and unloading, adequate cover of dumpsters, sweeping of area

Medium Waste handling procedures/ inspections

Secondary containment, secured and protected from rain

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Table 1 - Facilities and Operations Significant Materials

Permit No. MIS049000 Appendix

1.b.2

Storage Areas and

Activity Areas

Significant Materials

Exposure Method

Reasonable Potential

Evaluation (high,

medium, low)

Specific Non-Structural

Control

Specific Structural Control

Reasonable Potential Description, Other Notes

g) Maintenance and cleaning of vehicles, machines and equipment

Dry cleaning of vehicles and wash down of grounds equipment

Grass clippings, dirt, debris

Spray down of lawn equipment could lead to potential runoff of grass and dirt to drains

Medium

Procedures limit what can be sprayed down

Filter fabric catches grass and debris

If car washing is to occur, it is done off site at a carwash facility.

Grounds mowers are sprayed down in the rear of the building after each use. The rear drain is protected with fabric and cleaned out as necessary to prevent clippings from going into the drain.

Controls of what can be sprayed down (ei: no detergents, only items that can be captured by the inlet filters).

h) Areas of exposed and/or erodible soils

NA NA NA NA NA NA NA

i) Sites of Environmental Contamination listed under Part 201

Historical fuel oil tank release, tanks removed, remediation completed in 2006 and annual GW monitoring continues

Oil

Potential digging of the site

Low

NA

NA Tanks were removed and remediation in the area was completed in 2006.

Annual ground water testing and oversight from MDEQ.

Trained staff are very aware of the situation

j) Areas of significant material residues

NA NA NA NA NA NA NA

k) Areas where animals congregate (wild or domestic) and deposit wastes

NA

NA

NA

NA

NA

NA

NA

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Table 1 - Facilities and Operations Significant Materials

Permit No. MIS049000 Appendix

1.b.2

Storage Areas and

Activity Areas

Significant Materials

Exposure Method

Reasonable Potential

Evaluation (high,

medium, low)

Specific Non-Structural

Control

Specific Structural Control

Reasonable Potential Description, Other Notes

l) Other areas where stormwater may contact significant materials

Compost and soil storage North of Flint River

Mulch, wood chips, topsoil, compost, stones

During rain events, it is possible for run off on these materials

Low

Material handling procedure

Drain protection, and stone filters placed before the drains

Grounds Employees make sure drain protection is in place (fabric).

Mill Street, Harrison, UPAV, and NBC Parking Structures

Debris, vehicle fluids

Ramp wash down performed annually

Medium

Material and equipment handling procedure

Filter Fabric/Drain socks to catch debris and vehicle fluids

Employees install fabric/drain socks prior to starting wash down procedures in ramp including the sweeping of the decks.

Once operations are performed, the fabrics/socks are discarded appropriately.

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Table 2 – Facilities and Operations Best Management Practices

Responsibilities of Best Management Practice

Custodial Services

Daily Services Dispose and store cleaning chemicals properly

Disposal

Dumpsters are covered and wastewater goes to proper sanitary drains. Dispose of cleaning

equipment and shop vacuum waste properly

Grease waste and grease containers are inspected quarterly at a minimum

Special Cleaning or

Projects

If hazardous spills occur, contact EHS or DPS. Non-Hazardous spills should be cleaned

up properly

Responsibilities of

Maintenance

General

Repairs/Replacement

Cleanup equipment and dispose of waste properly

Installations Ensure no cross connections of drains exist during repairs/new installations

Carpentry work Dispose of drywall, dust, paint, and other supplies properly

Shelters Ensuring dumpsters are covered and loading docks are clean of debris

Responsibilities of

Skilled Trades

Maintenance Ensure proper disposal of waste and materials

Operation

Management

Ensure proper servicing of equipment and utility systems to prevent leaks, spills, and

accidents

Identification Identify sewer drains during repairs and installation, confirm proper connection, and make

repairs if encountered. Add additional signage to areas of special concern

Inspection

Follow standard operating procedure and record any concerns with utility systems an

notify proper departments

Repairs Ensure appropriate discharge when repairing water systems

Responsibilities of

Material Management and Fleet Maintenance

Provide shelter over

loading dock

Overhead cover will prevent materials stored in the receiving area from washing into the

storm drain.

Drains Identify locations of storm drains and develop means to cover or block if a spill occurs.

General

Repairs/Replacement

Equipment is cleaned up properly and waste is disposed of in the proper drain

*Refer to Section 6.1 on tracking methods.

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Table 3 - Facilities and Operations Significant Spills and Leaks

Date Location

Incident

Description

& Material

Volume Enter Storm

Sewer? Corrective Action

*No reported Significant Spills or Leaks as of November 2014. See Section 4.0: Spill and Leak

History.

Table 4 - Facilities and Operations Stormwater Discharge Sampling Data

Date

Sampled

Outfall /

Location Parameter

Result

(mg/l) Suspected Sources Corrective Action

*Stormwater sampling occurred with dry screening, but not with outfall. See Section 5.0:

Stormwater Discharge Sampling Data.

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Table 5 - Facilities and Operations Preventive Maintenance Tasks

Preventive Maintenance

Activity

Responsibility (department)

Frequency (weekly, monthly,

quarterly, etc.) Periodic inspection and if

needed clean-out of catch basin

sumps, inlets and outlet

structures with appropriate off-

site disposal of sediments and

wastes

F &O Grounds and EHS F&O- quarterly,

EHS- annually

(or more

frequently if

needed)

Periodic street sweeping of

paved areas

F&O Grounds Weather

dependent –

average 2-3

times per year

Use of low impact deicing

agents

F&O Grounds As needed -

weather

dependent

Routine inspection of outdoor

storage areas and areas of the

facility where good

housekeeping procedures are

implemented

F&O Grounds Quarterly

Inspection of ASTs and USTs F&O and EHS F&O- quarterly,

EHS- annually

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RESOURCES

Michigan Department of Environmental Quality issued NPDES Permit No. MI0053902 and

MIS040090

SME January 2013 Dry Weather Screening Report

University of Michigan Soil Erosion and Sediment Control Procedures

University of Michigan Stormwater Management Plan

University of Michigan-Flint Hazard Communication Program

University of Michigan-Flint Emergency Response Plan

University of Michigan-Flint Spill Prevention Control and Countermeasure Plan and Pollution

Incident Prevention Plan

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STORMWATER POLLUTION PREVENTION PLAN APPENDICES

Appendix A Certificate of Coverage and General Permit MIS040090

Appendix B Stormwater Operator Certification

Appendix C SWPPP Inspection Form

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Appendix A

Certificate of Coverage and General Permit MIS040090

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Appendix B

Stormwater Operator Certification

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Appendix C

SWPPP Inspection Forms

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U-M Flint Facilities and Operations Complex – SWPPP Quarterly Comprehensive Inspection

Date:

Time:

Inspector

Print:

Signature:

Is the Facility in compliance with the General Permit and the SWPPP: YES / NO If not in compliance provide a detail of non-compliance:

Areas Inspected Observation Corrective Actions Taken

Equipment

Garage/Maintenance Areas

Structural Pollution Prevention & Treatment Controls (ex: secondary containment, protective drains, etc.)

Inlets/Outfalls

Other:

ASTs/USTs/Pumps

Hydraulic Hoists

Trash, Recycling, and

Scrap Metal Dumpsters

Spill Kits

Drain Cover(s)

Parking Areas

Indoor Chemical

Storage (Hubbard and CEP)

Secondary Containment

*Note: Send completed & signed SWWP Inspection form to EHS, 801 Northbank Center

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U-M Flint Facilities and Operations Complex SWPPP Annual Inspection

Date of Review:

Reviewer

Print: Signature:

Annual SWPPP Review Checklist

1) Facility general information and SWPPP team information is current and accurate

Yes No

2) Site map is current and accurate Yes No

3) Significant material inventory is current and accurate Yes No

4) New exposures, processes and related controls have been documented

Yes No NA

5) Spills have been recorded and reported as appropriate Yes No NA

6) Records of routine preventative maintenance, housekeeping and employee training are available in the SWPPP file

Yes No

7) Comprehensive site inspections have been completed, certified and filed in the SWPPP file

Yes No

8) Corrective actions noted in the inspection reports have been completed

Yes No

9) Certified Stormwater Operator is current Yes No

10) Annual fees have been paid Yes No

11) Permit renewal request has been processed Yes No NA

12) SWPPP has been reviewed and signed by the Certified Stormwater Operator and the Permittee or designated representative

Yes No

13) F&O Inspection records are current and on file for review. Yes No

14) Corrective actions identified in the previous quarterly reports have been addressed/ corrected by F&O., or appropriate unit.

Yes No

Additional Comments: