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

The following is a summary of the requirements for MCM 6.
  1. Inventory all City owned property and develop standard operating procedures(SOP’s) that will prevent or reduce pollutant runoff from these property’s.  Identify the high priority sites and specific SOP’s and inspection programs that will prevent or reduce pollutant runoff from these property’s.
  2. Develop SOP’s for all municipal operations that can adversely affect stormwater runoff.
  3. Develop SOP’s governing city construction projects and contracted municipal operations.
  4. Develop SOP’s collecting and analyzing inspection reports for the purpose of improving municipal operations.
  5. Train employees, at a minimum, annually on the Construction Site Storm Water Runoff on Storm Water program.

Riverton City has implemented programs for MCM 6, described in this Section.

Programs
6.1: Long-Term Stormwater Management Plan (LTSWMP) Riverton Facilities/Property
6.2: Public Construction Contracts
6.3: Service Contract Operation and Maintenance Plan
6.4: Sweeping
6.5: Drainage System Maintenance
6.6: Public Infrastructure Retrofit Plan
6.7: Sandbag



 6.1:  Long-Term Stormwater Management Plan (LTSWMP) Riverton Facilities/Property
Year Executed: 2011
Currently only the Public Works Facility at 4150 West has a fully operational LTSWMP, however, all departments and divisions throughout the City are operating under functioning SOPs specifically written to protect the quality of runoff and the environment from City operations.
The development of LTSWMPs are in development for all City facilities.
Reference Regulation:
4.2.6.1, 4.2.6.2, 4.2.6.3, 4.2.6.4, 4.2.6.7.1
Target Pollutants:
Including but not limited to: Loose trash, sediment and debris, salt, pesticides, herbicides, nutrients, organic matter, metals, hydrocarbons, detergents, bacteria, chlorine…
Audiences:
MS4 Personnel
Description:
The LTSWMPs identifies the typical pollutants generated by operations and maintenance, and it describes the facilities inherent abilities and limitations to contain and control these pollutants.  SOPs have been written and implemented to specifically compensate for the limitations of the facilities design for the operations that are generally exposed to the environment, however the SOPs do not define the operations that are generally conducted indoors in a controlled and contained environment.
Rational:
The City chose the LTSWMP system to standardize how it maintains its properties and to create order and consistency with all departments and divisions. 
A LTSWMP is also expected by private development and the City’s LTSWMPs are considered to be the bar expected Riverton's private development.  City staff does not expect private development to do more than the City itself is doing, therefore the City’s LTSWMPs can be included as an educational component of the City’s LTSWMP Program for private development.  City staff also uses it own LTSWMPs as a benchmark when reviewing LTSWMPs created for private developments.
Measure of Success:
Evaluate of SOP compliance as reported by site inspections and field observations and conclude on effectiveness and staff adherence to SOPs.  Make recommendations.
Responsible Staff:
Stormwater Manager
Funding:
Stormwater Utility
Long-Term Stormwater Management Plans:
Public Works Facility 12526 South 4150 West
Appendix A Site Drawings and Details
Public Works Shop Site Plan
Public Works Site Plan and Details
Appendix B SOPs
Appendix C Site Inspections
Appendix B Site Evaluations
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:
 Operation Reports:
Stormwater System Maintenance Annual Report
Stormwater Camera Annual Report
Conclusion:
2014-2015
The program is functioning well for the Public Works Facility at 4150 W.  This documents is the baseline tool   Stormwater staffs uses to train City staff and document MS4 compliance. 



6.2: Public Constructions Contracts
Year Executed: 2011
Amended:
Reference Regulation:
4.2.6.8
Target Pollutants:
Pollutants related to Public construction and Maintenance activities
Audiences:
Constructors, City Staff
Description:
City projects are governed by the City Procurement Department.  City construction and service contracts follow the City’s Standard Contract Terms and Conditions.  This document requires that construction projects meet the terms of the ENC, LDPs and LTSWMP and these documents facilitate the stormwater project control programs.
Rational:
This process is developed by necessity because all City construction project contracts are required to be facilitated by the Procurement Department.
Measure of Success:
Evaluate Construction Projects facilitated by this program and conclude on its effectiveness and staff conformity
Responsible Staff:
Stormwater Manager
Funding:
Stormwater Utility
Standard Operations Procedures:
This program is governed by MCM4 Programs
4.0.20 Land Disturbance
4.0.10 Right-of-Way Encroachment
Appendix:
BMP 4.3 Land Disturbance Log
Conclusion:
2014-2015
Generally the program functions properly.  Some City projects were affected politically and occasionally begin without the programs 4.3 and 5.3 fully completed.



6.3: Service Contract Operation and Maintenance Plan
Year Executed: 2015
Reference Regulation:
4.2.6.7, 4.2.6.10
Target Pollutants:
Pollutants related to Public construction and Maintenance activities
Audiences:
Service Contractors, City Staff
Description:
The Service Contract Operation and Maintenance Plan is a plan required by service contractors providing City services.  It facilitates procedures to operate services in a manner that will control and contain pollutants generated by the service.  The service contracts are governed City’s Standard Contract Terms and Conditions managed by the Purchasing Department.  This document requires that construction projects meet the terms of the Service Contract Program that facilitates  a Service Contract Operation and Maintenance Plan.
Rational:
City projects are commissioned by the City Procurement Department and so it is necessary to incorporate the Service Contract Operation and Maintenance Plan program into the City Contract Program.  This process is necessary to ensure the multiple departments and divisions correlate the various jurisdictional tasks
Measure of Success:
Evaluate Service Contracts facilitated by this program and conclude on its effectiveness and staff conformity
Responsible Staff:
Stormwater Manager, Purchasing Manager, Related Departments and Divisions
Funding:
Stormwater Utility
Standard Operations Procedures:
O&M Plan Instruction for Service Contractors
Large Construction Terms & Conditions Bidding Contract
Tile, Small Construction Contract Terms & Conditions
Conclusion:
2014-2015
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 creating an O&M Plan resulting in uncontrolled pollutants.  Program documents have been revised which should facilitate implementation for 2015-2016.



6.4: Sweeping
Year Executed: 2000
Reference Regulation:
4.2.1.5, 4.2.6.4.5
Target Pollutants:
Sediment, organics, trash
Audiences:
City Staff
Description:
The Street Sweeping Program involves sweeping all Riverton public Right of Way roads as weather allows.  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.  Purpose is collecting natural tree and shrubbery shedding, roadway raveling, removal of sediment left by winter snow and ice removal operations and fugitive trash and debris.  
Rational:
Maintain neat and orderly roadways.  However, the sweeping operation is not intended to manage construction, maintenance and trash and debris that is the responsibility of private activities and properties.  Phase 1 of the Jordan River Water Quality Total Maximum Daily Load Study identifies organic material as the primary pollutant of concern at the Riverton City boundary.  In addition. the City should protect canals and creeks passing through private property from public roadway impacts and pipes must also remain open and clear to manage flood risk.    
Measure of Success:
Responsible Staff:
Stormwater Manager, Purchasing Manager, Related Departments and Divisions
Funding:
Stormwater Utility
Standard Operations Procedures:
Conclusion:
2020-2021  The sweeping program collected  more material than last year.  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.  These two factors resulted in a difference in sweeping statistics.  However because of covid the true differences in production may not be possible.
 


6.5: Drainage System Maintenance
Year Executed: 2011
Reference Regulation:
4.2.6.4.6
Target Pollutants:
Pollutants related to Public construction and Maintenance activities
Audiences:
City 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.  Purpose is collecting any sediment and debris that make it to City pipe systems.  

Rational:
Maintain adequate flood control system and responsibly manage pollution .  Any sediment and debris in our pipes will eventually reach canals, creeks or the Jordan River.  The City is accountable for everything we dump from our pipes.  Phase 1 of the Jordan River Water Quality Total Maximum Daily Load Study identifies organic material as the primary pollutant of concern at the Riverton City boundary.      


Responsible Staff:
 
Funding:
Stormwater Utility
Standard Operations Procedures:
 
Conclusion:
2019-2020 The jet truck was not operational most of this report period.  The City has ordered a jet truck and will available next report period.  This program is necessary and currently does not need to change. 

6.6: Public Infrastructure Retrofit Plan
Year Executed: 2010
Reference Regulation:
4.2.6.8, 4.2.6.9
Target Pollutants:
Trash, debris, nutrients, 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 designs. These systems efficiently carry runoff and all contaminates carried with it to water bodies.  These systems also increase runoff volumes because only small volumes of runoff is 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 through its vegetated or pervious xeriscape surface type landscaping. Detention LIDs do trap urban pollution but during high flow events pollution can pass through, is scoured out 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. 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 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 improve urban pollution management and improve infiltration rates thereby reducing runoff volumes contributing to flooding and reduce the potential for nuisance water remaining on the surface for long periods of time.
  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.  Centrifugal and siphon remove floating material and heavy sediments from runoff. Centrifugal types are usually more effective but are also more expensive but neither centrifugal or siphon types will remove water soluble pollutants and both are often susceptible to high flow scour.  WQD were required by City standards from 2003 and the vast majority are siphon types and a handful of 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 landuse 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:
Stormwater Manager, Public Works Director
Funding:
General fund, Stormwater Utility
Standard Operations Procedures:
Stormwater Design Standards and Regulations
Capital Facility Plan:
Capital Facility Plan(CFP) includes Impact and infrastructure deficiency based capital projects.  The water quality related deficiency are marked by the CFP description. 
Appendix:
Conclusion:
2018-2019
The program is functioning but all City Departments are not aware of this program.  More training and all City Department's and Division's support in necessary.  The Public Works Department and Stormwater Division are implementing this program and have built two projects this report period, see Retrofit Log.




6.7: Sandbag Program
Year Executed: 2019
Reference Regulation:
 
Target Pollutants:
plastic bags
Audiences:
 
Description:
 
Rational:
 
Measure of Success:
 
Responsible Staff:
 
Funding:
Stormwater Utility
Funding:
Sandbag Application

Standard Operations Procedures:
Conclusion:
2018-2019



 
Subscribe to
Email Notifications
Sign Up for
Text Message Alerts
Download the
Riverton Connect App