263-22 Proposal - Mott MacDonald.pdf

Proposal for Professional Engineering and Permit Assistance Services Municipal Stormwater Management Plan Updates Permit Compliance for NJPDES: NJG0151190 / PI ID#: 168118 West Orange Township, Essex County, New Jersey July 26, 2022, revised September 9, 2022 Dear Ms. Carballo: Thank you for reaching out to Mott MacDonald related to updating several items related to the West Orange Township Municipal Stormwater Management Plan, Stormwater Pollution Prevention plan and Municipal Separate Stormwater Sewer System (MS4 permit) updates and compliance. As discussed, these updates are of priority due to the letter received by NJDEP on December 4, 2020 which captures the Stormwater Compliance Assistance Audit (Audit Letter) findings from the NJDEP that was conducted on July 31, 2019. The Audit Letter covers 17 items to which the Township must provide response and have required action items documented. The Audit letter is attached to this letter as Attachment 1. We also note that on June 21, 2022 NJDEP’s Office of Water Compliance and Enforcement (Northern Regional Office) issued a second letter based upon an inspection conducted by the Department on February 17, 2022 related to issuance of a Notice of Violation (NOV) based upon non-compliance with a checklist of items that the inspector used during the evaluation that assess components of the MS4 permit and SPPP. At the time of the inspection, the NJDEP inspector cited submission of the Annual Report and Certification as out of compliance and therefore cause for the NOV. However, it is our understanding that the annual report was in the process of being submitted at the time. It is noted however, that there are several items that are under review and an overall comment by the inspector that the items noted in the 2020 Audit Letter. 1 Background The two primary documents requiring update are the Stormwater Pollution Prevention Plan (SPPP) and the Municipal Stormwater Management Plan (MSWMP). Both are a requirement of the Tier A MS4 Permit and both require updates. Based upon our conversation, the intent is to have West Orange be Zayibeth Carballo, PE.-LS, CME, CFM, Assistant Municipal Engineer 25 Lakeside Avenue West Orange. NJ 07052 Phone: (973) 325-4165 Fax: (973) 669-9588 zcarballo@westorange.org Your Reference Municipal SWP Our Reference 507107186 P6212022-ZC-West Orange SWMP.docx Mott MacDonald 111 Wood Avenue

range. NJ 07052 Phone: (973) 325-4165 Fax: (973) 669-9588 zcarballo@westorange.org Your Reference Municipal SWP Our Reference 507107186 P6212022-ZC-West Orange SWMP.docx Mott MacDonald 111 Wood Avenue South Iselin NJ 08830-4112 United States of America T +1 (800) 832 3272 mottmac.com

Mott MacDonald Zayibeth Carballo, PE.-LS, CME, CFM, Assistant Municipal Engineer July 26, 2022 Page 2 of 10 primarily responsible for the updates to the SPPP which consists of mostly templated text and a series of 17 ‘forms” that all now require update as the forms have changed since 2005. The SPPP also requires outfall mapping and other appendices The following table has been prepared to coalesce the work required to address the Audit Letter and clarify where work can be completed in-house by West Orange, where it may be more efficient to have Mott MacDonald complete the item and, in some instances, where work by both West Orange and Mott MacDonald will offer a complete solution to address the item. Please note in the table where we have marked an asterisk for notes. The asterisks are follows: Notes: * MM to update Outfall Map ** MM to provide some level of effort to coordinate *** Mostly WO but may need some technical depth or review from MM **** No Scope for MM

Mott MacDonald Zayibeth Carballo, PE.-LS, CME, CFM, Assistant Municipal Engineer July 26, 2022 Page 3 of 10 Table 1: July 31, 2019 Audit Letter: Summary of Deficiencies and Next Steps for Compliance Audit Letter Item Description Audit Letter Item Observation July 2019 SPPP/MSWMP/Tier A MS4 Permit/Other Current Status Next Step for Compliance By 1 Stormwater Pollution Prevention Plan Unable to Locate / Failed to Provide SPPP Located, Needs Update Update WO* 2 Municipal Stormwater Management Plan Unable to Locate / Failed to Provide MSWMP Located, Needs Update MSWP to be updated MM 3 Required Elements to be Posted on Permittee’s Website 1 & 2 Not Posted along with applicable ordinances Both Posted, Needs Update Once elements are updated, WO to post WO** 4 Local Public Education No Copy Public Education and Outreach Program SPPP/Tier A MS4 Permit Needs to be Prepared Review Permit Attachment B and current SPPP. WO DPW should coordinate with governing body and/or EC. MM could assist WO but no scope at this time. WO 5 Major Development Project Review Major Developments (SHP & GO Academy) Deficiencies and Lack of Inspection Data and Review Data MSWMP/Tier A MS4 Permit Missing Information WO to take lead in locating information or NJDEP may indicate no action but going forward major developments must have these reviews and testing conducted and documented. Hence, no scope proposed. WO**** MSWMP/Tier A MS4 Permit Nonstructural Strategies WO**** MSWMP/Tier A MS4 Permit Soil Testing WO**** MSWMP/Tier A MS4 Permit BMP Design/Calculation WO**** MSWMP/Tier A MS4 Permit Water Quantity WO**** MSWMP/Tier A MS4 Permit Water Quality WO**** MSWMP/Tier A MS4 Permit Groundwater Recharge WO**** MSWMP/Tier A MS4 Permit Maintenance Plans WO**** 6 Street Sweeping Unable to Locate / Failed to Provide SPPP/Tier A MS4 Permit Prepare Plan & add to SPPP WO to address and is in process WO**** 7 Catch Basin Inspection and Maintenance Unable to Locate / Failed to Provide SPPP/Tier A MS4 Permit Prepare Plan & add to SPPP MM to do the inspections and set up GIS tool to take data per SPPP forms. In future permit cycles, WO could take lead with training and onboarding of GIS tool. WO/MM 8 Municipal Maintenance Yard BMPs 25 Lakeside Salt Dome Drainage SPPP/Tier A MS4 Permit salt directed towards drain structures Addressed by WO WO**** 25 Lakeside Floor Drains Investigation SPPP/Tier A MS4 Permit

Maintenance Yard BMPs 25 Lakeside Salt Dome Drainage SPPP/Tier A MS4 Permit salt directed towards drain structures Addressed by WO WO**** 25 Lakeside Floor Drains Investigation SPPP/Tier A MS4 Permit unknown discharge and piping scheme Addressed by WO WO**** 25 Lakeside Storm Inlet Cleaning SPPP/Tier A MS4 Permit filled and clogged WO to do or contract WO 25 Lakeside Sweepings/Debris Clearing SPPP/Tier A MS4 Permit stockpiled not in conformance with permit and BMP WO to do or contract WO 590 Mt Pleasant Ave Other NOV clearing & secure the Industrial Stormwater Permit for Recycling Facility (not covered under Tier A Municipal Permit) Requires submission of separate SPPP and Basic Industrial Stormwater General Permit. May also require DPPC (gasoline/fuel spill) prevention plan if quantities have changed. WO to investigate further and consult legal counsel. No scope but MM could offer services separately. WO 9 Employee Training Municipal Training Program not available SPPP/Tier A MS4 Permit WO needs to have its new employees trained in Stormwater Management via NJDEP website WO to do. Review SPPP form in current report and update accordingly for SPPP. Review NJDEP website Submit training proof to NJDEP per MS4 permit WO 10 Municipal Board and Governing Body Member Related Training Municipal Board and Governing Body Member Related Training Program not available Tier A MS4 Permit WO needs to have its public servants trained in Stormwater Management via NJDEP website WO to do. Review SPPP form in current report and update accordingly. Submit training proof to NJDEP per MS4 permit WO 11 Outfall Pipe Map Unable to Locate / Failed to Provide SPPP/Tier A MS4 Permit Prepared and last updated in 2009 Submit current map immediately and then update and submit. Provide in paper and in GIS format per NJDEP requirements. Needs to also be included in the SPPP. Requires field work by MM MM 12 Outfall Pipe Stream Scouring Unable to Locate / Failed to Provide SPPP/Tier A MS4 Permit Needs to be prepared and inspections need to be done MM will set up inspection tool for data to load into GIS and populate SPPP form. Needs to be coordinated with NJDEP tool (“app”) Requires field work by MM MM 13 Illicit Discharge Detection and Elimination Unable to Locate / Failed to Provide SPPP/Tier A MS4 Permit Needs to be Prepared and Inspections performed Needs to be coordinated with NJDEP

rk by MM MM 13 Illicit Discharge Detection and Elimination Unable to Locate / Failed to Provide SPPP/Tier A MS4 Permit Needs to be Prepared and Inspections performed Needs to be coordinated with NJDEP tool (“app”) No scope for MM. WO**** 14 Stormwater Facilities Maintenance Unable to Locate / Failed to Provide SPPP/Tier A MS4 Permit Needs to be Prepared and maintenance implemented MM can prepare with WO. WO to implement and keep records. MM could set up tool to have the data collected by WO load into GIS automatically and populate SPPP form. Needs to be coordinated with NJDEP tool (“app”) MM/WO 15 Stormwater Facilities Maintenance (Privately Owned or Operated) Unable to Locate / Failed to Provide SPPP/Tier A MS4 Permit Needs to be Prepared and maintenance implemented MM can prepare with WO. WO to implement and keep records. MM could set up tool to have the data collected by WO load into GIS automatically and populate SPPP form. Needs to be coordinated with NJDEP tool (“app”) MM/WO 16 Total Maximum Daily Load (TMDL)/Impaired Waterway Unable to Locate / Failed to Provide SPPP/Tier A MS4 Permit Need to review 4 TMDL's for FC, 3 for Phosphorus, 1 for Verona Lake and associate if necessary to stream segments in municipality. Identify and develop strategies to address sources MM can prepare and include in SPPP and assess if optional reduction in pollutants is applicable MM 17 Annual Report and Certification Unable to Locate / Failed to Provide SPPP/Tier A MS4 Permit Report Documents need to be submitted WO to do and is the NOV item in the June 2022 NJDEP letter. No Scope for MM. WO

Mott MacDonald Zayibeth Carballo, PE.-LS, CME, CFM, Assistant Municipal Engineer July 26, 2022 Page 4 of 10 2 Scope of Work Based upon the above table, the following items are proposed to be included in Mott MacDonald’s scope: ● Items 2, 7, 11-12, 14-16 Hence, our proposed scope of work is as follows: 2.1 Item 2 (Municipal Stormwater Management Plan) Mott MacDonald prepared the original MSWMP in 2005. Mott MacDonald will update the document 10-part main section, 2 tables, 3 figures and 2 appendices as applicable. The following 10 Sections will be prepared and updated: ● Introduction (Update) ● Goals (Update) ● Stormwater Discussion (Update) ● Background (Update) ● Design and Performance Standards (Update) ● Plan Consistency (Update) ● Nonstructural Stormwater Management Strategies (Update) ● Land Use/Build-Out Analysis (Now Required) ● Mitigation Plans (Update) As a result of the Land Use/Buildout Analysis, additional tables and figures will be added to the report. To complete the buildout the analysis, the Township’s inventory of total land area sorted by HUC14 and land use zone will be tabulated using available GIS data. Existing Impervious lands and wetlands/water areas will be subtracted out of the total land area to calculate the developable area. The township’s allowable impervious coverage in each zone will be applied to indicate a theoretical build-out of impervious land. An additional calculation is then made by zoning type to compute pollutant loads of Total Phosphorus, Total Nitrogen and Total Suspended Solids Loads from the buildout data using load criteria published by NJDEP (lbs/acre/yr). For the above update, we propose 90 hours of engineering and scientist time to complete this task. 2.2 Item 7 (Catch Basin Inspection and Maintenance - Part IV.B.5.b.ii) As of 2018, it is now a requirement to inspect all municipally owned catch basins and inlets at least once every five years, and then clean as frequently as necessary to eliminate recurring problems and restore proper function. However, it is our understanding that whereas all inspections should have been complete by the end of this year (2022), to bring the system into compliance all inlets require inspection at this time. Hence, Mott MacDonald proposes to conduct the inspections and record the data in accordance with the current requirements of the permit and SPPP. Based on the length of

equire inspection at this time. Hence, Mott MacDonald proposes to conduct the inspections and record the data in accordance with the current requirements of the permit and SPPP. Based on the length of municipal roads, we estimate 2,000 catch basins to locate and inspect. We estimate one field person can conduct 75 inspections a day. Moreover, we will document where cleaning and clearing are needed and

Mott MacDonald Zayibeth Carballo, PE.-LS, CME, CFM, Assistant Municipal Engineer July 26, 2022 Page 5 of 10 provide the information as we progress the inspections to the Township so that arrangements by the Township can be made to clean the inlets. We propose to collect the data using digital form tied to an in-house GIS platform named MMFIT. The application makes use of the GPS capabilities of the user’s smartphone to locate assets in the field adequately for locating and identifying for inspection purposes. This provides a cost savings over traditional survey methods. As the conclusion of the project the data will be transmitted to the Town. The town may elect to continue to use the MMFIT platform on a subscription basis and use the dashboard features to track the ongoing inspection requirements. The Township will need to record the data and supporting documentation to log in the amount of wet tons of material collected. For the above update, we propose 286 hours of engineering and field technician specialist time to inspect the catch basins and inlets. In the event that there are significantly more inlets to inspect than anticipated we will inform the Town and provide a revised estimate. 2.3 Item 11 (Outfall Pipe Map - Part IV.B.6.a) We have modified this item into two components. Item 11a, is our baseline scope needed for the current permit cycle. Item 11b addresses the next MS4 permit cycle and is additional scope item Item 11a Outfall Pipe Map (Base Scope) West Orange is required to update its stormwater outfall mapping which was last updated in 2009. As such, Mott MacDonald will consult with the DPW staff and will request any mapping for inspection notes to identify known areas of updates/`changes in the outfall locations. Mott MacDonald will then deploy its survey and inspection crew to fill data gaps based upon the areas recommended by the DPW to investigate further. Outfalls will be logged in a GIS compatible file provided to the Town at the conclusion of the project. We anticipate walking the banks of the Town’s streams to identify as many outfalls as possible. We anticipate that the Town will help identify the streams that need to be walked. For this task, we propose 119 hours of field inspection time and field technician time. Item 11b (MS4 Full System Map, Additional Scope, see Proposal Letter dated September 9, 2022) Be advised that it will be

task, we propose 119 hours of field inspection time and field technician time. Item 11b (MS4 Full System Map, Additional Scope, see Proposal Letter dated September 9, 2022) Be advised that it will be required in the next permit cycle, the mapping requirement will be extended to all MS4 components, including but not limited to: ● MS4 outfalls (receiving surface water name, type of outfall); ● MS4 ground water discharge points (type); ● MS4 interconnections (type into/from, entity); ● Storm drain inlets (type, catch basin present, label present, retrofitted); ● MS4 manholes; ● MS4 conveyance (type, direction of flow); ● MS4 pump stations; ● Stormwater facilities (type); and