# Environmental Compliance

Environmental Health & Safety develops and maintains plans to ensure environmental safety and compliance. Our duties include stormwater pollution prevention, oil spill prevention, hazardous waste management and indoor air quality.

# Indoor Air Quality

[ Indoor air quality](https://www.epa.gov/indoor-air-quality-iaq/introduction-indoor-air-quality#:~:text=Indoor%20Air%20Quality%20(IAQ)%20refers,and%20comfort%20of%20building%20occupants. " Indoor air quality") covers a broad range of issues including temperature extremes, stuff in the air and unpleasant odors. If you suspect a problem with the air quality in your space, please contact the EHS department or complete the [Health and Safety Concern](https://arkansasstateuniversity.formstack.com/forms/safety_concerns "Health and Safety Concern") form.

# Hazardous Waste Management

Hazardous Waste Management Plan  
Purpose:  
Introduction  
The management of hazardous waste is governed by the Environmental Protection Agency   
(EPA) regulations, specifically, 40CFR260-262. These regulations are the implementation of the   
Resource Conservation and Recovery Act (RCRA). Some states, of which Arkansas is one, are   
authorized by the EPA to run their own hazardous waste program; these are known as   
agreement states. In Arkansas, this function is executed by the Arkansas Department of   
Environmental Quality (ADEQ) and the regulations are codified in AR regulation 23 rather than   
40CFR 260-262. While the ADEQ regulations are almost a duplicate copy of the EPA regulations,   
they are slightly more stringent. This increased stringency affects both small quantity and large   
quantity generators of hazardous waste.  
The word hazardous in the context of waste generation has a very specific and limited meaning.   
While hazardous in general uses means something that is a threat to human health, ADEQ takes   
the approach of environmental protection. When the word hazardous is used when referring to   
waste, it strictly means that the waste is subject to the regulations. A waste could legitimately   
be a threat to human health, but if it is not regulated according to regulation 23, it is not a   
hazardous (regulated) waste. Alternatively, a waste may be little or no threat to human health   
and still meet the regulatory definition of a hazardous waste.  
If a waste is determined to be hazardous by the regulations, its disposal options are explicitly   
defined by the hazardous waste management regulations; however, disposal options are not   
defined for non-regulated waste. Local ordinances may preclude disposal of chemical waste in   
the sewer or landfill so no chemical should be poured down the drain without written approval   
from the EHS director including container residues.   
Definitions  
Acutely Hazardous Waste means unused chemicals to be discarded that appear on the P-list or   
a spent chemical that appears on the F-list from F027-F033. The limit for accumulation at any   
one time of acutely hazardous waste for SQGs and CESQGs is one kilogram or one quart.  
Central Accumulation Area (CAA) means where hazardous waste is accumulated once a satellite   
accumulation area container is full.   
Characteristic Waste means any material that is a hazardous waste because it has certain   
characteristics. The characteristics are defined on the D-list.  
Conditionally Exempt Small Quantity Generator (CESQG) means a generator of hazardous waste  
that generates less than 100 kg per month (approximately 27 gallons) of hazardous waste and   
less than 1 kg of acutely hazardous waste and accumulates less than 1000 kg of hazardous   
waste and less than 1 kg of acutely hazardous waste on site at any one time.   
Corrosive means any material that has a pH of less than 2.0 or more than 12.5 or corrodes steel   
at a rate of more than 0.25 inches per year.  
D-list means the list that determines whether or not a waste is a hazardous waste based on the   
characteristics of that waste.  
DOT means US Department of Transportation.  
Environmental Health and Safety (EHS) means an individual trained to make a hazardous waste   
determination that will move chemical waste from the satellite accumulation area to the   
central accumulation area.  
F-list means the list that contains spent chemicals from non-specific sources. If a waste appears   
on this list, it is a hazardous waste.  
Flash point means the temperature at which a chemical can form an ignitable mixture with air   
(will ignite if a flame or spark is applied to the mixture). This information can be found on the   
Safety Data Sheet (SDS) for the chemical.  
Generator means any person that generates hazardous waste. It can also mean the entity that   
generates hazardous waste with respect to the generator status of an entity.  
Hazardous Waste means any waste that is regulated under RCRA. This includes both   
characteristic and listed waste. The word “hazardous” in this context may be used   
interchangeably with the word “regulated”.  
Ignitable means any material that has a flash point that is less than 140 degrees Fahrenheit (60   
degrees Celsius).  
K-list means the list that contains spent chemicals from specific sources. If a waste appears on   
this list, it is a hazardous waste.  
Large Quantity Generator (LQG) means a generator of hazardous waste that generates more   
than 1000 kg per month of hazardous waste or more than 1 kg of acutely hazardous waste or   
accumulates more than 6000 kg of hazardous waste or more than 1 kg of acutely hazardous   
waste on site at any one time.   
Listed Waste means any material that is a hazardous waste because appears on one of the EPA   
lists: F-list, K-list, P-list or U-list.  
Manifest means the shipping paperwork that must accompany a shipment of hazardous waste.  
Mixed Waste means hazardous waste that is mixed with biological or radioactive waste.  
Oxidizer means a material that has the ability to provide oxygen to help sustain a combustion   
reaction.  
P-list means the list that contains unused chemicals that are going to be discarded. If a waste   
appears on this list, it is an acutely hazardous waste.  
Reactive means is any material that is unstable, explosive, reacts violently with water or air or   
forms toxic gases when exposed to water or air at ambient temperature.  
Satellite Accumulation Area (SAA) means the area where waste is initially generated that is   
under the control of the generator. A room or lab would be considered one SAA.  
SDS means safety data sheet. This sheet is provided by the manufacturer and it contains   
information about a material such as the hazards associated with the chemical, the signs and   
symptoms of exposure to the chemical as well as some of the materials chemical and physical   
properties.  
Small Quantity Generator (SQG) means a generator of hazardous waste that generates more   
than 100 kg per month (approximately 27 gallons) of hazardous waste but less than 1000 kg per   
month, less than 1 kg of acutely hazardous waste and accumulates less than 6000 kg of   
hazardous waste and less than 1 kg of acutely hazardous waste on site at any one time.   
Toxic means any material that contains an amount over the regulatory limit of one or more of   
the 40 chemicals designated by the EPA as causing to have the characteristic of toxicity. These   
40 chemicals are given on the D-list.  
U-list means the list that contains unused chemicals that are going to be discarded. If a waste   
appears on this list, it is a hazardous waste.  
Roles and Responsibilities  
Generator in a laboratory or laboratory support area: The responsibilities of this type of  
generator are as follows:  
1\. The generator must be trained before hazardous waste is generated. This is the only   
way a generator will know how to properly manage their chemical waste.  
2\. The generator must apply a label to the waste container before waste is added to the   
container. The label must use the words “chemical waste”, a description of the waste   
and the date waste was first added to the container. A label template is available on the   
EHS website.  
3\. The generator must make sure the labeled container is closed tightly unless waste is   
being added to the container.   
4\. When the container is full, the generator must arrange for pickup of the full container   
with EHS via the online request form. EHS will take the container from the point of   
generation to the CAA for processing.   
5\. If a generator wishes to discard unused chemicals, the generator must notify EHS so that   
the disposition of the chemicals can be determined.  
6\. A generator must not pour chemicals down the drain without written approval from   
EHS.  
7\. A generator must not move waste from one SAA into another. Movement within one lab   
or room may be allowed, but check with the EHS first.  
8\. A generator may have a working container for chemical waste that can remain open   
while a process is ongoing. The working container must be emptied at the end of the   
process or the end of the day, whichever comes first, into an appropriately labeled and   
dated container.  
9\. A generator must provide his or her own container for chemical waste. If large volumes   
of waste will be generated, EHS may provide a container upon request. When using a   
container that previously contained a chemical for storage of chemical waste, the   
container must:  
a. Be thoroughly rinsed to be sure no residue of the previous chemical is left.  
b. Have the label defaced and a chemical waste label placed on it so that there is no   
confusion about the contents of the container.  
c. Be compatible with the waste that is going to be added to it.  
Generator in non-laboratory support areas: The responsibilities of this type of generator are as   
follows:  
1\. The generator must be trained before hazardous waste is generated. This is the only   
way a generator will know how to properly manage their hazardous waste.  
2\. The generator must apply a label to the waste container before waste is added to the   
container. The label must use the words “hazardous waste” and a description of the   
waste. A label template is available on the EHS website.  
3\. The generator must make sure the container is closed tightly unless waste is being   
added to the container.   
4\. When the container is full, the generator must arrange for pickup of the full container   
with EHS via the online request form. EHS will take the container from the point of   
generation to the CAA for processing.   
5\. If a generator wishes to discard unused chemicals, the generator must notify EHS so that   
the disposition of the chemicals can be determined.  
6\. A generator must not pour chemicals down the drain without written approval from   
EHS.  
7\. A generator must not move waste from one SAA into another. Movement within one   
room may be allowed, but check with the EHS first.   
8\. A generator must provide his or her own container for chemical waste. If large volumes   
of waste will be generated, EHS may provide a container upon request. When using a   
container that previously contained a chemical for storage of chemical waste, the   
container must:  
a. Be thoroughly rinsed to be sure no residue of the previous chemical is left.  
b. Have the label defaced and a hazardous waste label placed on it so that there is   
no confusion about the contents of the container.  
c. Be compatible with the waste that is going to be added to it.  
Environmental Health and Safety: The responsibilities of EHS are as follows:  
1\. EHS must be fully trained to handle hazardous waste. This includes:  
a. Training for RCRA on an annual basis  
b. Training for DOT every 3 years  
c. HAZWOPER training as often as appropriate  
2\. EHS must deliver training for all hazardous waste generators.  
3\. EHS must maintain control of the CAA.  
4\. EHS must perform weekly inspections of the CAA. The inspections shall include checking   
container integrity and compatibility with the materials stored, checking for appropriate   
labeling and checking for appropriate closure of the containers.  
5\. EHS must collect waste from the satellite accumulation areas for storage in the CAA  
upon request from generators. For waste generated in laboratories or laboratory   
support areas, pickup of containers will be accomplished upon request or less than six   
months from the date on the label, whichever comes first. For all other areas, pickup of   
containers of waste will be accomplished upon request or when the volume at a   
particular SAA exceeds 55 gallons, whichever comes first.  
6\. When waste is taken to the CAA, EHS must be sure the waste is added to a container   
that is properly labeled. The label must have:  
a. The words: “Hazardous Waste: Federal and state law prohibit improper disposal”  
b. A description of the waste  
c. The appropriate EPA waste codes  
d. The date the container was brought to the CAA  
7\. EHS must assure that waste is removed from the CAA within 180 days from the date   
waste was first brought into the CAA.  
8\. EHS must arrange for removal of hazardous waste from the CAA when appropriate.  
9\. EHS must assure that the hazardous waste manifest is completed appropriately and sign   
the document.  
10\. EHS is also the emergency coordinator (EC) for the site. EHS or an appropriately trained   
designee must respond to all emergencies, 24 hours a day, 7 days a week. EHS shall   
ensure that someone is on call to respond to emergencies, as defined in the emergency   
response section, outside of business hours.   
11\. EHS shall ensure that a return copy of the manifest for hazardous waste is received   
within 60 days of the shipment leaving the site. If this does not occur, EHS shall send a   
copy of the unsigned manifest and a letter of explanation to ADEQ.  
12\. EHS shall ensure that all waste manifests are kept on site for at least 3 years.  
13\. EHS shall ensure that an annual declaration is sent to ADEQ each year before January 31   
and that the appropriate fees, if applicable, have been paid.   
14\. EHS shall ensure that if any hazardous waste is analyzed that the records are kept on   
site for three years.  
Procedures  
Hazardous Waste Determination  
Ultimately, the determination about whether or not a waste is truly regulated will be made by   
EHS upon waste being placed in the central accumulation area when the waste is generated in a   
laboratory or a laboratory support area. In all other areas, it is the responsibility of the   
generator to determine whether or not a waste is a hazardous waste. It is important for all   
generators to understand how a waste becomes a hazardous waste to ensure proper disposal   
procedures are followed. Improper disposal of hazardous waste can lead to hefty fines and can   
be a danger to the environment and human health.  
A waste can gain the designation of hazardous waste by demonstrating a hazardous   
characteristic or by being listed. The characteristics of a waste that can make it a hazardous   
waste are ignitability, corrosivity, reactivity and toxicity and cause these wastes to carry a D   
code as indicated below:  
D001: Ignitable- A waste is ignitable if it has a flash point below 130F. Information about   
the flash point of a material can be found on the SDS for the material. In general,   
aqueous solutions with >80% water are not ignitable. All oxidizers are also considered to   
be ignitable and carry the D001 code.  
D002: Corrosive- A waste is corrosive if it has a pH below 2.0 or above 12.5 or if it   
corrodes steel at a rate greater than 0.25 inches per year.  
D003: Reactive- A waste is reactive if it readily and violently reacts with air or water at   
ambient temperatures, is shock sensitive, or a number of other conditions. If the SDS for   
a material describes the material as “unstable”, “explosive”, “dangerous when wet”,   
“generates toxic gas when exposed to air or water” or any other similar verbiage, the   
waste should be considered reactive.  
D004-D043: Toxic- A waste is toxic if it contains any of the 40 chemicals indicated in   
appendix A at the indicated level. Note that the term toxic in this context has a very   
limited meaning.  
Note that D codes apply if the material is used OR unused.  
There are four lists of hazardous wastes. The F-list contains chemicals that become waste from   
non-specific sources. The K-list contains waste from processes that are specific sources (wastes   
from this list are unlikely to be generated at Arkansas State University). The P-list and U-list   
contain unused chemicals that are hazardous waste if discarded or abandoned. Codes that are   
obtained by listed waste are designated by the list from which they come (ex. F-list contains   
chemicals that will receive F-codes).  
The primary way a chemical can obtain an F-code is by being used as a solvent. An important   
thing to remember is that concentration of one of these solvents within the waste cannot cause   
it to be removed from the list. In other words, if your waste contains one drop of a material   
that has an F-code (F003 is an exception), then it is a regulated waste. Common examples of   
solvents that carry F-codes are methylene chloride (F002), acetone (F003), methanol (F003) and   
toluene (F005). The complete F-list is contained in Appendix B.  
A chemical cannot obtain a U-code unless it is discarded unused. While used chemicals receive   
D, F or K-codes, a used chemical cannot receive a U-code (or a P-code). Since generated waste   
must be generated from the same process to be consolidated, adding unused chemicals to the   
waste drums is not allowed. Common examples of chemicals that have U-codes are acetone   
(U002), chloroform (U044), methanol (U154) and methylene chloride (U080). The complete Ulist is contained in Appendix C.  
A chemical cannot obtain a P-code unless it is discarded unused. Chemicals on the P-list are   
considered acutely hazardous by the EPA. Since generated waste must be generated from the   
same process to be consolidated, adding unused chemicals to the waste drums is not allowed.   
Furthermore, adding P-list waste to a container makes the entire mixture an acutely hazardous.   
Therefore, adding P-list waste to a drum would result in a jump to the most regulated   
generator status, LQG, because the limit for accumulation of acutely hazardous waste for SQG   
and CESQG is 1 kg (2.2 lbs). Common examples of chemicals that have P-codes are sodium azide   
(P105), osmium tetroxide (P087), vanadium pentoxide (P120) and nicotine (P075). The   
complete P-list is contained in Appendix D.  
Generating used chemical waste in laboratories and laboratory support areas  
1\. Review a process before beginning to determine if waste is going to be generated.  
2\. Label the container with the words “chemical waste”, a description of the waste and the   
date that waste was first added to the container. The use of the chemical waste label   
template is strongly encouraged.  
3\. Only open the container when waste is going to be added. The container shall remain   
closed at all other times.  
4\. Once the waste container is full, the process is complete and the container is no longer   
needed, the date on the container is within 30 days of reaching six months from the   
date on the container or the amount of waste in the SAA exceeds 55 gallons, contact   
EHS for pickup of the container. The waste shall be removed within 3 days if the amount   
of waste in the SAA exceeds 55 gallons.  
5\. Upon collection of a SAA chemical waste container, EHS shall transport the container to   
the CAA. At that point, EHS shall determine if the chemical waste is regulated hazardous   
waste and label and store the container appropriately.  
6\. While the vendor normally completed the hazardous waste manifest and applies the   
appropriate shipping labels, ensure that all of the following are done before the waste   
leaves the site:  
a. The hazardous waste manifest is correct including EPA ID number, address,   
telephone numbers, proper shipping names of materials and amounts.  
b. The appropriate DOT hazard labels are applied to the shipping containers.  
c. The appropriate hazardous waste label is applied to the shipping containers. This   
includes the following:  
i. The words “Hazardous Waste- Federal Law Prohibits Improper Disposal. If   
found, contact the nearest police or public safety authority or the US   
Environmental Protection Agency.”  
ii. The generator name and address  
iii. The generator EPA ID number  
iv. The manifest tracking number  
v. The appropriate waste codes  
Generating used chemical waste in all other areas  
1\. Review a process before beginning to determine if waste is going to be generated.  
2\. By analyzing the waste or using generator knowledge, determine if the waste is a   
hazardous waste.  
3\. If the waste is a hazardous waste, label the container with the words “hazardous waste”   
and a description of the waste. The use of the hazardous waste label template is   
strongly encouraged. If the waste is not a hazardous waste, it should be labeled as a   
non-hazardous waste (preferably with the label template on the website). For nonhazardous wastes, the rest of the following steps are encouraged, but not required.  
4\. Only open the container when waste is going to be added. The container shall remain   
closed at all other times.  
5\. Once the waste container is full, the process is complete and the container is no longer   
needed or the amount of waste in the SAA exceeds 55 gallons, contact EHS for pickup of   
the container. The waste shall be removed within 3 days if the amount of waste in the   
SAA exceeds 55 gallons.  
6\. Upon collection of a SAA chemical waste container, EHS shall transport the container to   
the CAA and apply the appropriate label (if necessary) and date.  
7\. While the vendor normally completed the hazardous waste manifest and applies the   
appropriate shipping labels, ensure that all of the following are done before the waste   
leaves the site:  
a. The hazardous waste manifest is correct including EPA ID number, address,   
telephone numbers, proper shipping names of materials and amounts.  
b. The appropriate DOT hazard labels are applied to the shipping containers.  
c. The appropriate hazardous waste label is applied to the shipping containers. This   
includes the following:  
i. The words “Hazardous Waste- Federal Law Prohibits Improper Disposal. If   
found, contact the nearest police or public safety authority or the US   
Environmental Protection Agency.”  
ii. The generator name and address  
iii. The generator EPA ID number  
iv. The manifest tracking number  
v. The appropriate waste codes  
Discarding unused materials in laboratories and laboratory support areas  
1\. Before deciding to discard unused materials, determine if the chemicals can be used by   
someone else in the lab.  
2\. If the chemicals cannot be used by someone else, make a list of the chemicals you wish   
to dispose in a spreadsheet. The spreadsheet should include: the chemical name, the   
size of the container, the amount in the container (include units; this will also indicate   
whether or not the material is a liquid or solid) and what the material from which the   
container is made (plastic, glass, metal, etc.). A template is available on the EHS website.   
EHS may be available to assist with this process.  
3\. Email a copy of the spreadsheet to EHS and arrange a time when the chemicals can be   
removed from the area.  
4\. Do not discard unused materials into the trash or down the drain without prior written   
approval from EHS.  
5\. Once unused chemicals are collected, they must be labeled with the CAA hazardous   
waste label and then stored in the CAA. The date must also be applied.  
6\. Unused chemicals must be placed in secondary containers and stored in the same   
secondary container with compatible chemicals only.  
7\. Refer to the section on used chemical waste to see the shipping requirements prior to   
the waste leaving the site (step 6).  
Discarding unused materials in all other areas  
1\. Before deciding to discard unused materials, determine if the chemicals can be used by   
someone else.  
2\. If it is a single chemical or only a few chemicals, use the online request form to request   
removal of the chemicals. If there are multiple chemicals that need to be disposed,   
make a list of the chemicals you wish to dispose in a spreadsheet. The spreadsheet   
should include: the chemical name, the size of the container, the amount in the   
container (include units; this will also indicate whether or not the material is a liquid or   
solid) and what the material from which the container is made (plastic, glass, metal,   
etc.). A template is available on the EHS website. EHS may be available to assist with this   
process.  
3\. Email a copy of the spreadsheet to EHS and arrange a time when the chemicals can be   
removed from the area.  
4\. Do not discard unused materials into the trash or down the drain without prior written   
approval from EHS.  
5\. Once unused chemicals are collected, they must be labeled with the CAA hazardous   
waste label and then stored in the CAA. The date must also be applied.  
6\. Unused chemicals must be placed in secondary containers and stored in the same   
secondary container with compatible chemicals only.  
7\. Refer to the section on used chemical waste to see the shipping requirements prior to   
the waste leaving the site (step 7).  
Laboratory Cleanout  
When there are many chemicals that require disposal in a laboratory or laboratory support   
area, a laboratory cleanout may be required. The advantage of a laboratory cleanout is that any   
chemicals disposed as a part of the process do not count toward the university’s generator   
status. If 20 or more unused chemicals need to be removed from the lab, a laboratory cleanout   
will be scheduled. The following is the procedure for initiating and completing a laboratory   
cleanout.  
1\. Segregate the chemicals that will potentially be disposed from those that will be left in   
the lab. If the desire is to dispose of all chemicals in the lab, this step may be skipped.  
2\. Make a spreadsheet list of all the chemicals that will potentially be disposed. A template   
is available on the EHS website.  
3\. Provide the list to someone within your department that can distribute the list to other   
faculty/staff within the department. This will allow the potential for a chemical to be   
used rather than being disposed.  
4\. After one week, the remaining chemicals will be disposed. The list must be submitted to   
EHS at this point. This will be the beginning date of the laboratory cleanout. The   
laboratory cleanout must be completed within 30 days of the beginning date.  
5\. EHS will remove the chemicals from the laboratory and transport them to the CAA. The   
chemicals will be appropriately labeled and stored when they are brought into the CAA.  
Materials with Special Considerations  
Discuss with EHS handling of any of the following materials prior to disposal:  
 Biological materials  
 Sharps  
 Fluorescent bulbs  
 Batteries (other than alkaline)  
 Used oil  
 Anything containing mercury  
Central Accumulation Area (CAA)  
The central accumulation area must stay under the control of EHS at all times. Unauthorized   
personnel may not enter the CAA without being escorted by authorized personnel.  
Storage in CAA  
Storage in the CAA must follow ADEQ regulations. All chemically incompatible wastes must be   
segregated. For example, corrosive materials should be segregated from organic materials.   
Adequate aisle space must be maintained between secondary containment pallets, a minimum   
of three feet. All containers must be oriented in such a way that the hazardous waste label is   
clearly visible.  
Safety Equipment in CAA  
The best way to avoid an incident is for all personnel to be fully trained to their job duties   
(described in the next section) and to have access to the appropriate fully-functioning safety   
equipment. The following equipment should be available in or near the CAA:  
 A portable fire extinguisher  
 Spill cleanup materials including:  
 Absorbent material  
 Containers to store contaminated spill cleanup materials  
 Scoop or shovel for cleaning up the spill  
 Appropriate PPE to safely clean up the spill   
 Combination safety shower/eyewash  
Maintenance of this equipment is also important. A checklist should be maintained for   
materials contained in the spill kit. Portable fire extinguishers require annual certification and a   
monthly visual inspection. Safety showers must be flushed monthly. Eyewashes should be   
flushed weekly. Personnel in control of the CAA must be trained on how to use all the safety   
equipment and in what situations it should be used.  
Inspection in CAA  
The CAA must be inspected on a weekly basis. The following items should be checked:  
1\) Is the CAA secure?  
2\) Are all of the containers in good conditions (no leaks, properly closed and no evidence   
of spills?  
3\) Are wastes segregated based on compatibility?  
4\) Are all containers labeled and dated?  
5\) Do all containers have the appropriate waste codes on the label?  
6\) Is there less than 1000 kg (2206 lbs.) of waste accumulated in the last month?  
7\) Is there less than 6000 kg (13224 lbs.) of total waste stored?  
8\) Is there adequate aisle space (minimum 3 feet)?  
9\) Are all spill and decontamination materials present and in good working order?  
10\) Is the fire extinguisher at appropriate pressure and the annual inspection up to date?  
11\) Has the safety shower/eyewash been flushed?  
Generator training:  
A generator must be trained on how to identify whether or not a generated waste is a   
hazardous waste. This is accomplished by classroom (or online) training. This training should be   
attended within 6 months of initial assignment to a job where waste may be generated. While   
attendance of this training is only required once, it is recommended that each generator attend   
classroom (or online) training annually. Live training will be given by EHS upon request. The   
training will describe how a waste becomes classified as a hazardous waste as well as specific   
instruction on how to handle waste materials. Training records shall be kept by EHS.  
Environmental Health and Safety (EHS) personnel training:  
If EHS is also a generator, then he/she must attend or give hazardous waste generator training   
on an annual basis. Beyond that, there are additional requirements for EHS because they work   
in the CAA. These workers will, for the remainder of this section, be referred to as operators.  
Operators of the CAA will need the following training:  
 Hazardous waste management (annual)  
 HAZWOPER 24 hour (initial only), must also review who on site is responsible for safety   
and health, the hazards present on site and where to access safety equipment and PPE.  
 HAZWOPER 8 hour refresher (annual), must also review who on site is responsible for   
safety and health, the hazards present on site and where to access safety equipment   
and PPE.  
 DOT hazardous materials shipping training (every 3 years)  
 Fire extinguisher training (annual)  
A copy of all training records shall be kept by EHS. A job description for each operator must also   
be kept with the training records along with their duties regarding management of hazardous   
waste.  
Emergency Response  
Emergencies must be addressed by the emergency coordinator (EHS) or designee only. A phone   
must be designated for use to report hazardous waste incidences and the emergency   
coordinator’s (EC) number must be posted by this phone. The location of fire extinguishers, spill   
control materials and fire alarms must also be posted by this phone. Each of the following   
situations would be considered an emergency:  
 Fire: The EC or designee shall call the fire department to extinguish the fire unless it is in   
incipient stage (less than pallet size and the chemicals involved in the fire are known to   
be non-toxic and do not break down to toxic components when burned).  
 Spill: The EC or designee shall contain the spill and clean it up as soon as possible. The   
spill residues will need to be containerized and labeled appropriately before being   
stored in the CAA. If the spill leaves the site as defined below, it will be considered a   
threat to human health and should be reported as described below.  
 Unauthorized access: If the CAA is accessed by someone unauthorized to do so, the EC   
or designee shall investigate. If necessary, the EC or designee shall contact the police   
department.  
If there is a threat to human health outside of the facility, it is required to contact the National   
Response Center and ADEQ Emergency Response once the appropriate local authorities have   
been contacted. This needs to be done as soon as possible, normally within 15 minutes. Each   
agency will need the following information:  
 The name, address and EPA ID number of the facility  
 The date, time and type of incident  
 The quantity and type of hazardous waste  
 The extent of injuries (if any)  
 The quantity and disposition of recovered materials  
The following situations would be considered a threat to human health outside the facility:  
 A fire where the formation of toxic compound(s) occur upon combustion of the waste.  
 Any spill that leaves the site including onto the ground (unless all material can be   
recovered), into storm drains or into water (creek, stream, lake, river, etc.) including   
rainwater runoff that leads to a water source or storm drain.  
 Any incident with hazardous waste that leads to injuries beyond the facility borders.  
 Theft of hazardous waste if the waste makes it beyond the facility borders.   
Phone numbers of the local authorities as well as the national and state response centers with   
the information needed for calling them is in Appendix E.   
Recordkeeping  
The following are the record keeping requirements for hazardous waste:  
 All hazardous waste manifests must be maintained on site for a minimum of 3 years.  
 If a closed manifest is not received within 60 days, an unsigned copy of the manifest and   
a written explanation must be sent to ADEQ.  
 An annual declaration must be sent to ADEQ by January 31 of each calendar year.  
 If any hazardous waste is sent for analysis, records of the analysis must be kept for 3   
years. Note that analysis for waste determination must be done by an ADEQ approved   
laboratory. A list of these is available on the ADEQ website.  
 A written report of attempts to reduce the amount of hazardous waste generated (a   
waste minimization report) should be included with the annual declaration

# Spill Prevention Control and Countermeasures

[**Spill Prevention Control and Countermeasures**](https://astate.sharepoint.com/:p:/r/sites/EnvHealth/Shared%20Documents/General/Environmental%20Health%20and%20Safety/Environmental%20and%20Industrial%20Hygiene/Spill%20Prevention,%20Control,%20and%20Countermeasure/SPCC%20Training%20Presentation%20Rough%20Draft.pptx?d=w09cdb4c1e71b4bd389d10db4cb50015e&csf=1&web=1&e=eysq2h "Spill Prevention Control and Countermeasures") - Spill prevention deals with the university's efforts to prevent pollution (oil and other hazardous materials) from entering our waterways.

# Stormwater Pollution Prevention

[Stormwater Pollution Prevention](https://astate.sharepoint.com/:b:/r/sites/EnvHealth/Shared%20Documents/General/Environmental%20Health%20and%20Safety/Stormwater/Stormwater%20Management%20Plan.pdf?csf=1&web=1&e=EIHZCs "Stormwater Pollution Prevention") - Along with trying to keep our waterways clean, the university must also make measured efforts to keep pollution from entering stormwater, which will end up in our waterways.

Executive Summary  
The primary purpose of this plan is to meet the requirements of the Arkansas Department of   
Environmental Quality (ADEQ) issued National Pollutant Discharge Elimination System (NPDES) small   
Municipal Separate Storm Sewer System (MS4) permit issued to the Arkansas State University (A-State)  
main campus (Jonesboro). ADEQ enforces the requirement of the Clean Water Act (CWA) and this   
stormwater management plan (SWMP) outlines how A-State complies with the portions of the CWA that   
pertain to stormwater by meeting the permit requirements. The SWMP is meant to describe how AState identifies sources of pollution that might impact stormwater discharges, implements Best   
Management Practices (BMPs) for activities (such as construction and municipal tasks) to reduce   
pollution to stormwater and measures the effectiveness of BMPs in reducing discharge of pollutants into   
stormwater that leaves campus to associated waterways of the state.  
A-State Environmental Health and Safety (EHS) has the primary responsibility for ensuring compliance   
with stormwater requirements and for developing and implementing procedures to that end. A-State   
also has a Stormwater Advisory Committee (SWAC) that reviews procedures developed by EHS and   
makes recommendations prior to implementation. The SWAC has the opportunity to review   
construction plans to provide input on reducing the stormwater impact of those projects. EHS updates   
the SWAC quarterly on the activities it undertakes to meet the SWMP requirements.  
A-State EHS has identified sources of stormwater pollution and ranks them on the basis of the likelihood   
of each pollutant entering the stormwater conveyance. With the list of sources identified, EHS develops   
and implements BMPs for each Minimum Control Measure required by the state. Minimum control   
measures include: public education and outreach on stormwater impacts, public   
involvement/participation, illicit discharge detection and elimination, construction site stormwater   
runoff control, post-construction stormwater management in new development and redevelopment   
and pollution prevention/good housekeeping for municipal operations (for the A-State campus,   
municipal operations includes Facilities Management). This plan discusses how each BMP addresses the   
minimal control measures intended to reduce stormwater pollution and how the effectiveness of each   
BMP at achieving this goal is measured.  
In conjunction with the mission of Arkansas State University Environmental Health and Safety, EHS   
develops and uses training, educational materials and public involvement activities to raise awareness of   
the campus community to their role in protecting water quality. These activities help prevent some   
stormwater pollution before it occurs. When the potential for stormwater pollution is high, A-State has   
BMPs intended to ensure that every reasonable measure is taken to reduce the impact of stormwater   
pollution. This includes punitive measures for any on campus that violate the requirement set forth in   
this plan. We believe that the combination of these two approaches is the most effective means of   
reducing the impact of stormwater pollution on water quality. Reducing the impact of stormwater   
pollution on campus by these means is in line with university mission of educating leaders, enhancing   
intellectual growth and enriching lives.   
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Contents  
Executive Summary........................................................................................................................................................1  
Chapter 1: Introduction .................................................................................................................................................4  
1.1 Regulatory Background.......................................................................................................................................4  
1.2 Roles and Responsibilities....................................................................................................................................4  
1.2.1 Responsible Official ......................................................................................................................................5  
1.2.2 Environmental Health and Safety (Cognizant Official).................................................................................5  
1.2.3 Stormwater Advisory Committee (SWAC)....................................................................................................5  
1.2.4 Facilities Management.................................................................................................................................6  
1.2.5 Construction Site Management ...................................................................................................................6  
1.2.6 Other Contract Personnel.............................................................................................................................6  
1.2.7 Other Staff, Faculty and Administrators ......................................................................................................7  
1.2.8 Students and Other Campus Community Members.....................................................................................7  
Chapter 2: Site Information ...........................................................................................................................................7  
Chapter 3: Potential Sources of Stormwater Contamination.........................................................................................8  
Chapter 4: Minimum Control Measures ........................................................................................................................9  
Chapter 5: Best Management Practices ........................................................................................................................9  
5.1 Public Education and Outreach ...........................................................................................................................9  
5.1.1 Rationale....................................................................................................................................................10  
5.1.2 Implementation and Measurable Goals.....................................................................................................10  
5.2 Public Involvement/Participation ......................................................................................................................11  
5.2.1 Rationale....................................................................................................................................................11  
5.2.2 Implementation and Measurable Goals.....................................................................................................12  
5.3 Illicit Discharge Detection and Elimination........................................................................................................13  
5.3.1 Rationale....................................................................................................................................................13  
5.3.2 Implementation and Measurable Goals.....................................................................................................14  
5.4 Construction Site Stormwater Runoff Control ...................................................................................................14  
5.4.1 Rationale....................................................................................................................................................14  
5.4.2 Implementation and Measurable Goals.....................................................................................................15  
5.5 Post-Construction Stormwater Management in New Development and Redevelopment................................16  
5.5.1 Rationale....................................................................................................................................................16  
5.5.2 Implementation and Measurable Goals.....................................................................................................16  
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5.6 Pollution Prevention/Good Housekeeping for Facilities....................................................................................17  
5.6.1 Rationale....................................................................................................................................................17  
5.6.2 Implementation and Measurable Goals.....................................................................................................17  
Chapter 6: Recordkeeping............................................................................................................................................18  
6.1 SWMP Updating ................................................................................................................................................18  
6.2 Monitoring.........................................................................................................................................................18  
6.3 Recordkeeping...................................................................................................................................................18  
6.4 SWMP Annual Reports ......................................................................................................................................19  
Chapter 7: Enforcement of Stormwater Rules .............................................................................................................20  
7.1 Illicit Discharges.................................................................................................................................................20  
7.2 Construction Site Stormwater ...........................................................................................................................20  
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Chapter 1: Introduction  
Stormwater is water that starts to run along the ground rather than soaking into the ground.   
Stormwater can carry with it unwanted pollutants into the waterways of the state. The pollutants that   
stormwater can carry include sediment, oil, pesticides, nutrients (like fertilizer), litter and many others.   
These pollutants can have effects very near to the source of pollution (such as carrying mud and dirt   
onto a road or sidewalk creating an unsafe situation) and very far away (such as carrying fertilizers from   
crops planted in the Mississippi River drainage basin causing dead zones in the Gulf of Mexico near the   
mouth of the Mississippi River). Thus, it is important to take steps to minimize pollution to protect our   
natural resources including our drinking water. The ultimate purpose of stormwater management is for   
A-State to do its part in protecting the waterways of the state of Arkansas and the United States.   
1.1 Regulatory Background  
In 1948, the United States established the Federal Water Pollution Control Act. This was the first law to   
provide broad protection for our water from pollution. In 1972, the law was amended and became   
known as the Clean Water Act (CWA). The Environmental Protection Agency (EPA) is the entity   
responsible for writing the regulations to enforce the CWA. In the state of Arkansas, the Arkansas   
Department of Environmental Quality (ADEQ) is the agency tasked with enforcing the regulations.   
Arkansas State University is classified as a small Municipal Separate Storm Sewer System (MS4); a small   
MS4 is a municipality that has stormwater discharges from an urbanized area that serves less than   
100,000 individuals. Each MS4 must obtain a permit from the state to discharge stormwater to the   
waterways of the state. This permit, called a National Pollutant Discharge Elimination System (NPDES)   
permit, requires the covered MS4 to develop a Stormwater Management Plan (SWMP). A-State has had   
several SWMPs in past years; since the NPDES permit must be renewed in 2019, an update to the SWMP   
seemed appropriate. This SWMP is the document that A-State uses to provide guidance to university   
employees, contractors and students and to enforce the stormwater regulations.  
The program requirements for Arkansas State University include: application for an NPDES permit for   
stormwater discharge, development of a stormwater management plan (which describes the required   
six minimum control measures), implementation of a stormwater management program using   
appropriate best management practices (BMPs), development of measurable goals for the stormwater   
program and evaluation of the effectiveness of the program periodically. A copy of the current permit is   
appendix B to this plan.  
1.2 Roles and Responsibilities  
Like safety and compliance in other areas, the responsibility for preventing stormwater pollution lies   
with everyone in the community. Staff, faculty, students and contractors all have an important role in   
helping ensure that stormwater is polluted as little as practicable. The roles and responsibilities for each   
person in the community are listed below.  
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1.2.1 Responsible Official  
The responsible official is a person within the organization that has the authority to make decisions on   
behalf of the MS4. The responsible official at A-State is currently the Assistant Vice Chancellor for   
Human Resources. The responsibilities of the responsible official include:  
 Signing the permit application every time a renewal is required.  
 Reviewing and signing the annual report each year.  
 Responding to queries, inspections and findings by ADEQ.  
1.2.2 Environmental Health and Safety (Cognizant Official)  
The Environmental Health and Safety (EHS) office has the primary responsibility for ensuring university   
compliance with the requirements of the SWMP. The director of EHS is the cognizant official, which is   
the person authorized by the responsible official to have responsibility for the environmental matters of   
the campus. The responsibilities of EHS include:  
 Development and implementation of the SWMP and any related stormwater pollution   
prevention plans (SWPPPs).  
 Semiannual sampling of outfalls as required by the SWPPPs for certain stormwater-related   
pollutants.  
 Quarterly inspection of sites that have a SWPPP.  
 Comprehensive annual inspection of sites that have a SWPPP.  
 Review of construction plans to ensure compliance with stormwater regulations.  
 Monthly inspection of construction sites to check for compliance with stormwater regulations.  
 Communication of inspection findings to the appropriate campus or contractor authority to   
encourage correction.  
 Enforcement of requirements of the SWMP if non-compliant issues are not corrected. This can   
include work stoppage and levying of fines (upon agreement from Facilities Management and   
the responsible official).  
 Development of literature and training for informing faculty, staff, students, administration and   
contractors of the impacts of stormwater pollution.  
 Organization of events for public involvement in the identification and/or reduction of   
stormwater pollution.  
 Respond to stormwater complaints and issues reported by the campus community.  
1.2.3 Stormwater Advisory Committee (SWAC)  
The stormwater advisory committee is made up of individuals from various parts of the campus. The   
committee meets quarterly to discuss stormwater issues on campus. The SWAC includes member from   
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the following areas: Environmental Health and Safety, Ecotoxicology, Parking Services, Facilities   
Management (Landscape Architect, Grounds Services or Recycling and Building Services), the student   
body and from the community outside of A-State. The responsibilities of the SWAC include:  
 Review of to ensure compliance with stormwater regulations.  
 Periodic review of the SWMP and SWPPPs.  
 Providing of ideas for public involvement activities.  
1.2.4 Facilities Management  
Construction projects on the campus are completed through the construction office of Facilities   
Management. If the completed project will be managed by the university, Facilities Management has a   
greater role than projects that will be managed by outside entities. The responsibilities of Facilities   
Management include:  
 Signing of the Notice of Intent and the Notice of Termination for projects that will be managed   
by the university once completed.  
 Support of enforcement actions against construction contractors including stop work orders and   
fines.  
 Compliance with the requirements of the SWPPP written for Facilities Management including   
corrections of issues found on inspections.  
 Communication of projects that could impact stormwater quality to EHS.  
 Maintenance of BMPs associated with the Facilities Management site.  
1.2.5 Construction Site Management  
Construction site management are the individuals that have authority on the construction site to correct   
stormwater compliance issues that are found. This can be a project manager, engineer, site foreman or   
any other individual with such authority. The responsibilities of the construction site management   
include:  
 Development of the Notice of Intent and SWPPP for the construction site.  
 Completion of field inspection at the interval required by the SWPPP.  
 Maintenance of the SWPPP and the site map as changes are made.  
 Maintenance of BMPs on the construction site.  
 Correction of stormwater compliance issues identified by EHS on monthly inspections.  
 Communication of stormwater requirements to all contractors on the construction site.  
1.2.6 Other Contract Personnel  
Other contract personnel are individuals that work on campus that are not employed by the university   
that are not construction site management. These contract personnel may be individuals that work on a   
construction site or individuals that perform other tasks on campus. The responsibilities of other   
contract personnel include:  
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 Compliance with the stormwater requirements described in information provided to the   
contractor by Facilities Management (literature provided by EHS).  
 Correction of issues at the direction of construction site management (on construction sites only  
and only for issues caused by the contractor).  
1.2.7 Other Staff, Faculty and Administrators  
Most of the individuals on the A-State campus do not have an active daily role in stormwater   
compliance. However, they do have the opportunity to be additional sets of eyes on the campus at   
large. Stormwater issues can occur at any time and EHS only performs periodic inspections. The   
responsibilities of staff, faculty and administrators include:  
 Report any issues with stormwater pollution to EHS.  
 Complete stormwater awareness training.  
 Refrain from littering.  
1.2.8 Students and Other Campus Community Members  
Everyone else in the campus community has a role in helping control stormwater pollution as well. The   
responsibilities of everyone else include:  
 Report any issues with stormwater pollution to EHS.  
 Refrain from littering.  
Chapter 2: Site Information  
The Arkansas State University Jonesboro campus is located within the city limits of Jonesboro, Arkansas.  
The city of Jonesboro is a separate MS4 from the A-State MS4; some stormwater leaves the City of   
Jonesboro MS4 and enters the A-State MS4. All of the stormwater leaves the A-State MS4 into Turtle   
Creek. Turtle Creek flows into the St. Francis River which in turn empties into the Mississippi River. The   
Mississippi River empties into the Gulf of Mexico. Any pollution of stormwater within the campus of AState can have an impact very far from where it initially occurs.   
Before entering Turtle Creek, most of the stormwater from the university flows into a stormwater ditch   
known as Turtle Creek Lateral. In the past, A-State had clear cut this ditch once a year. However,   
Facilities Management and the Stormwater Advisory Committee agreed that allowing vegetation to   
grow on the ditch bank is a better way to manage the stormwater that flows on campus. This has the   
advantage of stabilizing the ditch banks and potentially removing unwanted contaminants from   
stormwater. For these reasons, A-State no longer clear cuts Turtle Creek Lateral. A-State intends to   
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study the scientific literature on the subject and perhaps perform novel research regarding storm ditch   
vegetation during the permit cycle.  
A-State has many places where stormwater can enter the waterways of   
the state. There are stormwater inlets all over campus; EHS is working   
to ensure that all stormwater inlets are marked with an indicating plate   
demonstrating that they drain to a waterway (an example is pictured to   
the right). A map of these inlets is included in appendix D of this plan.   
EHS plans to have every inlet marked by the end of 2019. Water from   
these inlets and other places makes its way to about 50 outfalls from   
the university. EHS inspects these outfalls annually during periods of   
dry weather to detect any illicit discharges to stormwater conveyance. A   
map of these outfalls is included in appendix E of this plan. Finally, as of   
2019, the Arkansas State University MS4 does not discharge   
stormwater to any impaired waters.  
Chapter 3: Potential Sources of Stormwater Contamination  
It is important to identify the potential sources of stormwater contamination to maximize the   
effectiveness of control measures. Identification of these contaminants is determined by past and   
current sampling of stormwater as well as knowledge of the day-to-day operations of the university. The   
table below lists the contaminants, their sources and frequency of occurrence.  
Figure 2: Potential Sources of Contamination of Stormwater.   
Figure 1: Stormwater Drain Marker  
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Most contamination of stormwater can be prevented by simply taking measures to control them. Some   
sources cannot be controlled so easily, though. For example, oil and fuel that leaks from vehicles while   
driving on the road is inevitable. These types of pollution contribute little to the overall pollution.   
Control measures are primarily concerned with educating people to keep the rare events from becoming  
frequent and controlling the common and large quantity contaminants that are caused by human   
activity. While A-State strives to eliminate as much pollution as feasible from stormwater conveyance,   
primary attention is given to controlling sediment runoff due to human activity, which is the most   
common pollutant to the waterways of the state according to the Environmental Protection Agency. 70   
percent of sediment erosion into waterways is caused by human activity.  
Chapter 4: Minimum Control Measures  
Because of the risk of stormwater pollution to the health of our environment, EPA and ADEQ require as   
a part of our permit and SWMP certain minimum control measures. The six minimum control measures   
include:  
 Public education and outreach on stormwater impacts,  
 Public involvement/participation,  
 Illicit discharge detection and elimination,  
 Construction site stormwater runoff control,  
 Post-construction stormwater management in new development and redevelopment and  
 Pollution prevention/good housekeeping for municipal operations.  
For each control measure, A-State is required to have best management practices (BMPs) implemented   
for each measure and measurable goals for determining the success of each BMP including a rationale   
for why each BMP and associated measureable goals were chosen. The individuals tasked with   
implementing and coordinating the BMPs described in the SWMP is also required, including an   
organizational chart. The organizational chart is Appendix F of this plan.  
Chapter 5: Best Management Practices  
Best management practices are the strategies an entity employs in implementing control measures. The   
goal of these BMPs is to reduce stormwater pollution. Some BMPs directly influence contaminant levels   
by actively blocking water or filtering it before it moving into stormwater conveyance. The majority of   
BMPs are indirect, though. Whether it be inspection of areas to look for risks of contamination or public   
education and involvement initiatives, the goal of these indirect practices is to increase awareness about   
stormwater pollution and because of such prevent some pollution before it happens. This section   
outlines the BMPs that are used by A-State and the rationale behind selecting these BMPs to meet the   
minimum control measures required by the EPA and ADEQ.  
5.1 Public Education and Outreach  
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This control measure is intended to increase public awareness about stormwater pollution. The more   
aware the public is of the impacts of stormwater pollution, the more likely they are to take action to   
prevent or lessen it in their daily activities. Public education and outreach is intended to help the public,   
which at A-State includes students, faculty, staff and contractors, understand the types of stormwater   
pollution and what they can specifically do to reduce stormwater pollution.  
5.1.1 Rationale  
While awareness of pollution in general has grown in the public in the years since the initial first   
requirements for small MS4s to obtain a permit from the state for the discharge of stormwater, the   
public in general is still largely unaware of the impacts of stormwater pollution. A-State being an   
institution of higher learning is uniquely positioned to meet the goal of public education as education is   
the primary reason for the existence of the university. The public education and outreach goals are   
approved and updated by the Stormwater Advisory Committee and are chosen to reach as much of the   
public as possible. It is the goal of A-State to reach 100% of the campus community during the 5 year   
term of each permit cycle. The BMPs chosen are listed in the next section and are chosen to maximize   
this potential.  
The permit also requires that A-State chose five different themes to highlight during the permit term.   
These themes were chosen to address the most common forms or stormwater pollution that occur with   
the greatest frequency. The public education themes include:  
 Oil, petroleum products and other process chemicals -- 2019  
 Herbicides and pesticides -- 2020  
 Erosion control (construction activities and grounds maintenance) -- 2021  
 Illicit discharge detection -- 2022  
 Litter and debris – 2023  
The development and distribution of materials is largely the responsibility of the Director of EHS with   
input from the Stormwater Advisory Committee and Facilities Management.  
5.1.2 Implementation and Measurable Goals  
Most of these BMPs have already been implemented in past years, but there are some new BMPs and   
measurable goals for those BMPs. Each of these is described in the table below. Distribution of   
brochures reaches more individuals than any of the other methods as students are required to   
participate in safety week. Over the course of the permit cycle, 100% of the students are reached. The   
brochures also reach all employees that go through new employee orientation (required for new   
employees) and any that participate in the benefits fair. Stormwater training reaches Facilities   
Management personnel (required annually) and many others. New brochures targeted toward   
contractors should reach close to 100% of contractors on campus.  
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Figure 3: Best Management Practices for Public Education and Outreach  
5.2 Public Involvement/Participation  
This control measure is intended to increase public inclusion in and participation in the campus   
stormwater management. According to EPA Factsheet 2.4 for the Stormwater Phase II Final Rule, “The   
public can provide valuable input and assistance to a regulated small MS4’s municipal stormwater   
management program…” A-State wants the public (which includes the faculty, staff and students) to   
have as much involvement as they wish to have in the stormwater management program. Public   
involvement and participation activities are targeted toward encouraging engagement in our   
environmental programs, including stormwater management.  
5.2.1 Rationale  
A-State has historically had several ways that the campus community can be involved in stormwater   
management at the university. The Stormwater Advisory Committee includes members from various   
places within the campus community and includes one member from outside the campus community.   
The A-State Environmental Health and Safety Office participates annually in community awareness   
activities, like Earth Day, to educate the campus community and beyond on the impacts or stormwater   
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pollution, preventative measures that the university undertakes and ideas on how the community can   
impact water quality. We have both of these methods to be effective in meeting the goal of public   
participation so we have decided to continue both of these best management practices.  
The Stormwater Advisory Committee had some additional ideas on how we could increase community   
involvement. These ideas included continuing to pursue campus community cleanup initiatives and a   
newsletter to the campus community that highlights stormwater activity. Having a community cleanup   
involves the community more intimately, but tends not to be very broad in scope. A newsletter is the   
converse of that; it is lest impactful but reaches more people. Thus, the committee felt that having both   
types of BMPs would have the maximum impact on the community. Along with these two new ideas,   
EHS intends to finish marking all storm drains by the end of the permit cycle. We have asked employees   
to become involved in this endeavor by informing EHS when they observe an unmarked storm drain.  
5.2.2 Implementation and Measurable Goals  
As mentioned above, two of these BMPs have been implemented in past years. In addition to these two,   
there are three new BMPs. They are listed in the table below. We feel this combination of BMPs will   
increase public involvement both in the number of people involved and the depth of their involvement   
in stormwater pollution prevention. While having 100% of the public involved is not realistic, providing a   
variety of opportunities for the public involvement gives 100% of the campus community the option of   
participating.  
Figure 4: Best Management Practices for Public Involvement/Participation  
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5.3 Illicit Discharge Detection and Elimination  
An illicit discharge is defined by federal regulations as “…any discharge to a MS4 that is not composed   
entirely of stormwater…”, although there are a few exceptions to this rule. This control measure is   
intended to reduce the amount of stormwater pollution that occurs by unauthorized discharges and   
illegal dumping. This is accomplished by a combination of identification of outfalls, visual inspections,   
training, reporting mechanisms and response to illicit discharges if they do occur.  
There are a number of non-stormwater discharges that are allowed under the NPDES permit conditions.   
These include:  
While these discharges are allowed, the campus community is encouraged to minimize these types of   
discharges as well. Guidance for reducing these types of discharges to stormwater is given in the   
stormwater awareness training, literature distributed at events and on the A-State Environmental   
Health and Safety website on the page dedicated to stormwater.  
5.3.1 Rationale  
Detection and elimination of illicit discharges to stormwater requires a multi-faceted approach.   
Identification of potential problem areas, training on how to identify illicit discharges and a mechanism   
for reporting such issues are all items that A-State considers important for this BMP to be effective. A   
map of stormwater outfalls (Appendix E) and visual inspection of those outfalls are practices that are   
currently underway at A-State. The map is reviewed on an annual basis for accuracy and is also updated   
when new outfalls are added. The response to illicit discharges has also already been implemented;   
however, the mechanism for correction and enforcement will change with the new permit. Enforcement   
of stormwater rules is discussed in chapter 7 of this SWMP.  
Training of employees on identifying illicit discharges is something that A-State has been doing in   
training for a number of years, but this had not been counted as a measurable goal. More detail has   
been added to the training this year. Because of this training, there have been informal reports for illicit   
discharges (emails, phone calls, etc.), but there has never been an official reporting mechanism. A-State   
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and the SWAC feel that having a specific reporting mechanism will make reporting concerns easier, thus,   
adding this as a measurable goal seems appropriate.  
5.3.2 Implementation and Measurable Goals  
As mentioned above, three of these BMPs have been implemented in past years. In addition to these   
two, there are two new BMPs. They are listed in the table below. The BMPs that have already been   
implemented (map of stormwater outfalls, visual inspection of outfalls during dry weather and response   
to illicit discharges) have been effective in the past and thus will continue to be measured. The new   
BMPs should enhance our effectiveness in identifying and eliminating illicit discharges.  
Figure 5: Best Management Practices for Illicit Discharge Detection and Elimination  
5.4 Construction Site Stormwater Runoff Control  
Stormwater runoff from construction sites can cause environmental problems and is unsightly when it is   
polluted with sediment due to lack of effective BMPs. Sediment is the main pollutant of concern in   
stormwater according to the EPA. Thus the majority of attention on construction sites is dedicated to   
allowing the lowest amount of sediment practicable to leave the construction site. The construction site  
management is responsible for BMPs to control sediment leaving the construction site; A-State is   
responsible for ensuring that construction sites are using and maintaining the appropriate BMPs on the   
construction site.  
5.4.1 Rationale  
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A-State EHS and the stormwater advisory committee have determined that the current BMPs used for   
construction site stormwater runoff control are effective so those BMPs will remain in place. A more   
well-defined enforcement procedure for non-compliance with stormwater requirements at construction   
sites is necessary. A-State has been using the city of Jonesboro enforcement procedure up to this point;   
a simpler procedure has been devised with similar penalties to the city. The end goal being of   
implementing a new procedure is improvement to the overall performance of BMPs on a construction   
site when inadequacies are found rather than simply punitive measures.   
5.4.2 Implementation and Measurable Goals  
Site plan review for construction and monthly inspection of construction sites are BMPs that have long   
been a part of the stormwater management program. These BMPs will continue to be used as they are   
required by regulations and have been deemed very effective. A new, formal escalation process for   
enforcement of stormwater requirements has been developed. This new procedure better explains the   
expectations and responses to noncompliance issues of Arkansas State University. Enforcement   
procedures are explained more fully in chapter 7. Lastly, the ability of the public to comment on   
stormwater concerns relating to construction activities is a permit requirement. The addition of a   
reporting mechanism for illicit discharges will be added to the EHS website (see previous section). This   
same mechanism can be used for reporting issues with construction site activities as well. The best   
management practices for construction site stormwater runoff control are listed in the table below.  
Figure 6: Best Management Practices for Construction Site Stormwater Runoff Control  
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5.5 Post-Construction Stormwater Management in New Development and Redevelopment  
When redevelopment takes place within the A-State MS4 that disturbs an acre or greater, the project is   
treated the same as a new construction projects. All of the BMPs that apply to construction sites equally   
apply to redevelopment. The primary purpose for the best management practices that occur in this   
section is ensuring that the stormwater compliance process is seen through past the end of the   
construction phase. Furthermore, post-construction stormwater management must be considered in   
the design phase to achieve the required goal of 80% or greater removal of total suspended solid (TSS)   
from flows if the TSS exceeds the predevelopment level. Design of systems to retain stormwater for   
ground infiltration or slow stormwater flow is also encouraged in the design process.  
5.5.1 Rationale  
As mentioned above, several BMPs that apply to other areas equally apply to post-construction   
stormwater management. However, there are a few areas that are not addressed in other sections.   
First, the completion of a Notice of Termination (NOT) is required for any site that has completed   
construction. Since this is completed after construction has finished, it seems appropriate for it to be   
included as a post-construction BMP. This is the only BMP for post-construction that is completed after   
construction.  
Planning is necessary prior to construction for some of the post-construction requirements to be   
implemented. New stormwater outfalls may be constructed if a new construction or redevelopment   
takes place near the campus perimeter. Other stormwater issues can be identified prior to construction   
if EHS and the stormwater advisory committee are a part of the design review process. Facilities   
Management has informally asked for input regarding stormwater from EHS and the SWAC on new   
construction and redevelopment in the past. EHS and the SWAC will continue to be a part of the design   
process, specifically as it relates to stormwater management into the future. Thus, identification of new   
outfalls as the result of new construction or redevelopment and design review for post-construction   
stormwater management seem appropriate as BMPs. As physical post-construction stormwater BMPs  
are added as the result of new construction or redevelopment, additional inspections regarding   
maintenance of these physical BMPs will be added.  
5.5.2 Implementation and Measurable Goals  
Notices of termination have been completed for construction projects according to the regulations since   
A-State became a small MS4, but this has not been counted as a measurable goal until now. Adding this   
as a measurable goal will help ensure that NOTs are completed in a timely manner. Outfalls have also   
been added in an informal manner in the past; using this as a measurable goal will help ensure that new   
outfalls are identified early in the design and construction process rather than during or even after   
construction. Lastly, using design review for post-construction stormwater management as a   
measurable goal will ensure that EHS and the SWAC continue to have a seat at the table in the design   
phase. The best management practices for post-construction stormwater management in new   
development and redevelopment are listed in the table below.  
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Figure 7: Best Management Practices for Post-Construction Stormwater Management in New Development and Redevelopment  
5.6 Pollution Prevention/Good Housekeeping for Facilities  
Good housekeeping may be the most important aspect of stormwater pollution prevention. If areas   
within the MS4 that have the potential to pollute stormwater are kept neat and clean, the likelihood of   
those areas causing a contamination issue are greatly reduced. The most important elements of a good   
housekeeping program for municipal operations are training, inspection and procedures directly   
targeted as maintaining cleanliness. All of these aspects are addressed in the BMPs used by A-State in   
this section and other sections of the stormwater management plan.  
5.6.1 Rationale  
Training, inspections and cleaning procedures are the critical components of a good housekeeping   
program, thus it is appropriate to address all three of these areas with best management practices.   
Training on good housekeeping (along with other aspects of stormwater management) is included as a   
best management practices in other sections of this plan; to include it as a BMP in this section would be   
redundant. Inspection of areas at Facilities Management (the primary area of municipal activities) that   
have the potential to pollute stormwater and inspection of fuel storage areas all over campus are vital to   
ensure that these areas are well-maintained. Regular inspections are counted as a BMP. Efforts made to   
keep the campus clean also contribute to reducing stormwater pollution therefore these items are   
included as BMPs as well.  
5.6.2 Implementation and Measurable Goals  
Street sweeping, trash/litter collection and recycling are ongoing BMPs from previous SWMPs.   
Inspection of municipal operations has been occurring for many years as well, but has not been listed as   
a BMP in the stormwater management plan until now. Inspection of oil storage areas is a part of another   
environmental plan, but has not been included in this plan until now. The best management practices   
for pollution prevention and good housekeeping for are listed in the table below.  
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Figure 7: Best Management Practices for Pollution Prevention and Good Housekeeping in Facilities  
Chapter 6: Recordkeeping  
All records regarding stormwater management are kept and maintained by Arkansas State University   
Environmental Health and Safety department. The records kept include annual reports, inspection   
reports, email communications (when necessary), testing results (when sampling is performed),   
stormwater advisory committee meeting minutes and any communication between the state (ADEQ)   
and the university regarding stormwater. Details on how the records are kept and how long they are   
maintained is given in section 6.3  
6.1 SWMP Updating  
By permit requirement, the SWMP must be reviewed annually to see if updates are necessary. A   
standing item on the fall SWAC meeting agenda is review of the SWMP. Review of the plan will be   
documented in Appendix A. Changes will also be documented here. If a change requires resubmission of   
the SWMP to the state, this will be documented in this appendix and the appendix will be transferred to   
the new SWMP.  
6.2 Monitoring  
Requires monitoring of stormwater for the A-State MS4 includes inspection of outfalls during dry   
weather. All outfalls are inspected annually and some outfalls that have the highest risk of having illicit   
discharge are monitored quarterly. While sampling and testing are not required within the A-State MS4  
because of the lack of activities require sampling, EHS reserves the right to sample stormwater when   
illicit discharge is expected or if there is suspicion of some impact to the environment.  
6.3 Recordkeeping  
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Records for stormwater are kept in two ways: most records for the current year are kept in a notebook   
with sections for each type of record. Records kept this way include: construction site inspections,   
municipal activities inspections, monthly stormwater checklists for Facilities Management, annual   
reports to ADEQ and stormwater advisory committee meeting minutes. Notices of coverage and   
stormwater pollution prevention plans for construction sites are kept in a filing cabinet in the EHS   
Director’s office.   
All records are kept for a minimum of three years. Many records are kept beyond this because the   
records are used for historical purposes. Notices of coverage for ongoing project are posted on the   
construction site and are available to the public for viewing. These NOCs are removed once the notice of   
termination has been accepted by the state.  
6.4 SWMP Annual Reports  
A-State must complete an annual report to ADEQ each year. According to the permit, the following   
items must be included in the report:  
 The status of compliance with permit conditions;  
 An assessment of the appropriateness of the identified best management practices and the   
progress towards achieving the measureable goal for each of the minimum control measures;  
 Results of information collected and analyzed, if any, during the reporting period, including   
monitoring data used to assess the success of the program at reducing the discharge of   
pollutants;  
 A summary of the stormwater activities A-State plans to undertake during the next reporting   
cycle (including an implementation schedule);  
 Proposed changes to the stormwater management program, including changes to any BMPs or   
any identified measurable goals that apply to the program elements;  
 Description and schedule for implementation of additional BMPs that may be necessary, based   
on monitoring results, to ensure compliance with applicable TMDLs and implementation plans   
and  
 Notice that A-State is relying on another government entity to satisfy some of the permit   
obligations (if applicable).  
The last two bullet points do not currently apply to A-State, but they are listed here since they appear in   
the permit. The annual report is completed using a template downloaded from the ADEQ website. The   
annual report is completed and submitted by March 31 of each year.  
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Chapter 7: Enforcement of Stormwater Rules  
To ensure that the campus community, including contractors that are on campus, comply with the   
stormwater regulations, and enforcement mechanism is necessary. Previously, A-State had used the   
Jonesboro City ordinance as the enforcement procedure for stormwater violations. However, A-State   
has now developed a separate procedure that is similar to the city ordinance, but is adapted to meet the   
unique needs of the university community.  
7.1 Illicit Discharges  
Illicit discharges are any discharges other than stormwater to the waters of the state. A-State has best   
management practices in place to help prevent illicit discharges; however, unforeseen events,   
carelessness or purposeful action can lead to illicit discharges that cannot be controlled by any BMPs.   
Thus, A-State has a SOP that specifically outlines the process for escalating and enforcing the   
stormwater rules, which includes the prohibition on illicit discharges. The enforcement procedure for   
illicit discharges is explained in SOP SW-002 Enforcement of Stormwater Requirements on Campus and is   
attached as Appendix G to this plan.  
7.2 Construction Site Stormwater  
Construction sites have the highest probability of contaminating stormwater and thus need more   
regular attention. Inspections are performed on construction sites at least monthly. A clearly defined   
enforcement procedure is necessary to ensure that any non-compliant issues found as a result of   
inspections are corrected in a timely manner. The enforcement procedure for construction site   
stormwater is explained in SOP SW-001 Enforcement of Stormwater Requirements on Construction Sites   
and is attached as Appendix H to this plan

# Stormwater Management Plan

Executive Summary  
The primary purpose of this plan is to meet the requirements of the Arkansas Department of   
Environmental Quality (ADEQ) issued National Pollutant Discharge Elimination System (NPDES) small   
Municipal Separate Storm Sewer System (MS4) permit issued to the Arkansas State University (A-State)  
main campus (Jonesboro). ADEQ enforces the requirement of the Clean Water Act (CWA) and this   
stormwater management plan (SWMP) outlines how A-State complies with the portions of the CWA that   
pertain to stormwater by meeting the permit requirements. The SWMP is meant to describe how AState identifies sources of pollution that might impact stormwater discharges, implements Best   
Management Practices (BMPs) for activities (such as construction and municipal tasks) to reduce   
pollution to stormwater and measures the effectiveness of BMPs in reducing discharge of pollutants into   
stormwater that leaves campus to associated waterways of the state.  
A-State Environmental Health and Safety (EHS) has the primary responsibility for ensuring compliance   
with stormwater requirements and for developing and implementing procedures to that end. A-State   
also has a Stormwater Advisory Committee (SWAC) that reviews procedures developed by EHS and   
makes recommendations prior to implementation. The SWAC has the opportunity to review   
construction plans to provide input on reducing the stormwater impact of those projects. EHS updates   
the SWAC quarterly on the activities it undertakes to meet the SWMP requirements.  
A-State EHS has identified sources of stormwater pollution and ranks them on the basis of the likelihood   
of each pollutant entering the stormwater conveyance. With the list of sources identified, EHS develops   
and implements BMPs for each Minimum Control Measure required by the state. Minimum control   
measures include: public education and outreach on stormwater impacts, public   
involvement/participation, illicit discharge detection and elimination, construction site stormwater   
runoff control, post-construction stormwater management in new development and redevelopment   
and pollution prevention/good housekeeping for municipal operations (for the A-State campus,   
municipal operations includes Facilities Management). This plan discusses how each BMP addresses the   
minimal control measures intended to reduce stormwater pollution and how the effectiveness of each   
BMP at achieving this goal is measured.  
In conjunction with the mission of Arkansas State University Environmental Health and Safety, EHS   
develops and uses training, educational materials and public involvement activities to raise awareness of   
the campus community to their role in protecting water quality. These activities help prevent some   
stormwater pollution before it occurs. When the potential for stormwater pollution is high, A-State has   
BMPs intended to ensure that every reasonable measure is taken to reduce the impact of stormwater   
pollution. This includes punitive measures for any on campus that violate the requirement set forth in   
this plan. We believe that the combination of these two approaches is the most effective means of   
reducing the impact of stormwater pollution on water quality. Reducing the impact of stormwater   
pollution on campus by these means is in line with university mission of educating leaders, enhancing   
intellectual growth and enriching lives.   
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Contents  
Executive Summary........................................................................................................................................................1  
Chapter 1: Introduction .................................................................................................................................................4  
1.1 Regulatory Background.......................................................................................................................................4  
1.2 Roles and Responsibilities....................................................................................................................................4  
1.2.1 Responsible Official ......................................................................................................................................5  
1.2.2 Environmental Health and Safety (Cognizant Official).................................................................................5  
1.2.3 Stormwater Advisory Committee (SWAC)....................................................................................................5  
1.2.4 Facilities Management.................................................................................................................................6  
1.2.5 Construction Site Management ...................................................................................................................6  
1.2.6 Other Contract Personnel.............................................................................................................................6  
1.2.7 Other Staff, Faculty and Administrators ......................................................................................................7  
1.2.8 Students and Other Campus Community Members.....................................................................................7  
Chapter 2: Site Information ...........................................................................................................................................7  
Chapter 3: Potential Sources of Stormwater Contamination.........................................................................................8  
Chapter 4: Minimum Control Measures ........................................................................................................................9  
Chapter 5: Best Management Practices ........................................................................................................................9  
5.1 Public Education and Outreach ...........................................................................................................................9  
5.1.1 Rationale....................................................................................................................................................10  
5.1.2 Implementation and Measurable Goals.....................................................................................................10  
5.2 Public Involvement/Participation ......................................................................................................................11  
5.2.1 Rationale....................................................................................................................................................11  
5.2.2 Implementation and Measurable Goals.....................................................................................................12  
5.3 Illicit Discharge Detection and Elimination........................................................................................................13  
5.3.1 Rationale....................................................................................................................................................13  
5.3.2 Implementation and Measurable Goals.....................................................................................................14  
5.4 Construction Site Stormwater Runoff Control ...................................................................................................14  
5.4.1 Rationale....................................................................................................................................................14  
5.4.2 Implementation and Measurable Goals.....................................................................................................15  
5.5 Post-Construction Stormwater Management in New Development and Redevelopment................................16  
5.5.1 Rationale....................................................................................................................................................16  
5.5.2 Implementation and Measurable Goals.....................................................................................................16  
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5.6 Pollution Prevention/Good Housekeeping for Facilities....................................................................................17  
5.6.1 Rationale....................................................................................................................................................17  
5.6.2 Implementation and Measurable Goals.....................................................................................................17  
Chapter 6: Recordkeeping............................................................................................................................................18  
6.1 SWMP Updating ................................................................................................................................................18  
6.2 Monitoring.........................................................................................................................................................18  
6.3 Recordkeeping...................................................................................................................................................18  
6.4 SWMP Annual Reports ......................................................................................................................................19  
Chapter 7: Enforcement of Stormwater Rules .............................................................................................................20  
7.1 Illicit Discharges.................................................................................................................................................20  
7.2 Construction Site Stormwater ...........................................................................................................................20  
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Chapter 1: Introduction  
Stormwater is water that starts to run along the ground rather than soaking into the ground.   
Stormwater can carry with it unwanted pollutants into the waterways of the state. The pollutants that   
stormwater can carry include sediment, oil, pesticides, nutrients (like fertilizer), litter and many others.   
These pollutants can have effects very near to the source of pollution (such as carrying mud and dirt   
onto a road or sidewalk creating an unsafe situation) and very far away (such as carrying fertilizers from   
crops planted in the Mississippi River drainage basin causing dead zones in the Gulf of Mexico near the   
mouth of the Mississippi River). Thus, it is important to take steps to minimize pollution to protect our   
natural resources including our drinking water. The ultimate purpose of stormwater management is for   
A-State to do its part in protecting the waterways of the state of Arkansas and the United States.   
1.1 Regulatory Background  
In 1948, the United States established the Federal Water Pollution Control Act. This was the first law to   
provide broad protection for our water from pollution. In 1972, the law was amended and became   
known as the Clean Water Act (CWA). The Environmental Protection Agency (EPA) is the entity   
responsible for writing the regulations to enforce the CWA. In the state of Arkansas, the Arkansas   
Department of Environmental Quality (ADEQ) is the agency tasked with enforcing the regulations.   
Arkansas State University is classified as a small Municipal Separate Storm Sewer System (MS4); a small   
MS4 is a municipality that has stormwater discharges from an urbanized area that serves less than   
100,000 individuals. Each MS4 must obtain a permit from the state to discharge stormwater to the   
waterways of the state. This permit, called a National Pollutant Discharge Elimination System (NPDES)   
permit, requires the covered MS4 to develop a Stormwater Management Plan (SWMP). A-State has had   
several SWMPs in past years; since the NPDES permit must be renewed in 2019, an update to the SWMP   
seemed appropriate. This SWMP is the document that A-State uses to provide guidance to university   
employees, contractors and students and to enforce the stormwater regulations.  
The program requirements for Arkansas State University include: application for an NPDES permit for   
stormwater discharge, development of a stormwater management plan (which describes the required   
six minimum control measures), implementation of a stormwater management program using   
appropriate best management practices (BMPs), development of measurable goals for the stormwater   
program and evaluation of the effectiveness of the program periodically. A copy of the current permit is   
appendix B to this plan.  
1.2 Roles and Responsibilities  
Like safety and compliance in other areas, the responsibility for preventing stormwater pollution lies   
with everyone in the community. Staff, faculty, students and contractors all have an important role in   
helping ensure that stormwater is polluted as little as practicable. The roles and responsibilities for each   
person in the community are listed below.  
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1.2.1 Responsible Official  
The responsible official is a person within the organization that has the authority to make decisions on   
behalf of the MS4. The responsible official at A-State is currently the Assistant Vice Chancellor for   
Human Resources. The responsibilities of the responsible official include:  
 Signing the permit application every time a renewal is required.  
 Reviewing and signing the annual report each year.  
 Responding to queries, inspections and findings by ADEQ.  
1.2.2 Environmental Health and Safety (Cognizant Official)  
The Environmental Health and Safety (EHS) office has the primary responsibility for ensuring university   
compliance with the requirements of the SWMP. The director of EHS is the cognizant official, which is   
the person authorized by the responsible official to have responsibility for the environmental matters of   
the campus. The responsibilities of EHS include:  
 Development and implementation of the SWMP and any related stormwater pollution   
prevention plans (SWPPPs).  
 Semiannual sampling of outfalls as required by the SWPPPs for certain stormwater-related   
pollutants.  
 Quarterly inspection of sites that have a SWPPP.  
 Comprehensive annual inspection of sites that have a SWPPP.  
 Review of construction plans to ensure compliance with stormwater regulations.  
 Monthly inspection of construction sites to check for compliance with stormwater regulations.  
 Communication of inspection findings to the appropriate campus or contractor authority to   
encourage correction.  
 Enforcement of requirements of the SWMP if non-compliant issues are not corrected. This can   
include work stoppage and levying of fines (upon agreement from Facilities Management and   
the responsible official).  
 Development of literature and training for informing faculty, staff, students, administration and   
contractors of the impacts of stormwater pollution.  
 Organization of events for public involvement in the identification and/or reduction of   
stormwater pollution.  
 Respond to stormwater complaints and issues reported by the campus community.  
1.2.3 Stormwater Advisory Committee (SWAC)  
The stormwater advisory committee is made up of individuals from various parts of the campus. The   
committee meets quarterly to discuss stormwater issues on campus. The SWAC includes member from   
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the following areas: Environmental Health and Safety, Ecotoxicology, Parking Services, Facilities   
Management (Landscape Architect, Grounds Services or Recycling and Building Services), the student   
body and from the community outside of A-State. The responsibilities of the SWAC include:  
 Review of to ensure compliance with stormwater regulations.  
 Periodic review of the SWMP and SWPPPs.  
 Providing of ideas for public involvement activities.  
1.2.4 Facilities Management  
Construction projects on the campus are completed through the construction office of Facilities   
Management. If the completed project will be managed by the university, Facilities Management has a   
greater role than projects that will be managed by outside entities. The responsibilities of Facilities   
Management include:  
 Signing of the Notice of Intent and the Notice of Termination for projects that will be managed   
by the university once completed.  
 Support of enforcement actions against construction contractors including stop work orders and   
fines.  
 Compliance with the requirements of the SWPPP written for Facilities Management including   
corrections of issues found on inspections.  
 Communication of projects that could impact stormwater quality to EHS.  
 Maintenance of BMPs associated with the Facilities Management site.  
1.2.5 Construction Site Management  
Construction site management are the individuals that have authority on the construction site to correct   
stormwater compliance issues that are found. This can be a project manager, engineer, site foreman or   
any other individual with such authority. The responsibilities of the construction site management   
include:  
 Development of the Notice of Intent and SWPPP for the construction site.  
 Completion of field inspection at the interval required by the SWPPP.  
 Maintenance of the SWPPP and the site map as changes are made.  
 Maintenance of BMPs on the construction site.  
 Correction of stormwater compliance issues identified by EHS on monthly inspections.  
 Communication of stormwater requirements to all contractors on the construction site.  
1.2.6 Other Contract Personnel  
Other contract personnel are individuals that work on campus that are not employed by the university   
that are not construction site management. These contract personnel may be individuals that work on a   
construction site or individuals that perform other tasks on campus. The responsibilities of other   
contract personnel include:  
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 Compliance with the stormwater requirements described in information provided to the   
contractor by Facilities Management (literature provided by EHS).  
 Correction of issues at the direction of construction site management (on construction sites only  
and only for issues caused by the contractor).  
1.2.7 Other Staff, Faculty and Administrators  
Most of the individuals on the A-State campus do not have an active daily role in stormwater   
compliance. However, they do have the opportunity to be additional sets of eyes on the campus at   
large. Stormwater issues can occur at any time and EHS only performs periodic inspections. The   
responsibilities of staff, faculty and administrators include:  
 Report any issues with stormwater pollution to EHS.  
 Complete stormwater awareness training.  
 Refrain from littering.  
1.2.8 Students and Other Campus Community Members  
Everyone else in the campus community has a role in helping control stormwater pollution as well. The   
responsibilities of everyone else include:  
 Report any issues with stormwater pollution to EHS.  
 Refrain from littering.  
Chapter 2: Site Information  
The Arkansas State University Jonesboro campus is located within the city limits of Jonesboro, Arkansas.  
The city of Jonesboro is a separate MS4 from the A-State MS4; some stormwater leaves the City of   
Jonesboro MS4 and enters the A-State MS4. All of the stormwater leaves the A-State MS4 into Turtle   
Creek. Turtle Creek flows into the St. Francis River which in turn empties into the Mississippi River. The   
Mississippi River empties into the Gulf of Mexico. Any pollution of stormwater within the campus of AState can have an impact very far from where it initially occurs.   
Before entering Turtle Creek, most of the stormwater from the university flows into a stormwater ditch   
known as Turtle Creek Lateral. In the past, A-State had clear cut this ditch once a year. However,   
Facilities Management and the Stormwater Advisory Committee agreed that allowing vegetation to   
grow on the ditch bank is a better way to manage the stormwater that flows on campus. This has the   
advantage of stabilizing the ditch banks and potentially removing unwanted contaminants from   
stormwater. For these reasons, A-State no longer clear cuts Turtle Creek Lateral. A-State intends to   
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study the scientific literature on the subject and perhaps perform novel research regarding storm ditch   
vegetation during the permit cycle.  
A-State has many places where stormwater can enter the waterways of   
the state. There are stormwater inlets all over campus; EHS is working   
to ensure that all stormwater inlets are marked with an indicating plate   
demonstrating that they drain to a waterway (an example is pictured to   
the right). A map of these inlets is included in appendix D of this plan.   
EHS plans to have every inlet marked by the end of 2019. Water from   
these inlets and other places makes its way to about 50 outfalls from   
the university. EHS inspects these outfalls annually during periods of   
dry weather to detect any illicit discharges to stormwater conveyance. A   
map of these outfalls is included in appendix E of this plan. Finally, as of   
2019, the Arkansas State University MS4 does not discharge   
stormwater to any impaired waters.  
Chapter 3: Potential Sources of Stormwater Contamination  
It is important to identify the potential sources of stormwater contamination to maximize the   
effectiveness of control measures. Identification of these contaminants is determined by past and   
current sampling of stormwater as well as knowledge of the day-to-day operations of the university. The   
table below lists the contaminants, their sources and frequency of occurrence.  
Figure 2: Potential Sources of Contamination of Stormwater.   
Figure 1: Stormwater Drain Marker  
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Most contamination of stormwater can be prevented by simply taking measures to control them. Some   
sources cannot be controlled so easily, though. For example, oil and fuel that leaks from vehicles while   
driving on the road is inevitable. These types of pollution contribute little to the overall pollution.   
Control measures are primarily concerned with educating people to keep the rare events from becoming  
frequent and controlling the common and large quantity contaminants that are caused by human   
activity. While A-State strives to eliminate as much pollution as feasible from stormwater conveyance,   
primary attention is given to controlling sediment runoff due to human activity, which is the most   
common pollutant to the waterways of the state according to the Environmental Protection Agency. 70   
percent of sediment erosion into waterways is caused by human activity.  
Chapter 4: Minimum Control Measures  
Because of the risk of stormwater pollution to the health of our environment, EPA and ADEQ require as   
a part of our permit and SWMP certain minimum control measures. The six minimum control measures   
include:  
 Public education and outreach on stormwater impacts,  
 Public involvement/participation,  
 Illicit discharge detection and elimination,  
 Construction site stormwater runoff control,  
 Post-construction stormwater management in new development and redevelopment and  
 Pollution prevention/good housekeeping for municipal operations.  
For each control measure, A-State is required to have best management practices (BMPs) implemented   
for each measure and measurable goals for determining the success of each BMP including a rationale   
for why each BMP and associated measureable goals were chosen. The individuals tasked with   
implementing and coordinating the BMPs described in the SWMP is also required, including an   
organizational chart. The organizational chart is Appendix F of this plan.  
Chapter 5: Best Management Practices  
Best management practices are the strategies an entity employs in implementing control measures. The   
goal of these BMPs is to reduce stormwater pollution. Some BMPs directly influence contaminant levels   
by actively blocking water or filtering it before it moving into stormwater conveyance. The majority of   
BMPs are indirect, though. Whether it be inspection of areas to look for risks of contamination or public   
education and involvement initiatives, the goal of these indirect practices is to increase awareness about   
stormwater pollution and because of such prevent some pollution before it happens. This section   
outlines the BMPs that are used by A-State and the rationale behind selecting these BMPs to meet the   
minimum control measures required by the EPA and ADEQ.  
5.1 Public Education and Outreach  
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This control measure is intended to increase public awareness about stormwater pollution. The more   
aware the public is of the impacts of stormwater pollution, the more likely they are to take action to   
prevent or lessen it in their daily activities. Public education and outreach is intended to help the public,   
which at A-State includes students, faculty, staff and contractors, understand the types of stormwater   
pollution and what they can specifically do to reduce stormwater pollution.  
5.1.1 Rationale  
While awareness of pollution in general has grown in the public in the years since the initial first   
requirements for small MS4s to obtain a permit from the state for the discharge of stormwater, the   
public in general is still largely unaware of the impacts of stormwater pollution. A-State being an   
institution of higher learning is uniquely positioned to meet the goal of public education as education is   
the primary reason for the existence of the university. The public education and outreach goals are   
approved and updated by the Stormwater Advisory Committee and are chosen to reach as much of the   
public as possible. It is the goal of A-State to reach 100% of the campus community during the 5 year   
term of each permit cycle. The BMPs chosen are listed in the next section and are chosen to maximize   
this potential.  
The permit also requires that A-State chose five different themes to highlight during the permit term.   
These themes were chosen to address the most common forms or stormwater pollution that occur with   
the greatest frequency. The public education themes include:  
 Oil, petroleum products and other process chemicals -- 2019  
 Herbicides and pesticides -- 2020  
 Erosion control (construction activities and grounds maintenance) -- 2021  
 Illicit discharge detection -- 2022  
 Litter and debris – 2023  
The development and distribution of materials is largely the responsibility of the Director of EHS with   
input from the Stormwater Advisory Committee and Facilities Management.  
5.1.2 Implementation and Measurable Goals  
Most of these BMPs have already been implemented in past years, but there are some new BMPs and   
measurable goals for those BMPs. Each of these is described in the table below. Distribution of   
brochures reaches more individuals than any of the other methods as students are required to   
participate in safety week. Over the course of the permit cycle, 100% of the students are reached. The   
brochures also reach all employees that go through new employee orientation (required for new   
employees) and any that participate in the benefits fair. Stormwater training reaches Facilities   
Management personnel (required annually) and many others. New brochures targeted toward   
contractors should reach close to 100% of contractors on campus.  
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Figure 3: Best Management Practices for Public Education and Outreach  
5.2 Public Involvement/Participation  
This control measure is intended to increase public inclusion in and participation in the campus   
stormwater management. According to EPA Factsheet 2.4 for the Stormwater Phase II Final Rule, “The   
public can provide valuable input and assistance to a regulated small MS4’s municipal stormwater   
management program…” A-State wants the public (which includes the faculty, staff and students) to   
have as much involvement as they wish to have in the stormwater management program. Public   
involvement and participation activities are targeted toward encouraging engagement in our   
environmental programs, including stormwater management.  
5.2.1 Rationale  
A-State has historically had several ways that the campus community can be involved in stormwater   
management at the university. The Stormwater Advisory Committee includes members from various   
places within the campus community and includes one member from outside the campus community.   
The A-State Environmental Health and Safety Office participates annually in community awareness   
activities, like Earth Day, to educate the campus community and beyond on the impacts or stormwater   
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pollution, preventative measures that the university undertakes and ideas on how the community can   
impact water quality. We have both of these methods to be effective in meeting the goal of public   
participation so we have decided to continue both of these best management practices.  
The Stormwater Advisory Committee had some additional ideas on how we could increase community   
involvement. These ideas included continuing to pursue campus community cleanup initiatives and a   
newsletter to the campus community that highlights stormwater activity. Having a community cleanup   
involves the community more intimately, but tends not to be very broad in scope. A newsletter is the   
converse of that; it is lest impactful but reaches more people. Thus, the committee felt that having both   
types of BMPs would have the maximum impact on the community. Along with these two new ideas,   
EHS intends to finish marking all storm drains by the end of the permit cycle. We have asked employees   
to become involved in this endeavor by informing EHS when they observe an unmarked storm drain.  
5.2.2 Implementation and Measurable Goals  
As mentioned above, two of these BMPs have been implemented in past years. In addition to these two,   
there are three new BMPs. They are listed in the table below. We feel this combination of BMPs will   
increase public involvement both in the number of people involved and the depth of their involvement   
in stormwater pollution prevention. While having 100% of the public involved is not realistic, providing a   
variety of opportunities for the public involvement gives 100% of the campus community the option of   
participating.  
Figure 4: Best Management Practices for Public Involvement/Participation  
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5.3 Illicit Discharge Detection and Elimination  
An illicit discharge is defined by federal regulations as “…any discharge to a MS4 that is not composed   
entirely of stormwater…”, although there are a few exceptions to this rule. This control measure is   
intended to reduce the amount of stormwater pollution that occurs by unauthorized discharges and   
illegal dumping. This is accomplished by a combination of identification of outfalls, visual inspections,   
training, reporting mechanisms and response to illicit discharges if they do occur.  
There are a number of non-stormwater discharges that are allowed under the NPDES permit conditions.   
These include:  
While these discharges are allowed, the campus community is encouraged to minimize these types of   
discharges as well. Guidance for reducing these types of discharges to stormwater is given in the   
stormwater awareness training, literature distributed at events and on the A-State Environmental   
Health and Safety website on the page dedicated to stormwater.  
5.3.1 Rationale  
Detection and elimination of illicit discharges to stormwater requires a multi-faceted approach.   
Identification of potential problem areas, training on how to identify illicit discharges and a mechanism   
for reporting such issues are all items that A-State considers important for this BMP to be effective. A   
map of stormwater outfalls (Appendix E) and visual inspection of those outfalls are practices that are   
currently underway at A-State. The map is reviewed on an annual basis for accuracy and is also updated   
when new outfalls are added. The response to illicit discharges has also already been implemented;   
however, the mechanism for correction and enforcement will change with the new permit. Enforcement   
of stormwater rules is discussed in chapter 7 of this SWMP.  
Training of employees on identifying illicit discharges is something that A-State has been doing in   
training for a number of years, but this had not been counted as a measurable goal. More detail has   
been added to the training this year. Because of this training, there have been informal reports for illicit   
discharges (emails, phone calls, etc.), but there has never been an official reporting mechanism. A-State   
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and the SWAC feel that having a specific reporting mechanism will make reporting concerns easier, thus,   
adding this as a measurable goal seems appropriate.  
5.3.2 Implementation and Measurable Goals  
As mentioned above, three of these BMPs have been implemented in past years. In addition to these   
two, there are two new BMPs. They are listed in the table below. The BMPs that have already been   
implemented (map of stormwater outfalls, visual inspection of outfalls during dry weather and response   
to illicit discharges) have been effective in the past and thus will continue to be measured. The new   
BMPs should enhance our effectiveness in identifying and eliminating illicit discharges.  
Figure 5: Best Management Practices for Illicit Discharge Detection and Elimination  
5.4 Construction Site Stormwater Runoff Control  
Stormwater runoff from construction sites can cause environmental problems and is unsightly when it is   
polluted with sediment due to lack of effective BMPs. Sediment is the main pollutant of concern in   
stormwater according to the EPA. Thus the majority of attention on construction sites is dedicated to   
allowing the lowest amount of sediment practicable to leave the construction site. The construction site  
management is responsible for BMPs to control sediment leaving the construction site; A-State is   
responsible for ensuring that construction sites are using and maintaining the appropriate BMPs on the   
construction site.  
5.4.1 Rationale  
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A-State EHS and the stormwater advisory committee have determined that the current BMPs used for   
construction site stormwater runoff control are effective so those BMPs will remain in place. A more   
well-defined enforcement procedure for non-compliance with stormwater requirements at construction   
sites is necessary. A-State has been using the city of Jonesboro enforcement procedure up to this point;   
a simpler procedure has been devised with similar penalties to the city. The end goal being of   
implementing a new procedure is improvement to the overall performance of BMPs on a construction   
site when inadequacies are found rather than simply punitive measures.   
5.4.2 Implementation and Measurable Goals  
Site plan review for construction and monthly inspection of construction sites are BMPs that have long   
been a part of the stormwater management program. These BMPs will continue to be used as they are   
required by regulations and have been deemed very effective. A new, formal escalation process for   
enforcement of stormwater requirements has been developed. This new procedure better explains the   
expectations and responses to noncompliance issues of Arkansas State University. Enforcement   
procedures are explained more fully in chapter 7. Lastly, the ability of the public to comment on   
stormwater concerns relating to construction activities is a permit requirement. The addition of a   
reporting mechanism for illicit discharges will be added to the EHS website (see previous section). This   
same mechanism can be used for reporting issues with construction site activities as well. The best   
management practices for construction site stormwater runoff control are listed in the table below.  
Figure 6: Best Management Practices for Construction Site Stormwater Runoff Control  
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5.5 Post-Construction Stormwater Management in New Development and Redevelopment  
When redevelopment takes place within the A-State MS4 that disturbs an acre or greater, the project is   
treated the same as a new construction projects. All of the BMPs that apply to construction sites equally   
apply to redevelopment. The primary purpose for the best management practices that occur in this   
section is ensuring that the stormwater compliance process is seen through past the end of the   
construction phase. Furthermore, post-construction stormwater management must be considered in   
the design phase to achieve the required goal of 80% or greater removal of total suspended solid (TSS)   
from flows if the TSS exceeds the predevelopment level. Design of systems to retain stormwater for   
ground infiltration or slow stormwater flow is also encouraged in the design process.  
5.5.1 Rationale  
As mentioned above, several BMPs that apply to other areas equally apply to post-construction   
stormwater management. However, there are a few areas that are not addressed in other sections.   
First, the completion of a Notice of Termination (NOT) is required for any site that has completed   
construction. Since this is completed after construction has finished, it seems appropriate for it to be   
included as a post-construction BMP. This is the only BMP for post-construction that is completed after   
construction.  
Planning is necessary prior to construction for some of the post-construction requirements to be   
implemented. New stormwater outfalls may be constructed if a new construction or redevelopment   
takes place near the campus perimeter. Other stormwater issues can be identified prior to construction   
if EHS and the stormwater advisory committee are a part of the design review process. Facilities   
Management has informally asked for input regarding stormwater from EHS and the SWAC on new   
construction and redevelopment in the past. EHS and the SWAC will continue to be a part of the design   
process, specifically as it relates to stormwater management into the future. Thus, identification of new   
outfalls as the result of new construction or redevelopment and design review for post-construction   
stormwater management seem appropriate as BMPs. As physical post-construction stormwater BMPs  
are added as the result of new construction or redevelopment, additional inspections regarding   
maintenance of these physical BMPs will be added.  
5.5.2 Implementation and Measurable Goals  
Notices of termination have been completed for construction projects according to the regulations since   
A-State became a small MS4, but this has not been counted as a measurable goal until now. Adding this   
as a measurable goal will help ensure that NOTs are completed in a timely manner. Outfalls have also   
been added in an informal manner in the past; using this as a measurable goal will help ensure that new   
outfalls are identified early in the design and construction process rather than during or even after   
construction. Lastly, using design review for post-construction stormwater management as a   
measurable goal will ensure that EHS and the SWAC continue to have a seat at the table in the design   
phase. The best management practices for post-construction stormwater management in new   
development and redevelopment are listed in the table below.  
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Figure 7: Best Management Practices for Post-Construction Stormwater Management in New Development and Redevelopment  
5.6 Pollution Prevention/Good Housekeeping for Facilities  
Good housekeeping may be the most important aspect of stormwater pollution prevention. If areas   
within the MS4 that have the potential to pollute stormwater are kept neat and clean, the likelihood of   
those areas causing a contamination issue are greatly reduced. The most important elements of a good   
housekeeping program for municipal operations are training, inspection and procedures directly   
targeted as maintaining cleanliness. All of these aspects are addressed in the BMPs used by A-State in   
this section and other sections of the stormwater management plan.  
5.6.1 Rationale  
Training, inspections and cleaning procedures are the critical components of a good housekeeping   
program, thus it is appropriate to address all three of these areas with best management practices.   
Training on good housekeeping (along with other aspects of stormwater management) is included as a   
best management practices in other sections of this plan; to include it as a BMP in this section would be   
redundant. Inspection of areas at Facilities Management (the primary area of municipal activities) that   
have the potential to pollute stormwater and inspection of fuel storage areas all over campus are vital to   
ensure that these areas are well-maintained. Regular inspections are counted as a BMP. Efforts made to   
keep the campus clean also contribute to reducing stormwater pollution therefore these items are   
included as BMPs as well.  
5.6.2 Implementation and Measurable Goals  
Street sweeping, trash/litter collection and recycling are ongoing BMPs from previous SWMPs.   
Inspection of municipal operations has been occurring for many years as well, but has not been listed as   
a BMP in the stormwater management plan until now. Inspection of oil storage areas is a part of another   
environmental plan, but has not been included in this plan until now. The best management practices   
for pollution prevention and good housekeeping for are listed in the table below.  
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Figure 7: Best Management Practices for Pollution Prevention and Good Housekeeping in Facilities  
Chapter 6: Recordkeeping  
All records regarding stormwater management are kept and maintained by Arkansas State University   
Environmental Health and Safety department. The records kept include annual reports, inspection   
reports, email communications (when necessary), testing results (when sampling is performed),   
stormwater advisory committee meeting minutes and any communication between the state (ADEQ)   
and the university regarding stormwater. Details on how the records are kept and how long they are   
maintained is given in section 6.3  
6.1 SWMP Updating  
By permit requirement, the SWMP must be reviewed annually to see if updates are necessary. A   
standing item on the fall SWAC meeting agenda is review of the SWMP. Review of the plan will be   
documented in Appendix A. Changes will also be documented here. If a change requires resubmission of   
the SWMP to the state, this will be documented in this appendix and the appendix will be transferred to   
the new SWMP.  
6.2 Monitoring  
Requires monitoring of stormwater for the A-State MS4 includes inspection of outfalls during dry   
weather. All outfalls are inspected annually and some outfalls that have the highest risk of having illicit   
discharge are monitored quarterly. While sampling and testing are not required within the A-State MS4  
because of the lack of activities require sampling, EHS reserves the right to sample stormwater when   
illicit discharge is expected or if there is suspicion of some impact to the environment.  
6.3 Recordkeeping  
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Records for stormwater are kept in two ways: most records for the current year are kept in a notebook   
with sections for each type of record. Records kept this way include: construction site inspections,   
municipal activities inspections, monthly stormwater checklists for Facilities Management, annual   
reports to ADEQ and stormwater advisory committee meeting minutes. Notices of coverage and   
stormwater pollution prevention plans for construction sites are kept in a filing cabinet in the EHS   
Director’s office.   
All records are kept for a minimum of three years. Many records are kept beyond this because the   
records are used for historical purposes. Notices of coverage for ongoing project are posted on the   
construction site and are available to the public for viewing. These NOCs are removed once the notice of   
termination has been accepted by the state.  
6.4 SWMP Annual Reports  
A-State must complete an annual report to ADEQ each year. According to the permit, the following   
items must be included in the report:  
 The status of compliance with permit conditions;  
 An assessment of the appropriateness of the identified best management practices and the   
progress towards achieving the measureable goal for each of the minimum control measures;  
 Results of information collected and analyzed, if any, during the reporting period, including   
monitoring data used to assess the success of the program at reducing the discharge of   
pollutants;  
 A summary of the stormwater activities A-State plans to undertake during the next reporting   
cycle (including an implementation schedule);  
 Proposed changes to the stormwater management program, including changes to any BMPs or   
any identified measurable goals that apply to the program elements;  
 Description and schedule for implementation of additional BMPs that may be necessary, based   
on monitoring results, to ensure compliance with applicable TMDLs and implementation plans   
and  
 Notice that A-State is relying on another government entity to satisfy some of the permit   
obligations (if applicable).  
The last two bullet points do not currently apply to A-State, but they are listed here since they appear in   
the permit. The annual report is completed using a template downloaded from the ADEQ website. The   
annual report is completed and submitted by March 31 of each year.  
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Chapter 7: Enforcement of Stormwater Rules  
To ensure that the campus community, including contractors that are on campus, comply with the   
stormwater regulations, and enforcement mechanism is necessary. Previously, A-State had used the   
Jonesboro City ordinance as the enforcement procedure for stormwater violations. However, A-State   
has now developed a separate procedure that is similar to the city ordinance, but is adapted to meet the   
unique needs of the university community.  
7.1 Illicit Discharges  
Illicit discharges are any discharges other than stormwater to the waters of the state. A-State has best   
management practices in place to help prevent illicit discharges; however, unforeseen events,   
carelessness or purposeful action can lead to illicit discharges that cannot be controlled by any BMPs.   
Thus, A-State has a SOP that specifically outlines the process for escalating and enforcing the   
stormwater rules, which includes the prohibition on illicit discharges. The enforcement procedure for   
illicit discharges is explained in SOP SW-002 Enforcement of Stormwater Requirements on Campus and is   
attached as Appendix G to this plan.  
7.2 Construction Site Stormwater  
Construction sites have the highest probability of contaminating stormwater and thus need more   
regular attention. Inspections are performed on construction sites at least monthly. A clearly defined   
enforcement procedure is necessary to ensure that any non-compliant issues found as a result of   
inspections are corrected in a timely manner. The enforcement procedure for construction site   
stormwater is explained in SOP SW-001 Enforcement of Stormwater Requirements on Construction Sites   
and is attached as Appendix H to this plan