TCMA Chloride Management Plan - Prioritizing and Implementing Restoration and Protection
Contents
Prioritizing and Implementing Restoration and Protection
Reducing chloride at the source is needed throughout the entire TCMA, not only to restore already impacted waters but also to protect all water resources. There are multiple sources to consider, a variety of options to reduce chloride, and a large geographical area to address. This section is intended to provide guidance, resources, and information to assist in making the important decisions of the what, how and when for managing chloride. The available data indicates that surface waters and groundwater that exceed the state’s chloride standards, as well as many lakes and streams that are considered to be at high risk for chloride impairment. Many lakes, streams, and wetlands have minimal or no data available, especially during critical times of the year, which makes it difficult to determine the current chloride status. Reductions in chloride loads not only benefit surface and groundwater quality, but may also reduce damage to infrastructure and vehicles due to corrosion, and reduce impacts to vegetation along roadways. Finally, improved winter maintenance practices that reduce salt usage also result in direct cost-savings to winter maintenance organizations and private applicators. Without making efforts to reduce chloride loads, the trend of increasing chloride concentrations in lakes, wetlands, streams, and groundwater is expected to continue and the cost-savings related to improved winter maintenance practices will be lost. Treating waters already contaminated by chloride through RO or distillation is impractical and cost-prohibitive.
Performance-Based Approach for Reducing Chloride
Deicing salt is currently the most common and preferred method for meeting the public’s winter travel expectations. There is currently not an environmentally safe and cost-effective alternative that is effective at melting ice. Therefore, the continued use of salt as the predominant deicing agent for public safety in the TCMA is expected. Setting a specific chloride load reduction target for each individual winter maintenance chloride source is challenging, as is measuring actual chloride loads entering our surface and groundwater from deicing salt and other nonpoint sources in the TCMA. Therefore, priority should be put on improving winter maintenance practices to use only a minimal amount of salt, also referred to as Smart Salting, across the entire TCMA. With these considerations in mind, the implementation approach for achieving the TMDLs and protecting all waters in the TCMA is to focus on performance of improved winter maintenance practices as well as continuing to monitor trends in local waterbodies.
A standard approach to TMDL implementation is to translate the wasteload allocation (WLA) component of the TMDL directly to a numeric permit limit, which is typical for permitted facilities with monitoring requirements. In the case of urban stormwater regulated through a Municipal Separate Storm Sewer System (MS4) Permit, the WLA may be presented in the form of a percent reduction from a baseline condition. The specified percent reduction is then included in the MS4 Permit. With a performance-based approach, the numeric WLA is translated to a performance criterion. This can include the development and implementation of winter maintenance plan which identifies a desired level of the BMP implementation and a schedule for achieving specific implementation activities. Progress made towards those goals are documented and reported, along with annual estimates of salt usage and reductions achieved through BMPs implemented.
In cases where it is not feasible to calculate a numeric effluent limit, federal regulations allow for the use of the BMPs as effluent limits (40 CFR § 122.44(k)). Such a performance-based or BMP approach to compliance with WLAs is being taken by states to address the Chesapeake Bay TMDL for nutrients. The TMDL is being implemented through state Implementation Plans. Some states are taking a performance-based approach to addressing urban stormwater sources, requiring minimum levels of the BMP implementation rather than requiring specific levels of pollutant load reductions.
A performance-based approach will be tracked through documentation of existing winter maintenance practices, goals for implementing improved practices including schedules, and reporting on progress made. Entities may choose to use the Winter Maintenance Assessment tool (WMAt), which is a winter maintenance BMP tracking tool, to assess and document practices and set goals, or another approach of their choice. Entities should track progress and document efforts, including, to the extent possible, estimates of reduced salt usage as a result of improved practices. Entities that have achieved their goals for winter maintenance will have documented their practices in a winter maintenance plan. Entities that have already made significant progress in winter maintenance activities will be able to demonstrate this through their documentation of existing practices. This plan should be reviewed annually and evaluated against the latest knowledge and technologies available for winter maintenance.
The performance-based approach doesn’t focus on specific numbers to meet, but rather on making progress through the use of BMPs. Progress is measured by degree of implementation and trends in ambient monitoring. In a traditional approach with numeric targets, progress would be measured by accounting for salt applied and comparing to the targets. The performance-based approach is intended to allow for flexibility in implementation and recognize the complexities involved with winter maintenance. Because the performance-based approach does not provide a specific numeric target, a limitation of the approach is that it is not definitive on when enough progress has been made. This can only be determined by continued ambient monitoring that demonstrates compliance with water quality standards.
Prioritization and Critical Areas
This plan has been developed for many different audiences. Organizations interested in reducing the amount of salt in waters should start with an effort to fully understand the problem and determine what role the organization plays in contributing, preventing, or remediating the growing trend of increased chloride in surface and groundwater.
Prioritization of efforts to reduce chloride may be based on current water quality conditions. Waters found to exceed the state standard and their contributing watersheds should be given top priority for chloride reduction efforts. Many waters are considered to be high risk, but do not exceed the standard at this time. These areas may be given second priority unless there are no known chloride impairments in the watershed, and then the high risk waters could be given highest priority.
Prioritization of reduction efforts may also be based on the relative size and impact of the source of chloride, such as prioritizing winter maintenance activities in areas with a high density of impervious surfaces, or putting emphasis on residential water softeners for those watersheds where wastewater treatment facilities are identified as a major contributor of chloride. There may also be other ways that are more appropriate for each organization to determine where to prioritize reduction efforts.
Critical areas have been identified where chloride reduction efforts are necessary to achieve water quality goals. Two strategies have been used based on the source of chloride to identify critical watershed. The first strategy identifies watersheds with road densities of 18% or greater to identify watershed where chloride concentrations are typically above water quality standards. Figure 31 depicts the critical watersheds statewide; Figure 32 highlights the critical watersheds in southern Minnesota; and Figure 33 shows the critical watershed in the norther part of Minnesota. An interactive map showing these critical areas is available on the MPCA Road Salt & Water Quality website. The second strategy used to identify critical areas for chloride reduction focuses on areas with drinking water supply wells with hard and very hard water. Figure 10 identifies areas across the state where the drinking water supply is considered hard or very hard therefore requiring softening treatment. Through these two strategies critical areas have been identified across the state where chloride loadings are to be expected high and therefore implementation efforts to reduce chloride should be focused. For the protection of surface and ground waters implementation is encouraged statewide.
Implementation Strategies
This section provides the overall framework for the implementation strategies that are necessary to protect and restore our water resources. These high-level strategies are intended for both protection and restoration and are described by audience. The next section will provide more detailed implementation activities for the various sources of chloride. The over-arching implementation strategy is a performance-based approach. This approach allows stakeholders and regulators flexibility in the type of BMPs and the timing of implementation, and allows individuals an opportunity to develop chloride management strategies that are practical for their individual situation. Success under the performance-based approach will be measured in terms of the BMPs implemented.
A tool called the WMAt has been developed by the MPCA and is available for use by winter maintenance professionals across the state. The WMAt can be used voluntarily to understand current practices, identify areas of improvement, and track progress. While optional, everyone involved in winter maintenance is highly encouraged to use the WMAt. The tool is intended to streamline and simplify implementation goals and strategies. The tool can also be used to compare practices with other entities and learn from each other in order to achieve the greatest chloride reductions while providing a high level of service. Utilization of this planning tool will allow the user to track their progress over time and show the results of their efforts. The tool can serve as both a reporting mechanism to understand the current practices and as a planning tool to understand future practices. The planning side of the tool will help understand the challenges and costs associated with improved practices.
The overall performance-based implementation strategy for the primary audiences and a suggested timeframe is presented in the Performance-Based Chloride Reduction Strategies table with descriptive text following the figure. Secondary audiences are described at the end of this section and are not presented in a table.
Performance-Based Chloride Reduction Strategies
Link to this table
| Audience | years 1-2 | years 1-2 years 3-5 | years 6-10 | Beyond year 10 |
|---|---|---|---|---|
| Winter Maintenance Leadership (state, county, city, schools, private): those not involved in day to day operations of maintenance crew. |
|
|
|
|
| Winter Maintenance Professionals (state, county, city, schools, private): plow drivers, mechanics, supervisors of crew. |
|
|
|
|
| WMOs/WDs, Environmental Organizations and Institutions, and Educators |
|
|
|
|
| Municipalities |
|
|
|
|
| Wastewater Treatment Plants and Industrial Dischargers |
|
|
|
|
| Water Treatment Facilities (water supply) |
|
|
|
|
| Citizens |
|
|
|
|
| MPCA |
|
|
|
|
| Policy Makers (city, county, state, other) |
|
|
|
|
Winter Maintenance Leadership (State, County, City, Schools & Private)
Winter maintenance leadership is the group responsible for hands-on efforts and operation management. This group includes the individuals in charge of the shop facilities, selling winter maintenance services, determining the type of pavement overlays, or organizing the “getting ready for winter” refresher training. This group does not include the plow drivers or their direct supervisors.
Winter maintenance leadership is a very diverse group that plays a variety of roles across many organizations. Their influence is significant and they have great potential to positively impact reductions in salt use. This group can advocate for change by understanding the economic benefits of salt reduction, including the direct cost savings as a result of using less salt.
Table 9 presents example activities and timelines for winter maintenance leadership to consider. Throughout implementation, goals and practices should be reviewed, assessed, and adaptively updated to reduce the use of chloride. Examples presented in this section include specific possible actions. However, these actions are intended to be examples and are not meant to put emphasis on the specific actions. Each entity will need to assess the most relevant and cost-effective actions to take in their situation to reduce salt loadings.
Examples of Implementation Strategies for Winter Maintenance Leadership
Link to this table
| Assessment Items | Goals | Actions |
|---|---|---|
| Does salt leave storage sites in ways not intended? | No salty runoff water from salt sheds. | Storage sheds 1, 2, 4 are ok. Re-grade floor of storage shed 3 so water that enters the shed stays in shed. |
| Do customers know that salt harms the environment and that improved practices are being implemented to reduce salt use yet provide great service? | Give all customers the opportunity to learn about efforts to reduce salt. | Meet or talk to all customers when bidding on work explaining approaches to winter maintenance and environmental protection (private contractors) or run cable TV infomercials about salt reduction reasons and strategies during November (municipal). |
| Do trucks contribute salt to the truck wash water? | Re-use 50% of winter truck wash water for brine making or have less salt on truck prior to entering the wash. | Install filter system to remove wash water oils and solids, install tank to capture wash water, integrate filtered wash water in brine making system or Install a truck cleaning station before the truck wash to encourage thorough truck emptying in an area where granular salt can be easily reclaimed. |
| Which organizations have been most successful in reducing salt and what are the lessons learned? | Identify outstanding success in areas of interest (i.e. storage buildings, contracts that don’t bill by the ton, using non-traditional plow drivers to get 24 hour coverage). | Look at Clear Roads research, Snow and Ice Management Association (SIMA) research, APWA research, AASHTO research, attend the Freshwater Society’s annual Road Salt Symposium and other winter maintenance conferences to identify the leaders. Talk to them directly. |
| Are lower salt use pavements being installed (permeable, heated, narrower)? | Find some sort of pavement surface that requires 20% less salt on it. | Install permeable asphalt in parking lot near "Smith" lake. |
| Is payment based on amount of salt applied? | Have a profitable contract without billing by the ton which encourages overuse of salt. | Look at SIMA website for example contracts that do not charge by volume. |
| Is concern over liability resulting in over applying salt? | See if other states have a law to reduce liability for private companies doing winter maintenance. | Encourage legislators to look at New Hampshire’s law that limits liability of private contractors in winter maintenance. |
EXAMPLE: YEARS 1-2
- Better understand the impacts of salt on the environment and how organization may contribute.
- Create a chart of items to investigate that may reduce salt use/waste. Consider creating a list of items to be assessed, including goals, actions, and priorities.
- Visit the Snow and Ice Management Association website for example contracts that do not charge by volume.
- Encourage legislators to look at New Hampshire’s law that limits liability of private contractors in winter maintenance.
Watch a video: This video, produced by the MWMO and the UMN, is used to train seasonal and full-time property employees as well as business owners, front desk staff and anyone else who needs to control snow and ice in or near entrances and on sidewalks-
EXAMPLE: YEARS 3-5
- Install truck cleaning station before truck wash and provide training for proper use.
- Provide training for crew on how to monitor pavement temperatures, calibrate equipment, chose deicer’s that will work best based on pavement temperatures.
- Revise contracts to avoid billing by the ton and stay profitable, meet with them for ideas.
- Educate customers about winter maintenance strategies.
EXAMPLE: YEARS 6-10
- Re-grade floor of storage shed #3.
- Install permeable asphalt in parking lot near “Smith” Lake
Winter Maintenance Professionals (State, County, City, Schools, Parks, Private)
Winter maintenance professionals are responsible for performing outdoor, hands-on winter maintenance and those who supervise them. The primary duties include snow and ice removal from roads, sidewalks, parking lots, and trails, and applying a variety of deicers and abrasives. Some are part of emergency services and have exemption for laws that may cover weight restrictions on trucks or hours of consecutive work.
Winter maintenance professionals are employed by the public and private sectors, working for very small organizations to large organizations. Unusual hours and working in a variety of difficult winter weather conditions are typical in this industry. All of these professionals are under public scrutiny and receive comments about their work, because it directly and visibly impacts the public. There is a lot of pride within this sector as they are called on repeatedly, in the most difficult weather, to get the travelling public to their destinations safely.
The state, county, and city winter maintenance operations in the TCMA are under the extreme pressure of moving people safely on high volume, high speed roads, during all times of the day and night. Although their job is difficult, they often have the advantages of more sophisticated equipment, bigger support staff, less staff turn-over, and access to better and more frequent training than their private counterparts.
Private winter maintenance companies are very diverse and have a unique set of challenges. They often assume legal liability for “slip and falls” at their customer sites. They cannot bill clients when they attend training and have fewer incentives for training their crews. It can be difficult to locate this segment to invite them to Smart Salting trainings. The equipment used for small sites is less sophisticated and prone to over application of material. Their customers are spread out geographically, creating problems for proper and efficient storage and the transport of materials. Part-time seasonal workers fill many of the positions in these companies, which makes proper training an additional challenge for the employer.
The areas of maintenance vary greatly from seldom used sidewalks to the interstate. It ranges from concrete bridge decks to the marble steps of the capitol building. Each maintenance area has unique challenges that must be understood and mastered. The public generally does not understand or appreciate the difficulty of winter maintenance, and certainly does not understand the increasing challenges and changes coming to this industry as it moves towards conservative use of salt.
Maintenance professionals should become educated on the environmental impacts of salt and how their practices contribute to it. Maintenance professionals could attend training on lower salt use strategies, keep an open mind towards change, and look for ways to make salt use more efficient.
Operators could attend training and learn about changes that can be made on an individual basis. Many salt saving strategies do not need the cooperation of an entire agency; they can be incorporated into daily work. Other salt savings actions can be led by supervisors that will involve teamwork within the department, such as moving from manual controlled spreaders to computer controlled spreaders.
Supervisors may assess their current maintenance program using the WMAt, or other assessment techniques, to assess advanced, standard, and remedial practices. The remedial practices could be prioritized then followed by working towards improving good practices to make excellent practices.
Training opportunities, tools, and other resources for winter maintenance professionals can be found in Appendix D.
EXAMPLE: YEARS 1-2
- Clean out salt from truck thoroughly before washing truck.
- Reduce speed when applying salt.
- Avoid plowing off other’s salt, communicate with other drivers.
- Bring extra salt back to the pile, do not use it up on the route if not needed.
- Add tanks to 5 trucks a year starting in 2017.
- Work out agreement to buy brine from neighboring agency.
- All supervisors will attend training.
- Speed up physical removal of snow by changing our call out policy to 2 inches of snow.
- Reduce speed of application on high speed roads to 30mph.
- Calibrate most equipment yearly.
EXAMPLE: YEARS 3-5
- Speed up physical removal of snow by changing call out policy to 1 inch of snow.
- Work out salt building agreement for salt storage with neighboring agency.
- Calibrate all equipment yearly.
EXAMPLE: YEARS 6-10
- Push snow across bridges and/or truck it away.
- Adjust to selecting the appropriate material for the pavement temperature all of the time.
- All personnel will attend training.
Watershed Management Organizations & Districts and Soil & Water Conservation Districts
The WMOs, WDs, and SWCDs play a significant role in the management of the TCMA waters and provide an opportunity to combine the goals and recommendations of the CMP into watershed plans. This