CDPS MS4 Phase II STORMWATER MANAGEMENT PROGRAM DESCRIPTIONS FOR CITIES AND COUNTIES. March 2008 March 2013

Transcription

1 CDPS MS4 Phase II STORMWATER MANAGEMENT PROGRAM DESCRIPTIONS FOR CITIES AND COUNTIES March 2008 March 2013 Agency Name Southeast Metro Stormwater Authority (SEMSWA) Permit Certification Number COR MS4 Location Description (most permit certifications will cover a single city or county) City(s) Permitted: Centennial County Permitted: N/A Non-Standard MS4(s) Permitted (including location descriptions): East Cherry Creek Valley Water and Sanitation District (ECCV) located within the City of Centennial and Arapahoe County Map Attached MS4 Boundary Map Showing: Appendix A Jurisdictional Boundary (including all city, county and non-standard MS4s covered under SEMSWA s certification), which is the same as the Permit Boundary CDPS Program Descriptions Attached Program Implementation Area (Counties only) Permitted Area Entire Jurisdiction Joint Submittal No Yes 1 of 37

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5 TABLE OF CONTENTS Instructions Overall Program Perspective MCM1: Public Education & Outreach and MCM 2: Public Participation/Involvement MCM 3: Illicit Discharge Detection & Elimination MCM 4: Construction Site Runoff Control MCM 5: Post-Construction Stormwater Management MCM 6: Pollution Prevention/Good Housekeeping for Municipal Operations Appendix A: Map Appendix B: Discontinued Program Elements Appendix C: Arapahoe County s Program Description Document 5 of 37

6 CDPS Stormwater Management Program Descriptions Instructions A. Applicability This template is applicable for all permittees covered under the MS4 general permits COR and COR This template is not applicable to non-standard MS4s permitted under the COR general permit. B. Filling out the Template This template is intended to be filled out electronically, with additional lines added to the sections as descriptions are entered. C. Submitting the Program Description A complete program description, including the original signed certification on page 2, must be submitted to the Water Quality Control Division by June 10, The submittal must include an original signature. ed or faxed copies will not be accepted. D. Completeness The form must be completed accurately and in its entirety, or it will be deemed incomplete. This template is intended to be a summary of all of the content for the CDPS Stormwater Management Program Submittal required by Part I.A.6 of the MS4 general permits, COR and COR The descriptions provided must be detailed enough for the Water Quality Control Division to determine the permittee s general strategy for complying with the required items in each of the six CDPS Stormwater Management Program Minimum Control Measures (Parts I.B.1-6 of the general permits). E. Cited Permit Requirements Subsection B of this template for each of the six Minimum Control Measures includes citations of the specific permit requirements. Where permit requirements have been significantly modified from the previous versions of the general permits, the new language is identified in the template as either a Clarified or New permit requirement. Refer to Part II.H of the permit rationales for additional information on these changes. 6 of 37

7 Overall CDPS Stormwater Management Program Perspective STORMWATER DISCHARGES ASSOCIATED WITH MS4s Program Descriptions Summary description of the overall water quality concerns, priorities, and goals specific to the permittee that were considered in the development of the CDPS Stormwater Management Program: SEMSWA Stormwater Program Considerations The Southeast Metro Stormwater Authority (SEMSWA) was formed in September 2006 to manage stormwater in Arapahoe County via an Intergovernmental Agreement (IGA) between the City of Centennial, Arapahoe County, the Arapahoe County Water and Wastewater Authority (ACWWA), East Cherry Creek Valley Water and Sanitation District (ECCV), and Inverness Water and Sanitation District (IWSD). An Implementation Intergovernmental Agreement (IIGA) was jointly prepared between the City of Centennial and SEMSWA, and ECCV and SEMSWA, to provide process and procedures for SEMSWA to implement the MS4 requirements. SEMSWA holds the municipal separate storm sewer system (MS4) permit for the City of Centennial and ECCV. The City of Centennial is located in Arapahoe County and has a portion of the Cherry Creek Basin within its boundaries. ECCV falls within the City of Centennial and Arapahoe County with a portion in the Cherry Creek Basin. SEMSWA implements the MS4 Stormwater Programs throughout the City s entire jurisdiction. For the portion of ECCV that falls within unincorporated Arapahoe County, SEMSWA follows Arapahoe County s Program Description Document for the Construction Sites and the Post Construction Programs, attached as Appendix C. The IIGA between SEMSWA and the City of Centennial provides SEMSWA with the authority necessary to enforce the City of Centennial s regulatory mechanisms and ensure compliance with the MS4 Permit. For portions of the permitted area within Arapahoe County, SEMSWA relies on Arapahoe County for the authority necessary to enforce regulatory mechanisms and ensure compliance with the Illicit Discharge Detection and Elimination, Constructions Sites, and Post Construction Programs in the MS4 Permit. SEMSWA is in the process of completing a Memorandum of Understanding (MOU) with Arapahoe County entitled "Arapahoe County and SEMSWA, Water Quality Partnership MOU." This document defines how both entities implement the requirements under the County's MS4 permit. Pollutants of concern for the portion of the City of Centennial and ECCV within the Cherry Creek Basin consists of sediment and phosphorous. Phosphorous is the major nutrient causing algae productivity that leads to a high concentration of chlorophyll a in the Cherry Creek Reservoir. The Cherry Creek Reservoir has a chlorophyll a water quality standard of 15-µg/L, a phosphorous goal of 40-µg/L of total phosphorus and a total maximum annual load (TMAL) for phosphorous of 14,270 lbs/yr. Additional pollutants of concern for the City of Centennial and ECCV include the normal urban runoff with the constituents of trash and litter, nutrients from lawn care, bacteria from pet waste, and toxics from illegal dumping. Main goals of the SEMSWA s MS4 Stormwater Program are to support comprehensive water quality improvements in the Cherry Creek Basin, and protect state waters from pollution, contamination, and/or degradation. 7 of 37

8 Funding for the SEMSWA MS4 Stormwater Programs is provided though a Colorado State statute that permits collection of stormwater fees. SEMSWA has two types of stormwater fees: new development fee (System Development Fee per acre, paid by developers); and an annual charge to residential and non-residential property owners (based on impervious area per property). SEMSWA staff are responsible for the oversight of the MS4 Stormwater Programs within the City of Centennial and ECCV. For areas in unincorporated Arapahoe County, SEMSWA has a Memorandum of Understanding (MOU) with Arapahoe County detailing responsibility, processes, and procedures for implementing the MS4 Stormwater Program. 8 of 37

9 PUBLIC EDUCATION & OUTREACH STORMWATER DISCHARGES ASSOCIATED WITH MS4s Program Descriptions A. Program Perspective: The goal of the Public Education and Outreach Program is to increase public knowledge of local water quality problems caused by urban runoff in order to maintain public support for local stormwater quality programs. This support ranges from individuals changing their daily actions to community backing for all stormwater program elements. The program should take into account pollutants commonly associated with the urban environment. B. Permit Requirements The permittee must implement a public education program in an effort to promote behavior change by the public to reduce water quality impacts associated with pollutants in stormwater runoff and illicit discharges that includes: (Clarified permit requirement) 1) targeting specific pollutants and pollutant sources determined by the permittee to be impacting, or to have the potential to impact, the beneficial uses of receiving waters; 2) conducing outreach activities about the impacts of stormwater discharges on water bodies and the steps that the public can take to reduce pollutants in stormwater runoff; and (Clarified permit requirement) 3) informing businesses and the general public of the municipality s prohibitions against, and/or the water quality impacts associated with, illegal discharges and improper disposal of waste. C. Program Elements: By using existing, ongoing program elements to meet the permit requirements, the MS4 is committed to continuing each of these program elements. Any changes would require use of the program modification process as outlined in Part I.E.2. of the permit. 1. Forming Partnerships Public Education Program Element - Partnerships List each program element, briefly describe. Provide the year(s) for implementation or state ongoing for currently implemented programs. 1.a SEMSWA leads the Stormwater Permittees for Local Awareness of Stream Health (SPLASH) Group. The SPLASH Group works together to provide educational outreach, opportunities for public participation, and staff training to increase awareness of each person's role in protecting water quality. 1.b SEMSWA is a main supporter and funding partner of the Cherry Creek Stewardship Partners (Partners). The Partners provide regular informationsharing forums for all of SEMSWA s target audiences, including interested citizens, local government staff, agency personnel, technical consultants, and continue to expand their educational efforts at the school-age level. SEMSWA commits annual funds for the ongoing operation of the Partners and staff assist with outreach and participation events as planners and volunteers. Implementation Year or Ongoing Ongoing Ongoing 9 of 37

10 1.c SEMSWA collaborates with the Cherry Creek Basin Water Quality Authority (CCBWQA) to implement the Education Initiative, a comprehensive and coordinated education strategy and action plan. CCBWQA offers a comprehensive approach in water quality education by addressing best management practices (BMP) in both new construction and existing development by providing new tools and information. SEMSWA participates as needed in 319 grant-funded activities, attends Technical Advisory Committee (TAC) and education subcommittee meetings, and utilizes the educational materials produced as they pertain to construction and postconstruction BMPs. 1.d Urban Drainage and Flood Control District (UDFCD) reaches out to the citizens in SEMSWA s permit area through their public meeting/outreach process in their Master Plan Program, the Capital Improvements Program and their Maintenance Program. 1.e SEMSWA uses the Cherry Creek State Park s strong educational program to reach residents in the area. The Park allows SEMSWA to host a number of community outreach events at the Cherry Creek Reservoir. 1.f Douglas County Stormwater Cooperative Group cooperatively works with SEMSWA to implement all six program areas and provide a consistent message in the south Denver metro area. 1.g The Colorado Stormwater Council (CSC) is a statewide organization of MS4 permit holders. SEMSWA works with CSC to exchange technical information, promote educational opportunities and aid in the development and implementation of stormwater programs. 1.h SEMSWA uses intergovernmental agreements (IGAs) and memorandums of understanding (MOUs) with other stormwater entities to define NPDES specific roles and responsibilities and enhance opportunities for partnering. 2. Using Educational Materials and Strategies Public Education Program Element Educational Materials and Strategies List each program element, briefly describe. Provide the year(s) for implementation or state ongoing for currently implemented programs. 2.a SEMSWA uses the existing partners listed above for opportunities to distribute educational materials to target audiences and have face time with the community. Materials are produced and are distributed based on audience and media appropriate for the message. SEMSWA uses the following information to develop education and outreach strategies: Target Audiences: residents, homeowners, businesses, SEMSWA/City/ECCV staff, Homeowner Association (HOA) Groups Target Pollutants: sediment; urban runoff (trash, illegal dumping/illicit discharges, nutrients from lawn care, bacteria from pet waste); phosphorous Medias used: web sites, brochures, signage, posters, promotional materials (give-aways), newspapers, HOA newsletters, fact sheets, festivals, conferences, etc. Messages: Based on specific pollutants and are informational, educational, and/or encourage participation by the community. Ongoing Ongoing Ongoing Ongoing Ongoing Ongoing Implementation Year or Ongoing Ongoing 10 of 37

11 2.b SEMSWA works with Cherry Creek Stewardship Partners, SPLASH Group, and Douglas County Stormwater Cooperative, to develop and distribute outreach materials that reach diverse populations throughout the City, ECCV, and Cherry Creek Basin. These materials are developed and are distributed based on the target audience, message, and pollutant. Some examples of previously developed materials with a water quality message are Frisbees, beach balls, stickers, brochures, and fliers. These materials are distributed at festivals, conferences, and workshops, as appropriate. SEMSWA is committed to continuing to develop and distribute education and outreach materials addressing the target pollutants mentioned above. SEMSWA will distribute materials at a minimum of two events annually. 2.c SEMSWA works with the Cherry Creek Stewardship Partners and SPLASH Group to provide participation events for the community that reach diverse populations throughout the City, ECCV, and Cherry Creek Basin. Some past events include: sponsoring Science Fair Awards, storm stenciling activities with Boy Scouts and other civic groups, Colorado Cares Day, Cherry Creek Run for the Watershed, volunteer clean up days, etc. SEMSWA is committed to continuing efforts to encourage and provide opportunities for community participation in stormwater activities. SEMSWA will continue to participate in as many relevant public events as possible; although no specific events are described here, SEMSWA continues to commit to participate in Western Welcome Week annually. 2.d SEMSWA uses websites and links to other websites of interest to educate the public and facilitate public feedback. Past examples include Arapahoe County, Colorado Stormwater Council, SPLASH, etc. A stormwater complaint/feedback form and contact numbers to call are published on the SEMSWA website. SEMSWA is committed to continuing to use websites as mechanisms to educate and solicit feedback. 2.e SEMSWA distributes information relevant to water quality to residents and businesses in the City and Cherry Creek Basin though multiple medias such as newspaper ads, website, articles, signs, direct mailings, and public events and/or festivals. The media used to distribute information changes based on the target audience, pollutant, and message. Direct mailings rather than general mailings will be used in the permit term to address specific audiences such as HOA Groups and residents along drainageways. SEMSWA will continue to publish and distribute information about water quality, although the methods for publication and distribution may vary throughout the permit term. SEMSWA will publish a minimum of 25 awareness advertisements in local newspapers during the 5-year permit term (Note: the same advertisement placed in 5 different newspapers counts as 5 of the 25 advertisements required). 2.f SEMSWA conducts informal surveys periodically to determine program effectiveness and solicit feedback from the community. Ongoing Ongoing Ongoing Ongoing Ongoing 11 of 37

12 3. Signage and Stenciling Public Education Program Element Signage and Stenciling List each program element, briefly describe. Provide the year(s) for implementation or state ongoing for currently implemented programs. 3.a Although not required by the MS4 permit, SEMSWA implements a water quality signage program that includes requirements for construction site signage, drainageway and greenway signage, inlet signage, and trail signage. Implementation Year or Ongoing Ongoing 3.b Signs are replaced as needed. Ongoing 3.c Although not required, SEMSWA works with the Cherry Creek Stewardship Partners on a storm drain inlet labeling program. As applicable, stormwater inlets are pre-stamped with a water quality message. Ongoing 4. Reaching Diverse Audiences Program Description Diverse audiences are reached through long-term participation with the organizations, agencies and groups listed above. These partners have cultivated relationships with diverse groups, therefore, different viewpoints and areas of concern have been incorporated into the education and outreach plans utilized by these partners. For example, in partnership with the Cherry Creek Stewardship Partners, workshops targeting specific audiences such as developers, design engineers, contractors, inspectors, and local land use agencies within the Post Construction Program were offered. All information (brochures, pre-construction folders, etc.) is available free of charge and free events with stormwater materials are offered to the public. 5. Illicit Discharge Education to Businesses and the Public Program Description SEMSWA informs business and citizens of the impacts of illegal discharges and improper disposal of waste through the following elements: A website with applicable information and links to partner sites as well as to recycling and general water quality sites Door-to-door household hazardous waste collection for a minimal fee to homeowners in the City and ECCV Educational materials and/or information to homeowners and businesses in target areas along drainageways Illicit discharge investigations and follow up Partnerships with other permittees allow SEMSWA to frequently reach the target audiences through different medias with multiple messages. 6. Additional Requirements - Cherry Creek Reservoir Basin discharges (COR only) Program Description SEMSWA works with the Cherry Creek Stewardship Partners to distribute educational materials or equivalent outreach that address pollutant sources that have a significant potential to contribute phosphorus and nitrogen loads. In previous years, the Cherry Creek Stewardship Partners operated an annual booth at Tagawa Gardens, a large garden center in the Cherry Creek Basin. The booth is used to discuss fertilizer, weed control, and topics specific to the Cherry Creek Basin. Events held for community participation can also be advertised here. SEMSWA continues to team with the Cherry Creek Stewardship Partners to address fertilizer and weed control in the Cherry Creek Basin. 12 of 37

13 Some past events that SEMSWA participated in to raise awareness and address pollutant sources include the Cherry Creek Partners Annual Conference, World Monitoring Day Booth, and the Cherry Creek Run for the Watershed Relay Race. SEMSWA relies heavily on their partners for educational and participation events in the Cherry Creek Basin and continues to participate in relevant water quality events as much as possible. Some past materials distributed to increase watershed awareness in the Cherry Creek Basin include numerous free materials such as beach balls, Frisbees, brochures targeting lawn care, construction site management, and household wastes, BMP posters developed by the CCBWQA TAC distributed with Grading, Erosion and Sediment Control (GESC) permits, and inlet signage specific to the Cherry Creek Basin. SEMSWA continues to distribute information with a specific message about water quality to residents and business owners in the Cherry Creek Basin, although the methods used may vary throughout the permit term. D. Measurable Goals Inclusion of measurable goals are not necessary, as the elements described in Part C, above, constitute full program implementation and a commitment to continue these elements. 13 of 37

14 PUBLIC PARTICPATION / INVOLVMENT STORMWATER DISCHARGES ASSOCIATED WITH MS4s Program Descriptions II. PUBLIC PARTICIPATION/INVOLVMENT A. Program Perspective Public participation/involvement is often discussed in the context of the public education measure because they share a common goal reaching out to citizens to improve awareness and achieve program compliance. The distinction between the two programs is that public participation/involvement provides a conduit for citizens to participate in the development and implementation of the publicly funded stormwater program. B. Permit Requirements Public involvement/participation. The permittee must implement a public involvement program as follows: 1) The permittee must comply with the State and local public notice requirements when implementing the CDPS Stormwater Management Programs required under this permit. Notice of all public hearings should be published in a community publication or newspaper of general circulation, to provide opportunities for public involvement that reach a majority of citizens through the notification process. 2) The permittee must provide a mechanism and process to allow the public to review and provide input on the CDPS Stormwater Management Program. C. Program Elements: By using existing, ongoing program elements to meet the permit requirements, the MS4 is committed to continuing each of these program elements. Any changes would require use of the program modification process as outlined in Part I.E.2. of the permit. 1. Public Notices Program Description SEMSWA s has an effective mechanism for reaching the public by providing adequate public notice of all public hearings when implementing stormwater management programs required under the Stormwater MS4 Permit. SEMSWA follows all state and local public notification requirements. The following activities below have required procedures for Public Notification. Notice for Public Hearings Notification of Project Construction, Master Planning or Criteria Manual Public Meetings Sign Posting for Project Construction with contact names and phone numbers Request for Qualifications for Design and Construction of Capital Projects 14 of 37

15 2. Mechanism and Processes for Public Involvement/Feedback Public Involvement/Participation Program Element Public Feedback List each program element, briefly describe. Provide the year(s) for implementation or state ongoing for currently implemented programs. 2.a SEMSWA publishes the SEMSWA website address on their partners websites to allow interested parties to provide feedback directly to SEMSWA via a feedback form on the SEMSWA website. 2.b Procedures are in place to ensure calls are directed to the appropriate staff and/or department. 2.c In partnership with Cherry Creek Stewardship Partnership and SPLASH, SEMSWA provides community stewardship projects for the public to participate in, which also offer the public an opportunity to provide feedback. Examples: Cherry Creek Run for the Watershed, Creek Clean-ups along Cherry Creek, Volunteer Work Days (re-plantings/weed removal activities) 2.d Outreach and educational materials produced include a website and/or phone number to maximize the opportunity for citizens and businesses to provide feedback and ask questions. 2.e SEMSWA s CIP and Drainage Maintenance departments also provide opportunities for specific HOA groups during public meetings to ask stormwater related questions, which are brought back to the Water Quality Department for staff to respond to. Implementation Year or Ongoing Ongoing Ongoing Ongoing Ongoing Ongoing D. Measurable Goals Inclusion of measurable goals are not necessary, as the elements described in Part C, above, constitute full program implementation and a commitment to continue these elements. 15 of 37

16 ILLICT DISCHARGE DETECTION AND ELIMINATION STORMWATER DISCHARGES ASSOCIATED WITH MS4s Program Descriptions A. Program Perspective The goal of the Illicit Discharge Detection and Elimination Program is, to the maximum extent practicable, to reduce the frequency and environmental impact of illicit discharges in which pollutants are intentionally or accidentally discharged into the storm sewer system. B. Permit Requirements The permittee must develop, implement and enforce a program to detect and eliminate illicit discharges (as defined at 61.2) into the permittee s MS4. Illicit discharges do not include discharges or flows from fire fighting activities, or other activities specifically authorized by a separate CDPS permit. The permittee must: 1) Develop and maintain a current storm sewer system map, showing the location of all municipal storm sewer outfalls and the names and locations of all state waters that receive discharges from those outfalls. 2) To the extent allowable under State or local law, effectively prohibit, through ordinance or other regulatory mechanism, illicit discharges (except those identified in subparagraph 5 and 6 of this section) into the storm sewer system, and implement appropriate enforcement procedures and actions. (Clarified permit requirement) 3) Develop, implement, and document a plan to detect and address non-stormwater discharges, including illicit discharges and illegal dumping, to the system. The plan must include the following three components: procedures for locating priority areas likely to have illicit discharges, including areas with higher likelihood of illicit connections; procedures for tracing the source of an illicit discharge; and procedures for removing the source of the discharge. 4) Develop and implement a program to train municipal staff to recognize and appropriately respond to illicit discharges observed during typical duties. The program must address who will be likely to make such observations and therefore receive training, and how staff will report observed suspected illicit discharges. (New permit requirement) i) Specific Deadline for Renewal Permittees: Renewal Permittees must comply with the requirement of subparagraph (4) by no later than December 31, ) Address the following categories of non-stormwater discharges or flows (i.e., illicit discharges) only if the permittee identifies them as significant contributors of pollutants to the permittee s MS4: landscape irrigation, lawn watering, diverted stream flows, irrigation return flow, rising 16 of 37

17 ground waters, uncontaminated ground water infiltration (as defined at 40 CFR (20)), uncontaminated pumped ground water, springs, flows from riparian habitats and wetlands, water line flushing, discharges from potable water sources, foundation drains, air conditioning condensation, water from crawl space pumps, footing drains, individual residential car washing, dechlorinated swimming pool discharges, and water incidental to street sweeping (including associated side walks and medians) and that is not associated with construction. (Clarified permit requirement) The permittee may also develop a list of occasional incidental non-stormwater discharges similar to those in the above paragraph, (e.g., non-commercial or charity car washes, etc.) that will not be addressed as illicit discharges. These non-stormwater discharges must not be reasonably expected (based on information available to the permittee) to be significant sources of pollutants to the MS4, because of either the nature of the discharges or conditions the permittee has established for allowing these discharges to the MS4 (e.g., a charity car wash with appropriate controls on frequency, proximity to sensitive water bodies, BMPs, etc.). The permittee must document in their program any local controls or conditions placed on the discharges. The permittee must include a provision prohibiting any individual non-stormwater discharge that is determined to be contributing significant amounts of pollutants to the MS4. 6) The following sources are excluded from the prohibition against non-stormwater discharges and the requirements of subsections (2) and (3) above: i) Discharges resulting from emergency fire fighting activities. Such discharges are specifically authorized under this permit (see Part I.A.2). ii) Discharges specifically authorized by a separate CDPS permit. C. Program Elements: By using existing, ongoing program elements to meet the permit requirements, the MS4 is committed to continuing each of these program elements. Any changes would require use of the program modification process as outlined in Part I.E.2 of the permit. 1. Outfall map Program Description Outfall maps were completed as required by the previous permit. After new permanent BMP features are approved, GPS points are taken and used to update the map with new construction information. The same process is used to update and track new outfalls. When an outfall has been constructed and received final acceptance through the Public Improvement Permit process, GPS points of the outfall are taken and added to GIS. 2. Regulatory mechanism Program Description The following ordinance is used to implement the Illicit Discharge Detection and Elimination (IDDE) program within the City of Centennial. Municipal Code, Chapter 13, Article 1, Illicit Discharge Control Ordinance (adopted 1/3/2005) The Illicit Discharge Control Ordinance grants authority to inspect, enforce, and abate illicit discharges. For SEMSWA permitted areas within unincorporated Arapahoe County, SEMSWA follows the County s IDDE program. 17 of 37

18 3. Illicit Discharge Detection and Elimination Plan Program Description The Arapahoe County and City of Centennial IDDE Manual (Manuals) was developed and implemented in The Manuals are designed to outline procedures for locating priority areas, tracing the source, and removing the source of illicit discharges within both the City and County. It also includes guidance for tracking illicit discharges. Guidelines are included in the Manuals to identify priority areas. Tracing the source of an illicit discharge is dependent on the type of discharge. The outfall map is generally sufficient to trace illicit discharges. If the discharge cannot be traced through the outfall map, other tracking options such as manhole observation, video inspection, smoke testing, dye testing, aerial infrared and thermal photography can be used if SEMSWA feels it is valuable. Because there are various sources of illicit discharges to the storm sewer system, there are different kinds of actions SEMSWA takes to remove those sources and prevent future illicit discharges. SEMSWA groups those actions into three categories: compliance assistance and enforcement for illegal connections to homes and businesses; proper construction and maintenance of MS4s; and responding to and preventing illegal dumping. The Manuals are reviewed and updated periodically to include new technology and revised processes. 4. Staff Education Program Description SEMSWA provides training to all SEMSWA, City, and ECCV staff about the Stormwater Program. The training generally consists of how to identify and respond to illicit discharges. There are two levels of training for staff, the Visual Observation Program (VOP) and the Scheduled Outfall Inspection Program (VOIP). The programs are described below. IDDE VOP The VOP is broken into two categories, a general VOP and VOP for Field Staff. The general VOP is offered to all staff who drive a service vehicle and have the opportunity for a visual, albeit casual, drive-by visual observation of the drainageways. Staff is given basic training on the types of illicit discharges that may occur. The VOP for Field Staff is offered to staff that are in the drainageways for other purposes. The Field Staff are trained in the visual detecting of pollutants so that they can immediately intervene to prevent and help eliminate sources of impurities to the waterways. Training materials in the past have included the Storm Warning video, standard operating procedures (SOPs), fact sheets, and question and answer sessions. IDDE SOIP The SOIP training is offered to specific SEMSWA Technical Field staff that have the responsibility of conducting inspections of the outfalls as part of a scheduled inspection, as well as responding to an IDDE incident. The training, at a minimum, consists of inspection personnel reviewing the outfall inspection form and the SOP/fact sheet guidance. Training materials in the past have included the Storm Watch video, SOPs, fact sheets, and review of the IDDE Manuals. 18 of 37

19 D. Measurable Goals Measurable Goals are not required for Staff Education (Permit Requirement (4), in Part B, above), because this new permit condition is already being met. Additional measurable goals are not necessary because the elements described in Part C, above, constitute full program implementation and a commitment to continue these elements for all additional permit requirements. Check Box 1 or 2, below. The Table in Part 3 must be filled out if you check Box Staff training program(s) listed in Part C.4, above, have been fully implemented and are ongoing. (It is not necessary to complete Part 3 below if you check this box.) 2. One or more staff training program(s) have NOT been fully implemented and measurable goals have been provided in Part 3 below for each of the pending programs. (You must complete Part 3 below if you check this box.) 3. Illicit Discharge Detection and Elimination Measurable Goals: Include those staff training program(s) that have NOT already been fully implemented, and provide the year by which implementation will occur. Measurable Goals must be completed by Illicit Discharge Detection and Elimination Measurable Goals - Training Implementation List each program element, briefly describe. Provide the year(s) for implementation Year 3.a Not Applicable Not Applicable 19 of 37

20 CONSTRUCTION SITES RUNOFF CONTROL STORMWATER DISCHARGES ASSOCIATED WITH MS4s Program Descriptions A. Program Perspective The goal of the Construction Sites Runoff Control Program is to reduce, to the maximum extent practicable, sediment and other construction-related pollutants from entering the municipal separate storm sewer system. B. Permit Requirements The permittee must: 1) Develop, implement, and enforce a program to reduce pollutants in any stormwater runoff, and to reduce pollutants in, or prevent when required in accordance with I.B.3, non-stormwater discharges that have the potential to result in water quality impacts (e.g., construction dewatering, wash water, etc.), to the MS4 from construction activities that result in a land disturbance of one or more acres. Reduction of pollutants in discharges from construction activity disturbing less than one acre must be included in the program if that construction activity is part of a larger common plan of development or sale that would disturb one or more acres. If the Division waives requirements for stormwater discharges associated with a small construction activity in accordance with 61.3(2)(f)(ii)(B) (the R-Factor waiver), the permittee is not required to develop, implement, and/ or enforce its program to reduce pollutant discharges from such a site. (Clarified permit requirement) 2) Develop and implement the program to assure adequate design, implementation, and maintenance of BMP s at construction sites within the MS4 to reduce pollutant discharges and protect water quality. The program must include, at a minimum, the development, implementation, and documentation of: i) Program Requirements, including: A) An ordinance or other regulatory mechanism to require erosion and sediment controls, as well as sanctions and procedures adequate to ensure compliance, to the extent allowable under State or local law. B) Requirements for construction site operators to implement appropriate erosion and sediment control BMP s. C) Requirements for construction site operators to implement BMP s to control waste such as discarded building materials, concrete truck washout, chemicals, litter, sanitary waste, and other non-stormwater discharges including construction dewatering and wash water, at the construction site that may cause adverse impacts to water quality. (Clarified permit requirement) ii) Compliance Assessment, including: 20 of 37

21 A) Procedures for site plan review which incorporate consideration of potential water quality impacts. B) Procedures for construction site compliance assessment, including: 1) Site inspections; and 2) Receipt and consideration of information submitted by the public. iii) Compliance Assurance, including: A) Procedures for enforcement of control measures that includes documented procedures for response to violations of the permittee s program requirements. Procedures must include specific processes and sanctions adequate to minimize the occurrence of, and obtain compliance from, chronic and recalcitrant violators of control measures. (New permit requirement) 1) Specific Deadline for Renewal Permittees: Renewal Permittees must comply with the requirement of subparagraph (A) to develop, document and implement response procedures that specifically address chronic and recalcitrant violators by no later than December 31, B) An education and training program for municipalities, their representatives and/or construction contractors. At a minimum, the program must include an information program for construction site operators unfamiliar with the reviewing authority s regulatory requirements. C. Program Elements: By using existing, on going program elements to meet the permit requirements, the MS4 is committed to continuing each of these program elements. Any changes would require use of the program modification process as outlined in Part I.E.2. of the permit. 1. Regulatory Mechanism to require BMPs and sanctions to ensure compliance Program Description SEMSWA s construction program is operating under the regulatory mechanisms listed below within the City. These mechanisms allow SEMSWA to require BMPs and enables sanctions to ensure compliance. 1. City of Centennial s Land Development Code, Part 100, CCBWQA Requirements (Ord ) (adopted 12/11/05) 2. City of Centennial s Land Development Code, Chapter 8- Stormwater Quality Requirements (adopted 12/11/05) 3. Grading Erosion, and Sediment Control Manual (GESC Manual) Program Adoption Resolution was approved to implement and enforce the GESC Program in the City (Resolution10-42) (December 2010), effective January SEMSWA s GESC Manual includes erosion and sediment control regulations and are enforced with that document. All development plans submitted through SEMSWA must adhere to the GESC Manual, which incorporates CCBWQA s requirements for erosion and sediment control by reference. 21 of 37

22 4. The City of Centennial s Municipal Code, Chapter 13, Article 1, Illicit Discharge Control Ordinance (Ord O-27) (adopted 1/3/2005) grants authority to inspect, enforce, and abate illicit discharges, including imposing conditions and requirements or specifically reference one (1) or more BMPs on any land use approval, building permit or contract deemed necessary to ensure compliance of the development or redevelopment with this ordinance. For SEMSWA permitted areas within unincorporated Arapahoe County, SEMSWA is relying on Arapahoe County s Construction Sites Program to require BMPs and sanctions to ensure compliance. See attached Arapahoe County Program Description Document for details on Arapahoe County s Construction Sites Program. 2. Requirements for construction site operators to implement appropriate erosion and sediment control BMPs and materials handling BMPs Program Description The following are used to guide construction site operators in the selection and design of appropriate BMPs, stabilization methods and materials handling practices. 1. GESC Manual (March 2005) guides construction site operators in the selection and design of appropriate BMPs, stabilization methods and materials handling practices (includes requirements for GESC Plans, Standard Notes and Details, Checklist for GESC drawing, GESC permit, etc.). 2. GESC Field Manual (adopted Jan 2005), is designed to familiarize Owners, GESC Managers, Project Managers, Contractors, and other field personnel with an overview of GESC requirements. 3. City of Centennial s Land Development Code, Part 100, CCBWQA Requirements (Ord ) (adopted 12/11/05) 4. City of Centennial s Land Development Code, Chapter 8- Stormwater Quality Requirements (adopted 12/11/05) For SEMSWA permitted areas within unincorporated Arapahoe County, SEMSWA is relying on Arapahoe County s Construction Sites Program to require construction site operators to implement appropriate erosion and sediment control BMPs and materials handling BMPs. See attached Arapahoe County Program Description Document for details on Arapahoe County s Construction Sites Program. 3. Requirements for construction site operators to control waste including discarded building materials, concrete truck washout, chemicals, litter, and sanitary waste Program Description The following are used to require site operators to control waste including discarded building materials, concrete truck washout, chemicals, litter, and sanitary waste. 1. GESC Manual (March 2005) requires construction site operators to control waste including discarded building materials, concrete truck washout, chemicals, litter, and sanitary waste. 2. GESC Field Manual (adopted Jan 2005), designed to familiarize Owners, GESC Managers, Project Managers, Contractors, and other field personnel with an overview of GESC requirements, including waste control for discarded building materials, concrete truck washout, chemicals, litter, and sanitary waste. 22 of 37

23 3. City of Centennial s Land Development Code, Part 100, CCBWQA Requirements (Ord ) (adopted 12/11/05) 4. City of Centennial s Land Development Code, Chapter 8- Stormwater Quality Requirements (adopted 12/11/05) 5. The City of Centennial s Municipal Code, Chapter 13, Article 1, Illicit Discharge Control Ordinance (Ord O-27) (adopted 1/3/2005) grants authority to inspect, enforce, and abate illicit discharges, including imposing conditions and requirements or specifically reference one (1) or more BMPs on any land use approval, building permit or contract deemed necessary to ensure compliance of the development or redevelopment with this ordinance. For SEMSWA permitted areas within unincorporated Arapahoe County, SEMSWA is relying on Arapahoe County s Construction Sites Program to require site operators to control waste including discarded building materials, concrete truck washout, chemicals, litter, and sanitary waste. See attached Arapahoe County Program Description Document for details on Arapahoe County s Construction Sites Program. 4. Procedures for site plan review which incorporate consideration of potential water quality impacts a. Site Plan Development b. Site Plan Review Program Description For permitted areas within the City, SEMSWA follows the procedures below. a. Site Planning: Site planning to facilitate the reduction of pollutants discharging into SEMSWA s MS4 is currently required for construction activities within the City. The site planning and submittal requirements are specified in the GESC Manual. Through the development process, cases are referred to the CCBWQA for review and comment, if applicable. b. Site Plan Review: All cases associated with a new development or redevelopment in the City of Centennial are required to go through the land review process. During this process, SEMSWA staff outlines the requirements associated with water quality impacts. Applicants are given a handout outlining the applicable codes and criteria, namely the GESC Manual, that must be adhered to for development in the City. The applicant is directed to utilize the GESC Plan and Report checklist for subsequent submittals. For developments that meet the GESC permitting requirements outlined in the GESC Manual, the associated required drawings and reports must be submitted for review and comment by SEMSWA staff. SEMSWA works with the applicant to discuss the water quality related comments. Once all GESC-related comments are addressed, SEMSWA signs and stamps approved GESC plans. If field conditions change, the GESC Manager is expected to make modifications to the GESC Plans to meet GESC requirements, as approved by the Stormwater Inspector. Substantive changes to the approved GESC Plan may trigger a GESC plan resubmittal for SEMSWA s review and approval. 23 of 37

24 For SEMSWA permitted areas within unincorporated Arapahoe County, SEMSWA follows Arapahoe County s Construction Sites Program for site planning and site plan review. See attached Arapahoe County Program Description Document for details on Arapahoe County s Construction Sites Program. SOP 4.1, MS4 Permit Program 4, Land Development Cases and SOP 4.2, MS4 Permit Program 4, CIP Construction Projects document the role between SEMWA and Arapahoe County in the review of site plans. 5. Procedures for receipt and consideration of information submitted by the public Program Description Citizen inquiry calls to the City of Centennial or ECCV that are water quality related are forwarded to SEMSWA staff, which investigate the complaint and coordinate with proper staff to assure proper corrective action is taken, if necessary. Complaints are logged and tracked with a database and routed through appropriate SEMSWA staff until action is completed. For SEMSWA permitted areas within Arapahoe County, SOP 4.1, MS4 Permit Program 4, Land Development Cases and SOP 4.2, MS4 Permit Program 4, CIP Construction Projects document the procedures for receipt and consideration of information submitted by the public in the County. 6. Procedures for site inspection and enforcement of control measures a. Inspections b. Enforcement Program Description For permitted areas within the City, SEMSWA follows the procedures below. a. Inspections: SEMSWA has several types of inspections explained in the GESC Manual that are required throughout the duration of a construction project and routine compliance inspections are performed on permitted sites to monitor BMPs. An inspection form is completed to document the findings of an inspection, and whether or not action items are required of the permittee(s) and/or contractors. GESC inspections are conducted using the GESC Manual as guidance. An inspection program fact sheet that summarizes the inspection program is used for a quick reference for inspectors. A database is used to track information pertaining to SEMSWA-issued GESC permits including the receipt of required submittals, when inspections are performed, scheduling future inspections, as well as probationary acceptance, final acceptance, and close out of the permit. A complaint may warrant a field re-inspection, notification to the site GESC Manager or other follow-up actions as appropriate to the situation. In addition to the above inspections, SEMSWA may monitor sites or activities regardless of the size of the disturbance or whether or not a permit has been required. Projects are set-up on a priority basis, which is determined by a Project Criteria Sheet. b. Enforcement: SEMSWA classifies violations in one of two categories, depending on the severity of the violation and has different enforcement actions for each category. The GESC Manual Program Adoption Ordinance (Resolution 10-42)) outlines the procedures for enforcement. SEMSWA uses enforcement tools such as verbal warning, re-inspection fee, written compliance orders (pre-notice of violation and notice of violation), Stop Work Order, revocation of permits, denial of further review of plans, and denial of future inspections and/or permits. Disturbances that meet the GESC Manual s requirements for a standard permit are required to post a Letter of Credit or cash that 24 of 37

25 guarantees the BMP installation and maintenance per the approved plan. Failure to install or maintain BMPs, after notification by SEMSWA and failure to comply by the permit holder, can result in using the performance security collected at the time of permit issuance to perform corrective work to enforce control measures. SEMSWA escalates enforcement actions as needed to prevent repeat violations associated with chronic or recalcitrant violators. Enforcement actions are generally escalated in the order described above. However, flexibility is utilized to ensure that enforcement actions are carried out in a manner appropriate to the violation(s) and to the phase of construction. For SEMSWA permitted areas within unincorporated Arapahoe County, SEMSWA follows Arapahoe County s Construction Sites Program for procedures on site inspection and enforcement of control measures. See attached Arapahoe County Program Description Document for details on Arapahoe County s Construction Sites Program. SOP 4.1, MS4 Permit Program 4, Land Development Cases and SOP 4.2, MS4 Permit Program 4, CIP Construction Projects document the procedures for inspection and enforcement within the County. 7. Training and Education for Construction Site Operators This program element must, at a minimum, include an informational program for construction site operators unfamiliar with the MS4 s (reviewing authority s) regulatory requirements. Program Description All cases that are associated with a new development or redevelopment in the City of Centennial are required to go through the City s land development review process. SEMSWA staff attends meetings and outlines the requirements associated with water quality impacts. Applicants are given a handout outlining the applicable codes and criteria, including the GESC Manual, which must be adhered to for development in the City. The applicant is directed at presubmittal meetings to utilize the GESC checklist for subsequent submittals. When the applicant is issued a GESC permit, SEMSWA hands out a GESC Field Manual to the site operator. In addition, SEMSWA posts the GESC Manual and all related checklists on the SEMSWA website and routinely refers applicants and contractors to the site. SEMSWA also utilizes its partners for further training opportunities. Red Rocks Community College (RRCC) provides various and extensive education and training opportunities on erosion and sediment control BMPs for those employed in the construction business. UDFCD offers a BMPs for Construction in Waterways course available to site operators and municipal staff. Cherry Creek Stewardship Partners provides workshops on MS4 permit requirements with targeted audiences, specifically contractors. SEMSWA inspection staff attends classes and/or workshops in the Denver metro area to learn about new techniques and technologies in erosion and sediment control. For SEMSWA permitted areas within unincorporated Arapahoe County, SEMSWA follows Arapahoe County s Construction Sites Program for training and education for construction site operators. See attached Arapahoe County Program Description Document for details on Arapahoe County s Construction Sites Program. 25 of 37

26 D. Measurable Goals Measurable Goals are not required for the requirement in Part I.B.4(a)(2)(iii) of the permit (Permit Requirement (2)(iii) in Part B, above) because this new permit requirement is already being met. Additional measurable goals are not necessary because the elements described in Part C, above, constitute full program implementation and a commitment to continue these elements for all additional permit requirements. Check Box 1 or 2, below. The Table in Part 3 must be filled out if you check Box Procedures, as listed in Part C.6.b, above, have already been fully implemented to minimize the occurrence of, and obtain compliance from, chronic and recalcitrant violators of control measures. (It is not necessary to complete Part 3 below if you check this box.) 2. Procedures have NOT already been fully implemented to minimize the occurrence of, and obtain compliance from, chronic and recalcitrant violators of control measures. (You must complete Part 3 below if you check this box.) 3. Construction Sites Program Measurable Goals: The Measurable Goal has been provided. Include the year by which full implementation of procedures will be achieved to minimize the occurrence of, and obtain compliance from, chronic and recalcitrant violators of control measures will be implemented. Measurable Goals must be completed by Construction Sites Program Measurable Goals Chronic and Recalcitrant Violators Provide the year for implementation 3.a Fully Implement procedures to minimize the occurrence of, and obtain compliance from, chronic and recalcitrant violators of control measures Implementation Year Not Applicable 26 of 37

27 POST-CONSTRUCTION STORMWATER MANAGEMENT STORMWATER DISCHARGES ASSOCIATED WITH MS4s Program Descriptions A. Program Perspective The goal of the Post-Construction Stormwater Management program is to implement planning procedures and enforcement mechanisms to reduce, to the maximum extent practicable, stormwater impacts resulting from areas of new development and significant redevelopment. B. Permit Requirements Post-construction stormwater management in new development and redevelopment. The permittee must develop, implement, and enforce a program to address stormwater runoff from new development and redevelopment projects that disturb greater than or equal to one acre, including projects less than one acre that are part of a larger common plan of development or sale, that discharge into the MS4. The program must ensure that controls are in place that would prevent or minimize water quality impacts. The permittee must: 1) Develop, implement, and document strategies which include the use of structural and/or nonstructural BMPs appropriate for the community that address the discharge of pollutants from new development and redevelopment projects, and/or that maintain or restore hydrologic conditions at sites to minimize the discharge of pollutants and prevent in-channel impacts associated with increased imperviousness; (Clarified permit requirement) 2) Use an ordinance or other regulatory mechanism to address post- construction runoff from new development and redevelopment projects to the extent allowable under State or local law; 3) Develop, implement, and document procedures to determine if the BMPs required under Item (1), above, are being installed according to specifications. (This may be developed in conjunction with the Construction program area, as described in Part I.B.4); 4) Develop, Implement, and document procedures to ensure adequate long-term operation and maintenance of BMPs, including procedures to enforce the requirements for other parties to maintain BMPs when necessary; (Clarified permit requirement) 5) Develop, implement, and document an enforcement program, which addresses appropriate responses to common noncompliance issues, including those associated with both installation (subparagraph (3), above) and long term operation and maintenance (subparagraph (4), above) of the required control measures; (Clarified permit requirement) 6) Develop and implement procedures and mechanisms to track the location of and adequacy of operation of long-term BMPs implemented in accordance with the program. (Clarified permit requirement) 27 of 37

28 C. Program Elements: By using existing, ongoing program elements to meet the permit requirements, the MS4 is committed to continuing each of these program elements. Any changes would require use of the program modification process as outlined in Part I.E.2. of the permit. 1. Regulatory mechanism Program Description SEMSWA s post-construction program is operating under the regulatory mechanisms listed below for permitted areas within the City. These mechanisms allow SEMSWA to require permanent BMPs and enables sanctions to ensure compliance. 1. City of Centennial s Land Development Code, Part 100, CCBWQA Requirements (Ord ) (adopted 12/11/05) 2. City of Centennial s Land Development Code, Chapter 8- Stormwater Quality Requirements (adopted 12/11/05) 3. City of Centennial s Stormwater Management Manual including adoption of Urban Drainage Volumes I, II, and III by reference (Amended- Ord O-01) (February 2007) requires that a Stormwater Facilities Maintenance Agreement be executed for all permanent stormwater facilities. The agreement requires that the stormwater management facilities be maintained in accordance with the Operation & Maintenance Manual for the facility and provides legal authority to inspect, require maintenance of the permanent BMP, perform maintenance, and recoup costs from the owner. For SEMSWA permitted areas within unincorporated Arapahoe County, SEMSWA follows Arapahoe County s Post-Construction Program. See attached Arapahoe County Program Description Document for details on Arapahoe County s Post-Construction Program. 2. Design Criteria and Standards Program Description For permitted areas within the City, the following are used to guide developers in the selection and design of appropriate structural and non-structural BMPs appropriate for the community. 1. The City of Centennial s Stormwater Management Manual references Urban Drainage Volumes I, II, and III, and provides requirements for the planning, design, construction, and operation of stormwater facilities and includes design checklists for BMPs, a design table for appropriateness of BMPs, Operations and Maintenance Manual and Maintenance Agreement for all new permanent water quality BMPs. 2. SEMSWA s New Construction SOP provides guidance for staff by outlining requirements for permanent BMPs for CIP projects. In addition, SEMSWA has Master Drainage Plans, Outfall System Plans, and Flood Hazard Area Delineation studies for several drainageways in the service area that guides developers in the appropriate selection of permanent BMPs, as well as availability of regional water quality BMPs. For SEMSWA permitted areas within unincorporated Arapahoe County, SEMSWA follows Arapahoe County s Post-Construction Program. See attached Arapahoe County Program Description Document for details on Arapahoe County s Post-Construction Program. 28 of 37

29 3. Review and Approval Procedures i. Plan Review ii. Field verification iii. Municipal Projects Program Description For permitted areas within the City, SEMSWA follows the review and approval procedures below. i. Plan Review- Site plans and plats, drainage reports, construction drawings, and other technical plans are referred to SEMSWA as part of the City s land development review process. These plans include the design for proposed permanent water quality BMPs meeting the Stormwater Management Manuals requirements. Upon addressing all outstanding comments, SEMSWA issues a Memorandum of Design Approval to the City of Centennial. SEMSWA approves Drainage Reports and Standard Operating Procedures with the Maintenance Agreement (recorded against the property). The City, upon issuance of SEMSWA s Memorandum of Design Approval, approves construction drawings, site plans, plats, and other technical documents. Plans are tracked through a database. ii. Field verification- SEMSWA and the City jointly enter into a Subdivision Improvement Agreement (SIA) that serves as a guarantee of installation of permanent water quality BMPs and other stormwater improvements, per the approved plan. The SIA requires collateral that is not released until final approval of the permanent BMP. Stormwater Inspectors inspect permanent BMPs during installation to ensure proper installation. If a permanent BMP is installed incorrectly, collateral is held or can be used to correct the problem. iii. Municipal Projects Municipal projects follow the same criteria for review and approval as private developers. For SEMSWA permitted areas within unincorporated Arapahoe County, SEMSWA follows Arapahoe County s Post-Construction Program procedures for review and approval. See attached Arapahoe County Program Description Document for details on Arapahoe County s Post-Construction Program. Review and approval procedures have been developed between SEMSWA and Arapahoe County that address how minimum structural and non structural BMPs are reviewed and approved. SOP 5.1, MS4 Permit Program 5, Land Development Cases, and SOP 5.2, MS4 Permit Program 5, CIP Construction Projects, provide additional details on roles of staff as it relates to review and approval procedures for this program area. 4. Tracking Program Description In all SEMSWA permitted areas, permanent BMP locations are tracked using GPS and GIS. Maintenance history is tracked in a database. 29 of 37

30 5. Requiring long-term operation and maintenance of BMPs Program Description For permitted areas within the City, long-term maintenance is required through the following mechanisms: The City requires that a Stormwater Facilities Maintenance Agreement be executed for all permanent stormwater facilities. The agreement requires that the permanent stormwater management facilities be maintained in accordance with the Operation & Maintenance Manual (O & M Manual) for the facility. An O & M Manual must be developed in conjunction with the final design to provide operation and maintenance guidance for all post-construction BMPs and be submitted for City acceptance prior to City acceptance of the construction drawings. The City s Stormwater Management Manual outlines the development requirements for an O & M Manual. Drainage easements are required for all new features and the Maintenance Agreement identifies the party responsible for permanent BMP maintenance. The Maintenance Agreement provides legal authority to inspect, require maintenance of the permanent BMP, and perform maintenance and recoup costs from the owner. Prior to final approval, an inspection determines if new permanent BMPs are installed and constructed in accordance with specifications. For SEMSWA permitted areas within unincorporated Arapahoe County, SEMSWA follows Arapahoe County s Post-Construction Program to require long-term operation and maintenance of BMPs. See attached Arapahoe County Program Description Document for details on Arapahoe County s Post- Construction Program. SOP 5.1, MS4 Permit Program 5, Land Development Cases, and SOP 5.2, MS4 Permit Program 5, CIP Construction Projects, provide additional details on roles of staff as it relates to operation and maintenance of stormwater facilities for this program area. 6. Monitor long-term compliance a. Inspections b. Enforcement Program Description For permitted areas within the City, SEMSWA follows the procedures below. a. Inspections SEMSWA conducts inspections every year on permanent BMPs in the City that were installed prior to O and M Manual requirements. Permanent BMPs installed with a Maintenance Agreement require the property owner to submit an annual report to SEMSWA detailing maintenance activities for the year. If an annual report is not received, SEMSWA follows up with the property owner. If a complaint is received, SEMSWA conducts an additional inspection. b. Enforcement Responses for failure to maintain a permanent BMP may include verbal requests and meetings onsite to discuss proper maintenance, written request, charging the owner for corrective work and issuing a summons. Flexibility is utilized to ensure that enforcement actions are carried out in a manner appropriate to the corrections needed. 30 of 37

31 For SEMSWA permitted areas within unincorporated Arapahoe County, SEMSWA follows Arapahoe County s Post-Construction Program procedures to monitor long-term compliance. See attached Arapahoe County Program Description Document for details on Arapahoe County s Post-Construction Program. SOP 5.1, MS4 Permit Program 5, Land Development Cases, and SOP 5.2, MS4 Permit Program 5, CIP Construction Projects, provide additional details on roles of staff as it relates to inspection and enforcement of stormwater facilities D. Measurable Goals Inclusion of measurable goals is not necessary, as the elements described in Part C, above, constitute full program implementation and a commitment to continue these elements. 31 of 37

32 POLLUTION PREVENTION/ GOOD HOUSEKEEPING FOR MUNICIPAL OPERATIONS STORMWATER DISCHARGES ASSOCIATED WITH MS4s Program Descriptions A. Program Perspective The goal of the Pollution Prevention/Good Housekeeping for Municipal Operations program is to reduce, to the maximum extent practicable, the amount and type of pollution that is generated by municipal operations or from municipally-owned property. B. Permit Requirements The permittee must develop and implement an operation and maintenance program that includes an employee training component and has the ultimate goal of preventing or reducing pollutants in runoff from municipal operations. The program must also inform public employees of impacts associated with illegal discharges and improper disposal of waste from municipal operations. The program must prevent and/or reduce stormwater pollution from facilities such as streets, roads, highways, municipal parking lots, maintenance and storage yards, fleet or maintenance shops with outdoor storage areas, salt/sand storage locations and snow disposal areas operated by the permittee, and waste transfer stations, and from activities such as park and open space maintenance, fleet and building maintenance, street maintenance, new construction of municipal facilities, and stormwater system maintenance, as applicable. The permittee must: 1) Develop and maintain written procedures for the implementation of an operation and maintenance program to prevent or reduce pollutants in runoff from the permittee s municipal operations. The program must specifically list the municipal operations (i.e., activities and facilities) that are impacted by this operation and maintenance program. The program must also include a list of industrial facilities the permittee owns or operates that are subject to separate coverage under the State s general stormwater permits for discharges of stormwater associated with industrial activity; (New permit requirement) i) Specific Deadline for Renewal Permittees: Renewal Permittees must comply with the requirements of subparagraph (1) by no later than December 31, ) Develop and implement procedures to provide training to municipal employees as necessary to implement the program under Item 1, above. (Clarified permit requirement) C. Program Elements: By using existing, ongoing program elements to meet the permit requirements, the MS4 is committed to continuing each of these program elements. Any changes would require use of the program modification process as outlined in Part I.E.2 of the permit. 32 of 37

33 1. Implementation of an operation and maintenance program Program Description The Program 6 Procedures Manual applies to (1) all owned or leased properties presently utilized by the City for municipal operations, as well as future facilities to be owned or leased; (2) all municipal operations performed by the City itself, or performed on behalf of the City by outside contractors; (3) any new open space land acquisition, whether vacant or containing structures; and (4) all new construction that the City conducts itself or is conducted on behalf of the City by a contractor. A runoff control plan (RCP) was developed for the City facility, which includes the administrative offices/city Hall Building in Centennial. As other buildings are leased or constructed to conduct City business, they are evaluated to determine if an RCP is needed. The RCP document describes pollution prevention BMPs for the facility and SOPs for the operational areas and/or activities that could contribute to stormwater pollution. Audits of the RCPs are conducted to ensure the program is implemented at the site. SOPs have been prepared for municipal operations of interest. As operational activities change, new SOPs are written and existing SOPs are updated. SEMSWA will review existing documented procedures, and develop new written procedures, as necessary, for the implementation of an operation and maintenance program to prevent or reduce pollutants in runoff from ECCV s municipal operations. 2. Employee Training program Program Description The employee education and training programs provide education related to components of RCPs and the SOPs related to each employee s job function. The education program is implemented in various ways through short presentations at periodic safety meetings; by posting good housekeeping signs, where allowed and appropriate; and/or by providing specific training sessions for employees on the use of the RCP document and operational area SOPs. Some of the specific training and educational efforts include the following: Training employees and management regarding inappropriate non-stormwater discharges. Training on RCP and SOPs Training and signage (as allowed and appropriate) regarding proper spill reporting procedures including the use of spill kits and drip pans Signage and visible instructions throughout the facility (e.g. spill kit locations, no dumping, etc.) where allowed and appropriate Log of employee RCP and SOP training 33 of 37

34 SOPs and fact sheets have been developed for the following activities/operations: Street Sweeping Building Maintenance Parking Lot Maintenance Landscape Chemical Application Gravel Road Maintenance Detention Pond Maintenance Snow Removal General Landscaping Vehicle Fueling Open Space Maintenance Vehicle Repair and Maintenance Storm Inlet Pipe Maintenance Vehicle and Equipment Washing Vehicle and Equipment Storage General Good Housekeeping Spill Control Materials Storage Drainageway Maintenance ROW Maintenance Asphalt Replacement Program Concrete Replacement Program New Construction D. Measurable Goals Measurable Goals are required as per Part I.B.6(a)(1) of the permit (Permit Requirement (a)(1) in Part B, above), because this is a new permit requirement. Check Box 1 or 2, below. The Table in Part 3 must be filled out if you check Box Written procedures and lists, as listed in Part C.3, above, for the implementation of an operation and maintenance program to prevent or reduce pollutants in runoff from the permittee s municipal operations, have already been developed. (It is not necessary to complete Part 3 below if you check this box.) 2. Written procedures and lists for the implementation of an operation and maintenance program to prevent or reduce pollutants in runoff from the permittee s municipal operations have NOT already been fully developed. (You must complete Part 3 below if you check this box.) 3. Pollution Prevention/ Good Housekeeping Measurable Goals: The Measurable Goal has been provided. Include the year when written procedures for the implementation of an operation and maintenance program to prevent or reduce pollutants in runoff from the permittee s municipal operations will be fully developed. Measurable Goals must be completed by Pollution Prevention/ Good Housekeeping Measurable Goals Provide the year(s) for implementation 3.a Review existing documented procedures, and develop new written procedures, as necessary, for the implementation of an operation and maintenance program to prevent or reduce pollutants in runoff from the permittee s municipal operations. The documentation must specifically list the municipal operations (i.e., activities and facilities) that are impacted by this operation and maintenance program. The documentation must also include a list of the industrial facilities the permittee owns or operates that are subject to separate coverage under the State s general stormwater permits for discharges of stormwater associated with industrial activity. Implementation Year of 37

35 Appendix A MS4 Boundary Map- the SEMSWA permit boundary is the same as the jurisdictional boundary. 35 of 37

36

37 "GUN CLUB GUN CLUB UNIVERSITY COLORADO QUEBEC YOSEMITE HOLLY DAYTON HAVANA HAVANA HAVANA LIVERPOOL BUCKLEY C I TY & COUNTY o f D E N V E R YALE ILIFF A U R O R A E N G L E WO O D HAMPDEN CHERRY HILLS VILLAGE ARAPAHOE CENTENNIAL C E N T E N N I A L DRY CREEK COUNTY LINE Cherry Creek Reservoir ARAPAHOE Quincy Reservior F O X F I E L D ARAPAHOE D O U G L A S C O U N T Y 0 1,2502,500 5,000 7,500 10,000 Feet Appendix A -Page 1 SEMSWA Permit and Jurisdictional Boundary Centennial East Cherry Creek Valley (ECCV) Inverness Water and Sanitation District Arapahoe County Water and Wastewater Authority (ACWWA) Cherry Creek Basin Unincorporated Arapahoe County Outside SEMSWA service area Lakes Rivers SEMSWA Permit & Jurisdictional Boundary