City of Tacoma Stormwater Management Program Assessment. Attachment B3

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1 City of Tacoma Stormwater Management Program Assessment Attachment B3

2 Attachment B3. City of Tacoma Stormwater Management Program Assessment The following discussion includes an assessment of the appropriateness of Tacoma s Stormwater Management Program elements including any changes made or anticipated to be made, and why, per NPDES Stormwater Management Program (SWMP) Permit Sections S9.E.6 and S8.B.2. B3.1 Public Involvement and Participation Program Update: During 2011, the City proceeded with code updates to two programs related to mitigating the surface water impacts of new development and redevelopment projects under Permit Section S5.C.5: Urban Forestry and Critical Areas Preservation. Draft updates to the elements of the Comprehensive Plan and Land Use Regulatory Code related to tree and landscaping requirements were developed to help implement Tacoma s updated Urban Forest Policy and meet the City s tree canopy coverage goal of 30% by The updates incorporated public participation and input by members of the Planning Commission, City Council, Neighborhood Councils, and a variety of other stakeholders through the City s annual amendment process and supplemental public meetings coordinated by the Urban Forester. Tacoma s Critical Areas Preservation code was also updated primarily to streamline permitting and provide voluntary restoration options for Tacoma s residents without going through a costly and time intensive permitting process. Staff review and approval is still required in many cases, yet residents can now proceed with restoration efforts quickly on public and private land. Public Participation in developing the new code provisions included a citizens Focus Group, internal stakeholders from City Departments, and wetland consultants who have worked within the City permitting process. Additional updated items also included wetland buffer refinement, mitigation bank and In-lieu fee regulatory guidance. On February 15, 2012, the Planning Commission forwarded the new draft CAPO to the City Council. Program Assessment: The existing public participation process completes the related elements of the Stormwater Management Program and satisfies NPDES Permit requirements. B3.2 Controlling Runoff from New Development, Redevelopment and Construction Sites Program Update: The City completed significant updates to the Surface Water Management Manual to increase clarity and consistency during 2011 and the new manual was released February 1, Highlights included significant revisions to the conveyance guidance. There were no changes to any of the Permit Appendix 1 Minimum Technical Requirements for New Development and Redevelopment that would impact manual equivalency to the Ecology manual.

3 Coordination between inspector sign-offs on newly constructed stormwater connections and adding those approved connections to our mapping system is still being improved to better implement the standard operating procedures identified in the Stormwater Management Program. Preventing erosion and sediment loss during active construction is recognized as an ongoing challenge and will continue to be a focus of Building and Land Use Services (BLUS) Division, Construction Division, and Environmental Compliance inspectors. Improving inspections for soil amendment BMPs is also a need. A recent reorganization in the Public Works Department has moved the Construction Division Inspectors into the Environmental Services Division, and is anticipated to increase coordination and effectiveness of stormwater-related BMP inspections. Integration of stormwater review staff in the initial planning and pre-submittal conferences with permit customers is an ongoing process and continues to improve. We continue to work with BLUS permit specialists to have demolition applications which meet permit thresholds routed to stormwater staff for permit review and approval. Plan review and inspection staff training opportunities continued during Highlighted training includes City Stormwater Management Manual training on minimum requirements #1-10 and training on the operation and maintenance of emerging stormwater technologies. Tracking of staff training will continue to be developed and improved during Program Assessment: The existing program meets the minimum NPDES Permit requirements. Additional improvements in program implementation and effectiveness will continue to be identified and implemented in B3.3 Structural Stormwater Controls Program Update: In 2011, several stormwater treatment and flow reduction projects identified in the Capital Improvement Program spreadsheet started design or construction phases and are included in Attachment B4. Two highlighted projects include the Alaska Street Pervious Pavement Project and the Cheney Stadium Sustainable Stormwater Project. The Alaska Street Project initiated construction during 2011 and completion is scheduled for August This project includes porous parking lanes and infiltration trenches to recharge groundwater and reduce runoff in the vicinity of Wapato Lake. The Cheney Stadium Sustainable Stormwater Project replaces nearly one acre of parking areas with pervious pavement to treat nearly 5 acres of parking lot runoff. Cheyenne Street leading to the stadium was replaced with a section of porous asphalt, and another section is treated with bioretention facilities. Over 100 trees were planted. Both projects are currently pursuing Greenroads Certification. Cheney is currently under preliminary review for certification. In addition to installing water quality retrofits, the City is pursuing an aggressive pipe cleaning effort as a strategy to remove significant amounts of pollutants from the system and prevent them from entering the waterways. This effort has demonstrated significant cost-effective water quality improvements as identified in the Thea Foss Source Control

4 Report (attachment C-1). A new Stormwater Rapid Assessment Program (STRAP) to inspect the entire stormwater conveyance system in 4 years was initiated in 2011 to help to prioritize maintenance and repair projects (see more under section B3.6 Operation and Maintenance Program.) In 2011, pipe cleaning projects were focused in the North Tacoma, Flett Creek, Leach Creek and Foss Waterway watersheds. A Thea Foss Watershed model is being developed to identify the most cost-effective and beneficial placement and density of water quality best management practices in the storm system. The model builds on the analysis of nine years of modeling and statistical evaluation of stormwater quality data in the Thea Foss Watershed. In 2011, the model was calibrated to describe the transport of contaminants within the watershed. In 2012, Best Management Practices (BMPs) will be introduced to determine levels of improvement. In this way the model will direct the City to the most cost-effective actions or BMPs, and show where and at what intensity they should be implemented to protect water and sediment quality in the Thea Foss Waterway. The BMPs and development strategies currently budgeted include street sweeping, storm-line cleaning, StormFilter vaults and other BMPs. The results of this model will be incorporated into a plan to guide the type, location and intensity of the application of new green infrastructure methods and BMPs in addition to ongoing traditional stormwater management strategies to improve water quality. The focus of the plan is three-fold: 1) apply BMPs in high impact areas so that water quality can be improved; 2) group these efforts so that any improvement can be monitored; and 3) use the results to apply these BMPs to other like land uses. Once completed, the plan will be a stormwater information resource to City staff designing and reviewing stormwater systems throughout the City and to decision-makers as they consider Citywide land use and development-related decisions. Program Assessment: The Structural Stormwater Controls program completes the related elements of the Stormwater Management Program and satisfies NPDES Permit requirements. The new pipe assessment and watershed modeling efforts underway are anticipated to greatly improve the effectiveness of the program. B3.4 Source Control Program for Existing Development Program Update: In 2011, the Source Control inspectors continued a program of doorto-door inspections in order to accomplish permit requirements for developing a comprehensive list of Pollution Generating Sources and achieved inspection of over 95% of the city-wide businesses and multi-family dwellings during the permit term. The inspectors also continue to respond to 100% of spills and complaints. The inspections cover both stormwater and wastewater source control and compliance issues. As the inspection program matures, the proficiency and thoroughness of the inspections is continuing to improve. Also, the inspectors continue to refine protocols and provide data entry training to make the Environmental Compliance Inspection Database a more useful tool. Several enforcement-related documents were updated for clarity and effectiveness including Tacoma Municipal Code Chapter 12.08, the spill response and duty pager phone list, and the source control BMPs in Tacoma s Stormwater Management Manual Volume IV.

5 In 2012, efforts will focus on adjusting inspector areas to increase field presence and focus business inspections on sites with treatment and flow control devices, restaurants, wastewater pretreatment-permited industries, and other sites that require ongoing attention. The spill response policy will be updated, and staff training will continue and focus on incorporating more opportunities for guest speakers, field trips, and highlighting in-house expertise. Program Assessment: The existing source control program completes the related elements of the Stormwater Management Program and satisfies NPDES Permit requirements. B3.5 Illicit Connections and Illicit Discharges Detection and Elimination Program Update: Field crews have been investigating sanitary and storm crossconnections by initial smoke testing and verifying results with a dye test, if necessary. By the end of 2011, field screening was completed for 57,117 addresses in the City which equates to over 80% of the City of Tacoma s stormwater system, exceeding the Permit requirement by over 20%. In 2011, although most of the identified cross-connections were eliminated within the permit goal of 6 months, one cross-connection still remained to be corrected in 2012 and exceeded the 6-month timeframe. A G20 Notification letter has been sent to Ecology regarding this case. A Cross Connection Committee has been initiated including representatives from Stormwater Engineering, Sanitary Engineering, Sewer Transmission, Source Control, and Collection Systems Support. The committee has developed a sanitary to storm cross connection flow chart for repairs. This chart documents the events that need to take place from discovery to termination of the cross connection including documentation and reporting. The committee and flow chart are anticipated to assist in meeting the 6 month goal for eliminating illicit connections in the future. In April 2011, progress was made in updating Tacoma s Municipal Code Section to codify the Stormwater Compliance Policy updated in 2010, expand enforcement jurisdiction to properties with direct stormwater discharges to surface waters, and clarify definitions related to eliminating illicit discharges. IDDE training for City-wide field staff to identify and report illicit discharges remains an ongoing effort including training for field staff in Public Works, Police, Fire, and Tacoma Public Utilities. Program Assessment: The existing IDDE program completes the related elements of the Stormwater Management Program and satisfies NPDES Permit requirements with the exception of the City-wide field staff IDDE training requirement and 6 month time frame for eliminating all identified illicit connections, which are both continuing efforts.

6 B3.6 Operation and Maintenance Program Program Update: Maintenance Activity Summary As can be seen by comparing the maintenance summary reports from 2010 and 2011, the number of surface water maintenance tasks performed related to storm pipe and gutter-line maintenance; catch basin, culvert and manhole cleaning, maintenance and repair; and holding basin, ditch, and detention pond maintenance decreased from 2010 values. The 2011 value for storm pipe maintenance and repair still exceeded the annual goal of 150,000 linear feet per year. The decrease in footage from 2010 can be attributed to two explanations. First, in 2010, a higher percentage of catch basin lateral footage accounted for 36% of the total storm pipe footage cleaned. In 2011, catch basins laterals accounted for only a little over 12% of the totals which equates to a 90,000 foot difference. The other more important factor is that with the new Stormwater Rapid Assessment Program (STRAP) TV inspections, pipes do not have to be cleaned prior to TV inspection being performed. Pipes that are in need of cleaning or other maintenance are tracked in the GIS mapping layer and only the pipes that need cleaning or maintenance are put on the future work plan. A threefold increase in TV footage occurred in 2011, so the change of business process translates into a decrease in the footage maintained, but results in work efforts being more appropriately placed based on increased inspection footage and specific maintenance needs. Street gutter-line cleaning and gutter box replacements are performed by the Streets and Grounds Operation and Maintenance Division whose staffing reductions may account for the slight decrease in linear feet maintained in Also, budget limits may have affected the quantity of gutter boxes replaced. The street sweeping schedules were modified in late 2010, and throughout 2011 crews were able to meet the new, closely defined schedules for optimum service levels and an increase in miles swept over Stormwater Rapid Assessment Program (STRAP) A new Stormwater Rapid Assessment Program (STRAP) to inspect the entire stormwater conveyance system (400 miles) within a four year period was initiated in 2011 using an Ecology Capacity Grant. In addition to assessing pipe capacity and condition to prioritize maintenance and repair projects, the camera inspection system also identifies sewer cross connections and illegal connections to supplement the IDDE program. During 2011, a total of 322,757 feet of pipe were viewed and assessed. This is a threefold increase in TV footage data gathering compared with Using the results of the STRAP inspections, the Asset Management group identified drainage areas in the following watersheds as the targeted areas for the annual storm pipe cleaning focus in 2011: North Tacoma, Flett Creek, Leach Creek and the Foss Waterway. Maintenance Plans One method the program continues to use to assess and improve program effectiveness is maintenance plans for City-owned catch basins and stormwater facilities. These maintenance plans identify maintenance needs and are developed as a result of new equipment installations, as well as observations during regular maintenance visits by staff. Twenty maintenance plans were updated and 36 maintenance plans were created in 2011 in response to maintenance staff observations. As we complete storm facility

7 inspections, opportunities to improve current maintenance protocols and procedures are emerging. Creation of additional maintenance plans for new installations, and updates of the City s Stormwater Detention and Treatment Facilities O&M Manual will occur in Program Assessment: The Operation and Maintenance program completes the related elements of the Stormwater Management Program and satisfies NPDES Permit requirements. B3.7 Education and Outreach Program Program Update: Attached is a spreadsheet summarizing the Stormwater Education and Outreach Program activities in 2011 and identifying program updates and future direction for each activity (Attachment B14). Program Assessment: Evaluation of the overall understanding and adoption of target behaviors resulting from the Stormwater Education and Outreach Program is based on the results of the City of Tacoma Environmental Services Customer Survey which is a regularly administered, statistically valid, City-wide survey. The most recent round of this survey was administered in 2009, and the program activity updates and future direction are based on evaluation of the survey results. In 2011, we also performed a pre- and post-installation effectiveness evaluation of new dog waste stations and signage in two waterfront parks in Tacoma (see Attachment B14).