NPDES Phase II Permit

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1 NPDES Phase II Permit 2013 Stormwater Management Program

2 City of Vancouver 2013 Stormwater Management Program Introduction The purpose of this Stormwater Management Program (SWMP) document is to detail activities that the City of Vancouver intends to undertake between January 1 and December 31 of 2013 to maintain compliance with the Western Washington Phase II Municipal Stormwater Permit. This 2013 SWMP will be submitted to the Department of Ecology with the 2012 Annual Compliance Report on March 31, Regulatory Background The National Pollutant Discharge Elimination System (NPDES) is the program created under the Federal Clean Water Act for administering stormwater discharge permits and establishing pretreatment requirements for discharges to surface waters of the state from point sources. These permits are referred to as NPDES permits and are administered by the Washington State Department of Ecology for Washington State. The Western Washington Phase II Municipal Stormwater Permit was issued by the Washington State Department of Ecology on January 17, It was effective February 16, 2007, and expiring on February 15, 2012 and has been extended to August 1, The City of Vancouver, under this permit, is a Regulated Small Municipal Separate Storm Sewer System (MS4). The geographic area of coverage is the entire incorporated area of the city and will include all annexed parcels in the future. This Permit authorizes the discharge of stormwater to surface waters and to ground waters of the state from municipal separate storm sewer systems. Waters of the State includes those waters as defined as "waters of the United States" in 40 CFR Subpart within the geographic boundaries of Washington State and "waters of the state" as defined in Chapter RCW which includes lakes, rivers, ponds, streams, inland waters, underground waters, salt waters and all other surface waters and water courses within the jurisdiction of the State of Washington. These discharges are subject to the following limitations: Discharges to ground waters of the state through facilities regulated under the Underground Injection Control (UIC) program, Chapter WAC, are not covered under this Permit. Discharges to ground waters not subject to regulation under the federal Clean Water Act are covered in this permit only under state authorities, Chapter RCW, the Water Pollution Control Act. This Permit authorizes discharges of non-stormwater flows to surface waters and to ground waters of the state only under the following conditions: The discharge is authorized by a separate National Pollutant Discharge Elimination System (NPDES) or State Waste Discharge permit. The discharge is from emergency fire fighting activities. The discharge is from another illicit or non-stormwater discharge that is managed by the City as provided in Special Condition S5.C.3.b. This Permit does not relieve entities that cause illicit discharges, including spills, of oil or hazardous substances, from responsibilities and liabilities under state and federal laws and regulations pertaining to those discharges. In accordance with RCW , the discharge of toxicants to waters of the state of Washington which would violate any water quality standard, including toxicant standards, sediment criteria, and dilution zone criteria is prohibited. This Permit does not authorize a violation of Washington State Surface Water Quality Standards (Chapter A WAC), Ground Water Quality Standards (Chapter WAC), Sediment Management Standards (chapter WAC), or human health- 1

3 based criteria in the national Toxics Rule (Federal Register, Vol. 57, NO. 246, Dec. 22, 1992, pages ). The City of Vancouver is responsible for compliance with the terms of this permit and must: Reduce the discharge of pollutants to the maximum extent practicable (MEP), and Use all known, available, and reasonable methods of prevention, control and treatment (AKART) to prevent and control pollution of waters of the state of Washington. S5 Stormwater Management Program Administration Stormwater Management Program The Stormwater Management Program (SWMP) is a set of actions and activities designed to reduce the discharge of pollutants and to protect water quality. The purpose of the SWMP is to detail current and planned actions that the City of Vancouver may implement to meet the requirements of the Permit. This document is arranged as required to coincide with the Permit s program components: Public Education and Outreach (S5.C.1) Public Involvement and Participation (S5.C.2) Illicit Discharge Detection and Elimination (S5.C.3) Controlling Runoff From New Development, Redevelopment & Construction (S5.C.4) Pollution Prevention & Operations & Maintenance for Municipal Operations (S5.C.5) Monitoring (S8) This SWMP, and subsequent revisions to it, will be posted on the City s website and submitted to Ecology with the required Annual Report by March 31 st of each year as required by the permit. Public review and comment is encouraged. Contact information is available on the City s website at This SWMP details activities that are planned and that fall under the purview of the Permit. The City, Public Works, Surface Water Management and Stormwater Services conduct programs and activities that reduce flooding, protect and improve water quality, protect groundwater, and protect and restore aquatic habitat in the city s streams and lakes. For details on the city s Surface Water Management programs and activities not addressed in this SWMP see the city website. Permit Requirements (S5) Implement a Stormwater Management Program (SWMP) [S5 A1 Deadline 180 days prior to permit expiration]. Include coordination mechanisms among entities and departments within each jurisdiction to eliminate barriers to compliance with the terms of this permit [S5 A5a/b]. Coordination mechanisms shall clarify roles and responsibilities for the control of pollutants between physically interconnected MS4s permittees covered by a municipal stormwater permit [S5 A5ai]. Coordination mechanisms shall coordinate stormwater management activities for shared water bodies among permittees to avoid conflicting plans, policies and regulations [S5 A5aii]. Copies of interlocal agreements will be attached to the Annual Report as needed [S9 E2f]. Include with the Annual Report notification of any annexations, incorporations or jurisdictional boundary changes resulting in an increase or decrease in the City s geographic area of permit coverage during the reporting period, and implications for the SWMP [S9 E3]. 2

4 Track the number of inspections, official enforcement actions and types of public education activities as stipulated by the respective program component. This information shall be included in the annual report [S5 A3b]. Track the cost or estimated cost of development and implementation of each component of the SWMP. This information shall be provided to Ecology upon request. [S5 A3a Deadline January 1, 2009] Current Activities (S5) The City of Vancouver currently has in place many activities and programs that contribute to meeting the Permit requirements. Current activities associated with the above Permit requirements include: Coordination among entities, the City cooperates with other agencies throughout the region to improve water quality and reduce pollutants. Coordinated activities include Vancouver Lake Partnership, and scheduled meetings with the Port of Vancouver, and Clark County. Several City departments participate in activities to reduce, minimize or eliminate pollutant releases to waters of the state. Coordination among departments includes city staff meeting regularly regarding coordination of programs, activities and documentation for compliance with the Permit requirements. Several city departments are involved with Permit compliance including Development Review Services, but Public Works carries out the majority of programs and activities through Surface Water Management, Operations & Maintenance, Construction Services, Water Resources Education, and Urban Forestry. Cost tracking is in place. Systems and processes are continuing to be refined for financial and activity tracking. Implementation of the programs and activities to meet the Permit are within numerous city departments. Tracking systems, software programs and data entries are historically set up to meet the demands of each department. This complicates the effort to pull accurate reporting on finances and activities that meet the Permit. Planned Activities (S5) Continue to refine roles, responsibilities and coordination mechanisms with various departments and partners to enhance efficiency, effectiveness and achieve Permit compliance. Provide copies of interlocal agreements with the Annual Report as needed. Provide annexation updates to submit with the Annual Report. Continue to refine activity tracking systems and procedures needed to fulfill the Annual Report requirements of this Permit. Continue to refine the financial management systems and procedures needed to fulfill the requirements of this Permit. Continue to evaluate inspection and enforcement procedures to identify how computer hardware and software could be incorporated into the program so that inspectors can better perform compliance activities onsite and record site data more accurately and efficiently. 3

5 Permit Requirements (S5 C1) S5 C1 Public Education and Outreach Provide an education and outreach program for the area served by the MS4. The outreach program shall be designed to achieve measurable improvements in the target audience s understanding of the problem and what they can do to solve it. [S5 C1a Deadline February 15, 2009]. Education and outreach efforts shall be prioritized to target the following audiences and subject areas: General public General impacts of stormwater flows into surface waters. Impacts from impervious surfaces. Source control BMPs and environmental stewardship actions and opportunities in the areas of pet waste, vehicle maintenance, landscaping and buffers. General public, businesses, including home-based and mobile businesses BMPs for use and storage of automotive chemicals, hazardous cleaning supplies, carwash soaps and other hazardous materials. Impacts of illicit discharges and how to report them. Homeowners, landscapers and property managers Yard care techniques protective of water quality. BMPs for use and storage of pesticides and fertilizers. BMPs for carpet cleaning and auto repair and maintenance. Low Impact Development techniques, including site design, pervious paving, retention of forests and mature trees. Stormwater pond maintenance. Engineers, contractors, developers, review staff and land use planners Technical standards for stormwater site and erosion control plans. Low Impact Development techniques, including site design, pervious paving, retention of forests and mature trees. Stormwater treatment and flow control BMPs. Measure the understanding and adoption of the targeted behaviors for at least one targeted audience in at least one subject area. The resulting measurements shall be used to direct education and outreach resources most effectively, as well as to evaluate changes in adoption of the targeted behaviors. [S5C1b Deadline February 15, 2009] The City shall track and maintain records of public education and outreach activities. [S5 C1c Deadline February 15, 2009] Track the cost or estimated cost of development and implementation of this component of the SWMP. This information shall be provided to Ecology upon request. [S5 A3a Deadline January 1, 2009] Current Activities (S5 C1) Public education and outreach has long been a vital component of the City of Vancouver s ongoing efforts to protect and enhance water resources and aquatic habitat. Central to these efforts is the Water Resources Education Center, funded and operated directly by the City of Vancouver. In addition to the Water Center and other City departments, the City actively engages in community surface and stormwater 4

6 education and outreach through a variety of other communication vehicles, including local media advertisements and articles, and Internet information. The City is also an active partner with many other agencies in ongoing programs to educate and reach out to the community including the Urban Forestry Commission, Vancouver Watersheds Alliance, Columbia Springs Environmental Education Center and Coalition for Clean Rivers and Streams. The City revised its stormwater, erosion prevention and water protection ordinances in 2009 and continues to update related engineering standards and technical design requirements. These standards are used by local engineers and designers for developing plans. The public participates in developing updates through City Council workshops, stakeholder meetings and technical workgroups. In addition to public education and outreach, the City provides extensive technical assistance and outreach to local businesses and industries along with technical training for municipal operations crews. Since 2003 the Water Resources Protection program has been visiting and inspecting commercial operations offering guidance and assistance on practices which help protect both surface and groundwater resources. The Urban Forestry program provides technical advice to landscapers and related businesses which lend support to the City s water quality efforts. A report on current and planned stormwater-related education and outreach activities at the Water Resources Education Center is included as an attachment in the Annual Report. Planned Activities (S5 C1) As an active partner with many other agencies in ongoing programs to educate and reach out to the community, the following is a list of city and regional planned programs and activities: Continue to coordinate City departments and partners to enhance efficiency, effectiveness and achieve Permit compliance. Provide copies of interlocal agreements for the Annual Report as needed. Continue to refine appropriate measurement tools for assessing the success of outreach efforts. Continue to refine activity tracking methods to comply with the Annual Report requirements. Continue to support Urban Forestry workshops, outreach and technical assistance efforts, see the City of Vancouver s Urban Forestry Program Annual Report is attached to the NPDES Annual Report or at the following website: Continue to provide education and outreach through open public City Council workshops, hearings and stakeholder meetings. Continue to provide technical assistance and outreach to local businesses and industries. Continue to provide assistance and education on water quality best practices to municipal operations crews and other City staff. 5

7 Permit Requirement (S5 C2) S5 C2 Public Involvement and Participation Include ongoing opportunities for public involvement through advisory councils, watershed committees, participation in developing rate structures, stewardship programs, environmental activities or other similar activities. The City shall comply with applicable State and local public notice requirements when developing their SWMP [S5 C2]. Create opportunities for the public to participate in the decision-making processes involving the development, implementation and update of the City s entire SWMP. The City shall implement a process for consideration of public comments on their SWMP. [S5 C2a Deadline February 15, 2008] Make the City s SWMP, the annual report required under S9.A and all other submittals required by this Permit, available to the public. The annual report, and SWMP that was submitted with the latest annual report, shall be posted on the City s website. [S5 C2b Deadline March 31 each year] Track the number and types of public activities as stipulated by the respective program component. This information shall be included in the annual report [S5 A3b]. Track the cost or estimated cost of implementation of this component of the SWMP. This information shall be provided to Ecology upon request. [S5 A3a Deadline January 1, 2009] Current Activities (S5 C2) Many City departments and partners currently provide opportunities for public involvement and participation including the Urban Forestry Commission, Water Resources Education Center, Vancouver Watersheds Alliance and Vancouver Lake Watershed Partnership. The City of Vancouver provides information about opportunities for public involvement and participation in decision-making processes through a variety of communication vehicles, including newspaper advertisements and the Internet. The City posts on its website invitations to the public providing opportunity to contribute comments for the SWMP and ordinance revisions. Public participation opportunities have been provided through City Council workshops regarding ordinance adoption, the Urban Forestry program and Vancouver Watersheds Alliance. Planned Activities (S5 C2) Continue to coordinate City departments and partners to enhance efficiency, effectiveness and facilitate public access to achieve Permit compliance. Provide copies of interlocal agreements for the Annual Report as needed. Continue to refine activity tracking methods to comply with the Annual Report requirements. Post the SWMP and Annual Reports to the website by March 31 each year, as required by permit. Hold stakeholder meetings to discuss revisions to existing codes for stormwater control, erosion prevention and water resources protection. Meetings will be open to the public. Continue to look for and create opportunities for public participation and involvement. 6

8 S5 C3 Illicit Discharge Detection and Elimination Permit Requirement (S5 C3) Implement an ongoing program to detect and address non-stormwater discharges, spills, illicit connections and illegal dumping into the City s municipal separate storm sewer system. Include: Procedures for locating priority areas likely to have illicit discharges including prioritizing receiving waters for visual inspection. [S5 C3ci Deadline February 15, 2010, Annual Report]; Field assessment activities, including visual inspection of priority outfalls identified including field assessments for three high priority water bodies, [S5 C3cii Deadline February 15, 2011, Annual Report] then field assessments on at least one high priority water body annually thereafter. [S5 C3cii Deadline February 15, 2012, Annual Report]; Procedures for characterizing the nature of, and potential public or environmental threat posed by, any illicit discharges found by or reported to the City [S5 C3ciii]; Procedures for tracing the source of an illicit discharge [S5 C3civ]; Procedures for removing the source of the discharge [S5 C3cv]. [S5 C3c Deadline for implementing program 180 days prior to permit expiration] Implement an ordinance or other regulatory mechanism to effectively prohibit non-stormwater, illegal discharges, and/or dumping into the City s municipal separate storm sewer system to the maximum extent allowable under State and Federal law. [S5 C3b Deadline August 15, 2009] Maintain a municipal storm sewer system map. Include: The location of all known municipal separate storm sewer outfalls and receiving waters and structural stormwater BMPs owned, operated, or maintained by the City. Map the attributes listed below for all storm sewer outfalls with a 24 inch nominal diameter or larger, or an equivalent cross-sectional area for non-pipe systems: Tributary conveyances (indicate type, material, and size where known). Associated drainage areas. Land use. The City shall initiate a program to maintain a map of all connections to the municipal separate storm sewer authorized or allowed by the City after the effective date of this Permit. Geographic areas served by the City s storm system that do not discharge stormwater to surface waters. [S5 C3a Deadline February 15, 2011] Inform public employees, businesses, and the general public of hazards associated with illegal discharges and improper disposal of waste [S5 C3d]. Distribute appropriate information to target audiences identified pursuant to S5 C1, public education and outreach. [S5 C3di Deadline 180 days prior to permit expiration] List and publicize a hotline for reporting spills and illicit discharges. Record calls received and follow-up actions taken in accordance with S5C3cii through S5C3cv and include a summary in the annual report [S5 C3dii Deadline February 15, 2009, Annual Report]. Adopt and implement procedures for program evaluation and assessment, including tracking the number and type of spills or illicit discharges identified; inspections made; and any feedback received from public education efforts. A summary of this information shall be included in the annual report [S5 C3e]. 7

9 Ensure that all municipal field staff who are responsible for identification, investigation, termination, cleanup, and reporting illicit discharges, including spills, improper disposal and illicit connections are trained to conduct these activities [S5 C3fi Deadline August 15, 2009]. Implement an ongoing training program for all municipal field staff, which, as part of their normal job responsibilities, might come into contact with or otherwise observe an illicit discharge or illicit connection to the storm sewer system [S5 C3fii Deadline February 15, 2010]. Document and maintain records of the training provided and the staff trained and include a summary in the annual report [S5 C3fi]. Notify Ecology, document activity and summarize for the annual report discharges from the separate storm sewer system which cause or contribute to violations of the Water Quality Standards [S4 F, G3, G20]. Properly document Upsets [G21]. Track the cost or estimated cost of implementation of each component of the SWMP. This information shall be provided to Ecology upon request. [S5 A3a Deadline January 1, 2009] Current Activities (S5 C3) The City currently implements many activities and programs that contribute to meeting the Permit requirements. Many current activities are directly associated with the above Permit requirements: The City s Water Resources Protection Ordinance (VMC 14.26), which became law in 2003 and updated in 2009, mandates practices that help prevent illicit discharges to the storm system. The City currently works with local, state and federal agencies and departments to locate, assess, characterize, trace and remove sources of illicit discharges. The City maintains a storm sewer system map that is updated and corrected as needed. The City also maintains a related GIS Site Atlas for graphically representing Water Protection Program information. The City has established a hotline that allows citizens to report illicit discharges or dumping. Calls to the hotline are directed to the appropriate response authority. The Water Protection Program actively inspects and monitors industrial facilities, commercial operations and residences for water quality compliance and best management practices. The program is designed to provide technical assistance and, when necessary, initiate enforcement procedures to bring a site into compliance. Field assessments and outfall inspections are ongoing throughout the year with targeted screening during the dry weather months to locate and accurately map storm system features and look for indicators of illicit discharges. The Water Protection Program develops and distributes information and technical guidelines on proper handling and disposal of potentially harmful materials. 8

10 All inspections, investigations, illicit discharges and spill-related activities are currently tracked by Water Protection in detail in the program s database. Planned Activities (S5 C3) Continue to coordinate City departments and partners to enhance efficiency, effectiveness and achieve Permit compliance. Provide copies of interlocal agreements for the Annual Report as needed. Continue outfall screening, mapping and prioritize waterbodies according to Permit requirements and initiate program to begin identifying geographic areas that do not discharge stormwater to surface water. Continue to implement and refine standard operating procedures. Continue to research, review and develop business technical assistance tools to minimize accidental pollutant releases to water of the state. Continue Illicit Discharge Detection and Elimination training. Continue to refine methods for tracking the following: calls to the Hotline and responses, notifications to Ecology types of spills, illicit discharges identified, inspections made for illicit connections. 9

11 S5 C4 Controlling Runoff from Development, Redevelopment and Construction Sites Permit Requirements (S5 C4) The City shall implement and enforce a program to reduce pollutants in stormwater runoff to the City s stormwater system from new development, redevelopment and construction site activities. This program shall be applied to all sites that disturb a land area 1 acre or greater, including projects less than one acre that are part of a larger common plan of the development or sale. The program shall apply to private and public development, including roads. The Technical Thresholds in Appendix 1 shall be applied to all sites 1 acre or greater, including projects less than one acre that are part of a larger common plan of the development or sale. [S5 C4 Ecology Revised Deadline February 16, 2010] The program shall include an ordinance or other enforceable mechanism that addresses runoff from new development, redevelopment, and construction site projects including: the Minimum Requirements, technical thresholds, and definitions in Appendix 1. The Minimum Requirements in Appendix 1 include: Preparation of Stormwater Site Plans [4.1], Construction Stormwater Pollution Prevention Plans [4.2], Source Control of Pollution [4.3], Preservation of Natural Drainage Systems and Outfalls [4.4], On-site Stormwater Management [4.5], Runoff Treatment [4.6], Flow Control [4.7], Wetlands Protection [4.8], and Operations and Maintenance [4.9], a site planning process and BMP selection and design criteria that will protect water quality, reduce the discharge of pollutants to the maximum extent practicable and satisfy the State requirement under Chapter RCW to apply all known, available and reasonable methods of prevention, control and treatment (AKART) prior to discharge, provide the legal authority, through the approval process for new development, to inspect private stormwater facilities that discharge to the City s stormwater system, provisions to allow non-structural preventive actions and source reduction approaches such as Low Impact Development Techniques (LID), measures to minimize the creation of impervious surfaces and measures to minimize the disturbance of native soils and vegetation, and if the City chooses to allow construction sites to apply the Erosivity Waiver in Appendix 1, Minimum Requirement #2, the ordinance or regulatory mechanism shall include appropriate, escalating enforcement sanctions for construction sites that provide notice to the City of their intention to apply the waiver but do not meet the requirements (including timeframe restrictions, limits on activities that result in non-stormwater discharges, and implementation of appropriate BMPs to prevent violations of water quality standards) to qualify for the waiver. [S5 C4a - Ecology Revised Deadline February 16, 2010] The program shall include a permitting process with plan review, inspection and enforcement capability for both private and public projects, using qualified personnel including: review of all stormwater site plans, inspection, prior to clearing and construction, of all known development sites that have a high potential for sediment transport as determined through plan review based on definitions and requirements in Appendix 7, inspection of all known permitted development sites during construction to verify proper installation and maintenance of required erosion and sediment controls, 10

12 inspection of all permitted development sites upon completion of construction and prior to final approval or occupancy to ensure proper installation of permanent stormwater controls such as stormwater facilities and structural BMPs as well as verifying that a maintenance plan is completed and responsibility for maintenance is assigned. compliance during this permit term shall be determined by achieving at least 80% of scheduled inspections. an enforcement strategy shall be implemented to respond to issues of non-compliance. The City must require a Construction Stormwater Pollution Prevention Plan (SWPPP) as part of the stormwater site plan [Appendix 1, Section 4.2]. [S5 C4b - Ecology Revised Deadline February 16, 2010] The program shall include provisions to verify adequate long-term operation and maintenance of postconstruction stormwater facilities and BMPs that are permitted and constructed including: adoption of an ordinance or other enforceable mechanism that clearly identifies the party responsible for maintenance, requires inspection of facilities and establishes enforcement procedures, the City shall establish maintenance standards that are as protective or more protective of facility function than those specified in Chapter 4 of Volume V of the 2005 Stormwater Management Manual for Western Washington, annual inspections of all stormwater treatment and flow control facilities (other than catch basins) permitted by the City unless there are maintenance records to justify a different frequency, inspections of all new flow control and water quality treatment facilities, including catch basins, for new residential developments that are a part of a larger common plan of development or sale, every 6 months during the period of heaviest house construction (i.e., 1 to 2 years following subdivision approval) to identify maintenance needs and enforce compliance with maintenance standards as needed. [S5 C4c - Ecology Revised Deadline February 16, 2010] The program shall make available copies of the "Notice of Intent for Construction Activity" and copies of the "Notice of Intent for Industrial Activity" to representatives of proposed new development and redevelopment. The City will continue to enforce local ordinances controlling runoff from sites that are also covered by stormwater permits issued by Ecology [S5 C4e]. Verify that all staff responsible for implementing the program to control stormwater runoff from new development, redevelopment, and construction sites, including permitting, plan review, construction site inspections, and enforcement, are trained to conduct these activities. Follow-up training shall be provided as needed to address changes in procedures, techniques or staffing [S5 C4f - Ecology Revised Deadline February 16, 2010]. The program shall include a procedure for keeping records of inspections and enforcement actions by staff, including inspection reports, warning letters, notices of violations, and other enforcement records. Records of maintenance inspections and maintenance activities shall be maintained. The City shall document and maintain records of the training provided and the staff trained [S5 C4d/f, Annual Report]. Track the cost or estimated cost of implementation of each component of the SWMP. This information shall be provided to Ecology upon request [S5 A3a Deadline January 1, 2009]. 11

13 Current Activities (S5 C4) The City of Vancouver currently implements many activities and programs that contribute to meeting the Permit requirements. The current activities associated with the above Permit requirements include: Several City departments are currently involved with engineering design standards, the development review process, erosion prevention and building inspection programs, and the operations and maintenance of post-construction facilities and BMPs. City revised Stormwater Control ordinance and the Erosion Prevention and Sediment Control ordinance. These ordinance revisions took effect August 15, 2009 in anticipation of the original Permit deadline. The ordinances are part of the city s comprehensive program to reduce pollutants in stormwater runoff to the City s stormwater system from new development, redevelopment and construction site activities. A citywide process is established for controlling runoff from new development, redevelopment and construction sites. Development Review Services coordinates the overall site planning process while Surface Water Management provides all the technical review, support and responsibility related to stormwater runoff. Planned Activities (S5 C4) Continue to coordinate City departments and partners to enhance efficiency, effectiveness and achieve Permit compliance. Provide copies of interlocal agreements for the Annual Report as needed. Continue to refine the existing development review process and engineering details and modifying as necessary to ensure permit compliance. Continue to make available the "Notice of Intent for Construction Activity" and "Notice of Intent for Industrial Activity" to representatives of proposed new development and redevelopment. Continue to train staff as needed. Continue to refine methods for tracking the following: exceptions or variances to the minimum requirements granted, site plans approved, sites inspected for sediment transport prior to clearing and construction, sites inspected for erosion control compliance during construction, erosion control enforcement actions taken, sites with facilities and structural BMPs inspected for proper installation, installation inspection enforcement actions taken, sites inspected for post-construction operations and maintenance, post-construction structural BMPs inspected & enforcement actions taken, facilities inspected during the period of heaviest house construction, trainings provided, and staff trained. 12

14 S5 C5 Pollution Prevention and Operations and Maintenance for Municipal Operations Permit Requirements (S5 C5) The City shall at all times properly operate and maintain all facilities and systems of collection, treatment, and control (and related appurtenances) which are installed or used by the City for pollution control to achieve compliance with the terms and conditions of this Permit [G2]. The intentional bypass of stormwater from all or any portion of a stormwater treatment BMP whenever the design capacity of the treatment BMP is not exceeded is prohibited unless the conditions in G4 are met. [G4] With the exception of decant from street waste vehicles, the City shall not allow collected screenings, grit, solids, sludges, filter backwash, or other pollutants removed in the course of treatment or control of stormwater to be resuspended or reintroduced to the storm sewer system or to waters of the state. Decant from street waste vehicles resulting from cleaning stormwater facilities may be reintroduced only when other practical means are not available and only in accordance with the Street Waste Disposal Guidelines in Appendix 6 [G10]. The City shall implement an operations and maintenance (O&M) program that includes a training component and has the ultimate goal of preventing or reducing pollutant runoff from municipal operations and shall establish maintenance standards that are as protective, or more protective, of facility function than those specified in Chapter 4 of Volume V of the 2005 Stormwater Management Manual for Western Washington [S5 C5 Deadline February 15, 2010]. Compliance with the inspection requirements of S5 C5a,b&d shall be a program designed to inspect all sites and by achieving an annual rate of at least 95% of inspections. [S5 C5e Revised Ecology Deadline 180 days prior to permit expiration] Establish and implement practices to reduce stormwater impacts associated with runoff from streets, parking lots, roads or highways owned or maintained by the City, and road maintenance activities conducted by the City [S5 C5f]. The following activities shall be addressed: Pipe cleaning Cleaning of culverts that convey stormwater in ditch systems Ditch maintenance Street cleaning Road repair and resurfacing, including pavement grinding Snow and ice control Utility installation Pavement striping maintenance Maintaining roadside areas, including vegetation management Dust control Establish and implement policies and procedures to reduce pollutants in discharges from all lands owned or maintained by the City and subject to this Permit, including but not limited to: parks, open space, road right-of-way, maintenance yards, and stormwater treatment and flow control facilities [S5 C5g]. These policies and procedures shall address, but are not limited to: Application of fertilizer, pesticides, and herbicides including the development of nutrient management and integrated pest management plans. 13

15 Sediment and erosion control. Landscape maintenance and vegetation disposal. Trash management. Building exterior cleaning and maintenance. Implement a Stormwater Pollution Prevention Plan (SWPPP) for all heavy equipment maintenance or storage yards, and material storage facilities owned or operated by the City in areas subject to this Permit that are not required to have coverage under the Industrial Stormwater General Permit. Implementation of non-structural BMPs shall begin immediately after the pollution prevention plan is developed. A schedule for the implementation of structural BMPs shall be included in the SWPPP. The SWPPP shall include periodic visual observations of discharges from the facility to evaluate the effectiveness of the BMPs [S5 C5i]. Implement a stormwater inspection program that includes: inspection of all municipally owned or operated permanent stormwater treatment and flow control facilities, other than catch basins, and taking appropriate maintenance actions in accordance with the adopted maintenance standards on either an annual basis or less frequently as inspection records or equivalent information indicate would be sufficient [S5 C5b], spot checks of potentially damaged permanent treatment and flow control facilities (other than catch basins) after major (greater than 24-hour-10-year recurrence interval rainfall) storm events with repairs conducted in accordance with maintenance standards [S5 C5c], inspection of all catch basins and inlets owned or operated by the City on a circuit basis at least once before the end of the Permit term with cleaning conducted in accordance with maintenance standards [S5 C5d Deadline February 15, 2012]. Implement an on-going training program for employees of the City whose construction, operations or maintenance job functions may impact stormwater quality. The training program shall address the importance of protecting water quality, the requirements of this Permit, operation and maintenance standards, inspection procedures, selecting appropriate BMPs, ways to perform their job activities to prevent or minimize impacts to water quality, and procedures for reporting water quality concerns, including potential illicit discharges. Follow-up training shall be provided as needed to address changes in procedures, techniques or requirements [S5 C5h]. The City shall document and maintain records of training provided [S5 C5h]. Records of inspections and maintenance or repair activities conducted by the City shall be maintained in accordance with S9 Reporting Requirements [S5 C5j]. Track the cost or estimated cost of development and implementation of each component of the SWMP. This information shall be provided to Ecology upon request [S5 A3a Deadline January 1, 2009]. Current Activities (S5 C5) The City of Vancouver has many activities and programs that contribute to meeting the Permit requirements, with many departments involved in water quality protection. City of Vancouver Operations formed a Pollution Prevention Program Team comprised of representatives from Water Production & Distribution, Stormwater, Wastewater, Grounds & Parks, Greenway/Sensitive Lands, Facilities, Streets, Traffic, Equipment Services and Surface Water Engineering to implement a Pollution Prevention Plan for all city-owned and/or operated properties as required by the permit. 14

16 Operations Stormwater maintenance has an ongoing program to clean catch basins, other stormwater facilities and sweep City streets. The City has developed an Integrated Pest Management plan and employs licensed applicators. The Pollution Prevention Program Team implemented all needed components of a pollution prevention program by the permit deadline of February 15, The program includes regular Team meetings, monthly site and equipment inspections, training for all field staff and completing revisions to the Pollution Prevention Program manual. The Pollution Prevention Program addresses many regulatory elements as well as the SWPPP required for Operations equipment maintenance and materials storage facilities that are not required to have coverage under the Industrial Stormwater General Permit. Operations & Maintenance has ongoing training programs. In 2012 pollution prevention training (including stormwater, illicit discharges and spill control) continued for municipal field staff. Planned Activities (S5 C5) Continue to coordinate City departments and partners to enhance efficiency, effectiveness and achieve Permit compliance. Provide copies of interlocal agreements for the Annual Report as needed. Continue to review and revise standard operating procedures and the City s Operations and Maintenance Pollution Prevention Program and Manual as needed. Continue to review and revise inspection program for public stormwater facilities. Continue to refine methods as needed for tracking the following: known facilities, known facilities inspected, known catch basins, catch basins inspected, catch basins cleaned, trainings provided, staff trained. 15

17 S8 Monitoring Permit Requirements (S8) Prepare to participate in the implementation of a comprehensive long-term monitoring program. The monitoring program will include two components: stormwater monitoring and targeted Stormwater Management Program (SWMP) effectiveness monitoring. Stormwater monitoring is intended to characterize stormwater runoff quantity and quality at a limited number of locations in a manner that allows analysis of loadings and changes in conditions over time and generalization across the permittees jurisdictions. Stormwater program effectiveness monitoring is intended to improve stormwater management efforts by evaluating issues that significantly affect the success of, or confidence in, stormwater controls. The monitoring program can include long-term monitoring and short-term studies. The results of the monitoring program will be used to support the adaptive management process and lead to refinements of the SWMP [S8 C1]. Identify three outfalls or conveyances where stormwater sampling could be conducted. One outfall or conveyance shall represent commercial land use, the second shall represent high-density residential land use and the third will represent industrial land use [S8 C1aii Deadline December 31, 2010]. Identify at least two suitable questions and select sites where monitoring will be conducted and develop a monitoring plan for the sites [S8 C1bii Deadline December 31, 2010]. The City is not required to conduct water sampling or other testing during the effective term of this Permit, with the following exceptions: 1. Any water quality monitoring required for compliance with TMDLs, pursuant to section S7 Compliance with Total Maximum Daily Load Requirements and Appendix 2 of this Permit, and 2. Any sampling or testing required for characterizing illicit discharges pursuant to section S5.C.3. of this Permit [S8 A, G9]. Track the number and types of activities as stipulated by the respective program component. This information shall be included in the annual report [S5 A3b]. For each annual report: Provide a description of any stormwater monitoring or studies and include the type of information collected and analyzed during the reporting period [S8 B1, Annual Report], Provide an assessment of the appropriateness of the BMPs identified by the City for each component of the SWMP, and any changes made, or anticipated to be made, to the BMPs that were previously selected to implement the SWMP, and why [S8 B2]. Describe in the fourth annual report the status of identification of sites for stormwater monitoring, if required. Include a summary of proposed questions for the SWMP effectiveness monitoring and describe the status of developing the monitoring plan, including the proposed purpose, design, and methods [S8 C2]. Track the cost or estimated cost of development and implementation of this component of the SWMP. This information shall be provided to Ecology upon request [S5 A3a Deadline January 1, 2009]. 16

18 Current Activities (S8) Water quality monitoring on Burnt Bridge Creek resumed in 2011 to maintain consistency with past monitoring efforts, identify stream reaches that show improvement, and to provide feedback for adaptive strategies in stormwater management. In addition, ambient stream monitoring for up to six storm events is being conducted during the wet season. Field assessments and outfall inspections are ongoing throughout the year to locate and accurately map storm system features and look for indicators of illicit discharges. The City continues to partner with other southwest Washington MS4 agencies to develop a strategy for regional monitoring. Planned Activities (S8) Continue to coordinate City departments and partners to enhance efficiency, effectiveness and achieve Permit compliance. Provide copies of interlocal agreements for the Annual Report as needed. Water quality data will be collected at six sampling events along the main stem and three tributaries of Burnt Bridge Creek in June through October. The City will continue to provide technical support in the development of a TMDL water quality improvement plan for the stream. Continue outfall screening and mapping. Participate in regional and state monitoring forums and future legislative actions in order to influence development of feasible and effective alternative future monitoring requirements. 17

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