CITY OF MERCER ISLAND 2013 STORMWATER MANAGEMENT PROGRAM (SWMP) PLAN

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1 CITY OF MERCER ISLAND 2013 STORMWATER MANAGEMENT PROGRAM (SWMP) PLAN March 31, 2013

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3 CITY OF MERCER ISLAND 2013 S T O R M W A T E R M A N A G E M E N T P R O G R A M ( S W M P ) P L A N March 31, 2013 Contributors: Bill Sansbury Glenn Boettcher Patrick Yamashita

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5 City of Mercer Island, Washington 2013 Stormwater Management Program (SWMP) Plan Table of Contents Introduction and Background...1 Component 1: Public Education and Outreach and Phase II Permit Requirements...2 Current Activities...2 Planned Activities...4 Component 2: Public Involvement and Participation and Phase II Permit Requirements...5 Current Activities...6 Planned Activities...6 Component 3: Illicit Discharge Detection and Elimination and Phase II Permit Requirements...7 Current Activities...7 Planned Activities...8 Component 4: Controlling Runoff from New Development, Redevelopment, and Construction Sites and Phase II Permit Requirements...9 Current Activities...10 Planned Activities...11 Component 5: Pollution Prevention and Operation and Maintenance for Municipal Operations and Phase II Permit Requirements...13 Current Activities...14 Planned Activities...16 Monitoring and Phase II Permit Requirements...18 Current Activities...18 Planned Activities...19 Reporting and Phase II Permit Requirements...20 Current Activities...20 Planned Activities...20

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7 2013 SWMP Plan Introduction and Background In 1987, Congress amended the federal Clean Water Act to address municipal stormwater discharges through the National Pollution Discharge Elimination System (NPDES) permits. These are federally mandated permits developed by the Environmental Protection Agency (EPA). In Washington State, EPA delegated the power and duty to write, issue, and enforce NPDES permits to the Washington State Department of Ecology (Ecology). In 2007, NPDES Municipal Stormwater permits were issued in two phases, and were subsequently updated in Phase I permits were issued to large municipalities and county governments with populations over 100,000 (as of the 1990 census). Phase II Permits were issued to smaller governmental entities with populations under 100,000. The City of Mercer Island (City) is covered under Western Washington s Phase II Municipal Separate Stormwater Sewer System (MS4) NPDES permit (Phase II Permit). The Phase II Permit allows for stormwater system discharges into Lake Washington, as long as the City implements permit-required programs to protect the lake s water quality. These programs are intended to reduce the discharge of pollutants to the maximum extent practicable. The Phase II Permit requires the City to develop a Stormwater Management Program (SWMP). The SWMP must include the following components: 1. A public education and outreach program 2. A process for involving the public in the development of a stormwater management program 3. An illicit discharge detection and elimination (IDDE) program to identify and remove discharges into the MS4 system 4. Adoption of ordinances to control runoff from new development, redevelopment, and construction activities 5. An operation and maintenance program to reduce pollutants from municipal operations In addition, the Phase II Permit requires that the City prepare written documentation of the SWMP and update that documentation annually. This SWMP plan satisfies this requirement; it is the fifth update to the SWMP plan that was originally prepared in March In addition to the five components listed above, this SWMP plan also includes a discussion of the monitoring and reporting requirements of the Phase II Permit. The Phase II Permit that became effective on February 16, 2007 expired on February 15, 2012 ( Phase II Permit), but was reissued unmodified and remained effective through July 31, A 1-year permit was issued to cover the period from August 1, 2012, through July 31, 2013 ( Phase II Permit). This 1-year permit was essentially unchanged from the Phase II Permit. A new 5-year Phase II Permit is expected to become effective beginning August 1, 2013, and extending through SWMP Plan Update 3/31/13 1

8 2013 SWMP Plan July 31, The new 5-year Phase II Permit is referred to in this document as the Phase II Permit. Component 1: Public Education and Outreach The City of Mercer Island has a long history of providing education to its citizens on protecting Lake Washington from stormwater discharges and non-point pollution from public and private property. Numerous education and outreach activities exist to keep citizens informed on storm and surface water management. While there are many actions the City can take to protect water quality, the day-to-day behaviors of residents can have an even greater impact on water quality. This section describes the Phase II Permit requirements related to Public Education and Outreach, including the City s current and planned compliance activities and Phase II Permit Requirements Section S5.C.1 of the and Phase II Permit requires the City to develop and implement a public education and outreach program by February 16, 2009, specifically targeted to City residents, the general public, businesses, elected officials, policy makers, planning staff, and other City employees. Education and outreach efforts shall be prioritized in the following areas: 1. Impacts of stormwater on surface waters and the impacts from impervious surfaces 2. Source control best management practices (BMPs) related to pet wastes, vehicle maintenance, landscaping, and sensitive area buffers 3. BMPs for use and storage of automotive and household chemicals, handling and disposal of hazardous wastes, and for car washing 4. The impacts of illicit discharges and how to report them 5. Yard care techniques to protect water quality and proper storage of pesticides and fertilizers 6. BMPs and good housekeeping measures for carpet cleaning, auto repairs, and other maintenance activities 7. Low impact development (LID) techniques including site design, pervious paving, and retention of trees 8. Stormwater treatment and flow control facility maintenance Current Activities The City s Development Services Group (DSG) provides information on the City s website regarding LID techniques. Information has also been posted to the City s website detailing ways to limit pesticide and fertilizer use; properly store pesticides and fertilizers; properly dispose of hazardous waste; handle household chemicals; wash cars with less environmental impact; and retain pervious surface, trees, and native vegetation SWMP Plan Update 3/31/13 2

9 2013 SWMP Plan In 2010, the City developed a set of four brochures focusing on LID for single family residential development. The LID brochures provide information on rain gardens, permeable pavement, natural yard care, and cisterns for harvesting rainwater for irrigation. The LID brochures are available in the City Hall main lobby and can also be downloaded from the City s website: In 2011, the City s website was revamped. The updated color scheme and layout of the revised website should assist users with locating stormwater and LID information online. In addition to the LID website and the brochures, the City also provides hard copies of the Rain Garden Handbook for Western Washington Homeowners (developed by the Washington State University Pierce County Extension) in the City Hall main lobby and at the annual Leap for Green Earth Day celebration (held in April). Further LID education was brought to City residents during a Rain Garden Workshop hosted by the City, IslandVision, Stewardship Partners, and the Friends of the Cedar River Watershed at the Community Center on April 1, The City s cable channel MITV Channel 21 is also used to inform City residents of upcoming educational events as well as to present short informational segments on stormwater, aquatic habitat, and water quality. Another educational opportunity is the Leap for Green Earth Day celebration mentioned previously. Last year s event was held on April 21, The DSG also provides to the public an educational flyer entitled Storm Drainage and You All Part of the System. The flyer explains the elements of a typical storm drain system, recommended maintenance activities and frequencies, and the adverse impacts of a poorly maintained storm drain system. In 2009, the City stormwater team participated in the Mercer Island School District annual car wash by providing pumps to divert wash water to the sanitary sewer, hands on instruction with high school students, and literature on how to protect the lake from residential car washing. In 2010, the Mercer Island School District switched to a new fundraising strategy where they rented a commercial car wash for a day and sold car wash coupons, ensuring that the washwater was properly routed to the sanitary sewer system. This fundraising strategy was continued in 2011 and No slope protection and erosion prevention seminars were held in 2012 but future seminars will be provided when other large watercourse restoration projects are constructed. In 2012, storm drain markers were installed in the Town Center. In upcoming years, local Boy Scout troops will be volunteering to install storm drain markers. City staff continue to participate in regional educational forums such as the Stormwater Outreach for Regional Municipalities (STORM) group. This coalition of cities and counties works to develop effective messages to influence behaviors related to water pollution control, and assists the participating jurisdictions in complying with their Phase I and Phase II Permits. Mercer Island also assisted with a regional public education media campaign funded by a FY Ecology Stormwater Grant of Regional or Statewide Significance (GROSS). The specific stormwater outreach group (SOG) that Mercer Island worked with was the North End of King County and East Side of Lake SWMP Plan Update 3/31/13 3

10 2013 SWMP Plan Washington SOG, which included the following 15 jurisdictions: Bellevue, Bothell, Clyde Hill, Issaquah, Kenmore, Kirkland, Lake Forest Park, Medina, Mercer Island, Newcastle, Redmond, Sammamish, Seattle, Shoreline, and Woodinville. In addition to participation with the STORM group, the City also participated in a regional stormwater survey in March 2011 that evaluated changes in the level of understanding from the initial survey that was completed in Planned Activities Table 1 summarizes the City s planned activities associated with Public Education and Outreach. Table 1. Planned public education and outreach activities. Website updates Activity Tasks Lead Schedule or Frequency The City s website will be updated with public outreach material related to stormwater education on an ongoing basis R.O.W. Team Lead Leap for the Green Provide LID brochures and other stormwater information Communication Coordinator April 13, 2013 Information booths at Farmers Market and Summer Celebration Provide LID brochures and other stormwater information Communication Coordinator, starting in 2013 Participation in STORM and Puget Sound Starts Here Regular attendance R.O.W. Team Lead Education of City staff Develop staff training events R.O.W. Team Lead Storm Drainage and You All Part of the System flyer Provide flyer to the public DSG Low Impact Development brochures Provide brochures describing rain gardens, permeable pavement, cisterns for rainwater harvest for irrigation, and natural yard care to the public City Engineer Rain Garden Handbook for Western Washington Homeowners Provide handbook to the public City Engineer Pet waste bag dispensers Install pet waste bag dispensers at City parks Communication Coordinator, starting in 2013 Restaurant posters and spill kits Modify commercial restaurant posters and coordinate with restaurants to provide access to spill kits Communication Coordinator, starting in SWMP Plan Update 3/31/13 4

11 Table 1 (continued). Planned public education and outreach activities. Activity Tasks Lead Schedule or Frequency Stormwater posters Print and display posters at the Mercer View Community Center (MVCC) and City Hall lobby Communication Coordinator, starting in 2013 Tracking and documentation Set up public education and outreach tracking system Communication Coordinator Stewardship opportunities Boy Scout projects: Install drain markers at parks and street ends Communication Coordinator Catch basin inspections Citizen survey questions outside of grocery stores (e.g., Do you know what IDDE is?) Evaluating public education Measure the understanding and adoption of the targeted behaviors for at least one target audience in at least one subject area Communication Coordinator Before February 2, 2016 Component 2: Public Involvement and Participation Public input is important to the development and implementation of the SWMP. The City actively solicits public participation by making stormwater information available for review and providing opportunities for comment. This section describes the Phase II Permit requirements related to public involvement, including current and planned compliance activities and Phase II Permit Requirements Section S5.C.2 of the and Phase II Permit requires that by February 16, 2008, the City shall develop a plan for public involvement and participation that creates opportunities for the public to participate in developing the SWMP, and comply with applicable state and local public notice requirements. The two main components of this plan include: 1. Developing and implementing a process for consideration of public comments on the City s SWMP 2. Posting the Annual Report, SWMP Plan, IDDE Program Plan, and Stormwater Pollution Prevention Plans (SWPPPs) on the City s website SWMP Plan Update 3/31/13 5

12 Current Activities 2013 SWMP Plan The City will continue to encourage comments on the SWMP through a variety of communication methods, including the Mercer Island Weekly newsletter (~600 subscribers) and the City s website. The Annual Report, SWMP plan, IDDE Program Plan, and SWPPPs will continue to be posted on the website. The public will be able to provide feedback via , telephone, and letters. City staff have ongoing discussions with the Mercer Island Utility Board and City Council regarding stormwater and the Phase II Permit. Stormwater utility rate increases were discussed at the September 13, 2011, Utility Board meeting and subsequently adopted by the City Council. Planned Activities Table 2 summarizes the City s planned activities associated with public involvement and participation. Table 2. Planned public involvement and participation opportunities. Activity Tasks Lead Schedule or Frequency Public Involvement in the SWMP Solicit feedback on website and in M.I. Weekly Communication Coordinator Revise SWMP Plan Update SWMP Plan with planned activities for 2014 R.O.W. Team Lead Update SWMP Plan in spring 2014; post on City s website by May 31, 2014 Prepare and Submit Annual Report Prepare and submit Annual Report; submittal should include SWMP Plan and other supplemental documentation (if applicable) R.O.W. Team Lead No Annual Report submittal required in 2014; the next Annual Report submittal to Ecology is required by March 31, 2015 Component 3: Illicit Discharge Detection and Elimination An illicit discharge is defined as any discharge into the stormwater system that is not composed entirely of stormwater. Discharges may be from a variety of sources and activities including: 1. Illegal discharges, dumping, and improper disposal of discharges from: a. Potable water sources b. Lawn watering and other irrigation c. Swimming pools or other highly chlorinated water 2. Any incidental spills that have the potential to affect water quality such as oil, gas, diesel fuel, paints, or solvents 3. Dumping of material into a storm system SWMP Plan Update 3/31/13 6

13 2013 SWMP Plan This section describes the Illicit Discharge Detection and Elimination (IDDE) Phase II Permit requirements, as well as the City s current and planned compliance activities and Phase II Permit Requirements Section S5.C.3 of the and Phase II Permit requires the City to develop and fully implement an ongoing IDDE Program to detect and address nonstormwater discharges, spills, illicit connections, and illegal dumping into the stormwater system by August 16, The specific Phase II Permit requirements are as follows: 1. By February 16, 2007, initiate a program to develop and maintain a map of all connections to the stormwater system 2. By February 16, 2011, develop a stormwater system map that shows all known separate storm sewer outfalls, receiving waters, BMPs maintained by the City, tributary conveyances, associated drainage areas, and land use 3. By February 16, 2009, publicize a public hotline number for reporting of spills and other illicit discharges; and track all calls and follow-up actions taken 4. By August 16, 2009, implement an ordinance that effectively prohibits nonstormwater, illegal discharges, or dumping into the City s stormwater system to the maximum extent allowable by state and federal law 5. By August 16, 2009, ensure that all staff responsible for identification, investigation, termination, cleanup, and reporting illicit discharges are trained to conduct these activities 6. By August 16, 2010, develop and implement an ongoing training program for all municipal staff involved with IDDE 7. By August 16, 2011, distribute information to public employees, business, and the general public of the hazards associated with illegal discharges and improper disposal of wastes. Current Activities The City has completed the required stormwater system map and will continue making updates on an ongoing basis. The following public illicit discharge and spill hotline numbers are listed on the City s website ( and in the IDDE Program Plan: (206) (regular business hours, 8am 5pm) (425) (after hours) The City s IDDE Program Plan was finalized in June 2009; implementation of the IDDE Program began in late 2009 and continued through Modifications to the Mercer Island Municipal Code related to the IDDE ordinance became effective on December 18, 2009 (Section Discharges to Storm and Surface Water System and Ground Waters) SWMP Plan Update 3/31/13 7

14 2013 SWMP Plan Dry weather outfall inspections for Subbasins 6, 26, and 42 were performed on October 4, The outfall from Subbasin 6 was not flowing, but a sample was collected from an adjacent creek for analysis. The outfall from Subbasin 26 was on private property and could not be accessed, so a sample was collected upstream of the outfall. The outfall from Subbasin 42 was partially submerged, so a sample was collected upstream of the outfall at an inlet to a settling basin. No indicators of illicit discharges were observed based on visual observations and water quality sampling in any of the three subbasins inspected. Follow-up work and documentation resulting from the identification of an illicit discharge in October 2010 (leaking heating oil tank) was summarized in a memorandum to Ecology submitted with the final Pass-Through Grant report on July 15, Based on the limited soil and groundwater investigation conducted in May 2011, the decommissioning of the underground storage tank (UST) in November 2010 appears to have removed the primary source of contamination at this site. A follow-up inspection was performed on January 4, 2012 and no petroleum sheen or odors were observed in surface stormwater runoff at the stormwater catch basins near the site. An IDDE educational article (Clean Stormwater Runoff Protects Island Lakes and Streams) was prepared for City residents and published in the Mercer Island Weekly in August The article can also be downloaded from the Mercer Island Weekly newsletter archive: The article includes the definition of an illicit discharge, examples of illicit discharges, how to prevent illicit discharges for common residential activities, the illicit discharge hotline number, and links to additional information. An IDDE educational letter was also prepared for City businesses in August The letter was mailed to businesses in the City. The letter covered the same basic topics as the IDDE educational article for residents, but focused on how to prevent illicit discharges for the following types of businesses: Auto Industry, Carpet Cleaners and Dry Cleaners, and Restaurants and Retail Stores. Refresher training for 30 City staff on IDDE general awareness and spill response was held on June 28, Refresher training on field equipment and test kits for IDDE was also held on June 28, 2012, for a smaller group of staff who are responsible for IDDE response. Planned Activities Table 3 summarizes the planned activities associated with the City s IDDE program. Table 3. Planned illicit discharge detection and elimination activities. Activity Tasks Lead Schedule or Frequency IDDE Program Plan Implementation Update Standard Operating Procedures (SOPs) Implement IDDE Program plan requirements Update SOP for spill response and documentation R.O.W. Team Lead R.O.W. Team Lead Before June 30, SWMP Plan Update 3/31/13 8

15 Table 3 (continued). Planned illicit discharge detection and elimination activities. Activity Tasks Lead Schedule or Frequency Field Assessment Work Complete Mapping Requirements Publicize Phone Number for Reporting Spills and Illicit Discharges Tracking System for Complaints, Investigations, and Spill Response Illicit Discharge Field Screening Inspection of one priority waterbody per year Work with GIS technician to ensure maps are updated regularly Publicize phone number on website and in print material Use coding in work order system to track IDDE-related work Select and implement an illicit discharge field screening methodology R.O.W. Team Lead Spring/Summer 2013 City Engineer R.O.W. Team Lead R.O.W. Team Lead R.O.W. Team Lead Perform field screening on 40% of the MS4 by December 31, 2017 IDDE Ordinance Minor edits to IDDE ordinance R.O.W. Team Lead Before February 2, 2018 Staff Training Refresher training on IDDE general awareness and IDDE response R.O.W. Team Lead Component 4: Controlling Runoff from New Development, Redevelopment, and Construction Sites The DSG is responsible for permitting, inspection, and code enforcement actions for construction-related activities in the City. This section describes the Phase II Permit requirements related to controlling runoff from new development, redevelopment, and construction sites, including current and planned activities and Phase II Permit Requirements Section S5.C.4 of the and Phase II Permit requires the City to develop and implement a program to reduce pollutants in stormwater runoff from new development, redevelopment, and construction activities. The program is to be applied to all sites that disturb a land area 1 acre or greater, including projects less than 1 acre that are part of a larger common plan of development or sale. The specific Phase II Permit requirements are as follows: 1. Adopt an ordinance or other enforceable mechanism that addresses runoff from new development, redevelopment, and construction sites by February 16, SWMP Plan Update 3/31/13 9

16 2013 SWMP Plan 2. Develop and implement a site planning process and BMP selection and design criteria that meet the Technical Thresholds in Appendix 1 of the Phase II Permit and will protect water quality, reduce the discharge of pollutants to the maximum extent practicable, and satisfy State requirements to apply all known, available, and reasonable methods of prevention, control, and treatment (AKART) prior to discharge by February 16, Develop and adopt a permitting process with plan review, with the legal authority to inspect private stormwater facilities that discharge into the City stormwater system, using qualified personnel. Develop and implement a training program for planning and review staff. These provisions shall be in place no later than February 16, Develop a process for provisions to allow non-structural preventative actions and source reduction approaches such as LID techniques. 5. No later than February 16, 2010, verify that all staff responsible for implementing the program to control stormwater runoff from new development, redevelopment, and construction sites are trained to conduct these activities. Develop and implement a plan review and inspection training program for staff. Current Activities The City has a permitting process implemented through its DSG that includes plan review, inspection, and enforcement. All sites that include clearing, grading, other landdisturbing activities, or development must go through the permitting process. This process includes final inspections prior to approval of project construction to ensure proper installation of permanent stormwater controls such as stormwater facilities and structural BMPs. The Stormwater Management Manual for the Puget Sound Basin (1992) prepared by Ecology was adopted by ordinance in 1995 as the City s minimum standards for stormwater management. These standards were amended in 2000 to lower the minimum threshold for flow control from 5,000 square feet to 500 square feet of impervious surface for development/redevelopment projects. The City updated its standards in 2009 to be equivalent to Ecology s Stormwater Management Manual for Western Washington (2005) for projects disturbing more than 1 acre. The City currently issues stormwater permits and performs inspections for construction projects both greater than and less than Ecology s 1-acre threshold. The City s previous standards still apply for sites disturbing less than 1 acre. The regulations were adopted by ordinance by the City Council and became effective on December 18, The City s updated stormwater regulations clearly identify responsibilities for maintenance, repair, operation, and inspection of private stormwater systems. These responsibilities lie with the property owner. The DSG provided new and updated handouts at the permit counter describing the updated stormwater regulations, the permitting process, flow control for projects above and below the 1-acre land disturbance threshold, a detention system sizing chart for small SWMP Plan Update 3/31/13 10

17 2013 SWMP Plan impervious surfaces (less than 5,000 square feet), information regarding LID techniques, and guidance regarding the use of permeable pavers. The City takes a continuous improvement approach to develop new and update existing documents and forms to improve the permitting processes. The City also updates their website on an ongoing basis to include information regarding stormwater regulations, requirements, processes, information, tips, and LID. In 2010, the City developed a LID Feasibility Study to evaluate the feasibility and suitability of implementing LID stormwater management practices for use in the City. The City s Senior Development Engineer will use the information contained in the feasibility study when reviewing proposed LID improvements for single family residential projects. The City has an electronic permit tracking system called Trak-IT, developed by CRW Associates. This system is used to track the status of plan reviews, inspections, correction notices, and final project approvals. The City started a paperless process for inspections in February 2010 in an effort to reduce use of paper, reduce permit counter staff time, and simplify record keeping in the field. Field staff use Trak-IT in the field on laptop computers with wireless internet connections. The City has also offered electronic plan reviews since This has been a popular, environmentally-friendly alternative. The City, through its DSG, makes copies of Ecology s Notice of Intent for Construction Activity available at the permit counter. (The Notice of Intent for Industrial Activity is not provided since the City does not have any industrial zoned properties within its jurisdictional boundaries.) Training opportunities for City staff are pursued on an ongoing basis. In 2012, the Senior Development Engineer attended two writing courses to improve communication with owners, engineers, architects, and the public with respect to plan reviews. The Site Inspector attended training in February 2012 for recertification as a Certified Erosion and Sediment Control Lead (CESCL). The City Engineer participated in a 3-day training session related to public works including stormwater management and innovative stormwater management techniques. Internal staff training is conducted on an ongoing basis to leverage knowledge from City staff who have attended pertinent training courses. Planned Activities Table 4 summarizes the City s planned activities associated with controlling runoff from new development, redevelopment, and construction sites. Table 4. Planned activities to control runoff from new development, redevelopment, and construction sites. Activity Tasks Lead Schedule or Frequency Develop/update documents and forms to improve the permitting process Update City s website to improve stormwater management and regulatory information process City Engineer process City Engineer SWMP Plan Update 3/31/13 11

18 Table 4 (continued). Planned activities to control runoff from new development, redevelopment, and construction sites. Staff Training Activity Tasks Lead Schedule or Frequency Pursue training opportunities for development review and inspection staff Conduct internal staff training by leveraging knowledge from City staff who have attended pertinent training courses City Engineer Review All Stormwater Site Plans Continue current practices City Engineer Continue current practices and update as needed Construction Site Inspections Inspections of Subdivision Stormwater Controls During Construction Period Record Keeping Notice of Intent Availability Revise Stormwater Ordinances Review and Adopt New Stormwater Manual Expand Construction Site Inspection Program to Incorporate Sites < 1-acre Review and Revise Local Development-related Codes, Rules, Standards, and Other Enforceable Documents Summarize the Results of the Code Review and Revision Process Review and refine the inspection procedures used during construction to inspect/enforce TESC measures on projects exceeding the 1-acre land disturbance threshold Review and refine the inspection program for residential subdivisions while individual lots are in construction (1) Continue using electronic permit tracking system (Trak-It) to track the status of plan reviews, inspections, correction notices, and final project approvals Continue to support Ecology by distributing copies of the Notice of Intent for Construction Activity at the City permit counter Revise ordinances to reflect the elimination of the 1-acre threshold and incorporate new LID language Review the 2012 Stormwater Management Manual for Western Washington to determine if blanket adoption will work for the City Review and refine the inspection program for residential subdivisions Review and revise codes, rules, standards, and other enforceable documents to incorporate and require LID principles and LID BMPs This summary shall include a list of participants, documents reviewed, and revisions made (1) This requirement applies to projects greater than 1 acre. City Engineer City Engineer City Engineer City Engineer Continue current practices and modify as needed Continue current practices and modify as needed City Engineer Before December 31, 2016 City Engineer Before December 31, 2016 City Engineer Before December 31, 2016 City Engineer Before December 31, 2016 City Engineer Include as an attachment to the March 31, 2017, Annual Report SWMP Plan Update 3/31/13 12

19 Component 5: Pollution Prevention and Operation and Maintenance for Municipal Operations 2013 SWMP Plan In December 1995, the City of Mercer Island Municipal Code established the City s Storm and Surface Water Utility. The code set forth the primary authority and responsibility for carrying out the Puget Sound Water Quality Management Plan including responsibilities for maintenance, operation, and improvement of the City s storm and surface water drainage system. The primary utility activities are specified in the Mercer Island Municipal Code and include: basin planning, capital improvements, and facility maintenance. This section describes the Phase II Permit requirements related to pollution prevention and operation and maintenance for municipal operations, including current and planned activities and Phase II Permit Requirements Section S5.C.5 of the and Phase II Permit requires the City to develop and implement an operation and maintenance (O&M) program with the ultimate goal of preventing or reducing pollutant runoff from the municipal separate stormwater system and municipal O&M activities by February 16, The specific Phase II Permit requirements are as follows: 1. Establish maintenance standards that are at least as protective as those specified in Chapter 4 of Volume V of Ecology s Stormwater Management Manual for Western Washington (2005) 2. Perform inspection of all municipally owned stormwater treatment and flow control and treatment facilities, other than catch basins, and take appropriate maintenance actions 3. Spot check 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; and conduct maintenance and repairs as needed 4. Inspect all catch basins and inlets at least once by February 15, 2012 and clean as according to established maintenance standards 5. Establish an inspection program to determine inspection requirements 6. Have practices in place to reduce stormwater impacts associated with runoff from municipal O&M activities, including but not limited to streets, parking lots, roads, and highways owned or maintained by the City, and to reduce pollutants in discharges from all lands owned or maintained by the City 7. Establish and implement policies and procedures to reduce pollutants in discharges from all publicly owned lands, including parks, open spaces, road right-of-ways, and maintenance yards 8. Develop and implement an ongoing training program for City staff that addresses the importance of protecting water quality, the requirements of the Phase II SWMP Plan Update 3/31/13 13

20 2013 SWMP Plan Permit, O&M standards, inspection procedures, selecting appropriate BMPs, ways to perform job activities to prevent or minimize impacts to water quality, and procedures for reporting water quality concerns. 9. Prepare SWPPPs for all heavy equipment maintenance or storage yards and material storage facilities owned or operated by the City 10. Maintain inspection and maintenance repair records and summarize annual activities for the Pollution Prevention and Operations and Maintenance for Municipal Operations component of the Annual Compliance Report; including any updates to the SWMP Plan. Current Activities The City currently has stormwater field maintenance policies and procedures (consistent with Ecology s 2005 manual) in place that address the following activities: Storm event preparation Stormwater system patrol and inspection Inspecting and cleaning detention basins/ponds Inspecting and cleaning catch basins Cleaning stormwater lines Cleaning and flushing culverts Cleaning and reshaping ditches Street sweeping Erosion control in water courses Stormwater line repair and replacement Shoulder pulling Storm event preparation, system patrol, and inspection of storm drainage Hot Spot areas are performed by maintenance department crews within 24 hours of notification of a major weather event. City-maintained treatment and flow control facilities are inspected by stormwater maintenance department staff. City-owned detention ponds are inspected bi-annually and cleaned as necessary. Work orders are automatically generated as the preventative maintenance is due. Catch basin inspection and cleaning, culvert flushing, and line cleaning is performed annually under contract services. There are approximately 7,819 catch basins in the stormwater system on Mercer Island. The City is responsible for maintaining over 4,475 basins and 3,344 catch basins are privately owned and maintained. The cleaning and inspection of all City-owned catch basins has been completed as required by the Phase II Permit. Future maintenance and inspections will continue with annual inspections of the perimeter (East and West Mercer Way), Central Business District, and East Seattle area. Additional areas will be cycled in as the budget allows. The City SWMP Plan Update 3/31/13 14

21 2013 SWMP Plan budgets $70,000 annually to accomplish this component of the O&M program. The maintenance department maintains a database of these activities. The City implemented a program to reshape and revegetate ditches to help them perform more similarly to biofiltration swales or filter strips in 2010 and A demonstration project was installed on 89th Street next to Ellis Pond with the assistance of the Crest Horticulture Program and the Ellis Pond neighborhood. Approximately 2,500 linear feet of ditches were converted to grass filter strips in 2010 as part of this program and 3,400 linear feet in Before and after photographs from the 84th Street ditch conversion completed in 2010 are shown in Figures 1 and 2. Figure 1. Photograph taken before the 84th Street retrofit. Figure 2. Photograph taken after the 84th Street retrofit SWMP Plan Update 3/31/13 15

22 2013 SWMP Plan Street sweeping is performed by City maintenance staff and is an ongoing activity to reduce stormwater impacts. All street sweepings are separated from green debris and disposed of properly. Work orders are automatically generated as the preventative maintenance is due. All excavated spoils from utility operations and street waste are decanted to a holding pond for treatment. Solids are hauled to the disposal site. The City began a new policy for snow control and removal in 2010 that was continued in 2011 and Liquid anti-/deicers are now applied before a predicted snowstorm which results in application of less treated sand during the snowstorm. Maintenance and DSG staff meet on a monthly basis to stimulate ongoing communication regarding measures to protect water quality. Three Stormwater Pollution Prevention Plans (SWPPPs) were developed for the Administration and Maintenance Site, Luther Burbank and I-90 Lid Parks, and Fire Station 91 in June Implementation of the SWPPPs began in late 2009 and continued through Wet weather SWPPP inspections were conducted on January 4, 2012, and December 14, 2012, at the Administration and Maintenance Site, Luther Burbank Park, and I-90 Lid Park. Dry weather SWPPP inspections were conducted on August 16, 2012, at the same City facilities. Refresher training for 30 City staff on the SWPPPs and source control BMPs for pollution prevention was held on June 28, 2012, along with the IDDE general awareness refresher training. In terms of ongoing record keeping, the City documents SWPPP information (i.e., significant spills and leaks, dry and wet weather inspections, site modifications), tracks O&M costs, keeps inspection and maintenance repair records, and updates this SWMP plan annually. Planned Activities Table 5 summarizes the City s planned activities associated with pollution prevention and O&M for municipal operations. Table 5. Planned pollution prevention and operation and maintenance activities. Activity Tasks Lead Schedule or Frequency Implement maintenance procedures and standards Implement Stormwater Pollution Prevention Plans (SWPPPs) Treatment and flow control facility inspections process R.O.W. Team Lead process R.O.W. Team Lead ; dry and wet weather SWPPP inspections to be conducted in 2013 inspection program for detention basins/ponds and other stormwater facilities R.O.W. Team Lead SWMP Plan Update 3/31/13 16

23 Table 5 (continued). Planned pollution prevention and operation and maintenance activities. Activity Tasks Lead Schedule or Frequency Catch Basin Inspection Program inspection program for catch basins, and spot checking of hot spots R.O.W. Team Lead Street Sweeping program R.O.W. Team Lead Ditch Conversion to Grass Filter Strips program R.O.W. Team Lead Record Keeping Communication and Coordination Stormwater BMP Manuals for Maintenance Activities Evaluate Catch Basin Inspection Options Review and Adopt New Stormwater Manual Update SWPPPs Staff Training Continue record updates Document activities associated with SWPPPs Continue tracking costs Monthly meetings with DSG staff regarding measures to protect water quality Meetings with Maintenance and Parks staff to review findings of SWPPPs and discuss practices to reduce stormwater impacts Develop Stormwater BMP Manuals for Maintenance/ Right-of-Way Staff that address typical maintenance activities Three options for catch basin and inlet inspections: Option 1: Inspect at least once by August 1, 2017, and every 2 years thereafter Option 2: Inspect and clean catch basins on a circuit basis with inspections of 25% of catch basins and inlets within each circuit to identify maintenance needs Option 3: Clean all pipes, ditches, catch basins, and inlets within a circuit once during the permit term Review the 2012 Stormwater Management Manual for Western Washington to determine if blanket adoption will work for the City Update Administration and Maintenance Site and Luther Burbank and I-90 Lid Parks SWPPPs Refresher training on SWPPPs and source control BMPs R.O.W. Team Lead R.O.W. Team Lead Monthly/ R.O.W. Team Lead Before June 30, 2013 R.O.W. Team Lead Either August 1, 2017, or July 31, 2018 (depends on option selected) City Engineer? Before December 31, 2016 R.O.W. Team Lead Before June 30, 2013 R.O.W. Team Lead SWMP Plan Update 3/31/13 17

24 Monitoring 2013 SWMP Plan This section provides a brief discussion of the Phase II Permit monitoring requirements, including current and planned activities and Phase II Permit Requirements Section S8 of the and Phase II Permit requires the City to do the following: 1. Conduct sampling or testing required for characterizing illicit discharges pursuant to Section S5.C.3 or S6.D.3 of the Phase II Permit 2. Provide a description of any stormwater monitoring or studies conducted during the reporting period 3. Provide an assessment of the appropriateness of the BMPs identified 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. 4. Develop a monitoring plan in preparation for future, long-term monitoring due with the fourth Annual Report (March 31, 2011) that includes two components: Stormwater monitoring the City shall identify two outfalls or conveyances (one representing commercial land use and one representing high-density residential land use) where stormwater sampling could be conducted by December 31, Targeted SWMP effectiveness monitoring the City shall identify at least two suitable questions and select sites where stormwater, sediment or receiving water monitoring of physical, chemical, and/or biological characteristics monitoring will be conducted by December 31, The City is not required to conduct water quality monitoring for compliance with total maximum daily loads (TMDLs) pursuant to Section S7 and Appendix 2 of the Phase II Permit, since no TMDL implementation plans have been developed for Lake Washington. Current Activities City staff conducted dry weather outfall inspections in October 2012 (as described in the Component 3: Illicit Discharge Detection and Elimination section). Water quality testing was performed just upstream or adjacent to the outfalls from Subbasins 6, 26, and 42, but did not result in any indicators of illicit discharges. The City has contracted with King County Water and Land Resources Division since 1999 to provide stormwater monitoring in six drainage basins on Mercer Island. Stormwater monitoring studies conducted during 2011 and 2012 included King County s ongoing monitoring work focused on two drainage basins in the City (Basins 10 and 32b). Monitoring in these two drainage basins will continue into The goal of SWMP Plan Update 3/31/13 18

25 2013 SWMP Plan this phase of the monitoring program is to evaluate the water quality in these basins and to begin investigating upstream sources of copper and zinc. The most recent monitoring report published by King County (Water Quality Monitoring of Five Mercer Island Drainage Basins from ) included the following monitoring results: Streambank erosion in steep ravines continued to deliver a high sediment load to Lake Washington, reflected in the high total suspended solids concentrations, turbidity levels, and conductivity levels measured during sampled storm events Measurements of dissolved copper and zinc continued to exceed acute state water quality standards in Basins 10 and 32 Exceedances of the state water quality criteria for dissolved oxygen occurred in several drainage basins (primarily during baseflow sampling) and for temperature in Basin 10 (July and August 2009 only) No exceedances of state water quality criteria were measured for ph Chlorinated herbicides were not frequently detected and only one exceedance of EPA water quality criteria for herbicides or pesticides occurred during the 11-year monitoring period (for the insecticide diazinon) Elevated fecal coliform bacteria concentrations occurred both during storm events and baseflow sampling. Elevated storm event fecal coliform bacteria concentrations measured in Basins 6, 10, 26, and 42 may require additional investigation Benthic macroinvertebrate sampling in 2008 was consistent with previous years, with communities ranked as either poor or very poor according to the Benthic Index of Biotic Integrity (B-IBI). The City provides a qualitative assessment of the appropriateness of the BMPs identified for each component of the SWMP in the Annual Report that is submitted to Ecology. The City also met the deadline for developing and submitting a monitoring plan in preparation for future, long-term monitoring with the fourth Annual Report (March 31, 2011). Planned Activities The City is currently evaluating the proposed monitoring requirements in the Phase II Permit to determine if they will be opting in to the Regional Stormwater Monitoring Program (RSMP) or opting out and conducting their own monitoring. The RSMP includes three main components: status and trends monitoring, effectiveness studies, and source identification and diagnostic monitoring information repository. The City must notify Ecology by December 1, 2013, regarding which monitoring option they have selected for each component and start contributing to the RSMP fund beginning in August 2014 if they decide to participate in the RSMP. Stormwater monitoring studies conducted during 2013 will focus on identifying the sources of dissolved copper and zinc in Basins 10 and 32b SWMP Plan Update 3/31/13 19

26 2013 SWMP Plan Reporting This section provides a brief discussion of Phase II Permit reporting requirements, including current and planned activities and Phase II Permit Requirements Section S9 of the and Phase II Permit requires the City to submit the following on March 31 of each year of the Phase II Permit term: 1. A copy of the current SWMP plan 2. Appendix 3 Annual Report Form for Cities, Towns, and Counties 3. Notification of any annexations, incorporations, or jurisdictional boundary changes resulting in an increase or decrease in the geographic area of Phase II Permit coverage during the reporting period, and implications for the SWMP. Additional requirements for the fourth Annual Report (due on March 31, 2011) include: 1. Monitoring Plan (discussed in the Monitoring section) 2. A summary of identified barriers to the use of LID within the area covered by the Phase II Permit and measures to address the barriers 3. A report describing, at a minimum: Current Activities LID practices that are currently available and that can reasonably be implemented within the Phase II Permit term Potential or planned non-structural actions and LID techniques to prevent stormwater impacts Goals and metrics to identify, promote, and measure LID use Potential or planned schedules to require and implement the non-structural and LID techniques on a broader scale in the future. Since March 2008, the City has submitted an Annual Report to document the SWMP work completed in the prior year. The form of the report is developed by Ecology. The Annual Report is required to be updated each year in March through the Phase II Permit cycle. The Annual Report is accompanied by the City s current SWMP plan, which reflects the status of the implementation of each component of the SWMP. The 2013 SWMP Plan (this document) satisfies this requirement and is the City s fifth annual update to its SWMP. The City also developed a monitoring plan in preparation for future long-term monitoring and LID report that was included with the fourth Annual Report submitted to Ecology on March 31, Planned Activities The City will be submitting an Annual Report and SWMP Plan to Ecology on March 31, The next Annual Report is not due to Ecology until March 31, 2015; however, the City will be updating their SWMP Plan and posting it on their website by May 31, SWMP Plan Update 3/31/13 20

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