CITY OF MERCER ISLAND 2017 STORMWATER MANAGEMENT PROGRAM (SWMP) PLAN May, 2017
CITY OF MERCER ISLAND 2017 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 May 2017
City of Mercer Island, Washington 2017 Stormwater Management Program (SWMP) Plan Table of Contents Introduction and Background...6 Component 1: Public Education and Outreach...7 2013-2018 Phase II Permit Requirements...7 Planned Activities...8 Component 2: Public Involvement and Participation...8 2013-2018 Phase II Permit Requirements...9 Planned Activities...9 Component 3: Illicit Discharge Detection and Elimination...9 2013-2018 Phase II Permit Requirements...10 Planned Activities...10 Component 4: Controlling Runoff from New Development, Redevelopment, and Construction Sites...11 2013-2018 Phase II Permit Requirements...11 Planned Activities...12 Component 5: Municipal Operations and Maintenance...14 2013-2018 Phase II Permit Requirements...14 Planned Activities...15 Monitoring...15 2013-2018 Phase II Permit Requirements...15 Planned Activities...16 Reporting...16 2013-2018 Phase II Permit Requirements...16 Planned Activities...17
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 2009. 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; the SWMP plan has been updated annually since it was originally prepared in March 2008. 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 (2007-2012 Phase II Permit), but was reissued unmodified and remained effective through July 31, 2013. A 1-year permit was issued to cover the period from August 1, 2012, through July 31, 2013 (2012-2013 Phase II Permit). This 1-year permit was essentially unchanged from the 2007-2012 Phase II Permit. A new 5-year Phase II Permit 2017 SWMP Plan Update May 2017 6
became effective on August 1, 2013, and will expire on July 31, 2018. The new 5-year Phase II Permit is referred to in this document as the 2013-2018 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 planned compliance activities. 2013-2018 Phase II Permit Requirements Section S5.C.1 of the 2013-2018 Phase II Permit requires the City to develop and implement a public education and outreach program specifically targeted to City residents, the general public, businesses (including home-based and mobile), engineers, contractors, developers, land use planners, landscapers, and property managers/owners,. 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. Pet waste management and disposal 3. Use and storage of automotive chemicals, hazardous cleaning supplies, carwash soaps, and other hazardous materials 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 home/building maintenance 7. Low impact development (LID) principles and BMPs 8. Stormwater treatment and flow control BMPs/facilities and maintenance 9. Opportunities to become involved in stewardship activities 10. Dumpster and trash compactor maintenance 11. Technical standards for stormwater site and erosion control plans The City shall create stewardship opportunities and/or partner with existing organizations to encourage residents to participate in activities such as storm drain marking, volunteer monitoring, riparian plantings, and education activities. 2017 SWMP Plan Update May 2017 7
The City is required to measure the understanding and adoption of the targeted behaviors for at least one target audience in at least one subject area. The City shall use the resulting measurements to direct education and outreach resources most effectively, as well as to evaluate changes in adoption of the targeted behaviors. Planned Activities Table 1 summarizes the City s planned activities associated with Public Education and Outreach. Table 1. Planned public education and outreach activities. Activity Website updates Participation in Stormwater Outreach for Regional Municipalities (STORM), Stormwater Outreach Group (SOG), and Puget Sound Starts Here Tasks The City s website will be updated with public outreach material related to stormwater education on an ongoing basis Regular participations Schedule or Frequency Education of City staff Develop staff training events Storm Drainage and You All Part of the System flyer Provide flyer to the public Pet waste bag Re-fill pet waste bags at City parks Restaurant posters and spill kits Stormwater posters Modify commercial restaurant posters and coordinate with restaurants to provide access to spill kits Print and display posters at the Mercer View Community Center (MVCC) and City Hall lobby, and at the Summer Celebration event. Tracking and documentation Set up public education and outreach tracking system Conducting outreach for a target audience Evaluating public education Reach out to residents and MISD regarding vehicle washing. Reach out the animal owners for waste management and disposal. The City will measure the understanding and adoption of the targeted behaviors Continue with new audience in 2017 Continue into 2017 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. 2017 SWMP Plan Update May 2017 8
This section describes the Phase II Permit requirements related to public involvement, including planned compliance activities. 2013-2018 Phase II Permit Requirements Section S5.C.2 of the 2013-2018 Phase II Permit requires that the City shall create opportunities for the public to participate in the decision-making processes involving the development, implementation, and update of the SWMP, and comply with applicable state and local public notice requirements. The two main components include: 1. Developing and implementing a process for consideration of public comments on the City s SWMP 2. Posting the Annual Report and the SWMP Plan, on the City s website no later than May 31 of each year (Note: No Annual Report was required to be submitted in 2014.) As part of the annual update, the City invites public comment on the contents of the SWMP plan. 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 Schedule or Frequency Public Involvement in the SWMP Solicit feedback on website and in M.I. Weekly Revise SWMP Plan Update SWMP Plan with planned activities for 2018 Update SWMP Plan in early 2018; post on City s website by May 31, 2018 Prepare and Submit Annual Report Prepare and submit Annual Report; submittal should include SWMP Plan and other supplemental documentation (if applicable) Annual Report submittal to Ecology by March 31, 2018 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 2017 SWMP Plan Update May 2017 9
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 This section describes the Illicit Discharge Detection and Elimination (IDDE) Phase II Permit requirements, as well as the City s planned compliance activities. 2013-2018 Phase II Permit Requirements Section S5.C.3 of the 2013-2018 Phase II Permit requires the City to include an ongoing IDDE Program designed to prevent, detect, characterize, trace, and eliminate illicit connections and illicit discharges into the stormwater system. The specific Phase II Permit requirements are as follows: 1. Continue mapping on an ongoing basis 2. Publicize a public hotline number for reporting of spills and other illicit discharges; and track all calls and follow-up actions taken. 3. By February 2, 2018, adopt an updated 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. The City of Mercer Island Municipal Code 15.09.040 addresses these concerns. 4. By December 31, 2017, complete field screening of 40 percent of the stormwater system. After December 31, 2017, the City is required to complete field screening on an average of 12 percent of the stormwater system per year. 5. Ensure that all staff responsible for identification, investigation, termination, cleanup, and reporting illicit discharges are trained to conduct these activities. 6. Implement an ongoing training program for all municipal staff involved with IDDE. 7. Distribute information to public employees, business, and the general public of the hazards associated with illicit discharges and improper disposal of wastes. Planned Activities Table 3 summarizes the planned activities associated with the City s IDDE program. 2017 SWMP Plan Update May 2017 10
Table 3. Planned illicit discharge detection and elimination activities. Activity IDDE Program Plan Implementation Tasks Implement IDDE Program plan requirements Schedule or Frequency Illicit Discharge Field Screening Perform Field screening of stormwater system Perform field screening on 40% of the stormwater system by December 31, 2017 Complete Mapping Requirements Publicize Phone Number for Reporting Spills and Illicit Discharges Tracking System for Complaints, Investigations, and Spill Response Staff Training Work with GIS technician to ensure maps are updated regularly based on changes to infrastructure from CIP, private development, and Public Works Dept. Publicize phone number on website and in print material Use coding in work order system to track IDDE-related work Provide refresher training on IDDE general awareness and IDDE response to field staff 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 planned activities. 2013-2018 Phase II Permit Requirements Section S5.C.4 of the 2013-2018 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 specific Phase II Permit requirements are as follows: 1. Implement an ordinance or other enforceable mechanism that addresses runoff from new development, redevelopment, and construction sites by December 31, 2016. Include provisions to verify adequate long-term operation and maintenance (O&M) of stormwater treatment and flow control BMPs/facilities. 2. Continue to 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 2017 SWMP Plan Update May 2017 11
extent practicable, and satisfy State requirements to apply all known, available, and reasonable methods of prevention, control, and treatment (AKART) prior to discharge. 3. Continue to implement 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. training program for planning and review staff. 4. Conduct inspections of construction sites prior to clearing and construction, during construction, and upon completion of construction. 5. Conduct annual inspections of all stormwater treatment and flow control BMPs/facilities that discharge to the stormwater system and were permitted by the City since 2007 (unless maintenance records justify a reduced inspection frequency). 6. Provide ongoing training program for staff responsible for implementing the program to control stormwater runoff from new development, redevelopment, and construction sites. 7. Review, revise, and make effective local development-related codes, rules, standards, or other enforceable documents to incorporate and require LID principles and LID BMPs by December 31, 2016. Submit a summary of the results of the review and revision process with the annual report due no later than March 31, 2017. 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 Develop/update documents and forms to improve the permitting process Update City s website to improve stormwater management and regulatory information process process Tasks Schedule or Frequency 2017 SWMP Plan Update May 2017 12
Table 4 (continued). Planned activities to control runoff from new development, redevelopment, and construction sites. Staff Training Activity Tasks 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 Schedule or Frequency Review All Stormwater Site Plans Continue current practices 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 Enhance post-construction inspection Summarize the Results of the Code Review and Revision Process (1) This requirement applies to projects greater than 1 acre. Review and refine the inspection procedures used during construction to inspect/enforce TESC measures Review and refine the inspection program for residential subdivisions while individual lots are in construction (1) Continue using electronic permit tracking system (TRAKiT/CRW Systems) 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 Conduct annual post-construction inspection on required LID BMPs Compile a list of participants, documents reviewed, and revisions made Continue current practices and modify as needed Continue current practices and modify as needed June 5, 2017 June 5, 2017 June 5, 2017 June 5, 2017 August, 2017, 2017 SWMP Plan Update May 2017 13
Component 5: Municipal Operations and Maintenance 2017 SWMP Plan In December 1995, the City of Mercer Island Municipal Code 15.09.02 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 municipal operations and maintenance (O&M), including planned activities. 2013-2018 Phase II Permit Requirements Section S5.C.5 of the 2013-2018 Phase II Permit requires the City to develop and implement an O&M program with the ultimate goal of preventing or reducing pollutant runoff from the municipal separate stormwater system and municipal O&M activities. The specific Phase II Permit requirements are as follows: 1. Implement 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 (2012). 2. Perform annual inspections of all City-owned or operated permanent stormwater treatment and flow control BMPs/facilities, other than catch basins, and take appropriate maintenance actions. 3. Spot check potentially damaged permanent treatment and flow control BMPs/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 owned or operated by the City at least once by August 1, 2017 and clean as according to established maintenance standards. Inspect all catch basins and inlets every two years thereafter. 5. Continue to implement practices, policies, and procedures to reduce stormwater impacts associated with runoff from municipal O&M activities, including but not limited to streets, parking lots, roads, highways, buildings, parks, open space, road right-of-ways, maintenance yards, and stormwater treatment and flow control BMPs/facilities owned or maintained by the City, and to reduce pollutants in discharges from all lands owned or maintained by the City. 6. Continue to implement an ongoing training program for City staff that addresses the importance of protecting water quality, the requirements of the Phase II 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. 2017 SWMP Plan Update May 2017 14
7. Implement Stormwater Pollution Prevention Plans (SWPPPs) for all heavy equipment maintenance or storage yards and material storage facilities owned or operated by the City. 8. Maintain inspection and maintenance repair records and summarize annual activities for the Municipal Operations and Maintenance component of the Annual Compliance Report; including any updates to the SWMP Plan. Planned Activities Table 5 summarizes the City s planned activities associated with municipal O&M. Table 5. Planned municipal operations and maintenance activities. Activity Tasks Schedule or Frequency Implement maintenance procedures and standards Implement Stormwater Pollution Prevention Plans (SWPPPs) Treatment and flow control facility inspections Continue review and modify if needed Conduct ongoing Dry and Wet weather SWPPP inspections inspection program for detention basins/ponds and other stormwater facilities Street Sweeping program Record Keeping Communication and Coordination Catch Basin Inspection Program Staff Training Continue record updates. Document activities associated with SWPPPs. Monthly meetings with DSG staff regarding measures to protect water quality. Meetings with Public Works and Parks staff to review findings of SWPPPs and discuss practices to reduce stormwater impacts The City has selected the following two options for catch basin and inlet inspections: Option 1: Inspect at least once by August 1, 2017, and every 2 years thereafter Option 3: Clean all pipes, ditches, catch basins, and inlets within a circuit once during the permit term Refresher training on SWPPPs and source control BMPs Monthly/ Before August 1, 2017 (Option 1) or before July 31, 2018 (Option 3) Monitoring This section provides a brief discussion of the Phase II Permit monitoring requirements, including planned activities. 2013-2018 Phase II Permit Requirements Section S8 of the 2013-2018 Phase II Permit requires the City to do the following: 2017 SWMP Plan Update May 2017 15
1. Provide a description of any stormwater monitoring or stormwater-related studies conducted during the reporting period. 2. Pay into a collective fund to implement a Regional Stormwater Monitoring Program (RSMP) that includes the following three components: Status and trends monitoring (small stream and marine nearshore) Stormwater management program effectiveness studies Source identification and diagnostic monitoring (Source Identification Information Repository [SIDIR]) 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. Planned Activities The City decided to opt in to the RSMP and started contributing to the RSMP fund in August 2014. Stormwater monitoring studies conducted during 2013 focused on identifying the sources of dissolved copper and zinc in Basins 10 and 32b and continued in 2014. For 2015-2016, monitoring focused in Basin 10 which serves most of the town center. Five monitoring stations were used to identify seasonal patterns for pollutant loading to help identify potential sources. In 2016, the laboratory analysis from the monitoring will be reviewed and analyzed to determine next steps. Future work may continue the investigative efforts to identify and eliminate specific sources of pollutants if found or construct water quality treatment measures if grant funding is available. Reporting This section provides a brief discussion of Phase II Permit reporting requirements, including planned activities. 2013-2018 Phase II Permit Requirements Section S9 of the 2013-2018 Phase II Permit requires the City to submit the following on March 31 of each year (beginning in 2015) 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 Additional requirements for specific Annual Report submittals include: 1. March 31, 2017 Annual Report: Include a summary of the results of the review and revision process for local development-related codes, rules, standards, or 2017 SWMP Plan Update May 2017 16
other enforceable documents to incorporate and require LID principles and LID BMPs. This summary will be completed in August 2017 instead, and it shall include, at a minimum: A list of the participants (job title, brief job description, and department represented) Codes, rules, standards, and other enforceable documents reviewed Revisions made to those documents which incorporate and require LID principles and LID BMPs Planned Activities The City will be submitting an Annual Report and SWMP Plan to Ecology by March 31, 2018. The SWMP Plan will be posted on the City s website by May 31, 2018. 2017 SWMP Plan Update May 2017 17