HomeMy WebLinkAbout6.a. MS4 Permit - Authorize Preparation of NPDES/SDS General MS4 Permit�O r 1 SEMOU EXECUTIVE SUMMARY
CITY COUNCIL
Utility Commission Meeting: August 12, 2013
AGENDA ITEM: MS4 Permit — Authorize Preparation of
AGENDA SECTION:
NPDES /SDS General MS4 Permit
New Business
PREPARED BY: Andrew J. Brotzler, PE, Director of
AGENDA NO.
Public Works /City Engineer
r..
ATTACHMENTS: Example Application; Scope of
Services
APPROVED BY:
RECOMMENDED ACTION: Motion to authorize the preparation of the MS4 SWPPP
Application for Reauthorization.
ISSUE
The city is mandated under the Clean Water Act to prepare and submit an MS4 SWPPP Application for
Reauthorization for the NPDES /SDS General Small Municipal Separate Storm Sewer System (MS4)
Permit MNR040000. The submittal of the application for reauthorization is due to the Minnesota
Pollution Control Agency (MPCA) within 150 days from its reissuance date of August 1, 2013.
1:3M Ikei:161111`Ia]
As a small MS4 city, the city is required to maintain an MS4 permit with the MPCA. This permit is a
second generation permit that was adopted by the MPCA and issued with an effective date of August 1,
2013. As an MS4 city, the city has 150 days from the issuance date to submit a completed
reauthorization form.
Attached is a scope of services for assistance with the preparation and submittal of the reauthorization
form. Work previously completed to evaluate measures included in the previous MS4 permit will be
utilized to prepare the reauthorization form.
Following the submittal of the reauthorization form, a scope will be developed for an implementation
plan to be initiated in early 2014. This will include the review and development of necessary operating
procedures to comply with the MS4 Permit along with training, inspections, and preparation of the
annual report for the next 5 year permit period.
SUMMARY
Staff recommends that the Utility Commission authorize the preparation of the MS4 SWPPP
Application for Reauthorization in accordance with the attached scope of services.
GAUTILITY COMMISSION\UC Information \20130812 UC MS4 Permit - Review and Authorize Scope of Services and Fee.docx
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August 7, 2013
Mr. Andrew Brotzler
City of Rosemount
2875 145th Street West
Rosemount, MN 55068 -4941
701 Xenia Avenue South
Suite 300
Minneapolis, MN 55416
Tel: 763 - 541 -4800
Fax: 763 - 541 -1700
Re: Request for Authorization to Complete MS4 Application for Reauthorization
Dear Mr. Brotzler:
This letter is a scope of work for the preparation, review and submittal of the City of Rosemount's MS4
Application for Reauthorization. The updated permit became law on August 1, 2013 and the City will
need to submit their application for permit reauthorization by December 29, 2013. Please be advised that
this scope does not outline work that will need to be included as part of implementation of the SWPPP.
This work can better be defined once the Application for Reauthorization (SWPPP document) is
completed.
Task 1: Compile and Review Program Assessment Information ($1500)
As part of this task, WSB will schedule a meeting with the city staff and gather all necessary
information about the existing programs and any gaps that exist between the existing and the new
permit. This analysis will include previously collected information and any new information
required pertaining to:
Interviews with City staff with assigned MS4 responsibilities.
Reviews of existing Best Management Practices (BMPs), Comprehensive Water
Resource Management Plans (CWRMP), Well Head Protection Plans (WHPP),
Ordinances, TMDLs, storm sewer system mapping, and Watershed Requirements
Facilities inspections
The results from the above investigations will be used to develop information that can be used to
assist in the completion of an Application for Reauthorization (SWPPP Document).
Task 2: Develop Application for Reauthorization ($2500)
The information gathered during program assessment will be used to complete the application for
reauthorization (SWPPP Document) to receive permit coverage. This SWPPP Document
becomes a program assessment report and can be used by the City to identify deficiencies with
their program according to the new MS4 general permit.
St. Cloud • Minneapolis • St. Paul
Equal Opportunity Employer
wsbeng.com
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Mr. Andrew Brotzler
August 7, 2013
Page 2
Task 3: Present Application to Utility Council and Complete Final Review ($500)
The completed application will be presented to the Utility Council for final review and approval
prior to submission.
This proposal outlines the work needed to complete the tasks associated with the preparation, review and
submittal of the City of Rosemount's MS4 Application for Reauthorization. WSB proposes to complete
billed hourly and at a cost not to exceed $4,500.
All other tasks will be separate work plans billed as hourly or other directive ordered by the City.
This letter represents our complete understanding of the MS4 regulatory program and the proposed scope
of services. If you are in agreement with the scope of services and proposed fee, please sign in the
appropriate space below and return one copy to us.
We appreciate the opportunity to share this proposal with you, and look forward to working with the City
of Rosemount efficiently bring your MS4 Program into compliance. If you have any questions about this
proposal, please contact me at 651- 231 -4845 or walmsAwsbeng com.
Sincerely,
WSB & Associates, Inc.
William Alms
Water Resources Project Manager
of
ACCEPTED BY:
City of Rosemount
Name
Signature
Date
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Minnesota Pollution Example MS4 SWPPP
Control Agency
520 Lafayette Road North Application for Reauthorization
St. Paul, MN 55155 -4194
for the NPDES /SDS General Small Municipal Separate
Storm Sewer System (MS4) Permit MNR040000
reissued with an effective date of August 1, 2013
Stormwater Pollution Prevention Program (SWPPP) Document
Doc Type: Permit Application
** *The information in this example is meant to be just that, an example. Answers will be a composite of different MS4
perspectives (townships, city, university, etc.), and are not meant to be continuous throughout the example SWPPP
Document. Cleanwater, MN is a fictional town, and the websites related to Cleanwater in the below application do not
exist***
Note: Additional instructions are in "red- italicized text" and examples are in "blue text ".
Instructions: This is an application example of the MS4 SWPPP Application for Reauthorization (SWPPP Document) referencing the
authorization to discharge stormwater associated with Municipal Separate Storm Sewer Systems (MS4s) under the National Pollutant
Discharge Elimination System /State Disposal System (NPDES /SDS) Permit Program. The MS4 SWPPP Application for
Reauthorization Example (SWPPP Document Example) will provide a wide spectrum of ideas that represent examples that may be
incorporated into the SWPPP Document. The Minnesota Pollution Control Agency (MPCA) MS4 Permit Program website is:
http://www.pca.state.mn.us/ms4.
Submittal: This MS4 SWPPP Application for Reauthorization form must be submitted electronically via e -mail to the MPCA at
ms4permitproaram .pca(d,)state.mn.us from the person that is duly authorized to certify this form. All questions with an asterisk ( *) are
required fields. All applications will be returned if required fields are not completed.
*The MS4 SWPPP Application for Reauthorization; SWPPP Document and applicable attachments must be completed and returned
to the MPCA MS4 Permit Program e -mail: ms4permitproaram .pca(o)state.mn. us.
Questions: Contact Claudia Hochstein at 651- 757 -2881 or claudia .hochstein(a_)state.mn.us, Dan Miller at 651- 757 -2246 or
daniel.miller(d_)state.mn.us, or call toll -free at 800 - 657 -3864.
*These instructions skip the `General Contact infom73tior7. " "Verification, ° and `Certification" sections, though all three sections must
be completed in the MS4 SWPPP Appiication for Reauthorization form (wq- strm4 -49a) for an application to be processed.
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Stormwater Pollution Prevention Program Document
*Any references to "Permit" will refer to the 2013 MS4 General Permit Authorization to Discharge Stormwater Associated with Small
Municipal Separate Storm Sewer Systems under the National Pollutant Discharge Elimination System /State Disposal System
(NPDES/SDS) Permit Program with a Permit effective date of August 1, 2013.
*A complete MS4 SWPPP Application for Reauthorization (SWPPP Document) will be placed on public notice for a period of 30
days to provide the public the opportunity to review the permittee's stormwater pollution prevention program document (SWPPP
Document) and provide comment on the plan of the permittee to protect and improve water resources. The SWPPP Document shall
provide the public necessary information to understand the direction and planned activities of the permittee's Stormwater Pollution
Prevention Program over the course of the next permit term.
*If you are not sure whether your answer should be "yes" or "no" in the following questions, then check "no" and explain, in the
allotted space, how you are partially meeting the requirement, and how you will ultimately fulfill the entire requirement.
I. Partnerships: (Part II.D.1)
*if the permittee enters into a partnership for purposes of meeting SWPPP requirements, the permittee maintains legal
responsibility for compliance with this Permit (Part 111. D.).
A. List the regulated small MS4(s) with which you have established a partnership in order to satisfy one or more
requirements of this Permit. Indicate which Minimum Control Measure (MCM) requirements or other program
components that each partnership helps to accomplish (List all that apply). Check the box below if you currently have no
established partnerships with other regulated MS4s. If you have more than five partnerships, hit the tab key after the last
line to generate a new row.
❑ No partnerships with regulated small MS4s
Name and description of partnership
MCM /Other permit requirements involved
Cleanwater River Watershed District,
Provides educational material on waters hed- fnendiy
lawn practices to citizens of Cleanwater Township
Promotes our annual meeting on their website
MCMs 1, 2
Cleanwater County;
Partner to inspect for illicit discharges. We have a
memorandum of understanding with the County that
they will implement this effort on behalf of our
Township-
MCM 3
City of Riverside;
Joint annual meeting for public input on both of our
SWPPPs and SWPPP Documents. We also have a
contract with them to provide maintenance of streets
(snowplowing, etc.), and to perform our construction
stormwater inspections.
MCMs 2,4 & 5
B. If you have additional information that you would like to communicate about your partnerships with other regulated small
MS4(s), provide it in the space below, or include an attachment to the SWPPP Document, with the following file naming
convention: MS4NameHere_Partnerships.
Please refer to our stormwater website, www.ci.cleanwater.mn.us/cleanwatertownship/stormwate , where all of our non
MS4 partners are also listed.
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II. Description of Regulatory Mechanisms: (Part II.D.2)
Illicit discharges
A. Do you have a regulatory mechanism(s) that effectively prohibits non - stormwater discharges into your small MS4,
except those non - stormwater discharges authorized under the Permit (Part III.D.3.b.)? ❑ Yes ❑ No
1. If yes:
a. Check which type of regulatory mechanism(s) your organization has (check all that apply):
E Ordinance ❑ Contract language
® Policy /Standards ❑ Permits
❑ Rules
❑ Other, explain:
*Ordinances are generally filed in City Code with an appropriate reference citation- The SWPPP Document question
below requests a citation to city code or an electronic copy (preferably pdf) of the specific ordinance for MCM 3: Illicit
Discharge, Detection and Elimination (Part IN. D. 3. b). ;.
*Policies, Standards and Contract Language may be kept in an internal file with the MS4 permittee and will not likely be
filed in Code. The MS4 permittee is expected to submit the policy, standard or contract language as an attachment to
the SWPPP Document as referenced below.
b. Provide either a direct link to the mechanism selected above or attach it as an electronic document to this
form; or if your regulatory mechanism is either an Ordinance or a Rule, you may provide a citation:
Citation:
Cleanwater State University Policies >EnvironmentaI Management Policies>Stormwater >Illicit Discharges
Direct link:
y Check here if attaching an electronic copy of your regulatory mechanism, with the following file naming
convention: MS4NameHere_IDDEreg. (This would be attached as CleanwaterStateU IDDEreg.pdf)
2. If no:
Describe the tasks and corresponding schedules that will be taken to assure that, within 12 months of the date
permit coverage is extended, this permit requirement is met:
Construction site stormwater runoff control
A. Do you have a regulatory mechanism(s) that establishes requirements for erosion and sediment controls and waste
controls? ❑ Yes ❑ No
1. If yes:
a. Check which type of regulatory mechanism(s) your organization has (check all that apply):
E Ordinance ❑ Contract language
❑ Policy /Standards ❑ Permits
❑ Rules
❑ Other, explain:
*Ordinances are generally filed in City Code with an appropriate reference citation. The SWPPP Document question
below requests a citation to city code or an electronic copy (preferably pdt) of the specific ordinance for MCM 3: Illicit
Discharge, Detection and Elimination (Part Ill. D. 3. b).
*Policies, Standards and Contract Language may be kept in an internal file with the MS4 permittee and will not likely be
filed in Code. The MS4 permittee is expected to submit the policy, standard or contract language as an attachment to
the SWPPP Document as referenced below.
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b. Provide either a direct link to the mechanism selected above or attach it as an electronic document to this
form; or if your regulatory mechanism is either an Ordinance or a Rule, you may provide a citation:
Citation:
Cleanwater Township Ordinances 2007 -04
Direct link:
www.ci.cleanwater.mn.us/cleanwatertownship/twpcodes/2007/04.pdf
❑ Check here if attaching an electronic copy of your regulatory mechanism, with the following file naming
convention: MS4NameHere_CSWreg.
B. Is your regulatory mechanism at least as stringent as the MPCA general permit to Discharge Stormwater Associated
with Construction Activity (as of the effective date of this MS4 Permit)? i Yes ® No
If you answered yes to the above question, proceed to C.
If you answered no to the above permit requirement in B., describe the tasks and corresponding schedules that will be
taken to assure that, within 12 months of the date permit coverage is extended, these permit requirements are met:
We will update our construction site stormwater runoff control regulatory mechanism to be at least as stringent as the
MPCA CSW permit. This effort will be completed within 12 months of the date permit coverage is extended
C. Answer yes or no to indicate whether your regulatory mechanism(s) requires owners and operators of construction
activity to develop site plans that incorporate the following erosion and sediment controls and waste controls as
described in the Permit (Part III.D.4.a.(1) -(8)), and as listed below:
1. Best Management Practices (BMPs) to minimize erosion.
® Yes
❑ No
2. BMPs to minimize the discharge of sediment and other pollutants.
® Yes
❑ No
3. BMPs for dewatering activities.
❑ Yes
,: '; No
4. Site inspections and records of rainfall events
® Yes
No
5. BMP maintenance
❑ Yes
❑ No
6. Management of solid and hazardous wastes on each project site.
Z Yes
❑ No
7. Final stabilization upon the completion of construction activity, including the use of perennial
❑ Yes
❑ No
vegetative cover on all exposed soils or other equivalent means.
8. Criteria for the use of temporary sediment basins.
❑ Yes
❑ No
If you answered no to any of the above permit requirements, describe the tasks and corresponding schedules that will
be taken to assure that, within 12 months of the date permit coverage is extended, these permit requirements are met:
C.3. We currently have guidance for dewai er�,gig activities, and actively encourage contractors and developers to take
proper care. However, it is not part of our official ordinance. We will amend the ordinance to formalize our current
actions, The township clerk will work with the City of Cleanwater engineer (since City of Cleanwater does our
construction erosion and sediment control (ESC) inspections) to draft the amendment using language from the MPCA
model ESC ordinance as a guideline. Within 3 months following the due date of this application document to the
MPCA, there will be a public hearing regarding this amendment and the following amendments related to items (5) and
(8) The amended ordinance will be placed on the township board's meeting agenda for approval within 5 months
following the due date of this application document to the MPCA.
C.5 Amend ordinance to include the requirement that BMP maintenance is conducted by owners and operators of
construction activity The township clerk will draft the amendment, using the EPA's model ordinance as a reference. 11
will be placed on the township board's meeting agenda for approval within 5 months following the due date of this
application document to the MCPA.
C.B. Following the same procedure as for (3) and (5), the ordinance will be amended to include criteria for the use of
temporary sediment basins
Post - construction stormwater management
A. Do you have a regulatory mechanism(s) to address post- construction stormwater management activities?
IF' Yes ❑ No
If yes:
�0
Check which type of regulatory mechanism(s) your organization has (check all that apply):
❑ Ordinance ❑ Contract language
❑ Policy /Standards ❑ Permits
❑ Rules
❑ Other, explain:
www.pca.state.mn.us -
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*Ordinances are generally filed in City Code with an appropriate reference citation. The SWPPP Document question
below requests a citation to city code or an electronic copy (preferably pdf) of the specific ordinance for MCM 3: Illicit
Discharge, Detection and Elimination (Part III.D.3.b)
*Policies, Standards and Contract Language may be kept in an internal file with the MS4 permittee and will not likely be
filed in Code. The MS4 permittee is expected to submit the policy, standard or contract language as an attachment to
the SWPPP Document as referenced below.
b. Provide either a direct link to the mechanism selected above or attach it as an electronic document to this
form; or if your regulatory mechanism is either an Ordinance or a Rule, you may provide a citation:
Citation:
Cleanwater City Code, Title 9, Chapter 1145, Section 14
Direct link:
www ci cleanwater mn.usicitycode /title9 /chl 145/sec14 html
❑ Check here if attaching an electronic copy of your regulatory mechanism, with the following file naming
convention: MS4NameHere_PostCSWreg.
B. Answer yes or no below to indicate whether you have a regulatory mechanism(s) in place that meets the following
requirements as described in the Permit (Part III.D.5.a.):
1. Site plan review: Requirements that owners and /or operators of construction activity submit ❑ Yes ❑ No
site plans with post- construction stormwater management BMPs to the permittee for review and
approval, prior to start of construction activity.
2. Conditions for post construction stormwater management: Requires the use of any
combination of BMPs, with highest preference given to Green Infrastructure techniques and
practices (e.g., infiltration, evapotranspiration, reuse /harvesting, conservation design, urban
forestry, green roofs, etc.), necessary to meet the following conditions on the site of a
construction activity to the Maximum Extent Practicable (MEP):
a. For new development projects — no net increase from pre - project conditions (on an annual ❑ Yes ® No
average basis) of:
1) Stormwater discharge volume, unless precluded by the stormwater management
limitations in the Permit (Part III.D.5.a(3)(a)).
2) Stormwater discharges of Total Suspended Solids (TSS).
3) Stormwater discharges of Total Phosphorus JP).
b. For redevelopment projects — a net reduction from pre - project conditions (on an annual ❑ Yes ® No
average basis) of:
1) Stormwater discharge volume, unless precluded by the stormwater management
limitations in the Permit (Part III.D.5.a(3)(a)).
2) Stormwater discharges of TSS.
3) Stormwater discharges of TP.
3. Stormwater management limitations and exceptions:
a. Limitations
1) Prohibit the use of infiltration techniques to achieve the conditions for post- construction ❑ Yes No
stormwater management in the Permit (Part III.D.5.a(2)) when the infiltration structural
stormwater BMP will receive discharges from, or be constructed in areas:
a) Where industrial facilities are not authorized to infiltrate industrial stormwater under
an NPDES /SDS Industrial Stormwater Permit issued by the MPCA.
b) Where vehicle fueling and maintenance occur.
c) With less than three (3) feet of separation distance from the bottom of the
infiltration system to the elevation of the seasonally saturated soils or the top of
bedrock.
d) Where high levels of contaminants in soil or groundwater will be mobilized by the
infiltrating stormwater.
2) Restrict the use of infiltration techniques to achieve the conditions for post- construction ❑ Yes ❑ No
stormwater management in the Permit (Part III.D.5.a(2)), without higher engineering
review, sufficient to provide a functioning treatment system and prevent adverse
impacts to groundwater, when the infiltration device will be constructed in areas:
a) With predominately Hydrologic Soil Group D (clay) soils.
b) Within 1,000 feet up- gradient, or 100 feet down - gradient of active karst features.
c) Within a Drinking Water Supply Management Area (DWSMA) as defined in Minn.
R. 4720.5100, subp. 13.
d) Where soil infiltration rates are more than 8.3 inches per hour.
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3) For linear projects where the lack of right -of -way precludes the installation of volume ❑ Yes ❑ No
control practices that meet the conditions for post- construction stormwater management
in the Permit (Part III.D.5.a(2)), the permittee's regulatory mechanism(s) may allow
exceptions as described in the Permit (Part III.D.5.a(3)(b)). The permittee's regulatory
mechanism(s) shall ensure that a reasonable attempt be made to obtain right -of -way
during the project planning process.
4. Mitigation provisions: The permittee's regulatory mechanism(s) shall ensure that any
stormwater discharges of TSS and /or TP not addressed on the site of the original construction
activity are addressed through mitigation and, at a minimum, shall ensure the following
requirements are met:
a. Mitigation project areas are selected in the following order of preference: ®
® Yes ❑ No
1) Locations that yield benefits to the same receiving water that receives runoff from the
original construction activity.
2) Locations within the same Minnesota Department of Natural Resource (DNR)
catchment area as the original construction activity.
3) Locations in the next adjacent DNR catchment area up- stream
4) Locations anywhere within the permittee's jurisdiction.
b. Mitigation projects must involve the creation of new structural stormwater BMPs or the ❑
❑ Yes ❑ No
retrofit of existing structural stormwater BMPs, or the use of a properly designed regional
structural stormwater BMP.
c. Routine maintenance of structural stormwater BMPs already required by this permit cannot ❑
❑ Yes ® No
be used to meet mitigation requirements of this part.
d. Mitigation projects shall be completed within 24 months after the start of the original ®
® Yes ❑ No
construction activity.
e. The permittee shall determine, and document, who will be responsible for long -term ❑
❑ Yes ® No
maintenance on all mitigation projects of this part.
f. If the permittee receives payment from the owner and /or operator of a construction activity ❑
❑ Yes ® No
for mitigation purposes in lieu of the owner or operator of that construction activity meeting
the conditions for post- construction stormwater management in Part III.D.5.a(2), the
permittee shall apply any such payment received to a public stormwater project, and all
projects must be in compliance with Part III.D.5.a(4)(a) -(e).
5. Long -term maintenance of structural stormwater BMPs: The permittee's regulatory
mechanism(s) shall provide for the establishment of legal mechanisms between the permittee
and owners or operators responsible for the long -term maintenance of structural stormwater
BMPs not owned or operated by the permittee, that have been implemented to meet the
conditions for post- construction stormwater management in the Permit (Part III.D.5.a(2)). This
only includes structural stormwater BMPs constructed after the effective date of this permit and
that are directly connected to the permittee's MS4, and that are in the permittee's jurisdiction.
The legal mechanism shall include provisions that, at a minimum:
a. Allow the permittee to conduct inspections of structural stormwater BMPs not owned or ®
® Yes ❑ No
operated by the permittee, perform necessary maintenance, and assess costs for those
structural stormwater BMPs when the permittee determines that the owner and /or operator
of that structural stormwater BMP has not conducted maintenance.
b. Include conditions that are designed to preserve the permittee's right to ensure maintenance ❑
❑ Yes ® No
responsibility, for structural stormwater BMPs not owned or operated by the permittee, when
those responsibilities are legally transferred to another party.
c. Include conditions that are designed to protect/preserve structural stormwater BMPs and ®
® Yes [-]No
If you answered no to any of the above permit requirements, describe the tasks and corresponding schedules that will
be taken to assure that, within twelve (12) months of the date permit coverage is extended, these permit requirements
are met:
B 2.a., B.2-b. Amend current post - construction stormwater ordinance, which does not include anything related to
volume - control, to incorporate Permit requirements. For this to happen, our City Engineer is working with the
Cleanwater River Watershed District for guidance on how to craft an effective ordinance Cleanwater River Watershed
District already has a volume control ordinance in place, so most developers and contractors who apply for a permit
from us already have to meet these requirements. The City Engineer will make sure that our ordinance meets the
requirements of the Cleanwater River Watershed District, even though they are more stringent than the MPCA
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requirements. Beginning in the month of the application due date of this permit to the MPCA, the City Engineer will meet
bi- weekly with Cleanwater River Watershed District. Within 3 months of that date, the draft language will be open to a
public hearing. If there are any comments, we will respond to them and send an amended draft to the city council for
approval at the first opportunity. If there are no comments, we will send the draft directly to the city council for approval.
This process should be completed within 7 months of the due date of this application to the MPCA.
B.3.a.1 Our ordinance currently meets all of these requirements aside from restricting infiltration practices where
vehicle fueling and maintenance occurs We will amend the ordinance on the same schedule as the items in B.2.a and
B.2,b.
B 3,a.3. We will amend the ordinance to include the exceptions for linear projects as elaborated in the Permit (Part
III D.5.a(3)(b)). This will occur on the same schedule as the items above.
13.4.c: Currently, our ordinance contains nothing about whether routine maintenance can be used towards mitigation
requirements. On the same schedule as the above items we will codify the fact that it cannot be used for that purpose.
B.4.e: We will codify on the same schedule, the requirement to identify and document who is responsible for long -term
maintenance of mitigation requirements. At the point of codification, we will If t the requirement by having any
applicants for a grading permit identify the person who will be responsible f fig -term mainien ace of mn titgation
projects. This person's name will be attached to the permit and the records e project
B 4 if Since we have not had volume control requirements before. we haven't had any money paid tc u� :or mitigation
projects. We will draft an amendment to include language mandating that money received from an ownerioperator of
construction activity, in lieu of meeting the conditions for post - construction storrrlwater management, shall be used for a
public stormwater project. We will work on this amendment to our current post- constru cron stormwater ordinance on
the same timeline as the items listed above.
B 5.b The last item that we will include (on the same schedule) in the amendments to our post - construction stormwater
ordinance will be language that will ensure maintenance res sibihty on structural stormNivater BMPs that we do not
own or operate. We plan to do this by drafting language thaar °fl "" yes ma'ntenance responsibility for structural
stormwater BMPs to be tied to property records.
.h
"A complete MS4 SWPPP Application for Reauthorization (SWPPP Document) will be placed on public notice for a period of 30
days to provide the public the opportunity to review the permittee's stormwater pollution prevention program document (SWPPP
Document) and provide comment on the plan of the permittee to protect and improve water resources.
III. Enforcement Response Procedures (ERPs): (Part II.D.3)
A. Do you have existing ERPs that satisfy the requirements of the Permit (Part III.B.)? ❑ Yes ® No
1. If yes, attach them to this form as an electronic document, with the following file naming
convention: MS4NameHere_ERPs.
2. If no, describe the tasks and corresponding schedules that will be taken to assure that, with
twelve (12) months of the date permit coverage is extended, these permit requirements are met:
We will confer with the Public Works department of the Cleanwater County, which helps our
township with any enforcement requirements, to provide a written procedure that will satisfy
these requirements. We will initially meet with them within 3 months of the date of this
rrr? application.
B. Describe your ERPs
We do not currently have ERPs, see above implementation plan. See below for our current stage of draft:
Categories of Violations:
• Failure to apply for permit coverage
• Failure to prepare a Storm Water Pollution Prevention Plan (SWPPP)
• Inadequate SWPPP
• Failure to implement Best Management Practices (BMPs)
• Failure to maintain BMPs
• Failure to conduct or document inspections
• Non - stormwater discharge to the storm sewer system
Factors to Consider in the Selection of Enforcement Response:
• Whether there is an isolated or infrequent violation
• Frequent or repeat violations
• Other types of noncompliance involved
• Degree of impact to the environment
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Enforcement Response:
• Notice of Violation (NOV) - A written document issued by Regulator (us) to a permittee or other regulatee informing
them of the party's violation(s) of the applicable permit, statute or regulation
• Expedited Settlement Offer (ESO) - A consent agreement and final penalty order issued by us, in specified
circumstances., where violations of the applicable permit, statute or regulation may be resolved quickly through an
expedited process in which the violator'
• corrects identified deficiencies
• signs an agreement with us certifying that deficiencies have been corrected
• pays a penalty
• Administrative Order (AO) - A written document issued by us which contains findings of fact and which directs a
permittee or other regulatee to achieve compliance with the applicable permit, statute or regulation
• Administrative Penalty Order (APO) - An order entered by us assessing penalties against a permittee or other
regulatee for violating the applicable permit, statute or regulation
A Civil Action - A judicial action that typically seeks both penalties and injunctive relief for violating the applicable
permit; statute or regulation
IV. Storm Sewer System Map and Inventory: (Part II.D.4.)
A. Describe how you manage your storm sewer system map and inventory:
We work with the City of Cleanwater to make this system map and inventory. The City has a water resources
specialist, who updates the map on -site using a handheld GPS unit. This allows us to have real -time updates to the
stormsewer system map and inventory .
B. Answer yes or no to indicate whether your storm sewer system map addresses the following requirements from the
Permit (Part III.C.1.a -d), as listed below:
1. The permittee's entire small MS4 as a goal, but at a minimum, all pipes 12 inches or greater in ❑ Yes ❑ No
diameter, including stormwater flow direction in those pipes.
2. Outfalls, including a unique identification (ID) number assigned by the permittee, and an ® Yes ❑ No
associated geographic coordinate.
3. Structural stormwater BMPs that are part of the permittee's small MS4. ® Yes ❑ No
4. All receiving waters. ® Yes ❑ No
If you answered no to any of the above permit requirements, describe the tasks and corresponding schedules that will
be taken to assure that, within 12 months of the date permit coverage is extended, these permit requirements are met:
IV.B. Our map currently displays pipes 24 inches or greater in diameter, with a large majority of 12 inch pipes added as
well. Starting in March, we will continue working with the City of Cleanwater to map all pipeline locations that are 12
inches and greater in diameter We will use a GPS to field mark all additional pipeline needed to be added and then
integrate them into the map,
C. Answer yes or no to indicate whether you have completed the requirements of 2009 Minnesota Session Law, Ch. 172.
Sec. 28: with the following inventories, according to the specifications of the Permit (Part III.C.2.a. -b.), including:
1. All ponds within the permittee's jurisdiction that are constructed and operated for purposes of ❑ Yes No
water quality treatment, stormwater detention, and flood control, and that are used for the
collection of stormwater via constructed conveyances.
2. All wetlands and lakes, within the permittee's jurisdiction, that collect stormwater via constructed ❑ Yes [:]No
conveyances.
D. Answer yes or no to indicate whether you have completed the following information for each feature inventoried.
1. A unique identification (ID) number assigned by the permittee. ® Yes ❑ No
2. A geographic coordinate. ® Yes ❑ No
3. Type of feature (e.g., pond, wetland, or lake). This may be determined by using best professional ® Yes ❑ No
judgment.
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If you have answered yes to all above requirements, and you have already submitted the Pond Inventory Form to the
MPCA, then you do not need to resubmit the inventory form below.
If you answered no to any of the above permit requirements, describe the tasks and corresponding schedules that will
be taken to assure that, within 12 months of the date permit coverage is extended, these permit requirements are met:
C.1. We have recently constructed four new ponds as part of a development in our Township. We are gathering the
information of all of our ponds, including the new ones, and filling this into our inventory form to submit to the
Commissioner.
E. Answer yes or no to indicate if you are attaching your pond, wetland and lake inventory to the MPCA ❑ Yes ® No
on the form provided on the MPCA website at: htti)://www.oca.state.mn.us/ms4, according to the
specifications of Permit (Part III.C.2.b.(1) -(3)). Attach with the following file naming convention:
MS4NameHere_inventoty.
If you answered no, the inventory form must be submitted to the MPCA MS4 Permit Program within
12 months of the date permit coverage is extended.
*A complete MS4 SWPPP Application for Reauthorization (SWPPP Document) will be placed on public notice for a period of 30 days
to provide the public the opportunity to review the permittee's stormwater pollution prevention program document (SWPPP
Document) and provide comment on the plan of the permittee to protect and improve water resources
V. Minimum Control Measures (MCMs) (Part II.D.5)
A. MCM1: Public education and outreach
1. The Permit requires that, within 12 months of the date permit coverage is extended, existing permittees revise their
education and outreach program that focuses on illicit discharge recognition and reporting, as well as other specifically
selected stormwater - related issue(s) of high priority to the permittee during this permit term. Describe your current
educational program, including any high - priority topics included:
Our Township is primarily residential. and has a very limited business district. Therefore, our focus is on residential issues,
though we do not have specific high - priority topics. We partner with Cleanwater River Watershed District to provide
education to our residents. They provide us with brochures that we mail out to all households twice a year. These
brochures remind homeowners of proper practices for such activities as raking grass clippings, cleaning up pet waste, and
home car - washing. Cleanwater River Watershed District also has an annual water festival, where we are present to
answer questions about how Township residents should deal with stormwater. The Township has a stormwater page on
our website that we use to communicate stormwater- related messages.
2. List the categories of BMPs that address your public education and outreach program, including the distribution of
educational materials and a program implementation plan. Use the first table for categories of BMPs that you have
established and the second table for categories of BMPs that you plan to implement over the course of the permit term
Include the measurable goals with appropriate timeframes that each BMP category will be implemented and completed. In
addition, provide interim milestones and the frequency of action in which the permittee will implement and /or maintain the
BMPs. Refer to the U.S. Environmental Protection Agency's (EPA) Measurable Goals Guidance for Phase 11 Small MS4s
(http: / /www.epa.gov /npdes /pubs /measurablegoals.pdO. If you have more than five categories, hit the tab key after the
last line to generate a new row.
Established BMP categories
Measurable goals and timeframes
Brochures
A new topic is circulated to an audience of 300 households in
fall andspring each year.
Water Festival
Make face -to -face contact with at least 50 residents of the
Township at this annual event in June. Provide all children with
a take-away item.
Website
We measured 300 hits to our website last year.
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BMP categories to be implemented
Measurable goals and timeframes
Annual Meeting
Have at least 20 attendees at yearly meeting.
Starting with the 2014 spring brochures, we will include a written
survey in a random sample of mailings. The survey will gauge
Appropriate ublic notice
each selected household's practices related to the topic that will
be featured in the following fall's brochure. They will receive a
Availability of Stormwater Pollution Prevention
follow up the following spring. The same will happen with the fall
Program Document
for a different random sample, and this process will occur once
in the permit term, so that we can determine whether our
information affects household practices, and how we can
Citizen survey
improve our education information distribution.
Collaborate with Cleanwater City and Cleanwater River
Watershed District to create 3 separate programs for each grade
of 3 -5 students at the local elementary school each year. These
would include the basic concept of the water cycle and how
individual actions can make a big difference in stormwater and
Classroom presentations
water quality.
We hope to engage community groups in a storm drain
stenciling effort to increase awareness that the drains are
connected to our lakes and rivers. We want to stencil at least
Storm drain stenciling
100 drains in the next 3 years .
We currently have 30 followers on Twitter. and 100 likes on
Facebook We send a message or link to an interesting
stormwater related article at least once a month. If any important
events occur in our Township or nearby, we will send additional
messages. Our goal is to add at least 15 followers on both
Social media
media outlets every year.
3. Provide the name or the position title of the individual(s) who is responsible for implementing and /or coordinating this
MCM:
Township Clerk
B. MCM2: Public participation and involvement
1. The Permit (Part III.D.2.a.) requires that, within 12 months of the date permit coverage is extended, existing permittees
shall revise their program as necessary, and continue to implement a public participation /involvement program to solicit
public input on the SWPPP. Describe your current program:
Every year, we present and hear comments on our Stormwater Pollution Prevention Program at a regular Township Board
meeting. We usually do this at the October meeting. We put a notice in the local paper every week for a month before the
meeting,, and post a notice in the local library and town hall.
2. List the categories of BMPs that address your public participation /involvement program, including solicitation and
documentation of public input on the SWPPP. Use the first table for categories of BMPs that you have established and the
second table for categories of BMPs that you plan to implement over the course of the permit term.
Include the measurable goals with appropriate timeframes that each BMP category will be implemented and completed. In
addition, provide interim milestones and the frequency of action in which the permittee will implement and /or maintain the
BMPs. Refer to the EPA's Measurable Goals Guidance for Phase 11 Small MS4s
(http: / /www.epa.gov /npdes /pubs /measurablegoals.pdfl. If you have more than five categories, hit the tab key after the
last line to generate a new row.
Established BMP categories
Measurable goals and timeframes
Annual Meeting
Have at least 20 attendees at yearly meeting.
Make a weekly notice for one month in local paper. Post a paper
notice in at least 2 places around town one month prior to
Appropriate ublic notice
meeting.
Provide a copy of Stormwater Pollution Prevention Program
Availability of Stormwater Pollution Prevention
Document at the Town Hall and Library for viewing at any point
Program Document
in the year.
Booth at this yearly, June festival allows citizens to comment on
our Stormwater Pollution Prevention Program verbally or
Water Festival
throu h rovided comment forms.
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BMP categories to be implemented
Measurable goals and timeframes
Provide an electronic document of Stormwater Pollution
Online Availability of Stormwater Pollution Prevention
Prevention Program document online, to allow anytime, easier
Program Document
access to these documents.
Develop stormwater steering committee within 12 months of
permit coverage extension. Committee is made up of
representatives of various organizations: public, industrial,
commercial and construction entities. Involving stakeholders
early on in the program development will allow their voices to be
Establish a stormwater steering committee
heard prior to implementation.
The City will annually hold a coordination meeting involving co-
permittees, regulatory agencies, and interested stakeholders to
discuss progress of the storm water management program and
Coordination meeting
the next ear's activities.
3. Do you have a process for receiving and documenting citizen input? ❑ Yes ❑ No
If you answered no to the above permit requirement, describe the tasks and corresponding schedules that will be taken to
assure that, within 12 months of the date permit coverage is extended, this permit requirement is met:
4. Provide the name or the position title of the individual(s) who is responsible for implementing and /or coordinating this
MCM:
Education Coordinator
C. MCM 3: Illicit discharge detection and elimination
1. The Permit (Part III.D.3.) requires that, within 12 months of the date permit coverage is extended, existing permittees revise
their current program as necessary, and continue to implement and enforce a program to detect and eliminate illicit
discharges into the small MS4. Describe your current program:
We have an ordinance that prohibits illicit discharges and connections Our partners from the Clearwater County
Department of Public Works are trained to look for any signs of an illicit discharge while on the job. Our ERPs (attached)
guide what actions we take after an illicit discharge has been identified. One of our Township board members trains along
with County staff to identify illicit discharges. Clearwater River Watershed District has informational guides for fast food
restaurants on how to handle grease and proper dumpster usage and maintenance.
2. Does your Illicit Discharge Detection and Elimination Program meet the following requirements, as found in the Permit
(Part III.D.3.c. -g.)?
a. Incorporation of illicit discharge detection into all inspection and maintenance activities conducted ® Yes ❑ No
under the Permit (Part III.D.6.e.- f.)Where feasible, illicit discharge inspections shall be conducted
during dry- weather conditions (e.g., periods of 72 or more hours of no precipitation).
b. Detecting and tracking the source of illicit discharges using visual inspections. The permittee may ® Yes ❑ No
also include use of mobile cameras, collecting and analyzing water samples, and /or other detailed
procedures that may be effective investigative tools.
c. Training of all field staff, in accordance with the requirements of the Permit (Part III.D.6.g.(2)), in ® Yes [:]No
illicit discharge recognition (including conditions which could cause illicit discharges), and
reporting illicit discharges for further investigation.
d. Identification of priority areas likely to have illicit discharges, including at a minimum, evaluating ❑ Yes ® No
land use associated with business /industrial activities, areas where illicit discharges have been
identified in the past, and areas with storage of large quantities of significant materials that could
result in an illicit discharge.
e. Procedures for the timely response to known, suspected, and reported illicit discharges. ® Yes ❑ No
f. Procedures for investigating, locating, and eliminating the source of illicit discharges. ® Yes ❑ No
g. Procedures for responding to spills, including emergency response procedures to prevent spills from ® Yes ❑ No
entering the small MS4. The procedures shall also include the immediate notification of the
Minnesota Department of Public Safety Duty Officer, if the source of the illicit discharge is a spill or
leak as defined in Minn. Stat. § 115.061.
h. When the source of the illicit discharge is found, the permittee shall use the ERPs required by the ❑ Yes [-]No
Permit (Part III. B.) to eliminate the illicit discharge and require any needed corrective action(s).
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If you answered no to any of the above permit requirements, describe the tasks and corresponding schedules that will be
taken to assure that, within 12 months of the date permit coverage is extended, these permit requirements are met:
C.2.d. We have an ordinance that prohibits illicit discharges and connections, but will be revising our program to include
the identification of priority areas likely to have illicit discharges as outlined in the Permit (Part III.D.3.f.). We will be
incorporating these prioritization efforts within 5 months after permit coverage is extended.
3. List the categories of BMPs that address your illicit discharge, detection and elimination program. Use the first table for
categories of BMPs that you have established and the second table for categories of BMPs that you plan to implement
over the course of the permit term.
Include the measurable goals with appropriate timeframes that each BMP category will be implemented and completed. In
addition, provide interim milestones and the frequency of action in which the permittee will implement and /or maintain the
BMPs. Refer to the EPA's Measurable Goals Guidance for Phase ll Small MS4s
(http: / /www.epa.gov /npdes /pubs /measurablegoals.pdD. If you have more than five categories, hit the tab key after the
last line to generate a new row.
Established BMP categories
Measurable goals and timeframes
Review ordinance yearly to ensure that it continues to meet the
Ordinance
needs of the Township and legal requirements
County employees are on the lookout for illicit discharges while
they perform their normal duties, and inspections occur when
Inspections
we receive reports of an illicit discharge.
County employees.. and at least one Township Board member
will participate in training for spotting and handling illicit
Training
discharges
BMP categories to be implemented
Measurable goals and timeframes
Monthly inspections of high - priority outfalls, and around high-
risk establishments (fast food restaurants, dumpsters, car
Inspections
washes, mechanics, oil changes).
On a yearly basis, hire a consultant to televise a section of our
sewer system to find illicit connections to the system, as well as
leaks and cracks that might exist. This will happen in late
Storm Sewer Televising
summer or early fall of each year.
Allow citizens to dial a number and leave a message 24/7 to
Establish Illicit Discharge Reporting Hotline
report illicit discharges to the Township.
4. Do you have procedures for record - keeping within your Illicit Discharge Detection and Elimination (IDDE) program as
specified within the Permit (Part III.D.3.h.)? ❑ Yes 1 ; No
If you answered no, indicate how you will develop procedures for record - keeping of your Illicit Discharge, Detection and
Elimination Program, within 12 months of the date permit coverage is extended:
C.4 We are creating an Excel spreadsheet that will contain the date, time, and street address (or GPS coordinates if
found by County staff at a location with no address) of any reported illicit connections or discharges. Each entry will have
a description of the discharge, and if it is associated with a business. Next summer, we intend to have the funds for an
intern to put this information into GIS so we can track illicit discharges and target our inspections more efficiently in the
future.
5. Provide the name or the position title of the individual(s) who is responsible for implementing and /or coordinating this
MCM:
Director of Public Works
*A complete MS4 SWPPP Application for Reauthorization (SWPPP Document) will be placed on public notice for a period of 30
days to provide the public the opportunity to review the permittee's stormwater pollution prevention program document
(SWPPP Document) and provide comment on the plan of the permittee to protect and improve water resources
D. MCM 4: Construction site stormwater runoff control
1. The Permit (Part III.D.4.) requires that, within 12 months of the date permit coverage is extended, existing permittees
shall revise their current program, as necessary, and continue to implement and enforce a construction site stormwater
runoff control program. Describe your current program:
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We have a permit application required for any construction site that disturbs 1 acre or more. We require review of
construction site erosion and sediment control (ESC) plans before projects begin, and work with contractors to ensure
appropriate and correct use of erosion and sediment control BMPs on sites. We partner with the Cleanwater Soil and
Water Conservation District with a contract to perform our construction site ESC inspections. All site inspection checklists
are scanned and retained electronically and catalogued in a Microsoft Excel spreadsheet.
Does your program address the following BMPs for construction stormwater erosion and sediment control as required in
the Permit (Part III.D.4.b.):
a. Have you established written procedures for site plan reviews that you conduct prior to the start of ® Yes ❑ No
construction activity?
b. Does the site plan review procedure include notification to owners and operators proposing
❑ Yes ® No
construction activity that they need to apply for and obtain coverage under the MPCA's general
Process all applications within 30 days of receipt.
permit to Discharge Stormwater Associated with Construction Activity No. MN R100001?
Conduct inspections at 30% of permitted sites annually
Ins ections occur every week during the growing season.
c. Does your program include written procedures for receipt and consideration of reports of
Z Yes ❑ No
noncompliance or other stormwater related information on construction activity submitted by the
public to the permittee?
d. Have you included written procedures for the following aspects of site inspections to determine
compliance with your regulatory mechanism(s):
1) Does your program include procedures for identifying priority sites for inspection?
❑ Yes ❑ No
2) Does your program identify a frequency at which you will conduct construction site
'' Yes ❑ No
inspections?
3) Does your program identify the names of individual(s) or position titles of those responsible for
Z Yes ❑ No
conducting construction site inspections?
4) Does your program include a checklist or other written means to document construction site
❑ Yes ❑ No
inspections when determining compliance?
e. Does your program document and retain construction project name, location, total acreage to be
❑ Yes ❑ No
disturbed, and owner /operator information?
f. Does your program document stormwater - related comments and /or supporting information used to
❑ Yes ❑ No
determine project approval or denial?
g. Does your program retain construction site inspection checklists or other written materials used to Z Yes ❑ No
document site inspections?
If you answered no to any of the above permit requirements, describe the tasks and corresponding schedules that will be
taken to assure that, within 12 months of the date permit coverage is extended, these permit requirements are met.
2.b. We will notify owners and operators proposing construction activity to apply for and obtain coverage for the MPCA
general permit for construction activity We will incorporate this effort into our program within two months after permit
coverage is extended.
2.d.1) We plan to develop written procedures to explain our prioritization of inspections in the field. We will work with our
City inspector to record current procedures. We plan to have these efforts developed with our Construction Site
Stormwater Runoff Control program within two months after permit coverage is extended.
3. List the categories of BMPs that address your construction site stormwater runoff control program. Use the first table for
categories of BMPs that you have established and the second table for categories of BMPs that you plan to implement
over the course of the permit term.
Include the measurable goals with appropriate timeframes that each BMP category will be implemented and completed.
In addition, provide interim milestones and the frequency of action in which the permittee will implement and /or maintain
the BMPs. Refer to the EPA's Measurable Goals Guidance for Phase // Small MS4s
(http: / /www.epa.gov /npdes /pubs /measurablegoals.pdf). If you have more than five categories, hit the tab key after the
last line to generate a new row.
Established BMP categories
Measurable goals and timeframes
Permit Application System
Process all applications within 30 days of receipt.
Inspections
Conduct inspections at 30% of permitted sites annually
Ins ections occur every week during the growing season.
Education
Provide educational workshop on permit requirements for
general contractors once a year. Collaborate with County and
other LGUs.
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BMP categories to be implemented
Measurable goals and timeframes
Update our city permit and ordinance to meet MPCA General
Permit to Discharge Stormwater Associated with Construction
Permit Update
Activity.
Develop factsheet to accompany permit application to assist
Factsheet
contractors with understanding permit regulations.
Update procedures for site plan review on an annual basis and
Checklist for Site Plan Review
incorporate into the Checklist.
Ensure at least 10% of inspections conducted annually are
performed at deemed high priority inspection sites (e.g., near
Prioritize Inspections
sensitive receiving waters, projects larger than 5 acres
4. Provide the name or the position title of the individual(s) who is responsible for implementing and /or coordinating this
MCM:
Water Resource Technician
E. MCM 5: Post - construction stormwater management
1. The Permit (Part III.D.5.) requires that, within 12 months of the date permit coverage is extended, existing permittees
shall revise their current program, as necessary, and continue to implement and enforce a post- construction stormwater
management program. Describe your current program:
We have a post- construction stormwater management ordinance to encourage the utilization of BMPs for stormwater
runoff from new and redevelopment projects, as well as to ensure the maintenance and operation of the stormwater
BMPs.
2. Have you established written procedures for site plan reviews that you will conduct prior to the start of ® Yes ❑ No
construction activity?
3. Answer yes or no to indicate whether you have the following listed procedures for documentation of
post- construction stormwater management according to the specifications of Permit (Part III.D.5.c.):
a. Any supporting documentation that you use to determine compliance with the Permit (Part Z Yes [:]No
III.D.5.a), including the project name, location, owner and operator of the construction activity, any
checklists used for conducting site plan reviews, and any calculations used to determine
compliance?
b. All supporting documentation associated with mitigation projects that you authorize? ❑ Yes [:]No
c. Payments received and used in accordance with Permit (Part III.D.5.a.(4)(f))? IZi Yes ❑ No
d. All legal mechanisms drafted in accordance with the Permit (Part III.D.5.a.(5)), including date(s) of ❑ Yes ® No
the agreement(s) and names of all responsible parties involved?
If you answered no to any of the above permit requirements, describe the steps that will be taken to assure that, within 12
months of the date permit coverage is extended, these permit requirements are met.
E.3.d. We will develop procedures for documenting all legal mechanisms regarding long -term maintenance of structural
stormwater BMPs implemented through our post- construction stormwater management regulatory mechanism. This effort
will be completed within 5 months after permit coverage is extended.
4. List the categories of BMPs that address your post- construction stormwater management program. Use the first table for
categories of BMPs that you have established and the second table for categories of BMPs that you plan to implement
over the course of the permit term.
Include the measurable goals with appropriate timeframes that each BMP category will be implemented and completed.
In addition, provide interim milestones and the frequency of action in which the permittee will implement and /or maintain
the BMPs. Refer to the EPA's Measurable Goals Guidance for Phase 11 Small MS4s
(http: / /www.epa.gov /npdes /pubs /measurablegoals.pdf). If you have more than five categories, hit the tab key after the
last line to generate a new row.
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Established BMP categories
Measurable goals and timeframes
Inspections to verify proper maintenance of stormwater
BMPs
Annual inspections of 20% of completed City-owned BMPs.
Encourage the use of structural and non - structural
Provide a factsheet to all permit applicants about stormwater
BMPs during review of new and redevelopment
BMPs used to capture pollutants prior to discharging to nearby
projects
waters.
After ordinance was in place for 3 years, began evaluating
permits for how well they meet or exceed permit requirements,
by 5th year after ordinance was established, 95% of all building
permits will include descriptions and plans regarding storm
water control practices and site designs that comply with the
criteria and guidance specified or referenced in the municipal
Ordinance regulating new and redevelopment projects
code.
BMP categories to be implemented
Measurable goals and timeframes
Within 12 months of extension of permit coverage, revise
Update ordinance to meet new permit requirements
ordinance to meet permit requirements
Within 12 months of extension of permit coverage, develop site
plan review procedures that must be completed prior to the
Develop written procedures for site plan review
start of construction activity
Maintain all related documents pertaining to each new or
redevelopment project in more user - friendly filing system for
Document pertinent project information
better records management. Implement within 6 months.
Develop BMP Construction Guidance document for developers
BMP Construction Guidance
and contractors within 12 months of permit coverage extension.
5. Provide the name or the position title of the individual(s) who is responsible for implementing and /or coordinating this
MCM:
City Engineer
F. MCM 6: Pollution prevention /good housekeeping for municipal operations
1. The Permit (Part III.D.6.) requires that, within 12 months of the date permit coverage is extended, existing permittees shall
revise their current program, as necessary, and continue to implement an operations and maintenance program that
prevents or reduces the discharge of pollutants from the permittee owned /operated facilities and operations to the small
MS4. Describe your current program:
The City of Cleanwater currently inspects its structural pollution control devices on an annual basis and inspects all of its
outfalls, sediment basins and ponds each year. The City inspects stockpiles, storage and material handling areas at the
maintenance yard for potential discharges and maintenance of BMPs. The City is evaluating the use of road salt for winter
road maintenance activities to reduce chlorides entering our water resources. The City sweeps streets once in the fall after
leaf drop. Maintenance staff is trained semi - annually on various topics related to pollution prevention during maintenance
activities.
2. Do you have a facilities inventory as outlined in the Permit (Part III.D.6.a.)? ® Yes ❑ No
3. If you answered no to the above permit requirement in question 2, describe the tasks and corresponding schedules that
will be taken to assure that, within 12 months of the date permit coverage is extended, this permit requirement is met:
4. List the categories of BMPs that address your pollution prevention /good housekeeping for municipal operations program.
Use the first table for categories of BMPs that you have established and the second table for categories of BMPs that you
plan to implement over the course of the permit term.
Include the measurable goals with appropriate timeframes that each BMP category will be implemented and completed. In
addition, provide interim milestones and the frequency of action in which the permittee will implement and /or maintain the
BMPs. For an explanation of measurable goals, refer to the EPA's Measurable Goals Guidance for Phase 11 Small MS4s
http: / /www.epa.aov /npdes /pubs /measurablegoals.pdD. If you have more than five categories, hit the tab key after the
last line to generate a new row.
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Established BMP categories
Measurable goals and timeframes
Street Sweeping
Once a year after leaf drop
Inspect Maintenance Yard
Once a month and after all 1 inch or greater rain events
http: / /www.health. state. mn. us /divs /eh /water /swp /maps /index.htm. Is a map including the
Semi - annual training where staff utilize training materials in their
Internal training program
daily activities
1) Wells and source waters for drinking water supply management areas identified as
As part of training for new employees, both temporary and
vulnerable under Minn. R. 4720.5205, 4720.5210, and 4720.5330?
permanent, proper methods for handling and storing materials
2) Source water protection areas for surface intakes identified in the source water
and for spotting and correcting potential problems are
assessments conducted by or for the Minnesota Department of Health under the federal
discussed. Employees must score 95% on a scenario -based
New employee training
quiz to complete training.
c. Have you developed and implemented BMPs to protect any of the above drinking water
❑ Yes ❑ No
BMP categories to be implemented
Measurable goals and timeframes
6. Have you developed procedures and a schedule for the purpose of determining the TSS and
Develop plans describing spill prevention and control
TP treatment effectiveness of all permittee owned /operated ponds constructed and used for the
procedures by the end of Year 1 Conduct annual spill
collection and treatment of stormwater, according to the Permit (Part III.D.6.d.)?
prevention and response training sessions for all municipal
Develop Spill Prevention & Control Plans for Municipal
employees. Distribute educational materials, e.g., posters and
Facilities
pamphlets, to each municipal facility by the end of Year 2.
handling areas?
Once weekly and after all rain events utilizing a checklist for the
8. Have you developed and implemented a stormwater management training program commensurate with each
inspection that documents findings and allows staff to compare
Increase Inspection Frequency of Maintenance Yard
to previous inspections.
® Yes ❑ No
Develop facility inventory in year 1 of City -owned properties and
® Yes ❑ No
buildings including the compost site, HHW site and maintenance
Facility Inventory
yard . Consider other city-owned facilities to inventory in year 2.
In year 1, develop procedures for determining TSS and TP
treatment effectiveness of city -owned ponds used for treatment
Pond Assessment Procedures & Schedule
of stormwater Implement schedule in year 2 — 5.
Page 16 of 17
5. Does discharge from your MS4 affect a Source Water Protection Area (Permit Part III.D.6.c.)? ® Yes ❑ No
a. If no, continue to 6.
b. If yes, the Minnesota Department of Health (MDH) is in the process of mapping the
following items. Maps are available at
http: / /www.health. state. mn. us /divs /eh /water /swp /maps /index.htm. Is a map including the
following items available for your MS4:
1) Wells and source waters for drinking water supply management areas identified as
❑ Yes ® No
vulnerable under Minn. R. 4720.5205, 4720.5210, and 4720.5330?
2) Source water protection areas for surface intakes identified in the source water
❑ Yes ® No
assessments conducted by or for the Minnesota Department of Health under the federal
Safe Drinking Water Act, U.S.C. §§ 300j — 13?
c. Have you developed and implemented BMPs to protect any of the above drinking water
❑ Yes ❑ No
sources?
6. Have you developed procedures and a schedule for the purpose of determining the TSS and
❑ Yes ® No
TP treatment effectiveness of all permittee owned /operated ponds constructed and used for the
collection and treatment of stormwater, according to the Permit (Part III.D.6.d.)?
7. Do you have inspection procedures that meet the requirements of the Permit (Part III.D.6.e.(1)-
❑ Yes ❑ No
(3)) for structural stormwater BMPs, ponds and outfalls, and stockpile, storage and material
handling areas?
8. Have you developed and implemented a stormwater management training program commensurate with each
employee's job duties that:
a. Addresses the importance of protecting water quality?
® Yes ❑ No
b. Covers the requirements of the permit relevant to the duties of the employee?
® Yes ❑ No
c. Includes a schedule that establishes initial training for new and /or seasonal employees and
® Yes ❑ No
recurring training intervals for existing employees to address changes in procedures,
practices, techniques, or requirements?
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Page 16 of 17
9. Do you keep documentation of inspections, maintenance, and training as required by the Permit ❑ Yes ❑ No
(Part III.D.6.h.(1) -(5))?
If you answered no to any of the above permit requirements listed in Questions 5 -9, then describe the tasks and
corresponding schedules that will be taken to assure that, within 12 months of the date permit coverage is extended,
these permit requirements are met:
F.6. We are currently examining methods for assessing ponds to determine TSS and TP effectiveness, as we
mentioned in our BMP table This study will develop procedures for determining TSS and TP treatment effectiveness of
city -owned ponds used for treatment of stormwater. A schedule will be implemented in year 2 — 5.
10. Provide the name or the position title of the individual(s) who is responsible for implementing and /or coordinating this
MCM:
Street and Maintenance Supervisor
*A complete MS4 SWPPP Application for Reauthorization (SWPPP Document) will be placed on public notice for a period of 30
days to provide the public the opportunity to review the permittee's stormwater pollution prevention program document (SWPPP
Document) and provide comment on the plan of the permittee to protect and improve water resources
VI. Compliance Schedule for Total Maximum Daily Load (TMDL) with an Applicable Waste
Load Allocation (WLA) (Part II.D.6.)
A. Do you have an approved TMDL with a Waste Load Allocation (WLA) prior to the effective date
of the Permit?
1. If no. continue to section VII.
2. If yes, fill out and attach the MS4 Permit TMDL Attachment Spreadsheet (wq- strm4 -49c)
with the following naming convention: MS4NameHere_TMDL
This form is found on the MPCA MS4 Program website: http: / /www.pca.state.mn.us /ms4.
*Additional guidance on completing the MS4 Permit TMDL Attachment Spreadsheet is
provided on the MS4 Permit Program website as veil
VII. Alum or Ferric Chloride Phosphorus Treatment Systems (Part II.D.7.)
A. Do you own and /or operate any Alum or Ferric Chloride Phosphorus Treatment Systems which
are regulated by this Permit (Part III.F.)?
1. If no, this section requires no further information.
2. If yes, you own and /or operate an Alum or Ferric Chloride Phosphorus Treatment System
within your small MS4, then you must submit the Alum or Ferric Chloride Phosphorus
Treatment Systems Form supplement to this document, with the following naming
convention: MS4NameHere TreatmentSystem.
This form is found on the MPCA MS4 Program website: http: / /www.pca.state.mn.us /ms4.
VIII. Add any additional comments to describe your program:
Fey Yes ❑ No
❑ Yes ❑ No
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