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HomeMy WebLinkAbout6.d. Authorization for submittal of the MS4 SWPPP Application for Reauthorization 4 ROSEMOUNT EXECUTIVE SUMMARY CITY COUNCIL City Council Meeting: December 3, 2013 AGENDA ITEM: Authorization for submittal of the MS4 AGENDA SECTION: SWPPP Application for Reauthorization Consent PREPARED BY: Andrew J. Brotzler, PE, Director of% •lic AGENDA NO. d, Works/City Engineer ATTACHMENTS: Application APPROVED BY: RECOMMENDED ACTION: Authorize the submittal of the MS4 SWPPP Application for Reauthorization. ISSUE Attached for City Council's review and consideration is the draft MS4 SWPPP Application for Reauthorization that is due December 2013, 150 days from the permit reissuance date of August 1, 2013. BACKGROUND At the August 12, 2013 Utility Commission meeting,the Commission authorized the preparation of the MS4 SWPPP Application for Reauthorization for the NPDES/SDS General Small Municipal Separate Storm Sewer System (MS4) Permit MNR040000. • The MS4 permit is mandated and administered by the Minnesota Pollution Control Agency. • The permit requirements address federal regulations for stormwater management and discharges. • The original 5-year MS4 permit issued by the MPCA in 2006 expired in 2011. Communities have been operating under the original expired permit since this time. • This application for reauthorization is for a 5-year permit that was reissued by the MPCA on August 1, 2013. • Main issues addressed by the MPCA in the permit include the following: o Impaired waters and total maximum daily loads o Construction stormwater erosion and sediment control o Post construction best management practice (BMP) operation and maintenance o System mapping o Non-degradation o Minimum control measures for education • The draft application was reviewed by the Utility Commission and its November 18th meeting. • The Utility Commission adopted a motion recommending City Council authorization for submittal of the application. Following the submittal of the reauthorization form, a scope will be developed for the preparation of an implementation plan to be initiated in early 2014. G:\MS4 Permit\20131203 CC Authorize Submittal of MS4 SWPPPP Application for Reauthorization.docX SUMMARY Staff and the Utility Commission recommend City Council authorize the submittal of the MS4 SWPPP Application for Reauthorization. 2 MS4 SWPPP Application for Reauthorization 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 Instructions: This application is for authorization to discharge stormwater associated with Municipal Separate Storm Sewer Systems No fee (MS4s) under the National Pollutant Discharge Elimination System/State Disposal System (NPDES/SDS) Permit Program. is required with the submittal of this application. Please refer to “Example” for detailed instructions found on the Minnesota Pollution Control Agency (MPCA) MS4 website at http://www.pca.state.mn.us/ms4. Submittal: MS4 SWPPP Application for Reauthorization Thisform must be submitted electronically via e-mail to the MPCA at ms4permitprogram.pca@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. Questions: Contact Claudia Hochstein at 651-757-2881 or claudia.hochstein@state.mn.us, Dan Miller at 651-757-2246 or daniel.miller@state.mn.us, or call toll-free at 800-657-3864. General Contact Information (*Required fields) MS4 Owner (with ownership or operational responsibility, or control of the MS4) *MS4 permittee name: City of Rosemount *County: Dakota (city, county, municipality, government agency or other entity) *Mailing address: 2875 - 145th St. W *City: Rosemount *State: MN *Zip code: 55068-4997 *Phone 651-322-2022 *E-mail: andy.brotzler@ci.rosemount.mn.us (including area code): MS4 General contact (with Stormwater Pollution Prevention Program [SWPPP] implementation responsibility) *Last name: Brotzler *First name: Andrew (department head, MS4 coordinator, consultant, etc.) *Title: City Engineer th *Mailing address: 2875 - 145 St. W *City: Rosemount *State: MN *Zip code: 55068-4997 *Phone 651-322-2022 *E-mail: andy.brotzler@ci.rosemount.mn.us (including area code): Preparer information (complete if SWPPP application is prepared by a party other than MS4 General contact) Last name: Alms First name: Bill (department head, MS4 coordinator, consultant, etc.) Title: WSB & Associates Mailing address: 701 Xenia Ave South Suite 300 City: Minneapolis State: MN Zip code: 55416 Phone (763) 231-4845 E-mail: walms@wsbeng.com (including area code): Verification 1. I seek to continue discharging stormwater associated with a small MS4 after the effective date of this Permit, and shall MS4 SWPPP Application for Reauthorization submit this form, in accordance with the schedule in Appendix A, Table 1, with the SWPPP document completed in accordance with the Permit (Part II.D.). Yes 2. I have read and understand the NPDES/SDS MS4 General Permit and certify that we intend to comply with all requirements of the Permit. Yes www.pca.state.mn.us • 651-296-6300 • 800-657-3864 • TTY 651-282-5332 or 800-657-3864 • Available in alternative formats wq-strm4-49a • 5/31/13 Page 1 of 17 Certification (All fields are required) I certify under penalty of law that this document and all attachments were prepared under my direction or supervision Yes - in accordance with a system designed to assure that qualified personnel properly gathered and evaluated the information submitted. I certify that based on my inquiry of the person, or persons, who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of civil and criminal penalties. This certification is required by Minn. Stat. §§ 7001.0070 and 7001.0540. The authorized person with overall, MS4 legal responsibility must certify the application (principal executive officer or a ranking elected official). By typing my name in the following box, I certify the above statements to be true and correct, to the best of my knowledge, and that this information can be used for the purpose of processing my application. Name: (This document has been electronically signed) Title: Date : (mm/dd/yyyy) Mailing address: City: State: Zip code: Phone E-mail: (including area code): Note: The application will not be processed without certification. www.pca.state.mn.us • 651-296-6300 • 800-657-3864 • TTY 651-282-5332 or 800-657-3864 • Available in alternative formats wq-strm4-49a • 5/31/13 Page 2 of 17 Stormwater Pollution Prevention Program Document I. Partnerships: (Part II.D.1) regulated small MS4(s) A. List the 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 Dakota County; Partner with Dakota County (SWCD) for providing educational opportunities/materials. MCM 1 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 MS4NameHere_Partnerships. convention: 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 yes: 1. If type a. Check which of regulatory mechanism(s) your organization has (check all that apply): Ordinance Contract language Policy/Standards Permits Rules Other, explain: 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: City Code: Title 10 -> Chapter 2 -> Sec. 10-2-6.Discharge Prohibitions Direct link: http://sterlingcodifiers.com/codebook/index.php?book_id=452&section_id=534716 Check here if attaching an electronic copy of your regulatory mechanism, with the following file naming MS4NameHere_IDDEreg. convention: no: 2. If 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: www.pca.state.mn.us • 651-296-6300 • 800-657-3864 • TTY 651-282-5332 or 800-657-3864 • Available in alternative formats wq-strm4-49a • 5/31/13 Page 3 of 17 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 yes: 1. If type a. Check which of regulatory mechanism(s) your organization has (check all that apply): Ordinance Contract language Policy/Standards Permits Rules Other, explain: 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: City Code: Title 10 -> Chapter 1 -> Sec. 10-1-12. Erosion and Sediment Control City Code: Title 10 -> Chapter 2 -> Sec. 10-2-8. Industrial or Construction Activity Discharges City of Rosemount Engineering Guidelines City of Rostmount General Specifications GR-15, GR-16 & SP-23 Direct link: http://sterlingcodifiers.com/codebook/index.php?book_id=452&section_id=168860 http://sterlingcodifiers.com/codebook/index.php?book_id=452&section_id=534718 http://www.ci.rosemount.mn.us/DocumentCenter/Home/View/72 http://www.ci.rosemount.mn.us/DocumentCenter/View/636 Check here if attaching an electronic copy of your regulatory mechanism, with the following file naming MS4NameHere_CSWreg. convention: 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 the MS4 Permit)? Yes No yes If you answered to the above question, proceed to C. no If you answered to either of the above permit requirements listed in A. or 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: The City's construction site stormwater runoff control requlatory mechnaism will be updated to be at least as strigent as the MPCA CSW permit. This effort will completed within 12 months of the date permit coverage is extended. yesno C. Answer or 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. 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 no If you answered 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: www.pca.state.mn.us • 651-296-6300 • 800-657-3864 • TTY 651-282-5332 or 800-657-3864 • Available in alternative formats wq-strm4-49a • 5/31/13 Page 4 of 17 Post-construction stormwater management A. Do you have a regulatory mechanism(s) to address post-construction stormwater management activities? Yes No yes: 1. If type a. Check which of regulatory mechanism(s) your organization has (check all that apply): Ordinance Contract language Policy/Standards Permits Rules Other, explain: 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: City Code: Title 10 -> Chapter 1 -> 10-1: Surface Water Management City of Rosemount Engineering Guidelines Direct link: http://sterlingcodifiers.com/codebook/index.php?book_id=452&chapter_id=19762 http://www.ci.rosemount.mn.us/DocumentCenter/Home/View/72 Check here if attaching an electronic copy of your regulatory mechanism, with the following file naming MS4NameHere_PostCSWreg. convention: yesno B. Answer or 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.): Site plan review: 1. Requirements those 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. Conditions for post construction stormwater management: 2. 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 (TP). 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. Stormwater management limitations and exceptions: 3. 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. Yes No 2) Restrict the use of infiltration techniques to achieve the conditions for post-construction www.pca.state.mn.us • 651-296-6300 • 800-657-3864 • TTY 651-282-5332 or 800-657-3864 • Available in alternative formats wq-strm4-49a • 5/31/13 Page 5 of 17 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. 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. Mitigation provisions: 4. 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 upstream 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 site features that are implemented to comply with the Permit (Part III.D.5.a(2)). If site configurations or structural stormwater BMPs change, causing decreased structural stormwater BMP effectiveness, new or improved structural stormwater BMPs must be implemented to ensure the conditions for post-construction stormwater management in the Permit (Part III.D.5.a(2)) continue to be met. www.pca.state.mn.us • 651-296-6300 • 800-657-3864 • TTY 651-282-5332 or 800-657-3864 • Available in alternative formats wq-strm4-49a • 5/31/13 Page 6 of 17 no If you answered 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.3.a.1: The City will amend the ordinance and/or City Design Standards to include prohibiting the use of infiltration techniques for post-construction stormwater management as described in the Permit (Part III.D.5.a(3)(a).1). The ordinance will be amended on the same schedule as the items in B.2.a and B.2.b. B.3.a.2: The City will amend the ordinance and/or City Design Standards to include restricting the use of infiltration techniques for post-construction stormwater management as described in the Permit (Part III.D.5.a(3)(a).2). This will occur on the same schedule as the items above. B.3.a.3: The City will amend the ordinance and/or City Design Standards to include the exceptions for linear projects as described in the Permit (Part III.D.5.a(3)(b)). This will occur on the same schedule as the items above. B.4.a.: The City will amend the ordinance and/or City Design Standards to include order of preference for selecting mitigation project areas as described in the Permit (Part III.D.5.a(4)(a)). This will occur on the same schedule as the items above. B.4.b.: The City will amend the ordinance and/or City Design Standards to include requirements for the creation of mitigation projects as described in the Permit (Part III.D.5.a(4)(b)). This will occur on the same schedule as the items above. B.4.c.: The City will amend the ordinance and/or City Design Standards to include the restriction from using routine maintenance of structural BMPs to meet the requirements for mitigation projects as described in the Permit (Part III.D.5.a(4)(c)). This will occur on the same schedule as the items above. B.4.d.: The City will amend the ordinance and/or City Design Standards to include the requirement to complete mitigation projects within 24 months after the start of the original construction activity as described in the Permit (Part III.D.5.a(4)(d)). This will occur on the same schedule as the items above. B.4.e.: The City will amend the ordinance and/or City Design Standards to include the requirement to determine, and document, who will be responsible for long-term maintenance on all mitigation projects as described in the Permit (Part III.D.5.a(4)(e)). This will occur on the same schedule as the items above. B.4.f.: The City will amend the ordinance and/or City Design Standards to mandate that money received from an owner/operator of construction activity, in lieu of meeting the conditions for post-construction stormwater management, shall be used for a public stormwater project as described in the Permit (Part III.D.5.a(4)(f)). This will occur on the same schedule as the items above. B.5.a.: The City will amend the ordinance and/or City Design Standards to include the requirement to allow the permittee to conduct inspections, perform maintenance, and assess maintenance cost of structural stormwater BMPs not owned or operated by the permittee as described in the Permit (Part III.D.5.a(5)(a)). This will occur on the same schedule as the items above. B.5.b.: The City will amend the ordinance and/or City Design Standards to include conditions that require maintenance responsibility for structural stormwater BMPs through transfer of ownership as described in the Permit (Part III.D.5.a(5)(b)). This will occur on the same schedule as the items above. B.5.c.: The City will amend the ordinance and/or City Design Standards to include conditions to address BMP modification in the future as described in the Permit (Part III.D.5.a(5)(c)). This will occur on the same schedule as the items above. 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 yes 1. If , attach them to this form as an electronic document, with the following file naming MS4NameHere_ERPs. convention: no 2. If , 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: B. Describe your ERPs: http://sterlingcodifiers.com/codebook/index.php?book_id=&section_id=534723 The current ERPs are included in the following City Codes: Section 10-2-13 thru 10-2-20 Title 10 -> Chapter 2 -> Enforcement, Appeal of Notice of Violation, Enforcement Measure After Appeal, Cost of Abatement of the Violation, Legal Action, Compensatory Action, Nuisance, and Criminal Prosecution for Stormwater System Chapter violations. Section 10-1-14; Penalty for Surface Water Management Chapter violations. The City Code includes the following enforcement mechanisms: www.pca.state.mn.us • 651-296-6300 • 800-657-3864 • TTY 651-282-5332 or 800-657-3864 • Available in alternative formats wq-strm4-49a • 5/31/13 Page 7 of 17 - Notice of Violation - Public Nuisance - Misdemeanors - Stop work orders IV. Storm Sewer System Map and Inventory: (Part II.D.4.) A. Describe how you manage your storm sewer system map and inventory: New developments are required to provide electronic as-build data in accordance with the GIS Information Requirements located in the City Design Standard. The City GIS specialist updates and maintains all of the City's GIS Information. yesno B. Answer or to indicate whether your storm sewer system mapaddresses 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 no If you answered 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: yesno C. Answer or 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. yesno D. Answer or 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. yes If you have answered 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. no If you answered 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: yesno E. Answer or 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: http://www.pca.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_inventory . no, If you answered the inventory form must be submitted to the MPCA MS4 Permit Program within 12 months of the date permit coverage is extended. 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 www.pca.state.mn.us • 651-296-6300 • 800-657-3864 • TTY 651-282-5332 or 800-657-3864 • Available in alternative formats wq-strm4-49a • 5/31/13 Page 8 of 17 selected stormwater-related issue(s) of high priority to the permittee during this permit term. Describe your current any high-priority topics included educational program, including : The public education program has been developed to distribute educational materials to the community or conduct equivalent outreach activities. The BMPs identified will focus on the impact of storm water discharges on streams, rivers, and wetlands, and the steps that the public can take to reduce pollutants in storm water runoff. 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 Measurable Goals Guidance for Phase II Small MS4s BMPs. Refer to the U.S. Environmental Protection Agency’s (EPA) (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 The City will provide stormwater education and outreach programs for residents within the City. The City will complete and outline of the education program and implementation Education Activity Implementation Plan schedule for the upcoming permit year by June 30th. The City updates their web page by providing information on high priority storm water pollution prevention topics and effects of illicit discharge to City residents and business owners. The goal will be to add new material as it becomes available and City Web Page record the number of website hits annually. City staff will develop then distribute stormwater related articles in the City newsletter. This goal will be met by distributing a minimum of two storm water related articles in the City City Newsletter newsletter each year. The City will continue to implement the WHEP contingent upon Wetland Health Evaluation Program (WHEP): available City funding. The City will collaborate and coordinate the development and implementation of the City’s educational activities schedule with Coordination of Education Program the Dakota SWCD and VRWMO BMP categories to be implemented Measurable goals and timeframes 3. Provide the name or the position title of the individual(s) who is responsible for implementing and/or coordinating this MCM: City Engineer / Public Works Coordinator 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 current program, as necessary, and continue to implement a public participation/involvement program to solicit public input on the SWPPP. Describe your current program: Under this minimum control measure, the City provides measures to receive public input and opinion on the adequacy of the SWPPP. This input can be received from public meetings, oral testimony, and written correspondence. 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. Measurable Goals Guidance for Phase II Small MS4s Refer to the EPA’s (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 Provide public notice of meeting to provide input on the SWPPP Comply with Public Notice Requirements in accordance with City public hearing notification requirements. www.pca.state.mn.us • 651-296-6300 • 800-657-3864 • TTY 651-282-5332 or 800-657-3864 • Available in alternative formats wq-strm4-49a • 5/31/13 Page 9 of 17 Hold annual public meeting combined with City Council Meeting or other public participation/involvement event to solicit public Annual Meeting input on the SWPPP. The City will conduct a public meeting and host a web page on the City’s Storm Water Pollution Prevention Program. City staff will respond to all public comments and statements received from the public meeting, and document any proposed changes to the SWPPP for final approval by City Engineer (if applicable). The goal of this BMP will be met by documenting all written and oral input into the record of decision and submitted in Consider Public Input conjunction with the annual report to the MPCA. 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. 3. Do you have a process for receiving and documenting citizen input? Yes No no If you answered 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: City Engineer / Public Works 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: The City has an ordinance that prohibits illicit discharges and connections. City Staff and public works employees are trained to look for any signs of an illicit discharge while on the job. ERPs (linked) guide what actions the City can take after an illicit discharge has been identified. 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). no If you answered 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.b.The City will incorporate procedures into the IDDE program for detecting and tracking the source of illicit discharges www.pca.state.mn.us • 651-296-6300 • 800-657-3864 • TTY 651-282-5332 or 800-657-3864 • Available in alternative formats wq-strm4-49a • 5/31/13 Page 10 of 17 using visual inspections as described in the permit (Part III.D.3.d). Procedures will be in place within 12 months following the date permit coverage is extended.. C.2.d.The City will incorporate procedures into the IDDE program for prioritization of areas likely to have illicit discharges as described in the permit (Part III.D.3.f). Procedures will be in place within 12 months following the date 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 Measurable Goals Guidance for Phase II Small MS4s BMPs. Refer to the EPA’s (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 The goal of this BMP will be met by annually updating changes Storm Sewer System Mapping to the City’s storm sewer system map. The City will review and update (as necessary) the City’s ordinance to prohibit illicit and non-stormwater discharges into the City’s storm sewer and surface/ground waters. The goal of this BMP will be met by reviewing existing city ordinances and Illicit Discharge Detection and Elimination (IDDE) and implementing updates related to illicit/non-stormwater Enforcement Ordinance discharges (if necessary). The City will develop and implement a program to detect and reduce non-stormwater discharges, including illegal dumping. Procedures for detection may consist of visual inspections for non-stormwater discharges on City owned land and private property (as requested). Inspection frequency may be conducted concurrent with the outfall inspections and implementation schedule of the public works activities. The City will notify the MPCA state duty officer of any Illicit Discharge Detection and Elimination (IDDE) hazardous material spills or discharges (within 24 hours of Program receipt, if applicable, per NPDES Phase II requirements). BMP categories to be implemented Measurable goals and timeframes Develop written procedures for illicit discharge inspections, investigations, and response actions. Develop a process to document information as described in the Permit (Part III.3.h) within 12 months following the date permit coverage is IDDE Program Updates extended. In Year 1, the City will map out areas that are identified as high-priority outfalls and around high-risk establishments (fast food restaurants, dumpster, car washes, mechanics, and oil changes.) in years 2-5, the City will those integrate those sites Illicit Discharge Inspections into its annual inspection MS4 activities. As needed, City staff or a consultant will be used to televise a section of the sewer system, collect grab samples or perform other effective testing procedures to find illicit connection Illicit Discharge Investigation identified in the system. 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 No no If you answered , 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: 5. Provide the name or the position title of the individual(s) who is responsible for implementing and/or coordinating this MCM: Public Works Supervisor 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 www.pca.state.mn.us • 651-296-6300 • 800-657-3864 • TTY 651-282-5332 or 800-657-3864 • Available in alternative formats wq-strm4-49a • 5/31/13 Page 11 of 17 revise their current program, as necessary, and continue to implement and enforce a construction site stormwater runoff control program. Describe your current program: The City requires 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. The enginering and building inspectionis department are primarly responsible for checking compliance with construction site ESC plans. 2. 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’sgeneral Discharge Stormwater Associated with Construction Activity No. MN R100001 permit to ? c. Does your program include written procedures for receipt and consideration of reports of 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 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 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. D.2.d., City will develop written procedures for conducting site ESC inspections as described in the Permit (Part III.D.4.d). Procedures will be in place within 12 months following the date 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 Measurable Goals Guidance for Phase II Small MS4s and/or maintain the BMPs. Refer to the EPA’s If you have more than five categories (http://www.epa.gov/npdes/pubs/measurablegoals.pdf). , hit the tab key after the last line to generate a new row. Established BMP categories Measurable goals and timeframes The City will annually review and update (as necessary) the City’s erosion control ordinance. The Erosion and Sediment Control Ordinance was approved in Construction Site Stormwater Runoff Ordinance November 2007. City staff will continue to implement and enforce the construction site inspection program for erosion control on construction sites one acre or larger. Construction Site Erosion and Sediment Control The goal of this BMP is to document the number of site Inspections inspections conducted annually. The goal will be met by enforcing the NPDES Phase II permit requirements through the City’s construction site inspection Waste Controls for Construction Site Operators program. The City will require every applicant for a building permit, subdivision approval, or grading permit that disturbs one acre or more to submit a project specific stormwater management plan (if applicable). This goal will be met by only issuing City permits Construction Site Plan Review to applicants that have submitted project specific stormwater www.pca.state.mn.us • 651-296-6300 • 800-657-3864 • TTY 651-282-5332 or 800-657-3864 • Available in alternative formats wq-strm4-49a • 5/31/13 Page 12 of 17 management plans (if applicable). The City will establish a phone line and web page links for the Establishment of Procedures for the Receipt and public to report potential construction site erosion control and Consideration of Reports of Stormwater waste disposal infractions. The goal of this BMP will achieved by Noncompliance completing the timeline/implementation. The City will inspect construction sites for conformance to NPDES construction permit standards and applicable City Establishment of Procedures for Site Inspections and standards. This goal will be met by enforcing the City’s erosion Enforcement control and waste disposal standards. BMP categories to be implemented Measurable goals and timeframes Update the City Grading, Building, and ROW permits and Construction Site Stormwater Runoff ordinance to meet the new permit requirements within 12 months following the date permit Permit Update coverage is extended The City will develop a process to determine the frequency for inspecting high priority inspection sites (e.g., near sensitive Prioritize Inspections receiving waters, projects larger than 5 acres) Develop written procedures to improve tracking and archiving all plan review and inspection documents within 12 months Permit Application System following the date permit coverage is extended. 4. Provide the name or the position title of the individual(s) who is responsible for implementing and/or coordinating this MCM: City Engineer 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: The City has a surface water management ordinace to address storm water runoff from new development and redevelopment projects that disturb equal to or greater than one acre. This program insures that controls are in place that would prevent or minimize water quality impacts from development activities. 2. Have you established written procedures for site plan reviews that you will conduct prior to the start of Yes No construction activity? yesno 3. Answer or 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 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))? 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? no If you answered 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., The City will develop written procedures for documention of post-construciton stomwater management mitigation as described in the Permit (Part III.D.5.c.). Procedures will be in place within 12 months following the date 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 Measurable Goals Guidance for Phase II Small MS4s and/or maintain the BMPs. Refer to the EPA’s If you have more than five categories (http://www.epa.gov/npdes/pubs/measurablegoals.pdf). , hit the tab key after the last line to generate a new row. Established BMP categories Measurable goals and timeframes www.pca.state.mn.us • 651-296-6300 • 800-657-3864 • TTY 651-282-5332 or 800-657-3864 • Available in alternative formats wq-strm4-49a • 5/31/13 Page 13 of 17 The City will review and revise (if necessary, during the plan review process) permanent BMP designs and criteria for post- construction stormwater management associated with new development and redevelopment projects of one acre or more. The City will also actively look for non-structural opportunities where prudent and feasible. The goal of this BMP will be met if the City conducts plan reviews on new development and Site Plan Review Program redevelopment projects of one acre or more. Completed ordinance defining standards, review procedures and enforcement response procedures for erosion and sediment control at construction sites, and post construction Surface Water Management Ordinance runoff from new development and redevelopment in 2007. Completed SWMP in 2007 and ensured goals and policies were consistent with the NPDES General and Construction Stormwater Management Plan Permits. BMP categories to be implemented Measurable goals and timeframes Complete Ordinance updates for post construction runoff from new development and redevelopment Within 12 months of Update ordinance to meet new permit requirements extension of permit coverage. 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 12 months. 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 currently inspects its structural pollution control devices on an annual basis and inspects all of its outfalls, sediment basins and ponds every 5 years. 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 surface waters. The City sweeps streets once in the fall after leaf drop. Maintenance staff is trained 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 no 3. If you answered 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: F.3., The City will complete a facilities inventory as described in the Permit (Part III.D.6.a.). Inventory will be completed within 12 months following the date permit coverage is extended. 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 Measurable Goals Guidance for Phase II Small MS4s BMPs. For an explanation of measurable goals, refer to the EPA’s (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 The City will continue recording the frequency and miles of streets that are swept, per sweeping occurrence. The goal of this BMP will be met if the City conducts two street Street Sweeping sweeping occurrences per year. www.pca.state.mn.us • 651-296-6300 • 800-657-3864 • TTY 651-282-5332 or 800-657-3864 • Available in alternative formats wq-strm4-49a • 5/31/13 Page 14 of 17 Conduct one inspection of all City-owned ponds and outfalls prior to expiration date of this permit Annual inspection of 100% of structural pollution control devices Strom Sewer Inspection Program (Sumps, Water Quality Manholes, etc.) City staff will quarterly locate and inspect all exposed stockpiles and storage/material handling areas on City owned properties. All existing onsite BMP’s will be inspected for conformance to NPDES Phase II permit requirements. Any identified erosion Inspection of All Exposed Stockpile, Storage and control issues will be corrected and documented per NPDES Material Handling Areas Phase II standards. Based on storm sewer inspection findings determine if repair, replacement, or maintenance measures are necessary to ensure structures proper function and treatment effectiveness. Document annually number or structures repaired or scheduled Structural Stormwater BMP Maintenance Program for maintenance. The City will retain all records of inspection, maintenance, and corrective actions of the City’s stormwater system. The goal of Recording, Reporting, and Retention of All Inspections this BMP will be met if the City retains these records for a period and Responses to the Inspections of three years past the expiration of this permit. Evaluate inspection records and determine if inspection Evaluation of Inspection Frequency frequency needs to increase or decrease. The City will continue to annually review and adjust (if necessary) its current methods (as previously specified) of landscaping and lawn care maintenance. The City will annually document the results of the review. Success will be defined as annually reviewing and adjusting current practices if necessary Landscaping and Lawn Care Practices Review (if necessary). The City will record the annual activities of the salt distribution program. Success will be defined as adjusting current practices Road Salt Application Review as necessary. 1. The City will use the Minnesota Department of Health’s document “Evaluating Proposed Storm Water Infiltration Projects in Vulnerable Wellhead Protection Areas” (Draft-July 19, 2006) and other pertinent information as guidance in evaluating all infiltration projects within or adjacent to vulnerable DWSMA’s. 2. The City will prohibit the construction of the infiltration area or incorporate specific BMPs to reduce pollutants from infiltrating within vulnerable DWSMA’s. Evaluation of Proposed Storm Water Infiltration 3. The City will annually record the evaluation, denial, and Projects for Impacts within Source Water Protection implemented BMP’s, of all proposed infiltration projects within Areas and/or adjacent to vulnerable DWSMA’s. BMP categories to be implemented Measurable goals and timeframes Training focused on fertilizer application, pesticide/herbicide Park and Open Space Training Program application, and mowing discharge. Training focused on automotive maintenance program (automotive inspections and washing), spill cleanup training, hazardous materials training, building leak prevention and Fleet and Building Maintenance Training Program inspection training. Training focused on parking lot and street cleaning, storm drain Stormwater Systems Maintenance Training Program systems cleaning, road salt materials management Ensure that plans describing spill prevention and control procedures are consistent among all departments. Conduct annual spill prevention and response training sessions to all municipal employees. Distribute education materials to each Spill Prevention & Control Plans for Municipal Facilities municipal facility by the end of year 2. Develop facilities inventory to include potential pollutants as Facility Inventory each site. Create a map of all identified facilities. www.pca.state.mn.us • 651-296-6300 • 800-657-3864 • TTY 651-282-5332 or 800-657-3864 • Available in alternative formats wq-strm4-49a • 5/31/13 Page 15 of 17 In year 1, develop procedures for determining TSS and TP treatment effectiveness of city owned ponds use for treatment of Pond Assessment Procedures & Schedule stormwater. Implement schedule in year 2-5 5. Yes No Does discharge from your MS4 affect a Source Water Protection Area (Permit Part III.D.6.c.)? a. no If , continue to 6. b. yes If , 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. Yes No Have you developed and implemented BMPs to protect any of the above drinking water 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? 9. Do you keep documentation of inspections, maintenance, and training as required by the Permit Yes No (Part III.D.6.h.(1)-(5))? no Questions 5 – 9 If you answered to any of the above permit requirements listed in , thendescribe 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. The City will develop a procedure for assessing ponds to determine TSS and TP effectiveness as described in the Permit (Part III.D.6.d) 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 years 2 thru 5. F.7., The City will develop written procedures for inspection of structural stormwater BMPs, ponds and outfalls, and stockpile, storage and material handling areas as described in the Permit (Part III.D.6.f.). Procedures will be in place within 12 months following the date permit coverage is extended. F.8., The City will develop and implement a stormwater management training program commensurate with each employees job duties as described in the Permit (Part III.D.6.g.). Procedures will be in place within 12 months following the date permit coverage is extended. F.9., The City will developwitten procedures to document inspections, mainenance, and training as described in the Permit (Part III.D.6.h.). Procedures will be in place within 12 months following the date permit coverage is extended. 10. Provide the name or the position title of the individual(s) who is responsible for implementing and/or coordinating this MCM: City Engineer / Public Works Supervisor VI. Compliance Schedule for an Approved 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 Yes No of the Permit? www.pca.state.mn.us • 651-296-6300 • 800-657-3864 • TTY 651-282-5332 or 800-657-3864 • Available in alternative formats wq-strm4-49a • 5/31/13 Page 16 of 17 no 1. If , continue to section VII. yes 2. If , fill out and attach the MS4 Permit TMDL Attachment Spreadsheet with the following : MS4NameHere_TMDL. naming convention This form is found on the MPCA MS4 website: http://www.pca.state.mn.us/ms4. 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 Yes No are regulated by this Permit (Part III.F.)? no 1. If , this section requires no further information. yes 2. If , 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 MS4NameHere_TreatmentSystem convention: . This form is found on the MPCA MS4 website: http://www.pca.state.mn.us/ms4. VIII. Add any Additional Comments to Describe Your Program www.pca.state.mn.us • 651-296-6300 • 800-657-3864 • TTY 651-282-5332 or 800-657-3864 • Available in alternative formats wq-strm4-49a • 5/31/13 Page 17 of 17