The recently issued National Pollutant Discharge Elimination System and State Waste Discharge General Permit for Discharges from Small Municipal Separate Storm Sewers in Eastern Washington, hereafter referred to as the Phase II Permit, outlines storm water program activities and implementation milestones that permittees must follow to comply with the federal Clean Water Act. All Phase II jurisdictions are expected to develop a Storm water Management Program (SWMP) that includes the required activities, implement those activities within the required timeframes of the permit term, and submit annual reports to the Washington State Department of Ecology (Ecology) by March 31st each year to document progress toward complete program implementation. The Phase II permit was issued by Ecology on January 17, 2007, and became effective on February 16, 2007. The permit covers a five-year period that expires on February 15, 2012. While the effective date of the Phase II permit is February 16, 2007, CWU’s official effective date is November 8, 2007—the date on which CWU was given notification of coverage under the Phase II permit by Ecology.
Eastern Washington Phase II Municipal Storm water Permit #WAR04-6205
Storm water Management Program Components
The Phase II Permit is broken down into six components, and the implementation and enforcement of the six components is collectively referred to as a municipality’s SWMP.
The six components are:
- Public Education and Outreach
- Public Participation and Involvement
- Illicit Discharge Detection and Elimination
- Construction Site Storm water Runoff Control
- Post-Construction Storm water Management for New Development and Redevelopment
- Pollution Prevention and Good Housekeeping for Municipal Operations
In addition to these six minimum elements, the NPDES Permit II also requires the following:
- Compliance with storm water provisions of approved Total Maximum Daily Loads (TMDLs);
- Monitoring and program evaluation; and
- Record keeping and annual reporting.
The SWMP is designed to reduce the discharge of pollutants from municipalities to the maximum extent practicable, to satisfy the state requirement to apply “All know, Available, and Reasonable methods of prevention, control and Treatment” (AKART) prior to discharge, and to protect water quality. The Phase II Permit requires that specified activities from each category above be completed each year in order to achieve full compliance by the end of the first permit term. The Implementation Plan developed for CWU details through a breakdown (matrices) the required annual NPDES activities. This detailed listing of annual required activities, will represent the plan that CWU will use to track permit elements that are due in any given year and make judgments about the resources needed to meet the requirements.
The Implementation Plan will aid in:
- Tracking program implementation;
- Preparing and updating CWU’s required NPDES Phase II SWMP; and
- Preparing and submitting required annual NPDES Phase II reports to Ecology.
1. Public Education and Outreach—Special Condition S6.D.1
CWU will develop and implement a Public Education and Outreach (PE&O) Program aimed at distributing educational material to their students and staff about the impacts of stormwater discharges to water bodies and the steps that can be taken to reduce pollutants in stormwater. CWU’s education and outreach information will address the following topics:
- Educational Information—How storm water runoff affects local waterbodies
- Proper Disposal of Hazardous Waste
- Landscaping Practices
- Alternative equipment washing practices, including lawnmowers, cars, and trucks,that minimize pollutants in storm water.
- Proper handling and disposal of wastes, including the location of hazardous waste collection facilities in the area;
- Hazards associated with illicit connections; and
- Benefits of litter control and proper disposal of pet wastes.
- CWU will label all storm drain inlets by the end of the permit term.
2. Public involvement and participation—Special Condition S6.D.2
The Public Involvement and Participation (PI&P) activities to be implemented by CWU include publishing a public notice in the local newspaper, soliciting public review of the SWMP, and making the latest version of the SWMP available to the public. All of these items are due in Year 5 of the permit term.
- Hold public meetings and solicit public review of the stormwater management plan.
- Develop a news release for the local newspaper on the jurisdictions stormwater program.
3. Illicit Discharge Detection and Elimination—Special Condition S6.D.3
CWU will develop, implement, and enforce a program to detect and eliminate illicit discharges into its MS4. This element of the SWMP requires that CWU: (1) develop and adopt appropriate policies that prohibit non-stormwater (illicit) discharges and illegal dumping; (2) develop and implement an enforcement plan to ensure compliance with the illicit discharge policies; (3) develop a map of the MS4, showing the location of all known storm drain outfalls, labeling the receiving waters, and delineating the areas contributing runoff to each outfall; (4) conduct field inspections and visually inspect for illicit discharges at all known outfalls; (5) develop procedures for characterizing illicit discharges, spills, or illegal dumping, and procedures for tracing and removing sources of illicit discharges; (6) develop and implement a spill response plan that includes coordination with a qualified spill responder; (7) provide adequate training for relevant staff; and (8) keep records of inspections and follow-up activities, staff training, and other related items.
- Illicit Discharge Policy
- CWU will comply with all relevant ordinances, rules, and regulations of the City of Ellensburg (City) that pertain to non-stormwater discharges.
- Storm Sewer Mapping
- Develop and implement a plan to detect and address non-stormwater discharged, including illegal dumping, to the MS4.
- Visually inspect for illicit discharges during dry weather at all known outfalls that discharge to surface waters.
- Spill response plan
- Train staff on spill and illicit discharge BMPs
- Best Management Practices
4. Construction Site Storm water Runoff Control—Special Condition S6.D.4
This element of the SWMP requires that CWU: (1) Comply with all ordinances, rules, and regulations of the City of Ellensburg that govern construction phase stormwater pollution prevention measures; (2) Obtain coverage under the General NPDES Permit for Stormwater Discharges Associated with Construction Activities for all applicable construction projects under the control of CWU; (3) Coordinate with the City regarding construction projects owned and operated by other entities that have the potential to discharge into CWU’s storm drain system to ensure that the City achieves compliance with its own ordinances; (4) Provide training to educate appropriate staff in erosion and sediment control best management practices (BMP’s) and requirements; and (5) Coordinate with Ecology and the City to provide access for inspection of construction sites or other land disturbances during the active grading and/or construction period.
5. Post-Construction Storm water Management for New Development and Redevelopment—Special condition S6.D.5
This element of the SWMP requires the CWU: (1) comply with all ordinances, rules and regulations of the City that govern post-construction stormwater pollution prevention measures; and (2) coordinate with the City regarding projects owned and operated by other entities that have the potential to discharge into CWU’s storm sewer lines to ensure that the City achieves compliance with its own ordinances.
6. Pollution Prevention and Good Housekeeping for Municipal Operations—Special Condition S6.D.6
CWU will develop and implement a municipal operation and maintenance (O&M) plan to minimize stormwater pollution from activities conducted by the university. The O&M Plan will include appropriated pollution prevention and good housekeeping (PP&GH) procedures for various university operations, activities, and/or facilities. The O&M Plan shall include a schedule of inspections and recordkeeping requirements. CWU will develop and implement a formal training program for all staff whose job functions may impact stormwater quality. CWU will prepare and submit an annual report to Ecology. The report must include the most current version of CWU’s SWMP and status of compliance with the various conditions in the permit. The annual report must include: (1) the status of implementation of each SWMP component; (2) an assessment of CWU’s progress in meeting the minimum performance standards; (3) a summary of CWU’s evaluation of their SWMP; (4) if applicable, notification that CWU is relying on another governmental agency to satisfy any of the obligations under the permit; and (5) other reporting requirements.