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CITY OF
SHOREWOOD
5755 Country Club Road Shorewood, Minnesota 55331-8927 Tel (952) 474-3236 Fax (952) 474-0128
MEMORANDUM
TO:
Mayor and City Council
Craig Dawson, City Administrator
FROM:
Larry Brown, Director of Public Works
DATE:
April 24, 2003
RE:
National Pollutant Discharge Elimination System (NPDES) Phase II
First, proceeding without fIrst apologizing for the environmentalists out there who insist on attaching a
nondescript acronym to everything that they talk about, would be a crime. I often think when I read
these documents that there must be a small concrete bunker over in St. Paul that has a team of people
that dream up new acronyms. Now what would their title be? "Hello, I am an achronymologist." Or
perhaps one who goes offthe deep end would be an "achromaniac." For this, I wish that they
S-T-O-P!
Having vented, here are some defInitions that have been defIned by the EP A.
. EPA
. NPDES
. NPDES II
. MS4
. SWPPP
. BMP
Environmental Protection Agency
National Pollutant Discharge System (phase I)
National Pollutant Discharge System (Phase II)
Municipal Separate Storm Sewer Systems
Storm Water Pollution Prevention Program
Best Management Practices
In 1990 the Environmental Protection Agency promulgated Phase I of the National Pollutant Discharge
System under the Clean Water Act. Phase I permit coverage was to address (1) runoff generated from
medium and large municipal storm water systems generally serving populations of 100,000, or greater,
(2) any construction activity disturbing 5 acres of land or greater, and (3) ten particular categories of
industrial sites.
Generally speaking, permits were obtained from the Minnesota Pollution Control Agency for sites
greater than or equal to 5 acres. Reviews were performed for the design of proper erosion controls,
temporary sedimentation basins, and other Best Management Practices to minimize contamination of
downstream waters.
Mayor and City Council
NPDES IT Review
April 24, 2003
Page 2 of2
The Phase II program expands Phase I by requiring additional operators of municipal separate storm
sewer systems in urbanized areas, (systems less that 100,000 in population) and any construction
activities of small sites, (1 acre or greater in size) to adhere to a very rigorous program. Notice that
this program does not miss a drop. It includes the macro size of a city, to the micro size of a I-acre
site. Attachment 1 is an excerpt taken from the Environmental Protection Agency's web site that
provides an overview of the Phase IT program.
The plan required is very complicated. The first objective each city must meet is "To reduce pollution
to the maximum extent lJossible." This is a direct quote from the EPA. The issue becomes what or
who is to define the "maximum extent possible?" In addition, each municipality is to document and
file annually, with the EP A, a report that demonstrates that the City has achieved such an objective.
I encourage all that are curious to explore the Environmental Protection Agency's web site to begin to
grasp the magnitude of this program. Many cities have struggled in assembling such a program to
define, evaluate, and achieve measurable goals that they can certify annually that the City is doing the
maximum extent possible to reduce pollution.
While I apologize in advance for the volume of paper generated, it became difficult to abbreviate the
description of the program any further than what Mr. Willenbring, of WSB and Associates, has
assembled. Therefore, the next several pages are an excerpt that summarizes the various components
of the program.
As mentioned earlier, there is an annual (and perpetual) documentation phase of the program that is to
be filed with the Environmental Protection Agency that documents how the City is achieving the
defmed goals and objectives. I must give credit to Mr. Willenbring for arriving at goals that are
achievable, while condensing "this mass" into a form that is relatively clear to administrate.
This reporting system is included in the following pages. Once again, I apologize for the volume
generated. However, Staff felt that it was important for the City Council to review the objectives
defined in this program.
Staff will present the program at the work session on Monday night and seek any feedback the City
Council may have. Due to statutory filing requirements, the program will be on the May 12th, City
Council agenda for approval.
-1i
SHOREWOOD MS4 SWPPP
I.
INTRODUCTION
This Storm Water Pollution Prevention Program (SWPPP) has been prepared in conf~
with the National Pollutant Discharge Elimination System (NPDES), Phase IT RWesan.,J.~in
compliance with the provisions of the Clean Water Act, as amended, (33 U.S.C. 12S1Bt
SEQ; hereafter, the "Act"), 40 CFR 122, 123, and 124, as amended, ET SEQ; M",~
Statutes Chapters 115 and 116, as amended and Minnesota Rules, Chapter 700 1. The
urbanized area 90vered by this SWPPP is shown in Figure 1.
The goal of the National Pollutant Discharge Elimination System Permit is to restore and.
maintain the chemical, physical. and biological imegrity of waters of the state.througb.
management and treatment ofurban storm water runoff. The Department of Natural
Resources Wetland and Waters, and the wetlands identified in the Natiomd Wetland
Inventory located within the project area are shown in Figure 2. This program ~t1Utt
this be accomplished through the management of'Municipal Separate Storm SewerS"
(MS4s) through the preparation of a Storm Water Pollution Prevention Program (SWPPP).
The SWPPP identifies the goals and the Best Management Practices (BMPs) thatwillbe- .
undertaken to meet the requirements of the NPDES Phase IT rules. Measurable g_ha:ve
been established for each of the BMPs inc1udedin the SWPPP along with an ~
plan and the persons responsible for implementing the BMPs.
This SWPPP has been prepared to manage and minlml7.e the discharge of pollutants from
MS4s to the maximum extent practicable (MEP). This will be accomplished ~tbe
implementation of the BMPs outlined within this SWPPP. These BMh could be a
combination of education, maintenance, control techniques, system design and~
methods, and other such provisions that are appropriate to meet the requiremen1.J- of the
NPDES Phase IT permit. BMPs have been prepared to address each of the six ~
control measures as outlined in the rules. These six minimum control measurela:re:
1. Public education and outreach on storm water impacts.
2. Public participation and involvement
3. lliicit discharge detection and elimination.
4. Construction site runoff controL
5. Post construction stom1 water management in new development aftd.
redevelopment.
6. Pollution prevention/good housekeeping for municipal operations.
For each of these six minimum control measures, appropriate BMPs have. been idemifi-'
along with measurable goals, an implementation schedule, and the persons responsible to
complete each measure.
City of Shorewood
Municipal Sepanate Storm Sewer system Pollution Prevention ProJl'lllll -
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SHORE WOOD MS4 SWPPP
IT. MUNICIPAL SEPARATE STORM SEWER SYSTEM'EVAL1JATllUf
An evaluation of the storm8eW'er system was completed to determine,-thf: factors
affecting the Maximum Extent Practicable (MEP) standards set forth withiD.the'Nl'f'JlS
Phase II Rule. Factors which were used in developing the BMPs outlined iDthi.$WPPP
were as follows:
1. Sources of pollutants
2. Potential polluting activities'being conducted in tb.ewatershed
3. Sensitivity of receiving waters and wetlands within tbesystem
4. Intended uses of receiving waters
5. Local concerns and storm water issues
6. The size of the MS4, the available staff, and the'numherof~_
7. BMP implementation schedules
8. Ability to. finance storm water te1ated programs
9. Hydraulics aDd hydrology of the watershed
10. Geology
11. Ability to ~ and perform operation and maintena:nee offhe.MS4
12. Land uses \ '
13. Development and redevelopment expectations
14. Watershed characteristics
15. Organizational structure of the municipal operator \
An inventory of these factors and policies developed to manage water ~.withirJ.'
the City can be found in the City's Comprehensive Storm Water Manap..U".
(CSMP).
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In conformance with the requirements for the ,preparation of the Swppp, a~.r
non-storm water discharges were evaluated to determine if1:hey are sipitieant
contributors of pollutants. to thestonn sewer system. Non-storm water,~,"""
were evaluated include:
1. Flushing of municipal waterlines
2. Residential, commercial and agriculturallandscapeitrigation
3. Stream flow diversions
4. Groundwater outputs and rising elevations
5. Uncontaminated pumped ground water
6. Uncontaminated groundwater infiltration
7. Filtration backwash from municipal water treatment facility
8. Discharge offoundation drains into the MS4
9. Potable water soul'eedischarges
10. Condensation from air conditioning units
11. Car wa.qhing by individual residents
12. Discharges from the chlorinated swimmillg pools
13 . Wash water from street sweeping activities
14. . Water discharged from firefighting activities
City ofShorewood
Municipal Separate Storm Sewer system PoIlutioa PtevcntiOll Propam
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SHOREWOOD MS4 SWPPP
.'
These sources of non-stonn water inputs into the municipal separate storm sewer systcmt
were detennined Dot to be significant contributors of pollutants. Therefore, BMPs will
not be prepared to address these storm water discharges..
The City has developed this SWPPP. ' and lhe Best Management ~~. '. it, in. . an
.reSe h the goal ofreducm' gthe discharge of pollutants to e best ...
pract;ic . This SWPPP incorporates new activities and existing p . ces to develop a
I gram, designed to protect water quality as required by the Clean Water Act. The
BMPs included within this SWPPP, are the results of the City carefully and thoughtfully
evaluating the stonn water discharges within their jurisdiction.
ill. STORM WATER POLLUTION PREVENTION PROGRAM
MCM 1.0
PUBLIC EDUCATION AND OUTREACH
This Storm Water Pollution Prevention Program (SWPPP) outlines the Best ~
Practices (BMPs) which are appropriate for the City of Sborewood to control or ~
the pollutants in stonn water runoff to the maximum extent practicable. This SWPPP
was developed based on the factors previously discussed within the areas tributary to the
Municipal Separate Storm Sewer System.
The City of Shorewood reserves the right to amend and/or delete the describedBMPs
based on the availability of funding for this program. Furthermore, the City may
coordinate the responsibility of selected BMPs with other governing agencies, which
represent storm water watersheds within the City boundary.
Best Management Practices (BMPs) have been prepared for each of the six l11iftimum
control measures. A description of eacb BMP, an implementation schedule, mewm-'>le
goals that determine the success or benefit, and the person responsible to compIete_
BMP is included in Appendix A.
A description of the six minimum control measures and the BMPs which havo been
developed to meet the requirements of each minnnUtn control measure are ~.. the
following pages:
The public education program has been developed to distribute educational
materials to the community or conduct equivalent outreach activities. TheBMPs
identified will focus on the impact of storm water discharges on stleama, rivers,
and wetlands, and the steps that the public can take to reduce pollutalJ.tSiDstmm.
water runoff.
City ofShorewoO<l
Municipal Sepame Storm Sewer system Pollution Prevention Program .
,..;
These activities have been prepared to individually address each of them.
minimum control measures. For each minimum control measure, tb.eed.ucatiOl1
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SHOREWOOD MS4 SWPPP
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program identities the audience or audiences involved, ~<mal.~.' .....//
audience, activities used to reach educational.goals fOr eech, 8\Idi~' "
implementation plans, including responsible persons inel1atp. entiti-
responsible for given activities, andschedu1esand~~ mClll~IM:tI'taI,~
be used to determine success in reaching educatio1Utl goals. .
1) The City intends to produce and distribute infon:rJatiop.onillit;it
discharges, erosion, shoreline mAnagement,'~and ~ .
prevention and other applicable BMPs utilized in the swrPl^.TWJ, . .'
information may be distributed through City maitittgs, ~bm. '.
stuffing, and on the City website. '
The public education and outreach BMPs that will be undertaken. are:
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2) Incorporate public information on the SWPPPissues..iatb a~"'l'*:Ie .
on the City's website. The web pa.gewouldSJ*iicaD)' ~~;/
SWPPP, each minimum control measure, the.go81san4.~pI~qy
the City, provide links to BMPs, articles on each comro1 ~.....'
collect feedbick from site visitors.
3) Provide trainilig opportunities for City staffincluding et'llSioa~1, .
BMPs, good housekeeping, and pollution prevention. TraiDiIIt.....it".
could include, but are not limited to: . '.' ., .
a) MDIDOT Erosion Control Certification
b) Storm Water Polluti011 Prevention Program..W~.
c) Best Management Practices Workshops
d) Brochures and publications distributed to staff
4) Coordinate educational and outreach issues withcomt11unity~,...~
profit organizations, soil and water conservation 4istIictB,watcNt-" .
districts, watershed management Organi7.atiOns, schooldis1rictl,u.i~ty
of Minnesota Extension, county, regional, state, and :ftIieralp_m... .
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programs.
MCM 2.0 PUBUC PARTICIPATION AND INVOLVEMENT
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This minimum control measure requires that the City providemellSllNltorecli.,e
public input and opinion on the adequacy of the SWPPP. This. inputQlllbe .' .
received from public meetings, oral testimony, andwrittenCOl~-To
reach this goal, the City anticipates implementing the followinl JiMlt.:
1) Conduct an. annual public hearing on the City's .Storm Watatr..... .
Prevention Program and solicit opinion on the pia and, ~~
and oral input on the adequacy of the SWPP~.
City ofShorewood
Municipal Separate Storm Sewer system Pollution Prevaltion Pmanan
""6
SHOREWOOD MS4 SWPPP
2)
The City intends.to incorporate public information on SWPPP issues in.to
a separate page on the City's website. The web page would specifically
describe the SWPPP, each minimum control measure, the goals and
actions planned by the City, provide links to BMPs, articles on each
control measure, and collect feedback from site visitors.
MCM 3.0
ILLICIT DISCHARGE DETECTION AND ELIMINATION
A number ofBMPs have been developed to implement and enforce a prosramto
detect and eliminate illicit discharges into the municipal separate stormBeWer
system. These BMPs are:
1) Identify all City-owned storm sewer conveyances 24 inches or.....on a
storm sewer map. This will also identify all outfalls and dischargepc)iats
leaving the CitY. This map would be updated yearly to reflect cb.anaesor
additions to the storm sewer system.
2) Review the current storm water ordinance to evaluate it's effectiveness
toward illegal discharges.
3) Review City staff training in identifying and responding to illicit
discharges into municipal separate storm sewer system.
4) Continue to support County recycling program to discourage ill.
dumping by offering alternative uses for unwanted materials and drop-ofti
for household hazardous waste.
MCM 5.0
CONSTRUCTION SITE, STORM WATER RUNOFF CONTROL
A number ofBMPs have been developed and will be implemented and .woreed
to reduce pollutants and storm water runoff from construction activities with..land.
disturbances equal to or greater than one acre. These BMPs are: .
1) The City will review current erosion control ordinance and revise the
City's building permit to include construction site erosion and ~
control as part of the permit conditions. This erosion control ordinaaee
will also include sanctions to determine non-compliance with tJ:1epemrlt
and ordinances.
City ofShorewood
Municipal Separate Storm Sewer system Pollution Prevention Program .
'-7
2) Provide City Public Work staffwith training and proper location,
inspection, and installation of erosion control BMPs.
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,SHOREWOOD MS4 SWPPP
3)
Construction site inspection and enforcement will be in~;iIto..'.
activities of building inspectors. This will bean eftbrt'tO~_~
to MS4 from small construction activities.
MCM 6.0 POLLUTION PREVENTION/GOOD HOUSEKEEPING FOR
MUNICIPAL OPERATIONS
To meet the requirements of the pollution prevention and goodhol1ll~tbr
municipal operations. A number ofBMPs have been preparedinc1~."f .
following: " .
1) Continue to practice current municipal operations and J!lUU~
procedures within the City and update them to best prevent or reduce '> ','
pollutant runott.
2) Review the Cityts current practices and policies of road salt;~.'
The City will consider alternative products, calibration of ett.....lfi1t.'
inspection of vehicles and staff training to recb.1cepollutmts .~.'.mad;; ,
deicing activities.
3) Manage the Cityts current street sweepiDg,..aram,~f
improvements and implement changes toreduce'stotJa water,.........'
City ofShorewood
Municipal Separate $lonn Sewer system Pollutioa Prevauion Proaram '
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SHOREWOOD MS4 SWPPP
4) Manage the City's current landscaping and lawn-care practices, which
may include the use of fertilizers, pesticides, herbicides, lawn mowing,
grass clipping collection, mulching and composting, and developBMPs to
reduce storm water pollution.
5) Implement a program to incorporate BMPs for handling of equipmmt.and
hazardous materials used by City staff.
6) Manage storm sewer operation and maintenance program forthe.City.
Maintenance of the storm sewer system will include an annual~n
of the storm sewer system and a summary of the results.
7) Continue to follow spill response procedures, which include notifica1;ioo
numbers, responsible individuals, and procedures for minimizing the
potential contact of spill contents with storm water.
City of Shorewood
Municipal Separate Storm Sewer system Pollution Prevention Program
Pap 9
IV. BEST MANAGEMENT PRACTICES IMPLEMENTATION PLAN
Detailed descriptions of each pfthe BMPs contained within the SWPPP ate
provided in Appendix A. The individual responsible for each of the BMPs
outlined in Appendix A along with the anticipated completion date of each
activity are provided in Table 1.
;
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Produce and distribUte information'on
illicit discharges, erosion~l,
shoreline management, and other
swppp practices.
Establish website for residen~
business owners, and staff to receive
information, report violations and
. to SWPPP issues
swppp StaffT . . Provide training opportunities for City
rammg Staff on SWPPP.
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swppp Annual Public Hearina: Conduct one (1) DUblie .
Allow residents and'.business to
respond to SWPPP issues through the ~~~1OOs:
ci SWPPP website page,
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Create City stormsewarsystem map. Complelt.r'~March2008
SHOREWOOD MS4 8WPPP
Table 1
BMP IMPLEMENTATION PROGRAM
Brochures, Handouts, and
Newsletters
SWPPP Web Page
SWPPP Website
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Storm Sewer System Map and
Update
illegal Discharge Ordinance
Recycling Program
Develop illegal discharge ordinance.
Discourage illegal dumping by
offering drop-offs for hazardous
waste.
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Develop Erosion Control Ordinance
and review City's utililY ,ua:.mit.
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Erosion Control Ordinance
Public Works Department Staff
Trainina:
Train staff in BMPs.
Construction Site Inspection and
Enforcement Program.
Develop constroction site inspection
and enforcement program.
City of Shorewood
Municipal Separate Storm Sewer system Pollution Prevention Prosnun
A~__lQ'2004'" 2008
,
Begin irt2004t .~by..2009.
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2008.
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..'post.C~n$ftU~t:ioi1 Storlll,Water,n
... Mana cmleJ1tMeuures'
Storm Water Runoff Control
Program
... :*_i4r~~iili'
Reduce Pollutant Runoff from
Municipal Operations
Road Salt Application
Parking Lot and Street Sweeping
Pro
Landscaping and Lawn Care
Practices
Equipment and Hazardous
Material Storage
Storm Sewer Operation and
Maintenance Pro
Spill Response Prognun
SHOREWOOD MS4 SWPPP
Develop program to minimize runoff
within the City.
Evaluate municipal operations and
update. as needed to prevent/reduce
llutant runoff.
Revise City's road salt application
Evaluate current sweeping program.
Evaluate City's landscaping and lawn
care ractices.
Implement program and incorporate
BMPs for equipment and hazardous
material handlin .
Evaluate storm sewer operation and
maintenance ro for Ci .
Train staff in spill response procedures
City of Shorewood
Municipal Sepamte Storm Sewer system Pollution Prevention Program .
Annually
Annually
Annually
Annually
Annually
Annually
Annually
2003-2008
2003..2008
2,003..;2008
2003..2008
2003..2008
2003..2008
2003..2008
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SHOREWOOD MS4 SWPPP
V. ANNUAL REPORT
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An annual report will be prepared and submitted to the PCA,.pnor to.~.l"fk
each year from 2004 through 2008. This annual reportwi1l~tp4~..>,'
following: ' 'C .?:.>t~~;,~~~.~~~i~~~~~!~!.'.. '.
A. Status of~'Pli~ With Permit Conditions
The annual report will contain an assessment oftb.e appro~~the
BMPs and progress toward achieving the identified~"""i:Jr
each of the minimum control measures. This assessmerrt wiUbeh8se401l
results collected and analyzed, inspection findings, and'JNblicm,.>
received during ~ reporting period.
B. Work Plan
The annual report win contain a list of storm wateractiviti..... .
planning to be midertaken in the next reporting cycle. .. ".
c. Modifications to the.SWPPP
The annual te.port will identify BMPsor measurable goals for~~'" .....
minimum control measures. .
D. Notice ofC~ Activities
A notice. will be iDcluded in the annual report for any pPrti_of~'.' . .......
permit for which a government entity or OtpJt17Atioo: ou.tsideof~...~"'"
is being utilized .to fulfill any BMP contained in theSWPPP. ., .
City of Sborewood
Municipal SeparatAl Storm Sewer system PoIlutioo PreveDtioD Proaram
.,,""11
~
Mayor and City Council
NPDES II Review
April 24, 2003
Page 3 of3
:f
As mentioned earlier, there is an annual (and perpetual) documentation phase of the program that is to
be filed with the Environmental Protection Agency that documents how the City is achi~ving the
defined goals and objectives. I must give credit to Mr. Willenbring for arriving at . goals that. are
achievable, while condensing "this mass" into a form that is relatively clear to administrate.
This reporting system is included in the following pages. Once again, I apologize for. the volume
generated. However, Staff felt that it was important for the City Council to review. the . objectives
defined in this program.
Staff will present the program at the work session on Monday night and. seek any feedback.tbe..City
Council may have. Due to statutory filing requirements, the program will be on the May 12th. City
Council agenda for approval.
...
February 28,2003
Municipal Separate Storm Sewer System Program
Minnesota Pollution Control Agency
520 Lafayette Road North
St. Paul, MN 55155-4194
Re: Submittal of Annual Storm Water Prevention Program Report
for the City of Shorewood
To Whom.It May Concern:
Attached is a copy of the City of Shore wood Annual Storm Water Pollution Prevention
Program Report. This report is being submitted in conformance with the provisions of
the Clean Water Act, Minnesota Statutes to Chapters 115 and 116 as amended, and
Minnesota Rules Chapter 7001.
If you have any questions or comments concerning this annual report, please do not
hesitate to contact me.
Sincerely,
Larry Brown, Director of Public Works
City of Shorewood
F:\ WPWIN\NPDESPHASEIl\MS4s\Shorewood\Annual Report
#'
INTRODUCTION
This Annual Storm Water Pollution Prevention Program Report for the City of
Shorewood has been prepared in conformance with the City's Storm Water
Pollution Prevention Program and also to meet the provisions of the Clean Water
Act, Minnesota's Statutes Chapters 115 and 116, and Minnesota Rules Chapter
7001.
As required by these regulations, this annual report includes the following:
1. The status of the City's compliance with its permit conditions including an
assessment of the appropriateness of the Best Management Practices and
description of the progress made toward achieving the identified
measurable goals for each of the minimum control measures.
2. A gescription of the storm water activities that we intend to undertake
during the next reporting cycle.
3. A description of any proposed changes to the identified Best Management
Practices or measurable goals previously outlined in the City's Stonn
Water Pollution Prevention Program.
4. Provide notice if the City intends to change the Storm Water Pollution
Prevention Program over that previously submitted to expand reliance on
another entity to satisfy some of the permit obligations.
The following sections of the report provide more detailed discussion on each of
these reporting considerations.
n. REVIEW OF BEST MANAGEMENT PRACTICE IMPLEMENTATION
PROGRAM
The City of Shorewood developed a Best Management Practice Implementation
Program that addressed activities to be undertaken for each of the six minimum
control measures. A listing of each of the Best Management Practices, a
description of the goals associated with undertaking these Best Management
Practices, a listing of each of the persons responsible for the implementation and
the schedule for implementation are included on the attached Table 1.
In. ASSESSMENT OF ACTIVITIES COMPLETED
The City's Storm Water Pollution Prevention Program included undertaking a
number of Best Management Practices (BMP) (outlined in Table 1) to meet the
requirements of this permit. In order to track, and provide suitable documentation
regarding the implementation of each of these Best Management Practices, a
number of individuals at the City have been designated as being responsible to
make certain that each of the BMPs identified were implemented and that suitable
records were being kept to document that this implementation did take place.
F:\ WPWIN\NPDESPHASEII\MS4s\Shorewood\Annual Report
Appendix A of this docwnent provides a detailed description of each of the Best
Management Practices generally summarized in Table 1, along with
documentation for the describing specifics of the activities that were undertaken
in order to meet the intent of these Best Management Practices.
Based on a review of this documentation, it can be observed that the City
implemented all of the Best Management Practices outlined within the City's
Storm Water Pollution Prevention Program in the past year, and provided suitable
documentation attesting to this conclusion.,
IV. ASSESSMENT OF APPROPRIATENESS OF IDENTIFIED BEST
MANAGEMENT PRACTICES
Based on a review of the Best Management Practices that were implemented in
the past year, a review of the appropriateness of each of these Best Management
Practices has been completed. This review generally took into consideration the
results of inspection findings, public input, monitoring data, and/or other
information.
Based on this review and assessment of activities that have been undertaken in the
past year, the City is not proposing any changes to the identified Best
Management Practices, measurable goals, or other changes to the Storm Water
Pollution Prevention Program.
IV. ASSESSMEN'I' OF APPROPRIATENESS OF IDEN'I'IFIED BEST
MANAGEMEN'I' PRACTICES
Based on a review of the Best Management Practices that were implemented in
the past year, a review of the appropriateness of each of these Best Management
Practices has been completed. This review generally took into consideration the
results of inspection findings, public input, monitoring data, and/or other
information.
Based on this review and assessment of activities that have been undertaken in the
past year, we would propose the following changes in identified Best Management
Practices, measurable goals, or other changes to the Storm Water Pollution
Prevention Program to reflect this updated information that has been collected
over the past year.
1.
2.
3.
The attached summary Table 1 and associated detailed description of the Best
Management Practice has been modified to reflect the suggested changes to the
City's Storm Water Pollution Prevention Program.
F:\ WPWIN\NPDESPHASEIl\MS4s\Shorewood\Annual Report
"
v. NOTIFICATION THAT THE CITY INTENDS TO ADJUST PLAN TO
RELY ON OTHER ENTITIES TO MEET BMPS OUTLINED WITHIN
THE CITY'S STORM WATER PLAN
As required by the guidance documentation provided by the MPCA, please be
advised that at this time, the City is not proposing to change the current Storm
Water Pollution Prevention Program to rely on an entity other than the City.
II
Ji: NOTIFICATION THAT THE CITY INTENDS TO ADJUST PLAN TO RELY
ON OTHER ENTITIES TO MEET BMPS OUTLINED WITHIN THE CITY'S
STORM WATER PLAN
As required by the guidance documentation provided by the MPCA, please be
advised that we intend to modify the City's Storm Water Pollution Prevention
Program in the following ways to rely on an entity other than the City to satisfy
some of the permit obligations included within our current Storm Water Pollution
Prevention Program.
1.
2.
3.
F:\ WPWIN\NPDESPHASEII\MS4s\Shorewood\A.Mual Report
...
VI. SUMMARY
This annual Storm Water Pollution Prevention Report for the City of Shorewood
has been prepared in conformance with provisions of the Clean Water Act,
Minnesota Statutes Chapter 115 and 116 as amended, and Minnesota Ru1es
Chapter 7001.11 provides a review of the City's Best Management Practice
Implementation Program, an assessment of the activities that were completed in
the past year, a discussion of changes the City intends to make to this program in
the coming year, and generally defines the status of the City's compliance with
the conditions associated with its permit. This report has found that the City
believes it is in full compliance with the conditions of its NPDES Phase II Permit
for 2003 arid intends to proceed with the implementation of the Best Management
Practices outlined within its storm water pollution prevention program with any
amendments to it as outlined within this annual report for the coming year.
Any questions regarding implementation of this program may be directed to Larry
Brown, Director of Public Works, at the City of Shorewood.
F:\ WPWIN\NPDESPHASEU\MS4s\Shorewood\Annual Report
SHOREWOOD MS4 SWPPP
APPENDIX A
BEST MANAGEMENT PRACTICES
City of Shorewood
Stonn Sewer System Pollution Prevention Program - Municipal Separate Stann Sewer Systems
Page 13
BMPs
BROCHURES, HANDOUTS AND NEWSLETTERS 1.1
Minimum Control Measures Addressed by ThisBMP
X Public education and outreach
X Public participation and involvement
X Illicit discharge detection and elimination
BMP Description:
The City will produce and distribute articles and information on the City's Storm Water Pollution
Prevention Plan including information on the annual public hearing, illicit discharges, erosion control,
shoreline management, composting and pollution prevention and other applicable best management
practices. This publication will be distributed through City mailings and newsletters.
Education Goal: Timeline I Implementation Schedule:
This program is designed to develop an This activity will begin in 2003 and continue
understanding of the SWPPP among residents. annually through 2008.
X
X
X
Construction site runoff controls
],:lost-construction stormwater management
Pollution prevention! good housekeeping
Measurable Goals:
Document the number of publications and
households served by each publication.
Responsible Person:
Name: Larry Brown
Title: Public Works Director
Phone: 952-474-3236
E-mail: lbrown@ci.shorewood.mn.us
Audience:
This activity will be directed to City residents,
property owners, and business owners.
Recorded Activities Completed:
Outlined below is a description of the specific activities that were undertaken by the City over the
past year that document the City has met the measurable goals associated. with this BMP.
I hereby certify that the above activities were completed.
Signature of Responsible Official
Title
Date
BMPs
SWPPP STAFF TRAINING 1.2
Minimum Control Measures Addressed by This BMP
X Public education and outreach
Public participation and involvement
illicit discharge detection and elimination
BMP Description:
The Gty will provide training opportunities for Gty Staff in erosion control, best management practices,
good housekeeping, and pollution prevention. These may include but are not limited to: MnDOT erosion
control certification, SWPPP workshops, and Blv.1P workshops.
Education Goal: Timeline / Implementation Schedule:
The goal of this action is to introduce ideas and This activity will begin in 2003 and continue
develop an understanding of the SWPPP among annually through 2008.
Gty staff.
.---
X Construction site runoff controls
-P .
X ost-construction stormwater management
- .
X Pollution prevention/ good housekeeping
Measurable Goals:
The Gty will provide a minimum of one training
opportunity and document the number of training
sessions and the number of participants in
attendance.
Audience:
Gty Staff involved in public works projects,
construction projects, construction inspection,
and maintenance.
Responsible Person:
Name: Larry Brown
Title: Public Works Director
Phone: 952-474-3236
E-mail: lbrown@ci.shorewood.mn.us
Recorded Activities Completed:
Outlined below is a description of the specific activities that were undertaken by the City over the
past year that document the City has met the measurable goals associated with this BMP.
I hereby certify that the above activities were completed.
Signature of Responsible Official
Title
Date
BMPs
Swppp WEB PAGE 1.3
Minimum Control Measures Addressed by This BMP
X Public education and outreach X Construction site runoff controls
X Public participation and involvement X Post-construction stormwater management
X TIlicit discharge detection and elimination X Pollution prevention! good housekeeping
BMP Description:
The City will incorporate public information on SWPPP issues into a separate page on the City's Website.
This would specifically describe the SWPPP, each minimum control measure, the goals and actions
planned by the City, provide links to BMPS, articles on each control measure and collect feedback from
site visitors.
Education Goal: Timeline I Implementation Schedule:
The City will provide information on stormwater This activity will begin in 2004 and continue
pollution prevention, best management practices, the annually until 2008.
City SWPPP, and outside entity resources available
to City residents. Audience:
All City residents, property owners, and
Measurable Goals: business owners.
The City will develop a separate SWPPP web pa~ e
and document the number of publications produ ed.
..and. .e !l:..........Le... elf hits t"() tiLe ,,~b sitt..
Responsible Person:
Name: Larry Brown
Title: Public Works Director
Phone: 952-474-3236
E-mail: lbrown@ci.shorewood.mn.us
Recorded 1 ~ctivities Comoleted:
Outlined below is a description of the specifi activities that were undertaken by the City over the
past year that do~ent the City has met the measurable goals associated with this BMP.
I hereby certify that the above activities were COl j:lpleted.
Signature of Responsible Official Title Date
J
BMPs
ANNUAL PUBLIC MEETING 2.1 '"
Minimum Control Measures Addressed by This BMP
.--- Construction site runoff controls
X Public education and outreach
- Post-construction stormwater management
X Public participation and involvement
lllicit discharge detection and elimination - Pollution preventionf good housekeeping
BMP Description:
The City will conduct a public meeting on the City's Storm water Pollution Prevention Program; solicit
public opinion on the plan, and consider written and oral input into the SWPPP.
Measurable Goals: Timeline / Implementation Sched.ule:
Hold the public meeting, record attendance, keep This activity will be completed annually
minutes, record statements and written comments beginning in 2004 and continue through the life of
and document changes made to the SWPPP. this permit, 2008.
Responsible Person:
Name: Larry Brown
Title: Public Works Director
Phone: 952-474-3236
E-mail: lbrown@ci.shorewood.mn.us
Recorded Activities Completed
Outlined below is a description of the specific activities that were undertaken by the City over the
past year that document the City has met the measurable goals associated with this .BMP.
I hereby certify that the above activities were completed.
Signature of Responsible Official Title Date
BMPs
ILLICIT DISCHARGE ORDINANCE 3.1
Minimum Control Measures Addressed by This BMP
Public education and outreach
Public participation and involvement
X llIicit discharge detection and elimination
. BMP Description:
The City will develop an ordinance, which will address the issue of non-storm water discharges in the
City's Storm Sewer System. Elements of this ordinance will include but are not limited to defining
allowable discharges, setting policy as it pertains to violations and penalties and mitigation requirements.
Measurable Goals: Timeline I Implementation Schedule:
The City will prepare and adopt a stormwater system Draft ordinance 2005
illicit discharge ordinance. Pub~c comment period 2006
City council review 2006
Adopt ordinance 2006
Construction site runoff controls
Post-consh'Uction stormwater management
Pollution prevention{ good housekeeping
Responsible Person:
Name: Larry Brown
Title: Public Works Director
Phone: 952-474-3236
E-mail: lbrown@ci.shorewood.mn.us
Recorded Activities Completed
Outlined below is a description of the specific activities that were undertaken by the City over the
past year that document the City has met the measurable goals associated with this BMP.
I hereby certify that the above activities were completed.
Signature of Responsible Official
Title
Date
BMPs
RECYCLING PROGRAM 3.2
Minimum Control Measures Addressed by This BMP
X Public education and outreach
Public participation and involvement
X lllicit discharge detection and elimination
BMP Description:
The Gty or its designee will discourage illegal dumping by educating the public on alternative uses for
unwanted materials and providing drop-off sites for household hazardous waste. This BMP includes
providing information on recycling options, services, and programs within the City.
Measurable Goals: Timeline I Implementation Schedule:
The City will distribute recycling program literature This activity will be conducted and evaluated
to residents a minimum of one time annually. annually from 2004 -2008.
Construction site runoff controls
Post-construction stormwater management
Pollution prevention/ good housekeeping
Responsible Person:
Name: Larry Brown
Title: Public Works Director
Phone: 952-474-3236
E-mail: lbrown@ci.shorewood.mn.us
Recorded Activities Completed
Outlined below is a description of the specific activities that were undertaken by the City over the
past year that document the City has met the measurable goals associated with this BMP.
I hereby certify that the above activities were completed.
Signature of Responsible Official
Title
Date
BMPs
STORM SEWER MAP 3.3
Minimum Control Measures Addressed by This BMP
Public education and outreach
Public participation and involvement
X Illicit discharge detection and elimination
BMP Description:
The City currently has a map identifying all ponds, lakes, streams, storm sewer pipes and conveyances as
well as.outfalls and discharge points leaving City. As part of the SWPPP the City will annually update
this map to include changes to the storm sewer system through out the City including but not limited to,
new development, street improvements, water quality projects, wetland mitigation projects and any
changes to the storage or conveyance of water within the City.
r---
Construction site runoff controls
Post-construction stormwater management
Pollution prevention/ good housekeeping
f---
f--
Measurable Goals:
The City will map all storm sewer pipe owned by the
City and annually document changes in the storm.
sewer system.
Timeline I Implementation Schedule:
The City will conduct annual reviews of this
activity (2003-2008).
Responsible Person:
Name: Larry Brown
Title: Public Works Director
Phone: 952-474-3236
E-mail: lbrown@ci.shorewood.mn.us
Recorded Activities Completed
Outlined below is a description of the specific activities that were undertaken by the City over the
past year that document the City has met the measurable goals associated with this BMP.
I hereby certify that the above activities were completed.
Signature of Responsible Official
Title
Date
BMPs
EROSION CONTROL ORDINANCE 4.1
Minimum Control Measures Addressed by This BMP
Public education and outreach
Public participation and involvement
Illicit discharge detection and elimination
BMP Description:
The City will review their CUl'Tent permit review processes and include managing site erosion and
sediment control as part of the conditions of the permit. Staff will review current ordinances and City
codes and update as necessary.
x
Construction site runoff controls
Post-construction stormwater management
Pollutionpreventionl good housekeeping
Measurable Goals:
The City will review and update as necessary the
City's Erosion Control Ordinance.
Timeline I Implementation Sched.ule:
The City will review the current permit in 2004,
and add additional requirements in 2005.
The enforcement of new permit requirements
will be. in 2005 and last until 2008.
Responsible Person:
Name: Larry Brown
Title: Public Works Director
Phone: 952-474-3236
E-mail: lbrown@ci.shorewood.mn.us
Recorded Activities Completed
Outlined below is a description of the specific activities that were undertaken by the City over the
past year that document the City has met the measurable goals associated with this B:MP.
I hereby certify that the above activities were completed.
Signature of Responsible Official
Title
Date
BMPs
STAFF TRAINING 4.2
Minimum Control Measures Addressed by This BMP
Public education and outreach - Construction site runoff controls
X X
Public participation and involvement - Post-construction stormwater management
-
Illicit discharge detection and elimination X Pollution prevention/ good housekeeping
BMP Description:
The City will provide training to its staff on how to prevent soil erosion on a construction site, proper
erosion control, and review the components of the storm water pollution prevention plan (SWPPP)
annually with the staff.
Measurable Goals: Timeline I Implementation Schedule:
The City will hold a minimum of one training session a The City will begin documentation in 2004
year and document the number of employees with and continuing annually through 2008.
Mn/DOT certification, the number of workshops/
training sessions held, and keep attendance at each
workshop / training session.
Responsible Person:
Name: Larry Brown
Title: Public Works Director
Phone: 952-474-3236
E-mail: lbrown@ci.shorewood.mn.us
Recorded Activities Completed
Outlined below is a description of the specific activities that were undertaken by the City over the
past year that document the City has met the measurable goals associated with this BMP.
"::: :::~~~i~~ill~~:~1~i[~~~~ fjml~W~;j!l11~~~~~~r~l~ f4ir'~:: .:':.~~~~;:':.~~r..:~'!~~~~1c.ili~:
I hereby certify that the above activities were completed.
Signature of Responsible Official
Title
Date
BMPs
SURFACE WATER MANAGEMENT PLAN 5.1
Minimum Control Measures Addressed by This BMP
....- Public education and outreach Construction site runoff controls
I--
Public participation and involvement X Post-construction stormwater management
I-- Illicit discharge detection and elimination Pollution prevention/ good housekeeping
BMP Description:
The City currently has a Comprehensive Surface Water Management Plan. As part of this permit, the
City will review the policies, requirements and Best Management Practices included within this
document annually and will make amendments as necessary, as well as implement the plan.
Measurable Goals: Timeline I Implementation Schedule:
The City will implement the City's Surface Water The City will review its program annually
Management Plan and update the plan annually if beginning in 2003.
necessary.
Responsible Person:
Name: Larry Brown
Title: Public Works Dixector
Phone: 952-474-3236
E-mail: lbrown@ci.shorewood.mn.us
Recorded Activities Completed
Outlined below is a description of the specific activities that were undertaken by the City over the
past year that document the City has met the measurable goals associated with this BMP.
I hereby certify that the above activities were completed.
Signature of Responsible Official
. Title
Date
BMPs
DEVELOPMENT REVIEW 5.2
Minimum Control Measures Addressed by This BMP
Public education and outteach
Public participation and involvement
illicit discharge detection and elimination
BMP Description:
The City will continue to use existing development review policies currently in place to minimize the
negative impacts storm water runoff may have on water quality within the City. Utilizing these existing
policies, all development proposals must address water quality, water quantity, erosion control and site
grading, utilizing BMP's for each of these activities.
Measurable Goals:
The City will review new development plans for
conformance with BMF's outlined in the SWPPP and
document the number of development plans
l'eviewed annually.
Conscruction site runoff conttols
Post-consttuction stormwater management
Pollution prevention! good housekeeping
x
Timeline / Implementation Schedule:
The City will follow this activity annually 2003
through 2008.
Responsible Person:
Name: Larry Brown
Title: Public Works Director
Phone: 952-474-3236
E-mail: lbrown@ci.richfield.mn.us
Recorded Activities Completed
Outlined below is a description of the specific activities that were undertaken by the City over the
past year that document the City has met the measurable goals associated with this BMP.
I hereby certify that the above activities were completed.
Signature of Responsible Official
Title
Date
..
..
&EPA
Stonn Water Phase II
Final Rule
F act Sheet Series
Overview
1.0 - Storm Water Phase II Final
Rule: An Overview
Small MS4 Program
2.0 - Small MS4 Storm Water
Program Overview
2,1 - Who's Covered? Designation
and Waivers of Regulated Small
MS4s
2.2 ~ Urbanized Areas: Definition
and Description
Minimum Control Measures
2.3 - Public Education and
Outreach
2.4 - Public Participation!
Involvement
2.5 -Illicit Discharge Detection
and Elimination
2.6 - Construction Site Runoff
Control
2.7 - Post-Construction Runoff
Control
2.8 - Pollution Prevention/Good
Housekeeping
2.9 - Permitting and Reporting:
The Process alid Requirements
2.10 - Federal and State-Operated
MS4s: Program Implementation
Construction Program
3.0 - Construction Program
Overview
3.1 - Construction Rainfall
Erosivity Waiver
Industrial "No Exposure"
4.0 - Conditional No Exposure
Exclusion for Industrial Activity
United States
Environmental Protection
Agency I'
Office of Water
(4203)
EPA 833-F-00-00l
January 2000
Fact Sheet 1.0
Storm Water Phase II
Final Rule
An Overview
Why Is the Phase n Storm Water Program Necessary?
Since the passage of the Clean Water Act (CWA), the quality of our Nation's waters has
improved dramatically. Despite this progress, however, degraded waterbodies still exist.
According to the 1996 National Water Quality Inventory (Inventory), a biennial summary of
State surveys of water quality, approximately 40 percent of surveyed U.S. waterbodies are
still impaired by pollution and do not meet water quality standards. A leading source of this
impairment is polluted runoff. In fact, according to the Inventory, 13 percent of impaired
rivers, 21 percent of impaired lake acres and 45 percent of impaired estuaries are affected by
urban/suburban storm water runoff and 6 percent of impaired rivers, 11 percent of impaired
lake acres and 11 percent of impaired estuaries are affected by construction site discharges.
Phase I of the U.S. Environmental Protection Agency's (EPA) storm water program was
promulgated in 1990 under the CW A. Phase I relies on National Pollutant Discharge
Elimination System (NPDES) permit coverage to address storm water runoff from:
(1) "medium" and "large" municipal separate storm sewer systems (MS4s) generally serving
populations of 100,000 or greater, (2) construction activity disturbing 5 acres of land or
greater, and (3) ten categories of industrial activity.
The Storm Water Phase II Final Rule is the next step in EP A's effort to preserve, protect,
and improve the Nation's water resources from polluted storm water runoff. The Phase II
program expands the Phase I program by requiring additional operators of MS4s in urbanized
areas and operators of small construction sites, through the use of NPDES permits, to
implement programs and practices to control polluted storm water runoff. See Fact Sheets
2.0 and 3.0 for overviews of the Phase II programs for MS4s and construction activity.
Phase II is intended to further reduce adverse impacts to water quality and aquatic habitat by
instituting the use of controls on the unregulated sources of storm water discharges that have
the greatest likelihood of causing continued environmental degradation. The environmental
problems associated with discharges from MS4s in urbanized areas and discharges resulting
from construction activity are outlined below.
MS4s in Urbanized Areas
Storm water discharges from MS4s in urbanized areas are a concern because of the high
concentration of pollutants found in these discharges. Concentrated development in
urbanized areas substantially increases impervious surfaces, such as city streets, driveways,
parking lots, and sidewalks, on which pollutants from concentrated human activities settle
and remain until a storm event washes them into nearby storm drains. Common pollutants
include pesticides, fertilizers, oils, salt, litter and other debris, and sediment. Another
concern is the possible illicit connections of sanitary sewers, which can result in fecal
coliform bacteria entering the storm sewer system. Storm water runoff picks up and
transports these and other harmful pollutants then discharges them - untreated - to
waterways via storm sewer systems. When left uncontrolled, these discharges can result in
fish kills, the destruction of spawning and wildlife habitats, a loss in aesthetic value, and
contamination of drinking water supplies and recreational waterways that can threaten public
health. ATTACHMENT 1
NPDES II SUMMARY
www.epa.gov/npdeslregulationslphase2.pdf
Fact Sheet 1.0 - Storm Water Phase IT Final Rule: An Overview
..
Page 2
..
Construction Activitv
Uncontrolled runoff from construction sites is a water tJuality
concern because of the devastating effects that sedimehtation
can have on local waterbodies, particularly small streams.
Numerous studies have shown that the amount of sediment
transported by storm water runoff from construction sites
with no controls is significantly greater than from sites with
controls. In addition to sediment, construction activities yield
pollutants such as pesticides, petroleum products,
construction chemicals, solvents, asphalts, and acids that can
contaminate storm water runoff. During storms, construction
sites may be the source of sediment-laden runoff, which can
overwhelm a small stream channel's capacity, resulting in
streambed scour, streambank erosion, and destruction of near-
stream vegetative cover. Where left uncontrolled, sediment-
laden runoff has been shown to result in the loss of in-stream
habitats for fish and other aquatic species, an increased
difficulty in filtering drinking water, the loss of drinking
water reservoir storage capacity, and negative impacts on the
navigational capacity of waterways.
Are Municipally Operated Sources Exempted
by the Intermodal Surface Transportation
Efficiency Act (ISTEA) of 1991 Affected by
the Final Rule?
Provisions within ISTEA temporarily delayed the deadline
for Phase I industrial activities (with the exception of
power plants, airports, and uncontrolled sanitary landfills)
operated by municipalities with populations of less than
100,000 people to obtain an NPDES storm water discharge
permit. Congress delayed the permitting deadline for these
facilities to allow small municipalities additional time to
comply with NPDES requirements. The Phase II Final Rule
ended this temporary exemption from permitting and set a
deadline of no later than March 10,2003 for all ISTEA-
exempted municipally operated industrial activities to obtain
permit coverage.
How Was the Phase II Final Rule Developed?
EPA developed the Phase II Final Rule during extensive
consultations with a cross-section of interested
stakeholders brought together on a subcommittee chartered
under the Federal Advisory Committee Act, and with
representatives of small entities participating in an advisory
process mandated under the Small Business Regulatory
Enforcement Fairness Act. In addition, EPA considered
comments submitted by over 500 individuals and
organizations during a 90-day public comment period on
the proposed rule.
Why Does Part of the Phase II Final Rule Use a
Question and Answer Format?
The provisions pertaining to operators of small MS4s are
written in a "readable regulation" form that uses the
"plain language" method. Questions and answers are used to
create more reader-friendly and understandable regulations.
The plain language method uses "must" instead of "shall" to
indicate a requirement and words like "should," "could," or
"encourage" to indicate a recommendation or guidance.
Who Is Covered by the Phase n Final Rule?
The final rule "automatically" covers two classes of storm
water dischargers on a nationwide basis:
(1) Operators of small MS4s located in "urbanized
areas" as delineated by the Bureau of the Census.
A "small" MS4 is any MS4 not already covered by
Phase I of the NPDES storm water program. See
Fact Sheets 2.1 and 2.2 for more information on
small MS4 coverage.
(2) Operators of small construction activities that
disturb equal to or greater than 1 (one) and less
than 5 (five) acres of land. See Fact Sheet 3.0 for
more information on small construction activity
coverage.
Waivers
Permitting authorities may waive "automatically designated"
Phase II dischargers if the dischargers meet the necessary
criteria. See Fact Sheets 2.1 (small MS4 waivers overview),
3.0 (construction waivers overview) and 3.1 (construction
rainfall erosivity waiver) for details.
Phased-in Permit Coveraee
Permitting authorities may phase-in permit coverage for small
MS4s serving jurisdictions with a population under 10,000 on
a schedule consistent with a State watershed permitting
approach.
Additional Desienations bv the Permittine Authoritv
Small MS4s located outside of urbanized areas, construction
activity disturbing less than 1 acre, and any other storm water
discharges can be designated for coverage if the NPDES
permitting authority or EP A determines that storm water
controls are necessary. See Fact Sheet 2.1 for more
information on the designation of small MS4s located outside
of urbanized areas.
It
Fact Sheet 1.0 - Storm Water Phase II Final Rule: An Overview
Page 3
..
What Does the Phase II Final Rule Require?
Operators of Phase II-designated small MS4s and small
construction activity are required to apply for NPDES
permit coverage, most likely under a general rather than
individual permit, and to implement storm water discharge
management controls (known as "best management practices"
(BMPs)). Specific requirements for each type of discharge
are listed below.
Small MS4s
o A regulated small MS4 operator must develop,
implement, and enforce a storm water management
program designed to reduce the discharge of
pollutants from their MS4 to the "maximum extent
practicable," to protect water quality, and to satisfy
the appropriate water quality requirements of the
CW A. The rule assumes the use of narrative, rather
than numeric, effluent limitations requiring
implementation of BMPs.
o The small MS4 storm water management program
must include the following six minimum control
measures: public education and outreach; public
participation/involvement; illicit discharge detection
and elimination; construction site runoff control;
post-construction runoff control; and pollution
prevention/good housekeeping. See Fact Sheets 2.3
through 2.8 for more information on each measure,
including BMPs and measurable goals.
o A regulated small MS4 operator must identify its
selection of BMPs and measurable goals for each
minimum measure in the permit application. The
evaluation and assessment of those chosen BMPs
and measurable goals must be included in periodic
reports to the NPDES permitting authority. See Fact
Sheet 2.9 for more information on permitting and
reporting.
Small Construction Activity
o The specific requirements for storm water controls
on small construction activity will be defined by the
NPDES permitting authority on a State-by-State
basis.
o EPA expects that the NPDES permitting authorities
will use their existing Phase I general permits for
large construction activity as a guide for their
Phase II permits for small construction activity. If
this occurs, a storm water pollution prevention plan
will likely be required for small construction activity.
See Fact Sheet 3.0 for more information on potential
program requirements and appropriate BMPs for
small construction activity.
What Is the Phase II Program Approach?
The Phase II program, based on the use of federally
enforceable NPDES permits:
o Encourages the use of general permits;
o Provides flexibility for regulated operators to
determine the most appropriate storm water
controls;
o Allows for the recognition and inclusion of existing
NPDES and non-NPDES storm water programs in
Phase II permits;
o Includes public education and participation efforts
as primary elements of the small MS4 program;
o Attempts to facilitate and promote watershed
planning and to implement the storm water program
on a watershed basis; and
o Works toward a unified and comprehensive NPDES
storm water program with Phase I of the program.
How Does the Phase II Final Rule Address the
Phase I Industrial "No Exposure" Provision?
In addition to establishing a deadline for ISTEA facilities
and designating two new classes of dischargers, the
Phase II Final Rule revises the "no exposure" provision
originally included in the 1990 regulations for Phase I of the
NPDES storm water program. The provision was remanded
to EPA for further rulemaking and, subsequently, included in
its revised form in the Phase II rule.
Under the Phase II Final Rule, a conditional no exposure
exclusion is available to operators of all categories of Phase I
regulated industrial activity (except category (x) construction
activity) who can certify that all industrial materials and
activities are protected by a storm resistant shelter to prevent
exposure to rain, snow, snowmelt, and/or runoff. To obtain
the no exposure exclusion, written certification must be
submitted to the NPDES permitting authority. The final rule
includes a No Exposure Certification form for use only by
operators of industrial activity in areas where EP A is the
NPDES permitting authority. See Fact Sheet 4.0 for more
information on the conditional no exposure exclusion for
industrial activity.
Fact Sheet 1.0 - Storm Water Phase II Final Rule: An Overview
"
Page 4
,
What Is the Phase II Program Implementation
"Tool Box?"
Ep A is committed to providing tools to facilitate
implementation of the final Phase II storm water program
in an effective and cost-efficient manner. The "tool box" will
include the following components:
e
Fact Sheets;
Guidance Documents;
Menu ofBMPs;
Information Clearinghouse/Web Site;
Training and Outreach Efforts;
Technical Research;
Support for Demonstration Projects; and
Compliance Monitoring/Assistance Tools.
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e
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e
A preliminary working toolbox is available on EPA's web
site at www.epa.gov/npdes/stormwater. Three years after
publication of the final rule, when the general permits are
issued, a fully operational tool box is scheduled to be
available.
What Is the Schedule for the Phase II Rule?
o The Phase II Final Rule was published in the Federal
Register on December 8, 1999 (64 FR 68722).
o The Conditional No Exposure Exclusion option is
available February 7,2000, in States where EPA is
the permitting authority.
o The NPDES permitting authority will issue general
permits for Phase II-designated small MS4s and small
construction activity by December 9, 2002.
o Operators of Phase II "automatically" designated
regulated small MS4s and small construction activity
must obtain permit coverage within 90 days of permit
issuance.
o The NPDES permitting authority may phase-in
coverage for small MS4s serving jurisdictions with a
population under 10,000 on a schedule consistent with
a State watershed permitting approach.
o Operators of regulated small MS4s must fully
implement their storm water management programs
by the end of the first permit term, typically a 5-year
period.
For Additional Information
Contacts
.... U.S. EPA Office of Wastewater Management
Internet: www.epa.gov/npdes/storn1waler
· Phone: 202-564-9545
.... Your NPDES Permitting Authority. A list of names
and telephone numbers for each EP A Region and
State is located at: www.epa.gov/npdes/stormwater,
then click on "Contacts."
Reference Documents
.... Storm Water Phase II Final Rule Fact Sheet Series
Internet: cfpub.epa.gov/npdes/storm waterlswl1nal.cfm
.... Storm Water Phase II Final Rule (64 FR 68722)
Internet: www.epa.gov/npdes/regulations/phase2.pdf
CITY OF
SHOREWOOD
5755 Country Club Road Shorewood, Minnesota 55331-8927 Tel (952) 474-3236 Fax (952) 474-0128
MEMORANDUM
TO:
Mayor and City Council
Craig Dawson, City Administrator
FROM:
Larry Brown, Director of Public Works
DATE:
April 23, 2003
RE:
Discussion Regarding Sanitary Sewer Policies
Recent occurrences of utility failures and investigations have generated the need to formally define
policies regarding temporary measures to be taken under the two most common scenarios.
The first scenario is the event of a sanitary sewer backup caused by a sewer main obstruction, lift
station failure, or other difficulties with the City owned portion of the utility.
Last month, the City of Shorewood experienced an equipment failure in a lift station that resulted in a
single family home being impacted by wastewater in the basement. Thankfully, the basement
impacted was an unfinished basement. However, the backup affected many personal belongings and
pictures.
Staff immediately contacted the League of Minnesota Cities, who is the insurance carrier for
Shorewood. The carrier's policy is administrated by Berkley Risk Services.
Several conversations and site investigations were performed to determine the City's liability in this
case. While there is no dispute that the control equipment that operates the pumps failed, it is the
current opinion of the insurance adjuster that the City does not appear to be negligent. The lift station
had been checked on a routine schedule and daily logs of the checks were in order.
Under the Leagues policy statement, they will not pay for a claim unless the City was proven to be
negligent. Simple equipment failure that could not be anticipated or perceived by public works
personnel does not warrant compensation to the homeowner.
Concurrent to the above discussions and meetings, Staff consulted with the insurance adjuster and the
City Attorney to determine if the hiring of a contractor to enter the home and perform cleanup and
disinfection services was any admission of liability. The response by both individuals was that these
services could be performed without additional liability.
Mr. Keane was quick to point out that providing this type of customer service may protect the City
from later claims of illnesses due to mold, bacteria or other health issues caused by the backup.
Mayor and City Council
Sanitary Sewer Policies
April 24, 2003
Page 2 of3
Under this last scenario, the decision was very easy. The basement was unfinished, no carpet, with
minor damage to doors and woodwork. The cost of the cleanup was minor. Therefore, the contractor
was brought in immediately with little more discussion.
Having stated this, this lead to the question, "What should the appropriate short term response be if this
occurs in a finished basement?" Certainly, under these types of situations the homeowner is very
distraught. A backup in a finished basement will require removal of furniture, any carpeting, a portion
of the sheet rock, and any woodwork that was wetted. The League of Minnesota Cities estimates costs
for this type of operation averages $30.00 per square foot.
Unfortunately, (or maybe fortunately!) these incidents do not time themselves in sync with City
Council meetings, where approval for this type of expenditure could be obtained immediately. In
checking with other municipalities, it appears to be common practice that Staffmay authorize a
contractor to perform basic cleanup, removal of carpets, furniture and disinfection of the basement.
Most cities have stated that this of immediate action boils down to good customer service, and that it
does not result in any admission ofliability. Many of the cities have agreements with firms such as
Service Master to perform such duties on short notice.
Staff agrees that while cost for such a service may be significant, that this type of policy takes some of
the pressure off a very difficult situation.
Staff seeks feedback from the City Council on developing such a policy.
The second scenario is an instance of a sanitary sewer service issue. Typically, when calls of a sewer
backup are received, Public Works personnel are dispatched to determine if the issue is a sanitary
sewer main or a service line issue. Once on site, both upstream and downstream manholes are opened
to determine if there is an issue with the main line.
If the main line is without issue, the resident is notified immediately that the problem appears to be
with the individual sewer service. Most often the homeowner has already consulted with a plumber to
check the service line with a drain snake. Contracted plumbers are never very hesitant about stating it
appears to be an issue with the City's portion of the service, whether accurate or not.
The City owns the portion of the service that is within the public right of way. To determine exactly
what the problem is or whether the issue is private or public requires the use of a sanitary sewer
camera. Once the camera has sighted the problem, a special utility locate unit can follow the cable to
determine the exact location of the issue.
Current practice has been to negotiate with the homeowner an agreement that allows the City to
arrange for a contractor to video the line. If the location of the problem is within the public right of
way, the City will pay for the cost ofthe camera services. Ifhowever the location ofthe issue falls
within the private portion of the service, the homeowner is to pay for the camera services.
This practice has worked well in the past, and is consistent with the practice of other municipalities.
Having stated this, Staff is not aware of any set policy with regard to this matter. Therefore, Staff
desires feedback from the City Council on establishing a written policy for this issue.
CITY OF
SHOREWOOD
5755 Country Club Road Shorewood, Minnesota 55331-8927 Tel (952) 474-3236 Fax (952) 474-0128
MEMORANDUM
TO:
Mayor and City Council
Craig Dawson, City Administrator
FROM:
Larry Brown, Director of Public Works
DATE:
April 23, 2003
RE:
Discussion Regarding Stormwater Goals and Polices
Approximately two years ago, the City of Shore wood submitted the City's Comprehensive Water
Resource Plan to Met Council, Minnehaha Creek Watershed (MCWD), and the Board of Water and
Soil Resources for review and comment.
At that time, a comment letter was generated stating that a detailed function and values assessment had
to be completed, prior to approval of the City's Water Resource Plan. This type of study evaluates
what function each wetland currently plays in the ecosystem, and what value the wetland is or can
logically be restored to. This type of study is costly and time consuming.
Shortly thereafter, the MCWD stated that they would assume the responsibility for performing such a
study. MCWD enlisted the assistance of the Hennepin Conservation District to perform these services.
This study has now been completed and incorporated into the City's Water Resource Plan for board
review and approval.
Due to the volume of the document, policies and goals will be highlighted in detail during Monday
nights work session. Once reviewed by all agencies, the plan will be re-revised and adopted by the
City Council at a regular meeting.