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HomeMy WebLinkAbout5F MS4 SWWWP Application O � PRI�� ti � U 4646 Dakota Street SE Prior Lake, MN 55372 `�INIVESO� CITY COUNCIL AGENDA REPORT MEETING DATE: DECEMBER 9, 2013 AGENDA #: 5F PREPARED BY: PETE YOUNG, WATER RESOURCES ENGINEER PRESENTED BY: PETE YOUNG AGENDA ITEM: CONSIDER APPROVAL OF A RESOLUTION APPROVING THE MS4 SWPPP APPLICATION DISCUSSION: Introduction The purpose of this agenda item is to update the City Council on the City's Municipal Separate Storm Sewer System (MS4) Stormwater Pollution Prevention Program (SWPPP) Application for Reauthorization ("SWPPP DocumenY') and MS4 permit coverage status. Staff has prepared a draft SWPPP Document and is requesting approval to apply for permit coverage under the updated MS4 permit. Hi StOry An MS4 is a system of conveyances (pipes, catch basins, curb/gutter, ditches, etc.), owned or operated by a public body (such as a city), that discharges to public waters. It is designed or used to collect or convey stormwater, does not include sanitary sewer discharges, and is not part of a publically owned wastewater treatment facility. The City of Prior Lake operates a regulated MS4, as designated by the Minnesota Pollution Control Agency (MPCA). Authority to administer the MS4 program is delegated from the Environmental Protection Agency (EPA) to the MPCA. Under the MS4 program, stormwater discharges are regulated through the use of a National Pollutant Discharge Elimination System (NPDES) Permit. The NPDES Permit ("Permit") is a legal document, and according to this Permit, the City is required to develop a SWPPP Document that is used to apply for Permit coverage. The City obtained Permit coverage and developed Best Management Practices (BMPs) to meet conditions of the previous Permit (effective 2006- 2013). The MPCA approved a new statewide Permit that became effective on August 1, 2013. The new permit has more specific requirements for attaining compliance. Under the Permit, all regulated MS4s (including the City of Prior Lake) must re-apply for Permit coverage by submitting an updated SWPPP Document. Within the document the BMPs must be evaluated for compliance with the new Permit. Phone 952.447.9800 / Fa�: 952.44�.4245 / www.cityofpriorlake.com The SWPPP Document outlines the City's MS4 program and gives timelines for updating the program so that it will meet updated MS4 Permit requirements. The program must address the six minimum control measures along with any applicable TMDLs. The six minimum control measures are: 1. Public Education 2. Public Participation 3. Construction Site Runoff Control 4. Post Construction Site Runoff Control 5. Illicit Discharge Detection and Elimination 6. Good Housekeeping. The City of Prior Lake must submit its SWPPP Document to the MPCA by December 30, 2013.The following website contains additional information on the MS4 program: http://www. pca. state. m n. us/index. php/water/water-types-and- programs/stormwater/municipal-stormwater/municipal-separate-storm- sewer-systems-ms4. html Current Circumstances I Staff has reviewed the MPCA's Permit requirements and has completed the SWPPP Document. A copy of the document is attached to this agenda item. The Lakes Advisory Committee (LAC) reviewed and approved the SWPPP Document at its November 19, 2013 meeting. The Minnesota Cities Stormwater Coalition (MCSC), a fee-based League of Minnesota Cities service, has provided member cities with information and recommendations relating to the SWPPP Document. The City of Prior Lake is a member of the MCSC. The MCSC has provided the following guidance regarding the current application process: "It is expected that your regulatory mechanisms and current SWPPP BMPs will not be in compliance with the new permit at this time. You should not hesitate to answer many of the questions on the SWPPP Document Form with "No". In many cases, that will be the correct, appropriate, and expected answer. For each "No" response, you will just need to provide information about the process you will follow to develop the new SWPPP and BMP materials and language to meet the new permit requirements within the schedule." As outlined in the draft SWPPP Document, the City of Prior Lake's M84 program met the previous requirements (in effect from 2006-2013) but program updates are needed so that the City's MS4 program meets the new Permit requirements. Specifically, regulatory mechanisms relating to illicit discharge detection and elimination (IDDE), volume control, and erosion/sediment control will need to be addressed. Over the next few months City staff will review current ordinances and other policy documents such as the Public Works Design Manual and determine how these documents can be updated so that the City can meet Permit 2 requirements. In addition, the new Permit requires official regulatory mechanisms that show how the City meets certain permit requirements. In most cases the City is already meeting these Permit requirements but there is not an official written procedure outlining how the requirements are being met. Staff will use the final SWPPP Document as a guide for updating the City's MS4 program. Conclusion Substantive changes need to be made to the City's MS4 program in order ' to bring it into compliance with the new MS4 Permit. The City was in compliance with the previous MS4 Permit that expired on July 31, 2013. The new MS4 Permit, effective August 1, 2013, contains new and updated requirements. By submitting the attached SWPPP Document by December 30, 2013, the City will be applying for coverage under the new MS4 Permit. After MPCA has reviewed and tentatively approved the SWPPP Document, it will be placed on public notice for 30 days. After the public notice process has been completed, the City will receive a letter that states the date when Permit coverage begins. The City must be in full compliance with the terms of the Permit within 12 months of the date Permit coverage begins. It is anticipated that Permit coverage will begin in 15-18 months. ISSUES: By submitting the SWPPP Document as proposed, the City Council would be committing to the following major efforts (as required by the MS4 Permit) within the next 15-18 months: 1. Approving three new ordinances (Illicit Discharge, Erosion & Sediment Control, and Stormwater Management). These ordinances will form the basis for required regulatory mechanisms. To save staff time and to increase consistency with other cities, available model ordinances should be a starting point. 2. Revising the Public Works Design Manual to include updated technical details that comply with MS4 Permit requirements. 3. Creating Enforcement Response Procedures (ERPs) to document how the City will enforce and compel compliance with the updated regulatory mechanisms. While there is no question that we all wish to protect the environment and in the case of Prior Lake, our many lakes, these requirements represent an unfunded mandate. The entire process is such that we really do not know what our financial or staffing obligations will be until after we submit our application and it is "approved" assuming we take the actions imposed therein. Ultimately the implementation of these requirements are paid by our residents either as a user charge tax levy or both. There are 115 other MS4 cities in Minnesota currently facing the same application process. These facts notwithstanding, we must apply for the new MS4 SWPPP in order to continue the operation, maintenance expansion and improvement of our stormwater management system. 3 Finally, our customers whether developers, residents or tenants will face additional requirements and consequently costs and delays as they work to develop or improve property. As the enforcer of these requirements it should be no surprise that the city is seen as more regulatory and less development friendly. FINANCIAL Considerable staff resources will be required to bring the City's MS4 IMPACT: program into compliance with the new MS4 Permit. Ensuring compliance with State MS4 Permit requirements is one of the primary job duties of the City's Water Resources Engineer and therefore the work will be completed in-house. Funds for staff resources related to the City's MS4 program are identified in the Water Quality budget (Stormwater Utility). ALTERNATIVES: 1. Adopt the attached resolution approving the SWPPP Document (MS4 SWPPP application). 2. Table this item for a specific reason. 3. Deny this item for a specific reason and provide staff with direction. � RECOMMENDED Staff recommends Alternative #1 MOTION: 4 o � PRip� � � U tr� 4646 Dakota Street SE `�IN�so'��' Prior Lake, MN 55372 RESOLUTION 13-xxx A RESOLUTION APPROVING THE CITY OF PRIOR LAKE MS4 SWPPP APPLICATION FOR REAUTHORIZATION Motion By: Second By: WHEREAS, The City operates a regulated Municipal Separate Storm Sewer System (MS4); and WHEREAS, An MS4 is a system of conveyances (pipes, catch basins, curb/gutter, ditches, etc.) owned or operatetl by a public body (such as a city), that discharges to public waters. It is designated or used to collect or convey stormwater, does not include sanitary sewer discharges, and is not part of a publically owned wastewater treatment facility; and WHEREAS, The Minnesota Pollution Control Agency (MPCA) administers the MS4 program in Minnesota, with authority delegated from the United States Environmental Protection Agency (EPA); and WHEREAS, Under the MPCA MS4 program, the City is required to operate a Stormwater Pollution Prevention Program (SWPPP); and WHEREAS, The City, as a regulated MS4 community, must submit an application for MS4 Permit coverage by December 30, 2013. ' NOW THEREFORE, BE IT HEREBY RESOLVED BY THE CITY COUNCIL OF PRIOR LAKE, MINNESOTA as follows: 1. The recitals set forth above are incorporated herein. 2. The City of Prior Lake's MS4 SWPPP Application for Reauthorization ("SWPPP Document") is approved. 3. The Public Works Director is authorized to submit the SWPPP Document on behalf of the City by December 30, 2013. PASSED AND ADOPTED THIS 9th DAY OF DECEMBER, 2013. YES NO Hedber Hedber Keene Keene McGuire McGuire Morton Morton Souku Souku Frank Boyles, City Manager �iula�a, ��N� �''� Minnesota Potiutiar� MS4 SWPPP Application Control Agency 520 Lafayette Road North f o r Re a u t h o r i zat i o n St. Paul, MN 55155-4194 for the NPDES/SDS General Small Municipal Separate Storm Sewer System (MS4) Permit MNR040000 reissued with an effective date of August 1, 2073 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 (MS4s) under the National Pollutant Discharge Elimination System/State Disposal System (NPDES/SDS) Permit Program. No fee 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: This MS4 SWPPPApplication for Reauthorization form must be submitted electronically via e-mail to the MPCA at ms4permitprogram.qca 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(a�state.mn.us, Dan Miller at 651-757-2246 or daniel.millerCa�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 Prior Lake "County: Scott (city, county, municipality, government agency or other entity) "Mailing address: 4646 Dakota Street SE 'City: Prior Lake "State: MN *Zip code: 55372 *Phone (including area code): 952-447-9800 '`E-mail: info@cityofpriorlake.com MS4 General contact (with Stormwater Pollution Prevention Program [SWPPP] implementation responsibility) `Last name: Gehler *First name: Katv (department head, MS4 coordinator, consultant, etc.) *Title: Public Works Director 'Mailing address: 4646 Dakota Street SE 'City: Prior Lake '`State: MN *Zip code: 55372 "Phone (including area code): 952-447-9890 "E-mail: kqehler@cityofpriorlake.com Preparer information (complete if SWPPP application is prepared by a party other than MS4 General contact) Last name: Younq First name: Pete (department head, MS4 coordinator, consultant, etc.) Title: Wa ter Resources Engineer Mailing address: 4646 Dakota Street SE City: Prior Lake State: MN Zip code: 55372 Phone (including area code): 952-447-9831 E-mail: pvounq an,cityofpriorlake.com Verification 1. I seek to continue discharging stormwater associated with a small MS4 after the effective date of this Permit, and shall submit this MS4 SWPPP Application for Reauthorization 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 Poge 1 of 18 CertiflCltlon (All fields are required) ❑ Yes - 1 ce�tify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that quali�ed 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 infonnation submitted is, to the best of my knowledge and belief, true, accurate, and complete. 1 am aware that there are significant penalties for submitting false inforrnation, 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 (including area code): E-mail: I 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 P Z° f 18 Stormwater Pollution Prevention Program Document I. Partnerships: (Part II.D.1) A. List the regulated small MS4(s) with which you have established a partnership in order to satisfy one or more requirements of this Permit. Indicate which Minimum Control Measure (MCM) requirements or other program components that each partnership helps to accomplish (List all that apply). Check the box below if you currently have no established partnerships with other regulated MS4s. If you have more than five partnerships, hit the tab key after the last line to generate a new row. ❑ No partnerships with regulated small MS4s Name and descri tion of artnershi MCM/Other ermit re uirements involved Prior Lake-Spring Lake Watershed District; The City formed a partnership with the Prior Lake- Spring Lake Watershed District in 2013 in order to deliver an education and outreach program that meets MS4 permit requirements for both organizations. It is anticipated that this program will continue during the current ermit term. MCM1 B. If you have additional information that you would like to communicate about your partnerships with other regulated small MS4(s), provide it in the space below, or include an attachment to the SWPPP Document, with the following file naming convention: MS4NameHere Partnerships. II. Description of Regulatory Mechanisms: (Part II.D.2) Illicit discharges A. Do you have a regulatory mechanism(s) that effectively prohibits non-stormwater discharges into your small MS4, except those non-stormwater discharges authorized under the Permit (Part III.D.3.b.)? ❑ Yes � No 1. If yes: a. Check which type of regulatory mechanism(s) your organization has (check all that apply): ❑ 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: Direct link: ❑ Check here if attaching an electronic copy of your regulatory mechanism, with the following file naming convention: MS4NameHere IDDEreg. www.pca.state.mn.us • 651-296-6300 • 800-657-3864 • TTY 651-282-5332 or 800-657-3864 • Available in altemative formats wq-strm4-49a • 5/31/ 13 Page 3 of 18 2. If no: Describe the tasks and corresponding schedules that will be taken to assure that, within 12 months of the date permit coverage is extended, this permit requirement is met: The City will meet this pe►mit requirement within 12 months of the date permit coverage is extended. The following tasks will be completed: 1. City staff will develop an lllicit Discharge ordinance that meets current permit requirements. �, 2. The City Council will review and consider approving an lllicit Discharge ordinance. 3. Ordinance will be in effect within 12 months of the date permit coverage is extended. Construction site stormwater runoff control A. Do you have a regulatory mechanism(s) that establishes requirements for erosion and sediment controls and waste controls? � Yes ❑ No 1. If yes: a. Check which type of regulatory mechanism(s) your organization has (check all that apply): � Ordinance ❑ Contract language � Policy/Standards ❑ Permits ❑ Rules ❑ Other, expiain: 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 of Prior Lake Subdivision Code, Section 1004 (Design Standards). Section 1004.700, Erosion and Sediment Control. References the City's Public Wo►1cs Design Manual (direct link listed below) Direct link: www. cityofprio►1ake. com/pdf/designmanual. pdf See Part 111, Hydrology Rules; Section Three (directly references site NPDES permit and SWPPP) ❑ Check here if attaching an electronic copy of your regulatory mechanism, with the foltowing file naming convention: MS4NameHere CSWreg. B. Is your regulatory mechanism at least as stringent as the MPCA general permit to Discharge Stormwater Associated with Construction Activity (as of the effective date of the MS4 Permit)? ❑Yes � No If you answered yes to the above question, proceed to C. If you answered no 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: Although the City currently meets the permit requirement listed in A. above, a simpler and more effective regulatory mechanism is needed. The City will meet the permit requirements listed in A. and B. above within 12 months of fhe date permit coverage is extended. The following fasks will be completed: 1. City staff will develop an erosion and sediment control ordinance that meets current permit requirements. This ordinance will replace the various regulatory mechanisms that were previously used to regulate erosion and sediment control. 2. The City Council will review and consider approving an erosion and sediment control ordinance. 3. Ordinance will be in effect within 12 months of the date permit coverage is extended. 4. Ordinance will reference a document or set of documents that include all required elements of an effective construction site stormwater runoff control program. All reference documents will be completed and in effect within 12 months of the dafe permit coverage is extended. C. Answer yes or no to indicate whether your regulatory mechanism(s) requires owners and operators of construction activity to develop site plans that incorporate the following erosion and sediment controls and waste controls as described in the Permit (Part III.D.4.a.(1)-(8)), and as listed below: 1. Best Management Practices (BMPs) to minimize erosion. � Yes ❑ No 2. BMPs to minimize the discharge of sediment and other pollutants. � Yes ❑ No 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 18 ' 3. BMPs for dewatering activities. � Yes ❑ No 4. Site inspections and records of rainfail 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 compietion of construction activity, including the use of perennial � Yes ❑ No vegetative cover on all exposed soils or other equivalent means. 8. Criteria for the use of temporary sediment basins. � Yes ❑ No If you answered no to any of the above permit requirements, describe the tasks and corresponding schedules that will be taken to assure that, within 12 months of the date permit coverage is extended, these permit requirements are met: Post stormwater management A. Do you have a regulatory mechanism(s) to address post-construction stormwater management activities? � Yes ❑ No 1. If yes: a. Check which type 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 of Prior Lake Subdivision Code, Section 1004 (Design Standards). Section 1004.800, Storm Drainage. References the City's Public Works Design Manual (direct link listed below) Direct link: www. cityofpriorlake.com/pdf/designmanual. pdf See Part lll, Hydrology Rules; Section Four (Site hydrology, stormwater and volume management) ❑ Check here if attaching an electronic copy of your regulatory mechanism, with the following file naming convention: MS4NameHere PostCSWreg. B. Answer yes or no below to indicate whether you have a regulatory mechanism(s) in place that meets the following requirements as described in the Permit (Part III.D.S.a.): 1. Site plan review: Requirements that owners andlor operators of construction activity submit � Yes ❑ No �! site plans with post-construction stormwater management BMPs to the permittee for review and approval, prior to start of construction activity. ' 2. Conditions for post construction stormwater management: Requires the use of any combination of BMPs, with highest preference given to Green Infrastructure techniques and practices (e.g., infiltration, evapotranspiration, reuse/harvesting, conservation design, urban forestry, green roofs, etc.), necessary to meet the following conditions on the site of a construction activity to the Maximum Extent Practicable (MEP): a. For new development projects — no net increase from pre-project conditions (on an annual � Yes � No average basis) of: 1) Stormwater discharge volume, unless precluded by the stormwater management limitations in the Permit (Part III.D.5.a(3)(a)). 2) Stormwater discharges of Total Suspended Solids (TSS). 3) Stormwater discharges of Total Phosphorus (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. 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 18 3. Stormwater management limitations and exceptions: a. Limitations 1) Prohibit the use of infiltration techniques to achieve the conditions for post-construction ❑ Yes � No stormwater management in the Permit (Part III.D.S.a(2)) when the infiltration structural stormwater BMP will receive discharges from, or be constructed in areas: a) Where industrial facilities are not authorized to infiltrate industrial stormwater under an NPDES/SDS Industrial Stormwater Permit issued by the MPCA. b) Where vehicle fueling and maintenance occur. c) With less than three (3) feet of separation distance from the bottom of the infiltration system to the elevation of the seasonally saturated soils or the top of bedrock. d) Where high levels of contaminants in soil or groundwater will be mobilized by the infiltrating stormwater. 2) Restrict the use of infiltration techniques to achieve the conditions for post-construction ❑ Yes � No stormwater management in the Permit (Part III.D.5.a(2)), without higher engineering review, sufficient to provide a functioning treatment system and prevent adverse impacts to groundwater, when the infiltration device will be constructed in areas: a) With predominately Hydrologic Soil Group D(clay) soils. b) Within 1,000 feet up-gradient, or 100 feet down-gradient of active karst features. c) Within a Drinking Water Supply Management Area (DWSMA) as defined in Minn. R. 4720.5100, subp. 13. d) Where soil infiltration rates are more than 8.3 inches per hour. 3) For linear projects where the lack of right-of-way precludes the installation of volume ❑ Yes � No control practices that meet the conditions for post-construction stormwater management in the Permit (Part III.D.5.a(2)), the permittee's regulatory mechanism(s) may allow exceptions as described in the Permit (Part III.D.5.a(3)(b)). The permittee's regulatory mechanism(s) shall ensure that a reasonable attempt be made to obtain right-of-way during the project planning process. 4. Mitigation provisions: The permittee's regulatory mechanism(s) shall ensure that any stormwater discharges of TSS and/or TP not addressed on the site of the original construction activity are addressed through mitigation and, at a minimum, shall ensure the following requirements are met: a. Mitigation project areas are selected in the following order of preference: ❑ Yes � No 1) Locations that yield benefits to the same receiving water that receives runoff from the original construction activity. 2) Locations within the same Minnesota Department of Natural Resource (DNR) catchment area as the original construction activity. 3) Locations in the next adjacent DNR catchment area up-stream 4) Locations anywhere within the permittee's jurisdiction. b. Mitigation projects must involve the creation of new structural stormwater BMPs or the ❑ Yes � No retrofit of existing structural stormwater BMPs, or the use of a properly designed regional structural stormwater BMP. c. Routine maintenance of structural stormwater BMPs already required by this permit cannot � Yes � No be used to meet mitigation requirements of this part. d. Mitigation projects shall be completed within 24 months after the start of the original ❑ Yes � No construction activity. e. The permittee shall determine, and document, who will be responsible for long-term ❑ Yes � No maintenance on all mitigation projects of this part. f. If the permittee receives payment from the owner and/or operator of a construction activity ❑ Yes � No for mitigation purposes in lieu of the owner or operator of that construction activity meeting the conditions for post-construction stormwater management in Part III.D.5.a(2), the permittee shall apply any such payment received to a public stormwater project, and all projects must be in compliance with Part III.D.5.a(4)(a)-(e). 5. Long-term maintenance of structural stormwater BMPs: The permittee's regulatory mechanism(s) shall provide for the establishment of legal mechanisms between the permittee and owners or operators responsible for the long-term maintenance of structural stormwater BMPs not owned or operated by the permittee, that have been implemented to meet the conditions for post-construction stormwater management in the Permit (Part III.D.5.a(2)). This only includes structural stormwater BMPs constructed after the effective date of this permit and that are directly connected to the permittee's MS4, and that are in the permittee's jurisdiction. The legal mechanism shall include provisions that, at a minimum: 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 18 a. Allow the permittee to conduct inspections of structural stormwater BMPs not owned or ❑ Yes � No I ' I operated by the permittee, perform necessary maintenance, and assess costs for those I 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 protecUpreserve 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. If you answered no to any of the above permit requirements, describe the tasks and corresponding schedules that will be taken to assure that, within twelve (12) months of the date permit coverage is extended, these permit requirements are met: 8.2 - 8.5.: The City will meet the various post-construction stormwater management permit requirements within 12 months of the date permit coverage is extended. The following tasks will be completed: 1. City staff will develop a Stormwater Management ordinance that meets current pe►mit requirements. 2. The City Council will review and consider approving a Stormwater Management ordinance. 3. Ordinance will be in effect within 12 months of the dafe pem►it coverage is extended. 4. Ordinance will reference a document or set of documents that include all required elements of an effective stormwater management program, addressing all program elements that were not checked on the list above. All reference documents will be completed and in effect within 12 months of the date permit coverage is extended. III. Enforcement Response Procedures (ERPs): (Part II.D.3) A. Do you have existing ERPs that satisfy the requirements of the Permit (Part III.B.)? ❑ Yes � No 1. If yes, attach them to this form as an electronic document, with the following file naming I convention: MS4NameHere ERPs. I 2. If no, describe the tasks and corresponding schedules that will be taken to assure that, with , twelve (12) months of the date permit coverage is extended, these permit requirements are met: ' The City will meet the ERP requirements of the permit within 12 months of the date permit coverage is extended. The following tasks will be completed: 1. City staff will develop written ERPs to enforce and compel compliance with the regulatory mechanisms required by the MS4 permit. This wo►1c will be done in conjunction with the development of the updated regulatory mechanisms. 2. Written ERPs will be reviewed by the City Council and incorporated into the updated regulatory mechanisms. 3. City staff will develop a written process to document all enforcement conducted pursuant to the ERPs as required by the permit. B. Describe your ERPs: The City of Prior Lake does not have ERPs that meet current permit requirements. IV. Storm Sewer System Map and Inventory: (Part II.D.4.) A. Describe how you manage your storm sewer system map and inventory: The City maintains a robust storm sewer system map and inventory as requried by the MS4 permit. The map is GIS- based, and ourinventory�nspection database relies on Cartegraph soffware. A full system inspection and mapping update was completed during 2012-2013 using handheld GPS units. As a result of this update, system data repo►ted in future annual MS4 reports (such as stormwater pond quantities) will differ from previous years. Annual system inspections and mapping updates will continue throughout the current permit ferm. The City uses inspection data to prioritize system maintenance. B. Answer yes or no to indicate whether your storm sewer system map addresses the following requirements from the Permit (Part III.C.1.a-d), as listed below: 1. The permittee's entire small MS4 as a goal, but at a minimum, all pipes 12 inches or greater in � Yes ❑ No diameter, including stormwater flow direction in those pipes. 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 18 2. Outfalis, including a unique identification (ID) number assigned by the permittee, and an � Yes ❑ No associated geographic coordinate. 3. Structural stormwater BMPs that are part of the permittee's small MS4. � Yes ❑ No 4. All receiving waters. � Yes ❑ No If you answered no to any of the above permit requirements, describe the tasks and corresponding schedules that will be taken to assure that, within 12 months of the date permit coverage is extended, these permit requirements are met: C. Answer yes or no to indicate whether you have completed the requirements of 2009 Minnesota Session Law, Ch. 172. Sec. 28: with the following inventories, according to the specifications of the Permit (Part II I.C.2.a.-b.), including: 1. All ponds within the permittee's jurisdiction that are constructed and operated for purposes of � Yes ❑ No water quality treatment, stormwater detention, and flood control, and that are used for the collection of stormwater via constructed conveyances. 2. All wetlands and lakes, within the permittee's jurisdiction, that collect stormwater via constructed � Yes ❑ No conveyances. D. Answer yes or no to indicate whether you have completed the following information for each feature inventoried. 1. A unique identification (ID) number assigned by the permittee. � Yes ❑ No 2. A geographic coordinate. � Yes ❑ No 3. Type of feature (e.g., pond, wetland, or lake). This may be determined by using best professional � Yes ❑ No judgment. , If you have answered yes to all above requirements, and you have already submitted the Pond Inventory Form to the ' MPCA, then you do not need to resubmit the inventory form below. If you answered no to any of the above permit requirements, describe the tasks and corresponding schedules that will be taken to assure that, within 12 months of the date permit coverage is extended, these permit requirements are met: E. Answer yes or no to indicate if you are attaching your pond, wetland and lake inventory to the MPCA � Yes ❑ No on the form provided on the MPCA website at: http://www.qca.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. If you answered no, the inventory form must be submitted to the MPCA MS4 Permit Program within 12 months of the date permit coverage is extended. V. Minimum Control Measures (MCMs) (Part II.D.5) A. MCM1: Public education and outreach 1. The Permit requires that, within 12 months of the date permit coverage is extended, existing permittees revise their education and outreach program that focuses on illicit discharge recognition and reporting, as well as other specifically selected stormwater-related issue(s) of high priority to the permittee during this permit term. Describe your current educational program, including any high-priority topics included: The City is primarily residential and therefore our public education and outreach program focuses on urbaNsuburban issues. Starting in 2013, the City formed a partnership with the Prior Lake-Spring Lake Watershed District (PLSLWD) to deliver the program to our residents. Woricing under an o�cial agreement, PLSLWD and City staff annually develop an education and outreach plan that meets all MS4 permit requirements for both organizations. The plan identifies high-priority topics and summarizes the program. It is anticipated that this program will continue throughout the current permit term. A copy of the annual MS4 education and outreach plan can be found on the City's website: www.cityofprioriake.com/LINK. 2. List the categories of BMPs that address your public education and outreach program, including the distribution of educational materials and a program implementation plan. Use the first table for categories of BMPs that you have established and the second table for categories of BMPs that you plan to implement over the course of the permit term. Include the measurable goals with appropriate timeframes that each BMP category will be implemented and completed. In addition, provide interim milestones and the frequency of action in which the permittee will implement and/or maintain the BMPs. Refer to the U.S. Environmental Protection Agency's (EPA) Measurable Goals Guidance for Phase 11 Small MS4s (http://www.epa.gov/npdes/pubs/measurablegoals. pdfl. If you have more than five categories, hit the tab key after the last line to generate a new row. 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 18 Established BMP cate ories Measurable oals and timeframes New in 2013, our Raingarden-in-a-Box initiative provided a series of 4 workshops (with 47 total attendees), information, and materials to residents to install their own raingardens. A total of 8 raingardens were installed in the City 2013 as a result of the initiative. The program is our "foot in the door" for connecting motivated residents with water resources issues; any water quality benefits realized from the raingardens is a bonus as the locations are not prioritized with respect to water quality. This Rain arden-in-a-Box Initiative initiative will continue durin the current ermit term. In the past the City has periodically coordinated storm drain stenciling projects. In late 2012, the City created new guidelines for stenciling and started actively marketing the program to volunteer groups. Since late 2012 a total of 44 volunteers have marked 116 storm drains in priority drainage areas (only areas with direct drainage to Prior Lake were considered). This Storm Drain Stencilin ro ram will continue durin the current ermit term. The PLSLWD, under our shared education/outreach agreement, coordinates site tours with local residents and government officials to showcase specific projects and programs. Tours within the City include an annual boat tour and a projects tour that includes innovative stormwater management BMPs. City staff presents information about MS4-related projects during the tours. The goal is 2 tours per year within the City, with a total of Site Tours 25 attendees. The PLSLWD, under our shared education/outreach agreement, coordinates outreach events to involve local stakeholder groups such as the PLSLWD's Citizens Advisory Committee, the Prior Lake Association, the Spring Lake Association, the City's Lakes Advisory Committee, and other similar groups. The goal is to build local capacity for volunteers by involving stakeholder groups. Members of the groups can then become well-informed advocates for local water quality — when they attend other community events, they are better able to inform others about water quality. The goal is to coordinate 3 events per year; 2013 events included an ice-off litter pickup, "Dive the Lake" event, Communit Events and "Rake for the Lake". The PLSLWD, under our shared education/outreach agreement, coordinates the publication of fact sheets, brochures, press releases, and other information according to an "Education Calendar" included with our shared education and outreach plan. This calendar can be revised each year based on past Publications results and u dated riorit to ics. The PLSLWD, under our shared education/outreach agreement, coordinates the use of various social media communication tools, such as Facebook and Twitter, to connect with members of the local community and beyond. In addition, the Prior Lake Cable Access Channel is used to broadcast short public service announcements and other information, according to the schedule in the "Education Calendar" — this calendar outlines Communications Tools the annual oals for communication tools. City staff recently initiated and actively coordinates a local Water Resources Consortium (WRC) group consisting of technical staff from various organizations. Representatives from local watershed organizations, Scott SWCD, Scott County, the Shakopee Mdwakanton Sioux Community (SMSC), and LGUs (cities and townships) meet quarterly to discuss upcoming projects, potential collaboration opportunities, and other pertinent water resources topics. The overall goal is to keep an open dialogue with other organizations in order to reduce duplication of effort and increase collaboration. Although our organizations have different education/outreach needs and target audiences, the WRC helps us to identify collaborative opportunities where programs overlap. Quarterly meetings will Re ional Collaboration continue throu hout the current ermit term. 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 Pnge 9 of 18 BMP cate ories to be implemented Measurable oals and timeframes The City will update the Water Resources section of its website to include more information about the stormwater program, our SWPPP, and education/outreach. The website was last updated a few years ago and does not meet our current needs. City staff has already performed an evaluation of the current website content and mapped out a new strategy for delivering information to residents through this useful tool. The website update will be completed in 2014 and updated throughout the Cit Website U dates current ermit term. Use measurable goals to evaluate the program each year and then use the results to inform updates to the program. Process must be complete by November 30 each year to ensure that any recommended changes can be incorporated into the program by Pro ram Evaluation the be innin of the followin ear. 3. Provide the name or the position title of the individual(s) who is responsible for implementing and/or coordinating this MCM: Water Resources Engineer (primary); Public Wo►1cs and Natural Resources Director (secondary) 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: The City annually solicits comments on its SWPPP at a regular meeting of fhe City's Lakes Advisory Committee (LAC). The LAC's purpose is to advise the City Council on matters related to the SWPPP and our Comprehensive Lakes Management Plan, an LAC-created document that guides their activities.Notice is posted in the City's o�cial newspaper (the Prior Lake American) and on the City's website 30 days in advance of the meeting. 2. List the categories of BMPs that address your public participation�nvolvement program, including solicitation and documentation of public input on the SWPPP. Use the first table for categories of BMPs that you have established and the second table for categories of BMPs that you plan to implement over the course of the permit term. Include the measurable goals with appropriate timeframes that each BMP category will be implemented and completed. In addition, provide interim milestones and the frequency of action in which the permittee will implement and/or maintain the BMPs. Refer to the EPA's Measurable Goals Guidance forPhase 11 Small MS4s (http://www.epa.gov/npdes/qubs/measurablegoals.adfl. If you have more than five categories, hit the tab key after the last line to generate a new row. Established BMP cate ories Measurable oals and timeframes The City holds 1 annual public meeting to give the public an opportunity to provide input on the adequacy of the SWPPP, with the goal of having at least 5 attendees. The City tracks the number of attendees at each annual public meeting. This Public In ut — Annual Meetin rocedure will continue throu hout the current ermit term. The City provides the public with an opportunity to review and comment on the SWPPP at the annual public meeting. Oral and written comments are solicited from the public each year for inclusion at the annual public meeting. The City also solicits public input and provides an opportunity to comment on the SWPPP at any time through the City's website. Comments received are recorded and presented at the Public Input — SWPPP Review next annual meeting. These procedures will continue throughout the current permit and Comments term. The City complies with local public meeting notice requirements when advertising for Public Input — Annual Meeting the annual public meeting. This procedure will continue throughout the current permit Public Notice term. The City posts the current SWPPP document on its website: Documentation — Public Access htt ://www.cit of riorlake.com/documents/StormwaterPollutionPreventionPro ram. df BMP cate ories to be im lemented Measurable oals and timeframes Documentation — Public Access Enhance public access to SWPPP documentation by posting the 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 10of 18 SWPPP document, annual reports, and other documentation that supports or describes the SWPPP on the City's website. Create a separate MS4 section of the City's website to meet this oal b the end of 2014. Create a database for tracking public input as required by the permit. The database will track all relevant written input submitted by persons regarding the SWPPP, all responses from the permittee to written input received regarding the SWPPP, any modifications made to the SWPPP as a result of written input received, date(s) and location(s) of events held for purposes of compliance with the public participation/involvement requirements of the permit, and notices provided to the public of any events scheduled to meet the participation/involvement requirements of the permit, including any electronic correspondence (e.g., website, email distribution lists, notices, etc.). Database will be created by the end of 2014 and updated Documentation — Public In ut throu hout the rest of the current ermit term. 3. Do you have a process for receiving and documenting citizen input? ❑ Yes � No If you answered no to the above permit requirement, describe the tasks and corresponding schedules that will be taken to assure that, within 12 months of the date permit coverage is extended, this permit requirement is met: Although citizen input is being documented under the current program, as described in the table above, the City will work to create a database to receive and document citizen input in order to meet current permit requirements. 4. Provide the name or the position title of the individual(s) who is responsible for implementing and/or coordinating this MCM: Water Resources Engineer (primary); Public Wo►ics and Natural Resources Director (secondary) 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 currently relies on several different sections of its City Code (Sections 601, 605, 606, 607, 701, 706) to meet SWPPP requirements. Illicit discharge detection is incorporated into storm sewer system inspection and maintenance activities. When discovered, illicit discharges are tracked using the storrn sewer system map and inspection repo►ts. The City maintains a Stormwater Noncompliance Hotline (952-447-9890) for reporting illicit discharges to the storm sewer system. 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 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 Poge 11 of 18 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). If you answered no to any of the above permit requirements, describe the tasks and corresponding schedules that will be taken to assure that, within 12 months of the date permit coverage is extended, these permit requirements are met: C.2. c.: The current Illicit Discharge and Elimination Program (IDEP) does not meet the training requirements of the new MS4 permit. The City will draft a new lllicit Discharge ordinance and corresponding ERPs to meet this permit requirement within 12 months of the date permit coverage is extended. C.2.d.: The current IDEP does not meet the prioritization requirements of the new MS4 permit. The City will draft a new lllicit Discharge ordinance and corresponding ERPs to meet this permit requirement within 12 months of the date permit coverage is extended. C.2. e.: The current IDEP does not include written procedures that meet the timely response requirements of the new MS4 permit. The City will draft a new Illicit Discharge ordinance and corresponding ERPs to meet this permit requirement within 12 months of the date permit coverage is extended. C.2. f.: The current IDEP does not include wriften procedures that meet the investigatioMocation/elimination requirements of the new MS4 pe►mit. The City will draft a new lllicit Discharge ordinance and corresponding ERPs to meet this permit requiremenf within 12 months of the date permit coverage is extended. C.2.g.: The current IDEP does not include written procedures that meet the spill response requirements of the new MS4 permit. The City will draft a new lllicit Discharge ordinance and corresponding ERPs to meet this permit requirement within 12 months of the date permit coverage is extended. C.2. h.: The current IDEP does not include written ERPs, as required by the new MS4 permit. The City will draft a new lllicit Discharge ordinance and corresponding ERPs to meet this permit requirement within 12 months of 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 BMPs. Refer to the EPA's Measurable Goals Guidance forPhase 11 Small MS4s (http://www.eqa.qov/npdes/pubs/measurableqoals. pdfl. If you have more than five categories, hit the tab key after the last line to generate a new row. Established BMP cate ories Measurable oals and timeframes City employees annually inspect storm water system infrastructure as part of their normal job duties; these employees are trained to notify stormwater program staff of any illicit discharges. Stormwater program staff responds to all reported illicit discharges (by City staff and the public). All inspections are documented using the City's standard Ins ections stormwater infrastructure ins ection rocess. Use the City's existing ordinances to enforce illicit discharges (ongoing). Annually review existing ordinances and develop Re ulato Control recommendations for future ordinance u dates. BMP cate ories to be implemented Measurable oals and timeframes Public works field staff will incorporate illicit discharge inspections into their normal job duties. This program change will be done in conjunction with updates to ordinances and in Ins ections accordance with the new ERPs. Incorporate new training methodology to support ERPs that relate to illicit discharge detection and elimination (targeted to public works field staf�. Initial new training efforts will take Trainin lace in 2014 and continue throu hout the current ermit term. Update City website at least annually with general information about illicit discharge and specific information about the City's illicit discharge detection and elimination program. Promote Website website throu h the education and outreach ro ram MCM1 . 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 18 i 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 If you answered no, indicate how you will develop procedures for record-keeping of your Illicit Discharge, Detection and Elimination Program, within 12 months of the date permit coverage is extended: 5. Provide the name or the position title of the individual(s) who is responsible for implementing and/or coordinating this MCM: Water Resources Engineer (primary); Public Wo►fcs and Natural Resources Director (secondary) D. MCM 4: Construction site stormwater runoff control 1. The Permit (Part III.D.4) requires that, within 12 months of the date permit coverage is extended, existing permittees shall revise their current program, as necessary, and continue to implement and enforce a construction site stormwater runoff control program. Describe your current program: City code requires that all stormwater runoff and erosion and sediment control structures/procedures conform with the provisions of the Public Works Design Manual (PWDM) and other State regulations (Subdivision Code, Sections 1004.700 and 1004.800). The PWDM requires that all development that disturbs greater than 1 acre of land must apply for and comply with the requirements of the construction site NPDES permit. The SWPPP must be reviewed and approved by the City before an Excavating and Grading Permit may be issued. When coordinating with design engineers, the City uses checklists and review memos to outline design requirements. Development designs must meet or exceed all stormwater management and erosion and sediment control requirements before fhey can be approved through the City's platting process. During the review process the Prior Lake-Spring Lake Watershed District (PLSLWD) is invited to review and provide comments relating to all projects within their jurisdiction. The City inspects all active development projects under an agreement with the Prior Lake-Spring Lake Watershed District (PLSLWD). The PLSLWD provides site inspection services (minumum frequency is weekly), creates inspection reports that comply with current NPDES permit requirements, coordinates follow-up inspections with City staff, and keeps records of all inspections. City staff coordinates with contractors and uses the inspection results to compel contractors to comply with NPDES pe►mit requirements. 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's general permit to Discharge StormwaterAssociated with Construction Activity No. MN R100001? 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.c. & D.2.d.1): Although the City currently meets most per►nit requirement listed above, a simpler and more effective construction site stormwater runoff control program is needed. The City will meet the permit requirements listed in this section within 12 months of the date permit coverage is extended. The following tasks will be completed: 1. C ity staff will develop a n eros and sediment control o r d in a nce that meets current MS4 permit requirements. This 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 18 ordinance will replace the various regulatory mechanisms that were previously used to regulate erosion and sediment control. 2. The City Council will review and consider approving an erosion and sediment control ordinance. 3. Ordinance will be in effect within 12 months of the date pe►mit coverage is extended. 4. Ordinance will reference a document or set of documents that include all required elements of an effective construction site stormwater runoff control program, including procedures for identifying priority sites for inspection and identifying those responsible for conducting construction site inspections. These two program elements were not checked on the list above, but it is anticipated that the program will be addressed as a whole, ratMer than adding elements to the existing program. All reference documents will be completed and in effect within 12 months of 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 impiement over the course of the permit term. Include the measurable goals with appropriate timeframes that each BMP category will be implemented and completed. In addition, provide interim milestones and the frequency of action in which the permittee will implement and/or maintain the BMPs. Refer to the EPA's Measurable Goals Guidance for Phase 11 Small MS4s (http://www.eqa.gov/npdes/pubs/measurabiegoals.pdfl. If you have more than five categories, hit the tab key after the last line to generate a new row. Established BMP cate ories Measurable oals and timeframes The City has an ordinance that requires compliance with the current erosion and sediment control provisions of the State NPDES construction permit. All SWPPPs must be reviewed and approved by the City before construction may begin. The City will review the current ordinance, PWDM, and procedures at least annually to determine if revisions are needed in order to Ordinance meet MS4 ermit re uirements. The City uses an erosion and sediment control inspection program to ensure that all development sites comply with approved plans and permit requirements. If deficiencies are found, the City requires corrective actions by permit holders using escalating enforcement options according to ordinance and development agreements. The City will review the current inspection program procedures at least annually to determine if Ins ections revisions are needed in order to meet MS4 ermit re uirements BMP cate ories to be im lemented Measurable oals and timeframes Develop and implement written ERPs that meet permit requirements within 12 months of the date permit coverage is ERPs extended. ERPs will enhance existin enforcement mechanism. The City will annually review the existing education and outreach program (MCM1), with respect to MCM4, and determine if revisions are needed in order to meet MS4 permit Education re uirements. 4. Provide the name or the position title of the individual(s) who is responsible for implementing and/or coordinating this MCM: Water Resources Engineer (primary); Public Works and Natural Resources Director (secondary) E. MCM 5: Post-construction stormwater management 1. The Permit (Part III.D.S.) 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: 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 14of 18 City code requires that all stormwater runoff controls conform with the provisions of the Public Works Design Manual (PWDM) and other State regulations (Subdivision Code, Section 1004.800).The PWDM requires rate and volume control for all development, redevelopment, or change in use that creates more than 3, 500 square feet of new impervious area and disturbs more than 10, 000 square feet of land. When coordinating with design engineers, the City uses checklists and review memos to outline design requirements. Development designs must meet or exceed all stormwater management requirements before they can be approved through the City's platting process. During the review process the Prior Lake-Spring Lake Watershed District (PLSLWD) is invited to review and provide comments relating to all projects within their jurisdiction. 2. Have you established written procedures for site plan reviews that you will conduct prior to the start of � Yes ❑ No construction activity? 3. Answer yes or no to indicate whether you have the following listed procedures for documentation of � post-construction stormwater management according to the specifications of Permit (Part III.D.5.c.): a. Any supporting documentation that you use to determine compliance with the Permit (Part � 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)(fl)? ❑ Yes � No d. All legal mechanisms drafted in accordance with the Permit (Part III.D.5.a.(5)), including date(s) of ❑ Yes � No the agreement(s) and names of all responsible parties involved? If you answered no to any of the above permit requirements, describe the steps that will be taken to assure that, within 12 months of the date permit coverage is extended, these permit requirements are met. E.3.c.: The City does not currently have written procedures for documentation that meet the requirements of this section of the new MS4 permit. The City will draft written procedures to meet this permit requirement within 12 months of the date permit coverage is extended. E.3.d.: The City does not currently have written procedures for documentation that meet the requirements of this section of the new MS4 permit. The City will draft written procedures to meet this permit requirement within 12 months of the date permit coverage is extended. I 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 impfemented and completed. In addition, provide interim milestones and the frequency of action in which the permittee will implement and/or maintain the BMPs. Refer to the EPA's Measurable Goals Guidance forPhase 11 Small MS4s (httq�//www epa qov/npdes/pubs/measurablegoals pdfl. If you have more than five categories, hit the tab key after the last line to generate a new row. Established BMP cate ories Measurable oals and timeframes The City's site plan review process, with respect to MCM5, is well-established within the required platting process. All projects that trigger a review must be approved through this process. The City will continue to implement this BMP during the current permit term, and enhance the program with an Site Plan Review u dated re ulato mechanism and ERPs. BMP cate ories to be implemented Measurable oals and timeframes Develop and implement written ERPs that meet permit requirements for MCM5 within 12 months of the date permit ERPs covera e is extended. 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 18 5. Provide the name or the position title of the individual(s) who is responsible for implementing and/or coordinating this MCM: Water Resources Engineer (primary); Public Wo►ics and Natural Resources Director (secondary) 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 has an extensive operations and maintenance program in place that serves to prevent or reduce the discharge of pollutants from City owned/operated facilities and operations. In addition to annually inspecting at least 20% of all ponds and outfalls within the storm sewer system, City staff also annually inspects structural stormwater BMPs and basic stormwaterinfrastructure (inlets, catch basins, pipes, manholes, etc.). Detailed GIS maps and inspection records are kept and maintenance projects are prioritized based on a standardized rating system. Maintenance of the storm sewer system must be prioritized and implemented in order to keep up with system aging and to ensure that failing system elements do not threaten overall water quality. The Cify also implements a targeted street sweeping program with the goal of preventing excess sediment and nutrients from entering the sfoirn sewer system. Areas are targeted for enhanced street sweeping based on canopy cover, connectivity to surface water (location in the treatment train), and location within priority areas (for example, areas that drain to an impaired waterbody). 2. Do you have a facilities inventory as outlined in the Permit (Part III.D.6.a.)? ❑ Yes � No 3. If you answered no to the above permit requirement in question 2, describe the tasks and corresponding schedules that will be taken to assure that, within 12 months of the date permit coverage is eutended, this permit requirement is met: I F.2.: The City does not currently have a facilities inventory that meets the requirements of this section of the new MS4 � pe►mit. The City will complete a facilities inventory that meets this permit requirement within 12 months of 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 BMPs. For an explanation of ineasurable goals, refer to the EPA's Measurable Goals Guidance for Phase 11 Small MS4s (http�//www epa qov/npdes/pubs/measurablegoals pdfl. If you have more than five categories, hit the tab key after the last line to generate a new row. Established BMP cate ories Measurable oals and timeframes The City annually inspects ponds, outfalls, and structural stormwater BMPs to meet permit requirements. In addition, the City annually inspects other parts of the storm sewer system (inlets, catch basins, pipes, manholes, etc.). Based on the results of the inspections, storm sewer maintenance projects are prioritized for implementation. The City will continue to Stormwater Infrastructure Ins ections im lement this BMP throu hout the current ermit term. The City annually reviews and prioritizes potential stormwater infrastructure maintenance projects based on inspection results. The City will continue to implement this BMP throughout the Stormwater Infrastructure Maintenance current ermit term. BMP cate ories to be implemented Measurable goals and timeframes The City will complete a facilities inventory that meets this permit requirement within 12 months of the date permit coverage is Facilities Invento extended. The facilities invento will be u dated annuall . The City will incorporate BMPs into the SWPPP to protect BMPs within Source Water Protection Areas drinkin water sources as re uired b the ermit within 12 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 18 months of the date permit coverage is extended. The City will aiso include a map of these sources as required by the permit within 12 months of the date ermit covera e is extended. The City will develop procedures and a schedule for the purpose of determining the TSS and TP treatment effectiveness of all City-owned/operated stormwater ponds as required by the permit within 12 months of the date permit coverage is Pond Assessment Procedures and Schedule extended. The City will develop an enhanced employee stormwater management training program as required by the permit within 12 months of the date permit coverage is extended. The City will then implement this program throughout the remainder of the Trainin current ermit term. 5. Does discharge from your MS4 affect a Source Water Protection Area (Permit Part III.D.6.c.)? � Yes ❑ No a. If no, continue to 6. b. If yes, the Minnesota Department of Health (MDH) is in the process of mapping the following items. Maps are available at http�//www.health.state.mn.us/divs/eh/water/swp/maqs/index.htm. Is a map including the following items available for your MS4: 1) Wells and source waters for drinking water supply management areas identified as � Yes ❑ No vulnerable under Minn. R. 4720.5205, 4720.5210, and 4720.5330? 2) Source water protection areas for surface intakes identified in the source water � Yes ❑ No assessments conducted by or for the Minnesota Department of Health under the federal Safe Drinking Water Act, U.S.C. §§ 300j —13? c. Have you developed and implemented BMPs to protect any of the above drinking water � Yes ❑ No sources? 6. Have you developed procedures and a schedule for the purpose of determining the TSS and ❑ Yes � No TP treatment effectiveness of all permittee owned/operated ponds constructed and used for the collection and treatment of stormwater, according to the Permit (Part III.D.6.d.)? 7. Do you have inspection procedures that meet the requirements of the Permit (Part III.D.6.e.(1)- � Yes ❑ No (3)) for structural stormwater BMPs, ponds and outfalls, and stockpile, storage and material handling areas? 8. Have you developed and implemented a stormwater management training program commensurate with each employee's job duties that: a. Addresses the importance of protecting water quality? ❑ Yes � No b. Covers the requirements of the permit relevant to the duties of the employee? ❑ Yes � No c. Includes a schedule that establishes initial training for new and/or seasonal employees and ❑ Yes � No recurring training intervals for existing employees to address changes in procedures, practices, techniques, or requirements? 9. Do you keep documentation of inspections, maintenance, and training as required by the Permit � Yes ❑ No (Part III.D.6.h.(1)-(5))? If you answered no to any of the above permit requirements listed in Questions 5— 9, then describe the tasks and corresponding schedules that will be taken to assure that, within 12 months of the date permit coverage is extended, these permit requirements are met: F.6.: The City will develop procedures and a schedule for the purpose of determining the TSS and TP treatment effectiveness of all City owned/operated ponds constructed and used for the collection and treatment of stormwater, according to the permit, within 12 months of the date permit coverage is extended. F.8.a.: The City will develop a stormwater management training program commensurate with each employee's job duties to address the importance of protecting water quality within 12 months of the date permit coverage is extended. F.8.b.: The City will develop a stormwater management training program commensurate with each employee's job duties that covers the ► of the permit relevant to the duties of the employee within 12 months of the date permit coverage is extended. F.8.c.: The City will develop a stormwatermanagement training program commensurate with each employee's job duties that includes a schedule that establishes initial training for new and/or seasonal employees and recurring training intervals for existing employees to address changes in procedures, practices, techniques, or 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 POBe »°f 18 within 12 months of the date permit coverage is extended. 10. Provide the name or the position title of the individual(s) who is responsible for impiementing and/or coordinating this MCM: Water Resources Engineer (primary); Public Works and Natural Resources Director (secondary) VI. Compliance Schedule for an Approved Total Maximum Daily Load (TMDL) with an Applicable Waste Load Allocation (WLA) (Part ��.�.6.) A. Do you have an approved TMDL with a Waste Load Allocation (WLA) prior to the effective date � Yes ❑ No of the Permit? 1. If no, continue to section VII. 2. If yes, fill out and attach the MS4 Permit TMDL Attachment Spreadsheet with the following naming convention: MS4NameHere TMDL. 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 ��.�.�.) 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.)? 1. If no, this section requires no further information. 2. If yes, you own and/or operate an Alum or Ferric Chloride Phosphorus Treatment System within your small MS4, then you must submit the Alum or Ferric Chloride Phosphorus Treatment Systems Form supplement to this document, with the following naming convention: MS4NameHere TreatmentSystem. This form is found on the MPCA MS4 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 Poge 18 of 18