6b attach 2
FOR PHASE I PROPERTIES Updated March 2011 Port of Seattle Stormwater Management Program for Phase I Properties Table of Contents Introduction .......................................................................................................................................... 1 Port Overview .................................................................................................................................. 1 Permit Overview.............................................................................................................................. 2 Key Implementation Dates ............................................................................................................ 2 SWMP Organization ....................................................................................................................... 4 Public Education Program (S6.E.1) .................................................................................................. 5 Public Involvement and Participation (S6.E.2) ............................................................................... 7 Illicit Discharge Detection and Elimination (S6.E.3) ..................................................................... 8 Construction Site Runoff Control (S6.E.4) .................................................................................... 12 Post-Construction Stormwater Management for New Development and Redevelopment (S6.E.5) ................................................................................................................... 15 Operation and Maintenance Program (S6.E.6) ............................................................................. 17 Source Control in Existing Developed Areas (S6.E.7)................................................................. 20 Total Maximum Daily Load Requirements (S7) ............................................................................ 23 Monitoring (S8) .................................................................................................................................. 24 Reporting (S9)..................................................................................................................................... 30 Conclusion .......................................................................................................................................... 32 Port of Seattle Stormwater Management Program for Phase I Properties Updated March 2011 Introduction The Port of Seattle Seaport and Real Estate properties in the City of the Seattle (the Port) division of the Port of Seattle have produced this Stormwater Management Program (SWMP) to demonstrate compliance with the requirements of the National Pollutant Discharge Elimination System (NPDES) Phase I Municipal Stormwater Permit, issued January 17, 2007 and updated June 17, 2009 by the Washington State Department of Ecology (Ecology). The Port's SWMP provides an overview of the Port's activities related to stormwater management on properties covered by the Phase I Municipal Stormwater Permit (Phase I Properties). The SWMP was first submitted to Ecology in March 2008, along with the Port's first Phase I Municipal Stormwater Permit Annual Report. Annual updates to the SWMP accompany each subsequent year's Annual Report. Port Overview Within the City of Seattle, the Port owns, operates, and maintains approximately 1,200 acres of marine terminals, marinas, parks, and shoreline public access areas, and manages aquatic areas adjacent to port facilities. The Port's water-dependent facilities and activities are a substantial base of economic activity and employment within the City of Seattle, the port district, and the State of Washington. The Port is a publicly owned and operated municipal corporation authorized by state law to plan, construct, operate, and maintain harbor improvements within the port district. Specifically, the Port provides marine services and cargo and passenger terminals for large vessels, serving diverse marine transportation businesses. The Port also provides facilities for all elements of the fishing industry, other water-dependent and water-related commercial and industrial uses, and recreational boats, including improvements at Fishermen's Terminal, the Maritime Industrial Center, Harbor Island Marina, Shilshole Bay Marina and Bell Harbor Marina. The Port implements significant environmental restoration, cleanup, and habitat enhancement as part of its capital improvement programs and ongoing operations and management of Port facilities. The Port has also created 20 public shoreline access points where residents and visitors can get a first hand look at the City's maritime environment and economy. P o r t o f S e a t t l e S t o r m w a t e r M a n a g e m e n t P l a n f o r P h a s e I P r o p e r t i e s 1 otak K:\project\31100\31104J\Reports\SWMP\Seaport 2011 SWMP Final.doc Introduction Continued Permit Overview The NPDES program is a requirement of the Federal Clean Water Act. The Environmental Protection Agency (EPA) has delegated NPDES administration authority in Washington State to the Department of Ecology (Ecology). On January 17, 2007, Ecology issued the Phase I Municipal Stormwater Permit which addresses discharges from Large and Medium Municipal Separate Storm Sewer Systems (MS4s). An updated permit was issued June 17, 2009. The Port of Seattle (excluding Seattle-Tacoma International Airport) has been designated as a Secondary Permittee with coverage under the Phase I Municipal Stormwater Permit. The Phase I Municipal Stormwater Permit authorizes the discharge of stormwater from the MS4 to surface waters and ground waters of the state. To do so, the Port must develop and implement a Stormwater Management Program (SWMP) for the Phase I Properties that is designed to protect water quality and reduce the discharge of pollutants from the MS4 to the maximum extent practicable, as defined by the Phase I Municipal Stormwater Permit. The Phase I Municipal Stormwater Permit requires the Port to prepare written documentation of the SWMP for Phase I Properties. The written SWMP is to be updated as significant portions of the program are implemented (i.e. annually). In addition, the Port is required to submit Annual Reports by March 31 of each year to document the progress toward implementing the SWMP components on Phase I Properties over the prior calendar year. Key Implementation Dates The Phase I Municipal Stormwater Permit was issued on January 17, 2007, became effective February 16, 2007 and expires February 15, 2012. An updated permit was issued June 17, 2009 with an effective dated of July 17, 2009. The Port's official effective date is March 9, 2007 the date on which the Port submitted a Notice of Intent for Phase I Properties to comply with the Phase I Municipal Stormwater Permit. Ecology is expected to revise and reissue another multi-year permit in 2012. The Phase I Municipal Stormwater Permit includes phased deadlines for many of the program components over the first several years of the permit term. Table 1 shows a general overview of the deadlines and implementation dates for program activities. All deadlines and required implementation dates for the Phase I Properties are based on the March 9, 2007 effective date. P or t o f S e a t t l e S t o r m w a t e r M a n a g e m e n t P l a n f o r P h a s e I P r o p e r t i e s 2 otak K:\project\31100\31104J\Reports\SWMP\Seaport 2011 SWMP Final.doc Introduction Continued P o r t o f S e a t t l e S t o r m w a t e r M a n a g e m e n t P l a n f o r P h a s e I P r o p e r t i e s 3 otak K:\project\31100\31104J\Reports\SWMP\Seaport 2011 SWMP Final.doc Introduction Continued SWMP Organization The Port intends to achieve compliance with the Phase I Municipal Stormwater Permit by implementing a suite of Best Management Practices (BMPs) on Phase I Properties over the next three to five years. A stormwater BMP is defined as any program, technology, process, siting criterion, operating method, measure, or device that controls, removes, or reduces pollution. The current and proposed BMPs are grouped into the following program components organized according to the requirements in the Phase I Municipal Stormwater Permit: S6.E.1 Education Program (Section 1) S6.E.2 Public Involvement and Participation (Section 2) S6.E.3 Illicit Discharge Detection and Elimination (Section 3) S6.E.4 Construction Site Runoff Control (Section 4) S6.E.5 Post Construction Stormwater Management for New Development and Redevelopment (Section 5) S6.E.6 Operation and Maintenance Program (Section 6) S6.E.7 Source Control in Existing Developed Areas (Section 7) S7 Total Maximum Daily Load Requirements (Section 8) S8 Monitoring (Section 9) S9 Reporting (Section 10) A detailed listing of the requirements and the proposed implementation plan relating to each program component are presented in the tables included in the remaining sections of this SWMP. This updated SWMP documents BMPs implemented as of February 2011 and outlines a draft plan to meet permit deadlines and maintain compliance throughout the permit term. Note that this SWMP update (2011) does not include any changes to the proposed BMPs or implementation schedule of any program components. This update serves to document the progress to date in implementing the scheduled activities. P o r t o f S e a t t l e S t o r m w a t e r M a n a g e m e n t P l a n f o r P h a s e I P r o p e r t i e s 4 otak K:\project\31100\31104J\Reports\SWMP\Seaport 2011 SWMP Final.doc Section 1Public Education Program (S6.E.1) Public Education Program (S6.E.1) This section describes the permit requirements, programs, and planned activities related to Public Education. Current activities in this area include: Brochure distributed to Seaport tenants and posted on Port of Seattle website. Stormwater management information posted on Port of Seattle website. Video shown to employees who attended HAZWOPER Training. Email distribution of Seaport Stormwater News Bulletin. Developed and published stormwater-related website specific to Seaport issues. Website includes Phase I Municipal Stormwater Permit information and a resource pages for tenants and the public to learn more about stormwater. (http://www.dev.portseattle.org/community/environment-water/seaport/stormwater.shtml) Website update to expand educational information presented. Utilized a grant from Ecology to hire an education consultant to develop and implement tenant education program that is in addition to the Permit requirements. Activities performed by the education consultant include: o Prepared education outreach strategy. o Conducted site visits with tenants to educate them on their stormwater responsibilities, provides SWPPP templates for completion, and assists tenants in developing appropriate SWPPP documents. o Conducted stormwater understanding surveys to measure current tenant understanding of stormwater issues and responsibilities. o Published summary of work and results of stormwater understanding surveys for use in the Port's Targeted Stormwater Management Program Effectiveness Monitoring (S8.E). The following table outlines the implementation plan to achieve the goals and objectives of the Public Education program and meet the compliance deadlines in the Phase I Municipal Stormwater Permit. P o r t o f S e a t t l e S t o r m w a t e r M a n a g e m e n t P l a n f o r P h a s e I P r o p e r t i e s 5 otak K:\project\31100\31104J\Reports\SWMP\Seaport 2011 SWMP Final.doc Section 1Public Education Program (S6.E.1) Continued Permit Element Education Program S6.E.1 Purpose: Educate Port community about impacts to stormwater and importance of stormwater as an environmental resource. Reduce or eliminate behaviors and practices that cause or contribute adverse stormwater impacts. Applicability: Applies to Seaport tenants and Port employees. Permit Requirement Action Plan Schedule Notes S6.E.1.a Education Program Develop an education program aimed at tenants and Port Develop educational materials employees. Make educational and conduct outreach activities Due Date: September 2008 materials available to tenants Distribute educational materials Status: Program developed; and Port employees whose job Post distributed information on Implementation is ongoing. duties could impact the Seaport website stormwater. P o r t o f S e a t t l e S t o r m w a t e r M a n a g e m e n t P l a n f o r P h a s e I P r o p e r t i e s 6 otak K:\project\31100\31104J\Reports\SWMP\Seaport 2011 SWMP Final.doc Section 2Public Involvement and Participation (S6.E.2) Public Involvement and Participation (S6.E.2) This section describes the permit requirements, programs, and planned activities related to Public Involvement and Participation. Current activities in this area include: Posted SWMP and Annual report on the Seaport's new stormwater website. (http://www.dev.portseattle.org/community/environment-water/seaport/stormwater- municipalpermits.shtml) The following table outlines the implementation plan to achieve the goals and objectives of the Public Involvement and Participation program and meet the compliance deadlines in the Phase I Municipal Stormwater Permit. Permit Element Public Involvement and Participation S6.E.2 Purpose: Solicit public review of the SWMP for Phase I Properties. Applicability: Applies to Seaport tenants and general public. Permit Requirement Action Plan Schedule Notes S6.E.2.a Publish Notice Publish public notice to solicit SWMP input in the newspaper Request SWMP input via the Due Date: September 2011 Publish a public notice in the Port's Website Status: Public notice and local newspaper. Solicit Send request for comment public review of SWMP public review of the SWMP. notice to Port tenants and planned for 2011. surrounding properties Collect and review comments on SWMP S6.E.2.B Post SWMP on Website Make the SWMP available to Due date: September 2011 the public. Post the SWMP Post SWMP on Port website Status: Completed. on the Port's Website. P o r t o f S e a t t l e S t o r m w a t e r M a n a g e m e n t P l a n f o r P h a s e I P r o p e r t i e s 7 otak K:\project\31100\31104J\Reports\SWMP\Seaport 2011 SWMP Final.doc Section 3Illicit Discharge Detection and Elimination (S6.E.3) Illicit Discharge Detection and Elimination (S6.E.3) This section describes the permit requirements, programs, and planned activities related to Illicit Discharge Detection and Elimination (IDDE). Current activities in this area include: Field work to collect required mapping data. Office work to download collected data and create associated maps and reports. Developed and adopted an appropriate IDDE policy. Implementation of the City's relevant ordinances, rules and regulations that govern IDDE. Identified potential mechanisms to enforce the IDDE policy. Developed a spill response plan. Prepared IDDE Program Guidance Manual to document IDDE policies, enforcement mechanisms, field inspection procedures, and the spill response plan. Ongoing outfall inspections as weather and tides allow. Follow-up on suspected illicit discharge problem areas to determine if outflows are from receding tidal water, groundwater, or a legitimate illicit discharge. Worked through procedures to clean up and remove identified illicit discharges. Developed a Maximo database to track maintenance related activities. The following table outlines the implementation plan to achieve the goals and objectives of the IDDE program and meet the compliance deadlines in the Phase I Municipal Stormwater Permit. Permit Element Illicit Discharge Detection and Elimination S6.E.3 Purpose: Detect, remove, and prevent illicit connections and illicit discharges, including spills into the MS4. Applicability: Applies to all areas of the MS4 on Phase I Properties owned or operated by the Port. Permit Requirement Action Plan Schedule Notes S6.E.3 IDDE Program Prepare written documentation Include a program in the of the IDDE Program to SWMP to detect, remove, document IDDE policies, and prevent illicit enforcement mechanisms, connections and illicit See below field inspection procedures, discharges, including spills, and spill response plan. into the MS4 owned or Implement the activities and operated by the Port. BMPs listed in S6.E.3.a P o r t o f S e a t t l e S t o r m w a t e r M a n a g e m e n t P l a n f o r P h a s e I P r o p e r t i e s 8 otak K:\project\31100\31104J\Reports\SWMP\Seaport 2011 SWMP Final.doc Section 3Illicit Discharge Detection and Elimination (S6.E.3) Continued through S6.E.f.f. S6.E.3.a Compliance with Local Jurisdiction Comply with all ordinances, Verify that Port activities on rules, and regulations from Phase I Properties comply Due Date: Ongoing the local jurisdiction that with City of Seattle Status: Completed govern non-stormwater ordinances, rules, and discharges. regulations. S6.E.3.b IDDE Policy and Enforcement Develop and adopt appropriate policies prohibiting illicit discharges and illegal dumping. These Review City of Seattle policy policies shall address, at a and Phase I Permit minimum: illicit connections, requirements as background non-stormwater discharges for Port policy. Due Date: March 2008 as defined in S6.E.3.b.i Prepare draft policy for review Status: Completed through S6.E.3.b.v, and with legal council. spilling, dumping, or Finalize policy and present to otherwise improperly commission for adoption. disposing of hazardous materials, pet waste, and litter. Identify and discuss enforcement mechanisms with legal council. Identify possible Enforcement mechanisms include enforcement mechanisms to Due Date: March 2008 sending reminder notices to ensure compliance with illicit Status: Completed tenants and referring violations to discharge policies. the City of Seattle or Department of Ecology or an internal Port entity. Develop and implement and enforcement plan using Outline enforcement Due Date: September 2008 these mechanisms to ensure mechanisms for inclusion in Status: Completed compliance with illicit IDDE plan. discharge policies. P o r t o f S e a t t l e S t o r m w a t e r M a n a g e m e n t P l a n f o r P h a s e I P r o p e r t i e s 9 otak K:\project\31100\31104J\Reports\SWMP\Seaport 2011 SWMP Final.doc Section 3Illicit Discharge Detection and Elimination (S6.E.3) Continued S6.E.3.c Data Collection Include an ongoing program for gathering, maintaining, and using adequate information to conduct planning, priority setting, and program evaluation for Phase I Properties. The following information will be gathered and retained: Collect field data on all Mapping of known MS4 existing known outfalls. outfalls and maps depicting Download data and create land use for property owned appropriate maps and reports Due Date: March 2009 by the Port, and all other in GIS to meet Ecology Status: Completed properties served by the formatting requirements. MS4 owned or operated by Develop land use maps of the Port. Phase I Properties. Collect field data on all existing known outfalls. Mapping of tributary Define drainage basin conveyances and the boundaries for tributary associated drainage areas systems. of the MS4 outfalls owned or Due Date: March 2009 Download data and create operated by the Port with a Status: Completed appropriate maps and reports 24 inch nominal diameter or in GIS to meet Ecology larger or equivalent cross- formatting requirements. sectional area. Develop land use maps of Phase I Properties. To the extent consistent with national security laws and directives, make available to Review Port security policies Ecology upon request, GIS related to infrastructure data layers generated by the information sharing. Due Date: As requested Port depicting outfall If allowable, make GIS data Status: No requests to date locations, land use, tributary layers available to Ecology conveyances, and upon request. associated drainage areas of outfalls owned or operated by the Port. Develop stormwater facility inventory based on Document operation and Due Date: March 2009 construction plans, staff maintenance records for Status: Developed an O&M knowledge, and field visits. stormwater facilities covered database to track Enter inventory data in O&M under this permit. The stormwater related database and track O&M information shall be maintenance activities. actions. available for inspection by Records are available to Create annual O&M reports. Ecology. Ecology upon request. Make reports available to Ecology upon request. P o r t o f S e a t t l e S t o r m w a t e r M a n a g e m e n t P l a n f o r P h a s e I P r o p e r t i e s 10 otak K:\project\31100\31104J\Reports\SWMP\Seaport 2011 SWMP Final.doc Section 3Illicit Discharge Detection and Elimination (S6.E.3) Continued To the extent consistent with Review Port security policies national security laws and related to infrastructure directives, mapping Due Date: Not specified information sharing. information and O&M Status: Records can be If allowable, make data layers records shall be provided to provided upon request. available to the City upon the City in which the Port is request. located. S6.E.3.d Field Inspections Due Date: Inspect 1/3 of Develop inspection form to outfalls each year Conduct field inspections document field data. beginning by March 2009. and visually inspect for illicit Conduct inspections as Status: Initial inspections of discharges at all known required. all outfalls were conducted outfalls that discharge to Refer problems to appropriate as part of field data surface water. Keep records staff for follow-up. collection for mapping effort of inspections and follow-up activities. Maintain field inspection (S6.3.c). Inspections are onrecords. going each summer as weather and tides allow. Develop and implement Document field inspection Due Date: September 2008 procedures to identify and procedures in the IDDE Plan. Status: Completed. remove any illicit discharges. S6.E.3.d Spill Response Plan Develop and implement a Identify qualified spill spill response plan that responders. Due Date: September 2011 includes coordination with a Document spill response Status: Completed. qualified spill responder. procedures in IDDE plan. S6.E.3.f Staff Training Provide staff training or coordinate with existing Due Date: Not specified Coordinate with education training efforts to educate Status: Spill response efforts in S6.E.1 to train Port relevant staff on proper training included in annual staff. BMPs for preventing spills training program. and illicit discharges. P o r t o f S e a t t l e S t o r m w a t e r M a n a g e m e n t P l a n f o r P h a s e I P r o p e r t i e s 11 otak K:\project\31100\31104J\Reports\SWMP\Seaport 2011 SWMP Final.doc Section 4Construction Site Runoff Control (S6.E.4) Construction Site Runoff Control (S6.E.4) This section describes the permit requirements, programs, and planned activities related to Construction Site Runoff Control. Current activities in this area include: Seaport projects and tenant projects on Phase I Properties are subject to the City of Seattle development code. At this time, Seaport projects on Phase I Properties will be reviewed by Port staff and tenant projects on Phase I Properties will be submitted to the City for appropriate review. Seaport Master Spec (Section 02270) includes temporary erosion and sediment control guidelines for construction projects. Obtained NPDES Construction permits for applicable projects. Requires Certified Erosion and Sediment Control Lead (CESCL) training for contractors. Conducted CESCL training for Seaport staff. Implementation of the City's relevant ordinances, rules and regulations that govern construction site runoff. The following table outlines the implementation plan to achieve the goals and objectives of the Construction Site Runoff Control program and meet the compliance deadlines in the Phase I Municipal Stormwater Permit. Permit Element Construction Site Runoff Control S6.E.4 Purpose: Continue to reduce pollutants in stormwater runoff from construction activities. Applicability: Applies to construction activities on Phase I Properties under the functional control of the Seaport. Permit Requirement Action Plan Schedule Notes S6.E.4 Construction Runoff Control Program Include a program in the SWMP to reduce pollutants Implement the activities and in stormwater runoff from BMPs listed in S6.E.4.a See below construction activities under through S6.E.4.e. functional control of the Seaport. P o r t o f S e a t t l e S t o r m w a t e r M a n a g e m e n t P l a n f o r P h a s e I P r o p e r t i e s 12 otak K:\project\31100\31104J\Reports\SWMP\Seaport 2011 SWMP Final.doc Section 4Construction Site Runoff Control (S6.E.4) Continued S6.E.4.a Compliance with Local Jurisdiction Comply with all relevant rules and regulations of the Refer tenant new development local jurisdiction that govern and redevelopment projects to Due Date: March 2008 construction stormwater. To City of Seattle for design Status: Project Design the extent allowed by local review. Guidance Manual is ordinances, comply with the Prepare Project Design complete. Update applicable minimum Guidance Manual to guide anticipated in 2011. technical requirements for internal Seaport projects. new development and redevelopment. S6.E.4.b General Permit Coverage for Construction Activities When applicable, seek and Apply for permit for projects on obtain coverage under the Phase I Properties prior to Due Date: Ongoing General NPDES Permit for construction activity Status: Continue activities in Stormwater Discharges Refer tenant projects to City of 2011. Associated with Construction Seattle and Dept. of Ecology Activities. for permit coverage S6.E.4.c Compliance Coordination Coordinate with local jurisdiction regarding Due Date: Ongoing projects owned and Coordinate with City of Seattle Status: Continue operated by other entities as applicable. coordination on an as- that discharge into needed basis. interconnected MS3s. S6.E.4.d Staff Training Seaport staff or consultant Provide training or staff representatives coordinate with existing responsible for construction training efforts to educate sites will obtain their CESEL Port Staff responsible for Due Date: Not specified certification from an Ecology implementing construction Status: Continue activities in approved resource. stormwater erosion and 2011. Require construction sediment control BMPs. contractors responsible for OR: hire trained contractors erosion control to have CESEL to perform the work. certification P o r t o f S e a t t l e S t o r m w a t e r M a n a g e m e n t P l a n f o r P h a s e I P r o p e r t i e s 13 otak K:\project\31100\31104J\Reports\SWMP\Seaport 2011 SWMP Final.doc Section 4Construction Site Runoff Control (S6.E.4) Continued S6.E.4.e Access Coordination Provide Ecology or the local jurisdiction access (as Review legal authority and requested) for inspection of potential mechanisms to allow Due Date: As requested construction sites or land inspections as required. Status: Access provided as disturbances under the Provide access as requested requested. control of the Seaport during and legally allowable. active grading and/or construction period. P o r t o f S e a t t l e S t o r m w a t e r M a n a g e m e n t P l a n f o r P h a s e I P r o p e r t i e s 14 otak K:\project\31100\31104J\Reports\SWMP\Seaport 2011 SWMP Final.doc Section 5Post-Construction Stormwater Management for New Development and Redevelopment (S6.E.5) Post-Construction Stormwater Management for New Development and Redevelopment (S6.E.5) This section describes the permit requirements, programs, and planned activities related to Post-Construction Stormwater Management for New development and Redevelopment. Current activities in this area include: Seaport projects on Phase I Properties that connect to the City's drainage system and tenant projects comply with the City of Seattle development code. Seaport projects on Phase I Properties that connect to the City's drainage system and tenant projects submit to the City for appropriate review and permits. Completed Project Design Guidance Manual to guide internal Seaport projects. Implementation of relevant ordinances, rules and regulations that govern new development and redevelopment activities. The following table outlines the implementation plan to achieve the goals and objectives of the Post-Construction Stormwater Management program and meet the compliance deadlines in the Phase I Municipal Stormwater Permit. Permit Element Post-Construction Stormwater Management S6.E.5 Purpose: Continue to establish controls to prevent or minimize water quality impacts from new development and redevelopment projects. Applicability: New development and redevelopment projects on Phase I Properties. Permit Requirement Action Plan Schedule Notes S6.E.5 Post Construction Stormwater Management Include a program in the SWMP to address post- Implement the activities and construction stormwater BMPs listed in elements See below runoff from new S6.E.5.a and S6.E.5.b development and redevelopment projects. P o r t o f S e a t t l e S t o r m w a t e r M a n a g e m e n t P l a n f o r P h a s e I P r o p e r t i e s 15 otak K:\project\31100\31104J\Reports\SWMP\Seaport 2011 SWMP Final.doc Section 5Post-Construction Stormwater Management for New Development and Redevelopment (S6.E.5) Continued S6.E.5.a Compliance with Local Jurisdiction Prepare Project Design Guidance Manual to guide Comply with all relevant internal Seaport projects. ordinances, rules and Review internal Seaport regulations of the local projects that propose new jurisdiction that govern post- development and construction stormwater redevelopment projects on Due Date: March 2008 pollution prevention Phase I Properties for Status: Project Design (including operation and compliance with the Project Guidance Manual is maintenance). To the extent Design Guidance Manual. complete. Update allowed by local ordinances, Refer tenant new development anticipated in 2011. comply with the applicable and redevelopment projects to minimum technical City of Seattle for design requirements for new review. development and redevelopment. Develop an operation and maintenance program as described in element S6.E.6. 5.3 Compliance Coordination Coordinate with local jurisdiction regarding Due Date: Ongoing projects owned and Coordinate with City of Seattle Status: Continue operated by other entities as applicable. coordination as needed. that discharge into interconnected MS3s. P o r t o f S e a t t l e S t o r m w a t e r M a n a g e m e n t P l a n f o r P h a s e I P r o p e r t i e s 16 otak K:\project\31100\31104J\Reports\SWMP\Seaport 2011 SWMP Final.doc Section 6Operation and Maintenance Program (S6.E.6) Operation and Maintenance Program (S6.E.6) This section describes the permit requirements, programs, and planned activities related to the Operation and Maintenance Program. Current activities in this area include: Parking lot and street sweeping. Catch basin cleaning. Routine maintenance of stormwater treatment facilities and other structural BMPs. Inspection of suspected problems at stormwater treatment facilities and other structural BMPs. Prepared Operations and Maintenance Manual for stormwater infrastructure, including inspection schedules, maintenance standards, and required maintenance activities. Tracking maintenance activities in the Seaport's Maximo database. The following table outlines the implementation plan to achieve the goals and objectives of the Operation and Maintenance Program and meet the compliance deadlines in the Phase I Municipal Stormwater Permit. Permit Element Operation and Maintenance Program S6.E.6 Purpose: Ensure that all BMPs continue to function properly by developing an operation and maintenance program. Applicability: All stormwater treatment facilities, flow control facilities, and catch basins on 1 Phase I Properties under functional control of the Seaport. Permit Requirement Action Plan Schedule Notes S6.E.6 Operation and Maintenance Program Include an operation and maintenance program in the Implement the activities and SWMP for all stormwater BMPs listed in elements See below treatment and flow control S6.E.6.a through S6.E.6.d. facilities and catch basins. 1 The O&M Program does not apply to tenant-controlled properties. However, many tenant-controlled properties are subject to the source control requirements, including inspection and maintenance of stormwater facilities, outlined in Permit Element S6.E.7. P o r t o f S e a t t l e S t o r m w a t e r M a n a g e m e n t P l a n f o r P h a s e I P r o p e r t i e s 17 otak K:\project\31100\31104J\Reports\SWMP\Seaport 2011 SWMP Final.doc Section 6Operation and Maintenance Program (S6.E.6) Continued S6.E.6.a O&M Manual Document stormwater facilities on Phase I Properties under Prepare an O&M manual for Seaport control. all stormwater BMPs under Review existing operation and the functional control of the maintenance practices. Due Date: March 2009 Seaport. Retain a copy of Prepare operation and Status: Complete. the manual in the maintenance manual. appropriate Seaport department. Retain copies of the manual at Seaport Maintenance and Environmental Department. Review maintenance standards in Chapter 4 of Develop facility-specific Volume V of the 2005 maintenance standards that Stormwater Management are as protective as those in Due Date: March 2009 Manual for Western the Ecology Manual to Status: Complete. Washington. determine when Incorporate maintenance maintenance is required. standards into the O&M manual. S6.E.6.b Annual BMP Inspections and Maintenance Establish an inspection schedule in the O&M Manual. Create a stormwater facility inspection checklist or report form. Due Date: Annually Manage maintenance Train staff on facility inspection Status: Schedule and report activities to inspect all as part of element S6.E.6.c. forms are complete. facilities listed in the O&M Allocate staff resources to Continue training and Manual annually. facility inspections. inspections in 2011. Prepare inspection reports to document all inspection activities as part of element S6.E.6.d. Take appropriate Prepare maintenance requests maintenance action when for facilities that exceed the Due Date: As need is the maintenance standard is maintenance standard. identified exceeded. Maintenance Conduct maintenance Status: Maintenance shall be performed within the activities as needed. schedule depends on timeline identified in permit Prepare maintenance records inspection results. condition S6.E.6.b(ii). as part of element S6.E.6.d. P o r t o f S e a t t l e S t o r m w a t e r M a n a g e m e n t P l a n f o r P h a s e I P r o p e r t i e s 18 otak K:\project\31100\31104J\Reports\SWMP\Seaport 2011 SWMP Final.doc Section 6Operation and Maintenance Program (S6.E.6) Continued S6.E.6.c Staff Training Identify training courses. Send an appropriate percentage of maintenance Due Date: Not specified Provide appropriate training staff to training each year. Status: Training activities for Port maintenance staff. Establish resources for are ongoing. internal trainings videos, webcasts, staff meetings, hiring an outside trainer, etc. S6.E.6.d Record Keeping Maintain records of Due Date: Ongoing Maintain maintenance records inspections and Status: Continue activity in in Maximo database. maintenance activities. 2011. P o r t o f S e a t t l e S t o r m w a t e r M a n a g e m e n t P l a n f o r P h a s e I P r o p e r t i e s 19 otak K:\project\31100\31104J\Reports\SWMP\Seaport 2011 SWMP Final.doc Section 7Source Control in Existing Developed Areas (S6.E.7) Source Control in Existing Developed Areas (S6.E.7) This section describes the permit requirements, programs, and planned activities related to Source Control in Existing Developed Areas. Current activities in this area include: Phase I Properties with individual, industrial, or boat yard NPDES permits have prepared Stormwater Pollution Prevention Plans (SWPPPs). Phase I Properties with individual, industrial, or boat yard NPDES permits are implementing appropriate source controls. Implementation of the City of Seattle's relevant ordinances, rules and regulations that govern source control activities. Adoption of policies and activities to require pesticide-free and synthetic fertilizer-free landscaping. Distributed SWPPP templates to tenants required to develop SWPPPs. Provided technical assistance to tenants developing SWPPPs. Completed SWPPPs for Port-controlled Phase I Properties, including Maritime Industrial Center, Fisherman's Terminal, Shilshole Bay Marina, and Marine Maintenance Areas at Pier 2, Terminal 5, and Terminal 91. SWPPPs are complete or in progress for numerous Port-controlled Phase I Properties (piers and terminals) that house office space, parking, and moorage areas as well as vacant lands. The following table outlines the implementation plan to achieve the goals and objectives of the Source Control program and meet the compliance deadlines in the Phase I Municipal Stormwater Permit. P o r t o f S e a t t l e S t o r m w a t e r M a n a g e m e n t P l a n f o r P h a s e I P r o p e r t i e s 20 otak K:\project\31100\31104J\Reports\SWMP\Seaport 2011 SWMP Final.doc Section 7Source Control in Existing Developed Areas (S6.E.7) Continued Permit Element Source Control S6.E.7 Purpose: Identify and implement measures to prevent and control the contamination of discharges of stormwater to surface or ground water. Applicability: All Port-owned lands not covered by either a General Permit or an individual NPDES permit issued by Ecology that covers stormwater discharges. Note: SWPPPs will apply to 1. Heavy Equipment Maintenance, 2. Storage Yards, 3. Material Storage, and 4. Maintenance 2 Areas. Permit Requirement Action Plan Status S6.E.7.a Stormwater Pollution Prevention Plans (SWPPPs) Develop and implement one Identify sites already covered or more SWPPPs to identify by a General Permit or an Due Date: March 2009 and implement measures to individual NPDES permit. Status: Identification prevent and control the Implement the activities and complete. See below for contamination of discharges BMPs listed in elements implementation activities. of stormwater to surface or S6.E.7.b through S6.E.7.g. ground water. S6.E.7.b Facility Assessment Establish a list of sites that must be covered by a new SWPPP. SWPPP(s) shall include a Conduct site inspections to facility assessment with a Due Date: March 2009 collect data for the facility site plan, identification of Status: Complete for Portassessment. pollutant sources, and controlled Phase I Prepare facility assessment for description of drainage Properties. each site including site plan, system. identification of pollutant sources, and description of drainage system. 2 These are the four land uses that require source control and SWPPPs as described in permittee and other secondary permittee sections of the NPDES Phase I Permit. The City of Seattle source control code and manual applies to "all Port lands" as well as all City properties. The Port will include City BMPs as part of the Stormwater Management Program to all applicable properties. P o r t o f S e a t t l e S t o r m w a t e r M a n a g e m e n t P l a n f o r P h a s e I P r o p e r t i e s 21 otak K:\project\31100\31104J\Reports\SWMP\Seaport 2011 SWMP Final.doc Section 7Source Control in Existing Developed Areas (S6.E.7) Continued S6.E.7.c BMP Identification Identify BMPs used or Identify structural and non- proposed for use. Implement structural BMPs already in Due Date: March 2009 non-structural BMPs place. Status: Identification immediately following plan Identify additional source complete. Implementation to development. Include control BMPs. follow schedule in each schedule for implementing Develop an implementation SWPPP. structural BMPs in the schedule for structural BMPs. SWPPP. S6.E.7.d Inspections Maintain list of sites covered by a SWPPP. Maintain a list of sites Establish legal authority to covered by the SWPPP(s) conduct site inspections for required by this permit. source controls. Due Date: September 2011 Inspect at least 15 percent Develop an inspection Status: Inspections are of listed sites annually and schedule. ongoing. 80 percent of all listed properties within 180 days of Conduct site inspections to the the permit expiration. extent allowed by local ordinances, rules, and regulations. S6.E.7.e Pesticide Policy Identify policies to reduce Review existing Seaport pollutants associated with maintenance plan prohibiting Due Date: March 2009 pesticides, herbicides, and the use of pesticides. Status: Complete. fertilizer. Update policy if needed. S6.E.7.f Illicit Connections, Discharges and Spills Include measures to Include reference to the prevent, identify, and Seaport's IDDE Program in respond to illicit discharges, SWPPPs. Due Date: March 2009 illicit connections, spills, and Implement Seaport IDDE Status: Complete. See improper disposal. Notify the Program on Phase I Section 3 (S6.E.3) for City or County and Ecology Properties. details. immediately upon becoming Notify City and Ecology of aware of a spill. spills as needed. S6.E.7.g Inspection and Maintenance Include a component related Include reference to the to inspection and Seaport's O&M Manual in Due Date: March 2009. maintenance of stormwater SWPPPs. Status: Complete. See facilities and catch basins Implement Seaport O&M Section 6 (S6.E.6) for that is consistent with the Program on Phase I details. Port's Operation and Properties. Maintenance Program. P o r t o f S e a t t l e S t o r m w a t e r M a n a g e m e n t P l a n f o r P h a s e I P r o p e r t i e s 22 otak K:\project\31100\31104J\Reports\SWMP\Seaport 2011 SWMP Final.doc Section 8Total Maximum Daily Load Requirements (S7) Total Maximum Daily Load Requirements (S7) The Total Maximum Daily Load (TMDL) requirements only apply if a stormwater TMDL has been established for receiving waters that receive stormwater discharge from the stormwater system on Phase I Properties owned or operated by the Seaport. The applicable TMDLs that require additional compliance activities are listed in Appendix 2 of the Phase I Municipal Stormwater Permit. At this time, none of the TMDLs listed in Appendix 2 affect the Port. As such, no additional activities are required for compliance with TMDL conditions. The Port will continue to track the development of TMDLs and participate in their development and implementation when appropriate. P o r t o f S e a t t l e S t o r m w a t e r M a n a g e m e n t P l a n f o r P h a s e I P r o p e r t i e s 23 otak K:\project\31100\31104J\Reports\SWMP\Seaport 2011 SWMP Final.doc Section 9Monitoring (S8) Monitoring (S8) This section describes the permit requirements, programs, and planned activities related to Monitoring. The permit requires the development of monitoring programs with three components: Stormwater Runoff Monitoring Targeted SWMP Effectiveness Monitoring (two practices) BMP Evaluation Monitoring Current activities in this area include: Selected outfall for stormwater monitoring. Prepared and submitted draft Stormwater Monitoring Program Quality Assurance Project Plan (QAPP). Received and incorporated Ecology comments on the Stormwater Monitoring QAPP. Finalized approved Stormwater Monitoring QAPP. Began stormwater monitoring program. Identified targeted action, environmental outcome, and related hypotheses for Targeted SWMP Effectiveness monitoring. Prepared and submitted draft SWMP Effectiveness monitoring QAPP. Received and incorporated Ecology comments on the SWMP Effectiveness QAPP. Finalized approved SWMP Effectiveness QAPP. Began SWMP Effectiveness monitoring activities. Identified site for BMP Evaluation monitoring. Prepared and submitted draft BMP Evaluation monitoring QAPP. Received and incorporated Ecology comments on the BMP Evaluation QAPP. Submitted revised BMP Evaluation plan for Ecology review and received verbal approval of revised plan. Continued work on baseline monitoring to support BMP Evaluation monitoring. Baseline data will be used to determine tidal influence and contribute to development of finalized BMP Evaluation QAPP. The following table outlines the implementation plan to achieve the goals and objectives of the three part Monitoring program and meet the compliance deadlines in the Phase I Municipal Stormwater Permit. Because the permit language is extensive in this area, the requirements have been summarized in the implementation table below. See the Phase I Municipal Stormwater Permit (Section S8) for the complete Monitoring program requirements language. P o r t o f S e a t t l e S t o r m w a t e r M a n a g e m e n t P l a n f o r P h a s e I P r o p e r t i e s 24 otak K:\project\31100\31104J\Reports\SWMP\Seaport 2011 SWMP Final.doc Section 9Monitoring (S8) Continued Permit Element Monitoring S8 Purpose: Develop and implement a long term monitoring program to characterize stormwater runoff quantity and quality, evaluate stormwater management program effectiveness, and evaluate BMP effectiveness. Applicability: Phase I Properties at the Port of Seattle and Port of Tacoma Permit Requirement Action Plan Schedule Notes S8.C.1 Long Term Monitoring Program Develop and implement a long term monitoring program with three Develop a monitoring plan as Due Date: Varies (see components: described below. below) Stormwater Monitoring, Implement monitoring as part Status: Monitoring program Targeted SWMP of elements S8.D through status should be included in Effectiveness Monitoring, S8.F. each annual report. and BMP Evaluation Monitoring. S8.C.2 Quality Assurance Project Plan (QAPP) Due Date: March 2008 for draft Stormwater and Targeted SWMP Effectiveness QAPPs. September 2008 for final Stormwater and Targeted Each of the components of Hire qualified contractor to SWMP Effectiveness the monitoring program shall develop QAPP. QAPPs and draft BMP include a QAPP prepared in Coordinate with the Port of Evaluation QAPP. March accordance with Ecology's Tacoma on joint monitoring 2009 for final BMP QAPP guidelines. The efforts. Evaluation QAPP. monitoring program shall be Prepare QAPP for each Status: Stormwater and developed by qualified staff monitoring component. Targeted SWMP or contractors with Submit to Ecology for review Effectiveness QAPPs are experience in applying and approval prior to complete and approved. Ecology's or EPA's QAPP conducting monitoring Revised plan for BMP Guidelines. activities. Evaluation program has been approved (verbally) by Ecology. Revised BMP Evaluation QAPP will be submitted following baseline data collection. P o r t o f S e a t t l e S t o r m w a t e r M a n a g e m e n t P l a n f o r P h a s e I P r o p e r t i e s 25 otak K:\project\31100\31104J\Reports\SWMP\Seaport 2011 SWMP Final.doc Section 9Monitoring (S8) Continued S8.D Stormwater Monitoring Select one outfall or Review Phase I Properties conveyance for monitoring. and identify potential sites Stormwater monitoring sites meeting site selection criteria. shall have the tributary Document basin sizes, land conveyance system and use types, and contributing Due Date: March 2008 drainage area mapped, and drainage areas. Status: included in QAPP. shall be suitable for Select monitoring site. permanent installation and operation of flow-weighted Document site selection composite sampling criteria and justification in equipment. QAPP. Outline sampling procedures in the QAPP. Develop system to track storm Due Date: March 2008 for events, identify qualifying Sample the stormwater Draft QAPP; September storms, and mobilize staff to monitoring site according to 2008 for Final QAPP. collect samples. the frequency outlined in Status: QAPP approved; OR permit condition S8.D.2.a. Sampling activities are Hire consultant to track storm underway. events, identify qualifying storm events, and collecting samples at appropriate times. Sample storm events using Purchase sampling flow weighted composite equipment. sampling and conduct Identify lab for sample Due Date: March 2009 laboratory analysis as analysis and submit samples Status: Ongoing outlined in permit conditions for analysis following S8.D.2.b and S8.D.2.c. qualifying storm events. Outline sampling and testing Annually test the seasonal procedures in the QAPP. first-flush for toxicity as Due Date: March 2009 Identify lab for sample outlined in permit condition Status: Ongoing analysis and submit samples S8.D.2.d. annually. Outline sampling and testing Collect grab samples to test procedures in the QAPP. for TPH and Fecal coliform Due Date: March 2009 Identify lab for sample bacteria as outlined in Status: Ongoing analysis and submit samples permit condition S8.D.2.e. annually. Outline sampling and testing Collect annual sediment procedures in the QAPP. samples at the monitoring Due Date: March 2009 Identify lab for sample site as outlined in permit Status: Ongoing analysis and submit samples condition S8.D.2.f. annually. P o r t o f S e a t t l e S t o r m w a t e r M a n a g e m e n t P l a n f o r P h a s e I P r o p e r t i e s 26 otak K:\project\31100\31104J\Reports\SWMP\Seaport 2011 SWMP Final.doc Section 9Monitoring (S8) Continued Calculate the Event Mean Outline evaluation procedures Concentrations, total annual in the QAPP. pollutant load, and the Collect and maintain records Due Date: As data is seasonal pollutant load for of laboratory analysis as collected the wet and dry seasons as completed. Status: Ongoing outlined in permit condition Analyze data and track S8.D.2.g. analysis results. S8.E Targeted SWMP Effectiveness Monitoring Identify the targeted action: Increasing knowledge and changing behaviors of tenants through stormwater education. Formulate a hypothesis about the action that can be tested using before and after surveys. Outline a monitoring program Develop a monitoring with the elements listed in Due Date: March 2008 for program to evaluate the S8.E.3 and submit to Ecology monitoring. March 2009 for effectiveness of a targeted for review. starting surveys. action (or suite of actions) Identify appropriate survey Status: QAPP approved; as outlined in permit questions and methods for initial surveys and education condition S8.E. distributing and collecting program are complete; surveys. Begin initial surveys once Ecology has approved monitoring plan. Conduct public education campaign outlined in S6.E.1. Conduct follow-up surveys to evaluate knowledge and behavior changes. Identify the environmental outcome to be evaluated. Formulate a hypothesis about Due Date: March 2008 for the outcome that can be Develop a monitoring draft QAPP. September tested using monitoring data. program to evaluate the 2008 for final QAPP. March Identify the parameters to be effectiveness of achieving a 2009 for program measured and methods for targeted environmental implementation. collecting/testing the data. outcome as outlined in Status: QAPP approved; permit condition S8.E. Hire a consultant to prepare a monitoring program is QAPP outlining the underway. procedures for conducting targeted environmental outcome monitoring. P o r t o f S e a t t l e S t o r m w a t e r M a n a g e m e n t P l a n f o r P h a s e I P r o p e r t i e s 27 otak K:\project\31100\31104J\Reports\SWMP\Seaport 2011 SWMP Final.doc Section 9Monitoring (S8) Continued Submit QAPP to Ecology for review and finalize QAPP. Begin collecting and analyzing data once QAPP has been approved. S8.E BMP Evaluation Monitoring Identify potential BMPs and applicable sites on Phase I Identify at least one Properties for monitoring. treatment BMP (no less than Coordinate with Ecology to two sites) for full scale field Due Date: September 2008 receive approval for the monitoring as outlined in Status: included with QAPP. proposed monitoring sites. permit conditions S8.F.1, Document site selection S8.F.2 and S8.F.3. criteria and justification in QAPP. Due Date: Final QAPP due 90 days after receiving Ecology comments. Use appropriate sections of Hire a consultant to prepare a Status: Draft QAPP Ecology's guidance for QAPP for the BMP monitoring submitted to Ecology; preparing, implementing, that follows Ecology's comments received; revised and reporting on the results "Evaluation of Stormwater monitoring plan submitted; of the BMP evaluation Treatment Technologies" verbal approval received; program. document. baseline monitoring underway to determine QAPP modifications. Outline monitoring procedures and parameters to be tested in the QAPP. Due Date: To be Hire a consultant to collect determined based on Monitor whole water and and analyze monitoring data QAPP review schedule. sediment parameters as according to the procedures Status: Baseline monitoring outlined in permit conditions outlined in the QAPP. to support QAPP S8.F.5 and S8.F.6. Collect and maintain records development is underway; of laboratory analysis as Full monitoring will begin completed. after approval of final QAPP. Analyze data and track analysis results. P o r t o f S e a t t l e S t o r m w a t e r M a n a g e m e n t P l a n f o r P h a s e I P r o p e r t i e s 28 otak K:\project\31100\31104J\Reports\SWMP\Seaport 2011 SWMP Final.doc Section 9Monitoring (S8) Continued S8.H Monitoring Program Reporting Requirements Analyze and review collected Submit the stormwater data as part of elements S8.D monitoring report each year through S8.F. with the annual report Summarize and format data beginning in 2009 for Due Date: March 2009. annually to meet reporting independent monitoring and Status: Complete for requirements. 2010 for collaborative inclusion with the annual Prepare QA/QC report for monitoring. Reports shall report. each part of the monitoring include the information program. outlined in permit condition S8.H.1. Prepare and submit annual monitoring report. P o r t o f S e a t t l e S t o r m w a t e r M a n a g e m e n t P l a n f o r P h a s e I P r o p e r t i e s 29 otak K:\project\31100\31104J\Reports\SWMP\Seaport 2011 SWMP Final.doc Section 10Reporting (S9) Reporting (S9) This section describes the permit requirements, programs, and planned activities related to Reporting. Current activities in this area include: Submitted 2007, 2008, and 2009 Annual Reports and accompanying SWMP documents prior to the March 31 permit deadlines. Preparing 2010 Annual Report for submittal to Ecology. Preparing updated SWMP document to reflect activities completed in 2010 and planned for 2011. Ongoing record keeping of SWMP activities. The following table outlines the implementation plan to achieve the goals and objectives of the Reporting program and meet the compliance deadlines in the Phase I Municipal Stormwater Permit. Program Element Reporting S9 Purpose: Document SWMP activities on Phase I Properties and submit annual reports to Ecology. Applicability: All Seaport stormwater program activities on Phase I Properties related to NPDES Phase I Permit compliance. Permit Requirement Action Plan Schedule Notes S9.A, B, and G Annual Report Prepare SWMP document including implementation schedules and plan for meeting permit deadlines. Update SWMP annually. Prepare and submit an Complete Ecology provided Due Date: March 31 each annual report to Ecology annual report form (permit Year covering the previous Appendix 3). Status: Annual reports for calendar year. The annual Prepare stormwater 2007, 2008, and 2009 are report shall include the monitoring report as part of complete. Annual report for information outlined in S8.H beginning in 2009. 2010 is in development. permit condition S9.G. Identify and document jurisdictional boundary changes as applicable. Obtain necessary signatures and submit to Ecology on an annual basis. P o r t o f S e a t t l e S t o r m w a t e r M a n a g e m e n t P l a n f o r P h a s e I P r o p e r t i e s 30 otak K:\project\31100\31104J\Reports\SWMP\Seaport 2011 SWMP Final.doc Section 10Reporting (S9) Continued S9.C Maintain Records Identify Seaport staff responsible for recording Keep all records related to SWMP activities. the permit and the SWMP Develop procedures or for at least five years. develop database for Due Date: Ongoing Except as required in permit collecting and consolidating Status: in progress condition S9.G, records SWMP records. need to be submitted to Review records annually as Ecology only upon request. part of annual report development. S9.D Public Access Make records related to this permit and the Permittee's Identify locations for storing SWMP available to the permit and SWMP documents. public at reasonable times Post documents or information Due Date: Not specified during business hours. about document availability on Status: records are available Provide a copy of the most the Seaport website. upon request. recent annual report to any Copy records or annual individual entity, upon reports as requested. request. P o r t o f S e a t t l e S t o r m w a t e r M a n a g e m e n t P l a n f o r P h a s e I P r o p e r t i e s 31 otak K:\project\31100\31104J\Reports\SWMP\Seaport 2011 SWMP Final.doc Conclusion Conclusion This Stormwater Management Plan has been prepared to demonstrate compliance with the requirements of the NPDES Phase I Municipal Stormwater Permit. The implementation tables indicate current and planned activities on Phase I Properties as of February 2011. The Stormwater Management Plan for Phase I Properties is a living document that will be updated annually to document progress in implementing the stormwater management programs required for compliance with the Phase I Municipal Stormwater Permit. P o r t o f S e a t t l e S t o r m w a t e r M a n a g e m e n t P l a n f o r P h a s e I P r o p e r t i e s 32 otak K:\project\31100\31104J\Reports\SWMP\Seaport 2011 SWMP Final.doc
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