City of Dubuque Municipal Separate Storm Sewer System (MS4) InspectionCity of Dubuque
City Council Meeting
Consent Items # 018.
Copyrighted
June 5, 2023
ITEM TITLE: City of Dubuque Municipal Separate Storm Sewer System (MS4)
I nspection
SUMMARY: City Manager recommending City Council officially record the results of
the Iowa Department of Natural Resources (DNR's) recent inspection of
the City's National Pollution Discharge Elimination System (NPDES)
Municipal Separate Storm Sewer System (MS4) permit compliance
program in the minutes of the City Council.
SUGGESTED Suggested Disposition: Receive and File; Make Matter of Record
DISPOSITION:
ATTACHMENTS:
Description Type
MVM Memo City Manager Memo
Staff Memo Staff Memo
Report Supporting Documentation
Permit Supporting Documentation
THE C
DUjIBQTE
Masterpiece on the Mississippi
TO: The Honorable Mayor and City Council Members
FROM: Michael C. Van Milligen, City Manager
SUBJECT: City of Dubuque MS4 Inspection
DATE: May 31, 2023
Dubuque
WAWca 914
ii
2007-2012.2013
2017*2019
City Engineer Gus Psihoyos is recommending City Council officially record the results of
the Iowa DNR's recent inspection of the City's National Pollution Discharge Elimination
System (NPDES) Municipal Separate Storm Sewer System (MS4) permit compliance
program in the minutes of the City Council.
I concur with the recommendation and respectfully request Mayor and City Council
approval.
v
Mic ael C. Van Milligen
MCVM:sv
Attachment
CC' Crenna Brumwell, City Attorney
Cori Burbach, Assistant City Manager
Gus Psihoyos, City Engineer
Deron Muehring, Civil Engineer II
THE CjAQUE
DUB
Masterpiece on the Mississippi
TO: Michael Van Milligen, City Manager
FROM: Gus Psihoyos, City Engineer
SUBJECT: City of Dubuque MS4 Inspection
DATE: May 30, 2023
Dubuque
All -America Ciq
2007.2012.2013
2017*2019
INTRODUCTION
The purpose of this memo is to transmit the results of the Iowa DNR's recent
inspection of the City's National Pollution Discharge Elimination System (NPDES)
Municipal Separate Storm Sewer System (MS4) permit compliance program.
BACKGROUND
The federal clean water act requires the City to obtain a permit in order to discharge
stormwater from the city into waters of the United States (i.e., the Catfish Creek,
Mississippi, etc.). The City was issued Iowa NPDES Permit 31-26-0-04 on
November 1, 2019 "pursuant to the authority of section 402(b) of the Clean Water
Act (33 U.S.C. 1342(b)), Iowa Code section 455B.174, and rule 567--64.13, Iowa
Administrative Code."
DISCUSSION
The Iowa DNR performed an inspection of the City's NPDES MS4 (stormwater)
permit compliance program on May 15, 2023. Attached are the results. Per the
report, the City is meeting all permit requirements. There were no recommendations
or requirements following the inspection.
ACTION TO BE TAKEN
I respectfully request the results of the City of Dubuque MS4 inspection be officially
recorded in the minutes of the City Council.
DLM/kb
CC' Crenna Brumwell, City Attorney
Deron Muehring, Civil Engineer 11
IOWA DEPARTMENT OF NATURAL RESOURCES GOVERNOR Kim REYNOLDS
. LT. GOVERNOR ADAM GREGG
DIRECTOR KAYLA LYON
May 22, 2023
VIA EMAIL
CITY OF DUBUQUE
50 WEST 13T" ST
DUBUQUE IA 52001
ATTN: Deron Muehring, City of Dubuque Engineering — dmuehrin(a)cityofdubug ue.org
Subject: Stormwater MS4 Inspection, Dubuque, NPDES Permit 31-26-0-04
Please find enclosed a copy of a report resulting from the MS4 compliance inspection by Field Office 1 staff on
May 15, 2023.
Please note that the Annual Report may be submitted electronically by emailing to FO1.Notify(a)dnr.iowa.gov.
The cooperation of Mr. Deron Muehring, Mr. John Wiley, and Mr. Eric Schmechel during this inspection is
appreciated.
Sincerely,
ENVIRONMENTAL SERVICES DIVISION
lDigitally signed by Chris Gelner
Chris Gener
Date: 2023.05.22 06:58:58
-05'00'
Chris Gelner
Environmental Specialist Senior
Enc.
c: John Wiley, DSWCD — john.wiley cDdubuguecountyiowa.gov
Eric Schmechel, DSWCD — eric.schmechel(a)dubug uecountyiowa.gov
e-file — 31 STW Dubuque 3126004 Dubuque MS4 051523 ins csg
FIELD OFFICE 1, 1101 COMMERCIAL CT. STE. 10, MANCHESTER IA 52057
Phone: 563-927-2640 www.iowadnr.gov Fax: 563-927-2075
Dubuque MS4 Inspection Report
Page 1 of 4
REPORT OF INSPECTION
INVESTIGATION DATE
CURRENT: 5/15/2023
LAST: 11/15/2018
TO: City of Dubuque
50 West 13' St
Dubuque, IA 52001
SUBJECT: Stormwater MS4 Compliance Inspection
Iowa NPDES Permit 31-26-0-04
PERSONS Deron Muehring, City of Dubuque Engineering — 563/589-4270
CONTACTED:
Introduction
This compliance inspection of the city of Dubuque's MS4 program was made on May 15, 2023. The scope of
the inspection included an evaluation of the permit requirements and general discussions pertaining to the
city's stormwater program. An on -site visit to NPDES General Permit 2 (GP2) authorization 42292-41921 was
also conducted. Messrs. Muehring, Wiley, and Schmechel were interviewed during the inspection and
provided records as requested.
Iowa NPDES Permit
The city of Dubuque was issued Iowa NPDES Permit 31-26-0-04 for the discharge of stormwater for its
Municipal Separate Storm Sewer System (MS4), totaling approximately 32 square miles. The permit
expiration date is October 31, 2024. As a reminder, the date required to file for renewal of this permit is May
4, 2024.
Part II A. Public Education and Outreach on Stormwater Impacts - N/A = not applicable, N/O = not observed
Permit requirements
Yes
No
N/A
N/O
General stormwater education brochure
®
❑
❑
❑
Website
®
❑
❑
❑
Informational articles in the city newsletter
®
❑
❑
❑
Comments:
The city continues to implement a public education and outreach program to educate the public on the
impacts of various activities and pollutants on stormwater quality and quantity, as well as measures that
residents can implement to reduce pollutants in stormwater runoff. The city has several educational
brochures and an informative website available to the public.
Part II B. Public Involvement and Participation
Permit requirements
Yes
No
N/A
N/O
Public meetings
®
❑
❑
❑
Public notice requirements
®
❑
❑
❑
Telephone hotline number
0
❑
❑
❑
Dubuque MS4 Inspection Report
Page 2 of 4
Comments:
The city continues to include public involvement and participation in its stormwater program. The Resilient
Community Advisory Commission (RCAC) meets on a regular basis. This commission advises the permittee
on the effectiveness of the stormwater program and holds public meetings to gather public input. The 24/7
stormwater hotline (563/690-6200) is prominently placed on the main stormwater website and is included in
all educational materials.
Part II C. Illicit Discharge Detection and Elimination
Permit requirements
Yes
No
N/A
N/O
Illicit discharge prohibition ordinance
®
❑
❑
❑
Illicit discharge detection and elimination program
®
❑
❑
❑
Sanitary sewer backups and overflows
®
❑
❑
❑
Storm drain labeling
®
❑
❑
❑
Comments:
The city has implemented municipal code which pertains to the prohibition of unpermitted discharges. The
Dubuque Soil & Water Conservation District (DSWCD), on behalf of the city by a 28e agreement, carries out
inspections of outfalls on a routine basis as a means of identifying illicit discharges. A total of 108 outfall
inspections were conducted in 2021/2022. The city/DSWCD also investigates reports of illicit discharges and
requires the elimination of illicit discharges within 21 days of discovery.
Part II D. Construction Site Runoff Control
Permit requirements
Yes
No
N/A
N/O
Construction site runoff control ordinance
®
❑
❑
❑
Construction site review and inspection program
®
❑
❑
❑
Sediment and erosion control checklist
®
❑
❑
❑
Comments -
The city/DSWCD conducts construction site inspections according to the IDNR General Permit 2 (a minimum
of 1 per calendar quarter) as well as inspections in response to complaints received. The city reported 202
inspections for 2021/2022 with (22) verbal warnings and (2) Notice of Violations/municipal infractions issued
to make corrections.
The following GP2 authorizations were discussed during the inspection. No instances of discharge of
pollutants to a water of the State of Iowa were observed.
• 40265-39886 — This authorization was issued but construction activity has not yet taken place. Mr.
Wiley stated that he believes this project has been scrubbed and no construction will occur.
42100-41727 — It was determined that this site is planning to disturb less than 1 acre and is,
therefore, not subject to the MS4 program authority. Mr. Wiley stated that even though the site is not
regulated by the MS4 authority, he still makes random visits to observe if illicit discharges have
occurred.
• 42292-41921 — I visited this site along with Messrs. Muehring, Wiley, and Schmechel. Mr. Wiley
conducted a routine inspection at the site and made note of several minor maintenance issues that
needed to be addressed. Mr. Wiley issued a verbal warning to the site's project manager and made
his expectations and timeline clear. It should be noted that this site received approximately 0.75
inches of rain in the previous 24 hours and that maintenance of sediment controls had not yet taken
place by the permittee.
Dubuque MS4 Inspection Report
Page 3 of 4
Part II E. Post Construction Stormwater Management
Permit requirements
Yes
No
N/A
N/O
Post -construction runoff control policy ordinance
N
❑
❑
❑
Site plan review of post -construction runoff control devices
N
❑
❑
❑
Inspection of run-off control devices
N
❑
❑
❑
Watershed assessment program
N
❑
❑
❑
Cnmments-
The city has adopted SUDAS specifications, which include stormwater management. City policy adopted by
the City Council requires that all developments requiring a state NPDES construction site permit must not
increase the peak flow of runoff during the statistical 2, 10, and 100-year rain events. The city has a very
active watershed assessment program in the Bee Branch and Catfish Creek watershed systems.
Part II F. Pollution Prevention/Housekeeping
This section of the NPDES Permit addresses preventing and reducing pollutant runoff from municipal
operations.
Permit requirements
Yes
No
N/A
N/O
Operation and maintenance of MS4
N
❑
❑
❑
Pesticide and fertilizer management program
N
❑
❑
❑
Training program for municipal employees
N
❑
❑
❑
City facilities BMPs
N
❑
❑
❑
Comments:
The city of Dubuque Public Works Department oversees all inspection, televising, and cleaning of the storm
sewer components as well as street sweeping. The Engineering Department is charged with the installation
of and repair or replacement of storm sewer components.
The city implements a pesticide and fertilizer management program through its Leisure Services Department.
All pesticides and fertilizers are applied by State of Iowa licensed staff, which requires annual training. It was
noted in the annual report that the city has reduced pesticides and fertilizers to the maximum extent possible
while still maintaining effectiveness. Records of applications are maintained by the Leisure Services
Department in order to evaluate the effectiveness and make rate application decisions in the future. Mr.
Meuhring stated that the city will include this information in future annual stormwater reports.
Training is provided to city employees whose job duties will likely have an impact on stormwater quality.
Training includes application, handling, storage, and disposal of fertilizers and pesticides and is given at least
once during the GP2 permit cycle (5 years) and within the first year of employment for all new employees.
The city has implemented a program to assess BMPs at municipal facilities at a frequency of once per permit
cycle, including 6 separate municipal facilities in order to understand effectiveness and reduce pollutants in
stormwater.
Part II G. Monitoring Industrial and High -Risk Run -Off
Permit requirements
Yes
No
N/A
N/O
Each facility certifies annually compliance with SWMP & permit
❑
❑
N
❑
Annual sampling conducted
❑
❑
N
❑
Records of discharge or potential discharge
❑
❑
N
❑
Dubuque MS4 Inspection Report
Page 4 of 4
Comments:
Mr. Muehring stated that the city of Dubuque does not currently assess industries for high -risk run-off, nor
does the NPDES permit require this.
Part III. Reporting Requirements
An annual report is to be submitted to the DNR by September 30 of each year. DNR records indicate the last
annual report from the city of Dubuque was received on October 20, 2022. Please note that the annual
report may now be submitted electronically by emailing to FO1.Notify(a)_dnr.iowa.gov. .
RECOMMENDATIONS:
• None
REQUIREMENTS:
• None
AUTHENTICATION
INSPECTOR:
DATE:
Chris Gelner Digitally signed by Chris Gelner
Date: 2023.05.22 06:58:40-05'00'
Chris Gelner, Environmental Specialist Senior
REVIEWER:
M• Digitally signed by Michele Smith
ichele Smith Date: 2023.05.22 06:50:32-05'00'
DATE:
Michele Smith, Environmental Specialist Senior
IOWA DEPARTMENT OF NATURAL RESOURCES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMIT
PERMITTEE
City of Dubuque
50 W. 13'h St.
Dubuque, Iowa 52001
IOWA NPDES PERMIT NUMBER: 31-26-0-04
DATE OF ISSUANCE: November 1, 2019
DATE OF EXPIRATION: October 31, 2024
YOU ARE REQUIRED TO FILE
FOR RENEWAL OF THIS PERMIT BY: May 4, 2024
EPA NUMBER — IA0078671
IDENTITY AND LOCATION OF FACILITY
City of Dubuque
RECEIVING WATERCOURSES
Little Maquoketa, Cloie Branch, Granger
Creek, South Fork Catfish Creek, Middle Fork
Catfish Creek, North Fork Catfish Creek,
Catfish Creek, Mississippi River and other,
undesignated waterbodies
This permit is issued pursuant to the authority of section 402(b) of the Clean Water Act (33 U.S.C. 1342(b)), Iowa
Code section 45513.174, and rule 567--64.13, Iowa Administrative Code. You are authorized to operate the
disposal system and to discharge the pollutants specified in this permit in accordance with the monitoring
requirements and other terms set forth in this permit.
You may appeal any conditions of this permit by filing written notice of appeal and request for administrative
hearing with the director of this department within 30 days of receipt of this permit.
Any existing, unexpired Iowa operation permit or Iowa NPDES permit previously issued by the department for the
facility identified above is revoked by the issuance of this Iowa NPDES operation permit.
FOR THE DEPARTMENT OF NATURAL RESOURCES
By
Joe difffin
1113
Facility Name: City of Dubuque Municipal Separate Stonn Sewer System
Permit Number: 31-26-0-04 Droll Permit
PART 1. DISCHARGES AUTHORIZED UNDER THIS PERMIT
A. Permit Area
This permit covers all areas within the boundaries of the City of Dubuque totaling approximately 32 square
miles which is drained by the city's Municipal Separate Storm Sewer System (MS4) and any other areas added
while this permit is in effect.
B. Authorized Discharaes
This pen -nit authorizes all existing or new storm water point source discharges to waters of the State from the
MS4. This permit also authorizes the discharge of storm water commingled with flows contributed by process
wastewater, non -process wastewater, or storm water associated with industrial activity provided such
discharges are authorized under separate NPDES permits. as required by law. This permit does not authorize
discharges to the MS4.
C. Limitations on Coverage
The following discharges are not authorized or regulated by this permit:
Storm water discharges that are mixed with non -stone water and storm water associated with industrial activity
except where such discharges are:
1. in compliance with a separate NPDES permit; or
2. identified by and in compliance with Part IV. of this permit.
PART II. STORM WATER POLLUTION PREVENTION & MANAGEMENT
The permittee shall implement the Best Management Practices (BMPs), measurable goals and frequencies
described in the following sections.
A. Public Education and Outreach on Storm Water Impacts
The permittee shall continue implementing a public education and outreach program about the impacts of storm
water discharges and measures which the residents of the permittee can implement to reduce pollutants in storm
water runoff that includes the following:
1. General Storm Water Education Brochure — An informational brochure shall continue to be
distributed to all new businesses and residents served by the MS4. The brochure shall present
information regarding stone water impacts on water quality and measures that can be implemented
to reduce water quality degradation from storm water. The brochures shall be distributed to all
residents and businesses through utility billing statements at least once during the duration of the
permit. Brochures shall be made available on the permittee's website as they are created for the
duration of the permit.
2. Telephone Hotline Number — The permittee shall provide a telephone number for the reporting of
storm water related problems. The telephone number shall be made available on the website and
included in other storm water educational materials.
2113
Facility Name: City of Dubuque Municipal Separate Storm Sewer System
Pennit Number: 31-26-0-04 Draft Permit
The telephone number shall be made available for the duration of the permit.
Storm Water Web Page — The permittee's website shall contain information regarding storm water
impacts on water quality, measures residents can implement to reduce pollutants in storm water,
regulations, current local topics, information in the brochures and links to other relevant websites.
A form for reporting storm water complaints shall be provided on the website. The website shall
be updated as needed.
The storm water web page shall be maintained by the permittee for the duration of the permit.
4. Storm Drain Labeling -- All new and replaced storm sewer intakes shall be either embossed or
stamped by the manufacturer with a no dumping proscription. Should a catch basin be installed
that has no such proscription, the permittee shall affix a placard so indicating.
The program shall continue to be implemented by the permittee to ensure all municipal storm
sewer intakes are labeled for the duration of the permit.
S. Educational Television Program — The permittee shall continue to offer a video program which
presents information regarding storm water impacts on water quality and measures residents can
implement to reduce water quality degradation from storm water. The program shall be televised
at least once each calendar quarter and made available to residents on the permittee's website.
Fhe program shall be televised and made available for the duration of the permit.
b. Public Education Program — The permittee shall continue to make available to schools served by
the MS4 and shall encourage the adoption of educational materials regarding storm water and its
impact on water quality. Each school year the permittee shall contact the school board to
determine the status of the program and to ensure the material is still available for use in the
classrooms.
The educational materials shall be provided by the permittee for the duration of the permit.
B. Public Involvement and Participation
The permittee shall continue implementing a public involvement and participation program that includes
the following:
Resilient Community Advisory Commission — The pernlittee shall continue to hold meetings with
the Resilient Community Advisory Commission. The commission shall develop, articulate and
propose goals, objectives and policies regarding storm water issues. The commission shall also
advise and inform the permittee regarding compliance with the MS4 permit, hold public meetings
each calendar quarter where storm quality issues are discussed with residents. The commission
shall be allowed to provide infoixnation for storm water education programs, educational materials
and volunteer opportunities and shall provide input regarding storm water quality issues in
relationship to the permittee's storm water management activities. Businessmen, developers,
homeowners, members of environmental groups and members of the public at large shall be
allowed to participate, if interested. However, the permittee may place reasonable limits on the
total number of individuals participating in the group.
Meetings shall be held at least once each calendar quarter for the duration of the permit.
3113
Facility ]Name: City of Dubuque Municipal Separate Storm Sewer System
Permit Number: 31-26-0-04 Draft. Permit
2. Water Quality Monitoring — The permittee shall continue to work with water quality monitoring
groups to determine the water quality of waters of the state that receive discharges from the MS4
and are within the city limits of the permittee. The pennittee shall promote monitoring activity by
funding monitoring training and equipment. The data from the monitoring shall be trade available
to members of the public and to the Department as requested.
The monitoring activities shall continue for the duration of the permit,
3. Public Notice Requirements - When implementing a public involvement and participation
program, the permittee must comply with all state and local public notice requirements.
C. Illicit Discharge Detection and Elimination
The permittee shall continue implementing and enforcing a discharge detection and elimination program that
includes the following:
Illicit Discharge Prohibition Ordinance — An ordinance shall continue to be amended as necessary
and enforced by the permittee that prohibits anything other than storm water, allowable non -storm
water and pollutants for which an NPDES permit has been issued and when the discharge is in
compliance with the permit from entering the MS4. The ordinance shall include language that
enables the permittee to inspect private property if an illicit discharge is suspected and penalties
for non-compliance.
The ordinance shall be enforced by the permittee for the duration of the perm it.
2_ Illicit Discharge Detection and Elimination Program — A program shall continue to be
implemented to identify and eliminate illicit discharge to the MS4. The program shall include
annual dry weather flow inspections of all outfalls not already inspected since flows from newly
developed or re -developed areas have been discharged from the outfalls, sampling and analyses of
these dry weather flows, procedures to identify the sources of the dry weather Bows and
procedures for disconnecting illicit connections. Dry weather flow inspections may be made at
manholes and other points prior to the flows joining larger portions of the MS4 to facilitate
detection of illicit discharges. Records shall be kept of when inspections are performed, the
results of the inspections and measures taken to identify and, when appropriate, eliminate the
sources of any dry weather flows. The plan shall be evaluated annually to assess the effectiveness
of the program and any necessary changes made. All illicit discharges found must be eliminated
no more than 21 days after discovery. If it is not possible to eliminate an illicit discharge within 21
days of discovery, the permittee shall submit to the Department the reasons why the discharge
cannot be eliminated within 21 days of discovery and a plan which contains a timeline of activities
which will result in the elimination of the discharge, This statement and plan shall be submitted
within 21 days of discovery of the illicit discharge. If the Department does not approve the plan,
the permittee will then be required to eliminate the discharge no later than a date specified by the
Department. All illicit discharges shall be reported to the Department no later than the end of the
first business day after the day of the discovery.
The plan shall be implemented by the permittee for the duration of the permit.
3, Pet Waste Ordinance — An ordinance shall continue to be amended as necessary and enforced that
addresses the cleanup of pet feces. The ordinance shall require owners of pets to remove their
pets' feces immediately after being deposited on public property_ The ordinance shall also require
4/13
Facility Name: City of Dubuque Municipal Separate Storm Sewer System
Permit Number: 31-26-0-04 Draft Permit
the proper disposal of the feces. Exemptions for manure from agricultural livestock when used for
horticultural purposes may be included in the ordinance.
The ordinance shall be enforced by the permittee for the duration of the permit.
D. Construction Site Storm Water Runoff Control
The permittee shall continue implementing and enforcing a construction site storm water runoff control
program to reduce pollutants in any storm water runoff from construction activities for which storm water
permit coverage is required and that includes the following:
1, Construction Site Runoff Control Ordinance — An ordinance shall continue to be amended as
needed and enforced on all sites for which NPDES permits are required that requires proper soil
erosion and sediment control. This ordinance shall also address waste at construction sites that
may cause adverse impacts to water quality such as building materials, concrete truck washout,
chemicals, solid waste and sanitary waste. Authority to issue an order to terminate activities due
to failure to implement or maintain pollution control BMPs, authority for the permittee to enter
private property for the purposes of compliance inspections and penalties for non-compliance shall
be included. The ordinance shall require site plan and pollution prevention plan review and
approval by the permittee prior to issuance of any permits for the site by the permittee. The
ordinance shall require compliance with the Department's Storm Water General Permit no. 2.
The ordinance shall be enforced by the permittee for the duration of the permit.
2, Construction Site Review and Inspection Program - The permittee shall require site plan and
pollution prevention plan review and approval by the permittee or the permittee's agent prior to
issuance of any permits for the site by the permittee for construction activities for which an
NPDES permit is required. The program shall require compliance with the Department's Storm
Water General Permit no. 2 and inspections by the permittee of all sites for which coverage under
General Permit no. 2 is required. The program shall require each of these sites be inspected by the
permittee at least once each calendar quarter. City personnel shall ensure that all topsoil
preservation requirements stipulated by General Permit no. 2 are implemented on those sites for
which they are required,
If an entity other than the permittee reviews the site plans and pollution prevention plans, the
permittee shall provide sufficient oversight to ensure the reviews are done properly and that the
entity performing the reviews has no conflicts of interests in this matter.
The program shall be implemented by the permittee for the duration of the permit.
3. Contractor Workshop — The permittee shall continue to conduct or sponsor workshops intended to
educate developers, builders, contractors and consultants about ways in which developments and
construction sites can be designed and maintained to implement erosion and sediment control and
to improve the quality of storm water runoff.
The penn ittee shall hold or sponsor workshops at least once each year for the duration of the
permit.
5/13
Facility Name: City oFDubuque Municipal Separate Storm Sewer System
Permit Number: 31-26-0-04 Draft Permit
E. Post -construction _Storm Water Management
The permittee shall continue implementing and enforcing a program to address storm water runoff from new
construction and re -construction projects for which storm water coverage is required. The program must ensure
that controls are in place that will prevent or minimize water quality impacts and shall include the following:
1. Post --construction Site Runoff Control Policy Ordinance — An ordinance shall continue to be
amended as necessary and enforced will address the control of runoff from building activities after
construction has been completed. The ordinance shall require water quality and quantity
components be required in the design of new construction and implemented when feasible. The
ordinance shall promote the use of storm water detention, retention, infiltration, other Best
Management Practices specific to each site which address water quality and quantity issues and
proper operation and maintenance of these facilities.
The ordinance shall be enforced by the permittee for the duration of the permit.
2. Site Plan Review of Post --construction Runoff Controls — The permittee shall continue to
implement procedures and acceptance criteria for review of past -construction runoff controls for
all construction sites for which coverage under NPDES storm water pennits are required. The
permittee shall not allow construction activities to commence until the plans for post -construction
runoff controls have been reviewed and approved.
The program shall be implemented by the permittee for the duration of the permit.
3. Inspection of Runoff Control Devices — Storm water control devices and structures shall continue
to be inspected and reviewed for proper maintenance. Educational materials shall continue to be
made available to landowners which outline proper maintenance procedures, The permittee shall
properly maintain its own control devices and structures. All private post -construction controls
shall be inspected by the permittee at least once during the duration of the permit. All public post -
construction controls shall be inspected by the permittee at least once each calendar year.
Inspections shall be conducted and educational materials made available by the permittee for the
duration of the permit.
4, Watershed Assessment Program — A watershed assessment program and comprehensive land use
plan shall continue to be implemented which outlines measures to be implemented which reduce
flooding, reduce erosion in ditches and streams, improve water quality and reduce degradation of
habitat for fish and wildlife. The permittee shall then implement the program whenever possible
to meet these goals.
The program shall be implemented by the permittee for the duration of the permit.
Watershed Symposium — The permittee shall continue to conduct or sponsor the symposium
intended to educate developers, house builders and others about ways low impact development,
new design techniques that include structural best management practices, and other practices can
improve the quality of stone water runoff.
The permittee shall Fold or sponsor workshops at least once each year for the duration of the
permit.
CsIl3
Facility Name: City of Dubuque Municipal Separate Storm Sewer System
Permit Number: 31-26-0-04 Draft Permit
F. Pollution Prevention/Good Housekee in
The permittee shall continue implementing an operation and maintenance program. including a training
component, that shall prevent or reduce pollutant runoff from municipal operations and that shall include the
following-
1. Operation and Maintenance of MS4 - A program for inspecting, maintaining and cleaning all
components of the MS4 including street sweeping, cleaning ditches, culverts, storm sewer intakes
and stone sewer pipes and open channels shall continue to be implemented. Maintenance shall be
performed as needed on all described components.
The program shall be implemented by the permittee for the duration of the permit,
2. Pesticide and Fertilizer Management Program — A pesticide acid fertilizer management program
shall continue to be implemented and enforced which shall reduce pollutant discharge associated
with storage, application and disposal of pesticides and fertilizers for municipal operations. The
program shall identify all municipal entities that apply pesticides and fertilizers, require that
application of these chemicals be applied by properly trained individuals and require training on
management techniques addressing storage, application and disposal. Data regarding the
application rates of pesticides and fertilizers shall be gathered and evaluated to determine if lower
rates would be equally effective. Should it be determined that lower application rates would be
equally or nearly as effective it shall be required that the lower rates be applied.
The program shall be implemented by the permittee for the duration of the permit.
3. Training Program for Municipal Employees — The permittee shall continue to implement a
program for training municipal employees regarding practices to be implemented in city
operations to reduce pollutants in storm water. Training for existing municipal employees shall be
conducted at least once during the duration of the permit and for all new employees within one
year of initiation of municipal employment.
The program shall be implemented by the pennittee for the duration of the permit.
4. City Facilities BMPs — A program shall continue to be implemented to assess BMPs at all facilities
owned or operated by the permittee. These BMPs shall be designed to reduce pollutants in storm
water from these facilities. The BMPs shall then be implemented whenever practical.
These facilities shall be inspected and BMPs assessed and modified as necessary but at least once
during the duration of the permit.
PART III. REPORTING REQUIREMENTS
Annual Report
The permittee shall prepare an annual report to be submitted to the Department no later than September 30 of
each calendar year. The report shall be submitted to the appropriate Department field office and shall include
the following:
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Facility Name: City of Dubuque Municipal Separate Storm Sewer System
Permit Number: 31-26-0-04 Draft Permit
The status of implementing the components of this permit. Any modifications developed by the
permittee and approved by the Department or required by the Department shall also be addressed.
A summary of the data. including monitoring data if it exists, that is generated within the reporting
period including a narrative description of storm water quality improvements or degradation.
An estimate of the previous fiscal year's expenditures for implementation of the requirements of
this permit and the budget for the current fiscal year.
4. A summary describing the number and nature of inspections, enforcement actions, illicit
discharges discovered, ordinances adopted, public education programs conducted, components of
the MS4 cleaned, stream restoration activities, meetings held and any other actions taken by the
permittee required by this permit during the reporting period.
PART IV. SPECIAL CONDITIONS
Only storm water, allowable non -storm water, and pollutants for which an NPDES permit has been issued and
when the discharge is in compliance with the permit, are allowed to be discharged to the MS4. The permittee
shall not have nor allow any discharge of pollutants from a site, facility or source for which an NPDES permit
is required unless an NPDES permit has been issued for the discharge. Upon discovery of any unpermitted
discharge for which a permit is required or, if an NPDES permit has been issued for the discharge, a discharge
not in compliance with the permit, the permittee shall report the discharge to the Department no later than the
end of the next business day after the discharge is discovered. Floor drains and other potential sources of
pollutants shall be considered discharges even if no actual pollutants have been observed entering the MS4
from such a source.
The permittee is prohibited from issuing any permit, authorization or license allowing any construction,
excavating, clearing, grubbing, or any other soil disturbing activity and is prohibited from allowing a person.
persons, company, political unit or other entity, public or private, from doing same for which, in whole or as
part of another project, coverage under an NPDES permit is required without First ensuring that a storm water
authorization from the Department has been issued for the activity.
A construction site inspection program shall continue to be implemented for construction projects owned or
operated by the permittee that include areas of soil disturbance for which NPDES permits are required. The
inspection program shall be used to ensure that contractors are correctly implementing BMPs which have been
approved in the pollution prevention plan and any additional necessary measures. The program shall require
inspections by the permittee at least every 7 days and include any other provisions necessary to ensure
compliance by contractors with the storm water General Permit no, 2. Inspections made by the permittee that
satisfy the requirements of General Permit no. 2 may be used to satisfy the requirements of this permit.
A map of the MS4, including all outfails, shall be maintained for the duration of this permit.
Salt storage at the public works building shall be in a structure impervious to precipitation, Salt storage at the
location where the permittee receives salt shipments shall be on an impervious pad and kept covered by a
waterproof cover except when salt is being added or removed. Any spillage due to handling activities in either
area subject to runoff shall be immediately removed,
The permittee may directly place snow, free of trash, into or onto a Water of the State.
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Facility Name: City of Dubuque Municipal Separate Storm Sewer System
Permit Number: 3I-26-0-04 Draft Permit
The manner in which actions required by this permit are accomplished by the permittee is subject to review and
approval by the Department. Should the Department give notice to the permittee that the approach used by the
permittee to comply with any permit provision is unacceptable, the permittee must modify its approach as
required in order to be considered in compliance with the permit.
PART V. STANDARD CONDITIONS
A. Pemittee's Duty to Comply_
The permittee must comply with all conditions of this permit, Any permit noncompliance constitutes a
violation of the Clean Water Act (CWA) and is grounds for enforcement action; for permit termination,
revocation and reissuance, or modification; or for denial of a permit renewal application. Issuance of this
permit does not relieve the permittee of the responsibility to comply with all local, state and federal laws,
ordinances, regulations or other legal requirements applying to the operation of this facility (see 40 CFR
122.41(a) and 567-64.3(11) IAC),
B. Duty to Provide Information
The permittee shall furnish to the Department, within a time specified by the Department, any information that
the Department may request to determine whether cause exists for modifying, revoking and reissuing, or
terminating this permit or to determine compliance with this permit. The permittee must also furnish to the
Department, upon request, copies of any records required to be kept by this permit.
C. Need to Halt or Reduce Activity Not a Defense
It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or
reduce the permitted activity in order to maintain compliance with the conditions of this permit.
D. Signatory Requirements
Storm Water Pollution Prevention Plans, reports, certifications or information either submitted to the
Department or that this permit requires be maintained by the permittee, shall be signed as follows:
For a municipality, State, Federal, or other public facility: by either a principal executive officer or ranking
elected official. For purposes of this section, a principal executive officer of a Federal agency includes 1) the
chief executive officer of the agency, or 2) a senior executive officer having responsibility for the overall
operations of principal geographic unit of the agency.
Certification Any person signing documents shall maize the following certification:
I certify 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 qualified personnel properly gathered and
evaluated the information submitted. Based on my inquiry of the person or persons who manage the
system, or those persons directly responsible for gathering the information, the information submitted is, to
the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant
penalties for submitting false information, including the possibility of fine and imprisonment for knowing
violations.
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Facility Name: City of Dubuque Municipal Separate Storm Sewer System
Permit Number: 31-26-0-04 Draft Permit
E, Duty to Mitigate
The permittee shall take all reasonable steps to minimize or prevent any discharge in violation of this permit
that has a reasonable likelihood of adversely affecting human health or the environment.
F. Property Rights
The issuance of this permit does not convey any property rights of any sort, nor any exclusive privileges, nor
does it authorize any injury to private property nor any invasion of personal rights. nor any infringement of
Federal, State, or local laws or regulations.
G. Severability
The provisions of this permit are severable, and if any provision of this permit, or the application of any
provision of this permit to any circumstance, is held invalid, the application of such provision to other
circumstances, and the remainder of this permit shall not be affected thereby.
H. State/Environmental Laws
Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the permittee
from any responsibilities, liabilities, or penalties established pursuant to any applicable State law or regulation
under authority preserved by Section 510 of the Act. No condition of this permit shall release the penmittee
from any responsibility or requirements under other environmental statutes, regulations or permits.
1. Proper Operation and Maintenance
The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control
(and related appurtenances) that are installed or used by the permittee to achieve compliance with the
conditions of this permit and with the requirements of storm water pollution prevention plans. Proper operation
and maintenance also includes adequate laboratory controls and appropriate quality assurance procedures.
Proper operation and maintenance requires the operation of backup or auxiliary facilities or similar systems,
installed by the permittee only when necessary to achieve compliance with the conditions of the permit.
J. Inspection and Entry
The permittee shall allow the Department, an authorized representative or an authorized representative of the
municipal operator of the separate storm sewer receiving the discharge, upon the presentation of credentials and
other documents as may be required by law, to: enter upon the permittee's premises where a regulated facility
or activity is located or conducted or where records must be kept under the conditions of this permit; have
access to and copy at reasonable times, any records that must be kept under the conditions of this permit;
inspect at reasonable times any facilities or equipment (including monitoring and control equipment); and to
sample any discharge of pollutants.
K. Permit Actions
This pennit may be modified, revoked and reissued, or terminated for cause. The filing of a request by the
permittee for a permit modification, revocation and reissuance, or discontinuance, or a notification of planned
changes or anticipated noncompliance does not stay any permit condition. This permit may be modified due to
conditions or information on which this permit is based, including any new standard the Department may adopt
that would change the required effluent limits.
1 UIl3
Facility Name: City of Dubuque Municipal Separate Storm Sewer System
Permit Number: 31-26-0-04 Draft Permit
L. Potential or Realized Impacts on Water Quality
If there is evidence indicating potential or realized impacts on water quality or on a Iisted endangered species
due to any storm water discharge associated with industrial activity covered by this permit, the permit shall be
modified to include different limitations and/or requirements of the Pollution Prevention Plan and its
implementation.
M. Failure to submit fees
This permit may be revoked, in whole or in part, if the appropriate pennit fees are not submitted within sixty
(60) days of the date of notification that such fees are due.
N. Penalties For Violations of Permit Conditions
Section 309 of the CWA provides significant penalties for a person(s) who violates a permit condition
implementing Section 301, 302, 306, 307. 318, or 405 of the CWA, or any permit condition or limitation
implementing any such sections in a permit issued under Section 402. Any person(s) who violates any
condition of this permit is subject to a civil penalty not to exceed $25,000 per day of such violation, as well as
any other appropriate sanction provided by Section 309 of the CWA.
PART VI. DEFINITIONS
1. Allowable Non -Storm Water means: discharges from firefighting activities, fire hydrant flushings, potable
water sources, waterline flushings, uncontaminated groundwater, foundation or footing drains where flows
are not contaminated with process materials such as solvents, springs, riparian habitats, wetlands, irrigation
water, air conditioning condensate, exterior building washwater when no detergents or other surfactants are
used and pavement washwaters where spills or leaks of toxic or hazardous materials have not occurred and
when no detergents or other surfactants are used.
2. Best Management Practices ("BMPs") means schedules of activities, prohibitions of practices,
maintenance procedures, and other management practices to prevent or reduce the pollution of waters of the
State. BMPs also include treatment requirements, operating procedures, and practices to control facility site
runoff, spillage or leaks, sludge or waste disposal, or drainage from raw material storage.
3. Calendar quarter means each of the following periods: January thru March, April thru June, July thru
September and October thru December.
4. CWA means Clean Water Act (formerly referred to as the Federal Water Pollution Control Act or Federal
Water Pollution Control Act Amendments of 1972).
5. Department means the Iowa Department of Natural Resources (IDNR) or an authorized representative.
6. Discharge means the release of water and any elements, compounds and particles contained within or
upon, from property owned or controlled by an individual, individuals, or entity.
7. Facil4 means any entity which discharges storm water.
8. Municipal separate storm sewer system means the conveyance or system of conveyances including storm
sewers, roadways, roads with drainage systems, catch basins, curbs, gutters, ditches, constructed channels
and storm drains owned or operated by the permittee.
9. Permittee means the City of Dubuque.
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Facility Name: City of Dubuque Municipal Separate Storm Sewer System
Permit Number: 31-26-0-04 Draft Permit
10. Point source means any discernible, confined, and discrete conveyance, including but not limited to, any
pipe, ditch, channel, tunnel, conduit, well, discrete fissure, container, rolling stock, concentrated animal
feeding operation, landfill leachate collection system, vessel or other floating craft from which pollutants are
or may be discharged. This tern does not include return flows from irrigated agriculture or agricultural
storm water runoff.
11. Significant materials includes, but is not limited to: raw materials; fuels; materials such as solvents,
detergents, and plastic pellets; finished materials such as metallic products; raw materials used in food
processing or production; hazardous substances designated under Section 101(14) of Comprehensive
Environmental Response, Compensation and Liability Act (CERCLA); any chemical the facility is required
to report pursuant to Emergency Planning and Community Right -to -Know Act (EPCRA) Section 313;
fertilizers-, pesticides; and waste products such as ashes, slag and sludge that have the potential to be released
with storm water discharges.
12. Storm water means storm water runoff, snow melt runoff, snow and surface runoff and drainage.
13. Storm water discharge associated with industrial activity means the discharge from any conveyance that
is used for collecting and conveying storm water and that is directly related to manufacturing, processing or
raw materials storage areas at an industrial plant. The term does not include discharges from facilities or
activities excluded from the NPDES program, For the categories of industries identified in paragraphs (i)
through (x) of this definition, the term includes, but is not limited to, storm water discharges from industrial
plant yards; immediate access roads and rail lines used or traveled by carriers of raw materials, manufactured
products, waste material, or by-products used or created by the facility; material handling sites; refuse sites;
sites used for the application or disposal of process waste waters (as defined at 40 CFR Part 401); sites used
for the storage and maintenance of material handling equipment; sites used for residual treatment, storage, or
disposal; shipping and receiving areas; manufacturing buildings; storage areas (including tank farms) for raw
materials, and intermediate and finished products; and areas where industrial activity has taken place in the
past and significant materials remain and are exposed to storm water. For the categories of industries
identified in paragraph (xi) of this definition, the term includes only storm water discharges from all areas
(except access roads and rail lines) listed in the previous sentence where material handling equipment or
activities, raw materials, intermediate products, final products, waste materials, by-products, or industrial
machinery are exposed to storm water. For the purposes of this paragraph, material handling activities
include the storage, loading and unloading, transportation, or conveyance of any raw material, intermediate
product, finished product, by-product or waste product. The term excludes areas located on plant lands
separate from the plant's industrial activities, such as office buildings and accompanying parking lots as long,
as the drainage from the excluded areas is not mixed with storm water drained from the above described
areas. Industrial facilities (including industrial facilities that are Federally, State, or municipally owned or
operated that meet the description of the facilities listed in paragraphs (i) to (xi) of this definition) include
those facilities designated under 122.26(a)(1)(v). The following categories of facilities are considered to be
engaging in "industrial activity" for purposes of this subsection.
(i) Facilities subject to stone water effluent limitations guidelines, new source performance
standards, or toxic pollutant effluent standards under 40 CFR Subchapter N (except facilities with
toxic pollutant effluent standards that are exempted under category (xi) of this definition);
(ii) Facilities classified as Standard Industrial Classifications 24 (except 2434), 26 (except 265 and
267), 28 (except 283 and 285), 29, 31 I, 32 (except 323), 33, 3441, 373;
(iii) Facilities classified as Standard Industrial Classifications 10 through 14 (mineral industry)
including active or inactive mining operations (except for areas of coal mining operations no longer
meeting the definition of a reclamation area under 40 CFR 434.11(1) because the performance bond
issued to the facility by the appropriate SMCRA authority has been released, or except for areas of
non -coal mining operations that have been released from applicable State or Federal reclamation
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Facility Name: City orDubuque Municipal Separate Storm Sewer System
Permit Number: 31-26-0-04 Draft permit
requirements after December 17, 1990) and oil and gas exploration, production, processing, or
treatment operations, or transmission facilities that discharge storm water contaminated by contact
with or that has come into contact with, any overburden, raw material, intermediate products, finished
products, byproducts or waste products located on the site of such operations; inactive mining
operations are mining sites that are not being actively mined, but that have an identifiable
owner/operator;
(iv) Hazardous waste treatment, storage, or disposal facilities, including those that are operating under
interim status or a permit under Subtitle C of RCRA;
(v) Landfills, land application sites, and open dumps that have received any industrial wastes (waste
that is received from any of the facilities described under this subsection) including those that are
subject to regulation under Subtitle D of RCRA;
(vi) Facilities involved in the recycling of materials, including metal scrap yards, battery reclaimers,
salvage yards, and automobile junkyards, including but limited to those classified as Standard
Industrial Classification 5015 and 5093;
(vii) Steam electric power generating facilities, including coal handling sites;
(viii)Transportation facilities classified as Standard Industrial Classifications 40, 41, 42 (except 4221-
25), 43, 44, 45 and 5171 that have vehicle maintenance shops, equipment cleaning operations, or
airport deicing operations. Only those portions of the facility that are either involved in vehicle
maintenance (including vehicle rehabilitation, mechanical repairs, painting, fueling, and lubrication),
equipment cleaning operations, airport deicing operations, or that are otherwise identified under
paragraphs (i) to (vii) or (ix) to (xi) of this subsection are associated with industrial activity;
14. Treatment works treating domestic sewage or any other sewage sludge or wastewater treatment device or
system, used in the storage treatment, recycling, and reclamation of municipal or domestic sewage, including
land dedicated to the disposal of sewage sludge that are located within the confines of the facility, with a
design flow of 1-0 mgd or more, or required to have an approved pretreatment program under 40 CFR Part
403. Not included are farm lands, domestic gardens or lands used for sludge management where sludge is
beneficially reused and that are not physically located in the confines of the facility, or areas that are in
compliance with 40 CFR Part 503;
15. Construction activity including clearing, grading and excavation activities that result in the disturbance of
1 acre or more of total land area or which result in the disturbance of less than I acre but are part of a larger
common plan of development or sale of 1 acre or more;
16. Facilities under Standard Industrial Classifications 20, 21, 22, 23, 2434, 25, 265, 267, 27, 283, 285, 30, 31
(except 311), 323, 34 (except 3441), 35, 36, 37 (except 373), 38, 39, 4221-25, (and that are not otherwise
included within categories (i) to (x)).
17. Waters of the State means any river, stream, lake, pond, marsh, watercourse, waterway, well, spring,
reservoir, aquifer, irrigation system, drainage system and any other body or accumulation of water, surface or
underground, natural or artificial, public or private, which are contained within, flow through or border upon
the state or any portion thereof.
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