NPDES Phase II Permit ApplicationMEMORANDUM
February 25, 2003
TO:
FROM:
SUBJECT:
The Honorable Mayor and City Council Members
Michael C. Van Milligen, City Manager
National Pollution Discharge Elimination System (NPDES) Phase II Permit
Application
Acting Public Works Director Gus Psihoyos and the Environmental Stewardship
Commission recommend City Council approval of the City of Dubuque's National
Pollution Discharge Elimination System (NPDES) Phase II municipal separate storm
sewer system permit application. The permit application serves as Dubuque's
Stormwater Management Program to reduce the discharge of pollutants from
Dubuque's storm sewer system to the maximum extent practicable, as required by the
Federal government.
This is an unfunded Federal mandate with an estimated cost of $100,000 per year.
Fifty-five people, including the members of the Environmental Stewardship Commission,
served on five separate task forces to develop the plan for this permit application.
I concur with the recommendation and respectfully request Mayor and City Council
approval. Acting Public Works Director Gus Psihoyos has a brief presentation.
MiChael C. Van Milligen
MCVM/jh
Attachment
cc: Barry Lindahl, Corporation Counsel
Cindy Steinhauser, Assistant City Manager
Gus Psihoyos, Acting Public Works Director
MEM
ORANDUM
February 25, 2003
TO:
FROM:
Michael C. Van Milligen, City Manager
Gus Psihoyos, Assistant City Engineer
SUBJECT: National Pollution Discharge Elimination System (NPDES) Phase II Permit
Application
INTRODUCTION
The purpose of this memo is to present the City of Dubuque's NPDES Phase II
municipal separate storm sewer system (MS4) permit application for the City Council's
approval. The permit application serves as Dubuque's Stormwater Management
Program to reduce the discharge of pollutants from Dubuque's storm sewer system to
the maximum extent practicable.
BACKGROUND
The Clean Water Act (CWA) of 1972 prohibits the discharge of any pollutant into the
waters of the US from a point source, unless permitted by a NPDES permit. Point-
source pollution is categorized by the ability to clearly identify where the pollutant enters
a receiving water body (a lake, creek, stream, river, etc.).
Even after controlling point-source pollution, receiving waters exhibited poor water
quality. Therefore, in 1987 the CWA was amended to target non-point source pollution.
NPDES Phase I was initiated in November of 1990. Communities with populations of
100,000 or larger that operated municipal separate storm sewer systems (MS4s) had to
create a stormwater program (apply for an NPDES Phase I permit) to reduce the
discharge of pollutants from their storm sewer system. In addition to MS4s, an NPDES
permit was required for all construction sites that disturb five (5) or more acres.
On December 8, 1999 the final NPDES Phase II rule was published in the Federal
Register, establishing several milestones.
1. The US Environmental Protection Agency (EPA) was to issue a menu of Best
Management Practices (BMPs) by October of 2000.
2. By October of 2001 the EPA was to produce guidance pertaining to measurable
goals associated with each BMP.
3. By December of 2002 the Iowa Department of Natural Resources (IDNR), Iowa's
NPDES permitting authority, was to produce a general NPDES permit for Phase
II communities such as Dubuque.
4. By March 10, 2003 the City of Dubuque must submit a permit application (either
a general permit or an individual permit) to the IDNR.
Steps one and two above have been meet. However, the IDNR did not distribute a
general permit. As a result, Dubuque must produce an individual NPDES permit
application for its MS4.
There are specific requirements that the City of Dubuque must include in its permit
application. However, the majodty of the NPDES permit application process involves the
identification of best management practices (BMPs) that are appropriate for Dubuque.
BMPs must be selected for each of the six minimum control measures. The six
minimum control measures are:
1)
2)
3)
4)
5)
6)
Public Education and Outreach. This program requires the distribution of
educational materials and the steps the public can take to reduce the pollution
associated with storm water runoff.
Public Involvement and Participation. All state and local public notice
requirements must be followed when implementing the plan.
Illicit Discharge Detection and Elimination. The City must develop an
ordinance or other regulatory mechanism and enforcement program must be in
place to identify and remove illegal discharges into the drainage system.
Construction Site Stormwater Runoff Control. The City must develop an
ordinance to control pollutants in runoff from construction sites. BMPs must be
identified that control/reduce erosion and control sediment.
Post Construction Stormwater Runoff Control. The City must use an ordinance
or other regulatory mechanism to address post-construction runoff. Similar to
Construction Site Controls, but the BMPs for post construction are permanent
BMPs to remain and be maintained by the property owner.
Municipal Operation Good House Keeping. The City must develop an operation
and maintenance program that includes a training component to prevent or
reduce the pollutant runoff from municipal operations.
DISCUSSION
On December 16, 2002 the City Council approved a process to produce Dubuque's
NPDES permit application. The process included:
1) The formation of five (5) separate task forces to determine BMPs appropriate for
Dubuque that address the six (6) minimum control measures; and
2) The establishment of the Environmental Stewardship Advisory Commission as
the body to oversee the work of each task force and the formation of the NPDES
permit application.
page 2 of 6
PROCESS FLOW CHART
NPDESF
Iowa Department of Natural Resources
City Council
Environmental Stewardship Commission
City Staff Task Force
Task Force Membership
Each task force was comprised of: a member of the Environmental Stewardship
Advisory Commission, City staff, and private citizens (see Table 1). There are three
main reasons to involve private citizens in the process as members of a task force.
Foremost, as the authors of the regulations state, "an informed and knowledgeable
community is crucial to the success of a storm water management program . . . to
garner greater support and an awareness of personal responsibility." Secondly, the
more Dubuque can tap into the environmentally related citizen groups and educational
institutions the lower the program's cost will be to citizens of Dubuque. Lastly, as
stated previously, two of the six minimum control requirements of the program include
public education and participation.
page 3 of 6
Task Task Task Task Task
Force Force Force Force Force
~oster Member Organization #1 ¢Y2 #3 ~ #5
3aniel Calvert Environmental Stewardship X X
Advisory Commission
John Nemmers Environmental Stewardship X X X
Advisory Commission
Environmental Stewardship X X
Vlark Henning Advisory Commission
Vlichael Buelow Environmental Stewardship
Advisory Commission X X
Vlichael Hirsch Environmental Stewardship X
Advisory Commission
Environmental Stewardship
~,ndrea Bixler Advisory Commission / Clarke X
College
Environmental Stewardship
Nilliam Niemann Advisory Commission / University X X
9f Dubuque
3arry Lindahl City of Dubuque X X
3ill Blum City of Dubuque X
~ob Green City of Dubuque X
.~indy Steinhauser City of Dubuque X X
}an Brown City of Dubuque X
3eron Muehring City of Dubuque X X X X X
:)on Vogt ~.ity of Dubuque X X
Gil Spence $ity of Dubuque X
Gus Psihoyos .City of Dubuque X X X X X
Jerelyn O'Connor Dity of Dubuque X X
John Hail .3ity of Dubuque X
John Klosterman .City of Dubuque X X
Jon Brown .3ity of Dubuque X
Kyle Kritz 3ity of Dubuque X
Mark Munson 2,ity of Dubuque X
Mary Rose Corrigan .~ity of Dubuque X
Nancy Otterbeck .~ity of Dubuque X
Paul Horsfall ,3ity of Dubuque X
Paul Schultz .';ity of Dubuque X
Rich Russell .~ity of Dubuque X
Steve Pregler ICity of Dubuque X
Rick Steines City of Dubuque X
Scott Neyens City of Dubuque X
Jim Stangeland Bass Fishing Club of Dubuque X
Dan Arnold Bass Fishing Club of Dubuque X
John White Buesing & Associates X
page 4 of 6
~oster Member
Organization
Catfish Creek Coalition
rom Boland
Nayne Petersen Dept. of Agriculture
vlarty McNamer Developers Roundtable
:)r. Chades
Ninterwood Dubuque Audubon Society
Nalt Pregler Dubuque Boat Club
~ob White Dubuque Community Schools
=-arl Brimeyer
Jeff Klopfenstein
~ick Dickinson
Dubuque Dragon Boat
Durrant Group
Greater Dubuque Development
Corporation
Nayne Buchholtz IDNR - Mines of Spain
=at Norton IIW Engineers
~eter Ilich Loras College
_arry McDermott McDermott Excavating
North End Neighborhood
Nayne Klostermann Association
Yerry Heitkamp MSA
¥ony Zelinskas WHKS
Yheresa Weiss N RCS
Vlike Portzen Porizen Construction
~on Smith Ron Smith Construction
3ick Worm Sierra Club
:~ichard Cowart University of Dubuque
Vlarty Berns Walleye Fishing Club of Dubuque
Each task force met three times starting in December. The meeting objectives were:
1)
2)
3)
Familiarize task force members with the Phase 11 rule, summarize what is
required of the City of Dubuque, and outline the goal of each task force;
Outline the specific requirements of each task force, present
examples/suggestions of best management practices (BMPs) that Dubuque
might employ, and discuss alternative BMPs; and
Compile a plan to be presented to the Environmental Stewardship Commission,
the City Manager, the City Council, and the tDNR.
Over the course of three months, each task force discussed the NPDES Phase II
program, requirements of Dubuque, and the appropriateness of individual BMPs.
Besides the BMPs specifically required [see the shaded Sec. 122.34 (b) Minimum
control measure boxes in the permit application], the BMPs found in Dubuque's
individual permit application were arrived at by thoughtful discussion and task force
consensus.
page 5 of 6
Overall, Dubuque's storm water management program (NPDES permit application)
promotes the formation of partnerships with existing citizen organizations; the
distribution of existing and additional educational materials; and the use of a mixture of
advertising media to inform Dubuque residents how their day-to-day activities impact
area-receiving waters. In addition, it includes the development of three ordinances:
limiting discharges into the storm sewer system, controlling construction activity to
minimize erosion and sedimentation, and development techniques that reduce the
pollution potential in an urban setting.
On February 19, 2003 City staff presented the NPDES Phase II MS4 permit application
to the Environmental Stewardship Advisory Commission. After careful review of the
document, the Commission recommended that:
1. The City Council approve the NPDES permit application as drafted;
2. The Commission be involved with the implementation of the BMPs;
3. The Commission review the annual report required by the regulations prior to the
Council's review and the submittal to the IDNR; and
4. City staff provide quarterly updates to the Commission to ensure that progress is
being made towards the implementation of the BMPs.
RECOMMENDATION
I concur with the Environmental Stewardship Advisory Commission's recommendations
and respectfully request that the City Council approve the NPDES permit application
and authorize City staff to forward it to the IDNR.
BUDGET IMPACT
An annual appropriation of $100,000 is budgeted in the FY 2004-08 five-year capital
improvement budget to implement the BMPs. While staff hopes to initiate many of the
BMPs in the first permit year, Dubuque has five years to fully implement the BMPs
identified in the permit application. Section VIII of the permit application indicates the
target permit year to implement each BMP.
ACTION REQUESTED
I respectfully request that the City Council approve the NPDES Phase II MS4 permit
application and authorize City staff to forward it to the Iowa Department of Natural
Resources.
Prepared by Deron Muehring
CC: Michael Koch, Public Works Director
Cindy Steinhauser, Assistant City Manager
Pauline Joyce, Administrative Services Manager
Barry Lindahl, Corporation Council
Mary Rose Corrigan, Health Services Manager
Environmental Stewardship Commission
NPDES Task Force Members
attachments page 6 of 6
February 24, 2003
Honorable Mayor Terry M. Duggan and
City Council Members
City Hall
50 W. 13th Street
Dubuque IA 52001
Dear Mr. Mayor and Council Members:
As requested, the Environmental Stewardship Advisory Commission has served as the
oversight body for the City's formulation of an NPDES permit application. At least one
Commission members served on all five task forces created to address each point of
the application. In addition, Engineering staff met with the Commission three times.
Two of those meetings were to go over progress made by the various task forces. On
February 19, 2003, following its review, the Commission voted to approve the NPDES
permit application.
The Commission would like to thank City staff and the City Council for the opportunity
to be involved and offer input regarding this very important issue.
We recommend the following:
2.
3.
4.
The City Council approve the NPDES permit application as drafted;
The Commission be involved with the implementation of the Best
Management Practices (BMPs) identified in the permit application;
The Commission review the required annual report prior to its submittal to the
City Council and the Iowa Department of Natural Resources (IDNR); and
That City staff provide quarterly updates to the Commission to ensure that
progress is being made towards the implementation of the BMPs;
The Commission is committed to remaining informed with respect to the pollution
associated with storm water runoff and how it affects receiving creeks and rivers. One
of our Commissioners, Dan Calvert, will accompany City staff to a training session to
become more knowledgeable in the area of stormwater pollution and best management
practices.
I (or any Commission member) would be happy to address any questions you might
have.
Environmental Stewardship Advisory Commission
CC:
Michael C. Van Milligen, City Manager
Gus Psihoyos, Assistant City Engineer
Deron Muerhing, Engineering Division
INDIVIDUAL PERMIT APPLICATION
FOR DISCHARGE OF STORM WATER ASSOCIATED
WITH MUNICIPAL SEPARATE STORM SEWER
SYSTEMS UNDER THE NATIONAL POLLUTANT
DISCHARGE ELIMINATION SYSTEM
In accordance with the provisions of the Clean Water Act, as amended, (33
U.S.C. 1251 et. seq. the Act) 40 CFR 122, 123, and 124 the City of Dubuque has
prepared this permit application. The City of Dubuque asserts that the permit
application contained herein meets or exceeds NPDES requirements for a Small
Municipal Separate Storm Sewer System (MS4) as defined in 40 CFR
122.26(b)(16),
As such, the City of Dubuque requests a permit from the Iowa Department of
Natural Resources (IDNR), [the designated National Pollutant Discharge
Elimination System (NPDES) permitting authority for the State of Iowa] to
authorize storm water discharge from Dubuque's MS4 to waters of the United
States.
Moreover, unless notified by the IDNR to the contrary, during the period between
the submission of this permit application [and application fee] to the IDNR and
the issuance of a permit by the IDNR, the City of Dubuque is authorized to
discharge storm water associated with Dubuque's MS4 into waters of the United
States.
Terrance M. Duggan
Mayor
City of Dubuque (IA)
Da~:
City of Dubuque NPDES Phase II MS4 Individual Permit Application -page 1 of 35-
Name of the Phase II MS4 Applicant: City of Dubuque
Name of the Phase Il MS4 Responsible Authority: Michael C. Van Milligen
Address: 50 W. 13th Street
i Zip Code: 52001
(563) 589 - 4110
I Coun~:Dubuque
Name of the Designated Phase II MS4 Stormwater Management Program Contact:
Deren L. Muehdng
ineer
Public Works, Engineering Division
Address: 50 W. 13th Street
t Zip Code: 52001
(563) 589 - 4276
E-mail Address: dmuehrin~dtyofdubuque.org
I Count:Dubuque
Phase ]1 MS4 ownership status: Public
Total resident population of the Phase ]1 MS4:57,686 (2000 Census)
(square miles): 27.5
No entity, other than the City of Dubuque, will implement ~ of Dubuque's permit obligations on Dubuque's behalf.
Listed below are the waters of the United States to which Dubuque's Phase Il MS4 discharges:
Mississippi River* Granger Creek Bee Branch Creek
Catfish Creek South Fork Catfish Creek Middle Fork Catfish Creek
North Fork Catfish Creek
*Identified on Iowa's 303(d) list of impaired waters
The complete description of each BMP can be found in section VII. In addition, a BMP summary form is included for
BMP Full ~ BMP
Description / Summary
(Pages) (Paaes~
4-9 27-28
10-13 29-30
14-18 31-32
19-21 i 33
22-23 34
each minimum control measure (see section VIII).
Minimum Control Measure
Public Education and Outreach as to Stormwater Impacts
Public Involvement/Public Participation
illicit Discharge Detection and Elimination
Construction Site Stormwater Runoff Control
Post-construction Stormwater Management in New Development and Redevelopment
Pollution Prevention/Good Housekeeping for Municipal Operations
24-26 35
City of Dubuque NPDES Phase It MS4 Individual Permit Application -page 2 of 35-
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 upon 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.
Name of Phase II MS4 Responsible Authority (type or print):
Title: City Manager
Signature:
Michael C. Van Milligen
Date:
/ /
City of Dubuque NPDES Phase II MS4 Individual Permit Application -page 3 of 35-
BLANK PAGE
PUBLIC EDUCATION and OUTREACH
MINIMUM CONTROL MEASURE BMPS
Dubuque recognizes that there are three significant reasons to involve private citizens in
the process of selecting appropriate BMPs and implementing Dubuque's storm water
management program. Foremost, as the authors of the regulations state, "an informed
and knowledgeable community is crucial to the success of a storm water management
program . . . to garner greater support and an awareness of personal responsibility."
Secondly, the more Dubuque can tap into local citizen groups and educational
institutions the more Dubuque can stretch its financial resources. Lastly, as stated
previously, two of the six minimum control requirements of the program include the
public - public education and public participation.
To address the six (6) minimum control measures, the City formed five (5) separate task
forces, each with the objective of determining the BMPs appropriate for the City of
Dubuque. Task force membership was comprised of City staff, members of the City
Council appointed Environmental Stewardship Advisory Commission, IDNR, National
Resource Conservation Service, local engineers, local contractors, local developers,
and representatives from various citizen organizations (see table 1). The process
hierarchy and flow of communication is shown below:
Iowa Department of Natural Resources
City Council
Environmental Stewardship
Advisory Commission
City staff Task Force
City of Dubuque NPDES Phase II MS4 Individual Permit Application -page 4 of 35-
PUBLIC EDUCATION and OUTREACH
MiNIMUM CONTROL MEASURE BMPS
Task Task Task Task Task
Force Force Force Force Force
Roster Member Organization #1 #2 #-3 ~ #5
Daniel Calvert Environmental Stewardship X X
Advisory Commission
John Nemmers Environmental Stewardship X X X
Advisory Commission
Environmental Stewardship X X
Mark Henning Advisory Commission
Michael Bue]ow Environmental Stewardship X X
Advisory Commission
Michael Hirsch Environmental Stewardship X
Advisory Commission
Environmental Stewardship
~,ndrea Bixler Advisory Commission I Clarke X
College
Environmental Stewardship
~Viiliam Niemann Advisory Commission / University X X
of Dubuque
Barry Lindahl City of Dubuque X X
Bill Blum City of Dubuque X
Bob Green City of Dubuque X
3indy Steinhauser City of Dubuque X X
Dan Brown City of Dubuque X
Deron Muehring City of Dubuque X X X X X
Don Vogt City of Dubuque X X
,.Gil Spence City of Dubuque X
3us Psihoyos City of Dubuque X X X X X
Jerelyn O'Connor City of Dubuque X X
John Hail City of Dubuque X
John KIosterman City of Dubuque X X
Jon Brown City of Dubuque X
~yle Kritz City of Dubuque X
Vlark Munsen City of Dubuque X
Vlary Rose Corrigan City of Dubuque X
~lancy Otterbeck City of Dubuque X
~aul Horsfall City of Dubuque X
=au] Schultz City of Dubuque X
:~ich Russell City of Dubuque X
.~teve Pregler City of Dubuque X
~ick Steines City of Dubuque X
Scott Neyens City of Dubuque X
Jim Stangeland Bass Fishing Club of Dubuque X
:)an Arnold Bass Fishing Club of Dubuque X
John White Buesing & Associates X
City of Dubuque NPDES Phase II MS4 Individual Permit Application -page 5 of 35-
PUBLIC EDUCATION and OUTREACH
MINIMUM CONTROL MEASURE BMPS
Task Task Task Task Task
Force Force Force Force Force
Roster Member Organization #1 #2 #3 #4 #-5
Tom Boland Catfish Creek Coalition X
Wayne Petersen Dept. of Agriculture X
~/larty McNamer Developers Roundtable X
Dr. Charles
Winterwood Dubuque Audubon Society X
Walt Pregler Dubuque Boat Club X
Bob White Dubuque Community Schools X
Earl Bdmeyer Dubuque Dragon Boat X
.left KIopfenstein Durrant Group X
Rick Dickinson Greater Dubuque Development
Corporation X
~Vayne Buchholtz IDNR - Mines of Spain X
Pat Norton IIW Engineers X
Peter Ilich Loras College X
Larry McDermott McDermott Excavating X
North End Neighborhood X
~Vayne Klostermann Association
Terry Heitkamp MSA X
Tony Zelinskas WHKS X
Theresa Weiss NRCS X
¥1ike Portzen Portzen Construction X
:~on Smith Ron Smith Construction X
:)ick Worm Sierra Club X
~ichard Cowart University of Dubuque X
t4arty Berns Walleye Fishing Club of Dubuque X
Over the course of three months, each task force convened to discuss the NPDES
Phase II program, requirements of Dubuque, and the appropriateness of individual
BMPs.
Besides the few dictated by the Federal Register [see the shaded Sec. 122.34 (b)
Minimum control measure boxes], the BMPs found in Dubuque's individual permit
application were arrived at by thoughtful discussion and task force consensus.
City- of Dubuque NPDES Phase II MS4 Individual Permit Application -page 6 of 35-
PUBLIC EDUCATION and OUTREACH
MINIMUM CONTROL MEASURE BMPS
() (the-C~ty Of Dubuque) must ~mplement a public education program t9 d~strlbute
educatibqal materials to the commUnitY or conduct ,equivalent °ot~e~b__;h acti~ties' ab°bt
the impacts of storm water discharges on water bodies and the stePs thht the Public Can
take to reduce pollutants 'n storm water runoff.
(ii) Guidance: (the City of Dubuque) may use storm water educational,~materials
provided by your State, Tribe, EPA (Environmental Protection Agency). environmental,
~ubl!c interest o£ tradb organizatiOns, pr other MS4S. The pul~iic e~ucatlbn progra~
should inform individuals and households about the steps they can take,t0 reduce stbCm
wa[er p~llution, such as ensUring proper septic System maintenanpe, ensuring the
PrOPer use and disposal Of landscape and garden chemicals including fertilizers and
pesticides, protecting and restoring riparian vegetat on and propedy dispoSingof used
m~tor oil ,0r househOld hazardoUS wastes. EP~ recommends that'the progra~ inform
ind v!dualS ahd groups how to become involved` n 10c~l stream and b~gch restSrati0n
activities as well as activities that are coordinated by youth service and conservation
corps ~r other citizen groups. EPA recommends that the public education program be
tailored: us ng a mix o~ oca y, appropr ate stratege§; to targe~ specific au~ en~es and
communities.
The main objective behind the Clean Water Act is to maintain or improve the quality of
the nation's waters. The EPA believes that as the public gains a greater understanding
of the storm water program, the program will gain support. Moreover, the EPA believes
that the success of the program will be greater if the public understands how their
actions can impact area creeks, rivers, and streams. Well-informed citizens can act as
formal or informal educators to further disseminate information and gather support for
the program, thus easing the financial burden on the municipalities to perform
educational activities. Below is the list of BMPs the City of Dubuque will utilize to meet
the public education and outreach minimum control measure [see SECTION VIII. For
BMP implementation/completion schedule and responsible department(s)].
BMP:
1.1 Public Education Campaign Development
BMP Description: The City will develop a public education campaign.
The campaign will consist of:
1. Identifying specific groups to target (i.e. home owners, home builders, area
businesses, etc.).
City of Dubuque NPDES Phase II MS4 Individual Permit Application -page 7 of 35-
PUBLIC EDUCATION and OUTREACH
MINIMUM CONTROL MEASURE BMPS
2. Identifying the appropriate media to roach the target audiences. A
combination of two or more of the following will be utilized:
Brochuros, speakers' buroau, quarterly "City Focus" newsletter, web site, radio spots,
newspaper ads, "CityChannel 8" and public access television channels, flyers, mailers,
inserts, and any other commonly used method to advertise.
MEASURABLE GOALS:
1. The number of target groups will be tracked.
2. Each method chosen to send the information out to the public wile be tracked.
BMP:
1.2 Educational Video
BMP Description: The City will acquire an educational video on the topic of pollutants
associated with storm water runoff.
The video to be aired on the "CityChannel 8" and public access television channels,
and made available to the community upon request.
MEASURABLE GOALS:
1. The acquisition of educational videos will be documented.
BMP:
1.3 Storm Drain Labeling
BMP Description: The City will promote a storm drain-labeling program.
There are throe facets of the City storm drain-labeling program:
1. The labeling will consist of the application of a message next to street drains (inlets or
catch basins) reminding people to "Dump No Waste - Drains to Rive¢' or a similar
message accompanied by the image of a fish or other aquatic organism.
2. Door hangers will be hung in the neighborhoods where and when the storm drain
labeling is taking place, illustrating the connection between storm drains and the
receiving waters. The improper deposition of lawn/garden chemicals, grass/leaves,
motor oil, antifroeze, pet waste, and trash into storm drains will be illustrated.
3. A brochuro wilt be distributed that solicits citizens to participate in the storm drain
labeling program and provides citizens with tips on how to reduce pollution by properly
disposing of household hazardous wastes, lawn wastes, and pet wastes; reducing the
application of fertilizers; and recycling products whenever possible.
NOTE: This BMP has a public participation component. Please refer to the "Public
Participation/Involvement" BMPs. While the BMP descriptions are the same, the
measurable BMPs vary.
MEASURABLE GOALS:
1. The number of door-hangers placed on doors will be tracked.
2. The number of brochures distributed in neighborhoods will be tracked.
3. The number of storm drains labeled will be tracked.
City of Dubuque NPDES Phase II MS4 Individual Permit Application -page 8 of 35-
PUBLIC EDUCATION and OUTREACH
MINIMUM CONTROL MEASURE BMPS
BMP:
1.4 Execution of the Public Education Campaign
BMP Description: The City will execute the Public Education Campaign.
MEASURABLE GOALS:
1. All activities such as the distribution of brochures, flyers, mailers, and inserts;
speakers bureau engagements; quarterly "City Focus" newsletter articles published;
web site developments, radio spots, newspaper ads, "CityChannel 8" and public access
television channel aidngs, and the use of any other commonly used method of
advertising will be tracked.
BMP:
1.5 Storm Water Runoff Pollution Curriculum
BMP Description: The City will contact local educators and promote the use of
educational materials that teach students about the pollution associated with storm
water runoff.
MEASURABLE GOALS:
1. The number of educators contacted will be tracked.
2. Storm water pollution curriculum utilized by educators will be documented.
3. Explore & develop a curriculum to teach students about stormwater runoff pollution.
BMP:
1.6 Education Partnership Program
BMP Description: The City will assist local educators from the local colleges,
university, high schools, and grade schools with the inclusion of storm water pollution
related student activities where it is appropriate.
Appropriate student activities that the City would promote includes such things as:
1. Students learning about water quality issues in Dubuque,
2. Students preparing teaching materials,
3. Students making presentations to other students.
NOTE: This BMP has a public participation component. Please refer to the "Public
Participation/Involvement" BMPs. While the BMP descriptions are the same, the
measurable BMPs vary.
MEASURABLE GOALS:
1. The number of students who participate will be tracked.
2. The number of student presentations and the approximate size of the audience will be
tracked.
3. The number of educators contacted will be tracked.
City of Dubuque NPDES Phase II MS4 Individual Permit Application -page 9 of 35-
PUBLIC PARTICIPATION/iNVOLVEMENT
MINIMUM CONTROL MEASURE BMPS
Sec. 122.34 (b) Minimum control measures--(2) Publicinvolvement/par~icipation.
(i) (the City of Dubuque)must,. at a minimum, comply with State, Tribal and t9cal public
notice requirements When implementing a pub c nv0 Vement/part C pat °n pr°~ram
(ii) GUidance: EPA recommends that' the public be included in deyel0ping,
implementing, and reviewing yoUr Storm water management program and thatthe Pubiic
partii~ipation process should make efforts to reach out and engage all ec0nomi~ and
ethnic groups: Opportunities for members of the pubic to part c pate :n program
development and ~mplementabon include serving as c~hzen representatives' on a local
storm water management I~anet, attending public hearings, work ng as ~citizen
Volunteers to educate othe~:~ individuals about the progran~ assisting in program
coordination with other pre-existing programs, or participating in volunteer,monitoring
efforts.
The EPA believes that public involvement is an integral part of the MS4 storm water
management program and that there are two significant reasons why the public should
be allowed and encouraged to provide input and assistance during the development
and implementation of the City of Dubuque's program. First, early and frequent public
involvement can shorten implementation schedules and broaden public support for the
program. Second, public participation is likely to ensure a more successful storm water
program by providing valuable expertise and possible symbiotic relationships with other
programs and governments. This is particularly important if the Dubuque's MS4
program is to be implemented in a timely and cost effective manner. Below is the list of
BMPs the City of Dubuque will utilize to meet the public participation/involvement
minimum control measure [see SECTION VIII. For BMP implementation/completion
schedule and responsible department(s)].
BMP: 2.1 Public Notice Requirements
BMP Description: The City will comply with State and local public notice requirements
when implementing a public involvement/participation program.
MEASURABLE GOALS:
1. A copy of the public notice information will be retained.
2. The number of people who participate in the development of Dubuque's Storm Water
Management Program will be tracked.
City of Dubuque NPDES Phase I1 MS4 Individual Permit Application -page 10 of 35-
PUBLIC PARTICIPATION/INVOLVEMENT
MINIMUM CONTROL MEASURE BMPS
BMP:
2.2 Volunteer Creek Monitoring
BMP Description: The City will promote the participation of area citizens in the
IOWAter volunteer water quality-monitoring program through advertising methods.
MEASURABLE GOALS:
1. The number of sampling sites will be tracked.
2. The frequency of sampling at each site will be tracked.
BMP:
BMP:
2.3 Storm Drain Labeling
BMP Description: The City will promote a storm drain-labeling program.
There are three facets of the City storm drain-labeling program.
1. The labeling will consist of the application of a message next to street drains (inlets or
catch basins) reminding people to "Dump No Waste - Drains to River" or a similar
message accompanied by the image of a fish or other aquatic organism.
2. Door-hangers will be hung in the neighborhoods where and when the storm drain
labeling is taking place, illustrating the connection between storm drains and the
receiving waters. The improper deposition of lawn/garden chemicals, grass/leaves,
motor oil, antifreeze, pet waste, and trash into storm drains will be illustrated.
3. A brochure will be distributed that solicits citizens to participate in the storm drain
labeling program and provides citizens with tips on how to reduce pollution by properly
disposing of household hazardous wastes, lawn wastes, and pet wastes; reducing the
application of fertilizers; and recycling products whenever possible.
NOTE: This BMP has a public education component. Please refer to the "Public
Education and Outreach" BMPs. While the BMP descriptions are the same, the
measurable goals vary.
MEASURABLE GOALS:
1. The number and size of volunteer organizations will be recorded.
The number of storm drains labeled by volunteers will be tracked.
3. A location map of labeled storm drains will be developed and maintained.
2.4 Distribution of Educational Material
BMP Description: The City will provide materials to be dispersed at local volunteer
organization meetings in the community that provide citizens information pertaining to
the proper disposal of hazardous household wastes, proper disposal of yard wastes, or
the proper use of lawn fertilizers and herbicides OR information about the negative
impacts the pollutants have on the receiving water body.
City of Dubuque NPDES Phase II MS4 Individual Permit Application -page 11 of 35-
PUBLIC PARTICIPATION/INVOLVEMENT
MINIMUM CONTROL MEASURE BMPS
BMP:
MEASURABLE GOALS:
1. The number of volunteer organizations that receive materials will be tracked.
2. The type and number of all materials distributed will be tracked.
2.5 Co-Sponsored Competition
BMP Description: The City, along with local citizen organizations, will co-sponsor
competitions among area students. The City will explore partnerships with local
organizations to co-sponsor competitions among area students.
Contests will consist of cash or merchandise prizes donated by volunteer organizations
and/or the City to promote participation.
Sample contests are listed below:
1. Area grade school students who would be asked to produce a poster depicting
pollutants or ways to reduce the pollution associated with storm water runoff;
2. Area high school students who would be asked to produce either a video or web page
design depicting pollutants or ways to reduce the pollution associated with stormwater
runoff; and
3. Area college students who would be asked to produce either a video or web page
design depicting pollutants or ways to reduce the pollution associated with stormwater
runoff.
MEASURABLE GOALS:
1. The number of contests will be tracked.
2. The number of volunteer organizations that participate either through prize
sponsorship or other contest related activity such as providing a display area for entries,
serving as a judge, assist with the promotion of the competition, etc. will be tracked.
3. The number of contestants will be tracked.
BMP:
2.6 Education Partnership Program
BMP Description: The City will assist educators from the local colleges, university,
high schools, and grade schools with the inclusion of storm water pollution related
student activities where it is appropriate.
Appropriate student activities that the City would promote include such things as:
1. Students learning about water quality issues in Dubuque,
2. Students preparing teaching materials,
3. Students making presentations to other students.
NOTE: This BMP has a public education and outreach component. Please refer to the
"Public Education and Outreach" BMPs.
City of Dubuque NPDES Phase II MS4 Individual Permit Application -page 12 of 35-
PUBLIC PARTICIPATION/INVOLVEMENT
MINIMUM CONTROL MEASURE BMPS
MEASURABLE GOALS:
1. The number of schools and educators contacted will be tracked.
2. The number of students who participate will be tracked.
BMP:
2.7 Sewer and Outfall Monitoring
BMP Description: The City will facilitate volunteer organization's (such as the Catfish
Creek Coalition) inspection of sanitary sewers and inspection of storm sewer outfalls in
the vicinity of area creeks and identified target areas within the City.
Assistance may take the following forms:
1. Advertising the monitoring efforts of the Catfish Creek Coalition to grow the number of
participants (and monitoring sites); and
2. Provide volunteer monitors with the tools necessary to perform and record the
inspections.
NOTE: This BMP has an illicit discharge component. Please refer to the "Illicit
Discharge Detection and Elimination" BMPs. While the BMP descriptions are the same,
the measurable goals vary.
MEASURABLE GOALS:
1. The number of volunteer monitoring sites will be tracked.
2. The number and results of sanitary sewer and storm sewer outfall inspections will be
tracked.
City of Dubuque NPDES Phase II MS4 Individual Permit Application -page 13 of 35-
ILLICIT DISCHARGE DETECTION and ELIMiNATION
MINIMUM CONTROL MEASURE BMPS
Sec. 122.34 ~(b) Minimum control measures-=(3) illicit dischar, qe detection and
elimination.
(i) (The City of Dubuque) must.develop, imPlement and enforce a program to. detect and
eliminate illicit discharges (as defined at'§ r122.26(b)(2)) into its MS4.
(ii) (The City Of Dubuque) must: (A) Develop, if not already completed, a storm sewer
system map~ showing the location of all outfalls and the names and location of all
Waters of the United States that receive discharges from those outfalls;. (B) TO the
extent allowable under State, Tribal or local law, effectively prohibit, through 0rdinance~
or other regulatory mechanism, non-storm water discharges into your storm sewer
system 'and implement appropriate enforcement procedures and actions;. (C).Develop
and implement a' plan tc~ detect and address nomstorm water d SchavgSS nclqdin~l
illegal ~umping, to.your system; and (D) Inform public employees, businesses, and the
general public of hazaeds associated with illegal discharges and improPer disPosal of
waste;
(iii) (The City of Dubuque) needs to address the following categories of non,storm water
discharges 0,r flows (i.e., illicit discharges) only if (the City of Dubuque) identifies 'them
as Significant contributors Of pollutants to the City's MS4: water line flushing, !andscap~
irrgatioh diverted stream flows rs ng, grbund watei-s uncontaminated ground' water
infiltration (as defined at40 CFR 35.2005(20)), uncontaminated pumped ground water.
discharges from potable water sources, foundation drains, air conditioning
condensat on, irrigat on water, spr ngs water from crawl space pumps~ footing drains
lawn watering, individual residential car' washing, flows from riparian habitats and
wetlandS, de-chlorinated swimming pool discharges, and street wash water (discharges
or floWS from fire.fighting activities are excluded from the effective prohibition against
nomstbr~ water and need only be addressed Whe~ethey are identifie~ ~s Significant
sources of pollutants to waters of the United States).
(iv) Gu dance EPA recommends that the plan to.detect and address' licit d scharges
include~the following four components: (1) procedures for locating priority areas likely to
have illicit discharges; (,2) procedures for tracing the s0urce of an licit discharge; (3)
)rocedures for removing the source of the discharge; and (4) procedures for program
;valuation and assessment.
Studies have found that discharges from MS4s often include wastes and wastewater
from non-storm water "illicit" discharges. The EPA's Nationwide Urban Runoff Program
(NURP) indicated that a significant number of storm water outfalls continue to discharge
waters during substantially dry periods weeks after a rainfall event. These dry weather
flows were found to have pollutant levels high enough to substantially degrade the water
quality of receiving waters. Below is the list of BMPs the City of Dubuque will utilize to
meet the illicit discharge detection and elimination minimum control measure [see
City of Dubuque NPDES Phase II MS4 Individual Permit Application -page 14 of 35-
ILLICIT DISCHARGE DETECTION and ELIMINATION
MINIMUM CONTROL MEASURE BMPS
SECTION VIII. For BMP implementation/completion schedule and responsible
department(s)].
BMP:
3.'1 MS4 Map Development
BMP Description: The City will produce a storm sewer system map that shows the
intakes, outfalls, and waters of the United States. The MS4 map demonstrates an
awareness of the intakes and their proximity to potential sources of pollutants and
discharge areas where the pollutants would enter waters of the United States.
The City will inspect the identified receiving waters and vedfy the location of outfalls.
Photographs will be taken of outfalis when possible.
MEASURABLE GOALS:
1. The banks of the receiving waters will be walked at least twice.
2. The MS4 map will be updated.
3. The photographs taken of outfalls will be compiled.
BMP:
BMP:
3.2 Stormwater Ordinance
BMP Description: The City will develop and adopt an ordinance that prohibits (to the
extent allowable under State, Tribal, or local [aw) non-storm water discharges into the
MS4. The ordinance will include appropriate enfomement procedures.
MEASURABLE GOALS:
1. The ordinance will be drafted.
2. The adoption of the ordinance will be recorded.
3.3 Hazardous Waste Collection Program
BMP Description: The City will promote the proper disposal of household hazardous
wastes.
Residential property owners will be able to dispose of household hazardous wastes
free of charge at the Regional Collection Center, a state-authorized temporary storage
facility for household hazardous wastes. Waste materials are received, segregated,
packed and stored until picked up by a licensed hazardous materials contractor for
disposal.
MEASURABLE GOALS:
1. All activities such as the distribution of brochures, flyers, mailers, and inserts;
speakers bureau engagements; quarterly "City Focus" newsletter articles published;
web site developments, radio spots, newspaper ads, "CityChannel 8" and public
access television channel airings, and the use of any other commonly used method of
advertising will be tracked.
City of Dubuque NPDES Phase II MS4 Individual Permit Application -page 15 of 35-
ILLICIT DISCHARGE DETECTION and ELIMINATION
MINIMUM CONTROL MEASURE BMPS
BMP: 3.4 Pet Waste Disposal
BMP Description: The City will have an ordinance that establishes requirements on
the proper disposal of pet waste.
MEASURABLE GOALS:
1. The ordinance will be documented.
BMP:
3.5 Illicit Discharge Report Tracking
BMP Description: The City will utilize an Information Management System to
document illicit discharge detection and elimination data.
This information will be included in annual reports and will detail the following:
1. The number of citizen reports of illicit discharges;
2. The number of illicit discharges discovered;
3. The number of illicit discharges that were resolved.
MEASURABLE GOALS:
1. The City will track citizen reports of illicit discharges and citizen requests for
information pertaining to the City of Dubuque's MS4 NPDES program.
BMP:
BMP:
3.6 Citizen Reporting
BMP Description: The City will advertise a telephone hotline and a web page link to
facilitate citizen reporting of ordinance violations associated with the MS4.
The impacts of erosion, sedimentation, and illegal dumping will be advertised with a
phone number and web page to report possible infractions.
MEASURABLE GOALS:
1. Advertising will be documented.
2. The number of citizen reports will be tracked.
3.7 Illicit Sanitary Sewer Connection Reduction Program
BMP Description: The City will inspect homes to ensure that basement sump pumps
and downspouts are not illegally connected to the sanitary sewer system.
Illegal connections contribute to sanitary sewer overflows into area creeks during
rainstorms.
MEASURABLE GOALS:
1. The number of homes inspected will be tracked.
2. The illegal connections forced to disconnect will be documented.
City of Dubuque NPDES Phase II MS4 Individual Permit Application -page 16 of 35-
ILLICIT DISCHARGE DETECTION and ELIMINATION
MINIMUM CONTROL MEASURE BMPS
BMP: 3.8 Septic System Elimination Program
Description: The City will administer a program that promotes the connection of
private sewage systems within city limits to the City's sanitary sewer system.
A policy will require that properties (within city limits) connect to the city sanitary sewer
system if there is a sanitary sewer within 200 feet of the property.
Sanitary sewer construction projects that extend sewer to un-served properties will be
considered for inclusion in the annual 5-year capital improvement project budget.
MEASURABLE GOALS:
1. The number of residences removed from the septic system will be tracked.
2. Sanitary sewer extension projects will be documented and be given a priority.
BMP:
3.9 Illicit Discharge Detection Training for City Staff
BMP Description: The City will develop an education program for employees that
will help them to identify illicit discharges.
MEASURABLE GOALS:
1. The number of employees that are sent educational materials and receive training will
be documented.
BMP:
3.10 Determine Potential Illicit Discharge Sources to Target
BMP Description: The City will identify potential sources of pollution associated with
storm water runoff.
Using the MS4 and land use maps, industrial parks; large concentrations of industrial
businesses (manufacturing, warehousing, trucking, etc.); areas where there are large
concentrations of septic systems; and areas with older sanitary sewer lines will be
identified.
MEASURABLE GOALS:
1. Target areas will be recorded and identified on a map.
BMP:
3.11 Sewer and Ouffall Monitoring
BMP Description: The City will facilitate volunteer organization's (such as the Catfish
Creek Coalition) inspection of sanitary sewers and storm sewer outfalls in the vicinity of
area creeks and identified target areas within the City.
Assistance may take the following forms:
City of Dubuque NPDES Phase II MS4 Individual Permit Application -page 17 of 35-
ILLICIT DISCHARGE DETECTION and ELIMINATION
MINIMUM CONTROL MEASURE BMPS
1. Advertising the monitoring efforts of the Catfish Creek Coalition to increase the
number of participants (and monitoring sites); and
2. Provide volunteer monitors with the tools necessary to perform and record the
inspections.
NOTE: This BMP has a public participation component. Please refer to the "Public
Participation/Involvement" BMPs. While the BMP descriptions are the same, the
measurable goals vary.
MEASURABLE GOALS:
1. Sewer and outfall Inspection activities will be documented.
City of Dubuque NPDES Phase It MS4 Individual Permit Application -page 18 of 35-
BLANK PAGE
CONSTRUCTION SITE RUNOFF CONTROL
MINIMUM CONTROL MEASURE BMPS
SeC. ,122:34 (b) Minimum
storm water runoff contrOl.
(!) You must deVelop, implement; and enforce a Program to reduce pOIl[~tants in. any
storm water runoff to your small MS4 from construction activities, that result ,in a land
disturbance of greater than or equal to one acre. RedUction of storm Water discharges
from construction activity disturbing less than one acre muSt:be included.in your
program if that construction activity:is part cfa arger common plan of development or
sale :that would disturb one acre or more.
(ii) Your program must include the development and implementation of, at a minimum:
(A) An ordinance or other regulatory mechanism ~to require emsior~ and Sediment
cohtr01S~ as well as sancfions t0 ensur~ compliance, tO the extent allowablednde~ State.
Tribal, or local law; (B) ReqUirements for construction site operators to implement
appropriate erosion and Sediment control best management practices; (C)
Requirements for construction site operators to control waste ,such as discarded
building materials, concrete truck washout chemicals; litter; ~nd sanitary waste at ,the
construction site that may Cause adVerSe impacts to water quality; (D) [br°Cedures' for
site plan review which incorporate consideration of potential water quali~ty impacts;' (E)
~roc.~dures,for receipt and ~ns derat on of nformatibn submitted by thel~Ula ~:, and'(F)
Procedures for site inspection and enforcement of control measures.
(iii) Guidance: Examples of ,sanctions to ensure compliance include n~n-monetary
penalties; fines, bonding requirements and/or permit denials for non~ompriance. EPA
~'ecommends that procedures for site plan review include the review of individual pre:
¢onstructio~ :site plans tO ensure consistency with local sediment and erosion control
requirements. Procedures for site inSPections and enforcement of COntrol meaSUr~'
could include steps tO dentify priority sites for inspection and enforcement based on the
nature of the construction and the site characteristics.
According to the EPA, over a short period of time, construction site activity can
contribute more pollutants, including sediment, to a receiving water body than had been
deposited over several decades. The EPA asserts that generally, properly implemented
and enforced construction site ordinances effectively reduce these pollutants. In many
areas, however, the effectiveness of ordinances in reducing pollutants is limited due to
inadequate enforcement or incomplete compliance with such local ordinances by
construction site operators. Below is the list of BMPs the City of Dubuque will utilize to
meet the Construction site storm water runoff control minimum control measure [see
SECTION VIII. For BMP implementation/completion schedule and responsible
department(s)].
City of Dubuque NPDES Phase II MS4 Individual Permit Application -page 19 of 35-
CONSTRUCTION SITE RUNOFF CONTROL
MINIMUM CONTROL MEASURE BMPS
BMP:
4.1 Construction Site Tracking
BMP Description: As part of the Site Plan Review process, The City will require,
developers (of proposed construction projects requiring an NPDES permit per the Clean
Water Act) submit to the City of Dubuque Engineering Division a copy of the
construction site NPDES permit issued by the IDNR for the site and the associated
pollution prevention plan.
The City will use an information management system to track information submitted by
the developers and the public.
MEASURABLE GOAL:
1. The number of construction sites that obtain an NPDES construction site permit from
the IDNR will be tracked.
BMP:
4.2 Erosion & Sediment Control Ordinance
BMP Description: Under the extent allowable by law an ordinance will be put in place
that will establish guidelines and requirements for the control of erosion, sedimentation
and pollutants associated with construction activities.
MEASURABLE GOALS:
1. The existence of an ordinance that requires measures to limit erosion and
sedimentation and establishes restrictions on construction site pollutants.
BMP:
4.3 Training Material Development
BMP Description: The City will either develop or acquire a training video, presentation,
or other training aid to utilize for training sessions with contractors, developers, builders,
and City staff.
MEASURABLE GOALS:
1. The development or acquisition of training aids will be documented.
BMP:
4.4 City Staff Erosion & Sediment Control Training
BMP Description: City staff will be trained on identifying erosion and sedimentation
violations. City staff will then serve as watchdogs, capable of identifying possible
ordinance violations and alerting the proper authorities.
MEASURABLE GOALS:
1. The number of City staff trained and the training methods will be tracked and
recorded.
City of Dubuque NPDES Phase II MS4 Individual Permit Application -page 20 of 35-
CONSTRUCTION SITE RUNOFF CONTROL
MiNIMUM CONTROL MEASURE BMPS
BMP:
4.5 Construction Site Inspection
BMP Description: As part of the Site Plan and Subdivision Review process, that the
responsible party identified in an NPDES construction site permit issued by the tDNR,
submit a copy of all inspections required by the NPDES construction site permit to the
City Engineering Division. Random inspections of construction sites will be performed
by City staff to determine the overall compliance with the pollution prevention plan
associated with the NPDES construction site permit.
The failure to follow the inspection requirements established in the NPDES construction
site permit shall render the development non-compliant with the Site Plan or Sub-
division plan.
MEASURABLE GOALS:
1. Inspection reports obtained by the City of Dubuque Engineering Division will be
retained.
2. The number and reports for all random City staff inspections will be tracked and
retained.
BMP:
4.6 Contractor Workshop
BMP Description: The City will sponsor an annual workshop for homebuilders,
developers, and contractors with some of the following aspects:
1. An open forum to discuss the successes and failures (lessons learned) of the past
year;
2. Educational session that outlines the City's construction site pollution prevention
ordinance;
3, Training session on the proper use of a structural BMP for erosion and sediment
control; and
4. Emerging erosion and sediment control technologies.
MEASURABLE GOALS:
1. The number of people who attend the workshop will be tracked.
City of Dubuque NPDES Phase II MS4 Individual Permit Application -page 21 of 35-
BLANK PAGE
POST-CONSTRUCTION RUNOFF CONTROL
MINIMUM CONTROL MEASURE BMPS
~i) (The'City of Dubuque)'must develop implement and enforce a program to address
;m~m :water ~unOff f{om new deve/0Pmer~t and redevelopment' :projects~that d Sturb
greaterthan or equal to one acre, nc uding p[ojects ess than one acre that are part of a
larger common plan of development'or sale. t at discharge rote'your stoat MS4 Your
program mdst ensure that controls are in place that would prevent or minimize water
quality mpacts~
(ii) (Th~ City of Dubuque) must: (A) Develop and implement strategies whic~ nc ude a
combin&tion of stru~ural and/or non-structural belt management practices (13MRs)
appropriate for Dubuque; (B),Use an ordnance Or other regulato~ meChar~ism to
address post-construction runoff from new development and redevelopment, projects to
the extent allowable under State. Tribal or local law; and (C) Ensure adequate long-term
operation and maintenance of BMPs.
(iii) Guid~ance: 'EPA recommends that the BMPs chosen: be apprgpriate for the local
community; minimize 'Water quality impacts 'and attempt to mair~tain pre-de~/elopment
runoff conditions. In addition, the EPA recommends a process th'at identifies Dubuque's
program goal mn mize water qua ty mpacts; imp ementation"strategies (e g,' adopta
combination of structural and/or non-structural BMPs); operation and maintenance
policies'and procedures; and enforcement procedures
Experience has shown that planning and designing for the minimization of pollutants in
storm water discharges is the most cost-effective approach to storm water runoff quality
management. Reducing pollutant levels in receiving streams is far more expensive than
controlling the pollutant at the source. The minimization of impervious areas,
maintenance or restoration of natural infiltration, wetland protection, use of vegetated
drainage ways, and use of riparian buffers have been shown to reduce pollutant
loadings in storm water runoff from developed areas. EPA recommends that Cities
ensure the appropriate implementation of the structural BMPs by considering some or
all of the following: (1) Pre-construction review of BMP designs; (2) inspections during
construction to verify BMPs are built as designed; (3) post-construction inspection and
maintenance of BMPs; and (4) sanctions to ensure compliance with design,
construction or operation and maintenance (O&M) requirements of the program. Below
is the list of BMPs the City of Dubuque will utilize to meet the post-construction storm
water management in new development and re-development minimum control measure
[see SECTION VIII. For BMP implementation/completion schedule and responsible
department(s)].
City of Dubuque NPDES Phase II MS4 Individual Permit Application -page 22 of 35-
POST-CONSTRUCTION RUNOFF CONTROL
MINIMUM CONTROL MEASURE BMPS
BMP: 5.1 Site Plan & Sub-Division Review
BMP Description: The City will develop Site PIan and Sub-division review procedures
that address post construction storm water runoff control measures such as:
1. Green space requirements;
2. Detention basin requirements; and
3. Post construction erosion and sediment controls.
MEASURABLE GOALS:
1. The Site Plan review procedures will be documented.
BMP:
5.2 Post Construction Runoff Control Ordinance
BMP Description: The City will develop and adopt a post construction runoff control
ordinance.
The ordinance will outline water quantity and quality detention basin requirements. The
ordinance will promote the use of grass swales, buffer strips, preservation of existing
vegetation, establishment of vegetation, and proper maintenance of private storm water
facilities.
MEASURABLE GOALS:
1. Adoption of the ordinance will be documented.
BMP:
5.3 Developer & Home Builder Workshop
BMP Description: The City will sponsor a workshop for developers and homebui[ders.
The focus of the workshop wil~ be forms of Iow impact development and emerging
development techniques that incorporate structural post construction best management
practices.
MEASURABLE GOALS:
1. The workshop agenda and specific speakers will be documented.
2. The number of people who attend the workshop will be recorded.
City of Dubuque NPDES Phase II MS4 Individual Permit Application -page 23 of 35-
POLLUTION PREVENTION/GOOD HOUSEKEEPING
MINIMUM CONTROL MEASURE BMPS
Sec. 12Z34 (b) Minimum control
=revention[ooodhousekeepin.q for muniCipal operations.
(i) (The:City of Dubuque) must develop and im~plement an operation and maintenance
P~'ogram th~ includes a tra ning component an~t haS:the ultimate goal of prevent!ng Or
~:educing'PollUtant runoff from municipal operations. USing trainin~ mate~Sals that are
available from~ EpA, your state, Tribe, or other organizationS, Du~u~iue's program mbst
include, empleYee I~ining tb prevent and reduce storm'waier pOllutio? frOh~ e~ctivifies
such as, park and open space maintenance fleet and build ng maintenance; new
construction ~nd add disturl~ances, end storm water system maintenance
(ii) Guidance: EPA recommends that, ara m~nimum, (the City of Dubuque) consider the
following in developing your program: maintenance activ ties maintenanlc~'SCh~db/es,
and long-term inspection procedures for structural and nonstruCtural storm Wa;~er
controls to reduce fl0atables and other pollUtants diSCharged from your separate storm
sewers; controls fot reducing or eliminating the discharge Of pollutants from. streets
roads, highways, municipal parking lots, maintenance
that
and examine
~xisting prOjects for incorporating additional Water quality protection deVi~es or
~ractices. operation and m~ifltenance shOuld be ah integral component bf ali storm
~ater management programs: This measure is intended to jmpr0ve the ~icienSy of
these prOgramS and require new programs where necessary, prOperlY developed and
implemented operation and maintenance prOgrams reduc~ the risk of wat% qbality
problems, - --
This measure's emphasis on proper operations and maintenance of MS4s and
employee training, as opposed to requiring cities to undertake major new activities, is
meant to ensure that municipal activities are performed in the most efficient way to
minimize contamination of storm water discharges. EPA emphasizes that programs
should identify and incorporate existing storm water practices and training, as well as
non-storm water practices or programs that have storm water pollution prevention
benefits, as a means to avoid duplication of efforts and reduce overall costs. EPA
recommends that MS4s incorporate these new obligations into their existing programs
to the greatest extent. Below is the list of BMPs the City of Dubuque will utilize to meet
the Pollution prevention/good housekeeping for municipal operations minimum control
measure [see SECTION VIII. For BMP implementation/completion schedule and
responsible department(s)].
City of Dubuque NPDES Phase II MS4 Individual Permit Application -page 24 of 35-
POLLUTION PREVENTION/GOOD HOUSEKEEPING
MINIMUM CONTROL MEASURE BIvEPS
BMP: 6.1 City Employee Education
BMP Description: The City will develop and implement a City employee education
program.
The program will consist of:
1. The IDNR certification of all personnel responsible for applying pesticides,
herbicides, and fertilizers;
2. Distribution of materials that illustrate the pollution associated with storm water runoff
and ways to prevent the impairment of area creeks, rivers, and streams.
MEASURABLE GOALS:
1. Pesticide, herbicide, and fertilizer certifications will be documented.
2. The media used to provide information lo City employees will be documented.
BMP:
BMP:
BMP:
6.2 Sanitary Sewer Inspection
BMP Description: In conjunction with the reconstruction of city streets, sanitary sewers
will be inspected for defects and poor flow conditions.
MEASURABLE GOALS:
1. The linear feet of inspected sanitary sewer will be tracked.
2. The linear feet of sanitary sewer replaced in conjunction with the reconstruction of
City streets will be documented.
6.3 Catch Basin Inspection & Cleaning
BMP Description: The City wi[[ inspect and clean catch basins (storm sewer intakes).
MEASURABLE GOALS:
1. The number of catch basins inspected will be tracked.
2. The number of catch basins cleaned will be tracked.
6.4 Street Cleaning
BMP Description: The City will remove debris from streets with curb and gutters using
street sweepers.
MEASURABLE GOALS:
1. The number of lane-miles swept will be tracked.
City of Dubuque NPDES Phase II MS4 Individual Permit Application -page 25 of 35-
POLLUTION PREVENTION/GOOD HOUSEKEEPING
MINIMUM CONTROL MEASURE BMPS
BMP: 6.5 De-Icer Proper Application Training
BMP Description: (1) The City will calibrate all anti-icing and de-icing equipment. (2)
The City will train employees on the proper chemical application rate for snow and ice
control.
MEASURABLE GOALS:
1. The number of employees trained each year will be tracked.
2. Calibrations will be recorded.
BMP:
6.6 Leaf & Grass Clipping Disposal Program
BMP Description: The City will provide Dubuque residents with several options for
leaf and grass clipping disposal.
1. The City will facilitate the transfer of leaves and grass clippings between citizens
looking to discard them and citizens hoping to utilize them for composting, gardening,
and other yard applications.
2. The City will provide a "Leaf Collection" for City of Dubuque solid waste customers.
3. The City will advertise the options listed above as well as other non-City disposal
alternatives.
MEASURABLE GOALS:
1. The quantity of yard waste dropped off at the Dubuque Metro Landfill, Dubuque
Arboretum, and Splendid Valley Nursery will be tracked.
City of Dubuque NPDES Phase II MS4 Individual Permit Application -page 26 of 35-
BLANK PAGE
[] 1. Public Education and Outreach [] 3. illicit Discharge Detection/Elimination [] 5. Post-construction Stormwater Management (optional)
[] 2. Public Involvement/Participation [] 4. Construction Site Stormwater Runoff Control [] 6. Pollution Prevention/Good Housekeeping
1. The number of target groups will be tracked. The public education campaign will be Engineering Division
Public Education Campaign developed during the first permit year,
City Manager's Office
'~. 1 Development 2. Each method chosen to send the information out Graphic Arts
to the public will be tracked.
1.2 Educational Video The acquisition of educational videos will be The City will acquire a video in the first permit Engineering Division
documented, year.
'1. The number of door-hangers placed on doors will The City will promote volunteer participation
be tracked, in the first permit year.
2, The number of brochures distributed in Brochures will be developed in the first permit Engineering Division
1.3 Storm Drain Labeling neighborhoods will be tracked, year. City Manager's Office
Door hangers will be developed in the first Graphic Arts
3. The number of storm drains labeled will be permit year.
tracked.
Storm drain labeling will begin by the end of
the second permit year,
All activities such as the distribution of brochures,
flyers, mailers, and inserts; speakers bureau
engagements; quarterly "City Focus" newsletter The public education campaign developed in
1.4 Execution of Public Education articles published; web site developments, radio BMP 1.1 will be initiated by the end of the Engineering Division
Campaign spots, newspaper ads, "CityChannel 8" and public
access television channel aidngs, and the use of second permit year.
any other commonly used method of advertising will
be tracked.
1. The number of educators contacted will be The City will send correspondence to
tracked, educators in the first permit year,
Depending on the cooperation of local Engineering Division
2. Storm water pollution curriculum utilized by educators, curriculum pertaining to storm
1.5 Storm Water Runoff Pollution educators will be documente& water runoff pollution will be utilized by the
Curriculum end of the fourth permit year.
3. Explore and develop a curriculum to teach
students about storm water runoff pollution.
City of Dubuque -NPDES Phase II MS4 Individual Permit Application -page 27 of 35-
[] 1. Public Education and Outreach [] 3. Illicit Discharge Detection/Elimination [] 5. Post-construction Stormwater Management (optional)
[] 2. Public Involvement/Participation [] 4. Construction Site Stormwater Runoff Control [] 6. Pollution Prevention/Good Housekeeping
1. The number of students who participate will be The City will send correspondence to
tracked, educators in the first permit year.
1.6 Education Partnership Depending on the cooperation of local
Program 2. The number of student presentations and the Engineering Division
approximate size of the audience will be tracked, educators, the City will form partnership(s) by
the end of the third permit year.
3. The number of educators contacted will be
tracked.
city of Dubuque - NPDES Phase II MS4 Individual Permit Application -page 28 of 35-
[] 1. Public Education and Outreach [] 3. Illicit Discharge Detection/Elimination [] 5. Post-construction Stormwater Management (optional)
[] 2, Public Involvement/Participation [] 4. Construction Site Stormwater Runoff Control [] 6. Pollution Prevention/Good Housekeeping
1, A copy of the public notice information will be
retained.
2.1 Public Notice Requirements Public notice requirements will be Engineering Division
implemented in the first permit year. City Clerk's Office
2, The number of people who participate in the
development of Dubuque's Storm Water
Management Program will be tracked.
1, The number of sampling sites will be tracked. Advedising for IOWAter will be initiated in the
first year of the permit year.
2.2 Volunteer Creek Monitoring Engineering Division
2, The frequency of sampling at each site will be Volunteer monitoring will be initiated in the City Manager's Office
tracked, first permit year,
· I, The number and size of volunteer organizations The City will promote volunteer participation
will be recorded, in the first permit year.
2.3 Storm Drain Labeling 2. The number of storm drains labeled by Storm drain labeling will begin by the end of Engineering Division
volunteers will be tracked, the second permit year.
3, A location map of labeled storm drains will be
developed and maintained.
1. The number of volunteer organizations that The City will begin identifying organizations
receive materials will be tracked, willing to distribute educational materials in
the first permit year.
2.4 Distribution of Educational
Material Engineering Division
2, The type and number of all materials distributed Educational materials will be distributed to
will be tracked, organizations for distribution by the end of the
second permit year.
City of Dubuque -NPDES Phase II MS4 Individual Permit Application -page 29 of 35-
[] 1. Public Education and Outreach [] 3. Illicit Discharge Detection/Elimination [] 5, Post-construction Stormwater Management (optional)
[] 2. Public Involvement/Participation [] 4. Construction Site Stormwater RunoffControl [] 6, Pollution Prevention/Good Housekeeping
1. The number of contests will be tracked. The City will solicit co-sponsors in the first
permit year.
2, The number of volunteer organizations that
participate either through prize sponsorship or other Contest logistics will be determined by the Engineering Division
2.5 Co-Sponsored Competition contest related activity such as providing a display
area for entries, serving as a judge, assist with the end of the second permit year. City Manager's Office
promotion of the competition, etc, will be tracked.
3. The number of contestants will be tracked. A competition (or competitions) will be
initiated by the end of the third permit year,
'1, The number of schools and educators contacted The City will send correspondence to
will be tracked, educators in the first permit year.
2.6 Education Partnership Engineering Division
Program Depending on the cooperation of local
2. The number of students who participate will be educators, the City will form partnership(s) by
tracked, the end of the third permit year.
1. The number of volunteer monitoring sites will be
tracked.
2.7 Sewer and Outfall Monitoring Monitoring of outfalls will be initiated in the Engineering Division
first permit year. Water Pollution Contol
2. The number and results of sanitary sewer and
storm sewer outfall inspections will be tracked.
City of Dubuque -NPDES Phase Il MS4 Individual Permit Application -page 30 of 35-
[] 1. Public Education and Outreach [] 3. Illicit Discharge Detection/Elimination [] 5. Post-construction Stormwater Management (optional)
[] 2. Public Involvement/Participation [] 4. Construction Site Stormwater Runoff Control [] 6. Pollution Prevention/Good Housekeeping
1. The banks of the receiving waters will be walked
at least twice.
A map illustrating the MS4 outfalls and
3.1 MS4 Map Development 2, The MS4 map will be updated, waters of the United States will be completed Engineering Division
in the first permit year.
3. The photographs taken of outfalls will be
compiled.
1. The ordinance will be drafted. An ordinance will be drafted during the first Engineering Division
permit year. Legal
3.2 Stormwater Ordinance City Council
2. The adoption of the ordinance will be recorded. The ordinance will be adopted before the end Environmental Stewardship
of the first permit year. Advisory Commission
1. All activities such as the distribution of brochures,
flyers, mailers, and inseds; speakers bureau .... *
engagements; quaderly "City Focus" newsletter
3.3 Hazardous Waste Collection adicles published; web site developments, radio Adve~ising and educational materials will be Engineering Division
Program spots, newspaper ads, "CityChannel 8" and public produced and distributed in the first permit Dubuque Metro Area Solid
ac~ss television channel airings, and the use of year. Waste Agency (DMASWA)
any other commonly used method of advedising will
be tracked.
3.4 Pet Waste Disposal 1. The ordinance will be documented. The ordinance will be in place the first permit Legal
year. Health
1. The City will track citizen repods of illicit The City will begin tracking citizen repods of
3.5 Trackinglllicit Discharge Repo~ dischargeSpe~aining toandtheCitiZencity ofrequestSDubuque'sf°r Ms4inf°rmati°nNPDES possible illicit discharges and citizen requests Engineering Division
program, for information in the first permit year.
1, Adve~ising will be documented. The telephone "Hotline" and the web page
3.6 Citizen RepoSing will be established by the end of the second Engineering Division
2. The number of citizen repo~s will be tracked, permit year.
City of Dubuque - NPDES Phase Il MS4 Individual Permit Application -page 31 of 35-
[] 1. Public Education and Outreach [] 3. Illicit Discharge Detection/Elimination [] 5. Post-construction Stormwater Management (optional)
[] 2. Public Involvement/Participation [] 4. Construction Site Stormwater RunoffContrel [] 6. Pollution Prevention/Good Housekeeping
1. The number of homes inspected will be tracked.
Illicit Sanitary Sewer
3.7 Connection Reduction Home inspections will be conducted by the
end of the first permit year. Engineering
Program 2. The illegal connections fomed to disconnect will
be documented.
The policy requiring properties to connect to
1. The number of residences removed from the the city sanitary sewer system if thera is a
septic system will be tracked, sanitary sewer within 200 feet of the property
will be in place the first permit year, Engineering Division
3,8 Septic System Elimination
Program At least one sanitary sewer construction Health
project, that extends sewer to properties in City Council
2. Sanitary sewer extension projects will be the city without sanitary sewer, will be
documented and be given a priority, budgeted for construction by the second
permit year.
Illicit Discharge Detection t. The number of employees that are sent Educational materials will be distributed in the Engineering Division
3.9 Training for City Staff educational materials and receive training will be City Manager's Office
documented, first permit year.
A map showing the MS4, land use and the
sanitary sewer will be produced by the end of
3.10 Determine Potential Illicit 1, Target areas will be recorded and identified on a the second permit year.
Discharge Sources to Target map. Engineering Division
Areas will be targeted for inspection by the
end of the third permit year.
The City will solicit volunteers in the first
3.11 Sewer and Outfall Monitoring 1. Sewer and outfall Inspection activities will be permit year.
documented. Engineering Division
Volunteer monitoring will be initiated by the
end of the second permit year.
City of Dubuque -NPDES Phase II MS4 Individual Permit Application -page 32 of 35-
[] 1. Public Education and Outreach [] 3. Illicit Discharge Detection/Elimination [] 5. Post-construction Stormwater Management (optional)
[] 2. Public Involvement/Participation [] 4. Construction Site Stormwater RunoffControl [] 6. Pollution Prevention/Good Housekeeping
'1. The number of construction sites that obtain an
The tracking of construction sites will be
4.1 Construction Site Tracking NPDES construction site permit from the IDNR will initiated in the first permit year. Engineering Division
be tracked.
Engineering Division
1. The existence of an ordinance that requires Legal
4.2 Erosion & Sediment Control measures to limit erosion and sedimentation and An ordinance will be drafted during the first
Ordinance establishes restrictions on construction site permit year. City Council
pollutants, Environmental Stewardship
Advisory Commission
4.3 TrainingDevelopmentMaterial will'l' Thebe documented,devel°pment or acquisition of training aids Trainingof the firstmaterialSpermit year.Will be acquired by the end Engineering Division
4.4 City Staff Erosion & Sediment 1, The number of city staff trained and the trainir~g ~Training Of City staff will be initiated by the Engineering Division
Control Training methods will be tracked and recorded, end of the first permit year.
1. Inspection reports obtained by the City of
Dubuque Engineering Division will be retained.
4.5 Construction Site Inspection Construction site inspections will be initiated Engineering Division
--' in the first permit year.
2. The number and reports for all random City staff
inspections will be tracked and retained.
1, The number of people who attend the workshop A workshop will be held by the end of the Engineering Division
4.6 Contractor Workshop will be tracked, second permit year,
City of Dubuque -NPDES Phase 1I MS4 Individual Permit Application -page 33 of 35-
[] 1. Public Education and Outreach [] 3. Illicit Discharge Detection/Elimination [] 5. Post-construction Stormwater Management (optional)
[] 2. Public Involvement/Participation [] 4. Construction Site Stormwater RunoffControl [] 6. Pollution Prevention/Good Housekeeping
The site plan review procedures will be Planning
5, 1 Site Plan & Sub-Division 1. The Site Plan review procedures will be modified to include post-construction runoff
Review documented, control measures by the end of the first Engineering Division
permit year.
1. Adoption of the ordinance will be documented. An ordinance will be drafted during the first Engineering Division
Post Construction Runoff permit year. Legal
5.2 Control Ordinance City Council
Environmental Stewardship
Advisory Commission
1. The workshop agenda and specific
speakers will be documented.
Developer & Home Builder A workshop will be held by the end of the
5.3 Workshop 2, The number of people who attend the Engineering Division
workshop will be recorded second permit year.
City of Dubuque - NPDES Phase II MS4 Individual Permit Application -page 34 of 35-
[] 1. Public Education and Outreach [] 3. Illicit Discharge Detection/Elimination [] 5. Post-construction Stormwater Management (optional)
[] 2. Public Involvement/Participafion [] 4. Construction Site Stormwater Runoff Control [] 6. Pollution Prevenfion/Good Housekeeping
1. Pesticide, herbicide, and fertilizer certifications Employee certification for pesticide,
will be documented, herbicide, and fer[ilizer application will be in Engineering Division
6.1 City Employee Education place the first permit year.
City Manager's Office
2. The media used to provide information to City The distribution of educational materials will Personnel
J begin in the first permit year,
be
documented.
'1. The linear feet of inspected sanitary sewer will be Sanitary sewer inspections will be initiated in
tracked, the first permit year,
6.2 Sanitary Sewer inspection Engineering Division
2. The linear feet of sanitary sewer replaced in ! Sanitary sewer replacement in conjunction Operations & Maintenance
conjunction with the reconstruction of City streets with street reconstruction projects will begin
will be documented, in the first permit year.
'1. The number of catch basins inspected will be
6.3 Catch Basin Inspection & tracked. Catch basin inspections and debris removal
Cleaning 2. The number of catch basins cleaned will be will begin in the first permit year. Operations & Maintenance
tracked
6,4 Street Cleaning 1. The number of lane-miles swept will be tracked. Street sweeping will be initiated in the first
permit year Operations & Maintenance
'1. The number of employees trained each year will Employee training will by done by the end of
6.5 De-Icer Proper Application & be tracked, the first permit year.
Training Operations & Maintenance
2. Calibrations will be recorded. The calibration of de-icing equipment will take
)lace in the first permit year.
The leaf exchange program will be in place
the first permit year.
6.6 Leaf & Grass Clipping l. The quantity of yard waste dropped off at the
Disposal Program Dubuque Metro Landfill, Dubuque Arboretum, and The Leaf Rake-Out Collection will be initiated Engineering Division
Splendid Valley Nursery will be tracked, in the first permit year. Operations & Maintenance
Proper yard waste disposal will be advedised
by the end of the first permit year.
City of Dubuque NPDES Phase It MS4 Individual Permit Application -page 35 of 35-