NPDES - Pollution, City Respons
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MEMORANDUM
September 1,2004
TO:
The Honorable Mayor and City Council Members
FROM:
Michael C. Van Milligen, City Manager
SUBJECT: City's Response to the State's "Draft" NPDES (Stormwater Discharge)
Permit
Acting Public Works Director/City Engineer Gus Psihoyos is recommending a proposed
process to respond to the State's "draft" National Pollution Discharge Elimination
System (NPDES) permit.
I concur with the recommendation and respectfully request Mayor and City Council
approval.
(fkJA ~I1L
Michåel C. Van Milligen
MCVM/jh
Attachment
cc: Barry Lindahl, Corporation Counsel
Cindy Steinhauser, Assistant City Manager
Gus Psihoyos, Acting Public Works Director/City Engineer
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MEMORANDUM
August 31,2004
FROM:
Michael C. Van Milligen, City Manager
Gus Psihoyos, Acting Public Works Director yjQ
TO:
SUBJECT: City's Response to the State's "Draft" NPDES (Stormwater Discharge)
Permit
INTRODUCTION
This memo outlines the process Engineering is proposing to employ to facilitate the
City's response to the differences between the "Draft" National Pollution Discharge
Elimination System (NPDES) stormwater permit supplied by the Iowa Department of
Natural Resources (IDNR) and the permit application authorized by the City Council.
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 an 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.). In 1987 the CWA was
amended to target non-point source pollution such as stormwater runoff.
Phase I, initiated in November of 1990, required communities with populations in excess
of 100,000 to create a stormwater program (apply for an NPDES Phase I permit) to
reduce the discharge of pollutants associated with the storm sewer system. On
December 8, 1999, Phase II was published. It specifically mandated that the City of
Dubuque obtain a permit for stormwater runoff. As outlined in the Federal Register, the
permit must include six minimum control measures. They are:
1 )
2)
3)
4)
5)
6)
Public education and outreach;
Public involvement and participation;
Illicit discharge detection and elimination;
Construction site stormwater runoff control;
Post construction stormwater runoff control; and
Municipal operations and good housekeeping.
Dubuque's permit application was prepared with oversight from the Environmental
Stewardship Advisory Commission (ESAC) and included input from five task forces
totaling fifty-five people consisting of Dubuque residents, ESAC members, and City staff
personnel.
In March of 2003, the City Council approved the NPDES permit application (see
attachment) and authorized City staff to forward it to the permitting authority for Iowa,
the IDNR.
On July 6, 2004, Engineering received a "Draft NPDES permit" and "Public Notice" from
the IDNR (see attachment). On July 23rd, the "Public Notice" was published in the
Telegraph Herald as required by Iowa Administrative Code.
DISCUSSION
If no objections are received by the IDNR by October 7,2004 (90 days after the notice
date established by the IDNR), the draft permit will become Dubuque's NPDES
stormwater discharge permit and the first permit year will begin on November 1S\ 2004
and run through September 30th, 2005. The permit will be valid for five years, expiring
on September 30th, 2009.
Over the past few weeks, Engineering has reviewed the "draft" permit and compared it
to the plan authorized by the City Council. ATTACHMENT A is a summary that
compares the requirements and deadlines outlined by the State's to Dubuque's permit
application authorized by the City Council.
Because the ramifications of the permit reach beyond the Engineering Division, it
appears necessary to convene past members of the five individual NPDES Task Forces
to review the differences between the two documents and assess how they will impact
the City. The proposed schedule to review and make a recommendation to the City
Council is as follows:
Task Force Review of Draft Permit:
Individual Task Force Meetings to Discuss Response:
Discussion/Negotiations with IDNR:
Group Task Force Meeting to Make Recommendation:
Recommendation Presented to the City Council:
September 2nd to September 9th
September 9th to September 16th
September 16th to September 23rd
September 23rd
October 4th
Because of the limited response period, Engineering will proceed with the distribution of
materials and the scheduling the proposed meetings. Should the City Council provide
alternative direction, the meetings will be rescheduled or cancelled.
RECOMMENDATION
I recommend that the City Council review the proposed process to respond to the
State's "draft" NPDES permit and provide City staff direction, as they feel appropriate.
ACTION TO BE TAKEN
I respectfully request City Council concurrence with the proposed process to outline the
City's response to the State's "draft" NPDES permit and outline additional direction, as
they deem appropriate.
Attachments
Prepared by Deron Muehring
cc: Cindy Steinhauser, Assistant City Manager
Barry Lindahl, Corporation Council
Bill Blum, City Solicitor
Bob Green, Water Department Manager
Dan Brown, Fire Chief
Don Vogt, Operations and Maintenance Manager
Gil Spence, Leisure Services Manager
Paul Horsfall, Water Pollution Control Manager
Rich Russell, Building Services Manager
Laura Carstens, Planning Services Manager
Mark Munson, Transit Manager
Mary Rose Corrigan, Health Services Manager
John Klostermann, Street and Sewer Maintenance Supervisor
Jon Brown, Assistant Water Pollution Control Manager
John Hail, Park Division Manager
Rick Steines, Assistant Fire Chief
Scott Neyens, Fire Marshall
Deron Muehring, Civil Engineer II
Steve Pregler, City Forester
Jerelyn O'Connor, Neighborhood Development Specialist
Paul Schultz, Solid Waste Management Supervisor
Nancy Otterbeck, Solid Waste Management
Kyle Kritz, Associate Planner
Environmental Stewardship Commission
ATTACHMENT A
Dubuque's NPDES Permit Application vs. the State's "Draft" Permit
SECTION 1. PUBLIC EDUCATION AND OUTREACH
Dubuque's Permit Application
IDNR's Draft Permit
1.1 Develop a public education campaign
that identifies target groups such as
homeowners, homebuilders, area businesses,
etc. Then develop appropriate media for public
consumption, including at least two of the
following methods: brochures, speakers'
bureau, quarterly "City Focus" newsletter, web
site, radio spots, newspaper ads, "City
Channel 8" and public access teievision
channels, flyers, mailers, inserts, and any
other commonly used method to advertise.
1. A general brochure shall be developed and
distributed to all businesses and residents.
DEADLINE: END OF 1ST PERMIT YEAR
2. A telephone "hotline" shall be made available for
reporting of stormwater related problems.
DEADLINE: END OF 1ST PERMIT YEAR
DEADLINE: END OF 1ST PERMIT YEAR
3. A stormwater web page shall be developed that
contains information regarding stormwater impacts and
measures that residents can implement to reduce
pollutants in stormwater.
DEADLINE: END OF 1 ST PERMIT YEAR
GENERAL BROCHURE: The City identified the brochure as an option because Engineering staff, with
oversight from Public Information Officer Susan Gwiasda, can easily produce one due to the examples
already available on the topic. It will cost approximateiy $500 to print the brochures and $85 to insert
and distribute the brochures with the existing City utility bills. The estimated annual cost is $585.
TELEPHONE HOTLINE: The telephone hotline was included in the City's permit. See section 3.6 below.
The estimated start-up cost is between $50 and $200 and the estimated annual cost for the
"hotline" is $48.
STORMWATER WEB PAGE: Use of the City's web page is a logical location to provide information
about the impacts of stormwater runoff and how citizens can mitigate its impacts. While there is little to
no costs associated with adding the information to the City's existing web page, the number of peopie
reached will be limited. City staff personnel along with a representative from the Dubuque Metro Landfill
have been investigating a joint venture to create a single address to attract area residents concerned
with the environment. The estimated start up cost is between $0 and $5,000 and the estimated
annual cost is $0 to $1,200.
1.2 Obtain an educational video on the topic Develop or obtain an educational video presenting the
of pollutants associated with stormwater. The impacts of stormwater on the receiving streams and
video would be aired on "City Channel 8" and measures that residents can implement to reduce water
public access television channels. quality degradation from stormwater.
DEADLINE: END OF 1ST PERMIT YEAR DEADLINE: END OF 1 ST PERMIT YEAR
EDUCATIONAL VIDEO: Engineering has already obtained an educational video (free from the EPA) and
we just received confirmation from the EPA that the City is free to broadcast the video. Two additionai
contacts have been made with producers of alternative videos. In each case the cost to obtain the video
and broadcast rights is less than $50.
Page10f12
ATTACHMENT A
Dubuque's NPDES Permit Application vs. the State's "Draft" Permit
1.3 Develop a storm drain labeling program
that includes: the application of a message
next to street drains (inlets or catch basins)
reminding people to "Dump No Waste - Drains
to River"; distribute door hangers place that
illustrate the connection between storm drains
and the receiving waters in the neighborhoods
where and when the storm drain labeling is
taking; and a brochure that solicits citizen to
participation in the storm drain labeling
program.
Develop a program to label all storm sewer intakes by
the end of the five-year permit term.
DEADLINE: Begin labeling
END OF 2ND PERMIT YEAR
Complete labeling
END OF 5TH PERMIT YEAR
DEADLINE: Grow partic~ation
END OF 1s PERMIT YEAR
Produce brochures
END OF 1 ST PERMIT YEAR
Begin labeling
END OF 2ND PERMIT YEAR
STORM DRAIN LABELING: The IDNR requires that all storm drains be labeled by 8/31/2009.
Dubuque's permit application was to rely on volunteers to do the labeling. While volunteers will still be
sought, to ensure that the work is completed on time, the City will likely be forced to pay hourly wages to
label the storm drains. Assuming that six can be labeled per hour, it will take about 1,067 hours to label
the approximately 6,400 storm drains in Dubuque. At an hourly wage of $6, the estimated labor cost is
$6,400. Material costs are estimated at $6,500. Total estimated annual cost is $2,580.
1.4 Implement public education campaign SEE Section 1.1 above
developed in Section 1.1 above.
1.5 Contact local educators and promote the Make available to schools and encourage the adoption
use of educational materials that deal with the of educational materials regarding stormwater and its
pollution assocIated with stormwater runoff. water quality impacts. Each school year, local school
boards must be contacted to determine the status of the
program and ensure that material is available for use in
the classroom.
DEADLINE: END OF 3"D PERMIT YEAR
DISTRIBUTION OF CURRICULUM: The cost of curriculum materials will remain unknown until a local
educator accepts the invitation to utilize stormwater related materials in the classroom.
1.6 Promote student activities that include the
pollution associated with stormwater runoff.
Activities might include specific curriculum
aimed at water quality issues in Dubuque.
preparation of lesson plans and/or
presentations to other students on the topic.
Not required under the IDNR draft permit.
Page20f12
ATTACHMENT A
Dubuque's NPDES Permit Application vs. the State's "Draft" Permit
SECTION 2. PUBLIC INVOLVEMENT AND PARTICIPATION
Dubuque's Permit Application IDNR's Draft Permit
2.1 The City will comply with State and local Not required other than the publication of the draft
public notice requirements when implementing permit supplied by the IDNR.
a public involvement/participation program.
2.2 The City will promote the participation of The City shall organize volunteers to conduct
area citizens in the IOWAter volunteer water stormwater quality monitoring of stormwater discharges
quality-monitoring program through advertising and receiving streams. Data collected shall be made
methods. available to the public and the IDNR as requested.
DEADLINE: END OF 1ST PERMIT YEAR DEADLINE: END OF 1ST PERMIT YEAR
VOLUNTEER WATER QUALITY MONITORING: The City proposed the promotion of volunteer
monitoring activities, advertising their efforts with the hope of growing the number of volunteers and, thus
growing the number of monitoring sites. The iDNR requires that the City organize volunteers, contact
existing volunteers and organize their efforts. Contact information can be obtained at the IOWAter web
site and Engineering can try and lead but as volunteers they are not required to follow. Although actual
costs are unknown, the estimated financial or staff demands are similar. The estimated annual cost
has not been established.
The City should consider objecting to "organize" versus "promote." The existing volunteers are already
organizing through the IOWAter web site. Trying to re-organize them seems arrogant and frivolous; there
are no obvious benefits. Growing the number of volunteers as outlined in the City's permit application
would increase the availability of water quality data.
2.3 The City will promote citizen participation in Not required under the IDNR draft permit. While the
the storm drain-labeling program outlined in IDNR requires a storm drain labeling program (see 1.3
section 1.3 above. above), citizen participation is not required.
2.4 The City will provide educational materials Not required under the IDNR draft permit.
to be dispersed at local volunteer organization
meetings in the community.
2.5 The City will explore partnerships with local Not required under the IDNR draft permit.
organizations to co-sponsor competitions
among area students such as the production of
a video, poster, .or web page with information
about the pollutants associated with
stormwater runoff.
The City will assist educators from locai Make available to schools and encourage the adoption
colleges, universities, high schools, and grade of educational materials regarding stormwater and its
schools to include activities or curriculum water quality impacts. Each school year, local school
dealing with the pollution associated with boards must be contacted to determine the status of the
stormwater. This item is related to section 1.6 program and ensure that material is available for use in
above. the classroom.
DEADLINE: END OF 3RD PERMIT YEAR
Page 3 of 12
ATTACHMENT A
Dubuque's NPDES Permit Application vs. the State's "Draft" Permit
The IDNR requirement is the same as the one outlined in Section 1.5 above.
2.6 The City will promote the inspection of The City shall organize volunteers to conduct
storm sewer outfalls by volunteer organizations stormwater quality monitoring of stormwater discharges
such as the Catfish Creek Coalition. and receiving streams. Data collected shall be made
Assistance may be advertising the monitoring available to the public and the IDNR as requested.
efforts of the Catfish Creek Coalition to grow
the number of participants (and monitoring DEADLINE: END OF PERMIT PERIOD
sites) and providing volunteers with the tools
necessary to perform and record inspections.
DEADLINE: END OF PERMIT PERIOD
VOLUNTEER WATER QUALITY MONITORING: The IDNR requirement for this section is the same as
the requirement outlined in Section 2.2.
2.7 No similar item included in Dubuque's The City shall establish a Stormwater Advisory
permit application. Committee that will participate in decision-making, hold
public meetings, and work with volunteer groups.
Members of the public shall be allowed to participate.
The City may place reasonable limits on the total
number of group participants.
DEADLINE: END OF PERMIT PERIOD
sTORMWATER ADVISORY COMMITTEE: While the idea of a stormwater committee is attractive, the
value of the committee is unknown. There is no guidance provided by the IDNR identifying under what
circumstances the committee should participate. What exactly they would do, and when?
One potential option is to have the Environmental Stewardship Advisory Committee act as the
stormwater advisory committee.
SECTION 3, ILLICIT DISCHARGE DETECTION & ELIMINATION
Dubuque's Permit Application IDNR's Draft Permit
3.1 The city will produce a storm sewer system All outfalls, intakes, aboveground conveyances, basins,
map that shows the intakes, outfalls, and other structures, and monitoring sites of the storm
waters of the United States. sewer system must be mapped.
DEADLINE: END OF 1ST PERMIT YEAR DEADLINE: Mapping shall commence in 1ST PERMIT
YEAR and be completed by END OF PERMIT PERIOD.
STORM WATER FACILITY MAPPING: The Dubuque Area Geographical Information System (DAGls)
includes mapping of the City's storm sewer system. The only cost for this action is City personnel time to
update and add information to the mapping as needed. Annual cost is $0.00.
3.2 The City will develop and adopt an An illicit discharge ordinance must be adopted or
ordinance that prohibits (to the extent amended prohibiting non-stormwater discharge into the
allowable under State, Tribal, or local law) non- storm sewer system. The ordinance shall include
storm water discharges into the MS4. The language that enables the City to inspect private
ordinance will include appropriate enforcement
Page 4 of 12
ATTACHMENT A
Dubuque's NPDES Permit Application vs. the State's "Draft" Permit
procedures. property if an illicit discharge is suspected.
DEADLINE: END OF 1ST PERMIT YEAR DEADLINE: END OF 1ST PERMIT YEAR
ILLICIT DISCHARGE ORDINANCE: In April of 2004, the City Council approved an amendment to the
City of Dubuque Code of Ordinance prohibiting non-stormwater discharges into the City's stormwater
management system. Annual cost is $0.00.
3.3 The City will promote the proper disposal Not required under the IDNR draft permit.
of household hazardous wastes.
The City of Dubuque and the Dubuque Metro Area Landfill already promote the proper disposal of
hazardous wastes.
3.4 The City will have an ordinance that An ordinance shall be developed and enforced that
establishes requirements on the proper requires pet owners to remove pet feces immediately
disposal of pet waste. after deposition on public property. It shall require the
DEADLINE: END OF 1ST PERMIT YEAR disposal of the feces into the municipal trash collection
system or the sanitary sewer system.
DEADLINE: END OF 1sT PERMIT YEAR
PET WASTE DISPOSAL ORDINANCE: The existing City of Dubuque Code of Ordinance already
includes the proper disposal of pet wastes. No further action is required other than reporting the
existence of the ordinance. Annual cost is $0.00.
3.5 The City will utilize an Information Actions and inspections pertaining to illicit discharges
Management System to document illicit must be tracked and reported annually.
discharge detection and elimination data.
DEADLINE: END OF 1ST PERMIT YEAR DEADLINE: END OF 1ST PERMIT YEAR
ILLICIT DISCHARGE DETECTION & ELIMINATION DOCUMENTATION: Engineering previously
purchased an NPDES database program for to help track all aspects of the detection and elimination of
illicit discharges. The annual cost is $600.00.
3.6 The City will advertise a telephone hotline A telephone "hotline" shall be made available for
and a web page link to facilitate citizen reporting of stormwater related problems.
reporting of ordinance violations associated DEADLINE: END OF 1ST PERMIT YEAR
with the storm sewer system.
DEADLINE: END OF 2ND PERMIT YEAR
TELEPHONE HOTLINE: Outlined in Section 1.1 above.
3.7 The City will inspect homes to ensure that
sump pumps and downspouts are not illegally
connected to the sanitary sewer system,
contributing to sanitary sewer overflows into
area creeks during rainstorms.
Not required under the IDNR draft permit.
Page 5 of 12
ATTACHMENT A
Dubuque's NPDES Permit Application vs. the State's "Draft" Permit
The home inspection program already exists.
3.8 The City will administer a program that Not required under the IDNR draft permit.
promotes the connection of private sewage
systems within city limits to the City's sanitary
sewer system.
The program already exists.
3.9 The City will deveiop an education program Not required under the IDNR draft permit.
for employees that will help them to identify
illicit discharges.
3.10 Using the sewer maps and land use The identification of target areas is not required under
maps, industrial parks; large concentrations of the IDNR draft permit.
industrial businesses; areas where there are
large concentrations of septic systems; and
areas with older sanitary sewer lines will be
identified.
3.11 The City will promote the inspection of The City shall organize volunteers to conduct
storm sewer outfalls by volunteer organizations stormwater quality monitoring of stormwater discharges
such as the Catfish Creek Coalition. and receiving streams. Data collected shall be made
available to the public and the IDNR as requested.
DEADLINE: (Seek volunteers) DEADLINE: END OF 1ST PERMIT YEAR
END OF 1ST PERMIT YEAR
(Volunteer monitoring): 9/1/2006
END OF 2ND PERMIT YEAR
VOLUNTEER WATER QUALITY MONITORING: The IDNR requirement for this section is the same as
the requirement outlined in Section 2.2 above.
SECTION 4, CONSTRUCTION SITE STORMWATER RUNOFF CONTROL
Dubuque's Permit Application IDNR's Draft Permit
4.1 As part of the Site Plan Review process, Site plan and pollution prevention plan review and
the City will require a copy of construction site approval by the City shall be required prior to the
NPDES permits issued by the IDNR and the issuance of any permits for the site by the City.
associated pollution prevention plan. DEADLINE: END OF 2ND PERMIT YEAR
DEADLINE: END OF 1ST PERMIT YEAR
SITE PLAN & POLLUTION PREVENTION PLAN: IDNR's requirement restricting the issuance of any
permit prior to the City's approval of the site plan & pollution prevention plan will have drastic implications
for developers and City staff. Currently, City staff will review a site plan in about seven working days. It
then takes time for the developer's engineer/architect to revise the site plan with the requested revisions.
The process takes about thirty days. Currently, the City will issue a preliminary grading and even a
foundation permit prior to an approved site plan. The IDNR requirement will delay a development by the
approximately thirty days.
Page60f12
ATTACHMENT A
Dubuque's NPDES Permit Application vs. the State's "Draft" Permit
4.2 The City will establish guidelines and An erosion and sediment control ordinance shall be
requirements for the control of erosion, developed.
sedimentation and pollutants associated with
construction activities through the adoption of It shaH include:
an ordinance.
1. The authority to issue a stop order to terminate
DEADLINE: END OF 1ST PERMIT YEAR activities due to the failure to implement or properly
maintain pollution control BMPs such as silt fence.
2. Site plan and pollution prevention plan review and
approval by the City prior to the issuance of any permits
for the site by the City.
DEADLINE: END OF 2ND PERMIT YEAR
EROSION & SEDIMENT CONTROL ORDINANCE: While the City's permit application included the
ordinance; the IDNR specifically requires that the City review and APPROVE the pollution prevention
plan. Due to involvement with the International Erosion Control Society's annual conference and various
workshops, Engineering personnel has the technical background to review pollution prevention plans.
However, it will be a new responsibility demanding considerable manpower hours.
4.3 The City will either develop or acquire a Not required under the IDNR draft permit. Although it
training video, presentation, or other training could be done in conjunction with Section 4.6 below.
aid for training sessions with contractors,
developers, builders, and City staff.
DEADLINE: END OF 1ST PERMIT YEAR
4.4 The City will train staff to identify potential
erosion and sediment problems. City staff will
then serve as watchdogs, capable of
identifying possible ordinance violations and
alerting the proper authorities.
DEADLINE: END OF 1 ST PERMIT YEAR
Not required under the IDNR draft permit.
4.5 The City will require that the responsible
party, identified in an NPDES construction site
permit issued by the IDNR. submit a copy of
inspections required by site permit to the City
Engineering Division. City staff, to determine
the overall compliance with the pollution
prevention plan associated with the NPDES
construction site permit, will perform random
inspections of construction sites.
Site plan inspection shall be required once every
quarter for every development/construction site that
equals or exceeds an acre in area.
DEADLINE: END OF 2ND PERMIT YEAR
DEADLINE: END OF 1 ST PERMIT YEAR
Page 7 of 12
ATTACHMENT A
Dubuque's NPDES Permit Application vs. the State's "Draff' Permit
PRIVATE DEVELOPMENT INSPECTION: The IDNR requires that a City agent visit each active
construction site (public and private) once every quarter to ensure that the approved pollution prevention
plan (erosion and sediment control plan) has been implemented and has been adequately maintained.
Engineering does not currently have personnel to perform this task. One potential option is to have one
full-time person inspect construction sites, detention basins (Section 5.5), and catch basins (Section 6.3).
4.6 The City wili sponsor an annuai workshop The City will sponsor an annual workshop for
for homebuilders, developers, and contractors homebuilders, developers, and contractors that outline
that may contain an open forum to discuss the ways that construction sites can be operated and
successes and failures (lessons learned) of the maintained with erosion and sediment controls and to
past year; an educational session that outlines improve the quality of stormwater runoff.
the City's construction site pollution prevention DEADLINE: END OF 2ND PERMIT YEAR
ordinance; a training session on the proper use
of a structural control of erosion and sediment;
and a discussion on emerging erosion and
sediment control technologies.
DEADLINE: END OF 2ND PERMIT YEAR
DEVELOPER/HOMEBUILDER WORKSHOP: The workshop Is similar to, and could be done in
conjunction with the workshop outlined in Section 5.3. The costs associated with a workshop are meals,
snacks, and beverages (usually required to help garner higher attendance), securing a conference room,
and hiring a speaker for the presentation. The estimated annual cost is $1,500 (mostly depends on the
speaker).
SECTION 5, POST-CONSTRUCTION SITE STORMWATER RUNOFF
CONTROL
Post-construction runoff controls are practices or facilities in place after the
construction is completed. Therefore, they must be considered during the site
plan or subdivision planning process.
Dubuque's Permit Application IDNR's Draft Permit
5.1 The City will develop Site Plan and Sub- The city shall establish procedures and acceptance
division review procedures that address post criteria for the review of post-construction BMPs for
construction storm water runoff control which coverage under a construction site NPDES
measures such as: green space requirements; permit is required.
detention basin requirements; and post
construction erosion and sediment controls. The city shall not allow construction activity to
DEADLINE: END OF 1ST PERMIT YEAR commence until the plans for post-construction runoff
contrDls have been reviewed and approved.
DEADLINE: END OF 2ND PERMIT YEAR
Page 8 of 12
..-..----.- - -. -..------.
ATTACHMENT A
Dubuque's NPDES Permit Application vs. the State's "Dràft" Permit
SITE PLAN & SUBDIVISION PLAN APPROVAL: Runoff control measures such as green space
requirements, detention basin requirements, and post construction erosion and sediment controls are
currently included in the site plan and subdivision review process. One major departure from current
practices involves restricting construction until the overall plan is approved. Currently, preliminary
grading permits are granted and developers are allowed to proceed with the construction at his/her own
risk prior to having a site plan or subdivision improvement plans approved.
5.2 The City will adopt a post construction An ordinance shall be adopted that promotes
runoff control ordinance that outlines water stormwater detention, grass swales, and other BMPs
quantity and quality detention basin that reduce the pollutants in stormwater runoff.
requirements. It will promote the use of grass DEADLINE: END OF 2ND PERMIT YEAR
swales, buffer strips, preservation of existing
vegetation, establishment of vegetation, and
proper maintenance of private storm water
facilities.
DEADLINE: END OF 1ST PERMIT YEAR
POST DEVELOPMENT ORDINANCE: Engineering is in the process of convert the existing detention
basin policy into an ordinance. While the impetus for the change is rooted in the prevention of fiood
damage, detention aiso has water quality benefits.
While a "green development" or a "low impact development" would be desirable, promoting them in an
ordinance may be of little value; no development would be considered in violation of an ordinance that
simply promotes a behavior. Financial assistance is an alternative way to promote the use of low impact
development BMPs. A catalog of BMPs could be established that identify exactly when and where the
use of a BMP makes sense.
5.3 The City will sponsor a workshop for The city shall conduct or sponsor a workshop once per
developers and homebuilders focused on low year, intended to educate developers and house
impact deveiopment and emerging builders about ways low impact development and new
development techniques that incorporate design techniques that reduce the pollutants in runoff.
structural post construction best management DEADLINE: END OF 2ND PERMIT YEAR
practices that reduce the negative impacts of
storm water runoff.
DEADLINE: END OF 2ND PERMIT YEAR
DEVELOPER/HOMEBUILDER WORKSHOP: The costs associated with a workshop are meals, snacks,
and beverages (usually required to help garner higher attendance), securing a conference room, and
hiring a speaker for the presentation. The estimated annual cost is $1,500 (depends largely on the
speaker).
5.4 No similar item included in Dubuque's
permit application.
The city shall develop a watershed assessment
program and comprehensive land use plan that outlines
measures that reduce flooding; reduce erosion in
ditches and streams; improve the quality of creeks,
rivers, and streams; and reduces the degradation of fish
and wildlife habitat.
DEADLINE: END OF 3"D PERMIT YEAR
Page 9 of 12
ATTACHMENT A
Dubuque's NPDES Permit Application vs. the state's "Draft" Permit
WATERSHED ASSESSMENT PROGRAM: The city has never addressed all of the items in one plan.
The Drainage Basin Master Plan (DBMP) was formulated utilizing the land-use plan and it outlines ways
to reduce flooding in two major watersheds, the Bee Branch and North Fork Catfish Creek watersheds.
The three detention basins included in the plan will provide for the reduction of erosion in ditches and
streams. However, the DBMP does not specifically address fish or wildlife habitat. Further study of the
two watersheds might be required. In addition, the Catfish Creek watershed has not been studied. The
estimated cost is between $50,000 and $100,000.
5.5 No similar item included in Dubuque's The City shall inspect stormwater control devices (both
permit application. public and private) to ensure they are adequately
maintained.
Educational materials shall be developed and made
available to landowners illustrating proper maintenance
procedures.
DEADLINE: END OF 3RD PERMIT YEAR
RUNOFF CONTROL INSPECTION: The inspection of private stormwater systems has only been done
on a complaint basis. Currently, there are over 100 private detention basins scattered around the city.
The City must determine which department is responsible for the inspections. Engineering does not
currently have personnel to perform this task. One potential option is to have one full-time person
inspect construction sites (Section 4.5), detention basins (Section 5.5), and catch basins (Section 6.3).
SECTION 6. MUNICIPAL OPERATION GOOD HOUSEKEEPING
Dubuque's Permit Application
6.1 The City will develop and implement a City
employee education program consisting of the
certification of all personnel responsible for
applying pesticides, herbicides, and fertilizers
and the distribution of materials that illustrate
the pollution associated with storm water runoff
and ways to prevent the impairment of area
creeks, rivers, and streams.
IDNR's Draft Permit
1. A program for municipal employee training shall be
developed that outlines practices for city operations to
limit pollutants in stormwater.
DEADLINE: END OF 1sT PERMIT YEAR
DEADLINE: END OF 1sT PERMIT YEAR
2. A pesticide and fertilizer management program
shall be developed that outlines the storage,
application, and disposal of pesticides and fertilizers for
municipal operations. The program must identify all city
operations that apply these chemicals and ensure that
they are properly trained on management techniques
such as the storage, application, and disposal of the
chemicals.
Moreover, the application rates shall be gathered and
evaluated to determine if lower rates would be equally
effective. Lower rates shall be required if found to be
nearly as effective.
DEADLINE: Program development
END OF 1 ST PERMIT YEAR
Fully implemented
END OF 2ND PERMIT YEAR
Page 10 of 12
ATTACHMENT A
Dubuque's NPDES Permit Application vs. the State's "Draft" Permit
MUNICIPAL EMPLOYEE TRAINING: Dubuque's permit appiìcation proposed disseminating information
to all city employees in the Spirit Times, the bi-weekly newsletter that is distributed with each paycheck.
The program outlined by the IDNR would likely consist of identification of operation activities that might
impact the quality of stormwater. Secondly, proper protocols would be developed to reduce those
impacts. Finally, a training method would be identified. The program development and implementation
will require significant staff time. Annual cost is $0.00.
PESTICIDE and FERTILIZER MANAGEMENT PROGRAM: All municipal employees who apply these
chemicals must aiready be certified by the IDNR - a different division of the IDNR. While tracking of
application rates can be done, it is unclear who would assess if lesser rates would be nearly as effective.
Annual cost is $0.00.
6.2 In conjunction with the reconstruction of Not required under the IDNR draft permit.
city streets, sanitary sewers will be inspected
fDr defects and poor flow conditions.
Already performed by city personnel.
6.3 The City will inspect and clean catch Ail catch basins and above ground components of the
basins (storm sewer intakes). stormwater drainage system shall be inspected
annually.
DEADLINE: END OF 1 ST PERMIT YEAR DEADLINE: END OF 1ST PERMIT YEAR
CATCH BASIN INSPECTION: The number of catch basins inspected by the Operations & Maintenance
Department varies from year to year. However, it is unlikely that the department has ever inspected all
6,400 catch basins in a given year. That would necessitate the inspection of 20 catch basins every day. If
it takes approximately 1 hour to inspect 20 catch basins, then the annual cost will be approximately
$4,000. However, the inspection would necessitate an additional pick-up truck to enable the inspector to
visit the sites and remove and debris found in and around the catch basin. This would be an additional
cost of around $25,000. Therefore, the estimated annual cost is $9,000. Engineering does not
currently have personnel to perform this task. One potential option is to have one person inspect
construction sites (Section 4.5), detention basins (Section 5.5), and catch basins (Section 6.3).
6.4 The City will remove debris from streets Street sweeping shall be implemented.
with curb and gutters using street sweepers.
DEADLINE: END OF 1 ST PERMIT YEAR
DEADLINE: END OF 1 ST PERMIT YEAR
STREET SWEEPING: Street sweeping is already carried out by the Operations and Maintenance
Department. Annual cost is $375,000.00.
6.5 The City wili calibrate ail anti-icing and de- Not required under the IDNR draft permit.
icing equipment and train employees on the
proper chemicai application rate for snow and
ice control.
City personnel already emplDY this practice.
Page 11 of 12
6.6 The City will provide Dubuque residents Not required under the IDNR draft permit.
with several options for leaf and grass clipping
disposal. The City will facilitate the transfer of
leaves and grass clippings between citizens
looking to discard them and citizens hoping to
utilize them for com posting , gardening, and
other yard applications. The City will provide a
"Leaf Collection" for City of Dubuque solid
waste customers. The City will advertise the
options listed above as well as other non-City
disposal alternatives.
These programs already exist.
ATTACHMENT A
Dubuque's NPDES Permit Application vs. the State's "Draft" Permit
6.7 No similar item included in Dubuque's A program shall be developed and implemented that
permit application. assess best management practices (BMPs) at city
facilities that reduce pollutants in stormwater from these
facilities.
DEADLINE: END OF 2ND PERMIT YEAR
CITY FACILITY BMPs: The development of this program can coincide with the development of the
municipal employee training as the processes to develop each program is logically similar. The only
significant costs associated with the program development are staff time. Costs may be limited to the
increased time it takes to complete an operation.
6.8 No similar item included in Dubuque's All salt storage shall be in a structure impervious to
permit application. precipitation and any spillage due to handling activities
in an area subject to runoff shall be removed
immediately.
DEADLINE: END OF 1ST PERMIT YEAR
SALT STORAGE: One of the bid alternatives associated with the new Operations & Maintenance facility
on Kerper Ct. is a salt dome; the alternate was approved by the City Council and it is reflected in the
contract.awarded the Contractor. Based on the Contractor's bid, the cost of the dome is $140,000.
Page 12 of 12
~\\t'I"'"
. ~ ~ ~
Fields of Opportunities
STATE OF
IOWA
THOMAS J. VILSACK, GOVERNOR
SALLY J, PEDERSON, LT, GOVERNOR
DEPARTMENT OF NATURAL RESOURCES
JEFFREY R. VONK, DIRECTOR
June 28, 2004
Deron L. Muehring
City DfDubuque
Public WDrks Department
50 W. 13ili St.
Dubuque, IA 52001
RE: Draft NPDES Permit No.3 1-26-0-04
Dear Mr. Muehring:
Please find enclDsed the draft National Pollutant Discharge Elimination System (NPDES) permit for the
discharge Df stom water from YDur municipal separate stDrm sewer system. Please read and fDllDW the
enclosed instructions for completing the public notice requirements and return the enclosed certification fDrm
with a proof of publicatiDn, the fee payment form, fee payment and any comments you may have regarding the
draft permit.
If you have any questions or comments cDncerning this matter Dr you wish to schedule a meeting tD discuss the
draft pemit, please contact me at 515-281-7017.
Sincerely,
~/~ / J /.;t;¡:;'
Joseph D. Griffm
Wastewater SectiDn
Environmental Protection Division
Enclosures: I) Draft permit 2) 3 public notices 3) 1 Public notice certification 4) 1 Payment fDm
cc: Field Office #1
WALLACE STATE OFFICE BUILDING /502 EAST 9th STREET / DES MOINES, IOWA 50319
515-281-5918 TDD 515-242-5967 FAX 515-281-6794 www.iowadnr.com
City of Dubuque Municipal Separate Storm Sewer System
Permit Number: 31-26-0-04
PART I. DISCHARGES AUTHORIZED UNDER THIS PERMIT
A.
Permit Area
This permit covers all areas within the boundaries of the City of Dubuque totaling approximately 27.5
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 Discharges
This permit 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 stDrm 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.
LimitatiDns on Coverage
PART II. STORM WATER POLLUTION PREVENTION & MANAGEMENT PROGRAM
The permittee shall implement the Best Management Practices (BMPs), measurable goals,
implementation dates and fTequencies described in the following sections.
A.
Public Education and Outreach on Storm Water Impacts
The permittee shall implement 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:
I.
Genera! Storm Water Education Brochure - An informational brochure shall be developed
and distributed to all businesses and residents served by the MS4. The brochure shall
present information regarding storm water impacts on water quality and measures that can
be implemented tD reduce water quality degradatiDn fTDm storm water.
The brochures shall be written and distributed by the permittee during the period Df the
permit with distribution commencing no later than September I, 2005. The brochures shall
also be made available Dn the permittee's website and at all city offices.
1/13
City DfDubuque Municipal Separate StDrm Sewer System
Permit Number: 31-26-0-04
B.
2.
TelephDne 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.
The telephone number shall be established no later than September I, 2005 and remain in
effect for the duration of the permit.
3.
Storm Water Web Page - The permittee's website shall contain information regarding storm
water impacts on water quality, measures residents can implement to reduce pDllutants 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 sha.1I be established by the permittee no later than September I,
2005 and maintained for the duration of the permit.
4.
StDrm Drain Labeling - A program shall be developed to label all storm sewer intakes. All
intakes shall be marked within five years of the issue date of the permit with approximately
20% of the existing intakes each year and all new intakes as constructed.
The labeling shall commence no later than September I, 2006 and all intakes shall be
labeled no later than the expiration date of the permit. The labels shall be re-applied as
needed to maintain legibility. ,,'
5.
Educational Television Program - The permittee shall develop or obtain a videotape
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.
The program shall be developed or obtained and televised no later than September I, 2005
and then televised at least once each calendar quarter for the remainder of the duration of
the permit.
6.
Public Education Program - The permittee shall 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 no later than September I,
2008 and shall be made available for the remainder of the duration of the permit.
Public Involvement and Participation
The permittee shall implement a public involvement and participation program that includes the
following:
Establish Storm Water Advisory Committee - The permittee shall establish a storm water
advisory committee to participate in decision making, holding public hearings and working
2/13
City of Dubuque Municipal Separate Storm Sewer System
Permit Number: 31-26-0-04
c.
with volunteer groups. Businessmen, developers, homeowners, members of environmental
groups and members of the public at large sha1l be allowed to participate, if interested.
However, the permittee may place reasonable limits on the total number of individuals
participating in the group.
The group shall be established no later than September I, 2005 and meetings held at least
once each calendar year for the remainder of the duration of the permit.
2.
Water Quality Monitoring - The permittee sha1l organize volunteers tD conduct storm water
quality monitoring of storm water discharges and receiving streams. The data from the
monitoring sha1l be made available to members of the public and to the Department as
requested.
The monitoring activities shall begin no later than September I, 2005 and continue for the
remainder of the duration of the permit.
Illicit Discharge Detection and Elimination
The permittee sha1l develop, implement and enforce
includes the fo1lowing:
ge detection and elimination prDgram that
1.
Illicit Discharge Prohibi nance shall be adopted or amended as
necessary by the permi ing other than storm water, a1lowable non-
storm water and po1lutant NPDES permit has been issued and when the
discharge is in compliance e permit from entering the MS4. The ordinance sha1l
include language that enables the permittee to inspect private property if an i1licit discharge
is suspected and penalties for non-compliance.
The ordinance sha1l be adopted or amended as necessary no later than September l, 2005
and enforced by the permittee for the remainder of the duration of the permit.
2.
Illicit Discharge Detection and Elimination Program - A program sha1l be developed to
identify and eliminate i1licit discharge to the MS4. The programsha1l include annual dry
weather flow inspections of a1l known outfa1ls, sampling and analyses of dry weather flows,
procedures to identify the sources of the dry weather flows and procedures for
disconnecting illicit connections. Records sha1l 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 sha1l be evaluated annua1ly to
assess the effectiveness of the program and any necessary changes made. A1l 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 sha1l
submit to the Department the reasons why the discharge cannot be eliminated within 21
days Df discovery and a plan which contains a timeline of activities which will result in the
eliminatiDn of the discharge. This statement and plan sha1l be submitted within 21 days Df
discovery of the i1licit discharge. If the Department does not approve the plan, the permittee
wi1l then be required to eliminate the discharge no later than a date specified by the
Department. A1l i1licit discharges sha1l be reported to the Department no later than the end
of the flISt business day after the day of the discDvery.
3/13
City of Dubuque Municipal Separate Storm Sewer System
Permit Number: 31-26-0-04
D.
The plan shall be developed and implemented by the permittee noc'.later than September I,
2005 and for the remainder of the duration of the permit.
3.
Storm Sewer System Map - All outfalls, intakes, above-ground conveyances, basins, other
structures and monitoring sites of the MS4 shaH be mapped. Approximately 20% Df the
existing system shaH be mapped each year of the permit. New intakes, outfalls and piping
added during the term of the permit shaH be mapped as they are constructed.
The mapping shaH commence no later than September I, 2004 by the permittee and shaH be
completed no later than the expiration date of the permit.
4.
Pet Waste Ordinance - An ordinance shall be developed 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 the
disposal of the feces in either the municipal trash collection system or the sanitary sewer
system. Exemptions for manure from agricultural livestock when used for horticultural
purposes may be included in the ordinance.
The ordinance shaH be adopt~d by the permittee no later than September 1,2005.
Construction Site Storm Water Runoff Control
..,.
The permittee shall develop, implement and .enforce 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 be developed or amended
as needed and enforced on all sites for which NPDES permits are required that requires
proper soil erosion and sediment control. This ordinance shaH 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 poHution
control BMPs, authority for the permittee to enter private property for the purposes of
compliance inspections and penalties for non-compliance shaH 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 shaH be adopted or amended by the permittee as necessary no later than
September I, 2006 and enforced beginning no later than September I, 2006 for the
remainder Dfthe duration of the permit.
2.
Construction Site Review and Inspection Program - The permittee shaH 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 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 cover~ge 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.
4/13
City of Dubuque Municipal Separate Storm Sewer System
Permit Number: 31-26-0-04
3.
E.
The program shall be fully implemented by the permittee no later than September 1,2006
and for the remainder of the duration of the permit.
Contractor Workshop - The permittee shall cDnduct 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 erosiDn and sediment
control and to improve the quality of storm water runoff.
The first workshop shall be held no later than September 1,2006 and at least Dnce each year
for the remainder of the duration of the permit.
PDst-constructiDn Storm Water Management
The permittee shall develop, implement and enforce a program to address storm water runoff from new
construction and fe-construction projects for which storm water coverage is required. The program must
ensure that controls are in place that wil1 prevent or minimize water quality impacts and shall include the
fol1owing:
1.
2.
Site Plan Review of Post--construction Runoff Controls - The permittee shall establish
procedures and acceptance criteria for review of post-construction runoff controls for all
construction sites for which cDverage under NPDES storm water permits are required. The
permittee shall not al1ow construction activities to commence until the plans for post-
construction runoff controls have been reviewed and approved.
The program shall be developed by the permittee no later than September I, 2006 and
implemented for the remainder of the duration of the permit.
3.
Inspection of Runoff Control Devices - Storm water control devices and structures shal1 be
inspected and reviewed for proper maintenance. EducatiDnal materials shall be developed
and made available tD landowners which outline proper maintenance procedures. The
permittee shall properly maintain its own control devices and structures.
Inspections shall be conducted beginning no later than September 1, 2007 and for the
remainder of the duration of the permit. The educational materials shall be developed no
later than September I, 2007 and made available fDr the remainder of the duration Df the
permit.
4.
Watershed Assessment Program - A watershed assessment program and comprehensive
land use plan shall be develDped which outlines measures to be implemented which reduce
5/13
City of Dubuque Municipal Separate Storm Sewer System
Pennit Number: 31-26-0-04
F.
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 established by the permittee no later than September I, 2007 and
implemented for the remainder of the duration of the permit.
5.
DevelDper and House Builder Workshop - The permittee shall conduct or sponsor
workshops intended to educate developers and house builders about ways low impact
development and new design techniques that include structural best management practices
can improve the quality Df storm water runoff.
The first workshop shall be held no later than September I, 2006 an at least once each year
for the remainder of the duration of the permit.
Pollution Prevention/Good HousekeeDing
The permittee shall develop and implement 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:
\.
;..~,
Operation and Maintenance of MS4 - A program for inspecting, maintaining and cleaning
all components of the MS4 including .street sweeping shall be implemented. All catch
basins and above-ground components of the MS4 shall be inspected at least once each year
and maintenance performed as appropriate. .
The program shall be implemented by the permittee no later than September I, 2005 and for
the remainder of the duration Dfthe permit.
2.
Pesticide and Fertilizer Management Program - A pesticide and fertilizer management
program shall be developed, 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, 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 developed by the permittee no later than September I, 2005 and fully
implemented no later than September I, 2006.
3.
Training Program for Municipal Employees - The permittee shall develop a program for
training municipal employees regarding practices to be implemented in city operations to
reduce pollutants in storm water.
The program shall be developed and implemented by the permittee nD later than September
1,2005 and for the remainder of the duration of the permit.
6/13
City of Dubuque Municipal Separate Storm Sewer System
Permit Number: 31-26-0-04
4.
City Facilities BMPs - A program shall be developed and implemented to assess BMPs at
city facilities to be implemented that reduce pDllutants in storm water from these facilities.
These measures shall then be implemented whenever practical.
The program shall be implemented by the permittee beginning no later than September I,
2006 and for the remainder of the duration of the permit.
PART Ill. 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 with the first report due in calendar year 2005. The report shall include the
following:
PART IV.
1.
The status of implementing the components of the storm water pollution prevention and
management plan. Any modifications develDped b the permittee and approved by the
Department or required by the Department sha e addressed.
2.
The status of compliance with any
modifications to this permit.
. established by this permit or by any
3.
A summary of all revisions to
4.
A summary of the data, includin monitoring data, that is generated within the reporting
period including a narTative description of storm water quality improvements or
degradation.
5.
An estimate of the previous fiscal year's expenditures for implementation of the
management plan and the budget for the current fiscal year.
6.
A summary describing the number and nature of inspections, enforcement actiDns, 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.
SPECIAL CONDITIONS
Only storm water, allowable non-storm water, and pDllutants 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 Df pollutants from a site, facility or source for
which an NPDES permit is required unless an NPDES permit has been issued fDr 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 SDurees of pollutants shall be considered discharges even if
no actual pollutants have been observed entering the MS4 from such a source.
7/13
City of Dubuque Municipal Separate Storm Sewer System
Permit Number: 31-26-0-04
The permittee is prohibited from issuing any peI1l1it, authorization or license aIIowing 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, cDverage under an NPDES peI1l1it is required without fITst ensuring
that a storm water authorization from the Department has been issued for the activity.
A construction site inspection program shall be developed and implemented for construction projects
owned Dr operated by the peI1l1ittee that include areas of sDil disturbance for which NPDES peI1l1its 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 peI1l1ittee at least every 7 days and within 2 business days of
a 0.50 inch or greater rain event and include any other provisions necessary to ensure compliance by
contractors with the storm water General PeI1l1it no. 2. Inspections required by General Permit no. 2
must also be conducted by the contractors or the permittee including inspections within 24 hours of the
end of a 0.50 inch or greater rain event. Inspections made by the peI1l1ittee that satisfy the requirements
of General Permit no. 2 may be used tD satisfy the requirements of this peI1l1it.
All salt storage shall be in a structure impervious to precipitation and any spillage due to handling
activities in an area subject to runoff shall be immediately removed.
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.
PARTY. STANDARD CONDITIONS
A.
Pemittee's Duty tD Comnlv
The permittee must comply with all conditions of this peI1l1it. Any peI1l1it 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 peI1l1it renewal application. Issuance of this
permit does not relieve you of the responsibility to cDmply with all local, state and federal laws,
ordinances, regulations or other legal requirements applying to the operation of your facility (see 40 CFR
I 22.4 I(a) and 567-64.3(11) lAC).
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 pennit. You must also furnish
to the Director, 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 peI1l1ittee in an enforcement action that it would have been necessarY to halt
or reduce the peI1l1itted activity in order to maintain compliance with the conditions of this permit.
8/13
City of Dubuque Municipal Separate Stonn Sewer System
Pennit Number: 31-26-0-04
D.
Signatorv Requirements
Stonn Water Pollution Prevention Plans, reports, certifications or infonnation either submitted to the
Department or that this pennit requires be maintained by the pennittee, shan 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 a principal geographic unit of the agency.
Certification Any person signing documents shan make the foUowing certification:
I certify under penalty of law that this document and aU attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gathered and evaluated the infonnation submitted. Based on my inquiry of the persDn or
persons who manage the system, or those persons directly responsible for gathering the infonnation,
the infonnation 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.
E. Duty to Mitigate j~
The permittee shan take aU reasonab~e t . .." .. ...' t o\.event any discharge in violation of this
pennit that has a reasonable likelihoo I g human health or the environment.
F. ProDertv Rights
The issuance of this permit dDes 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 penn it 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 tD other
circumstances, and the remainder of this permit shan not be affected thereby.
H. StateÆnvironmenta] Laws
Nothing in this pennit shall be c,<nstrued tD preclude the institution of any legal action or relieve the
pennittee from any responsibilities, liabilities, or penalties established pursuant to any applicable State
law or regulation under authority preserved by Section 510 Df the Act. No condition of this permit shall
release the permittee from any responsibility or requirements under other environmental statutes,
regulations or permits.
I.
Prover aDeration and Maintenance
The pennittee shall at aU times prDperly operate and maintain aU facilities and systems of treatment and
control (and related appurtenances) that are installed or used by the pennittee to achieve compliance with
the conditions of this pennit and with the requirements of stonn water pollution prevention plans. Proper
and maintenance also includes adequate laboratory controls and appropriate quality assurance
Proper operation and maintenance requires the operation of backup Dr auxiliary facilities or
9/13
City of Dubuque Municipal Separate Stonn Sewer System
PennitNumber; 3]-26-0-04
similar systems, installed by the pennittee only when necessary to achievè compliance with the
conditions of the pennit.
J.
Inspection and Entry
The pennittee shall allow the Department, an authorized representative or an authorized representative of
the municipal operator of the separate stonn sewer receiving the discharge, upon the presentation of
credentials and other documents as may be required by law, to: enter upon the pennittee's premises
where a regulated facility or activity is located or conducted or where records must be kept under the
conditions of this pennit; have access to and copy at reasonable times, any records that must be kept
under the conditions of this penn it; inspect at reasonable times any facilities or equipment (including
monitoring and control equipment); and to sample any discharge of pollutants.
K.
Pennit Actions
This penn it may be modified, revoked and reissued, or tenninated for cause. The filing of a request by
the pennittee for a penn it modification, revocation and reissuance, or discontinuance, or a notification of
planned changes or anticipated noncompliance does not stay any penn it condition. This pennit may be
modified due to conditions or infonnation on ,which this penn it is based, including any new standard the
Department may adopt that would change the required effluent limits.
L.
Potential or Realized Impacts on Waièr OtiaIitv
If there is evidence indicating potential or realízed i1Ì1pattson water quality or on a listed endangered
species due to any stonn water discharge associated with industrial activity covered by this penn it, the
penn it shall be modified to include different limitationsandlor requirements of the Pollution Prevention
Plan and it's implementation.
M.
Failure to submit fees
This pennit 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 Penn it Conditions
Section 309 of the CWA provides significant penalties for a person(s) who violates a pennit condition
implementing Section 301, 302, 306, 307, 318, or 405 of the CW A, or any pennit condition or limitation
implementing any such sections in a permit issued under Section 402. Any person(s) who violates any
condition of this pennit is subject to a civil penalty not to exceed $25,000 per day of such violation, as
well as any other appropriate sanction prDvided by Section 309 of the CW A.
PART VI. DEFINITIONS
Allowable Non-Stonn Water means: discharges from fire fighting 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 conditiDning condensate, exterior building washwater wben no
detergents or other surfactants are used and pavement wasbwaters where spills or leaks of toxic or
bazardous materials bave not occurred and when no detergents or other surfactants are used.
10/13
City of Dubuque Municipal Separate Storm Sewer System
Permit Number: 31-26-0-04
Best Management Practices ("BMPs") means schedules of activities, prohibitions of practices,
maintenance procedures, and other management practices to prevent or reduce the pollutiDn of waters
of the State. BMPs also include treatment requirements, operating procedures, and practices to control
facility site runoff, spillage or leaks, sludge Dr waste disposal, or drainage from raw material storage.
Calendar Quarter means each of the following periods: December thru February, March thru May,
June thru August and September thru November.
CW A means Clean Water Act (fonnerly referred to as the Federal Water Pollution Control Act or
Federal Water Pollution Control Act Amendments of 1972).
Department means the Iowa Department of Natural Resources (IDNR) or an authorized representative.
Discharge means the release Df water and any elements, compounds and particles contained within or
upon, from property owned or controlled by an individual, individuals, or entity.
Facility means any entity which discharges stonn water.
Municipal separate stonn sewer svstem means the conveyance or system of cDnveyances including
stonn sewers, roadways, roads with drainage systems, catch basins, curbs, gutters, ditches, constructed
channels and stonn drains owned or Dperated by the pennittee.
Pennittee means the City of Dubuque.
Point source means any discernible, confined
any pipe, ditch, channel, tunnel, conduit,
animal feeding operation, landfill leac
pollutants are or may be discharged.
or agricultural stonn water runoff.
Significant materials includes, but is not I d to: raw materials; fuels; materials such as solvents,
detergents, and plastic pellets; finished materials such as metallic prDducts; 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 stonn water discharges.
Stann water means stonn water runoff, snow melt runoff, and surface runoff and drainage.
Stonn water discharge associated with industrial activity means the discharge from any conveyance
that is used for collecting and conveying stonn water and that is directly related to manufacturing,
processing or raw materials storage areas at an industrial plant. The tenn does not include discharges
from facilities or activities excluded from the NPDES program. For the categories of industries
identified in paragraphs (i) through (x) Dfthis definition, the tenn includes, but is not limited to, stonn
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 fDr the stDrage and maintenance of material
handling equipment; sites used for residual treatment, storage, Dr disposal; shipping and receiving
areas; manufacturing buildings; storage areas (including tank farms) for raw materials, and
intennediate and finished products; and areas where industrial activity has taken place in the past and
significant materials remain and are exposed to stDnn water. For the categories Df industries identified
in paragraph (xi) of this definitiDn, the tenn includes only stonn water discharges from all areas
(except access roads and rail lines) listed in the previous sentence where material handling equipment
veyance, including but not limited to,
tainer, rolling stock, concentrated
I or other floating craft from which
de return flows from irrigated agriculture
11113
City afDubuque Municipal Separate Stann Sewer System
PennitNumber: 31-26-0-04
or activities, raw materials, intennediate products, final products, waste materials, by-products, or
industrial machinery are exposed to stonn water. For the purposes of this paragraph, material handling
activities include the storage, IDading and unloading, transportation, or conveyance of any raw
material, intennediate product, finished product, by-product or waste product. The tenD 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 stonn
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)(I)(v).
The following categories of facilities are considered to be engaging in "industrial activity" for
purposes of this subsection.
Facilities subject to stonn water effluent limitations guidelines, new SDurce perfonnance
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);
Facilities classified as Standard Industrial Classifications 24 (except 2434),26 (except 265 and
267),28 (except 283 and 285), 29, 31 1,32 (except 323),33,3441,373;
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
perfonnance 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 requirements afterOecember 17, 1990) and oil and gas exploration,
production, processing, or treatment operations, or transmission facilities that discharge stonn
water contaminated by contact with Dr that has come into contact with, any overburden, raw
material, intennediate 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;
Hazardous waste treatment, storage, or disposal facilities, including those that are operating
under interim status or a penn it under Subtitle C ofRCRA;
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;
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 SOlS and 5093;
Steam electric power generating facilities, including coal handling sites;
Transportation facilities classified as Standard Industrial Classifications 40, 41, 42 (except
4221-25), 43, 44, 45 and 5171 that have vehicle maintenance ShDPS, 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;
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
12/13
City of Dubuque Municipal Separate Storm Sewer System
Permit Number: 31-26-0-04
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 Dr lands used fDr sludge management where sludge is beneficially reused and that are
not physically located in the confines Df the facility, or areas that are in compliance with 40
CFRPart 503;
Construction activity including clearing, grading and excavation activities that result in the
disturbance of I acre or more of total land area or which result in the disturbance of less than 1
acre but are part of a larger common plan of development or sale of 1 acre or more;
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 categDries (i) to (x)).
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 Dr underground, natural or artificial, public or private, which are contained within, flow
through Dr border upon the state or any portion thereof.
13il3
D~
~<Æ~
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.
Date:
g¡;ø:3
City of Dubuque NPDES Phase II MS4 Individual Pem,;t Application
-page 1 of35-
Van Milli en
Count Dubu ue
DivisiDn
Zi Code: 52001
Coun : Dubu ue
Listed below are the waters Df the United States tD which Dubuque's Phase II MS4 discharges:
Mississippi River'
Granger Creek
SDuth FDrk Catfish Creek
Bee Branch Creek
Catfish Creek
North FDrk Catfish Creek
Middle FDrk Catfish Creek
'Identified Dn IDwa's 303(d) list Df impaired waters
SECTION IV. MINIMUM CONTROL MEASURES
The cDmplete description of each BMP can be fDund in section VII. In additiDn, a BMP summary form is included for
each minimum contrDI measure (see section VIII).
8MP Full 8MP
Minimum CDntrol Measure D¡~~~~~~n ~~~:~?'
Public Education and Outreach as tD Stormwater Impacts 4-9 27-28
Public InvolvemenVPublic Participation 10-13 29-30
Illicit Discharge Detection and EliminatiDn 14-18 31-32
CDnstruction Site Stormwater Runoff CDntrol 19-21 33
PDst-construction StDrmwater Management in New Development and RedevelDpment 22-23 34
PDllution Prevention/GDDd HDusekeepino fDr Municipal OperatiDns 24-26 35
City of Dubuque NPDES Phase II MS4 Individual Pennit Application
-page 2 Df35-
I certify under penalty of law that this dDcument and all attachments were prepared under my directiDn or supervision in
accordance with a system designed tD assure that qualified persDnnel properly gathered and evaluated the informatiDn
submitted. Based upDn my inquiry of the persDn or persons who manage the system, or thDse persDns directly
respDnsible fDr gathering the infDrmatiDn, the informatiDn submitted is, tD the best Df my knDwledge and belief, true,
accurate and cDmplete. I am aware that there are significant penalties fDr submitting false infDrmatiDn, including the
possibility of fine and imprisDnment for knowing viDlatiDns.
Name Df Phase II MS4 RespDnsible AuthDrity (type Dr print):
Title:
Signature:
Michael C. Van Milligen
Date:
:) / Y /(¿)
City of Dubuque NPDES Phase II MS4 Individual Permit Application
-page3 Df35-
BLANK PAGE
1.1
Public Education Campaign
Development
1.2
Educationai Video
1.3
Storm Drain Labeling
1.4
Execution of Public Education
Campaign
1.5
Storm Water Runoff Pollution
Curriculum
1. The number of target groups will be tracked.
2. Each method chosen to send the information out
to the public will be tracked.
The acquisitiDn of educatiDnal videos will be
documented.
1. The number of door-hangers placed Dn dDors will
be tracked.
2. The number of brochures distributed in
neighborhoods will be tracked.
J. The number of storm drains labeled will be
tracked.
All activities such as the distribufion 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.
1. The number of educators contacted will be
tracked.
2. Storm water poliutiDn curriculum utilized by
educators will be documented.
J. Explore and develop a curriculum to teach
students about stDrm water runoff pollution.
City of Dubuque - NPDES Phase II MS4 Individual Permit Application
The public education campaign will be
developed during the first permit year.
The City will acquire a videD in the first permit
year.
The City will promote volunteer participation
in the first permit year.
Brochures will be developed in the first permit
year.
Door hangers will be develDped in the first
permit year.
Storm drain labeling will begin by the end of
the second permit year.
The public education campaign developed in
BMP 1.1 will be initiated by the end of the
second permit year.
The City will send correspondence to
educatDrs in the first permit year.
Depending on the cooperation of local
educators, curriculum pertaining to storm
water runoff pollution will be utilized by the
end of the fourth permit year.
Engineering Division
City Manager's Office
Graphic Arts
En9ineering Division
Engineering Division
City Manager's Office
Graphic Arts
Engineering Division
Engineering Division
-page 27 of35-
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1. A copy of the public notice information will be
retained.
2.1
Public Notice Requirements
2. The number of peDple who participate in the
development of Dubuque's Siorm Water
Management Program will be tracked.
1. The number Df sampling sites will be tracked.
2.2
Volunteer Creek Monitorin9
2. The frequency of sampling at each site will be
tracked.
1. The number and size of volunteer organizations
will be recorded.
2.3
2. The number of storm drains labeled by
volunteers will be tracked.
Storm Drain Labeling
3. A IDcation map Df labeled storm drains will be
developed and maintained.
1. The number Df volunteer organizations that
receive materials will be tracked.
2.4
Distribution of Educational
Material
2. The type and number Df all materials distributed
will be tracked.
City of Dubuque - NPDES Phase II MS4 Individual Permit Application
Pubiic notice requirements will be
implemented in the first permit year.
Engineering Division
City Clerk's Office
Advertising for IOWAter will be initiated in the
first year of the permit year.
Engineering Division
City Manager's Office
Volunteer monitoring will be initialed in the
first permit year.
The City will promote volunteer participation
in the first permit year.
Storm drain labeling will begin by the end of
the second permit year.
Engineering Division
The City will begin identifying organizations
willin9 to distribute educatiDnal materials in
the first permit year.
Engineering Division
Educational materials will be distributed to
organizations for distribution by the end of the
second permit year.
-page 29 0135-
1. The number of contests will be tracked.
2.5
2. The number of volunteer organizatiDns 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
romotion of the competition. etc. will be tracked.
CD-SponsDred Competition
3. The number of cDntestants will be tracked.
1. The number of schools and educators contacted
will be tracked.
2,6
Education Partnership
Program
2. The number oi students who participate will be
tracked.
2.7
Sewer and Outtall Monitoring
1. The number of volunteer monitoring sites will be
tracked.
2. The number and results of sanitary sewer and
storm sewer Duttall inspections will be tracked.
City of Dubuque - NPDES Phase II MS4 Individual Permit Application
The City will solicit co-sponsors in the first
permit year.
Contest logistics will be determined by the
end of the second permit year.
Engineering Division
City Manager's Office
A competition (or competitions) will be
initiated by the end of the third permit year.
The City will send correspondence to
educators in the first permit year.
Engineering DivisiDn
Depending Dn the cooperation of local
educators. the City will form partnership(s) by
Ihe end of the third permit year.
Monitoring of outfalls will' be initiated in the
first permit year.
Engineering Division
Water Pollution Conto!
-page 30 0135-
1. The banks of the receiving waters will be walked
at least twice.
3.1
2. The MS4 map will be updated.
MS4 Map Development
3. The photographs taken of oulfalls will be
compiled.
1. The ordinance will be drafted.
3.2
Stormwater Ordinance
2. The adDptiDn of the ordinance will be recDrded.
3.3
HazardDus Waste Collection
Program
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 Df
any other commonly used method Df advertising will
be tracked.
3.4 Pet Waste DispDSal
3.5 illicit Discharge RepDrt
Tracking
3.6 Citizen Reporting
1. The ordinance will be dDcumented.
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.
1. Advertising will be documented.
2. The number of citizen reports will be tracked.
City of Dubuque - NPDES Phase II MS4 Individual Permit Application
A map illustrating the MS4 outfalls and
waters of the United States will be completed
in the first permit year.
An ordinance will be drafted during the first
permit year.
The ordinance will be adopted before the end
of the first permit year.
Advertising and educational materials will be
produced and distributed in the first permit
year.
The ordinance will be in place the first permil
year.
The City will begin tracking citizen reports of
possible illicit discharges and citizen requests
for informatiDn in the first permil year.
The telephone "Hotline" and the web page
will be established by the end of the second
permit year.
Engineering Division
Engineering DivisiDn
Legal
City Council
Environmental Stewardship
Advisory Commission
Engineering Division
Dubuque Metro Area Solid
Waste Agency (DMASWA)
Legal
Health
Engineering Division
Engineering Division
-page 31 of35-
Illicit Sanitary Sewer
Connection Reduction
Program
3.8
Seplic System Eliminalion
Program
3.9
Illicit Discharge DetectiDn
Training for City Staff
3.10
Determine Potential Illicit
Discharge Sources to Target
3.11
Sewer and Outfall Monitoring
2. The illegal connections forced to disconnect will
be documented.
1. The number Di residences removed from the
septic system will be tracked.
2. Sanitary sewer extension projects will be
documented and be given a priority.
1. The number of emplDyees that are sent
educatiDnal materials and receive training will be
dDcumented.
1. Target areas will be recorded and identified on a
map.
1. Sewer and Dutfaliinspection activities will be
dDcumented.
City of Duhuque - NPDES Phase II MS4 Individual Pennit Application
Home inspections will be conducted by the
end of the first permit year.
The policy requiring properties to connect tD
the city sanitary sewer system if there is a
sanitary sewer within 200 feet of the property
will be in place the first permit year.
At least one sanitary sewer construction
project, that extends sewer to properties in
the city without sanitary sewer, will be
budgeted for constructiDn by the second
permit year.
Educational materials will be distributed in the
first permit year.
A map showing the MS4, land use and the
sanitary sewer will be produced by the end Df
the second permit year.
Areas will be targeted for inspection by the
end of the third permit year.
The City will solicit volunteers in the first
permit year.
Volunteer monitoring will be initiated by the
end of the second permit year.
Engineering
Engineering Division
Heallh
City Council
Engineering Division
City Manager's Office
Personnel
Engineering Division
Engineering Division
-page 32 of35-
4.1
1. The number of constructiDn sites that obtain an
NPDES construction site permit from the IDNR will
be tracked.
Construction Site Tracking
4.2
Erosion & Sediment CDntrol
Ordinance
1. The existence of an ordinance that requires
measures 10 limit erosion and sedimentation and
establishes restrictions Dn CDnstruction site
pollutants.
4.3
Training Material
Development
1. The develDpment or acquisition of training aids
will be documented.
4.4
City Staff Erosion & Sediment
Control Training
1, The number of City staff trained and the training
methods will be tracked and recorded.
1, InspectiDn repDrts obtained by the City of
Dubuque Engineering Division will be retained.
4.5
CDnslruction Site Inspection
2. The number and reports for all random City staff
inspections will be tracked and retained.
4.6
1. The number of people who attend the workshop
will be tracked.
Contractor Workshop
City of Dubuque - NPDES Phase II MS4 Individual Permit Application
The tracking of construction sites will be
initiated in the first permit year.
An ordinance will be drafted during Ihe first
permit year.
Training materials will be acquired by the end
of the firsl permil year.
Training of City staff will be initiated by the
end of the first permit year.
Construction site inspections will be initialed
in the first permit year.
A workshop will be held by the end of the
second permit year.
Engineering Division
Engineering Division
Legal
City Councit
Environmental Stewardship
Advisory Commission
Engineering Division
Engineering Division
Engineering Division
Engineering Division
-page 33 of35-
5.1
Sile Plan & Sub-Division
Review
1. The Site Plan review procedures will be
documented.
The site plan review procedures will be
modified to include post-construction runoff
control measures by the end Df the first
permit year.
1. Adoption of the ordinance will be documented.
An ordinance will be drafted during the first
permit year.
5.2
PDst CDnstruction Runoff
Control Ordinance
1. The workshop agenda and specific
speakers will be documented.
5.3
Developer & Home Builder
WDrkshop
A workshop will be held by the end of the
second permit year.
2. The number of people who attend the
workshDP will be recorded
City of Dubuque - NPDES Phase II MS4 Individual Pennit Application
Planning
Engineering Division
Engineering Division
Legal
City Council
Environmental Stewardship
AdvisDry CDmmission
Engineering Division
-page 34 of35-
6.1
City Employee Education
6.2
Sanitary Sewer Inspection
6.3
Catch Basin Inspection &
Cleaning
6.4
Street Cleaning
6.5
De-leer Proper Application &
Training
6.6
Leaf & Grass Clipping
Disposal Program
1. Pesticide, herbicide, and fertilizer certifications
will be documented.
2. The media used to provide information to City
employees will be documented.
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.
1. The number of catch basins inspected will be
tracked.
2. The number Df catch basins cleaned will be
tracked
1. The number of lane-miles swept will be tracked.
1. The number of employees trained each year will
be tracked.
2. Calibrations will be recorded.
1. The quantity Df yard waste dropped off al the
Dubuque Metro Landfill. Dubuque Arboretum, and
Splendid Valley Nursery will be tracked.
City of Dubuque - NPDES Phase II MS4 Individual Pernlit Application
Employee certification for pesticide,
herbicide, and fertilizer application will be in
place the first permit year.
The dislribution of educational materials will
begin in the first permit year.
Sanitary sewer inspections will be initiated in
the first permit year.
Sanitary sewer replacement in conjunction
with street reconstruction projects will begin
in the first permil year.
Catch basin inspections and debris removal
will begin in the first permit year.
Street sweeping will be initiated in the first
permit year
Employee training will by done by the end of
the first permit year.
The calibratiDn of de-icing equipment will take
place in the first permit year.
The leaf exchange program will be in place
the first permit year.
The Leaf Rake-Out Collection will be Initiated
in the first permit year.
Proper yard waste disposal will be advertised
by the end of the first permit year.
Engineering Division
City Manager's Office
Personnel
Engineering Division
Operations & Maintenance
Operations & Maintenance
Operations & Maintenance
Operations & Maintenance
Engineering Division
Operations & Maintenance
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