CR2002-112 City Contribution to LMC - NPDES Phase II
C \ I" Y OF
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June 27, 2002 HOPKINS Council Report 2002-112
. Approve City Contribution to LMC ~ NPDES Phase II Implementation
Proposed Action
Staif recommends adoption of the following motion: Move that Council approve a
$5,000 contribution to the League of Minnesota Cities for development of a NPDES
Phase II Permit Guide Plan.
Overview
As a part of the National Pollution Discharge Elimination System (NPDES) program and
to comply with Federal regulation, the Milmesota Pollution Control Agency will be
requiring that all MS4 Cities, such as Hopkins, submit an application for an NPDES,
Phase II permit by March la, 2003. The goal of the NPDES, Phase II, program is to
reduce storm water pollutant discharge. The permit application requires that we develop
a Hopkins storm water pollution prevention program designed to reduce the discharge of
pollutants from our storm sewer system. The permit application must define best
management practices (BMPs) and measurable goals for the following six specific
control measures:
1. Public education and outreach
2. Public participation/involvement
3. Illicit discharge detection and elimination
4. Construction site storm water runoff control
. 5. Post-construction storm water management
6. Pollution prevention/good housekeeping for municipal operations
Staff has already begun planning for this required permit by attending various seminars
and discussing the permit with other cities. To date we have identified some specific
actions that Hopkins will need to take along with this permit, such as:
. Set up a comprehensive public involvement and education program
. Set up a catch basin, pond, stormccptor inspection and maintenance program
. Revise our ordinances to match NPDES, Phase 11, requirements and enforce them
Since development of the plan and permit application for each city is a completely new
and potentially very expensive task to undertake, the League of Minnesota Cities has
otfered to organize interestcd cities to pool together funds to develop a "guide plan" that
can be used by the citics to complete most of their permit applications using in-house
resources. Staff is recommending that Council authorize a contribution of $5,000 (as
requested by the LMC) to the LMC for development of the guide plan. Since this permit
is directly related to the storm se\ver system, staff proposcs to fund this contribution from
the storm sewer fund.
Supporting Information
. Memo from Steve Stadler to Steve Mielke dated June 11, 2002
. NPDES Phase II Permit Guide PIan Letter from the LMC dated June 7, 2002
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. Steven G. Bot, Assistant City Engineer
financial Impact: $ 5,000 Budgeted: Y iN No Source: Storm Sewer Utility Fund
Related Documents (C1P, ERP, etc.): _
. Public Works Department
Memorandum
To: Steven C. Mielke, City Manager
Copy: Steve Bot, Asst. City Engineer
From: Steven J. Stadler, Public Works Director
Date: June 11, 2002
Subject: NPDES, Phase II Implementation (StormWater Pollution Prevention Prog)
As you know, the National Pollution Discharge Elimination System (NPDES) program
regarding monitoring and control of sanitary sewage treatment and discharge has
been in place for decades. The NPDES, Phase II program goal is to reduce storm
. water pollutant discharge. Phase II requires that we develop a Hopkins storm water
pollution prevention program - designed to reduce the discharge of pollutants from our
storm sewer system. Specifically, the State law requires that we submit an application
for a NPDES, Phase II permit by March 10, 2003. The permit application must define
best management practices (BMPs) and measurable goals for several control
measures. These control measures are as follows:
. Public Education and outreach
This measure includes educational materials specific to storm water
impacting activities; coordination with nonprofits, community groups,
watershed districts, school districts, etc.; and at least one public meeting
addressing the city's program. The Minnehaha Creek Watershed District will
be playing a large role in helping us meet the requirements of this control
measure. The Minnesota Erosion Control Association has also stated they
will be putting together an education package geared towards helping cities
meet this requirement.
. Public Participation/involvement
This has to do with the public meeting/s and, generally, affording interested
persons the opportunity to comment on the city's pollution prevention
. program.
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. Illicit discharge detection and elimination
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We must develop a storm sewer map showing all pipes, control structures,
treatment devices, and outfalls. During the past couple years, we have been
field-verifying our system and already have a GIS map developed. We also
must develop a program to prohibit, detect, and enforce, through ordinance,
non-storm water discharges into our system.
. Construction site storm water runoff control
We must develop, implement, and enforce a program to reduce pollutant
runoff from construction activities disturbing one acre or more. This we
already are doing - we just need to write our procedures and ordinance
requirements into the pollution prevention plan.
. Post-construction storm water management
This item addresses storm water runoff from new developments or
redevelopments. This we, in conjunction with the watershed districts, have
been doing for some time, i.e., requiring structural BMPs (stormceptors,
detention ponds, etc., along with operation and maintenance requirements).
. . Pollution prevention/good housekeeping for municipal operations
This item includes developing systematic procedures for annual inspections,
record keeping, street sweeping and cleaning of all structural pollution
controls (grit chambers, separators, outfalls, sediment basins, ponds). It also
includes an operation/maintenance program, including employee training, to
prevent or reduce pollutant runoff from municipal operations (park/open
space maintenance, fleet and building maintenance, land disturbances, etc.).
Some of the specific actions we'll have to take are:
. Set up a comprehensive public involvement and education program
. Set up a catch basin, pond, stormceptor inspection and maintenance
program
. Revise our ordinances to match NPDES, Phase II requirements and
enforce them
One of the most important elements of putting together our permit application is setting
up our proposed BMPs, goals and timelines for implementation. This is where getting
on-board with the proposed LMC effort will really help. Their proposed steering
committee process and resulting guidance will ensure that each city is consistent in
setting BMPs and developing goals that are acceptable to the MPCA, but not too
. difficult or expensive for cities. Steve Bot has attended a comprehensive workshop on
NPDES, Phase II implementation and he & I will be developing an estimated 2003
budget impact. I would propose that we join the LMC effort and we've already
contacted them to express our interest. I'd propose that we ask City Council on July 2
to approve the $5,000 contribution toward developing the guide pian.
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LMC 145 University Avenue West, St. Paul, MN 55103-2044
. phone: (651) 281-1200 · (800) 925.1122
TDD (651) 281-1290
L"a9UQ 0/ Minnesota CW"s LMC Fax: (651) 281.1299 · LMCIT Fax: (651) 281-1298
Citi"s pro....ati"9 c:<C<JR"""" W e1 Site: http://www.lmnc.org
June 7, 2002
Dear Mayor, City Engineer and City Administrator/Clerk:
Your NPDES Phase II Permit Application will be due on March 10, 2003. Will you be
ready?
The League of Minnesota Cities can help. A group of League members concerned about this
. stormwater regulation has met and decided to explore the possibility of developing a Pennit
"Guide Plan". This Guide Plan would be designed to help MS4 cities complete 50% to 65% of
their NPDES Phase II Permit Application and Storm Water Pollution Prevention Program
(SWPPP) using in-house resources.
A rough estimate of the cost to develop the Guide Plan is $250,000. This cost would need to be
split between 50 or more permitees to make it affordable and cost-effective - $5,000 per city. If
more cities join this effort, the cost for each city will be lower.
If enough cities express an interest in the project, a steering committee will be formee:o direct
the project. The steering committee would be involved in selecting a consultant and providing
assistance to the League in managing the endeavor.
The reasons to develop the Guide Plan are:
. Efficiency
Instead of every city struggling to start from the beginning, the League could develop
the Guide Plan and distribute it to many MS4 cities.
. Cost savings
Some cities have estimated their total NPDES Phase II Permit development cost at
$50,000 or more. Using the Guide Plan at a cost of only $5,000, a city could complete
half or more of the Permit and SWPPP using in-house resources.
. Support from the 1\1N Pollution Control Agency CMPCA)
. The MPCA strongly supports this effort by the League. MPCA staff will review and
"pre-approve" the Guide Plan. The MPCA considers the Guide a significant step in
moving this entire program forward quickly and effectively.
AN EQUAL OPPORTUNITY! AFPmMA TIVE ACTION EMPLOYER
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. . Consistency
This is a new program with a tight schedule. The Guide Plan will help make the
Permit Applications and SWPPP's more consistent. This will facilitate review by the
MPCA and provide a degree of security for the :MPCA and the cities in the event of
review by the USEP A.
The first step in developing the Guide Plan is to assemble a Steering Committee to determine
what elements should be in the Guide. Our first pass at defining these components is:
Guide Plan Elements
Permit task checklist
. Required tasks
. When they need to be done
Checklist for existing city programs
. Extensive list of possible existing programs
. Cover full range of city departments
. Match programs with:
0 Minimum Control Measures
0 Measurable Goals
List of acceptable BMP's
. Extensive list of possible BMP' s
. Match programs with:
. 0 Minimum Control Measures
0 Measurable Goals
Ordinances
. List required ordinances
0 Include recommended provisions
Employee training, educational materials & programs, state & county programs
. List of sources and descriptions of available materials and programs
. Match materials and programs with:
0 Minimum Control Measures
0 Measurable Goals
. Provide contact information
. Provide forms letters and agreements for outside providers
Funding options
. Provide details and options for funding mechanisms
The tasks remaining after a city completes its work with the Guide Plan might be:
. Fill in the gaps
. Write the Application & the SWPPP
. Public meetings
. Respond to comments
. Implement SWPPP
:. . Prepare Annual Reports
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. What do we need from your city?
If the Guide is to be useful, we need to move ahead quickly. We need funding to pay for the
development of the Guide Plan. We need representatives from cities to join the Steering
Committee.
Most importantly, we need responses quickly from the cities regulated under this program to the
following questions:
1- Is your city interested in joining with other cities to develop the Guide Plan?
2. Will your city contribute approximately $5,000 to the development of the Guide Plan?
3. Will a representative from your city participate on the Steering Committee?
Please respond to Remi Stone at the League of Minnesota Cities before June 28,2002 at 651-
281-1256 or rstone@lmnc.org. The Steering Committee will meet during July.
For additional information about NPDES Phase II and the Guide Plan, please attend the session
on these subjects at the LMC Annual Conference - June 19,2002, 10:45 AM to 12:00 noon.
Sincerely,
. PO-.tfY/diw
Jim Miller
Executive Director
Cc: Commissioner Karen Studders, J\.1PCA
Don Jakes, 1v1PCA
Gene Ranieri, AMJvI
Christopher Hood, Flaherty & Hood
Janette Brimmer, MCEA
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. Preliminary List from MPCA Board slideshow ~ 5/2812002 - 176 listings
Based on 2002 Census data & additional criterion
Albert Lea Elk River Maple Grove Sartell
Andover Empire Township Maple Plain Sauk Rapids
Anoka Excelsior Maplewood Sauk Rapids Township
Apple Valley Fairmount Marion Township Savage
Arden Hills Falcon Heights Marshall Shakopee
Austin Faribault Medicine Lake Shore view
Bemidji Farmington Medina Shorewood
Big Lake Fergus Fans Mendota South St. Paul
Big Lake Township Forest Lake Mentota Heights Spring Lake Park
Birchwood Village Fort Snelling Midway Township Spring Lake Township
Blaine Unorganized Minden Township Spring Park
Bloomington Fridley Minnetonka S1. Anthony
Brainerd Gem Lake Minnetonka Beach S1. Bonifacius
Brockway Township Golden Valley Minnetrista S1. Cloud
Brooklyn Center Grant Monticello S1. Cloud Township
Brooklyn Park Greenwood Moorhead S1. Joseph
Buffalo Ham Lake Moorhead Township S1. Joseph Township
Bums Township Hastings Mound S1. Louis Park
B urnsville Haven Township Mounds View S1. Michael
. Carver Haverhill Township New Brighton S1. Paul
Cascade Township Hermantown Township New Hope S1. Paul Park
Centervi1le Hibbing New DIm Stillwater
Champlin Hilltop Newport Sunfish Lake
Chanhassen Hopkins North Mankato Tanka Bay
Chaska Hugo North Oaks Vadnais Heights
Chaska Township Hutchinson North S1. Paul Victoria
Circle Pines Independence Northfield Waite Park
Cloquet Inver Grove Heights Oak Grove Watab Township
Columbia Heights Jackson Township Oakdale Wayzata
Coon Rapids La Crescent Oakport Township West Lakeland
Corcoran La Crescent Township Orono Township
Cottage Grove Lake Elmo Osseo West S1. Paul
Credit River Township Laketown Township Owatonna White Bear Lake
Crystal Lakeville Pine Springs White Bear Township
Dayton Landfall Plymouth Willemie
Deephaven Lauderdale Prior Lake Willmar
Dellwood Le Sauk Township Proctor Winona
Dilworth Lexington Ramsey Woodbury
Dresbach Township Lilydale Red Wing Woodland
Duluth Lino Lakes Rice Lake Township Worthington
Duluth Township Little Canada Richfield
Eagan Long Lake Robbinsdale
East Bethel Loretto Rochester
. East Grand Forks Louisville Township Rochester Township
Eden Prairie Mahtomedi Rosemount
Edina Mankato Roseville
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