DRAFT. Texas Pollutant Discharge Elimination System Permit No. WQ April, 2012

Transcription

1 Texas Pollutant Discharge Elimination System Permit No. WQ DRAFT April, 2012 Prepared by: City of Dallas Trinity Watershed Department 320 East Jefferson Boulevard, Room 108 Dallas, Texas 75203

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3 FINAL ~DRAFT~ STORMWATER MANAGEMENT PROGRAM TPDES Permit No. WQ APRIL, 2012 Prepared by: City of Dallas Trinity Watershed Department 320 East Jefferson Boulevard, Room 108 Dallas, Texas 75203

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5 TABLE OF CONTENTS List of Abbreviations and Acronyms iii 1.0 INTRODUCTION DESCRIPTION OF THE PERMIT AREA SWMP REVISIONS AND RATIONALE FOR REVISIONS STORMWATER MANAGEMENT PROGRAM ORGANIZATION STORMWATER MANAGEMENT PROGRAM ELEMENTS 5 1 Element 1 MS4 Maintenance Activities 5 3 Element 2 Post Construction Stormwater Control Measures 5 15 Element 3 Illicit Discharge Detection and Elimination 5 19 Element 4 Pollution Prevention and Good Housekeeping 5 30 Element 5 Industrial and High Risk Runoff 5 39 Element 6 Construction Site Stormwater Runoff 5 45 Element 7 Public Education, Outreach, Involvement and Participation 5 51 Element 8 Monitoring, Evaluation and Reporting REFERENCES 6 1 APPENDICES Appendix A Watershed Maps Appendix B Interim Bacteria Reduction Plan Appendix C Permitted Entities within the MS4 Appendix D Water Quality Monitoring Program FIGURES Figure 2 1 MS4 Watershed Map Figure 4 1 Matrix of City Department SWMP Element Participation Figure 4 2 SWMP Organizational Chart TABLES Table 2 1 Watersheds and Subwatersheds within the City of Dallas Permit Area Table 2 2 Classified Water Bodies, and Designated Uses Table 2 3 Water Quality Impairment Table 3 1 Comparison of SWMP Elements Table 5 1 Element 1: MS4 Maintenance Activities Table 5 2 Element 2: Post Construction Controls Table 5 3 Element 3: Illicit Discharge Detection and Elimination Table 5 4 Element 4: Pollution Prevention and Good Housekeeping Table 5 5 Element 5: Industrial and High Risk Stormwater Runoff Table 5 6 Element 6: Construction Site Stormwater Runoff Table 5 7 Element 7: Public Education, Outreach, Involvement and Participation Table 5 8 Element 8: Monitoring, Evaluation and Reporting City of Dallas MS4 Page i Final Draft SWMP

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7 List of Abbreviations and Acronyms AD ALU BMPs BOD5 CAFOs CCTV CFR CFU CGP CRMS CSN CWA CY DCAD DSHS EDMS ELGs EMS EPA FEMA GIS GPS HC3 HHW HUC IBI IBRP ISO iplan IPM iswm LEED LID MCM MEP MS4 MSGP MPN NC NCTCOG NEC NELAP Administrative Directive Aquatic Life Use Best Management Practices Biochemical Oxygen Demand, measured over a 5 day period Confined Animal Feeding Operations Closed Circuit Television Code of Federal Regulations Colony Forming Units (Unit measurement for bacteria) Construction General Permit (Discharge Permit for Construction Activities) Customer Response Management System Construction Site Notice Clean Water Act Cubic Yards Dallas County Appraisal District Texas Department of State Human Services Environmental Data Management System Effluent Limit Guidelines Environmental Management System Environmental Protection Agency Federal Emergency Management Agency Geographic Information System Global Positioning System Household Chemical Collection Center Household Hazardous Waste Hydrologic Unit Codes Index of Biotic Integrity Interim Bacteria Reduction Plan International Standards Organization Implementation Plan Integrated Pesticide Management Program Integrated Stormwater Management Program Leadership in Energy and Environmental Design Low Impact Development Minimum Control Measure (also referred to as a Permit Element) Maximum Extent Practicable Municipal Separate Storm Sewer System Multi Sector General Permit (Discharge Permit for Industrial Facilities) Most Probable Number (Measure for bacteria) Non compliance North Central Texas Council of Governments No Exposure Certification National Environmental Laboratory Accreditation Program City of Dallas MS4 Page iii Final Draft SWMP

8 List of Acronyms and Abbreviations (Continued) NEC NOC NOI NOT NOV NPDES PCBs PHF PY# QAPP RBP RWWCP SARA SCM SCN SOG SOP SSO SWIMs SWM SWMP SWPPP TAC TCEQ TCRP TDS TMDLs TPDES TPWD TRA TSS TWM UOTM WWTF No Exposure Certification Notice of Change Notice of Intent Notice of Termination Notice of Violation National Pollutant Discharge Elimination System Poly Chlorinated Bi phenols Pesticides, Herbicides, and Fertilizer Permit Year Number Quality Assurance Project Plan Rapid Bioassessment Protocols Regional Wet Weather Characterization Program Superfund Amendment and Reauthorization Act Stormwater Control Measure Small Site Construction Notification Standard Operating Guidance Standard Operating Procedure Sanitary Sewer Overflow Stormwater Information Management System Stormwater Management Program Stormwater Management Plan Stormwater Pollution Prevention Program Texas Administrative Code Texas Commission on Environmental Quality Texas Clean Rivers Program Total Dissolved Solids Total Maximum Daily Load Texas Pollutant Discharge Elimination System Texas Parks and Wildlife Department Trinity River Authority Total Suspended Solids Trinity Watershed Management Department Used Oil and Toxic Materials Wastewater Treatment Facility City of Dallas MS4 Page iv Final Draft SWMP

9 1.0 INTRODUCTION As the operator of a Phase I Municipal Separate Storm Sewer System (MS4), the City of Dallas (City) is required under Texas Pollutant Discharge Elimination System (TPDES) Permit Number WQ (permit) to develop and implement a comprehensive Stormwater Management Program (SWM). This permit requires the City to develop, implement, and revise, as necessary, a comprehensive Stormwater Management Plan(SWMP) which includes pollution prevention measures, treatment or pollutant removal techniques, stormwater monitoring, use of legal authority, and other appropriate means to control the quality of stormwater discharged from the MS4 to Waters of the United States (U.S.). In addition, each element of the plan must be developed to include measureable goals, when feasible. The SWM is guided by the written SWMP document that describes the various control measures and other activities the City will undertake to implement the MS4 permit. The SWMP document includes an overview of the ordinances and other regulatory mechanisms that provide the legal authority to implement and enforce the requirements of the permit, and outlines the Stormwater Control Measures (SCMs) used to meet the Permit requirements. These SCMs are developed to protect water quality, and satisfy requirements of the TPDES permit as issued by the Texas Commission on Environmental Quality (TCEQ) under authority of the United States Environmental Protection Agency (EPA). Each element of the SWMP has been outlined to include measurable goals whenever feasible. The SWMP, taken as a whole, includes the controls necessary to effectively prohibit the discharge of nonstormwater into the MS4, and reduce the discharge of pollutants from the MS4 to the maximum extent practicable. The SWMP is intended to cover the term of the permit and will be updated as necessary or as required by the TCEQ, to ensure compliance with Section 402 of the Clean Water Act (CWA), Chapter 26 of the Texas Water Code, applicable EPA and TCEQ regulations, and the requirements of the MS4 permit. The SCMs and Best Management Practices (BMPs) included in the SWMP constitute effluent limitations for the purposes of compliance with the requirements of 30 Texas Administrative Code (TAC) Chapter 319, Subchapter B, related to Hazardous Metals, unless otherwise limited in the permit. The SWMP is comprised of the following sections: o Section 1.0 Introduction: provides the purpose and general format of the SWMP; o Section 2.0 Description of the Permit Area: provides a description of the geographic boundary of the MS4, the listed and classified waters, and watersheds comprised within the corporate boundaries of the City; o Section 3.0 SWMP Revisions and Rationale for Revisions: provides a detailed description of the proposed revisions to the existing SWMP to be considered for this new SWMP and permit term; o Section 4.0 SWMP Program Organization: provides an overview of the program including roles and responsibilities for implementation of the SWMP; o Section 5.0 SWMP Elements: provides a summary of each SWMP element, related SWMP activities, measurable goals, SCMs, and implementation schedule. This SWMP replaces and supersedes any and all previous SWMPs developed for the City MS4 permit. City of Dallas MS4 Page 1 1 Final Draft SWMP

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11 2.0 DESCRIPTION OF THE PERMIT AREA The permit area includes the incorporated areas of the City of Dallas, including lands within Dallas, Collin, Denton, Rockwall and Kaufman Counties. The permit boundary will be expanded, as necessary, to include any newly incorporated areas. The permit area is comprised of a predominantly developed urban area within the Blackland prairie ecoregion. The City of Dallas permit area represents approximately 246,208 acres or square miles. There are digit Hydrologic Unit Code (HUC) defined watersheds that are located wholly or partially within the City limits. Table 2 1 provides a summary of the watersheds and subwatersheds with respective areas that are included in the City s Permit area. The sub watershed names generally correspond with the watershed names used in the prior SWMP, to allow water quality trend analyses over time. Figure 2 1 on page 2 7, illustrates the general area, classified waterbodies and representative watersheds included in the City s permit area. Maps that illustrate land use, the MS4 layout and outfalls, and other key system features are included in Appendix A. 12 Digit HUC Table 2 1 Watersheds and Subwatersheds in the City of Dallas MS4 Permit Area Area Sub watershed Watershed Name (Square Name Miles) City of Dallas White Rock Creek Cottonwood Creek East Fork Trinity River Lower White Rock Creek Drainage Area (Acres) 22, Cottonwood Creek 27, Deep Branch Ten Mile Creek 32 Lower Ten Mile Creek 20, Low Branch Mountain Creek 48 Joe Pool Lake Dam 32, Headwaters Ten Mile Creek 45 Ten Mile Creek 29, Fish Creek Mountain Creek Lake 43 Mountain Creek Lake Dam 26, Headwaters Five Mile Creek 38 Upper Five Mile Creek 24, Cottonwood Creek Mountain Creek Lake 29 Mountain Creek Lake Dam 19, Hickory Creek Parsons Slough 30 Parson s Slough 18,992 South Dallas 3,462 Southeast Dallas 4, Five Mile Creek Trinity River 47 Elam Creek 2,897 Lower Five Mile Creek 8,103 Trinity River above Ten 4,028 Newton Creek 7, Mustang Creek East Fork Trinity River 38 East Fork Trinity River 24,611 City of Dallas MS4 Page 2 1 Final Draft SWMP

12 Table 2 1 Watersheds and Subwatersheds in the City of Dallas MS4 Permit Area 12 Digit HUC Watershed Name Area Sub watershed (Square Name Miles) Main Stem above Prairie Creek Trinity River 58 Trinity River Turtle Creek Trinity River North Mesquite Creek East Fork Trinity River South Mesquite Creek Delaware Creek West Fork Trinity River 34 Drainage Area (Acres) 24,885 Prairie Creek 12,202 Dallas West Bank 11,076 West Dallas 1,929 Cedar Creek 6,380 Coombs Creek 2, North Mesquite Creek 23,929 Upper South Mesquite Creek 17,840 Delaware Creek 9,658 Lower Mountain Creek 12, Headwaters Turtle Creek 34 Dallas East Bank 15,285 Dallas Warren 6, Rowlett Creek East Fork Trinity River 24 Rowlett Creek 15, Cottonwood Branch Hackberry Creek 21 Elm Fork Trinity River 13, Bachman Branch Elm Fork Trinity River 42 Northwest Dallas 6,314 Joe s Creek 4,588 Lower Bachman Creek 2,282 Upper Bachman Creek 6,147 Elm Fork Trinity River 7, White Rock Creek White Rock Lake 35 White Rock Dam 22,713 Farmer s Branch 8, Farmers Branch Elm Fork Trinity River 25 Elm Fork Above Cottonwood Branch 7, Duck Creek 42 Upper Duck Creek 27, Rowlett Creek Lake Ray Hubbard 27 Rowlett Creek 17, Grapevine Creek Elm Fork Trinity River Floyd Branch White Rock Creek 33 Hutton Branch 9,237 Grapevine Creek 10,205 Upper/Middle White Rock Creek 21, Camp Creek Lake Ray Hubbard 40 Camp Creek 25,619 City of Dallas MS4 Page 2 2 Final Draft SWMP

13 12 Digit HUC Table 2 1 Watersheds and Subwatersheds in the City of Dallas MS4 Permit Area Area Sub watershed Watershed Name (Square Name Miles) Indian Creek Elm Fork Trinity River 33 Elm Fork Above Denton Creek Drainage Area (Acres) 21, Muddy Creek Lake Ray Hubbard 48 Muddy Creek 30, Headwaters White Rock Creek 31 Upper White Rock Creek 19,972 TOTAL WATERSHED AREA: ,786 The entire permit area is included in the Upper Trinity River Basin (Basin number 8 in the Texas watershed system). Table 2 2 includes the classified water bodies within the permit area and their designated use(s). Table 2 2 Classified Water Bodies, and Designated Uses Water Body Segment Number Classified Water Use(s) East Fork Trinity River 0819 Primary contact recreation and intermediate aquatic life use Lake Ray Hubbard 0820 Elm Fork Trinity River below Lewisville Lake 0822 Primary contact recreation, public water supply*, and high aquatic life use Primary contact recreation, public water supply, and high aquatic life use White Rock Lake 0827 Primary contact recreation and high aquatic life use Joe Pool Lake 0838 Primary contact recreation, public water supply, and high aquatic life use Mountain Creek Lake 0841A Primary contact recreation and intermediate aquatic life use Lower West Fork Trinity River 0841 Primary contact recreation and intermediate aquatic life use Upper Trinity River 0805 Primary contact recreation and high aquatic life use East Fork Trinity River 0819 Primary Contact Recreation, High Aquatic Life * Segment 0820 (Lake Ray Hubbard) is owned and managed by the City of Dallas for water supply purposes; however, the City s MS4 system currently does not discharge into this water body. The unclassified receiving waters have a presumed minimum aquatic life use as high aquatic life use for perennial streams, limited aquatic life use for intermittent streams with perennial pools, and no significant life use for intermittent streams. The designated uses for a water body determine the types of general and numerical water quality criteria that are used to assess compliance. The general and numerical criteria which form the stream water quality standards are provided in 30 TAC City of Dallas MS4 Page 2 3 Final Draft SWMP

14 Using these criteria, Segment Numbers 0805, 0819, 0822, and 0841 are currently listed on the State's inventory of impaired and threatened waters (the Clean Water Act (CWA) Section 303(d) list). Table 2 3 summarizes the water quality impairments within the permit area. Table 2 3 Water Quality Impairment Water Body Segment Number Water Quality Impairment East Fork Trinity River 0819 Sulfate, total dissolved solids (TDS), and chlorides Lake Ray Hubbard 0820 No Identified impairment at this time Elm Fork Trinity River below Lewisville Lake 0822 Bacteria White Rock Lake 0827 No identified impairment at this time Joe Pool Lake 0838 No identified impairment at this time Mountain Creek Lake Lower West Fork Trinity River 0841A 0841 Chlordane and other legacy pollutants, polychlorinated biphenols (pcbs) in fish tissue Bacteria, chlordane, polychlorinated bi phenols (pcbs) in fish tissue Upper Trinity River 0805 Bacteria, chlordane, polychlorinated bi phenols (pcbs) in fish tissue * Segment 0820 (Lake Ray Hubbard) is owned and managed by the City of Dallas for water supply purposes; however, the City s MS4 currently does not discharge into this water body. Total Maximum Daily Loads (TMDLs) and an implementation plan (i Plan) were established in 2001 to address water quality impairment from chlordane and other legacy pollutants (primarily pesticides) for the affected stream segments. A TMDL is an estimate of the allowable pollutant load that a water body can accept, and still be in compliance with the water quality standards for the designated use. Legacy pollutants are substances whose use has been banned or severely restricted by EPA. These substances have a slow rate of decomposition and strong sorption to organic matter and tissue; therefore, they frequently remain at elevated levels in the environment for many years after their widespread use has ceased. Chlordane and PCBs have accumulated in the sediments of these segments. As the existing sediments migrate through the water bodies and new sediment deposition occurs, fluctuations in the concentration of chlordane and PCBs in these segments are expected. Recent sediment and fish tissue samples collected in some of these water bodies suggest that legacy pollutant levels are diminishing. In July 2010, the Texas Department of State Health Services (DSHS) issued a no consumption advisory for Lower West Fork Trinity River and Upper Trinity River due to elevated levels of PCBs and dioxins in fish; however, they indicated that chlordane was no longer considered to be a contaminant of concern (TCEQ, 2011). The TCEQ has established two (2) TMDLs for Indicator Bacteria in Upper Trinity River (Segment 0805)(TCEQ 2011a). Two (2) new TMDLs are being drafted within the drainage area covered by this City of Dallas MS4 Page 2 4 Final Draft SWMP

15 permit: one TMDL for Indicator Bacteria in Cottonwood Branch and Grapevine Creek (Assessment Units 0822A and 0822B), and one TMDL for Indicator Bacteria in the Lower West Fork Trinity River (Segment 0841). The City is working with the North Central Texas Council of Governments (NCTCOG) Bacteria Task Force to develop a regional i Plan to reduce bacterial loading to affected stream segments. The City s draft Interim Bacteria Reduction Plan (ibrp) is attached to this SWMP as Appendix B. TMDLs are in development for pcbs in fish tissue; at present, the TMDL process for this constituent has not been finalized, or approved by the TCEQ or EPA. Total Dissolved Solids (TDS) and sulfates have been identified in segments of the East Fork Trinity River in excess of surface water standards. The TCEQ is continuing data collection and assessment of water quality conditions for this water body. Other pollutants of concern are floatables, seasonal dissolved oxygen levels and petroleum products. SCMs to address these and other potential pollutants within the MS4 have been incorporated into this SWMP, along with measurable goals and water quality monitoring. In particular, the SCMs and BMPs that are included in the IBRP are highlighted in green shading in the element tables to illustrate how these measures are integrated into the SWMP. City of Dallas MS4 Page 2 5 Final Draft SWMP

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19 3.0 SWMP REVISIONS AND RATIONALE FOR REVISIONS This SWMP proposes several revisions to strengthen the program and streamline program administration. The revisions to the SWMP have been made in consideration of State and Federal water quality regulations and other guidance including, but not limited to: 40 CFR (d)(1)(iii)(B), the City's new TPDES MS4 permit, the United States Environmental Protection Agency (EPA) MS4 Program Evaluation Guidance (January 2007), the National Research Council, Urban Stormwater Management Report (NRC, 2008) and the recent U.S. EPA MS4 Permit Improvement Guide (April, 2010). The SWMP revisions and the related rationale are as follows: 1. Watershed definitions: The City has revised the watershed definitions listed in the SWMP from the previous Permit term to conform to the federally defined 12 digit Hydrologic Unit Code (HUC) watershed definitions. In 2009, the United States Geological Survey (USGS) completed watershed delineation for the United States, using a standard national hierarchical system that is generally based upon hydrologic surface features. The 12 digit HUC watersheds have been locally adopted for use by the Federal Emergency Management Agency (FEMA) for floodplain management, and by the North Central Texas Council of Governments (NCTCOG) for the regional watershed monitoring program. Map review and field reconnaissance were used to conform the 38 watersheds that are wholly or partially located within the City MS4 as defined in the prior SWMP, into 32 comparable 12 digit HUC defined watersheds. The actual area managed by the City MS4 program does not change, and there are no related changes to the City s water quality monitoring programs. This change in watershed definition simply provides greater data consistency with other regional watershed based stormwater quality and floodplain management programs. 2. Nomenclature: The term Best Management Practice (BMP) has been replaced with Stormwater Control Measure (SCM). This is consistent with the recommendations of the National Research Council Urban Stormwater Report (NRC, 2008, p. 283). SCMs are defined as measures used to prevent stormwater discharges from degrading local water bodies. The use of the term SCM is specific to the field of stormwater. In contrast, BMP is a general term may not be clearly defined for stormwater activities. 3. SWMP Element Definition: Consistent with MS4 Permit instructions that encourage SWMP modifications and changes that strengthen, update, replace, de emphasize, or remove SWMP elements, the City has re organized the current SCMs into new SWMP elements. The 11 elements from the prior SWMP have been reduced to eight (8) elements that correspond to the elements as outlined in the new Permit. These changes help align the SWMP with national movements towards greater consistency in the Phase I and Phase II MS4 program requirements. Consideration of State and Federal regulations including 40 CFR (d)(1)(iii)(B), the City's new TPDES MS4 permit, the EPA MS4 Program Evaluation Guidance (January 2007) and the recent EPA MS4 Permit Improvement Guide (April 2010) has been incorporated into the development of the proposed elements. Table 3 1, on the following page, provides a comparison of the eight (8) proposed elements compared to the existing eleven (11) elements. City of Dallas MS4 Page 3 1 Final Draft SWMP

20 Proposed SWMP Elements 1 MS4 Maintenance Activities 2 Post Construction Controls Illicit Discharge Detection and Elimination Pollution Prevention and Good Housekeeping for Municipal Operations Industrial and High Risk Stormwater Runoff Table 3 1 Comparison of SWMP Elements 1 Structural Controls 3 Roadways 6 IDDE Floatables* 2 Prior SWMP Elements Areas of New Development and Significant Redevelopment 4 Flood Control Projects 6 Illicit Discharges and Improper Disposal Pollution Prevention and Good Housekeeping** 5 Pesticide, Herbicide, and Fertilizer Application 7 Spill Prevention and Response 8 Industrial and High Risk Runoff 6 Construction Site Stormwater Runoff 9 Construction Site Runoff 7 Public Education, Outreach, Involvement and Participation 10 Public Education and Outreach 8 Monitoring, Evaluation and Reporting 11 Monitoring and Screening Programs * Note: IDDE Floatables were listed under Element 6 IDDE in the prior permit, but are addressed through the various structural controls in Element 1 Structural Controls ** Pollution Prevention and Good Housekeeping is a new Element 4. SWMP Format: The format of the element definition within the SWMP has been restructured to include a brief description of the purpose and overview of each element, the corresponding regulatory permit requirement(s), and an outline of the related activities, followed by a table containing the applicable SCMs, measurable goals as metrics to be tracked, and implementation schedule. Those SCMs that comprise a part of the Interim Bacteria Reduction Plan are highlighted in green in each table. This streamlines the format of the SWMP, and is also intended to enhance future documentation of SWMP performance. 5. Other Minor Changes: Other minor changes that have been made to the SWMP include: a) Short term planning activities or studies that were completed during the last permit cycle ( ) have been removed or updated with new goals. b) The SCMs for training and outreach efforts in support of all of the permit elements have been compiled into Element 7, Public Education, Outreach, Involvement and Participation. c) New general program delivery goals have been included to address identified pollutants of concern and measurable behavior changes, to provide program flexibility and responsiveness over the permit term. City of Dallas MS4 Page 3 2 Final Draft SWMP

21 4.0 STORMWATER MANAGEMENT PROGRAM ORGANIZATION As a part of the MS4 permit requirements, the City has developed this SWMP to guide and facilitate its stormwater management program. The goals of the SWMP are protection and improvement of stormwater and surface water quality through the implementation of a variety of activities including, but not limited to, inspection, maintenance, enforcement, education, planning, design, and monitoring. 4.1 Program Responsibilities The City Manager s Office is the designated operator for the City of Dallas for this MS4 Permit. The City Manager is responsible for developing and implementing policies established by the Mayor and City Council, recommending the budget for accomplishing the work of the City, appointing and supervising personnel not directly appointed by the Mayor and City Council, enforcing the City laws and ordinances, and recommending improvements to the City s operations. The City Manager s Office has designated the Trinity Watershed Management Department to manage the SWMP, and has delegated the responsibility and authority to enforce the permit requirements. Stormwater Management, a section of the Trinity Watershed Management, manages the SWMP, performs compliance and enforcement inspections, water quality monitoring, stormwater specific outreach and citizen response, develops annual reports, and provides fiscal program management. Day to day SWMP activities are performed by 16 different City departments. Figure 4 1 provides a matrix of City Departments and SWMP Element participation. Figure 4 1 Matrix of City Department SWMP Element Participation 1 MS4 Maintenance 2 Post Construction Controls 3 IDDE 4 Pollution Prevention & Good Housekeeping 5 Industrial 6 Construction 7 Public Education /Outreach, Involvement 8 Monitoring, Evaluation & reporting Trinity Watershed Management X X X X X X X X Aviation X X X X X Equipment & Building Services X X X X X City Attorney s Office X X X Code Compliance X X Courts and Detention Services City Marshalls's Office X X X X Dallas Fire Rescue X X Dallas Water Utilities X X X X X X X Dallas Police Department X X X Strategic Customer Services Ofc of Environmental Quality X X X Park and Recreation X X X X X X Public Information Office X X Public Works X X X Sanitation X X X X Street Services X X X X Sustainable Development & Construction X X City of Dallas MS4 Page 4 1 Final Draft SWMP

22 An organizational chart showing the roles and responsibilities for implementing the SWMP is provided as Figure 4 2. Stormwater Permit Related Activities City Council Dallas Water Utilities Planning & Capital Projects Cesar Baptista, P.E. Assistant Director City GIS Casey Gardner SWM GIS Team City Manager Trinity Watershed Management Department Stormwater Management Section Program Management Mary Suhm City Manager Jill A. Jordan, P.E. - ACM Kelly High Director Sarah Standifer - Assistant Director Susan Alvarez, P.E., CFM Sr. Program Manager 1. MS4 Maintenance Trinity Watershed Management Street Services Equipment & Bldg Services Dallas Water Utilities Park &Recreation 3. IDDE: Trinity Watershed Management Park & Recreation Code Compliance Dallas Water Utilities Ofc. of Environmental Quality City Marshall s Office Dallas Fire Rescue City Attorney s Office 5. Industrial & High-Risk Stormwater Runoff: Trinity Watershed Management Equipment & Bldg Services Dallas Water Utilities Sanitation Aviation 7. Public Education, Outreach, Involvement & Participation: Trinity Watershed Management Dallas Water Utilities Ofc of Environmental Quality Public Information Office NCTCOG (Non-City) 2. Post Construction Controls: Trinity Watershed Management Park & Recreation Equipment & Bldg Services Sustainable Dev & Construction City Design Studio Public Works 4. Pollution Prevention & Good Housekeeping Trinity Watershed Management Sanitation Street Services Ofc. of Environmental Quality Equipment & Bldg Services Dallas Water Utilities Dallas Fire Rescue Park and Recreation Dallas Police Department 6. Construction Site Stormwater Runoff: Trinity Watershed Management Public Works Dallas Water Utilities Park & Recreation 8. Monitoring & Screening Programs: Trinity Watershed Management Dallas Water Utilities NCTCOG (Non-City) Trinity River Authority (Non-City) Figure 4.2 Program Organization A SWM program staff member is designated to lead each element and is responsible for convening regular meetings with key personnel from the participating departments to coordinate performance measures, discuss related technical issues, potential code or ordinance changes and to provide regulatory updates or other information that may affect performance of the activities of that element. Performance measures and budget status are monitored on a quarterly basis. 4.2 Legal Authority The City has established the legal authority to carry out all aspects of the SWMP, including the authority to control discharges to and from those portions the MS4 over which it has jurisdiction to: 1. Control the contribution of pollutants to the MS4 by storm water discharges associated with industrial activity and the quality of storm water discharged from sites of industrial activity; 2. Prohibit illicit discharges to the MS4; 3. Control the discharge of spills and the dumping or disposal of materials other than storm City of Dallas MS4 Page 4 2 Final Draft SWMP

23 water (e.g. industrial and commercial wastes, trash, used motor vehicle fluids, leaf litter, grass clippings, animal wastes) into the MS4; 4. Require compliance with conditions in ordinances, permits, contracts, or orders; and 5. Carry out all inspection, surveillance and monitoring procedures necessary to determine compliance with permit conditions. Ordinances, and other regulatory mechanisms that provide the legal authority necessary to implement and enforce the requirements of this permit, include, but are not limited to, the following sections of the Dallas City Code: Volume 1, Chapter 19, Article IX Storm Drainage System. Volume II, Chapter 49 Water and Wastewater. Volume III, Chapter 51A, Part II of the Dallas Development Code, Article V, Division 51A Floodplain Regulations. Volume III, Chapter 51A, Part II of the Dallas Development Code, Article VIII, Section 51A Storm Drainage Design. City of Dallas Ordinance as amended by Ordinance Green Building Program. These codes and ordinances provide definitions of allowable and prohibited discharges. They also contain penalty provisions to ensure compliance with construction and industrial requirements, to control the discharge of spills and dumping or disposal of materials other than stormwater, require the removal of illicit discharges, and to address noncompliance with permit terms. The City uses an escalating enforcement response, with increased enforcement actions applied to ongoing or egregious noncompliance. These codes and ordinances are reviewed and updated as necessary to address encountered compliance situations, trends in noncompliance and/or other regulatory requirements. City of Dallas MS4 Page 4 3 Final Draft SWMP

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25 5.0 STORMWATER MANAGEMENT PROGRAM ELEMENTS This section provides a brief description of each program element, with the applicable permit reference section(s), and the planned activities to prevent the discharge of pollutants into waters of the state. Each element description is followed by a table that summarizes the planned SCMs, measurable goals, and schedule for implementation. The measures implemented within each element as a part of the Cities Interim Bacteria Reduction Plan are highlighted with green shading. City of Dallas MS4 Page 5 1 Final Draft SWMP

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27 ELEMENT 1: MS4 MAINTENANCE ACTIVITIES The storm drainage system requires regular maintenance to make sure that the control structures intended to prevent pollution are functioning as intended, and to mitigate/reduce negative impacts to water quality. Implementing a comprehensive maintenance program to address structural controls, floatables, and roadways improves the integrity of the storm sewer system and decreases the potential for the discharge of pollutants to the MS4. Applicable Stormwater Control Measures A. Structural Controls Structural controls within the MS4 that are owned, operated and maintained by the City include the conveyances (creeks and channels) in addition to the engineered control systems: drainage inlets and piping systems, culverts, sumps with pump stations and trash racks, detention and retention ponds, litter booms, in line stormwater interceptor structures, and the Trinity River levees. Ongoing operations and maintenance of these structural controls can reduce the discharge of pollutants from the MS4 to the MEP. Permit Reference [Part III, Section B.2.a.i]: To the maximum extent practicable (MEP), the permittee shall operate and maintain the MS4, including any storm water structural controls, in such a manner as to reduce erosion and the discharge of pollutants. At present, the City manages a storm drainage system that drains 385 square miles within five counties. The MS4 infrastructure includes at least: 67,000 Inlets 1,800 miles Storm Sewers 7 Pressure Sewers 9 Street Pump Stations 33 miles Levees 11 Sump areas with 9 Pump Stations 100 Inline Stormwater Interceptors 200 Retention/Detention Ponds & Lakes 11,000 Drainage outfalls 180 miles Creeks and Channels The MS4 maintenance program for structural controls includes a regular program of inspections, repair and maintenance activities for the above infrastructure. The City uses a tiered maintenance approach to prioritize cleaning and repair activities and opportunities to incorporate water quality improvement measures. City of Dallas MS4 Page 5 3 Final Draft SWMP

28 A.1 Pipe Conveyance System Repair and Maintenance The storm drain piping system and City owned culverts are segments of the MS4 that the City maintains to provide flood conveyance, and to limit pollutant transport. The City operates at least 1,800 miles of gravity storm sewer, 7 different pressure sewer systems and 9 street pump stations. Regular inspections, maintenance and repair for these pump stations, pipes, and culverts can prevent blockages, reduce flooding and reduce pollution to the MS4. Inspections are conducted through Closed Circuit Televiewing (cctv), with associated prioritization for any necessary cleaning, and repair. A.2 Water Quality and Flood Control Structures Sump areas, levees, inlets, and retention and detention ponds are part of the City s structural controls that are used to convey stormwater and collect material from the drainage system that may have the potential to degrade surface water quality. The core of the City is protected by a 33 mile long system of levees, with associated sumps to capture local drainage, and pump stations to convey it to the river. The City provides a fairly vigorous program of levee inspection, maintenance and repairs in accordance with U.S. Army Corps of Engineers requirements. Maintenance includes regular mowing, vegetation and debris removal and erosion repairs as necessary. The 11 maintained sump areas (with associated pump stations and trash racks) include: Able, Baker, Charlie, Delta, Eagle Ford, Frances Street, Hampton, Noble Branch, Pavaho, Rochester and Trinity Portland Sumps. Activities within the levees and sumps includes regular inspections, erosion repairs, de silting as necessary, and cleaning of the trash racks, and sump areas to remove collected debris. The City maintains over 67,000 curbside inlets to convey street drainage into the storm drainage system, and to trap sediment and debris to prevent system clogging, and or being transporting downstream into the Trinity River. The City performs regular inspections, cleaning and repairs of these inlets. The City has installed inlet protection devices at the City service centers, the Zoo, and several other areas with high pedestrian use. These devices are effective at preventing solids from entering the storm drainage system, but can require more frequent maintenance and replacement, to maintain effectiveness, and prevent localized street flooding. There are also over 200 retention/detention basins, and 1,800 miles of creeks and channels on City property. Maintenance of these facilities includes regular inspections, minor erosion repairs, and desilting as necessary to maintain flood control capacity. The City also responds to citizen service requests concerning water quality related to the creeks, ponds and channels within the MS4. While all water quality requests are investigated immediately upon notification, of particular concern are the fish kills that can occur with abrupt changes in temperature, long hot, dry periods, and other system disturbances. The investigation includes water quality sampling, fish retrieval and monitoring over a period of several days. The fish are retrieved and assessed for potential cause of mortality. Water quality is sampled at the site where the dead fish are observed, and at key locations above and below that location, and is monitored daily until water quality resumes City of Dallas MS4 Page 5 4 Final Draft SWMP

29 ambient conditions. The TCEQ and Texas Park and Wildlife Department (TPWD) are notified of fish kill events that cause more than 50 mortalities, and a formal report is provided following the investigation. A.3 Stormwater Interceptor Program Stormwater interceptors remove captured materials and floatables from the storm drainage system. At present, the City maintains over 100 in line stormwater interceptors at various City facilities. Regularly inspecting, maintaining and cleaning the in line stormwater interceptors prevents system failure, backup, vectors, overflow, odors and other biochemical reactions from occurring. B. Floatables Floatables form the most visible indication of man made pollution to surface water. The City has implemented a multi faceted floatables program to address this issue. In addition to structural controls such as inlets and trash racks, the City also uses litter booms, special event litter protection, and litter abatement programs to reduce the discharge of floatables into the MS4. These measures augment an aggressive regional media campaign that included in the Public Outreach and Education program (Element 7). Permit Reference [Part III, Section B.2.a.ii]: The permittee shall implement a program to reduce the discharge of floatables (for example, litter and other human generated solid refuse) into the MS4. The permittee shall include source controls at a minimum, and structural controls and other appropriate controls where necessary. Permit Reference [Part VI, Section B]: The permittee shall maintain two locations where floatable material can be removed before the storm water is discharged to or from the MS4. Floatable material must be collected at the frequency necessary for maintenance of the removal devices, but not less than twice per year. The amount of material collected shall be estimated by weight, volume, or by other practical means. Results shall be included in the Annual Report required in this permit. Implementing a floatables removal program on City water bodies improves surface water quality, channel aesthetics and drainage system conveyance. B.1 Litter Booms The City monitors and maintains three (3) litter booms located at key locations within the MS4: Williamson Branch Creek at White Rock Lake; Lake Cliff Park in Oak Cliff; and Bachman Greenbelt near Bachman Lake. Each site includes a litter boom that floats at or near the water surface and extends across the width of the creek to trap floating materials. The City regularly monitors the condition of each boom. As City of Dallas MS4 Page 5 5 Final Draft SWMP

30 needed, each site is cleaned when the areas adjacent to the booms allow equipment access without damaging the adjacent shoreline. Activities under this SCM include monitoring, removing debris, and assessing the types and volume of debris collected. These data are then used to focus outreach efforts in and near these facilities. B.2 Special Event Floatables Protection During the last Permit term, the City initiated a new program to provide floatables protection for parades and other special events with high levels of anticipated pedestrian activity, and associated litter. Event examples include: the Martin Luther King Day Parade, the St. Patty s Day Parade and the NBA Mavericks Championship Celebration and Parade. The special events litter mitigation effort entails marking the inlets in the vicinity of the event; immediately preceding the event, bio logs (filter socks ) are placed along the inlets along the route. Following the event and subsequent street sweeping, the inlet protection is removed and stored for another occasion. Each event is evaluated with respect to implementation ease, waste captured and overall effectiveness; necessary program adjustments are made on the following event. This BMP has been found to be a very effective way of preventing literally tons of floatable material from entering the storm drainage system. B.3 Litter Abatement The City is implementing a litter abatement program through two different regional partnerships: 1) Benchmarking litter surveys of roadways and streams through Keep Dallas Beautiful, 2) implementing a regional media and education campaign with the Tarrant Regional Water District. Each year Keep Dallas Beautiful, an affiliate chapter of Keep America Beautiful, implements standard roadside surveys of litter, junk cars, and graffiti, in order to bring attention to the problem, and to help focus education efforts. Another benefit of this program is that performing these standardized surveys across the United States allows benchmarking with respect to overall improvement, and where a community stands relative to other comparably sized communities. These surveys can be conducted over time to assess effectiveness of follow on abatement activities. Dallas is partnering with Keep Dallas Beautiful to conduct these surveys of selected representative roadways, and stream segments in four quadrants of the City. The results will be provided to the City departments that provide related code enforcement and cleanup activities. The results will also be used to focus media campaigns, staff clean up and code enforcement activities, and education to Reverse Litter (under Element 7). Follow on surveys will be performed to assess effectiveness of the media and other education campaigns. C. Roadways A regular program of efficient and effective roadway maintenance contributes to limiting the discharge of pollutants to the MS4. Street sweeping can be used to limit particulate dust, floatables, sediment and other pollutants from entering into the MS4. Street sweeping can also help limit the volume of litter, City of Dallas MS4 Page 5 6 Final Draft SWMP

31 leaf and yard wastes that are washed into the storm drains. Winter sweeping is used to address the residuals from deicing activities. Permit Reference [Part III, Section B.2.a.iii]: The permittee shall operate and maintain public streets, roads, and highways to minimize the discharge of pollutants, including pollutants related to deicing or sanding activities. Activities under this element are street sweeping, deicing and road and bridge maintenance. C.1 Street Sweeping The City s prioritization for sweeping focuses on high vehicular use areas, higher pedestrian traffic areas downtown, and City owned parking lots. The City s road maintenance program includes street sweeping for 234 miles of designated prime network roads on a monthly basis, and sweeping within the Central Business District five nights a week. Other sweeping events are conducted as needed to address inclement weather or Customer Service requests. Several recent studies, including a USGS study of street sweeping in the Charles River watershed in Boston, and another study of street sweeping in Newport Beach, indicate that street sweeping may be effective in reducing bacterial loading, and may contribute to decreased bacteria regrowth from biofilm within city gutters, thus providing benefits towards basin wide reductions in bacteria (USGS, 2005, Stormwater, 2010). C.2 Deicing The City typically experiences three to five weather events each year that require deployment of deicing crews and subsequent clean up. Sweeping typically follows the event. Removal of deicing materials by street sweeping, limits the volume of salt, sand, and other materials from entering the MS4. Additionally, innovative deicing techniques and materials are regularly evaluated and assessed for the ability to provide overall program improvement and water quality enhancements. C.3 Road and Bridge Maintenance Program The City typically conducts about 3,000 routine road and bridge repairs each year. Implementing temporary or permanent SCMs at these routine road and bridge maintenance projects can effectively reduce or prevent the discharge of pollutants. SCMs used to support road and bridge maintenance include, but are not limited to: inlet protection, silt fence, rock berms, stabilized construction entrances, work area de watering, designated concrete washout areas, seeding, sodding and soil stabilization matting. Table 5 1 summarizes the activities, measurable goals, (or metrics to be tracked) and the implementation schedule for the SCMs associated with Element 1 MS4 Maintenance Activities. City of Dallas MS4 Page 5 7 Final Draft SWMP

32 A. Structural Controls Table 5-1 Element 1: MS4 Maintenance Activities Activities Metrics to be Tracked Annually Implementation Schedule A.1 Conveyance System Repair and Maintenance A.1.a Gravity Storm Sewer System Maintenance 1. Inspect underground gravity storm drainage piping through cctv televiewing. 2. Record the damaged storm drain piping areas and schedule maintenance. Miles of pipe inspected # of pipe areas scheduled for maintenance # of repairs completed 3. Remove debris from storm drain system. Volume of debris removed in CY 4. Investigate roadside ditches and culverts through service requests 5. Repair and maintain City-owned roadway culverts A.1.b Pressure Sewer System Maintenance 1. Inspect 7 pressure sewer systems including pump station & outfall at least twice per year # of ditch and culvert maintenance requests # number and type of roadway culverts repaired # of culvert replacements Volume of debris removed in CY # of pressure Sewer System inspections 2. Maintain pressure sewer system 3. Inspect 9 street pump stations, including pump station & outfall at least twice per year 4. Maintain street pump stations # of maintenance activities performed Volume of debris removed in CY # of Street Pump Station inspections # of cleaning & repair activities performed Volume of debris removed in CY City of Dallas MS4 Page 5 8 Final Draft SWMP

33 Table 5-1 Element 1: MS4 Maintenance Activities Activities Metrics to be Tracked Annually Implementation Schedule A.2 Water Quality Structures A.2.a Levee/Dallas Floodway Inspections & Maintenance 1. Maintain eleven (11) identified sump areas by: a) Visually inspecting each sump area, including pump stations and trash racks, at least twice a year; b) Cleaning trash racks after rain events, as needed; and c) Cleaning the sumps by de-silting, removing litter and woody debris, mowing, managing vegetation to ensure access to structures, and excavating sediments, as needed. 2. Maintain levees by: a) Visually inspecting each levee at least twelve times a year; Sump inspections performed # of trash rack inspections/pump station Volume of debris removed from trash racks in CY # of maintenance activities per sump in CY Acres and types of vegetative management performed Volume of materials removed during maintenance activities in CY # of visual inspections conducted (entire length) b) Conducting erosion repair, as needed # of erosion repairs by levee c) Removing litter, mowing, managing vegetation, and maintaining levee access as needed # of acres mowed (entire system) Volume of litter and debris removed in CY City of Dallas MS4 Page 5 9 Final Draft SWMP

34 Table 5-1 Element 1: MS4 Maintenance Activities Activities Metrics to be Tracked Annually Implementation Schedule A.2.b Inlet System Inspections & Maintenance 1. Conduct 12,000 inlet inspections within the City s jurisdiction annually Types and locations of inlets inspected 2. Clean and repair inlets as necessary year. Inlet cleaning and repair activities include: a) Cleaning inlets by removing material(s) Number, type, and locations of inlets cleaned Volume of material removed from inlets in CY b) Repairing damaged inlets Number, type(s) and locations of inlets repaired # of devices inspected 3. Inspect inlet protection devices at City-owned facilities # Repairs/device replacements completed # New devices installed Volume of material removed from inlet protection devices in CY A.2.c Retention/Detention Facility Inspections & Maintenance 1. Inspect at least ten (10) City-owned retention/detention ponds per year and each pond at least once during the permit term. 2. Maintain the flood control capacity and water quality efficacy of City-owned detention/retention ponds. # of Ponds inspected Number and type of pond maintenance activities performed (de-silting, litter removal, etc) Volume of materials removed in CY City of Dallas MS4 Page 5 10 Final Draft SWMP

35 Table 5-1 Element 1: MS4 Maintenance Activities Activities Metrics to be Tracked Annually Implementation Schedule A.2.d Creek/Channel Maintenance 1. Respond to creek and channel maintenance requests Number and type(s) and creek and channel maintenance requests 2. Maintain the flood control capacity and water quality efficacy of City-owned creeks and channels 3. Respond to service requests related to surface water quality 4. Investigate cause and effect for service requests related to Fish Kills Number of locations with dredging/ de-silting performed Acres of vegetated buffer management Volume of materials removed from City-owned waterways in CY Number, Type(s) and locations of water-quality related response activities performed Number of Fish-kill investigations performed Number of Reported Fish-kills with more than fifty identified fish/wildlife mortalities City of Dallas MS4 Page 5 11 Final Draft SWMP

36 Table 5-1 Element 1: MS4 Maintenance Activities Activities Metrics to be Tracked Annually Implementation Schedule A.3 Stormwater Interceptor Program 1. Inspect the City-owned in-line stormwater interceptors. 2. Clean the City-owned in-line stormwater interceptors. 3. Update inventory of the City-owned in-line stormwater interceptors. B. Floatables B.1 Litter Booms 1. Inspect litter booms for trapped materials, at least two (2) times per year. 2. Remove, dispose, and recycle if possible, collected materials. B.2 Special Events Floatable Protection 1. Prevent floatables from entering the storm drainage system during special events # of Interceptor inspections performed # of Cleaning events performed Volume of material removed in CY # of Interceptors added to City system # of Litter boom inspections performed Volume of floatables collected and disposed in CY # of events where litter intervention is provided # of inlets protected Volume of debris from related street cleaning/disposal in CY B.3 Litter Abatement 1. Perform a bi-annual review of the City litter/floatables program, and identify any necessary opportunities for improvement # of reviews, and recommendations made Permit Year 1, 3 and 5 City of Dallas MS4 Page 5 12 Final Draft SWMP

37 Table 5-1 Element 1: MS4 Maintenance Activities Activities Metrics to be Tracked Annually Implementation Schedule 2. Participate in local and regional litter abatement programs (eg, TREES, Keep Dallas Beautiful, Trinity Trash Bash, etc) 3. Retrieve Litter and floatables litter abatement activities C. Roadways C.1 Street Sweeping 1. Sweep the prime network roads twelve (12) times per year. # of events participated in by City staff Permit Years 1- Permit Year 5 Volume of Debris collected in CY Permit Years 1- Permit Year 5 Total gutter miles of prime network roads swept Volume of debris collected from prime network roads in CY 2. Sweep the Central Business District five times a week and other areas, as needed. Total gutter miles swept in the Central Business District and other areas Volume of debris collected from the Central Business District and other areas in CY 3. Evaluate the efficacy of the street sweeping program. Program evaluation completed. Permit Years 1, 3 and 5 City of Dallas MS4 Page 5 13 Final Draft SWMP

38 Table 5-1 Element 1: MS4 Maintenance Activities Activities Metrics to be Tracked Annually Implementation Schedule C.2 Deicing 1. Sweep the streets where deicing materials have been applied to icy patches. # of icing events Total gutter miles treated Total treated gutter miles swept 2. Evaluate availability and feasibility of innovative deicing techniques, annually. C.3 Road and Bridge Maintenance Program Program evaluation completed. Permit Years 1, 3 and 5 Incorporate temporary or permanent SCMs to reduce or prevent the discharge of pollutants from routine maintenance activities for roads and bridges. The SCMs may include but are not limited to: a) Temporary inlet protection b) Erosion control measures (e.g., silt fence, re-vegetative measures, soil stabilizing matting, etc.), c) Rock berms or check dams, d) Stabilized construction entrances, and/or e) Work area dewatering measures. Number, type and location of SCMs implemented City of Dallas MS4 Page 5 14 Final Draft SWMP

39 ELEMENT 2: POST CONSTRUCTION CONTROLS Stormwater discharges from new development and redevelopment sites have the potential to degrade water quality, from soil disturbance associated with construction, or from an increase in impervious surface cover. Stormwater control measures addressing post construction discharges incorporate several different approaches to maintain and/or improve water quality. Permit Reference [Part III.B.2.b.i ii]: The permittee shall implement a comprehensive master planning process (or equivalent) to develop, implement, and enforce controls to minimize the discharge of pollutants from areas of new development and significant redevelopment, after construction is completed. The goals of such controls must include: A) limiting increases in erosion and the discharge of pollutants in storm water as a result of new development; and B) reducing erosion and the discharge of pollutants in storm water from areas of redevelopment. ii. Within one year of permit issuance, this requirement shall be expanded to include all new development and redevelopment projects that disturb one acre or more of land, including projects that are part of a larger common plan of development. that will result in disturbance of one acre or more. The activities under this element include an integrated Stormwater Management (iswm) planning and design process, Dallas City Code updates, evaluating flood control projects for water quality opportunities, and evaluating performance of low impact development (LID) and green infrastructure controls to mimic pre development hydrologic flow conditions, and/or provide passive water quality treatment. Applicable Stormwater Control Measures A. Comprehensive Planning Process for New and Redevelopment Projects Requirements for planning, design, and construction of water quality, streambank protection, stormwater conveyance and flood control measures are included in the comprehensive integrated Stormwater Management (iswm) process. To reduce stormwater runoff volumes and pollutant discharges from areas of new development and significant redevelopment, the City is implementing the iswm program into City design processes, and is participating in related regional NCTCOG iswm manual development and outreach efforts. B. Dallas City Code Review and Updates Regular Code updates maintain the City s ability to enforce the requirements of the permit, in addition to any updates to state and federal laws. City of Dallas MS4 Page 5 15 Final Draft SWMP

40 Permit Reference Permit Reference [Part III.B.2.b.iii]: The permittee shall evaluate its existing SWMP as necessary to ensure that this MCM includes a regulatory mechanism such as an ordinance to implement and enforce the new requirements of this program, and shall ensure that the SWMP includes strategies for structural and non structural controls (i.e., BMPs) appropriate for the community. In addition, the permittee shall provide for adequate long term operation and maintenance of BMPs. When necessary, the Dallas City Code will be updated to include water quality provisions to support enforcement including spill response, reflect changes in state and federal regulations, and improve development/ redevelopment planning measures to promote water quality including provisions for adequate long term operations and maintenance of BMPs. C. Evaluation of Flood Control Projects Several recent studies and the technical documents used to develop the local TMDLs indicate the potential for significant pollutant transport to occur during the peak flow periods associated with flood events. Incorporating water quality features into capital improvement projects for flood control may provide an effective way of addressing pollutant transport while providing local flood relief. Another approach to reducing flood borne contaminant transport is to reduce the volume of runoff from developing sites. This secondarily addresses water quality by affecting the hydrologic response of the receiving waterbody; (that is, it reduces the volume of water available to convey pollutants downstream). Permit Reference [Part III.B.2.b.iv]: The permittee shall assess the impacts on the receiving water(s) for all flood control projects. Where feasible, new flood control structures must be designed, constructed, and maintained to provide erosion prevention and pollutant removal from storm water. If applicable, the retrofitting of existing structural flood control devices to provide additional pollutant removal from storm water shall be implemented, to the maximum extent practicable (MEP). The City evaluates capital improvement projects each year that offer the potential to integrate water quality design features into flood management focused design. D. Implementation and Performance of Structural/Non structural Controls Structural and non structural controls associated with low impact development are typically intended to provide both direct and indirect benefits to the water quality of the receiving water body. However, because many of these measures are relatively new, performance has not been fully assessed with respect to effectiveness in improving local water quality. The low impact development (LID) design elements and green infrastructure controls at City facilities will be tracked by type, and location. In addition, the number, location, size and land use types of new development and redevelopment projects using these measures will also be tracked. These data will be correlated with watershed monitoring data to allow evaluation of performance by control type, land use and location. Table 5 2 summarizes the activities, measurable goals, (or metrics to be tracked) and the implementation schedule for the SCMs associated with Element 2 Post Construction Controls. City of Dallas MS4 Page 5 16 Final Draft SWMP

41 Table 5-2 Element 2: Post Construction Controls Activities Metrics to be Tracked Annually Implementation Schedule A. Implement Comprehensive Master Planning Process for New and Redevelopment Projects 1) Participate in City and regional implementation of integrated Stormwater Management (iswm) master planning process for new and redevelopment projects. 2) Expand existing City iswm program to apply to sites greater than one acre in size B. Dallas City Code Review and Update 1) Identify changes made to Dallas City Code with regard to federal, state, and local environmental regulations and design practices. C. Evaluation of Flood Control Projects 1) Evaluate City capital improvement projects for flood control on a case-by-case basis to assess feasibility of incorporating stormwater controls to address water quality Number, size, type and location of projects implemented using iswm within City limits Number, size, type and location of projects implemented using iswm within City limits Number and types of updates made to Dallas City Code # of Flood control and drainage capital improvement project designs evaluated for water quality measures # of Flood control and drainage construction projects with water quality measures initiated # of Flood control and drainage construction projects with water quality measures completed Permit Year 2 Permit Years 1, 3 and 5 Types and locations of measures implemented City of Dallas MS4 Page 5 17 Final Draft SWMP

42 D. Implementation and Performance of Structural /Non-structural Controls Promote the use of Low Impact Development (LID) and green infrastructure controls including, but not limited to: a) Green Roofs b) Rain harvesting systems c) Retention Ponds d) Riparian buffer systems e) Permeable pavement f) Bio-swales g) Constructed wetlands h) Other Number, type(s) and locations of LID features implemented at City facilities Number, size, type(s), land use and locations of new and redevelopment projects over 1 acre Correlate water quality data with and data concerning types and locations of post construction controls in order to assess effectiveness of LID/Green Infrastructure Permit Years 4 and 5 City of Dallas MS4 Page 5 18 Final Draft SWMP

43 ELEMENT 3: ILLICIT DISCHARGE DETECTION AND ELIMINATION Illicit discharges, are formally defined as any discharge to a municipal separate storm sewer that is not composed entirely of stormwater with a few excepted discharges resulting from fire fighting activities, certain water utility discharges, and discharges from TPDES/NPDES permitted sources (40 CFR (b)(2)). A listing of these categories, along with a description of the local controls or conditions placed on these discharges is included in Appendix C, along with a listing of other TPDES permitted discharges within the permit area. All other illicit discharges are prohibited from entering the MS4. The City has a comprehensive illicit discharge detection and elimination (IDDE) program with activities to detect and eliminate illicit discharges to the storm sewer system, and to address sanitary sewer overflows, household hazardous waste collection, citizen response, yard waste and animal wastes, and illegal dumping. The City is also continuing ongoing efforts to maintain and regularly update an accurate MS4 map that includes all MS4 outfalls, and verifies system infrastructure. These activities, combined with ongoing monitoring (Element 8) provide for a proactive illicit discharge detection and elimination program. Applicable Stormwater Control Measures A. Illicit Discharge Detection and Elimination (IDDE) Illicit discharge detection and elimination (IDDE) is used to locate and remove prohibited discharges from entering the storm drainage system. Permit Reference [Part III.B.2.c.i]: The permittee shall prohibit illicit non storm water discharges from entering the MS4. The City s IDDE program uses a combination of dry weather outfall inspections, closed circuit televiewing (CCTV), and storm drain system information from the asset inventory database to trace the origin of a suspected illicit discharge(s). Potential illicit discharges and disposal are also investigated through a coordinated City wide complaint response process. The City maintains a city wide Customer Request Management System (CRMS) that provides internet and telephone (3 1 1) opportunities for citizen notification of illicit discharges or other stormwaterrelated concerns. The City s stormwater related public education materials encourage the public to use the system to report illicit discharges. The City staff respond to citizen complaints and document responses using field reports that are logged back into the CRMS system, and also into the Stormwater Management database. These databases allow assessment of the numbers and types of calls, and the locations of complaints. These data are then used to guide follow on outreach, and training efforts. A.1 Illegal Discharges and Improper Disposal The City eliminates illicit discharges and improper disposal sources of non stormwater materials into the MS4 by investigating complaints, issuing citations, and making arrests for illicit discharges and improper disposal. City of Dallas MS4 Page 5 19 Final Draft SWMP

44 Permit Reference [Part III.B.2.c.vii.A)]: The permittee shall require the operator of an illicit discharge or improper disposal practice to eliminate the illicit discharge or stop the improper disposal practice as quickly as reasonably possible. If the elimination of an illicit discharge within 30 days is not possible, the permittee shall require the operator of the illicit discharge to remove the discharge according to an expeditious schedule. Until the illicit discharge or improper disposal is eliminated, the permittee shall require the operator of the illicit discharge to take all reasonable measures to minimize the discharge of pollutants to the MS4. The City Marshals Illegal Dump Team patrols the City to address illegal dumping, and illicit discharges. This team maintains and coordinates the proper cleanup and discharge or removal of disposed materials within 30 days of discovery, or as expeditiously as reasonably possible. A special unit within this team has been formed to patrol the Dallas Floodway to prevent illegal dumping, damages to the levees and flood control system, and other related vandalism. A.2 Grass Clippings, Leaf Litter and Animal Wastes Grass clippings, leaf litter and animal wastes are addressed through several different initiatives to limit biological wastes and nutrients discharges into the MS4. Because of the TMDLs established to address bacteria within the permit area, these measures are important towards achieving the necessary reductions in bacteria loading within the Upper Trinity River system through Dallas. Permit Reference [Part III.B.2.c.vii.B)]: The permittee shall prohibit the discharge and intentional disposal of grass clippings, leaf litter and animal wastes into the MS4. Grass clippings and leaf litter are primarily addressed in the spring and fall through outreach and education as discussed in Element 7. Because improper yard waste disposal is typically performed quickly with leaf blowers, it can be challenging to enforce. Seasonal blitzes are implemented a couple of times each year during heavy periods of spring and fall landscape activities. Staff drive residential areas, and provide education and, as necessary, notices of violation (NOVs) to property owners and landscape contractors who are performing landscape maintenance during the blitz period. Code enforcement concerning proper yard waste management is provided year round. The City also addresses animal wastes related to pets through outreach and education, and appropriate Code enforcement concerning leash and pooper scooper laws. The City has formed a Feral Hog Task Force to address the growing challenge posed by feral hog populations within the Dallas Floodway. The Task Force is developing recommendations for managing these populations to address damage to the levees, channels and flood control structures from these animals, and limiting related waste discharges in/near the waterways. Additional stormwater controls to address feral hogs may be developed through the Task Force recommendations. As shown by the landuse mapping in Appendix A, the majority of the City s permit area is developed into urban and ultra urban landuse types with limited areas that retain agricultural operations. The City will review data from the local county tax appraisal districts to identify properties with agricultural tax City of Dallas MS4 Page 5 20 Final Draft SWMP

45 exemptions; these areas may support potential livestock grazing or other landuses that may warrant consideration of additional stormwater controls to address animal waste. Any necessary controls that may be identified will be coordinated with the applicable local soil and water conservation district personnel. Available public records do not indicate any confined animal feeding operations (CAFOs) in the permit area; however, facilities with industrial permits that may generate animal wastes are addressed by the SCMs under Element 5. A.3 MS4 Screening and Illicit Discharge Inspections Illicit discharge inspection activities are conducted in response to complaints, to address identified illicit discharges and/or improper disposal, or in response to information obtained through the dry weather screening program. Permit Reference [Part III.B.2.c.vii.A/C, Part IiI.B.2.h.i]: The permittee shall require the operator of an illicit discharge or improper disposal practice to eliminate the illicit discharge or stop the improper disposal practice as quickly as reasonably possible. If the elimination of an illicit discharge within 30 days is not possible, the permittee shall require the operator of the illicit discharge to remove the discharge according to an expeditious schedule. Until the illicit discharge or improper disposal is eliminated the permittee shall require the operator of the illicit discharge to take all reasonable measures to minimize the discharge of pollutants to the MS4. C)Within one (1) year from the date of permit issuance, the SWMP must include the following: 1)a list of techniques used for detecting illicit discharges; and 2) appropriate actions and enforcement procedures for removing the source of an illicit discharge. i) The permittee shall maintain a system for handling and responding to complaints in a manner that is conducive to locating areas of the MS4 where new illicit discharges and improper disposals may be suspected. The City s dry weather screening program focuses on identifying and eliminating illicit connections and improper discharges to the MS4. Techniques used for detecting illicit discharges include, but are not limited to: Dry Weather Outfall Inspections: Dry weather inspections are integrated into the MS4 map documentation tasks, and all known outfalls are scheduled for inspection within this permit term. If new outfalls are identified as a part of the process, then the MS4 system maps are updated with these data. Watersheds are prioritized for dry weather screening by age of the neighborhood, age and condition of the infrastructure, and areas with heavy industrial and commercial land uses. The outfalls are geo located using a Global Positioning System (GPS) unit. Any observations of discharge from the outfall are noted and are sampled for field parameters (ph, temperature, total suspended solids, turbidity, ammonia, chlorine, conductivity copper, iron, detergents dissolved oxygen, and hardness) using a dry weather sample kit. If there is an unusual color, odor, or other field parameter(s) noted outside of the ambient water quality conditions, then a full sample is collected and transmitted to a NELAP certified laboratory for selected analyses. City of Dallas MS4 Page 5 21 Final Draft SWMP

46 Illicit Discharge Investigations: When there are detected illicit discharges, the flow is traced from the discharge location to the source. Field observations and CCTV review are used with dye testing as necessary to determine the source location. The identified owner is then compelled to make the appropriate system improvements to reduce the impact to the MS4. As appropriate for the severity of the discharge, the owner may be provided with a Notice of Violation, outside complaint or citation for an illicit connection, or discharge to the MS4. Discharges meeting the requirements for reportable quantities of hazardous materials, as defined in 30 TAC 327 are reported the TCEQ. Routine Industrial and Construction Compliance Inspections: While most routine industrial and construction compliance inspections include a review of the Stormwater Pollution Prevention Plan (SWPPP); these inspections also include a facility outfall inspection. Any illicit discharges identified through these inspections are noted in the inspection report, and sampled as described under the above dry weather description. Service Request Responses Concerning Unusual Water Conditions: Staff may also encounter illicit discharges through responses to water quality service requests. When the request includes information concerning unusual water conditions, staff will contact the complainant to get more information on the discharge, including physical characteristics and when and where it was first noticed. Under this circumstance, the MS4 map is used with inlet and outfall inspections to trace the origin of the release. CCTV is used as necessary to trace the source. Emergency Response to Spills and Fish Kills: Illicit discharges are sometimes identified as a part of the City s investigation into the cause(s) and sources of spills and fish kills. The protocols followed are similar to those identified for unusual water conditions, and dry weather investigations. Aerial Photographic Screening: The City has recently implemented regular review of aerial photography as another way of identifying potential illicit discharges that may not otherwise be apparent during a routine facility or dry weather outfall inspection. Recent aerial photos of the MS4 are screened by light duty personnel for anomalies in discharge location, water color or geomorphology. Any areas with identified anomalies are investigated through routine dry weather sampling, industrial facility inspections (as appropriate) and standard department procedures for IDDE detection and elimination. A.4 Sanitary Sewer Overflows and Infiltration In many cities across the United States, combined sewer systems and sanitary sewer overflows form the primary source of bacterial pollution to surface water. The City of Dallas does not have a combined sewer system. However, like many U.S. cities, the City has aging sanitary sewer infrastructure, and the related challenges of addressing sanitary sewer overflows (SSOs) and infiltration. Permit Reference [Part III.B.2.c.viii]: Overflows and Infiltration. The permittee shall implement controls where necessary and feasible to prevent dry weather and wet weather overflows from sanitary sewers into the MS4. The permittee shall limit the infiltration of seepage from municipal sanitary sewers into the MS4. City of Dallas MS4 Page 5 22 Final Draft SWMP

47 The City actively implements several SCMs for the municipal sanitary sewer system to limit the inadvertent release of sewage from this system into the MS4. The City participates in the EPA Sanitary Sewer Overflow (SSO) Initiative to reduce the number of SSOs by improving the wastewater system and reducing the amount of grease build up, inflow, and infiltration. The City reduces SSOs and infiltration by conducting the following activities: Providing proper grease disposal information and education at public outreach events to residential customers, industry, and trade organizations; Inspecting grease generating establishments; Performing sewer main cleaning, conducting CCTV inspections of the wastewater system, inspecting manholes, and inspecting selected sewer basins and areas with exposed sewer mains due to creek/stream erosion; Completing system upgrades through sliplining and replacement; Inspecting and remotely monitoring collection system lift stations; Conducting smoke tests; Applying root control application; and Using GIS technology to identify areas that may require more frequent inspections and maintenance to proactively address issues before they become emergencies. A.5 Household Hazardous Waste and Used Vehicle Motor Fluid Program Most households routinely use small amounts of pesticides, herbicides, fertilizers, used oil and other automotive fluids, batteries paints, paint remover and solvents in the day to day upkeep of their homes, apartments and condominiums. These materials may contain hazardous materials, and are classified as household hazardous waste. Improper discharge of these materials through the City s trash collection, or storm drainage system, can pose a significant environmental impact. Permit Reference [Part III.B.2.c.ix]: The permittee shall prohibit the discharge or disposal of used motor vehicle fluids, and household hazardous wastes into the MS4. A) The permittee shall ensure the implementation of programs to collect used motor vehicle fluids (including, at a minimum, oil and antifreeze) and household hazardous waste materials (including paint, solvents, pesticides, herbicides, and other hazardous materials) for recycling, reuse, or proper disposal. Such programs shall be readily available to the residential sector within the MS4 and shall be publicized and promoted on a regular basis. B) Household hazardous waste (HHW) collection activities that are conducted by the permittee as a SWMP element are not an industrial activity requiring a separate TPDES authorization for the discharge of storm water, unless the HHW collection center is operated at a facility that has a primary activity defined in 40 CFR (b)(14). The City provides funding to the Dallas County Home Chemical Collection Center (HC3) to support the Dallas County Household Hazardous Waste (HHW) Program, and promotes and assists with collection events. The City of Dallas MS4 Page 5 23 Final Draft SWMP

48 program focuses on decreasing improper disposal of household hazardous chemicals and used oil. Promoting this facility helps to educate residents on proper use, care and disposal of these materials. A.6 List of Permitted Discharges Maintaining an updated list of permitted discharges can be useful towards identifying facilities operating without the appropriate permits. Follow up on non permitted sites to require appropriate site permitting is an effective way to prevent illicit discharges. Permit Reference [Part III.B.2.c.xi]: The permittee shall maintain an updated list of facilities that discharge directly to the MS4 and have been issued an NPDES or a TPDES permit. The list must include the name, location and permit number (if known) of the discharger. The City maintains a database of known discharges with a NPDES or TPDES permit that directly discharge into the MS4. The database includes site name, available owner and operator contact information, location, permit number, permit related notices, inspection reports, site photos, related service requests, and any monitoring data related to the site. These data are updated as new information is submitted, or otherwise becomes available. The database can generate lists of permittees, that are routinely correlated with other data sources to identify facilities that should be permitted in order to prevent illicit discharges from these facilities. While these lists vary month to month due to changes in site construction schedules and facility operations, a current list of permitted entities is included in Appendix C. A.7 MS4 Map Verification and Update Maintaining an updated, accurate map of the MS4 can be critical to providing timely emergency response for spills, and in detecting illicit discharges through the system. Permit Reference [Part III.B.2.c.xii]: A) The permittee shall maintain a current, accurate MS4 map that includes: the location of all MS4 outfalls; the names and locations of all waters of the U.S. that receive discharges from the outfalls; and any additional information needed by the permittee to implement its SWMP. B) The permittee shall document the source of information used to develop the MS4 map, including how the outfalls are verified and how the map will be regularly updated. C) New MS4 Areas: Within one year from the date of permit issuance, the permittee shall develop and implement procedures to insure that the above requirements are met for all new portions of the MS4. D) Existing MS4 Areas: Within four (4) years from the date of permit issuance, the permittee shall demonstrate that it has evaluated all existing portions of the MS4 and that the new mapping requirements have been implemented to the MEP. The City presently operates a system with about 11,000 different storm sewer outfalls, 1,800 miles of storm sewer pipe, and over 67,000 inlets. The original MS4 system mapping was developed through City of Dallas MS4 Page 5 24 Final Draft SWMP

49 scanned archive construction documents that were submitted to the Building Official for approval prior to construction. This system was field verified by survey crews working under a registered public land surveyor as a part of the original system documentation conducted in the 1990s and early 2000s, and the maps were then digitized into the Stormwater Information Management System. During the previous permit term, the City implemented a unified asset inventory system that assigned unique identifiers to the City s stormwater assets which allows efficient tracking of system conditions, inspections, and maintenance. The system is a GIS based data management system that integrates system inventory data into the system map. Regular updates, corrections and additions to this data management system provide timely, accurate data needed to effectively manage the stormwater infrastructure system. At present, the field asset verification program involves several efforts: The 11,000 outfall locations are being verified as a part of the Dry Weather Inspection program. All outfall locations are verified using a survey grade GPS system, and these data are uploaded into the asset inventory system. Staff use a combination of system mapping and physically walking the channel banks to locate any outfalls that were previously not identified. In addition to verifying the location and performing dry weather discharge monitoring, the outfall condition is also noted, and any repair or replacement needs are forwarded to the appropriate department for action. Outfall locations on industrial facilities are verified as a part of the regular site compliance inspections, with staff physically locating and inspecting each sample outfall identified in the SWPPP. Outfalls that require repair or other improvements are noted in the facility inspection report. Significant variances between the SWPPP and observed field conditions will also be noted and may warrant an NOV. The 67,000 inlet locations are being verified by light duty staff on an established City wide schedule that will allow verification of the entire system within the required four year period. These inspections include location verification using survey grade GPS, along with an assessment of inlet condition. Any needed cleaning or repairs are noted, and these data are electronically uploaded into the asset inventory. The inlet and outfall inspections are coordinated on a watershed by watershed basis in advance of the cctv television system inspections to more efficiently streamline the cctv operations with respect to unknown system conditions. The cctv crews teleview all of the primary storm sewers to verify location, size, pipe type, and condition. They also upload electronic data into the asset system, and provide recommendations for any necessary line cleaning or repair. There is one cctv team dedicated to new construction documentation. Upon receiving notification from the building inspection officials that construction is complete, the cctv crew field verifies the locations, type and sizes of the inlets, manholes, storm sewers and outfalls associated with the new construction. All data is collected using a combination of field grade GPS equipment, and cctv, and is uploaded into the asset inventory. The asset inventory is also updated through GPS locations of surface features and cctv inspections that are conducted in response to customer requests for storm sewer system locations. City of Dallas MS4 Page 5 25 Final Draft SWMP

50 The asset inventory may also be updated through contracted cctv and field verification of storm drainage facilities on a site specific basis. Contracted asset map updates are required to be consistent with the City s Field Asset Verification protocols. Table 5 3 provides a list of the activities, measurable goals, or metrics to be tracked, and the implementation schedule for the SCMs included in Element 3 Illicit Discharge Detection and Elimination. City of Dallas MS4 Page 5 26 Final Draft SWMP

51 Table 5-3 Element 3: Illicit Discharge Detection and Elimination Activities Metrics to be Tracked Annually Implementation Schedule A. Illicit Discharge Detection and Elimination A.1 Elimination of Illicit Discharges Work to correct the discharge, or remove the improperly disposed materials, within 30 days or as soon as reasonably possible. #of illicit discharges and illegal disposal sources identified and the time to resolve A.2 Grass Clippings, Leaf Litter and Animal Waste Management # of Leaf Litter Blitzes provided Work to reduce improper disposal of grass clippings and leaf litter # of homes and businesses contacted through the blitz or other Code enforcement activities concerning yard waste # of pamphlets and NOVs provided Work to reduce impacts from improper animal waste management by participating in local and regional Feral Hog initiatives # of meetings attended by City personnel # of recommendations developed and implemented Review tax records, and other data sources to identify areas where additional controls may be required to prevent animal wastes from impacting the MS4 # of tax records obtained Permit Year 1 # of properties identified Permit Year 2 # of properties reviewed for additional control requirements Permit Year 3 City of Dallas MS4 Page 5 27 Final Draft SWMP

52 Table 5-3 Element 3: Illicit Discharge Detection and Elimination Activities Metrics to be Tracked Annually Implementation Schedule A.3 MS4 Screening and Illicit Discharge Inspections Detect, inspect, and investigate illicit discharges and/or improper disposals. Illicit discharges or improper disposals Facilitate public reporting and response to resident concerns regarding illegal dumping or improper discharge of non-stormwater materials. Number and types of illicit discharge related calls received per watershed A.4 Limit Sanitary Sewer Overflows and Infiltration 1. Minimize the number and effects of sanitary sewer releases to storm drains by: a) Inspecting sanitary sewer pipes; Miles of sanitary sewer inspected using CCTV b) Performing preventative maintenance of the sanitary sewer system; and Miles of root control application completed to sanitary sewers c) Cleaning and repairing the sanitary sewer system. Miles of sanitary sewer pipes cleaned Number and location of repairs completed per watershed 2. Evaluate effectiveness of sanitary sewer overflow SCMs. Identified wet weather and dry weather sanitary sewer discharges to the MS4 Locations of wet weather and dry weather sanitary sewer overflows per watershed City of Dallas MS4 Page 5 28 Final Draft SWMP

53 Table 5-3 Element 3: Illicit Discharge Detection and Elimination Activities Metrics to be Tracked Annually Implementation Schedule A.5 Household Hazardous Waste and Used Motor Fluids Program 1. Promote and participate in the Dallas County Home Chemical Collection Center (HC3). Motor vehicle fluids and HHW collected from City of Dallas residents per Year 2. Assist Dallas County with one (1) off-site Household Hazardous Waste (HHW) collection event. A.6 List of Permitted Discharges Maintain a list of dischargers to the MS4 with TPDES/ NPDES stormwater permits associated with industry and construction activities. A.7 MS4 Map Verification and Update 1. Verify existing drainage asset data (i.e., inlets, outfalls, pipes and other features) 2. Compile new drainage asset data (i.e., inlets, outfalls, pipes and other features) to a unified asset inventory system and assign unique identifier. 3. Review data acquisition procedures, and revise as necessary. Motor vehicle fluids and HHW collected from City of Dallas residents collected through this off-site event Name, location, and TPDES/NPDES permit number for each permitted activity Number and types of updates to asset mapping database Number and types of updates to asset mapping database Document review conducted and any recommended revisions to the SWMP Permit Year 1 - Permit Year 4 City of Dallas MS4 Page 5 29 Final Draft SWMP

54 ELEMENT 4: POLLUTION PREVENTION & GOOD HOUSEKEEPING FOR MUNICIPAL OPERATIONS Promoting good internal pollution prevention and good housekeeping measures at city facilities ensures that cities walk the talk as far as preventing stormwater pollution from day to day city operations and maintenance activities. These actions are important with respect to maintaining integrity with the communities served, and ultimately in being able to effectively enforce environmental regulations within the Permit area. These measures also promote compliance with the pollution prevention and good housekeeping requirements as outlined in the Federal Phase II rule (40 CFR (b)(6)(i)), that are included in this permit to promote greater consistency between the requirements in the local Phase 1 and Phase II MS4 permits. Permit Reference [Part III.B.2.d.i]: the permittee shall implement a pollution prevention and good housekeeping program for municipal operations. The program must include MCMs that address: A) identification and implementation of good housekeeping and best management practices (BMPs) to reduce pollutant runoff from municipal operations such as street and highway maintenance, parks, municipal office buildings, and water treatment plants; B) reduction of discharge of pollutants to the MEP from road repair, equipment yards, and material storage facilities, or maintenance facilities; and C) training for all employees responsible for municipal operations which includes information on preventing and reducing storm water pollution from all municipal operations subject to this MCM. The City of Dallas has an existing pollution prevention and good housekeeping program that focuses on continuous improvement processes to reduce pollutant runoff from municipal operations. This program incorporates the City s Environmental Management System (EMS), and provides for appropriate management of the waste removed from the MS4, any pesticides, herbicides and fertilizers, facilityspecific Spill Prevention Control and Countermeasure (SPCC) Plans (when required), and emergency response requirements that are accounted for and executed on a city wide basis. As described in Element 7, training to prevent and reduce stormwater pollution from municipal operations is provided through an ongoing in reach education program promoted by environmental staff in several departments. Applicable Stormwater Control Measures A. Establish Pollution Prevention Program A.1 Implement Environmental Management Program The City established an Environmental Management Systems (EMS) program during the last permit period that is currently certified under the International Standards Organization (ISO) protocols for EMS. At the same time, the City also implemented several Administrative Directives (ADs) that govern City environmental policy and set forth specific requirements for all operations to minimize the impact of their activities on the environment. This program requires identification and implementation of good housekeeping and best management practices (BMPs), development of Standard Operating Guidance (SOGs) to promote reduction of discharge of pollutants to the MEP from road repair, City of Dallas MS4 Page 5 30 Final Draft SWMP

55 equipment yards, and material storage facilities, water plants, and maintenance facilities, and regular training for all employees responsible for municipal operations including, but not limited to information on preventing and reducing stormwater pollution from all municipal operations. A.2 Maintain List of Municipal Facilities Developing a good inventory of municipal facilities with the potential to impact the environment is integral to the implementation of an EMS program, because it allows documentation of internal and external environmental compliance audits, and tracking of programmatic improvements. Permit Reference [Part III.B.2.d.iv]: The SWMP must include a list of all municipal operations subject to the municipal operation, maintenance, and training programs listed under this MCM and all municipally owned and operated industrial activities subject to TPDES or NPDES industrial storm water regulations. As a part of the EMS implementation, the City developed a list of municipal facilities that are required to participate in the program. This information is maintained in a database that tracks EMS activities at each location. The list of municipal operations that are subject to the requirements of this element is included in Appendix C, along with a current list of TPDES Construction General Permitted projects, and a list of all municipally owned and operated industrial activities subject to the Multi Sector General Permit (Industrial Permit). A.3 Training for Municipal Employees A description of the City wide program to provide appropriate environmental training including pollution prevention, and spill response is included in Element 7. This program includes, but is not limited to providing information on preventing and reducing storm water pollution from all municipal operations. City employees are trained on the proper procedures for reporting, containing spills and preventing pollutants from entering the storm drains. B. MS4 Waste Management Preventing environmental impacts through appropriate management of the waste materials removed from the MS4 is as important as removing the wastes from the MS4. Permit Reference [Part III.B.2.d.ii]: The permittee shall ensure proper disposal of waste that is removed from the MS4 or from other municipal operations. Appropriate municipal waste management is one facet of the City s EMS program, and waste manifests are reviewed for completeness and accuracy. Wastes are reused and recycled wherever possible and appropriate. The volume of waste that is removed from the MS4 is monitored year by year to assess trends in floatables, and other pollutants, and to focus outreach and enforcement efforts. It is important to note however, that the storm drainage system is comprised of man made features within a natural City of Dallas MS4 Page 5 31 Final Draft SWMP

56 environment, and thus will be influenced by natural fluctuations such as climactic, biologic, and geomorphologic processes that may be largely outside of the City s control. Some variation should be expected in year to year waste volumes, particularly those related to the natural, organic wastes such as trees, and woody debris. C. Pesticides, Herbicides and Fertilizer Application Program Pesticides, herbicides and fertilizers (PHF) can have a negative impact to the environment when improperly used, including over application, or applications made under conditions that can cause direct or indirect discharge into the MS4. In addition, the TCEQ recently implemented TPDES General Permit No , concerning the Discharge of Biological Pesticides, and Chemical Pesticides that Leave a Residue in Water (TCEQ, 2011b). This permit applies to pesticide and herbicide applicators that apply pesticides and herbicides to water bodies, and requires an Integrated Pest Management Plan, tracking of applicators certifications, and documenting pesticide applications made each year. Permit Reference [Part III.B.2.d.iii]: The permittee shall implement controls to reduce the discharge of pollutants related to the storage and application of pesticides, herbicides, and fertilizers, by the permittee's employees or contractors, to public right of ways, parks, or other municipal property. The City maintains a program to reduce the discharge of pollutants related to the storage and application of pesticides, herbicides and fertilizers applied by City employees or contractors, to public rights of way, parks, and other City property. During the last Permit term, the City developed draft standard operating guidance (SOG), a draft Integrated Pest Management Program (IPM), and related policy, in order to establish uniform standards and guidelines for using these substances at City facilities. Ongoing efforts include further implementation, periodic review and updates and providing related training. In addition, the City submitted a Notice of Intent(NOI)/Self Certification as a Compliance Action Level II Operator under TPDES Permit No Compliance with this related General Permit requires documentation of the types, quantities and aerial extent of biological and chemical pesticides that the City and their contractors use each year. The City will also track proper certification of the City s pesticide applicators by maintaining a list of qualified personnel and reviewing personnel licenses, training and registration. D. Spill Response Source controls and an established spill response program provide a systematic approach to minimize and prevent, where feasible, hazardous and non hazardous substances from entering a water of the state. Permit Reference [Part III.B.2.d.v]: The permittee shall implement existing programs which prevent, contain, and respond to spills that may discharge into the MS4. The spill response programs may include: A) a combination of spill response actions by the permittee or another public or private entity, and B) legal requirements for private entities within the jurisdiction of the permittee. City of Dallas MS4 Page 5 32 Final Draft SWMP

57 The spill response program is supported through the activities of multiple City departments. This program incorporates the City s Environmental Management System (EMS), facility specific Spill Prevention Control and Countermeasure (SPCC) Plans (when required) and emergency response requirements that are accounted for and executed on a city wide basis. The City responds to spills, reports the number of spill responses, and maintains a spill prevention program that includes the proper handling, storage, and disposal of hazardous and non hazardous materials. The City uses additional SCMs relative to preventative vehicle maintenance of City vehicles to minimize entry of pollutants from City owned vehicles into the MS4. The City uses the 311/911 system for receiving and dispatching notice of hazardous and non hazardous spills. If a spill of this type enters the City s MS4 system, attempts are made to mitigate the effects to the MEP, to prevent the materials from reaching Waters of the United States. The City tracks all spills, including those with a discharge to the MS4, and those that are successfully mitigated so there are no MS4 impacts. The City promotes effective development and implementation of City Code and policies that help limit stormwater pollutants, and maintains legal requirements for private entities within the jurisdiction of the permittee concerning spills and illicit discharges. Element 2 includes a regular review of these related City Codes to identify any needed updates to these Codes. Table 5 4 provides a list of the activities, measurable goals, or metrics to be tracked and the implementation schedule for the SCMs described in Element 4 Pollution Prevention and Good Housekeeping Measures for Municipal Operations. City of Dallas MS4 Page 5 33 Final Draft SWMP

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59 Table 5-4 Element 4: Pollution Prevention & Good Housekeeping for Municipal Operations Activities Metrics to be Tracked Annually Implementation Schedule A. Establish Pollution Prevention Program # of internal environmental audits performed # of external environmental audits performed 1. Implement EMS program to promote continuous improvement with respect to pollution prevention and good housekeeping at municipal operations % of identified environmental issues addressed within 90 days. # green procurement contracts utilized # of SOGs, BMPs, ADs and work instructions updated to reduce pollutant runoff from municipal operations Permit Year 1, 3 and 5 2. Reduce potential for pollution by reducing the number and quantity of harmful chemicals used for municipal operations # of non-toxic chemicals used Total # of chemicals used % of non toxic chemicals used 2. Maintain list of municipal facilities included in EMS Program # of City facilities audited # of oil/water separator cleanings 3. Promote good housekeeping practices for City facilities and vehicles to minimize spills and pollutant discharge into the MS4. # of City vehicles recieving preventative maintenance Total # of vehicular spills # of City owned vehicular/equipment spills that enter the MS4 City of Dallas MS4 Page 5 35 Final Draft SWMP TPDES Permit No. WQ April 1, 2012

60 Table 5-4 Element 4: Pollution Prevention & Good Housekeeping for Municipal Operations (Continued) B. MS4 Waste Management Activities Metrics to be Tracked Annually Implementation Schedule 1. Promote good housekeeping practices by tracking appropriate waste management by City facilities 2. Promote good housekeeping practices by tracking appropriate waste management by City facilities (Continued) 3. Promote effective waste management for waste removed from the MS4 # of City Departments that are small quantity conditionally exempt waste generators # of City Departments that are large quantity waste generators Volume of waste managed in support of Emergency response and spill remediation in tons Volume of classified hazardous and universal waste managed by the City facilities in tons Volume of wastes removed through MS4 maintenance activities in tons C. Pesticides, Herbicides and Fertilizer (PHF) Application 1. As necessary, review and update the Integrated Pest Management (IPM) Plan to maintain uniform standards and guidelines for applying pesticides, herbicides, and fertilizers on City-owned property. Number and types of changes to the IPM plan Permit Years 1, 3 and 5 Document Plan review conducted Permit Years 1, 3 and 5 # of City facilities using PHF 2. Document City compliance with requirements of Pesticide General Permit No # of application locations by, or contracted on behalf of City departments that are in/near water bodies Total acreage in/near water bodies that are treated using pesticides and herbicides City of Dallas MS4 Page 5 36 Final Draft SWMP TPDES Permit No. WQ April 1, 2012

61 Table 5-4 Element 4: Pollution Prevention & Good Housekeeping for Municipal Operations (Continued) Activities Metrics to be Tracked Annually Implementation Schedule C. Pesticides, Herbicides and Fertilizer (PHF) Application (Continued) 3. Maintain a list of employees who are licensed pesticide applicators, and review personnel licenses, training and registration # of current licensed applicators # of training hours accrued D. Spill Response Program Respond to spills of hazardous and non-hazardous substances that enter the City s storm drainage system for which the City is notified by: a) Mitigating the effects of the spill, and # type and location of spill responses b) Preventing the spilled substances, to the extent practicable, from entering a Water of the State. # of successfully mitigated spills # of spills entering a Water of the State City of Dallas MS4 Page 5 37 Final Draft SWMP TPDES Permit No. WQ April 1, 2012

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63 ELEMENT 5: INDUSTRIAL AND HIGH RISK RUNOFF The City addresses industrial facility stormwater discharges to the MS4 that may pose a threat to water quality through a comprehensive industrial program that includes regular screening, monitoring and inspections. The industrial facilities are identified through a variety of methods and include facilities that are permitted under the TPDES Multi Sector General Permit Number TXR , facilities that are operating under a No Exposure Certification (NEC), and facilities that are identified through screening and need to be permitted. Permit References [Part III.B.2.e.v, PartIII.B.2.h.iii]: The permittee shall continue to improve its existing programs to identify and control pollutants in storm water discharges to the MS4 from: municipal landfills; other treatment, storage, or disposal facilities for municipal waste (e.g. transfer stations, incinerators, etc.); hazardous waste treatment, storage, disposal and recovery facilities; facilities that are subject to Emergency Planning and Community Right to Know Act (EPCRA) Title III, Section 313; and any other industrial or commercial discharge the permittee determines are contributing a substantial pollutant loading to the MS4. Applicable Stormwater Control Measures A. Inspections and Control Measures Regular inspections and control measures are generally effective in reducing the discharge of pollutants from industrial and high risk facilities to the MS4. Permit References [Part III.B.2.e.v.ii]: This MCM must include: A) priorities and procedures for inspections and for establishing and implementing control measures for such discharges; City staff inspect industrial and high risk facilities operating with the potential to discharge pollutants to the MS4 including permitted industrial facilities known to the City, Superfund Amendment and Reauthorization Act (SARA) 313 facilities, permitted landfills, transfer stations and other Treatment, Storage and Disposal (TSD) facilities, and facilities that are required to have an NOI that are subject to the Emergency Planning and Community Right to Know Act (EPCRA) Title III, Section 313. Follow up inspections are performed as required to enforce stormwater permit compliance. Industrial and high risk facilities within the City limits with the potential to discharge pollutants to the MS4 are regularly inspected for adequate control measures to reduce the discharge of pollutants to the MS4. The inspection verifies that the structural and non structural control measures as outlined in the Storm Water Pollution Prevention Plan (SWPPP) for the site are reflected on the site, and functioning as intended to prevent pollution from the site. Sector U (Food and Kindred Products) facilities that have the potential to generate biological waste, including high Biochemical Oxygen Demand (BOD5), or bacteria in the site discharge will be inspected on City of Dallas MS4 Page 5 39 Final Draft SWMP

64 a more frequent basis, with additional sampling requirements for these constituents as deemed necessary from a review of site monitoring data. Sites that have an NEC certification for no exposure of their operations to stormwater will be inspected to verify that site conditions warrant the no exposure waiver. The priorities for inspection are as follows: Facility Risk Type Superfund Amendment and Reauthorization Act (SARA) 313 facilities City permitted landfills, transfer stations and other Treatment, Storage and Disposal (TSD) facilities Other City facilities with TPDES MSGP permits High Risk Facilities subject to the Emergency Planning and Community Right to Know Act (EPCRA) Title III, Section 313 Sector U, or other facilities that pose a risk of biological/bacterial discharge Non compliant sites, or sites with benchmark exceedences Sites with No Exposure Certification (NEC) and all other MSGP permitted sites Minimum Inspection Frequency Annual with more frequent follow up as needed Annual with more frequent follow up as needed Annual with more frequent follow up as needed Annual with more frequent follow up as needed Annual with additional sampling and more frequent follow up as required Minimum quarterly with additional sampling and more frequent follow up as required until site is in compliance. Once per permit term, with follow up as needed The City maintains legal authority to inspect industrial facilities, require site compliance, and provide tiered enforcement of non compliance: Non compliance (NC) Notice of violation (NOV) Three NOVs, or egregious offense warrants transfer to Enforcement Team Outside Complaints or Citations Transfer to the Enforcement Team involves more frequent inspections, additional monitoring and submittal and implementation of a Compliance Action Plan by the facility operator. Operator training is provided as a part of the training activities outlined under Element 7, Public Education/ Outreach. B. Screening Program The City implements an ongoing screening program to identify qualifying industrial facilities that may require permitting under the Multi Sector General Permit (MSGP). City of Dallas MS4 Page 5 40 Final Draft SWMP

65 Permit References [Part III.B.2.e.v, PartIII.B.2.h.iii]: This MCM must include: B) an Industrial and High Risk Monitoring Program as described in Part III, Section B.2.h.iii of this permit: A) This program must include monitoring for pollutants in storm water discharges to the MS4 from: municipal landfills; other treatment, storage, or disposal facilities for municipal waste (for example, transfer stations and incinerators); hazardous waste treatment, storage, disposal and recovery facilities; facilities that are subject to EPCRA Title III, Section 313; and any other industrial or commercial discharge the permittee determines is contributing a substantial pollutant loading to the MS4. B) The Industrial and High Risk Runoff Monitoring Program must include the collection and review of quantitative data on parameters that have been identified by the permittee as a pollutant of concern for that facility, and must: 1) coincide with the corresponding industrial sector specific requirements of the TPDES Multi Sector General Permit TXR050000, or any applicable general permit issued after September 29, 1995, and is not contingent on whether a particular facility is actually covered by the general permit; 2) coincide with the monitoring requirements of any individual permit for the storm water discharges from that facility; or 3) include pollutants of concern for the storm water discharge from that facility as identified by the permittee. The City uses Dunn & Bradstreet, the EPA Toxic Release Inventory, the TCEQ Central Registry, and other available information to screen industries by Standard Industrial Code (SIC) to identify potentially unpermitted facilities that may be required to permit. The City performs follow up inspections at these facilities to assess whether a permit is required, and whether the site is generally compliant with the permit requirements. If the site is not compliant, then the normal tiered enforcement process applies. The screening process enforces Federal, State and City stormwater requirements while addressing discharges with the potential to impact water quality of the MS4 receiving water bodies. Water quality screening is also performed by reviewing the site water quality monitoring data for permitted sites as submitted by the industrial facility operator. The City uses a proactive approach of soliciting the monitoring data from the sites that are required to do benchmark sampling. The data is entered into Environmental Data Management (EDMS) database, and compared to sector benchmark thresholds. Facilities that exceed the benchmark threshold values for one or more constituents are required to develop and implement a compliance action plan that includes additional BMPs, structural and non structural controls as necessary to bring the site into compliance. The Industrial water quality program is described further in Element 7, Monitoring, Evaluation and Reporting. Table 5 5 provides a list of the activities, measurable goals or metrics to be tracked, and the implementation schedule for the above SCMs for Element 5 Industrial and High Risk Runoff. City of Dallas MS4 Page 5 41 Final Draft SWMP

66 Table 5-5 Element 5: Industrial and High Risk Runoff Activities Metrics to be Tracked Annually Implementation Schedule A. Inspections and Control Measures 1. Inspect 500 permitted industrial facilities known to the City. 2. Inspect all Superfund Amendment and Reauthorization Act (SARA) 313 facilities. 3. Inspect permitted municipal landfills and Treatment, Storage and Disposal (TSD) facilities. 4. Inspect City facilities required to have a Notice of Intent (NOI) and that are subject to Emergency Planning and Community Right-to-Know Act (EPCRA) Title III, Section Inspect Sector U, (Food Products and Kindred Products ) and other similar facilities that have the potential to discharge biological constituents. # and type of inspections performed # and type of inspections performed # and type of municipal landfills inspected # and type of TSDs inspected # and type of inspections performed # and type of inspections performed B. Industrial Monitoring and Screening Program 1. Screen facilities with a Standard Industrial Classification Code (SIC) that may require permitting under the Multi-Sector General Permit. 2. Evaluate the effectiveness of the screening program. 3. Use monitoring data review to enhance facility compliance # of facilities identified through screening process that have SIC Codes that may require a MSGP Permit # of new permits received as a result of screening % of industrial facilities submitting required benchmark monitoring data City of Dallas MS4 Page 5 42 Final Draft SWMP

67 Table 5-5 Element 5: Industrial and High Risk Runoff (Continued) Activities Metrics to be Tracked Annually Implementation Schedule 3. Use monitoring data review to enhance facility compliance (continued) % of submitted facility data sets that are compliant with benchmark parameters # of Corrective Action Plans required to achieve compliance % Action Plan Facilities brought into compliance City of Dallas MS4 Page 5 43 Final Draft SWMP

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69 ELEMENT 6: CONSTRUCTION SITE STORMWATER RUNOFF The City is required to enforce compliance with the TPDES General Construction Permit Number TXR for construction sites that disturb more than one acre of land. Stormwater runoff from construction sites is addressed by implementing effective controls per site specific Stormwater Pollution Prevention Plans (SWPPPs), construction site inspections, and notifying building applicants of the applicable requirements that affect projects under the TPDES permit regulations. Additional requirements have been added to address the construction site runoff control provisions included in the Federal Phase II rule (40 CFR (b)(4)(i) and (ii)). These regulations require existing construction programs to regulate sites that discharge into the MS4 and disturb more than one acre, to address construction wastes, include plan review that addresses water quality impacts and incorporates ways of addressing public concerns related to construction activities. Permit Reference [Part III.B.2.f.i]: The permittee shall continue to implement a program to reduce the discharge of pollutants into the MS4 from construction sites. Within one year of date of permit issuance, the permittee shall ensure that the existing program is revised as necessary to address construction projects that are one acre or more in size, or that are part of a larger common plan of development or sale that is one acre or more in size. The City has an existing program to reduce the discharge of pollutants into the MS4 from construction sites. The program currently program addresses construction projects that are greater than one acre in size, or that are part of a larger common plan of development. In addition, the program also addresses sites that are less than one acre in size, in response to a citizen request or complaint concerning that site. Construction sites are inspected on the following frequencies: Large Sites (> 5 acres, or that are part of a common plan, or are located within the escarpment or geologically similar area): no less than every 14 calendar days; Small Sites (1> x >5acres): no less than every 30 calendar days; Very small sites (<1 acre (not permitted): less than 4 calendar days from receipt of a complaint. Note: all sites with construction related complaints will receive a full inspection in no more than 4 calendar days from the receipt of the complaint. Applicable Stormwater Control Measures A. Construction Site Runoff The City identifies, inspects and requires the contractor to implement controls to reduce the discharge of pollutants from construction sites to the MS4. Activities in the City s construction permit process include: reviewing SWPPPs, inspecting projects in progress for the implementation of effective control measures, and conducting enforcement actions to reduce pollutant discharge(s) to the MS4, as necessary. The City also makes building permit applicants aware their responsibilities under the TPDES General Construction Permit. City of Dallas MS4 Page 5 45 Final Draft SWMP

70 A.1 Use and Maintenance of Controls The City utilizes the building permit process to plan and design for stormwater management control, including erosion and sediment controls to protect water quality. Permit Reference [Part III.B.2.f.i.A/B, Part III.B.2.f.ii.A)]: This MCM must include,permittee must require within one year: A) requirements to use and maintain appropriate structural and nonstructural BMPs to reduce pollutants discharged to the MS4 from construction sites; B) requirements for construction site operators to address the control of site waste such as discarded building materials, concrete truck washout water, chemicals, litter, and sanitary waste at a construction site; The City currently requires SWPPPs for all building and construction permit applications that disturb more than five acres, that are located within the escarpment or geologically similar area, or that are part of a common plan of development. The City reviews and maintains a copy of the SWPPP to identify the erosion and sediment controls for reducing discharge of pollutants from the individual construction site(s). All sites that disturb more than an acre are required to implement appropriate controls to reduce sediment and other pollutants from being discharged from the construction site. In addition, appropriate pollution prevention and housekeeping measures to address litter, waste materials, concrete truck washouts, chemicals and sanitary waste are also required for every site, regardless of size. A.2 Inspection of Construction Sites and Enforcement of Control Measure Requirements Construction inspections focus on achieving site compliance through effective site water management, erosion control and sediment control. Permit Reference [Part III.B.2.f.i.C)]: This MCM must include: C) inspection of construction sites and enforcement of control measure requirements; The inspection verifies that the structural and non structural control measures as outlined in the Storm Water Pollution Prevention Plan (SWPPP) are accurately reflected on the site, and are functioning as intended to prevent pollution from the site. The City maintains legal authority to inspect construction sites, require site compliance, and provide tiered enforcement of non compliance as follows: Non compliance (NC) Notice of violation (NOV) Three NOVs, or egregious offense warrants transfer to Enforcement Team Outside Complaints or Citations Stop Work Order, and/or hold placed on Building Permit, or Certificate of Occupancy City of Dallas MS4 Page 5 46 Final Draft SWMP

71 Transfer to the Enforcement Team involves more frequent inspections to bring the site into compliance. Construction site operator training is provided as a part of the training activities outlined under Element 7, Public Education and Outreach. Inspections are documented using paperless field methods, and supported by a Geographic Information System (GIS) mapping system with Oracle formatted Stormwater information management system. The SWIMs system provides support in correlating NOVs with other data, allows targeting for outreach by site issue, or location, and provides inspection scheduling within the required performance timeframes. A.3 Notification of Applicants of Responsibilities The City notifies contractors and construction building permit applicants of their responsibilities under the TPDES General Construction Permit, as a part of the building permit process, and during the inspections. Permit Reference [Part III.B.2.f.i.D)/ Part III.B.2.f.ii.B)]: This MCM must include: D) notification to construction site operators of their potential responsibilities under the NPDES or TPDES permitting regulations and permits for construction site runoff. B)Within one year from the date of permit issuance, the permittee shall develop procedures for site plan reviews that incorporate consideration of potential water quality impacts, receipt and consideration of information submitted by the public, and site inspection and enforcement of control measures to the extent allowable under state and local law. The City evaluates the site planning checklist that building permit applicants and other contractors use to make sure that a SWPPP is submitted to the City, and to promote consideration of the iswm comprehensive program to incorporate water quality benefits into the design and construction of the project (See Element 2). The City s plan review process currently incorporates consideration of potential water quality impacts, receipt and consideration of information submitted by the public, and site inspection and enforcement of control measures to the extent allowable under state and local law. The City also informs the contractors and other building permit applicants of their responsibility to provide a copy of a Construction Site Notice (CSN) or Notice of Intent (NOI) to support appropriate coverage under the TPDES Construction General Permit. The City provides training related to the construction permit, as described under Element 7, Public Education and Outreach. A.4 List of Construction Sites A comprehensive list of the active NPDES/TPDES construction sites in the construction compliance program can help with staff scheduling, trip planning to reduce gas consumption, and identifying those sites found in the field that may require some encouragement to acquire the necessary permitting. Permit Reference [Part III.B.2.f.ii.]: The permittee shall maintain a current list of construction sites that discharge directly to the MS4 and have been issued an NPDES or a TPDES permit. The list must include the name, location and permit number of the discharges that have been authorized under an NPDES or TPDES storm water discharges permit for construction activities (if known). City of Dallas MS4 Page 5 47 Final Draft SWMP

72 The City uses the SWIMs database to document the construction permit documents, site location, operator contact information, permit number and inspection status for about 6,000 to 7,000 inspections each year. This list is updated daily as new NOIs are entered, and completed sites are terminated and archived. Thus, the actual number of sites on this list at any one time varies considerably on a monthto month basis, based on variable construction schedules for the sires inspected. A copy of the current list is included in Appendix C. Table 5 6 provides a list of the activities, measurable goals, or metrics to be tracked and the implementation schedule for the SCMs included in Element 6 Construction Site Stormwater Runoff. City of Dallas MS4 Page 5 48 Final Draft SWMP

73 Table 5-6 Element 6: Construction Site Runoff Activities Metrics to be Tracked Annually Implementation Schedule A. Construction Site Runoff A.1 Use and Maintenance of Controls Require and inspect Stormwater Pollution Prevention Plans (SWPPPs) for specific building and construction permits in accordance with State regulations. # of SWPPPs presented A.2 Inspection of Construction Sites and Enforcement of Control Measure Requirements 1. Inspect construction sites for compliance with stormwater management practices. Conduct inspections as follows: a) Five (5) acres and greater in size, in the escarpment or geologically similar area, or part of a common plan of development: every two weeks; and b) Sites greater than or equal to one (1) acre and less than five (5) acres in size on a monthly basis Number, type and location of inspections 2. Conduct supplemental inspections of construction sites in response to complaints. Number, type and location of inspections A.3 Notification of Applicants of Responsibilities Review and revise the building permit procedures to ensure a process is in place that emphasizes notification of requirements under TPDES permit regulations, and incorporation of appropriate water quality measures and citizen involvement. Revisions to process procedures Permit Years 1, 3 and 5 City of Dallas MS4 Page 5 49 Final Draft SWMP

74 Table 5-6 Element 6: Construction Site Runoff (Continued) Activities Metrics to be Tracked Annually Implementation Schedule A.4 List of Construction Sites Maintain a list of active construction sites that are inspected for compliance # of new sites added # of sites terminated City of Dallas MS4 Page 5 50 Final Draft SWMP

75 ELEMENT 7: PUBLIC EDUCATION, OUTREACH, INVOLVEMENT AND PARTICIPATION This SWMP incorporates a focused and comprehensive public education, outreach, involvement and participation program to encourage stewardship of the City s surface water resources by raising awareness of the issues, providing information on SCMs that may be used to improve water quality, and providing opportunities for the public to provide meaningful input into the program. Permit Reference [Part III.B.2.g.i.A)]: Within one year from the date of permit issuance, the permittee shall document and ensure that the SWMP promotes, publicizes, and facilitates public education and outreach to: residents, visitors, public service employees, businesses, commercial and industrial facilities, and construction site personnel. The permittee shall provide justification for any group that is not addressed by the program The permittee shall document the activities conducted and materials used to fulfill this program element and provide enough detail to demonstrate the amount of educational and outreach resources and materials used to address each group. The City s outreach program promotes, publicizes and facilitates public reporting of spills, kills, illicit discharges and improper disposal of materials, and the management and disposal of used motor fluids and household hazardous wastes. The program also promotes and publicizes the proper use, application and disposal of pesticides, herbicides and fertilizers, pet waste management and yard waste management. The program is diverse, multi faceted, multi generational, and is targeted towards children, residents, non governmental entities, visitors, staff, businesses, and operators of commercial and industrial facilities within the permit area. The SCMs of the City s outreach program are implemented through efforts aligned in three primary focus areas: Public Education including technical training in direct support of the permit elements (Including inreach to City staff); Outreach; Public Involvement and participation to solicit input into the SWMP. Applicable Stormwater Control Measures A. Public Education The focus of the City s education and outreach campaign is to improve stormwater quality by promoting greater awareness of issues related to stormwater management. This includes, but is not limited to topics related to: basic watershed concepts, illicit discharges and proper waste disposal, proper use and storage of herbicides, pesticides and fertilizers, proper yard waste and pet waste management, used oil and toxic materials, household hazardous waste (HHW), and general pollution prevention. Program effectiveness is measured by participation at outreach events, the number of visits to websites, general trends in the number of notice of violations (NOVs) at facility and site inspections and overall general public feedback on stormwater information dissemination. City of Dallas MS4 Page 5 51 Final Draft SWMP

76 A.1 Community Education The City provides public education and community outreach through presentations made across the city to community groups, including participation at public events. Topics include illicit discharges, improper disposal, pet waste, yard waste, pesticides, herbicides and fertilizers (PHF) and used oil and toxic materials (UOTM). Providing timely information on the proper use of these materials can help to prevent inadvertent illicit discharges to the MS4, and raise environmental awareness. A.2 School Education Students within the City have the potential to impact stormwater and water quality in the MS4, and can also positively affect their families outlook. The City promotes a stormwater education campaign at area schools that focuses on watershed concepts and stormwater pollution prevention. The school programs run the gamet from providing story time and summer camp programs to younger students, to University level classes and providing environmental science programs to teach the teacher. In addition, training on illicit discharges is also provided to school facility managers to prevent inadvertent discharges into the storm drain system during normal end of year cleaning and facility maintenance operations. A.3 Business Education Illicit discharges, pesticides, herbicides and fertilizers (PHF) and used oil and toxic materials (UOTM) have the potential to degrade water quality in the MS4. Permit Reference Permit Reference [Part III.B.2.g.i.B.1) 2), 3)]: The permittee shall continue to implement a public education and outreach program component to promote, publicize, and facilitate: 1) public reporting of illicit discharges or improper disposal of materials, including floatables, into the MS4; 2) the proper management and disposal of used oil and household hazardous wastes; 3) the proper use, application, and disposal of pesticides, herbicides, and fertilizers by public, commercial, and private applicators and distributors; The City provides focused training targeting businesses and trade organizations associated with these activities to disseminate information on current requirements, pollution prevention, and acceptable SCMs for protecting water quality. B. Technical Training The City provides focused topic specific technical training for identified sectors with a high potential to affect stormwater quality. This training is implemented to promote SCMs and stormwater management awareness. The technical training target audiences include city employees, operators of construction sites and industrial facilities, community members and specialized stakeholders such as contractors, technical consultants and business owners. City of Dallas MS4 Page 5 52 Final Draft SWMP

77 B.1 Construction Site Operator Training Runoff from construction sites has an identified potential to degrade water quality in the MS4. The construction site operators program affects site compliance by providing several opportunities to educate site operators and other affiliated personnel concerning appropriate ways of reducing stormwater pollution from their site. Permit Reference Permit Reference [Part III.B.2.g.i.B.4)]: The permittee shall continue to implement a public education and outreach program component to promote, publicize, and facilitate: 4) Appropriate education and training measures for construction site operators. The City provides three types of construction training focused on promoting acceptable construction site SCMs to address effective site water management, erosion control, and sediment management: Construction site operator workshops for owners, operators, contractors and their consultants; One time on site consultation with the Operator following receipt of the NOI; and On site tailgate type training sessions in English and Spanish that are targeted to on site construction staff. B.2 Industrial Site Operator Training Industrial operators discharging to the MS4 have the potential to impact water quality. The City provides training to industrial facility owners, operators, and their consultants to disseminate information on current TPDES Multi Sector General Permit requirements and to provide information on available resources to protect water quality in the MS4. B.3 City Staff Education (Inreach) The City conducts an Inreach initiative to raise City employees awareness and promote pollution prevention practices to reduce discharge of pollutants into stormwater. Educational information is disseminated to City employees through electronic announcements, internet websites, new employee orientation presentations, and stormwater education modules. Topics include illicit discharges, floatables and litter, proper management and disposal of used oil and household hazardous wastes, and proper use, application, and disposal of pesticides, herbicides, and fertilizers by city staff or contracted vendors. Project Managers are also invited to special workshops concerning appropriate construction site management SCMs, the TPDES General Construction Permit, Spill Response and other related issues Spill prevention and training is provided on a three tiered system, depending on job duties. Training ranges from basic pollution prevention training, to spill prevention, to emergency response and incident command system training. Task specific training is provided, as required, to personnel directly involved in the spill prevention and response programs. City of Dallas MS4 Page 5 53 Final Draft SWMP

78 C. Outreach C.1 Community Outreach The City provides community outreach through neighborhood based events and presentations and larger regional events downtown. Topics can include but are not limited to illicit discharges, general pollution prevention, and watershed science, floatables and litter, pet waste and yard waste management, used vehicular fluids and household hazardous wastes, and pesticides, herbicides, and fertilizers. Permit Reference Permit Reference [Part III.B.2.g.i.B. 3)]: The permittee shall continue to implement a public education and outreach program component to promote, publicize, and facilitate: 3) the proper use, application, and disposal of pesticides, herbicides, and fertilizers by public, commercial, and private applicators and distributors; Neighborhood based outreach is provided to Homeowners Associations, parent teachers associations, church and school organizations, and non governmental organizations to disseminate stormwater pollution prevention messages aimed at a wide range of topics depending upon the age group, demographics, and community interest. The City also sponsors 3 or 4 larger regional events each year, such as the Margaret Hunt Hill Bridge opening, the Wind Festival, and EarthFest that are more generally focused on promoting stewardship of the Trinity River and the environment. These are widely attended and provide a great opportunity to provide outreach to residents, businesses, and visitors. C.2 Visitor and Tourist Outreach The City provides outreach to visitors and tourists through a traveling exhibit that is displayed at various public locations such as Love Field, the Executive Airport, local museums and community centers and the public libraries. The City also maintains 10 kiosks and other pamphlet displays at public venues with high visitor and tourist traffic such as City Hall, the Library, Texas Discovery Gardens, the Dallas Aquarium and Fair Park. These kiosks are stocked with brochures that address a variety of environmental topics. C.3 Media based Outreach The success of the SWMP is dependent on the ability to disseminate timely and relevant information in a manner that is readily understood by the targeted audience(s). The City uses a variety of print and electronic media to disseminate program information. The use of multiple media sources expands the reach of the program, reinforces the SWMP s SCMs and encourages positive behavior concerning surface water resources. Media are developed to support the various technical and educational campaigns and are regularly updated to address current issues within the program. City of Dallas MS4 Page 5 54 Final Draft SWMP

79 C.4 Household Hazardous Waste Improper disposal of hazardous and non hazardous household substances also has the potential to degrade water quality in the MS4. Permit Reference Permit Reference [Part III.B.2.g.i.B. 2)]: The permittee shall continue to implement a public education and outreach program component to promote, publicize, and facilitate: 2) the proper management and disposal of used oil and household hazardous wastes; The Dallas County Home Chemical Collection Center (HCCC) provides a convenient and local disposal option for community members to properly dispose of household hazardous and non hazardous substances. Encouraging participation in City sponsored waste collection days as well as use of the HCCC for waste disposal, removes hazardous and non hazardous substances from potentially impacting water quality in the MS4. C.5 Facilitate Public Reporting and Response Source controls and an established spill response program provide a systematic approach to minimize and prevent, where feasible, hazardous and non hazardous substances from entering a water of the state. Permit Reference Permit Reference [Part III.B.2.g.i.B.1) The permittee shall continue to implement a public education and outreach program component to promote, publicize, and facilitate: 1) public reporting of illicit discharges or improper disposal of materials, including floatables, into the MS4; The City uses the 311/911 system for receiving and dispatching notice of hazardous and non hazardous spills. These systems are actively promoted by the outreach and service response personnel as the most efficient way of reporting incidents, because the calls are tracked in the Customer Response Management System (CRMS), and responses are generally made in a more timely manner. D. Public Participation and Involvement The City will engage the community in stormwater related activities to encourage the protection and enhancement of stormwater quality. Like the outreach program itself, the program, will include opportunities for a wide variety of people who live, work and play in Dallas to participate in the SWMP development and implementation. Permit Reference Permit Reference [Part III.B.2.g.ii] Within one year from the date of permit issuance, the permittee shall develop and implement a public involvement and participation program which complies with State, Tribal, and local public notice requirements. This program element must include opportunities for a wide variety of constituents within the MS4 area to participate in the SWMP development and implementation. City of Dallas MS4 Page 5 55 Final Draft SWMP

80 Public participation/ involvement will be conducted by providing opportunities for volunteer involvement, and by actively soliciting input and feedback to the SWMP update and revision process. D.1 Education and Outreach Program Evaluation The City will correlate water quality data, locations and types of notices of violation, and CRMS customer service requests, along with the Outreach efforts, to allow targeting of specific messages to a specific audience. Adjustments to the program will be recommended, as needed, in the annual report. D.2 Volunteer Opportunities The City continues to facilitate volunteer participation in the Texas Stream Team Volunteer Water Quality Monitoring Program (formerly Texas Watch ). These activities are part of a state wide program that promotes watershed stewardship by soliciting volunteers to monitor ambient water quality in local creeks, lakes, and rivers. Volunteers monitor for: ph, air temperature, water temperature, conductivity, and dissolved oxygen, and make field observations. The City also promotes increased community awareness and protection of stormwater quality by encouraging participation in the storm drain marking program. D.3 SWMP Development and Public Involvement SWMPs can be a great tool to use in fostering community stewardship of the streams and creeks of their neighborhoods. The SWMP is also improved by involving the community into the process of developing and implementing the program. The public gains greater insights into the program challenges, and the program in turn, gains insights into the community s priorities. The City will engage the public in the development of the SWMP by providing related information on the City s websites and newsletter, and by providing a web portal to solicit input into the new draft SWMP, to provide information concerning program activities, and to solicit feedback to be used to develop future annual SWMP updates. Table 5 7 provides a list of the activities, measurable goals, or metrics to be tracked, and the implementation schedule for the SCMs described under Element 7 Public Education and Outreach/Public Involvement. City of Dallas MS4 Page 5 56 Final Draft SWMP

81 Table 5-7 Element 7: Public Education and Outreach/Public Involvement Activities Metrics to be Tracked Annually Implementation Schedule A. Public Education A.1 Community Education 1. Present one (1) annual presentation to community organizations in each of the five (5) target programs: Illicit discharge (IDDE) Pesticides, herbicides and fertilizers (PHF) Used Oil Toxic Materials (UOTM) Pet waste Yard waste Number of presentations for each program, and attendees A.2 School Education 1. Present five (5) educational presentations per year to K-12 students within the City s watersheds, including assemblies, camps, story time, and library events. Number and geographic distribution of presentations A.3 Business Education 1. Present one (1) annual presentation to businesses/ trade organizations in each of the five (5) target programs: Illicit discharge (IDDE) Pesticides, herbicides and fertilizers (PHF) Used Oil Toxic Materials (UOTM) Yard waste Animal waste Number and geographic distribution of presentations City of Dallas MS4 Page 5 57 Final Draft SWMP

82 B. Technical Training Table 5-7 Element 7: Public Education and Outreach/Public Involvement Activities Metrics to be Tracked Annually Implementation Schedule B.1 Construction Site Operator Program 1. Present two (2) workshops to contractors, operators and construction site affiliated personnel on acceptable construction site SCMs, per year. # of workshops provided and number of attendees 2. Present on-site consultations to operators and construction site personnel on site-specific construction site SCMs, per year. 3. Present on-site tail-gate training sessions to operators and construction site personnel on acceptable construction site SCMs, per year. B.2 Industrial Operator Workshops Present two (2) workshops to industrial operators on TPDES stormwater permit requirements, per year. B.3 Municipal Staff Training (Inreach) # of consultations provided and number of attendees # of tailgate training sessions provided and number of attendees Workshops provided and number of attendees 1. Publish two (2) electronic announcements addressing stormwater management, per year. 2. Provide two (2) internal training events on current stormwater issues, per year. # of Announcements published Topic(s) of announcements published # training events and attendees 3. Educate employees about stormwater pollution prevention practices. Number of employees completing Stormwater Awareness Training during new employee orientation City of Dallas MS4 Page 5 58 Final Draft SWMP

83 Table 5-7 Element 7: Public Education and Outreach/Public Involvement Activities Metrics to be Tracked Annually Implementation Schedule 4. Provide at least one (1) internal and one (1) community training on spill prevention, per year. 5. Provide at least one (1) internal City spill response training, per year. Training events conducted on Spill Prevention and number of attendees Training events conducted on Spill Response and number of attendees 6. Identify City employees certified to perform incident response. C. Public Participation/Involvement C.1 Education and Outreach Program Evaluation Number(s) of staff trained and types of certifications 1. Evaluate the existing stormwater education program for effectiveness and make recommendations for potential changes to the SWMP in the annual report. C.2 Volunteer Activities/Participation Number of people reached determined by attendance records and website activity Document geographic distribution of outreach program activities in correlation with annual water quality data Permit Years 1, 3 and 5 Permit Years 1, 3 and 5 1. Encourage participation in the Texas Stream Team volunteer water quality monitoring program within the City limits of Dallas. # of Texas Stream Team trainings and recertified members Number of participants and watersheds represented 2. Encourage participation in the storm drain marking program. Number of participants and watersheds represented # of Storm drains marked City of Dallas MS4 Page 5 59 Final Draft SWMP

84 Table 5-7 Element 7: Public Education and Outreach/Public Involvement Activities Metrics to be Tracked Annually Implementation Schedule C.3 SWMP Development/Public Involvement 1. Develop update to website(s) to solicit public input. Update(s) made, and comments received Permit Year 1, 3 and 5 2. Develop newsletter article(s) to solicit public input Article(s) printed, and comments received City of Dallas MS4 Page 5 60 Final Draft SWMP

85 ELEMENT 8: MONITORING, EVALUATION AND REPORTING A comprehensive monitoring and assessment program has been established to track progress in complying with permit provisions and to protect water quality of receiving waterbodies in the MS4. The City of Dallas has elected to perform the required storm event discharge monitoring under Permit Section IV, Option 1, NCTCOG Regional Wet Weather Characterization Program (RWWCP), and Option 3, Representative Rapid Bioassessment sampling, as augmented by dry weather monitoring and local wet weather sampling. All sample locations are indicated on the MS4 map located in Appendix A. Sample protocols are included in Appendix D. The screening and monitoring efforts include both dry and wet weather screening, Rapid Bioassessment Protocol (RBP) monitoring, industrial and high risk runoff monitoring, and limited pilot construction effluent guideline (ELGs) monitoring. The City is also participating in regional efforts related to Total Maximum Daily Loads (TMDLs) to address bacteria, and polychlorinated bi phenols (pcbs) in fish tissue in the Trinity River. These data are used to guide efforts of the SWMP and to evaluate overall effectiveness of the SWMP in making measurable improvements in the water quality of the Dallas creeks and rivers. Applicable Stormwater Control Measures A. Monitoring and Screening Current surface water conditions within the MS4 are characterized through a comprehensive monitoring and screening program that includes dry weather screening, wet weather sampling of at least two watersheds per year, and rapid bioassessment protocol monitoring within the digit HUC defined watersheds with lands that are wholly, or partially contained within the MS4. Monitoring and screening results are used to evaluate implemented SCMs and focus additional SWMP resources to positively affect water quality. A.1 Dry Weather Screening The City s dry weather screening program focuses on identifying and eliminating illicit connections and improper discharges to the MS4, as described in Element 3 Illicit Discharge Detection and Elimination. Watersheds and subwatersheds are prioritized for dry weather screening by age of the neighborhood, age and condition of the infrastructure, and areas with heavy industrial and commercial land uses. Permit Reference [Part III.B.2.h.i.]: This program must continue efforts to detect the presence of illicit connections and improper discharges to the MS4. The permittee shall identify high risk and high priority areas, which shall include but are not limited to heavy commercial and heavy industrial areas. These high risk and high priority areas must be screened at least once during the permit term. City of Dallas MS4 Page 5 61 Final Draft SWMP

86 A.2 Wet Weather Screening The City monitors watershed response to wet weather events through a wet weather screening program designed to identify and investigate areas that may contribute excessive concentrations of pollutants to the MS4, and to establish baseline data on receiving streams. Because the pollutant load is typically higher during wet weather events, these data reflect a worse case scenario with respect to pollutants conveyed into the Trinity River. Permit Reference [Part III.B.2.h.ii]: The permittee shall identify, investigate, and address areas within their jurisdiction that may be contributing excessive levels of pollutants to the MS4. The wet weather screening program must: A)screen the MS4, as specified in the SWMP; and B)specify the sampling and non sampling techniques to be used for current screening and also for follow up screening. Wet weather water quality data from each watershed that is located entirely within the City limits are collected at least once during the permit term. The City s wet weather screening efforts are coordinated with the NCTCOG Regional Wet Weather Characterization Program to identify regional water quality trends, as data availability permits. Additional information on the City s Wet Weather Screening Program and the NCTCOG Regional Wet Weather Characterization Program is included in Appendix D. A.3 Rapid Bioassessment Protocol Monitoring The City performs rapid bioassessment protocol (RBP) monitoring in accordance with the TCEQ Surface Water Quality Monitoring Procedures, Volume 2: Methods for Collecting and Analyzing Biological Assemblage and Habitat Data (TCEQ, 2007, RG 416). The RBP monitoring evaluates the chemical, physical, and biological in stream features that promote a healthy and diverse habitat; as such, this method provides a good overall assessment of watershed conditions. The RBP monitoring involves performing an Aquatic Life Use assessment of all 32 of the 12 Digit HUC code watersheds within the City of Dallas boundaries, in addition to reference watersheds. Two sampling events are conducted each year in accordance with the spring and summer index periods from the TCEQ guidance. Additional information on the City s RBP monitoring is included in Appendix D. A.4 Industrial and High Risk Runoff Monitoring The City s industrial and high risk monitoring program evaluates the water quality of discharges to the MS4 by permitted industrial and high risk facilities that may contribute pollutant loads to the MS4. The City reviews the data or the No Exposure certifications provided by the permitted facilities. Data are reviewed for compliance with the individual facility permit requirements and the TPDES MSGP. A.5 Quality Assurance Program for Effluent Limitations Guidelines Monitoring The EPA recently adopted Effluent Limit Guidelines (ELGs) for Construction, in order to address the sediment load associated with many construction sites. These guidelines may go into effect during the City of Dallas MS4 Page 5 62 Final Draft SWMP

87 next permit term, and will require turbidity monitoring from construction sites with a disturbed area greater than 10 acres. The City will develop policy and guidelines for implementing these requirements, a standard operating guide for performing quality assurance sampling, and will train staff prior to the effective date of these regulations. Tracking the overall number of sites that fall into this size class will also allow an assessment of the overall impact of these regulations on current SWMP operations. A.6 TMDL Implementation Plan Development Two segments of the Upper Trinity River that pass through the City are presently included on the draft 2010 Clean Water Act Section 303(d) list of impaired waters for bacteria, and for polychlorinated biphenols (PCBs) in fish tissue. The City will continue to participate in the local and regional efforts to develop the TMDL implementation plans to address these known water quality impairments. As actions from these plans are known, the SWMP will be revised as necessary to incorporate the water quality improvement SCMs identified as a part of these TMDL Implementation Plans. The two segments of the Upper Trinity River that passes through the City are presently monitored by the Trinity River Authority (TRA) Texas Clean Rivers Program (TCRP). The data used to develop these TMDLs is based upon several years of data monitoring from one location in each river segment. The City of Dallas has joined the TCRP as a contributing partner, and is monitoring three additional locations within these segments in order to provide a larger data set. Monitoring is conducted on a quarterly basis. The locations for these sampling are included in the MS4 Map Appendix A. A copy of the Quality Assurance Project Plan for these efforts is included in Appendix D. Table 5 8 provides a list of the activities, measurable goals or metrics to be tracked, and the implementation schedule for the SCMs in Element 8 Monitoring, Evaluating and Reporting. City of Dallas MS4 Page 5 63 Final Draft SWMP

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89 A. Monitoring and Screening A.1 Dry Weather Screening Table 5-8 Element 8: Monitoring, Evaluation and Reporting Activities Metrics to be Tracked Annually Implementation Schedule Investigate flows from outfalls during dry weather, sample the discharge, investigate the source, and act to eliminate the discharge. A.2 Wet Weather Screening 1. Perform bi-annual wet weather screening within designated watersheds once per permit term in accordance with the local Wet Weather Sampling Program. 2. Coordinate with the NCTCOG Regional Wet Weather Characterization Program and perform sampling per RWWCP schedule. A.3 Rapid Bioassessment Protocol Monitoring 1. Perform Rapid Bioassessment Protocol monitoring in at least three (3) watersheds plus a reference site, per year. A.4 Industrial and High Risk Runoff Monitoring # of Outfalls inspected, discharges found, and sources identified Wet weather screening results for each watershed sampled Wet weather screening results for each watershed sampled RBP monitoring results 1. Identify and prioritize the facilities that have the potential to discharge pollutants into the MS4. # of Facilities required to submit monitoring data # of Number of data sets received and reviewed 2. Evaluate SCMs, or inspection and monitoring programs, for effectiveness. # of Facilities required to submit an Action Plan and/or more frequent monitoring to reduce pollutants discharged into the MS4 City of Dallas MS4 Page 5 65 Final Draft SWMP

90 Table 5-8 Element 8: Monitoring, Evaluation and Reporting Activities Metrics to be Tracked Annually Implementation Schedule A.5 Quality Assurance Program for Effluent Limitations Guidelines Monitoring 1. Identify scope of the Quality Assurance Program for the Effluent Limitations Guidelines (ELG) monitoring requirements within City limits. 2. Develop and implement City Quality Assurance Program for ELG monitoring program by: a) Developing standard operating guidelines (SOG) for ELG monitoring by City staff; b) Training City staff on ELG monitoring program; and c) Assessing ELG monitoring data from sites greater than 10 acres. 3. Evaluate the Quality Assurance Program for the ELG monitoring and recommend any changes, as needed. Number of construction sites greater than 10 acres per watershed Number of construction related complaints for projects greater than 10 acres per watershed Document SOG developed Permit Year 1 # of Staff trained Permit Year 2 - Permit Year 5 # of Sites monitored Permit Year 2 - Permit Year 5 Document the review was conducted Permit Year 3 - Permit Year 5 A.6 TMDL Implementation Plan Development 1. Develop Interim Bacteria Reduction Plan (ibrp) that outlines measures the City will implement to reduce Bacteria concentrations within the City Append ibrp to SWMP Permit Year 1 1. Participate in development of a Total Maximum Daily Load (TMDL) Implementation Plan for bacteria. 2. Participate in development of a TMDL Implementation Plan for polychlorinated biphenyls (PCBs) in fish tissue. 3. Provide ambient conditions sampling at three (3) locations along the Upper Trinity River in accordance with protocols included in the TRA CLRP QAPP. Document participation Document participation Provide ambient water quality results in SWMP Annual report City of Dallas MS4 Page 5 66 Final Draft SWMP

91 6.0 REFERENCES EPA Quality Criteria for Water (1986), EPA 440/ , 5/1/86 EPA MS4 Permit Improvement Guide, U.S. EPA, Office of Water, Office of Wastewater Management, Water Permits Division, EPA 833 R April. NCTCOG The North Central Texas Regional Wet Weather Characterization Plan Proposal for the Third Permit Term, Submitted to the TCEQ on December 13, 2010 (approved by letter dated February 11, 2011). NRC Urban Stormwater Management Report, National Research Council, prepared for the National Academy of Sciences, August. Skinner, J.F., Kappeler, J, and J. Guzman, Regrowth of Enterococci & Fecal Coliform in Biofilm, Studies of street gutters and storm drains in Newport Beach, CA, suggest causes for high bacteria levels Stormwater Magazine, June 30. Available at: TAC Texas Surface Water Quality Standards, 30 TAC Chapter 307 (effective July 22, 2010). TCEQ. 2010a. Two Total Maximum Daily Loads (TMDLs) for Indicator Bacteria in the Upper Trinity River, Dallas, Texas, Segment 0805, Assessment Units: 0805_03 and 0804_04. prepared by TCEQ, Field Operations Division, Region 4, Strategic Assessment Division, TMDL Team (adopted by TCEQ on May 11, 2011 and approved by EPA on August 3, 2011). Available at: trinitybacteria.html TCEQ. 2010b. Improving Water Quality in Dallas and Tarrant Counties, Nine TMDLs for Legacy Pollutants, Fact Sheet. August. Available at: dallas.pdf TCEQ Surface Water Quality Monitoring Procedures, Volume 1: Physical and Chemical Monitoring Methods, RG 415. Prepared by the Monitoring and Assessment Section, Water Quality Planning Division Texas Commission on Environmental Quality. October. TCEQ Surface Water Quality Monitoring Procedures, Volume 2: Methods for Collecting and Analyzing Biological Assemblage and Habitat Data. RG 416 Prepared by the Monitoring and Assessment Section, Water Quality Planning Division Texas Commission on Environmental Quality. June TCEQ "Procedures to Implement the Texas Surface Water Quality Standards," Texas Commission on Environmental Quality, January TCEQ.2001a. Implementation Plan for Dallas and Tarrant County Legacy Pollutant TMDLs For Segments 0805, 0841, and 0841A, prepared by TCEQ, Field Operations Division, Region 4, Strategic Assessment Division, TMDL Team, August. City of Dallas MS4 Page 6 1 Final Draft SWMP

92 TCEQ Nine Total Maximum Daily Loads for Legacy Pollutants in Streams and a Reservoir in Dallas and Tarrant Counties For Segments 0805, 0841, and 0841A, prepared by TCEQ, Field Operations Division, Region 4, Strategic Assessment Division, TMDL Team (adopted by TCEQ on December 20, 2000 and approved by EPA on June 27, 2001). TCEQ The State of Texas Water Quality Inventory, 13th Edition, Publication No. SFR 50, Texas Commission on Environmental Quality, December. Zarriello, P.J., Breault, R.F., and Weiskel, P.K., 2003, Potential Effects of Structural Controls and Street Sweeping on Stormwater Loads to the Lower Charles River, Massachusetts: U.S. Geological Survey Water Resources Investigations Report , 48 p. City of Dallas MS4 Page 6 2 Final Draft SWMP