HomeMy WebLinkAboutUtilities 2011-03-15 Item 2A - Color 2011 Stormwater Management ProgramCity of Tukwila
2011 Update
Stormwater Management Program
(SWMP)
Prepared By
City of Tukwila
Public Works Department
Permit #WAR04 -5544
City of Tukwila
Stormwater Management Program
March, 2011
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City of Tukwila
Stormwater Management Program
Table of Contents
1 INTRODUCTION ..............................3
2. NPDES PHASE II PROGRAM COMPONENTS ..............................4
2.1 Public Education and Outreach ..............................4
2.2 Public Involvement and Participation ..............................6
2.3 Illicit Discharge Detection and Elimination ..............................7
2.4 Controlling Runoff from New Development, Redevelopment, and
ConstructionSites .............................10
2.5 Pollution Prevention and Operation and Maintenance for Municipal
Operations.................................................................................... .............................12
2.6 Monitoring .............................15
3 CONCLUSION .............................16
City of Tukwila
Stormwater Management Program 2 of 16 A.larch, 2011
1. INTRODUCTION
The National Pollutant Discharge Elimination System (NPDES) permit program is a
requirement of the federal Clean Water Act. The federal Environmental Protection
Agency (EPA) has delegated permit authority to state environmental agencies. In
Washington, the NPDES delegated permit authority is the Washington State Department
of Ecology (DOE). The City must comply with the Phase II Municipal Stormwater
Permit.
This document was prepared by the City of Tukwila to meet the requirements for a
Stormwater Management Program (SWMP) as required by the NPDES Phase II Permit
issued by the DOE. The SWMP was developed to outline the reduction of pollutant
discharges from the City's Municipal Separate Storm Sewer System (MS4).
The Permit allows discharge of stormwater runoff from municipal drainage systems into
the state's water bodies (i.e., streams, rivers, lakes, wetlands, etc.) as long as
municipalities implement programs to protect water quality by reducing the discharge of
"non -point source" pollutants to the "maximum extent practicable" (MEP). In addition,
the City must meet "all known and reasonable treatment" (AKART) through application
of Permit specified "best management practices" (BMPs). The practices specified in the
Permit are collectively referred to as the SWMP and grouped under the following
program components:
o Public Education and Outreach
o Public Involvement and Participation
o Illicit Discharge Detection and Elimination
o Controlling Runoff from New Development, Redevelopment and Construction
Sites
o Pollution Prevention and Operation and Maintenance for Municipal Operations
The Permit requires that the City report annually (by March 31 of each year) on the
SWMP implementation from the prior year. The Permit also requires submittal of
documentation that describes proposed program activities for the coming year. As of
December 31, 2010, the City meets the initial Permit requirements.
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2. NPDES PHASE 11 PROGRAM COMPONENTS
Tukwila is defined as a Phase II community by the Washington State Department of
Ecology and, therefore, is required to comply with the requirements of the Phase II
National Pollution Discharge Elimination System Stormwater (NPDES) Permit. Phase II
communities are those that:
o Own and operate a storm drain system
o Discharge to surface waters of the state
o Are located in urbanized areas
o Have a population of more than 1,000
Phase II communities were required to complete a NPDES Phase II Stormwater Permit
Application and submit to the DOE by March 10, 2003. The NPDES Phase II Permit was
issued to Tukwila on January 17, 2007 and went into effect on February 16, 2007. The
Permit was modified on June 17, 2009 and expires on February 15, 2012.
As stated, the major program components listed in the Permit are as follows:
o Public Education and Outreach
o Public Involvement and Participation
o Illicit Discharge Detection and Elimination
o Controlling Runoff from New Development, Redevelopment and Construction
Sites.
o Pollution Prevention and Operation and Maintenance for Municipal Operations
The following sections describe each of the program components and how the City is
currently addressing each requirement and the City's future planned activities. In general,
the City of Tukwila is currently performing all required NPDES Phase II Permit activities
and has programs in place to address future requirements.
2.1 PUBLIC EDUCATION AND OUTREACH
2.1.1 Permit Requirements
Section S5.C.1 of the Phase II permit requires that the City provide an educational and
outreach program for the area served by its MS4 no later than 2/15/2009. The purpose of
this program is to reduce or eliminate behaviors and practices that cause or contribute to
adverse stormwater impacts. The educational program will target audiences including:
the general public, businesses, industries, elected officials, policy makers, planning staff,
engineers, maintenance staff, and other City employees. Records of public education and
outreach activities including measurements of understanding and adoption of targeted
behaviors need to be tracked and maintained throughout the Permit's duration.
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2.1.2 Current Activities
The City currently has an active public educational and outreach program that uses a
variety of approaches to inform residents and businesses about stormwater related
pollution prevention activities. The City uses many resources for educational information
such as DOE's Hazardous Waste and Toxics Reduction Program, Environmental
Protection Agency's Region 10 Pacific Northwest, King County's Department of Natural
Resources and Parks, Water Resource Inventory Area 9, and local environmental
organizations. The City's current educational activities consist of the following:
Water Course Signing
The City has placed and maintains signs at all stream crossings to educate
pedestrians and motorists of the location of local streams. Signs read
"This Stream Is In Your Care
2. Catch Basin Labeling
o All new public or private catch basins are required by City standards to be
labeled with a torch down pavement decal stating "Dump No Waste
Drains to Stream
o All paving projects, both private and public, that pave around an existing
catch basin are required to label all catch basins with a torch down
pavement decal stating "Dump No Waste Drains To Stream
o All inlet castings are required by City standards to be labeled "Outfall to
Stream Dump No Pollutants
City Newsletter Article
The City of Tukwila publishes a newsletter 5 times a year and includes articles
concerning stormwater related topics at least 4 times a year. Typical topics
covered include:
o Car Washing
Illegal dumping of materials in storm drains
Landscape chemicals
Proper disposal and methods of reducing household hazardous wastes
4. Water Quality Brochures
The Public Works Department has brochures and handout materials available and
on display that include the following topics:
o Spill Kit Pilot Program, Stormwater Education for Businesses
o Puget Sound Shoreline Stewardship Guidebook
o Disposing of Hazardous Wastes Information Card
o Hazardous Waste Directory
o Ecology Shoptalk, Spills -Who Do You Call?
o Antifreeze Recycling
o EPA's Information Sheet Regarding Oil /Water Separators
o Automotive and the Do It Yourselfer
o Puget Sound Shoreline Stewardship Guidebook
o Ecology Five Steps to Natural Yard Care
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o Pet Waste Brochures that Specifically Address Stormwater Pollution
Prevention
User Surveys
The City conducted a survey to a targeted audience that measured the public's
understanding of surface water related topics. Information obtained from the
survey will be used to guide future education and outreach programs.
6. Regional Outreach
Participate in the King County's regional outreach forum, STORM, on an
ongoing basis to share ideas on public education efforts.
2.1.3 Planned Activities
The City will continue all current public education and outreach activities listed above
and will add the following activities in 2011:
1. Additional Water Quality Brochures that become available
2. Offer Environmental Stewardship Training
3. Tukwila Reporter (new for 2011) will be used to publish storinwater articles
4. Provide Residential Recycling Collection Event
5. Distribute King County Drainage Maintenance Standards for Commercial and
Multi Family Drainage Facilities
6. Initiate development of an Elementary School Education Series
7. Conduct a Stormwater Community Survey (required annually)
8. Car Wash Activities will be directed to the Multi Family Residences (for
example, apartment and condominium properties)
9. Installation of metal storm drain markers at catch basin locations
2.2 PUBLIC INVOLVEMENT AND PARTICIPATION
2.2.1 Permit Requirements
This program component requires that the City include ongoing opportunities for public
involvement through advisory councils, committees, and participation in developing rate
structures and environmental activities. In addition, the public will have opportunities to
aid in the development of the City's SWMP annual report(s) and other submittals.
2.2.2 Current Activities
The City has several ongoing public involvement and participation activities that
compliment and work with the City's public education and outreach activities. These
activities include the following:
1. City Website
The City makes available all required permit submittals as well as Stormwater
planning documents for public information and comment. Posted information
includes:
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o General NPDES Information
o Annual NPDES Reports
o Annual SWMP Updates
o City Infrastructure Design and Construction Standards
o Surface Water Studies
o Illicit Discharge Contact Information
o Council and Committee Agenda
o City News Articles
2. Public Meetings
The City uses the following public meetings for all contracts, required submittals,
programs, and budgets related to NPDES:
o City Council
o Committee of the Whole
o Utilities Committee
2.2.3 Planned Activities
The City will offer Environmental Stewardship Training. This program element
will provide training for citizens who want to learn how to care for wetlands,
streams, and buffers.
2. The City will provide an opportunity for a Hands -On Environmental Stewardship
Work Party. This work party will consist of City and other community volunteers
that will work to complete a small stream buffer restoration project.
Continue with the Pet Waste Program and invite dog owners to participate in the
publication of brochures.
4. Provide a Stormwater Community Survey with other Phase 11 Communities.
The City will continue all current public involvement and participation activities listed
above. The City will update all required NPDES information including the 2011 SWMP
and 2010 Annual Report on its website www. ei. tukwila .wa.us /Dubwks /nDdes.html) by
March 31 of each year. Any other submittals required by the Permit will also be posted
as necessary on the website.
2.3 ILLICIT DISCHARGE DETECTION AND ELIMINATION (IDDE)
2.3.1 Permit Activities
The City is required to implement an ongoing program to detect and remove illicit
connections, discharges, and improper disposal, including any spills not under the
purview of another responding authority, into the MS4 owned or operated by the City.
The goals and requirements of the program are as follows:
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o Develop a municipal storm sewer system map that includes information on the
City's MS4 (for example, outfalls, receiving waters, connection points, and areas
that don't discharge to surface water, etc.).
o Effectively prohibit, through ordinance or other regulatory mechanism, non
stormwater, illegal discharges, and dumping into the City's MS4, including
locating priority areas likely to have illicit discharges.
o Develop and implement a program to detect and address non- stormwater
discharges, spills, illicit connections, and illegal dumping into the City's MS4.
o Inform public employees, businesses, and the general public of hazards associated
with illegal discharges and improper waste disposal.
o Implement procedures for program evaluation and assessment which includes a
program to track spills and illicit discharges (both number and type), record
inspections made and any feedback received from public education effort.
o Provide appropriate training to City employees on IDDE into the City's MS4.
o Establish a hotline number for public reporting of spills and other illicit
discharges. Maintain a record of all calls received and actions taken.
2.3.2 Current Activities
The City currently has several of the elements required for an IDDE program in place and
others will be developed as required. Current activities include the following:
Outfall Mapping
The City began a geographic information system (GIS) mapping program in 2003
that has mapped approximately 90% of the City. All receiving water body
outfalls have been mapped. The City has funding in place to complete mapping
by the required permit deadline of 2/15/2011. This program includes mapping all
public surface water pipes 8" and larger and obtaining system information such as
pipe invert, condition, and material. All GIS information is then added to the
City's GIS Database and is available for staff use. The information is also
provided upon request to the public.
2. Reporting Hotline
The City has an advertised reporting phone number, (206) 433 -1860, where
illegal dumping and spills can be reported.
Training Program
The City has an ongoing training program that consisted of the following
activities:
o Staff training was conducted on June 29, 2010 for 14 employees, which
consisted of Parks and Golf maintenance field supervisors, technicians and
specialists.
o Staff training was conducted on November 17, 2010 for 4 employees,
which consisted of Development Engineers and a Construction Inspector.
4. Video Inspection
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Stormwater Management Program 8 of 16 March, 2011
The City's Surface Water Maintenance's inspection program is divided into four
zones. Video equipment is used to inspect storm water piping in these zones. This
2010 reporting period consisted of condition based video inspections. Illegal pipe
connections and questionable discharges are investigated and corrective measures
are taken when warranted.
5. Car Wash Program
As part of the City's ongoing public education program, a SudSafe Car Wash
program is in place. All organized charity car washing events must use this
program. In addition, facilities without a commercial wash base are allowed the
use of a sudsafe car wash kit providing the discharge is limited to the sanitary
sewer.
6. Spill Response Kit
The City has a Spill Response Kit Program that targets potentially polluting
activities within the commercial and industrial areas of the City.
7. IDDE Ordinance
The City adopted a new IDDE Ordinance on 2/16/2010 that fully complied with
NPDES Permit requirements.
8. Implementation of an Industrial and Commercial Inspection Program that targets
businesses with potential pollutant activities.
2.3.3 Planned Activities
The City will continue all current IDDE activities listed above. In addition to these
activities, the City will implement the following activities in 2011:
1. Outfall Mapping
The City will complete Area 7 of our GIS mapping program.
2. Monitoring
Continue with monitoring the prioritized Receiving Waters. These are three
outfalls, one within the Green River and two within the Duwamish River, for
visual inspection and for potential future testing. The characteristics of the
outfalls are:
o Strander Blvd This outfall drains a portion of the Tukwila Urban Center
which is a highly developed commercial center. The discharge area
contains primarily office and retail businesses as well as City storm
drainage.
o Allentown (South 122' Outfall) This outfall drains the majority of the
Allentown neighborhood which is primarily made up of single family
residents and City roadways. The area is an older neighborhood and
surface waters are discharged directly into the Duwamish River without
treatment.
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Stormwater Management Program 9 of 16 Alarch, 2011
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o South 104 Outfall This outfall drains industrial facilities along a
portion of East Marginal Way South. Surface waters are discharged into
the Duwamish River without treatment.
3. Training Program
The City will continue with a staff training program that will consist of the
following activities:
o Staff training for all new employees and any additional field personnel
missed during the last training session.
o Staff training for new techniques and procedures as they become known.
4. Reporting Spill Hotline
The City will continue to evaluate the existing spill hotline procedure to
determine if this method is working as intended and modify the procedure if
necessary.
5. The City started an industrial and commercial inspection program in late 2009.
This program will continue to be developed and implemented.
6. Car wash activities will be directed to the multi family residences (apartment
rental properties).
2.4 2.4 CONTROLLING RUNOFF FROM NEW DEVELOPMENT,
REDEVELOPMENT, AND CONSTRUCTION SITES
2.4.1 Permit Requirements
The Phase Il Permit requires that the City develop, implement, and enforce a program to
reduce pollutants in stormwater runoff to its MS4 from any new development,
redevelopment, and construction site activities that result in a land disturbance of greater
than or equal to one acre including projects less than one acre that are part of a larger
common plan of the development or sale. The minimum elements included in this
program are:
o An ordinance or other regulatory mechanism to address runoff from new
development, redevelopment, and construction site projects. City codes,
ordinances and development specifications may require smaller sites to comply
with these requirements as well.
o Develop and implement a permit process with plan review, inspection, and
enforcement capability including adequate long -term operation and maintenance
of the stormwater facilities and infrastructure.
o Develop and implement procedures for documenting inspections and enforcement
actions.
o Make available copies of the Notice of Intent for Construction Activity and Notice
of Intent for Industrial Activity for representatives of new developments and
redevelopments.
o Develop and implement a training program for staff responsible for implementing
the program to control stormwater runoff from new development, redevelopment
City of Tukwila
Stormwater Management Program 10 of 16 .March, 2011
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and construction sites including permitting, plan review, construction site
inspection and enforcement.
2.4.2 Current Activities
The City has an active program to reduce pollutants in stormwater runoff from new
development, redevelopment, and construction site activities. The existing program
applies to both public and private projects, including roads. The current compliance
activities associated with the above permit requirements are summarized below:
o The City amended city codes and revised standards to meet permit requirements
for development, redevelopment, construction and post construction stormwater
management, including escalating enforcement provisions for illicit discharge
originating from construction sites. The development related codes became
effective February 15, 2010 which are included in Ordinances 2274 and 2275.
In summary, for the purpose of development and redevelopment the City follows the
listed items:
Design Standards
The City uses the minimum design standards of the 2009 King County Surface
Water Design Manual with an option to use DOE's Surface Water Management
Manual for Western Washington.
2. Construction Site Inspection
All sites are inspected by the City prior to the start of construction. The City
tracks and maintains inspection records and enforcement actions by staff.
3. Construction Standards
City's Infrastructure Design and Construction Standards, and WSDOT Standard
Specifications for Road, Bridge, and Municipal Construction are used for
construction standards.
4. Enforcement
TMC 8.45 provides for a system of escalating enforcement procedures necessary
to sustain the existing codes and standards throughout the construction and
development process.
5. Notice of Intent
The City provides Notice of Intent for Construction Activity and Notice of Intent
for Industrial Activity to representatives of proposed new development or
redevelopment projects.
6. Long -term operation and maintenance of stormwater control facilities is provided
for by ordinance whereby maintenance responsibility, standards and inspection
procedures are addressed.
City of T ukwila
Stormwater Management Program 11 of 16 Alarch, 2011
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7. Runoff control from project sites that require a Department of Ecology
stormwater permit is also subject to City runoff control requirements.
8. Appropriate staff members are CESCL- certified (Construction Site Erosion
and Sediment Control).
2.4.3 Planned Activities
1. Continuing with construction site visits and creating an open forum for:
o Discussing types of pollution- prevention techniques
o Educating project personnel of impacts of pollution
2. Continue to improve Controlling Runoff by refining the following elements:
o Procedures
o Techniques
o Information Management
3. Continue staff training as necessary
4. Continue to develop an education and maintenance follow -up program for private
storm drainage facilities approved prior to the current NPDES Phase II permit.
2.5 POLLUTION PREVENTION AND OPERATION AND MAINTENANCE
FOR MUNICIPAL OPERATIONS
2.5.1 Permit Requirements
This minimum control measure requires that the City provide a pollution prevention and
operation and maintenance program including a training component that has the ultimate
goal of preventing or reducing pollutant runoff from municipal operations. All elements
of the operations and maintenance program must be in place by February 16, 2010. The
minimum elements included in this program component are:
Establishment of maintenance standards that are as protective, or more protective,
of facility functions than those specified in Chapter 4 of Volume V of the 2005
Stormwater Management Manual for Western Washington. The purpose of the
maintenance standards is to determine if maintenance is required on a particular
facility or structure. If maintenance is deemed necessary during inspection, the
following schedule is required for completion of the required maintenance:
o Within 6 months for typical maintenance
o Within 9 months for maintenance requiring re- vegetation
o Within 1 year for wet pool facilities and retention/detention pond
o Within 2 years for maintenance that requires capital construction of less
than $25,000.
2. Develop and implement an operations and maintenance (O &M) program with the
ultimate goal of preventing or reducing pollutant runoff from municipal separate
stormwater system and municipal operations and maintenance activities.
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Stormwater Management Program 12 of 16 March, 2011
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3. Perform required inspections of stormwater facilities on a regular basis.
Inspections will be documented with the work needed or completed on the
stormwater facilities according to the Permit requirements for reporting.
4. Develop and implement a program to reduce the stormwater impacts from streets,
parking lots, roads, highways, and other lands owned, operated or maintained by
the City, including road maintenance.
5. Develop and implement a training program for City employees whose job
functions may impact stormwater quality.
6. Develop a Stormwater Pollution Prevention Plan (S WPPP) for all heavy
equipment maintenance yards and material storage facilities owned or operated by
the City that is not required to have coverage under the Industrial Stormwater
General Permit.
2.5.2 Current Activities
The City has an active pollution prevention and operation and maintenance program
implemented by the City's Surface Water Maintenance Division. This program includes
the following activities:
Catch Basin Inspection
The City inspects all catch basins and inlets owned and operated by the City at
least once before the end of the permit term (minimum 5 -year rotating schedule).
If the catch basin has over 6 inches of deposited sediment in the sump, it will be
cleaned.
2. Conveyance System Inspection/Cleaning
The City's piped storm drainage system has been delineated into zones by the
Public Works staff. Pipe system maintenance is scheduled by zone, and each zone
is maintained on a 3 to 5 -year cycle. This includes repair of all pipes and catch
basins, with particular attention given to chronic problem areas and areas for
which complaints have been received from citizens.
Flow /Water Quality Facilities
The City inspects all surface water flow control and water quality facilities on an
annual basis. Maintenance is performed as needed and includes vegetative
control, structure repair, and sediment removal. Maintenance is performed at
least once every 10 years, or as needed through the current circuit or condition
based inspection and compliant process.
4. Drainage Complaints
The City responds to all stormwater related complaints. Complaints are submitted
to the City through Requests for Action (RFAs), Environmental Report Tracking
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System (ERTS), City Council meetings, letters, e- mails, and telephone calls.
These complaints are forwarded to the appropriate division and /or to the
respective property owner /project site.
5. Problem Areas
Maintenance staff keeps an informal list of problem areas occurring in the City's
ditch system. These problem areas are maintained every 3 to 5 years.
6. Video Inspection
The City maintains an annual closed circuit television (CCTV) inspection
schedule of its existing pipeline system to help identify illegal connections to
drainage systems, damaged, and obstructed sections of pipe. This information is
used to schedule repairs and further investigate illicit discharges and connections.
7. Hazardous Material Spills
Tukwila Fire Department responds to hazardous material spills. Though City
maintenance crews are often the first group to respond to spill complaints, they
are limited to the use of absorbent pillows and oil absorbing particulate materials.
2.5.3 Planned Activities
The City will continue with all programs and procedures currently in place. In addition to
these, the City will conduct the following activities in 2011:
Procedural Review
o The City will continue to review and revise, when necessary, all current
practices that reduce impacts from runoff or maintenance activities
associated with municipally owned or operated streets, parking lots, and
roads.
o The City will continue to develop and implement a more formalized plan
for inspection and documentation of all catch basins, inlets, stormwater
treatment and flow control facilities owned and operated by the City. The
plan will include performing spot checks on potentially damaged
permanent treatment and flow control facilities after major storm events.
o The City will continue to review and revise, as necessary, the current
S WPPP.
2. The City will continue with the current training program for existing and new
employees as needed and as new information and techniques become available.
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Stormwater Management Program 14 of'16 March, 2011
2.6 MONITORING
2.6.1 Permit Requirements
Permittees are required to prepare for the implementation of a comprehensive long -term
monitoring program under the next permit term. The program includes two components:
stormwater monitoring and targeted SWMP effectiveness monitoring.
The Permittees are not required to conduct water quality sampling or other testing during
this permit term, with the following exceptions:
o Water quality monitoring required for compliance with TMDLs (Total Maximum
Daily Pollutant Loads).
o Any sampling or testing required for characterizing illicit discharges pursuant to
the Illicit Discharge Detection and Elimination section of the permit.
2.6.2 Current Activities
The City currently has several of the elements required for a monitoring program in place
and others will be developed as required. Current activities include the following:
A TMDL has not been established for the City of Tukwila, so monitoring is not
required at this time. The Department of Ecology is currently conducting TMDL
analysis of the lower Duwamish River.
2. Outfalls
The City has developed and maintains a map of all MS4 outfalls as part of our
GIS mapping program and will continue to be developed.
3. The City has prioritized three receiving waters for visual inspections.
4. The Department of Ecology is assessing Phase I Permittees monitoring plans.
Upon completion of assessment, Ecology will provide the guidance needed for the
Phase II Permittees to develop their long term monitoring plans.
2.6.3 Planned Activities
The City will continue with all programs and procedures currently in place. In addition,
the City will conduct the following activities in 2011:
I. Monitoring Plan
o Conduct field assessment on at least one high priority water body.
o Continue to participate in the regional, state and local monitoring forums
to develop and integrate monitoring and assessment requirements.
o Prepare to develop a long -term monitoring plan once the Department of
Ecology provides further guidance.
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3. CONCLUSION
This Surface Water Management Program has been prepared to demonstrate compliance
with the requirements of the NPDES Phase II Permit and outline planned activities for
2011. This SWMP will be a working document until the final plan is to be completed by
August 19, 2011.
There are multiple tasks that the City is undertaking to align itself with the Permit
requirements and the many elements that need to be accomplished and built upon.
The Public Education and Outreach Program has been implemented and exciting
opportunities exist to be even more creative in developing a program that reaches out
with useful information that will benefit the general public, business district, and
industrial community.
The City has an ongoing Illicit Discharge Detection and Elimination Program in place
and will continue to update it with staff training, enforcement of the IDDE ordinance, and
distribute additional educational materials.
With the knowledge base that the City has in place, controlling runoff from new
development, redevelopment, and construction sites will now be more manageable.
With the use of various SWPPP's and the 2009 King County Surface Water Design
Manual, the City has a program in place that meets its obligation of pollution prevention
for municipal operations.
Additional information on the City's NPDES program can be found online at
http://www.ci.tukwila.wa.us/pubwks/npdes.html.
The public is encouraged to participate in the development of the SWMP. Please contact
the Public Works Department with questions, comments, or ideas.
Contact Information:
Mail: Greg Villanueva, NPDES Coordinator
City of Tukwila
Department of Public Works
6300 Southcenter Blvd. Suite 100
Tukwila, WA 98188 -8548
Phone: 206 431 -2442
Email: 2villanueva a,ci.tukwila.wa.us
Website: www .ei.tukwila.wa.us /pubwk/npdes
(W:PW Png/ Projects /A- DR/93 -dr10 /2010 Annual Report/SWMP 2011)
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