LUTC PKT 03-03-2008OR I 0i I NAL
MEETING AGENDA
1. CALL TO ORDER
2. APPROVAL OF MINUTES: February 25, 2008
3. PUBLIC COMMENT (3 minutes)
4. BUSINESS ITEMS
A. SWMP Plan and Annual Report
5. FUTURE MEETINGS/AGENDA ITEMS
6. ADJOURN
Committee Members
Linda Kochmar, Chair
Jim Ferrell
Dini Duclos
G:ILUTCILUTCAgenelas and Summaries 1008U-03-08 LUTCAgenda.doc
Action 30 min/Bucich
City Staff
Cary M. Roe, P.E., Assistant City Manager/Emergency Manager
Darlene LeMaster, Administrative Assistant H
253-835-2701
City of Federal Way
City Council
Land Use/Transportation Committee
City Hall
March 31 2008
Council Chambers
6:00 p.m.
MEETING AGENDA
1. CALL TO ORDER
2. APPROVAL OF MINUTES: February 25, 2008
3. PUBLIC COMMENT (3 minutes)
4. BUSINESS ITEMS
A. SWMP Plan and Annual Report
5. FUTURE MEETINGS/AGENDA ITEMS
6. ADJOURN
Committee Members
Linda Kochmar, Chair
Jim Ferrell
Dini Duclos
G:ILUTCILUTCAgenelas and Summaries 1008U-03-08 LUTCAgenda.doc
Action 30 min/Bucich
City Staff
Cary M. Roe, P.E., Assistant City Manager/Emergency Manager
Darlene LeMaster, Administrative Assistant H
253-835-2701
February 25, 2008
6:00 pm
City of Federal Way
City Council
Land Use/Transportation Committee
MEETING MINUTES
City Hall
City Council Chambers
In attendance: Committee Chair Linda Kochmar, Council Member Jim Ferrell, Committee Member Dim Duclos,
Assistant City Manager/Chief Operations Officer/Emergency Manager Cary Roe, Deputy Public Works Director Ken
Miller, City Staff Attorney Monica Buck, Surface Water Manager Paul Bucich, Director of Community Development
Services Greg Fewins, Senior Planner Margaret Clark, Street Systems Project Engineer John Mulkey, Acting Deputy
Public Works Director Marwan Salloum, Senior Planner Janet Shull, Street Systems Engineer Jeff Huynh and
Administrative Assistant II Darlene LeMaster.
1. CALL TO ORDER
Committee Chair Kochmar called the meeting to order at 6:05 p.m.
2. APPROVAL OF MINUTES
The February 4, 2008 LUTC meeting minutes were approved.
Moved: Duclos Seconded: Ferrell Passed: Unanimously, 3-0
3. PUBLIC COMMENT
There was no public comment.
4. BUSINESS ITEMS
A. 2008 Asphalt Overlay Program — Bid Award
John Mulkey provided background information on this item. There was no discussion.
Moved: Ferrell Seconded: Duclos Passed: Unanimously, 3-0
Committee PASSED Option 1 to the March 4, 2008, City Council Consent Agenda for approval.
B. Surface Water Infrastructure Maintenance and Service Contract — Bid Award
Paul Bucich provided background information on the item. There was no discussion.
Moved: Duclos Seconded: Ferrell Passed: Unanimously, 3-0
Committee PASSED Option 1 to the March 4, 2008, City Council Consent Agenda for approval.
C. SWM Callout Truck Bed Bid Award
Paul Bucich provided background information on the item. Committee Chair Kochmar asked where the
Fab Shop is located, to which Mr. Bucich answered Edgewood.
Moved: Ferrell Seconded: Duclos Passed: Unanimously, 3-0
Committee PASSED Option 1 to the March 4,'2008, City Council Consent Agenda for approval.
D. Clearing and Grading and Tree Preservation Overview
Greg Fewins introduced the topic to the committee and let the committee know that staff would like to
know how the committee would like them (staff) to proceed with this topic. Janet Shull provided
background information on the item. There were three public comments:
John Norris, Norris Homes - Mr. Norris spoke in support of affordable housing and how the current codes,
not to mention future codes are indirectly driving up home costs. Mr. Norris requested the committee
consider allowing flexibility for the developer to decide how/when to grade and replant; don't plan the
GALUTC\LUTC Agendas and Summaries 2008\02-25-08 Minutes.do
Land Use/Transportation Committee Page 2
February 25, 2008
development around the trees, plan the trees around the development. By clearing the plat first, you can
plant the trees in the appropriate places.
H. David Kaplan, Federal Way — Mr. Kaplan thanked staff for listening to and incorporating his comments
in their recommendations and wants the committees to consider what other cities do. He also encouraged
the committee to note his comments to the topic in Exhibit E, pp. 6-11. Other items he wanted the
committee to take note of are: retaining natural vegetation and whether or not that vegetation is invasive
or non-invasive, DNR (Dept. of Nat'l Resources) over-riding City codes (ie. Campus Drive), considering
fee in lieu of /offsite plantings as a last resort, and Exhibit C, p. 1 — recommended tree species (should be
considered strongly).
Garrett Huffman, King and Snohomish Counties Master Builders Association — Mr. Huffman asked what
exactly would be decided tonight by the committee. Committee Chair Kochmar explained that tonight's
presentation was just for staff to get direction from the committee on the issue at hand. There will be five
future opportunities for public comment to be heard prior to Council adopting any new code amendments.
Mr. Huffman wanted the committee to consider utilizing low impact development, possibly an incentive
program to retain trees (street trees, right of way trees and bike path trees). With smaller lot sizes and very
few remaining areas of vacant land, could trees be planted around the development versus within the
development?
Mr. Norris spoke again about monitoring and bonding significant trees. This process adds more costs to
the builder. It would be less costly just to add 15% more trees instead. Also the tree plan (currently a
requirement) is very expensive. This money would be better spent somewhere else. As the City re-
evaluates its tree ordinance, it needs to be made reader friendly. Committee Member Ferrell asked about
"root guard." Mr. Norris commented that root guard blocks roots from growing upwards, potentially
interfering with curbs, sidewalks, concrete and asphalt. To meet the current requirements, it costs more in
root guard and effort planting the tree, than the tree does itself. Committee Member Farrell asked how
Federal Way ranks amongst other cities. Mr. Norris said that in the past year, Federal Way has become
much easier to work with from the developer's perspective. The City is beginning to listen to the
developers. Committee Member Duclos asked for clarification between tree canopies and tree clusters. Mr.
Norris would like the city to be flexible and consider each property as a unique situation.
Committee Chair Kochmar summarized what has been heard this evening and that the Committee is
recommending staff's request to move forward with option 3 of the Policy Question. Committee Members
Duclos and Ferrell echoed each other, asking staff to go back to the Planning Commission and add
flexibility to developers into the code amendments. Ms. Shull wants the Committee to make sure and voice
their opinions about all issues they may be concerned with. Staff will go back to the Planning Commission
and present options to the Committee in the near future.
5. FUTURE MEETING
6. ADJOURN
The meeting adjourned at 7:18 PM.
G:\LUTC\LUTC Agendas and Summaries 2008\02-25-08 Minutes.doc
COUNCIL MEETING DATE: March _18, 2008ITEM #:
CITY OF FEDERAL WAY
CITY COUNCIL
AGENDA BILL
SUBJECT: NPDES Permit Requirements/Annual Report and SWMP
POLICY QUESTION: Does Council approve the 2008 Annual Report and Stormwater Management Program
(SWMP) documents for submittal to the Department of Ecology as required by the Western Washington
(NPDES) Phase II Municipal Stormwater Permit?
COMMITTEE: Land Use and Transportation Committee
CATEGORY:
® Consent ❑ Ordinance
❑ City Council Business ❑ Resolution
STAFF REPORT BY: Paul Bucich, P.E., SWM Manager
Don Robinett, ESA & NPDES Coordinator
MEETING DATE: March 3, 2008
❑ Public Hearing
❑ Other
DEPT: Public Works Department.
Attachments: Land Use and Transportation Committee memorandum dated March 3, 2008
2008 Annual Report and Stormwater Management Program
Options Considered:
1. Approve the 2008 Annual Report and SWMP documents and authorize the City Manager to submit to
the Department of Ecology by March 31" to satisfy the City's NPDES Permit obligations.
2. Do not approve the 2008 Annual Report and SWMP documents and provide direction to staff.
STAFF RECOMMENDATION: Staff recommends Option 1.
CITY MANAGER APPROVAL:
Council
DIRECTOR APPROVAL:
Conutittee— Council
COMMITTEE RECOMMENDATION: Place Option l on the March 18''', 2008 Council Consent Agenda for
approval.
Linda Kochmar, Chair Jim Ferrell, Member Dini Duclos, Member
PROPOSED COUNCIL MOTION: `I move approval of the 2008 Annual Report and SWMP documents and
authorize the City Manager to submit to the Department of Ecology by March 31" to satisfy the City's NPDES
Permit obligations. "
BELOW TO BE COMPLETED BY CITY CLERKS OFFICE
COUNCIL ACTION:
13 APPROVED COUNCIL BII L #
❑ DENIED 1sT reading
❑ TABLED/DEFERRED/NO ACTION Enactment reading
❑ MOVED TO SECOND READING (ordinances only) ORDINANCE #
REVISED — 02/06/2006 RESOLUTION #
CITY OF FEDERAL WAY
MEMORANDUM
DATE: March 3, 2008
TO: Land Use and Transportation Committee e44
VIA: Cary M. Roe, P.E., Assistant City Manager, Chief Operations Officer, Emergency Manager
FROM: Paul A. Bucich, P.E., Surface Water Manager
Don Robinett, CPESC, ESA & NPDES Coordinator
SUBJECT: NPDES Permit Requirements/Annual Report and SWMP
BACKGROUND:
The National Pollutant Discharge Elimination System (NPDES) is a federal permit that regulates
stormwater and wastewater discharges to waters of the State. While it is a federal permit, the regulatory
authority lies with Washington State Department of Ecology (DOE).
The NPDES Phase II Municipal Stormwater Permit for Western Washington was issued by DOE on
January 17, 2007 and went into effect on February 15, 2007. The permit requires that all affected
municipalities create and implement a Stormwater Management Program (SWMP) which addresses five
required program elements: 1) Public Education and Outreach, 2) Public Involvement and Participation,
3) Illicit Discharge Detection and Elimination, 4) Construction Site Run -Off, and 5) Operations and
Maintenance of Post Construction Stormwater Facilities. While the Permit went into effect in February of
2007, the permit phases program implementation requirements over the next four years.
In addition to the SWMP, the permit also requires permittees to submit an Annual Report intended to
update the DOE on the status of the permittee's compliance with the NPDES Phase II Permit. Annual
Reports must be submitted to DOE on or before March 31St of each year of the permit starting in 2008.
Since the effective date of this permit, City staff has been working with the DOE and several regional
forums to determine how to best meet the permit requirements. City staff has prepared the following
documents to meet the 2008 SWMP and Annual Report requirements as specified under the permit.
• The SWMP describes the City's applicable existing programs, as well as the plan to update and
modify these programs as necessary to meet the requirements of the permit. The SWMP is a
planning document which will be updated each year. The SWMP is considered a draft document
until the final document has been approved and supporting ordinances have been adopted by City
Council in 2011.
• The Annual Report is primarily a 92 item checklist intended to illustrate the City's compliance
with the NPDES Phase II Permit. [Note: Pursuant to the guidance provided by the Department of
Ecology, the answer "Yes" was only used when the program is fully implemented. The answer,
"No" or "NA" and brief comments were used to describe the status of all other permit
requirements.]
cc: Project File
Day File
44k
OF
Federal Way
Draft
2007 Annual Report
Issued March 2008
Pursuant to the
Western Washington Phase II
Municipal Stormwater Permit
#WAR 04-5516
Instructions on Filling out the Western WA Phase II Permit Annual Report
Form --Excel worksheet version
1. Complete all TABS in the worksheet: (1) Permittee Information; (2) Certification; (3) ANNUAL
REPORT (Section VI); (4) Info Collection (Section VII -A); (5) Info Collection (Section VII -B); (6)
Info Collection (Section VII -C); and (7) Info Collection (Section VII -D).
2. The Certification form/TAB must be signed and certified by the responsible official(s). All TABs
(except the INSTRUCTIONS) must be printed out and mailed to Ecology.
3. Answer every question. Use the Comments and Attachment fields only when necessary to
provide additional information.
4. Type in a 0 (zero) in the # field of the ANNUAL REPORT tab if no activity has occurred. Do not
leave the field blank. Do not type in NA (not applicable).
5. Do not add text to shaded fields.
6. Use the following tables to guide filling out the Y/N/NA field. The NA response is only available
for certain questions. See below.
7. Save your completed Annual Report and email the Excel worksheet PLUS attachments to:
PH2 WAnnRpt@ecy.wa.gov. Ecology cannot accept incomplete or partially completed
Annual Report forms.
For questions in the ANNUAL
REPORT and INFO
COLLECTION tabs, select
the category below that best
describes your program's
implementation status for the
reporting year.
If your answer is "YES"...
If your answer is "NO"...
Did you fully meet the permit
Mark Y in the Y/N/NA field.
Mark N in the Y/N/NA field.
requirement by the deadline
noted in the permit?
You may choose to provide
Provide following information in
additional detail about activities
Comments field: "reasons why,
from the previous year in the
corrective steps taken and proposed, and
Comments field.
expected dates that the deadline will be
met." [See S9.E.2.d for full description
of required additional information.]
Did you fully meet the permit
Mark Y in the Y/N/NA field.
Mark N in the Y/N/NA field if you have
requirement in advance of the
not fully met this requirement and note
permit deadline?
You may choose to note in
in Comments that the requirement
Comments that this requirement
deadline is not yet due.
has been met ahead of the permit
deadline.
IFnr thnse questions that accent an NA (not applicable) response...
-- - -- - -- -I ---- -- - - -- -- -- - - - -L.-
For questions 87-92 in Section VI and questions 1-4 in Section VII,
Mark NA in the Y/N/NA field.
Part D
Note in the Comments field that the
If this question does not apply to you...
requirement does not apply.
For questions 1-6 in Section VII, Part B:
Mark NA in the Y/N/NA field.
If you are not yet implementing BMPs for a component of the
Note in the Comments field that you are
SWMP...
not yet implementing this SWMP
component.
REMINDER: Proceed to the Permittee 1n#ovei i i 00"w#41#jt t ;
I. Permittee Information
Permittee Name
Permittee Coverage Number
City of Federal Way
WAR 04-5516
Contact Name
Phone Number
Paul A. Bucich, P.E.
253 835-2750
Mailing Address
PO Box 9718
City
State Zip + 4
Federal Way
WA 98063-9718
Email Adddress
Paul. Bucich@cityoffederalway.com
II. Regulated Small MS4 Location
Entity Type: Check the box that applies
Jurisdiction County Ci /Town Other
City of Federal Way X
Major Receiving Water(s)
The Puget Sound
III. Relying on another Governmental Entity
If you are relying on another governmental entity to satisfy one or more of the
permit obligations, list the entity and briefly describe the permit obligation(s) they
are implementing on your behalf below. Attach a copy of your agreement with the
other entity to provide additional detail.
Name of Entity: Permit Obligation(s):
N/A
IV. Certification
All annual reports must be signed and certified by the responsible official(s) of permittee or co -
permittees. Please print and sign this page of the reporting form and mail it (with an original
signature) to Ecology at the address noted below. An electronic signature will not suffice.
I certify under penalty of law, that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that Qualified Personnel properly gathered and
evaluated the information submitted. Based on my inquiry of the person or persons who manage the system or
those persons directly responsible for gathering information, the information submitted is, to the best of my
knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting
false information, including the possibility of fine and imprisonment for willful violations.
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a
2007 Annual Report - Appendix A (Stormwater Studies)
Description of stormwater monitoring, studies, or type of
information collected and analyzed during the reporting period.
Staff Contact
(S8.B.1)
Continuous water quality monitoring at four (4) in -pipe MS4 locations
Dan Smith,
1
utilizing automated instrumentation for flow, dissolved oxygen,
Water Quality Coordinator
temperature, and pH.
253-835-2756
2
Continuous water quality monitoring at one (1) in -pipe MS4 location
Dan Smith,
lity Water Quardinator
Coordinator
Co r
utilizing automated instrumentation for turbidity.
253-lity
Continuous water quality monitoring at three (3) surface water
Dan Smith,
3
locations utilizing automated instrumentation for flow, dissolved
Water Quality Coordinator
oxygen, temperature, pH, and turbidity.
253-835-2756
Continuous water quality monitoring at two (2) surface water
Dan Smith,
4
locations utilizing automated instrumentation for flow, dissolved
Water Quality Coordinator
oxygen, temperature, and pH.
253-835-2756
5
Continuous temperature monitoring at seventeen (17) individual (both
Dan Smith,
Coordinator
Co r
lity Water Quardinator
MS4 and surface water) sites utilizing automated loggers.
253-lity
Various grab samples collected to quantify stormwater contaminants
Dan Smith,
6
of concern associated with prohibited stormwater discharges and code
Water Quality Coordinator
enforcement action. Samples were submitted to a local environmental
253-835-2756
laboratory for analysis.
7
In -stream B -IBI macroinvertebrate samples collected and analyzed
Dan Smith,
Water Quality Coordinator
from seven (7) individual sites.
253-835-2756
Paul Bucich, PE
8
Catch basin sediment level monitoring.
Surface Water Manager
253-835-2750
9
Volunteer water quailty monitoring data. No quality control review or
Dan Smith,
o
lity Water QuaCoordinator
Co
Co r
data evaluation was conducted on this data.
253-lity
4k
OF Federal Way
Draft
Stormwater Management
Program
(SWMP)
March 2008
Pursuant to the
Western Washington Phase II
Municipal Stormwater Permit
# WAR 04 - 5516
Page 1 of 28
City of Federal Way
NPDES Phase II Stormwater Management Program
TABLE OF CONTENTS
TABLEOF CONTENTS.......................................................................................................... 2
BACKGROUND...................................................................................................................... 4
INTRODUCTION.................................................................................................................... 5
SECTION 1 - Public Education and Outreach......................................................................... 6
Targeted Audiences and Subject Areas................................................................................ 6
MeasureUnderstanding......................................................................................................11
Trackand Maintain Records............................................................................................... 11
SECTION 2 - Public Involvement and Participation..............................................................
12
Public Participation in Development of SWMP.................................................................
12
Evaluation of Public Comments.........................................................................................
13
Stewardship Programs & Environment Activities..............................................................
14
Web Page - SWMP and Annual Report ..............................................................................
14
SECTION 3 - Illicit Discharge Detection and Elimination....................................................
15
Municipal Storm Sewer Map..............................................................................................
15
Permit Requirement S.5.C.3.a
15
Illicit Discharge Detection and Elimination (IDDE) Ordinance .........................................
16
Implementationof IDDE....................................................................................................
16
Permit Requirement S.5.C.3.c
16
IDDE Education (Hazards Associated with Illicit Discharges) ..........................................
18
IDDEAssessment, Evaluation and Tracking......................................................................
18
Permit Requirement S.5.C.3.e
18
Municipal Field Staff Training ......................................................................................
(Permit Requirement S.5.C.3.f)..........................................................................................
19
SECTION 4 - Controlling Runoff from Construction Sites ...................................................
20
Program Ordinance and Enforcement Mechanisms...........................................................
20
Permit Requirement S.5.C.4.a
20
Permitting Process with Review, Inspection and Enforcement ..........................................
21
Inspection Program to Verify Long -Term Operation & Maintenance of Stormwater
Facilities..............................................................................................................................
23
Tracking Inspections, Enforcements, Warnings and Violations .........................................
24
NPDESForms Available to the Public...............................................................................
24
Verification Staff Responsible for Program Implementation are Trained ..........................
24
SECTION 5 - Pollution Prevention and Operations and Maintenance ...................................
25
MaintenanceStandards.......................................................................................................
25
AnnualInspections..............................................................................................................
25
SpotCheck Inspections.......................................................................................................
26
Page 2 of 28
City of Federal Way
NPDES Phase II Stormwater Management Program
CBand Inlet Inspections..................................................................................................... 26
Compliance with Inspection Requirements........................................................................ 26
Practices to Reduce Stormwater Impacts............................................................................ 26
BMPs to Reduced Pollutants Discharged from City Lands ................................................ 27
Develop & Implement On -Going Training......................................................................... 27
Develop and Implement SWPPPs (Heavy Equipment and Storage Yards) ........................ 27
Record Keeping and Tracking............................................................................................ 28
Page 3 of 28
City of Federal Way
NPDES Phase II Stormwater Management Program
BACKGROUND
The National Pollutant Discharge Elimination System (NPDES) is a federal permit
authorized under the Federal Clean Water Act of 1972 (as amended in 1977) that regulates
stormwater and wastewater discharges to waters of the State. While NPDES is a federal
permit, it is primarily administered by state governments. The NPDES Phase II Municipal
Stormwater Permit for Western Washington was issued by the Washington State Department
of Ecology on January 17, 2007 and went into effect on February 16, 2007.
While there are several types of NPDES permits, the municipal permit is intended to reduce
the impacts from both point source (i.e. construction site run-off) and non -point source
pollution carried by stormwater. Construction site run-off and non -point source pollution,
such as oils and metals from cars, fertilizers and pesticides from lawns, soaps from car
washes and pet waste are major contributors to water quality degradation in our lakes,
streams, wetlands and the Puget Sound.
One of the major requirements under the Municipal NPDES Permit is that all affected
municipalities create and implement a Stormwater Management Program (SWMP) which
addresses five required program elements: 1) Public Education and Outreach, 2) Public
Involvement and Participation, 3) Illicit Discharge Detection and Elimination, 4)
Construction Site Run -Off, 5) Operations and Maintenance of Post Construction Stormwater
Facilities. While the permit went into effect in February of 2007, the permit phases program
implementation requirements over the next four years.
Page 4 of 28
City of Federal Way
NPDES Phase II Stormwater Management Program
INTRODUCTION
This document has been prepared to meet the City of Federal Way's Western Washington
Phase II Municipal Stormwater Permit (Permit) requirement for development of a
Stormwater Management Program (SWMP) identified in Section S5.A.2 of the Permit.
The City's SWMP is designed to reduce the discharge of pollutants from the City's
Municipal Separate Storm Sewer System (MS4) to the maximum extent practicable (MEP),
meet Washington State's All Known and Reasonable Technology (AKART) requirements,
and protect water quality once it is fully implemented.
As will be demonstrated in the following sections, many of the required SWMP elements are
already being implemented by the City. The City will gather, track, maintain and use
information on an on-going basis to evaluate the SWMP development, implementation,
Permit compliance, and to set priorities as part of the implementation of the City's SWMP.
Pursuant to the requirements of the Permit, the SWMP will be updated annually until the
permit expires on February 16, 2012. The SWMP shall be considered a draft document and
used as a planning tool until such time as the SWMP and any supporting ordinances have
been formally adopted by the City of Federal Way City Council.
Relationship to 1995 Surface Water Management Comprehensive Plan
The following SWMP should be considered a draft update to Chapter III (Surface Water
Utility Programs) of the City of Federal Way 1995 Surface Water Management
Comprehensive Plan. The other chapters of the 1995 Comprehensive Plan are still in effect.
Page 5 of 28
City of Federal Way
NPDES Phase II Stormwater Management Program
SECTION 1 - Public Education and Outreach
"The SWMP shall include an education program aimed at residents, businesses, industries,
elected officials, policy makers, planning staff and other employees of the City. The goal of
the education program will be to reduce or eliminate behaviors and practices that cause or
contribute to adverse stormwater impacts. The City's education program may be developed
locally or regionally. " (Permit Requirement S5. C. 1)
Pursuant to Permit requirement S5. C. La., a Public Education and Outreach Program must
be in place by February 16, 2009.
The City of Federal Way maintains an active Public Education and Outreach Program. The
City uses a variety of approaches to inform residents and businesses about stormwater
pollution prevention, stewardship opportunities, capital improvement projects, watershed
planning and maintenance activities, engaging both citizens and stakeholders alike.
Public education is important to protecting our water resources. It is a utility goal to increase
water quality compliance by helping people realize their individual and collective
responsibilities for protecting our waterways. Public education and participation has also
proven to be a useful tool in water quality compliance and enforcement. An informed
community can be very effective at keeping a watchful eye on our waterways.
The Surface Water Management Division (SWM) is actively producing and distributing
public educational materials (i.e. posters, press releases, brochures, booklets and flyers) on a
variety of subjects related to improving water quality. All SWM publications are available
on the web at http://www.cityoffederalway.com/SWM.
Targeted Audiences and Subject Areas
(Permit Requirement S5. C.1. a)
SWM's existing programs listed below target a wide variety of audiences and subject
areas. The programs are organized by targeted audiences and subject areas as identified
in Section S5.C.l .a of the Permit.
i) The General Public
(1) Impacts of Stormwater Flows into Surface Waters and Impacts from
Impervious Surfaces
The broad topics of impacts from impervious surfaces and stormwater flows are
addressed several ways within SWM's existing public education, outreach and
involvement programs. Examples of these include our quarterly newsletter (The
Water Log), web pages, catch basin curb markers, charity car wash kits, natural
yard care and pet waste brochures.
Further, SWM staff is actively involved in the Regional NPDES Outreach
Forum with the goal of developing a regional stormwater educational campaign
for the greater Puget Sound area. The NPDES Regional Outreach Forum is a
Page 6 of 28
City of Federal Way
NPDES Phase II Stormwater Management Program
group of public education and outreach professionals from Phase I & II
jurisdictions from the greater Puget Sound area working together to share and
develop education and outreach programs and research.
(2) Source Control BMPs, Environmental Stewardship Actions, Pet Waste,
Vehicle Maintenance, Landscaping and Buffers
(a) Source Control BMPs
(i) Construction Site Erosion Control Brochure
SWM has developed an erosion/sedimentation control educational
brochure targeted at single family contractors. The brochure outlines
the erosion control inspection process and provides details on the
standard best management practices (BMPs). The brochure is
currently attached to all new single family construction permits.
Brochures are also distributed by SWM inspectors to contractors at the
preconstruction conference.
(ii) Restaurant Industry Poster
The Good Cleaning Practices for the Restaurant Industry Poster
describes industry specific waste disposal and cleaning best
management practices in three languages, English, Spanish and
Korean. The poster is intended to reduce the number of illicit
discharges from restaurant businesses. The posters were delivered to
all restaurants within the City of Federal Way in 2004 and continue to
be handed out through the Illicit Discharge Detection and Elimination
(IDDE) program.
(iii) Auto Industry Poster
The Good Cleaning Practices for the Automotive Industry Poster
describes industry specific waste disposal and cleaning best
management. The poster is intended to reduce the number of illicit
discharges from restaurant businesses. The posters are distributed
every few years through door to door distribution, as well as through
code enforcement. The posters were hand delivered to all auto industry
businesses within the City of Federal Way starting in 2004 and
continue to be handed out through the IDDE program.
(iv) Catch Basin Curb Marker Program
Through this program, local youth organizations, like Boy Scouts and
Girl Scouts and other special interest groups, volunteer to glue these
colorful four inch plastic markers to curbs, sidewalks or roads adjacent
to catch basins in residential neighborhoods. The program is designed
to raise awareness that all City storm drains flow to natural waterways,
as well as to reduce pollutants entering the storm system.
Page 7 of 28
City of Federal Way
NPDES Phase II Stormwater Management Program
(v) Charity Car Wash Program
As a proactive measure to educate and assist the public interested in
holding charity car wash events, the City maintains the Fish Friendly
Car Wash Program. The program offers two "fish friendly" car wash
alternatives: 1) Sell charity car wash tickets through the Puget Sound
Car Wash Association; and 2) Check out car wash kits free of charge.
Kits may be borrowed from the City for charity events held within the
City. The kits are designed to divert wash water to the sanitary sewer
system. The program also includes disseminating public education
materials in the form of letters, flyers and press releases targeted at
local charities and special interest groups, as well as local businesses.
(b) Environmental Stewardship
(i) Pet Waste Brochure
The pet waste brochure identifies the numerous adverse impacts pet
waste can have on water quality and describes environmentally
friendly disposal techniques. Pet waste brochures are displayed at
local parks, pet stores and veterinary clinics.
(ii) Don't Feed the Ducks or Geese Poster
This poster was created by King County and displays four reasons not
to feed the ducks or geese. Posters are on display at local lakes and
ponds and are distributed to North and Steel Lake residents annually as
a part of their aquatic weed management programs. They are designed
to reduce nutrient loading and other harmful impacts resulting from
feeding waterfowl.
(iii) Be a Lake Steward Flyer
The lake steward flyer encourages lake residents to adopt or modify
residential practices and behaviors to help improve water quality in
local lakes. The flyer was distributed in July/August of 2007.
(iv) Stream Team
Through this volunteer program residents and interested parties
regularly check out water quality monitoring kits and conduct basic
water quality tests in local streams. The program is designed to raise
awareness on the health of streams and encourage stewardship. The
group also reports any adverse conditions or illicit discharges they may
observe.
(v) Lakota Creek Clean Up
During this annual spring event volunteers and SWM staff walk the
Lakota Creek stream corridor removing litter and debris which can
damage water quality and cause flooding or channel erosion.
Participants are educated on the adverse impacts of litter and other
pollutants on stream health and stability.
Page 8 of 28
City of Federal Way
NPDES Phase II Stormwater Management Program
(vi) Invasive Plant Removal
SWM coordinates seasonal volunteer events to hand remove invasive
plants from our stream and wetland restoration areas. Participants are
taught the importance of allowing native plants to thrive in these areas
such as improving wildlife habitat, creating natural buffers and
providing shade to keep streams and wetlands cool.
(c) Vehicle Maintenance
SWM does not currently have any specific educational programs targeting
vehicle maintenance and vehicular impacts to water quality. It is anticipated
that this issue will be addressed through the Regional NPDES Public
Education and Outreach Forum.
(d) Landscaping & Buffers
(i) Natural Yard Care
The City of Federal Way actively participates in the Natural Yard Care
Program created by King County. The program offers a series of three
workshops every spring to teach residents environmentally friendly
lawn and garden care techniques.
(ii) Lake Friendly Landscape Brochure
SWM staff in cooperation with the Washington State Lake Protection
Association have updated the "Blueprint for a Lake Friendly
Landscape" brochure. The brochure describes native planting
alternatives, encourages the creation of native landscape buffers along
the shoreline and discourages shoreline armoring. The brochure is
designed to reduce the use for fertilizers and pesticides, improve
wildlife values and water quality. The brochure was last distributed by
mail to all lake residents in 2004.
(iii) Taking Care of Streams Brochure
This regional streams brochure originally created by Oregon State
University, promotes stewardship practices in an effort to improve
natural processes and water quality. The brochure was distributed by
mail to all stream front property owners.
ii) The General Public & Businesses (including mobile & home based)
(1) BMPs for Use and Storage of Automotive Chemicals, Hazardous Cleaning
Supplies, Car Wash Soaps and Hazardous Materials
Several of SWM's existing programs address the BMPs for the use and storage
of automotive chemicals, cleaning supplies, hazardous materials and car wash
soaps including: the Auto Industry Poster, The Restaurant Industry Poster, the
Fish Friendly Car Wash Program and articles in "The Water Log".
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City of Federal Way
NPDES Phase II Stormwater Management Program
(2) Impacts of Illicit Discharges and How to Report Them
The impacts from illicit discharges and how to report them are addressed in both
the Stormwater Pollution Prevention Brochure and in periodic articles within
SWM's quarterly newsletter "The Water Log". Both subjects are also covered
in depth on the City's web site. SWM plans to examine additional venues to
make IDDE reporting numbers more easily accessible to the public.
iii) Homeowners, Landscapers and Property Managers
(1) Yard Care Techniques Protective of Water Quality & BMPs for Use and
Storage of Pesticides and Fertilizers
The existing Natural Yard Care Program targets homeowners and residential
use of pesticides and fertilizers and encourages environmentally friendly
techniques. The City hopes to target landscaping firms and property managers
through an expansion of the existing Natural Yard Care Program or through the
efforts of the Regional Public Education and Outreach Forum.
(2) BMPs for Carpet Cleaning and Auto Repair and Maintenance
These topics are primarily addressed through the Auto Industry Poster, the
Catch Basin Curb Marker Program, The Fish Friendly Car Wash Program and
periodic articles in "The Water Log". SWM currently does not specifically
target carpet cleaning activities.
(3) Low Impact Development (LID)Techniques
The City of Federal is one of 13 jurisdictions chosen by the Puget Sound
Partnership to receive technical assistance in integrating LID techniques into the
City's development regulations in 2008. The City plans to create educational
materials to promote the use of these LID techniques once they have been
integrated and adopted into the development regulations.
Also, SWM staff are currently examining different existing educational
materials on LID techniques and design standards, including WSU Extension's
"Rain Garden Handbook".
(4) Stormwater Pond Maintenance
Through SWM's annual private storm system inspection program, SWM
inspectors conduct inspections and determine maintenance requirements of over
600 multi -family and commercial properties with known stormwater detention
or flow control facilities. Education of the property owners on maintenance
benefits and needs is done by our inspectors through verbal communication,
postcards, letters and correction notices. In addition a Maintenance Manual for
Private Stormwater Systems is available on SWM's main web page and this is
shared with the facility owner.
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City of Federal Way
NPDES Phase II Stormwater Management Program
iv) Engineers, Contractors, Developers, Review Staff and Land Use Planners
(1) Technical Standards for Stormwater & Erosion Control Plans
Technical standards and BMPs for stormwater and erosion control are available
on the City's web page (www.cityoffederalwgy.com/swm). In additional a
Single Family Erosion Control Brochure is attached to all single family
construction permits and distributed by inspection staff.
(2) Low Impact Development Techniques
The City of Federal is one of 13 jurisdictions chosen by the Puget Sound
Partnership to receive technical assistance in integrating LID techniques into the
City's development regulations. The City plans to create educational materials
to promote the use of these LID techniques once they have been integrated and
adopted into the development regulations.
Measure Understanding
(Permit Requirement S5. C.1. b)
Surface Water Management's existing Education and Outreach Program is designed to
achieve measurable improvements in the target audience's understanding of stormwater
and water quality impacts and what they can do to help reduce or prevent these impacts.
Specifically, the Education and Outreach Program is designed to raise awareness by
identifying problems (potential pollutant sources) and to change behaviors by identifying
and encouraging the adoption of practices and behaviors to improve and/or protect water
quality. SWM staff are currently evaluating how to measure the effectiveness of the
different educational campaigns within our program.
Track and Maintain Records
(Permit Requirement S5. C.1. c)
Currently SWM does not track or maintain detailed records of the Public Education and
Outreach Program. SWM staff are currently evaluating different tracking systems
including Red Ridge's Volunteer Works program.
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City of Federal Way
NPDES Phase II Stormwater Management Program
SECTION 2 - Public Involvement and Participation
"The SWMP shall include ongoing opportunities for public involvement through advisory
councils, watershed committees, participation in developing rate -structures, stewardship
programs, environmental activities or other similar activities. Each Permittee shall comply
with applicable State and local public notice requirements when developing their SWMP. "
(Permit Requirement SS. C. 2)
Pursuant to Permit requirements SS. C.2. a., an on-going Public Participation Program must
be initiated by February 16, 2008.
The City of Federal Way encourages residents and interested parties to participate in the
decision making processes involving the update and implementation of the City's
Stormwater Management Program (SWMP), as well as other public involvement and
participation opportunities offered by the City. The City of Federal Way believes public
involvement and participation are important to promoting stewardship of both the City and
its natural environments. Through public involvement citizens help make a difference in
their quality of life and the quality of our natural habitats and waterways.
Public Participation in Development of SWMP
(Permit Requirement S5. C. 2. a & b)
The City of Federal Way Surface Water Management Utility is well established with an
existing rate structure and all of the Permit programs (i.e. Illicit Discharge Detection and
Elimination, Public Education & Outreach, Construction Site Run-off Inspection, Post
Construction Stormwater Inspection, etc.) already in place. As a result, large scale
changes to SWM's existing programs and ordinances are not expected. However, the
SWM programs will be updated to meet the conditions of the permit. Public participation
on the SWMP will be focused on how to improve the City's existing stormwater
programs and what changes are necessary to meet the Permit requirements.
Opportunities for public participation in the development of the SWMP will be made
available through the following venues:
i) Public Notices — Public Notices will be posted in the local newspaper, the Federal
Way Mirror. Notices will identify opportunities for public participation in the
development of the SWMP in the form of a web site address, e-mail & phone contact
information and the date and time of public meetings.
ii) SWM Newsletter — The quarterly SWM newsletter, `The Water Log", will be used to
raise awareness of the Permit requirements and update the public on the development
of the SWMP. NPDES update articles appeared in the both the August and
December issues of the Water Log.
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City of Federal Way
NPDES Phase II Stormwater Management Program
iii) SWM Web Page — A link to the City of Federal Way's NPDES Phase II web page
has been added to SWM's web page (www.cityoffederalway.com/swm). The
NPDES Phase II web page provides a general description of the Permit and links to
the Department of Ecology's web site for the Permit and other pertinent information.
The site also describes the progress on the development of the SWMP and will
display the SWMP and the Annual Reports as they become available. The web page
also provides links to SWM's existing programs and provides opportunities for public
comment and participation, via e-mail.
iv) Public Meetings
(1) Open House — An NPDES Open House was held on October 11, 2007 to educate
the public on SWM's existing programs and the NPDES Phase II Permit
requirements, as well as to solicit input.
(2) Land Use and Transportation Committee (LUTC) — An opportunity for
participation in the development of SWMP is also available to city residents
through the LUTC meetings. The LUTC will review many of the programmatic
and policy changes proposed under the SWMP. The LUTC opens the floor to
public comment on all of their agenda items. The LUTC meets the first and third
Monday of each month. Meeting times and agendas can be accessed through the
City Calendar web page
(http://www.cityoffederalway.com/page.aspx?view--192).
(3) City Council — Many of the programmatic and policy changes related to the
SWMP must be reviewed and approved by City Council. Public comments will
be accepted during all City Council meetings. [Note: City Council or the LUTC
can schedule additional public meetings if they deem it necessary to allow for
public comment/participation.] The City Council meets on the first and third
Tuesday of each month. Meeting times and agendas can be accessed through the
City Calendar web page
(http://www.cityoffederalway.com/page.aspx?view--192).
(4) Parties of Record —In addition to the State public noticing requirements, SWM
will maintain a Party of Record List. Parties of Record will be notified of all new
information and public meetings relating to the SWMP.
Evaluation of Public Comments
(Permit Requirement S5. C. 2. a)
No public comments have been received to date. Once public comments are received
they will be categorized by topic and evaluated based on quantity and pertinence to
the subject matter. Public comments will be addressed in the annual SWMP updates.
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City of Federal Way
NPDES Phase II Stormwater Management Program
Stewardship Programs & Environment Activities
(Permit Requirement S5. C. 2)
SWM currently maintains the following stewardship and environmental activity
programs: the Stream Team, the Lakota Creek Clean Up, Invasive Plant Removal, the
Catch Basin Curb Marker Program, and the Fish Friendly Car Wash Program.
Descriptions of these programs can be found in the Stewardship portions of Section 1
- Public Education and Outreach. SWM web pages are also used to promote
volunteer programs.
Web Page - SWMP and Annual Report
(Permit Requirement S5. C. 2. b)
As previously described, SWM's NPDES Permit web page
(www.cityoffederalway.co npdes) will display both the City's SWMP and Annual
Report as they become available. Pursuant to the Permit, these documents will be
updated and posted annually.
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City of Federal Way
NPDES Phase II Stormwater Management Program
SECTION 3 - Illicit Discharge Detection and Elimination
"The SWMP shall include an ongoing program to detect and remove illicit connections,
discharges as defined in 40 CFR 122.26(b)(2), and improper disposal, including any spills
not under the purview of another responding authority, into the municipal separate storm
sewers owned or operated by the Permittee. Permittees shall fully implement an ongoing
illicit discharge detection and elimination (IDDE) program no later than 180 days prior to
the expiration date of this Permit. "(Permit Requirement S5. C.3)
Pursuant to Permit requirement S5. C. 3., a series of phased deadlines are created for the
implementation of the Illicit Discharge Detection and Elimination Program beginning with
the creation of the Illicit Discharge Hotline required as of February 16, 2009.
The City of Federal Way has maintained an active Illicit Discharge Detection and
Elimination (IDDE) program since it was implemented in 1999. The City actively
investigates prohibited discharges and illicit connections to the City's stormwater system in
an effort to improve water quality in the City's surface water resources. Through this
program, areas throughout the City are targeted for water quality inspections due to their
potential impacts to the City's infrastructure and downstream surface waters.
Municipal Storm Sewer Map
(Permit Requirement S5. C.3. a)
The City of Federal Way is currently implementing an ongoing program to prepare and
maintain a comprehensive map of the City's municipal separate storm sewer system
(MS4) pursuant to the requirements of sections S5.C.3.a. of the Permit prior to the
required deadline of February 16, 2011. The City has mapped approximately 75% of all
known MS4 structures, and has mapped 100% of all known receiving waters. The city is
currently working toward implementing the practices and procedures designed to
complete this effort, including physically surveying all MS4 structures using mobile
GIS/GPS and incorporating these data into ESRI ArcView.
Prior to February 16, 2011, the ongoing mapping program will map:
i) All known MS4 outfalls, receiving waters and structural storm sewer BMPs
owned or operated by the City consistent with the requirements of section S5.
C.3.a.i. of the Permit.
ii) All connections to the MS4 authorized or allowed by the City.
iii) All geographic areas served by the City that do not discharge stormwater to
surface waters.
iv) Make an electronic version of the map available to Ecology upon request.
V) To the extent appropriate, make mapping information available to any secondary
or co -permittees upon request. [Note: The City does not currently have any
secondary or co -permittees.]
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City of Federal Way
NPDES Phase II Stormwater Management Program
Illicit Discharge Detection and Elimination (IDDE) Ordinance
(Permit Requirement S5. C. 3. b)
The City of Federal Way has several regulatory mechanisms already in place that require
the implementation of the best known, available, and reasonable management practices to
prevent the contamination of stormwater, surface water, and groundwater:
i) The City implemented an ordinance in 1999 enacting the Surface and Stormwater
section (Chapter 21) of Federal Way City Code (FWCC). Chapter 21 includes
Article IV, Water Quality that was designed to provide minimum requirements for
reducing and controlling the discharge of contaminants from commercial,
industrial, governmental, agricultural, residential and other land use activities in
Federal Way through a regulatory mechanism that effectively prohibits non-
stormwater illegal discharges, and/or dumping into the City's MS4 to the
maximum extent allowable under state and federal law.
ii) If a violation has been committed, Chapter 21, Article IV is enforced using
Chapter 1 FWCC, Article III, Enforcement of Code. Chapter 1 establishes an
efficient, civil administrative system to enforce the development of regulations of
the City. It provides: an opportunity for an appeal of determination of violations;
prompt hearings and decisions on any such appeals; monetary penalties for
violations; and procedures for the collection of said penalties. Enforcement
actions may include Order to Cease Activity, Notice of Violation, Infractions and
Voluntary Correction Agreement.
iii) The Zoning section (Chapter 22) of FWCC includes Article XIII, Division 12,
Water Quality that establishes water quality standards based on how the water
leaves the subject property. Pursuant to this code section, all water entering the
public stormwater system (22-1198) from the subject property must meet
prescribed water quality standards.
In order to meet the stringent requirements set forth in the Permit, the City plans to
review the existing FWCC and begin drafting new ordinance language that complies with
S5.C.3.b.i through S5.C.3.b.vi of the Permit. The entire process of creating new
language, staff review and City Council adoption will be completed no later than August
16, 2009, pursuant to the requirements of the Permit.
Implementation of IDDE
(Permit Requirement S5. C. 3. c)
The City maintains an active and effective Illicit Discharge Detection and Elimination
program which detects and addresses non-stormwater discharges to the City's storm
system.
i) Identify Priority Areas
The City's current program detects and addresses illicit discharges to the MS4.
This program includes a system to record illicit discharges and citizen complaints,
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City of Federal Way
NPDES Phase II Stormwater Management Program
and includes a regulatory mechanism that effectively prohibits non-stormwater
illegal discharges, and/or dumping into the City's MS4 to the maximum extent
allowable under state and federal law through FWCC. This program is used to
determine an appropriate management response and possible enforcement action.
Systematic business source control inspections have been focused in the West
Hylebos Creek watershed due to its larger concentration of commercial
development and greater likelihood of prohibited stormwater discharges. In
addition, this basin has also been targeted due to the presence of endangered
Chinook salmon in downstream stream reaches.
The City has begun reviewing existing IDDE procedures to determine compliance
with the Permit. Any amendments or changes to existing procedures needed to
meet the requirements of the Permit will be completed by August 19, 2011.
ii) Assessment/Inspection of Priority Outfalls
The City plans to develop procedures to assess and inspect priority outfalls as
described within section S5.C.3.c.ii of the Permit. This element of the IDDE
program will be implemented by August 19, 2011.
iii) Procedures Characterizing Nature & Environmental Threat Posed by Illicit
Discharges
The City currently implements a program to detect and address illicit discharges
to the MS4. This program includes an active source control, operations and
maintenance inspection program, and the implementation of a system to record
illicit discharges and citizen complaints. The program also includes a regulatory
mechanism that effectively prohibits non-stormwater illegal discharges, and/or
dumping into the City's MS4 to the maximum extent allowable under state and
federal law through FWCC. This program is used to evaluate whether the
discharge should be immediately contained, and includes steps to be taken for
containment of the discharge.
The City has begun reviewing existing IDDE procedures regarding the
characterization of the nature and environmental threat posed by illicit discharges
to determine compliance with section S5.C.3.c.iii of the Permit. Any amendments
or changes to existing procedures needed to meet the requirements of the Permit
will be completed by August 19, 2011.
iv) Procedures for Tracing the Source of Illicit Discharges
The City's existing IDDE program traces illicit discharges using visual
inspections throughout the MS4. This program includes the use of techniques
including, but not limited to the use of mobile cameras, smoke testing, dye
testing, and water sampling.
To date, the City has not entirely formalized the procedures for this program
pursuant to section S5.C.3.c.iv. of the Permit. The City plans to evaluate existing
IDDE procedures regarding tracing the source of illicit discharges to determine
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City of Federal Way
NPDES Phase II Stormwater Management Program
compliance with this section of the Permit. Any amendments or changes to
existing procedures needed to meet the requirements of the Permit will be
completed by August 19, 2011.
V) Procedures for Removing Source of Illicit Discharges
While no formalized procedures have been adopted, the existing IDDE program
includes notification of appropriate authorities, notification of property owners,
technical assistance for eliminating the discharge, follow-up inspections, and
escalating enforcement and legal actions if the discharge is not eliminated.
City staff plan to review and amend its existing procedures as necessary to meet
the requirements and timelines required under section S5.C.3.c.v of the Permit by
August 19, 2011.
IDDE Education (Hazards Associated with Illicit Discharges)
(Permit Requirement S5. C. 3. d)
The City's existing public education and outreach program includes educational materials
designed to prevent illicit discharges, by educating business owners and employees on
best management practices and waste disposal techniques (e.g. see Restaurant Industry
Poster and Auto Industry Poster descriptions in Section 1 of this SWMP).
i) Distribution of Materials
City staff will evaluate its existing IDDE educational materials to review whether
they clearly identify the hazards associated with illicit discharges. Any necessary
changes to the IDDE educational program will be made and new materials
distributed by August 19, 2011.
ii) Publicly List Phone Number for Reporting Spills
The City's Public Works Department main number (253-835-2700) has been
publicly listed for reporting spills or illicit discharges. If this number is called
after normal business, it identifies an after hours number (253-946-6416) which
should be called for reporting spills. While this number has been publicized on
the web and in other mediums, the City plans to evaluate its existing approach and
review options for improving the publishing of the number, as well as call
tracking procedures.
IDDE Assessment, Evaluation and Tracking
(Permit Requirement S5. C. 3. e)
The City's existing IDDE program tracks and documents information regarding spill
types, number of spills, illicit discharge types, number of illicit discharges, and
inspections. Distribution of all public education materials for this program, however, is
not currently tracked.
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City of Federal Way
NPDES Phase II Stormwater Management Program
City staff plan to develop and implement procedures to fully track, assess and evaluate
the IDDE program by August 19, 2011.
Municipal Field Staff Training
(Permit Requirement S5. C.3.0
i) IDDE Level A Training - Investigation, Reporting and Clean Up
Through the City's existing IDDE program some training has been provided to all
field staff responsible for identification, investigation, termination, cleanup and
reporting of illicit discharges. Prior to August 19, 2009 the City will evaluate its
existing training efforts to determine compliance with section S5.C.3.f.i of the
Permit and implement any necessary changes.
Additionally, the City also plans to provide the necessary follow-up training as
needed to address changes in procedures, techniques or requirements. All training
records (including training information and the staff trained) will be documented
and maintained.
ii) IDDE Level B Training - All Municipal Field Staff
Prior to February 16, 2010, the City will create and implement an ongoing
training program to train all municipal field staff, which as a part of their normal
duties may observe an illicit discharge. This level of training will focus on the
identification of illicit discharges/connections and how to report or respond to
these illicit discharges/connections. This level of training will likely be required
for staff from most of the City Departments including: Public Works, Community
Development, Parks and Public Safety.
The City also plans to provide the necessary follow-up training as needed to
address changes in procedures, techniques or requirements. All training records
(including course information and the staff trained) will be documented and
maintained.
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City of Federal Way
NPDES Phase II Stormwater Management Program
SECTION 4 - Controlling Runoff from Construction Sites
"Each Permittee shall develop, implement, and enforce a program to reduce pollutants in
stormwater runoff to a regulated small MS4 from new development, redevelopment and
construction site activities. This program shall be applied to all sites that disturb a land area
1 acre or greater, including projects less than one acre that are part of a larger common
plan of the development or sale. The program shall apply to private and public development,
including roads. The "Technical Thresholds" in Appendix 1 shall be applied to all sites 1
acre or greater, including projects less than one acre that are part of a larger common plan
of the development or sale. " (Permit Requirement SS. C. 4)
Pursuant to Permit requirement SS. C. 4. a., a construction site runoffprogram must be in
place by August 16, 2009.
The City of Federal Way recognizes that construction site run-off is a major contributor to
water quality degradation in the greater Puget Sound region. To address this issue and to
better protect our natural waterways, the City's current construction site run-off program
already exceeds the minimum requirements of the Permit in many respects. Construction site
run-off is reviewed and inspected for all construction projects, ranging from single family
structures to large commercial developments. The responsibility for plan review and
inspection are shared between the Surface Water Management and Development Services
Divisions of the Public Works Department.
Program Ordinance and Enforcement Mechanisms
(Permit Requirement S5. C. 4. a)
i) Minimum Requirements, Technical Thresholds and Definitions
The 1998 King County Stormwater Design Manual as amended by Federal Way City
Code 21-9 is the current standard used by development review and inspection staff
when establishing stormwater and erosion control requirements (minimum
requirements, technical thresholds, definitions etc.) for all construction projects in the
City. Thresholds for permit review are determined by the City's Land Modification
Code (FWCC 22-1091 through 22-1095).
In 2008 City staff plan to review the City's existing technical requirements as well as
King County's 2005 Stormwater Design Manual and/or Department of Ecology's
2005 Stormwater Management Manual for Western Washington for potential
adoption as the new minimum requirements and technical thresholds.
ii) Site Planning Process & BMP Selection
The City also uses the 1998 King County Manual for BMP selection and design
criteria. The current site planning process is established in Chapter 22 of Federal
Way City Code.
City staff plans to review these processes, BMP selection and design criteria in 2008.
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NPDES Phase II Stormwater Management Program
iii) Legal Authority to Conduct Inspections
The legal authority to conduct inspections on new developments is granted during
construction pursuant to an access agreement allowed under Federal Way City Code
(FWCC) 22-153. Authority to conduct post construction inspection of private
drainage facilities discharging to the City's storm system from new development is
established through drainage covenants and conditions attached to the final permit, as
well as FWCC 21.16.
iv) Provisions to Allow Low Impact Development (LID) or Other Non -Structural
Improvements
Non-structural preventive actions and source control improvements measures, such as
LID, are currently allowed through the variance process. In December of 2007, the
City of Federal was one of 13 jurisdictions chosen by the Puget Sound Partnership
(PSP) to receive technical assistance in integrating LID techniques into the City's
development regulations. City staff will be working with PSP to develop
recommendations for integrating LID into the City's existing regulations in 2008.
The City plans to evaluate these recommendations for potential inclusion in 2009.
v) Erosivity Waiver
The City of Federal Way will evaluate the creation of an Erosivity Waiver as
described within Appendix 1 of the Permit in 2008 & 2009. The Erosivity Waiver is
designed primarily for and areas, such as Eastern Washington and has a very limited
applicability to Federal Way given our existing soil types and rainfall patterns.
Permitting Process with Review, Inspection and Enforcement
(Permit Requirement S5. C. 4. b)
The City's existing permitting process includes plan review, inspection and enforcement
capabilities which meet the majority of the requirements of the permit as described
below. City staff plans to evaluate this process in 2008 and determine how best to
modify our existing program to meet the needs of the City and the requirements of the
Permit.
i) Review of Stormwater Site Plans
The Development Services Division of Public Works ensures that development
within the City of Federal Way meets current city codes and development standards.
Development Services works to accomplish this goal by being involved in all types
and phases of development within the City, providing technical project review,
project permitting and construction inspection. Code authority to conduct site plan
review is granted through the Subdivision and Zoning Codes (FWCC 20 & 22). The
Development Services Division site plan review process includes review criteria for
both stormwater design and construction site erosion sedimentation control (King
County, Washington Surface Water Design Manual 1998).
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NPDES Phase II Stormwater Management Program
ii) Site Inspection Prior to Clearing and Grading
The responsibility for construction site inspection is divided between two divisions of
the Public Works Department. The Development Services inspectors are responsible
for inspection of plats, multi -family and commercial development. A "Pre -
Construction Meeting" is required for all construction sites prior to any clearing and
grading on the site. Development Services currently conducts this meeting with the
contractor at City Hall, rather than at the construction site. City staff plans to revise
this procedure to meet the site inspection requirements of the Permit.
The Surface Water Management inspectors are responsible for conducting erosion
control inspection for all single family construction. Prior any clearing and grading
activity on the construction site, a Pre -Construction inspection is conducted on site
with the contractor to review initial erosion control requirements and the inspection
process.
iii) Erosion Sedimentation Control Inspection During Construction
A minimum of two erosion control inspections are conducted by City inspection staff
between the Pre -Construction Meeting and Final Inspection to ensure erosion control
measures are being maintained throughout the construction stage of the project.
iv) Final Inspection of Development Sites Upon Completion of Construction
A final or permanent erosion control inspection is conducted prior to final building
permit approval of single-family, multi -family and commercial construction.
v) Inspection History/Record Keeping
Records of inspections are currently being kept through a data base permit tracking
system. However, the manner in which records are kept between the two divisions
(Development Services and Surface Water Management) differs. In 2008 City staff
plans to review and amend the inspection tracking system to provide consistency
between the two divisions and to simplify the reporting process.
vi) Enforcement Strategy
The ability to conduct enforcement of erosion control and stormwater requirements is
provided within the City's existing development review and inspection process
(FWCC 1-14 through 1-23, 21-15, International Building Code R113 & R114).
While no formal tiered strategy has been adopted, inspectors have the ability and
discretion to issue verbal or written corrections depending on the scale of the problem
and to issue Stop Work Orders if corrections are not completed or if significant
violations are discovered.
In 2008 City staff plan to review enforcement codes and the enforcement strategies
between the two inspection teams and make modifications to these inspection
programs to develop a common enforcement strategy, as well as provide training to
ensure these strategies are consistently applied.
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NPDES Phase II Stormwater Management Program
vii) Erosivity Waiver
As discussed previously, the City will evaluate the creation of an Erosivity Waiver
within its development review or inspection process in 2008/2009.
Inspection Program to Verify Long -Term Operation & Maintenance
of Stormwater Facilities
(Permit Requirement S5. C. 4. c)
i) Adoption of Ordinance or Enforceable Mechanism
An enforceable mechanism requiring long-term operation and maintenance of storm
systems on new developments is already in place. Covenants are attached to all new
developments with stormwater detention and flow control facilities at the time of final
approval. The covenant both allows access for inspection and requires long term
operation and maintenance of stormwater facilities. (FWCC 21-27 & 21-28)
ii) Establish Maintenance Standards
Maintenance standards for private stormwater systems are established and available
on the SWM's main web page (www.cityoffederalwU.com/swm). City staff plans to
initiate review of the existing maintenance standards to ensure they meet or exceed
the standards specified in Chapter 4 of Volume V of the 2005 Stormwater
Management Manual for Western Washington. City staff are also actively
participating in the NPDES Regional Operations and Maintenance Forum and its
Maintenance Standards Committee in an effort to stay informed of the review of
existing regional maintenance standards.
iii) Conduct Annual Inspections of Treatment & Flow Control Facilities
The City's existing inspection program also includes annual post construction
inspection of all known private commercial stormwater treatment and flow control
facilities. Over 600 private stormwater systems are inspected each year.
iv) Inspection of Large Common Plan Development's Stormwater Facilities During
Residential Constructions
Under the existing system all subdivisions and planned unit developments containing
storm systems are strongly encouraged to dedicate these stormwater facilities to the
City at the time of final approval. The developer/owner is required to create and
maintain a two-year performance bond to ensure the owner continues to maintain
these facilities during the first two years (most often the heaviest construction period)
following final approval. SWM maintenance and inspection staff conducts periodic
inspection of these facilities during the period of the performance bond to identify the
maintenance needs and enforce compliance with maintenance standards. The City
takes over operation and maintenance of these facilities after dedication to the city
when the performance bond is released.
In 2008 SWM plans to evaluate and modify (if necessary) this existing program to
ensure the inspection frequency during the two year performance meets the minimum
requirements specified within the Permit.
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City of Federal Way
NPDES Phase II Stormwater Management Program
Tracking Inspections, Enforcements, Warnings and Violations
(Permit Requirement S5. C. 4. d)
Records of inspections and enforcements regarding long term maintenance of private
stormwater'systems are maintained under our existing inspection programs. However, in
2008 SWM staff plans to review and evaluate our record keeping procedures in an effort
to simplify reporting on the different aspects of this program.
NPDES Forms Available to the Public
(Permit Requirement S5. C. 4. e)
NPDES Construction Stormwater General Permit Focus Sheets have been made available
at the City's Permit Center since June of 2007. Pursuant to a communication from the
Department of Ecology dated May 30, 2007, these focus sheets may be made available to
the public in lieu of the application (Notice of Intent). In addition, during the
development review process, the City's Development Services staff notifies developers if
the project meets the one acre threshold for the NPDES Construction Stormwater General
Permit.
Verification Staff Responsible for Program Implementation are
Trained
(Permit Requirement S5. C. 4. f)
Currently all permanent construction site run-off inspection staff have attained the
Certified Erosion Sedimentation Control Lead (CESCL) certification or higher.
Development review staff and post construction inspection staff are trained under our
existing development review criteria and maintenance standards.
As these existing programs may be modified to meet the requirements of this Permit, the
City will ensure that prior to August 16th 2009; all staff responsible for the
implementation of these programs are trained on the pertinent changes to these programs.
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City of Federal Way
NPDES Phase II Stormwater Management Program
SECTION 5 - Pollution Prevention and Operations and
Maintenance
"Within three years of the effective date of this Permit, each Permittee shall develop and
implement an operations and maintenance (O&M) program that includes a training
component and has the ultimate goal of preventing or reducing pollutant run-off from
municipal operations. " (Permit Requirement S5. C. 5.)
Pursuant to Permit requirement S5. C. 5., all elements of the operations and maintenance
program must be in place by February 16, 2010.
The City of Federal Way maintains a proactive and effective maintenance program of the
City's drainage infrastructure, which includes catch basins, pipes, open channels, as well as
residential and regional retention/detention facilities. SWM conducts regular inspection and
maintenance of these facilities to ensure they are functioning properly — reducing the
incidence of flooding and providing water quality treatment.
Maintenance Standards
(Permit Requirement S5. C. 5. a)
The Surface Water Management Division has maintenance standards in place prior to the
effective date of this Permit (Stormwater System Operations & Maintenance Manual,
KCM. June 1997). Regular maintenance of SWM's facilities is conducted by SWM
Maintenance staff consistent with the adopted standards to ensure stormwater facilities
are functioning properly.
SWM staff have already begun to review our existing maintenance standards in
comparison to regional standards (the Regional Road Maintenance ESA Program
Guidelines & Chapter 4 of the 2005 Stormwater Management Manual for Western
Washington) to determine what changes are necessary to meet the minimum
requirements of this Permit. In addition, SWM staff are actively participating in the
Regional NPDES O & M Forum, known as NPDES Road Map, which is also evaluating
regional maintenance standards for compliance with NPDES permit requirements.
Annual Inspections
(Permit Requirement S5. C. 5. b)
Under SWM's existing program, inspection of all municipally owned or operated
permanent stormwater treatment and flow control facilities are inspected and maintained
at a minimum, annually. All City owned or operated stormwater retention/detention
ponds are currently inspected and maintained a minimum of three times a year and after
every major storm event.
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City of Federal Way
NPDES Phase II Stormwater Management Program
SWM staff plan to review the maintenance program's record keeping system during the
Permit cycle to determine what changes are necessary to meet the tracking and reporting
requirements of the Permit.
Spot Check Inspections
(Permit Requirement S5. C. 5. c)
SWM maintains a "Hot Spot" list of stormwater facilities which can potentially be
damaged from major storm events. SWM staff conducts "Spot Check" inspections of
these locations on the Hot Spot list during and after major storm events to ensure the
systems are functioning properly and to determine any maintenance or repair needs.
SWM then conducts appropriate maintenance and repairs within a timely manner.
SWM staff also plan to evaluate the tracking and record keeping process in place for
these types of inspections during this Permit cycle.
CB and Inlet Inspections
(Permit Requirement S5. C. 5. d)
SWM's existing catch basin monitoring program monitors sediment levels in catch basins
and inlet structures. Sediment levels in catch basins (CBs) have been monitored over a
period of five years. Based on the information gathered, the City has been divided into
seven sub -areas or circuits. Sampling locations have been established within each circuit.
When sediment levels equals or exceeds 50% of the capacity of the CB sump on average
in the sampling circuit, all CBs and inlet structures in that circuit are cleaned. In
addition, high use areas (such as arterials) in each sub -area are cleaned annually.
Prior to the end of the Permit period, SWM will review the existing sampling locations
for all circuits to ensure the minimum sampling requirements identified in the Permit are
met. SWM staff also plan to review and evaluate existing record keeping methods for
this program in an effort to simplify tracking and reporting.
Compliance with Inspection Requirements
(Permit Requirement S5. C. 5. e)
While the City is currently meeting the majority of the inspection requirements identified
in the above sections, prior to February of 2010, SWM staff will evaluate and modify our
existing programs as necessary to ensure that the minimum 95% goal for inspection of all
sites is achieved.
Practices to Reduce Stormwater Impacts
(Permit Requirement S5. C. 5.0
As a part of the review of maintenance standards SWM staff plans to refine and where
necessary establish and implement practices and procedures to reduce stormwater
impacts associated with runoff from streets, parking lots, roads and highways owned or
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City of Federal Way
NPDES Phase II Stormwater Management Program
maintained by the City, as well as road maintenance activities conducted by the City.
Activities that will be addressed include: pipe & culvert cleaning, ditch maintenance,
street cleaning, road repair and resurfacing, snow and ice control, utility installation,
pavement striping, maintaining roadside areas and vegetation, and dust control.
These practices are also being reviewed by the NPDES Road Map group. The NPDES
Road Map group is currently reviewing existing manuals such as the ESA Regional Road
Maintenance Manual to determine there applicability and compliance with NPDES
requirements in regards to Operations & Maintenance practices and activities.
BMPs to Reduced Pollutants Discharged from City Lands
(Permit Requirement S5. C. 5. g)
Prior to February 2010, City staff plans to review and if necessary, modify policies and
procedures regarding the maintenance and operation of all lands owned or maintained by
the City in an effort to reduce the discharge of stormwater pollutants. These lands will
include, but are not limited to: parks, open space, road right-of-way, maintenance yards,
and stormwater treatment and flow control facilities. Policies and procedures to be
addressed include: application of fertilizers, pesticides and herbicides, sediment and
erosion control, landscape maintenance, vegetation disposal, and cleaning and
maintenance of building exteriors.
Develop & Implement On -Going Training
(Permit Requirement S5. C. 5. h)
The City plans to develop and implement an on-going training program for employees
whose construction, operations or maintenance job functions may impact water quality.
The training program will address the importance of protecting water quality, the
requirements of this Permit, operations and maintenance standards, inspection
procedures, BMP selection, ways to perform their job activities to prevent or minimize
impacts to water quality and procedures for reporting water quality concerns, including
potential illicit discharges. The City will provide follow-up training as needed to address
changes in procedures, techniques or requirements. The City will also track and maintain
records of training provided.
The broad scope of training will affect staff from most of the City Departments including,
Public Works, Community Development, Public Safety, and Parks, Recreation and
Cultural Services.
Develop and Implement SWPPPs (Heavy Equipment and Storage
Yards)
(Permit Requirement S5. C. 5. i)
The City will development and implement a Stormwater Pollution Prevention Plan
(SWPPP) for all heavy equipment maintenance or storage yards, and material storage
facilities owned or operated by the City in areas subject to the City's Permit that are not
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City of Federal Way
NPDES Phase II Stormwater Management Program
required to have coverage under the Industrial Stormwater General Permit.
Implementation of non-structural BMPs will begin after the pollution prevention plans
are developed. A schedule for implementation of structural BMPs will be included in the
SWPPP. Generic SWPPPs that can be applied at multiple sites may be used to comply
with this requirement. The SWPPP will include periodic visual observation of discharges
from the facility to evaluate the effectiveness of the BMPs.
Record Keeping and Tracking
(Permit Requirement S5. C. 5j)
The City will maintain records of inspections and maintenance or repair activities in
accordance with the S9 Reporting Requirements of the Permit. While an existing
tracking program is in place for many of the required elements of the O & M Section of
the Permit, methods of record keeping and tracking varies between the program elements.
Prior to February 16, 2010, City staff will evaluate existing record keeping and tracking
methods in an effort to simplify annual reporting on these programs.
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City of Federal Way
NPDES Phase II Stormwater Management Program