Despite economic challenges, MS4 communities throughout the United States continue to put forth a significant effort in addressing one of the key elements of NPDES Phase II: pollution prevention and good housekeeping.
North Port, FL
In North Port, FL, stormwater manager Elizabeth Wong of the Planning Zoning and Engineering Department (PZE), oversees the NPDES Phase II program, which addresses pollution prevention/good housekeeping in a proactive and reactive manner. Her goal is to be successful enough in the proactive realm that it would be a rare occurrence to respond to a problem reactively.
North Port has a population of nearly 56,000; its first NPDES Phase II permit was issued in January 1995. Before Wong was hired in 2006, the city contracted the NPDES reporting to outside consultants who had done minimal work, she notes.
“That’s my primary emphasis here–to improve what we do under the NPDES program,” she says.
The program is funded through North Port’s Department of Public Works Road and Drainage District.
North Port’s pollution prevention and good housekeeping efforts are separated into two sections: city-owned facilities and non city-owned facilities. Proactive and reactive inspections are conducted at both.
City facilities with a stormwater treatment system are inspected annually, with issues documented for follow-up repair.
“Of course, if we see something that needs fixing when we walk about daily, we do that in addition to formally doing it once a year as part of an NPDES and/or Southwest Florida Water Management District [SWFWMD] requirement,” says Wong.
“NPDES has different time frames, depending on the part of the system,” she adds. “Water control structures are required to be inspected four times a year, which we do. Pond inspection frequency is between one and a half to two years, and we diligently do it at least once a year.”
Additionally, SWFWMD has different time frames for reinspection of the stormwater system, which is conducted on different time clocks, from 18 months to sometimes as long as four years for ponds that have historically been well-maintained.
“If we happen do to an inspection one year for SWFWMD recertification purposes, that will also satisfy the NPDES requirement. Otherwise we will inspect all systems at least once a year to make sure everything is working fine–that there’s no erosion, no pollution, so silt accumulation, no dead grass,” says Wong.
“For commercial, industrial, or residential subdivisions, SWFWMD requires reinspection and certification, which is done by a Florida-licensed professional engineer,” says Wong. “I do it for our city-owned facilities, and the private sector retains their own engineers and submits reports to SWFWMD.”
As part of Wong’s proactive inspections, she’ll pick as many non-city-owned facilities as she can in one year with whatever help she can garner from the Public Works inspectors; her own PZE department has been reduced from 15 to two employees, and she lost all of the inspectors.
“For the proactive inspections, there’s no finite number of inspections we need to do per year by the NPDES permit,” says Wong. “I target around 10 facilities a year, depending on how much time and staff we have. We did really well two years ago, and this year we didn’t do as many, as we lost our PZE inspectors.”
And although she hasn’t encountered too many reactive inspections, she follows through on reports of illegal discharges and spills.
Other factors involved in good housekeeping include garbage collection, recycling, picking up litter, street sweeping, stormwater pipe maintenance, and cleaning up silts.
Wong also monitors water-quality samples as required by the NPDES permit and conducts inspections during construction to make sure there is no runoff or pollutants coming from the machinery.
Stormwater system maintenance, pollution prevention, and housekeeping practices together take up about half of the Public Works Road and Drainage District budget.
North Port collaborates with the other five NPDES permit co-permittees (Sarasota County, Florida Department of Transportation, town of Longboat Key, city of Sarasota, and city of Venice). “We’re very well tuned in with each other through meetings and
e-mails,” says Wong. “We share the same permit, and everybody is on board with the permitting requirements.”
While North Port’s program has not been audited by the EPA, it has been audited by the Florida Department of Environmental Protection (FDEP). That agency recommended improved bookkeeping practices.
“They like things documented, documented, documented,” points out Wong. “That takes a lot of our time. FDEP’s position is that a task is not completed if there is no paper or digitally recorded trail.”
Wong says there is always room for improvement in pollution prevention and good housekeeping. “As the city gets more developed, you expect more pollution,” she points out.
Wong is also extensively involved in development review. “You ask the developer to implement low-impact development [LID] designs as much as possible, as the minimum stormwater treatment requirements are not 100% effective,” she says. At best, wet ponds can remove nutrients at 40%; dry ponds at 80%, Wong says.
“Implementing LIDs to the maximum extent practicable MEP is the new buzzword,” she says. “It’s not mandatory, but I’d like them to at least look at it and tell me how they can incorporate LIDs into the stormwater design.”
A few years ago, Wong had examined the use of recycled tires as permeable pavement layer, but has found it to be a lot more costly than asphalt layer.
Because of her concern that stormwater measures be not only environmentally effective but also cost-effective, Wong has developed a list of measures that meet those criteria:
- Minimize the impervious area and use pervious pavement. “Don’t put in more impervious area than what you actually need; get the water back in the ground,” she says. “Do you really need so much parking? Do you really need all of these extra driveways? Instead of using hard piping and catch basins to get into the stormwater pond system, there’s a way to sheet flow it into the grass swales and it’s a lot cheaper. The grass can help remove the pollutants and seep the water into the ground.”
- Use rain systems. “We’ve been really successful on our own fire stations,” says Wong. “We have a proactive fire chief, and he’s really in tune with going green. He’s putting rain cisterns systems in that help get the water off the parking lot and reuses it for irrigation, flushing toilets, and filling up his fire trucks. I had one developer willing to do it, then at the last minute did not because of the economy. They have a spot for it when the economy comes back.”
- Reuse stormwater for irrigation. “That’s a really good one for sites with large wet ponds” notes Wong. “We have one large facility under construction that’s almost completed where we’re going to reuse the water for irrigation. We’ve had two successes with developers here already. We require purple pipe in the ground in case of future availability of wastewater effluent reuse water. If they don’t have wastewater effluent reuse coming into the facility, we always try to work with the developer to see if they can use the stormwater for irrigation until such time wastewater effluent reuse water is available. There is definitely an initial capital cost, between $40,000 and $60,000. When they calculate how much money they can save from not having to buy potable water, it makes sense in the long run.”
- Other measures include the use of non-invasive plant materials in the littoral zone and the use of fountains and aeration devices in wet ponds. “That helps put oxygen back in the water and it helps the breakdown of organics,” notes Wong. “They have to put it in wet ponds unless they can demonstrate why they can’t do it. These are all good pollution prevention and reduction measures.”
Puyallup, WA
Puyallup, WA–population 38,900–had instituted pollution prevention and good housekeeping practices long before the NPDES Phase II permit went into effect February 2007 and was modified in June 2009. In the state of Washington, the Department of Ecology has been delegated the responsibility of managing NPDES permits.
Puyallup’s stormwater program is funded through a stormwater utility. The utility receives the bulk of its funding from user fees that are based on amount of a property’s impervious surface, and secondarily through system development fees from new development. A small amount of funding has been obtained through grants for LID efforts and other specific projects.
Puyallup had established its stormwater utility in 1988 for the purpose of implementing management strategies focused on six specific areas, giving the city a head start on many of the requirements of the NPDES II permit, according to Donald Keith Henry, collections supervisor for the Public Works Department.
Those areas include:
- Hydraulic/hydrologic analysis. The city developed standards to provide for flood protection by undertaking basin planning and hydraulic modeling for all of its major drainages. Additionally, the city instituted interlocal cooperation and regional participation on a watershed basis.
- Water quality. Puyallup created development standards to manage construction and reduce runoff, and staff was assigned to monitor water quality and coordinate compliance. Puyallup funded environmental grants to the local school district and Stream Team Coordinator. Stream Team is an “education to action” program for volunteers interested in protecting and enhancing local streams, rivers, lakes, and Puget Sound. Volunteers plant trees, mark storm drains, gather stream health data, remove litter, talk to people at local viewing sites about spawning salmon, and offer classes and field trips on a wide range of topics, including shellfish, salmon, native plants, geology, and “stream bugs.”
- Regulatory. The city passed a critical-areas ordinance to preserve and enhance streams and wetlands and amended its stormwater ordinance.
- Maintenance management. Puyallup established crew configuration, performance standards, and maintenance frequencies; purchased additional Vactor truck and related equipment; and hired additional maintenance staff.
- Geo-based mapping. The city commissioned aerial surveys, developed a utility base map on AutoCAD, and assigned asset identifications to all structures.
- Finance. Puyallup established financing authority and structure with primary funding coming from impervious-surface-based fees in on developed property and a secondary funding source through new development fees.
These days, Puyallup not only continues those efforts, but has built upon them through its focus on a number of pollution prevention and good housekeeping program activities.
Catch basins are inspected or cleaned at least twice a year, and two street sweepers are in regular service to remove grit, sand, and other debris from roadways. City employees have been trained to recognize and report illicit discharges and respond to spills. Illicit discharges are also located and removed through CCTV inspection, smoke testing, and other techniques.
Water-quality staff monitors complaints, investigates, and works with businesses and individuals to ensure compliance.
Stormwater pollution prevention plans (SWPPPs) were written for city facilities and are in force.
A computerized maintenance management system (CMMS) is being implemented to improve performance and reporting capabilities.
“The pollution prevention and good housekeeping program measures are all significant investments of labor and capital,” says Mark A. Palmer, LEED AP, who is a stormwater engineer for the Public Works Department of Puyallup. “We have been trying to obtain an additional street sweeper for some time, recognizing the street sweeping program’s effectiveness in preventing pollution from city streets.”
The city recently acquired a new CCTV truck. “That will enable us to perform more construction inspections and illicit discharge detection and elimination [IDDE] investigations,” says Palmer. “The SWPPP for corporate yards has generated a capital improvement project to improve the wash bay and retrofit the existing stormwater pond for water quality treatment.
“The CMMS system has been an expensive acquisition, with a large effort required to get it up and running,” adds Palmer. “All of these expenses demonstrate Puyallup’s commitment to stormwater issues.”
Puyallup has been fortunate to have successful and active NPDES coordinator groups in the area, says Palmer. “Both the South Puget Sound and Central Puget Sound coordinators’ groups have met frequently to exchange approaches and ideas to all facets of the NPDES requirements. While these were focused primarily on education and outreach efforts, other coordination occurred with maintenance plans, IDDE, and other facets of the permit. These groups were very helpful in highlighting effective practices.”
Despite the program being understaffed, Palmer says he believes Puyallup has put together a strong and effective effort. “The housekeeping and pollution prevention aspects of Puyallup’s program were initiated well ahead of the permit, so they had a head start on other programs,” says Palmer. “I feel that we are actually ahead in performance in these categories, but are a little behind in the detailed reporting. The CMMS program will help us get caught up on that.”
As a whole, good housekeeping and pollution prevention is part of Puyallup’s comprehensive approach to NPDES Phase II measures.
Residential stormwater pollution accounts for nearly 75% of the 140,000 pounds of toxics entering Puget Sound each day. One of the ways in which Puyallup is trying to address that is through encouraging residents to disconnect from their stormwater system–in essence, keeping stormwater onsite instead of letting it flow into the city’s stormwater systems. The city’s goal is for 10% of households to participate in some form of disconnect to keep more than nine million gallons of stormwater out of the stormwater systems each year. If all participated, the city would keep more than 380 million gallons of stormwater out of the system.
Currently, 2.6 million gallons are being kept out of the stormwater system through rainwater harvesting (42%), rain gardens (37%), porous pavement (20%), and green roofs (1%).
Puyallup’s city hall has included many LID practices, which led to its attainment of LEED Gold certification, setting itself up as a role model for its residents.
The city is about ready to proceed with an LID retrofit project in one of its neighborhoods (8th Avenue NW). The city, in conjunction with Washington State University (WSU)–Puyallup and stewardship partners, had been awarded a competitive Ecology grant to fund a demonstration project that will convert one block of 8th Avenue NW into a Street Edge Alternative (SEA) street, patterned after pioneering efforts in Seattle, WA.
The SEA street will include a porous asphalt roadway, permeable paver sidewalks, and rain gardens in the public right of way to capture any excess stormwater runoff from the street, sidewalks, and driveways. This particular neighborhood has good-draining soils and community support for the project.
The aim is for 100% of the rainfall to be infiltrated in the porous pavement on the street and sidewalks.
The city has been preliminarily awarded three Green Partnership Fund grants, sponsored by Pierce Conservation District. The grants focus on riparian restoration and LID installations, such as a porous driveway initiative.
Through its Fish Friendly Car Wash program, Puyallup offers residents the opportunity to check out for five days from the city at no cost the Fish Friendly Car Wash Kit, which uses a stormwater drain insert and pump to send dirty water to the sanitary sewer system or to a grassy area where it can infiltrate, instead of to the stormwater drains, from which it would flow directly into the streams, the Puyallup River, and eventually Puget Sound. Additionally, the city encourages residents to wash their cars on their lawns or use a local car wash facility, which pipes the polluted water to a treatment facility.
Puyallup had recently received two $500,000 State Department of Ecology Municipal Stormwater Grants of Regional or Statewide Significance (GROSS Grants). One grant funds creation, development, and maintenance of a Process, Protocol and Product Evaluation Program for New Stormwater Emerging Technologies. The program establishes a procedure to provide review and evaluation of newly emerging stormwater treatment technologies.
The grant will fund the creation of a technical resource center for stormwater management solutions and education at WSU–Puyallup, which will house long-term and ongoing stormwater research designed to support relevant and current stormwater management strategies and practices.
Going forward, Puyallup plans to add more maintenance staff. Currently, the program is “critically and chronically understaffed,” with budget limitations prohibiting hiring for vacant positions, says Henry.
There also are plans to continue to improve asset inventories and data management and provide the ability to update information in the field near real time.
“We’ll continue to track performance, find inefficiencies, and improve standard operating procedures,” says Henry. “We’ll assess the staffing and equipment requirements of the upcoming renewal of the NPDES permit.”
Puyallup also plans to begin implementation of LID measures in public works projects as the norm rather than exception, Palmer notes.
Palmer says he’s comfortable that Puyallup has done everything possible toward successfully meeting the criteria for NPDES Phase II. “At this point in time, I would not have done anything differently,” he says. “That may change with a little more distance in the mirror. There is always something you could have done better, but I don’t see any major course corrections that I would have made, given a second chance.”